[Federal Register Volume 81, Number 52 (Thursday, March 17, 2016)]
[Proposed Rules]
[Pages 14528-14630]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-04813]
[[Page 14527]]
Vol. 81
Thursday,
No. 52
March 17, 2016
Part II
Department of Energy
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10 CFR Parts 429 and 430
Energy Conservation Program: Energy Conservation Standards for General
Service Lamps; Proposed Rule
Federal Register / Vol. 81 , No. 52 / Thursday, March 17, 2016 /
Proposed Rules
[[Page 14528]]
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DEPARTMENT OF ENERGY
10 CFR Parts 429 and 430
[Docket Number EERE-2013-BT-STD-0051]
RIN 1904-AD09
Energy Conservation Program: Energy Conservation Standards for
General Service Lamps
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of proposed rulemaking (NOPR) and announcement of public
meeting.
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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 lamps (GSLs). EPCA also requires the U.S. Department of
Energy (DOE) to periodically determine whether more-stringent, amended
standards would be technologically feasible and economically justified,
and would save a significant amount of energy. In this notice, DOE
proposes amended energy conservation standards for GSLs, and also
announces a public meeting to receive comment on these proposed
standards and associated analyses and results.
DATES: Meeting: DOE will hold a public meeting on Wednesday, April 20,
2016, from 9:00 a.m. to 4:00 p.m., in Washington, DC. The meeting will
also be broadcast as a webinar. See section VIII, ``Public
Participation,'' for webinar registration information, participant
instructions, and information about the capabilities available to
webinar participants.
Comments: DOE will accept comments, data, and information regarding
this NOPR before and after the public meeting, but no later than May
16, 2016. See section VIII, ``Public Participation,'' for details.
Comments regarding the likely competitive impact of the proposed
standard should be sent to the Department of Justice contact listed in
the ADDRESSES section before April 18, 2016.
ADDRESSES: The public meeting will be held at the U.S. Department of
Energy, Forrestal Building, Room 6E-069, 1000 Independence Avenue SW.,
Washington, DC 20585. Any foreign national wishing to participate in
the meeting should advise DOE as soon as possible by contacting
[email protected] to initiate the necessary procedures.
Please also note that any person wishing to bring a laptop into the
Forrestal Building will be required to obtain a property pass. Visitors
should avoid bringing laptops, or allow an extra 45 minutes. Persons
may also attend the public meeting via webinar.
Instructions: Any comments submitted must identify the NOPR on
Energy Conservation Standards for GSLs, and provide docket number EERE-
2013-BT-STD-0051 and/or regulatory information number (RIN) 1904-AD09.
Comments may be submitted using any of the following methods:
1. Federal eRulemaking Portal: www.regulations.gov. Follow the
instructions for submitting comments.
2. Email: [email protected]. Include the docket number and/
or RIN in the subject line of the message. Submit electronic comments
in WordPerfect, Microsoft Word, PDF, or ASCII file format, and avoid
the use of special characters or any form of encryption.
3. Postal Mail: Ms. Brenda Edwards, U.S. Department of Energy,
Building Technologies Office, Mailstop EE-5B, 1000 Independence Avenue
SW., Washington, DC 20585-0121. If possible, please submit all items on
a compact disc (CD), in which case it is not necessary to include
printed copies.
4. Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of
Energy, Building Technologies Office, 950 L'Enfant Plaza SW., Suite
600, Washington, DC 20024. Telephone: (202) 586-2945. If possible,
please submit all items on a CD, in which case it is not necessary to
include printed copies.
Written comments regarding the burden-hour estimates or other
aspects of the collection-of-information requirements contained in this
proposed rule may be submitted to Office of Energy Efficiency and
Renewable Energy through the methods listed above and by email to
[email protected].
EPCA requires the Attorney General to provide DOE a written
determination of whether the proposed standard is likely to lessen
competition. The U.S. Department of Justice Antitrust Division invites
input from market participants and other interested persons with views
on the likely competitive impact of the proposed standard. Interested
persons may contact the Division at [email protected] before
April 18, 2016. Please indicate in the ``Subject'' line of your email
the title and Docket Number of this rulemaking notice.
No telefacsimilies (faxes) will be accepted. For detailed
instructions on submitting comments and additional information on the
rulemaking process, see section VIII of this document (``Public
Participation'').
Docket: The docket, which includes Federal Register notices, public
meeting attendee lists and transcripts, comments, and other supporting
documents/materials, is available for review at www.regulations.gov.
All documents in the docket are listed in the www.regulations.gov
index. However, some documents listed in the index may not be publicly
available, such as those containing information that is exempt from
public disclosure.
A link to the docket Web page can be found at: http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx?ruleid=83. This Web page contains a link to the docket
for this notice on the www.regulations.gov site. The
www.regulations.gov Web page contains simple instructions on how to
access all documents, including public comments, in the docket. See
section VIII, ``Public Participation,'' for further information on how
to submit comments through www.regulations.gov.
FOR FURTHER INFORMATION CONTACT: Ms. Lucy deButts, U.S. Department of
Energy, Office of Energy Efficiency and Renewable Energy, Building
Technologies Office, EE-5B, 1000 Independence Avenue SW., Washington,
DC 20585-0121. Telephone: (202) 287-1604. Email: [email protected].
Ms. Celia Sher, U.S. Department of Energy, Office of the General
Counsel, GC-33, 1000 Independence Avenue SW., Washington, DC 20585-
0121. Telephone: (202) 287-6122. Email: [email protected].
For further information on how to submit a comment, review other
public comments and the docket, or participate in the public meeting,
contact Ms. Brenda Edwards at (202) 586-2945 or by email:
[email protected].
SUPPLEMENTARY INFORMATION: DOE intends to incorporate by reference the
following industry standard into 10 CFR part 430:
Underwriter Laboratories 1598C-2014 (``UL 1598C''), Standard for
Light-Emitting Diode Retrofit Luminaire Conversion Kits, First Edition,
dated January 16, 2014.
Copies of Underwriter Laboratories' Standard for Light-Emitting
Diode Retrofit Luminaire Conversion Kits are available from http://
[[Page 14529]]
ulstandards.ul.com/standards-catalog/ or can be reviewed in person at
U.S. Department of Energy, Building Technologies Program, 950 L'Enfant
Plaza SW., Suite 600, Washington, DC 20024. See section VII.M for a
further discussion of this standard.
Table of Contents
I. Synopsis of the Proposed Rule
A. Benefits and Costs to Consumers
B. Impact on Manufacturers
C. National Benefits and Costs
D. Conclusion
II. Introduction
A. Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for GSLs
III. General Discussion
A. Product Classes and Scope of Coverage
B. Test Procedure
1. Standby- and Off-Mode Energy Consumption
C. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
D. Energy Savings
1. Determination of Savings
2. Significance of Savings
E. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Consumers
b. Savings in Operating Costs Compared to Increase in Price (LCC
and PBP)
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 Scope of Coverage
A. Appropriations Rider
B. Clarification of General Service Lamp Definition
1. General Lighting Applications
2. Lamps Addressed in Other Rulemakings
3. High-Lumen Lamps (>2,600 Lumens)
4. Lamps Without an ANSI Base
5. Operating Voltage
6. Summary of GSL Interpretation
C. Definitions Supporting GSLs
1. General Service LED Lamps
2. Organic Light-Emitting Diode Lamps
3. Integrated Lamp and Non-integrated Lamp
4. Hybrid Lamps
5. Base Types
6. Light Fixture
7. LED Downlight Retrofit Kits
8. Summary of Definitions
D. Exempted Lamps
1. Exempted Lamp Types
a. Colored Lamp
b. Appliance Lamp
c. Black Light Lamp
d. Bug Lamp
e. Plant Light Lamp
f. Infrared Lamp
g. Sign Service Lamp
h. Showcase Lamp
i. Marine Signal Service Lamp, Mine Service Lamp, Silver Bowl
Lamp, and Traffic Signal Lamp
j. Designed and Marketed
2. Non-Exempted Lamp Types
a. Reflector Lamp
b. Rough Service Lamp, Shatter-Resistant Lamp, and Vibration
Service Lamp
c. Three-Way Lamp
d. Left-Hand Thread Lamp and Marine Lamp
e. Lamps of Specific Shapes
E. GSLs Under Consideration for Standards
1. Integrated Candelabra and Intermediate-Base Lamps
2. Pin Base Lamps
a. Non-Integrated Pin Base CFLs and LED Lamps
b. GU24 Base Lamps
c. MR16 Lamps
3. Organic Light-Emitting Diode Lamps
4. Summary of GSLs Under Consideration for Standards
F. Scope of Metrics
1. Existing MBCFL Metrics
a. Lumen Maintenance
b. Rapid Cycle Stress Testing
c. Lifetime
2. Additional MBCFL Metrics
a. Color Rendering Index
b. Power Factor
c. Start Time
d. Total Harmonic Distortion, Correlated Color Temperature,
Operating Frequency
3. Additional Integrated LED Metric
4. Summary of Metrics
V. Methodology and Discussion of Related Comments
A. Market and Technology Assessment
1. Product Classes
a. Lamp Technology
b. Lamp Component Location
c. Lumen Package
d. Standby Mode
e. Covering
f. Lamp Spectrum
g. Summary of Proposed Product Classes
2. Technology Options
a. CFL Technology Options From the Preliminary Analysis
b. LED Lamp Technology Options From the Preliminary Analysis
c. Summary
B. Screening Analysis
1. CFL Technology Options Screened Out
a. Multi-Photon Phosphors
2. LED Technology Options Screened Out
a. AC LEDs
b. Quantum Dots
c. Improved Emitter Materials
3. Summary
C. Engineering Analysis
1. General Approach
2. Representative Product Classes
3. Baseline Lamps
a. Integrated Lamps
b. Non-Integrated Lamps
4. More Efficacious Substitutes
a. Integrated Lamps
b. Non-Integrated Lamps
5. Efficacy Levels
a. Integrated Lamps
b. Non-Integrated Lamps
6. Scaling to Other Product Classes
D. Product Price Determination
1. Price Weightings
2. CFL Prices in the Integrated Low-Lumen Product Class
3. LED Lamp Prices in the Integrated Low-Lumen Product Class
E. Energy Use Analysis
1. Operating Hours
a. Residential Sector
b. Commercial Sector
2. Input Power
3. Lighting Controls
F. Life-Cycle Cost and Payback Period Analysis
1. Product Cost
2. Installation Cost
3. Lumen Range Distribution
4. Electricity Prices
5. Electricity Price Trends
6. Product Lifetime
7. Residual Value
8. Disposal Cost
9. Discount Rates
10. Efficacy Distributions
11. LCC Savings Calculation
12. Payback Period Analysis
G. Shipments Analysis
1. Shipments Model
a. Lamp Demand Module
b. Price-Learning Module
c. Market-Share Module
2. Rare Earth Oxides
H. National Impact Analysis
1. National Energy Savings
a. Smart Lamps
2. Net Present Value Analysis
I. Consumer Subgroup Analysis
J. Manufacturer Impact Analysis
1. Overview
2. GRIM Analysis and Key Inputs
a. Capital and Product Conversion Costs
b. Manufacturer Production Costs
c. Shipment Scenarios
d. Markup Scenarios
3. Discussion of Comments
4. Manufacturer Interviews
a. Testing Burden
b. Impacts of Technology-Neutral Standards
K. Emissions Analysis
L. 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. Social Cost of Other Air Pollutants
M. Utility Impact Analysis
N. Employment Impact Analysis
VI. Analytical Results and Conclusions
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
[[Page 14530]]
c. Indirect Impacts on Employment
4. Impact on Utility or Performance of Products
5. Impact of Any Lessening of Competition
6. Need of the Nation to Conserve Energy
7. Other Factors
8. Summary of National Economic Impacts
C. Conclusion
1. Benefits and Burdens of TSLs Considered for GSL Standards
2. Summary of Annualized Benefits and Costs of the Proposed
Standards
VII. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
1. Description on Estimated Number of Small Entities Regulated
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. Description of Materials Incorporated by Reference
VIII. Public Participation
A. Attendance at the Public Meeting
B. Procedure for Submitting Prepared General Statements for
Distribution
C. Conduct of the Public Meeting
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
IX. Approval of the Office of the Secretary
I. Synopsis of the Proposed Rule
Title III, Part B \1\ of the Energy Policy and Conservation Act of
1975 (EPCA or the Act), Public Law 94-163 (42 U.S.C. 6291-6309, as
codified), established the Energy Conservation Program for Consumer
Products Other Than Automobiles.\2\ These products include general
service lamps (GSLs), the subject of this document.
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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 the Energy Efficiency Improvement Act of
2015, Public Law 114-11 (Apr. 30, 2015).
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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 is technologically feasible and economically justified.
(42 U.S.C. 6295(o)(2)(A)) Furthermore, the new or amended standard must
result in a significant conservation of energy. (42 U.S.C.
6295(o)(3)(B)) EPCA also provides that not later than 6 years after
issuance of any final rule establishing or amending a standard, DOE
must publish either a notice of determination that standards for the
product do not need to be amended, or a notice of proposed rulemaking
(NOPR) including new proposed energy conservation standards. (42 U.S.C.
6295(m)(1))
In accordance with these and other statutory provisions discussed
in this document, DOE proposes new and amended energy conservation
standards for GSLs. The proposed standards, which are expressed in
minimum lumen (lm) output per watt (W) of a lamp, are shown in Table I-
1. These proposed standards, if adopted, would apply to all GSLs listed
in Table I-1 and manufactured in, or imported into, the United States
on and after the date three years after the publication of the final
rule for this rulemaking. Table I-1 shows the efficacy levels proposed
for the Integrated Low-Lumen, Integrated Low-Lumen Standby-Mode
Functionality, Integrated High-Lumen, Integrated High-Lumen Standby-
Mode Functionality, and Non-Integrated product classes.
Table I-1--Proposed Energy Conservation Standards for General Service Lamps
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Efficacy * (lm/W)
Trial standard DOE proposed ---------------------------------------------
Product class level efficacy level Capable of operating
No standby mode in standby mode
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Integrated ** Low-Lumen (310 <= TSL 3 EL 3 101.6-29.42 * 96.0-29.42 *
Initial Lumen Output <2,000). 0.9983[supcaret]Init 0.9983[supcaret]Init
ial Lumen Output. ial Lumen Output.
Integrated ** High-Lumen (2,000 <= TSL 3 EL 2 73.4-29.42 * 70.5-29.42 *
Initial Lumen Output <=2,600). 0.9983[supcaret]Init 0.9983[supcaret]Init
ial Lumen Output. ial Lumen Output.
Non-Integrated [dagger] (310 <= TSL 3 EL 0 N/A.................. N/A.
Initial Lumen Output <=2,600
lumens).
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* See chapter 5 of the NOPR technical support document for plots of the efficacy curves.
** Integrated lamp means a lamp that contains all components necessary for the starting and stable operation of
the lamp, does not include any replaceable or interchangeable parts, and is connected directly to a branch
circuit through an ANSI base and corresponding ANSI standard lamp-holder (socket).
[dagger] Non-integrated lamp means a lamp that is not an integrated lamp.
A. Benefits and Costs to Consumers
Table I-2 presents DOE's evaluation of the economic impacts of the
proposed standards on consumers of GSLs, as measured by the average
life-cycle cost (LCC) savings and the simple payback period (PBP).\3\
The average LCC savings are positive for all product classes at all TSL
levels analyzed.
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\3\ The average LCC savings are measured relative to the
efficacy distribution in the no-new-standards case, which depicts
the market in the compliance year in the absence of standards (see
section IV.F.9). The simple PBP, which is designed to compare
specific ELs, is measured relative to the baseline model (see
section IV.C.1.a).
[[Page 14531]]
Table I-2--Impacts of Proposed Energy Conservation Standards on
Consumers of General Service Lamps (TSL 3)
------------------------------------------------------------------------
Average LCC
Product class savings Simple payback
(2014$) period (years)
------------------------------------------------------------------------
Residential Sector
------------------------------------------------------------------------
Integrated Low-Lumen.................... 0.75 2.14
Integrated High-Lumen................... 0.96 3.86
------------------------------------------------------------------------
Commercial Sector
------------------------------------------------------------------------
Integrated Low-Lumen.................... 1.32 0.70
Integrated High-Lumen................... 2.02 1.23
Non-Integrated.......................... 0 --
------------------------------------------------------------------------
DOE's analysis of the impacts of the proposed standards on
consumers is described in section V.F of this proposed rule.
B. Impact on Manufacturers
The industry net present value (INPV) is the sum of the discounted
cash flows to the industry from the reference year through the end of
the analysis period (2015 to 2049). Using a real discount rate of 6.1
percent, DOE estimates that the INPV for manufacturers of GSLs in the
case without new and amended standards is $911.0 million in 2014$.
Under the proposed standards, DOE expects that manufacturers may lose
up to 24.3 percent of this INPV, which is approximately $221.0 million.
Additionally, based on DOE's interviews with the manufacturers of GSLs,
DOE does not expect significant impacts on manufacturing capacity or
loss of employment for the industry as a whole to result from the
proposed standards for GSLs.
DOE's analysis of the impacts of the proposed standards on
manufacturers is described in section V.J of this document.
C. National Benefits and Costs \4\
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\4\ All monetary values in this section are expressed in 2014
dollars and, where appropriate, are discounted to 2015 unless
explicitly stated otherwise. Energy savings in this section refer to
the full-fuel-cycle savings (see section IV.H for discussion).
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DOE's analyses indicate that the proposed energy conservation
standards for GSLs would save a significant amount of energy. Relative
to the case where no new or amended energy conservation standard is set
(hereinafter referred to as the ``no-new-standards case''), the
lifetime energy savings for GSLs purchased in the 30-year period that
begins in the anticipated year of compliance with the new or amended
standards (2020-2049) amount to 0.85 quadrillion Btu (quads).\5\ This
represents a savings of 16 percent relative to the energy use of these
products in the no-new-standards case.
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\5\ A quad is equal to 10\15\ British thermal units (Btu). The
quantity refers to full-fuel-cycle (FFC) energy savings. FFC energy
savings 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. For more information on the FFC
metric, see section V.H.1.
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The cumulative net present value (NPV) of total consumer costs and
savings of the proposed standards for GSLs ranges from $4.4 billion (at
a 7-percent discount rate) to $9.1 billion (at a 3-percent discount
rate). This NPV expresses the estimated total value of future
operating-cost savings minus the estimated increased product and
installation costs (only for the commercial sector) for GSLs purchased
in 2020-2049.
In addition, the proposed standards for GSLs would have significant
environmental benefits. DOE estimates that the proposed standards would
result in cumulative emission reductions (over the same period as for
energy savings) of 52 million metric tons (Mt) \6\ of carbon dioxide
(CO2), 31 thousand tons of sulfur dioxide (SO2),
91.5 thousand tons of nitrogen oxides (NOX), 215 thousand
tons of methane (CH4), 0.64 thousand tons of nitrous oxide
(N2O), and 0.11 tons of mercury (Hg).\7\ The cumulative
reduction in CO2 emissions through 2030 amounts to 14.5 Mt,
which is equivalent to the emissions resulting from the annual
electricity use of 1.3 million homes.
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\6\ A metric ton is equivalent to 1.1 short tons. Results for
emissions other than CO2 are presented in short tons.
\7\ DOE calculated emissions reductions relative to the no-new-
standards case, which reflects key assumptions in the Annual Energy
Outlook 2015 (AEO 2015) Reference case. AEO 2015 generally
represents current legislation and environmental regulations for
which implementing regulations were available as of October 31,
2014.
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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.\8\ The derivation of the SCC values is discussed
in section V.L. Using discount rates appropriate for each set of SCC
values (see Table I-3), DOE estimates the present monetary value of the
CO2 emissions reduction (not including CO2
equivalent emissions of other gases with global warming potential) is
between $0.362 billion and $5 billion, with a value of $1.6 billion
using the central SCC case represented by $40.0/t in 2015. DOE also
estimates the present monetary value of the NOX emissions
reduction to be $0.1 billion at a 7-percent discount rate and $0.3
billion at a 3-percent discount rate.\9\
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\8\ 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;
May 2013; revised July 2015) (Available at: https://www.whitehouse.gov/sites/default/files/omb/inforeg/scc-tsd-final-july-2015.pdf.
\9\ DOE estimated the monetized value of NOX
emissions reductions using benefit per ton estimates from the
Regulatory Impact Analysis titled, ``Proposed Carbon Pollution
Guidelines for Existing Power Plants and Emission Standards for
Modified and Reconstructed Power Plants,'' published in June 2014 by
EPA's Office of Air Quality Planning and Standards. (Available at:
http://www3.epa.gov/ttnecas1/regdata/RIAs/111dproposalRIAfinal0602.pdf.) See section V.L.2 for further
discussion. Note that the agency is presenting a national benefit-
per-ton estimate for particulate matter emitted from the Electricity
Generating Unit sector based on an estimate of premature mortality
derived from the ACS study (Krewski et al., 2009). If the benefit-
per-ton estimates were based on the Six Cities study (Lepuele et
al., 2011), the values would be nearly two-and-a-half times larger.
Because of the sensitivity of the benefit-per-ton estimate to the
geographical considerations of sources and receptors of emissions,
DOE intends to investigate refinements to the agency's current
approach of one national estimate by assessing the regional approach
taken by EPA's Regulatory Impact Analysis for the Clean Power Plan
Final Rule. Note that DOE is currently investigating valuation of
avoided SO2 and Hg emissions.
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[[Page 14532]]
Table I-3 summarizes the national economic benefits and costs
expected to result from the proposed standards for GSLs.
Table I-3--Summary of National Economic Benefits and Costs of Proposed
Energy Conservation Standards for General Service Lamps (TSL 3) *
------------------------------------------------------------------------
Present value
Category (Billion Discount rate
2014$) (%)
------------------------------------------------------------------------
Benefits
------------------------------------------------------------------------
Consumer Operating-Cost Savings......... 3.5 7
7.6 3
CO2 Reduction Monetized Value ($12.2/t 0.4 5
case) **...............................
CO2 Reduction Monetized Value ($40.0/t 1.6 3
case) **...............................
CO2 Reduction Monetized Value ($62.3/t 2.6 2.5
case) **...............................
CO2 Reduction Monetized Value ($117/t 5.0 3
case) **...............................
NOX Reduction Monetized Value [dagger].. 0.1 7
0.3 3
Total Benefits [dagger][dagger]......... 5.3 7
------------------------------------------------------------------------
9.6 3
Costs
------------------------------------------------------------------------
Consumer Incremental Installed Costs -0.9 7
[Dagger]...............................
------------------------------------------------------------------------
-1.4 3
Total Net Benefits
------------------------------------------------------------------------
Including CO2 and NOX Reduction 6.2 7
Monetized Value [dagger][dagger].......
11.0 3
------------------------------------------------------------------------
* This table presents the costs and benefits associated with GSLs
shipped in 2020-2049. These results include benefits to consumers
which accrue after 2049 from the products purchased in 2020-2049. The
costs account for the incremental variable and fixed costs incurred by
manufacturers due to the standard, some of which may be incurred in
preparation for the rule.
** The CO2 values represent global monetized values of the SCC, in
2014$, in 2015 under several scenarios of the updated SCC values. The
first three cases use the averages of SCC distributions calculated
using 5-percent, 3-percent, and 2.5-percent discount rates,
respectively. The fourth case represents the 95th percentile of the
SCC distribution calculated using a 3-percent discount rate. The SCC
time series incorporate an escalation factor. The value for NOX is the
average of high and low values found in the literature.
[dagger] The $/ton values used for NOX are described in section V.L. DOE
estimated the monetized value of NOX emissions reductions using
benefit per ton estimates from the Regulatory Impact Analysis titled,
``Proposed Carbon Pollution Guidelines for Existing Power Plants and
Emission Standards for Modified and Reconstructed Power Plants,''
published in June 2014 by EPA's Office of Air Quality Planning and
Standards. (Available at: http://www3.epa.gov/ttnecas1/regdata/RIAs/111dproposalRIAfinal0602.pdf.) See section V.L.2 for further
discussion. Note that the agency is presenting a national benefit-per-
ton estimate for particulate matter emitted from the Electric
Generating Unit sector based on an estimate of premature mortality
derived from the ACS study (Krewski et al., 2009). If the benefit-per-
ton estimates were based on the Six Cities study (Lepuele et al.,
2011), the values would be nearly two-and-a-half times larger. Because
of the sensitivity of the benefit-per-ton estimate to the geographical
considerations of sources and receptors of emissions, DOE intends to
investigate refinements to the agency's current approach of one
national estimate by assessing the regional approach taken by EPA's
Regulatory Impact Analysis for the Clean Power Plan Final Rule.
[dagger][dagger] Total Benefits for both the 3-percent and 7-percent
cases are derived using the series corresponding to average SCC with 3-
percent discount rate ($40.0/t case).
[Dagger] This reduction in product costs occurs because (1) more
efficacious lamps have longer average lifetimes than less efficacious
lamps, resulting in fewer replacement purchases, (2) the purchase
price of more efficacious LED lamps is lower than the price of less
efficacious LED lamps, and (3) the purchase price of LED lamps
declines faster than the price of CFLs during the analysis period,
resulting in LED lamps becoming less expensive than CFLs.
The benefits and costs of the proposed standards, for GSLs sold in
2020-2049, can also be expressed in terms of annualized values. The
monetary values for the total annualized net benefits are the sum of:
(1) The national economic value of the benefits in reduced operating
costs, minus (2) the increase in product purchase prices and
installation costs, plus (3) the value of the benefits of
CO2 and NOX emission reductions, all
annualized.\10\
---------------------------------------------------------------------------
\10\ To convert the time-series of costs and benefits into
annualized values, DOE calculated a present value in 2015, 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 2015. 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, as shown in Table I-3. 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.
---------------------------------------------------------------------------
Although DOE believes that the values of operating-cost savings and
CO2 emission reductions are both important, two issues are
relevant. First, the national operating 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 GSLs shipped in 2020-2049.
Because CO2 emissions have a very long residence time in the
atmosphere,\11\ the SCC values in future years reflect future
CO2-emissions impacts that continue beyond 2100.
---------------------------------------------------------------------------
\11\ The atmospheric lifetime of CO2 is estimated of
the order of 30-95 years. Jacobson, MZ (2005), ``Correction to
`Control of fossil-fuel particulate black carbon and organic matter,
possibly the most effective method of slowing global warming,' '' J.
Geophys. Res. 110. pp. D14105.
---------------------------------------------------------------------------
Estimates of annualized benefits and costs of the proposed
standards are
[[Page 14533]]
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 average SCC series that has a value of $40.0/t in
2015),\12\ the estimated cost of the standards proposed in this rule is
$-93 million per year in increased equipment costs, while the estimated
annual benefits are $373 million in reduced equipment operating costs,
$95 million in CO2 reductions, and $13.6 million in reduced
NOX emissions. In this case, the net benefit amounts to $574
million per year. Using a 3-percent discount rate for all benefits and
costs and the average SCC series that has a value of $40.0/t in 2015,
the estimated cost of the proposed standards is $-82 million per year
in increased equipment costs, while the estimated annual benefits are
$438 million in reduced operating costs, $95 million in CO2
reductions, and $17.2 million in reduced NOX emissions. In
this case, the net benefit amounts to $632 million per year.
---------------------------------------------------------------------------
\12\ DOE used a 3-percent discount rate because the SCC values
for the series used in the calculation were derived using a 3-
percent discount rate (see section V.L.).
Table I-4--Annualized Benefits and Costs of Proposed Energy Conservation Standards for General Service Lamps (TSL 3)
--------------------------------------------------------------------------------------------------------------------------------------------------------
(Million 2014$/year)
-----------------------------------------------------------------------------------
Discount rate Low net benefits estimate High net benefits estimate
Primary estimate * * *
--------------------------------------------------------------------------------------------------------------------------------------------------------
Benefits
--------------------------------------------------------------------------------------------------------------------------------------------------------
Consumer Operating-Cost Savings... 7%.............................. 373....................... 334....................... 404.
3%.............................. 438....................... 386....................... 481.
CO2 Reduction Value ($12.2/t case) 5%.............................. 29........................ 26........................ 31.
**.
CO2 Reduction Value ($40.0/t case) 3%.............................. 95........................ 86........................ 101.
**.
CO2 Reduction Value ($62.3/t case) 2.5%............................ 138....................... 125....................... 148.
**.
CO2 Reduction Value ($117/t case) 3%.............................. 287....................... 262....................... 308.
**.
NOX Reduction Monetized 7%.............................. 13.6...................... 12.6...................... 32.2.
Value[dagger].
3%.............................. 17.2...................... 15.8...................... 41.1.
Total Benefits [dagger][dagger]... 7% plus CO2 range............... 415 to 674................ 373 to 608................ 467 to 744.
7%.............................. 481....................... 433....................... 537.
3% plus CO2 range............... 483 to 742................ 428 to 663................ 552 to 829.
3%.............................. 549....................... 488....................... 623.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Costs
--------------------------------------------------------------------------------------------------------------------------------------------------------
Consumer Incremental Installed 7%.............................. -93....................... -81....................... -105.
Product Costs [Dagger].
3%.............................. -82....................... -70....................... -95.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Net Benefits
--------------------------------------------------------------------------------------------------------------------------------------------------------
Total [dagger][dagger]............ 7% plus CO2 range............... 508 to 767................ 453 to 689................ 571 to 849.
7%.............................. 574....................... 513....................... 642.
3% plus CO2 range............... 566 to 824................ 498 to 733................ 647 to 924.
3%.............................. 632....................... 558....................... 718.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* This table presents the annualized costs and benefits associated with GSLs shipped in 2020-2049. These results include benefits to consumers which
accrue after 2049 from the products purchased in 2020-2049. 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 estimate assumes the reference case electricity prices and
floorspace growth projections from the Annual Energy Outlook (AEO) 2015 and decreasing product prices for both compact fluorescent lamps (CFLs) and
LED GSLs, due to price learning. The Low Benefits Estimate uses the Low Economic Growth electricity prices and floorspace growth from AEO 2015 and a
faster decrease in product prices for LED GSLs. The High Benefits Estimate uses the High Economic Growth electricity prices and floorspace growth from
AEO 2015 and a slower decrease in product prices for LED GSLs. The methods used to derive projected price trends are explained in section V.G.1.b.
** The CO2 values represent global monetized values of the SCC, in 2014$, in 2015 under several scenarios of the updated SCC values. The first three
cases use the averages of SCC distributions calculated using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The fourth case
represents the 95th percentile of the SCC distribution calculated using a 3-percent discount rate. The SCC time series incorporate an escalation
factor.
[dagger] The $/ton values used for NOX are described in section V.L. DOE estimated the monetized value of NOX emissions reductions using benefit per ton
estimates from the Regulatory Impact Analysis titled, ``Proposed Carbon Pollution Guidelines for Existing Power Plants and Emission Standards for
Modified and Reconstructed Power Plants,'' published in June 2014 by EPA's Office of Air Quality Planning and Standards. (Available at: http://www3.epa.gov/ttnecas1/regdata/RIAs/111dproposalRIAfinal0602.pdf.) See section V.L.2 for further discussion. For DOE's Primary Estimate and Low Net
Benefits Estimate, the agency is presenting a national benefit-per-ton estimate for particulate matter emitted from the Electric Generating Unit
sector based on an estimate of premature mortality derived from the ACS study (Krewski et al., 2009). For DOE's High Net Benefits Estimate, the
benefit-per-ton estimates were based on the Six Cities study (Lepuele et al., 2011), which are nearly two-and-a-half times larger than those from the
ACS study. Because of the sensitivity of the benefit-per-ton estimate to the geographical considerations of sources and receptors of emission, DOE
intends to investigate refinements to the agency's current approach of one national estimate by assessing the regional approach taken by EPA's
Regulatory Impact Analysis for the Clean Power Plan Final Rule.
[dagger][dagger] Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to the average SCC with a 3-
percent discount rate ($40.0/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.
[Dagger] This reduction in product costs occurs because (1) more efficacious lamps have longer average lifetimes than less efficacious lamps, resulting
in fewer replacement purchases, (2) the purchase price of more efficacious LED lamps is lower than the price of less efficacious LED lamps, and (3)
the purchase price of LED lamps declines faster than the price of CFLs during the analysis period, resulting in LED lamps becoming less expensive than
CFLs.
[[Page 14534]]
DOE's analysis of the national impacts of the proposed standards is
described in sections V.H, V.J.1 and V.L of this NOPR. In addition to
the national impacts described previously in this section, lamps that
meet the expanded GSL definition proposed in this rulemaking would be
subject to the 45 lm/W efficacy level starting in 2020 as specified by
the EISA 2007 backstop provision. It is estimated that the impact of
the EISA 2007 backstop on such lamps, excluding those included in the
scope of coverage of this rulemaking, would bring about energy savings
of approximately 3 quads for lamps sold in 2020-2049 and a carbon
reduction of approximately 200 million metric tons by 2030.\13\
---------------------------------------------------------------------------
\13\ Meyers, S., A. Williams, P. Chan, and S. Price. Energy and
Economic Impacts of U.S. Federal Energy and Water Conservation
Standards Adopted From 1987 Through 2014. 2015. Lawrence Berkeley
National Laboratory: Berkeley, CA. Report No. LBNL-6964E. (Last
accessed January 20, 2016.) http://eetd.lbl.gov/sites/all/files/lbnl-6964e.pdf.
---------------------------------------------------------------------------
D. Conclusion
DOE has tentatively concluded that the proposed standards represent
the maximum improvement in energy efficiency that is technologically
feasible and economically justified, and would result in the
significant conservation of energy. DOE further notes that products
achieving these standard levels are already commercially available for
all product classes covered by this proposal. Based on the analyses
described above, DOE has tentatively concluded that the benefits of the
proposed standards to the Nation (energy savings, positive NPV of
consumer benefits, consumer LCC savings, and emission reductions) would
outweigh the burdens (loss of INPV for manufacturers and LCC increases
for some consumers).
DOE also considered more-stringent and less-stringent energy
efficacy levels as potential standards, and is still considering them
in this rulemaking. However, DOE has tentatively concluded that the
potential burdens of the more-stringent energy efficacy levels would
outweigh the projected benefits. Based on consideration of the public
comments DOE receives in response to this notice and related
information collected and analyzed during the course of this rulemaking
effort, DOE may adopt energy efficacy levels presented in this notice
that are either higher or lower than the proposed standards, or some
combination of level(s) that incorporate the proposed standards in
part.
II. Introduction
The following section briefly discusses the statutory authority
underlying this proposed rule, as well as some of the relevant
historical background related to the establishment of standards for
GSLs.
A. Authority
Title III, Part B of EPCA established the Energy Conservation
Program for Consumer Products Other Than Automobiles, a program
covering most major household appliances.\14\ Subsequent amendments
expanded Title III of EPCA to include additional consumer products,
including GSLs--the products that are the focus of this NOPR. In
particular, amendments to EPCA in the Energy Independence and Security
Act of 2007 (EISA) directed DOE to conduct two rulemaking cycles to
evaluate energy conservation standards for GSLs. (42 U.S.C.
6295(i)(6)(A)-(B))
---------------------------------------------------------------------------
\14\ Part B was re-designated Part A on codification in the U.S.
Code for editorial reasons.
---------------------------------------------------------------------------
For the first rulemaking cycle, EPCA, as amended by EISA, directs
DOE to initiate a rulemaking no later than January 1, 2014, to evaluate
standards for GSLs and determine whether exemptions for certain
incandescent lamps should be maintained or discontinued. (42 U.S.C.
6295(i)(6)(A)(i)) The scope of the rulemaking is not limited to
incandescent lamp technologies. (42 U.S.C. 6295(i)(6)(A)(ii)) Further,
for this first cycle of rulemaking, the EISA amendments provide that
DOE must consider a minimum standard of 45 lumens per watt (lm/W). (42
U.S.C. 6295(i)(6)(A)(ii)) If DOE fails to meet the requirements of 42
U.S.C. 6295(i)(6)(A)(i)-(iv) or the final rule from the first
rulemaking cycle does not produce savings greater than or equal to the
savings from a minimum efficacy standard of 45 lm/W, sales of GSLs that
do not meet the minimum 45 lm/W standard beginning on January 1, 2020,
will be prohibited. (42 U.S.C. 6295(i)(6)(A)(v))
The EISA-prescribed amendments further directed DOE to initiate a
second rulemaking cycle by January 1, 2020, to determine whether
standards in effect for general service incandescent lamps (GSILs)
should be amended with more-stringent requirements and if the
exemptions for certain incandescent lamps should be maintained or
discontinued. (42 U.S.C. 6295(i)(6)(B)(i)) For this second review of
energy conservation standards, the scope is not limited to incandescent
lamp technologies. (42 U.S.C. 6295(i)(6)(B)(ii))
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. 6295(o)(3)(A) and (r)) 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. (42 U.S.C.
6295(s)) The DOE test procedures for GSILs are set forth at title 10 of
the Code of Federal Regulations (CFR), part 430, subpart B, appendix R,
and test procedures for medium base compact fluorescent lamps (MBCFLs)
are set forth at 10 CFR part 430, subpart B, appendix W. The term GSL
includes these lamps and others including, compact fluorescent lamps
(CFLs), general service light-emitting diode (LED) lamps, organic
light-emitting diode (OLED) lamps, and any other lamps that the
Secretary determines are used to satisfy lighting applications
traditionally served by GSILs. 10 CFR 430.2 DOE has initiated test
procedures for integrated LED lamps and compact fluorescent lamps,
which includes integrated and non-integrated CFLs. EPCA sets forth
generally applicable criteria and procedures for DOE's adoption and
amendment of test procedures. (42 U.S.C. 6293)
DOE must follow specific statutory criteria for prescribing new or
amended standards for covered products, including GSLs. Any new or
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) and
(3)(B)) 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
[[Page 14535]]
prescribe a standard: (1) For certain products, including GSLs, if no
test procedure has been established for the product, or (2) if DOE
determines by rule that the standard is not technologically feasible or
economically justified. (42 U.S.C. 6295(o)(3)(A)-(B)) In deciding
whether a proposed standard is economically justified, DOE must
determine whether the benefits of the standard exceed its burdens. (42
U.S.C. 6295(o)(2)(B)(i)) DOE must make this determination after
receiving comments on the proposed standard, and by considering, to the
greatest extent practicable, the following seven 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 standard;
(3) The total projected amount of energy (or as applicable, water)
savings likely to result directly from the standard;
(4) Any lessening of the utility or the performance of the covered
products likely to result from 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
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))
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. (42 U.S.C. 6295(o)(2)(B)(iii))
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 in any covered product type (or
class) of performance characteristics (including reliability),
features, sizes, capacities, and volumes that are substantially the
same as those generally available in the United States. (42 U.S.C.
6295(o)(4))
Additionally, 42 U.S.C. 6295(q)(1) specifies requirements when
promulgating an energy conservation standard for a covered product that
has two or more subcategories. DOE must specify a different standard
level for a type or class of product that has 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 the
feature and other factors DOE deems appropriate. Id. Any rule
prescribing such a standard must include an explanation of the basis on
which such higher or lower level was established. (42 U.S.C.
6295(q)(2))
Federal energy conservation requirements generally supersede state
laws or regulations concerning energy conservation testing, labeling,
and standards. (42 U.S.C. 6297(a)-(c)) DOE may, however, grant waivers
of federal preemption for particular state laws or regulations, in
accordance with the procedures and other provisions set forth under 42
U.S.C. 6297(d)).
Finally, pursuant to the amendments contained in EISA 2007, any
final rule for new or amended energy conservation standards promulgated
after July 1, 2010, is 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 a
single 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 determined that it is not possible for GSLs included in the scope
of this rulemaking to meet the off-mode criteria because there is no
condition in which a GSL connected to main power is not already in a
mode accounted for in either active or standby mode. DOE notes the
existence of a small number of commercially available GSLs that operate
in standby mode. DOE discusses GSLs that operate in standby mode in
further detail in sections III.B.1 and V.A.1. DOE's test procedures
under development for LED lamps and CFLs address standby mode energy
use. In this rulemaking, DOE intends to incorporate such energy use
into any amended energy conservation standards it adopts in the final
rule.
The Natural Resource Defense Council, Appliance Standards Awareness
Project, American Council for an Energy-Efficient Economy, Alliance to
Save Energy, Consumer Federation of America, National Consumer Law
Center, Northeast Energy Efficiency Partnerships, Northwest Energy
Efficiency Alliance, and Northwest Power and Conservation Council
(hereafter the ``Energy Efficiency Advocates'' or the ``EEAs'') jointly
commented that initial test results by DOE's Commercially Available LED
Product Evaluation and Reporting (CALiPER) testing program showed
instances where manufacturers were exaggerating equivalency claims when
making comparisons between more efficacious technologies and
conventional incandescent lamps. In order to help consumers make well
informed purchasing decisions, EEAs recommended DOE work closely with
the FTC to establish minimum equivalency levels in this rulemaking in
which manufacturers who claim that a 10 W LED lamp replaces a 60 W
incandescent lamp should be required to comply with the corresponding
lumen output levels contained in a table established by FTC and DOE.
They recommended DOE consider ENERGY STAR[supreg]'s lumen equivalency
table in its Lamps Specification as a starting point. (EEAs, No. 32 at
pp. 13-14) \15\ DOE notes that for these consumer products, the FTC is
responsible for implementing and enforcing labeling requirements. (See
42 U.S.C. 6294) Such requirements are outside the scope of this
rulemaking. However, DOE understands concerns regarding potentially
incorrect lumen equivalency claims of covered products, and DOE will
continue to work with FTC on labeling issues.
---------------------------------------------------------------------------
\15\ 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 GSLs (Docket No. EERE-2013-BT-STD-
0051), which is maintained at www.regulations.gov. This notation
indicates that the statement preceding the reference was made by
EEAs, is from document number 32 in the docket, and appears at pages
13-14 of that document.
---------------------------------------------------------------------------
[[Page 14536]]
B. Background
1. Current Standards
This is the first cycle of energy conservation standards
rulemakings for GSLs. Of the lamps covered by this rulemaking, only
GSILs, modified spectrum GSILs, intermediate base incandescent lamp,
candelabra base incandescent lamp, and MBCFLs have existing standards.
The Consolidated and Further Continuing Appropriations Act, 2015
(Publ. L. 113-235, Dec. 16, 2014; hereafter referred to as the
``Appropriations Rider''), in relevant part, restricts the use of
appropriated funds in connection with several aspects of DOE's
incandescent lamps energy conservation standards program. Specifically,
section 313 states that none of the funds made available by the Act may
be used to implement or enforce standards for GSILs, intermediate base
incandescent lamps, and candelabra base incandescent lamps.\16\
---------------------------------------------------------------------------
\16\ Public Law 113-235, Section 313 provides: ``None of the
funds made available in this Act may be used--(1) to implement or
enforce section 430.32(x) of title 10, Code of Federal Regulations;
or (2) to implement or enforce the standards established by the
tables contained in section 325(i)(1)(B) of the Energy Policy and
Conservation Act (42 U.S.C. 6295(i)(1)(B)) with respect to BPAR
incandescent reflector lamps, BR incandescent reflector lamps, and
ER incandescent reflector lamps.
---------------------------------------------------------------------------
The current standards for GSILs are summarized in Table II-1. In
addition GSILs are required to have a coloring redering index (CRI)
greater than or equal to 80. 10 CFR 430.32(x)(1). These standards for
GSILs are currently subject to the Appropriations Rider.
Table II-1--Existing Efficacy Standards for GSILs
----------------------------------------------------------------------------------------------------------------
Maximum rate Minimum rate
Rated lumen ranges wattage lifetime (hrs) Effective date
----------------------------------------------------------------------------------------------------------------
1490-2600.............................................. 72 1,000 1/1/2012
1050-1489.............................................. 53 1,000 1/1/2013
750-1049............................................... 43 1,000 1/1/2014
310-749................................................ 29 1,000 1/1/2014
----------------------------------------------------------------------------------------------------------------
The current standards for modified spectrum GSILs are shown in
Table II-2. In addition, modified spectrum GSILs are required to have a
color rendering index greater than or equal to 75. 10 CFR 430.32(x)(1)
These standards for modified spectrum GSILs are currently subject to
the Appropriations Rider.
Table II-2--Existing Efficacy Standards for Modified Spectrum GSILs
----------------------------------------------------------------------------------------------------------------
Maximum rate Minimum rate
Rated lumen ranges wattage lifetime (hrs) Effective date
----------------------------------------------------------------------------------------------------------------
1118-1950.............................................. 72 1,000 1/1/2012
788-1117............................................... 53 1,000 1/1/2013
563-787................................................ 43 1,000 1/1/2014
232-562................................................ 29 1,000 1/1/2014
----------------------------------------------------------------------------------------------------------------
Current standards require that candelabra base incandescent lamps
not exceed 60 rated watts and intermediate base incandescent lamps not
exceed 40 rated watts. 10 CFR 430.32(x)(2)-(3) These standards for
candelabra base incandescent lamp and intermediate base incandescent
lamp are subject to the Appropriations Rider.
The current standards for MBCFLs are summarized in Table II-3. 10
CFR 430.32(u)
Table II-3--Existing Efficacy Standards for MBCFLs
----------------------------------------------------------------------------------------------------------------
Lamp configuration Lamp power (W) Minimum efficacy (lm/W)
----------------------------------------------------------------------------------------------------------------
Bare lamp............................................ Lamp power <15.............. 45.0.
Lamp power >=15............. 60.0.
Covered lamp, no reflector........................... Lamp power <15.............. 40.0.
15 >= lamp power <19........ 48.0.
19 >= lamp power <25........ 50.0.
Lamp power >=25............. 55.0.
Lumen Maintenance at 1,000 Hours..................... The average of at least 5 lamps must be a minimum 90% of
initial (100-hour) lumen output at 1,000 hours of rated
life.
Lumen Maintenance at 40% of Rated Lifetime........... 80% of initial (100-hour) rating (per ANSI C78.5 Clause
4.10).
Rapid Cycle Stress Test.............................. Per ANSI C78.5 and IESNA LM65 (clauses 2,3,5, and 6)
exception: cycle times must be 5 minutes on, 5 minutes
off. Lamp will be cycled once for every two hours of
rated life. At least 5 lamps must meet or exceed the
minimum number of cycles.
Lamp Life............................................ >=6,000 hours as declared by the manufacturer on
packaging. <=50% of the tested lamps failed at rated
lifetime. At 80% of rated life, statistical methods may
be used to confirm lifetime claims based on sample
performance.
----------------------------------------------------------------------------------------------------------------
[[Page 14537]]
2. History of Standards Rulemaking for GSLs
DOE published notices in the Federal Register announcing the
availability of the framework document and preliminary analysis,
respectively. 78 FR 73737 (Dec. 9, 2013); 79 FR 73503 (Dec. 11, 2014).
This NOPR is the next step of DOE's first cycle of review to evaluate
standards for GSLs and whether the standards should apply to additional
GSL types. (42 U.S.C. 6295(i)(A)) Additionally, this rulemaking
satisfies the requirements under 42 U.S.C 6295(m)(1) for DOE to review
the existing standards for MBCFLs, as CFLs are included in the
definition of GSL. It also addresses 42 U.S.C. 6295(gg)(3) in which DOE
is directed to incorporate standby-mode and off-mode energy use in any
amended (or new) standard adopted after July 1, 2010, pursuant to 42
U.S.C. 6295(o).
Additionally, DOE is conducting a rulemaking setting energy
conservation standards for ceiling fan light kits (hereafter the ``CFLK
rulemaking''). The rulemaking published a NOPR proposing an efficacy
standard for the lamps packaged with CFLKs. 80 FR 48624 (August 13,
2015). The California Energy Commission (CEC) asked DOE to consider
incorporating CFLK standards in this GSL rulemaking because current
CFLKs standards are strongly related to GSLs. (CEC, No. 31 at p. 2).
While DOE acknowledges that certain GSLs are packaged with CFLKs, EPCA
addresses CFLKs as a separate covered product. Moreover, CFLK standards
apply to light kits packaged with lamps and GSL standards apply to
individual lamps. Because of the statutory treatment of CFLKs and the
difference in product type, market structure, and manufacturers, DOE
declines to combine the CFLK and GSL rulemakings in this proposal.
III. General Discussion
DOE developed this proposal after considering verbal and written
comments, data, and information from interested parties that represent
a variety of interests. The following discussion addresses issues
raised by these commenters.
A. Product Classes and Scope of Coverage
The term, general service lamp, includes GSILs, CFLs, general
service LED lamps, OLED lamps, and any other lamps that the Secretary
determines are used to satisfy lighting applications traditionally
served by GSILs; however, this definition does not apply to any
lighting application or bulb shape excluded from the ``general service
incandescent lamp'' definition, or any general service fluorescent lamp
or incandescent reflector lamp. (See 42 U.S.C. 6291(30)(BB)) section IV
covers the comments and discussion on each part of this definition to
clearly define the scope of this rulemaking.
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 justify
differing standards. In making a determination whether a performance-
related feature justifies a different standard, DOE must consider such
factors as the utility of the feature to the consumer and other factors
DOE determines are appropriate. (42 U.S.C. 6295(q)) For further details
on product classes, see section V.A.1 and chapter 3 of the NOPR
technical support document (TSD).
B. 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.
DOE is developing and amending test procedures for products included in
the definition of GSLs. The term GSL includes GSILs, CFLs, general
service LED lamps, OLED lamps, and any other lamps that the Secretary
determines are used to satisfy lighting applications traditionally
served by general service incandescent lamps. 10 CFR 430.2
DOE's test procedures for GSILs are set forth at 10 CFR part 430,
subpart B, appendix R. These test procedures provide instructions for
measuring GSIL performance largely by incorporating industry standards.
These test procedures were updated in a final rule published in January
2012. 77 FR 4203 (January 27, 2012). The rule updated citations and
references to the industry standards currently referenced in DOE's test
procedures for GSILs and established a new test procedure for
determining the rated lifetime of GSILs.
In the preliminary analysis of the general service fluorescent lamp
(GSFL) and incandescent reflector lamp (IRL) energy conservation
standards rulemaking (hereafter the ``GSFL and IRL standards
rulemaking''), DOE determined that the term ``compact fluorescent
lamps'' includes both pin base and medium base CFLs.\17\ DOE's current
test procedures for MBCFLs are set forth at 10 CFR part 430, subpart B,
appendix W. These test procedures provide instructions for measuring
MBCFL performance by referencing the August 9, 2001, ENERGY
STAR[supreg] Program Requirements for CFLs Version 2.0. Currently there
is no DOE test procedure for non-integrated CFLs (also referred to as
pin base CFLs); however, DOE has initiated a CFL test procedure
rulemaking to amend existing test procedures for MBCFLs at appendix W
and to include test procedures for additional CFL metrics and CFL
types, including non-integrated CFLs (hereafter the ``CFL test
procedure rulemaking'').\18\
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\17\ The preliminary analysis technical support document for the
GSFL and IRL Standards Rulemaking is available at
www.regulations.gov/#!documentDetail;D=EERE-2011-BT-STD-0006-0022.
\18\ See 80 FR 45724 (July 31, 2015).
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DOE is also currently completing a rulemaking to develop test
procedures for LED lamps (hereafter the ``LED TP rulemaking''). DOE
published a supplemental notice of proposed rulemaking (SNOPR) on July
9, 2015, to propose test procedures for integrated LED lamps. 80 FR
39644.
DOE is not considering establishing one test procedure for all
GSLs. While DOE is maintaining a technology-neutral approach to this
rulemaking, there are inherent mechanical and electrical differences
between lamp types that require separate testing methods. Additionally,
DOE test procedures frequently incorporate references to industry-
approved test methods. The Illuminating Engineering Society of North
America (IES) has developed separate standards for solid-state lighting
(SSL) products (i.e., LEDs and OLEDs) and CFLs. However, DOE intends to
coordinate the test procedures in development for CFLs and integrated
LED lamps and prescribe consistent testing methodologies when possible.
DOE is proposing changes to 10 CFR parts 429 and 430 of subpart B
in support of any standards adopted in this GSL rulemaking. In 10 CFR
part 429 subpart B, DOE is proposing to add GSLs to the annual
certification filing requirements in section 429.12 and to remove the
lamp types that are GSLs (i.e., MBCFLs, GSILs, intermediate base
incandescent lamps, and candelabra base incandescent lamps) from the
filing requirements in Sec. 429.12. As discussed in the proposed test
procedure for certain categories of general service lamps published
elsewhere in this issue of the Federal Register, in 10 CFR part
[[Page 14538]]
430 subpart B DOE is proposing to add a new paragraph to Sec. 430.23
for test procedures for GSLs.
1. Standby- and Off-Mode Energy Consumption
EPCA requires energy conservation standards adopted for a covered
product after July 1, 2010, to address standby-mode and off-mode energy
use. (42 U.S.C. 6295(gg)(3)) EPCA defines active mode as the condition
in which an energy-using piece of equipment is connected to a main
power source, has been activated, and provides one or more main
functions. (42 U.S.C. 6295(gg)(1)(A)) Standby mode is defined as the
condition in which an energy-using piece of equipment is connected to a
main power source and offers one or more of the following user-oriented
or protective functions: Facilitating the activation or deactivation of
other functions (including active mode) by remote switch (including
remote control), internal sensor, or timer; or providing continuous
functions, including information or status displays (including clocks)
or sensor-based functions. Id. Off mode is defined as the condition in
which an energy-using piece of equipment is connected to a main power
source, and is not providing any standby or active mode function. Id.
To satisfy the statutory definition of off mode (42 U.S.C.
6295(gg)(1)), the lamp must not be providing any active mode function
(i.e., emitting light) or standby mode function. DOE determined that it
is not possible for GSLs included in the scope of this rulemaking to
meet the off-mode criteria because there is no condition in which a GSL
is connected to main power and is not already in a mode accounted for
in either active or standby mode. DOE notes the existence of a small
number of commercially available GSLs that operate in standby mode. DOE
discusses GSLs that operate in standby mode in further detail in
section V.A.1.
C. 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). Additionally, it is DOE policy not to include in its
analysis any proprietary technology that is a unique pathway to
achieving a certain efficacy level. Section V.B of this NOPR discusses
the results of the screening analysis for GSLs, particularly the
designs DOE considered, those it screened out, and those that are the
basis for the standards considered in this rulemaking. For further
details on the screening analysis for this rulemaking, see chapter 4 of
the NOPR TSD.
2. Maximum Technologically Feasible Levels
When DOE proposes to adopt an amended standard for a type or class
of covered product, it must determine the maximum improvement in energy
efficiency or maximum reduction in energy use that is technologically
feasible for such product. (42 U.S.C. 6295(p)(1)) Accordingly, in the
engineering analysis, DOE determined the maximum technologically
feasible (``max-tech'') improvements in energy efficiency for GSLs,
using the design parameters for the most efficient products available
on the market or in working prototypes. The max-tech levels that DOE
determined for this rulemaking are described in section V.C.5 of this
proposed rule.
D. Energy Savings
1. Determination of Savings
For each trial standard level (TSL), DOE projected energy savings
from application of the TSL to GSLs purchased in the 30-year period
that begins in the year of compliance with the proposed standards
(2020-2049).\19\ The savings are measured over the entire lifetime of
GSLs purchased in the above 30-year period. DOE quantified the energy
savings attributable to each TSL as the difference in energy
consumption between each standards case and the no-new-standards case.
The no-new-standards case represents a projection of energy consumption
that reflects how the market for a product would likely evolve in the
absence of new or amended energy conservation standards.
---------------------------------------------------------------------------
\19\ Each TSL is comprised of specific efficacy levels for each
product class. The TSLs considered for this NOPR are described in
section VI.A. DOE conducted a sensitivity analysis that considers
impacts for products shipped in a 9-year period.
---------------------------------------------------------------------------
DOE used its national impact analysis (NIA) spreadsheet model to
estimate energy savings from potential new or amended standards for
GSLs. The NIA spreadsheet model (described in section V.H of this
proposed rule) calculates savings in site energy, which is the energy
directly consumed by products at the locations where they are used.
Based on the site energy, DOE calculates national energy savings (NES)
in terms of primary energy savings at the site or at power plants, and
also in terms of full-fuel-cycle (FFC) energy savings. 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
conservation standards.\20\ DOE's approach is based on the calculation
of an FFC multiplier for each of the energy types used by covered
products or equipment. For more information on FFC energy savings, see
section V.H.1 of this proposed rule.
---------------------------------------------------------------------------
\20\ The FFC metric is discussed in DOE's statement of policy
and notice of policy amendment. 76 FR 51282 (Aug. 18, 2011), as
amended at 77 FR 49701 (Aug. 17, 2012).
---------------------------------------------------------------------------
2. Significance of Savings
To adopt any new or amended 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 for the District of
Columbia Circuit, in Natural Resources Defense Council (NRDC) v.
Herrington, 768 F.2d 1355, 1373 (D.C. Cir. 1985), opined that Congress
intended ``significant'' energy savings in the context of EPCA to be
savings that were not ``genuinely trivial.'' The energy savings for all
of the TSLs considered in this rulemaking, including the proposed
standards (presented in section VI.B), are nontrivial, and, therefore,
DOE considers them ``significant'' within the meaning of section 325 of
EPCA.
[[Page 14539]]
E. Economic Justification
1. Specific Criteria
As noted above, 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)(I)-(VII)) 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 manufacturer impact analysis (MIA), as
discussed in section V.J. 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: (1) INPV, which
values the industry on the basis of expected future cash flows; (2)
cash flows by year; (3) changes in revenue and income; and (4) 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 NPV (and annualed national NPV) of the consumer costs and
benefits expected to result from particular standards. DOE also
evaluates the impacts of potential standards on identifiable subgroups
of consumers that may be affected disproportionately by a standard.
b. Savings in Operating Costs Compared to Increase in Price (LCC and
PBP)
EPCA requires DOE to consider the savings in operating costs
throughout the estimated average life of the covered product in the
type (or class) compared to any increase in the price of, or in the
initial charges for, or maintenance expenses of, the covered product
that are likely to result from a 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. The LCC analysis requires a variety of inputs, such as
product prices, product energy consumption, energy prices, maintenance
and repair costs, product lifetime, and discount rates appropriate for
consumers. To account for uncertainty and variability in specific
inputs, such as product lifetime and discount rate, DOE uses a
distribution of values, with probabilities assigned to each value.
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 change in purchase cost
due to a more-stringent standard by the change in annual operating cost
for the year that standards are assumed to take effect.
For its LCC and PBP analysis, DOE assumes that consumers will
purchase the covered products in the first year of compliance with new
or amended standards. The LCC savings for the considered efficacy
levels (ELs) are calculated relative to the case that reflects
projected market trends in the absence of amended standards. DOE's LCC
and PBP analysis is discussed in further detail in section V.F.
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 III.D.1, DOE uses the NIA spreadsheet models to
project NES.
d. Lessening of Utility or Performance of Products
In establishing product classes and in evaluating design options
and the impact of potential standard levels, DOE evaluates potential
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 proposed in this document 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 proposed 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 will transmit a copy of this proposed
rule to the Attorney General with a request that the Department of
Justice (DOJ) provide its determination on this issue. DOE will publish
and respond to the Attorney General's determination in the final rule.
f. Need for National Energy Conservation
DOE also considers the need for national energy conservation in
determining whether a new or amended standard is economically
justified. (42 U.S.C. 6295(o)(2)(B)(i)(VI)) The energy savings from the
proposed standards are likely to provide improvements to the security
and reliability of the nation's energy system. Reductions in the demand
for electricity also may result in reduced costs for maintaining the
reliability of the nation's electricity system. DOE conducts a utility
impact analysis to estimate how standards may affect the nation's
needed power generation capacity, as discussed in section V.M.
The proposed standards also are likely to result in environmental
benefits in the form of reduced emissions of air pollutants and
greenhouse gases (GHG) associated with energy production and use. DOE
conducts an emissions analysis to estimate how potential standards may
affect these emissions, as discussed in section V.K; the emissions
impacts are reported in section VI.B.6 of this NOPR. DOE also estimates
the economic value of emissions reductions resulting from the
considered TSLs, as discussed in section V.L.
[[Page 14540]]
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))
To the extent interested parties submit any relevant information
regarding economic justification that does not fit into the other
categories described above, DOE could consider such information under
``other factors.''
2. Rebuttable Presumption
As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA creates a
rebuttable presumption that an energy conservation standard is
economically justified if the additional cost to the consumer of a
product that meets the standard is less than three times the value of
the first year's energy savings resulting from the standard, as
calculated under the applicable DOE test procedure. DOE's LCC and PBP
analyses generate values used to calculate the effects that proposed
energy conservation standards would have on the payback period for
consumers. These analyses include, but are not limited to, the 3-year
payback period contemplated under the rebuttable-presumption test. In
addition, DOE routinely conducts an economic analysis that considers
the full range of impacts to consumers, manufacturers, the nation, and
the environment, as required under 42 U.S.C. 6295(o)(2)(B)(i). The
results of this analysis serve as the basis for DOE's evaluation of the
economic justification for a potential standard level (thereby
supporting or rebutting the results of any preliminary determination of
economic justification). The rebuttable-presumption payback calculation
is discussed in section V.F of this proposed rule.
IV. Issues Affecting Scope of Coverage
This section examines the various issues affecting the scope of
coverage of this rulemaking. These issues include: Restrictions of the
Appropriations Rider; clarifications to the GSL definition; additional
proposed definitions supporting the GSL definition; and lamps that DOE
is proposing to exempt from the GSL definition. Additionally, DOE
addresses the GSLs for which it is proposing standards. Finally, DOE
discusses the proposed scope of metrics in the rulemaking. DOE received
many comments on these issues in response to the preliminary analysis
and responds to these comments below.
A. Appropriations Rider
GSILs are included in the definition of GSL. Although 42 U.S.C.
6295(i)(6) authorizes DOE to evaluate energy conservation standards for
GSLs which, by definition, includes GSILs, the Appropriations Rider, in
relevant part, restricts the use of appropriated funds in connection
with several aspects of DOE's incandescent lamps energy conservation
standards program. Specifically, section 313 of Public Law 113-235
prohibits expenditure of funds appropriated by that law to implement or
enforce: (1) 10 CFR 430.32(x), which includes maximum wattage and
minimum rated lifetime requirements for GSILs and maximum wattage
requirements for candelabra base incandescent lamps and intermediate
base incandescent lamps; and (2) standards set forth in section
325(i)(1)(B) of EPCA (42 U.S.C. 6295(i)(1)(B)), which sets minimum lamp
efficiency ratings for IRLs. Because of the applicability of the
Appropriations Rider to these lamps, DOE is not analyzing GSILs,
intermediate-base incandescent lamps, or candelabra base incandescent
lamps in this rulemaking. DOE is also directed by 42 U.S.C.
6295(i)(6)(A)(i)(II) to determine whether the exemptions for certain
incandescent lamps should be maintained or discontinued based, in part,
on exempted lamp sales collected from manufacturers. However, as
stated, DOE is prohibited from using appropriated funds to implement or
enforce standards for GSILs and thus cannot re-evaluate the existing
exemptions for GSILs in the rulemaking. DOE received several comments
on the inclusion of GSILs in the scope of this rulemaking.
Earthjustice commented that section 325(i)(6)(A)(i) of EPCA
requires DOE to initiate a rulemaking proceeding no later than January
1, 2014, to determine whether the standards in effect for GSLs should
be strengthened and whether ``the exemptions for certain incandescent
lamps should be maintained or discontinued.'' To meet these
obligations, Earthjustice asserted, DOE must, among other things,
analyze standards for GSILs and lamps that have been exempted from the
requirements applicable to GSILs. Earthjustice stated that DOE has
failed to address these lamps, and is now in violation of its statutory
duty to initiate a rulemaking that meets the requirements of section
325(i)(6)(A)(i) no later than January 1, 2014. (Earthjustice, No. 30 at
p. 1)
DOE confirms that as the Appropriations Rider contains a
congressional directive disallowing the use of appropriated funds to
implement or enforce standards on any products in 10 CFR 430.32(x),
such lamps are not included in this statutorily prescribed rulemaking
at this time. Under 42 U.S.C. 6295(i)(6)(A)(v), if DOE fails to (1)
complete a rulemaking in accordance with clauses (i) through (iv),
which includes determining whether the exemptions for certain
incandescent lamps should be maintained or discontinued, or (2) publish
a final rule that will meet or exceed the energy savings associated
with the EISA 2007 45 lm/W backstop, then the backstop will be
triggered beginning January 1, 2020. Due to the Appropriations Rider,
DOE is unable to perform the analysis required in clause (i) of 42
U.S.C. 6295(i)(6)(A). As a result, the backstop in 6296(i)(6)(A)(v) is
automatically triggered.
Earthjustice stated that their comments on the previous stages of
this rulemaking also explained that the plain language of the
Appropriations Rider that currently prohibits DOE from using
appropriated funds ``to implement or enforce section 430.32(x) of title
10, Code of Federal Regulations,'' does not prevent DOE from amending
the standards for the lamp types exempted from the GSIL definition.
Based on the preliminary TSD's discussion of the Appropriations Rider,
Earthjustice stated that DOE may be misinterpreting the status of those
22 types of incandescent lamps exempted from EPCA's definition of
``general service incandescent lamp.'' The preliminary TSD states that
DOE believes it is prohibited by the Appropriations Rider from
modifying the existing exemptions for GSILs in this rulemaking.
Earthjustice disagreed that the broad interpretation DOE gives the
Appropriations Rider is reasonable and urged DOE to reconsider its
interpretation. Additionally, if that interpretation remains unchanged,
Earthjustice asked DOE to explain how the prohibition in the text of
the Appropriations Rider applies to the exempted lamp types.
(Earthjustice, No. 30 at pp. 1-2) The Pacific Gas and Electric Company,
Southern California Gas Company, San Diego Gas and Electric, and
Southern California Edison (hereafter, the ``California investor-owned
utilities or the ``CA IOUs'') agreed in a joint comment that DOE has
taken an overly restrictive interpretation of the Appropriations Rider,
which specifically prohibits DOE from using appropriated funds ``to
implement or enforce'' 10 CFR 430.32(x), but does not prevent DOE from
amending standards for any incandescent lamp. CA IOUs
[[Page 14541]]
thought the interpretation of the Appropriations Rider should allow
room to close loophole opportunities that allowed inexpensive
incandescent general service products to be sold as exempted products.
(CA IOUs, No. 33 at pp. 1-2) Earthjustice further specified that
nothing in EPCA suggests discontinuing the exemptions for these lamps
would make them GSILs. The exemption that DOE must decide whether to
maintain or discontinue is an exemption from the GSL standards, not an
exemption from the statute's definition of the term ``general service
incandescent lamp.'' Therefore, Earthjustice concluded that while DOE
cannot use appropriated funds to implement or enforce standards for
GSILs, there is no prohibition on applying standards to any of the 22
types of lamps exempted in EPCA's definition of ``general service
incandescent lamp.'' If DOE regulated the exempted lamps outside the
GSIL rubric, the Appropriations Rider does not block the path to energy
conservation standards. For example, the preliminary TSD suggests that
DOE believes it would be authorized to regulate the subset of exempted
incandescent lamps that are subject to tracking requirements under
section 325(l). DOE has continued meeting its obligation to collect and
analyze shipment data for these lamps, notwithstanding the
Appropriations Rider. 79 FR 15058 (Mar. 18, 2014). If the distinction
DOE has drawn, that enables the implementation of standards for these
lamps, is that they are not GSILs if regulated under section 325(l),
DOE needs to consider that they would also not be GSILs if DOE adopts
standards for them under section 325(i)(6)(A). (Earthjustice, No. 30 at
p. 2)
By definition, GSL does not apply to any lighting application or
bulb shape excluded from the ``general service incandescent lamp''
definition. (42 U.S.C. 6291(30)(BB)) Therefore, based on the GSL
definition, the 22 incandescent lamps that are excluded in EPCA from
the definition of GSIL would not be GSLs. It is the case, however, that
DOE could determine under the authority in 42 U.S.C.
6295(i)(6)(A)(i)(II) to discontinue the exemption for the 22 types of
lamps exempted from EPCA's definition of GSIL. If DOE were to do so and
agreed with Earthjustice and the CA IOUs that discontinuing the
exemptions would not make any of those lamps GSILs, it would be the
case that those formerly exempted lamps would also not be GSLs for
which DOE could establish standards in the current rulemaking. Rather,
the formerly exempted lamp types would have to be considered GSILs in
order for DOE to regulate the lamps under its authority to promulgate
standards for GSLs. Since the Appropriations Rider prohibits the
expenditure of funds to implement or enforce standards for GSILs, DOE
would not be able to establish or amend energy conservation standards
for any of these lamps. As a result, making a determination about
discontinuing the exemption from the GSIL definition for any of the 22
types of lamps would make no difference in the GSL rulemaking, and DOE
declines to address the exemptions at the present time.
The National Electrical Manufacturers Association (NEMA) and NRDC
commented that they understand the rulemaking is complicated by the
existence of the Appropriations Rider. NEMA acknowledged that they
appreciated the explanation provided by DOE that the Appropriations
Rider (and similar predecessor legislation) makes it difficult to
consider the real baseline in this rulemaking and other issues;
however, they fundamentally disagreed with DOE's approach to product
classes in this rulemaking and the proposal for technology-neutral
energy conservation standards. NEMA stated that the Appropriations
Rider has influenced DOE's selection of this approach in a manner not
intended by Congress in EISA 2007. (NEMA, No. 34 at p. 2; NRDC, Public
Meeting Transcript, No. 29 at p. 42)
DOE notes that the definition of general service lamps includes
lamps of various technologies including CFLs, LED lamps, and OLED lamps
in addition to GSILs, and section 325(i)(6)(A)(ii)(I) explicitly states
that the GSL rulemaking is not limited to incandescent lamp
technologies. Therefore, as further discussed in section V.A.1, DOE is
evaluating standards in a technology-neutral approach in this
rulemaking in order to carry out the more expansive analysis of lamps
that serve general service lighting applications intended by EPCA.
While the Appropriations Rider has vast impacts on the analyses of this
rulemaking, such limitations precipitate from the prohibition placed on
the implementation or enforcement of standards on GSILs, the
Appropriations Rider has not influenced DOE's proposed product class
structure. While DOE may not analyze GSILs in this rulemaking, DOE has
taken a broad interpretation for what can be considered a GSL,
analyzing non-GSIL lamps intended to serve in general lighting
applications. See section V.A.1 for the resulting product classes.
B. Clarification of General Service Lamp Definition
The term, general service lamp, includes GSILs, CFLs, general
service LEDs, OLEDs, and any other lamps that the Secretary determines
are used to satisfy lighting applications traditionally served by
GSILs; however, this definition does not apply to any lighting
application or bulb shape excluded from the ``general service
incandescent lamp'' definition, or any general service fluorescent lamp
or incandescent reflector lamp. (42 U.S.C. 6291(30)(BB)) Pursuant to
the definition of GSL, DOE has the authority to consider additional
lamps that it determines are used to satisfy lighting applications
traditionally served by GSILs. In the preliminary analysis, DOE took a
broad interpretation of what lamps can be considered GSLs. DOE
determined GSLs are lamps intended to serve in general lighting
applications (as defined in 10 CFR 430.2) by providing an interior or
exterior area with overall illumination. Thus, DOE considered GSLs as
lamps which have a lumen output of 310 lumens or greater, have an ANSI
base,\21\ are not a light fixture, operate on any voltage, are not
designed and labeled for use in non-general applications, and are not
or could not be considered in another rulemaking proceeding. DOE
received several comments on this approach.\22\
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\21\ A lamp base standardized by the American National Standards
Institute.
\22\ GSL preliminary analysis at 2-25.
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Some stakeholders supported DOE's broad interpretation of GSLs.
EEAs commented that DOE should include all lamps that provide light
between 310 and 2,600 lumens in the GSL standards scope, regardless of
the shape of the lamp's cover, or the size of the lamp's base. They
urged DOE to limit exemptions to lamps that cannot provide general
service illumination due to technical, definable characteristics. For
example, limiting covered lamps to a list of conventional shapes
creates an incentive for manufacturers to evade the standards by making
a slight modification to the shape of the lamp, which does not provide
any additional functionality. Therefore, EEAs requested that DOE
broaden the scope of coverage to eliminate such loopholes. (EEAs, No.
32 at p. 5) Overall, CA IOUs agreed that some lamps previously excluded
from the definition of GSIL can be used to provide general illumination
and as replacements for GSLs. They supported DOE's findings that lamps
with other
[[Page 14542]]
ANSI bases (non-E26 \23\ screw bases), directional lamps, high-lumen
lamps (>2,600 lumens), and lamps with operating voltage outside the
range of 110-130 V could be considered GSLs. (CA IOUs, No. 33 at p. 2)
---------------------------------------------------------------------------
\23\ An E26 base, or medium screw base, means an Edison screw
base identified with the prefix E-26 in the ``American National
Standard for Electric Lamp Bases'', ANSI_IEC C81.61-2003, published
by the American National Standards Institute. 10 CFR 430.2
---------------------------------------------------------------------------
However, some stakeholders disagreed with DOE's interpretation of
GSLs. GE stated that DOE is applying an extremely broad scope and
should limit it to large potential for energy savings and lamp use. GE
determined that the intent of this rulemaking is to look at lamps that
provide the highest volume and therefore highest potential for energy
savings; namely, the medium screw base lamps that are between 310 and
2,600 lumens where the bulk of the general lighting applications occur.
(GE, Public Meeting Transcript, No. 29 at pp. 26-27) Southern Company
also agreed that the intent of the legislation was for standard
consumer lighting products, and that a scope that is too broad may
result in unintended consequences for specialized industrial
applications. They also cautioned against setting standards too high on
CFLs and LED lamps with the potential of encouraging more people to use
incandescent technology. (Southern Company, Public Meeting Transcript,
No. 29 at pp. 27, 30-31)
DOE has interpreted the definition of GSLs in order to ensure that
products used for general service lighting applications are included.
DOE gave careful consideration to each criteria and what lamp types it
would cover. DOE determined a lower bound lumen range and ANSI base
specification were essential in identifying lamps used in general
service lighting applications. DOE also found that voltages higher and
lower than line voltage are also being used in general lighting
applications and therefore, a voltage specification was not useful.
Further DOE's interpretation accounted for exemption of specialty lamps
that could not provide overall illumination and confirmation that there
is no overlap of coverage among lamp rulemakings. Therefore, DOE finds
that its interpretation adequately captures the intention of a general
service lamp. DOE is proposing a new definition of ``general service
lamp'' in section 430.2 to capture the criteria and exemptions
discussed in more detail in the following sections.
DOE considered lamps' potential for energy savings, including
impacts such as shifts to incandescent technologies, when determining
which GSLs to establish standards for in this rulemaking (see section
IV.E for further details).
DOE received specific comments on several aspects of the
interpretation of the GSL definition, as discussed in the following
sections.
1. General Lighting Applications
CA IOUs questioned the term general lighting application. They
noted that it is defined in 10 CFR 430.2 as ``lighting that provides an
interior or exterior area with overall illumination,'' and yet there is
no definition of overall illumination. CA IOUs requested an
interpretation from DOE. (CA IOUs, Public Meeting Transcript, No. 29 at
p. 28) The definition for general lighting application was added to the
CFR upon codifying the Energy Independence and Security Act of 2007
(Public Law 110-140; EISA 2007). DOE considers the term ``overall
illumination'' to be similar in meaning to the term ``general
lighting'' as defined in the industry standard ANSI/IES RP-16-10
(hereafter ``RP-16''). RP-16 states that ``general lighting'' means
lighting designed to provide a substantially uniform level of
illuminance throughout an area, exclusive of any provision for special
local requirements.
2. Lamps Addressed in Other Rulemakings
As discussed previously, DOE has the authority to consider
additional lamp types that it determines are used to satisfy lighting
applications traditionally served by GSILs. To limit the probability
that one lamp type might be subject to two different standards, DOE did
not consider adding lamp types that are or could be addressed in a
separate rulemaking proceeding. For example, the GSFL and IRL
rulemaking considered establishing standards for additional types of
fluorescent lamps (such as 2-foot linear fluorescent lamps). 80 FR
4041, 4055 (Jan. 26, 2015). While that rulemaking ultimately concluded
that additional lamps should not be subject to standards, DOE did not
consider the additional lamps evaluated as GSFLs to be candidates for
coverage in the GSL rulemaking.
NEMA agreed with DOE's assessment in the preliminary analysis that
SBMV lamps should not be included in this rulemaking as they are high-
intensity discharge (HID) lamps, and as such could be covered in
another rulemaking. (NEMA, No. 34 at p. 6) Further, Westinghouse
acknowledged that they agreed with not considering any products that
are covered under another rulemaking due to potential complications.
(Westinghouse, Public Meeting Transcript, No. 29 at p. 39) Having
received no other feedback on this topic, DOE continues not to propose
standards in this rulemaking for products currently covered by other
rulemakings. DOE requests comment on this approach.
3. High-Lumen Lamps (>2,600 Lumens)
In the preliminary analysis, DOE considered including lamps with
lumen output between 310 and 2,600 lumens.\24\ DOE maintains this lower
bound because lamps with lumen output less than 310 lumens do not
provide sufficient overall illumination. Regarding lamps with a lumen
output greater than 2,600 lumens, DOE believes that these lamps can be
used in overall illumination and therefore meet the definition of GSL.
However, in the preliminary analysis DOE considered not establishing
standards for GSLs with lumens greater than 2,600 due to a potential
shift to incandescent technologies. As noted previously, due to the
Appropriations Rider, DOE is unable to consider modifying the existing
exemption for GSILs with lumen output greater than 2,600 lumens. In the
preliminary analysis, DOE reasoned that establishing energy
conservation standards for higher lumen lamps in more-efficient
technologies (e.g., integrated and non-integrated CFLs), while not also
addressing higher lumen incandescent lamps, may ultimately increase
national energy consumption due to a shift to lower-cost incandescent
technologies.\25\
---------------------------------------------------------------------------
\24\ Id. at 2-27.
\25\ Id. at 2-28.
---------------------------------------------------------------------------
EEAs recommended that DOE broaden the scope of coverage considered
in the preliminary analysis to include lamps with outputs between 2,601
and 3,300 lumens. EEAs noted that this change would ensure lamps
currently exceeding 150 W are also covered and would remove any
incentive for manufacturers to introduce slightly brighter bulbs as a
means to avoid compliance with standards. Conventional 150 W
incandescent lamps produce around 2,500-2,700 lumens, and EEAs had
noticed an increased amount of 150 W and 200 W incandescent lamps
available in stores. EEAs stated that they also expect LED ELs to
continue to increase, leading to new LED lamps that deliver higher
light levels on the market by 2020. As DOE may not implement or enforce
energy conservation standards on GSILs in this rulemaking, should DOE
promulgate standards for CFLs and LED lamps with
[[Page 14543]]
outputs between 2,601 and 3,300 lumens, there could be an even more
pronounced migration to the 150 W and 200 W incandescent lamps. (EEAs,
No. 32 at p. 7)
Earthjustice found that DOE's determination that establishing
standards for CFL and LED versions of high-lumen lamps, but not for
high-lumen incandescent lamps, could increase national energy
consumption fails to consider that including high-lumen lamps as GSLs
would trigger the 45 lm/W backstop requirement. While Earthjustice
disagreed with DOE's interpretation that the Appropriations Rider
prohibits DOE from promulgating standards for high-lumen incandescent
lamps, Earthjustice noted that even with DOE's interpretation, the
backstop still applies to any lamps DOE determines meet the EPCA
criterion for coverage as a general service lamp. Therefore,
Earthjustice asserted that all high-lumen lamps, including incandescent
high-lumen lamps, will need to meet a standard of 45 lm/W. Earthjustice
urged DOE to reconsider its approach to the scope of coverage given the
backstop provision's application to all GSLs. (Earthjustice, No. 30 at
pp. 3-4)
Southern Company commented that if the backstop goes into effect
and the standard is at 45 lm/W, there will most likely need to be
exceptions based on available technology. Southern Company stated that
there are instances where consumers trying to use higher lumen bulbs
are forced to use incandescents because there is no product on the
market that fits their size limitations. Southern Company requested DOE
consider exceptions for products with space constraints or higher lumen
outputs. (Southern Company, Public Meeting Transcript, No. 29 at pp.
131-132)
DOE agrees that the backstop under 42 U.S.C. 6295(i)(6)(A)(v), in
all likelihood, will become effective beginning January 1, 2020. In
this NOPR analysis, DOE further evaluated products in the high-lumen
range and found limited product offerings and concluded that these
products have a low market share and therefore, would not result in
significant energy savings. (See chapter 3 of the NOPR TSD for further
details.) Further, DOE agrees there are technological limitations
currently to creating higher efficacy replacements while maintaining
form factor for high lumen lamps. Hence, regardless of implications of
the backstop, DOE maintains its decision not to establish standards for
GSLs greater than 2,600 lumens in this rulemaking. DOE requests comment
on the energy savings potential of standards for GSLs greater than
2,600 lumens.
4. Lamps without an ANSI Base
In the preliminary analysis, DOE considered GSLs to have an ANSI
base to ensure they can be used in sockets commonly found in
residential, commercial, and industrial fixtures.\26\ NRDC asked for
clarification on this ANSI base criterion for meeting the GSL
definition. NRDC asked for example, if DOE would consider a lamp with a
non-ANSI base that uses an adapter to fit a medium screw base socket;
although, NRDC noted that this combination is not currently in
practice. (NRDC, Public Meeting Transcript, No. 29 at pp. 24-25)
Westinghouse commented that they make adapters, but stated that, as per
EPAct, they are not permitted to make any adapter that converts a
medium screw base socket to any other socket type. (Westinghouse,
Public Meeting Transcript, No. 29 at pp. 25-26)
---------------------------------------------------------------------------
\26\ Id. at 2-28.
---------------------------------------------------------------------------
DOE is not aware of any lamps on the market relevant to the GSL
scope that have a non-ANSI base which can be converted into an ANSI
base via an adapter or other device. DOE will continue to monitor the
market for such products and requests comments on whether such lamps
are commercially available.
5. Operating Voltage
CA IOUs recommended that lamps designed and marketed to be operated
at 130 V or higher (often marketed as long-life lamps) be included in
the definition of GSL. (CA IOUs, No. 33 at p. 2) In the preliminary
analysis, DOE stated that lamps with operating voltage outside the
range of 110 to 130 V can be used in general lighting applications and
are therefore, GSLs.\27\ Specifically, DOE found that lamps operating
on low voltage (i.e., requires the use of a transformer) can provide
overall illumination. However, DOE's interpretation of not requiring
GSLs to operate on a specific voltage means that lamps operating at 130
V or higher are also within the scope of GSLs.
---------------------------------------------------------------------------
\27\ Id. at 2-22.
---------------------------------------------------------------------------
6. Summary of GSL Interpretation
In summary, DOE is proposing to interpret general service lamps as
lamps intended to serve in general lighting applications and have the
following basic characteristics: (1) An ANSI base with the exclusion of
light fixtures; (2) lumen output of 310 lumens or greater; (3) operate
at any voltage; (4) are not the subject of other rulemakings; and (5)
are not designed and labeled for use in certain non-general
applications (see section IV.D for more information).
C. Definitions Supporting GSLs
DOE also considered several definitions to support its
interpretation of the GSL definition and received comments on certain
definitions, discussed in the sections below.
1. General Service LED Lamps
General service LED lamps are included in the definition of GSL.
LED lamps can be integrated or non-integrated. DOE does not currently
have a definition for ``general service LED lamp,'' however ``light-
emitting diode or LED'' is defined at 10 CFR 430.2 as a p-n junction
solid-state device of which the radiated output, either in the infrared
region, the visible region, or the ultraviolet region, is a function of
the physical construction, material used, and exciting current of the
device. In the preliminary analysis, DOE considered the following
definition for general service LED lamps: ``General service light-
emitting diode (LED) lamp means an integrated or non-integrated LED
lamp designed for use in general lighting applications (as defined in
430.2).'' \28\
---------------------------------------------------------------------------
\28\ Id. at 3-5.
---------------------------------------------------------------------------
NEMA suggested additional wording to clarify the use of LEDs in
general service LED lamps and proposed the language ``that uses light
emitting diodes as the primary source of light'' be added to the end of
DOE's proposed definition. (NEMA, No. 34 at p. 3) DOE agrees that the
additional language may provide clarification by connecting the lamp
type with the light source used. DOE therefore proposes the following
definition for general service LED lamp and requests comment on whether
further modifications are needed: ``General service light-emitting
diode (LED) lamp means an integrated or non-integrated LED lamp
designed for use in general lighting applications (as defined in 430.2)
and that uses light-emitting diodes as the primary source of light.''
2. Organic Light-Emitting Diode Lamps
OLED lamps are also included in the definition of GSL. DOE does not
currently have a definition for OLED lamp; however, OLED is defined at
10 CFR 430.2 as a thin-film light-emitting device that typically
consists of a series of organic layers between two electrical contacts
(electrodes). In the preliminary analysis, DOE considered defining
``Organic light-emitting diode or OLED lamp to mean an integrated or
non-
[[Page 14544]]
integrated lamp that uses OLEDs as the primary source of light.'' \29\
---------------------------------------------------------------------------
\29\ A typographical error occurred on p. 3-6 of the preliminary
analysis stating ``as light'' rather than ``of light.''
---------------------------------------------------------------------------
NEMA noted that a typographical error existed in the definition
considered for OLED lamp and suggested the following revisions:
``Organic light-emitting diode or OLED lamp means an integrated or non-
integrated lamp designed for use in general lighting applications that
uses OLEDs as the primary source of light.'' (NEMA, No. 34 at p. 3) DOE
agrees that specifying that OLED lamps are for use in general lighting
applications further clarifies the scope of the GSL rulemaking. DOE
also appreciates NEMA noting the typographical error and has corrected
the error in the proposed definition. Therefore, DOE is proposing the
following definition for OLED lamp in this NOPR analysis and requests
comment on whether further modifications are needed: ``Organic light-
emitting diode or OLED lamp means an integrated or non-integrated lamp
designed for use in general lighting applications that uses OLEDs as
the primary source of light.''
3. Integrated Lamp and Non-integrated Lamp
In the preliminary analysis, DOE considered defining integrated
lamps and non-integrated lamps for GSLs as: ``Integrated lamp means a
lamp that contains all components necessary for the starting and stable
operation of the lamp, does not include any replaceable or
interchangeable parts, and is connected directly to a branch circuit
through an ANSI base and corresponding ANSI standard lamp-holder
(socket)'' and ``Non-integrated lamp means a lamp that is not an
integrated lamp.'' \30\
---------------------------------------------------------------------------
\30\ GSL preliminary analysis at 3-4.
---------------------------------------------------------------------------
NEMA disagreed with DOE's proposed definition of integrated lamp
stating that the bases on integrated lamps mentioned in the definition
should be limited to those bases most commonly used with the lamps
covered within the rulemaking's scope. Currently, these bases would be
limited to medium screw bases and GU24 bases \31\ for integrated lamps,
but those could be adjusted if the scope of the regulation changed in
the future. NEMA suggested the following definition: ``Integrated lamp
means a CFL or LED lamp that contains all components necessary for the
starting and stable operation of the lamp, does not include any
replaceable or interchangeable parts, and is intended to be connected
directly to a branch circuit through a Medium Screw Base or a GU24
base.'' (NEMA, No. 34 at pp. 2-3)
---------------------------------------------------------------------------
\31\ Medium screw base is defined in 10 CFR 430.2, and DOE
proposes a definition for GU24 base in section IV.C.5.
---------------------------------------------------------------------------
NEMA also disagreed with the DOE's proposed definition of non-
integrated lamps because many of the lamps that would be covered by
this broad definition are not within the scope of the rulemaking.
(NEMA, No. 34 at p. 7) GE added that the non-integrated lamp definition
is too broad and remarked that DOE needs to provide the specifics of
what a non-integrated lamp is within the scope of this rulemaking. (GE,
Public Meeting Transcript, No. 29 at pp. 52-53) NEMA suggested the
following definition: ``Non-integrated lamp means a lamp that requires
additional external components for starting and stable operation of the
lamp, such as a ballast or a driver and has a single-ended 2-pin or 4-
pin base.'' (NEMA, No. 34 at p. 3)
DOE developed the definitions of ``integrated lamp'' and ``non-
integrated lamp'' to be technology neutral and broadly encompass any
ANSI base in order to cover all lamp types within the GSL scope, and
not just those for which standards are being set in this rulemaking.
Further, for standards specific to a base type, DOE would clearly state
the base type to which standards are applicable. Additionally, lamp
designs of GSLs are either integrated (i.e., include within them all
components for operation) or are non-integrated (i.e., require an
external component for operation). Because all lamps fit in either one
or the other configuration, DOE finds that its approach to defining
non-integrated lamps as any lamp that is not an integrated lamp to
comprehensively include all possible GSLs with the external component
configuration. Therefore, DOE proposes to maintain the definitions of
``integrated lamp'' and ``non-integrated lamp'' as specified in the
preliminary analysis.
4. Hybrid Lamps
In the preliminary analysis, DOE noted that the CFL test procedure
rulemaking is proposing the definition of ``Hybrid compact fluorescent
lamp to mean a compact fluorescent lamp that incorporates one or more
supplemental light sources of different technology.'' 80 FR 45724 (July
31, 2015).
NEMA commented that DOE's proposed definition of hybrid CFLs was
vague and suggested the following definition to increase clarity:
``Hybrid compact fluorescent lamp means a compact fluorescent lamp that
incorporates one or more supplemental light sources of different
technology, such as halogen or LED, which are energized and operated
independently and may or may not operate simultaneously.'' (NEMA, No.
34 at p. 4) Because this definition is being proposed in the CFL test
procedure rulemaking, DOE will address NEMA's comment within that
rulemaking.
5. Base Types
As NEMA agreed with the preliminary definition of pin base lamps
(NEMA, No. 34 at p. 4), and DOE received no other comments, DOE is
continuing to propose the definition of ``Pin base lamp to mean a lamp
that uses a base type designated as a single pin base or multiple pin
base system in Table 1 of ANSI C81.61, Specifications for Electrics
Bases.''
In the preliminary analysis, DOE also considered defining ``GU24
base to mean the GU24 base standardized in ANSI C81.61.'' NEMA agreed
with the proposed definition for GU24 base. (NEMA, No. 34 at p. 4)
Since DOE received no further comments, DOE is continuing to propose
the definition for GU24 base as specified in the preliminary analysis.
In the preliminary analysis, for non-integrated lamps DOE had
identified pin bases and screw bases as the only bases that would meet
the scope of GSLs. DOE requested comment on this assessment. NEMA
confirmed that there are no other base types for non-integrated lamps
that meet the definition of GSLs. (NEMA, No. 34 at p. 7)
6. Light Fixture
In the preliminary analysis, DOE considered adding the definition
of ``light fixture'' to the Federal Register in order to ensure that
complete light fixtures with ANSI bases (e.g., certain retrofit kits)
are not included in the scope of this rulemaking. Specifically, DOE
considered the definition for ``Light Fixture to mean a complete
lighting unit consisting of lamp(s) and ballast(s) (when applicable)
together with the parts designed to distribute the light, to position
and protect the lamps, and to connect the lamp(s) to the power
supply.'' \32\
---------------------------------------------------------------------------
\32\ Id. at 3-6.
---------------------------------------------------------------------------
NEMA agreed with the considered light fixture definition. (NEMA,
No. 34 at p. 4) DOE is proposing to slightly modify the definition to
clarify that a light fixture may contain light sources other than
lamps, such as LED modules or arrays, and drivers in addition to
ballasts. Therefore, DOE is proposing the following definition for
``light fixture'' in this NOPR analysis and is requesting comment on
this definition:
[[Page 14545]]
``Light Fixture means a complete lighting unit consisting of light
source(s) and ballast(s) or drivers(s) (when applicable) together with
the parts designed to distribute the light, to position and protect the
light source, and to connect the light source(s) to the power supply.''
7. LED Downlight Retrofit Kits
DOE did not consider a definition for LED downlight retrofit kits
in the preliminary analysis; however, DOE conducted a survey of the
market and found several LED downlight retrofit kits available at
common distribution channels and determined a definition was necessary
to clarify whether these kits are considered GSLs. DOE found that LED
downlight retrofit kits are designed to directly replace traditional
downlights that use technologies such as incandescent or halogen lamps
or CFLs. DOE also determined that LED downlight retrofit kits generally
use an ANSI lamp base and are certified to the UL 1598C standard for
LED Retrofit Luminaire Conversion Kits.\33\ The retrofit kits integrate
the light source and trim and therefore require the existing trim and
lamp to be removed before installing in the existing fixture housing.
DOE does not consider LED downlight retrofit kits to be GSLs because
the kits integrate additional components such as the trim and require
the existing trim to be removed. In support of the scope of this
rulemaking, DOE is proposing a definition for LED downlight retrofit
kits which aligns with the definition for SSL Downlight Retrofits in
the May 29, 2015, ENERGY STAR Program Requirements for Luminaires
(Light Fixtures) Version 2.0 (hereafter ``ENERGY STAR Luminaires
Specification V2.0'').\34\ The definition proposed for ``LED Downlight
Retrofit Kit'' means a product intended to install into an existing
downlight, replacing the existing light source and related electrical
components, typically employing an ANSI standard lamp base, either
integrated or connected to the downlight retrofit by wire leads, and is
a retrofit kit classified or certified to UL 1598C . LED downlight
retrofit kit does not include integrated lamps or non-integrated
lamps.'' DOE requests comment on the definition proposed.
---------------------------------------------------------------------------
\33\ Underwriter's Laboratory. Standard for Light-Emitting Diode
(LED) Retrofit Luminaire Conversion Kit. 2014. Underwriter's
Laboratory Inc. (Last accessed July 21, 2015.) http://ulstandards.ul.com/standard/?id=1598C&edition=1&doctype=ulstd.
\34\ ENERGY STAR. ENERGY STAR Program Requirements: Product
Specification for Luminaires (Light Fixtures): Eligibility Criteria,
Version 2.0. 2015. U.S. Environmental Protection Agency: Washington,
DC (Last accessed July 7, 2015.) https://www.energystar.gov/sites/default/files/Luminaires%20V2.0%20Final%20Specification.pdf.
---------------------------------------------------------------------------
8. Summary of Definitions
In the preliminary analysis, DOE developed definitions for the
following terms in support of the scope of the rulemaking: ``Integrated
lamp,'' ``non-integrated lamp,'' ``general service LED lamp,'' ``OLED
lamp,'' ``light fixture,'' ``pin base lamp,'' and ``GU24 base.'' In the
NOPR analysis, DOE is continuing to propose the definitions considered
in the preliminary analysis for these terms except for the edits to
``general service LED lamp,'' ``OLED lamp,'' and ``light fixture,'' as
specified in previous sections. DOE is also proposing a new definition
for ``LED downlight retrofit kits.'' The proposed definitions are
detailed in chapter 3 of this NOPR TSD.
D. Exempted Lamps
DOE considered whether lamps designed or labeled for specific
applications could provide overall illumination and therefore meet the
definition of general service lamp. DOE determined that the exemptions
for specialty applications listed in 42 U.S.C. 6291(30)(D)(ii) are only
applicable to GSILs.\35\ Although the GSIL exemptions do not
automatically apply to other lamp technologies, DOE considered whether
these exemptions should be continued for GSLs. The definition of
``general service incandescent lamp'' includes the following list of
exempted incandescent lamps:
---------------------------------------------------------------------------
\35\ GSL preliminary analysis at 3-7.
(1) An appliance lamp;
(2) A black light lamp;
(3) A bug lamp;
(4) A colored lamp;
(5) An infrared lamp;
(6) A left-hand thread lamp;
(7) A marine lamp;
(8) A marine signal service lamp;
(9) A mine service lamp;
(10) A plant light lamp;
(11) A reflector lamp;
(12) A rough service lamp;
(13) A shatter-resistant lamp (including a shatter-proof lamp
and a shatter-protected lamp);
(14) A sign service lamp;
(15) A silver bowl lamp;
(16) A showcase lamp;
(17) A 3-way incandescent lamp;
(18) A traffic signal lamp;
(19) A vibration service lamp;
(20) A G shape lamp (as defined in ANSI C78.20) and ANSI C79.1-
2002 with a diameter of 5 inches or more;
(21) A T shape lamp (as defined in ANSI C78.20) and ANSI C79.1-
2002 and that uses not more than 40 watts or has a length of more
than 10 inches; and
(22) A B, BA, CA, F, G16-1/2, G-25, G30, S, or M-14 lamp (as
defined in ANSI C79.1-2002) and ANSI C78.20 of 40 watts or less.
10 CFR 430.2
In the preliminary analysis, DOE assessed whether each specified
lamp type provides overall illumination and therefore can be used in
general lighting applications.\36\ DOE found the lumen output of some
of these lamps was insufficient to provide overall illumination. Thus,
DOE considered not establishing standards for appliance lamps, black
lights, bug lamps, colored lamps, infrared lamps, marine signal lamps,
mine service lamps, plant lights, sign service lamps, silver bowl
lamps, showcase lamps, and traffic signal lamps under the GSL
rulemaking because the lamps are intended for use in non-general
applications. DOE preliminarily determined that left-hand thread lamps,
marine lamps, reflector lamps, rough service lamps, shatter-resistant
lamps, 3-way lamps, vibration service lamps, and lamps of several
specific shapes could provide overall illumination and therefore do not
require exemption for standards. DOE received comments regarding these
potential exemptions and definitions for these lamp types. Therefore,
in this NOPR analysis, DOE is proposing definitions for each of the
specified lamp types to better delineate the GSL definition, especially
in regards to determining the possible GSLs that use technologies other
than incandescent and operate in applications equivalent to those of
the lamps exempted from the GSIL definition. DOE requests comment on
the definitions proposed. In addition, DOE requests comment on if there
are any other lamp types that do not serve in general lighting
applications and should be exempted from general service lamp
standards.
---------------------------------------------------------------------------
\36\ Id.
---------------------------------------------------------------------------
1. Exempted Lamp Types
NEMA agreed that colored lamps, appliance lamps, black light lamps,
bug lamps, plant lamps, infrared lamps, sign service lamps, showcase
lamps, marine signal lamps, mine service lamps, silver bowl lamps, and
traffic signal lamps should be exempted from standards since these are
low volume lamps designed for specialty applications and do not provide
overall illumination. (NEMA, No. 34 at pp. 4-5) CA IOUs and EEAs also
recommended that DOE look closely at plant light lamps, bug lamps,
silver bowl lamps, colored lamps, and appliance lamps to ensure that
adequate legal definitions are in place to prevent lamps that could
easily be used in general lighting applications from being
[[Page 14546]]
manufactured and marketed under these exemptions. (CA IOUs, No. 33 at
p. 2; EEAs, No. 32 at pp. 6-7) DOE discusses these lamp types and
others that it is proposing to exempt, as well as the relevant
definitions, in the sections that follow.
a. Colored Lamp
In the preliminary analysis, DOE considered the definition for
``Colored lamp to mean a colored fluorescent lamp, a colored
incandescent lamp, or a lamp designed and marketed as a colored lamp
and not designed or marketed for general lighting applications with
either of the following characteristics (if multiple modes of operation
are possible [such as variable CCT], either of the below
characteristics must be maintained throughout all modes of operation):
(1) A CRI less than 40, as determined according to the method set forth
in CIE Publication 13.3; or (2) A correlated color temperature less
than 2,200 K or greater than 7,000 K as determined according to the
method set forth in IES LM-66 or IES LM-79 as appropriate.'' \37\
---------------------------------------------------------------------------
\37\ Id. at 3-8.
---------------------------------------------------------------------------
NEMA agreed with the considered definition of colored lamps. (NEMA,
No. 34 at p. 3) GE commented that this definition has been used
successfully for linear fluorescent lamp technology for years and tends
to push lamps into areas that define the colored space. Therefore, GE
found it logical for this definition to also to work for CFLs or LED
lamps. However, GE also noted that a definition for colored lamps needs
to be further reviewed within the industry. (GE, Public Meeting
Transcript, No. 29 at pp. 42-43) EEAs urged DOE to develop clear legal
definitions for each exempted lamp type in order to prevent a
manufacturer from simply applying an inexpensive removable cover to an
incandescent lamp that could be used in general service applications if
the cover was removed. They recommended that DOE include language in
its definition that would not exempt such lamps that are operable once
one or more components are removed. Additionally, EEAs noted that the
definition of colored incandescent lamp includes lamps with a
correlated color temperature (CCT) below 2,500 K, which might also
represent a potential loophole as it is not far from the 2,700 K of
conventional lamps. EEAs asked that DOE eliminate this language in its
regulations. (EEAs, No. 32 at p. 6) In interviews, some manufacturers
noted that colored lamps are evaluated based on perceived color, and as
such would be better defined by the wavelength of the light emitted,
rather than the CRI or CCT. However, given the different possible
colors of colored lamps, manufactuers noted it would be problematic to
include distinct wavelengths in the definition, especially given the
definition's application to developing LED technologies. Given that CRI
and CCT may be the best descriptors of the lamp type overall, DOE
received feedback from manufacturers interviewed that the lower CCT
limit should be raised to 2,500 K to accommodate the demand for 2,200-
2,450 K atmospheric mood lighting in hospitality applications.
Accordingly, DOE continues to propose defining this lamp type with CRI
and CCT, but broadens the lower CCT range to less than 2,500 K as:
``Colored lamp means a colored fluorescent lamp, a colored incandescent
lamp, or a lamp designed and marketed as a colored lamp and not
designed and marketed for general lighting applications with either of
the following characteristics (if multiple modes of operation are
possible [such as variable CCT], either of the below characteristics
must be maintained throughout all modes of operation): (1) A CRI less
than 40, as determined according to the method set forth in CIE
Publication 13.3; or (2) A correlated color temperature less than 2,500
K or greater than 7,000 K as determined according to the method set
forth in IES LM-66 or IES LM-79 as appropriate.''
b. Appliance Lamp
CA IOUs and EEAs recommended that DOE establish a maximum allowable
light output for appliance lamps to prevent the lamps from being used
in general service applications. EEAs specified that DOE should
establish this maximum allowable light output level at approximately
400 lumens. CA IOUs and EEAs noted that these lamps often utilize
thicker glass in order to withstand higher temperatures, but they could
potentially be made to look and operate like a conventional GSIL. EEAs
added that a manufacturer could simply alter a current 43 W halogen
incandescent, add a thicker glass enclosure, and market it as an
equivalent of a GSL, only identifying it as an appliance lamp in
smaller print on the front of the package. EEAs stated that the 400-
lumen limit, a light output just below conventional 40 W incandescent
lamps, would be sufficient to illuminate the small oven spaces for
which appliance lamps are intended and prevent them from being used as
a loophole to compliance with standards. (CA IOUs, No. 33 at p. 2;
EEAs, No. 32 at pp. 6-7)
A statutory definition of appliance lamp currently exists at 42
U.S.C. 6291(30)(T). Appliance lamp is defined as: ``Appliance lamp
means any lamp that-- (1) Is specifically designed to operate in a
household appliance, has a maximum wattage of 40 watts, is sold at
retail (including an oven lamp, refrigerator lamp, and vacuum cleaner
lamp); 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 for appliance use.'' 10 CFR
430.2.
DOE acknowledges that the 40 W limit currently included in the
statutory definition of appliance lamp is intended for incandescent
technology; however, DOE is unable to modify this wattage limit as it
is part of a statutory definition. Per the definition, appliance lamps
are required to be designated and marketed as such on both the lamp
packaging and marketing materials. Further, DOE clarified the term
``designed and marketed'' in the GSFL and IRL standard rulemaking to
ensure that the marketing materials explicitly stated the intended
application of the exempted lamp. DOE defined ``designated and
marketed'' to mean that the intended application of the lamp is clearly
stated in all publicly available documents (e.g., product literature,
catalogs, and packaging labels). 80 FR 4053-4054 (Jan. 26, 2015).
Therefore, DOE believes the specialty application of appliance lamps
will be sufficiently clear, thus preventing consumers from using
appliance lamps in general service lighting applications.
c. Black Light Lamp
In interviews, DOE presented a preliminary definition of ``Black
light lamp to mean a lamp that is designed and marketed as a black
light lamp and is an ultraviolet lamp that emits a significant portion
of its radiative power in the UV-A band (315 to 400 nm).''
Manufacturers agreed with this preliminary definition of black
light lamps based on the definition of black light lamp in the industry
standard RP-16. RP-16 defines black light lamp as an ultraviolet lamp
that emits a significant portion of its radiative power in the UV-A
band (315 to 400 nm). However, DOE determined that additional
specificity was necessary for the definition of black light lamp to
clearly describe the exemption. Therefore, DOE proposes to exempt black
light lamps defined as: ``Black light lamp means a lamp that is
designed and marketed as a black light lamp and is an ultraviolet lamp
with the highest radiant power
[[Page 14547]]
peaks in the UV-A band (315 to 400 nm) of the electromagnetic
spectrum.''
d. Bug Lamp
In manufacturer interviews, DOE presented a preliminary definition
of bug lamp ``Bug lamp to mean a lamp that emits a significant portion
of its radiative power in the UV-A band (315 to 400 nm) and the visible
spectrum (380 to 770 nm).''
Manufacturers disagreed with this definition, noting that bug lamps
are not those lamps made to attract insects, but rather those designed
to emit light outside the typical perception of night-flying insects.
Such lamps emit light only in the red or yellow part of the spectrum
and are marketed as a bug lamp. Therefore, in this NOPR DOE proposes to
exempt bug lamps defined as: ``Bug lamp means a lamp that is designed
and marketed as a bug lamp, has radiant power peaks above 550 nm on the
electromagnetic spectrum, and has a visible yellow coating.''
e. Plant Light Lamp
In manufacturer interviews, DOE received feedback on the following
preliminary definition for plant light lamps: ``Plant light lamp means
a lamp that contains a filter to suppress the yellow and green portion
of the spectrum. Plant light lamps must be specifically designed and
marketed for plant growing applications.''
Some manufacturers noted that the definition applies only to
incandescent lamps, as other lighting technologies are not constrained
to use filters. Manufacturers pointed out that the main purpose of such
lamps is to mimic sunlight for growing plants indoors. The light output
of the lamp may be more tailored to the needs of the specific plants
being cultivated. Therefore, DOE amends the preliminary definition and
instead proposes to exempt plant light lamps defined as: ``Plant light
lamp means a lamp that is designed to promote plant growth by emitting
its highest radiant power peaks in the regions of the electromagnetic
spectrum that promote photosynthesis: blue (440 nm to 490 nm) and/or
red (620 to 740 nm). Plant light lamps must be designed and marketed
for plant growing applications.''
f. Infrared Lamp
In manufacturer interviews, DOE received feedback on the following
preliminary definition for infrared lamp: ``Infrared lamp means a lamp
that radiates predominately in the infrared spectrum (770 nm to 1
mm).''
Manufacturers commented that DOE should align the definition with
that used in the RP-16. Further, manufacturers specifically requested
that DOE remove the wavelength range and add a clause that the visible
radiation is not of principle interest. RP-16 defines ``infrared lamp''
as a lamp that radiates predominately in the infrared; the visible
radiation is not of principal interest. DOE finds the wavelength range
necessary for clearly describing the exemption and also believes that
describing the primary application of infrared lamps (i.e., to provide
heat) is more straightforward. Therefore, DOE proposes defining
infrared lamp to align with the RP-16 definition with slight
modifications as: ``Infrared lamp means a lamp that is designed and
marketed as an infrared lamp, has its highest radiant power peaks in
the infrared region of the electromagnetic spectrum (770 nm and 1 mm),
and which has a primary purpose of providing heat.''
g. Sign Service Lamp
In interviews, DOE received feedback from manufacturers generally
agreeing with a preliminary definition of sign service lamps, proposed
below. DOE received some feedback regarding additional technology-
specific features that should be incorporated in the definition.
However, DOE is proposing technology-neutral definitions to support the
scope of the rulemaking. Therefore, DOE proposes to define sign service
lamps as: ``Sign service lamp means a vacuum type or gas-filled lamp
that has sufficiently low bulb temperature to permit exposed outdoor
use on high-speed flashing circuits, is designed and marketed as a sign
service lamp, and has a maximum rated wattage 15 watts.''
h. Showcase Lamp
In manufacturer interviews, DOE received feedback on the following
preliminary definition for showcase lamp: ``Showcase lamp means a lamp
that has a T-shape as specified in ANSI C78.20 and ANSI C79.1 and a
length exceeding 25 cm [centimeters] and is marketed as a showcase
lamp.''
The majority of manufacturers agreed with a preliminary definition
of showcase lamps, however DOE received some feedback to remove the
length requirement, as there was concern that showcase lamps varied in
length. DOE agrees the definition is sufficiently narrow without the
length requirement and therefore proposes to define showcase lamps as:
``Showcase lamp means a lamp that has a T-shape as specified in ANSI
C78.20 and ANSI C79.1, is designed and marketed as a showcase lamp, and
has a maximum rated wattage of 75 watts.''
i. Marine Signal Service Lamp, Mine Service Lamp, Silver Bowl Lamp, and
Traffic Signal Lamp
In interviews, DOE received feedback from manufacturers agreeing
with several preliminary definitions of exempted lamp types including
marine signal service lamps, mine service lamps, silver bowl lamps, and
traffic signal lamps. DOE did not receive any negative feedback or
suggested changes. Therefore, DOE proposes to define these terms as:
``Marine signal service lamp means a lamp that is designed and marketed
for marine signal service applications''; ``Mine service lamp means a
lamp that is designed and marketed for mine service applications'';
``Silver bowl lamp means a lamp that has a reflective coating applied
directly to part of the bulb surface that reflects light toward the
lamp base and that is designed and marketed as a silver bowl lamp'';
and ``Traffic signal lamp means a lamp that is designed and marketed
for traffic signal applications.''
j. Designed and Marketed
In the recent final rule for general service fluorescent lamps and
incandescent reflector lamps, DOE adopted a definition for the term
``designed and marketed'' to ensure 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 disclosures be consistent about the
intended use or application of the lamp. 80 FR 4042, 4053-4054 (January
26, 2015).
DOE is proposing a revised definition of ``designed and marketed''
to clarify that the term means that a lamp is specifically designed for
a specialty application and that, when distributed in commerce, the
packaging and all publicly available documents indicate the intended
application. This will help ensure that lamps that are exempt from the
definition of general service lamp do not have packaging or marketing
materials that imply they are for use in general lighting applications.
DOE proposes to revise the definition of ``designed and marketed'' to
read: ``Designed and marketed means that the product is specifically
designed to fulfill the indicated application and, when distributed in
commerce, is designated and marketed for the intended application, with
the designation on the packaging and all publicly available documents
(e.g., product literature,
[[Page 14548]]
catalogs, and packaging labels) indicating the intended application.
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.''
2. Non-Exempted Lamp Types
In the preliminary analysis, DOE determined that several of the
specified lamp types were able to provide overall illumination and
therefore could serve in general lighting applications and did not
require an exemption from standards. NRDC and CEC expressed their
support of the determination that many of the currently exempt lamps do
provide overall illumination and therefore do not need to be exempted.
(NRDC, Public Meeting Transcript, No. 29 at p. 12; CEC, No. 31 at p. 2)
DOE discusses these lamp types in the following sections.
a. Reflector Lamp
In the preliminary analysis, DOE considered defining the term
``reflector lamp'' in support of the scope of coverage and presented
the definition for ``Reflector lamp to mean a lamp that has an R, PAR,
BPAR, BR, ER, MR, or similar bulb shape as defined in ANSI C78.20 and
ANSI C79.1 and is used to direct light.'' \38\
---------------------------------------------------------------------------
\38\ Id. at 3-9.
---------------------------------------------------------------------------
NEMA agreed with the proposed definition of reflector lamps. (NEMA,
No. 34 at p. 4) However, NEMA did not think it was appropriate to
include reflector lamps as covered products in this rulemaking because
they are designed for specific applications and offer unique
performance and efficiency features. (NEMA, No. 34 at p. 6) DOE
observes that reflector lamps provide overall illumination and serve in
general lighting applications. DOE finds no evidence that reflector
lamps would be prohibited from use in general service applications, and
therefore proposes the definition of reflector lamp considered in the
preliminary analysis. DOE welcomes comment on including non-IRLs in the
definition of GSLs.
DOE also considered the following definition for ``non-reflector
lamp'' in the preliminary analysis to further define the scope: ``Non-
reflector lamp means a lamp that is not a reflector lamp.'' \39\ NEMA
commented that the definition of non-reflector lamp was vague and
suggested modifying the definition to mean ``an integrated or non-
integrated lamp that is not a reflector lamp.'' (NEMA, No. 34 at p. 4)
DOE notes that the definitions for reflector and non-reflector are
intended to describe the shapes of the lamps specifically. DOE is
therefore maintaining the definition for non-reflector lamp. DOE
proposes definitions for integrated and non-integrated lamp in section
IV.C.3.
---------------------------------------------------------------------------
\39\ Id.
---------------------------------------------------------------------------
b. Rough Service Lamp, Shatter-Resistant Lamp, and Vibration Service
Lamp
In the preliminary analysis, DOE noted that rough service lamps and
vibration service lamps are defined specifically in the context of
incandescent or halogen technology. However, DOE determined that the
utility of rough service, vibration service, and shatter-resistant
lamps is their service in applications where vibrations occur or in
applications where broken glass due to shattering would be a safety
hazard and therefore must be contained. DOE believes that LED lamps are
inherently durable and thus can provide the necessary utility to serve
in these applications.
NRDC and CA IOUs commented that special treatment lamps such as
shatter-resistant and vibration service lamps can be used in general
applications. (NRDC, Public Meeting Transcript, No. 29 at pp. 12-13; CA
IOUs, No. 33 at p. 2) EEAs agreed that energy-efficient CFLs and LED
lamps already exist on the market to meet the needs of each of these
lamp types, and in some cases provide superior functionality. As LED
lamps are not filament based, they are more robust than vibration
service incandescent lamps. (EEAs, No. 32 at pp. 5-7) NEMA commented
that the rough service lamp definition and vibration service lamp
definition are unique to incandescent technology and are not applicable
to CFL or LED lamp technology as those lamps are more shock resistant
by design. NEMA further noted that shatter-resistant lamps normally
contain a coating that absorbs a small portion of the light output; and
therefore, light absorption factors would have to be considered when
setting efficacy regulations covering this technology. (NEMA, No. 34 at
p. 5) However, as LED lamps capable of operating in shatter-resistant
applications exist at the highest ELs, DOE finds there is no
technological reason to separate them into their own product class, let
alone exempt them from standards. Because DOE found that the utilities
offered by these lamp types are available at higher levels of efficacy,
DOE is proposing not to exempt non-incandescent lamps for use in rough
service, shatter-resistant, and vibration service applications in this
GSL rulemaking.
c. Three-Way Lamp
In the preliminary analysis, DOE determined that 3-way lamps are
able to provide overall illumination, and therefore can be used in
general lighting applications. Further, DOE found that 3-way CFLs and
LED lamps are available, and one of the most-efficacious GSLs currently
available on the market is a 3-way LED lamp. Therefore, DOE found no
technological reason not to include non-incandescent 3-way lamps in
this GSL rulemaking.\40\
---------------------------------------------------------------------------
\40\ Id. at 3-8.
---------------------------------------------------------------------------
NRDC and CA IOUs agreed that 3-way lamps can be used in general
applications. (NRDC, Public Meeting Transcript, No. 29 at pp. 12-13; CA
IOUs, No. 33 at p. 2) EEAs agreed that 3-way CFLs and LED lamps already
exist on the market designed to replace conventional 3-way incandescent
lamps. (EEAs, No. 32 at pp. 6-7) NEMA commented that if 3-way CFL or
LED lamps are regulated, the efficiency requirements should be
evaluated based on the highest, most energy consuming setting, as is
done in other current standards (e.g., ENERGY STAR) for these products.
NEMA explained that 3-way CFLs will operate at different efficacies at
different light levels and it is important that DOE base compliance
with standards at the most-efficacious or highest light output level.
Forcing the lower light output settings to meet high ELs would be very
problematic for industry and may remove this product utility from the
market. (NEMA, No. 34 at p. 5) DOE agrees with NEMA that the unique
utility of 3-way lamps needs to be retained and that 3-way lamps
performance varies depending on the light output setting. Therefore, in
both the CFL TP NOPR and the LED TP SNOPR, DOE proposed to operate CFLs
and LED lamps at the maximum input power. 80 FR 45724 (July 31, 2015);
80 FR 39644 (July 9, 2015). Further, when tested at the highest output
level, DOE finds that 3-way lamps are available at the highest ELs and
therefore proposes not to exempt 3-way lamps from this rulemaking.
d. Left-Hand Thread Lamp and Marine Lamp
DOE did not consider providing exemptions for left-hand thread
lamps or marine lamps in the preliminary analysis. NEMA and EEAs agreed
that
[[Page 14549]]
the left-hand thread lamp and marine lamp exemptions are not necessary
for CFL or LED lamp technology. (NEMA, No. 34 at p. 6; EEAs, No. 32 at
pp. 6-7) DOE agrees that these lamp types provides overall illumination
and can serve in general lighting applications, and therefore continues
not to propose an exemption for left-hand thread lamps or marine lamps
from GSL standards.
e. Lamps of Specific Shapes
In the preliminary analysis, DOE determined that lamps of several
specific shapes (such as G, T, B, BA, CA, F, G16.5, G25, G30, S, and
M14, as defined in ANSI C79.1-2002 and ANSI C78.20) provide overall
illumination, and therefore can serve in general lighting applications
and do not require an exemption from standards.\41\ EEAs agreed with
DOE's determination that lamps of these shapes provide overall
illumination and can serve in general lighting applications and as such
would no longer warrant an exemption. (EEAs, No. 32 at pp. 6-7) NEMA
commented that specific lamp shapes exempted in the current
incandescent rule primarily provide decorative illumination and are not
wholly functional in all general service applications. NEMA stated that
decorative lamp shapes provide unique technical challenges for both CFL
and LED lamp technology, and they cannot be assumed to be capable of
reaching similar efficacy levels. NEMA noted that the technical effort
necessary to mimic the consumer-demanded performance attributes of some
decorative products would come with corresponding trade-offs in
efficacy. NEMA added that because manufacturers are only beginning to
develop these types of lamps, the size of this impact on efficacy is
not well-known. NEMA commented that regulating this emerging product
category at this time would slow product innovation, as well as
development and consumer acceptance, as standards inhibit the
flexibility of the manufacturer to experiment with product
specifications that may relate to the utility of the product. NEMA
suggested DOE regulate these products in a future rulemaking. (NEMA,
No. 34 at p. 6)
---------------------------------------------------------------------------
\41\ Id.
---------------------------------------------------------------------------
DOE recognizes the rapid development of LED lamps, and notes that
products with certain lamp shapes are part of emerging product lines at
this time. As stated previously, DOE determined that these lamps could
serve in general lighting applications because they emit a minimum of
310 lumens, thus providing overall illumination. However, based on
comments received and feedback from manufacturer interviews, DOE
considered whether lamps of these certain shapes were able to achieve
the same level of efficacy as the more common 60 W A-shape equivalent
replacements. DOE also considered whether lamps of these shapes could
achieve those higher levels of efficacy in their existing form factors.
DOE found that in general the lamps of these certain shapes were
not able to achieve the highest levels of efficacy under consideration
in the NOPR analysis while maintaining their form factors. (See section
V.C.5 for more information on the ELs.) DOE compared the size of the
CFL and LED lamps that were available in these certain shapes to more
efficacious 60 W A-shape equivalent replacements to determine if the
form factors were smaller, which could indicate that space constraints
were preventing the lamps from achieving comparable efficacies. DOE
found that B-shape lamps (including blunt shape), C- and CA-shape lamps
(including candle shape), F-shape lamps (including flame or flame tip
shape), S-shape lamps, and torpedo or torpedo tip shape lamps were
considerably smaller in size than the 60 W A-shape equivalent
replacements. Therefore, DOE is proposing to exempt from the standards
proposed in this rulemaking lamps of these shapes that have a diameter
of less than or equal to 1.875 inches when measured at the widest
point. DOE also determined that the G-shape lamps (including globe
shape) with lamp diameter when measured at the widest point of less
than or equal to 2.0625 inches and A15 lamps with diameter when
measured at the widest point of less than or equal to 2.185 inches were
also notably smaller in size than the 60 W A-shape equivalent
replacements. DOE is therefore also proposing to exempt these lamp
types from the standards proposed in this rulemaking. In summary, DOE
is proposing to exempt B-, blunt, C-, CA-, candle, F-, flame, flame
tip, S-, torpedo, and torpedo tip shape lamps with a diameter of less
than or equal to 1.875 inches; G- and globe shape lamps with a diameter
of less than or equal to 2.0625 inches; and A15 lamps with a diameter
of less than or equal to 2.185 inches. DOE notes that these lamps are
general service lamps but is not proposing standards for these lamps in
this NOPR analysis. DOE will reconsider these exemptions from GSL
standards as the market continues to evolve. DOE welcomes comment on
the exemptions proposed for non-incandescent lamps of certain shapes,
in particular on the proposed diameters.
E. GSLs Under Consideration for Standards
In the preliminary analysis, DOE did not consider establishing
standards for all GSLs. Specifically, DOE considered establishing
standards in this rulemaking for the following GSLs: (1) Integrated,
non-reflector, medium screw base lamps with a lumen output between 310
and 2,600 lumens; (2) integrated and non-integrated, non-reflector GU24
base lamps with a lumen output between 310 and 2,600 lumens; and (3)
non-integrated, non-reflector, pin base, CFLs with a lumen output
between 310 and 2,600 lumens.
EEAs stated that their support for including a lamp type as a
covered lamp is contingent on DOE ultimately setting a standard for
that lamp type. EEAs stated they do not support DOE covering a lamp
type, and thereby preempting state standards, without also establishing
standards. (EEAs, No. 32 at p. 5)
In the preliminary analysis, DOE did not consider establishing
standards for GSLs for which it determined that there would be low
potential for energy savings; it would not be technologically feasible
to establish standards; and/or restrictions from the Appropriations
Rider prevented consideration of standards. DOE notes that for GSLs,
state preemption requirements are specified for California and Nevada
under 42 U.S.C. 6295(i)(6)(A)(vi). Namely, beginning, January 1, 2018,
no provision of law could preclude these states from adopting: (1) A
final rule adopted in accordance with 42 U.S.C. 6295(i)(6)(A)(i)-(iv);
(2) the minimum efficacy standard of the backstop requirement (45 lm/W)
if no final rule was adopted; or (3) for the state of California, any
California regulations related to the covered products adopted pursuant
to state statute in effect as of the date of enactment of EISA 2007. 42
U.S.C. 6295(i)(6)(A)(vi). Other than these narrow exceptions, EPCA's
statutory pre-emption provision would prohibit any state from adopting
energy conservation standards for any type of GSL regardless of whether
DOE sets standards for that type of GSL.
CA IOUs and Earthjustice commented that any lamp type determined to
be a general service lamp in this rulemaking also becomes subject to
the backstop requirement. These commenters stated that EPCA's
definition of ``general service lamp'' incorporates a few specific
types of lamps, including GSILs, CFLs, and LED lamps, but it also
authorizes DOE to determine that a lamp is a general service lamp if it
is ``used to satisfy lighting applications
[[Page 14550]]
traditionally served by general service incandescent lamps.'' 42 U.S.C.
6291(30)(BB)(i). Therefore, commenters asserted that if DOE determines
that a type of lamp meets this criterion, it automatically becomes
subject to the backstop requirement. CA IOUs noted that setting
standards for CFL and LED lamp technologies should not be problematic
as the backstop would stop market migration to incandescent
technologies. (CA IOUs, Public Meeting Transcript, No. 29 at p. 32;
Earthjustice, No. 30 at p. 3) DOE agrees that if the backstop goes into
effect on January 1, 2020, per statutory requirement, any lamp that DOE
determines is a GSL would be subject to the backstop.
NRDC stated that should the Appropriations Rider be lifted, DOE
should review the coverage of other base types, lumen outputs above
2,600, and other such lamps in this rulemaking. (NEMA, No. 34 at p. 2;
NRDC, Public Meeting Transcript, No. 29 at p. 42) As noted in the
preliminary analysis, DOE's evaluation of GSLs for which to establish
standards considered the restrictions based on the Appropriations
Rider. If the limitation on DOE's use of appropriated funds per the
Appropriations Rider is removed during the course of this rulemaking,
DOE will consider revising the scope of the rulemaking.
DOE also received several specific comments on its assessment of
GSLs considered for standards in this rulemaking.
1. Integrated Candelabra and Intermediate-Base Lamps
In the preliminary analysis DOE determined that while these lamp
types are within the scope, it would not set standards for GSLs with
candelabra and intermediate bases in this rulemaking due to the
Appropriations Rider.\42\ Earthjustice stated that as of March 2015,
DOE will be in violation of its obligation to review and amend the
energy conservation standards for intermediate-base incandescent lamps
and candelabra base incandescent lamps under 42 U.S.C. 6295(m)(1).
(Earthjustice, No. 30 at p. 1) EEAs urged DOE to cover lamps with
candelabra and intermediate bases as equivalent, given that GSIL
versions of these lamps currently are subject to wattage limits only
and there is nothing inherently unique about these lamps besides the
size of the screw base. EEAs stated that candelabra and intermediate-
base lamps are available using incandescent, CFL, and LED technology.
(EEAs, No. 32 at p. 5)
---------------------------------------------------------------------------
\42\ Id. at 3-11.
---------------------------------------------------------------------------
DOE evaluated integrated GSLs with intermediate and candelabra
bases. DOE identified one incandescent/halogen reflector candelabra
base integrated lamp and a limited number of incandescent/halogen
reflector intermediate-base integrated lamps. However, as stated
previously DOE is not considering these lamp types due to the
Appropriations Rider. DOE identified very few reflector candelabra base
or intermediate base integrated lamps in CFL or LED technology. Due to
this low market share and thereby low energy savings potential, DOE
continues to maintain its decision not to establish standards for
reflector candelabra and intermediate-base integrated lamps.
Regarding non-reflector lamps, DOE found that there are fewer
candelabra and intermediate bases offered in CFL and LED lamp
technology compared to the number offered with incandescent/halogen
technology; the latter technology cannot be considered due to the
Appropriations Rider (see section IV.A for further details). Due to
this low market share and thereby low energy savings potential, DOE
continues to maintain its decision not to establish standards for non-
reflector candelabra and intermediate base integrated lamps.
2. Pin Base Lamps
DOE considered several types of integrated and non-integrated pin
base lamps in the preliminary analysis including non-integrated pin
base CFLs, non-integrated pin LED lamps, pin base lamps with GU24
bases, and MR16 pin base lamps.\43\ DOE received comments on its
assessment of whether standards should be established for these lamp
types.
---------------------------------------------------------------------------
\43\ Id. at 3-12.
---------------------------------------------------------------------------
a. Non-Integrated Pin Base CFLs and LED Lamps
In the preliminary analysis, DOE considered establishing standards
for non-integrated pin base CFLs. NEMA, GE, and Philips commented that
non-integrated pin base lamps that go in dedicated fixtures and have
dedicated ballasts are mostly commercial products and consumers have
not been buying them for many years. Because such lamps are not an
acceptable replacement for traditional GSILs, NEMA, GE, and Philips did
not support including them in the scope. (NEMA, No. 34 at p. 16; GE,
Public Meeting Transcript, No. 29 at pp. 40-41; Philips, Public Meeting
Transcript, No. 29 at p. 41) GE commented that they do not believe
there are significant opportunities to save energy with pin base lamps
and do not think that pin base lamps should be included in an analysis
aimed at medium screw base lamps as they are not replacements for such
lamps. (GE, Public Meeting Transcript, No. 29 at pp.39-40, 79) NEMA
explained that non-integrated pin base CFLs are rarely used in
residential applications and cannot directly replace medium screw base
GSLs without replacing the entire fixture. Fixtures using these lamp
types are nearly all designed for commercial applications. (NEMA, No.
34 at p. 7, 11-12) Due to the complexity, the limited energy savings
potential, and the maturity of this product line, NEMA suggested that
DOE remove the product category from the scope of this rulemaking.
(NEMA, No. 34 at p. 16)
Although non-reflector pin base non-integrated lamps are available
in incandescent/halogen, CFL, and LED technologies, CFLs are by far the
most common type. DOE determined that the term compact fluorescent
includes both integrated and non-integrated CFLs and therefore DOE
considered non-integrated, or pin base, CFLs in the scope of this
rulemaking. DOE notes that the market share of pin base CFLs is not
insignificant given the vast number of product offerings and common use
in commercial applications. Further, DOE's analysis of non-integrated
pin base lamps within the non-integrated product class has shown that
there are levels of efficacy as well as reduced wattage options and
therefore, a standard for these lamps is technologically feasible.
DOE's analysis showed that the proposed efficacy levels for these lamp
types would retain almost all the different base type options for non-
integrated pin-base base CFLs. See section V.C for further details
regarding the engineering analysis for the non-integrated product
class. For these reasons, DOE continues to consider standards for non-
integrated pin base lamps.
DOE also received comments on non-integrated pin base LED lamps.
Regarding LED replacements for non-integrated pin base CFLs, NEMA
acknowledged that there are some LED lamp replacements being developed
at this time but noted that they do not create energy savings as they
generally have an identical wattage to non-integrated pin base CFLs and
represent a loss of utility as they do not work with some types of
controls and dimming systems. Lamp and ballast pairings that NEMA has
investigated do not have Underwriters Laboratories (UL) listing, which
they considered significant. They stated that if one is going to
retrofit pin base CFLs, there are more efficacious
[[Page 14551]]
choices than the non-reflector pin base non-integrated LED lamps.
Additionally, compatibility problems with reduced wattage lamps are not
well understood in the DOE analysis, and could result in field issues
if pursued. Finally, NEMA asked DOE to afford the same recognition of
the implications of a lamp rule on non-integrated ballast systems as
they did in the GSFL and IRL standards rulemaking. (NEMA, No. 34 at p.
7, 11-12)
DOE agrees with NEMA regarding the issues with non-integrated pin
base LEDs currently available on the market. DOE evaluated the non-
integrated pin base LED lamps and found they are still in the
development stage and currently do not maintain the same utility (e.g.,
lumen output, system compatibility) of the pin base CFLs they are
designed to replace. DOE therefore is not proposing to establish
standards for these lamp types in this rulemaking.
b. GU24 Base Lamps
In the preliminary analysis, DOE considered including integrated
and non-integrated GSLs with GU24 bases. NEMA commented that they
believe the market share for integrated CFLs with GU24 bases is
insignificant (less than 4 percent), and that GU24 base CFL products
should be excluded from scope. Additionally, NEMA commented that
currently there are no additional bases besides medium screw base used
for GSLs that have a significant market share. (NEMA, No. 34 at p. 7)
As stated previously, DOE has taken a broad interpretation of GSL and
considers lamps with base types other than medium screw bases to be
general service lamps because lamps with other base types, including
GU24, are frequently used in general lighting applications. Further,
DOE found that of the integrated pin bases considered, lamps with GU24
bases compose the vast majority of the market. While GU24 lamps may not
currently be sold in the same volume as medium screw base lamps, DOE
expects their sales to increase as a result of regulations, such as
California's Building Code Standards Title 24,\44\ which allows for the
use of GU24 base lamps as high efficacy light sources. Given their
expected market share, DOE proposes to include GU24 base integrated
lamps in the GSL rulemaking.
---------------------------------------------------------------------------
\44\ California Energy Commission's Building Code Standards are
available at: http://www.energy.ca.gov/title24/.
---------------------------------------------------------------------------
c. MR16 Lamps
In the preliminary analysis, DOE considered not establishing
standards for integrated and non-integrated pin base MR16 lamps.\45\ GE
agreed that MR16 lamps should not be covered in this rulemaking because
they are still being developed to be a suitable replacement for the
other technologies. (GE, Public Meeting Transcript, No. 29 at pp. 39-
40) NEMA agreed that current MR16 LED lamps cannot provide all the
functionality of currently available halogen MR16 lamps and should not
be regulated during this rulemaking as it is a developing product
category. (NEMA, No. 34 at p. 7)
---------------------------------------------------------------------------
\45\ Id. At 3-13.
---------------------------------------------------------------------------
CA IOUs and EEAs also supported DOE's proposal to not cover LED
MR16s or other small diameter directional lamps (those with diameters
less than 2.25 inches) in this rulemaking at this time. However, CA
IOUs disagreed with DOE's rationale behind the decision. CA IOUs
observed that DOE stated in the preliminary TSD that it would not
consider setting standards for LED MR16s because DOE did not believe
that LED technology is able to provide the same utility as halogen
technology in the MR16 lamp shape. CA IOUs noted that DOE referenced
the 2014 CALiPER study that found tested LED lamps provided a lower
center beam candle power (CBCP) than would be predicted based on their
claimed halogen equivalence (using ENERGY STAR's CBCP calculator).
However, CA IOUS asserted that the CALiPER report did not conclude that
LED MR16s are not able to provide the same utility as their halogen
counterparts; thus, DOE should be cautious about drawing such
conclusions. EEAs also disagreed with DOE's finding that energy-
efficient options do not currently exist for MR16s and commented that
there are many high-quality LED lamps in this form factor that meet a
range of application needs. CA IOUs additionally stated that there are
currently LED products that provide more center beam intensity than the
minimum required by ENERGY STAR for a 50 W equivalent lamp of the same
beam angle. Further, CA IOUs noted that DOE is not considering
standards for halogen MR16s due to the Appropriations Rider, and
therefore this comparison is irrelevant. (CA IOUs, No. 33 at pp. 2-3;
EEAs, No. 32 at p. 7)
Instead, CA IOUs and EEAs supported the proposal not to include LED
MR16s in this rulemaking because of momentum in multiple states (such
as California and Washington) to regulate MR16s. CA IOUs and EEAs
stated that such efforts would promote market transformation and lay
the groundwork for NES. Once they are adopted at the state level, CA
IOUs suggested that DOE should consider adopting standards for these
products at levels equal to or higher than those adopted by the states.
They requested that DOE remove or correct its statement that LED
technology is not able to provide the same utility as halogen
technology because there is no reason for DOE to make such an
assessment in this rulemaking, and because there is not sufficient
evidence to support such a claim. EEAs suggested that DOE should not
establish standards for MR16 lamps based on the rational that the
Appropriations Rider prevents DOE from updating IRL standards. EEAs
noted that improved standards for substitutes or near-substitutes could
backfire, further shifting the market to the unregulated lamps. (CA
IOUs, No. 33 at pp. 2-3; EEAs, No. 32 at p. 7)
DOE finds that a comparison of halogen MR16 lamps to LED MR16 lamps
is essential in determining if it is technologically feasible to set
standards for these lamps. Data provided in the CALiPER report and
DOE's assessment of MR16 products on the market do provide sufficient
evidence that, at this time, LED MR16s are not able to provide the same
utility as their halogen counterparts. From the CALiPER report, DOE
determined that none of the tested lamps emitted comparable lumen
output to the 50 W halogen MR16 lamps that CALiPER tested, despite 17
of the 27 products claiming equivalency to that wattage (or higher),
nor could any CALiPER tested lamp match the ENERGY STAR predicted CBCP
for 50 W halogen MR16s at any beam angle.\46\ (See chapter 3 of the
NOPR TSD for more information.) DOE also assessed MR16 LED lamps on the
market and found that, in general for a given beam angle, the maximum
lumen output of halogen lamps is not always achieved by LED
replacements and the CBCP of LED replacements is generally lower than
halogen lamps. Further, DOE found very few 120 V 50 W equivalent MR16s
and no 12 V 50 W equivalent MR16s that met the Energy Star predicted
CBCP based on halogen equivalencies, although some do meet the minimum
ENERGY STAR requirements. Drawing its conclusions from not only the
CALiPER report but its own evaluation of products on the market, DOE
maintains that, at this time, LED technology is currently not able to
provide the same utility as halogen technology in the MR16 lamp shape.
[[Page 14552]]
Hence, DOE is not setting standards for MR16 lamps in this rulemaking
because more-efficient replacements maintaining the same utility are
not available.
---------------------------------------------------------------------------
\46\ U.S. Department of Energy. CALiPER Application Summary
Report 22: LED MR16 Lamps. June 2014. (Last accessed November 21,
2014.) http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/caliper_22_summary.pdf.
---------------------------------------------------------------------------
3. Organic Light-Emitting Diode Lamps
DOE considered not setting standards for OLED lamps in the
preliminary analysis because OLED lamps are an emerging technology with
limited commercial availability, and it remains unclear if the efficacy
of existing OLED products can be improved.\47\ NEMA agreed that it was
premature to establish standards for OLED products at this time. This
is due to concern with regulating emerging product categories, creating
a substantial risk of slowing product innovation, development, and
consumer acceptance. (NEMA, No. 34 at p. 6) GE agreed with DOE's
position stating that most of industry believes it is too early to
regulate OLEDs because it is a developing technology and there is not
enough information about how it is going to develop. (GE, Public
Meeting Transcript, No. 29 at pp. 19-20) Thus, DOE continues to not
propose standards for OLED lamps in this NOPR analysis.
---------------------------------------------------------------------------
\47\ GSL preliminary analysis at 3-6.
---------------------------------------------------------------------------
4. Summary of GSLs Under Consideration for Standards
In summary, DOE is proposing standards for the following GSLs: 1)
integrated, non-reflector, medium screw base lamps with an initial
lumen output between 310 and 2,600 lumens; 2) GU24 base, integrated and
non-integrated, non-reflector lamps with an initial lumen output
between 310 and 2,600 lumens; and 3) non-integrated, non-reflector, pin
base, CFLs with an initial lumen output between 310 and 2,600 lumens.
For further details on the assessment of GSLs considered for standards
see chapter 3 of this NOPR TSD. DOE requests comments on its
assessments of GSLs for which standards should be proposed.
F. Scope of Metrics
Because CFLs are included in the definition of a GSL, this
rulemaking satisfies the requirements under 42 U.S.C 6295(m)(1) to
review existing standards for MBCFLs. EPAct 2005 amended EPCA by
establishing energy conservation standards for MBCFLs. Performance
requirements were specified for five metrics: (1) Minimum initial
efficacy; (2) lumen maintenance at 1,000 hours; (3) lumen maintenance
at 40 percent of lifetime; (4) rapid cycle stress; and (5) lamp life.
(42 U.S.C. 6295(bb)(1)) In addition to revising the existing
requirements for MBCFLs, DOE has the authority to establish
requirements for additional metrics including CRI, power factor,
operating frequency, and maximum allowable start time based on the
requirements prescribed by the August 9, 2001, ENERGY STAR[supreg]
Program Requirements for CFLs Version 2.0, or establish other
requirements after considering energy savings, cost effectiveness, and
consumer satisfaction. (42 U.S.C. 6295(bb)(2)-(3))
DOE received several general comments regarding the determination
of metrics in the preliminary analysis. CA IOUs recommended that DOE
analyze the impacts of improvements to the minimum quality metrics for
GSLs and adopt standards that result in increased energy savings or
increased LCC savings for consumers as they believe that cost-effective
improvements to performance aspects, such as product lifetime and power
factor, may be achievable and those are two metrics where DOE has the
authority to set standards. (CA IOUs, No. 33 at p. 8) In this proposal,
DOE considered energy savings, cost effectiveness, and consumer
satisfaction when assessing performance metric requirements pertinent
to this rulemaking, including lifetime and power factor.
DOE received several overarching comments about adopting the latest
ENERGY STAR specifications for existing and proposed additional MBCFL
metrics. NRDC and EEAs supported updating the performance requirements
for CFLs with the intent of aligning with ENERGY STAR. (NRDC, Public
Meeting Transcript, No. 29 at pp. 46-47; EEAs, No. 32 at p. 8) GE
stated that ENERGY STAR is supposed to be promoting a higher quality
type of product. In regards to product lifetime, GE noted that
traditionally, the DOE minimum standard lifetime of a product is a
couple of thousand hours fewer than the ENERGY STAR requirement. GE
suggested that DOE should consider levels other than those prescribed
by ENERGY STAR for the non-energy efficiency related quality metrics.
Furthermore, GE commented that, since the latest ENERGY STAR
specifications for lamps came out recently, fewer lamps may meet the
new criteria. (GE, Public Meeting Transcript, No. 29 at pp. 46, 48-50)
Southern Company added that there are times that ENERGY STAR has a high
percentage of the products on the market before updating standards, but
the long-term goals of ENERGY STAR is closer to the range of 20 percent
of the market. (Southern Company, Public Meeting Transcript, No. 29 at
pp. 48-49) Philips stated that ENERGY STAR, by definition, should only
represent the top 25 percent of the marketplace. Therefore, should DOE
align performance requirements with ENERGY STAR, 75 percent of
available products could be forced off the market. (Philips, Public
Meeting Transcript, No. 29 at p. 47)
NRDC thought that more CFLs met ENERGY STAR requirements and urged
DOE to examine the market share of CFLs that are ENERGY STAR qualified.
(NRDC, Public Meeting Transcript, No. 29 at p. 48) EEAs stated that,
unlike other ENERGY STAR product categories, the vast majority of CFLs
on the market meet the existing ENERGY STAR requirements. In addition,
EEAs noted the current ENERGY STAR specification was finalized in 2014
and the DOE regulations will not go into effect until 2020. (EEAs, No.
32 at p. 8) CA IOUs and EEAs recommended that DOE consider performance
metric revisions to be consistent with the latest ENERGY STAR
specification. The ENERGY STAR Program recently initiated an update to
its Lamps Specification (Version 2), and if finalized in time, CA IOUs
urged DOE to consider aligning with its specifications. (CA IOUs, No.
33 at p. 10; EEAs, No. 32 at p. 8))
DOE recognizes that ENERGY STAR requirements are meant to
distinguish a certain premium among available products on the market.
In its review of existing metrics for MBCFLs and determining additional
metrics to establish for these lamp types, DOE examined various sources
including the latest ENERGY STAR market share estimates, ENERGY STAR
specifications (ENERGY STAR Program Requirements Product Specification
for Lamps [Light Bulbs] Eligibility Criteria Version 1.1 [hereafter
``ENERGY STAR Lamps Specification V1.1'']), industry standards, and
characteristics of lamps currently on the market.\48\ The most recent
market penetration report of ENERGY STAR lamps for the year 2014
indicated that 64 percent of CFLs were ENERGY STAR certified,
indicating wide market adoption.\49\ Based on this comprehensive
evaluation, DOE determined the performance metrics that would
appropriately satisfy the requirements of energy savings, cost
[[Page 14553]]
effectiveness, and consumer satisfaction for MBCFLs.
---------------------------------------------------------------------------
\48\ DOE understands that ENERY STAR has completed an update to
its current lamp specifications. Because this version remained in
draft stage, at the time of this analysis, DOE referenced the ENERGY
STAR Lamps Specification V1.1, the specifications currently in
effect.
\49\ ENERGY STAR. Unit Shipment and Market Penetration Report
Calendar Year 2014 Summary. (Last accessed January 20, 2016.) http://www.energystar.gov/ia/partners/downloads/unit_shipment_data/2014_USD_Summary_Report.pdf?f531-f608.
---------------------------------------------------------------------------
1. Existing MBCFL Metrics
a. Lumen Maintenance
For lumen maintenance at 1,000 hours, DOE requires that the average
of at least five lamps be a minimum of 90 percent of initial lumen
output at 1,000 hours. The ENERGY STAR Lamps Specification V1.1
maintained this requirement with the added specification that all units
must be surviving at 1,000 hours. For lumen maintenance at 40 percent
of lifetime, DOE requires that 80 percent of the initial lumens must be
achieved at 40 percent of lifetime. The ENERGY STAR Lamps Specification
V1.1 also maintained this requirement with the added specification that
no more than three units may be less than 75 percent of the initial
lumen rating. In the preliminary analysis, DOE considered maintaining
its current requirements for lumen maintenance at 1,000 hours and at 40
percent of lifetime for MBCFLs.\50\
---------------------------------------------------------------------------
\50\ GSL preliminary analysis at 3-17.
---------------------------------------------------------------------------
EEAs noted that the test procedure utilized by ENERGY STAR
currently requires a sample size of 10 lamps, five base up and five
base down, unless the manufacturer restricts specific use or position.
EPAct 2005 (i.e., the current DOE standards) only require five samples.
EEAs recommended that DOE utilize 10 samples in its requirements to be
consistent with ENERGY STAR. EEAs also supported inclusion of ENERGY
STAR's requirement that all units shall be surviving at 1,000 hours,
and no more than three units may have lumen maintenance less than 75
percent at 40 percent of rated life. (EEAs, No. 32 at p. 8) However,
NEMA commented that the current statutory and regulatory requirements
for CFLs for lumen maintenance are acceptable. (NEMA, No. 34 at p. 8)
DOE determined that its current requirements for lumen maintenance
adequately address potential issues with lumen depreciation that could
lead to consumer dissatisfaction. DOE noted that the ENERGY STAR Lamps
Specification V1.1 also maintained these requirements and added the
requirements that all units shall survive at 1,000 hours and no more
than three units may be 75 percent of the initial lumen rating. DOE,
however, determined these additional requirements were not necessary to
confirm the quality of the lamp; the existing requirements would ensure
the lumen maintenance would be satisfactory to consumers. DOE assessed
data submitted for the Compliance Certification Management System
(CCMS) reporting requirements and found that the majority of lamps
certified exceeded the minimum lumen maintenance standards. Regarding
sample size, the number of MBCFL units tested is dictated by the DOE
test procedure for these lamps, amendments to which are not within the
scope of this rulemaking. (See section III.B for further details on
relevant test procedures for GSLs.) Therefore, DOE is proposing to
maintain the existing requirements of 90 percent of initial lumen
output at 1,000 hours and 80 percent of initial lumen output at 40
percent of lifetime for MBCFLs.
b. Rapid Cycle Stress Testing
DOE has a minimum requirement for rapid cycle stress for MBCFLs
that requires at least five lamps to survive cycling once per every two
hours of rated lifetime. The ENERGY STAR Lamps Specification V1.1
specifies that CFLs with a start time greater than 100 milliseconds
(ms) (i.e., non-instant start) survive cycling once per hour of rated
lifetime or a maximum of 15,000 cycles; and that CFLs with a start time
less than or equal to 100 ms (instant start) are only required to
survive cycling once per every two hours of rated lifetime. In the
preliminary analysis, DOE considered increasing the number of cycles
required for non-instant start lamps to once per every hour of rated
life, or a maximum of 15,000 cycles and maintaining the requirement for
instant start lamps to survive one cycle per every two hours of rated
lifetime.\51\
---------------------------------------------------------------------------
\51\ Id.
---------------------------------------------------------------------------
NEMA commented that the current statutory and regulatory
requirements for CFLs for rapid cycle stress testing are acceptable and
increasing rapid cycle stress tests to current ENERGY STAR standards is
not necessary to set an energy conservation standard. (NEMA, No. 34 at
p. 8)
DOE found that manufacturers do not publish information on rapid
cycle stress for MBCFLs. Further, manufacturers simply report the
number of surviving units for DOE CCMS reporting requirements. However,
as stated previously, the latest ENERGY STAR market penetration report
indicates that 64 percent of CFLs were ENERGY STAR certified thus
indicating the majority of CFLs meet the rapid cycle stress
requirements.\52\ Therefore, in this NOPR, DOE proposes to maintain the
requirement for instant start lamps (i.e., MBCFLs with a start time
less than or equal to 100 ms) to survive one cycle per every two hours
of lifetime and increasing the number of cycles required for non-
instant start lamps (i.e., MBCFLs with start times greater than 100 ms)
to once per every hour of rated life or a maximum of 15,000 cycles.
---------------------------------------------------------------------------
\52\ ENERGY STAR. Unit Shipment and Market Penetration Report
Calendar Year 2014 Summary. (Last accessed January 20, 2016.) http://www.energystar.gov/ia/partners/downloads/unit_shipment_data/2014_USD_Summary_Report.pdf?f531-f608.
---------------------------------------------------------------------------
c. Lifetime
DOE currently requires a minimum lifetime of 6,000 hours for
MBCFLs. The ENERGY STAR Lamps Specification V1.1 requires the minimum
lifetime to be 10,000 hours. In the preliminary analysis, DOE
considered revising the lifetime standard for MBCFLs to adopt ENERGY
STAR's minimum of 10,000 hours for MBCFLs.\53\ NEMA commented that the
current statutory and regulatory requirements for CFL lifetime are
acceptable and that increasing the minimum lifetime standard to the
ENERGY STAR level of 10,000 hours is not necessary for energy
conservation standards. NEMA and GE added that if the minimum lifetime
were increased, industry would recommend no more than 8,000 hours for
the federal minimum as, by definition, not all products are intended to
meet ENERGY STAR performance levels. (NEMA, No. 34 at p. 8; GE, Public
Meeting Transcript, No. 29 at p. 46)
---------------------------------------------------------------------------
\53\ Id. at 3-18.
---------------------------------------------------------------------------
As previously noted, DOE understands that ENERGY STAR requirements
are meant to determine the more energy-efficient products on the
market. However, based on an assessment of commercially available lamps
in manufacturer catalogs, DOE found that the majority of MBCFLs on the
market have lifetimes of at least 10,000 hours. Further, of the MBCFLs
for which data was submitted to DOE for CCMS reporting, 83 percent have
a lifetime of at least 10,000 hours. Given that commercially available
MBCFLs are already achieving this higher level of performance, DOE does
not find such a minimum to be indicative of only the premium products
on the market. Therefore, in this NOPR, DOE is proposing requiring
MBCFLs to have a minimum lifetime of 10,000 hours.
2. Additional MBCFL Metrics
a. Color Rendering Index
DOE does not currently have a standard for CRI. The ENERGY STAR
Lamps Specification V1.1 requires that CFLs have a CRI of at least 80.
In the preliminary analysis, DOE considered adding a requirement for
CRI of 80 or
[[Page 14554]]
greater for MBCFLs.\54\ NEMA stated that CRI is not necessary for
consideration in this rulemaking. Additionally, they commented that
they do not believe that CRI is an appropriate characteristic for a
minimum energy conservation standard. (NEMA, No. 34 at p. 8-9)
---------------------------------------------------------------------------
\54\ Id. at 3-19.
---------------------------------------------------------------------------
DOE has explicit authority to consider a CRI standard for MBCFLs.
(42 U.S.C. 6295(bb)(2)) Furthermore, a standard for CRI ensures
consumer satisfaction because high CRI light sources render colors
well, which could encourage the adoption of energy-efficient
technology. Based on an assessment of commercially available lamps in
manufacturer catalogs, DOE found that over 99 percent of MBCFLs on the
market have a CRI of at least 80. Because a minimum CRI requirement
would increase consumer satisfaction and DOE found that nearly all
commercially available MBCFLs are already achieving a CRI of at least
80, DOE is proposing to require MBCFLs to have a CRI of 80 or greater.
b. Power Factor
DOE does not currently have a standard for power factor, however,
DOE has explicit authority to consider power factor for MBCFLs. (42
U.S.C. 6295(bb)(2)) DOE reviewed industry specifications for MBCFLs and
found that the ENERGY STAR Lamps Specification V1.1 and V2.0 require
that CFLs have a power factor of 0.5 or greater. The industry standard
ANSI C82.77 Harmonic Emission Limits--Related Power Quality
Requirements for Lighting Equipment \55\ suggests a power factor of 0.5
for integrally ballasted medium screw base compact light sources with
input power less than or equal to 35 W. Based on an assessment of
commercially available lamps in manufacturer catalogs, DOE determined
that the majority of MBCFLs have a power factor in the range of 0.5 to
0.6 and a limited number of MBCFLs have a power factor greater than
0.6. Therefore, in the preliminary analysis, DOE considered adding a
standard for power factor of 0.5 or greater for MBCFLs.\56\
---------------------------------------------------------------------------
\55\ ANSI C82.77 Harmonic Emission Limits--Related Power Quality
Requirements for Lighting Equipment (January 17, 2002)
\56\ GSL preliminary analysis at 3-19.
---------------------------------------------------------------------------
NEMA commented that adding power factor requirements was not
necessary and urged DOE to refrain from including a power factor
requirement for GSLs in this rulemaking. They did not agree with DOE's
assertion that a minimum power factor requirement could decrease energy
use because that conclusion appeared to be based on a document not
relevant to GSLs.\57\ Additionally, NEMA commented that there are
trade-offs associated with increasing the power factor in CFL and LED
lamps that will reduce lamp efficacy and increase energy use, which
contradicted DOE's statement in the preliminary analysis. (NEMA, No. 34
at p. 8) Further, NEMA commented that increasing the power factor for
residential ballasts would raise ballast losses, which would more than
offset any gains in distribution efficiency and could have a negative
impact on system reliability. (NEMA, No. 34 at pp. 9-10)
---------------------------------------------------------------------------
\57\ Specifically, DOE referenced Reducing Power Factor Cost,
available here: http://www.energy.gov/eere/amo/downloads/reducing-power-factor-cost.
---------------------------------------------------------------------------
On the contrary, CA IOUs and EEAs noted that improving a lamp's
power factor has significant financial benefits for electric utility
customers, as well as societal greenhouse gas benefits. A load with a
low power factor draws more current than a load with a high power
factor for the same amount of useful power transferred. CA IOUs and
EEAs stated that higher currents mean increased energy losses both on
the customer side of the meter, and on the utility side (grid losses).
The losses from a small load (for example a CFL) with a poor power
factor may be small, but losses increase exponentially as the total
current increases (power loss is a function of the current squared
times the resistance of the wiring). CA IOUs calculated that three
lamps with poor power factor on a circuit result in nine times the
losses of one lamp. (CA IOUs, No. 33 at p. 9; EEAs, No. 32 at p. 9)
Furthermore, CA IOUs and EEAs noted that grid efficiency is an
integral part of electric rate design. In other words, if electric
grids do not operate efficiently, rate payers will end up paying more
for the energy they use through higher rates. So, in addition to the
losses on the customer side of the meter, in the long run, consumers
also pay for losses on the utility side of the meter. Therefore, CA
IOUs stated that given CFLs now constitute roughly 30-40 percent of the
screw base GSL market, CFL power factor has huge implications for
consumer energy bills, grid efficiency, and greenhouse gas emissions.
(CA IOUs, No. 33 at p. 9; EEAs, No. 32 at p. 9) NEMA, however, stated
that GSLs do not typically represent a major portion of the power used,
and in any scenario where CFLs or LED lamps are used to replace
traditional incandescent lamps, the substantially lower wattage of
these replacement lamps will result in a reduced lighting load
regardless of power factor. (NEMA, No. 34 at pp. 8-9)
NEMA argued that CFLs used in the home have a leading power factor
that tends to offset the lagging power factor of motor loads and helps
to balance the overall power factor of the home. (NEMA, No. 34 at p.
10) CA IOUs disagreed that a combination of leading and lagging power
factors will cancel each other out. They noted that displacement power
factor is generally associated with capacitive and inductive loads;
inductive loads, like motors, have ``lagging'' power factor, where
current lags behind voltage, while typical capacitive loads
(capacitors, electronics) have ``leading'' power factor (where the
current leads voltage). However, CA IOUs pointed out that these types
of equipment with poor power factor do not ``cancel each other out'' if
they are non-linear loads with distortion power factor. CFL ballasts
are an example of such a non-linear load (i.e., they draw current in
short spikes which generally do not relate to the voltage waveform).
For these types of non-linear loads, the combination of leading and
lagging power factors will not cancel each other out predictably,
consistently, or effectively. Additionally, there is no displacement
effect unless the two types of linear-load equipment within a given
metered circuit operate at exactly the same time. CA IOUs noted that
the low incidence of concurrent operation is rarely considered when the
displacement argument is made. (CA IOUs, No. 33 at pp. 9-10)
In its determination of additional metrics for MBCFLs, DOE may
consider features that are indicative of lamp quality, specifically
energy usage, cost effectiveness, and consumer satisfaction. (42 U.S.C.
6295(bb)(3)) Due to the non-linear loads and the different phase angles
associated with these loads, realizing the effect of a lamp's power
factor on lagging power factors created by motors connected to the grid
is difficult and depends on what is active on the grid.\58\ However,
DOE finds that power factor does impact energy use and, in general, it
is important to ensure grid losses are minimized. Passive and active
technologies that can correct power factors in lamps are commercially
available and the circuitry used in power factor correction (PFC) is
made to be very efficient, while consuming small
[[Page 14555]]
amounts of power.\59\ Therefore, DOE finds that setting a minimum power
factor standard for MBCFLs to ensure that low quality products are not
being used on the electrical grid is ultimately relevant to energy
usage, cost effectiveness, and consumer satisfaction.
---------------------------------------------------------------------------
\58\ USAID Asia. Power Factor: Policy Implications for the
Scale-up of CFL Programs. 2010. (Last accessed July 13, 2015.)
http://standby.iea-4e.org/files/otherfiles/0000/0057/2010_USaid_PF_study_CFLs.pdf.
\59\ Ibid.
---------------------------------------------------------------------------
Upon reviewing ENERGY STAR's qualified product list for non-
directional CFLs, EEAs reported that of the 1,189 models on the list,
225 had a power factor of 0.5 and 957 had a power factor of 0.6. As 80
percent of the listed models already have a power factor of 0.6, EEAs
recommend DOE consider a power factor of at least 0.6. (EEAs, No. 32 at
p. 9)
CA IOUs recounted that in the earlier days of the U.S. CFL market,
most major manufacturers offered CFLs with PFC, and some still do. CA
IOUs stated that in the United States, high power factor (0.85 or
greater) is common in non-integrated CFL lamp-and-ballast systems,
while less common among integrated CFLs, which have very low power
factors, in the range of 0.5 to 0.6. The industry has settled on these
values because that is all that has been required by ENERGY STAR, which
is referenced by most utility programs. Other countries have promoted
or adopted policy initiatives to encourage or require high power factor
in CFLs, and these products are available from a number of major
manufacturers at competitive prices in other markets. CA IOUs commented
that in the European Union, high power factor is common in higher
wattage CFL products (above 25 W). India is another market that has a
large presence of high power factor CFLs, including many residential,
lower-wattage product lines. CA IOUs provided the example of the
Philips Tornado HPF line. CA IOUs' research found that there is a wide
variety of high power factor CFL products offered at popular Indian
online retailers at prices that are comparable to low power factor
product prices. CA IOUs and EEAs encouraged DOE to draw from these
international markets (where products are produced in large quantities)
as a reference point for product costs, given that residential,
integrated high power factor products are not as common in the United
States. (CA IOUs, No. 33 at pp. 8-9; EEAs, No. 32 at p. 9) Further, CA
IOUs recommended that DOE adopt a minimum power factor requirement for
integrated and non-integrated CFLs of 0.85, as PFC chips are relatively
inexpensive and are extremely cost-effective. (CA IOUs, No. 33 at pp.
8-9)
DOE agrees that MBCFLs exist with a power factor greater than 0.8,
but found these lamps to be extremely uncommon in the U.S. market.
Based on EPA's ENERGY STAR Certified Light Bulbs Database, less than 1
percent of MBCFLs had a power factor greater than 0.8. As noted DOE
considered ENERGY STAR requirements, industry standards, and
characteristics of lamps in the current market. The vast majority of
the U.S. market reports power factors in the range of 0.5 to 0.6 for
CFLs, which is consistent with ENERGY STAR and ANSI C82.77 requirement
of a minimum power factor of 0.5 for these lamps. Thus, DOE believes
that requiring a minimum power factor of 0.5 is achievable for MBCFLs
while supporting improved overall efficacy.
c. Start Time
DOE does not currently have a standard for start time. The ENERGY
STAR Lamps Specification V1.1 requires that the time needed for a lamp
to become fully illuminated must be within one second of application of
electrical power. In the preliminary analysis, DOE considered requiring
a start time of within one second of the application of electrical
power for MBCFLs.\60\ NEMA stated that adding start time requirements
is not necessary for energy conservation standards. Additionally, NEMA
did not agree that start time has any effect on energy efficiency.
(NEMA, No. 34 at p. 9)
---------------------------------------------------------------------------
\60\ GSL preliminary analysis at 3-20.
---------------------------------------------------------------------------
Westinghouse agreed with a one-second start time requirement for
CFLs. Regarding the definition of ``fully illuminated,'' Westinghouse
believed ENERGY STAR requires 80 percent of rated lumens, not 100
percent. Westinghouse noted that the definition needed to be clarified.
(Westinghouse, Public Meeting Transcript, No. 29 at p. 45)
EEAs noted that one of the complaints consumers voice about CFLs is
the reduced level of light some CFLs produce when first turned on and
the time it takes for the lamp to reach full brightness. EEAs suggested
DOE include standards not just for start time, but also for run-up
time. On February 13, 2015, the U.S. Environmental Protection Agency
(EPA) issued its first draft of Version 2.0 of its lamp specification,
which shortened the required time to achieve 80 percent stabilized
light output to 60 seconds or less, from the current Version 1.0
requirement that allows 120 seconds. EEAs suggested DOE adopt the new
run-up time from the draft of Version 2 of the ENERGY STAR lamp
specifications. (EEAs, No. 32 at p. 8)
DOE finds that start time impacts consumer satisfaction, because a
delay in starting is undesirable and can affect acceptance of a more-
efficient lamp technology. Manufacturers do not publish information on
start time for MBCFLs. However, one-second start time has been the
ENERGY STAR specification for several years, and DOE finds that such a
start time is reasonable for MBCFLs. DOE requests information on start
times of the CFL market.
Further, DOE notes that it is the ENERY STAR specification for run-
up time rather than start-up time that requires the lamp to achieve 80
percent stabilized light output. The ENERGY STAR specification for
start time is the time it takes to maintain continuous illumination
from the time the lamp is turned on. While DOE understands the
distinction in these measurements and usefulness of the run-up time
measurement, DOE finds that both start time and run-up time are
capturing the consumer requirement of having a lamp provide light
output in a timely manner. Because start time is more noticeable by
consumers and an immediate indication of a low quality lamp, and to
limit undue burden to manufacturers, DOE is proposing to require only
start time for MBCFLs. Hence, in this NOPR, DOE is continuing to
propose a requirement for start time. However, instead of specifying at
full illumination, DOE's proposed requirement for start time is that
the lamp must remain continuously illuminated within one second of
application of electrical power.
d. Total Harmonic Distortion, Correlated Color Temperature, Operating
Frequency
In the preliminary analysis DOE did not consider setting
requirements for total harmonic distortion (THD), CCT, or operating
frequency.\61\ DOE determined that THD is directly related to power
factor and setting a minimum power factor requirement will effectively
set a standard for THD. DOE found that different CCTs are desirable
depending on the application. DOE determined that operating frequency
does not directly impact energy savings, cost effectiveness, or
consumer satisfaction. NEMA agreed that requirements for THD, CCT, and
operating frequency should not be considered. (NEMA, No. 34 at p. 8)
Receiving no other comments and finding no other evidence to support
standards for these factors, in this NOPR, DOE is not proposing
[[Page 14556]]
standards for THD, CCT, or operating frequency.
---------------------------------------------------------------------------
\61\ Id. at 3-18.
---------------------------------------------------------------------------
3. Additional Integrated LED Metric
EEAs asserted that DOE possesses the authority to require LED
performance specifications in order to provide the consumer
satisfaction necessary to assure that the energy savings anticipated
from standards are achieved in practice. Yet, because CEC is currently
evaluating its own performance quality metrics for LEDs, EEAs
recommended that DOE not consider adopting such requirements at this
time. (EEAs, No. 32 at pp. 8-9) CA IOUs encouraged DOE to continue
monitoring the progress underway in CEC's Title 20 rulemaking regarding
quality metrics for LED GSLs, and consider the resulting standards for
adoption. (CA IOUs, No. 33 at p. 10)
As noted in section IV.F.2.b, DOE finds that power factor does
impact energy use and, therefore, is also proposing a power factor
requirement for integrated LED lamps. DOE considered ENERGY STAR
requirements, industry standards, and characteristics of lamps in the
current market. The vast majority of the U.S. market reports power
factors greater than 0.7 for integrated LED lamps, which is consistent
with ENERGY STAR Specification for Lamps V1.1 and ANSI C82.77
requirement of a minimum power factor of 0.7 for these lamps. DOE notes
that the ENERGY STAR Specification for Lamps V2.0 \62\ finalized
December 2015 has adjusted the power factor requirement for general
purpose lamps between 5 and 10 watts to 0.6 and exempted lamps less
than 5 watts from a power factor requirement. In making this decision,
ENERGY STAR noted recent growing sales trends for lower cost LED lamps
with power factors below 0.7.\63\ DOE requests comment on its proposal
to require integrated LED lamps to meet a power factor of 0.7 or the
reason and supporting information for choosing another power factor.
---------------------------------------------------------------------------
\62\ ENERGY STAR. ENERGY STAR Program Requirements: Product
Specification for Lamps (Light Bulbs): Eligibility Criteria, Version
2.0. 2015. U.S. Environmental Protection Agency: Washington, DC
(Last accessed January 29, 2016). http://www.energystar.gov/sites/default/files/ENERGY%20STAR%20Lamps%20V2_0%20Program%20Requirements.pdf.
\63\ ENERGY STAR. ENERGY STAR Program Requirements: Product
Specification for Lamps (Light Bulbs): Eligibility Criteria, Version
2.0 DRAFT FINAL. 2015. U.S. Environmental Protection Agency:
Washington, DC. (Last accessed January 29, 2016.) Available at:
http://www.energystar.gov/sites/default/files/ENERGY%20STAR%20Lamps%20V2%200%20Draft%20Final%2012-04-2015.pdf.
---------------------------------------------------------------------------
4. Summary of Metrics
DOE is proposing to maintain the existing requirements for lumen
maintenance at 1,000 hours and lumen maintenance at 40 percent of
lifetime. DOE is proposing to increase the stringency of some existing
standards for MBCFLs, raising the required lifetime standard for MBCFLs
to a minimum of 10,000 hours, and the number of cycles required for
non-instant start lamps (i.e., lamps with start times greater than 100
ms) to once per every hour of rated life with a maximum of 15,000
cycles. Finally, DOE is proposing three new performance metrics for
MBCFLs; namely, requiring such lamps to have a CRI of 80 or greater, a
power factor of 0.5 or greater, and a start time of within one second
of the application of electrical power. NRDC agreed overall with the
updates to the CFL quality parameters. (NRDC, Public Meeting
Transcript, No. 29 at p. 13) CEC commented that additional standards
for lifetime, lumen maintenance, power factor, and spectral content
were needed because standards for efficacy without these quality
metrics are less meaningful in implementation. (CEC, No. 31 at p. 2)
DOE agrees with this assessment and provides the following table to
summarize the MBCFL performance metrics proposed in this rulemaking. In
addition, in this NOPR analysis, DOE is proposing that integrated LED
lamps be required to meet a power factor of 0.7 or greater, as shown in
Table IV-1. DOE requests any comments regarding proposed metrics for
GSLs in this NOPR analysis.
Table IV-1--Performance Metrics for Medium Base Compact Fluorescent
Lamps and Integrated LED Lamps
------------------------------------------------------------------------
Minimum standard
Lamp type Metric considered
------------------------------------------------------------------------
MBCFLs........................ Lumen maintenance 90 percent of initial
at 1,000 hours. lumen output at
1,000 hours.
Lumen maintenance 80 percent of initial
at 40 percent of lumen output at 40
lifetime .* percent of lifetime.
Rapid cycle MBCFL with start time
stress. > 100 ms: survive
one cycle per hour
of lifetime * or a
maximum of 15,000
cycles.
MBCFLs with a start
time of <= 100 ms:
survive one cycle
per every two hours
of lifetime.*
Lifetime *....... 10,000 hours.
Power factor..... 0.5.
CRI.............. 80.
Start time....... The time needed for a
MBCFL to remain
continuously
illuminated must be
within one second of
application of
electrical power.
Integrated LED Lamps.......... Power factor..... 0.7.
------------------------------------------------------------------------
* Lifetime refers to lifetime of a compact fluorescent lamp as defined
in 10 CFR 430.2.
V. Methodology and Discussion of Related Comments
This section addresses the analyses DOE has performed for this
rulemaking with regard to GSLs. Separate subsections address each
component of DOE's analyses.
DOE used several analytical tools to estimate the impact of the
standards proposed in this document. The first tool is a spreadsheet
that calculates the LCC savings and PBP of potential amended or new
energy conservation standards. The national impacts analysis uses a
second spreadsheet set that provides shipments forecasts and calculates
NES and NPV of total consumer costs and savings expected to result from
potential energy conservation standards. DOE uses the third spreadsheet
tool, the Government Regulatory Impact Model (GRIM), to assess
manufacturer impacts of potential standards. These three spreadsheet
tools are available on the DOE Web site for this rulemaking: http://
www1.eere.energy.gov/buildings/
[[Page 14557]]
appliance_standards/rulemaking.aspx?ruleid=83. Additionally, DOE used
output from the latest version of the Energy Information
Administration's (EIA's) Annual Energy Outlook (AEO), a widely known
energy forecast for the United States, for the emissions and utility
impact analyses.
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 GSLs. DOE is restricted by the Appropriations Rider from using
appropriated funds to implement or enforce standards for GSILs and
therefore is not considering GSILs in this rulemaking at this time. See
section IV.A for further details.
1. Product Classes
DOE divides covered products into classes by: (a) The type of
energy used; (b) the capacity of the product; or (c) other performance-
related features that justify different standard levels, considering
the consumer utility of the feature and other relevant factors. (42
U.S.C. 6295(q)) In evaluating product class setting factors, DOE
considers their impact on both efficacy and consumer utility. After
evaluating several GSL characteristics, in the preliminary analysis,
DOE considered ballast/driver location and lumen output as product
class setting factors, resulting in three product classes: (1) Non-
Integrated (i.e., ballast/driver location external to the lamp); (2)
Integrated Low-Lumen (i.e., ballast/driver location internal to the
lamp with light output from 310 to less than 2,000 lumens); and (3)
Integrated High-Lumen (i.e., lamps with light output from 2,000 to
2,600 lumens).\64\
---------------------------------------------------------------------------
\64\ Id. at 2-59.
---------------------------------------------------------------------------
DOE received some general comments regarding the product class
structure presented in the preliminary analysis. CA IOUs support DOE's
proposal to establish product classes based only on lumen output and
ballast/driver location. (CA IOUs, No. 33 at p. 4) NEMA, however,
disagreed with the preliminary analysis product class structure. NEMA
stated that product classes should be determined by technical
capability and varying utility of differing technological approaches to
produce the same light output. NEMA asserted that placing all GSLs in
common lumen ranges will result in the elimination of all technologies
and all product utilities except that provided by the most-efficacious
technology. Therefore determining product classes based only on lumen
output is not appropriate for GSLs. NEMA also stated it was not good
public policy to adopt a technology-neutral approach for GSLs under
EPCA, in particular for general service CFL and LED lamp segments
presently under consideration in this rulemaking, and for the halogen
incandescent, CFL, and LED lamp classes. (NEMA, No. 34 at p. 11)
NEMA proposed a product class structure that would set separate
product classes for standard incandescent/halogen lamps, modified
spectrum incandescent lamps, LED lamps, and CFLs, further sub-divided
by bare CFLs and covered CFLs. Further NEMA proposed five lumen package
product class divisions. (NEMA, No. 34 at p. 13) NEMA's proposed
product classes as well as comments on specific product class setting
factors are discussed in detail in the following sections.
a. Lamp Technology
In the preliminary analysis, DOE did not find unique performance
features in any lamp technology (i.e., CFLs or LED lamps) that
warranted separate product classes and therefore presented a
technology-neutral product class structure. Several stakeholders
supported DOE's decision not to set separate product classes for CFLs
and LED lamps.
CEC stated that DOE's approach recognizes the general purpose of
the lamps, focuses on achieving cost-effective energy savings, and
avoids substitution issues caused by product classes. (CEC, No. 31 at
pp. 1-2) EEAs noted that the product class structure recognizes that
many technologies provide general illumination and allows all
technologies to compete on a level playing field. (EEAs, No. 32 at p.
3) Earthjustice and CA IOUs agreed with DOE's decision noting that
neither CFLs nor LED lamps represent a distinct utility for the
consumer. (Earthjustice, No. 30 at p. 4; CA IOUs, No. 33 at p. 4) CA
IOUs however, recognized that CFLs play an important role in the market
as the current low-cost, high-efficacy option and they will continue to
monitor the progress of LED lamps as their prices continue to drop and
approach parity with CFLs. (CA IOUs, No. 33 at p. 4) While NRDC agreed
with DOE's technology-neutral approach to product classes, they
recommended that DOE continue to consider how LED lamps will evolve.
(NRDC, Public Meeting Transcript, No. 29 at p. 13, 100-101) Southern
Company stated that while there may not be enough differences to
justify a separate class, there were sufficient differences in
performance characteristics to warrant both CFLs and LED lamps on the
market and urged DOE to set criteria to allow for a broad range of
products to exist. (Southern Company, Public Meeting Transcript, No. 29
at p. 101)
In its product class determination, DOE does not factor in costs
and bases its assessment on performance characteristics that clearly
provide a crucial utility to consumers. 42 U.S.C. 6295(q). As noted in
the above stakeholder comments and confirmed by DOE's own analysis in
chapter 3 of the NOPR TSD, no such utility was identified that would
necessitate separate product classes for CFLs and LED lamps.
NEMA disagreed with the technology-neutral approach to product
classes and recommended three technology-based product classes with
separate efficacy levels to allow each technology to remain available:
Incandescent/halogen, CFL, and LED lamps, all of which have a medium
screw base and are designed to operate directly on 120 or 130 volts.
NEMA commented that the three technologies offer considerable
differences in performance and utility; and allow consumers to choose
the best technology for their application. In general, NEMA stated that
filament lamps are low-cost omnidirectional point sources, CFL lamps
are low-cost omnidirectional diffuse sources, and LED lamps are high
cost directional point sources. (NEMA, No. 34 at p. 13)
Specifically, NEMA noted several differences between CFLs and LED
lamps: LED lamps have a higher initial cost than CFLs; LED lamps have a
longer lifetime than CFLs which are also susceptible to a shortened
lifetime due to frequent switching; and LED lamps have very high
efficiency while CFLs have relatively high efficiency. Further, while
CFL operation is affected by high or low ambient temperature, LED lamp
operation is affected only by high ambient temperature. NEMA noted
CFLs' natural slow start as an advantage for dark area eye adaptation.
Additionally, NEMA noted CFLs are omnidirectional, have diffuse light,
low pleasing surface brightness while LED lamps are a directional point
source, have extremely high chip surface brightness, and require
special optics and diffusing materials for
[[Page 14558]]
omnidirectional applications. Another difference cited was that color
can be modified with some loss in efficiency at high chromaticity and
high CRIs for CFLs and low chromaticity and high CRIs for LED lamps.
(NEMA also noted several similarities between CFLs and LED lamps: Good
CRI capability, vibration resistant, unaffected by occasional direct
water spray, low heat source, and dimming with limitations.) (NEMA, No.
34 at pp. 12-13)
When determining product classes DOE does not factor in cost. (See
42 U.S.C. 6295(q)) DOE considers costs in determining the economic
justification of standard levels for each product class. DOE did not
find that the differences between CFLs and LED lamps noted by NEMA
identified a unique utility that required separate product classes for
each lamp type. LED lamp features of longer life, lack of issues due to
frequent switching, and ability to operate in low ambient temperature
would not be eliminated if LED lamps and CFLs were in one product
class, as LED lamps are more efficient than CFLs. Further, the slow
start in CFLs is usually considered a disadvantage and the potential
for it being useful in dark area eye adaptation seems a limited
application and of less value to the typical consumer compared to the
benefit of an instant on LED lamp.
Moreover, although CFLs and LED lamps may attain color with a
certain loss in efficiency at different ends of the chromaticity
spectrum, they are able to achieve the same ranges of CCTs and CRIs.
Likewise, while LEDs are a directional point source, with the use of
optics and diffusing materials, they are able to attain
omnidirectionality similar to that of CFLs. The surface brightness of
LEDs is also mitigated by optics and covers. Additionally, LED lamps
are designed and marketed for GSL applications and are being used as
replacements for CFLs. Therefore, the utilities valued by consumers
would not be eliminated in a technology-neutral product class
structure.
NEMA stated that the unusual market distribution further
illustrates the problems with putting all technologies together in the
same product classes. The candidate standard level (CSL) 1 becomes
mostly CFLs, while CSL 2 and CSL 3 represent older LED lamp
technologies that are still on the market because of the rapid LED lamp
product evolution. CSL 4 and 5 represent differing types of LED lamp
technology that could never be met by CFLs. (NEMA, No. 34 at p. 22) GE
added that there is a vast difference in technology between CFLs and
LED lamps, one is very mature and one is still in an evolving stage.
(GE, Public Meeting Transcript, No. 29 at p. 100) GE suggested two
separate classes for CFLs and LED lamps because they would have
different baselines and different efficiencies over time. GE further
noted that having CFLs and LED lamps in one product class implies that
CFLs will be eliminated and one criteria of this regulation is not to
eliminate an entire product class. (GE, Public Meeting Transcript, No.
29 at p. 72)
The observed distribution of lamp technologies at ELs is a function
of the general higher efficiency of LED technology relative to CFL
technology. However, a product class division must be based on both a
difference in efficacy and a unique consumer utility. Similarly, DOE
cannot create a separate product class based on the maturity of a
technology unless it results in a unique consumer utility. DOE
standards are also not structured to eliminate products. Based on DOE's
own evaluation, comments from stakeholders, and feedback in
manufacturer interviews, DOE did not find any unique features that
required separate product classes for lamp technologies (i.e., CFLs and
LED lamps).
Westinghouse warned that by not having two separate product classes
for CFLs and LED lamps, ensuring higher lumen products are available to
consumers would be challenging, particularly since the volume of CFLs
is in the lower lumen bins and the necessary economies of scale may no
longer exist from a manufacturing standpoint. (Westinghouse, Public
Meeting Transcript, No. 29 at pp. 73-74) In its product class
determination, DOE ensures that consumer utility is met by GSL products
across lumen ranges at all ELs (see section V.A.1.c). In this NOPR
analysis, DOE declines to establish a product class based on lamp
technology.
NEMA understood that DOE cannot currently address incandescent/
halogens, but commented that it should be recognized as a product class
within the general service lamp area which is currently regulated. NEMA
commented that the unique utility and attributes of incandescent or
halogen lamp technologies are: low initial cost, omnidirectional point
source with good optical control, ability to provide high sparkle and
high brightness, operation unaffected by high or low ambient
temperature, warm color appearance difficult to modify without loss of
efficiency, very high CRI, relative low efficiency, relative short
lifetime, adversely affected by vibration and direct water contact,
lifetime not affected by frequent switching, good infrared source,
immediate on to full brightness, great full range dimming in all
applications. (NEMA, No. 34 at p. 12) DOE is not considering
incandescent/halogen lamps in this rulemaking due to the Appropriations
Rider. See section IV.A for further details.
b. Lamp Component Location
In the preliminary analysis, DOE considered a product class based
on the location of the ballast or driver of the lamp: (1) Integrated
lamps in which the ballast or driver are enclosed within the lamp and
(2) non-integrated lamps in which the ballast or driver is an external,
replaceable component. DOE is also proposing definitions for
``integrated lamp'' and ``non-integrated lamp'' in this NOPR (see IV
for further details). NEMA commented that non-integrated pin base CFLs
should not be included in the scope of this rulemaking and, therefore,
should not be given a GSL product class. (NEMA, No. 34 at p. 11)
Non-integrated pin base CFLs are within the proposed scope of this
rulemaking, and DOE is establishing standards for these lamps (see
section IV.E.2). DOE determined that self-ballasted lamps may have
lower inherent efficacy compared to lamps that utilize external
ballasts due to the additional components and circuitry integrated into
a self-ballasted lamp. The use of a self-ballasted lamp can be
advantageous in that a consumer need only replace one lamp unit rather
than two separate components. Self-ballasted lamps are also generally
more compact and thus can be used in applications with size
constraints. For these reasons, as in the preliminary analysis, DOE
proposes establishing separate product classes based on ballast
location in this NOPR analysis. (See chapter 3 of the NOPR TSD for
further details.)
c. Lumen Package
In the preliminary analysis, DOE considered the product class
setting factor of lumen package within the integrated lamp product
classes. DOE determined that higher lumen output products cannot
achieve the same levels of efficacy as lower lumen output products and
considered the following product class divisions within the integrated
lamp product class: (1) Low Lumen (i.e., from 310 to less than 2,000
lumens) and (2) High Lumen (i.e., 2,000 to 2,600 lumens). DOE received
several comments supporting preliminary analysis' lumen package product
class division.
Earthjustice noted that following the EPCA provision for
establishment of product classes, DOE correctly concluded that lumen
output provides
[[Page 14559]]
the only basis for product class divisions among integrated lamps.
(Earthjustice, No. 30 at p. 4) EEAs also agreed with DOE's decision
noting that high-lumen lamps may require different technological
approaches to manage heat and maintain a form factor that fits consumer
fixtures making them less efficient than low-lumen lamps. (EEAs, No. 32
at p. 3) Noting that LED lamps are not currently widely available above
2,000 lumens, CA IOUs tentatively supported the distinction between
High-Lumen and Low-Lumen product classes. However, they noted one
product class for integral lamps would be sufficient if higher lumen
LED lamps become available. Additionally, CA IOUs stated that no
further lumen package product class divisions were necessary because
the sloped standards under consideration adequately address the
difference in efficacy achieved by products of different lumen outputs.
(CA IOUs, No. 33 at p. 4)
NEMA recommended that DOE consider more than two lumen package
divisions. NEMA commented that with all technologies, efficiency
decreases with decreasing wattage due to inescapable power losses from
components. GE and NEMA stated that there are four natural, lumen
ranges associated with wattage equivalencies as defined in existing
GSIL standards and commonly used by consumers (see 10 CFR
430.32(x(iii)(A)) These lumen ranges are as follows: 100 W = 1,490-
2,600 lumens, 75 W = 1,050-1,489 lumens, 60 W = 750-1,049 lumens, 40 W
= 310-749 lumens. NEMA suggested that DOE should establish product
classes based on these lumen ranges for each of its recommended lamp
technology product class divisions (i.e., incandescent/halogen,
modified spectrum halogen, bare CFL, covered CFL, LED lamps). Asserting
that the 100 W equivalent lumen bin was exaggerated at the higher end
\65\ and agreeing with DOE's proposal that the higher lumen range can
be limited to 2,000 lumens for current LED lamp technology, NEMA
proposed splitting the 1,490-2,600 lumen bin into 1,490-2,000 lumens
and 2,000-2,600 lumens product class divisions. NEMA asserted that
technical limitations and performance can vary greatly depending on the
wattage and technology and this approach would allow DOE to set a
lumens per watt number, wattage limit, a linear equation, a quadratic
equation or an exponential equation as necessary within the lumen range
and technology under consideration for each product class. (NEMA, No.
34 at p. 13; GE, Public Meeting Transcript, No. 29 at pp. 54-55)
---------------------------------------------------------------------------
\65\ NEMA noted that the 100 W and 40 W ranges are exaggerated
on the high end and the low end to extend the regulated product
range to just above 25 W and just below 150 W traditional
incandescent lamps.
---------------------------------------------------------------------------
NRDC stated that it was open to refining the 1,999 lumen upper
bound under consideration in the preliminary analysis but did not
support the four bin approach because it could result in gaming, and
consequently dimmer bulbs. Instead, they advocated the use of a smooth
continuous curve for the regulations. (NRDC, Public Meeting Transcript,
No. 29 at pp. 55-56)
DOE analyzed commercially available lamps and found that a
continuous equation best describes the relationship between efficacy
and lumens rather than lumen bins. Further, DOE assessed equations of
the ELs analyzed to ensure that consumer utility would be met by GSLs
across all lumen ranges. In doing so, in the preliminary analysis, DOE
determined that higher lumen output products cannot achieve the same
levels of efficacy as lower lumen output products, specifically LED
lamp replacements for incandescent lamps of wattages higher than 100 W.
Because DOE determined that higher lumen packages offer a consumer
utility, DOE considered a product class division based on lumen
package. Therefore, in this NOPR analysis, within the integrated lamp
product classes, DOE is continuing to propose separate product classes
for lumen outputs from 310 to less than 2,000 and from 2,000 to
2,600.\66\
---------------------------------------------------------------------------
\66\ The higher bound of 2,600 lumens aligns with the scope of
this rulemaking (see section [scope section on lumens]).
---------------------------------------------------------------------------
Hence, NEMA's proposal to establish product classes by lumen bins
per GSIL standards to allow for flexibility in setting the type of
standard is not necessary for preserving consumer utility and would
result in an inconsistent configuration of standards for products
covered under this rulemaking. Instead, DOE finds that its equation-
based approach to standards and product class division based on high
and low lumens, appropriately captures how GSL technologies are
achieving ELs across lumen ranges using a consistent methodology.
Southern Company warned that many CFLs in the range of 1500 lumens
will not fit in enclosed fixtures and unless LED lamps in this lumen
range improve, products will not be available on the market. Southern
Company recommended DOE consider a product class addressing physical
constraint for higher lumen products. (Southern Company, Public Meeting
Transcript, No. 29 at pp. 131-132) Westinghouse noted that even above
1600-1800 lumens, the physical size becomes a concern in terms of
fitting in fixtures, particularly for LED lamps, and expressed concern
that the 1,999 lumen upper bound might be too high. (Westinghouse,
Public Meeting Transcript, No. 29 at p. 54) NRDC responded that there
are 100 watt-equivalent LED lamps that offer 1,600 lumens and the form
factor is similar to the lower wattage, lower light output LED lamps,
which should address size constraints issues. (NRDC, Public Meeting
Transcript, No. 29 at pp. 55-56; 132-133)
DOE did ensure that an integrated LED lamp in the 1,500-1,600 lumen
range certified for enclosed fixtures met the highest ELs being
analyzed. Therefore, DOE does not find that an additional product class
related to lumen package is necessary.
d. Standby Mode
In the preliminary analysis, DOE evaluated setting a product class
based on the ability of a lamp to operate in standby mode.\67\ DOE
believes that standby mode operation offers a consumer utility because
these lamps have the ability to be remotely turned off, turned on,
dimmed, among other functionality. However, DOE assumed that the market
would shift to the lowest energy consuming method available, such as
Bluetooth, and the energy consumed in standby mode would be negligible.
Therefore, DOE did not consider standby mode functionality as a product
class setting factor. NEMA agreed that standby power for LED products
will be minimal compared to impacts of the classifications shown above
and would not require a separate class. (NEMA, No. 34 at p. 14)
---------------------------------------------------------------------------
\67\ GSL preliminary analysis at 2-58.
---------------------------------------------------------------------------
However, Westinghouse and the Northwest Energy Efficiency Alliance
(NEEA) commented that standby power consumption for smart lamps is not
zero. (Westinghouse, Public Meeting Transcript, No. 29 at pp. 239-240;
NEEA, Public Meeting Transcript, No. 29 at p. 244) Westinghouse stated
that smart lamps are similar to a fan remote control in that a switch
has to be left on in order for the lamps to receive a control signal
and this functionality consumes at least a minimal amount of power.
(Westinghouse, Public Meeting Transcript, No. 29 at pp. 239-240)
In the NOPR analysis, DOE conducted testing on commercially
available lamps with standby mode capability and determined that while
standby power
[[Page 14560]]
consumption can vary based on the standby technology used, it is not
negligible. DOE conducted active mode and standby mode testing per the
LED Test Procedure SNOPR \68\ of all lamps with standby mode
functionality found on the market. These lamps were designed with
varying communication methods, including Zigbee, Bluetooth, Wi-Fi, and
radio frequency remote controls. The majority of lamps identified also
operate using a central hub for communication between the end-user and
the lamp itself. DOE's test results, as presented in appendix 5A,
indicate that the tested standby power generally varied between 0.2 W
and 0.5 W. Specifically, the measured standby power was less than 0.5 W
for 29 out of 31 tests. DOE finds that these results indicate that
lamps with standby power have a non-negligible standby power
consumption that will likely lower their efficacy, compared to lamps
without standby power, all things being equal. Therefore, based on
utility and impact on efficacy DOE is proposing a product class
division based on standby mode.
---------------------------------------------------------------------------
\68\ 80 FR 39644 (July 9, 2015).
---------------------------------------------------------------------------
e. Covering
In the preliminary analysis, DOE evaluated lamp cover (i.e.,
something added to the lamp such that the main light source is not
distinguishable) as a product class setting factor.\69\ However, unable
to find a consistent correlation between the addition of a cover and
efficacy, DOE did not consider a product class division for lamps with
covers versus without covers. DOE received several comments regarding a
product class setting factor based on lamp cover.
---------------------------------------------------------------------------
\69\ GSL preliminary analysis at 2-54.
---------------------------------------------------------------------------
CA IOUs supported DOE's decision to include covered and bare lamps
in one product class because when considering the whole GSL product
category, there is no relationship to efficacy. While minor efficacy
reduction results from covering a CFL, CA IOUs pointed out that some of
the most efficient and most cost-effective products on the market are
LED lamps that have the ``covered'' appearance. (CA IOUs, No. 33 at p.
4) Earthjustice also noted that covered CFLs provide no distinct
utility because covered LED lamps are available to provide the same
aesthetic values at higher efficacies. (Earthjustice, No. 30 at p. 4)
Southern Company, however, stated that there are some functional
differences between covered and bare lamps such as aesthetics:
consumers will not use bare spiral lamps where they are visible.
Southern Company emphasized that this is not a trivial consideration
for consumers and recommended that separate product classes be set up
for bare and covered lamps. (Southern Company, Public Meeting
Transcript, No. 29 at pp. 108-110) Philips commented that one of the
biggest advantages for the covered CFL is that it eliminates concerns
about mercury because they are almost unbreakable, which is unique to
CFLs and creates a large market for them. (Philips, Public Meeting
Transcript, No. 29 at pp. 109-110)
NEMA recommended that DOE establish a product class for CFLs and
within it bare and covered product class divisions. NEMA asserted that
while covered CFLs have meaningfully lower efficiency they provide a
unique utility in contrast to bare lamps. NEMA also noted that the CSLs
proposed for CFL are not for two levels of performance of the same
product, but instead for different products. CSL 0 is for a lamp with a
cover, and CSL 1 is for bare spiral lamps. (NEMA, No. 34 at p. 12, 15)
Southern Company added that bare and covered product class divisions
would avoid the preliminary analysis results where CSL 1 is cheaper
than CSL 0. (Southern Company, Public Meeting Transcript, No. 29 at pp.
108-110)
As noted previously, DOE is not proposing a separate product class
for CFLs. In the preliminary analysis, DOE found that while a cover
generally decreased efficacy in CFLs, a cover in the form of phosphor
coating transforms light emitted from LEDs into visible light and
increases efficacy.\70\ Further many LED lamps that have covers also
have high efficacies. Therefore, when considering all lamp
technologies, a covering on a lamp does not have a consistent
correlation with efficacy and there are products with coverings
available at the highest levels of efficacy analyzed. For these
reasons, in this NOPR analysis, DOE is continuing to not propose a
product class for covered versus bare products. Regarding the
differences in representative CFLs for the baseline and CSL 1 of the
integrated lamp product classes presented in preliminary analysis, see
section V.C for further details.
---------------------------------------------------------------------------
\70\ Id.
---------------------------------------------------------------------------
f. Lamp Spectrum
In the preliminary analysis, DOE evaluated lamp spectrum (i.e.,
modified spectrum versus standard spectrum lamps) as a product class
setting factor.\71\ However, not finding a consistent correlation
between spectrum and efficacy in GSL products, DOE did not consider
spectrum as a product class setting factor. DOE received several
comments regarding spectrum as a potential product class division.
---------------------------------------------------------------------------
\71\ Id. at 2-57.
---------------------------------------------------------------------------
NEMA stated that a modified spectrum product class was not
necessary for CFLs and LED lamps. NRDC also agreed with not setting
product class based on modified spectrum. CA IOUs supported the
decision to remove the product class distinction for modified spectrum
lamp. CA IOUs continued that there is no relation between efficacy
potential and spectrum modification when considering the whole GSL
product class. (NEMA, No. 34 at p. 14; NRDC, Public Meeting Transcript,
No. 29 at p. 13; CA IOUs, No. 33 at p. 4) EEAs agreed with the
determination that a manufacturer can produce a modified spectrum lamp
without a decrease in efficacy and that a separate product class for
modified spectrum lamps GSLs is not warranted. (EEAs, No. 32 at p. 9)
Modified spectrum is achieved by increasing the contrast between
reds and greens in the spectral power distribution (SPD). Because
efficacy is impacted in different ways based on the method used to
achieve modified spectrum GSLs, DOE did not consider separate product
classes for standard and modified spectrum GSLs. Therefore, DOE
continues to not consider spectrum as a product class setting factor in
this NOPR analysis. DOE also notes that this rulemaking is not removing
any product classes based on spectrum applicable to existing standards.
EEAs stated that the current standards for modified spectrum GSILs
are 25 percent less efficient than non-modified spectrum GSILs (10 CFR
430.32(x)(iii)(B)) and are too generous. EEAs stated that shelf space
at big box retailers for modified spectrum GSILs can exceed that for
non-modified spectrum, indicating that producing modified spectrum
GSILs is the easiest way to comply with existing standards. EEAs
continued that while they did not have specific sales data, it was
likely that consumers that purchase modified spectrum GSILs receive
less light than the conventional incandescent lamp they meant to
replace, potentially causing consumers to shift to the 75 W equivalent
lamp, instead of the 60 W, to increase light levels, resulting in
increased energy consumption. (EEAs, No. 32 at pp. 9-10) DOE notes that
it is not considering incandescent/halogen lamps in this rulemaking due
to the Appropriations Rider. See section IV.A for further details.
[[Page 14561]]
g. Summary of Proposed Product Classes
In this NOPR analysis, DOE reevaluated the product class setting
factors considered in the preliminary analysis and also considered an
additional class setting factor. DOE is maintaining the product class
divisions presented in the preliminary analysis and adding standby mode
as product class setting factor. Table V-1 is a summary of the GSL
product classes proposed in this NOPR. DOE requests comments on the
proposed product classes.
Table V-1--Proposed GSL Product Classes
------------------------------------------------------------------------
Initial lumen Standby mode/No
Lamp type output standby mode
------------------------------------------------------------------------
Integrated GSLs (e.g., Self..... 310 <= Initial No Standby Mode.
Ballasted CFL, Integrated....... Lumen Output < Capable Of
LED lamp)....................... 2,000. Operating In
Standby Mode.
2,000 <= Initial Lumen Output <= No Standby Mode...
2,600. Capable Of
Operating In
Standby Mode..
Non-Integrated GSLs (e.g.,...... 310 <= Initial ..................
Externally Ballasted CFL)....... Lumen Output <=
2,600.
------------------------------------------------------------------------
2. Technology Options
In the technology assessment, DOE identifies technology options
that are feasible means of improving lamp efficacy. This assessment
provides the technical background and structure on which DOE bases its
screening and engineering analyses. To develop a list of technology
options, DOE reviewed manufacturer catalogs, recent trade publications
and technical journals, and consulted with technical experts.
In the preliminary analysis, DOE identified several technology
options that can improve the efficacy of GSLs.\72\ Recognizing that
GSLs comprise multiple lamp types, each with their own mechanisms for
improving efficacy, DOE identified technology options by lamp type.
Specifically, DOE presented technology options for CFL and LED lamp
types and also identified a change in technology (e.g., moving from
CFLs to LED lamps) as a technology option. DOE received several
comments on these options, as discussed in the following sections.
---------------------------------------------------------------------------
\72\ Id. at 3-45.
---------------------------------------------------------------------------
a. CFL Technology Options From the Preliminary Analysis
Stakeholders provided general comments regarding CFL technology.
NEMA commented that the apparent differences in CFL efficacies are
likely the result of differing manufacturing processes employed by
individual manufacturers, rather than of superior design. (NEMA, No. 34
at p. 10) DOE has observed CFL efficacies of lamps with similar
characteristics (e.g. CCT, CRI, shape) ranging from 57.1 lm/W to 69.2
lm/W, a difference that is likely not explainable by improved
manufacturing processes alone. Further, numerous CFL products are
offered at one particular efficacy from several manufacturers. DOE
therefore finds that the different levels of CFL efficacies are not
just the result of differences in how the lamps are manufactured.
GE and NEMA stated that many of the technology options listed have
already been used over the years to optimize CFL efficacy and such
technology is no longer able to make large improvements. (GE, Public
Meeting Transcript, No. 29 at p. 59; NEMA, No. 34 at p. 9)
Specifically, NEMA commented that while improvements have been made in
glass coatings, a technological breakthrough would be needed to capture
further efficacy gains with this option and there are no actions
underway that would result in major improvements. Regarding electrode
coatings, NEMA noted that their overall performance is already designed
for energy conservation and long life, stating that further changes may
shorten lamp lifetime. Additionally, potential improvements to this
technology would be minimal. For higher efficiency phosphors, NEMA
stated that because of rare earth oxide availability and cost issues,
all coating resources are being used to reduce losses and optimize
current technology performance, and current high efficiency phosphor
technology is limited until a technological break-through occurs, which
is unlikely. NEMA also stated that manufacturers have already reached
the limits of gas fill technology.
In the preliminary analysis, DOE considered glass coatings, highly
emissive electrode coatings, and higher efficiency phosphors as
technology options for CFLs. As NEMA notes, these are mechanisms for
improving lamp efficacy. Based on DOE's research of manufacturer
catalogs, recent trade publications, and technical journals, and
through discussions with technical experts, DOE concludes that there
are various combinations of highly emissive electrode coatings; weights
and mixes of phosphors; types and ratios of fill gases; and glass
coatings that can be used in CFLs. Because of the range in efficacy
levels for CFLs on the market, the less efficacious CFLs must not be
using the optimal forms and/or combinations of these mechanisms.
Additionally, DOE does not incorporate cost in the technology
assessment. DOE considers costs in determining the economic
justification of any standard levels developed using these
technologies. Therefore, DOE proposes these technologies as means of
improving the efficacy of current product offerings of CFLs in this
NOPR analysis.
NEMA also commented that the effectiveness of any cold spot design
is limited by the ambient temperature of a lamp in operation as the
cold spot temperature can never be lower than adjacent ambient
temperature, which limits the potential light output gains through cold
spot optimization. (NEMA, No. 34 at p. 9)
In the preliminary analysis, DOE identified cold spot optimization
as a technology option for improving CFL efficacy. The ``cold spot'' is
the lowest temperature on the CFL where the vaporized mercury
condenses. The cold spot is a function of current density, and light
output increases with current density until it reaches a certain
saturation point. Therefore, lamp efficacy can be increased at the
optimal cold spot temperature. In a study of commercially available T2
and T3 CFLs, researchers found that light output reaches a maximum at
about 48 [deg]C for
[[Page 14562]]
lamps with a fixed current of 140 mA.\73\ According to the OSRAM Web
site, the cold spot for fluorescent lamps should be designed to reach
temperatures between 45 [deg]C and 50 [deg]C at 100 percent luminous
flux.\74\ These optimal cold spot temperatures could be achieved for a
range of ambient temperatures. DOE understands that it may be difficult
to achieve the most optimal cold spot temperature at very high ambient
temperature environments, but these situations would be limited and
some gains could still be possible with the level of cold spot
optimization that is achievable. Therefore, DOE continues to consider
cold spot optimization as a means for improving lamp efficacy and
proposes it as a technology option in this NOPR analysis.
---------------------------------------------------------------------------
\73\ Feng, Xiangfen and Yang, Hu. Design Principle Study of High
Efficiency Compact Fluorescent Lamps. LEUKOS VOL 8 NO 4. (April
2012): 301-311.
\74\ Osram Sylvania. Cold Spot technology: Condensation point in
the discharge tube. 2015. (Last accessed July 14, 2015.) http://www.osram.com/osram_com/news-and-knowledge/fluorescent-lamps/professional-knowledge/cold-spot-technology/index.jsp.
---------------------------------------------------------------------------
Regarding ballast components, NEMA agreed that the use of higher
grade components could slightly reduce energy loss and that cost impact
must be evaluated in determining requirements. However, NEMA stated
that they are unaware of any emerging technology that promises to lower
ballast losses while maintaining the performance of current premium
ballast designs. (NEMA, No. 34 at p. 10)
In the preliminary analysis, DOE identified improvement in quality
of electronic ballast components used in integrated CFLs and improved
ballast circuit designs as means of improving the efficacy factor of
the ballast, and thereby overall lamp efficacy.\75\ Regarding the cost
of improved ballast components, as noted previously, DOE does not
factor in cost when assessing viability of technology options, but
instead analyzes cost when determining the economic justification of
using viable technologies. Regarding circuit designs, DOE identified
advanced designs, such as cathode cut-out technology, integrated
circuits, improved starting method, and synchronous rectification that
could increase ballast efficiency. Because there are different levels
of ballast efficiencies for integrated CFLs, DOE finds that circuit
designs and/or features of varying efficiencies must be in use.
Therefore, DOE continues to consider ballast designs as a means from
improving efficacy and considers it as a technology option in this NOPR
analysis.
---------------------------------------------------------------------------
\75\ GSL preliminary anaylsis at 3-52.
---------------------------------------------------------------------------
NEMA disagreed with active cooling as a technology option and
commented that active cooling approaches for CFLs have been studied,
but are absolutely cost prohibitive, and may lower efficacy due to the
power needs of the active cooling system. (NEMA, No. 34 at p. 9) DOE
did not identify active cooling as a technology option to improve CFL
efficacy in the preliminary analysis. DOE did consider active thermal
managements systems for enhancing LED lamp efficacy which is discussed
in section V.A.2.b.
Additionally, NEMA stated that manufacturers are already producing
lamps with ideal diameters for maximum efficiency. (NEMA, No. 34 at p.
9) DOE notes it did not consider higher efficiency diameters as a means
for improving CFL technology in the preliminary analysis.
b. LED Lamp Technology Options From the Preliminary Analysis
Stakeholders had some general comments on LED lamp technology. GE
noted that LED lamps are a newer technology and therefore more likely
to have continued efficacy advancements than CFLs. (GE, Public Meeting
Transcript, No. 29 at p. 59) NEEA observed that an energy conservation
standard promulgated by this rulemaking would not require compliance
until 2020. As even the technology options under consideration that are
in early stages of development are being commercialized at a fast pace,
DOE will likely have more information on them before the final rule
stage of this rulemaking. NEEA encouraged DOE to take into account all
new information that emerges between the preliminary analysis and the
NOPR. (NEEA, Public Meeting Transcript, No. 29 at pp. 60-61)
As part of the NOPR analysis, DOE does a thorough assessment of the
technology options relevant to this rulemaking. In the NOPR analysis,
DOE provides updates on the progress in research and development for
the technologies identified in the preliminary analysis, as well as
identifying any new technology options that may have emerged. DOE
received several specific comments on technology options identified for
increasing LED lamp efficacy in the preliminary analysis that are
discussed below.
Efficient Down Converters
NEMA commented that efficient down converters are not in use today
due to technical challenges surrounding narrow-band phosphors that
enable high spectral efficiency, including robust packaging for lumen
maintenance while achieving high quantum efficiency under high
temperature and flux. (NEMA, No. 34 at p. 10) CA IOUs, however,
supported the inclusion of quantum dot and phosphor emitter materials
as technology options in the preliminary analysis. (CA IOUs, Public
Meeting Transcript, No. 29 at p. 62)
In the preliminary analysis, DOE presented efficient down
converters as a technology option that uses high-efficiency wavelength
conversion materials to convert narrow band monochromatic light emitted
by LED lamps into white light.\76\ Feedback from manufacturer
interviews indicated that manufacturers are continually trying to
improve down conversion methods. One method is using phosphor, which
involves incorporating the phosphor in the body of a blue LED, causing
some of the blue light to be converted into yellow light and the
remaining blue light to be mixed with the yellow light, resulting in
white light. The vast majority of white LED lamps currently used in SSL
applications employ the phosphor-conversion approach.\77\ The
performance of phosphor conversion can be increased by using improved
phosphor material. DOE acknowledges that current phosphors have high
quantum yields, but show wide emission spectra and saturation effects
at high temperatures and high flux.\78\ DOE has found there are
research efforts and existing patents on optimized phosphor coating for
LED lamps. DOE is funding a project that intends to increase the
thermal conductivity of the encapsulant, resulting in lower temperature
of phosphor particles by as much as 50 [deg]C and raising the effective
quantum efficiency (QE) to 95 percent for the phosphors at 150 [deg]C
at 35 A/cm\2\ in white-light-emitting SSL sources.\79\ Further, DOE is
also aware of ongoing research regarding the use of quantum dots as a
down conversion method. (See chapter 3 of the NOPR TSD for further
details.) Therefore, based on the use of this technology in GSL
products and the indication of continued research and development to
resolve existing issues and further improve efficacy, DOE continues to
consider efficient down
[[Page 14563]]
converters as a viable means of increasing LED lamp efficacy and
proposes it as a technology option in this NOPR analysis.
---------------------------------------------------------------------------
\76\ Id. at 3-53.
\77\ U.S. Department of Energy. 2015 Solid-State Lighting R&D
Plan. May 2015. (Last accessed July 14, 2015.) http://energy.gov/sites/prod/files/2015/06/f22/ssl_rd-plan_may2015_0.pdf.
\78\ Ibid.
\79\ U.S. Department of Energy. 2015 Project Portfolio: Solid-
State Lighting. January 2015. (Last accessed July 14, 2015.) http://energy.gov/sites/prod/files/2015/01/f19/2015_ssl-project-portfolio.pdf.
---------------------------------------------------------------------------
Improved Package Architectures
NEMA noted reliable die attachment methods are needed to enable
high temperature operation for improved package architectures. NEMA
also commented that there is a need for polymer optical encapsulants to
improve color stability and emitter lifetime, and high thermal
conductivity to reduce down-converting layer temperatures. Further,
NEMA specified that another challenge is the development of high index
encapsulants to increase photon extraction. The barriers to improvement
differ depending on the architecture approach; NEMA gave the example of
mixed color solutions requiring additional controls that would increase
the cost of the total package. (NEMA, No. 34 at p. 10)
In the preliminary analysis, DOE presented improved package
architecture as a technology option, noting examples of architecture
enhancements such as RGB+, hybrid color, and bonding the chip directly
on to the heat sink.\80\ DOE is aware that die attachment and
encapsulation are being continually improved. The challenge with die
attachment is that defects can occur in the die if the bonding material
requires high temperature. However, there is research regarding bonding
materials that can be used at lower temperatures. For example, there is
a patent on using a conductive paste as bonding method to allow bonding
to occur at a lower temperature.\81\ Further, in June 2015, Dow Corning
was issued a patent by the Korean Intellectual Property Office (KIPO)
for its new LED Optical Silicone Encapsulant Technology, which
potentially offers improved light output, improved mechanical
protection, and can act as a gas barrier to enhance component
reliability.\82\ Regarding color mixing, Cree's TrueWhite Technology,
which mixes the light from red and unsaturated yellow LEDs to create
white light, preserves high color consistency over the life of the
product.\83\ With respect to cost, as noted earlier, the technology
option analysis examines mechanisms that increase efficacy, regardless
of cost. Therefore, given that package architectures are continually
being improved in GSL products and issues related to further advancing
this technology are under research and development, DOE is proposing
improved package architecture as a viable means of improving LED lamp
efficacy in this NOPR analysis.
---------------------------------------------------------------------------
\80\ GSL preliminary analysis at 3-54.
\81\ Miyairi, M., Ogashiwa, T., and Shioya, A. (2015) U.S.
Patent No. 2,833,393. Washington, D.C: U.S. Patent and Trademark
Office.
\82\ Wright, Maury. LED business news: Dow Corning IP, new
funding, and Eaton management. June 2015. (Last accessed July 14,
2015.) http://www.ledsmagazine.com/articles/2015/06/led-business-news-dow-corning-ip-new-funding-and-eaton-management.html.
\83\ Cree. FAQs about Cree LED Components. 2015. (Last accessed
July 14, 2015.) http://www.cree.com/led-components-and-modules/tools-and-support/faqs.
---------------------------------------------------------------------------
Alternative Substrate Materials
NEMA stated that the cost of gallium nitride (GaN) substrates is
high for LEDs. Further NEMA stated the performance of Si and GaN-on-Si-
based devices is not significantly better than sapphire-based devices
and would not warrant a transition to these substrates. (NEMA, No. 34
at p. 10)
In the preliminary analysis DOE presented alternative substrates as
a technology option noting certain alternatives to the most commonly
used, sapphire substrate material.\84\ A greater lattice match between
the substrate material and the GaN LED material reduces the likelihood
of defects and increases lumen efficacy of the LED. The lattice
mismatch of sapphire (16 percent) and silicon (18 percent) are
comparable and high. However, the lattice mismatch of silicon carbide
(SiC) is 3.5 percent and for GaN is zero.\85\ Therefore, DOE agrees
that while the use of silicon may not result in better performance
compared to sapphire, there are alternative substrates such as SiC and
GaN that can enhance the efficacy of LED lamps. Soraa manufactures
lamps using GaN on GaN LEDs and recently announced a new LED package
reaching 75 percent wall-plug-efficiency.\86\ Regarding the cost of GaN
material, DOE notes that it does not take cost into consideration when
identifying technology options and considers costs in determining the
economic justification of any standard levels developed using these
technologies. Hence, DOE continues to consider use of alternative
substrates as a technology option to improve LED lamp efficacy.
---------------------------------------------------------------------------
\84\ GSL preliminary analysis at 3-58.
\85\ Solid State Technology. Beyond sapphire: LED substrates
from GaN to ZnO, SiC, and Si. May 14, 2012. (Last accessed July 14,
2015.) http://electroiq.com/blog/2012/05/beyond-sapphire-led-substrates-gan-zno-sic-si/.
\86\ Soraa. Soraa develops the world's most efficient LED;
begins integration into large lamp line. February 24, 2014. (Last
Accessed July 14, 2015.) http://www.soraa.com/news/soraa-large-lamp-gen3-022414.
---------------------------------------------------------------------------
Improved Thermal Interface Materials (TIMs)
NEMA stated that challenges to using improved TIMs include
developing TIMs that enable high efficiency thermal transfer for long-
term reliability and performance optimization of the LED device and
overall lamp product. (NEMA, No. 34 at p. 10)
In the preliminary analysis, DOE presented improved TIMs as a
technology option that allows for higher efficiency thermal transfer,
which can improve LED efficacy by lowering LED junction
temperature.\87\ There are also research efforts targeting reliable
high efficiency thermal transfer materials such as chemical vapor
deposition (CVD) diamond, which provides high thermal conductivity,
while allowing for standard methods of attachment (e.g., solders and
epoxies).\88\ Companies such as Electrolube are focusing on reduced
viscosity compounds with higher bulk thermal conductivities to produce
TIMs that maximize efficiency in heat dissipation by minimizing thermal
resistance.\89\ Indium Corporation introduced a Heat-Spring, which is a
metal thermal interface material that provides high thermal
conductivity and is designed not to bake out or pump out, optimizing
long-term performance consistency.\90\ Therefore, there is continued
development of higher efficiency and longer reliability TIMs. Further,
in manufacturer interviews, several manufacturers noted that TIMs are a
mechanism used to improve lamp efficacy. Therefore, DOE is continuing
to consider improved TIMs as a viable means for increasing LED lamp
efficacy.
---------------------------------------------------------------------------
\87\ RPI. Junction temperature in light-emitting diodes assessed
by different methods. (Last accessed June 14, 2015.) http://
www.ecse.rpiscrews.us/~schubert/Reprints/
2005%20Chhajed%20et%20al%20%28SPIE%20Photonics%20West%29%20Junction%2
0temperature%20in%20LEDs.pdf
\88\ Aidala, Dwain A. CVD Diamond Solves Thermal Challenges.
Solid State Technology. (Last accessed July 14, 2015.) http://electroiq.com/blog/2006/10/cvd-diamond-solves-thermal-challenges/.
\89\ Electrolube. Thermal Management of LEDs: Looking Beyond
Thermal Conductivity Values. 2015. (Last accessed July 14, 2015.)
http://www.electrolube.com/technical-articles/thermal-management-of-leds-looking-beyond-thermal-conductivity-values/.
\90\ Indium Corporations. Indium Corporation Features Heat-
Spring for LED Manufacturing at Strategies in Light. January 8,
2015. (Last accessed on July 14, 2015). http://www.indium.com/people/marketing-communications/news-releases/heat-spring-for-led-manufacturing-at-strategies-in-light.
---------------------------------------------------------------------------
Optimized Heat Sink Design
NEMA observed that the performance of the heat sink is generally
compromised by material cost and geometrical constraints. (NEMA, No. 34
at p. 10)
[[Page 14564]]
In the preliminary analysis, DOE presented optimized heat sinks as
a technology option that improves thermal conductivity and heat
dissipation, lowering the temperature at the LED junction and
increasing lamp efficacy.\91\ DOE determined that geometrical
constraints can be addressed in optimized heat sink designs. For
example, finned designs made out of materials with high thermal
transfer coefficients have been utilized in commercially available A-
shape lamps. Further, there are existing patents on optimized heat
sinks for LED lamps indicating this is an area of ongoing research. GE
developed a heat sink that includes a reflective layer over the heat
sink body with a reflectivity greater than 90 percent for light in the
visible spectrum. Further is a light transmissive protective layer over
the reflective layer that can sufficiently reflect visible and infrared
light impinging on the surface of the heat sink, and still transmit
heat from the LED lamp to the ambient environment with greater
efficacy.\92\ Therefore, DOE finds that geometrical constraints can be
overcome to improve heat sink designs, and DOE is continuing to
consider optimized heat sinks as a technology option that can increase
the efficacy of LED lamps in this NOPR analysis.
---------------------------------------------------------------------------
\91\ GSL preliminary analysis at 3-59.
\92\ Allen, Gary and Chowdhury, Ashfaqul. GELighting Solutions,
LLC. (2014) U.S. Patent No. 8,672,516. Washington DC: U.S. Patent
and Trademark Office.
---------------------------------------------------------------------------
Active Thermal Management Systems
Regarding active thermal management systems, NEMA commented that
reliability and cost are major concerns. (NEMA, No. 34 at p. 10)
In the preliminary analysis, DOE considered active thermal
management systems, which are specifically designed to provide cooling
to LED components, decreasing the LED junction temperature.\93\ Some
active thermal management systems take the form of integral fans or
vibrating membranes, increasing convection. Additionally, as active
thermal management systems are being used in commercially available
lamps, such as Philips MASTER LEDspot MR16s, DOE believes reliability
concerns can be addressed by manufacturers.\94\ Hence, DOE continues to
consider active thermal management systems as a technology options that
can increase the efficacy of LED lamps.
---------------------------------------------------------------------------
\93\ GSL preliminary analysis at 3-59.
\94\ Philips. MASTER LEDspot LV--The ideal solution for spot
lighting. July 3, 2015. (Last Accessed July 14, 2015.) http://download.p4c.philips.com/l4bt/3/322779/master_ledspot_lv_322779_ffs_aen.pdf.
---------------------------------------------------------------------------
Improved Driver Design
In terms of improved driver design, NEMA commented that in addition
to efficacy, drivers must meet many specifications (such as cost, power
quality, flicker, dimmability, isolation, line regulation, and
transient protection) and optimizing for specific applications often
leads to a compromise in efficacy. (NEMA, No. 34 at p. 11)
In the preliminary analysis, DOE considered improved driver design
as a mechanism for increasing overall lamp efficacy.\95\ Manufacturer
feedback during interviews and DOE's review of catalogs indicate a
range of efficiencies associated with drivers. The existence of this
range, coupled with historical increases in driver efficiency in
commercially available lamps, demonstrates the potential for
improvement in driver design, while meeting the functional
specifications of the product. Therefore, DOE continues to consider an
improved driver design as a technology option for improving LED lamp
efficacy.
---------------------------------------------------------------------------
\95\ GSL preliminary analysis at 3-60.
---------------------------------------------------------------------------
Reduced Current Density
NEMA stated that current density is only one aspect in the design
of an efficient LED die and there are many trade-offs that take place
to ensure higher efficacy. Further NEMA asserted that optimization of
current density could result in lower overall efficacy. (NEMA, No. 34
at p. 11)
In the preliminary analysis, DOE presented reduced current density
as a technology option for improving LED lamp efficacy.\96\ DOE notes
that increasing current results in a commensurate decrease in LED
efficacy. This decrease in efficacy at higher currents is referred to
as ``efficacy droop'' and is discussed in further detail in chapter 3
of the NOPR TSD. DOE's research shows that reducing current density
within the appropriate package architecture will increase LED lamp
efficacy while maintaining practical levels of lumen output per unit
area. (See chapter 3 of the NOPR TSD for more information.) For
example, chip-on-board (COB) is an LED packaging technology with very
compact arrays of LEDs, allowing for greater light intensity and
uniformity per unit area.\97\ This technology uses many low-powered
chips rather than a few high-powered chips to produce the desired lumen
output, but at a higher lamp efficacy because the chips can be run at
low current. New filament-style LED lamps use strands of as many as 36
low-powered LEDs running at low current (i.e., approximately 15 mA)
connected in series, encapsulated on glass or sapphire substrates, and
coated in a phosphor resin. Lamps using these filament strands are
currently some of the most efficacious on the market according to
manufacturer catalogs.\98\ A known issue with lower current density is
that the each LED die produces fewer lumens. Methods of compact die
arrays that allow for more dies per unit area mitigate this issue.
Therefore, DOE finds that manufacturers are utilizing reduced current
density to increase LED lamp efficacy and continues to consider it as a
technology option in this NOPR analysis.
---------------------------------------------------------------------------
\96\ Id. at 3-61.
\97\ Pro Photonix. Chip-on-Board LED Technology. 2015. (Last
accessed July 14, 2015.) http://www.prophotonix.com/resources/Technical-Overviews/about-chip-on-board.aspx.
\98\ Tevaja Lighting. FiLED, Filament LED Bulbs, visual effects
of incandescents. 2015. (Last accessed July 14, 2015.) http://www.tevaja.com/?page_id=11.
---------------------------------------------------------------------------
Device Level Optics
Regarding the use of device level optics, NEMA commented that
package size limits the extent of beam-shaping that can be done with
reasonable extraction efficacy and that it may not be desirable to
integrate application-specific functions at a low system level for
complexity management reasons. (NEMA, No. 34 at p. 11)
In the preliminary analysis, DOE presented device level optics as a
technology option that involves optimizing optics at the chip level or
the primary optic, so that the outer secondary optic can be removed,
thereby eliminating losses due to absorption.\99\ A primary optic is
integrated into the LED package and optimizes light extraction using
mechanisms such as reflective structure coatings and integrated lenses.
DOE found that there are research efforts addressing issues of
optimizing extraction efficiency for small package sizes, as well as
improving beam shaping. An existing patent presents 27 different
primary optic configurations that achieve more controlled beam shapes
while allowing for a more simplified and efficient secondary
optic.\100\ Another patent discusses LED packages with enhanced mirror
reflectivity that improve the overall emissions of the chip by stopping
light absorption by the multiple chip layers.\101\ Therefore, DOE
considers
[[Page 14565]]
optics as a viable means of increasing LED lamp efficacy in this NOPR
analysis.
---------------------------------------------------------------------------
\99\ GSL preliminary analysis at 3-60.
\100\ Tars, E., Kellerm, B., Guschl, P., and Negley, G. (2011)
U.S. Patent No. 8,564,004. Washington DC: U.S. Patent and Trademark
Office.
\101\ Bergmann, M. et al. and Cree. (2014) U.S. Patent No.
8,686,429. Washington DC: U.S. Patent and Trademark Office.
---------------------------------------------------------------------------
Further DOE determined that the main mechanism for increasing lamp
efficacy through ``device level optics'' is through improvement in
primary optics. Therefore, in this NOPR analysis, in order to clearly
define this technology option, DOE is proposing to rename ``device
level optics'' as ``improved primary optics.'' DOE is also refining the
description of the technology option as enhancements to the primary
optic of the LED package such as surface etching that would optimize
extraction of usable light from the LED package and reduce losses due
to light absorption at interfaces. DOE requests comment on its proposed
renaming of ``device level optics'' to ``improved primary optics'' and
refined description of this technology option. For further details of
this technology option see chapter 3 of the NOPR TSD.
Increased Light Utilization
Regarding the increased light utilization technology option, NEMA
commented that there is a trade-off between increased light utilization
and system level cost. (NEMA, No. 34 at p. 11) In the preliminary
analysis, DOE considered increased light utilization as a means for
reducing optical losses from housing, diffusion, beam shaping, and
color-mixing through mechanisms such as highly reflective coatings
inside the lamp, thereby increasing overall luminaire efficacy. DOE
does not take cost into consideration when identifying technology
options. DOE considers costs in determining the economic justification
of any standard levels developed using these technologies.
Further, in the NOPR analysis, DOE determined that the term
``increased light utilization'' can encompass many mechanisms for
improving lamp efficacy including use of improved primary optics,
improved package architecture, etc. However, the intent of this
technology option is to specifically describe how reduction in optical
losses is achieved through secondary optics such as diffuse coatings on
the lamp. Therefore, in this NOPR analysis, in order to clearly define
this technology option, DOE is proposing to replace the term
``increased light utilization'' with ``improved secondary optics.''
Further DOE is refining the description of the technology option as the
reduction or elimination of optical losses from the lamp housing,
diffusion, beam shaping, and other secondary optics to increase
efficacy, using mechanisms such as reflective coatings and improved
diffusive coatings. Additionally, DOE finds that because increased lamp
efficacy through increased light utilization is a general phenomenon,
covered in many proposed technology options, it does not need to be
proposed as specific mechanism for achieving LED lamp efficacy. DOE
requests comment on its proposal to replace the term ``increased light
utilization'' with ``improved secondary optics'' and the refined
definition of this technology option. For further details of this
technology option see chapter 3 of the NOPR TSD.
c. Summary
In summary, after conducting an update of relevant publications and
feedback in manufacturer interviews, DOE is proposing the technology
options as shown in Table V-2. For further information on all
technology options considered in this NOPR, see chapter 3 of the NOPR
TSD. DOE requests comments on the proposed technology options.
Table V-2--GSL Technology Options
------------------------------------------------------------------------
Name of technology
Lamp type option Description
------------------------------------------------------------------------
CFL.................. Highly Emissive Improved electrode
Electrode Coatings. coatings allow electrons
to be more easily removed
from electrodes, reducing
lamp power and increasing
overall efficacy.
Higher Efficiency Fill gas compositions
Lamp Fill Gas improve cathode
Composition. thermionic emission or
increase mobility of ions
and electrons in the lamp
plasma.
Higher Efficiency Techniques to increase the
Phosphors. conversion of ultraviolet
(UV) 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.
Multi-Photon Emitting more than one
Phosphors. visible photon for each
incident UV photon.
Cold Spot Improve cold spot design
Optimization. to maintain optimal
temperature and improve
light output.
Improved Ballast Use of higher grade
Components. components to improve
efficiency of integrated
ballasts.
Improved Ballast Better circuit design to
Circuit Design. improve efficiency of
integrated ballasts.
Change in Technology. Replace CFL with LED
technology.
LED.................. Efficient Down New high-efficiency
Converters. wavelength conversion
materials, including
optimized phosphor
conversion, quantum dots,
have the potential for
creating warm-white LEDs
with improved spectral
efficiency, high color
quality, and improved
thermal stability.
Improved Package Novel package
Architectures. architectures such as
color mixing (RGB+) and
hybrid architecture to
improve package efficacy.
Improved Emitter The development of
Materials. efficient red, green, or
amber LED emitters, will
allow for optimization of
spectral efficiency with
high color quality over a
range of CCT and which
also exhibit color and
efficiency stability with
respect to operating
temperature.
Alternative Substrate Alternative substrates
Materials. such as gallium nitride
(GaN), silicon carbide
(Si-C) to enable high-
quality epitaxy for
improved device quality
and efficacy.
Improved Thermal TIMs that enable high
Interface Materials. efficiency thermal
transfer for long-term
reliability and
performance optimization
of the LED device.
Optimized Heat Sink Improve thermal
Design. conductivity and heat
dissipation from the LED
chip thus reducing
efficacy loss from rises
in junction temperature.
Active Thermal Devices such as internal
Management Systems. fans and vibrating
membranes to improve
thermal dissipation from
the LED chip.
Improved Primary Enhancements to the
Optics. primary optic of the LED
package such as surface
etching that would
optimize extraction of
usable light from the LED
package and reduce losses
due to light absorption
at interfaces.
Improved Secondary Reduce or eliminate
Optics. optical losses from the
lamp housing, diffusion,
beam shaping, and other
secondary optics to
increase efficacy using
mechanisms such as
reflective coatings and
improved diffusive
coatings.
Improved Driver Increase driver efficiency
Design. through novel and
intelligent circuit
design.
[[Page 14566]]
AC LEDs.............. Eliminate the requirements
of a driver and therefore
reduce efficiency losses
from the driver.
Reduced Current Driving LED chips at lower
Density. currents while
maintaining light output,
and thereby reducing the
efficiency losses
associated with efficacy
droop.
------------------------------------------------------------------------
B. Screening Analysis
After DOE identifies the technologies that improve the efficacy of
GSLs, 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)):
1. Technological feasibility. DOE will consider technologies
incorporated in commercially available products or in working
prototypes to be technologically feasible.
2. 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.
3. 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.
4. 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 the screening analysis presented in the GSL
preliminary analysis.
1. CFL Technology Options Screened Out
a. Multi-Photon Phosphors
NEMA commented that multi-photon phosphors have been analyzed in
the past and no cost effective improved performance phosphors have been
identified, so NEMA agreed with DOE's decision to screen out multi-
photon phosphors. (NEMA, No. 34 at p. 9)
In the preliminary analysis, DOE screened out multi-photon phosphor
technology based on the first criterion, technological feasibility,
because the technology was still in the research phase.\102\ DOE finds
that the technology remains in research phase and is unaware of any
prototypes or commercially available products that incorporate this
technology and therefore proposes to continue to screen multi-photon
phosphor technology out based on the first criterion, technological
feasibility.
---------------------------------------------------------------------------
\102\ GSL preliminary analysis at 2-61.
---------------------------------------------------------------------------
2. LED Technology Options Screened Out
a. AC LEDs
NEMA noted that true AC LEDs have less than 50 percent utilization
and require external components for, among other things, surge
protection and flicker mitigation. Further, for high voltage LEDs there
is an efficiency loss due to die segmentation and increased package
complexity to sustain the high voltage and wide variety of optimum
forward voltages. Therefore, NEMA agreed with DOE's decision to screen
out AC LEDs. (NEMA, p. 11)
In the preliminary analysis, DOE presented AC LEDs as a technology
option that removed the need for a driver component, potentially
reducing efficiency losses.\103\ DOE determined that manufacturers are
finding solutions to several of the issues noted by NEMA. DOE found
that Seoul Semiconductor has a number of high voltage AC LED modules
commercially available for integration into lamps. Further, in July
2014, Seoul Semiconductor announced a new line of AC LED modules with
improved AC drivers designed specifically for the omnidirectional
lamps, improved compatibility with TRIAC dimmers, and mitigated flicker
issues with dimming. Regarding utilization issues, DOE found
improvements in circuit design can increase LED utilization. For
example, Texas Instruments' (TI's) TPS92411 MOSFET switch allows a
small capacitor to be placed across each LED segment on a circuit,
storing energy to keep all LEDs lit, even when the AC line voltage is
too low, thereby increasing LED utilization.
---------------------------------------------------------------------------
\103\ Id.
---------------------------------------------------------------------------
However, at the time of the preliminary analysis, DOE did not find
commercially available products that contained this technology, and
screened it out based on the first criterion, technological
feasibility. During research conducted for the NOPR analysis, DOE found
that Eastar Lighting is producing two 5 W G-shaped AC LED lamp models
with 330 lumens and 360 lumens that could meet the scope of GSLs.
Because only two models are being produced by one manufacturer, it is
unclear if these lamps could be produced on a commercial scale.
Additionally, the products are not available across a range of lumen
packages and limited to the G-shape. Therefore, DOE is proposing to
screen out AC LEDs based on the second and third criteria, respectively
practicability to manufacture, install, and service and adverse impacts
on product utility or product availability.
b. Quantum Dots
NRDC mentioned that new TVs are starting to use quantum dots and
have LED back lights. As these technologies are out of the research
phase, they could be applicable to general lighting applications.
(NRDC, Public Meeting Transcript, No. 29 at p. 60) However, Philips
disagreed, commenting that the technology is being very closely
monitored within the lighting industry, but it is currently cost
prohibitive. (Philips, Public Meeting Transcript, No. 29 at p. 61)
In the preliminary analysis, DOE screened out this technology based
on the first criterion, technological
[[Page 14567]]
feasibility. DOE acknowledges the continued development of quantum dots
and their use in TVs and other lighting displays, and notes that in a
recent report from Yole D[eacute]veloppement, the use of quantum dots
in lighting is projected to rise by 2020.\104\ However, DOE continues
to find no evidence that quantum dot technology is currently used in
commercially available lamps. Therefore, DOE proposes to continue to
screen out this technology option based on the first criterion,
technological feasibility, and will not consider quantum dot
technologies as a design option for improving the efficacy of GSLs.
---------------------------------------------------------------------------
\104\ I-Micronews. Phosphors & Quantum Dots 2015: LED
Downconverters for Lighting & Displays. 2015. (Last accessed July14,
2015.) http://www.i-micronews.com/led-report/product/phosphors-quantum-dots-2015-led-downconverters-for-lighting-displays.html#description.
---------------------------------------------------------------------------
c. Improved Emitter Materials
In the preliminary analysis, DOE screened out improved emitter
materials, which can increase the efficiency of LED emitters, the
component that generates light output. In particular LED lamp efficacy
can be improved with the use of more efficient green emitters. However,
because research in this area was ongoing, DOE screened out this
technology option based on the first criterion, technological
feasibility. In this NOPR analysis, DOE found that improved emitter
materials remain in the research phase and proposes to continue to
screen them out based on technological feasibility.
3. Summary
In this NOPR, of the technology options identified for improving
GSL efficacy, DOE is proposing screening out the following:
CFL Technology Options Screened Out
Multi-photon phosphors because they could not be proven to
be technologically feasible.
LED Technology Options Screened Out
AC LEDs because they could not be proven to be practicable
to manufacture, install and service and had adverse impacts on product
utility or product availability;
Improved emitter materials because they could not be
proven to be technologically feasible; and
Quantum dot technologies because they could not be proven
to be technologically feasible.
The following are GSL technologies that DOE has not screened out
and is proposing as design options:
CFL Design Options
Highly Emissive Electrode Coatings
Higher Efficiency Lamp Fill Gas Composition
Higher Efficiency Phosphors
Glass Coatings
Cold Spot Optimization
Improved Ballast Components
Improved Ballast Circuit Design
Change in Technology
LED Design Options
Efficient Down Converters (with the exception of quantum
dots technologies)
Improved Package Architectures
Alternative Substrate Materials
Improved Thermal Interface Materials
Optimized Heat Sink Design
Active Thermal Management Systems
Improved Primary Optics
Improved Secondary Optics
Improved Driver Design
Reduced Current Density
See chapter 4 of the NOPR TSD for further details on the GSL
screening analysis. DOE requests comment on the proposed design options
in this NOPR analysis.
C. Engineering Analysis
1. General Approach
The engineering analysis is generally based on commercially
available lamps that incorporate the design options identified in the
technology assessment and screening analysis. (See chapters 3 and 4 of
the NOPR TSD for further information on technology and design options.)
The methodology consists of the following steps: (1) Selecting
representative product classes, (2) selecting baseline lamps, (3)
identifying more efficacious substitutes, and (4) developing ELs by
directly analyzing representative product classes and then scaling
those ELs to non-representative product classes. The details of the
engineering analysis are discussed in chapter 5 of the NOPR TSD. The
following discussion summarizes the general steps of the engineering
analysis:
Representative product classes: DOE first reviews covered lamps and
the associated product classes. When a product has multiple product
classes, DOE selects certain classes as ``representative'' and
concentrates its analytical effort on these classes. DOE selects
representative product classes primarily because of their high market
volumes and/or distinct characteristics.
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. For this NOPR analysis, DOE uses performance data
presented in manufacturer catalogs to determine lamp efficacy. DOE also
considers other lamp characteristics in choosing the most appropriate
baseline for each product class such as wattage, lumen output, CCT,
shape, 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 V.B or chapter
4 of the NOPR TSD). DOE also sought to maintain the baseline lamp's
characteristics, such as base type, CCT, and CRI among other
specifications, for substitute lamps. For non-integrated GSLs, DOE
pairs each lamp with an appropriate ballast because non-integrated GSLs
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 lumen packages to comply
with the standard level of a given product class; and (3) the max-tech
EL. DOE then scales the ELs of representative product classes to any
classes not directly analyzed.
DOE received comments on the general approach to the engineering
analysis presented in the preliminary analysis. NEMA and Westinghouse
expressed concerns over DOE's use of catalog data. In general, NEMA
stated that rated or initial lumens reported in catalogs are long term
means and are not necessarily measured values. NEMA especially noted
that catalog data for the covered products that are currently without
published test procedures would be particularly problematic.
Westinghouse commented that manufacturers may be aggressively marketing
their product and without supporting test data, it is difficult to
determine which numbers are legitimate. Westinghouse further requested
that DOE exclude outliers and set standards that allow for differences
between specialty and high-volume manufacturing. (NEMA, No. 34 at p.
15; Westinghouse, Public Meeting Transcript, No. 29 at pp. 97-98)
DOE used performance data of commercially available GSLs presented
in manufacturer catalogs to identify potential baseline lamps and
develop ELs. DOE used catalog data as the basis of its engineering
analysis because it is
[[Page 14568]]
the largest and most comprehensive dataset. However, DOE also used
publicly available test data from CEC's Appliance Efficiency Database,
DOE's LED Lighting Facts Product List, EPA's ENERGY STAR Certified
Light Bulbs Database, and DOE's CCMS Database when possible to verify
efficacies calculated from catalog values and to ensure lamps can
comply with ELs based on test data. DOE also conducted independent
testing, using the LED Test Procedure SNOPR, of representative units
and similar lamps to verify performance at the highest levels of
efficacy. See section V.C.4 and appendix 5A of the NOPR TSD for more
information.
Although certain products included in the scope of this rulemaking
do not currently have finalized DOE test procedures (e.g., LED lamps),
industry standards for measuring efficacy have been in place for
several years for these products. Therefore, manufacturers and the
organizations conducting verification testing are likely using existing
industry standard test methods to determine performance values. EPCA
directs DOE to establish test procedures for covered products in
advance of prescribing an energy conservation standard. (42 U.S.C.
6295(o)(3)(A)) Thus, DOE plans to finalize test procedures for all GSLs
for which DOE is proposing standards prior to the completion of this
rulemaking.
Regarding outliers, DOE identified data outliers in both its
collection of lamp performance data from manufacturer catalogs and in
its review of efficacy values from DOE's CCMS Database. DOE identified
both on the high and low end outliers, and in cases where DOE was
unable to verify the value using test data or manufacturer
confirmation, DOE maintained its approach from the preliminary analysis
of not considering the lamp in the engineering analysis. DOE welcomes
comment on the data approach.
2. Representative Product Classes
In the case where a covered product has multiple product classes,
DOE identifies and selects certain product classes as
``representative'' and concentrates its analytical effort on those
classes. DOE chooses product classes as representative primarily
because of their high market volumes and/or unique characteristics. DOE
then scales its analytical findings for those representative product
classes to other product classes that are not directly analyzed. In the
preliminary analysis, DOE considered directly analyzing all product
classes for GSLs: Integrated low-lumen GSLs, integrated high-lumen
GSLs, and non-integrated GSLs.
In this NOPR analysis, DOE is directly analyzing both the
Integrated Low-Lumen and the Integrated High-Lumen product classes
because there are technological limitations to producing high-lumen
(i.e., 2,000 lumens or greater) GSLs using LED technology and therefore
ELs for this product class cannot be scaled from the Integrated Low-
Lumen product class. DOE is also continuing to directly analyze the
Non-Integrated product class because of observed differences in
efficacy trends and maximum technologically feasible levels between
integrated and non-integrated lamps. Further, manufacturer feedback
indicated that scaling between the integrated and non-integrated
products is not appropriate.
As stated in section V.A.1, for this NOPR analysis, DOE is also
proposing a product class division based on standby mode functionality
for the Integrated Low-Lumen and Integrated High-Lumen product classes.
Based on manufacturer feedback and testing conducted, DOE determined
that standby power consumption is not negligible and therefore the
efficacy of these lamps would be impacted. Because standby mode
functionality also offers a consumer utility, DOE is proposing a
product class division. Based on manufacturer feedback and testing
conducted, DOE determined that integrated lamps with standby mode
functionality are typically the same design as integrated lamps without
standby mode functionality but with the addition of wireless
communication components. Because the technology is fundamentally the
same, DOE is proposing to scale from the Integrated Low-Lumen and
Integrated High-Lumen product classes without standby mode to the
respective product classes capable of operating in standby mode. See
section V.C.6 for more information on scaling.
In summary, DOE is proposing to directly analyze the product
classes shown (in gray) in Table V-3 as representative in the NOPR
analysis. See chapter 5 of the NOPR TSD for further discussion.
Table V-3--General Service Lamps Representative Product Classes
------------------------------------------------------------------------
Standby mode
Lamp type Lumen package operation
------------------------------------------------------------------------
Integrated GSLs................. 310 <=Initial No Standby Mode.
Lumen Output Capable Of
<2,000. Operating In
Standby Mode.
2,000 <=Initial No Standby Mode.
Lumen Output Capable Of
<=2,600. Operating In
Standby Mode.
Non-Integrated GSLs............. 310 <=Initial ..................
Lumen Output
<=2,600.
------------------------------------------------------------------------
3. Baseline Lamps
Once DOE identifies the 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 meets existing energy conservation standards. Specific lamp
characteristics were used to characterize the most common lamps
purchased by consumers (e.g., wattage, CCT, CRI, and light output).
Because certain products within the scope of this rulemaking have
existing standards, GSLs that fall within the same product class as
these lamps must meet the existing standard in order to prevent
backsliding. (See 42 U.S.C. 6295(o)(1)) Thus, DOE only considered
baseline lamps in the Integrated Low-Lumen and Integrated High-Lumen
product classes that meet the existing standards for bare MBCFLs. The
Non-Integrated product class does not have any applicable existing
standards.
a. Integrated Lamps
In the preliminary analysis, DOE identified baseline lamps in the
integrated lamps product classes as the most common, least efficacious
lamps in those product classes that meet existing standards for
MBCFLs.\105\ For the Integrated Low-Lumen product class in the
preliminary analysis, DOE found that the most common lamps were 60 W
equivalent lamps and typically produced lumen output in the range of
700-900 lumens. DOE determined that the baseline lamp for the
Integrated Low-Lumen product class was a 14 W, 750 lumen (i.e., 60 W
equivalent) A-shape CFL with a lifetime of 10,000
[[Page 14569]]
hours, a CRI of 80, and a CCT of 2,700 K. For the Integrated High-Lumen
product class in the preliminary analysis, DOE found that the most
common lamps were 125 W equivalent lamps which typically produce lumen
output in the range of 2,000-2,600 lumens. DOE determined that the
baseline was a 32 W, 2,000 lumen (i.e., greater than 100 W equivalent)
spiral CFL with a lifetime of 10,000 hours, a CRI of 80, and a CCT of
2,700 K.
---------------------------------------------------------------------------
\105\ GSL preliminary analysis at 5-4.
---------------------------------------------------------------------------
DOE received comments from stakeholders on the baseline lamps
selected for the Integrated Low-Lumen product class. GE, NEMA, and
Westinghouse commented that the baseline (CSL 0) and CSL 1 did not
represent two ELs for CFLs, but rather two distinct products used for
different purposes. Specifically, GE, NEMA, and Westinghouse noted that
the baseline in the Integrated Low-Lumen product class was a covered
CFL and CSL 1 was a bare CFL, and lamps with covers should not be
eliminated because they provide consumer utility. (GE, Public Meeting
Transcript, No. 29 at pp. 71-72; NEMA, No. 34 at p. 15; Westinghouse,
Public Meeting Transcript, No. 29 at pp. 208-209)
NEMA also commented that because ENERGY STAR requirements are
designed for premium products and are not mandatory, DOE should not set
the baseline for MBCFLs to align with the ENERGY STAR specification.
NEMA further noted that there are energy-efficient MBCFLs currently on
the market that do not meet ENERGY STAR requirements. (NEMA, No. 34 at
pp. 8, 15)
As stated in section V.A.1, DOE is not proposing a product class
division for covered versus bare products because LED lamps are
available at higher levels of efficacy with a cover. In addition DOE
typically selects a baseline lamp that is the most common, least
efficacious lamp that meets existing energy conservation standards.
Because spiral lamps are more common than covered lamps, DOE determined
a spiral lamp was more representative of the product class. Further,
DOE agrees that ENERGY STAR requirements are not mandatory and is
therefore not analyzing these requirements as the baseline. The
requirements in the current ENERGY STAR specification, ENERGY STAR
Lamps Specification V1.1, are higher than the existing energy
conservation standards, and DOE typically selects the most common lamp
that just meets existing energy conservation standards as the baseline.
NEEA noted a discrepancy in the lumen bins used across the analyses
that could result in data inconsistencies. Regarding the Integrated
Low-Lumen product class baseline, NEEA noted that the engineering
analysis considered replacement options between 700 and 900 lumens for
60 W equivalent replacements, while the LCC and PBP analyses considered
a range of 750 to 1,050 lumens. (NEEA, Public Meeting Transcript, No.
29 at p. 231) DOE appreciates the comment from NEEA on the
inconsistency of the lumen bin equivalencies. DOE revised the NOPR
analysis to consider 60 W equivalent replacements, including the
baseline, as lamps with lumen output between 750 and 1,049 lumens,
which aligns with the EISA 2007 lumen bins and the downstream analyses.
See sections V.G and V.H for more information.
In the NOPR analysis, based on a review of lamps that had the most
common characteristics, DOE identified a 14 W, 800 lumen (i.e., 60 W
equivalent) spiral CFL with a lifetime of 8,000 hours, a CRI of 82, and
a CCT of 2,700 K. Therefore, DOE analyzed a bare spiral CFL with
efficacy closest to the existing energy conservation standard as the
baseline in the Integrated Low-Lumen product class for the NOPR
analysis. DOE did not receive comments on the baseline lamp selected
for the Integrated High-Lumen product class. DOE confirmed a 32 W,
2,000 lumen (i.e., greater than 100 W equivalent) spiral CFL with a
lifetime of 10,000 hours, a CRI of 80, and a CCT of 2,700 K is the
appropriate baseline for the Integrated High-Lumen product class.
DOE is proposing the baseline lamps for the Integrated Low-Lumen
and Integrated High-Lumen product classes specified in Table V-4. DOE
requests comment on the baseline lamps analyzed in the NOPR analysis,
in particular the spiral CFL baseline in the Integrated Low-Lumen
product class.
Table V-4--Integrated Product Classes' Baseline Lamps
--------------------------------------------------------------------------------------------------------------------------------------------------------
Nominal Initial Rated
Product class Lamp shape Base type Lamp type wattage lumens efficacy Lifetime CCT (K) CRI
(W) (Im) (Im/W) (hr)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Integrated Low-Lumen (310 <= Spiral........... E26.............. CFL............. 14 800 57.1 8,000 2,700 82
Initial Lumen Output < 2,000).
Integrated High-Lumen (2,000 Spiral........... E26.............. CFL............. 32 2,000 62.5 10,000 2,700 80
<= Initial Lumen Output <=
2,600).
--------------------------------------------------------------------------------------------------------------------------------------------------------
b. Non-Integrated Lamps
In the preliminary analysis, DOE identified the baseline lamp in
the Non-Integrated product class as the most common, least efficacious
lamp.\106\ The Non-Integrated product class does not have applicable
existing standards and therefore the lowest efficacy lamps on the
market were considered for the baseline. DOE found that the base types
of non-integrated CFLs typically correspond to certain wattages and
lumen outputs, and thus DOE concentrated on a common wattage and its
associated base type. Based on a review of lamps that had the most
common characteristics, DOE determined that the baseline lamp for the
Non-Integrated product class was a 26 W, 1,710 lumen double tube \107\
G24q-3 base CFL with a lifetime of 10,000 hours and a CCT of 4,100 K in
the preliminary analysis.
---------------------------------------------------------------------------
\106\ Id. at 5-12.
\107\ The double tube shape for CFLs, that is, a CFL with two U-
shaped glass tubes, is also sometimes referred to as quad tube in
industry.
---------------------------------------------------------------------------
NEMA expressed concern regarding the baseline lamp selected for the
Non-Integrated product class, noting that because CFL pin base lamps
have unique base and pin configurations, if the baseline lamp is
eliminated, consumers will be forced to replace their fixtures and will
be left with stranded assets. (NEMA, No. 34 at p. 15) As stated, DOE
selected a common wattage and its associated base type as
representative in the Non-Integrated product class and therefore chose
a baseline lamp with these characteristics. However, DOE ensured that
the vast majority of base types will be available at EL 1. DOE also
determined through
[[Page 14570]]
manufacturer feedback that non-integrated CFLs replaced with a lamp of
the same base type and shape would not require a fixture, socket, or
ballast change provided the ballast is compatible with the replacement
lamp. Therefore, consumers replacing baseline lamps are not expected to
have stranded assets. See section V.C.5 for more information.
In this NOPR analysis, DOE confirmed a 26 W, 1,710 lumen double
tube G24q-3 base CFL with a lifetime of 10,000 hours and a CCT of 4,100
K is the appropriate baseline for the Non-Integrated product class. DOE
is proposing the baseline lamp for the Non-Integrated product classes
specified in Table V-5.
Table V-5--Non-Integrated Product Class Baseline Lamp
--------------------------------------------------------------------------------------------------------------------------------------------------------
Nominal Rated Initial Mean Rated
Lamp shape Base type Lamp type wattage wattage lumens lumens efficacy Lifetime CCT (K) CRI
(W) (W) (Im) (Im) (Im/W) (hr)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Double Tube..................... G24q-3........ CFL........... 26 26 1,710 1,450 65.8 10,000 4,100 82
--------------------------------------------------------------------------------------------------------------------------------------------------------
4. More Efficacious Substitutes
DOE selects a series of more efficacious replacements for the
baseline lamps considered within each representative product class. DOE
considered only technologies that met all four criteria in the
screening analysis. In the preliminary analysis, these selections were
made such that potential substitutions maintained light output within
10 percent of the baseline lamp's light output with similar
characteristics when possible.\108\ In identifying the more efficacious
substitutes, DOE utilized a database of commercially available lamps.
Further details specific to the more efficacious substitutes of the
Integrated Low-Lumen, Integrated High-Lumen, and Non-Integrated product
classes are discussed in the following sections.
---------------------------------------------------------------------------
\108\ GSL preliminary analysis at 5-13.
---------------------------------------------------------------------------
a. Integrated Lamps
For integrated GSLs, DOE identified more efficacious substitute
lamps that saved energy and had light output within 10 percent of the
baseline lamp's light output. DOE selected more efficacious substitutes
with the same base type as the baseline lamp since replacing an
integrated lamp with a lamp of a different base type would potentially
require a fixture or socket change and thus is considered an unlikely
replacement. For the preliminary analysis, DOE also ensured that the
more efficacious substitutes were marketed as omnidirectional, thus
maintaining the even light distribution of the baseline lamp. DOE
received comments on these requirements and the more efficacious
substitutes analyzed for the Integrated Low-Lumen and Integrated High-
Lumen product classes.
Omnidirectionality
NEMA agreed that in order to satisfy consumer expectations for
replacement lamps, substitutes must be within 10 percent of the lumen
output from the baseline lamp. In addition, NEMA commented that more
efficacious substitutes should be reasonably omnidirectional in order
to serve in general service lamp applications. NEMA noted that ENERGY
STAR specifies intensity distribution requirements for
omnidirectionality, however CFLs are excluded from testing because they
are presumed to be omnidirectional and thus requiring
omnidirectionality in a substitute lamp could inadvertently exclude
CFLs. (NEMA, No. 34 at p. 15)
DOE agrees that A-shape and spiral CFLs are not typically marketed
as omnidirectional despite exhibiting such properties. Therefore, DOE
did not require the more efficacious A-shape and spiral CFLs to be
explicitly marketed as omnidirectional. However, because A-shape LED
lamps are frequently available in both omnidirectional and semi-
omnidirectional versions, DOE confirmed that omnidirectional LED lamps
were selected in order to maintain omnidirectionality and to ensure
that the more efficacious substitutes could be used in the same
applications as the lamps being replaced. For the NOPR analysis, DOE
maintained the approach of analyzing LED lamps explicitly marketed as
omnidirectional and CFLs that are spiral or A-shape as more efficacious
substitutes.
Additional CFL More Efficacious Substitutes
Several stakeholders commented that DOE should consider analyzing
higher efficacy CFL representative units in the Integrated Low-Lumen
product class. CA IOUs and EEAs remarked that CFLs are available in a
broad range of efficacies, and there should be more than one CSL
corresponding to the different levels of CFL performance. (CA IOUs, No.
33 at p. 4; CA IOUs, Public Meeting Transcript, No. 29 at pp. 88-89;
EEAs, No. 32 at p. 4) CEC stated that DOE should consider the existence
of more efficacious CFLs at CSLs 2 and 3 and incorporate the wattages,
lifetimes, and shipments of those more efficacious CFLs in the NIA.
(CEC, No. 31 at p. 2) NRDC commented that they believe the intention
was not to eliminate CFLs, and noted there are more efficacious CFLs
available than analyzed. (NRDC, Public Meeting Transcript, No. 29 at p.
92) Westinghouse agreed with NRDC, stating that it is preferable to
preserve CFLs to allow a wider product assortment, benefiting consumers
and industry. (Westinghouse, Public Meeting Transcript, No. 29 at p.
98)
Stakeholders offered specific suggestions on more efficacious CFLs
to consider in the analysis. EEA commented that there are 60 W
replacement CFLs available today with efficacies up to 69.2 lm/W and
100 W replacements with efficacies that exceed 70 lm/W. (EEAs, No. 32
at p. 4) NRDC encouraged DOE to set a CSL between the current CSL 1 and
CSL 2 with the same efficacy as CSL 2 but with a shorter lifetime of
10,000 hours. (NRDC, Public Meeting Transcript, No. 29 at p. 194) CA
IOUs noted that the CSLs in the Integrated Low-Lumen product class can
have multiple lamp technologies that meet the levels. CA IOUs stated
that DOE assumes that only LED lamps can meet EL 2, however CFLs can
also meet this level. CA IOUs explained that there are CFLs available
on the market with efficacies above 67 lm/W, including products on the
ENERGY STAR Qualifying Product List from over 12 manufacturers. (CA
IOUs, No. 33 at p. 4; CA IOUs, Public Meeting Transcript, No. 29 at pp.
88-89)
DOE acknowledges that higher efficacy CFLs exist on the market
currently. Therefore for this NOPR analysis, DOE also analyzed an
energy-saving 11 W CFL with 750 lumens, an efficacy of 68.2 lm/W, and a
lifetime of 10,000 hours as a 60 W equivalent replacement at EL 2 in
the Integrated
[[Page 14571]]
Low-Lumen product class. This lamp is modeled based on a commercially
available 11 W CFL with the same lifetime and slightly lower lumen
output, however DOE believes this efficacy improvement is
technologically feasible. In addition, DOE identified other non-energy-
saving options including a 13 W CFL with 900 lumens and an efficacy of
69.2 lm/W that can meet EL 2. However, DOE did not analyze this lamp as
a representative unit because DOE typically only analyzes energy-saving
options in the engineering analysis. DOE did, however, account for the
availability of this option in the NIA. See section V.H for more
information.
Improvement of LED Lamps
DOE received several comments regarding potential efficacy
improvements of LED lamps. NRDC, EEAs, and CEC encouraged DOE to use a
forward thinking-approach for LED lamps and to consider even higher
levels of efficacy due to recent and future expected market
developments. NRDC and EEAs pointed out that as an individual LED
becomes more efficient, fewer LEDs are required to produce the same
amount of light. This allows an LED lamp to have a smaller heat sink
(because there is less heat to dissipate) and smaller components
(because there is less power required), leading to an overall smaller
form factor. All of these changes lead to an increase in overall lamp
efficacy and typically an accompanying decrease in overall lamp
cost.\109\ NRDC noted that DOE is not predicting improvements in the
efficacy of LED lamps besides what is currently commercially available.
However, given historical improvements, it is expected such gains will
occur by 2020. EEAs urged DOE to consult with EIA and the agency's
Solid-State Lighting Program to ensure that expected efficiency trends
are captured in the analysis. CEC specifically asked DOE to consider
ELs with even greater levels of efficacy to reflect the levels under
consideration in California. For example, a 60 W replacement lamp at
the most stringent CSL under consideration in the preliminary analysis
had a required efficacy of approximately 85 lm/W, whereas CEC is
proposing a standard of 98 lm/W with similar quality requirements (such
as CRI). (NRDC, Public Meeting Transcript, No. 29 at pp. 98-100; EEAs,
No. 32 at p. 4; CEC, No. 31 at p. 1)
---------------------------------------------------------------------------
\109\ See section V.D for discussion of the product price
determination methodology and comments related to pricing.
---------------------------------------------------------------------------
DOE agrees that LED lamp technology is rapidly developing and that
new products are continuously being introduced. DOE has identified more
efficacious commercially available products since the preliminary
analysis and has increased the efficacy of the ELs under consideration.
For example, the maximum technologically feasible (max-tech) level in
the preliminary analysis was represented by a 60 W replacement with an
efficacy of 84.2 lm/W (corresponding to an A-value of 91.7), and in
this NOPR analysis, DOE identified LED lamps with efficacies in excess
of 100 lm/W, as discussed in the following paragraphs. During the
course of this rulemaking, DOE will continue to monitor the market for
new commercially available products and information on working
prototypes and update its analysis as appropriate.
While DOE publishes information on market trends through its Solid-
State Lighting Program and reviews publications from other agencies,
including the EIA, DOE only considers technologies incorporated in
commercially available products or in working prototypes to be
technologically feasible. 10 CFR 430, subpart C, appendix A, section
4(a)(4)(i) DOE does, however, use market trends and efficacy
projections to inform its assumptions in the national impacts analysis.
See section V.H for more information on the efficacy market
distributions by product class.
As stated, for the NOPR analysis, DOE found several more
efficacious LED lamps at levels of efficacy higher than the max-tech
level identified in the preliminary analysis of 84.2 lm/W for a 60 W
equivalent replacement in the Integrated Low-Lumen product class. When
selecting more efficacious substitutes, DOE identified multiple 8.5 W
LED lamps with 800 lumens, efficacy of 94.1 lm/W, and lifetime of
25,000 hours. DOE also identified a few 60 W equivalent replacement LED
lamps with even lower wattages and greater efficacies, ranging from
about 100 lm/W to 124.6 lm/W. The characteristics of these lamps were
typically unique to one manufacturer. Because these lower-wattage
products were newly introduced on the market, most of the lamps did not
have test data available, and therefore DOE conducted independent
testing to confirm the rated performance of these lamps for this NOPR
analysis.
DOE conducted efficacy testing in accordance with the LED Test
Procedure SNOPR \110\ on multiple integrated LED lamps that exceeded
the max-tech level identified in the preliminary analysis.
Specifically, DOE tested 8.5 W, 8 W, 7 W, and 6.5 W LED lamps with
rated lumen output within the range of 750-1,049 lumens (i.e., 60 W
equivalent replacements). As noted in appendix 5A of the NOPR TSD, DOE
was able to confirm that the tested values of the 8.5 W, 8 W, and 6.5 W
LED lamps matched or exceeded the rated performance characteristics
with tested efficacies ranging from 94.8 lm/W for an 8.5 W lamp to 113
lm/W for a 6.5 W lamp. The 7 W LED lamp tested below the minimum lumen
output DOE considered as suitable for 60 W equivalent replacements and
therefore was not considered as a more efficacious substitute.
Additionally, in order to maintain more efficacious substitutes across
all lumen packages of the Integrated Low-Lumen product class, DOE did
not analyze the 6.5 W LED lamp. See section V.C.5 for more information.
---------------------------------------------------------------------------
\110\ 80 FR 39644 (July 9, 2015).
---------------------------------------------------------------------------
DOE notes that the 8 W LED lamp tested was a 3-way lamp tested at
its middle setting and resulted in an efficacy of 111.4 lm/W. Based on
the testing, DOE has determined that a commercially available 3-way LED
lamp when operated at its middle setting demonstrated the potential for
a standard, non-3-way, 8 W LED lamp to achieve this EL. Therefore,
using the rated performance values, DOE modeled an 8 W LED lamp with
820 lumens and an efficacy of 102.5 lm/W. DOE assumed the modeled lamp
would have similar characteristics to the most common commercially
available 60 W equivalent LED replacements. Thus, DOE modeled the lamp
to have an A19 shape, medium base type, 25,000 hour lifetime, 2,700 K
CCT, 80 CRI, and dimming functionality. DOE requests comment on the 3-
way lamp used as a basis for the modeled LED lamp and information on
whether such a lamp would meet DOE's screening criteria and should be
maintained for the final rule analysis.
Based on catalog information and the independent testing conducted
for the NOPR analysis, DOE selected an 8.5 W LED lamp with 800 lumens,
efficacy of 94.1 lm/W, and lifetime of 25,000 hours as a more
efficacious substitute corresponding to EL 3 in the Integrated Low-
Lumen product class. DOE also found that for the LED lamps above EL 2,
the consumer price decreased as efficacy increased. (See section V.D
for more information on product price determination.) Therefore, DOE
did not analyze any additional lamps between EL 2 and EL 3 because the
8.5 W was at the lowest incremental first cost for a commercially
available product above
[[Page 14572]]
EL 2. DOE also analyzed the modeled 8 W LED lamp with 820 lumens,
efficacy of 102.5, and lifetime of 25,000 hours as a more efficacious
substitute at EL 4.
The more efficacious substitutes analyzed in this NOPR analysis for
the Integrated Low-Lumen and Integrated High-Lumen product classes are
summarized in Table V-6.
Table V-6--Integrated Product Classes' Representative Lamp Units
--------------------------------------------------------------------------------------------------------------------------------------------------------
Initial Rated
Product class EL Lamp shape Base Lamp Nominal lumens efficacy Lifetime CCT (K) CRI
type type wattage (W) (Im) (Im/W) (hr)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Integrated Low-Lumen......... Baseline........ Spiral......... E26..... CFL..... 14 800 57.1 8,000 2,700 82
(310 <= Initial Lumen Output
<2,000).
EL 1............ Spiral......... E26..... CFL..... 13 800 61.5 10,000 2,700 80
EL 2............ A19............ E26..... LED..... 12 800 66.7 25,000 2,700 83
Spiral......... E26..... CFL..... \111\ 11 750 68.2 10,000 2,700 82
EL 3............ A19............ E26..... LED..... 8.5 800 94.1 25,000 2,700 80
EL 4............ A19............ E26..... LED..... \112\ 8 820 102.5 25,000 2,700 80
Integrated High-Lumen (2,000 Baseline........ Spiral......... E26..... CFL..... 32 2,000 62.5 10,000 2,700 82
<= Initial Lumen Output
<=2,600).
EL 1............ Spiral......... E26..... CFL..... 30 2,000 66.7 10,000 2,700 82
EL 2............ Spiral......... E26..... CFL..... 29 2,200 75.9 12,000 2,700 82
--------------------------------------------------------------------------------------------------------------------------------------------------------
---------------------------------------------------------------------------
\111\ Lamp is modeled based on commercially available 11 W CFLs.
\112\ Lamp is modeled based on commercially available 3-way lamp
with same specifications at middle setting.
---------------------------------------------------------------------------
b. Non-Integrated Lamps
For non-integrated GSLs, DOE considered more efficacious lamps that
did not increase energy consumption relative to the baseline and had
light output within 10 percent of the baseline lamp-and-ballast system
when possible. Due to potential physical and electrical constraints
associated with switching base types, DOE selected substitute lamps
that had the same base type as the baseline lamp. DOE identified
substitute lamps that were the same wattage as the baseline but
produced more light and were therefore more efficacious or lamps that
were lower wattage than the baseline but produced similar light and
were therefore more efficacious. DOE paired each representative lamp
with an appropriate ballast because non-integrated GSLs are a component
of a system, and their performance is related to the ballast on which
they operate. DOE received comments on these requirements and the more
efficacious substitutes analyzed for the Non-Integrated product class.
Lumen Output Criterion
DOE received comments regarding the lumen output criterion used for
selecting more efficacious substitutes in the Non-Integrated product
class. GE commented that consideration must be given to the
Occupational Safety and Health Administration (OSHA) safety and minimum
light requirements. GE noted that non-integrated CFLs are typically
designed to meet certain requirements in commercial spaces and if the
lighting level drops, there could be issues meeting safety requirements
such as OSHA exit lighting requirements. (GE, Public Meeting
Transcript, No. 29 at pp. 84-85)
On the contrary, NEEA observed that most buildings are grossly over
lit because the buildings are designed to meet lighting safety
requirements when the lamps eventually fall to 70 percent of their
initial lumen output. NEEA commented that lumen reductions of 20 to 30
percent are feasible in well-designed spaces and thus a 10 to 11
percent reduction is safe and acceptable. (NEEA, Public Meeting
Transcript, No. 29 at pp. 85-86) GE clarified that there are a variety
of spaces and their concern is specifically regarding the spaces that
are not currently over lit. (GE, Public Meeting Transcript, No. 29 at
p. 86)
DOE understands the concern to maintain lumen output. Therefore,
for this NOPR analysis, DOE continued to utilize the criterion of
maintaining 10 percent of the mean lumen output when possible in
developing lamp-and-ballast replacement scenarios. As stated, DOE
paired the non-integrated GSLs with representative ballasts because the
non-integrated GSLs operate on a ballast in practice. For the NOPR
analysis, DOE again paired the non-integrated GSLs with a one-lamp
electronic, programmed start ballast to represent the lamp and ballast
combinations present in the market. In assessing light output of the
representative systems for the Non-Integrated product class, DOE made a
distinction between mean and initial lumen output. DOE used catalog
initial lumen output to calculate efficacy when determining ELs. As
noted by stakeholders, the light output of a lamp decreases over time.
To account for this real-world depreciation in lumens, DOE analyzed
more efficacious systems that maintain mean lumen output within 10
percent of the baseline system, when possible. Mean lumen output is a
measure of light output midway through the rated life of a lamp, and a
10 percent change is a common parameter used by lighting designers to
specify acceptable substitute products on the basis of light output.
NEMA commented that the baseline and more efficacious substitutes
are 4-pin non-integrated CFLs specifically used in commercial
applications. (NEMA, No. 34 at p. 15) NEMA, GE, and Westinghouse
further commented that the two CSL 1 choices are problematic because
the full wattage lamp has slightly higher lumens but does not offer
energy savings and the reduced wattage lamp is not within 10 percent of
the baseline lumen output and may not be compatible with the existing
ballast or acceptable to consumers. (NEMA, No. 34 at p. 15; GE, Public
Meeting Transcript, No. 29 at pp. 72-73; Westinghouse, Public Meeting
Transcript, No. 29 at pp. 74-75)
DOE determined the reduced wattage more efficacious substitute is a
viable replacement, particularly in the commercial sector where energy
savings are prioritized. Although the initial lumen output of the
reduced wattage lamp was 11 percent lower than the
[[Page 14573]]
baseline lamp, the mean lumen output of the reduced wattage lamp chosen
was significantly closer to the baseline lamp's mean lumen output. As
stated previously, DOE considers mean lumen output in order to account
for lumen deprecation of the system. Therefore, when comparing system
mean lumen output of the reduced wattage lamp and baseline lamp, the
lumen output of the reduced wattage system was only 5 percent lower
than the baseline system. Additionally, DOE acknowledges that the full
wattage replacement does not achieve energy savings, however DOE
believes this a likely replacement option for consumers in specific
applications and therefore maintained this replacement option for
scenarios where light output must remain constant for this NOPR
analysis.
Compatibility of More Efficacious Substitutes
Westinghouse expressed concern over the expectation that the
consumer would understand the lamp-and-ballast-matching process.
Westinghouse noted that consumers understand one-to-one wattage
replacements, but it cannot be assumed that consumers would know how to
select a replacement lamp to operate on an existing ballast if the
original wattage is no longer available. Westinghouse observed that
consumers return lamps after having tried to fit a replacement on the
wrong ballast. Regardless of whether matching the base type was all
that was needed to correctly replace a lamp with a new product
compatible with the ballast, Westinghouse commented that consumers
tended to rely only on matching wattage when replacing lamps.
(Westinghouse, Public Meeting Transcript, No. 29 at pp. 79, 80-82)
Conversely, NRDC suggested that DOE reexamine the assumption that
more efficacious lamps with different wattages would be incompatible
with the installed ballast and socket. Specifically, NRDC pointed out
that the more efficacious lamps would have a lower wattage than the
lamps they were replacing, and therefore would not impose a safety
risk. NRDC noted that wattage equivalency guidance had been successful
at educating consumers replacing screw base lamps and similar guidance
could be deployed for pin base lamps. In addition, NRDC related that
consumers typically bring these lamps to the store when purchasing
replacements to ensure a lamp of the proper shape and base type is
selected, and therefore a slightly different wattage should not pose an
issue. (NRDC, Public Meeting Transcript, No. 29 at pp. 83-84)
DOE agrees that more efficacious substitutes with lower wattages
can be suitable replacements for installed lamps. DOE found lamps with
the same base type and shape as their higher wattage counterparts that
were listed as compatible with the same ballast. Manufacturer feedback
also confirmed that non-integrated CFLs replaced with a lamp of the
same base type and shape would not require a fixture, socket, or
ballast change provided the ballast is compatible with the replacement
lamp. Therefore, for this NOPR analysis, DOE maintained the replacement
option of a reduced wattage in addition to the full wattage lamp.
The more efficacious substitutes analyzed in this NOPR analysis for
the Non-Integrated product class are summarized in Table V-7.
Table V-7--Non-Integrated Product Class Design Representative Lamp Units
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Nominal Rated Initial Mean Rated
CSL Lamp shape Base type Lamp type wattage wattage lumens lumens efficacy Lifetime CCT (K) CRI
(W) (W) (Im) (Im) (Im/W) (hr)
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline.......................... Double Tube.......... G24q-3............... CFL........... 26 26 1,710 1,450 65.8 10,000 4,100 82
EL 1.............................. Double Tube.......... G24q-3............... CFL........... 26 26 1,800 1,525 69.2 12,000 4,100 82
EL 1.............................. Double Tube.......... G24q-3............... CFL........... 21 21 1,525 1,400 72.6 16,000 4,100 82
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
5. Efficacy Levels
After identifying more efficacious substitutes for each of the
baseline lamps, in the preliminary analysis DOE developed CSLs based on
the consideration of several factors, including: (1) the design options
associated with the specific lamps being studied (e.g., grades of
phosphor for CFLs, improved package architecture for LEDs); (2) the
ability of lamps across the applicable lumen range to comply with the
standard level of a given product class; and (3) the max-tech level. In
the preliminary analysis, DOE considered an equation-based approach to
establish CSLs for GSLs reflecting the relationship between efficacy
and lumen output. DOE received comments specific to this approach
presented in the preliminary analysis.
NEMA expressed concern about how the efficacy curves will translate
across the four lumen ranges. NEMA stated that there can be slight
discontinuities in efficacy, depending on the technology used in the
various ranges. They suggested that each lumen bin be evaluated
separately to set the proper EL for that bin and each specific
technology. NEMA added that it is likely that the curve will not
connect smoothly across all four bins at every CSL, and there will be
fewer CSL levels for CFL technology, whether integrated or non-
integrated. (NEMA, No. 34 at pp. 16-17)
Conversely, NRDC, EEAs, and CA IOUs expressed support for ELs that
are smooth continuous curves rather than the bin approach. (NRDC,
Public Meeting Transcript, No. 29 at p. 12; EEAs, No. 32 at pp. 3-4; CA
IOUs, Public Meeting Transcript, No. 29 at p. 96) NRDC commented that
they were opposed to the current four bin approach because the current
standards have four bins which has resulted in gaming and dimmer bulbs.
(NRDC, Public Meeting Transcript, No. 29 at pp. 55-56) CA IOUs and EEAs
agreed noting that the current step functions used for the GSIL
standards had the unintended consequence of encouraging manufacturers
to product dimmer bulbs. (CA IOUs, Public Meeting Transcript, No. 29 at
p. 96; CA IOUs, No. 33 at p. 3; EEAs, No. 32 at pp. 3-4; EEAs, No. 32
at pp. 3-4) EEAs cited as an example halogen incandescent lamps that
are almost 10 percent dimmer than the incandescent lamps they are
intended to replace. EEAs concluded that DOE's proposed continuous
function results in efficacy requirements that scale with light output,
which removes the incentive for manufacturers to market dimmer bulbs as
a means to comply with the standards. (EEAs, No. 32 at pp. 3-4)
DOE is continuing to propose an equation-based approach in this
NOPR analysis that results in a smooth, continuous curve. DOE is
maintaining
[[Page 14574]]
the continuous function approach based on its assessment that a step
function, where efficacy rises significantly at certain increments in
lumen output or wattage, is not representative of the technology used
in the products covered by this rulemaking. Further, DOE agrees that a
step function increases the potential for products to be introduced at
the lowest lumen output that is required for a given wattage to comply
with the standard.
Regarding NEMA's concern about the impacts of the efficacy curves
across the four lumen bins (or packages), DOE has ensured that GSLs
across lumen packages are maintained at the highest EL for each product
class, including the four lumen packages in the Integrated Low-Lumen
product class. DOE does however, agree, that the ELs may not be
continuous across product classes. DOE analyzed fewer ELs in the
Integrated High-Lumen product class because DOE found that suitable LED
replacements lamps were not available and therefore only analyzed CFLs
in this product class. Similarly, DOE analyzed fewer ELs in the Non-
Integrated product class because suitable LED replacement lamps were
not available. DOE also developed unique ELs for the Non-Integrated
product class because DOE determined the efficacy-lumen relationship
was different for non-integrated GSLs. The specific ELs proposed for
each product class are discussed in more detail in the following
sections.
CA IOUs also supported DOE's proposal to set standards as a
function of light output, rather than wattage because the utility of a
bulb is more closely tied to its lumen output than its wattage. Despite
consumers historically identifying products by their wattage, there is
a much broader range of efficacies and wattages available today. CA
IOUs added that it is important to align standards with these changes
in the lighting industry and ensure that they are relevant to the new
mix of products available on the market. (CA IOUs, No. 33 at pp. 3-4)
DOE agrees that the primary utility provided by a lamp is lumen
output, which can be achieved through a wide range of wattages
depending on the lamp technology. DOE believes that lamps providing
equivalent lumen output and therefore intended for the same
applications should be subject to the same minimum efficacy
requirements. Therefore, DOE is maintaining its lumens-based approach
in this NOPR analysis.
The following sections discuss the ELs developed in the NOPR
analysis for the Integrated Low-Lumen, Integrated High-Lumen, and Non-
Integrated product classes in more detail.
a. Integrated Lamps
In the preliminary analysis, DOE analyzed CSLs for both the
Integrated Low-Lumen and the Integrated High-Lumen product classes. DOE
used commercially available lamps and their associated efficacies when
possible to determine the design options required to meet each CSL. For
the Integrated Low-Lumen and Integrated High-Lumen product classes, DOE
used the catalog initial lumen output and the catalog wattage of the
lamp to calculate efficacy. To establish final minimum efficacy
requirements for each CSL, DOE evaluated whether any adjustments were
necessary to the initial CSLs to ensure lamps were available across the
entire lumen range represented by the product class and to ensure the
CSLs were achievable.
For the Integrated Low-Lumen representative product class, five
CSLs were considered in the preliminary analysis.\113\ The baseline
represented a basic CFL with an efficacy near the existing MBCFL
standard level. CSL 1 represented an improved CFL with more-efficient
phosphors and improved ballast components. CSL 2 represented a basic
LED lamp with an efficacy near the lowest performing LED lamps
currently available on the market. CSL 3 represented an improved LED
lamp with improved package architecture, high-efficiency driver, and
improved optics. CSL 4 represented an advanced LED lamp with further
improved package architecture, high-efficiency driver, and improved
optics. CSL 5 was the maximum technologically feasible level and
represented an LED lamp with the most-efficacious combination of
package architecture, driver, and optics available on the market today.
---------------------------------------------------------------------------
\113\ GSL preliminary analysis at 2-73.
---------------------------------------------------------------------------
NEMA recommended revisions to the integrated low-lumen CSLs
presented in the preliminary analysis. Specifically, NEMA proposed for
bare CFLs an EL of 50 lm/W for lamps within 310-749 lumens; 60 lm/W for
lamps within 750-1,049 lumens; 61 lm/W for lamps within 1,050-1,489;
and 62 lm/W for lamps within 1,490-2,000 lumens. For covered CFLs, NEMA
proposed an EL of 45 lm/W for lamps within 310-749 lumens; 50 lm/W for
lamps within 750-1,049 lumens; 52 lm/W for lamps within 1,050-1,489;
and 55 lm/W for lamps within 1,490-2,000 lumens. For LED lamps, NEMA
proposed an EL of 55 lm/W for lamps within 310-749 lumens and 65 lm/W
for lamps within 750-2,000 lumens.\114\ (NEMA, No. 34 at p. 14)
---------------------------------------------------------------------------
\114\ NEMA also proposed CSLs for incandescent/halogen lamps.
However, DOE cannot consider standards for incandescent/halogen
lamps due to the Appropriations Rider.
---------------------------------------------------------------------------
As discussed in section V.A.1, regarding NEMA's proposed levels,
DOE continued to maintain technology-neutral product classes in the
NOPR analysis with no division for lamps with a cover. Further, DOE is
proposing four levels of efficacy above the baseline. The baseline
represents a basic CFL with an efficacy near the existing MBCFL
standard level. EL 1 represents an improved CFL with more-efficient
phosphors and improved ballast components. EL 2 is represented by a
basic LED lamp with an efficacy near the lowest performing LED lamps
currently available on the market, and an advanced CFL modeled based on
the highest performing commercially available CFLs (see section V.C.4
for more information). EL 3 represents an improved LED lamp with
improved package architecture, high-efficiency driver, and improved
optics. EL 4 is the maximum technologically feasible level and
represents an advanced LED lamp modeled based on the highest performing
commercially available LED lamp \115\ using the most-efficacious
combination of package architecture, driver, reduced current density,
and optics (see section V.C.4 for more information).
---------------------------------------------------------------------------
\115\ This lamp is modeled based on a commercially available 3-
way lamp that is operating at the middle setting.
---------------------------------------------------------------------------
For the Integrated High-Lumen representative product class, two
CSLs were considered in the preliminary analysis.\116\ The baseline
represented a basic CFL with an efficacy near the existing MBCFL
standard level. CSL 1 represented an improved CFL with more-efficient
phosphors and improved ballast components. CSL 2 was the maximum
technologically feasible level and represented the most-efficacious
combination of phosphors and ballast components.
---------------------------------------------------------------------------
\116\ GSL preliminary analysis at 2-73.
---------------------------------------------------------------------------
NEMA also recommended revisions to the Integrated High-Lumen CSLs
presented in the preliminary analysis. Specifically, NEMA proposed for
bare CFLs an EL of 62 lm/W for lamps within 2,000-2,600 lumens. For
covered CFLs, NEMA proposed an EL of 55 lm/W for lamps within 2,000-
2,600 lumens. For LED lamps, NEMA proposed no standard for lamps with
2,000 lumens or greater. (NEMA, No. 34 at p. 14)
For the NOPR analysis, regarding NEMA's suggested levels, DOE
maintained no product class division for
[[Page 14575]]
lamps with a cover for the Integrated High-Lumen product class.
Further, DOE is proposing two ELs. The baseline represents a basic CFL
with an efficacy near the existing MBCFL standard level. EL 1
represents an improved CFL with more-efficient phosphors and improved
ballast components. EL 2 is the maximum technologically feasible level
and represents the most-efficacious combination of phosphors and
ballast components.
As stated previously, DOE adopted an equation-based approach to
establish ELs for GSLs. In the preliminary analysis, DOE developed the
general form of the equation by evaluating efficacy trends of
integrated GSLs across a range of lumen outputs. The continuous
equations specified a minimum lamp efficacy requirement across the
lumen output range and represented the efficacy a lamp achieves. DOE
determined that adjustments to CSLs considered in the preliminary
analysis were necessary. DOE made slight adjustments to capture the
efficacy of lamps with those design options across the entire lumen
output range. This allowed for continuous CSLs across product classes.
DOE also found that compliance and verification testing data supported
the CSLs under consideration and therefore did not make any adjustments
to CSLs based on this additional data.
Adjustments to Efficacy Levels
DOE received comments suggesting potential adjustments to the CSLs
considered in the preliminary analysis due to lumen package
availability and testing and verification data. Southern Company
expressed concern regarding the availability and size of products with
lumen outputs in the upper end of the Integrated Low-Lumen product
class range, specifically in the 1,500 to 2,000 lumen range. Southern
Company indicated there could be issues with form factor for both CFLs
and LED lamps and a separate product class may be warranted to ensure
consumer needs are satisfied. (Southern Company, Public Meeting
Transcript, No. 29 at pp. 199-200)
For the NOPR analysis, DOE again analyzed the impacts of the ELs
across all lumen packages. In the Integrated Low-Lumen product class,
DOE confirmed that 40 W, 60 W, 75 W, and 100 W equivalent replacements,
which correspond to the four lumen bins of the current GSIL standard,
could meet the highest EL proposed (EL 4) in the NOPR analysis. DOE did
not consider ELs that were not achievable for all lumen packages within
the product class. Regarding Southern Company's concern for replacement
lamps in the range of 1,500 to 2,000 lumens, DOE identified several LED
lamps in this range (i.e., 100 W equivalent replacements) that meet the
max-tech level proposed, EL 4. Further, DOE confirmed that the form
factors of the LED lamps at EL 4 (max tech) and the CFLs available at
EL 2 (highest level a CFL can meet) are consistent with the lamps they
are intended to replace. DOE determined that the majority of the 100 W
GSILs in this lumen range are A21 shapes. DOE found that the LED lamps
meeting EL 4 are designed in the A21 form factor and the majority of
CFLs available at EL 2 are spiral shapes with dimensions that also fit
within the A21 form factor. Therefore, DOE concluded that consumers
should not experience issues with incompatible length or diameter of
replacement lamps.
In addition to lumen package, DOE also analyzed whether the full
range of CCTs were available at the highest EL proposed. In the
Integrated Low-Lumen product class, DOE made a slight downward
adjustment to EL 4 in order to ensure lamps of all CCTs were able to
meet the EL. In the Integrated High-Lumen product class, DOE made a
slight downward adjustment to EL 2 to ensure lamps of all CCTs were
available. Additionally, this adjustment allowed for higher lumen
output 100 W equivalent replacements (e.g., 1,800 lumen lamps) to meet
EL 2 in the Integrated Low-Lumen product class.
CA IOUs commented that if DOE believes that higher efficacy CFLs
would not meet CSL 2, such as if testing showed that their actual
efficacies are slightly lower than the values reported in specification
sheets or to Energy Star, they recommend that DOE include a CSL that is
specifically designed to align with these higher performance CFLs by
lowering CSL 2 slightly, or by adding a new CSL between CSLs 1 and 2.
(CA IOUs, No. 33 at p. 4; CA IOUs, Public Meeting Transcript, No. 29 at
pp. 88-89)
For the NOPR analysis, DOE used publicly available certification
data and verification testing from CEC's Appliance Efficiency Database,
EPA's ENERGY STAR Certified Light Bulbs Database, and DOE's CCMS
Database to confirm that commercially available CFLs are able to meet
EL 2. DOE found that DOE's CCMS Database supported the catalog values
of numerous lamps, and in some cases the certification and verification
data exceeded the catalog values. Thus, DOE determined that EL 2 was
achievable for CFLs.
Impacts of Efficacy Levels
In addition, DOE received several comments on the impacts of the
CSLs it presented for the Integrated Low-Lumen and Integrated High-
Lumen product classes in the preliminary analysis. NEMA commented that
placing all integrated lamps into only two categories results in CSLs
that only represent one type of technology. They are concerned that
this will cause the standards to be set too low thus allowing all
technologies, or too high thus allowing only the most efficient LED
lamps. NEMA noted that either situation would not be ideal for energy
savings, product cost/availability or utility. They recommended that a
product class matrix that separates lamps by technology be used to
mitigate these issues. (NEMA, No. 34 at p. 16)
As discussed in section V.A.1, DOE is proposing product classes
that are not separated by technology because CFLs and LED lamps offer
similar utility. Further, two of the four ELs (i.e., EL 1 and EL 2)
analyzed by DOE are met by both CFLs and LED lamps. DOE weighed the
benefits and burdens of each potential standard in order to select the
proposed standard level. See section VI.C.1 for more information.
Westinghouse remarked that the reason they there are efficacy
differences between bare and covered CFLs is because the light output
from the internal spiral is captured by the covering. Westinghouse
noted that the correct level is one that allows covered products to be
manufactured because there are applications where those are necessary.
(Westinghouse, Public Meeting Transcript, No. 29 at p. 98) As discussed
in section V.A.1, DOE was unable to find a consistent correlation
between the addition of a cover and efficacy and therefore did not
consider a product class division for lamps with covers versus without
covers. Further, LED lamps are available at higher levels of efficacy
with a cover if an application exists that necessitates a lamp with a
cover.
Regarding the standard to be proposed, CEC noted that federal
standards could have a preemptive effect and thus if less stringent,
could have negative implications on California's energy consumption.
(CEC, No. 31 at p. 2) With some exceptions, Federal energy conservation
requirements generally supersede state laws or regulations concerning
energy conservation testing, labeling, and standards. (42 U.S.C.
6297(a)-(c)) However, 42 U.S.C. 6295(i)(6)(A)(vi) states that
California or Nevada beginning on or after January 1, 2018 shall not be
precluded from adopting: (1) a final rule adopted by the Secretary in
accordance with 42 U.S.C. 6295(i)(6)(A)(i)-(iv); (2) the backstop
[[Page 14576]]
provision of 45 lm/W if no final rule has been adopted; or (3) any
California regulations for GSLs adopted pursuant to state statute in
effect as of the date of enactment of the Energy Independence and
Security Act of 2007 if no final rule is adopted.
Table V-8 summarizes the efficacy requirements at each EL for the
Integrated Low-Lumen and Integrated High-Lumen product classes. DOE
requests comment on the ELs under consideration for both of the
integrated lamp product classes, including the max-tech levels.
Table V-8--Summary of ELs for GSL Integrated Representative Product
Classes
------------------------------------------------------------------------
Representative product class Efficacy level Efficacy lm/W
------------------------------------------------------------------------
Integrated Low-Lumen (310 <= EL 1................ 67.6-29.42*0.9983[su
Initial Lumen Output < pcaret]Initial
2,000). Lumen Output.
EL 2................ 73.4-29.42*0.9983[su
pcaret]Initial
Lumen Output.
EL 3................ 101.6-29.42*0.9983[s
upcaret]Initial
Lumen Output.
EL 4................ 108.6-29.42*0.9983[s
upcaret]Initial
Lumen Output.
Integrated High-Lumen (2,000 EL 1................ 67.6-29.42*0.9983[su
<= Initial Lumen Output <= pcaret]Initial
2,600). Lumen Output.
EL 2................ 73.4-29.42*0.9983[su
pcaret]Initial
Lumen Output.
------------------------------------------------------------------------
b. Non-Integrated Lamps
In the preliminary analysis, DOE analyzed CSLs for the Non-
Integrated product class. DOE used commercially available lamps and
their associated rated efficacies to determine the design options
required to meet CSLs. For the Non-Integrated product class, DOE used
the catalog initial lumen output and the ANSI rated wattage of the
lamp, or nominal wattage if the ANSI rated wattage was not available,
to calculate efficacy. To establish final minimum efficacy requirements
for each CSL, DOE evaluated whether any adjustments were necessary to
the initial CSL to ensure lamps were available across the entire lumen
range represented by the product class.\117\
---------------------------------------------------------------------------
\117\ Id. at 2-75.
---------------------------------------------------------------------------
In the preliminary analysis, one CSL was considered for the Non-
Integrated representative product class. The baseline represented a
basic CFL with an efficacy near the lowest performing non-integrated
GSLs currently available on the market. DOE considered two
representative lamp units at CSL 1. The first representative unit at
CSL 1 was a full wattage, improved CFL with more-efficient phosphors
and thus more light output. The second representative unit at CSL 1 was
a more efficacious reduced wattage CFL that produced similar lumen
output as the baseline unit. The full wattage representative lamp unit
was used to set the minimum efficacy requirements of EL 1 because it
represented the maximum technologically feasible level that applied
across all lumen packages within the product class. The reduced wattage
CFL gave consumers the option to replace their current full wattage
lamp with one that saves energy. DOE maintained this approach for the
NOPR analysis.
As stated previously, DOE adopted an equation-based approach to
establish CSLs for GSLs in the preliminary analysis. DOE utilized a
similar approach as was used with the other product classes and
developed the general form of the equation by evaluating efficacy
trends of non-integrated GSLs across a range of lumen outputs. The
continuous equation developed specified a minimum lamp efficacy
requirement across the lumen output range and represented the efficacy
a lamp achieves.
NEMA expressed concern on how the CSL equation for non-integrated
GSLs was developed because the lamps are currently unregulated and have
no test procedure. NEMA is unaware of databases for these lamps and the
veracity of potential data. NEMA stressed that DOE cannot rely upon
catalog data to determine the efficacy of pin base CFLs. Nominal and
rated wattage are not measured watts and catalog initial lumens
represent long-term data, not individual lamp photometric performance.
Further, NEMA commented that testing laboratories may not be using the
same test methods since there is no defined test procedure for non-
integrated lamps and thus the information published in individual
manufacturers' catalogs may not be comparable. (NEMA, No. 34 at pp. 15-
16)
DOE understands the concern regarding the lack of available test
data for non-integrated CFLs; however, industry standards for testing
efficacy have been in place for several years for these products.
Therefore, manufacturers are likely using existing industry standard
test methods to determine performance values published in catalogs.
Further, catalog data are the most comprehensive data source currently
available for this product class. For these reasons, DOE maintained its
approach in the NOPR analysis of using catalog initial lumen output and
the ANSI rated wattage of the lamp, or nominal wattage if the ANSI
rated wattage was not available, to calculate efficacy and to
subsequently determine the EL. DOE notes that EPCA directs DOE to
establish test procedures for covered products in advance of
prescribing an energy conservation standard. (42 U.S.C. 6295(o)(3)(A))
Thus, DOE plans to finalize test procedures for GSLs for which DOE is
proposing standards prior to the completion of this rulemaking.
Base Type and Fixture Compatibility
In the preliminary analysis, as stated, DOE made slight adjustments
to capture the efficacy of lamps with those design options across the
entire lumen output range. In particular, DOE ensured that lamps of
different base types were represented at the CSL. DOE evaluated the
impacts of CSL 1 on the individual base types in the Non-Integrated
product class. DOE confirmed that the vast majority of base types were
still available at CSL 1, and thus consumers would not be forced to
switch between lamps with differing base types. Further, DOE concluded
that because the different bases are maintained at CSL 1 and base type
dictates the required ballast, consumers will not be required to change
ballasts. DOE also evaluated whether replacing the baseline lamp with
more efficacious substitutes at the higher CSL would require a fixture
change. DOE concluded that fixture compatibility would not be an issue
for the vast majority of consumers because the fixtures most frequently
used with the non-integrated GSLs analyzed were available in
configurations for several different lamp types thus indicating
flexibility in size.\118\
---------------------------------------------------------------------------
\118\ Id.
---------------------------------------------------------------------------
DOE received several comments pertaining to base type and fixture
requirements when replacing non-integrated GSLs. Manufacturers
expressed concern over the replacement
[[Page 14577]]
of pin base CFL system components. GE commented that pin base lamps and
their corresponding ballasts are pinned and keyed in specific ways to
deter improper replacement which can potentially result in safety and
performance issues. GE stated that due to this sophisticated safety
system, there are very few options to save energy in ballasted pin base
lamp applications. (GE, Public Meeting Transcript, No. 29 at pp. 77-78)
However, NEEA noted that, from their experience, if the base is correct
and fits into the socket, and the lumen output is in the desired range,
then the correct lamp was chosen and will work with the existing
ballast. (NEEA, Public Meeting Transcript, No. 29 at pp. 80-82) GE
agreed that if a lamp fits the key way it will likely be compatible for
most applications, however GE clarified that even if a more efficacious
replacement lamp fits in the socket, performance may be impacted. GE
noted that lamp compatibility can be affected if installed on a
different system or dimmer. For these reasons, GE stated that pin base
CFLs are often sold paired with a compatible ballast. (GE, Public
Meeting Transcript, No. 29 at pp. 82-84)
Philips added that particular lamps and ballasts must be installed
together, and thus if a lamp needs to be replaced with a more
efficacious product, the ballast also could need to be replaced.
Philips further noted that because a large percentage of these lamps
are operating in recessed can lights, it would be very difficult to
access the ballasts for replacement. (Philips, Public Meeting
Transcript, No. 29 at p. 78) Westinghouse agreed, noting that as the
ballasts are typically not field replaceable, if standards made a
certain wattage lamp unavailable, the consumer would be forced to
replace the entire fixture. (Westinghouse, Public Meeting Transcript,
No. 29 at p. 79) NEMA concluded that if the baseline non-integrated pin
base CFL would be eliminated, the unique base and pin configurations
would force consumers to replace entire fixtures resulting in stranded
assets. (NEMA, No. 34 at p. 15)
DOE understands the concerns regarding lamp and ballast
compatibility for non-integrated GSLs. DOE ensured that the more
efficacious substitutes analyzed as representative in the Non-
Integrated product class were compatible with the existing ballast
paired with the baseline lamp. DOE used publicly available ballast
specifications published by manufacturers to confirm compatibility and
to ensure a ballast replacement would not be required. For the NOPR
analysis, DOE also ensured that consumers with non-integrated GSLs
installed typically would not be forced to switch to a lamp of a
different base type by confirming that the vast majority of base types
were still available at EL 1.\119\ Additionally, DOE is not aware of a
technological reason why the base type of a non-integrated CFL would
prevent a lamp from achieving EL 1. Because DOE ensured that the vast
majority of base types were available at EL 1 and is not aware of
technological limitations for increasing the efficacy of the others,
DOE does not believe that consumers would be forced to change fixtures.
Therefore, DOE considered fixture replacement to be an unlikely
replacement scenario. Consequently, DOE did not evaluate ballast or
fixture replacement scenarios for this NOPR analysis. DOE requests
comment on the assumption that the efficacy of non-integrated CFLs can
be improved for those lamps with base types that potentially cannot
meet EL 1.
---------------------------------------------------------------------------
\119\ DOE identified three base types that are potentially
unable to meet EL 1 out of an original 26 base types. DOE believes
these lamps were typically used in fixtures, such as desk lamps or
fan fixtures, and have already transitioned to more efficacious
technologies.
---------------------------------------------------------------------------
NEMA also commented that pin base CFLs are available in either 2-
pin or 4-pin bases, corresponding to a particular socket and ballast
type. NEMA added that 2-pin lamps have an internal starter and are
designed for preheat, magnetic operation, while 4-pin lamps are
dimmable and designed for electronic ballast operation. NEMA concluded
that removing a base type reduces utility. (NEMA, No. 34 at pp. 17-18)
Westinghouse commented that there may not be 2-pin reduced wattage
replacement options compatible with existing ballasts. Westinghouse
noted there is more flexibility with 4-pin non-integrated CFLs because
these lamps can be dimmed, however using reduced wattage 2-pin
replacement options may not be technically feasible. (Westinghouse,
Public Meeting Transcript, No. 29 at pp. 74-75)
As stated previously, DOE ensured that the vast majority of base
types were maintained at EL 1, including 2-pin lamps. Further, DOE
identified reduced wattage 2-pin replacement lamps. Therefore, it is
technologically feasible for a 2-pin reduced wattage lamp to be
manufactured and operated with an existing ballast, and consumers have
the option to choose reduced wattage lamps in addition to full wattage
lamps as replacements for currently installed systems when available.
NEMA further commented that non-integrated lamps must be paired
with a unique ballast and a specific socket to electrically and
mechanically operate, and noted that DOE selected only one of these
systems to analyze despite dozens of other potential lamp and ballast
combinations included in the scope. NEMA stated that analyzing
different lamp and ballast combinations will produce different results
and will likely result in no energy savings in most cases. NEMA also
noted that non-integrated CFLs are not acceptable replacements for
traditional GSLs, and concluded that DOE should remove these lamps from
the scope of the rulemaking due to the complexity, maturity of this
product line, and limited energy savings. NEMA further commented that
while fixtures are available in configurations for various lamps types,
a particular fixture is generally configured for a lamp of a particular
base, length, and shape, with the exception or recessed cans. NEMA
added that it cannot be assumed that the lamps complying with EL 1 will
be the correct shape or have the correct base to fit into an existing
fixture. In cases where the lamp no longer fits, consumers need to
replace the entire fixture and are subsequently left with stranded
assets. NEMA further stated that while many lamps are still available
at CSL 1, these products have slightly higher lumen output at the same
wattage as the baseline and therefore have no energy savings and the
potential for over-illumination. (NEMA, No. 34 at pp. 16-18)
As discussed in section IV.C, DOE determined that the term
``compact fluorescent lamps'' is not limited to MBCFLs. DOE therefore
concluded that both integrated and non-integrated CFLs could be
considered in the GSL rulemaking. For the Non-Integrated product class,
DOE selected the most common lamp type and ballast to analyze as
representative in the engineering analysis based on manufacturer
feedback and a survey of the market. While DOE agrees that different
lamp and ballast combinations may produce varying results, DOE
determined the lamp-and-ballast system analyzed is representative of a
significant portion of the installed systems. Further, because DOE
ensured that the vast majority of base types were available at EL 1 and
that the impacts of EL 1 were consistent across lumen packages, DOE
concluded the results would be fairly consistent across different lamp
and ballast combinations. Regarding size issues, DOE analyzed the
dimensions of lamps in the Non-Integrated product class and ensured
that lamps that meet EL 1 with the same base type and shape have nearly
[[Page 14578]]
identical dimensions on average as the lamps they are replacing that do
not comply with EL 1. Because the vast majority of base types are not
being eliminated and the replacements are similar in size, DOE
concluded that the comparable form factors of the more efficacious non-
integrated GSL replacements will not require consumers to replace
entire fixtures. DOE weighs the benefits and burdens of standards in
section VI.A.
Table V-9 summarizes the efficacy requirements at EL 1 for the Non-
Integrated product class in the NOPR analysis. DOE requests comment on
the EL under consideration for the Non-Integrated product class,
including the max-tech level.
Table V-9--Summary of ELs for GSL Non-Integrated Representative Product
Class
------------------------------------------------------------------------
Representative product class Efficacy level Efficacy (lm/W)
------------------------------------------------------------------------
Non-Integrated................ EL 1............. 72.6-25.00*0.9989[sup
(310 <= Initial Lumen Output caret]Initial Lumen
<= 2,600). Output.
------------------------------------------------------------------------
6. 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. In the preliminary analysis, DOE analyzed all
product classes as representative and therefore did not scale. In this
NOPR analysis, DOE added a product class division for GSLs with standby
mode functionality and did not directly analyze the Integrated Low-
Lumen and Integrated High-Lumen product classes with standby mode
functionality. Therefore, ELs developed for the Integrated Low-Lumen
and Integrated High-Lumen product classes were scaled to obtain levels
for the Integrated Low-Lumen Standby-Mode Functionality and Integrated
High-Lumen Standby-Mode Functionality product classes.
DOE conducted standby testing and used the test data to calculate
the appropriate scaling factor. Based on test data, DOE found that
standby power consumption was 0.5 W or less for the vast majority of
lamps. (See appendix 5A of the NOPR TSD for more information on the
test results.) Therefore, DOE assumed a typical wattage constant for
standby mode power consumption of 0.5 W. This wattage was added to the
rated wattage of the non-standby mode representative units in the
Integrated Low-Lumen product class to calculate the expected efficacy
of lamps representative of the same design options but with the
addition of standby mode functionality. DOE then applied a ratio of the
recalculated efficacies (with standby mode power) divided by the
representative units' efficacies (without standby mode power) to the A-
values of the ELs for the Integrated Low-Lumen product class without
standby mode to determine the scaled ELs. Because DOE selected A-values
that resulted in continuous equations across the Integrated Low-Lumen
and Integrated High-Lumen product classes, the scaled A-values were
applicable for both product classes capable of operating in standby
mode. (See Table V-10 for scaling factors and resulting scaled ELs.)
DOE determined that for the Integrated Low-Lumen Standby-Mode
Functionality product class slight adjustments to EL 1 were necessary
to prevent backsliding from existing standard levels. DOE requests
comment on the scaling factors determined. Table V-10 shows the ELs
proposed for the Integrated Low-Lumen Standby-Mode Functionality and
Integrated High-Lumen Standby-Mode Functionality product classes.
Table V-10--Summary of Scaled ELs for GSL Standby Mode Non-Representative Product Class
----------------------------------------------------------------------------------------------------------------
Efficacy (lm/W)
----------------------------------
Product class Efficacy level Lumens Capable of A-value
No standby mode operating in reduction
standby mode
----------------------------------------------------------------------------------------------------------------
Integrated-Low Lumen........ EL 1........... Initial Lumen 67.6-29.42*0.99 65.1-29.42*0.99 3.7
Output < 877. 83[supcaret]In 83[supcaret]In N/A
877 <= Initial itial Lumen itial Lumen N/A
Lumen Output < Output. Output. 3.7
900. 67.6-29.42*0.99 1/15 * Initial
900 <= Initial 83[supcaret]In Lumen Output.
Lumen Outputs itial Lumen 60.............
<= 1030. Output. 65.1-29.42*0.99
1030 < Initial 67.6-29.42*0.99 83[supcaret]In
Lumen Output < 83[supcaret]In itial Lumen
2,000. itial Lumen Output.
Output.
67.6-29.42*0.99
83[supcaret]In
itial Lumen
Output.
EL 2........... 310 <= Initial 73.4-29.42*0.99 70.5-29.42*0.99 4.0
Lumen Output < 83[supcaret]In 83[supcaret]In
2,000. itial Lumen itial Lumen
Output. Output.
EL 3........... 310 <= Initial 101.6-29.42*0.9 96.0-29.42*0.99 5.6
Lumen Output < 983[supcaret]I 83[supcaret]In
2,000. nitial Lumen itial Lumen
Output. Output.
EL 4........... 310 <= Initial 108.6-29.42*0.9 102.2-29.42*0.9 5.9
Lumen Output < 983[supcaret]I 983[supcaret]I
2,000. nitial Lumen nitial Lumen
Output. Output.
Integrated-High Lumen....... EL 1........... 2,000 <= 67.6-29.42*0.99 65.1-29.42*0.99 3.7
Initial Lumen 83[supcaret]In 83[supcaret]In
Output <= itial Lumen itial Lumen
2,600. Output. Output.
EL 2........... 2,000 <= 73.4-29.42*0.99 70.5-29.42*0.99 4.0
Initial Lumen 83[supcaret]In 83[supcaret]In
Output <= itial Lumen itial Lumen
2,600. Output. Output.
----------------------------------------------------------------------------------------------------------------
[[Page 14579]]
D. Product Price Determination
Typically, DOE develops manufacturing selling prices (MSPs) for
covered products and applies markups to create consumer prices to use
as inputs to the LCC analysis and NIA. Because GSLs are difficult to
reverse-engineer (i.e., not easily disassembled), DOE directly derives
consumer prices for the lamps covered in this rulemaking. Consumer
price refers to the product price a consumer pays before tax and
installation. Because non-integrated CFLs operate with a ballast in
practice, DOE also developed prices for ballasts that operate those
lamps.
In the preliminary analysis, DOE reviewed and used publicly
available retail prices to develop consumer prices for GSLs. In its
review, DOE observed a range of consumer prices paid for a lamp,
depending on the distribution channel through which the lamp was
purchased. Specifically, DOE identified the following four main
distribution channels: Small Consumer-Based Distributors (i.e.,
Internet retailers); Large Consumer-Based Distributors: (i.e., home
centers); Electrical Distributors; and State Procurement.\120\
---------------------------------------------------------------------------
\120\ GSL preliminary analysis at 6-2.
---------------------------------------------------------------------------
For each distribution channel, DOE calculated an aggregate price
for the representative lamp unit at each EL using the average prices
for the representative lamp unit and similar lamp models. Because the
lamps included in the calculation were equivalent to the representative
lamp unit in terms of performance and utility (i.e., had similar
wattage, CCT, bulb shape, base type, CRI), DOE considered the pricing
of these lamps to be representative of the technology of the EL. DOE
developed average consumer prices for the representative lamp units
sold in each of the four main distribution channels identified. DOE
then calculated an average weighted consumer price using estimated
shipments through each distribution channel. To determine prices for
CFL ballasts, DOE compared the blue book prices of CFL ballasts to
comparable fluorescent lamp ballasts and developed a scaling factor to
apply to the consumer prices of the fluorescent lamp ballasts developed
in the 2011 Ballast Rule. DOE received several comments on its pricing
methodology and results.
1. Price Weightings
DOE received several comments regarding the application of sales
weightings and the assessment of lamps sold in multi-packs. NEEA noted
that the per-lamp price is lower when lamps are sold in multi-packs and
pointed out that if DOE had accounted for the higher shipment volumes
of these products, DOE's consumer prices would be lower. (NEEA, Public
Meeting Transcript, No. 29 at pp. 153-154) NWPCC and the Appliance
Standards Awareness Project (ASAP) agreed that weighting prices using
sales volume, instead of averaging prices based on the number of
products on store shelves, would result in lower consumer prices.
(NWPCC, Public Meeting Transcript, No. 29 at p. 154; ASAP, Public
Meeting Transcript, No. 29 at p. 112-113) Westinghouse added that only
averaging the prices of lamps sold in single- and multi-packs would
allow outliers to disproportionately affect the results. Due to the
frequency of large pricing disparities for the same lamp type,
Westinghouse stated that outliers would need to be appropriately
weighted. (Westinghouse, Public Meeting Transcript, No. 29 at pp. 114-
115) EEAs and NRDC recommended that DOE modify its analysis to weight
each lamp equally, meaning the cost of an individual lamp sold in a
pack of four is counted four times and the cost of a lamp sold singly
is counted once. While they did not have specific data, EEAs expected
multi-packs to sell in higher volume than single-packs due to their
increased value per bulb. (EEAs, No. 32 at p. 12; NRDC, Public Meeting
Transcript, No. 29 at pp. 117-118) ASAP requested clarification on how
DOE dealt with pricing from single- and multi-packs of the same lamp.
(ASAP, Public Meeting Transcript, No. 29 at p. 112-113)
In the preliminary analysis, DOE did not weight the price per lamp
by the number of lamps contained in its packaging or by sales data of
that lamp. However, DOE agrees with the stakeholders' recommendation
regarding package weighting, and in the NOPR analysis, DOE weighed each
lamp price by the number of lamps with which it was sold. For example,
if a lamp is sold in a single-pack for $1 and is sold also in a multi-
pack of four lamps for $3, then one $1 lamp and four $0.75 lamps were
used to create an average price. DOE did not include an additional
weighting factor to reflect sales volume because the package-weighting
factor described above already reflects sales volume; CFLs are most
commonly offered in multi-packs, whereas LED lamps are most commonly
offered in single-packs.
DOE also received comments on the distribution channel weightings
used in the preliminary analysis. GE and CA IOUs agreed with DOE's
approach of analyzing typical prices from different sales channels and
weighting them according to the portion of the market that uses those
channels. GE stated that they have not specifically reviewed
distribution channel percentages or exact sales data, but agreed that
DOE's estimated percentage of shipments through each channel seemed
reasonable. (GE, Public Meeting Transcript, No. 29 at p. 111) CA IOUs
agreed with DOE's decision to give the most weighting to the Large
Consumer-Based Distributors channel. (CA IOUs, No. 33 at p. 5)
In the preliminary analysis, DOE identified four main distribution
channels for GSLs and applied weightings based on estimated shipments
through each channel. DOE used different shipment percentages for
integrated lamps and non-integrated lamps because integrated lamps are
more commonly residential products, while non-integrated lamps are more
commonly commercial products. In the preliminary analysis, for the
integrated lamps, DOE applied a 10 percent weighting to the Small
Consumer-Based Distributors channel, 75 percent to the Large Consumer-
Based Distributors channel, 10 percent to the Electrical Distributors
channel, and 5 percent to the State Procurement channel.\121\ In the
NOPR analysis, DOE modified these percentages slightly by applying 80
percent to the Large Consumer-Based Distributors channel and 5 percent
to the Electrical Distributors channel. As these lamps are sold mainly
to the residential market, DOE determined the electrical distributors
likely comprise a lesser share and the large consumer-based
distributors likely have a higher share of shipments than estimated in
the preliminary analysis.
---------------------------------------------------------------------------
\121\ Id. at 6-3.
---------------------------------------------------------------------------
2. CFL Prices in the Integrated Low-Lumen Product Class
DOE received comments regarding the consumer prices for ELs
represented by CFLs in the Integrated Low-Lumen product class. NRDC
questioned why DOE's consumer price for the baseline level representing
a CFL was $6.00, when the price of such lamps is $1.50 or $2.00 when
sold in multi-packs at big box stores, which are part of the highest
weighted distribution channel in DOE's analysis. (NRDC, Public Meeting
Transcript, No. 29 at p. 107) Southern Company stated that there are
differences in utility between a covered and a bare CFL and suggested
that DOE establish different product classes for the two lamp types in
order to avoid having a baseline level more expensive than CSL1.
(Southern Company, Public
[[Page 14580]]
Meeting Transcript, No. 29 at pp. 108-109)
In the preliminary analysis, the representative lamp unit at the
baseline was a 14 W covered CFL, and the representative lamp at CSL 1
was a 13 W bare (spiral) CFL in the Integrated Low-Lumen product class.
Covered CFLs are priced higher than bare CFLs, resulting in a higher
price in the preliminary analysis at the baseline than at CSL 1. In
this NOPR analysis, DOE continued to not establish product classes
based on lamp cover but evaluated a 14 W bare CFL as the representative
lamp unit at the baseline. (See section V.A.1 for further details
regarding product classes and section V.C.4 for further details on
representative units.) With this update, in the NOPR analysis the
consumer price at the baseline and CSL 1 are, respectively, $2.27 and
$2.71.
3. LED Lamp Prices in the Integrated Low-Lumen Product Class
Southern Company suggested that the inclusion of different types of
LEDs were causing confusion in the pricing analysis. Specifically,
Southern Company noted that directional LED products tend to be more
expensive than omnidirectional LED lamps, and comparing their prices
directly would be problematic as directional LED lamp products might
not be usable in all applications. (Southern Company, Public Meeting
Transcript, No. 29 at pp. 154-155)
When determining consumer prices for an EL, DOE used prices for
representative lamp units or similar lamps at that EL. DOE ensured that
similar lamps had the same characteristics (e.g., wattage, CCT, bulb
shape, base type, CRI) that made them equivalent in terms of
performance and utility. For the Integrated Low-Lumen product class,
all representative lamp units were omnidirectional lamps, and therefore
DOE did not use any prices for directional LED lamps in the pricing
analysis.
For the Integrated Low-Lumen product class, DOE's preliminary
analysis results showed prices of LED lamps decreasing as efficacy
increased.\122\ Stakeholders provided feedback on this price trend.
NRDC and EEAs noted that LED lamps are becoming more efficacious and
less expensive at the same time, which is not typical. NRDC explained
that as an individual LED package becomes more efficacious, not as many
of them are required to produce the needed light output and the size of
the heat sink and other components can be reduced, allowing for a
smaller form factor and lower overall cost. (NRDC, Public Meeting
Transcript, No. 29 at pp. 98-99; EEAs, No. 32 at p. 4)
---------------------------------------------------------------------------
\122\ Id.
---------------------------------------------------------------------------
Several stakeholders pointed out that the rapid turnover in LED
product offerings on the market may be affecting the LED price trend
presented in the preliminary analysis. Philips stated that it did not
make sense that products that were more efficacious would have a lower
cost or that consumers would purchase less efficacious products at a
higher cost. Philips suggested that because the LED market is so
dynamic, robust data cannot be generated and DOE's use of older data
points is skewing the analysis. (Philips, Public Meeting Transcript,
No. 29 at pp. 188-189) NEMA explained that LED product development
results in surges of new products rather than the continuous evolution
that is more typical of other technologies. Therefore, even though an
abundance of data might be available, lamps that are a year old are
already obsolete. (NEMA, Public Meeting Transcript, No. 29 at pp. 155-
156) EEAs noted that the prices shown in the examples for CSL 2 and CSL
3 reflected products that were being discontinued and replaced by new,
more efficacious products that were also less expensive than the prior
versions. (EEAs, No. 32 at p. 12) NRDC commented that the high price at
CSL 2 could be because it was an older model. (NRDC, Public Meeting
Transcript, No. 29 at pp. 160-161)
DOE uses the most current prices available at the time of analysis
to develop average prices for each EL. Based on the data collected for
the preliminary and NOPR analyses, DOE has noted a trend showing that
lower wattage, more efficacious LED lamps have lower prices than higher
wattage, less efficacious LED lamps. As stakeholders indicated, and
manufacturers confirmed in interviews, manufacturers begin to phase out
their less efficacious LED products as they introduce products that are
more efficacious. The low volume and older technology of the less
efficacious products likely results in higher prices. Hence, the trend
of decreasing prices for more efficacious LED lamps results from the
following combination of factors: (1) The ability to make LED lamps
more efficacious at a lower cost and (2) the low volume and
subsequently higher prices of the less efficacious lamps. DOE
consistently found this decreasing LED lamp price trend in the pricing
data collected for the preliminary analysis and in the updated pricing
data collected for the NOPR analysis.
NEMA stated that the short market exposure and high rate of
innovation for LED lamps has resulted in strong price reductions with
large technology improvements, such that families of LED lamp products
are only now evolving in a linear method similar to other mature lamp
technologies. Hence, it is incorrect to compare prices of lamps for
sale today with lamps for sale a few years ago because the latest lamp
is a new design incomparable to the older version of the lamp. Noting
that DOE's typical analysis model examined mature products with
incremental improvements, NEMA suggested DOE redesign the price model
for LED lamps to recognize this phenomenon. (NEMA, No. 34 at pp. 18-19)
CA IOUs also commented on DOE's pricing model, suggesting that,
given the extremely fast rate of price reductions in the LED market,
DOE should use forecasted 2020 pricing estimates, rather than utilizing
current 2014 pricing. (CA IOUs, No. 33 at p. 5) CA IOUs stated that the
prices DOE estimated for LED lamps were too high, especially when
considering what the price of the lamps would be in 2020, the first
year of compliance. To support this assertion, CA IOUs provided DOE
with graphs of online retail price data \123\ collected between
December 2013 and January 2015 along with projections up to December
2017. CA IOUs stated that according to DOE's findings during the recent
GSFL and IRL standards rulemaking (80 FR 4041 [Jan. 26, 2015]), on
average, online pricing is generally higher than in-store pricing,
suggesting that if anything, those average prices collected by CA IOUs
should overestimate the prices for most end users. CA IOUs stated that
DOE forecasted the consumer price to be $28.12 ($35.26/kilolumen \124\)
for CSL 2,
[[Page 14581]]
when CA IOUs' data suggest that such products are currently below $30/
kilolumen, and projected prices to be below $10/kilolumen within two
years. Similarly, for CSL 3, CA IOUs stated that DOE forecasted the
consumer price to be $18.02 ($22.53/kilolumen), when CA IOUs' data
suggest that such products are currently approximately $17/kilolumen.
For CSL 4 and CSL 5, CA IOUs stated that DOE's forecasted prices were
around $13-14 ($17-18/kilolumen), when the CA IOUs' data suggest that
they are currently that low. (CA IOUs, No. 33 at p. 8, 11-13) NRDC
stated DOE's consumer price of $15.28 (with sales tax) at CSL 4, which
hypothetically reflects a typical 60 W LED replacement lamp, is too
high and such lamps are $10.00 or less at big box stores. (NRDC, Public
Meeting Transcript, No. 29 at pp. 151-152) Further, CA IOUs projected
that current prices will drop by 30 to 70 percent in the next two years
and the most-efficacious products will see the fastest price
reductions. They asked DOE to revisit their assumptions for LED lamp
price forecasts and to lower them based on this information. (CA IOUs,
No. 33 at p. 8, 11-13)
---------------------------------------------------------------------------
\123\ CA IOUs collected over 40,000 unique price points, for LED
replacement lamps over 300 lumens, retrieved at regular intervals
between December 2013 and January 2015 from HomeDepot.com,
Lowes.com, Acehardware.com, Costco.com, 1000bulbs.com, bulbs.com,
and several others. CA IOUs provided three graphs of these data,
presenting the average online pricing by EL, along with estimated
future pricing developed by applying exponential growth to the data.
One graph showed data for all LED replacement lamps over 300 lm
(including A, G, PAR, BR, MR, decorative, and downlight lamp
shapes), the second showed data for only A-shaped lamps over 300
lumens, and the third showed data for A-shaped lamps between 700 and
1100 lm. CA IOUs also provided a cross-section of price points
collected on January 8, 2015, for LED A-shaped lamps between 700 and
1100 lm, with efficacies above 80 lm/W and price data from
flikart.com of high and low power factor CFLs. These graphs are
available in CA IOUs' public comment on regulations.gov under docket
number EERE-2013-BT-STD-0051-0033.
\124\ Derived by CA IOUs by dividing the consumer prices
developed by DOE in the preliminary analysis by 0.8 based on an 800-
lumen lamp.
---------------------------------------------------------------------------
In the preliminary analysis, DOE did not modify prices in the
product price determination based on developments in LED technology
that have not yet occurred, but rather used the latest pricing data
available at the time of the analysis to determine consumer prices. DOE
determined the full price of lamps at each EL rather than pricing
incremental design improvements. DOE understands that there may be
differences in the design of an LED lamp from one year to the next.
However, these changes in design, and the effect they have on the
overall lamp price, is unknown. DOE is aware that LED technology is
expected to improve over the next several years, but there is no
guarantee that a reduction in the price of an LED will be immediately
accompanied by a decrease in the price of the lamp in which it is
incorporated. Manufacturers may change other aspects of the lamp at the
same time, such as improving the light distribution or adding features
to enable connectivity. DOE acknowledges that, during interviews,
manufacturers indicated they were focusing their development efforts on
reducing the price of LED lamps to encourage widespread adoption. To do
so, manufacturers expected to eliminate features valued by consumers,
such as the ability to dim and long lifetimes. In this rulemaking, DOE
analyzes and determines corresponding prices for LED lamps that
maintain consumer utility. As described in section V.C.5, DOE has
ensured the availability of features valued by consumers at the highest
analyzed EL.
DOE updated its pricing analysis for the NOPR using the most recent
available prices for actual LED lamps being sold on the market. DOE
also reviewed in detail the data and graphs provided by CA IOUs. In
comparison to the price data CA IOUs collected, DOE's updated pricing
analysis in the NOPR shows lower prices for levels represented by LED
lamps. Specifically, DOE determined that the average weighted price for
EL 2 (representing a 12 W LED lamp at 66.7 lm/W) is $14.10 (2015$) and
the average weighted price decreases at higher efficacy levels with the
max-tech lamp at $9.33. DOE also notes that the NIA applies a price-
learning factor, which results in even lower prices in future years as
shipments of LED lamps increase in volume. (See section V.H for further
details.)
E. Energy Use Analysis
The purpose of the energy use analysis is to determine the annual
energy consumption of GSLs at different efficacies in representative
U.S. single-family homes, multi-family residences, and commercial
buildings, and to assess the energy savings potential of increased GSL
efficacy. To develop annual energy use estimates, DOE multiplied GSL
input power by the number of hours of use (HOU) per year and a factor
representing the impact of controls. The energy use analysis estimates
the range of energy use of GSLs in the field (i.e., as they are
actually used by consumers) and provides the basis for other analyses
DOE performs, particularly assessments of the energy savings and the
savings in consumer operating costs that could result from adoption of
new or amended standards.\125\
---------------------------------------------------------------------------
\125\ GSL preliminary analysis at 7-1.
---------------------------------------------------------------------------
1. Operating Hours
a. Residential Sector
To determine the average HOU of GSLs in the residential sector, DOE
collected data from a number of sources. Consistent with the approach
taken in the preliminary analysis, DOE used data from various regional
field-metering studies of GSL operating hours conducted across the U.S.
DOE determined the regional variation in average HOU using average HOU
data from the regional metering studies, all of which are listed in the
energy use chapter (chapter 7 of the NOPR TSD). DOE determined the
average HOU for each EIA Residential Energy Consumption Survey (RECS)
reportable domain (i.e., state, or group of states).\126\ For regions
without HOU metered data, DOE used data from adjacent regions.
---------------------------------------------------------------------------
\126\ U.S. Department of Energy-Energy Information
Administration. 2009 RECS Survey Data. (Last accessed June 9, 2015.)
http://www.eia.gov/consumption/residential/data/2009/.
---------------------------------------------------------------------------
In the preliminary analysis, DOE assumed that GSL operating hours
do not vary by light source technology.\127\ The reasoning was as
follows: because section 313 of the Appropriations Rider states that
none of the funds made available by the Act may be used to implement or
enforce standards for GSILs, intermediate-base incandescent lamps and
candelabra base incandescent lamps, DOE did not consider these lamps in
its analyses. Furthermore, because these lamps are not included in the
scope of this rulemaking, in the preliminary analysis DOE assumed that
a potential GSL final rule would not yield sufficient energy savings to
avoid triggering the EISA 2007 backstop. Therefore, DOE assumed that
the EISA 2007 backstop will go into effect on January 1, 2020. DOE
assumed that the compliance date for a potential final GSL rule would
be concurrent with the compliance date for the EISA 2007 backstop. (See
42 U.S.C. 6295(i)(6)(A)(ii), (i)(6)(A)(iii) and (i)(6)(A)(v)) Thus,
during the analysis period, DOE assumed that CFL and LED GSLs would
fill all sockets currently filled by GSLs. Although some metering
studies have observed higher hours of operation for CFL GSLs compared
to incandescent/halogen GSLs--such as NMR Group, Inc.'s Northeast
Residential Lighting Hours-of-Use Study\128\--DOE assumed that the
higher HOU found for CFL GSLs is based on those lamps currently
disproportionately filling sockets with higher HOU. This would not be
the case during the analysis period, when CFL and LED GSLs are expected
to fill all GSL sockets. This assumption was equivalent to assuming no
rebound in operating hours as a result of more efficacious technologies
filling sockets currently filled by less efficacious technologies prior
to, or as a result of, the EISA 2007 backstop. Additionally, operating
hours were assumed to be equivalent for CFL and LED GSLs in the
reference scenario. In other words, the reference scenario assumed no
rebound
[[Page 14582]]
as a result of a potential GSL energy conservation standard.
---------------------------------------------------------------------------
\127\ GSL preliminary analysis at 7-1.
\128\ NMR Group, DNV GL. Northeast Residential Lighting Hours-
of-Use Study. May 5, 2014. Prepared for Connecticut Energy
Efficiency Board, Cape Light Compact, Massachusetts Energy
Efficiency Advisory Council, National Grid Massachusetts, National
Grid Rhode Island, New York State Energy Research and Development
Authority. (Last Accessed August 22, 2014.)
---------------------------------------------------------------------------
Regarding the set of lamps potentially subject to the backstop,
Southern Company requested that DOE consider including exemptions for
space-constrained products with high-lumen output because consumer
utility will be eliminated unless LED technology improves fast enough
to cover those applications by the time the backstop takes effect.
(Southern Company, Public Meeting Transcript, No. 29 at pp. 131-132)
Earthjustice stated that EPCA's backstop requirement applies to all
lamps that DOE deems GSLs, even if said lamps are not covered in the
scope of this rulemaking (e.g., high-lumen lamps). (Earthjustice, No.
30 at pp. 3-4) EEAs and the California Investor-Owned Utilities (CA
IOUs) disagreed with DOE's interpretation of the Appropriations Rider,
but agreed with DOE's assumption that not including GSILs in the scope
of this rulemaking will cause the backstop to come into effect. (EEAs,
No. 32 at p. 2; CA IOUs, No. 33 at pp. 1-2) Conversely, NEMA disagreed
with DOE's assumption that the backstop will be triggered, stating that
rapid LED adoption and innovation will bring the energy consumption of
the mix of GSLs by January 1, 2020 below that of the energy consumption
assuming all GSLs at January 1, 2020 had an efficiency of 45 lm/W.
(NEMA, No. 34 at pp. 20-21).
As discussed previously, due to the Appropriations Rider, DOE is
not considering GSILs, including exclusions or exemptions, in this
rulemaking. Under 42 U.S.C. 6295(i)(6)(A)(v), if DOE fails to (1)
complete a rulemaking in accordance with clauses (i) through (iv),
which includes determining whether the exemptions for certain
incandescent lamps should be maintained or discontinued, or (2) publish
a final rule that will meet or exceed the energy savings associated
with the EISA 2007 45 lm/W backstop, then the backstop will be
triggered beginning January 1, 2020. Therefore DOE assumes that the
backstop will be triggered beginning January 1, 2020. Thus, as in the
preliminary analysis, for the NOPR analysis DOE assumes that the
compliance date for a potential final GSL rule would be simultaneous
with the compliance date for the EISA 2007 backstop. DOE requests
comment on its assumption that the EISA 2007 backstop will be triggered
(see issue 25 in section VIII.E).
Southern Company disagreed with DOE's assumption that more
efficacious GSLs do not have higher operating hours than less
efficacious GSLs. (Southern Company, Public Meeting Transcript, No. 29
at p. 123) NEMA agreed with Southern Company, citing increased consumer
convenience in using long-lived, more efficacious lamps in sockets with
higher HOU (due to less lamp replacements), as well as the energy
savings associated with using lower-wattage lamps in the most-used
sockets. (NEMA, No. 34 at pp. 19-20) NRDC highlighted the complexity
involved in estimating operating hours for GSLs and supported the 2.3
hours per day average estimated by DOE in the preliminary analysis.
(NRDC, Public Meeting Transcript, No. 29 at pp. 130-131)
DOE agrees that, currently, consumers are likely to place more
efficacious, longer-lived GSLs in the most-used sockets, especially if
the efficacies or lifetimes of the lamps differ greatly. However, DOE
does not believe this effect to be substantial in the case of replacing
a CFL with an LED lamp. Because DOE's analyses assume no GSLs with
efficacy below 45 lm/W are shipped during the analysis period, CFL and
LED lamps represent the only GSLs on the market. Therefore, as in the
preliminary analysis, for the NOPR analysis DOE assumed that GSL
operating hours do not vary by light source technology. Based on the
methodology described in this section and in further detail in chapter
7 of the NOPR TSD, DOE estimated the national weighted-average HOU of
GSLs in the residential sector to be 2.3 hours per day.
To estimate the variability in GSL HOU by room type, DOE developed
HOU distributions for each room type using data from NEEA's Residential
Building Stock Assessment Metering Study (RBSAM),\129\ a metering study
of 101 single-family houses in the Northwest. DOE assumed that the
shape of the HOU distribution for a particular room type would be the
same across the United States, even if the average HOU for that room
type varied by geographic location. To determine the distribution of
GSLs by room type, DOE used data from NEEA's 2011 RBSAM for single-
family homes,\130\ which included GSL room-distribution data for more
than 1,400 single-family homes throughout the Northwest.
---------------------------------------------------------------------------
\129\ Ecotope Inc. Residential Building Stock Assessment:
Metering Study. 2014. Northwest Energy Efficiency Alliance: Seattle,
WA. Report No. E14-283. (Last accessed June 15, 2015.) http://
neea.org/docs/default-source/reports/residential-building-stock-
assessment--metering-study.pdf?sfvrsn=6.
\130\ Northwest Energy Efficiency Alliance. 2011 Residential
Building Stock Assessment Single-Family Database. (Last accessed
June 29, 2015.) http://neea.org/resource-center/regional-data-resources/residential-building-stock-assessment.
---------------------------------------------------------------------------
For more details on the methodology DOE used to estimate the HOU
for GSLs in the residential sector, see chapter 7 of the NOPR TSD. DOE
requests comment on the data and methodology used to estimate operating
hours for GSLs in the residential sector, as well as on the assumption
that GSL operating hours do not vary by light source technology (see
issue 26 in section VIII.E).
b. Commercial Sector
DOE determined the HOU for GSLs in commercial buildings using
lighting data for 15 commercial building types obtained from the 2010
U.S. Lighting Market Characterization (LMC).\131\ For each commercial
building type presented in the LMC, DOE determined average HOU based on
the fraction of installed lamps utilizing each of the light source
technologies typically used in GSLs and the HOU for each of these light
source technologies. DOE estimated the national-average HOU for the
commercial sector by weighting the building-specific HOU for GSLs by
the relative floor space of each building type as reported in in the
2003 EIA Commercial Buildings Energy Consumption Survey (CBECS).\132\
The national weighted-average HOU for GSLs in the commercial sector
were estimated at 10.7 hours per day.
---------------------------------------------------------------------------
\131\ Navigant Consulting, Inc. Final Report: 2010 U.S. Lighting
Market Characterization. 2012. U.S. Department of Energy. (Last
accessed June 10, 2015.) http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf
\132\ U.S. Department of Energy-Energy Information
Administration. 2003 CBECS Survey Data. (Last accessed June 9,
2015.) http://www.eia.gov/consumption/commercial/data/2003/index.cfm?view=microdata.
---------------------------------------------------------------------------
To capture the variability in HOU for individual consumers in the
commercial sector, DOE used data from NEEA's 2014 Commercial Building
Stock Assessment (CBSA).\133\ DOE invites comments and data on its
approach to account for variability in HOU in the commercial sector
(see issue 27 in section VIII.E). For further details on the commercial
sector operating hours, see chapter 7 of the NOPR TSD.
---------------------------------------------------------------------------
\133\ Northwest Energy Efficiency Alliance. Commercial Building
Stock Assessment 2014. (Last accessed June 26, 2015.) http://neea.org/resource-center/regional-data-resources/commercial-building-stock-assessment.
---------------------------------------------------------------------------
2. Input Power
The input power used in the energy use analysis is the input power
presented in the engineering analysis (chapter 5 of the NOPR TSD) for
the representative lamps (or lamp-and-ballast systems) at each EL for
each of
[[Page 14583]]
the three representative product classes considered in this rulemaking:
Integrated Low-Lumen, Integrated High-Lumen, and Non-Integrated GSLs.
3. Lighting Controls
For GSLs that operate with controls, DOE assumed an average energy
reduction of 30 percent in the preliminary analysis. This estimate was
based on a meta-analysis of field measurements of energy savings from
commercial lighting controls by Williams, et al.\134\ Because field
measurements of energy savings from controls in the residential sector
are very limited, DOE assumed that controls would have the same impact
as in the commercial sector.
---------------------------------------------------------------------------
\134\ Williams, A., B. Atkinson, K. Garbesi, E. Page, and F.
Rubinstein. Lighting Controls in Commercial Buildings. LEUKOS. 2012.
8(3): pp. 161-180.
---------------------------------------------------------------------------
NEEA suggested that lighting controls do not necessarily translate
into real energy savings; however, DOE notes that its energy savings
estimate from controls are based on a meta-analysis of commercial
building controls studies indicating an average savings of 30 percent
for lamps on controlled sockets. (NEEA, Public Meeting Transcript, No.
29 at pp. 125, 138-139)
NRDC contended that DOE's assumption of energy savings from
controls in the residential sector should be lower, because DOE based
this assumption on data collected on commercial buildings, which have
different control systems. (NRDC, Public Meeting Transcript, No. 29 at
p. 136) ASAP requested DOE review the data to see if manual and central
control types were accounted for separately, and if so, to use the
energy savings from manual controls for the residential sector. (ASAP,
Public Meeting Transcript, No. 29 at p. 137) General Electric noted
that residential dimming is in general much more variable than dimming
in the commercial sector, where lights are not dimmed to very low
levels. (General Electric Lighting, Public Meeting Transcript, No. 29
at pp. 139-140)
The meta-analysis DOE used to base its assumption of 30-percent
energy savings from lighting controls does provide energy savings
estimates for individual control types (including manual controls);
however, it is unclear that manual lighting controls in commercial
buildings would be used in the same manner as manual controls in
residences. DOE was able to find a single study that looked at the
energy savings of controls in the residential sector,\135\ which
suggested that energy savings from dimming may be larger than 30
percent in the residential sector. However, because of the very small
sample size of this study (the findings were based on metered data from
two houses in California), DOE did not base its analysis on the
findings of this study.
---------------------------------------------------------------------------
\135\ Consortium for Energy Efficiency. Residential Lighting
Controls Market Characterization. Available at: http://library.cee1.org/sites/default/files/library/11458/CEE_LightingMarketCharacterization.pdf.
---------------------------------------------------------------------------
NEMA supported DOE's assumption of 30-percent energy savings for
GSLs on controls in the residential sector, but suggested DOE use 5-
percent energy savings for pin base GSLs in the commercial sector.
(NEMA, No. 34 at pp. 21-22) DOE found no data indicating the energy
savings from controls for commercial pin base fluorescent GSLs is less
than 30 percent. DOE also believes that the majority of the lamps
measured in the studies considered by the lighting controls meta-
analysis were pin base fluorescent lamps. The meta-analysis found an
average energy savings from controls of approximately 30 percent;
therefore, DOE does not believe the available data indicate only 5-
percent energy savings from controls in the commercial sector for pin
base fluorescent GSLs. Therefore, DOE has maintained its assumption of
30-percent energy savings from lighting controls in both the
residential and commercial sectors for all lamp technologies. DOE
requests comment on the energy reduction estimate of 30 percent, as
well as data and information on the energy use implications of using
dimmers in the residential sector (see issue 28 in section VIII.E).
Southern Company stated that the data on energy savings from
controls are likely to come from regions with strong energy efficiency
programs, which systematically biases estimated energy savings from
controls to be larger than they actually are. (Southern Company, Public
Meeting Transcript, No. 29 at pp. 141-142) In response, NEEA indicated
that DOE's estimate may be appropriately representative. (NEEA, Public
Meeting Transcript, No. 29 at pp. 142-143) The meta-analysis DOE used
to estimate savings from controls does not provide information on the
geographic representativeness of the analyzed data; however, DOE notes
that even if the existence of requirements for controls is linked to
regions with strong energy efficiency programs, it is not clear that
this would translate into any impact on the usage of controls once
installed or indicate that savings from controls in such regions are
overestimated.
Philips expressed concern with DOE's assumption that the HOU for
GSLs in 2020 will be the same as the current HOU, and highlighted
building standards requiring more controls to support this concern.
(Philips, Public Meeting Transcript, No. 29 at pp. 123-124) NEMA agreed
with DOE's assumption that there are few dimmable CFLs and that the
percentage of dimmable LEDs is expected to be higher. (NEMA, No. 34 at
p. 21) NEMA added that because of building and energy codes, it is
reasonable to assume that most commercial floor space will have
controls of various types. (NEMA, No. 34 at p. 27)
In its reference scenario, DOE assumed an increase in commercial
floor space utilizing controls, with the increase being driven by
building codes. Furthermore, while DOE's reference scenario assumes a
constant 14 percent of residential GSLs operate on controls external to
the lamp for all light source technologies, DOE has also analyzed an
alternative scenario in the LCC and national impact analyses in which
the fraction of GSLs operated with such controls \136\ increases to 50
percent by the end of the analysis period (see appendices 8B and 10E of
the NOPR TSD). Rather than disaggregate the impact of controls between
a reduction in HOU and a reduction in input power, DOE has attributed a
30-percent reduction in energy use for all GSLs that operate with
controls. DOE also notes that in the NOPR analyses, although it
continues to assume that 5 percent of CFLs are dimmable, the fraction
of CFLs and LEDs that are used with controls external to the lamp is
assumed to be the same (14 percent in the reference case) in the
residential sector, due to residential code requirements for non-
dimming lighting controls such as vacancy sensors.\137\ DOE requests
comment on this assumption (see issue 29 in section VIII.E). Chapter 7
of the NOPR TSD provides details on DOE's energy use analysis for GSLs.
---------------------------------------------------------------------------
\136\ In the energy use and LCC analyses, DOE did not consider
smart lamps, as the product class containing such lamps is a non-
representative product class and DOE presents energy use and LCC
results for representative product classes only. Smart lamps are
considered in the national impact analysis.
\137\ Lutron Electronics Co., Inc. Illuminating the Title 24
2013 Residential Lighting Requirements. 2014. (Last accessed June
29, 2015.) http://www.lutron.com/TechnicalDocumentLibrary/Illuminating_Title_24%20_2013_Resi_Lighting_Requirements.pdf.
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F. Life-Cycle Cost and Payback Period Analysis
DOE conducted LCC and PBP analyses to evaluate the economic impacts
on individual consumers of potential energy conservation standards
[[Page 14584]]
for GSLs. The effect of new or amended energy conservation standards on
individual consumers usually involves a reduction in operating cost and
an increase in purchase cost. DOE used the following two metrics to
measure consumer impacts:
The LCC is the total consumer expense of an appliance or
product over the life of that product, consisting of total installed
cost (product price, sales tax, and installation costs) plus operating
costs (expenses for energy use, maintenance, and repair) and any
applicable disposal costs. When computing operating costs or disposal
costs, DOE discounts future costs to the time of purchase and sums them
over the lifetime of the product. For products with lifetimes greater
than the LCC analysis period (the lifetime of the shortest-lived
product in each product class), DOE also accounts for their residual
value, which is applied as a credit in the calculation of the LCC.
The PBP (payback period) is the estimated amount of time
(in years) it takes consumers to recover any increased purchase cost
(including installation) of a more-efficient product through lower
operating costs. DOE calculates the PBP by dividing the change in
purchase cost at higher ELs by the change in annual operating cost for
the year that amended or new standards are assumed to take effect.
For each EL developed in the engineering analysis, DOE first
calculated the average LCC and PBP if a nationally representative
consumer sample were to make a purchase at that EL. Separate
calculations were conducted for the residential and commercial sectors.
DOE developed consumer samples based on the 2009 RECS and the 2003
CBECS, for the residential and commercial sectors, respectively. For
each consumer in the sample, DOE determined the energy consumption of
the GSL purchased and the appropriate electricity price. By developing
consumer samples, the analysis captured the variability in energy
consumption and energy prices associated with the use of GSLs.
DOE added sales tax, which varied by state, and installation cost
(for the commercial sector) to the cost of the product developed in the
product price determination to determine the total installed cost.
Inputs to the calculation of operating expenses include annual energy
consumption, energy prices and price projections, lamp lifetimes, and
discount rates. DOE created distributions of values for lamp lifetimes,
discount rates, and sales taxes, with probabilities attached to each
value, to account for their uncertainty and variability. For the
Integrated Low-Lumen product class, DOE also developed and analyzed two
non-representative lamp options for EL 2 (based on common lamp types
with significant market share), as well as lamp options across three
additional lumen ranges based on the 60 W equivalent lamp options.
For each GSL standards case (i.e., case where a standard would be
in place at a particular EL), DOE then measured the LCC savings
resulting from the considered standard based on the estimated change in
efficacy distribution in the standards case relative to the estimated
efficacy distribution in the no-new-standards case. These efficacy
distributions include market trends that can result in some lamps with
efficacies that exceed the minimum efficacy associated with the
standard under consideration. In contrast, the PBP only considers the
average time required to recover any increased first cost associated
with a purchase at a particular EL relative to the baseline product.
The computer model DOE uses to calculate the LCC and PBP results
relies on a Monte Carlo simulation to incorporate uncertainty and
variability into the analysis. The Monte Carlo simulations randomly
sample input values from the probability distributions and GSL consumer
user samples. The model calculated the LCC and PBP for a sample of
10,000 consumers per simulation run.
DOE calculated the LCC and PBP results for all consumers as if each
were to purchase a new product in the expected year of compliance with
new or amended standards. Any amended standards would apply to GSLs
manufactured no earlier than three years after the date on which any
amended standard is published. (42 U.S.C. 6295(i)(6)(A)(iii)) DOE
assumed that the compliance date for any final GSL rule would be
January 1, 2020.
Though DOE assumed the compliance date for any final GSL rule would
be January 1, 2020 in the reference scenario, CEC asked DOE to consider
phased-in effective dates, whereby the compliance date for a potential
final GSL rule would instead be subsequent to the compliance date for
the EISA 2007 backstop. (CEC, No. 31 at pp. 2-3) DOE has analyzed an
alternative scenario in which the compliance date for a potential final
GSL rule is 2022, or two years after the compliance date of the EISA
2007 backstop. This scenario aligns with the suggestion put forth by
CEC, and the results can be found in the appendix 10E of this NOPR TSD.
Table V-11 summarizes the approach and data DOE used to derive
inputs to the LCC and PBP calculations. The subsections that follow
provide further discussion. DOE requests comment on the overall
methodology and results of the LCC and PBP analyses (see issue 30 in
section VIII.E). Details of the spreadsheet model, and of all the
inputs to the LCC and PBP analyses, are contained in chapter 8 of the
NOPR TSD and its appendices.
Table V-11--Summary of Inputs and Methods for the LCC and PBP Analysis*
------------------------------------------------------------------------
Inputs Source/method
------------------------------------------------------------------------
Product Cost.................... Weighted-average consumer price
determined in the product price
determination. For the Integrated Low-
Lumen product class, DOE developed
and analyzed two non-representative
lamp options for EL 2, as well as
lamp options across three additional
lumen ranges based on the 60W-
equivalent lamp options. To project
lamp prices to the compliance year,
DOE used a price-learning analysis
for both CFLs and LEDs.
Sales Tax....................... Derived 2019 population-weighted-
average tax values for each state
based on Census population
projections and sales tax data from
Sales Tax Clearinghouse.
Installation Costs.............. Used RSMeans and U.S. Bureau of Labor
Statistics data to estimate an
installation cost of $1.45 per
installed GSL for the commercial
sector.
Lumen Range Distribution........ Residential sector: Used national
sales data from the year 2000 for
incandescent lamps.
Commercial sector: Used lumen range
distribution data from NEEA's 2014
CBSA.
Disposal Cost................... Assumed 35 percent of commercial CFLs
are disposed of at a cost of $0.70
per CFL. Assumptions based on
industry expert feedback and a
Massachusetts Department of
Environmental Protection mercury lamp
recycling rate report.
[[Page 14585]]
Energy Use...................... Derived in the energy use analysis.
Varies by geographic location and
room type in the residential sector
and by building type in the
commercial sector.
Energy Prices................... Electricity: Based on 2014 average and
marginal electricity price data from
the Edison Electric Institute.
Variability: Electricity prices vary
by season, U.S. region, and baseline
electricity consumption level.
Energy Price Trends............. Based on AEO 2015 price forecasts.
Residual Value.................. Represents the value of surviving
lamps at the end of the LCC analysis
period. DOE discounts the residual
value to the start of the analysis
period and calculates it based on the
remaining lamp's lifetime and price
at the end of the LCC analysis
period.
Product Lifetime................ A Weibull survival function is used to
provide the survival probability as a
function of GSL age, based on the
GSL's rated lifetime and sector-
specific HOU. On-time cycle length
effects are included for residential
CFLs.
Discount Rates.................. Approach involves identifying all
possible debt or asset classes that
might be used to purchase the
considered appliances, or might be
affected indirectly. Primary data
source was the Federal Reserve
Board's Survey of Consumer Finances.
Efficacy Distribution........... Estimated by the market-share module
of shipments model. See chapter 9 of
the NOPR TSD for details.
Assumed Compliance Date......... 2020
------------------------------------------------------------------------
* References for the data sources mentioned in this table are provided
in the sections following the table or in chapter 8 of the NOPR TSD.
1. Product Cost
To derive the GSL product cost, DOE used the weighted-average
consumer price determined in the product price determination. For the
Integrated Low-Lumen product class, DOE also developed and analyzed two
additional non-representative lamp options at EL 2 (a CFL and an LED
lamp), in order to better reflect the current GSL market at that EL.
For the same product class, which is the only product class that
includes LED lamps, due to the high variability in LED lamp price by
light output, DOE developed and analyzed lamp options across four lumen
ranges (310-749 lm, 750-1049 lm, 1050-1489 lm, and 1490-1999 lm). For
details on the methodology to derive product prices for the two non-
representative lamp options and the lamp options in the three
additional lumen ranges, see chapter 8 of the NOPR TSD.
DOE also used a price-learning analysis to account for changes in
lamp prices that are expected to occur between the time for which DOE
has data for lamp prices (2015) and the assumed compliance date of the
rulemaking (2020). For details on the price-learning analysis, see
section V.G.1.b.
DOE applied sales tax, which varies by geographic location, to the
product cost. DOE collected sales tax data from the Sales Tax
Clearinghouse \138\ and used population projections from the Census
Bureau \139\ to develop population-weighted-average sales tax values
for each state in 2020.
---------------------------------------------------------------------------
\138\ Sales Tax Clearinghouse, Inc. State Sales Tax Rates Along
with Combined Average City and County Rates. 2014. (Last accessed
June 15, 2015.) http://thestc.com/STrates.stm.
\139\ U.S. Census Bureau, Population Division, Interim State
Population Projections, 2005. Table A1: Interim Projections of the
Total Population for the United States and States: April 1, 2000 to
July 1, 2030.
---------------------------------------------------------------------------
2. Installation Cost
In the preliminary analysis, DOE did not consider installation
costs in the LCC and PBP analysis. NEMA suggested that many consumers
will require an electrician, and therefore incur an installation cost,
to replace a failed ballast or fixture on a non-integrated GSL. (NEMA,
No. 34 at p. 23) The Northwest Power and Conservation Council agreed
with NEMA, adding that installation costs should be included for any
commercial lamps. (Northwest Power and Conservation Council, Public
Meeting Transcript, No. 29 at p. 151) DOE agrees with NEMA and the
Northwest Power and Conservation Council that commercial GSLs are
likely to incur an installation cost. Therefore, DOE used RSMeans \140\
and U.S. Bureau of Labor Statistics data \141\ to estimate a commercial
installation cost of $1.45 per installed GSL.
---------------------------------------------------------------------------
\140\ RSMeans. Facilities Maintenance and Repair Cost Data 2013.
2012. RSMeans: Norwell, MA.
\141\ U.S. Department of Labor. Bureau of Labor Statistics. May
2014 Occupational Employment Statistics Survey. National
Occupational and Wage Estimates. (Last accessed June 30, 2015.)
http://www.bls.gov/oes/tables.htm.
---------------------------------------------------------------------------
For details on the installation cost calculation, see chapter 8 of
the NOPR TSD. DOE has continued to assume zero installation cost for
the residential sector. DOE requests comment on the installation cost
assumptions used in its analyses (see issue 31 in section VIII.E).
3. Lumen Range Distribution
In the preliminary analysis, DOE developed market-share estimates
for each lumen range of integrated GSLs (310-749 lm, 750-1049 lm, 1050-
1489 lm, and 1490-1999 lm for the Integrated Low-Lumen product class,
and 2000-2600 lm for the Integrated High-Lumen product class) in the
residential and commercial sectors.\142\ In response to the lumen
distribution presented in the preliminary analysis, NRDC commented that
DOE should update its market estimate and cited available data sources.
Specifically, NRDC provided national sales data across lumen ranges for
screw base incandescent lamps from 2000 and 2006 and noted that given
the relatively stable condition of the lighting market during that
period, DOE should consider that CFL and LED replacements for screw
base sockets would have similar market shares across lumen ranges. EEAs
also pointed out that DOE's market-share estimates may be biased by
specific lamp types included in the Cadeo Group data used by DOE in the
preliminary analysis. (EEAs, No. 32 at pp. 10-12) NEMA expressed
agreement with DOE's assumption that approximately 3 percent of all
residential-sector GSLs with integrated ballasts or drivers are
brighter than 2,000 lumens. (NEMA, No. 34 at p. 24)
---------------------------------------------------------------------------
\142\ GSL preliminary analysis at 8-18.
---------------------------------------------------------------------------
DOE concurs with NRDC's assessment of available lumen-distribution
information and thus, in the NOPR analyses, has updated its residential
sector lumen-distribution estimate based on the data provided by NRDC.
For the residential sector, DOE used
[[Page 14586]]
national sales data from the year 2000 \143\ across lumen ranges for
screw base incandescent lamps (because screw base lamps are used
predominantly in the residential sector).\144\ Based on DOE's updated
approach, the fraction of residential-sector GSLs with integrated
ballasts or drivers brighter than 2,000 lumens (i.e., those
residential-sector GSLs in the Integrated High-Lumen product class) is
about 0.5 percent. DOE notes that this updated estimate is based on
actual sales data, whereas the preliminary analysis estimate was based
on the number of product offerings on the market. For the commercial
sector, DOE has also updated its approach from the preliminary analysis
and determined the lumen distribution using installed lamp data from
NEEA's 2014 CBSA metering study.\145\ For more details regarding the
lumen range distributions, see chapter 8 of the NOPR TSD. DOE requests
comment on the methodology and assumptions used to determine the market
share of the lumen range distributions (see issue 32 in section
VIII.E).
---------------------------------------------------------------------------
\143\ ECOS Consulting, Davis Energy Group, and Energy Solutions.
Codes and Standards Enhancement Initiative for PY2004: Title 20
Standards Development: Analysis of Standards Options for General
Service Incandescent Lamps. 2004. Pacific Gas & Electric Company:
San Francisco, CA. (Last accessed June 30, 2015.) http://www.energy.ca.gov/appliances/2004rulemaking/documents/case_studies/CASE_Gen_Serv_Incand_Lamps.pdf.
\144\ Navigant Consulting, Inc. Final Report: 2010 U.S. Lighting
Market Characterization. 2012. U.S. Department of Energy. (Last
accessed June 10, 2015.) http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf.
\145\ Northwest Energy Efficiency Alliance. Commercial Building
Stock Assessment 2014. (Last accessed June 26, 2015.) http://neea.org/resource-center/regional-data-resources/commercial-building-stock-assessment.
---------------------------------------------------------------------------
NEEA expressed concern with the lumen bins DOE used for parts of
its analysis, specifically that an approximate range of 700-900 lumens
was used in the engineering analysis to select an equivalent
representative GSL for a 60 W incandescent bulb, whereas the EISA lumen
bins were used to sample lamps for the LCC and PBP analysis. (NEEA,
Public Meeting Transcript, No. 29 at pp. 231-232) Of the EISA lumen
bins, the 750-1,049 lumen bin is divided between the 700-900
approximate lumen range DOE used in selecting representative units for
the preliminary analysis. While DOE agrees with NEEA that using
consistent lumen bins across analyses is important for analytical
consistency, DOE notes that the discrepancy identified by NEEA has no
actual impact on the analysis results. Furthermore, DOE is only aware
of market-share data for GSLs broken out across the four EISA lumen
bins. Therefore, for the NOPR analysis DOE continued to use the EISA
lumen-binned GSL market-share data for its LCC and PBP analysis.
4. Electricity Prices
In the preliminary analysis, DOE used average retail electricity
prices to conduct its analyses.\146\ For the NOPR analyses, DOE used
both marginal and average electricity prices to calculate the operating
costs associated with each EL. Specifically, DOE used average
electricity prices to characterize the baseline EL and marginal
electricity prices to characterize incremental electricity cost savings
associated with the other proposed ELs. The electricity prices used in
the LCC analysis vary by season, region, and baseline electricity
consumption level. DOE estimated these prices using data published with
the Edison Electric Institute (EEI) Typical Bills and Average Rates
reports for summer and winter 2014.\147\ DOE assigned seasonal marginal
and average prices to each household or commercial building in the LCC
sample based on its location and its baseline monthly electricity
consumption for an average summer or winter month. For a detailed
discussion of the development of electricity prices, see appendix 8D of
the NOPR TSD.
---------------------------------------------------------------------------
\146\ GSL preliminary analysis at 8-20.
\147\ Edison Electric Institute. Typical Bills and Average Rates
Report. Winter 2014 published April 2014, Summer 2014 published
October 2014. See http://www.eei.org/resourcesandmedia/products/Pages/Products.aspx.
---------------------------------------------------------------------------
5. Electricity Price Trends
To arrive at electricity prices in future years, DOE multiplied the
2014 electricity prices by the forecast of annual residential or
commercial electricity price changes for each Census division from
EIA's AEO 2015, which has an end year of 2040.\148\ To estimate the
trends after 2040, DOE used the average rate of change during 2025-
2040. For each purchase sampled, DOE applied the projection for the
Census division in which the purchase was located. The AEO electricity
price trends do not distinguish between marginal and average prices, so
DOE used the same (AEO 2015) trends for both marginal and average
prices. DOE reviewed the EEI data for the years 2007 to 2014 and
determined that there is no systematic difference in the trends for
marginal vs. average electricity prices in the data.
---------------------------------------------------------------------------
\148\ U.S. Energy Information Administration. Annual Energy
Outlook 2015 with Projections to 2040. 2015. Washington, DC Report
No. DOE/EIA-0383(2015). http://www.eia.gov/forecasts/aeo/pdf/0383(2015).pdf.
---------------------------------------------------------------------------
DOE used the electricity price trends associated with the AEO
reference case, which is a business-as-usual estimate, given known
market, demographic, and technological trends. DOE also included AEO
High Growth and AEO Low-Growth scenarios in the analysis. The high- and
low-growth cases show the projected effects of alternative economic
growth assumptions on energy prices.
6. Product Lifetime
In the NOPR analyses, as in the preliminary analysis, DOE
considered the GSL lifetime to be the service lifetime, i.e., the age
at which the GSL is retired from service.\149\ In response to the
lifetime scenarios presented in the preliminary analysis, Southern
Company suggested DOE account for the possibility that some non-
dimmable CFL GSLs are placed in dimmable sockets and experience very
early failure. (Southern Company, Public Meeting Transcript, No. 29 at
p. 170) DOE is unaware of any data indicating that a significant
fraction of CFL GSLs experience immediate retirement due to being
installed on sockets with dimmer switches. Therefore, in the reference
scenario DOE has not assumed any immediate failures of this nature in
the NOPR analyses. However, DOE did conduct an alternative NOPR
analysis to account for the possibility of 5 percent of GSLs
experiencing failure within the first year of use.
---------------------------------------------------------------------------
\149\ GSL preliminary analysis at 8-23.
---------------------------------------------------------------------------
General Electric suggested that DOE cannot assume that every bulb
of a specific type of GSL will have the same lifetime; some bulbs will
be retired earlier than the average lifetime. (General Electric
Lighting, Public Meeting Transcript, No. 29 at pp. 35-36) In response,
NRDC stated that even if a GSL is retired prior to the average lifetime
modeled by DOE, the lamp will most likely be replaced by a more
efficacious, lower-cost lamp. (NRDC, Public Meeting Transcript, No. 29
at pp. 36-37) DOE notes that in both its preliminary and NOPR analyses,
distributions were used to model GSL lifetimes. Therefore, not all GSLs
of a specific type have identical lifetimes and some installed GSLs are
retired earlier than indicated by the lamp's modeled median lifetime.
CEC, NEEA, and NRDC all suggested that DOE consider that long-life
GSLs in the Early Replacement lifetime scenario will likely get rotated
to less-used sockets, rather than being retired outright. (CEC, Public
Meeting Transcript, No. 29 at pp. 171-172;
[[Page 14587]]
NEEA, Public Meeting Transcript, No. 29 at p. 172; NRDC, Public Meeting
Transcript, No. 29 at pp. 173-174) DOE acknowledges that long-lived,
efficient lamps may currently be rotated from higher-use sockets,
rather than retired outright, when a consumer purchases a new, more-
efficient lamp. However, this phenomenon is more likely to occur with
the current mix of lighting technologies used by GSLs in homes, and is
less likely to occur if the majority of GSLs installed in homes are CFL
and LED lamps, because the marginal efficacy increase in the latter
case is much smaller than in the former case. Because DOE's analyses
assume that CFL and LED lamps are the only GSLs on the market
throughout the analysis period, DOE has not assumed that consumers will
rotate lamps from higher-use sockets when more efficacious lamps are
purchased.
NRDC also commented that the 5-year median lifetime for the Early
Replacement lifetime scenario used in the preliminary analysis was too
low. (NRDC, Public Meeting Transcript, No. 29 at p. 228) Southern
Company and Philips expressed concern with the long GSL lifetimes
modeled in the preliminary analysis, with Philips indicating that low-
cost electronic components in the lamp may have shorter lifetimes than
the lamp's lumen maintenance (for LED GSLs) performance indicates.
(Southern Company, Public Meeting Transcript, No. 29 at p. 33; Philips,
Public Meeting Transcript, No. 29 at p. 33) NEMA indicated agreement
with the lifetime scenarios considered, but found fault with the
underlying Weibull function DOE used to model GSL lifetimes, stating
that the underlying function was derived for non-integrated linear
fluorescent lamps, not CFL and LED GSLs. (NEMA, No. 34 at p. 23)
For the NOPR analysis, DOE made a number of updates to its three
lifetime scenario models. In place of 5-year median lifetime used in
the Early Replacement lifetime alternative scenario for the preliminary
analysis, for the NOPR analyses DOE has assumed a 10-year median
lifetime for the ``short lifetime'' alternative scenario. This scenario
applies only to LED GSLs and is intended to account for the possibility
that the future service lifetime of LED GSLs could be significantly
shorter than expected today. DOE has maintained the ``rated lifetime''
and ``renovation-driven lifetime'' scenarios from the preliminary
analysis, but DOE has updated the data upon which these models (and the
``short lifetime'' model) are based, in accordance with NEMA's
observation. For the NOPR analysis, DOE used a report containing data
on the cycle life characteristics of CFL GSLs that was published by the
California Public Utilities Commission\150\ in place of the underlying
Weibull function used in the preliminary analysis. DOE also analyzed a
scenario in which the renovation-driven lifetime scenario was modified
to assume that five percent of GSLs fail within the first year of use
(called ``immediate failures''). Further discussion of and results from
these analyses are provided in appendix 8E. DOE invites comment on the
three GSL service life scenarios in its analyses, as well as on the
lifetime scenario accounting for GSL failure in the first year of use
(see issue 33 in section VIII.E).
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\150\ James J. Hirsch and Associates and Erik Page & Associates,
Inc. CFL Laboratory Testing Report: Results from a CFL Switching
Cycle and Photometric Laboratory Study. 2015. California Public
Utilities Commission--Energy Division: California. (Last accessed
June 18, 2015.) http://www.energydataweb.com/cpuc/search.aspx?did=1258.
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7. Residual Value
The residual value represents the remaining dollar value of
surviving lamps at the end of the LCC analysis period (the lifetime of
the shortest-lived GSL in each product class), discounted to the
compliance year. To account for the value of any lamps with remaining
life to the consumer, the LCC model applies this residual value as a
``credit'' at the end of the LCC analysis period. Because DOE estimates
that GSLs undergo price learning, the residual value of these lamps is
calculated based on the lamp price at the end of the LCC analysis
period.
Philips expressed concern with DOE's residual value calculation in
the preliminary analysis, stating that consumers typically dispose of
their original lamp and purchase a newer lamp at a comparable price,
rather than capturing any value from the original lamp by selling it.
(Philips, Public Meeting Transcript, No. 29 at pp. 179-180). To
clarify: When comparing products with differing lifetimes, DOE selected
a common period over which to evaluate LCCs so that longer-lived lamps
were not penalized for continuing to accrue operating costs over a
longer operational life. DOE's residual value calculation does not
consider the resale value of a lamp; rather, it calculates the value to
a consumer of having a lamp that is still operational, instead of a
lamp that has failed and must be replaced, at the end of the LCC
analysis period.
The Northwest Power and Conservation Council suggested an
alternative way for DOE to conduct the residual value analysis, which
is to include the replacement cost of the shortest-lived lamp in its
LCC. (Northwest Power and Conservation Council, Public Meeting
Transcript, No. 29 at p. 181). The CEC commented that DOE needs to
consider the remaining value of the energy savings associated with
longer-lived lamps. (CEC, Public Meeting Transcript, No. 29 at pp. 193-
194) Because consumers of lamps with shorter lives may choose to
replace them with longer-lived or more efficacious lamps when they
fail, DOE believes that it is inappropriate to make assumptions about
the replacement costs borne or relative operating-cost savings
accumulated by a consumer after the end of the LCC analysis period.
8. Disposal Cost
Disposal cost is the cost a consumer pays to dispose of their
retired GSL. In the preliminary analysis, DOE assumed that 10 percent
of commercial consumers pay $1 per lamp to dispose of CFL and LED
lamps.\151\ General Electric agreed with DOE's assumption that
residential consumers do not pay for recycling their CFL lamps;
however, General Electric indicated that up to 40 percent of CFL lamps
are recycled in the commercial sector, at an average price of
approximately $0.50 per lamp. (General Electric Lighting, Public
Meeting Transcript, No. 29 at pp. 176-177) Westinghouse Lighting
largely agreed with General Electric, stating that the disposal cost
for commercial CFL lamps is below $1.00 per lamp, and estimating that
the cost may actually be closer to $0.70 per lamp. (Westinghouse
Lighting, Public Meeting Transcript, No. 29 at p. 177) NEMA cited the
Universal Waste Rule to confirm that the lamp user is responsible for
disposal, and also highlighted various approaches to lamp disposal
taken by some states and retailers. (NEMA, No. 34 at pp. 23-24)
---------------------------------------------------------------------------
\151\ GSL preliminary analysis at 8-25.
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DOE reviewed the available data and agrees with GE and Westinghouse
that a higher percentage of commercial fluorescent lamps are recycled,
but at a lower cost than DOE assumed in the preliminary analysis. As
discussed in the ceiling fan light kits energy conservation standards
NOPR,\152\ in 2004 and 2009 the estimated recycling rates for
fluorescent lamps were approximately 29 percent and 33 percent,
respectively. In the NOPR analyses, DOE assumed that by the
[[Page 14588]]
compliance year 35 percent of CFLs are recycled, and this fraction was
assumed to remain constant over the analysis period (for the NIA). DOE
also received feedback from a lighting industry consultant indicating a
recycling charge of $0.70 per lamp is reasonable; therefore, DOE has
assumed for the NOPR analyses that it costs commercial consumers $0.70
per lamp to recycle CFLs. DOE has continued to assume no disposal cost
for CFLs in the residential sector. Because LED lamps do not contain
mercury, DOE has continued to assume no disposal costs for LED lamps in
both the residential and commercial sectors.
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\152\ The Ceiling Fan Light Kits Energy Conservation Standards
docket can be accessed at: http://www.regulations.gov/#!docketDetail;dct=FR%252BPR%252BN%252BO%252BSR%252BPS;rpp=25;po=25;D
=EERE-2012-BT-STD-0045.
---------------------------------------------------------------------------
DOE requests comment and relevant data on the disposal cost
assumptions used in its analyses (see issue 34 in section VIII.E).
9. Discount Rates
In the calculation of LCC, DOE applies discount rates appropriate
to consumers to estimate the present value of future operating costs.
To establish residential discount rates for the LCC analysis, DOE
estimated a distribution of residential discount rates for GSLs based
on consumer financing costs and opportunity cost of funds related to
appliance energy cost savings. DOE identified all relevant household
debt or asset classes to approximate a consumer's opportunity cost of
funds related to GSL energy cost savings. It estimated the average
percentage shares of the various types of debt and equity by household
income group using data from the Federal Reserve Board's Survey of
Consumer Finances \153\ (SCF) for 1995, 1998, 2001, 2004, 2007, and
2010. Using the SCF and other sources, DOE developed a distribution of
rates for each type of debt and asset by income group to represent the
rates that may apply in the year in which amended standards would take
effect. DOE assigned each sample household a specific discount rate
drawn from one of the distributions. The average rate across all types
of household debt and equity and income groups, weighted by the shares
of each type, is 4.5 percent.
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\153\ Board of Governors of the Federal Reserve System. Survey
of Consumer Finances. 1995, 1998, 2001, 2004, 2007, and 2010. (Last
accessed June 30, 2015.) http://www.federalreserve.gov/econresdata/scf/scfindex.htm.
---------------------------------------------------------------------------
To establish commercial consumer discount rates for the LCC
analysis, DOE estimated the cost of capital for companies that purchase
GSLs. The weighted-average cost of capital is commonly used to estimate
the present value of cash flows to be derived from a typical company
project or investment. Most companies use both debt and equity capital
to fund investments, so their cost of capital is the weighted average
of the cost to the firm of equity and debt financing, as estimated from
financial data for publicly traded firms in the sectors that purchase
GSLs. For this analysis, DOE used Damodaran online \154\ as the source
of information about company debt and equity financing. The average
rate across all types of companies that purchase GSLs, weighted by the
total number of GSLs associated with each type, is 5.0 percent.
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\154\ Damodaran, A. Cost of Capital by Sector. January 2014.
(Last accessed September 25, 2014.) http://people.stern.nyu.edu/adamodar/New_Home_Page/datafile/wacc.htm.
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See chapter 8 of the NOPR TSD for further details on the
development of consumer discount rates.
10. Efficacy Distributions
To accurately estimate the share of consumers that would be
affected by a potential energy conservation standard at a particular
EL, DOE's LCC analysis considered the projected distribution (i.e.,
market shares) of product efficacies that consumers purchase under the
no-new-standards case and each of the standards cases (i.e., the cases
where a standard would be set at each TSL) in the assumed compliance
year. The estimated market shares for the no-new-standards case and
each standards case are determined by the shipments analysis and are
shown in Table V-12 and Table V-13. See section V.G.1 of this NOPR and
chapter 9 of the NOPR TSD for further information on the derivation of
the market efficacy distributions.
Table V-12--GSL Market Efficacy Distribution by Trial Standard Level in 2020 for the Residential Sector
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial Standard Level EL 0 (%) EL 1 (%) EL 2 (%) EL 3 (%) EL 4 (%) Total (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Integrated Low-Lumen GSLs
--------------------------------------------------------------------------------------------------------------------------------------------------------
No-New-Standards........................................ 3.6 4.7 35.9 31.2 24.7 100
TSL 1................................................... 0 6.8 36.9 31.4 24.8 100
TSL 2................................................... 0 0 43.8 31.4 24.8 100
TSL 3................................................... 0 0 0 48.4 51.6 100
TSL 4................................................... 0 0 0 0 100 100
--------------------------------------------------------------------------------------------------------------------------------------------------------
Integrated High-Lumen GSLs
--------------------------------------------------------------------------------------------------------------------------------------------------------
No-New-Standards........................................ 25.8 29.1 45.1 .............. .............. 100
TSL 1................................................... 0 39.2 60.8 .............. .............. 100
TSL 2................................................... 0 0 100 .............. .............. 100
TSL 3................................................... 0 0 100 .............. .............. 100
TSL 4................................................... 0 0 100 .............. .............. 100
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V-13--GSL Market Efficacy Distribution by Trial Standard Level in 2020 for the Commercial Sector
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level EL 0 (%) EL 1 (%) EL 2 (%) EL 3 (%) EL 4 (%) Total (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Integrated Low-Lumen GSLs
--------------------------------------------------------------------------------------------------------------------------------------------------------
No-New-Standards........................................ 1.8 3.7 25.7 36.3 32.6 100
TSL 1................................................... 0 4.9 26.1 36.4 32.6 100
TSL 2................................................... 0 0 31.0 36.4 32.6 100
[[Page 14589]]
TSL 3................................................... 0 0 0 43.7 56.3 100
TSL 4................................................... 0 0 0 0 100 100
--------------------------------------------------------------------------------------------------------------------------------------------------------
Integrated High-Lumen GSLs
--------------------------------------------------------------------------------------------------------------------------------------------------------
No-New-Standards........................................ 16.9 23.5 59.6 .............. .............. 100
TSL 1................................................... 0 28.3 71.7 .............. .............. 100
TSL 2................................................... 0 0 100 .............. .............. 100
TSL 3................................................... 0 0 100 .............. .............. 100
TSL 4................................................... 0 0 100 .............. .............. 100
--------------------------------------------------------------------------------------------------------------------------------------------------------
Non-Integrated GSLs
--------------------------------------------------------------------------------------------------------------------------------------------------------
No-New-Standards........................................ 31.9 68.1 .............. .............. .............. 100
TSL 1................................................... 31.9 68.1 .............. .............. .............. 100
TSL 2................................................... 31.9 68.1 .............. .............. .............. 100
TSL 3................................................... 31.9 68.1 .............. .............. .............. 100
TSL 4................................................... 0 100 .............. .............. .............. 100
--------------------------------------------------------------------------------------------------------------------------------------------------------
11. LCC Savings Calculation
In the reference scenario, DOE calculated the LCC savings at each
TSL based on the change in LCC for each standards case compared to the
no-new-standards case, considering the efficacy distribution of
products derived by the shipments analysis. This approach allows
consumers to choose more-efficient (and sometimes less expensive)
products at higher ELs and is intended to more accurately reflect the
impact of a potential standard on consumers.
In response to DOE's assumption that in a standards case consumers
are assumed to purchase lamps that are at least as efficient as the
ones they would purchase in the absence of standards, ASAP and NEEA
expressed agreement while NEMA pointed out the possibility of
manufacturers producing lamps with increased color rendering, long
life, or other metrics, but lower efficiency in the no-new-standards
case. (ASAP, Public Meeting Transcript, No. 29 at pp. 191-192; NEEA,
Public Meeting Transcript, No. 29 at p. 192; NEMA, No. 34 at p. 22)
Incorporating this could mean more consumers start with less efficient
lamps in the no-new-standards case, but NEMA understands the difficulty
in predicting future product development and acknowledged that DOE's
assumption may be the most reasonable approach. (Id.)
DOE clarifies that the statement ``consumers are assumed to
purchase lamps that are at least as efficient as the ones they would
purchase in the absence of standards'' was not a constraint applied in
determining the fraction of purchases made at each EL; rather, it was
an attempt to describe how specific consumers in the LCC sample were
assigned to ELs when a standard was assumed to be in place, where the
fraction of consumers at each EL under a standard was determined by the
consumer-choice model in the shipments analysis.
The consumer-choice model determines the fraction of consumers at
each EL under a standard, but cannot track the purchasing decision for
individual consumers in the LCC sample. Thus, in order to determine the
fraction of consumers who experience a net cost, DOE must make a
simplifying assumption to relate purchases for a particular consumer in
a standards case and in the no-new-standards case. DOE assumed that the
rank order of consumers, in terms of the efficacy of the product they
purchase, is the same in the no-new-standards case as in the standards
cases. In other words, DOE assumed that the consumers who purchased the
most-efficacious products in the efficacy distribution in the no-new-
standards case would continue to do so in standards cases, and
similarly, those consumers who purchased the least efficacious products
in the efficacy distribution in the no-new-standards case would
continue to do so in standards cases. This assumption is only relevant
in determining the fraction of consumers who experience a net cost in
the LCC savings calculation, and has no effect on the estimated
national impact of a potential standard. DOE has continued to make this
simplifying assumption for the NOPR analysis.
CA IOUs indicated DOE should not assume that all products are
barely compliant with the efficacy under consideration; instead, DOE
should use a ``shift'' approach to model the likelihood of some
consumers voluntarily exceeding the minimum efficiency standard. (CA
IOUs, No. 33 at p. 8)
To clarify: In both the preliminary and the NOPR analyses, DOE has
presented two sets of results in the LCC analysis per product class.
The first set are the ``LCC results'', which represent the average
costs a consumer is projected to pay for a product purchased at a
particular ELs in the compliance year. These results are not intended
to represent the impact of a standard. The second set of results are
the ``LCC Savings'', which indicate the average change in LCC that
consumers are projected to experience if a standard is set at a
particular EL. In order to determine the LCC savings, DOE estimated the
change to the efficacy distribution that would result from a standard
set at each of the ELs under consideration. To do this DOE used a
consumer-choice model, which allows for the possibility of consumers
purchasing GSLs that exceed a given minimum efficiency standard under
consideration.
For details on the LCC savings calculation, see chapter 8 of the
NOPR TSD. For details on the consumer-choice model, see chapter 9 of
the NOPR TSD.
12. Payback Period Analysis
The payback period is the amount of time it takes the consumer to
recover any additional installed cost of more-efficient products,
compared to the baseline product, through energy cost savings. Payback
periods are expressed in years. Payback periods that exceed
[[Page 14590]]
the life of the product mean that the increased total installed cost is
not recovered in reduced operating expenses.
The inputs to the PBP calculation for each EL are the change in
total installed cost of the product and the change in the first year's
annual operating expenditures relative to the baseline product. The PBP
calculation uses the same inputs as the LCC analysis, except that
discount rates and energy price trends are not needed.
As noted previously, EPCA, as amended, 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 first year's energy savings resulting from
the standard, as calculated under the applicable test procedure. (42
U.S.C. 6295(o)(2)(B)(iii)) For each considered EL, DOE determined the
value of the first year's energy savings by calculating the energy
savings in accordance with the applicable DOE test procedure, and
multiplying those savings by the average energy price forecast for the
year in which compliance with the amended standards would be required.
G. Shipments Analysis
DOE uses projections of annual product shipments to calculate the
national impacts of potential amended energy conservation standards on
energy use, NPV, and future manufacturer cash flows.\155\ The shipments
model takes an accounting approach, tracking market shares of each
product class and the vintage of units in the stock. Stock accounting
uses product shipments as inputs to estimate the age distribution of
in-service product stocks for all years. The age distribution of in-
service product stocks is a key input to calculations of both the NES
and NPV, because operating costs for any year depend on the age
distribution of the stock.
---------------------------------------------------------------------------
\155\ DOE uses data on manufacturer shipments as a proxy for
national sales, as aggregate data on sales are lacking. In general
one would expect a close correspondence between shipments and sales.
---------------------------------------------------------------------------
1. Shipments Model
The shipments model projects shipments of GSLs over a thirty-year
analysis period for the no-new-standards case 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 GSL lamp shipments for this rulemaking
has three main interacting elements: (1) A lamp demand module that
estimates the demand for GSL lighting for each year of the analysis
period; (2) a price-learning module, which projects future prices based
on historic price trends; and (3) a market-share module that assigns
shipments to the available lamp options.
a. Lamp Demand Module
The lamp demand module first estimates the national demand for GSLs
in each year. The 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 2015
projections of residential and commercial floor space.\156\ A lamp
turnover calculation estimates demand for new lamps in each year given
the growth of floor space in each year, the historical shipments of
lamps in each product class, the expected lifetimes of the lamps, and
sector-specific assumptions on operating hours and the distribution of
per-lamp lumen output desired by consumers. (The assumed operating
hours include the effect of rebound in the standards cases for the
alternative scenario that includes rebound.) The lamp demand module
also accounts for the adoption of integral LED luminaires into lighting
applications traditionally served by GSLs; for the possibility that
commercial consumers will transition between the non-integrated and
integrated GSL product classes in the future; and for consumers'
transitioning between GSILs and CFL or LED GSLs during the analysis
period, either spontaneously or due to standards. Further details on
the assumptions used to model these market transitions are presented in
chapter 9 of the NOPR TSD.
---------------------------------------------------------------------------
\156\ U.S. Energy Information Administration. Annual Energy
Outlook 2015 with Projections to 2040. 2015. Washington, DC Report
No. DOE/EIA-0383(2015). (Last accessed June 5, 2015.) http://www.eia.gov/forecasts/aeo/pdf/0383(2015).pdf.
---------------------------------------------------------------------------
CEC asked DOE to update the shipments analysis to reflect market
changes that occurred between the preliminary analysis and the NOPR
analyses. (CEC, No. 31 at p. 2). The shipments analysis in this NOPR
accounted for shipments that occurred through the first calendar
quarter of 2015 \157\ and utilized inputs from the updated engineering
analysis that considered 2015 market conditions. DOE requests relevant
data on GSL shipments as they become available in order to improve the
accuracy of the shipments analysis (see issue 35 in section VIII.E).
---------------------------------------------------------------------------
\157\ National Electrical Manufacturers Association. Lamp
Indices. (Last accessed July 7, 2015.) http://www.nema.org/Intelligence/Pages/Lamp-Indices.aspx.
---------------------------------------------------------------------------
The demand module used in the preliminary analysis required
assumptions about the breakdown of integrated GSLs between the
Integrated Low-Lumen and Integrated High-Lumen product classes, as well
as about the rate of transition between non-integrated and integrated
GSLs. NEMA disagreed with DOE's assumption that non-integrated CFL GSLs
will remain a constant fraction of the installed GSL stock in the
commercial sector, indicating that non-integrated CFL GSLs will be
significantly replaced by LEDs over the next 30 years (thereby
significantly lowering the market share of non-integrated CFL GSLs).
(NEMA, No. 34 at p. 24) General Electric and NEEA agreed with NEMA.
(General Electric Lighting, Public Meeting Transcript, No. 29 at p.
224; NEEA, Public Meeting Transcript, No. 29 at pp. 225-226) DOE agrees
that non-integrated CFL GSLs will have a shrinking market share during
the analysis period for the reasons mentioned by the commenters. In the
NOPR analysis, DOE has assumed that no non-integrated GSL systems are
installed in new construction or in renovations, with systems removed
for renovation being replaced either by integrated GSLs or by
integrated LED fixtures. Because of this, the total shipments of
integrated GSLs fall monotonically over the analysis period and
eventually reach zero.
In the preliminary analysis, DOE assumed that some fraction of
residential consumers currently utilizing GSILs will spontaneously
adopt CFL or LED GSLs in each year before 2020. As discussed
previously, DOE assumes that the EISA backstop provision will take
effect in 2020; therefore, all GSL shipments in 2020 and after were
assumed to be CFL or LED GSLs.
NEMA agreed that in each year prior to 2020 there will be some
shift from incandescent lamps to CFL and LED lamps, as well as some
shift from CFL lamps to LED lamps, and that these shifts will be
increasing over time. (NEMA, No. 34 at p. 26) However, NEMA did not
agree with DOE's assumption that a substantial fraction of the GSL
market will shift from incandescent to CFL and LED in 2020, indicating
that the dramatic sales increase presented in the preliminary analysis
shipments results is an impractical assumption. (Id.) Given the
[[Page 14591]]
current, significant gap in efficacy between halogen incandescent lamps
and the 45 lm/W efficacy level specified by the EISA 2007 backstop
requirement, DOE believes that it is very unlikely that GSILs will be
able to meet the EISA backstop requirement. Therefore, if the backstop
takes effect in 2020, all remaining GSIL demand will shift out of
necessity to CFL and LED GSLs. This NOPR modifies the assumptions about
this shift that were utilized in the preliminary analysis by assuming
that the shift will take place over a period of several years, rather
than occurring largely in 2020, since some GSILs have low HOU, and,
accordingly, longer lifetimes. DOE requests comment on the assumption
that the shift to CFL and LED GSLs during the shipments analysis period
will take place over several years (see issue 36 in section VIII.E).
NEMA also requested that DOE consider an alternative scenario in which
halogen lamps remain on the market. (NEMA, No. 34 at p. 27) As
discussed previously, due to the Appropriations Rider, DOE did not
analyze GSILs in this NOPR, and thus did not consider halogen lamps.
b. Price-Learning Module
The price-learning module estimates GSL prices in each year of the
analysis period using a standard price-learning model,\158\ which
relates the price of a given technology to its cumulative production,
as represented by total cumulative shipments. DOE applied experience
curves to CFL and LED lamps separately according to recent studies on
price and shipments trends for these technologies.159 160
Current cumulative shipments are determined for each technology at the
start of the analysis period and are augmented in each subsequent year
of the analysis based on the shipments determined for the prior year.
New prices for each technology are calculated from the updated
cumulative shipments according to the experience curve for each
technology. The current year's shipments, in turn, affect the
subsequent year's prices. As shown in chapter 9 of the NOPR TSD,
because LED GSLs are a relatively young technology, their cumulative
shipments increase rapidly and hence they undergo a substantial price
decline during the shipments analysis period. By contrast, since CFL
technology is more mature, CFL GSL prices decline by a relatively small
amount.
---------------------------------------------------------------------------
\158\ Taylor, M. and S. K. Fujita. Accounting for Technological
Change in Regulatory Impact Analyses: The Learning Curve Technique.
2013. Lawrence Berkeley National Laboratory: Berkeley, CA. Report
No. LBNL-6195E. (Last accessed June 23, 2015.) http://eetd.lbl.gov/publications/accounting-for-technological-change-0.
\159\ Gerke, B., A. Ngo, A. Alstone, and K. Fisseha. The
Evolving Price of Household LED Lamps: Recent Trends and Historical
Comparisons for the US Market. 2014. Lawrence Berkeley National
Laboratory: Berkeley, CA. Report No. LBNL-6854E. (Last accessed June
15, 2015.) http://eetd.lbl.gov/publications/the-evolving-price-of-household-led-l.
\160\ Gerke, B. F., A. T. Ngo, and K. S. Fisseha. Recent Price
Trends and Learning Curves for Household LED Lamps from a Regression
Analysis of Internet Retail Data. 2015. Lawrence Berkeley National
Laboratory: Berkeley, CA. Report No. LBNL-184075. (Last accessed
June 24, 2015.) http://eetd.lbl.gov/publications/recent-price-trends-and-learning-curv.
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CA IOUs indicated that the prices DOE used in the preliminary
analysis for integrated low-lumen lamps at each EL in 2020 are too
high. (CA IOUs, No. 33 at p. 5) DOE notes that the prices indicated by
CA IOUs in their comment were the 2014 prices DOE used in the
preliminary analysis, not the prices DOE projected for 2020. Due to
price learning, the 2020 prices DOE used in the preliminary analysis
were lower than the 2014 prices CA IOUs based their comment on.
Discussion of the 2014 prices can be found in V.D.
Westinghouse Lighting stated that DOE should not assume any price
learning for CFL lamps. (Westinghouse Lighting, Public Meeting
Transcript, No. 29 at p. 209) The California IOUs suggested DOE account
for price learning for all LED representative units considered in the
analysis. (California IOUs, Public Meeting Transcript, No. 29 at p.
211) DOE believes that price learning will continue for any
technologies on the market that are not obsolete and, further, that CFL
GSLs are not an obsolete technology in general. Additionally, DOE
believes that all of the LED GSL lamp options considered in this
analysis represent lamps with an active presence in the current market.
Therefore, DOE has assumed that price learning will occur for all lamp
options considered in this NOPR. Further discussion on the price
learning DOE applied for the NOPR analysis is in chapter 9 of the NOPR
TSD. DOE invites comment on its approach to price learning (see issue
37 in section VIII.E).
The preliminary analysis assumed that there was no minimum price
difference between lamps with different lumen outputs at a given
EL.\161\ Southern Company, NRDC, the California IOUs, Westinghouse
Lighting, and NEMA suggested DOE ensure that its analyses assume a
difference in the incremental price of LED lamps in different lumen
bins (i.e., lamps in higher lumen bins will never have exactly the same
price as lamps in lower lumen bins). (Southern Company, Public Meeting
Transcript, No. 29 at pp. 213-215; NRDC, Public Meeting Transcript, No.
29 at p. 216; California IOUs, Public Meeting Transcript, No. 29 at p.
217; Westinghouse Lighting, Public Meeting Transcript, No. 29 at pp.
218-219; NEMA, No. 34 at p. 25) DOE agrees that lamps in different
lumen bins will continue to have a non-zero price difference. In this
NOPR, DOE has assumed that lamps in brighter lumen bins have a fixed
fractional price increment relative to lamps in dimmer lumen bins. With
this approach, the absolute price difference between lumen bins will
decline if lamp prices decline, but the difference will always remain
greater than zero. DOE requests comment on the assumption that brighter
lumen bins have a fixed fractional price increment relative to lamps in
dimmer lumen bins (see issue 39 in section VIII.E).
---------------------------------------------------------------------------
\161\ GSL preliminary analysis at 2-87.
---------------------------------------------------------------------------
NEMA commented that high efficiency standards could cause lamp
prices to remain constant, as manufacturers are forced to focus more on
efficiency than cost reduction; alternatively, NEMA believes that
setting a lower efficiency standard would allow manufacturers to pursue
cost savings, resulting in increased adoption of efficient GSLs. (NEMA,
No. 34 at p. 25) DOE has observed that the prices of LED GSLs have
fallen rapidly even as the efficacy of such lamps has improved in
recent years. The price trends used in this analysis are based on these
recent price declines that have occurred in tandem with increased
efficacy. Based on this history, DOE believes that it is possible for
efficacy to continue to improve even as prices decline for LED GSLs.
c. Market-Share Module
The market-share module apportions the lamp shipments in each year
among the different lamp options developed in the engineering and LCC
analyses, based on consumer sensitivity to lamp price, lifetime, energy
savings, and mercury content, as measured in a recent market
study,\162\ as well as on consumer preferences for lighting technology
(CFL or LED) as revealed in historical shipments data. The market-share
module assumes that, when replacing a lamp, consumers will choose from
among all of the available lamp options with a similar lumen output to
the lamp being replaced. It also assumes that the distribution of lamp
lumen outputs
[[Page 14592]]
demanded for new construction and renovations is the same as the
average distribution for all shipments. Substitution matrices were
developed to specify the product choices available to consumers
depending on the lumen output they require. 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. The market-share module also incorporates a
limit on the diffusion of LED technology into the market using the
widely accepted Bass adoption model,\163\ the parameters of which are
based on historic penetration rates of new lighting technologies into
the market. In this way, the module assigns market shares to the
different ELs based on observations of consumer preferences.
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\162\ Krull, S. and D. Freeman. Next Generation Light Bulb
Optimization. 2012. Pacific Gas and Electric Company. (Last accessed
June 23, 2015.) http://www.etcc-ca.com/sites/default/files/OLD/images/stories/Lighting_Conjoint_Study_v020712f.pdf.
\163\ Bass, F. M. A New Product Growth Model for Consumer
Durables. Management Science. 1969. 15(5): pp. 215-227. (Last
accessed June 23, 2015.) http://pubsonline.informs.org/doi/abs/10.1287/mnsc.15.5.215.
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Westinghouse Lighting and the Northwest Power and Conservation
Council highlighted the inverse relationship between GSL life and cost,
indicating that GSL cost is a major driver of adoption. (Westinghouse
Lighting, Public Meeting Transcript, No. 29 at p. 35; Northwest Power
and Conservation Council, Public Meeting Transcript, No. 29 at p. 37)
DOE notes that in the shipments analysis, the market-share module
accounts for consumer sensitivity to cost, efficiency, and other
metrics (see chapter 9 of the NOPR TSD for more details).
2. Rare Earth Oxides
Rare earth oxides (REOs) are used in CFL GSL phosphors to increase
luminous efficacy, so affect CFL prices. Large increases in REO prices
in 2010 and 2011 raised manufacturer concerns that future price
increases could have adverse impacts on the market. DOE developed
shipments scenarios in its preliminary analysis to reflect
uncertainties in the prices of REOs. DOE's reference case assumed that
REO prices would remain constant at the June 2014, level, but DOE
acknowledged the uncertainty about prices and included a scenario with
much higher REO prices.
Philips indicated that recent reports are suggesting the prices of
REOs may increase, due to China's overwhelming control over their
production quantities of REOs. (Philips, Public Meeting Transcript, No.
29 at p. 228) NEMA indicated that an increase in rare earth oxide
prices impacts the industry as well as consumers. NEMA also referenced
the comments they submitted to the GSFL and IRL standards
rulemaking,\164\ in which NEMA indicated that rare earth oxide prices
are more likely to increase in the future than decrease, and that
higher efficiency fluorescent lamps have more rare earth oxide contents
(by weight). (NEMA, No. 34 at p. 25)
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\164\ For all materials related to this GSFL and IRL standards
rulemaking, see regulations.gov under docket number EERE-2011-BT-
STD-0006.
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DOE has monitored the price of REOs since the publication of the
preliminary analysis and found that their prices have declined over
that time period.\165\ Additionally, DOE's data show that the price of
REOs remained relatively stable over the last half of 2014 and the
first half of 2015. Therefore, DOE has maintained its reference
scenario assumption from the preliminary analysis: Rare earth oxide
prices remain constant at their June 2014 level. Moreover, because REO
prices represent a very small portion of the total price of CFL GSLs,
the alternative REO price scenario had a minimal impact on the outcome
of the preliminary analyses. For this reason, and because REO prices
have been stable or declining for several years, DOE did not analyze a
scenario with higher REO prices for this NOPR.
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\165\ Metal-Pages. Historical Prices. 2015. (Last accessed June
23, 2015.) http://www.metal-pages.com/.
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H. National Impact Analysis
The NIA assesses the NES and the national NPV from a national
perspective of total consumer costs and savings that would be expected
to result from new or amended standards at specific ELs.\166\
(``Consumer'' in this context refers to consumers of the product being
regulated.) DOE calculates the NES and NPV based on projections of
annual product shipments and prices, along with the HOU and energy
prices from the energy use and LCC analyses.\167\ For the present
analysis, DOE projected the energy savings, operating-cost savings,
product costs, and NPV of consumer benefits over the lifetime of GSLs
sold from 2020 through 2049.
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\166\ The NIA accounts for impacts in the 50 States and the U.S.
territories.
\167\ For the NIA, DOE adjusts the installed cost data from the
LCC analysis to exclude sales tax, which is a transfer.
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DOE evaluates the impacts of new and amended standards by comparing
a case without such standards with standards-case projections. The no-
new-standards case characterizes energy use and consumer costs for each
analyzed product class in the absence of new or amended energy
conservation standards. DOE compares the no-new-standards case with
projections characterizing the market for each product class if DOE
adopted new or amended standards at specific ELs (i.e., the TSLs or
standards cases) for that class. For the standards cases, DOE considers
how a given standard would likely affect the market shares of products
with efficacies greater than the standard.
DOE uses a spreadsheet model to calculate the energy savings and
the national consumer costs and savings from each TSL. Interested
parties can review DOE's analyses by changing various input quantities
within the spreadsheet. The NIA spreadsheet model uses typical values
(as opposed to probability distributions) as inputs.
Table V-14 summarizes the inputs and methods DOE used for the NIA
analysis for the NOPR. Discussion of these inputs and methods follows
the table. See chapter 10 of the NOPR TSD for further details.
Table V-14--Summary of Inputs and Methods for the National Impact
Analysis
------------------------------------------------------------------------
Inputs Method
------------------------------------------------------------------------
Shipments Annual shipments for each lamp option
from shipments model for the no-new
standards case and each TSL analyzed.
Assumed compliance date of January 1, 2020.
standard.
No-new-standards efficacy Estimated from market-share module of
distribution. shipments analysis.
Standards-case efficacy Estimated by the market-share module
distribution. of the shipments analysis.
Annual energy use per unit...... Calculated for each lamp option based
on inputs from the Energy Use
Analysis.
Total installed cost per unit... Uses lamp prices, and for the
commercial sector only, installation
costs from the LCC analysis.
[[Page 14593]]
Electricity prices.............. Estimated marginal electricity prices
from the LCC analysis.
Energy price trends............. AEO 2015 forecasts (to 2040) and
extrapolation thereafter.
Annual operating cost per unit.. Calculated for each lamp option using
the energy use per unit, and
electricity prices and trends.
Energy Site-to-Primary A time-series conversion factor based
Conversion. on AEO 2015.
Discount rate................... Three and seven percent real.
Present year.................... 2015.
------------------------------------------------------------------------
1. National Energy Savings
The NES analysis involves a comparison of national energy
consumption of the considered products in each TSL with consumption in
the case with no new or amended energy conservation standards. DOE
calculated the annual national energy consumption by multiplying the
number of units (stock) of each lamp option (by vintage or age) by the
unit energy consumption (also by vintage) for each year in the
analysis. The NES is based on the difference in annual national energy
consumption for the no-new-standards case and each of the standards
cases. DOE estimated the energy consumption and savings based on site
energy and converted to the electricity consumption and savings at the
power plant using annual conversion factors derived from AEO 2015.
Cumulative energy savings are the sum of NES for each year over the
analysis period, taking into account the full lifetime of lamps shipped
in 2049.
DOE accounts for the direct rebound effect in its NES analyses.
Direct rebound reflects the idea that as appliances become more
efficient, consumers use more of their service because their operating
cost is reduced. In the case of lighting, the rebound could be
manifested in increased HOU or in increased lighting density (lamps per
square foot). In the preliminary analysis DOE assumed no rebound in
both the residential and commercial sectors. General Electric and
Westinghouse Lighting suggested DOE assume some amount of rebound.
(General Electric Lighting, Public Meeting Transcript, No. 29 at pp.
236-237; Westinghouse Lighting, Public Meeting Transcript, No. 29 at
pp. 238-239) ASAP and NEEA commented that they do not expect a rebound
effect associated with moving from a CFL lamp to an LED lamp. (ASAP,
Public Meeting Transcript, No. 29 at p. 241; NEEA, Public Meeting
Transcript, No. 29 at p. 241) NEMA expects little to no rebound effect
in the commercial sector, but foresees an 8.5 percent to 15 percent
rebound effect for LED lamps used in the residential sector. (NEMA, No.
34 at p. 27)
While some commenters believed that some degree of rebound would be
expected in moving from incandescent GSLs to more efficacious CFL and
LED GSLs, most commenters did not anticipate rebound when moving from
CFLs to LED lamps (the case considered by this rulemaking) in the
residential sector, and none anticipated rebound in the commercial
sector. Due to the relatively small incremental increase in efficacy
between CFLs and LED GSLs, DOE did not include any rebound in either
the residential or commercial sectors in the reference scenario.
Additionally, as discussed in more detail in appendix 10D of the NOPR
TSD, examining DOE's 2001 and 2010 U.S. LMC studies 168 169
indicates that there has been reduction in total lamp operating hours
in the residential sector concomitant with increases in lighting
efficiency. This operating hour reduction was derived from residential
usage of incandescent, fluorescent, HID, and solid state GSL lamps and
may be explained by a negative rebound effect or other economic factors
such as the recent economic downturn.
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\168\ Navigant Consulting, Inc. U.S. Lighting Market
Characterization, Volume I: National Lighting Inventory and Energy
Consumption Estimate. 2002. U.S. Department of Energy. (Last
accessed June 10, 2015.) http://apps1.eere.energy.gov/buildings/publications/pdfs/corporate/lmc_vol1.pdf.
\169\ Navigant Consulting, Inc. Final Report: 2010 U.S. Lighting
Market Characterization. 2012. U.S. Department of Energy. (Last
accessed June 10, 2015.) http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf.
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The daily operating hours for residential incandescent GSL lamps
from both 2001 and 2010 LMC reports indicate that incandescent lamps
have lower operating hours, 1.9 hours per day when compared to lamps
such as CFLs and LED lamps, which were reported to have usage rates as
high at 2.2 hours per day. This could be construed to suggest that a
positive rebound may result if a significant portion of the market
moves from incandescent GSLs to more efficacious CFL or LED lamps.
However, DOE's understanding is that the CFL and LED GSLs are currently
preferentially installed in sockets with higher operating hours. NEMA's
comments on the preliminary analysis corroborate this point. (NEMA, No.
34 at p. 19) The lower overall hours of use in 2010 suggests no
positive rebound on a per-socket basis. Therefore DOE assumed that the
overall hours of use for all GSLs when CFLs and LEDs fill all sockets
during the analysis period will be the same as the current overall
hours of use for all GSLs. DOE did consider an alternative scenario, in
which there was 15 percent rebound in the residential sector, to
illustrate the impact rebound would have. See appendix 10E of the NOPR
TSD.
Consistent with what was stated above for the residential sector,
DOE does not expect there to be any rebound effect associated with the
commercial sector due to the relatively small incremental increase in
efficacy between CFL and LED GSLs. NEMA agreed that rebound is not
expected for the commercial sector in its response to the preliminary
analysis. (NEMA, No. 34 at p. 27) However, DOE requests comment on the
rebound assumptions for both the residential and commercial sectors and
any data that can be used to further refine the rebound effect
assumptions used in the shipments and NIA analyses (see issue 40 in
section VIII.E).
In response to the recommendations of a committee on ``Point-of-Use
and Full-Fuel-Cycle Measurement Approaches to Energy Efficiency
Standards'' appointed by the National Academy of Sciences, DOE
announced its intention to use FFC measures of energy use and
greenhouse gas and other emissions in the national impact analyses and
emissions analyses 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 which DOE explained its determination
that EIA's National Energy Modeling System (NEMS) is the most
appropriate tool for its FFC analysis and its intention to use NEMS for
that purpose. 77 FR 49701
[[Page 14594]]
(August 17, 2012). NEMS is a public domain, multi-sector, partial
equilibrium model of the U.S. energy sector that EIA uses to prepare
its AEO.\170\ The approach used for deriving FFC measures of energy use
and emissions is described in appendix 10B of the NOPR TSD.
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\170\ For more information on NEMS, refer to The National Energy
Modeling System: An Overview, DOE/EIA-0581 (98) (Feb.1998)
(Available at: http://www.eia.gov/oiaf/aeo/overview/).
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a. Smart Lamps
Integrated GSLs with standby functionality, henceforth referred to
as smart lamps, were not explicitly analyzed in the shipments analysis.
To account for the additional energy use due to standby for such lamps
in the NIA, DOE assumed that smart lamps would make up an increasing
fraction of integrated low-lumen lamps following a Bass adoption curve.
In the preliminary analysis, DOE considered a reference scenario in
which penetration of smart lamps increased over the analysis period,
reaching 50 percent by the end of the analysis period, as well as
alternative scenarios in which the smart-lamp penetration in the
residential sector never exceeded 0 percent and reached 100 percent by
the end of the analysis period to gauge the impact of smart lamp
penetration.\171\
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\171\ GSL preliminary analysis at 10-7.
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NEMA agreed that the penetration of smart lamps into the
residential sector will increase, but did not believe the market share
for smart lamps will ever reach 100 percent, as there will always be a
market for more basic, lower-cost lamps. (NEMA, No. 34 at p. 27) DOE
agrees with NEMA that smart lamps are unlikely to ever achieve 100
percent market share in the residential sector, particularly given the
existence of lighting controls that are external to the lamp. In the
NOPR analyses, DOE considered three lighting-controls scenarios
including a smaller range of penetration for smart lamps: 0 percent
smart-lamp penetration in the residential sector by 2049, 50 percent
penetration (the reference scenario), and a high residential-controls
scenario which assumed that externally controlled sockets increase to
50 percent of all sockets in 2049 in addition to a 50 percent
penetration of smart lamps in 2049. DOE invites comment on these
scenarios (see issue 42 in section VIII.E).
In the preliminary analysis, DOE assumed that there was no standby
power associated with smart lamps.\172\ In response to this assumption,
Westinghouse Lighting stated that smart lamps must have some associated
standby power, otherwise they would not function as intended.
(Westinghouse Lighting, Public Meeting Transcript, No. 29 at pp. 239-
240) NEEA suggested smart lamps may have standby power on the order of
0.5 watts. (NEEA, Public Meeting Transcript, No. 29 at p. 243) For the
NOPR analysis, DOE has estimated that smart lamps have a standby power
consumption of 0.5 watts due to the receiver. This estimation was based
on the findings from a 4E Electronic Devices & Networks Annex report
(hereafter referred to as the ``EDNA report'') \173\ as well as the
maximum standby power allowed in the ENERGY STAR Luminaires
Specification V2.0 \174\ for luminaires with integral motion sensors,
occupancy sensors or photosensors, or connected functionality.
Furthermore, DOE attributed an additional 0.33 W of standby power for
each smart lamp to account for the power draw of the hub for smart
lamps that operate with one. This value is based on data indicating
smart-lamp hubs consume approximately 2 W of power on average (from the
EDNA report), as well as the assumption that 50 percent of smart lamps
operate with a hub and three smart lamps, on average, are connected to
each hub.
---------------------------------------------------------------------------
\172\ Id. at 10-8.
\173\ Smart Lamp Testing--Initial Results. 2014. 4E Electronic
Devices & Networks Annex. (Last accessed June 25, 2015.) http://edna.iea-4e.org/files/otherfiles/0000/0100/Smart_Lights_Paper_for_EDNA_Website_v3.pdf.
\174\ ENERGY STAR. ENERGY STAR Program Requirements: Product
Specification for Luminaires (Light Fixtures): Eligibility Criteria,
Version 2.0. 2015. U.S. Environmental Protection Agency: Washington,
DC (Last accessed July 7, 2015.) https://www.energystar.gov/sites/default/files/Luminaires%20V2.0%20Final%20Specification.pdf.
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In the preliminary analysis, DOE assumed smart lamps would achieve
the same 30 percent energy savings as lamps under other types of
controls. NEEA and Southern Company commented that the enhanced
convenience associated with smart lamps, even though the lamps are
inherently controlled, means these lamps will not necessarily result in
real energy savings. (NEEA, Public Meeting Transcript, No. 29 at pp.
240, 243; Southern Company, Public Meeting Transcript, No. 29 at pp.
242-243) DOE is unaware of any data suggesting how HOU or the impact of
controls may differ for smart lamps compared to other GSLs that operate
with controls; therefore, for the NOPR analysis DOE continued to assume
30 percent energy savings for smart lamps. DOE requests data and
information on the assumption of 30 percent energy savings for smart
lamps (see issue 43 in section VIII.E).
2. Net Present Value Analysis
The inputs for determining the NPV of the total costs and benefits
experienced by consumers 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 calculates net
savings each year as the difference between the no-new-standards case
and each standards case in terms of total savings in operating costs
versus total increases in installed costs. DOE calculates operating-
cost savings over the lifetime of each product shipped during the
forecast period.
As discussed in section V.G.1.b of this notice, DOE developed GSL
prices using a price-learning module incorporated in the shipments
analysis. By 2049, which is the end date of the forecast period, the
average LED GSL price is projected to drop 83 percent relative to 2015
and the average price of CFL GSLs is projected to drop 13 percent
relative to 2015. DOE's projection of product prices is described in
chapter 9 of the NOPR TSD.
The operating-cost savings are primarily energy cost savings, which
are calculated using the estimated energy savings in each year and the
projected price of electricity. To estimate energy prices in future
years, DOE multiplied the average national marginal electricity prices
by the forecast of annual national-average residential or commercial
electricity price changes in the reference case from AEO 2015, which
has an end year of 2040. To estimate price trends after 2040, DOE used
the average annual rate of change in prices from 2020 to 2040.
To evaluate the impact of the economic assumptions used in the NIA,
DOE considered two alternative scenarios; a low benefits scenario and a
high benefits scenario. The low benefits scenario uses AEO 2015 Low
Economic Growth scenario for energy price trends and floorspace growth,
coupled with a high price decline rate for LED GSLs. The high benefits
scenario uses AEO 2015 High Economic Growth scenario for energy price
trends and floorspace growth, coupled with low price decline rate for
LED GSLs. The benefits to consumers from GSL standards are lower if LED
GSL prices decline faster because consumers convert to LED GSLs more
quickly in the no-new-standards case; conversely, the benefits to
consumers from GSL standards are higher if LED GSL prices decline
slower because consumers are slow to convert to LED GSLs in the no-new-
standards
[[Page 14595]]
case. The high and low price trends are based on the 95-percent
confidence interval of the learning rate for LED GSLs from a recent
study of LED price trends.\175\ DOE invites comments on the high and
low benefits scenarios considered in its analysis (see issue 44 in
section VIII.E). NIA results for the high and low benefits scenarios
are presented in appendix 10E of the NOPR TSD.
---------------------------------------------------------------------------
\175\ Gerke, et al. (2015), op. cit.
---------------------------------------------------------------------------
In addition to the high and low benefits scenarios, DOE considered
several other scenarios in its shipments and NIA analyses. DOE invites
comments on whether there are other scenarios that should be considered
(see issue 45 in section VIII.E). Results for the alternative scenarios
can be found in appendix 10E of the NOPR TSD.
In calculating the NPV, DOE multiplies the net savings in future
years by a discount factor to determine their present value. For this
NOPR, DOE estimated the NPV of consumer benefits using both a 3-percent
and a 7-percent real discount rate. DOE uses these discount rates in
accordance with guidance provided by the Office of Management and
Budget (OMB) to federal agencies on the development of regulatory
analysis.\176\ The discount rates for the determination of NPV are in
contrast to the discount rates used in the LCC analysis, which are
designed to reflect a consumer's perspective. The 7-percent real value
is an estimate of the average before-tax rate of return to private
capital in the U.S. economy. The 3-percent real value represents the
``social rate of time preference,'' which is the rate at which society
discounts future consumption flows to their present value.
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\176\ United States Office of Management and Budget. Circular A-
4: Regulatory Analysis,'' (Sept. 17, 2003), section E (Available at:
www.whitehouse.gov/omb/memoranda/m03-21.html).
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I. Consumer Subgroup Analysis
In analyzing the potential impact of new or amended standards on
consumers, DOE evaluates the impact on identifiable subgroups of
consumers that may be disproportionately affected by a new or amended
national standard. DOE evaluates impacts on particular subgroups of
consumers by analyzing the LCC impacts and PBP for those particular
consumers from alternative standard levels. For this NOPR, DOE analyzed
the impacts of the considered standard levels on low-income households
and small businesses. DOE requests comment on the consumer subgroups
selected for analysis in this NOPR (see issue 46 in section VIII.E).
Chapter 11 in the NOPR TSD describes the consumer subgroup analysis.
NEMA stated that low-income consumers will be most affected if low-
cost halogen or CFL lamps are no longer available in 2020. (NEMA, No.
34 at p. 27) In the NOPR, DOE analyzed the impacts of amended energy
efficiency standards on low-income consumers and small businesses. The
results of these analyses can be seen in section VI.B.1.b. DOE found
that the average LCC savings and PBPs for low-income households at the
considered ELs are not substantially different from the averages for
all households.
J. Manufacturer Impact Analysis
1. Overview
DOE conducted an MIA for GSLs to estimate the financial impact of
proposed standards on manufacturers of GSLs. 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 the GSLs
covered in this rulemaking. The key GRIM inputs are data on the
industry cost structure, manufacturer production costs (MPCs),
shipments, and assumptions about manufacturer markups, and manufacturer
conversion costs. The key MIA output is INPV. The GRIM calculates
annual cash flows using standard accounting principles. DOE used the
GRIM to compare changes in INPV between a no-new-standards case and
various TSLs (the standards cases). The difference in INPV between the
no-new-standards case and standards cases represents the financial
impact of new and amended energy conservation standards on GSL
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; the cumulative regulatory
burden place on the GSL industry; and any impacts on competition.
DOE conducted the MIA for this rulemaking in three phases. In the
first phase, DOE prepared an industry characterization based on the
market and technology assessment, preliminary manufacturer interviews,
and publicly available information. In the second phase, DOE estimated
industry cash flows in the GRIM using industry financial parameters
derived in the first phase and the shipment scenarios created in the
shipment analysis. In the third phase, DOE conducted interviews with a
variety of GSL manufacturers that account for the majority of domestic
GSL sales covered by this rulemaking. During these interviews, DOE
discussed engineering, manufacturing, procurement, and financial topics
specific to each company and obtained each manufacturer's view of the
GSL industry as a whole. The interviews provided information that DOE
used to evaluate the impacts of new and amended standards on
manufacturers' cash flows, manufacturing capacities, and direct
domestic manufacturing employment levels. See section VI.B.2.b of this
NOPR for the discussion on the estimated changes in the number of
domestic employees involved in manufacturing GSLs covered by standards.
See section V.J.4 of this NOPR for a description of the key issues that
manufacturers raised during manufacturer interviews.
During the third phase, DOE also used the results of the industry
characterization analysis in the first phase and feedback from
manufacturer interviews to group manufacturers that exhibit similar
production and cost structure characteristics. DOE identified one
manufacturer subgroup for a separate manufacturer impact analysis--
small businesses. DOE determined that GSL manufacturing falls under the
North American Industry Classification System (NAICS) code of 335110,
electric lamp bulb and part manufacturing. The Small Business
Administration (SBA) defines a small business as having less than 1,000
total employees for manufacturers operating under this NAICS code. This
threshold includes all employees in a business' parent company and any
other subsidiaries. Based on this classification, DOE identified 41 GSL
manufacturers that qualify as small businesses. The complete MIA is
presented in chapter 12 of the NOPR TSD, and the analysis required by
the Regulatory Flexibility Act, 5 U.S.C. 601, et seq., is presented in
section VII.B of this NOPR.
2. GRIM Analysis and Key Inputs
DOE uses the GRIM to quantify the changes in cash flows over time
due to new and amended energy conservation standards. These changes in
cash flows result in either a higher or lower INPV for the standards
cases compared to the no-new-standards case. The GRIM uses a standard
annual cash-flow analysis that incorporates MPCs, manufacturer markups,
shipments, and industry financial parameters as inputs. It then models
changes in MPCs, manufacturer investments, and shipments that result
from new and amended energy conservation standards. The GRIM uses these
inputs to calculate a series of annual cash flows beginning with the
[[Page 14596]]
reference year of the analysis, 2015, and continuing to 2049. DOE
computes INPV by summing the stream of annual discounted cash flows
during the analysis period. DOE used a real discount rate of 6.1
percent for GSL manufacturers. This initial discount rate estimate was
derived from industry corporate annual reports to the Securities and
Exchange Commission (SEC 10-Ks). During manufacturer interviews, GSL
manufacturers were asked to provide feedback on this discount rate.
Most GSL manufacturers agreed that a 6.1 percent discount rate
accurately reflected their typical rate of return on their investments.
Many inputs into the GRIM come from the engineering analysis, the
shipment analysis, manufacturer interviews, and other research
conducted during the MIA. The major GRIM inputs are described in detail
in the following sections.
a. Capital and Product Conversion Costs
DOE expects new and amended energy conservation standards to cause
manufacturers to incur conversion costs by bringing their tooling and
product designs into compliance with new and amended standards. For the
MIA, DOE classified these conversion costs into two major groups: (1)
Capital conversion costs and (2) product conversion costs. Capital
conversion costs are investments in property, plant, and equipment
necessary to adapt, change, or expand existing tooling equipment such
that new product designs can be fabricated and assembled. Product
conversion costs are investments in research, development, testing,
marketing, certification, and other non-capitalized costs necessary to
make product designs comply with new and amended standards.
Using feedback from manufacturer interviews, DOE conducted a
bottom-up analysis to calculate the capital and product conversion
costs for GSL manufacturers for each product class at each EL. To
conduct this bottom-up analysis, DOE used manufacturer input from
manufacturer interviews regarding the types and dollar amounts of
discrete capital and product expenditures that would be necessary to
convert specific production lines and product designs for each GSL
product class at each EL. Manufacturers frequently provided a range of
potential conversion costs for each product class at each EL. DOE used
this range to create a high and low conversion cost investment scenario
due to the uncertainty of these costs across the entire industry. Each
conversion cost investment scenario leads to different levels of
investment by manufacturers, which, when used in the discounted cash
flow model, results in varying free cash flow impacts on GSL
manufacturers.
For ELs that can be met with CFLs, DOE assumed that capital
conversion costs would be limited to tooling costs, since manufacturers
would not need to significantly alter the production equipment used to
product more efficacious CFLs. For ELs that require LED lamps, DOE
assumed manufacturers would incur larger capital conversion costs since
GSL manufacturers would need to make investments in production
equipment to further expand their LED lamp manufacturing capacity to
meet expected market demand for these products. Product conversion
costs at all efficacy levels are based on the number of models that
would require redesign, retesting, and recertification due to
standards.
In addition to calculating the conversion costs manufacturers would
be required to make at each efficacy level, DOE also estimated the
capital and product conversion costs GSL manufacturers would have to
make due to the implementation of the minimum 45 lm/W backstop
stipulated in EISA 2007 in the no-new-standards case. It is assumed GSL
manufacturers would be required to make these investments regardless of
whether DOE proposes and ultimately sets further GSL standards as a
result of this rulemaking. Therefore, these conversion costs caused by
the EISA 2007 backstop are included in the no-new-standards case.
Conversion costs at higher standards analyzed by this rulemaking are in
addition to these no-new-standards case conversion costs.
Once DOE compiled capital and product conversion costs, DOE took
average values (i.e., average number of hours or average dollar
amounts) based on the range of responses given by manufacturers for
each type of capital and product conversion cost at each EL. See
chapter 12 of the NOPR TSD for a complete description of DOE's
assumptions for the capital and product conversion costs and section
VI.B.2.a of this NOPR for the capital and product conversion costs
estimates for each TSL.
b. Manufacturer Production Costs
Manufacturing more efficacious GSLs can result in changes in MPCs
as a result of varying components and technology types required to meet
ELs at each TSL. Changes in MPCs for these more efficacious components
can impact the revenue, gross margin, and the cash flows of GSL
manufacturers. Typically, DOE develops MPCs for the covered products
using reverse-engineering. These costs are used as an input to the LCC
analysis and NIA. However, because lamps are difficult to reverse-
engineer, DOE directly derived end-user prices and then used those
prices in conjunction with average distribution chain markups and
manufacturer markups to calculate the MPCs of GSLs.
To determine MPCs of GSLs from the end-user prices, DOE divided the
end-user price by the average distribution chain markup and then again
by the average manufacturer markup of the representative GSLs at each
EL. DOE determined the manufacturer markup by examining the SEC 10-Ks
of all publicly traded GSL manufacturers to estimate an average GSL
manufacturer markup of 1.55. DOE determined the distribution chain
markup by examining the SEC 10-Ks of the major lighting retail
manufacturers to estimate a distribution chain markup of 1.52 for all
GSLs. Feedback from manufacturer interviews and previous lighting
rulemakings (i.e., GSFL and IRL standards rulemaking and CFLK
rulemaking) indicated that the respective markups were appropriate for
the GSL industry.
DOE requests comment on the use of 1.52 as an average distribution
chain markup and 1.55 manufacturer markup for all GSLs. For a complete
description of end-user prices, see the product price determination in
section V.D of this NOPR.
c. Shipment Scenarios
INPV, which is the key GRIM output, depends on industry revenue,
which depends on the quantity and prices of GSLs shipped in each year
of the analysis period. Industry revenue calculations require forecasts
of: (1) Total annual shipment volume of GSLs; (2) the distribution of
shipments across product classes (because prices vary by product
class); and, (3) the distribution of shipments across ELs (because
prices vary with lamp efficacy).
DOE developed a consumer-choice-based model to estimate shipments
of GSLs. The model projects consumer purchases (and hence shipments)
based on sector-specific consumer sensitivities to first cost, energy
savings, lamp lifetime, and lamp mercury content. For a complete
description of the shipments, see the shipments analysis discussion in
section V.G of this NOPR.
d. Markup Scenarios
As discussed in the previous manufacturer production costs section,
the MPCs for GSLs are the manufacturers' costs for those units. These
costs include materials, labor, depreciation, and overhead, which are
[[Page 14597]]
collectively referred to as the cost of goods sold (COGS). The MSP is
the price received by GSL manufacturers from their consumers, typically
a distributor, regardless of the downstream distribution channel
through which the GSLs are ultimately sold. The MSP is not the cost the
end-user pays for GSLs because there are typically multiple sales along
the distribution chain and various markups applied to each sale. The
MSP equals the MPC multiplied by the manufacturer markup. The
manufacturer markup covers all the GSL manufacturer's non-production
costs (i.e., selling, general and administrative expenses (SG&A);
research and development (R&D); interest) as well as profit. Total
industry revenue for GSL manufacturers equals the MSPs at each EL
multiplied by the number of shipments at that EL.
DOE only modeled one markup scenario, the preservation of gross
margin markup scenario, for the MIA. DOE chose not to model additional
manufacturer markup scenarios, since there are already significant
market transformations taking place due to the implementation of the
EISA 2007 backstop, which is included in the no-new-standards case. DOE
finds that higher efficacy standards analyzed in the standards cases,
above 45 lm/W, would not significantly alter the manufacturer markup
modeled in the no-new-standards case for the GSL market.
The preservation of gross margin markup scenario assumes that the
COGS for each product is marked up by a fixed percentage to cover SG&A
expenses, R&D expenses, interest expenses, and profit. This allows
manufacturers to preserve the same gross margin percentage in the
standards cases as in the no-new-standards case. In this markup
scenario GSL manufacturers are able to fully pass any additional MPC
increase due to standards to their consumers.
To derive the preservation of gross margin markup percentages for
GSLs, DOE examined the SEC 10-Ks of all publicly traded GSL
manufacturers to estimate the industry average gross margin percentage.
Manufacturers were then asked to verify the industry gross margin
percentage derived from SEC 10-Ks during manufacturer interviews.
3. Discussion of Comments
During the January 2015 public meeting, interested parties
commented on the assumptions and results of the preliminary analysis.
These issues included, manufacturer investments, manufacturer
subgroups, and ancillary benefits of specific standards.
NEMA stated that regulatory actions that force manufacturers to
make incremental investments in mature lighting products that generate
only modest energy-saving benefits can make it more difficult for
manufacturers to invest in LED lamps. NEMA said it is unlikely that GSL
manufacturers would invest in these more mature technologies. NEMA
continued saying that mandatory investment in mature lighting
technologies can hinder competition and competitiveness. (NEMA, No. 34
at p. 29) DOE understands that the majority of GSL manufacturers are
focusing their investments and R&D on LED lamps and are unlikely to
make significant investments in CFLs.
DOE acknowledges that for the Integrated High-Lumen and Non-
Integrated product classes, any standards proposed for those product
classes would require investments in CFL production from GSL
manufacturers in order to comply with any potential standards set for
those product classes. Since DOE is not proposing standards for the
Non-Integrated product class, manufacturers would not be required to
make any investments in that product class. DOE also recognizes the
opportunity cost associated with any investment in CFLs, and agrees
that manufacturers would need to spend capital on their CFL production
for the Integrated High-Lumen product class to meet the proposed
standards for that product class that they would not have to spend in
the no-new-standards case. As a result, manufacturers must determine
the extent to which they will balance investment in CFL technologies
with investment in LED lamp technologies. GSL manufacturers will have
to weigh trade-offs between abandoning CFL production and deploying
additional capital to those technologies. DOE also acknowledges that
manufacturers will have to make large investments to significantly
expand their LED product offerings and production volumes for the
Integrated Low-Lumen product class as a result of the proposed
standards for this product class. These large investments could
significantly strain manufacturers' free cash flow in the years leading
up to the effective date of this rulemaking. See section VI.C.1 for a
discussion of the benefits and burdens of the proposed TSL.
NRDC commented during the preliminary analysis public meeting that
DOE should reach out to a variety of GSL manufacturers, including GSL
manufacturers that only make LED lamps and GSL manufacturers that have
a large percentage of the CFL market when conducting manufacturer
interviews and developing the manufacturer subgroup analysis. (NRDC,
Public Meeting Transcript, No. 29 at p. 250) DOE reached out to a
variety of GSL manufacturers including manufacturers that exclusively
sell LED lamps and manufacturers that have a large share of the CFL
market when conducting manufacturer interviews for this NOPR analysis.
Non-disclosure agreements (NDAs) were used when conducting these
manufacturer interviews, which also cover which manufacturers agreed to
participate. DOE was able to interview every GSL manufacturer that
expressed a desire to be interviewed for this NOPR analysis.
DOE did not conduct a separate manufacturer subgroup analysis based
on the types of GSL technologies that manufacturers produce. Based on
DOE market research, DOE was not able to find any GSL manufacturer
covered by this rulemaking whose GSL portfolio did not include LED
lamps. DOE also did not analyze GSL manufacturers that only produce LED
lamps as a separate manufacturer subgroup from GSL manufacturers that
produce both LED lamps and CFLs, because manufacturers that only
produce LED lamps would not be disproportionally negatively impacted by
GSL standards compared to GSL manufacturers that produce both LED lamps
and CFLs. DOE only identified one manufacturer subgroup that could be
disproportionally impacted by potential standards: small businesses.
During the public meeting, NEEA questioned if the MIA, and
specifically the employment impact analysis, would consider some of the
potential benefits of standards on the ancillary enabling technology
manufacturers associated with more efficacious lighting technologies.
(NEEA, Public Meeting Transcript, No. 29 at p. 253) DOE has determined
that the MIA, and domestic employment impact analysis, will only
examine the direct impacts on GSL manufacturers. DOE will not include
any potential ancillary benefits in industries not primarily involved
in GSL manufacturing as part of the MIA. Typically, DOE does not
examine other manufacturing industries that are not primarily involved
in manufacturing of the covered products due to the speculative nature
of the potential impacts on those industries.
4. Manufacturer Interviews
DOE conducted additional interviews with manufacturers following
the preliminary analysis as part of this NOPR analysis. In these
interviews, DOE asked manufacturers to describe
[[Page 14598]]
their major concerns with this GSL rulemaking. Manufacturers identified
two major areas of concern: (1) Testing burden and (2) impacts of
technology-neutral standards.
a. Testing Burden
Several manufacturers expressed concern over the testing burden
associated with GSL energy conservation standards. Manufacturers
expressed concern regarding new testing requirements for LED lamps and
expanded scope of CFLs to comply with GSL standards. Instead of
spending capital on R&D that could result in an increase in energy
savings from these lamps, manufacturers stated that they would need to
spend capital on testing and certifying already efficacious lamps to
demonstrate compliance with GSL standards. Additionally, manufacturers
claimed that standards covering LED lamps could present a barrier to
entry for small LED lamp manufacturers due to the increase in testing
and certification requirements caused by GSL standards. Manufacturers
claim this could result in a potential decrease of product innovation
and energy-saving potential for LED lamps.
DOE notes that both large and small LED lamp manufacturers would
have to test and certify their products regardless of the standards set
for this rulemaking due to the EISA 2007 mandate of 45 lm/W for all
GSLs effective January 1, 2020. (42 U.S.C. 6295(i)(6)(A)(v))
Furthermore, DOE performed a separate MIA analysis for small business
subgroups to analyze the financial impacts due to the increase in
testing and certification requirements. Further discussion on the
impacts to small businesses can be found in section VII.B.
b. Impacts of Technology-Neutral Standards
Manufacturers are concerned that technology-neutral standards for
GSLs could have a disproportionate effect on the range of technologies
covered by standards. If GSL standards are set at the highest ELs,
manufacturers are concerned that they may experience a loss of product
differentiation among their lighting offerings. Manufacturers claim
that as premium products become the baseline offering to consumers,
previously offered advantages in lighting utility could be eliminated
in an attempt to meet these higher standards. DOE grouped CFLs and LED
lamps in the same product classes for this NOPR analysis. The criteria
used to create the product classes used in this analysis are discussed
in more detail in section V.A.1 of this NOPR.
Several manufacturers also stated they are concerned that GSL
standards could be set at unattainable ELs for CFLs. If CFLs are
regulated out of the market, it could force CFL manufacturers to either
make significant investments in converting their production lines to
other lighting technologies, and cause them to incur a significant loss
on the stranded assets associated with their existing CFL production,
or exit the GSL lighting market altogether. Lastly, manufacturers claim
that setting GSL standards at ELs that cannot be attained by CFLs would
remove product utility from the market as consumers still value CFLs
for certain applications and derive utility from these products due to
their lower first cost.
DOE acknowledges that the proposed standards set for the Integrated
Low-Lumen product class would eliminate CFLs from the market place.
This would cause manufacturers to incur substantial capital and product
conversion costs to significantly expand their LED product offerings
and production volumes to replace their wide range of non-compliant
CFLs product offerings and sales. The methodology for these
manufacturer conversion costs are discussed in detail in section
V.J.2.a and the values used for each TSL are displayed in section
VI.B.2.a.
K. Emissions Analysis
The emissions analysis consists of two components. The first
component estimates the effect of potential energy conservation
standards on power sector and site (where applicable) combustion
emissions of CO2, NOX, SO2, and Hg.
The second component estimates the impacts of potential standards on
emissions of two additional greenhouse gases, CH4 and
N2O, as well as the reductions to emissions of all species
due to ``upstream'' activities in the fuel production chain. These
upstream activities comprise extraction, processing, and transporting
fuels to the site of combustion. The associated emissions are referred
to as upstream emissions.
The analysis of power sector emissions uses marginal emissions
factors that were derived from data in AEO 2015, as described in
section V.M. The methodology is described in chapter 13 and chapter 15
of the NOPR TSD.
Combustion emissions of CH4 and N2O are
estimated using emissions intensity factors published by the EPA, GHG
Emissions Factors Hub.\177\ The FFC upstream emissions are estimated
based on the methodology described in chapter 15 of the NOPR TSD. The
upstream emissions include both emissions from fuel combustion during
extraction, processing, and transportation of fuel, and ``fugitive''
emissions (direct leakage to the atmosphere) of CH4 and
CO2.
---------------------------------------------------------------------------
\177\ Available at: http://www.epa.gov/climateleadership/inventory/ghg-emissions.html.
---------------------------------------------------------------------------
The emissions intensity factors are expressed in terms of physical
units per MWh or MMBtu of site energy savings. Total emissions
reductions are estimated using the energy savings calculated in the
NIA.
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 each ton of gas 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,\178\ DOE used
GWP values of 28 for CH4 and 265 for N2O.
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\178\ Intergovernmental Panel on Climate Change. Chapter 8:
Anthropogenic and Natural Radiative Forcing. In Climate Change 2013:
The Physical Science Basis. Contribution of Working Group I to the
Fifth Assessment Report of the Intergovernmental Panel on Climate
Change. T. F. Stocker, D. Qin, G.-K. Plattner, M. M. B. Tignor, S.
K. Allen, J. Boschung, A. Nauels, Y. Xia, V. Bex, and P. M. Midgley,
Editors. 2013. Cambridge University Press: Cambridge, United Kingdom
and New York, NY, USA. (Last accessed June 22, 2015.) http://www.ipcc.ch/pdf/assessment-report/ar5/wg1/WG1AR5_Chapter08_FINAL.pdf.
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The AEO incorporate the projected impacts of existing air quality
regulations on emissions. AEO 2015 generally represents current
legislation and environmental regulations, including recent government
actions, for which implementing regulations were available as of
October 31, 2014. DOE's estimation of impacts accounts for the presence
of the emissions control programs discussed in the following
paragraphs.
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). (42 U.S.C. 7651 et seq.) SO2
emissions from 28 eastern states and DC were also limited under the
Clean Air Interstate Rule (CAIR). 70 FR 25162 (May 12, 2005). CAIR
created an allowance-based trading program that operates along with the
Title IV program. In 2008, CAIR was remanded to EPA by the U.S. Court
of Appeals for the District of Columbia Circuit, but it remained in
effect.\179\ In 2011, EPA
[[Page 14599]]
issued a replacement for CAIR, the Cross-State Air Pollution Rule
(CSAPR). 76 FR 48208 (August 8, 2011). On August 21, 2012, the D.C.
Circuit issued a decision to vacate CSAPR,\180\ and the court ordered
EPA to continue administering CAIR. 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.\181\ On October 23, 2014, the D.C. Circuit lifted the stay of
CSAPR.\182\ Pursuant to this action, CSAPR went into effect (and CAIR
ceased to be in effect) as of January 1, 2015.
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\179\ 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).
\180\ 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).
\181\ See EPA v. EME Homer City Generation, 134 S.Ct. 1584, 1610
(U.S. 2014). 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.
\182\ See Georgia v. EPA, Order (D.C. Cir. filed October 23,
2014) (No. 11-1302).
---------------------------------------------------------------------------
EIA was not able to incorporate CSAPR into AEO 2015, so it assumes
implementation of CAIR. Although DOE's analysis used emissions factors
that assume 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 emissions impacts from energy conservation standards.
The attainment of emissions caps is typically flexible among EGUs
and is enforced through the use of emissions allowances and tradable
permits. Under existing EPA regulations, any excess SO2
emissions allowances resulting from the lower electricity demand caused
by the adoption of an efficiency standard could be used to permit
offsetting increases in SO2 emissions by any regulated EGU.
In past rulemakings, DOE recognized that there was uncertainty about
the effects of efficiency standards on SO2 emissions covered
by the existing cap-and-trade system, but it concluded that negligible
reductions in power sector SO2 emissions would occur as a
result of standards.
Beginning in 2016, however, SO2 emissions will fall as a
result of the Mercury and Air Toxics Standards (MATS) for power plants.
77 FR 9304 (Feb. 16, 2012). In the 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
2015 assumes that, in order to continue operating, coal plants must
have either flue gas desulfurization or dry sorbent injection 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.\183\ Therefore, DOE believes that energy conservation standards
will generally reduce SO2 emissions in 2016 and beyond.
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\183\ DOE notes that the Supreme Court recently remanded EPA's
2012 rule regarding national emission standards for hazardous air
pollutants from certain electric utility steam generating units. See
Michigan v. EPA (Case No. 14-46, 2015). DOE has tentatively
determined that the remand of the MATS rule does not change the
assumptions regarding the impact of energy efficiency standards on
SO2 emissions. Further, while the remand of the MATS rule
may have an impact on the overall amount of mercury emitted by power
plants, it does not change the impact of the energy efficiency
standards on mercury emissions. DOE will continue to monitor
developments related to this case and respond to them as
appropriate.
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CAIR established a cap on NOX emissions in 28 eastern
States and the District of Columbia.\184\ 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 from other
facilities. However, standards would be expected to reduce
NOX emissions in the states not affected by the caps, so DOE
estimated NOX emissions reductions from the standards
considered in this NOPR for these states.
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\184\ 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 emissions is slight.
---------------------------------------------------------------------------
The MATS limit mercury emissions from power plants, but they do not
include emissions caps and, as such, DOE's energy conservation
standards would likely reduce Hg emissions. DOE estimated mercury
emissions reduction using emissions factors based on AEO 2015, which
incorporates the MATS. DOE requests comment on its approach to
conducting the emissions analysis for GSLs (see issue 47 in section
VIII.E).
L. Monetizing Carbon Dioxide and Other Emissions Impacts
As part of the development of this proposed rule, DOE considered
the estimated monetary benefits from the reduced emissions of
CO2 and NOX that are expected to result from each
of the TSLs considered. To make this calculation analogous 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 NOPR.
For this NOPR, DOE relied on a set of values for the SCC that was
developed by a federal interagency process. The basis for these values
is summarized in the next section, and a more detailed description of
the methodologies used is provided in appendices 14A and 14B of the
NOPR TSD. DOE invites input on its approach to estimating monetary
benefits associated with emissions reductions (see issue 52 in section
VIII.E).
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) climate-change-related
changes in net agricultural productivity, human health, property
damages from increased flood risk, and the value of ecosystem services.
Estimates of the SCC are provided in dollars per metric ton of
CO2. A domestic SCC value is meant to reflect the value of
damages in the United States resulting from a unit change in
CO2 emissions, while a global SCC value is meant to reflect
the value of damages worldwide.
Under section 1(b) 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. The estimates are presented with an acknowledgement
of the many
[[Page 14600]]
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 these 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
CO2 emissions, the analyst faces a number of challenges. A
report from the National Research Council \185\ points out that any
assessment will suffer from uncertainty, speculation, and lack of
information about: (1) Future emissions of GHGs; (2) the effects of
past and future emissions on the climate system; (3) the impact of
changes in climate on the physical and biological environment; and (4)
the translation of these environmental impacts into economic damages.
As a result, any effort to quantify and monetize the harms associated
with climate change will raise questions of science, economics, and
ethics and should be viewed as provisional.
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\185\ National Research Council, Hidden Costs of Energy:
Unpriced Consequences of Energy Production and Use, National
Academies Press: Washington, DC (2009).
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Despite the limits of both quantification and monetization, SCC
estimates can be useful in estimating the social benefits of reducing
CO2 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. 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.
Specially, 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.
In 2010, the interagency group selected four sets of SCC values for
use in regulatory analyses. Three sets of values are based on the
average SCC from the three integrated assessment models, at discount
rates of 2.5, 3, and 5 percent. The fourth set, which represents the
95th percentile SCC estimate across all three models at a 3-percent
discount rate, was 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,\186\ although preference is given to consideration of the
global benefits of reducing CO2 emissions. Table V-15
presents the values in the 2010 interagency group report,\187\ which is
reproduced in appendix 14A of the NOPR TSD.
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\186\ 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.
\187\ 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) (Available at:
www.whitehouse.gov/sites/default/files/omb/inforeg/for-agencies/Social-Cost-of-Carbon-for-RIA.pdf).
[[Page 14601]]
Table V-15--Annual SCC Values From 2010 Interagency Report, 2010-2050
[2007$ 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 this notice were generated using the most
recent versions of the three integrated assessment models that have
been published in the peer-reviewed literature, as described in the
2013 update from the interagency working group (revised July
2015).\188\ Table V-16 shows the updated sets of SCC estimates from the
latest interagency update in 5-year increments from 2010 to 2050. The
full set of annual SCC values between 2010 and 2050 is reported in
appendix 14B of the NOPR TSD. The central value that emerges is the
average SCC across models at the 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.
---------------------------------------------------------------------------
\188\ 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 July 2015) (Available at: http://www.whitehouse.gov/sites/default/files/omb/inforeg/scc-tsd-final-july-2015.pdf.
Table V-16--Annual SCC Values From 2013 Interagency Update (Revised July 2015), 2010-2050
[2007$ per metric ton CO2]
----------------------------------------------------------------------------------------------------------------
Discount rate
---------------------------------------------------------------
5% 3% 2.5% 3%
Year ---------------------------------------------------------------
95th
Average Average Average percentile
----------------------------------------------------------------------------------------------------------------
2010............................................ 10 31 50 86
2015............................................ 11 36 56 105
2020............................................ 12 42 62 123
2025............................................ 14 46 68 138
2030............................................ 16 50 73 152
2035............................................ 18 55 78 168
2040............................................ 21 60 84 183
2045............................................ 23 64 89 197
2050............................................ 26 69 95 212
----------------------------------------------------------------------------------------------------------------
It is important to recognize that a number of key uncertainties
remain, and that current SCC estimates should be treated as provisional
and revisable because they will evolve with improved scientific and
economic understanding. The interagency group also recognizes that the
existing models are imperfect and incomplete. The National Research
Council report mentioned previously points out that there is tension
between the goal of producing quantified estimates of the economic
damages from an incremental ton of carbon and the limits of existing
efforts to model these effects. There are a number of 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 (revised July 2015), adjusted to 2014$ using
the implicit price deflator for gross domestic product (GDP) from the
Bureau of Economic Analysis. For each of the four sets of SCC cases
specified, the values for emissions in 2015 were $12.2, $40.0, $62.3,
and $117 per metric ton avoided (values expressed in 2014$). 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.
2. Social Cost of Other Air Pollutants
As noted previously, DOE has estimated how the considered energy
conservation standards would reduce site NOX emissions
nationwide and
[[Page 14602]]
decrease power sector NOX emissions in those 22 States not
affected by the CAIR.
DOE estimated the monetized value of NOX emissions
reductions using benefit per ton estimates from the Regulatory Impact
Analysis titled, ``Proposed Carbon Pollution Guidelines for Existing
Power Plants and Emission Standards for Modified and Reconstructed
Power Plants,'' published in June 2014 by EPA's Office of Air Quality
Planning and Standards. The report includes high and low values for
NOX (as PM2.5) for 2020, 2025, and 2030
discounted at 3 percent and 7 percent,\189\ which are presented in
chapter 14 of the NOPR TSD. DOE assigned values for 2021-2024 and 2026-
2029 using, respectively, the values for 2020 and 2025. DOE assigned
values after 2030 using the value for 2030.
---------------------------------------------------------------------------
\189\ For the monetized NOX benefits associated with
PM2.5, the related benefits (derived from benefit-per-ton
values) are based on an estimate of premature mortality derived from
the ACS study (Krewski et al., 2009), which is the lower of the two
EPA central tendencies. Using the lower value is more conservative
when making the policy decision concerning whether a particular
standard level is economically justified so using the higher value
would also be justified. If the benefit-per-ton estimates were based
on the Six Cities study (Lepuele et al., 2012), the values would be
nearly two-and-a-half times larger. (See chapter 14 of the NOPR TSD
for further description of the studies mentioned above.)
---------------------------------------------------------------------------
DOE multiplied the emissions reduction (tons) in each year by the
associated $/ton values, and then discounted each series using discount
rates of 3 percent and 7 percent as appropriate. DOE will continue to
evaluate the monetization of avoided NOX emissions and will
make any appropriate updates of the current analysis for the final
rulemaking.
DOE is evaluating appropriate monetization of avoided
SO2 and Hg emissions in energy conservation standards
rulemakings. DOE has not included monetization of those emissions in
the current analysis.
NEMA stated that because of the uncertainty in modeling the value
of emissions reductions, DOE should use manufacturer impacts, consumer
impacts, employment impacts, energy savings, and competition as the
sole metrics for justifying an energy efficiency standard. (NEMA, No.
34 at p. 28) DOE acknowledges that there is uncertainty regarding the
value of emissions reductions, and it uses a wide range of SCC values
to estimate the value of CO2 emissions reductions. Regarding
the inclusion of emissions impacts, the need for national energy and
water conservation is one of the factors that DOE must evaluate in
determining whether a potential energy conservation standard is
economically justified. (42 U.S.C. 6295(o)(2)(B)(i)(VI)) Given the
threats posed by global climate change to the economy, public health,
and national security, combined with the well-recognized potential of
many energy conservation measures to reduce emissions of greenhouse
gases, DOE believes that evaluation of the potential benefits from
slowing anthropogenic climate change must be part of the consideration
of the need for national energy conservation.
M. Utility Impact Analysis
The utility impact analysis estimates several effects on the
electric power industry that would result from the adoption of new or
amended energy conservation standards. The utility impact analysis
estimates the changes in installed electrical capacity and generation
that would result for each TSL. The analysis is based on published
output from the NEMS associated with AEO 2015. NEMS produces 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
published side cases to estimate the marginal impacts of reduced energy
demand on the utility sector. These marginal factors are estimated
based on the changes to electricity sector generation, installed
capacity, fuel consumption and emissions in the AEO reference case and
various side cases. Details of the methodology are provided in the
appendices to Chapters 13 and 15 of the NOPR TSD.
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 electricity savings calculated in the NIA
to provide estimates of selected utility impacts of new or amended
energy conservation standards. DOE seeks comment on its approach to
conducting the utility impact analysis (see issue 53 in section
VIII.E).
N. Employment Impact Analysis
DOE considers employment impacts in the domestic economy as one
factor in selecting a proposed standard. Employment impacts from new or
amended energy conservation standards include both direct and indirect
impacts. Direct employment impacts are any changes in the number of
employees of manufacturers of the products subject to standards, their
suppliers, and related service firms. 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 appliances. Indirect
employment impacts from standards consist of the net jobs created or
eliminated in the national economy, other than in the manufacturing
sector being regulated, caused by: (1) Reduced spending by end users on
energy; (2) reduced spending on new energy supply by the utility
industry; (3) increased consumer spending on new products to which the
new standards apply; 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).\190\ 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.\191\ 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). Thus, based
on the BLS data alone, DOE believes net national employment may
increase due to shifts in economic activity resulting from energy
conservation standards.
---------------------------------------------------------------------------
\190\ Data on industry employment, hours, labor compensation,
value of production, and the implicit price deflator for output for
these industries are available upon request by calling the Division
of Industry Productivity Studies (202-691-5618) or by sending a
request by email to [email protected].
\191\ U.S. Department of Commerce: Bureau of Economic Analysis.
Regional Multipliers: A User Handbook for the Regional Input-Output
Modeling System (RIMS II). 1992. U.S. Government Printing Office:
Washington, DC (Last accessed June 22, 2015.) https://ia801602.us.archive.org/5/items/regionalmultipl00unit/regionalmultipl00unit.pdf.
---------------------------------------------------------------------------
DOE estimated indirect national employment impacts for the standard
levels considered in this NOPR using an input/output model of the U.S.
economy
[[Page 14603]]
called Impact of Sector Energy Technologies Version 3.1.1 (ImSET).\192\
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 187 sectors most
relevant to industrial, commercial, and residential building energy
use.
---------------------------------------------------------------------------
\192\ Scott, M., J. Roop, O. Livingston, R. Schultz, and P.
Balducci. ImSET 3.1: Impact of Sector Energy Technologies Model
Description and User's Guide. 2009. Pacific Northwest National
Laboratory: Richland, WA. (Last accessed June 10, 2015.) http://www.pnl.gov/main/publications/external/technical_reports/PNNL-18412.pdf.
---------------------------------------------------------------------------
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 overestimate actual job
impacts over the long run for this rule. Therefore, DOE generated
results for near-term timeframes, where these uncertainties are
reduced. DOE welcomes input on its approach to assessing national
employment impacts (see issue 54 in section VIII.E). For more details
on the employment impact analysis, see chapter 16 of the NOPR TSD.
VI. Analytical Results and Conclusions
The following section addresses the results from DOE's analyses
with respect to the considered energy conservation standards for GSLs.
It addresses the TSLs examined by DOE, the projected impacts of each of
these levels if adopted as energy conservation standards for GSLs, and
the standards levels that DOE is proposing to adopt in this NOPR.
Additional details regarding DOE's analyses are contained in the NOPR
TSD supporting this notice.
A. Trial Standard Levels
DOE analyzed the benefits and burdens of four TSLs for GSLs. These
TSLs were developed by combining specific ELs for each of the product
classes analyzed by DOE. DOE presents the results for the TSLs in this
document, while the results for all efficacy levels that DOE analyzed
are in the NOPR TSD. TSL 4 is composed of the max-tech ELs. TSL 3 is
composed of the ELs that yield the maximum NPV with any energy savings
for products currently available on the market. TSL 2 is composed of
the ELs that would minimize manufacturer impacts and allow for a
continuous standard for all integrated GSLs. TSL 1 corresponds to the
lowest standard level with any energy savings.
DOE used data on the representative product classes from the
engineering and pricing analyses described in section V.C.2 to evaluate
the benefits and burdens of each of the TSLs. DOE analyzed the benefits
and burdens by conducting the analyses described in section III.E.1 for
each TSL. Table VI-1 presents the TSLs and the corresponding ELs for
GSLs.
Table VI-1--Composition of TSLs for GSLs by Efficacy Level
----------------------------------------------------------------------------------------------------------------
Representative product class
TSL ---------------------------------------------------------------------------
Integrated low-lumen Integrated high-lumen Non-integrated
----------------------------------------------------------------------------------------------------------------
1................................... EL 1................... EL 1................... EL 0.
2................................... EL 2................... EL 2................... EL 0.
3................................... EL 3................... EL 2................... EL 0.
4................................... EL 4................... EL 2................... EL 1.
----------------------------------------------------------------------------------------------------------------
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
DOE analyzed the economic impacts on GSL consumers by looking at
the effects potential new or amended standards at each TSL would have
on the LCC and PBP. DOE also examined the impacts of potential
standards on consumer subgroups. These analyses are discussed below.
a. Life-Cycle Cost and Payback Period
In general, higher efficiency products affect consumers in two
ways: (1) purchase price increases, and (2) annual operating costs
decrease. In the case of GSLs, however, DOE projects that higher
efficacy GSLs will sometimes have a lower purchase price than less
efficacious lamps. Inputs used for calculating the LCC and PBP include
total installed costs (i.e., product price plus installation costs),
and operating costs (i.e., annual energy use, energy prices, energy
price trends, repair costs, and maintenance costs). The LCC calculation
also uses product lifetime and a discount rate. Chapter 8 of the NOPR
TSD provides detailed information on the LCC and PBP analyses.
Table VI-2 through Table VI-7 show the LCC and PBP results for the
ELs considered for each product class. The results in the first of each
pair of tables represent the average values if all consumers in the
sample make a purchase at the specified EL, and the simple payback for
each EL is measured relative to the baseline product (EL 0). In
addition, the lifetime operating cost of each EL is calculated for the
LCC analysis period, which is the lifetime of the baseline product (EL
0) in each product class. In the second table of each pair, the impact
of a potential standard is measured based on the change in the efficacy
distribution under the specified TSL in the compliance year compared to
the distribution in no-new-standards case (see section V.F.11 of this
notice). The savings refer only to consumers who are affected by a
standard at a given TSL. Those whose purchasing decision is not
affected are not included in the calculation. Consumers for whom the
LCC increases under a given TSL experience a net cost.
[[Page 14604]]
Table VI-2--Average LCC and PBP Results by Efficacy Level for Integrated Low-Lumen GSLs
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2014$)
---------------------------------------------------------------- Average
EL Lifetime Simple payback lifetime
Installed cost First year's operating LCC (years) (years)
operating cost cost*
--------------------------------------------------------------------------------------------------------------------------------------------------------
Residential Sector
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 2.55 2.18 3.65 6.19 -- 5.5
1....................................................... 3.04 2.03 3.39 5.95 3.32 6.8
2....................................................... 5.15 1.62 2.67 5.44 4.59 6.8**, 18.0**
3....................................................... 4.31 1.36 2.23 4.49 2.14 18.0
4....................................................... 4.05 1.28 2.10 4.23 1.68 18.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Commercial Sector
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 3.94 6.39 10.56 14.71 -- 2.6
1....................................................... 4.42 5.96 9.84 13.79 1.12 3.2
2....................................................... 6.27 4.58 7.57 11.15 1.29 3.2**, 7.7**
3....................................................... 5.62 3.99 6.59 9.73 0.70 7.7
4....................................................... 5.37 3.77 6.23 9.22 0.55 7.7
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each EL represent the average value if all purchasers use products at that EL.
The PBP is measured relative to the baseline (EL 0) product.
* Calculated over the LCC analysis period, which is the lifetime of the EL 0 lamp.
** The two lifetimes correspond to the CFL (shorter) and LED (longer) lamp options at each EL.
Table VI-3--Average LCC Savings Relative to the No-New-Standards Case for Integrated Low-Lumen GSLs
----------------------------------------------------------------------------------------------------------------
Percent of
Average LCC consumers that
TSL EL savings* (2014$) experience net
cost
----------------------------------------------------------------------------------------------------------------
Residential Sector
----------------------------------------------------------------------------------------------------------------
1...................................................... 1 0.32 1.4
2...................................................... 2 0.32 1.4
3...................................................... 3 0.75 1.3
4...................................................... 4 0.88 1.0
----------------------------------------------------------------------------------------------------------------
Commercial Sector
----------------------------------------------------------------------------------------------------------------
1...................................................... 1 1.33 0.2
2...................................................... 2 1.33 0.2
3...................................................... 3 1.32 0
4...................................................... 4 1.40 0
----------------------------------------------------------------------------------------------------------------
* The savings represent the average LCC for affected consumers.
Table VI-4--Average LCC and PBP Results by Efficacy Level for Integrated High-Lumen GSLs
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average Costs 2014$
---------------------------------------------------------------------------- Simple payback Average lifetime
EL First year's Lifetime years years
Installed cost operating cost operating cost * LCC
--------------------------------------------------------------------------------------------------------------------------------------------------------
Residential Sector
--------------------------------------------------------------------------------------------------------------------------------------------------------
0..................................... 9.14 3.95 8.42 17.57 -- 6.6
1..................................... 9.92 3.71 7.89 17.81 3.20 6.6
2..................................... 10.55 3.58 7.63 16.79 3.86 7.7
--------------------------------------------------------------------------------------------------------------------------------------------------------
Commercial Sector
--------------------------------------------------------------------------------------------------------------------------------------------------------
0..................................... 10.58 12.53 24.85 35.64 -- 3.1
1..................................... 11.36 11.77 23.33 34.91 1.02 3.1
2..................................... 11.99 11.39 22.58 33.21 1.23 3.8
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each EL represent the average value if all purchasers use products at that EL. The PBP is measured relative to the baseline (EL 0)
product.
* Calculated over the LCC analysis period, which is the lifetime of the EL 0 lamp.
[[Page 14605]]
Table VI-5--Average LCC Savings Relative to the No-New-Standards Case for Integrated High-Lumen GSLs
----------------------------------------------------------------------------------------------------------------
Percent of
Average LCC consumers that
TSL EL savings * experience
(2014$) net cost
----------------------------------------------------------------------------------------------------------------
Residential Sector
----------------------------------------------------------------------------------------------------------------
1............................................................... 1 0.24 23.2
2............................................................... 2 0.94 8.9
3............................................................... 2 0.96 8.7
4............................................................... 2 0.96 8.7
----------------------------------------------------------------------------------------------------------------
Commercial Sector
----------------------------------------------------------------------------------------------------------------
1............................................................... 1 1.13 3.3
2............................................................... 2 2.00 4.9
3............................................................... 2 2.02 4.9
4............................................................... 2 2.02 4.9
----------------------------------------------------------------------------------------------------------------
* The savings represent the average LCC for affected consumers.
Table VI-6--Average LCC and PBP Results by Efficacy Level for Non-Integrated GSLs
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average costs (2014$)
---------------------------------------------------------------- Simple Average
EL Lifetime payback lifetime
Installed cost First year's operating cost LCC (years) (years)
operating cost *
--------------------------------------------------------------------------------------------------------------------------------------------------------
Commercial Sector
--------------------------------------------------------------------------------------------------------------------------------------------------------
0....................................................... 9.00 10.21 20.17 29.38 .............. 3.1
1....................................................... 9.69 10.11 19.97 28.44 6.73 3.8 ** 5.0 **
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The results for each EL represent the average value if all purchasers use products at that EL.
The PBP is measured relative to the baseline (EL 0) product.
* Calculated over the LCC analysis period, which is the lifetime of the EL 0 lamp.
** The two lifetimes correspond to the two different lamp options at this EL.
Table VI-7--Average LCC Savings Relative to the No-New-Standards Case for Non-Integrated GSLs
----------------------------------------------------------------------------------------------------------------
Percent of
Average LCC consumers that
TSL EL savings* (2014$) experience net
cost
----------------------------------------------------------------------------------------------------------------
Commercial Sector
----------------------------------------------------------------------------------------------------------------
4...................................................... 1 0.95 6.1
----------------------------------------------------------------------------------------------------------------
* The savings represent the average LCC for affected consumers.
b. Consumer Subgroup Analysis
In the consumer subgroup analysis, DOE estimated the impact of the
considered TSLs on low-income households and small businesses. Table
VI-8 through Table VI-12 compares the average LCC savings and PBP at
each EL for the two consumer subgroups, along with the average LCC
savings for the entire sample. In most cases, the average LCC savings
and PBPs for low-income households and small businesses at the
considered ELs are not substantially different from the averages for
all households and all buildings. Chapter 11 of the NOPR TSD presents
the complete LCC and PBP results for the subgroups.
Table VI-8--Comparison of LCC Savings and PBP for Low-Income Households and All Households for Integrated Low-
Lumen GSLs
----------------------------------------------------------------------------------------------------------------
Average life-cycle cost Simple payback period (years)
savings (2014$) -------------------------------
TSL EL --------------------------------
Low-income Low-income All households
households All households households
----------------------------------------------------------------------------------------------------------------
1............................... 1 0.37 0.32 3.28 3.32
2............................... 2 0.37 0.32 4.53 4.59
3............................... 3 0.73 0.75 2.11 2.14
[[Page 14606]]
4............................... 4 0.85 0.88 1.65 1.68
----------------------------------------------------------------------------------------------------------------
Table VI-9--Comparison of LCC Savings and PBP for Small Businesses and All Buildings for Integrated Low-Lumen
GSLs
----------------------------------------------------------------------------------------------------------------
Average life-cycle cost Simple payback period (years)
savings (2014$) -------------------------------
TSL EL --------------------------------
Small Small All businesses
businesses All businesses businesses
----------------------------------------------------------------------------------------------------------------
1............................... 1 1.26 1.33 1.10 1.12
2............................... 2 1.26 1.33 1.27 1.29
3............................... 3 1.30 1.32 0.69 0.70
4............................... 4 1.38 1.40 0.54 0.55
----------------------------------------------------------------------------------------------------------------
Table VI-10--Comparison of LCC Savings and PBP for Low-Income Households and All Households for Integrated High-
Lumen GSLs
----------------------------------------------------------------------------------------------------------------
Average life-cycle cost Simple payback period (years)
savings (2014$) -------------------------------
TSL EL --------------------------------
Low-income Low-income All households
households All households households
----------------------------------------------------------------------------------------------------------------
1............................... 1 0.20 0.24 3.18 3.20
2............................... 2 0.88 0.94 3.84 3.86
----------------------------------------------------------------------------------------------------------------
Table VI-11--Comparison of LCC Savings and PBP for Small Businesses and All Buildings for Integrated High-Lumen
GSLs
----------------------------------------------------------------------------------------------------------------
Average life-cycle cost Simple payback period (years)
savings (2014$) -------------------------------
TSL EL --------------------------------
Small Small All businesses
businesses All businesses businesses
----------------------------------------------------------------------------------------------------------------
1............................... 1 1.06 1.13 1.02 1.02
2............................... 2 1.89 2.00 1.23 1.23
----------------------------------------------------------------------------------------------------------------
Table VI-12--Comparison of LCC Savings and PBP for Small Businesses and All Buildings for Non-Integrated GSLs
----------------------------------------------------------------------------------------------------------------
Average life-cycle cost Simple payback period (years)
savings (2014$) -------------------------------
TSL EL --------------------------------
Small Small All businesses
businesses All businesses businesses
----------------------------------------------------------------------------------------------------------------
4............................... 1 0.93 0.95 6.68 6.73
----------------------------------------------------------------------------------------------------------------
c. Rebuttable-Presumption Payback
As discussed in section V.F.12, 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. In calculating a rebuttable-
presumption payback period for each of the considered ELs, DOE used
discrete values, and, as required by EPCA, based the energy use
calculation on the DOE test procedure for GSLs. In contrast, the PBPs
presented in section VI.B.1.a were calculated using distributions for
input values, with energy use based on field studies and RECS data.
Table VI-13 through Table VI-15 presents the rebuttable-presumption
payback periods for the considered ELs in each product class. While DOE
examined the rebuttable-presumption criterion, it considered whether
the standard levels considered for the NOPR are economically justified
through a more detailed analysis of the economic impacts of those
levels, pursuant to 42
[[Page 14607]]
U.S.C. 6295(o)(2)(B)(i), that considers the full range of impacts to
the consumer, manufacturer, nation, and environment. The results of
that analysis serve as the basis for DOE to definitively evaluate the
economic justification for a potential standard level, thereby
supporting or rebutting the results of any preliminary determination of
economic justification.
Table VI-13--Rebuttable-Presumption Payback Period Results for
Integrated Low-Lumen GSLs
------------------------------------------------------------------------
Residential Commercial
EL sector sector
------------------------------------------------------------------------
1....................................... 3.18 0.95
2....................................... 4.39 1.10
3....................................... 2.05 0.60
4....................................... 1.60 0.47
------------------------------------------------------------------------
Table VI-14--Rebuttable-Presumption Payback Period Results for
Integrated High-Lumen GSLs
------------------------------------------------------------------------
Residential Commercial
EL sector sector
------------------------------------------------------------------------
1....................................... 3.06 0.87
2....................................... 3.69 1.05
------------------------------------------------------------------------
Table VI-15--Rebuttable-Presumption Payback Period Results for Non-
Integrated GSLs
------------------------------------------------------------------------
Commercial
EL sector
------------------------------------------------------------------------
1....................................................... 5.74
------------------------------------------------------------------------
2. Economic Impacts on Manufacturers
DOE performed an MIA to estimate the impact of new and amended
energy conservation standards on manufacturers of GSLs. The following
sections describe the expected impacts on manufacturers at each TSL.
Chapter 12 of the NOPR TSD explains the analysis in further detail.
a. Industry Cash-Flow Analysis Results
Table VI-16 through Table VI-17 present the estimated financial
impacts (represented by changes in INPV) of the analyzed new and
amended energy conservation standards on GSL manufacturers, as well as
the conversion costs that DOE estimates GSL manufacturers would incur
at each TSL. To evaluate the range of cash-flow impacts on the GSL
industry, DOE used the preservation of gross margin markup scenarios to
estimate the impacts on manufacturers. This preservation of gross
margin markup scenario assumes that in the standards cases,
manufacturers would be able to pass along any higher production costs
required for more efficacious products to their consumers.
Specifically, the industry would be able to maintain its average no-
new-standards case gross margin (as a percentage of revenue) despite
any potential higher production costs in the standards cases.
DOE also modeled a low investment scenario and a high investment
scenario for manufacturers that correspond to the range of potential
investments manufacturers must make in order to comply with the
analyzed new and amended standards. Each investment 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 no-new-standards case and the
standards cases that result from the sum of discounted cash flows from
the reference year (2015) through the end of the analysis period
(2049). The results also discuss the difference in cash flows between
the no-new-standards case and the standards cases in the year before
the compliance date for proposed standards. This difference in cash
flow represents the size of the required conversion costs relative to
the cash flow generated by the GSL industry in the absence of new and
amended energy conservation standards.
To assess the upper (less severe) end of the range of potential
impacts on GSL manufacturers, DOE modeled a low investment conversion
cost scenario and to assess the lower (more severe) end of the range of
potential impacts on GSL manufacturers, DOE modeled a high investment
conversion cost scenario. Table VI-16 and Table VI-17 present the
projected range of potential results for GSL manufacture for the low
investment and high investment scenarios. DOE examined results for all
product classes together.
Table VI-16--Manufacturer Impact Analysis for General Service Lamps--Low Investment Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard levels
Units No-new- ---------------------------------------------------------------
standards case 1 2 3 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV...................................... 2014$ millions.............. 911.0 894.3 877.3 753.3 731.3
Change in INPV............................ 2014$ millions.............. .............. (16.7) (33.7) (157.7) (179.6)
%........................... .............. (1.8) (3.7) (17.3) (19.7)
Product Conversion Costs.................. 2014$ millions.............. 50.3 74.2 96.7 178.7 184.8
Capital Conversion Costs.................. 2014$ millions.............. 201.4 204.4 205.2 245.5 253.1
Total Conversion Costs.................... 2014$ millions.............. 251.7 278.6 301.9 424.1 437.9
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table VI-17--Manufacturer Impact Analysis for General Service Lamps--High Investment Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard levels
Units No-new- ---------------------------------------------------------------
standards case 1 2 3 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV...................................... 2014$ millions.............. 911.0 886.6 862.2 690.0 665.9
Change in INPV............................ 2014$ millions.............. .............. (24.4) (48.8) (221.0) (245.1)
%........................... .............. (2.7) (5.4) (24.3) (26.9)
Product Conversion Costs.................. 2014$ millions.............. 50.3 85.9 119.6 242.6 250.8
Capital Conversion Costs.................. 2014$ millions.............. 201.4 204.8 206.0 266.4 274.1
Total Conversion Costs.................... 2014$ millions.............. 251.7 290.7 325.7 509.0 525.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 14608]]
For the no-new-standards case DOE typically assumes conversion
costs are zero, because manufacturers typically do not need to make
additional investments beyond their normal capital expenditures and
investments in research and development if no-new-standards are
prescribed by a rulemaking. However, DOE included conversion costs in
the no-new-standards case since manufacturers would have to make
significant one-time investments to comply with the EISA 2007 45 lm/W
backstop. DOE estimates manufacturers will incur product conversion
costs of $50.3 million and capital conversion costs of $201.4 million
to comply with the efficacy requirements prescribed by the EISA 2007
backstop. Product conversion costs include investments in research,
development, testing, marketing, and certification that manufacturers
must make to create new GSL designs intended to replace the product
offering eliminated by the EISA 2007 backstop efficacy requirements.
Capital conversion costs include investments in production equipment
that GSL manufacturers would be required to make in order to
significantly expand their LED manufacturing capacity to meet expected
market demand for LED lamps caused by the EISA 2007 backstop.
TSL 1 sets the efficacy level at baseline for the Non-Integrated
product class and EL 1 for Integrated Low-Lumen and Integrated High-
Lumen product classes. At TSL 1, DOE estimates impacts on INPV to range
from -$24.4 million to -$16.7 million, or a change in INPV of -2.4
percent to -1.8 percent. At TSL 1, industry free cash flow (operating
cash flow minus capital expenditures) is expected to range from -$37.4
million to -$33.3, which is a decrease of approximately $13.5 million
and $9.4 million respectively, compared to the no-new-standards case
value of -$24.0 million in 2019, the year leading up to standards.
Percentage impacts on INPV are slightly negative at TSL 1. DOE
estimates that 96 percent of integrated low-lumen shipments, 78 percent
of integrated high-lumen shipments, and 100 percent of non-integrated
shipments will meet the ELs required at TSL 1 in 2020, the expected
compliance year of standards.
DOE expects product conversion costs will rise from $50.3 million
at the no-new-standards case to $74.2 million in the low investment
scenario and to $85.9 million in the high investment scenario at TSL 1.
Product conversion costs are driven primarily by manufacturers
redesigning CFLs to meet standards. DOE expects capital conversion
costs to increase from $201.4 million in the no-new-standards case to
$204.4 million in the low investment scenario and to $204.8 million in
the high investment scenario at TSL 1. The additional capital
conversion consists of minor retooling costs necessary to accommodate
the redesigned CFLs. DOE does not estimate any manufacturers would be
required to make any additional major production equipment expenditures
not made in the no-new-standards case, since manufacturers would either
simply remove product offering of non-compliant CFLs or make minor
modifications requiring retooling expenditures to existing CFL
production lines to comply with standards set at this TSL.
At TSL 1, the shipment-weighted average MPC increases by 1 percent
relative to the no-new-standards case MPC in 2020, the expected year of
compliance. In both the high and low investment scenarios,
manufacturers are not able to recover their conversion costs through
the slight increase in MPC over the course of the analysis period
resulting in a slightly negative INPV for each investment scenario.
TSL 2 sets the efficacy level at baseline for the Non-Integrated
product class and EL 2 for Integrated Low-Lumen and Integrated High-
Lumen product classes. EL 2 represents max tech for the Integrated
High-Lumen product class. At TSL 2, DOE estimates impacts on INPV to
range from -$48.8 million to -$33.7 million, or a change in INPV of -
5.4 percent to -3.7 percent. At TSL 2, industry free cash flow is
expected to range from -$49.3 million to -$41.3, which is a decrease of
approximately $25.4 million to $17.3 million respectively, compared to
the no-new-standards case value of -$24.0 million in 2019, the year
leading up to standards.
Percentage impacts on INPV range from slightly negative to
moderately negative at TSL 2. DOE estimates that 94 percent of
integrated low-lumen shipments, 52 percent of integrated high-lumen
shipments, and 100 percent of non-integrated shipments will meet the
ELs required at TSL 2 in 2020.
DOE expects product conversion costs will rise from $74.2 million
at TSL 1 to $96.7 million at TSL 2 in the low investment scenario and
from $85.9 million at TSL 1 to $119.6 million at TSL 2 in the high
investment scenario. This increase is primarily driven by more CFL
models needing to be redesigned to meet this analyzed TSL. DOE expects
capital conversion costs to increase from $204.4 million at TSL 1 to
$205.2 million at TSL 2 in the low investment scenario and from $204.8
million at TSL 1 to $206.0 million at TSL 2 in the high investment
scenario. This increase is driven by an expected increase in the number
of CFL models that would require new tooling due to their redesign.
Again, DOE does not estimate any manufacturers would be required to
make any additional major production equipment expenditures at this TSL
that are not made in the no-new-standards case.
At TSL 2, the shipment-weighted average MPC increases by 1 percent
relative to the no-new-standards case MPC in 2020. In both the high and
low investment scenarios, manufacturers are not able to recover their
conversion costs through the slight increase in MPC over the course of
the analysis period resulting in a slightly negative INPV for the low
investment scenario and a moderately negative INPV for the high
investment scenario.
TSL 3 sets the efficacy level at baseline for the Non-Integrated
product class, EL 2 for the Integrated High-Lumen product class, and EL
3 for the Integrated Low-Lumen product class. EL 3 is the first
efficacy level to require the use of LED lamps for the Integrated Low-
Lumen product class. At TSL 3, DOE estimates impacts on INPV to range
from -$221.0 million to -$157.7 million, or a change in INPV of -24.3
percent to -17.3 percent. At TSL 3, industry free cash flow is expected
range from -$126.4 million to -$88.8, which is a decrease of
approximately $102.4 million and $64.8 million respectively, compared
to the no-new-standards case value of -$24.0 million in 2019, the year
leading up to standards.
Percentage impacts on INPV are moderately negative at TSL 3. DOE
estimates that 57 percent of integrated low-lumen shipments, 52 percent
of integrated high-lumen shipments, and 100 percent of non-integrated
shipments will meet the ELs required at TSL 3 in 2020.
DOE expects product conversion costs will significantly rise from
$96.7 million at TSL 2 to $178.7 million at TSL 3 in the low investment
scenario and from $119.6 million at TSL 2 to $242.6 million at TSL 3 in
the high investment scenario. At this TSL, manufacturers would have to
abandon CFL production for the Integrated Low-Lumen product class and
spend a considerable amount of R&D to introduce replacement LED lamps
for those CFLs being removed from the market. DOE expects capital
conversion costs to significantly increase from $205.2 million at TSL 2
to $245.5 million at TSL 3 in the low
[[Page 14609]]
investment scenario and from $206.0 million at TSL 2 to $266.4 million
at TSL 3 in the high investment scenario. This increase is driven by an
expected increase in the number of production lines for LED lamps to
accommodate the increase in demand for LED lamps.
At TSL 3, the shipment-weighted average MPC decreases by 1 percent
relative to the no-new-standards case MPC in 2020. The slight decrease
in MPC and increase in conversion costs incurred by manufacturers
result in a moderately negative INPV in the low investment scenario and
a significantly negative INPV in the high investment scenario at TSL 3.
TSL 4 sets the efficacy level at EL 1 for the Non-Integrated
product class, EL 2 for the Integrated High-Lumen product class, and EL
4 for the Integrated Low-Lumen product class. TSL 4 represents max tech
for all product classes. At TSL 4, DOE estimates impacts on INPV to
range from -$245.1 million to -$179.6 million, or a change in INPV of -
26.9 percent to -19.7 percent. At TSL 4, industry free cash flow is
expected to range from -$133.5 million to -$94.9, which is a decrease
of approximately $109.5 million and $70.9 million respectively,
compared to the no-new-standards case value of -$24.0 million in 2019,
the year leading up to standards.
Percentage impacts on INPV range from moderately negative to
significantly negative at TSL 4. DOE estimates that 25 percent of
integrated low-lumen shipments, 52 percent of integrated high-lumen
shipments, and 68 percent of non-integrated shipments will meet the ELs
required at TSL 4 in 2020.
DOE expects product conversion costs will slightly rise from $178.7
million at TSL 3 to $184.8 million at TSL 4 in the low investment
scenario and from $242.6 million at TSL 3 to $250.8 million at TSL 4 in
the high investment scenario. At this TSL, manufacturers would have to
improve the efficacy of CFLs in the Non-Integrated product class, which
would result in an increase in R&D, testing, and certification costs.
DOE expects capital conversion costs to slightly increase from $245.5
million at TSL 3 to $253.1 million at TSL 4 in the low investment
scenario and from $266.4 million at TSL 3 to $274.1 million at TSL 4 in
the high investment scenario. DOE does not expect manufacturers to have
to make significant additional production equipment expenditures at TSL
4 compared to the production equipment expenditures made at TSL 3 to
make the more efficacious non-integrated CFLs required at TSL 4. DOE
only assumes that there would be some increase in tooling costs
associated with the redesign of some LED models for the Integrated Low-
Lumen product classes as well as some increase in tooling costs
associated with the redesign of some of the CFL models for the Non-
Integrated product class required at TSL 4 that would not be incurred
at TSL 3.
At TSL 4, the shipment-weighted average MPC decreases by 3 percent
relative to the no-new-standards case MPC in 2020. The slight decrease
in MPC and increase in conversion costs incurred by manufacturers
result in a moderately negative INPV in the low investment scenario and
a significantly negative INPV in the high investment scenario at TSL 4.
b. Impacts on Employment
DOE determined that there was only one GSL manufacturer that
manufactured lamps or lamp components covered by this rulemaking
domestically. During manufacturing interviews, manufacturers stated
that the vast majority of LED manufacturing, and all CFL manufacturing,
is done abroad. Some of these facilities are owned by the GSL
manufacturer and others outsource their GSL production to original
equipment manufacturers located primarily in Asia. However, several CFL
manufacturers have domestic employees responsible for the R&D,
marketing, sales, and distribution of CFLs.
Based on manufacturer interviews, DOE estimates that there are
approximately 100 domestic employees dedicated to the non-production
aspects of CFLs. Since the majority of CFLs are in the Integrated Low-
Lumen product class, DOE believes there would be a sizable reduction in
this number of domestic non-production employees at the proposed TSL.
Manufacturers claim that the market disruption caused by eliminating
CFLs from the Integrated Low-Lumen product class, would cause some
manufacturers to reduce the number of domestic non-production
employees.
DOE also limited the employment impact analysis to the domestic
production of CFLs and LED lamps covered by this rulemaking and did not
analyze the impact of the EISA 2007 45 lm/W backstop on the domestic
production of other lamps, since they are outside the scope of this
rulemaking.
Overall, based on DOE's market research, manufacturer feedback, and
the scope of the employment impact analysis, DOE anticipates a limited
impact on domestic employment, due to the elimination of domestic
employees responsible for R&D, marketing, sales, and distribution of
CFLs, caused by the proposed standard in this NOPR.
DOE seeks comment on the assumption that there is only one GSL
manufacturer with domestic production of LED lamps and none with
domestic production of CFLs. DOE also requests comment on the
assumption that approximately 100 employees are involved in the R&D,
marketing, sales, and distribution of CFLs. Additionally, DOE seeks
comment on any potential domestic employment impacts as a result of the
proposed new and amended energy conservation standards for GSLs in this
NOPR.
c. Impacts on Manufacturing Capacity
During manufacturer interviews several GSL manufacturers expressed
concern over the potential LED manufacturing capacity of any standards
that could only be met by LED lamps for the Integrated Low-Lumen
product class. These manufacturers stated that as other countries and
regions adopt more-stringent lighting efficiency standards, especially
Europe, around the compliance date of this rulemaking, worldwide LED
manufacturing capacity would be severely strained if LED lamps are
required to meet DOE's GSL energy conservation standards.
Manufacturers stated that if DOE sets energy conservation standards
that only LED lamps could meet (i.e., TSL 3 or 4), the demand for LED
lamps would increase by 2 or 3 times over the course of a single year.
This is supported by DOE shipment analysis which projects Integrated
Low-Lumen LED shipments rising from approximately 242 million units in
2019 in the no-new-standards case to over 675 million units in 2020 at
TSLs 3 and 4. Manufacturers further claimed that they would not be
willing to invest significantly to increase LED manufacturing capacity,
because the LED market would shrink over the following 10 years since
LED lamps have extremely long lifetimes. This is again supported by
DOEs shipment analysis which projects Integrated Low-Lumen LED
shipments declining from over 675 million units in 2020 to
approximately 172 million units in 2030 at TSLs 3 and 4.
Manufacturers stated that any manufacturer that significantly
increased their LED manufacturing capacity could face the possibility
of going out of business before they were able to recover their
investments required to increase their LED manufacturing capacity due
to this decline in future LED shipments. Therefore, it would be
difficult for GSL manufacturers to meet the GSL demand for any
standards that could only be met
[[Page 14610]]
by using LED lamps for the Integrated Low-Lumen product class.
DOE is proposing standards that require the use of LED lamps to
meet the Integrated Low-Lumen product class and acknowledges that
manufacturers would have to face a difficult decision of whether to
invest in the required production equipment necessary to supply the
market with LED lamps in the compliance year and the years immediately
following that, given that they may not be able to recover all of those
investments due to the long-term drop in LED lamp shipments. DOE also
acknowledges that as other nations and regions implement their own
general service lighting regulations that require the use of LED lamps
there could be a potential global supply chain shortage of LEDs around
the effective date of this rulemaking. However, DOE believes that GSL
manufacturers are capable of meeting the U.S. demand for LED lamps at
proposed standard, TSL 3, given the three year time frame between the
announcement of a final rule and the implementation of that final rule.
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
disproportionately affected. DOE only identified one manufacturer
subgroup that it believes could be disproportionally impacted by energy
conservation standards and would require a separate analysis in the
MIA, small businesses. DOE analyzes the impacts on small businesses in
a separate analysis in section VII.B of this NOPR as part of the
Regulatory Flexibility Analysis. DOE did not identify any other
adversely impacted manufacturer subgroups for GSLs for this rulemaking
based on the results of the industry characterization. DOE seeks
comment on any other potential manufacturer subgroups that could be
disproportionally impacted by new and amended energy conservation
standards for GSLs.
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. Multiple
regulations affecting the same manufacturer can strain profits and lead
companies to abandon product lines or markets with lower expected
future returns than competing products. For these reasons, DOE conducts
a cumulative regulatory burden analysis as part of its rulemakings for
GSLs.
DOE identified a number of requirements, in addition to new and
amended energy conservation standards for GSLs, that GSL manufacturers
will face for products they manufacture approximately three years prior
to and three years after the estimated compliance date of these new and
amended standards. The following section addresses key related concerns
that manufacturers raised during interviews regarding cumulative
regulatory burden.
Manufacturers raised concerns about other DOE energy conservation
standards that lighting manufacturers must comply with. In addition to
the proposed new and amended energy conservation standards on GSLs,
several other existing and pending federal regulations may apply to
other products produced by GSL manufacturers. These lighting
regulations include the finalized metal halide lamp fixture standards
(79 FR 7746 [Feb. 10, 2014]), the finalized GSFL standards (80 FR 4042
[Jan. 26, 2015]), the finalized ceiling fan light kit standards (81 FR
580 [Jan. 6, 2016]), and the ongoing fluorescent lamp ballast standards
(80 FR 35886 [Jun. 23, 2015]).
DOE acknowledges that each regulation can impact a manufacturer's
financial operations. Multiple regulations affecting the same
manufacturer can strain manufacturers' profit and possibly cause them
to exit particular markets. Table VI-18 lists other DOE energy
conservation standards that could also affect GSL manufacturers in the
three years leading up to and after the estimated compliance date of
the new and amended energy conservation standards for GSLs. On December
9, 2015 DOE published a final determination for high-intensity
discharge lamps that determined standards were not technologically
feasible or economically justified based in part on manufacturers
concerns regarding costs asscociated to meet more stringent efficacy
levels. (80 FR 76355)
Table VI-18--Other DOE Regulations Potentially Affecting General Service
Lamp Manufacturers
------------------------------------------------------------------------
Approximate Estimated industry
Regulation compliance total conversion
date expenses
------------------------------------------------------------------------
Metal Halide Lamp Fixtures........ 2017 $25 million
(2012$).\193\
General Service Fluorescent Lamps. 2018 $26.6 million
(2013$).\194\
Ceiling Fan Light Kits............ 2019 $17.0-$18.9 million
(2014$).\195\
Fluorescent Lamp Ballast.......... * 2022 N/A[dagger].
Candelabra Base Incandescent Lamps bN/A N/A[dagger].
and Intermediate-Base
Incandescent Lamps.
Other Incandescent Reflector Lamps bN/A N/A[dagger].
------------------------------------------------------------------------
* The dates listed are an approximation. The exact dates are pending
final DOE action.
[dagger] For energy conservation standards for rulemakings awaiting DOE
final action, DOE does not have a finalized estimated total industry
conversion cost.
b These rulemakings are placed on hold due to the Consolidated and
Further Continuing Appropriations Act, 2015 (Public Law 113-235, Dec.
16, 2014).
[[Page 14611]]
Manufacturers also stated that they must comply with other Federal
and state regulations and certifications, separate from DOE's energy
conservation standards, which cover the GSLs they manufacture. These
include California Title 20, which has energy conservation standards
identical to DOE's existing medium base CFL standards, but requires an
additional certification; Interstate Mercury Education and Reduction
Clearinghouse (IMERC) labeling requirements for CFLs; FTC's labeling
requirements for all GSLs; and the Federal Communications Commission's
electromagnetic interference verification for LEDs. Lastly, as
described in EISA 2007, all lamps classified as GSL, regardless of
whether standards are set for those products in this rulemaking, will
have to meet a minimum of 45 lm/W by January 1, 2020. (42 U.S.C.
6295(i)(6)(A)(v)) DOE included the significant conversion costs that
GSL manufacturers would have to make to comply with the EISA 2007
backstop in the no-new-standards case to more accurately reflect the
total investments GSL manufacturers would have to make at the analyzed
standard levels. These EISA 2007 backstop conversion costs are included
in the cash flow analyses described in section VI.B.2.a.
---------------------------------------------------------------------------
\193\ Estimated industry conversion expenses were published in
the TSD for the February 2014 metal halide lamp fixtures final rule.
79 FR 7746 The TSD for the 2014 metal halide lamp fixture final rule
can be found at http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/16.
\194\ Estimated industry conversion expenses were published in
the TSD for the January 2015 general service fluorescent lamps final
rule. 80 FR 4042 The TSD for the 2015 general service fluorescent
lamps final rule can be found at http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/24.
\195\ Estimated industry conversion expenses were published in
the TSD for the January 2016 celing fan light kit final rule. 81 FR
580 The TSD for the 2016 ceiling fan light kit final rule can be
found at https://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/66.
---------------------------------------------------------------------------
Manufacturers also stated that several of their models sold in the
U.S. are also sold in other international markets and therefore must
also comply with a handful of other international standards.
Manufacturers stated that there are standards that GSLs must comply
with in order to be sold in Canada and Mexico.
DOE discusses these and other requirements in chapter 12 of the
NOPR TSD. DOE seeks comment on the compliance costs of any other
regulations GSL manufacturers must make, especially if compliance with
those regulations is required three years before or after the estimated
compliance date of these proposed standards (2020).
3. National Impact Analysis
a. Significance of Energy Savings
To estimate the energy savings attributable to potential standards
for GSLs, DOE compared the energy consumption of those products under
the no-new-standards case to their anticipated energy consumption under
each TSL. The savings are measured over the entire lifetime of products
purchased in the 30-year period that begins in the year of anticipated
compliance with amended standards (2020-2049). Table VI-19 present
DOE's projections of the NES for each TSL considered for GSLs. The
savings were calculated using the approach described in section V.H of
this NOPR.
Table VI-19--Cumulative National Energy Savings for GSLs Shipped in 2020-2049
----------------------------------------------------------------------------------------------------------------
Trial standard level (quads)
---------------------------------------------------------------
1 2 3 4
----------------------------------------------------------------------------------------------------------------
Primary Energy.................................. 0.039 0.055 0.81 1.05
FFC Energy...................................... 0.041 0.058 0.85 1.09
----------------------------------------------------------------------------------------------------------------
OMB Circular A-4 \196\ requires agencies to present analytical
results, including separate schedules of the monetized benefits and
costs that show the type and timing of benefits and costs. Circular A-4
also directs agencies to consider the variability of key elements
underlying the estimates of benefits and costs. For this rulemaking,
DOE undertook a sensitivity analysis using nine, rather than 30, years
of product shipments. The choice of a nine-year period is a proxy for
the timeline in EPCA for the review of certain energy conservation
standards and potential revision of and compliance with such revised
standards.\197\ The review timeframe established in EPCA is generally
not synchronized with the product lifetime, product manufacturing
cycles, or other factors specific to GSLs. Thus, such results are
presented for informational purposes only and are not indicative of any
change in DOE's analytical methodology. The NES sensitivity analysis
results based on a nine-year analytical period are presented in Table
VI-20. The impacts are counted over the lifetime of GSLs purchased in
2020-2028.
---------------------------------------------------------------------------
\196\ U.S. Office of Management and Budget. Circular No. A-4,
Regulatory Analysis. 2003. Washington, DC (Last accessed June 15,
2015.) http://www.whitehouse.gov/sites/default/files/omb/assets/regulatory_matters_pdf/a-4.pdf.
\197\ 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 VI-20--Cumulative National Energy Savings for GSLs; Nine Years of Shipments (2020-2028)
----------------------------------------------------------------------------------------------------------------
Trial standard level (quads)
---------------------------------------------------------------
1 2 3 4
----------------------------------------------------------------------------------------------------------------
Primary Energy.................................. 0.023 0.027 0.444 0.562
FFC Energy...................................... 0.024 0.028 0.464 0.587
----------------------------------------------------------------------------------------------------------------
[[Page 14612]]
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 GSLs. In
accordance with OMB's guidelines on regulatory analysis,\198\ DOE
calculated NPV using both a 7-percent and a 3-percent real discount
rate. Table VI-21 shows the consumer NPV results with impacts counted
over the lifetime of products purchased in 2020-2049. Table VI-21
implicitly includes a negative total incremental installed cost of $0.9
billion and $1.4 billion dollars at seven and three percent discount
rates, respectively. The negative total cost increment is explained by
the reduction in product costs that occurs because (1) more efficacious
lamps have longer average lifetimes than less efficacious lamps,
resulting in fewer replacement purchases, (2) the purchase price of
more efficacious LED lamps is lower than the price of less efficacious
LED lamps, and (3) the purchase price of LED lamps declines faster than
the price of CFLs during the analysis period, resulting in LED lamps
becoming less expensive than CFLs. However, negative compliance costs
run counter an economic theory that assumes a perfect capital market
with perfect rationality of agents having complete information. In such
a market, because the more efficacious GSLs are less expensive and
longer lived than the baseline product, consumers would have an
incentive to purchase them even in the absence of standards. For these
reasons, DOE requests comment on various aspects of the inputs to the
installed cost analysis, such as assumptions about consumers' response
to first cost versus long-term operating cost, the price structure
developed for LED lamps, the application of learning curves that yield
declining prices over the analysis period, the increased lifetime of
the more efficacious products, assumptions for manufacturer capital and
product conversion costs, and other factors. In addition, DOE requests
comment and information on any other factors that might be more
difficult to quantify, such as any lessening of utility of the more
efficient product or consumer welfare losses due to the more stringent
standards.
---------------------------------------------------------------------------
\198\ U.S. Office of Management and Budget, ``Circular A-4:
Regulatory Analysis,'' section E, (Sept. 17, 2003) (Available at:
http://www.whitehouse.gov/omb/circulars_a004_a-4/).
Table VI-21--Cumulative Net Present Value of Consumer Benefits for GSLs Shipped in 2020-2049
----------------------------------------------------------------------------------------------------------------
Trial standard level (billion 2014$)
---------------------------------------------------------------
1 2 3 4
----------------------------------------------------------------------------------------------------------------
3%.............................................. 0.34 0.53 9.05 11.66
7%.............................................. 0.15 0.24 4.41 5.69
----------------------------------------------------------------------------------------------------------------
The NPV results based on the aforementioned 9-year analytical
period are presented in Table VI-22. The impacts are counted over the
lifetime of products purchased in 2020-2028. As mentioned previously,
such results are presented for informational purposes only and are not
indicative of any change in DOE's analytical methodology or decision
criteria.
Table VI--22 Cumulative Net Present Value of Consumer Benefits for GSLs; Nine Years of Shipments (2020-2028)
----------------------------------------------------------------------------------------------------------------
Trial standard level (billion 2014$)
Discount rate ---------------------------------------------------------------
1 2 3 4
----------------------------------------------------------------------------------------------------------------
3%.............................................. 0.23 0.27 5.75 7.33
7%.............................................. 0.12 0.15 3.36 4.31
----------------------------------------------------------------------------------------------------------------
The above results utilize the reference economic and price
assumptions in the shipments and NIA analyses. DOE also conducted a
number of alternative analyses, results of which can be found in
appendix 10E of the NOPR TSD.
c. Indirect Impacts on Employment
DOE expects energy conservation standards for GSLs to reduce energy
bills for consumers of those products, with the resulting net savings
being redirected to other forms of economic activity. These expected
shifts in spending and economic activity could affect the demand for
labor. As described in section V.N of this document, 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 timeframes
(2020-2025), where these uncertainties are reduced.
The results suggest that the proposed standards are likely to have
a 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 16 of the NOPR TSD presents detailed results
regarding anticipated indirect employment impacts.
4. Impact on Utility or Performance of Products
DOE has tentatively concluded that the standards proposed in this
NOPR would not reduce the utility or performance of GSLs under
consideration in this rulemaking. Manufacturers of these products
currently offer units that meet or exceed the proposed standards.
[[Page 14613]]
5. Impact of Any Lessening of Competition
As discussed in section III.E.1.e, the Attorney General determines
the impact, if any, of any lessening of competition likely to result
from a proposed standard, and transmits such determination in writing
to the Secretary, together with an analysis of the nature and extent of
such impact. To assist the Attorney General in making such
determination, DOE has provided DOJ with copies of this NOPR and the
accompanying TSD for review. DOE will consider DOJ's comments on the
proposed rule in determining whether to proceed to a final rule. DOE
will publish and respond to DOJ's comments in that document.
6. Need of the Nation To Conserve Energy
Enhanced energy efficiency, where economically justified, improves
the Nation's energy security, strengthens the economy, and reduces the
environmental impacts (costs) of energy production. Reduced electricity
demand due to energy conservation standards is also likely to reduce
the cost of maintaining the reliability of the electricity system,
particularly during peak-load periods. As a measure of this reduced
demand, chapter 15 in the NOPR TSD presents the estimated reduction in
generating capacity, relative to the no-new-standards case, for the
TSLs that DOE considered in this rulemaking.
Energy conservation from new or amended standards for GSLs is
expected to yield environmental benefits in the form of reduced
emissions of air pollutants and greenhouse gases. Table VI-23 provides
DOE's estimate of cumulative emissions reductions expected to result
from the TSLs considered in this rulemaking. The table includes both
power sector emissions and upstream emissions. The emissions were
calculated using the multipliers discussed in section V.K. DOE reports
annual emissions reductions for each TSL in chapter 13 of the NOPR TSD.
Table VI-23--Cumulative Emissions Reduction for GSLs Shipped in 2020-2049
----------------------------------------------------------------------------------------------------------------
Trial standard level
---------------------------------------------------------------
1 2 3 4
----------------------------------------------------------------------------------------------------------------
Power Sector Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)....................... 2.390 3.334 49.043 63.306
SO2 (thousand tons)............................. 1.496 2.060 30.593 39.457
NOX (thousand tons)............................. 2.594 3.634 53.280 68.795
Hg (tons)....................................... 0.006 0.008 0.114 0.147
CH4 (thousand tons)............................. 0.213 0.294 4.362 5.627
N2O (thousand tons)............................. 0.030 0.042 0.619 0.798
----------------------------------------------------------------------------------------------------------------
Upstream Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)....................... 0.129 0.182 2.670 3.449
SO2 (thousand tons)............................. 0.024 0.034 0.497 0.642
NOX (thousand tons)............................. 1.848 2.609 38.234 49.394
Hg (tons)....................................... 0.000 0.000 0.001 0.001
CH4 (thousand tons)............................. 10.190 14.395 210.958 272.547
N2O (thousand tons)............................. 0.001 0.002 0.025 0.032
----------------------------------------------------------------------------------------------------------------
Total FFC Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)....................... 2.520 3.517 51.713 66.755
SO2 (thousand tons)............................. 1.521 2.094 31.090 40.099
NOX (thousand tons)............................. 4.442 6.244 91.514 118.189
Hg (tons)....................................... 0.006 0.008 0.115 0.148
CH4 (thousand tons)............................. 10.403 14.689 215.319 278.173
CH4 (thousand tons CO2eq) *..................... 291.287 411.299 6028.941 7788.852
N2O (thousand tons)............................. 0.031 0.043 0.643 0.830
N2O (thousand tons CO2eq) *..................... 8.327 11.491 170.517 219.961
----------------------------------------------------------------------------------------------------------------
* CO2eq is the quantity of CO2 that would have the same GWP.
Negative values refer to an increase in emissions.
As part of the analysis for this proposed rule, DOE estimated
monetary benefits likely to result from the reduced emissions of
CO2 and NOX that DOE estimated for each of the
considered TSLs for GSLs. As discussed in section V.L of this document,
for CO2, DOE used the most recent values for the SCC
developed by an interagency process. The four sets of SCC values for
CO2 emissions reductions in 2015 resulting from that process
(expressed in 2014$) are represented by $12.2/metric ton (the average
value from a distribution that uses a 5-percent discount rate), $40.0/
metric ton (the average value from a distribution that uses a 3-percent
discount rate), $62.3/metric ton (the average value from a distribution
that uses a 2.5-percent discount rate), and $117/metric ton (the 95th-
percentile value from a distribution that uses a 3-percent discount
rate). The values for later years are higher due to increasing damages
(public health, economic and environmental) as the projected magnitude
of climate change increases.
Table VI-24 presents the global value of CO2 emissions
reductions at each TSL. For each of the four cases, DOE calculated a
present value of the stream of annual values using the same discount
rate as was used in the studies upon which the dollar-per-ton values
are based. DOE calculated domestic values as a range from 7 percent to
23 percent of the global values; these results are presented in chapter
14 of the NOPR TSD.
[[Page 14614]]
Table VI-24 Estimates of Global Present Value of CO2 Emissions Reduction for Products Shipped in 2020-2049
----------------------------------------------------------------------------------------------------------------
SCC case * (million 2014$)
---------------------------------------------------------------
TSL 3% discount
5% discount 3% discount 2.5% discount rate, 95th
rate, average rate, average rate, average percentile
----------------------------------------------------------------------------------------------------------------
Power Sector Emissions
----------------------------------------------------------------------------------------------------------------
1............................................... 16.9 76.5 121 232
2............................................... 23.3 106 168 323
3............................................... 344 1562 2478 4747
4............................................... 443 2017 3200 6130
----------------------------------------------------------------------------------------------------------------
Upstream Emissions
----------------------------------------------------------------------------------------------------------------
1............................................... 0.89 4.1 6.5 12.3
2............................................... 1.2 5.7 9.1 17.4
3............................................... 18.2 83.8 133.32 255
4............................................... 23.6 108 172.29 330
----------------------------------------------------------------------------------------------------------------
Total FFC Emissions
----------------------------------------------------------------------------------------------------------------
1............................................... 17.8 80.5 128 244
2............................................... 24.6 112 178 340
3............................................... 362 1646 2612 5002
4............................................... 467 2125 3372 6459
----------------------------------------------------------------------------------------------------------------
* For each of the four cases, the corresponding SCC value for emissions in 2015 is $12.2, $40.0, $62.3, and $117
per metric ton (2014$). The values are for CO2 only (i.e., not CO2eq of other greenhouse gases).
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
reduced CO2 emissions in this rulemaking is subject to
change. DOE, together with other federal agencies, will continue to
review various methodologies for estimating the monetary value of
reductions in CO2 and other GHG emissions. This ongoing
review will consider the comments on this subject that are part of the
public record for this and other rulemakings, as well as other
methodological assumptions and issues. However, consistent with DOE's
legal obligations, and taking into account the uncertainty involved
with this particular issue, DOE has included in this proposed rule the
most recent values and analyses resulting from the interagency review
process.
DOE also estimated the cumulative monetary value of the economic
benefits associated with NOX emissions reductions
anticipated to result from the considered TSLs for GSLs. The dollar-
per-ton value that DOE used is discussed in section V.L of this
document. Table VI-25 presents the cumulative present values for
NOX emissions for each TSL calculated using 7-percent and 3-
percent discount rates.
Table VI-25--Estimates of Present Value of NOX Emissions Reduction for
GSLs Shipped in 2020-2049
------------------------------------------------------------------------
Million 2014$
-------------------------------
TSL 3% discount 7% discount
rate rate
------------------------------------------------------------------------
Power Sector Emissions
------------------------------------------------------------------------
1....................................... 8.66 3.90
2....................................... 12.00 5.22
3....................................... 176.27 76.68
4....................................... 227.63 98.76
------------------------------------------------------------------------
Upstream Emissions
------------------------------------------------------------------------
1....................................... 6.02 2.62
2....................................... 8.43 3.55
3....................................... 123.78 52.22
4....................................... 159.99 67.35
------------------------------------------------------------------------
Total FFC Emissions
------------------------------------------------------------------------
1....................................... 14.67 6.52
2....................................... 20.43 8.77
3....................................... 300.06 128.90
4....................................... 387.62 166.11
------------------------------------------------------------------------
7. Other Factors
The Secretary of Energy, in determining whether a standard is
economically justified, may consider any other factors that the
Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII)) No
other factors were considered in this analysis.
8. 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
VI-26 presents the NPV values that result from adding the estimates of
the potential economic benefits resulting from reduced CO2
and NOX emissions in each of four valuation scenarios to the
NPV of consumer savings calculated for each TSL considered in this
rulemaking, at both a 7-percent and 3-percent discount rate. The
CO2 values used in the columns of each table correspond to
the four sets of SCC values discussed above.
[[Page 14615]]
Table VI-26--Net Present Value of Consumer Savings Combined With Present Value of Monetized Benefits From CO2
and NOX Emissions Reductions
----------------------------------------------------------------------------------------------------------------
Billion 2014$ Consumer NPV at 3% Discount Rate added with:
---------------------------------------------------------------
TSL SCC Case $12.2/ SCC Case $40.0/ SCC Case $62.3/ SCC Case $117/
metric ton and metric ton and metric ton and metric ton and
3% NOX value 3% NOX value 3% NOX value 3% NOX value
----------------------------------------------------------------------------------------------------------------
1............................................... 0.372 0.434 0.481 0.598
2............................................... 0.579 0.667 0.732 0.895
3............................................... 9.715 10.999 11.964 14.355
4............................................... 12.519 14.177 15.424 18.511
----------------------------------------------------------------------------------------------------------------
Consumer NPV at 7% Discount Rate added with:
---------------------------------------------------------------
TSL SCC Case $12.2/ SCC Case $40.0/ SCC Case $62.3/ SCC Case $117/
metric ton and metric ton and metric ton and metric ton and
7% NOX value 7% NOX value 7% NOX value 7% NOX value
----------------------------------------------------------------------------------------------------------------
1............................................... 0.176 0.239 0.286 0.402
2............................................... 0.269 0.356 0.421 0.584
3............................................... 4.904 6.189 7.154 9.545
4............................................... 6.320 7.979 9.225 12.312
----------------------------------------------------------------------------------------------------------------
In considering the above results, two issues are relevant. First,
the national operating-cost savings are domestic U.S. 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
products shipped in 2020 to 2049. Because CO2 emissions have
a very long residence time in the atmosphere,\199\ the SCC values in
future years reflect future CO2-emissions impacts that
continue beyond 2100.
---------------------------------------------------------------------------
\199\ The atmospheric lifetime of CO2 is estimated of
the order of 30-95 years. Jacobson, MZ, ``Correction to `Control of
fossil-fuel particulate black carbon and organic matter, possibly
the most effective method of slowing global warming,''' J. Geophys.
Res. 110. pp. D14105 (2005).
---------------------------------------------------------------------------
C. Conclusion
When considering proposed standards, the new or amended energy
conservation standards 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
by, to the greatest extent practicable, considering 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))
For this NOPR, DOE considered the impacts of amended standards for
GSLs at each TSL, beginning with the maximum technologically feasible
level, to determine whether that level was economically justified.
Where the max-tech level was not justified, DOE then considered the
next most efficient level and undertook the same evaluation until it
reached the highest efficacy level that is both technologically
feasible and economically justified and saves a significant amount of
energy.
To aid the reader as DOE discusses the benefits and/or burdens of
each TSL, tables in this section present a summary of the results of
DOE's quantitative analysis for each TSL. 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 and impacts on
employment.
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
delaying or altering purchases; (4) excessive focus on the short term,
in the form of inconsistent weighting of future energy cost savings
relative to available returns on other investments; (5) computational
or other difficulties associated with the evaluation of relevant trade-
offs; and (6) a divergence in incentives (for example, between renters
and owners, or builders and purchasers). Having less than perfect
foresight and a high degree of uncertainty about the future, consumers
may trade off these types of investments at a higher-than-expected rate
between current consumption and uncertain future energy cost savings.
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 the
purchase of a product in the standards case, this decreases sales for
product manufacturers, and the impact on manufacturers attributed to
lost revenue 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 regulatory option decreases the number of products
purchased by consumers, this decreases the potential energy savings
from an energy conservation standard. DOE provides estimates of
shipments and changes in the volume of product purchases in chapter 9
of the NOPR TSD. However, DOE's current analysis does not explicitly
control for
[[Page 14616]]
heterogeneity in consumer preferences, preferences across subcategories
of products or specific features, or consumer price sensitivity
variation according to household income.\200\
---------------------------------------------------------------------------
\200\ 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 energy conservation
standards, and potential enhancements to the methodology by which these
impacts are defined and estimated in the regulatory process.\201\ 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 regulatory analysis in future rulemakings (see issue
55 in section VIII.E).
---------------------------------------------------------------------------
\201\ Alan Sanstad, Notes on the Economics of Household Energy
Consumption and Technology Choice. Lawrence Berkeley National
Laboratory (2010) (Available online at: www1.eere.energy.gov/buildings/appliance_standards/pdfs/consumer_ee_theory.pdf).
---------------------------------------------------------------------------
1. Benefits and Burdens of TSLs Considered for GSL Standards
Table VI-27 and Table VI-28 summarize the quantitative impacts
estimated for each TSL for GSLs. The national impacts are measured over
the lifetime of GSLs purchased in the 30-year period that begins in the
anticipated year of compliance with amended standards (2020-2049). The
energy savings, emissions reductions, and value of emissions reductions
refer to FFC results. The ELs contained in each TSL are described in
section VI.A of this NOPR.
Table VI-27--Summary of Analytical Results for GSL TSLs: National Impacts
--------------------------------------------------------------------------------------------------------------------------------------------------------
Category TSL 1 TSL 2 TSL 3 TSL 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
Cumulative FFC National Energy Savings (quads)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0.041....................... 0.058...................... 0.847...................... 1.093
--------------------------------------------------------------------------------------------------------------------------------------------------------
NPV of Consumer Costs and Benefits (2014$ billion)
--------------------------------------------------------------------------------------------------------------------------------------------------------
3% discount rate............... 0.339....................... 0.53....................... 9.05....................... 11.66
7% discount rate............... 0.151....................... 0.235...................... 4.41....................... 5.69
--------------------------------------------------------------------------------------------------------------------------------------------------------
Cumulative FFC Emissions Reduction (Total FFC Emission)
--------------------------------------------------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)...... 2.520....................... 3.517...................... 51.713..................... 66.755
SO2 (thousand tons)............ 1.521....................... 2.094...................... 31.090..................... 40.099
NOX (thousand tons)............ 4.442....................... 6.244...................... 91.514..................... 118.189
Hg (tons)...................... 0.006....................... 0.008...................... 0.115...................... 0.148
CH4 (thousand tons)............ 10.403...................... 14.689..................... 215.319.................... 278.173
CH4 (thousand tons CO2eq) *.... 291.287..................... 411.299.................... 6028.941................... 7788.852
N2O (thousand tons)............ 0.031....................... 0.043...................... 0.643...................... 0.830
N2O (thousand tons CO2eq) *.... 8.327....................... 11.491..................... 170.517.................... 219.961
--------------------------------------------------------------------------------------------------------------------------------------------------------
Value of Emissions Reduction (Total FFC Emissions)
--------------------------------------------------------------------------------------------------------------------------------------------------------
CO2 (2014$ billion) **......... 0.018 to 0.244.............. 0.025 to 0.340............. 0.362 to 5.002............. 0.467 to 6.459
NOX--3% discount rate (2014$ 14.7 to 32.9................ 20.4 to 45.6............... 300.1 to 669.8............. 387.6 to 865.0
million).
NOX--7% discount rate (2014$ 6.5 to 14.5................. 8.8 to 19.5................ 128.9 to 287.2............. 166.1 to 370.1
million).
--------------------------------------------------------------------------------------------------------------------------------------------------------
Parentheses indicate negative (-) values.
* 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 VI-28--Summary of Analytical Results for GSL TSLs: Manufacturer and Consumer Impacts
----------------------------------------------------------------------------------------------------------------
Category TSL 1 * TSL 2 * TSL 3 * TSL 4 *
----------------------------------------------------------------------------------------------------------------
Manufacturer Impacts
----------------------------------------------------------------------------------------------------------------
Industry NPV (2014$ million) (No-new- 886.6-894.3 862.2-877.3 690.0-753.3 665.9-731.3
standards case INPV = $911.0
million)...........................
Industry NPV (% change)............. (2.7)-(1.8) (5.4)-(3.7) (24.3)-(17.3) (26.9)-(19.7)
----------------------------------------------------------------------------------------------------------------
Residential Sector
----------------------------------------------------------------------------------------------------------------
Consumer Average LCC Savings
(2014$):
Integrated Low-Lumen............ 0.32 0.32 0.75 0.88
Integrated High-Lumen........... 0.24 0.94 0.96 0.96
Consumer Simple PBP (years):
Integrated Low-Lumen............ 3.32 4.59 2.14 1.68
Integrated High-Lumen........... 3.20 3.86 3.86 3.86
Percentage of Consumers that
Experience Net Cost:
Integrated Low-Lumen............ 1.4 1.4 1.3 1.0
[[Page 14617]]
Integrated High-Lumen........... 23.2 8.9 8.7 8.7
----------------------------------------------------------------------------------------------------------------
Commercial Sector
----------------------------------------------------------------------------------------------------------------
Consumer Average LCC Savings
(2014$):
Integrated Low-Lumen............ 1.33 1.33 1.32 1.40
Integrated High-Lumen........... 1.13 2.00 2.02 2.02
Non-Integrated.................. 0 0 0 0.95
Consumer Simple PBP (years)
Integrated Low-Lumen............ 1.12 1.29 0.70 0.55
Integrated High-Lumen........... 1.02 1.23 1.23 1.23
Non-Integrated.................. ................. ................. ................. 6.73
Percentage of Consumers that
Experience Net Cost
Integrated Low-Lumen............ 0.2 0.2 0 0
Integrated High-Lumen........... 3.3 4.9 4.9 4.9
Non-Integrated.................. 0 0 0 6.1
----------------------------------------------------------------------------------------------------------------
* Parentheses indicate negative (-) values. The entry ``n.a.'' means not applicable because there is no change
in the standard at certain TSLs.
DOE first considered TSL 4, which represents the max-tech EL. TSL 4
would save 1.1 quads of energy, an amount DOE considers significant.
Under TSL 4, the NPV of consumer benefit would be 5.7 billion using a
discount rate of 7 percent, and 11.7 billion using a discount rate of 3
percent.
The cumulative emissions reductions at TSL 4 are 66.8 Mt of
CO2, 40.1 thousand tons of SO2, 118.2 thousand
tons of NOX, 0.15 ton of Hg, 278 thousand tons of
CH4, and 0.83 thousand tons of N2O. The estimated
monetary value of the CO2 emissions reduction at TSL 4
ranges from 476 million to 6,459 million.
At TSL 4, the average LCC impact in the residential sector is a
savings of $0.88 in the Integrated Low-Lumen product class and savings
of $0.96 in the Integrated High-Lumen product class. In the commercial
sector, the average LCC impact is a savings of $1.40 in the Integrated
Low-Lumen product class, a savings of $2.02 in Integrated High-Lumen
product class, and a savings of $0.95 in the Non-Integrated product
class. The simple payback period in the residential sector is 1.68
years in the Integrated Low-Lumen product class and 3.86 years in the
Integrated High-Lumen product class. The simple payback period in the
commercial sector is 0.55 years in the Integrated Low-Lumen product
class, 1.23 years in the Integrated High-Lumen product class, and 6.73
in the Non-Integrated product class. The fraction of consumers
experiencing a net LCC cost in the residential sector is 1.0 percent in
the Integrated Low-Lumen product class and 8.7 percent in the
Integrated High-Lumen product class. The fraction of consumers
experiencing a net LCC cost in the commercial sector is 0 percent in
the Integrated Low-Lumen product class, 4.9 percent in the Integrated
High-Lumen product class, and 6.1 percent in the Non-Integrated product
class.
At TSL 4, the projected change in INPV ranges from a decrease of
$245.1 million to a decrease of $179.6 million, which represent
decreases of 26.9 percent and 19.7 percent, respectively. As discussed
in section V.C.4, the representative lamp unit at TSL 4 in the
Integrated Low-Lumen product class is a modeled LED lamp. DOE modeled
the lamp based on a commercially available 3-way LED lamp that, when
tested at its middle setting of 8 W, was more efficacious than other
commercially available LED lamps that could be considered an adequate
replacement for the baseline lamp. DOE concluded that the efficacy
achieved by the 8 W setting of this lamp demonstrated the potential for
a standard, non 3-way 8 W LED lamp to achieve the same efficacy level.
Because TSL 4 is based on a modeled product, a commercially available
lamp suitable for a direct lamp replacement that complies with TSL 4 is
not currently commercially available. Although new LED products are
introduced into the market at a rapid pace, DOE is uncertain as to
whether such a lamp would be commercially available at the time
manufacturers must comply with the proposed standard.
Additionally, DOE identified only one level of efficacy for the
Non-Integrated product class. TSL 4, which represents the max-tech
level, proposes a standard for the Non-Integrated product class.
Although there are LCC savings associated with the efficacy level for
the Non-Integrated product class, the simple payback period is longer
than the lifetime of the representative units. Further, DOE anticipates
minimal energy savings for the product class based on the choices
consumers are expected to make when purchasing at a higher level of
efficacy.
The Secretary tentatively concludes that at TSL4 for GSLs, the
benefits of energy savings, positive NPV of consumer benefits, emission
reductions, and the estimated monetary value of the emissions
reductions would be outweighed by the potential reduction in industry
value, the potentially limited availability of compliant lamps in the
Low-Lumen Integrated product class, and the long payback period and
limited energy savings associated with the Non-Integrated product
class. Consequently, the Secretary has tentatively concluded that TSL 4
is not justified.
DOE then considered TSL 3 which would save an estimated 0.85 quads
of energy, an amount DOE considers significant. Under TSL 3, the NPV of
consumer benefit would be 4.4 billion using a discount rate of 7
percent, and 9.1 billion using a discount rate of 3 percent.
The cumulative emissions reductions at TSL 3 are 51.7 Mt of
CO2, 31.1 thousand tons of SO2, 91.5 thousand
tons of NOX, 0.12 ton of Hg, 215 thousand tons of
CH4, and 0.64 thousand tons of N2O. The estimated
monetary value of the CO2 emissions reduction at TSL 3
ranges from 362 million to 5,002 million.
At TSL 3, the average LCC impact in the residential sector is a
savings of $0.75 in the Integrated Low-Lumen product class and savings
of $0.96 in the
[[Page 14618]]
Integrated High-Lumen product class. In the commercial sector, the
average LCC impact is a savings of $1.32 in the Integrated Low-Lumen
product class and a savings of $2.02 in Integrated High-Lumen product
class. The simple payback period in the residential sector is 2.14
years in the Integrated Low-Lumen product class and 3.86 years in the
Integrated High-Lumen product class. The simple payback period in the
commercial sector is 0.70 years in the Integrated Low-Lumen product
class and 1.23 years in the Integrated High-Lumen product class. The
fraction of consumers experiencing a net LCC cost in the residential
sector is 1.3 percent in the Integrated Low-Lumen product class and 8.7
percent in the Integrated High-Lumen product class. The fraction of
consumers experiencing a net LCC cost in the commercial sector is 0
percent in the Integrated Low-Lumen product class and 4.9 percent in
the Integrated High-Lumen product class.
At TSL 3, the projected change in INPV ranges from a decrease of
$221.0 million to a decrease of $157.7 million, which represent
decreases of 24.3 percent and 17.3 percent, respectively. For the
Integrated Low-Lumen product class, the largest product class by
volume, manufacturers would have to abandon CFL production for LED
lamps. This would cause manufacturers to spend a considerable amount of
R&D to introduce replacement LED lamps for those CFLs being removed
from the market and make a sizable investment to increase their
production equipment required to significantly expand their existing
LED capacity.
After considering the analysis and weighing the benefits and
burdens, the Secretary has tentatively concluded that at TSL 3 for
GSLs, the benefits of energy savings, positive NPV of consumer
benefits, emission reductions, the estimated monetary value of the
emissions reductions, and positive average LCC savings would outweigh
the reduction in industry value, the size of manufacturer investments,
and the potentially limited availability of LED lamps due to
manufacturer capacity constraints. Accordingly, the Secretary has
tentatively concluded that TSL 3 would offer the maximum improvement in
efficiency that is technologically feasible and economically justified,
and would result in the significant conservation of energy.
Therefore, based on the above considerations, DOE proposes to adopt
the energy conservation standards for GSLs at TSL 3. The proposed
amended energy conservation standards for GSLs are shown in Table VI-
29.
Table VI-29--Proposed Energy Conservation Standards for GSLs
------------------------------------------------------------------------
Representative product class Efficacy level Efficacy (lm/W)
------------------------------------------------------------------------
Integrated Low-Lumen (310 <= EL 3.............. 101.6-29.42*0.9983
Initial Lumen Output < 2,000). [supcaret]Initial
Lumen Output.
Integrated High-Lumen (2,000 <= EL 2.............. 73.4-29.42*0.9983[
Initial Lumen Output <= 2,600 supcaret]Initial
lumens). Lumen Output.
Non-Integrated (310 <= Initial EL 0.............. N/A.
Lumen Output <= 2,600).
------------------------------------------------------------------------
2. Summary of Annualized Benefits and Costs of the Proposed Standards
The benefits and costs of the proposed standards can also be
expressed in terms of annualized values. The annualized net benefit is
the sum of: (1) The annualized national economic value (expressed in
2014$) of the benefits from operating products that meet the proposed
standards (consisting primarily of operating-cost savings from using
less energy, minus increases in product purchase costs, and (2) the
annualized monetary value of the benefits of CO2 and
NOX emission reductions.\202\
---------------------------------------------------------------------------
\202\ 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
(2020, 2030, etc.), and then discounted the present value from each
year to 2015. 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.
---------------------------------------------------------------------------
Table VI-30 shows the annualized values for GSLs under TSL 3,
expressed in 2014$. The results under the primary estimate are as
follows.
Using a 7-percent discount rate for benefits and costs other than
CO2 reductions (for which DOE used a 3-percent discount rate
along with the average SCC series corresponding to a value of $40.0/ton
in 2015 (2014$)), the estimated cost of the proposed standards for GSLs
is $-93 million per year in increased equipment costs, while the
estimated benefits are $373 million per year in reduced equipment
operating costs, $95 million per year in CO2 reductions, and
$13.6 million per year in reduced NOX emissions. In this
case, the net benefit amounts to $574 million per year.
Using a 3-percent discount rate for all benefits and costs and the
average SCC series corresponding to a value of $40.0/ton in 2015
(2014$), the estimated cost of the proposed standards for GSLs is $-82
million per year in increased equipment costs, while the estimated
annual benefits are $438 million in reduced operating costs, $95
million in CO2 reductions, and $17.2 million in reduced
NOX emissions. In this case, the net benefit amounts to $632
million per year.
Table VI-30--Annualized Benefits and Costs of Proposed Energy Conservation Standards for General Service Lamps (TSL 3)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Million 2014$/year
-----------------------------------------------------------------------------------
Discount rate Low net benefits estimate High net benefits estimate
Primary estimate * * *
--------------------------------------------------------------------------------------------------------------------------------------------------------
Benefits
--------------------------------------------------------------------------------------------------------------------------------------------------------
Consumer Operating-Cost Savings... 7%.............................. 373....................... 334....................... 404
3%.............................. 438....................... 386....................... 481
[[Page 14619]]
CO2 Reduction Value ($12.2/t) **.. 5%.............................. 29........................ 26........................ 31
CO2 Reduction Value ($40.0/t) **.. 3%.............................. 95........................ 86........................ 101
CO2 Reduction Value ($62.3/t) **.. 2.5%............................ 138....................... 125....................... 148
CO2 Reduction Value ($117/t) **... 3%.............................. 287....................... 262....................... 308
NOX Reduction Value [dagger]...... 7%.............................. 13.6...................... 12.6...................... 32.2
3%.............................. 17.2...................... 15.8...................... 41.1
Total Benefits 7% plus CO2 range............... 415 to 674................ 373 to 608................ 467 to 744
[dagger][dagger].
7%.............................. 481....................... 433....................... 537
3% plus CO2 range............... 483 to 742................ 428 to 663................ 552 to 829
3%.............................. 549....................... 488....................... 623
--------------------------------------------------------------------------------------------------------------------------------------------------------
Costs
--------------------------------------------------------------------------------------------------------------------------------------------------------
Consumer Incremental Product Costs 7%.............................. -93....................... -81....................... -105
[Dagger].
3%.............................. -82....................... -70....................... -95
Total [dagger][dagger]............ 7% plus CO2 range............... 508 to 767................ 453 to 689................ 571 to 849
7%.............................. 574....................... 513....................... 642
3% plus CO2 range............... 566 to 824................ 498 to 733................ 647 to 924
3%.............................. 632....................... 558....................... 718
--------------------------------------------------------------------------------------------------------------------------------------------------------
* This table presents the annualized costs and benefits associated with GSLs shipped in 2020-2049. These results include benefits to consumers which
accrue after 2049 from the products purchased in 2020-2049. 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 estimate assumes the reference case electricity prices and floorspace growth projections from AEO 2015 and decreasing product prices for
both CFL and LED GSLs, due to price learning. The Low Benefits Estimate uses the Low Economic Growth electricity prices and floorspace growth from AEO
2015 and a faster decrease in product prices for LED GSLs. The High Benefits Estimate uses the High Economic Growth electricity prices and floorspace
growth from AEO 2015 and a slower decrease in product prices for LED GSLs. The methods used to derive projected price trends are explained in section
V.G.1.b.
** The CO2 values represent global monetized values of the SCC, in 2014$, in 2015 under several scenarios of the updated SCC values. The first three
cases use the averages of SCC distributions calculated using 5-percent, 3-percent, and 2.5-percent discount rates, respectively. The fourth case
represents the 95th percentile of the SCC distribution calculated using a 3-percent discount rate. The SCC time series incorporate an escalation
factor.
[dagger] The $/ton values used for NOX are described in section V.L. DOE estimated the monetized value of NOX emissions reductions using benefit per ton
estimates from the Regulatory Impact Analysis titled, ``Proposed Carbon Pollution Guidelines for Existing Power Plants and Emission Standards for
Modified and Reconstructed Power Plants,'' published in June 2014 by EPA's Office of Air Quality Planning and Standards. (Available at: http://www3.epa.gov/ttnecas1/regdata/RIAs/111dproposalRIAfinal0602.pdf.) See section V.L.2 for further discussion. For DOE's Primary Estimate and Low Net
Benefits Estimate, the agency is presenting a national benefit-per-ton estimate for particulate matter emitted from the Electric Generating Unit
sector based on an estimate of premature mortality derived from the ACS study (Krewski et al., 2009). For DOE's High Net Benefits Estimate, the
benefit-per-ton estimates were based on the Six Cities study (Lepuele et al., 2011), which are nearly two-and-a-half times larger than those from the
ACS study. Because of the sensitivity of the benefit-per-ton estimate to the geographical considerations of sources and receptors of emission, DOE
intends to investigate refinements to the agency's current approach of one national estimate by assessing the regional approach taken by EPA's
Regulatory Impact Analysis for the Clean Power Plan Final Rule.
[dagger][dagger] Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to the average SCC with a 3-
percent discount rate ($40.0/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.
[Dagger] This reduction in product costs occurs because (1) more efficacious lamps have longer average lifetimes than less efficacious lamps, resulting
in fewer replacement purchases, (2) the purchase price of more efficacious LED lamps is lower than the price of less efficacious LED lamps, and (3)
the purchase price of LED lamps declines faster than the price of CFLs during the analysis period, resulting in LED lamps becoming less expensive than
CFLs.
VII. 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 the proposed standards set forth in this NOPR are
intended to address are as follows:
(1) Insufficient information 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 equipment are not
realized due to misaligned incentives between purchasers and users. An
example of such a case is when the equipment 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 appliances and equipment that are not captured by the
users of such products. These benefits include externalities related to
public health, environmental protection, and national energy 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. DOE attempts to quantify some of the external benefits through
use of social cost of carbon values.
The Administrator of the Office of Information and Regulatory
Affairs (OIRA) in the OMB has determined that the proposed regulatory
action is a significant regulatory action under section (3)(f) of
Executive Order 12866.
[[Page 14620]]
Accordingly, pursuant to section 6(a)(3)(B) of the Order, DOE has
provided to OIRA: (i) The text of the draft regulatory action, together
with a reasonably detailed description of the need for the regulatory
action and an explanation of how the regulatory action will meet that
need; and (ii) An assessment of the potential costs and benefits of the
regulatory action, including an explanation of the manner in which the
regulatory action is consistent with a statutory mandate. DOE has
included these documents in the rulemaking record.
In addition, the Administrator of OIRA has determined that the
proposed regulatory action is an ``economically'' significant
regulatory action under section (3)(f)(1) of Executive Order 12866.
Accordingly, pursuant to section 6(a)(3)(C) of the Order, DOE has
provided to OIRA an assessment, including the underlying analysis, of
benefits and costs anticipated from the regulatory action, together
with, to the extent feasible, a quantification of those costs; and an
assessment, including the underlying analysis, of costs and benefits of
potentially effective and reasonably feasible alternatives to the
planned regulation, and an explanation why the planned regulatory
action is preferable to the identified potential alternatives. These
assessments can be found in the NOPR TSD for this rulemaking.
DOE has also reviewed this regulation pursuant to Executive Order
13563, issued on January 18, 2011. 76 FR 3281 (Jan. 21, 2011).
Executive Order 13563 is supplemental to and explicitly reaffirms the
principles, structures, and definitions governing regulatory review
established in Executive Order 12866. To the extent permitted by law,
agencies are required by Executive Order 13563 to: (1) Propose or adopt
a regulation only upon a reasoned determination that its benefits
justify its costs (recognizing that some benefits and costs are
difficult to quantify); (2) tailor regulations to impose the least
burden on society, consistent with obtaining regulatory objectives,
taking into account, among other things, and to the extent practicable,
the costs of cumulative regulations; (3) select, in choosing among
alternative regulatory approaches, those approaches that maximize net
benefits (including potential economic, environmental, public health
and safety, and other advantages; distributive impacts; and equity);
(4) to the extent feasible, specify performance objectives, rather than
specifying the behavior or manner of compliance that regulated entities
must adopt; and (5) identify and assess available alternatives to
direct regulation, including providing economic incentives to encourage
the desired behavior, such as user fees or marketable permits, or
providing information upon which choices can be made by the public.
DOE emphasizes as well that Executive Order 13563 requires agencies
to use the best available techniques to quantify anticipated present
and future benefits and costs as accurately as possible. In its
guidance, 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 NOPR is
consistent with these principles, including the requirement that, to
the extent permitted by law, benefits justify costs and that net
benefits are maximized.
B. Review Under the Regulatory Flexibility Act
The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires
preparation of an initial regulatory flexibility analysis (IRFA) for
any rule that by law must be proposed for public comment, unless the
agency certifies that the rule, if promulgated, will not have a
significant economic impact on a substantial number of small entities.
As required by Executive Order 13272, ``Proper Consideration of Small
Entities in Agency Rulemaking,'' 67 FR 53461 (August 16, 2002), DOE
published procedures and policies on February 19, 2003, to ensure that
the potential impacts of its rules on small entities are properly
considered during the rulemaking process. 68 FR 7990. DOE has made its
procedures and policies available on the Office of the General
Counsel's Web site (http://energy.gov/gc/office-general-counsel). DOE
has prepared the following IRFA for the products that are the subject
of this rulemaking.
1. Description on Estimated Number of Small Entities Regulated
For manufacturers of GSLs, the SBA has set a size threshold, which
defines those entities classified as ``small businesses'' for the
purposes of the statute. DOE used the SBA's small business size
standards to determine whether any small entities would be subject to
the requirements of the rule See 13 CFR part 121. The size standards
are listed by NAICS code and industry description and are available at
http://www.sba.gov/sites/default/files/files/Size_Standards_Table.pdf.
Manufacturing of GSLs is classified under NAICS 335110, ``Electric Lamp
Bulb and Part Manufacturing.'' The SBA sets a threshold of 1,000
employees or less for an entity to be considered as a small business
for this category.
To estimate the number of companies that could be small businesses
that sell GSLs covered by this rulemaking, DOE conducted a market
survey using publicly available information. DOE's research involved
information provided by trade associations (e.g., NEMA \203\) and
information from DOE's Compliance Certification Management System
(CCMS) Database,\204\ EPA's ENERGY STAR Certified Light Bulbs
Database,\205\ LED Lighting Facts Database,\206\ previous rulemakings,
individual company Web sites, SBA's database, and market research tools
(e.g., Hoover's reports \207\). DOE also asked stakeholders and
industry representatives if they were aware of any small businesses
during manufacturer interviews and DOE public meetings. DOE used
information from these sources to create a list of companies that
potentially manufacture or sell GSLs and would be impacted by this
rulemaking. 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.
---------------------------------------------------------------------------
\203\ National Electric Manufacturers Association [verbar]
Member Products [verbar] Lighting Systems [verbar] Related
Manufacturers, http://www.nema.org/Products/Pages/Lighting-Systems.aspx (last accessed July 13, 2015).
\204\ DOE's Compliance Certification Database [verbar] Lamps--
Bare or Covered (No Reflector) Medium Bas Compact Fluorescent,
http://www.regulations.doe.gov/certification-data (last accessed
July 13, 2015).
\205\ ENERGY STAR Qualified Lamps Product List, http://downloads.energystar.gov/bi/qplist/Lamps_Qualified_Product_List.xls?dee3-e997 (last accessed July 13,
2015).
\206\ LED Lighting Facts Database, http://www.lightingfacts.com/products (last accessed July 13, 2015).
\207\ Hoovers [verbar] Company Information [verbar] Industry
Information [verbar] Lists, http://www.hoovers.com (last accessed
July 13, 2015).
---------------------------------------------------------------------------
DOE identified approximately 118 small businesses that sell GSLs in
the United States that are covered by this rulemaking. However, DOE
estimates that approximately 65 of these potential small businesses are
rebranders who typically purchase fully assembled lamps from original
equipment manufacturers and are not involved in the product development
or manufacturing of those lamps. Subsequently, DOE determined that 53
companies were small businesses that are involved in the product
development and/or manufacturing of GSLs covered by this rulemaking.
[[Page 14621]]
DOE was able to interview five small GSL businesses as part of the
NOPR manufacturer interviews. DOE seeks comments, information, and data
on the number of small businesses, including the number of rebranders,
in the GSL industry that DOE identified, including their estimated
market share.
2. Description and Estimate of Compliance Requirements
DOE assumed that LED manufacturers would be required to test and
certify their LED lamps in the absence of DOE setting energy
conservation standards for this GSL rulemaking, since the EISA 2007 45
lm/W backstop would be triggered and would include LED lamps. This
backstop would require LED manufacturers to test and certify their LED
lamps using the same DOE test procedure that these manufacturers would
use if DOE sets energy conservation standards for this GSL rulemaking.
DOE assumes that the proposed standards would not increase the
regulatory burden on GSL manufacturers that are making compliant
products compared to the no-new-standards case regulatory burden.
Additionally, DOE assumes that the GSL small businesses that are not
responsible for the product development or manufacturing of the lamps
they sell (i.e., rebranders) have significantly less conversion costs
and compliance costs for any products that would need to be redesigned
because of the proposed standards compared to GSL manufacturers who do
either their own product development or manufacturing. DOE assumes that
while rebranders are responsible for certifying their lamps to DOE's
energy conservation standards, typically the original equipment
manufacturers provide the rebranders with the test data necessary for
certification. Therefore, DOE assumes these certification costs will
not significantly impact these small businesses.
According to DOE's analysis, of the 118 GSL small businesses,
approximately 84 exclusively sell LED lamps and do not sell lamps using
other technologies (i.e., CFLs). Of those 84 small businesses
exclusively selling LEDs, DOE estimates that approximately half are
rebranders and half are involved in the product development and/or the
manufacturing of the LEDs they sell.
DOE anticipates that in 2020 approximately 63 percent of all LED
lamps covered by this rulemaking would meet the standards required at
TSL 3. Also, given the short product development lifetime of LEDs, DOE
anticipates that most, if not all, LED lamps that fail to meet the
proposed standards would have experienced a product redesign during the
three year compliance period in the absence of GSL energy conservation
standards. So while DOE assumes that small businesses exclusively
selling LED lamps would incur additional R&D investments to increase
the efficacy of some of their products to meet the proposed standards,
DOE also assumes that a portion of the testing and certification costs
would be incurred by these small businesses in the no-new standards
case.
Additionally, DOE does not assume small businesses exclusively
selling LED lamps will incur additional investment in production
equipment (i.e., capital conversion costs) due to the proposed
standards, since most LED small businesses either do not own their LED
production equipment or could use their existing LED production
equipment to manufacture more efficacious LED lamps that meet the
proposed standards. Lastly, DOE assumes that original equipment
manufacturers frequently produce the same LEDs for a variety of
rebranders. Therefore, original equipment manufacturers would not pass
on all of these R&D and testing costs caused by the proposed standards,
to an individual rebrander. Instead the original equipment manufacturer
would most likely spread these R&D and testing costs over a variety of
rebranders that purchase an LED lamp from this original equipment
manufacturer. Overall, DOE does not anticipate a significant impact to
the majority of small businesses that exclusively sell LED lamps,
especially for the rebranders, based on the proposed standards, TSL 3.
DOE estimates that there are approximately 29 small businesses that
sell both CFLs and LEDs. These small businesses could be
disproportionally impacted by the proposed energy conservation
standards compared to large GSL manufacturers. The impact on each
individual small business will depend on the portion of sales that
CFLs, and to a lesser extent LED lamps that are not compliant with
proposed standards, make up of a small business' total revenue and the
number of CFL models that would need to be removed and LED lamp models
that would need to be redesigned due to the proposed standards. The
proposed standards would likely create a large shift in the market
share of GSL manufacturers, and therefore some small businesses selling
CFLs may not be able to replace that lost revenue with an increase in
their additional LED lamp revenue.
Lastly, there are approximately five small businesses that
exclusively sell CFLs and do not sell any LED lamps. These small
businesses would be the most severely impacted by the proposed
standards. Because their products would no longer meet the proposed
standards, these small busineses would have to discontinue their CFL
product lines and replace their portfolio with compliant LED lamps to
stay in business. This would require using a completely different
technology for all their products and finding new component suppliers
(for the two manufacturers) or original equipment manufacturers (for
the three rebranders).
DOE calculated the conversion costs that typical small and large
general service lamp manufacturers would need to make in order to
comply with standards set at each TSL. DOE presents a range of
conversion costs for a typical small and large general service lamp
manufacturer to account for both the low and high investment scenarios
used at each TSL.
Table VII-1 Comparison of Typical Small and Large Manufacturer's Total Conversion Costs
----------------------------------------------------------------------------------------------------------------
Total conversion costs for Total conversion costs for
Trial standard level typical small manufacturer typical large manufacturer
(2014$ millions) (2014$ millions)
----------------------------------------------------------------------------------------------------------------
TSL 1............................................. 1.3--1.4 4.7--4.9
TSL 2............................................. 1.5--1.6 4.8--5.2
TSL 3............................................. 2.2--2.6 6.4--7.7
TSL 4............................................. 2.3--2.7 6.5--7.8
----------------------------------------------------------------------------------------------------------------
[[Page 14622]]
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 proposed new and amended standards. DOE
seeks comment on any rules or regulations that could potentially
duplicate, overlap, or conflict with the proposed new and amended
standards.
4. Significant Alternatives to the Rule
The discussion in the previous section analyzes impacts on small
businesses that would result from DOE's proposed rule, TSL 3. In
reviewing alternatives to the proposed rule, DOE examined energy
conservation standards set at lower efficiency levels. While TSL 1 and
TSL 2 would reduce the impacts on small business manufacturers, it
would come at the expense of a reduction in energy savings. TSL 1
achieves 95 percent percent lower energy savings compared to the energy
savings at TSL 3. TSL 2 achieves 93 percent percent lower energy
savings compared to the energy savings at TSL 3.
DOE believes that establishing standards at TSL 3 balances the
benefits of the energy savings at TSL 3 with the potential burdens
placed on GSL manufacturers, including small business manufacturers.
Accordingly, DOE is declining to adopt one of the other TSLs considered
in the analysis, or the other policy alternatives detailed as part of
the regulatory impacts analysis included in Chapter 17 of this NOPR
TSD.
DOE does not have the capability of extending the compliance date
for small businesses beyond January 1, 2020 due to the statutory
requirement in 42 U.S.C. 6295(i)(6)(A)(iii); however, additional
compliance flexibilities may be available through other means. For
example, individual manufacturers may petition for a waiver of the
applicable test procedure. (See 10 CFR 430.27) Further, EPCA provides
that a manufacturer whose annual gross revenue from all of its
operations does not exceed $8 million 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 10 CFR part 1003 for
additional details.
DOE requests any available data or reports that would contribute to
the analysis of alternatives to standards for GSLs. In particular, DOE
seeks information on the effectiveness of existing or past efficiency
improvement programs for these products (see issue 57 in section
VIII.E).
NEMA indicated that depending on the energy efficiency standard set
by the rulemaking, utilities may decide to forego their lamp rebate
programs, which may actually result in slower GSL adoption rates.
(NEMA, No. 34 at p. 29) DOE notes that it did not assume the continued
existence of utility rebate programs for GSLs in its analysis of the
considered TSLs. DOE did consider policy alternatives, including
consumer rebates, to energy efficiency standards and determined that
the energy savings of these alternatives are significantly smaller than
those that would be expected to result from adoption of the proposed
standard levels.
C. Review Under the Paperwork Reduction Act
Manufacturers of GSLs 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 GSLs, 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. 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. DOE requested OMB approval of an extension of this
information collection for three years, specifically including the
collection of information proposed in the present rulemaking, and
estimated that the annual number of burden hours under this extension
is 30 hours per company. In response to DOE's request, OMB approved
DOE's information collection requirements covered under OMB control
number 1910-1400 through November 30, 2017. 80 FR 5099 (January 30,
2015).
Notwithstanding any other provision of the law, no person is
required to respond to, nor shall any person be subject to a penalty
for failure to comply with, a collection of information subject to the
requirements of the PRA, unless that collection of information displays
a currently valid OMB control number.
D. Review Under the National Environmental Policy Act of 1969
Pursuant to the National Environmental Policy Act (NEPA) of 1969,
DOE has determined that the proposed rule fits within the category of
actions included in Categorical Exclusion (CX) B5.1 and otherwise meets
the requirements for application of a CX. See 10 CFR part 1021, App. B,
B5.1(b); 1021.410(b) and App. B, B(1)-(5). The proposed rule fits
within this category of actions because it is a rulemaking that
establishes energy conservation standards for consumer products or
industrial equipment, and for which none of the exceptions identified
in CX B5.1(b) apply. Therefore, DOE has made a CX determination for
this rulemaking, and DOE does not need to prepare an Environmental
Assessment or Environmental Impact Statement for this proposed rule.
DOE's CX determination for this proposed rule is available at http://cxnepa.energy.gov/.
E. Review Under Executive Order 13132
Executive Order 13132, ``Federalism,'' 64 FR 43255 (August 10,
1999), imposes certain requirements on federal agencies formulating and
implementing policies or regulations that preempt state law or that
have Federalism implications. The Executive Order requires agencies to
examine the constitutional and statutory authority supporting any
action that would limit the policymaking discretion of the states and
to carefully assess the necessity for such actions. The Executive Order
also requires agencies to have an accountable process to ensure
meaningful and timely input by state and local officials in the
development of regulatory policies that have Federalism implications.
On March 14, 2000, DOE published a statement of policy describing the
intergovernmental consultation process it will follow in the
development of such regulations. 65 FR 13735. DOE has examined this
proposed rule and has tentatively determined that it would not have a
substantial direct effect on the states, on the relationship between
the national government and the states, or on the distribution of power
and responsibilities among the various levels of government. EPCA
governs and prescribes federal preemption of state regulations as to
energy conservation for the products that are the subject of this
proposed rule. States can petition DOE for exemption from such
preemption to the extent, and based on criteria, set forth in EPCA. (42
U.S.C. 6297)
[[Page 14623]]
Therefore, 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; (3)
provide a clear legal standard for affected conduct rather than a
general standard; and (4) promote simplification and burden reduction.
61 FR 4729 (Feb. 7, 1996). Regarding the review required by section
3(a), section 3(b) of Executive Order 12988 specifically requires that
Executive agencies make every reasonable effort to ensure that the
regulation: (1) Clearly specifies the preemptive effect, if any; (2)
clearly specifies any effect on existing federal law or regulation; (3)
provides a clear legal standard for affected conduct while promoting
simplification and burden reduction; (4) specifies the retroactive
effect, if any; (5) adequately defines key terms; and (6) addresses
other important issues affecting clarity and general draftsmanship
under any guidelines issued by the Attorney General. Section 3(c) of
Executive Order 12988 requires Executive agencies to review regulations
in light of applicable standards in section 3(a) and section 3(b) to
determine whether they are met or it is unreasonable to meet one or
more of them. DOE has completed the required review and determined
that, to the extent permitted by law, this proposed rule meets the
relevant standards of Executive Order 12988.
G. Review Under the Unfunded Mandates Reform Act of 1995
Title II of the Unfunded Mandates Reform Act of 1995 (UMRA)
requires each federal agency to assess the effects of federal
regulatory actions on state, local, and tribal governments and the
private sector. Public Law 104-4, sec. 201 (codified at 2 U.S.C. 1531).
For a proposed regulatory action likely to result in a rule that may
cause the expenditure by state, local, and tribal governments, in the
aggregate, or by the private sector of $100 million or more in any one
year (adjusted annually for inflation), section 202 of UMRA requires a
federal agency to publish a written statement that estimates the
resulting costs, benefits, and other effects on the national economy.
(2 U.S.C. 1532(a), (b)) The UMRA also requires a federal agency to
develop an effective process to permit timely input by elected officers
of state, local, and tribal governments on a proposed ``significant
intergovernmental mandate,'' and requires an agency plan for giving
notice and opportunity for timely input to potentially affected small
governments before establishing any requirements that might
significantly or uniquely affect them. 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/sites/prod/files/gcprod/documents/umra_97.pdf.
Although this proposed rule does not contain a federal
intergovernmental mandate, it may require expenditures of $100 million
or more in any one year by the private sector. Such expenditures may
include: (1) Investment in R&D and in capital expenditures by GSL
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 more efficacious GSLs.
Section 202 of UMRA authorizes a federal agency to respond to the
content requirements of UMRA in any other statement or analysis that
accompanies the proposed rule. (2 U.S.C. 1532(c)) The content
requirements of section 202(b) of UMRA relevant to a private sector
mandate substantially overlap the economic analysis requirements that
apply under section 325(o) of EPCA and Executive Order 12866. The
SUPPLEMENTARY INFORMATION section of this NOPR and the TSD for this
proposed rule respond to those requirements.
Under section 205 of UMRA, the Department is obligated to identify
and consider a reasonable number of regulatory alternatives before
promulgating a rule for which a written statement under section 202 is
required. (2 U.S.C. 1535(a)) DOE is required to select from those
alternatives the most cost-effective and least burdensome alternative
that achieves the objectives of the proposed rule unless DOE publishes
an explanation for doing otherwise, or the selection of such an
alternative is inconsistent with law. As required by 42 U.S.C. 6295(d),
(f), and (o), 6313(e), and 6316(a), this proposed rule would establish
new and amended energy conservation standards for GSLs that are
designed to achieve the maximum improvement in energy efficiency that
DOE has determined to be both technologically feasible and economically
justified. A full discussion of the alternatives considered by DOE is
presented in the ``Regulatory Impact Analysis'' section of the TSD for
this proposed rule.
H. Review Under the Treasury and General Government Appropriations Act,
1999
Section 654 of the Treasury and General Government Appropriations
Act, 1999 (Pub. L. 105-277) requires federal agencies to issue a Family
Policymaking Assessment for any rule that may affect family well-being.
This rule would not have any impact on the autonomy or integrity of the
family as an institution. Accordingly, DOE has concluded that it is not
necessary to prepare a Family Policymaking Assessment.
I. Review Under Executive Order 12630
Pursuant to Executive Order 12630, ``Governmental Actions and
Interference with Constitutionally Protected Property Rights,'' 53 FR
8859 (March 15, 1988), DOE has determined that this proposed rule 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 information
quality 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 NOPR under the OMB and DOE
guidelines and has concluded that it is consistent with applicable
policies in those guidelines.
K. Review Under Executive Order 13211
Executive Order 13211, ``Actions Concerning Regulations That
Significantly Affect Energy Supply, Distribution, or Use,'' 66 FR 28355
(May 22, 2001), requires federal agencies to prepare and submit to OIRA
at OMB, a Statement of Energy Effects for any proposed significant
energy action. A ``significant energy action'' is defined as any action
by an agency that promulgates or is expected to lead to promulgation of
a final rule, and that: (1) is a significant regulatory action under
Executive Order 12866, or any successor order; and (2) is likely to
have a significant adverse effect on the supply, distribution, or use
of energy, or (3) is designated by the Administrator of
[[Page 14624]]
OIRA as a significant energy action. For any proposed significant
energy action, the agency must give a detailed statement of any adverse
effects on energy supply, distribution, or use should the proposal be
implemented, and of reasonable alternatives to the action and their
expected benefits on energy supply, distribution, and use.
DOE has tentatively concluded that this regulatory action, which
proposes new and amended energy conservation standards for GSLs, is not
a significant energy action because the proposed standards are not
likely to have a significant adverse effect on the supply,
distribution, or use of energy, nor has it been designated as such by
the Administrator at OIRA. Accordingly, DOE has not prepared a
Statement of Energy Effects on this proposed rule.
L. Review Under the Information Quality Bulletin for Peer Review
On December 16, 2004, OMB, in consultation with the Office of
Science and Technology Policy (OSTP), issued its Final Information
Quality Bulletin for Peer Review (the Bulletin). 70 FR 2664 (Jan. 14,
2005). The Bulletin establishes that certain scientific information
shall be peer reviewed by qualified specialists before it is
disseminated by the federal government, including influential
scientific information related to agency regulatory actions. The
purpose of the Bulletin is to enhance the quality and credibility of
the Government's scientific information. Under the Bulletin, the energy
conservation standards rulemaking analyses are ``influential scientific
information,'' which the Bulletin defines as ``scientific information
the agency reasonably can determine will have, or does have, a clear
and substantial impact on important public policies or private sector
decisions.'' Id. at 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. Description of Materials Incorporated by Reference
In this NOPR, DOE proposes to incorporate by reference the standard
published by UL, titled ``Standard for Light-Emitting Diode Retrofit
Luminaire Conversion Kits,'' First Edition, dated January 16, 2014, UL
1598C-2014. UL 1598C-2014 is an industry accepted standard that
describes the requirements for LED retrofit luminaire conversion kits
intended to replace existing incandescent, fluorescent, induction, and
HID systems that comply with existing requirements for luminaires. The
standard proposed in this NOPR references UL 1598C-2014 for the
definition of the term ``LED Downlight Retrofit Kit.'' UL 1598C-2014 is
readily available on http://ulstandards.ul.com/standards-catalog/.
VIII. Public Participation
A. Attendance at the Public Meeting
The time, date, and location of the public meeting are listed in
the DATES and ADDRESSES sections at the beginning of this NOPR. If you
plan to attend the public meeting, please notify Ms. Brenda Edwards at
(202) 586-2945 or [email protected].
Please note that foreign nationals visiting DOE Headquarters are
subject to advance security screening procedures which require advance
notice prior to attendance at the public meeting. If a foreign national
wishes to participate in the public meeting, please inform DOE of this
fact as soon as possible by contacting Ms. Regina Washington at (202)
586-1214 or by email ([email protected]) so that the
necessary procedures can be completed.
DOE requires visitors to have laptops and other devices, such as
tablets, checked upon entry into the Forrestal Building. Any person
wishing to bring these devices into the building will be required to
obtain a property pass. Visitors should avoid bringing these devices,
or allow an extra 45 minutes to check in. Please report to the
visitor's desk to have devices checked before proceeding through
security.
Due to the REAL ID Act implemented by the Department of Homeland
Security (DHS), there have been recent changes regarding identification
(ID) requirements for individuals wishing to enter federal buildings
from specific states and U.S. territories. As a result, driver's
licenses from several states or territory will not be accepted for
building entry, and instead, one of the alternate forms of ID listed
below will be required. DHS has determined that regular driver's
licenses (and ID cards) from the following jurisdictions are not
acceptable for entry into DOE facilities: Alaska, American Samoa,
Arizona, Louisiana, Maine, Massachusetts, Minnesota, New York,
Oklahoma, and Washington. Acceptable alternate forms of Photo-ID
include: U.S. Passport or Passport Card; an Enhanced Driver's License
or Enhanced ID-Card issued by the States of Minnesota, New York, or
Washington (Enhanced licenses issued by these states are clearly marked
Enhanced or Enhanced Driver's License); a military ID or other federal-
government-issued photo ID-card.
In addition, you can attend the public meeting via webinar. Webinar
registration information, participant instructions, and information
about the capabilities available to webinar participants will be
published on DOE's Web site at: https://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx?ruleid=83. Participants are
responsible for ensuring their systems are compatible with the webinar
software.
B. Procedure for Submitting Prepared General Statements for
Distribution
Any person who has plans to present a prepared general statement
may request that copies of his or her statement be made available at
the public meeting. Such persons may submit requests, along with an
advance electronic copy of their statement in PDF (preferred),
Microsoft Word or Excel, WordPerfect, or text (ASCII) file format, to
the appropriate address shown in the ADDRESSES section at the beginning
of this NOPR. The request and advance copy of statements must be
received at least one week before the public meeting and may be
emailed, hand-delivered, or sent by mail. DOE prefers to receive
requests and advance copies via email. Please include a telephone
number to enable DOE staff to make follow-up contact, if needed.
C. Conduct of the Public Meeting
DOE will designate a DOE official to preside at the public meeting
and may also use a professional facilitator to aid discussion. The
meeting will not be a judicial or evidentiary-type public hearing, but
DOE will conduct it in accordance with section 336 of EPCA. (42 U.S.C.
6306) A court reporter will be present to record the proceedings and
prepare a transcript. DOE reserves the right to schedule the order of
presentations and to establish the
[[Page 14625]]
procedures governing the conduct of the public meeting. There shall not
be discussion of proprietary information, costs or prices, market
share, or other commercial matters regulated by U.S. anti-trust laws.
After the public meeting, interested parties may submit further
comments on the proceedings, as well as on any aspect of the
rulemaking, until the end of the comment period.
The public meeting will be conducted in an informal, conference
style. DOE will present summaries of comments received before the
public meeting, allow time for prepared general statements by
participants, and encourage all interested parties to share their views
on issues affecting this rulemaking. Each participant will be allowed
to make a general statement (within time limits determined by DOE),
before the discussion of specific topics. DOE will allow, as time
permits, other participants to comment briefly on any general
statements.
At the end of all prepared statements on a topic, DOE will permit
participants to clarify their statements briefly and comment on
statements made by others. Participants should be prepared to answer
questions by DOE and by other participants concerning these issues. DOE
representatives may also ask questions of participants concerning other
matters relevant to this rulemaking. The official conducting the public
meeting will accept additional comments or questions from those
attending, as time permits. The presiding official will announce any
further procedural rules or modification of the above procedures that
may be needed for the proper conduct of the public meeting.
A transcript of the public meeting will be included in the docket,
which can be viewed as described in the Docket section at the beginning
of this notice and will be accessible on the DOE Web site. In addition,
any person may buy a copy of the transcript from the transcribing
reporter.
D. Submission of Comments
DOE will accept comments, data, and information regarding this
proposed rule before or after the public meeting, but no later than the
date provided in the DATES section at the beginning of this proposed
rule. Interested parties may submit comments, data, and other
information using any of the methods described in the ADDRESSES section
at the beginning of this NOPR.
Submitting comments via www.regulations.gov. The
www.regulations.gov Web page will require you to provide your name and
contact information. Your contact information will be viewable to DOE
Building Technologies staff only. Your contact information will not be
publicly viewable except for your first and last names, organization
name (if any), and submitter representative name (if any). If your
comment is not processed properly because of technical difficulties,
DOE will use this information to contact you. If DOE cannot read your
comment due to technical difficulties and cannot contact you for
clarification, DOE may not be able to consider your comment.
However, your contact information will be publicly viewable if you
include it in the comment itself or in any documents attached to your
comment. Any information that you do not want to be publicly viewable
should not be included in your comment, nor in any document attached to
your comment. Otherwise, persons viewing comments will see only first
and last names, organization names, correspondence containing comments,
and any documents submitted with the comments.
Do not submit to www.regulations.gov information for which
disclosure is restricted by statute, such as trade secrets and
commercial or financial information (hereinafter referred to as
confidential business information or CBI). Comments submitted through
www.regulations.gov cannot be claimed as CBI. Comments received through
the Web site will waive any CBI claims for the information submitted.
For information on submitting CBI, see the Confidential Business
Information section below.
DOE processes submissions made through www.regulations.gov before
posting. Normally, comments will be posted within a few days of being
submitted. However, if large volumes of comments are being processed
simultaneously, your comment may not be viewable for up to several
weeks. Please keep the comment tracking number that www.regulations.gov
provides after you have successfully uploaded your comment.
Submitting comments via email, hand delivery/courier, or mail.
Comments and documents submitted via email, hand delivery/courier, or
mail also will be posted to www.regulations.gov. If you do not want
your personal contact information to be publicly viewable, do not
include it in your comment or any accompanying documents. Instead,
provide your contact information in a cover letter. Include your first
and last names, email address, telephone number, and optional mailing
address. The cover letter will not be publicly viewable as long as it
does not include any comments.
Include contact information each time you submit comments, data,
documents, and other information to DOE. If you submit via mail or hand
delivery/courier, please provide all items on a CD, if feasible, in
which case it is not necessary to submit printed copies. No
telefacsimiles (faxes) will be accepted.
Comments, data, and other information submitted to DOE
electronically should be provided in PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file format. Provide documents that
are not secured, that are written in English, and that are free of any
defects or viruses. Documents should not contain special characters or
any form of encryption and, if possible, they should carry the
electronic signature of the author.
Campaign form letters. Please submit campaign form letters by the
originating organization in batches of between 50 to 500 form letters
per PDF or as one form letter with a list of supporters' names compiled
into one or more PDFs. This reduces comment processing and posting
time.
Confidential Business Information. Pursuant to 10 CFR 1004.11, any
person submitting information that he or she believes to be
confidential and exempt by law from public disclosure should submit via
email, postal mail, or hand delivery/courier two well-marked copies:
One copy of the document marked ``confidential'' including all the
information believed to be confidential, and one copy of the document
marked ``non-confidential'' with the information believed to be
confidential deleted. Submit these documents via email or on a CD, if
feasible. DOE will make its own determination about the confidential
status of the information and treat it according to its determination.
Factors of interest to DOE when evaluating requests to treat
submitted information as confidential include: (1) A description of the
items; (2) whether and why such items are customarily treated as
confidential within the industry; (3) whether the information is
generally known by or available from other sources; (4) whether the
information has previously been made available to others without
obligation concerning its confidentiality; (5) an explanation of the
competitive injury to the submitting person that would result from
public disclosure; (6) when such information might lose its
confidential character due to the passage of time; and (7) why
disclosure of the information would be contrary to the public interest.
It is DOE's policy that all comments may be included in the public
docket,
[[Page 14626]]
without change and as received, including any personal information
provided in the comments (except information deemed to be exempt from
public disclosure).
E. Issues on Which DOE Seeks Comment
Although DOE welcomes comments on any aspect of this proposal, DOE
is particularly interested in receiving comments and views of
interested parties concerning the following issues:
1. DOE requests comment on its consideration to exclude from the
scope of the GSL rulemaking lamps that are addressed in other
rulemakings. See section IV.B.2.
2. DOE requests comment on the energy savings potential of
standards for GSLs greater than 2,600 lumens. See section IV.B.3.
3. DOE requests comment on the revised definitions proposed for
general service LED lamp, OLED lamp, and light fixture. See sections
IV.C.1, IV.C.2, and IV.C.6.
4. DOE requests comment on the definition proposed for LED
downlight retrofit kit. See section IV.C.7.
5. DOE requests comment on if there are any other lamp types
that do not serve in general lighting applications and should be
exempted from general service lamp standards. See section IV.D.
6. DOE welcomes comment on the exemptions proposed for non-
incandescent lamps of certain shapes, in particular on the proposal
to exempt B-shape lamps (including blunt shape), C- and CA-shape
lamps (including candle shape), F-shape lamps (including flame or
flame tip shape), S-shape lamps, and torpedo or torpedo tip shape
lamps with diameters of 1.875 inches or less, G-shape lamps with
diameters of 2.0625 or less, and A15 lamps with diameter of 2.185 or
less. See section IV.D.2.e.
7. DOE welcomes comment on including non-IRLs in the definition
of GSLs. See section IV.D.2.a.
8. DOE requests comment on the various definitions based on GSIL
exemptions proposed to better delineate the GSL definition,
especially in regards to determining the possible GSLs that use
technologies other than incandescent and operate in applications
equivalent to those of the lamps exempted from the GSIL definition.
See section IV.D.
9. DOE requests comments on its assessments of GSLs for which
standards should be proposed. See section IV.E.4.
10. DOE requests information on start times available on the CFL
market. See section IV.F.2.c.
11. DOE requests comment on its proposal to require integrated
LED lamps to meet a power factor of 0.7 or some other value. See
section IV.F.3.
12. DOE requests any comments regarding proposed metrics for
GSLs in this NOPR analysis. See section IV.F.4.
13. DOE requests comments on the proposed product classes. See
section V.A.1.
14. DOE requests comment on its proposed renaming of ``device
level optics'' to ``improved primary optics'' and refined
description of this technology option. See section V.A.2.b.
15. DOE requests comment on its proposal to replace the term
``increased light utilization'' with ``improved secondary optics''
and the refined definition of this technology option. See section
V.A.2.b.
16. DOE requests comments on the proposed technology options.
See section V.A.2.c.
17. DOE requests comment on the proposed design options in this
NOPR analysis. See section V.B.3.
18. In its collection of lamp performance data, DOE did not
consider high and low end outliers in the engineering analysis where
DOE was unable to verify values using test data or manufacturer
confirmation. DOE welcomes comment on the data approach. See section
V.C.1.
19. DOE requests comment on the baseline lamps analyzed in the
NOPR analysis, in particular the spiral CFL baseline in the
Integrated Low-Lumen product class. See section V.C.3.a.
20. DOE requests comment on the 3-way lamp used as a basis for
the modeled LED lamp and information on whether such a lamp would
meet DOE's screening criteria and should be maintained for the final
rule analysis. See section V.C.4.
21. DOE requests comment on the ELs under consideration for both
of the integrated lamp product classes, including the max-tech
levels. See section V.C.5.a.
22. DOE requests comment on the assumption that the efficacy of
non-integrated CFLs can be improved for those lamps with base types
that potentially cannot meet EL 1. See section V.C.5.b.
23. DOE requests comment on the EL under consideration for the
Non-Integrated product class, including the max-tech level. See
section V.C.5.b.
24. DOE requests comment on the scaling factors determined. See
section V.C.6.
25. DOE requests comment on its assumption that the EISA 2007
backstop will be triggered. See section V.E.1.a.
26. DOE requests comment on the data and methodology used to
estimate operating hours for GSLs in the residential sector, as well
as on the assumption that GSL operating hours do not vary between
CFLs and LED GSLs. See section V.E.1.a.
27. DOE invites comments and data on its approach to account for
variability in HOU in the commercial sector. See section V.E.1.b.
28. DOE requests comment on the energy reduction estimate of 30
percent, as well as data and information on the energy use
implications of using dimmers in the residential sector. See section
V.E.3.
29. DOE requests comment on the assumption that, although in the
NOPR analyses DOE continues to assume that 5 percent of CFLs are
dimmable, the fraction of CFLs and LEDs that are used with controls
external to the lamp is assumed to be the same (14 percent in the
reference case) in the residential sector. See section V.E.3.
30. DOE requests comment on the overall methodology and results
of the LCC and PBP analyses. See section V.F.
31. DOE requests comment on the installation cost assumptions
used in its analyses. See section V.F.2.
32. DOE requests comment on the methodology and assumptions used
to determine the market share of the lumen range distributions. See
section V.F.3.
33. DOE invites comment on the three GSL service life scenarios
in its analyses. DOE also invites comment on the lifetime scenario
accounting for GSL failure in the first year of use. See section
V.F.6.
34. DOE requests comment and relevant data on the disposal cost
assumptions used in its analyses. See section V.F.8.
35. DOE requests relevant data on GSL shipments as they become
available in order to improve the accuracy of the shipments
analysis. See section V.G.1.a.
36. DOE requests comment on the assumption that the shift to CFL
and LED GSLs during the shipments analysis period will take place
over several years. See section V.G.1.a.
37. DOE requests comment on whether there are data, in the
lighting sector, showing that consumers might purchase, in quantity,
existing products on the market prior to compliance of a new, more
efficient standard.
38. DOE invites comments on its approach to price learning for
LED GSLs. See section V.G.1.b.
39. DOE requests comment on the assumption that brighter lumen
bins have a fixed fractional price increment relative to lamps in
dimmer lumen bins. See section V.G.1.b.
40. DOE has assumed zero rebound effect in the reference
scenario for consumers switching from CFLs to LED lamps in both the
commercial and residential sectors. In an alternative scenario, DOE
has assumed 15 percent rebound in the residential sector for
consumers switching from CFLs to LED lamps, and zero rebound in the
commercial sector. DOE requests comment on these assumptions and any
data that can be used to further refine the rebound effect
assumptions used in the shipments and NIA analyses. See section
V.H.1.
41. DOE estimated a reduction in product costs at the proposed
standard level because (1) more efficacious lamps have longer
average lifetimes than less efficacious lamps, resulting in fewer
replacement purchases, (2) the purchase price of more efficacious
LED lamps is lower than the price of less efficacious LED lamps, and
(3) the purchase price of LED lamps declines faster than the price
of CFLs during the analysis period, resulting in LED lamps becoming
less expensive than CFLs. DOE requests comment on the cost reduction
estimate. See section VI.C.2.
42. DOE considered three lighting-controls scenarios including a
smaller range of penetration for smart lamps: 0 percent smart-lamp
penetration in the residential sector by 2049, 50 percent
penetration (the reference scenario), and a high residential-
controls scenario which assumed that externally controlled sockets
increase to 50 percent of all sockets in 2049 in addition to a 50
percent penetration of smart lamps in 2049. DOE invites comment on
these scenarios. See section V.H.1.a.
43. DOE requests data and information on the assumption of 30
percent energy savings for smart lamps. See section V.H.1.a.
44. DOE invites comment on the low and high benefits scenarios
considered in its analysis. See section V.H.2.
[[Page 14627]]
45. In addition to the high and low benefits scenarios, DOE
considered several other scenarios in its shipments and NIA
analyses. DOE invites comments on whether there are other scenarios
that should be considered. See section V.H.2.
46. DOE requests comment on the consumer subgroups selected for
analysis in this NOPR. See section V.I.
47. DOE requests comment on its approach to conducting the
emissions analysis for GSLs. See section V.K.
48. DOE requests comment on the use of 1.52 as an average
distribution chain markup and 1.55 as the manufacturer markup for
all GSLs. See section V.J.2.b.
49. DOE seeks comment on the assumption that there is only one
GSL manufacturer with domestic production of CFLs or LED lamps.
Additionally, DOE seeks comment on any potential domestic employment
impacts as a result of the proposed new and amended energy
conservation standards for GSLs in this NOPR. See section VI.B.2.b.
50. DOE seeks comment on any other potential manufacturer
subgroups that could be disproportionally impacted by new and
amended energy conservation standards for GSLs. See section
VI.B.2.d.
51. DOE seeks comment on the compliance costs of any other
regulations GSL manufacturers must make, especially if compliance
with those regulations is required three years before or after the
estimated compliance date of these proposed standards (2020). See
section VI.B.2.e.
52. DOE invites input on its approach to estimating monetary
benefits associated with emissions reductions. See section V.L.
53. DOE seeks comment on its approach to conducting the utility
impact analysis. See section V.M.
54. DOE welcomes input on its approach to assessing national
employment impacts. See section V.N.
55. DOE requests comment on its assumption that there will be no
lessening of utility or performance such that the performance
characteristics, including physical constraints, diameter, lumen
package, color quality, lifetime, and ability to dim, would be
adversely affected for the GSL efficacy levels. See sections VI.B.4,
V.A, V.B, and V.C.
56. 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 regulatory analysis in future
rulemakings. See section VI.C.
57. DOE requests any available data or reports that would
contribute to the analysis of alternatives to standards for GSLs. In
particular, DOE seeks information on the effectiveness of existing
or past efficiency improvement programs for these products. See
section VII.B.4.
IX. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of this notice of
proposed rulemaking.
List of Subjects
10 CFR Part 429
Confidential business information, Energy conservation, Household
appliances, Imports, Reporting and recordkeeping requirements.
10 CFR Part 430
Administrative practice and procedure, Confidential business
information, Energy conservation, Household appliances, Imports,
Incorporation by reference, Intergovernmental relations, Small
businesses.
Issued in Washington, DC, on February 12, 2016.
David T. Danielson,
Assistant Secretary, Energy Efficiency and Renewable Energy.
For the reasons set forth in the preamble, DOE proposes to amend
parts 429 and 430 of chapter II, subchapter D, of title 10 of the Code
of Federal Regulations, as set forth below:
PART 429--CERTIFICATION, COMPLIANCE, AND ENFORCEMENT FOR CONSUMER
PRODUCTS AND COMMERCIAL AND INDUSTRIAL EQUIPMENT
0
1. The authority citation for part 429 continues to read as follows:
Authority: 42 U.S.C. 6291-6317.
0
2. Section 429.12 is amended by revising paragraph (d) to read as
follows:
Sec. 429.12 General requirements applicable to certification reports.
* * * * *
(d) Annual filing. All data required by paragraphs (a) through (c)
of this section shall be submitted to DOE annually, on or before the
following dates:
------------------------------------------------------------------------
Product category Deadline for data submission
------------------------------------------------------------------------
Fluorescent lamp ballasts, Incandescent Mar. 1.
reflector lamps, General service
fluorescent lamps, General service lamps,
Residential ceiling fans, Residential
ceiling fan light kits, Residential
showerheads, Residential faucets,
Residential water closets, and
Residential urinals.
Residential water heater, Residential May 1.
furnaces, Residential boilers,
Residential pool heaters, Commercial
water heaters, Commercial hot water
supply boilers, Commercial unfired hot
water storage tanks, Commercial packaged
boilers, Commercial warm air furnaces,
Commercial unit heaters and Residential
furnace fans.
Residential dishwashers, Commercial June 1.
prerinse spray valves, Illuminated exit
signs, Traffic signal modules, Pedestrian
modules, and Distribution transformers.
Room air conditioners, Residential central July 1.
air conditioners, Residential central
heat pumps, Small duct high velocity
system, Space constrained products,
Commercial package air-conditioning and
heating equipment, Packaged terminal air
conditioners, Packaged terminal heat
pumps, and Single package vertical units.
Residential refrigerators, Residential Aug. 1.
refrigerators-freezers, Residential
freezers, Commercial refrigerator,
freezer, and refrigerator-freezer,
Automatic commercial automatic ice
makers, Refrigerated bottled or canned
beverage vending machine, Walk-in
coolers, and Walk-in freezers.
Torchieres, Residential dehumidifiers, Sept. 1.
Metal halide lamp fixtures, External
power supplies, and Pumps.
Residential clothes washers, Residential Oct. 1.
clothes dryers, Residential direct
heating equipment, Residential cooking
products, and Commercial clothes washers.
------------------------------------------------------------------------
[[Page 14628]]
* * * * *
PART 430--ENERGY CONSERVATION PROGRAM FOR CONSUMER PRODUCTS
0
3. 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
4. Section 430.2 is amended by:
0
a. Adding in alphabetical order the definitions of ``Black light
lamp,'' ``Bug lamp,'' ``Colored lamp,'' ``General service light-
emitting diode LED lamp,'' ``GU24 base,'' ``Infrared lamp,''
``Integrated lamp,'' ``LED Downlight Retrofit Kit,'' ``Light fixture,''
``Marine signal service lamp,'' ``Mercury vapor lamp,'' ``Mine service
lamp,'' ``Non-integrated lamp,'' ``Non-reflector lamp,'' ``OLED lamp,''
``Pin base lamp,'' ``Plant light lamp,'' ``Reflector lamp,'' ``Showcase
Lamp,'' ``Sign service lamp,'' ``Silver bowl lamp,'' and ``Traffic
signal lamp;'' and
0
b. Revising the definitions of ``designed and marketed'' and ``general
service lamp.''
The additions and revisions read as follows:
Sec. 430.2 Definitions.
* * * * *
Black light lamp means a lamp that is designed and marketed as a
black light lamp and is an ultraviolet lamp with the highest radiant
power peaks in the UV-A band (315 to 400 nm) of the electromagnetic
spectrum.
* * * * *
Bug lamp means a lamp that is designed and marketed as a bug lamp,
has radiant power peaks above 550 nm on the electromagnetic spectrum,
and has a visible yellow coating.
* * * * *
Colored lamp means a colored fluorescent lamp, a colored
incandescent lamp, or a lamp designed and marketed as a colored lamp
and not designed and marketed for general lighting applications with
either of the following characteristics (if multiple modes of operation
are possible [such as variable CCT], either of the below
characteristics must be maintained throughout all modes of operation):
(1) A CRI less than 40, as determined according to the method set
forth in CIE Publication 13.3 (incorporated by reference; see Sec.
430.3); or
(2) A correlated color temperature less than 2,500 K or greater
than 7,000 K as determined according to the method set forth in IES LM-
66 or IES LM-79 as appropriate (incorporated by reference; see Sec.
430.3).
* * * * *
Designed and marketed means that the product is specifically
designed to fulfill the indicated application and, when distributed in
commerce, is designated and marketed for the intended application, with
the designation on the packaging and all publicly available documents
(e.g., product literature, catalogs, and packaging labels) indicating
the intended application. 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.
* * * * *
General service lamp means a lamp that has an ANSI base, operates
at any voltage, has an initial lumen output of 310 lumens or greater
(or 232 lumens or greater for modified spectrum general service
incandescent lamps), is not a light fixture, is not an LED downlight
retrofit kit, and is used in general lighting applications. General
service lamps include, but are not limited to, general service
incandescent lamps, compact fluorescent lamps, general service light-
emitting diode lamps, and general service organic light-emitting diode
lamps, but do not include general service fluorescent lamps;
incandescent reflector lamps; mercury vapor lamps; appliance lamps;
black light lamps; bug lamps; colored lamps; infrared lamps; marine
signal lamps; mine service lamps; plant light lamps; sign service
lamps; traffic signal lamps; and medium screw base incandescent lamps
that are left-hand thread lamps, marine lamps, reflector lamps, rough
service lamps, shatter-resistant lamps (including a shatter-proof lamp
and a shatter-protected lamp), silver bowl lamps, showcase lamps, 3-way
incandescent lamps, vibration service lamps, G shape lamps as defined
in ANSI C78.20 (incorporated by reference; see Sec. 430.3) and ANSI
C79.1-2002 (incorporated by reference; see Sec. 430.3) with a diameter
of 5 inches or more, T shape lamps as defined in ANSI C78.20 and ANSI
C79.1-2002 and that use not more than 40 watts or have a length of more
than 10 inches, and B, BA, CA, F, G16-1/2, G-25, G30, S, or M-14 lamps
as defined in ANSI C79.1-2002 and ANSI C78.20 of 40 watts or less.
General service light-emitting diode (LED) lamp means an integrated
or non-integrated LED lamp designed for use in general lighting
applications (as defined in Sec. 430.2) and that uses light-emitting
diodes as the primary source of light.
* * * * *
GU24 base means the GU24 base standardized in ANSI C81.61
(incorporated by reference; see Sec. 430.3).
* * * * *
Infrared lamp means a lamp that is designed and marketed as an
infrared lamp, has its highest radiant power peaks in the infrared
region of the electromagnetic spectrum (770 nm to 1 mm), and which has
a primary purpose of providing heat.
Integrated lamp means a lamp that contains all components necessary
for the starting and stable operation of the lamp, does not include any
replaceable or interchangeable parts, and is connected directly to a
branch circuit through an ANSI base and corresponding ANSI standard
lamp-holder (socket).
* * * * *
LED Downlight Retrofit Kit means a product intended to install into
an existing downlight, replacing the existing light source and related
electrical components, typically employing an ANSI standard lamp base,
either integrated or connected to the downlight retrofit by wire leads,
and is a retrofit kit classified or certified to UL 1598C (incorporated
by reference; see Sec. 430.3). LED downlight retrofit kit does not
include integrated lamps or non-integrated lamps.
* * * * *
Light fixture means a complete lighting unit consisting of light
source(s) and ballast(s) (when applicable) together with the parts
designed to distribute the light, to position and protect the light
source, and to connect the light source(s) to the power supply.
* * * * *
Marine signal service lamp means a lamp that is designed and
marketed for marine signal service applications.
* * * * *
Mercury vapor lamp means a high intensity discharge lamp, including
clear, phosphor-coated, and self-ballasted screw base lamps, in which
the major portion of the light is produced by radiation from mercury
typically operating at a partial vapor pressure in excess of 100,000
pascal (approximately 1 atmosphere).
* * * * *
Mine service lamp means a lamp that is designed and marketed for
mine service applications.
* * * * *
Non-integrated lamp means a lamp that is not an integrated lamp.
[[Page 14629]]
Non-reflector lamp means a lamp that is not a reflector lamp.
* * * * *
OLED lamp means an integrated or non-integrated lamp designed for
use in general lighting applications that uses OLEDs as the primary
source of light.
* * * * *
Pin base lamp means a base type designated as a single pin base or
multiple pin base system in Table 1 of ANSI C81.61, Specifications for
Electrics Bases (incorporated by reference; see Sec. 430.3).
* * * * *
Plant light lamp means a lamp that is designed to promote plant
growth by emitting its highest radiant power peaks in the regions of
the electromagnetic spectrum that promote photosynthesis: Blue (440 nm
to 490 nm) and/or red (620 to 740 nm). Plant light lamps must be
designed and marketed for plant growing applications.
* * * * *
Reflector lamp means a lamp that has an R, PAR, BPAR, BR, ER, MR,
or similar bulb shape as defined in ANSI C78.20 (incorporated by
reference; see Sec. 430.3) and ANSI C79.1-2002 (incorporated by
reference; see Sec. 430.3) and is used to direct light.
* * * * *
Showcase lamp means a lamp that has a T-shape as specified in ANSI
C78.20 (incorporated by reference; see Sec. 430.3) and ANSI C79.1-2002
(incorporated by reference; see Sec. 430.3), is designed and marketed
as a showcase lamp, and has a maximum rated wattage of 75 watts.
* * * * *
Sign service lamp means a vacuum type or gas-filled lamp that has
sufficiently low bulb temperature to permit exposed outdoor use on
high-speed flashing circuits, is designed and marketed as a sign
service lamp, and has a maximum rated wattage 15 watts.
Silver bowl lamp means a lamp that has a reflective coating applied
directly to part of the bulb surface that reflects light toward the
lamp base and that is designed and marketed as a silver bowl lamp.
* * * * *
Traffic signal lamp means a lamp that is designed and marketed for
traffic signal applications.
* * * * *
0
5. Section 430.3 is amended by adding paragraph (u)(4) to read as
follows:
Sec. 430.3 Materials incorporated by reference.
* * * * *
(u) * * *
(4) UL 1598C-2014 (``UL 1598C''), Standard for Light-Emitting Diode
(LED) Retrofit Luminaire Conversion Kits, First Edition, dated January
16, 2014, IBR approved for Sec. 430.2.
* * * * *
0
6. Section 430.32 is amended by removing and reserving paragraphs (u)
and (x), and adding paragraph (z) to read as follows:
Sec. 430.32 Energy and water conservation standards and their
compliance dates.
* * * * *
(u) Removed and Reserved.
* * * * *
(x) Removed and Reserved.
* * * * *
(z) General service lamps. (1) Energy conservation standards for
general service lamps:
(i) General service incandescent lamps manufactured after the dates
specified in the tables below, except as described in paragraph
(z)(1)(ii) of this section, shall have a rated wattage no greater than
the values shown in the table in this paragraph:
General Service Incandescent Lamps
------------------------------------------------------------------------
Maximum rate Compliance
Rated lumen ranges wattage date
------------------------------------------------------------------------
1490-2600............................... 72 1/1/2012
1050-1489............................... 53 1/1/2013
750-1049................................ 43 1/1/2014
310-749................................. 29 1/1/2014
------------------------------------------------------------------------
(ii) Modified spectrum general service incandescent lamps
manufactured after the dates specified in the table in this paragraph
shall have a rated wattage no greater than the values shown in the
table in this paragraph:
Modified Spectrum General Service Incandescent Lamps
------------------------------------------------------------------------
Maximum rate Compliance
Rated lumen ranges wattage date
------------------------------------------------------------------------
1118-1950............................... 72 1/1/2012
788-1117................................ 53 1/1/2013
563-787................................. 43 1/1/2014
232-562................................. 29 1/1/2014
------------------------------------------------------------------------
(iii) Each candelabra base incandescent lamp shall not exceed 60
rated watts.
(iv) Each intermediate base incandescent lamp shall not exceed 40
rated watts.
(v) A bare or covered (no reflector) medium base compact
fluorescent lamp manufactured on or after January 1, 2006, must meet or
exceed the following requirements:
------------------------------------------------------------------------
Factor Requirements
------------------------------------------------------------------------
Labeled Wattage (Watts) & Minimum initial lamp efficacy (lumens
Configuration *. per watt) must be at least:
Bare Lamp: .....................................
Labeled Wattage <15.......... 45.0
Labeled Wattage >=15......... 60.0
Covered Lamp (no reflector): .....................................
Labeled Wattage <15.......... 40.0
15<= Labeled Wattage <19..... 48.0
19<= Labeled Wattage <25..... 50.0
Labeled Wattage >=25......... 55.0
------------------------------------------------------------------------
* Use labeled wattage to determine the appropriate efficacy requirements
in this table; do not use measured wattage for this purpose.
(vi) Except as provided in paragraph (z)(3) of this section, each
general service lamp manufactured on or after [DATE 3 YEARS AFTER DATE
OF PUBLICATION IN THE Federal Register OF FINAL RULE] that:
(A) Is an integrated, non-reflector lamp with a medium screw base
and an initial lumen output between 310 and 2,600 lumens; or
(B) Is an integrated or non-integrated non-reflector lamp with a
GU24 base and an initial lumen output between 310 and 2,600 lumens;
shall have:
(1) A power factor greater than or equal to 0.7 for integrated LED
lamps (as defined in Sec. 430.2) and 0.5 for integrated compact
fluorescent lamps (as defined in appendix W of subpart B); and
(2) A lamp efficacy greater than or equal to the values shown in
the table in this paragraph:
[[Page 14630]]
----------------------------------------------------------------------------------------------------------------
Minimum lamp efficacy
Lamp type Lumen package (lumens) Standby mode operation (lm/W)
----------------------------------------------------------------------------------------------------------------
Integrated GSLs...................... 310 <= Initial Lumen No standby mode........ 101.6 -
Output <2,000. 29.42*0.9983[supcaret]
Initial Lumen Output.
Capable of operating in 96.0--29.42*0.9983[supc
standby mode. aret]Initial Lumen
Output.
2,000 <= Initial Lumen No standby mode........ 73.4 -
Output <= 2,600. 29.42*0.9983[supcaret]
Initial Lumen Output.
Capable of operating in 70.5 -
standby mode. 29.42*0.9983[supcaret]
Initial Lumen Output.
----------------------------------------------------------------------------------------------------------------
(vii) Effective beginning January 1, 2020, each general service
lamp sold shall meet a minimum efficacy standard of 45.0 lumens per
watt.
(2) Other standards for general service lamps:
(i) General service incandescent lamps manufactured after the dates
specified in the tables below, except as described in paragraph
(z)(2)(ii) of this section, shall have a color rendering index greater
than or equal to 80 and shall have a rated lifetime not less than the
values shown in the table in this paragraph:
General Service Incandescent Lamps
------------------------------------------------------------------------
Minimum
Rated lumen ranges rate life- Compliance
time (hrs) date
------------------------------------------------------------------------
1490-2600...................................... 1,000 1/1/2012
1050-1489...................................... 1,000 1/1/2013
750-1049....................................... 1,000 1/1/2014
310-749........................................ 1,000 1/1/2014
------------------------------------------------------------------------
(ii) Modified spectrum general service incandescent lamps
manufactured after the dates specified shall have a color rendering
index greater than or equal to 75 and shall have a rated lifetime not
less than the values shown in the table in this paragraph:
Modified Spectrum General Service Incandescent Lamps
------------------------------------------------------------------------
Minimum
Rated lumen ranges rate life- Compliance
time (hrs) date
------------------------------------------------------------------------
1118-1950...................................... 1,000 1/1/2012
788-1117....................................... 1,000 1/1/2013
563-787........................................ 1,000 1/1/2014
232-562........................................ 1,000 1/1/2014
------------------------------------------------------------------------
(iii) Medium base CFLs (as defined in Sec. 430.2) manufactured on
or after the dates specified in the table below shall meet or exceed
the following standards:
------------------------------------------------------------------------
Requirements for
Requirements for MBCFLs
MBCFLs manufactured on or
Metrics manufactured on or after [DATE 3
after January 1, YEARS AFTER
2006 PUBLICATION OF
FINAL RULE]
------------------------------------------------------------------------
Lumen Maintenance at 1,000 Hours >= 90.0%
---------------------------------------
Lumen Maintenance at 40 Percent >= 80.0%
of Lifetime *.
---------------------------------------
Rapid Cycle Stress Test......... At least 5 lamps must meet or exceed
the minimum number of cycles.
---------------------------------------
All MBCFLs: Cycle MBCFLs with start
once per every time > 100 ms:
two hours of Cycle once per
lifetime.* hour of lifetime
* or a maximum of
15,000 cycles.
MBCFLs with a
start time of <=
100 ms: Cycle
once per every
two hours of
lifetime.*
Lifetime *...................... >= 6,000 hours.... >= 10,000 hours.
CRI............................. No requirement.... 80.
Start time...................... No requirement.... The time needed
for a MBCFL to
become fully
illuminated must
be within one
second of
application of
electrical power.
------------------------------------------------------------------------
* Lifetime refers to lifetime of a compact fluorescent lamp as defined
in 10 CFR 430.2.
(3) The standards described in paragraph (z)(1)(vi) of this section
do not apply to:
(i) Non-integrated CFLs with a pin base;
(ii) Non-integrated LED lamps with a pin base;
(iii) Lamps that have initial lumen outputs greater than 2600
lumens;
(iv) Reflector lamps;
(v) OLED lamps;
(vi) General service incandescent lamps;
(vii) The following medium screw base lamps that are not
incandescent lamps:
(A) A15 lamps (as defined in ANSI 79.1-2002 (incorporated by
reference; see Sec. 430.3)) with lamp diameter when measured at the
widest point of less than or equal to 2.185 inches.
(B) Any of the following shapes with lamp diameter when measured at
the widest point of less than or equal to 2.0625 inches: G lamps (as
defined in ANSI 79.1-2002) and lamps specifically designed and marketed
as a globe shape.
(C) Any of the following shapes with lamp diameter when measured at
the widest point of less than or equal to 1.875 inches: B lamps (as
defined in ANSI 79.1-2002); C lamps (as defined in ANSI 79.1-2002); CA
lamps (as defined in ANSI 79.1-2002); F lamps (as defined in ANSI 79.1-
2002); S lamps (as defined in ANSI 79.1-2002); and lamps specifically
designed and marketed as a blunt, candle, flame, flame tip, torpedo, or
torpedo tip shape.
[FR Doc. 2016-04813 Filed 3-16-16; 8:45 am]
BILLING CODE 6450-01-P