Energy Conservation Program: Energy Conservation Standards for General Service Fluorescent Lamps and Incandescent Reflector Lamps
Federal RegisterJan 26, 2015
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DEPARTMENT OF ENERGY
10 CFR Part 430
[Docket Number EERE-2011-BT-STD-0006]
RIN 1904-AC43
Energy Conservation Program: Energy Conservation Standards for General Service Fluorescent Lamps and Incandescent Reflector Lamps
AGENCY:
Office of Energy Efficiency and Renewable Energy, Department of Energy.
ACTION:
Final rule.
SUMMARY:
The Energy Policy and Conservation Act of 1975 (EPCA), as amended, prescribes energy conservation standards for various consumer products and certain commercial and industrial equipment, including general service fluorescent lamps (GSFLs) and incandescent reflector lamps (IRLs). EPCA also requires the U.S. Department of Energy (DOE) to determine whether more-stringent standards would be technologically feasible and economically justified, and would save a significant amount of energy. In this final rule, DOE is adopting more-stringent energy conservation standards for GSFLs. It has determined that the amended energy conservation standards for these products would result in significant conservation of energy, and are technologically feasible and economically justified. DOE concluded in this final rule that amending energy conservation standards for IRLs would not be economically justified.
DATES:
The effective date of this rule is March 27, 2015. Compliance with the amended
standards established for GSFLs and IRLs in this final rule is January 26, 2018.
ADDRESSES:
The docket, which includes
Federal Register
notices, public meeting attendee lists and transcripts, comments, and other supporting documents/materials, is available for review at regulations.gov. All documents in the docket are listed in the regulations.gov index. However, some documents listed in the index, such as those containing information that is exempt from public disclosure, may not be publicly available.
A link to the docket Web page can be found at:
www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/24
. The regulations.gov Web page will contain simple instructions on how to access all documents, including public comments, in the docket.
For further information on how to review the docket, contact Ms. Brenda Edwards at (202) 586-2945 or by email:
Brenda.Edwards@ee.doe.gov
.
FOR FURTHER INFORMATION CONTACT:
Ms. Lucy deButts, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue SW., Washington, DC 20585-0121. Telephone: (202) 287-1604. Email:
General_Service_Fluorescent_Lamps@ee.doe.gov
.
Ms. Elizabeth Kohl, U.S. Department of Energy, Office of the General Counsel, GC-71, 1000 Independence Avenue SW., Washington, DC 20585-0121. Telephone: (202) 586-7796. Email:
Elizabeth.Kohl@hq.doe.gov
.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Summary of the Final Rule and Its Benefits
A. Benefits and Costs to Consumers
B. Impact on Manufacturers
C. National Benefits
D. Conclusion
II. Introduction
A. Authority
B. Background
1. Current Standards
2. Corrections to Codified Standards
3. History of Standards Rulemaking for General Service Fluorescent Lamps and Incandescent Reflector Lamps
4. Test Procedure
a. Standby and Off Mode Energy Consumption
III. General Discussion
A. Product Classes and Scope of Coverage
B. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
C. Energy Savings
1. Determination of Savings
2. Significance of Savings
D. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Consumers
b. Savings in Operating Costs Compared to Increase in Price
c. Energy Savings
d. Lessening of Utility or Performance of Products
e. Impact of Any Lessening of Competition
f. Need for National Energy Conservation
g. Other Factors
2. Rebuttable Presumption
IV. Issues Affecting Rulemaking Schedule
V. Issues Affecting Scope
A. Clarifications of General Service Fluorescent Lamp Definition
B. General Service Fluorescent Lamp Scope of Coverage
1. Additional General Service Fluorescent Lamp Types
2. Additional General Service Fluorescent Lamp Wattages
C. Incandescent Reflector Lamp Scope of Coverage
1. Incandescent Reflector Lamp Types
2. Incandescent Reflector Wattages
D. Summary of Scope of Coverage
VI. Methodology and Discussion
A. Market and Technology Assessment
1. General Service Fluorescent Lamp Technology Options
a. Highly Emissive Coatings
b. Higher Efficiency Lamp Fill Gas Composition
c. Higher Efficiency Phosphors
d. Summary of GSFL Technology Options
2. Incandescent Reflector Lamp Technology Options
a. Thinner Filaments
b. Efficient Filament Coiling
c. Efficient Filament Orientation
d. Higher Efficiency Inert Fill Gas
e. Higher Pressure Tungsten-Halogen Lamps
f. Infrared Glass Coatings
g. Efficient Filament Placement
h. Integrally Ballasted Low Voltage Lamps
i. Summary of IRL Technology Options
B. Screening Analysis
1. General Service Fluorescent Lamp Design Options
2. Incandescent Reflector Lamp Design Options
a. Higher Temperature Operation
b. Thinner Filaments
c. Higher Efficiency Reflector Coatings
d. Higher Pressure Tungsten-Halogen Lamps
C. Product Classes
1. General Service Fluorescent Lamp Product Classes
a. Two-Foot U-Shaped Lamps
b. Long-Life Lamps
c. Summary of GSFL Product Classes
2. Incandescent Reflector Lamp Product Classes
a. Rated Voltage
b. Modified Spectrum
c. Summary of IRL Product Classes
D. Engineering Analysis
1. General Approach
2. General Service Fluorescent Lamp Engineering
a. Data Approach
b. Representative Product Classes
c. Baseline Lamps
d. More Efficacious Substitutes
e. General Service Fluorescent Lamp Systems
f. Max Tech
g. Efficacy Levels
h. Scaling to Other Product Classes
i. Rare Earth Phosphors
3. Incandescent Reflector Lamp Engineering
a. Representative Product Classes
b. Baseline Lamps
c. More Efficacious Substitutes
d. Max Tech
e. Efficacy Levels
f. Scaling to Other Product Classes
g. Xenon
h. Proprietary Technology
E. Product Pricing Determination
F. Energy Use
1. Operating Hours
2. Lighting Controls
a. General Service Fluorescent Lamp Lighting Controls
b. Incandescent Reflector Lamp Lighting Controls
G. Life-Cycle Cost Analysis and Payback Period Analysis
1. Consumer Product Price
2. Sales Tax
3. Installation Cost
4. Annual Energy Use
5. Product Energy Consumption Rate
6. Electricity Prices
7. Electricity Price Projections
8. Replacement and Disposal Costs
9. Lamp Purchase Events
10. Product Lifetime
a. Lamp Lifetime
b. Ballast Lifetime
11. Discount Rates
12. Analysis Period
13. Compliance Date of Standards
14. Incandescent Reflector Lamp Life-Cycle Cost Results in the NOPR
H. Consumer Subgroup Analysis
I. Shipments Analysis
J. National Impact Analysis—National Energy Savings and Net Present Value Analysis
1. National Energy Savings
2. Net Present Value of Consumer Benefit
a. Total Annual Installed Cost
b. Total Annual Operating Cost Savings
K. Manufacturer Impact Analysis
1. Manufacturer Production Costs
2. Shipment Projections
3. Markup Scenarios
4. Product and Capital Conversion Costs
5. Other Comments From Interested Parties
a. High Cost to Manufacturers versus Relatively Low Energy Savings
b. Impacts on Competition
c. Impact of GSFL and IRL Standards on Alternative Lighting Technologies
6. Manufacturer Interviews
L. Emissions Analysis
M. Monetizing Carbon Dioxide and Other Emissions Impacts
1. Social Cost of Carbon
a. Monetizing Carbon Dioxide Emissions
b. Development of Social Cost of Carbon Values
c. Current Approach and Key Assumptions
2. Valuation of Other Emissions Reductions
N. Utility Impact Analysis
O. Employment Impact Analysis
P. Proposed Standards in April 2014 NOPR
1. GSFLs Proposed Standards
2. IRL Proposed Standards
VII. Analytical Results
A. Trial Standard Levels
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
a. Life-Cycle Cost and Payback Period
b. Consumer Subgroup Analysis
c. Rebuttable-Presumption Payback
2. Economic Impacts on Manufacturers
a. Industry Cash-Flow Analysis Results
b. Impacts on Employment
c. Impacts on Manufacturing Capacity
d. Impacts on Subgroups of Manufacturers
e. Cumulative Regulatory Burden
3. National Impact Analysis
a. Significance of Energy Savings
b. Net Present Value of Consumer Costs and Benefits
c. Alternative Scenario Analyses
d. Indirect Impacts on Employment
4. Impact on Utility or Performance of Equipment
5. Impact of Any Lessening of Competition
6. Need of the Nation to Conserve Energy
7. Summary of National Economic Impacts
C. Conclusions
1. Benefits and Burdens of Trial Standard Levels Considered for General Service Fluorescent Lamps
2. Summary of Benefits and Costs (Annualized) of the Adopted Standards for General Service Fluorescent Lamps
3. Benefits and Burdens of Trial Standard Levels Considered for Incandescent Reflector Lamps
VIII. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
1. Description and Estimated Number of Small Entities Regulated
a. Methodology for Estimating the Number of Small Entities
b. Manufacturer Participation
c. GSFL Industry Structure and Nature of Competition
d. Comparison Between Large and Small Entities
2. Description and Estimate of Compliance Requirements
3. Duplication, Overlap, and Conflict With Other Rules and Regulations
4. Significant Alternatives to the Rule
C. Review Under the Paperwork Reduction Act
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Review Under the Information Quality Bulletin for Peer Review
M. Congressional Notification
IX. Approval of the Office of the Secretary
I. Summary of the Final Rule and Its Benefits
Title III, Part B
1
of the Energy Policy and Conservation Act of 1975 (EPCA or the Act), Pub. L. 94-163 (42 U.S.C. 6291-6309, as codified), established the Energy Conservation Program for Consumer Products Other Than Automobiles.
2
These products include GSFLs and IRLs, the subject of this final rule.
1
For editorial reasons, upon codification in the U.S. Code, Part B was redesignated Part A.
2
All references to EPCA in this document refer to the statute as amended through the American Energy Manufacturing Technical Corrections Act (AEMTCA), Pub. L. 112-210 (Dec. 18, 2012).
Pursuant to EPCA, any new or amended energy conservation standard must be designed to achieve the maximum improvement in energy efficiency that DOE determines is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, the new or amended standard must result in significant conservation of energy. (42 U.S.C. 6295(o)(3)(B)) In accordance with these and other statutory provisions discussed in this rule, DOE is adopting amended energy conservation standards for GSFLs. The amended standards, which are the minimum lumen output per watt of a lamp, are shown in Table I.1. These amended standards apply to all products listed in Table I.1, and manufactured in, or imported into, the United States on or after January 26, 2018. For IRLs, DOE considered an efficacy level (EL) as a means of increasing energy savings. However, based on the analyses presented in this final rule, DOE concluded that standards for IRLs are not economically justified and therefore, is not amending IRL standards. On July 14, 2009, DOE published a final rule in the
Federal Register
, which prescribed the current energy conservation standards for GSFLs and IRLs manufactured on or after July 14, 2012. 74 FR 34080.
Table I.1—Energy Conservation Standards for General Service Fluorescent Lamps
[Compliance starting January 26, 2018]
Lamp type
Covered wattages
W
Correlated color
temperature
Kelvin
Adopted level
lm/W *
Percent
increase over current
standards
4-Foot Medium Bipin
≥25 W
≤4,500 K
>4,500 K and ≤7,000 K
92.4
88.7
3.8
0.8
2-Foot U-Shaped
≥25 W
≤4,500 K
>4,500 K and ≤7,000 K
85.0
83.3
1.2
2.8
8-Foot Slimline
≥49 W
≤4,500 K
>4,500 K and ≤7,000 K
97.0
93.0
0.0
0.0
8-Foot Recessed Double Contact High Output
All
≤4,500 K
>4,500 K and ≤7,000 K
92.0
88.0
0.0
0.0
4-Foot Miniature Bipin Standard Output
≥25 W
≤4,500 K
>4,500 K and ≤7,000 K
95.0
89.3
10.5
10.2
4-Foot Miniature Bipin High Output
≥44 W
≤4,500 K
>4,500 K and ≤7,000 K
82.7
76.9
8.8
6.8
* A “lumen” is a measurement of the radiometric energy emission from a light source weighted by the response function of a human eye, called the photopic spectral luminous efficiency function, V(λ). Test procedures for measuring lumens are also specified at 10 CFR part 430, subpart B, appendix R.
A. Benefits and Costs to Consumers
Table I.2 presents DOE's evaluation of the economic impacts of these standards on consumers of GSFLs, as measured by the average life-cycle cost (LCC) savings and the median payback period (PBP). The weighted-average LCC savings are positive for all product classes with amended standards.
Table I.2—Impacts of Energy Conservation Standards on Consumers of General Service Fluorescent Lamps
Product class
Weighted-average LCC savings
2013$
Weighted-average mean payback
period *
years
4-foot medium bipin ≤4,500 K
5.98
3.1
4-foot T5 miniature bipin standard output ≤4,500 K
5.68
4.0
4-foot T5 miniature bipin high output ≤4,500 K
4.74
2.8
8-foot single pin slimline ≤4,500 K
**0.00
**0.0
8-foot recessed double contact HO ≤4,500 K
**0.00
**0.0
* Does not include weighting for “NER” Scenarios. “NER” indicates standard levels that do not reduce operating costs, which prevents the consumer from recovering the increased purchase cost.
** Standards were not amended.
B. Impact on Manufacturers
The industry net present value (INPV) is the sum of the discounted cash flows to the industry from the base year through the end of the analysis period (2015 to 2047). Using a real discount rate of 9.2 percent, DOE estimates that the INPV for manufacturers of GSFLs is $1,551.6 million in 2013$. Under these standards, DOE expects that manufacturers may lose up to 21.3 percent of their INPV, which is approximately $330.0 million. Additionally, based on DOE's interviews with the manufacturers of GSFLs, DOE does not expect any plant closings or significant loss of employment.
C. National Benefits
3
3
All monetary values in this section are expressed in 2013 dollars and are discounted to 2014.
DOE's analyses indicate that these standards would save a significant amount of energy. The energy savings over the entire lifetime of GSFLs installed during the 30-year period that begins in the year of compliance with amended standards (2018-2047), in comparison to the base case without amended standards, amount to 2.5 quadrillion Btu (quads)
4
for GSFLs. This represents a savings of 7.1 percent relative to the energy use of this product in the base case without amended standards. No savings are realized for IRLs, as DOE is not amending the standards for IRLs.
4
A quad is equal to 10
15
British thermal units (Btu).
The cumulative net present value (NPV) of total consumer costs and savings of these standards for GSFLs ranges from $2.0 billion (at a 7-percent discount rate) to $5.5 billion (at a 3-percent discount rate). This NPV expresses the estimated total value of future operating-cost savings minus the estimated increased product costs for products purchased in 2018-2047.
In addition, these standards for GSFLs would have significant environmental benefits. The energy savings from the 30-year product purchase period with these standards, relative to the base case without amended standards, would result in cumulative greenhouse gas emission reductions of approximately 160 million metric tons (Mt)
5
of carbon dioxide (CO
2
), 650 thousand tons of methane, 140 thousand tons of sulfur dioxide (SO
2
), 230 thousand tons of nitrogen oxides (NO
X
), 2.0 thousand tons of nitrous oxide (N
2
O), and 0.43 tons of mercury (Hg).
6
The cumulative reduction in CO
2
emissions through 2030 amounts to 90 Mt, which is
equivalent to the emissions associated with annual electricity use of approximately 12 million homes.
5
A metric ton is equivalent to 1.1 short tons. Results for NO
X
and Hg are presented in short tons.
6
DOE calculated emissions reductions relative to the Annual Energy Outlook (AEO) 2014 Reference case, which generally represents current legislation and environmental regulations for which implementing regulations were available as of October 31, 2013.
The value of the CO
2
reductions is calculated using a range of values per metric ton of CO
2
(otherwise known as the Social Cost of Carbon, or SCC) developed by a recent Federal interagency process.
7
The derivation of the SCC values is discussed in section VI.M.1. Using discount rates appropriate for each set of SCC values, DOE estimates that the net present monetary value of the CO
2
emissions reductions for GSFLs is between $1.36 billion and $17.6 billion, with a value of $5.72 billion using the central SCC case represented by $40.5/t in 2015.
8
DOE also estimates that the net present monetary value of the NO
X
emissions reductions is $400 million at a 3-percent discount rate, and $240 million at a 7-percent discount rate.
9
7
Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866.
Interagency Working Group on Social Cost of Carbon, United States Government. May 2013; revised November 2013.
http://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbon-for-regulator-impact-analysis.pdf
.
8
The values only include CO
2
emissions, not CO
2
equivalent emissions; other gases with global warming potential are not included.
9
DOE is currently investigating valuation of avoided Hg and SO
2
emissions for future rule makings.
Table I.3 summarizes the national economic costs and benefits expected to result from these standards for GSFLs.
Table I.3—Summary of National Economic Benefits and Costs of Amended Energy Conservation Standards for General Service Fluorescent Lamps *
Category
Present value
Billion 2013$
Discount rate
(%)
Benefits
Operating Cost Savings
11.2
18.9
7
3
CO
2
Reduction Monetized Value ($12.0/t case) **
1.3
5
CO
2
Reduction Monetized Value ($40.5/t case) **
5.72
3
CO
2
Reduction Monetized Value ($62.4/t case) **
8.92
2.5
CO
2
Reduction Monetized Value ($119/t case) **
17.6
3
NO
X
Reduction Monetized Value (at $2,684/ton)
0.24
0.40
7
3
Total Benefits †
17.1
25.1
7
3
Costs
Incremental Installed Costs ‡
9.17
13.5
7
3
Including Emissions Reduction Monetized Value †
7.96
11.6
7
3
* This table presents the costs and benefits associated with GSFLs shipped in 2018-2047. These results include impacts on consumers that accrue after 2047 from the products purchased in 2018-2047. The results account for the incremental variable and fixed costs incurred by manufacturers due to the standard, some of which may be incurred in preparation for the rule.
** The CO
2
values represent global monetized values of the SCC, in 2013$, in 2015 under several scenarios of the updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 3%, and 2.5% discount rates, respectively. The fourth case represents the 95th percentile of the SCC distribution calculated using a 3% discount rate. The SCC time series incorporate an escalation factor.
† Total Benefits for both the 3% and 7% cases are derived using the series corresponding to average SCC with 3-percent discount rate ($40.5/t case).
The benefits and costs of these standards, for products sold in 2018-2047, can also be expressed in terms of annualized values. The annualized monetary values are the sum of (1) the annualized national economic value of the benefits from operating the product that meets the amended standard (consisting primarily of operating cost savings from using less energy, minus increases in product purchase prices and installation costs), which is another way of representing consumer NPV, and (2) the annualized monetary value of the benefits of emission reductions, including CO
2
emission reductions.
10
10
To convert the time-series of costs and benefits into annualized values, DOE calculated a present value in 2014, the year used for discounting the NPV of total consumer costs and savings. For the benefits, DOE calculated a present value associated with each year's shipments in the year in which the shipments occur (
e.g.,
2020 or 2030), and then discounted the present value from each year to 2014. The calculation uses discount rates of 3 and 7 percent for all costs and benefits except for the value of CO
2
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.
Although adding the value of consumer savings to the values of emission reductions provides a valuable perspective, two issues should be considered. First, the national operating cost savings are domestic U.S. consumer monetary savings that occur as a result of market transactions, whereas the value of CO
2
reductions is based on a global value. Second, the assessments of operating cost savings and CO
2
savings are performed with different methods that use different time frames for analysis. The national operating cost savings is measured for the lifetime of GSFLs shipped in 2018-2047. The SCC values, on the other hand, reflect the present value of all future climate-related impacts resulting from the emission of one metric ton of carbon dioxide in each year. These impacts continue well beyond 2100.
Estimates of annualized benefits and costs of these standards for GSFLs are shown in Table I.4. The results under the primary estimate are as follows. Using a 7-percent discount rate for benefits and costs other than CO
2
reduction, for which DOE used a 3-percent discount rate along with the SCC series that has a value of $40.5/t in 2015, the cost of the standards in this rule is $841 million per year in increased equipment costs, while the
benefits are $1,030 million per year in reduced equipment operating costs, $310 million in CO
2
reductions, and $22.4 million in reduced NO
X
emissions. In this case, the net benefit amounts to $516 million per year. Using a 3-percent discount rate for all benefits and costs and the SCC series that has a value of $40.5/t in 2015, the cost of the standards in this rule is $724 million per year in increased equipment costs, while the benefits are $1,020 million per year in reduced operating costs, $310 million in CO
2
reductions, and $21.6 million in reduced NO
X
emissions. In this case, the net benefit amounts to $627 million per year.
11
11
The annualized consumer operating cost savings, NO
X
reduction monetized value, and consumer incremental product costs are higher with a 7-percent discount rate than with a 3-percent discount rate. This is in contrast to the present values in Table I.3. Under certain conditions, different present values may lead to similar annualized values when calculated with different discount rates. In this case, the combined effects of (a) projecting to 2018 the present values that DOE calculated in 2014, and (b) annualizing the projected values with 3 percent and 7 percent discount rates over the 30-year analysis period, lead to similar annualized values. For consumer incremental product costs, the effect is more pronounced because the time series covers only 30 years, instead of the longer period covered for operating cost savings and NO
X
reduction monetized value.
Table I.4—Annualized Benefits and Costs of Amended Energy Conservation Standards for General Service Fluorescent Lamps *
Discount rate
million 2013$/year
Primary estimate
LowNet benefits estimate
HighNet benefits estimate
Benefits
Consumer Operating Cost Savings
7%
3%
1,030
1,020
1,010
1,000
1,050
1,050
CO
2
Reduction Monetized Value ($12.0/t case) **
5%
97.5
97.1
97.5
CO
2
Reduction Monetized Value ($40.5/t case) **
3%
310
308
310
CO
2
Reduction Monetized Value ($62.4/t case) **
2.5%
448
446
448
CO
2
Reduction Monetized Value ($119/t case) **
3%
950
946
950
NO
X
Reduction Monetized Value (at $2,684/ton) **
7%
3%
22.4
21.6
22.3
21.5
22.4
21.6
Total Benefits †
7% plus CO
2
range
1,150 to 2,000
1,130 to 1,980
1,170 to 2,030
7%
1,360
1,340
1,390
3% plus CO
2
range
1,140 to 2,000
1,120 to 1,970
1,170 to 2,030
3%
1,360
1,330
1,390
Costs
Consumer Incremental Product Costs
7%
3%
841
724
882
763
841
724
Net Benefits
Total †
7% plus CO
2
range
300 to 1,160
241 to 1,090
328 to 1,180
7%
516
452
540
3% plus CO
2
range
415 to 1,270
350 to 1,200
443 to 1,300
3%
627
561
655
* This table presents the annualized costs and benefits associated with GSFLs shipped in 2018−2047. These results include benefits to consumers that accrue after 2047 from the products purchased in 2018−2047. The results account for the incremental variable and fixed costs incurred by manufacturers due to the standard, some of which may be incurred in preparation for the rule. The Primary Benefits Estimate assumes the Reference case energy prices from
AEO 2014
and decreasing incremental product cost, due to price learning. The Low Benefits Estimate uses the Low Economic Growth energy prices from
AEO 2014
and constant real product prices. The High Benefits Estimate assumes the Low Economic Growth energy price estimates from
AEO 2014
and the same decreasing incremental product costs as in the Primary Benefits Estimate.
** The CO
2
values represent global monetized values of the SCC, in 2013$, in 2015 under several scenarios of the updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 3%, and 2.5% discount rates, respectively. The fourth case represents the 95th percentile of the SCC distribution calculated using a 3% discount rate. The SCC time series used by DOE incorporate an escalation factor. The value for NO
X
is the average of the low and high values used in DOE's analysis.
† Total Benefits for both the 3% and 7% cases are derived using the series corresponding to the average SCC with 3-percent discount rate ($40.5/t case). In the rows labeled “7% plus CO
2
range” and “3% plus CO
2
range,” the operating cost and NO
X
benefits are calculated using the labeled discount rate, and those values are added to the full range of CO
2
values.
D. Conclusion
Based on the analyses culminating in this final rule, DOE found that for GSFLs the benefits to the nation of the standards (energy savings, consumer LCC savings, positive NPV of consumer benefit, and emission reductions) outweigh the burdens (loss of INPV and LCC increases for some users of these products). DOE has concluded that the standards in this rule represent the maximum improvement in energy efficiency that is technologically feasible and economically justified, and would result in significant conservation of energy.
II. Introduction
The following section briefly discusses the statutory authority underlying this rule, as well as some of the relevant historical background related to the establishment of existing standards for GSFLs and IRLs.
A. Authority
Title III, Part B of the Energy Policy and Conservation Act of 1975 (EPCA or the Act), Public Law 94-163 (42 U.S.C. 6291-6309, as codified) established the Energy Conservation Program for Consumer Products Other Than Automobiles, a program covering most major household appliances (collectively referred to as “covered products”), which includes the types of GSFLs and IRLs that are the subject of this rulemaking. (42 U.S.C. 6292(a)(14))
EPCA prescribed energy conservation standards for these products (42 U.S.C. 6295(i)(1)), and directed DOE to conduct further rulemakings to determine whether to amend these standards. (42 U.S.C. 6295(i)(3)-(5)) On July 14, 2009, DOE published a final rule in the
Federal Register
, which completed the first rulemaking cycle to amend energy conservation standards for GSFLs and IRLs (hereafter the “2009 Lamps Rule”). 74 FR 34080. That rule adopted standards for additional GSFLs, amended the definition of “colored fluorescent lamp” and “rated wattage,” and also adopted test procedures applicable to the newly covered GSFLs. Information regarding the 2009 Lamps Rule can be found on regulations.gov, docket number EERE-2006-STD-0131 at
www.regulations.gov/#!docketDetail;D=EERE-2006-STD-0131
.
This rulemaking encompasses DOE's second cycle of review to determine whether the standards in effect for GSFLs and IRLs should be amended, including whether the standards should be applicable to additional GSFLs. (DOE notes that under 42 U.S.C. 6295(m), the agency must periodically review its already established energy conservation standards for a covered product. Under this requirement, the next review that DOE would need to conduct must occur no later than six years from the issuance of a final rule establishing or amending a standard for a covered product.)
Pursuant to EPCA, DOE's energy conservation program for covered products consists essentially of four parts: (1) Testing; (2) labeling; (3) the establishment of federal energy conservation standards; and (4) certification and enforcement procedures. The Federal Trade Commission (FTC) is primarily responsible for labeling, and DOE implements the remainder of the program. Subject to certain criteria and conditions, DOE is required to develop test procedures to measure the energy efficiency, energy use, or estimated annual operating cost of each covered product. (42 U.S.C. 6293) Manufacturers of covered products must use the prescribed DOE test procedure as the basis for certifying to DOE that their products comply with the applicable energy conservation standards adopted under EPCA and when making representations to the public regarding the energy use or efficiency of those products. (42 U.S.C. 6293(c) and 6295(s)) Similarly, DOE must use these test procedures to determine whether the products comply with standards adopted pursuant to EPCA.
Id.
The DOE test procedures for GSFLs and IRLs currently appear at title 10 of the Code of Federal Regulations (CFR) part 430, subpart B, appendix R.
DOE must follow specific statutory criteria for prescribing amended standards for covered products. As indicated above, any amended standard for a covered product must be designed to achieve the maximum improvement in energy efficiency that is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, DOE may not adopt any standard that would not result in the significant conservation of energy. (42 U.S.C. 6295(o)(3)) Moreover, DOE may not prescribe a standard: (1) For certain products, including GSFLs and IRLs, if no test procedure has been established for the product, or (2) if DOE determines by rule that the amended standard is not technologically feasible or economically justified. (42 U.S.C. 6295(o)(3)(A)-(B)) In deciding whether an amended standard is economically justified, DOE must determine whether the benefits of the standard exceed its burdens. (42 U.S.C. 6295(o)(2)(B)(i)) DOE must make this determination after receiving comments on the proposed standard, and by considering, to the greatest extent practicable, the following seven statutory factors:
1. The economic impact of the standard on manufacturers and consumers of the products subject to the standard;
2. The savings in operating costs throughout the estimated average life of the covered products in the type (or class) compared to any increase in the price, initial charges, or maintenance expenses for the covered products that are likely to result from the imposition of the standard;
3. The total projected amount of energy, or as applicable, water, savings likely to result directly from the imposition of the standard;
4. Any lessening of the utility or the performance of the covered products likely to result from the imposition of the standard;
5. The impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to result from the imposition of the standard;
6. The need for national energy and water conservation; and
7. Other factors the Secretary of Energy (Secretary) considers relevant. (42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))
EPCA, as codified, also contains what is known as an “anti-backsliding” provision, which prevents the Secretary from prescribing any amended standard that either increases the maximum allowable energy use or decreases the minimum required energy efficiency of a covered product. (42 U.S.C. 6295(o)(1)) Also, the Secretary may not prescribe an amended or new standard if interested persons have established by a preponderance of the evidence that the standard is likely to result in the unavailability in the United States of any covered product type (or class) of performance characteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as those generally available in the United States. (42 U.S.C. 6295(o)(4))
Further, EPCA, as codified, establishes a rebuttable presumption that a standard is economically justified if the Secretary finds that the additional cost to the consumer of purchasing a product complying with an energy conservation standard level will be less than three times the value of the energy savings during the first year that the consumer will receive as a result of the standard, as calculated under the applicable test procedure. See 42 U.S.C. 6295(o)(2)(B)(iii).
Additionally, 42 U.S.C. 6295(q)(1) specifies requirements when promulgating a standard for a type or class of covered product that has two or more subcategories. DOE must specify a different standard level than that which applies generally to such type or class of products for any group of covered products that have the same function or intended use if DOE determines that products within such group (A) consume a different kind of energy from that consumed by other covered products within such type (or class); or (B) have a capacity or other performance-related feature which other products within such type (or class) do not have and such feature justifies a higher or lower standard. (42 U.S.C. 6295(q)(1)) In determining whether a performance-related feature justifies a different standard for a group of products, DOE must consider such factors as the utility to the consumer of such a feature and other factors DOE deems appropriate.
Id.
Any rule prescribing such a standard must include an explanation of the basis on which such higher or lower level was established. (42 U.S.C. 6295(q)(2))
Federal energy conservation requirements generally supersede state laws or regulations concerning energy conservation testing, labeling, and standards. (42 U.S.C. 6297(a)-(c)) DOE may, however, grant waivers of federal preemption for particular state laws or regulations, in accordance with the procedures and other provisions set forth under 42 U.S.C. 6297(d)).
Finally, pursuant to the amendments contained in section 310(3) of the Energy Independence and Security Act
of 2007 (EISA 2007), any final rule for new or amended energy conservation standards promulgated after July 1, 2010, are required to address standby mode and off mode energy use. (42 U.S.C. 6295(gg)(3)) Specifically, when DOE adopts a standard for a covered product after that date, it must, if justified by the criteria for adoption of standards under EPCA (42 U.S.C. 6295(o)), incorporate standby mode and off mode energy use into the standard, or, if that is not feasible, adopt a separate standard for such energy use for that product. (42 U.S.C. 6295(gg)(3)(A)-(B)) DOE has determined that standby mode and off mode do not apply to GSFLs and IRLs and that their energy use is accounted for entirely in the active mode. Therefore, DOE is not addressing standby and off modes, and will only address active mode in this rulemaking.
DOE has also reviewed this regulation pursuant to Executive Order (E.O.) 13563, issued on January 18, 2011 (76 FR 3281, Jan. 21, 2011). E.O. 13563 is supplemental to and explicitly reaffirms the principles, structures, and definitions governing regulatory review established in Executive Order 12866, “Regulatory Planning and Review,” 58 FR 51735 (Oct. 4, 1993). To the extent permitted by law, agencies are required by Executive Order 13563 to: (1) Propose or adopt a regulation only upon a reasoned determination that its benefits justify its costs (recognizing that some benefits and costs are difficult to quantify); (2) tailor regulations to impose the least burden on society, consistent with obtaining regulatory objectives, taking into account, among other things, and to the extent practicable, the costs of cumulative regulations; (3) select, in choosing among alternative regulatory approaches, those approaches that maximize net benefits (including potential economic, environmental, public health and safety, and other advantages; distributive impacts; and equity); (4) to the extent feasible, specify performance objectives, rather than specifying the behavior or manner of compliance that regulated entities must adopt; and (5) identify and assess available alternatives to direct regulation, including providing economic incentives to encourage the desired behavior, such as user fees or marketable permits, or providing information upon which choices can be made by the public.
DOE emphasizes as well that Executive Order 13563 requires agencies to use the best available techniques to quantify anticipated present and future benefits and costs as accurately as possible. In its guidance, the Office of Information and Regulatory Affairs (OIRA) has emphasized that such techniques may include identifying changing future compliance costs that might result from technological innovation or anticipated behavioral changes. For the reasons stated in the preamble, DOE believes that this rule is consistent with these principles, including the requirement that, to the extent permitted by law, benefits justify costs and that net benefits are maximized. Consistent with E.O. 13563, and the range of impacts analyzed in this rulemaking, the energy-efficiency standard adopted herein by DOE achieves maximum net benefits. For further discussion of how this rulemaking achieves maximum net benefits, see section VII.
B. Background
1. Current Standards
In the 2009 Lamps Rule, DOE prescribed the current energy conservation standards for GSFLs and IRLs manufactured on or after July 14, 2012 (hereafter the “July 2012 standards”). 74 FR 34080. The current standards are set forth in Table II.1 and Table II.2.
Table II.1—July 2012 Standards for General Service Fluorescent Lamps
Lamp type
Correlated color temperature
Minimum
average lamp
efficacy
lm/W
Four-Foot Medium Bipin
≤4,500K
>4,500 K and ≤7,000 K
89
88
Two-Foot U-Shaped
≤4,500 K
>4,500 K and ≤7,000 K
84
81
Eight-Foot Slimline
≤4,500 K
>4,500 K and ≤7,000 K
97
93
Eight-Foot High Output
≤4,500 K
>4,500 K and ≤7,000 K
92
88
Four-Foot Miniature Bipin Standard Output
≤4,500 K
>4,500 K and ≤7,000 K
86
81
Four-Foot Miniature Bipin High Output
≤4,500 K
>4,500 K and ≤7,000 K
76
72
Table II.2—July 2012 Standards for Incandescent Reflector Lamps
Rated lamp wattage
Lamp spectrum
Lamp diameter
inches
Rated voltage
Minimum
average lamp
efficacy
lm/W
40-205
Standard Spectrum
>2.5
≥125 V
<125 V
6.8*P
0.27
5.9*P
0.27
≤2.5
≥125 V
<125 V
5.7*P
0.27
5.0*P
0.27
40-205
Modified Spectrum
>2.5
12
≥125 V
<125 V
5.8*P
0.27
5.0*P
0.27
≤2.5
≥125 V
<125 V
4.9*P
0.27
4.2*P
0.27
Note 1: P is equal to the rated lamp wattage, in watts.
Note 2: Standard Spectrum means any incandescent reflector lamp that does not meet the definition of modified spectrum in 430.2.
2. Corrections to Codified Standards
In
this final rule, DOE is correcting errors in the codified standards for GSFLs and IRLs. In particular, DOE is correcting the typographical errors in the sections of the CFR that lay out the GSFL standards specified in EPCA and the IRL standards established by the 2009 Lamps Rule. Specifically, for the GSFL standards codified at 10 CFR 430.32(n)(1), the “less than or equal to 35 W” associated with the 8-foot single pin (SP) slimline lamp type should instead be associated with the 2-foot U-shaped lamp type. For 8-foot SP slimline product class with a minimum color rendering index (CRI) of 45 and a minimum average lamp efficacy of 80.0 lumens per watt (lm/W), the rated wattage should be less than or equal to 65 W, not greater than 65 W. The revised table will read as follows:
12
Shown correctly in this table; erroneously written as “≤125V” in the CFR.
Table II.3—GSFL Standards Prescribed by EPAct
Lamp type
Nominal lamp wattage
Minimum CRI
Minimum average lamp
efficacy
lm/W
Effective date
4-foot medium bipin
>35 W
≤35 W
69
45
75.0
75.0
Nov. 1, 1995.
Nov. 1, 1995.
2-foot U-shaped
>35 W
≤35 W
69
45
68.0
64.0
Nov. 1, 1995.
Nov. 1, 1995.
8-foot slimline
>65 W
≤65 W
69
45
80.0
80.0
May 1, 1994.
May 1, 1994.
8-foot high output
>100 W
≤100 W
69
45
80.0
80.0
May 1, 1994.
May 1, 1994.
For the IRL standards adopted by the 2009 Lamps Rule that are codified in 10 CFR 430.32(n)(5), the minimum lamp efficacy of 5.8P
0.27
is for lamps with a rated wattage of 40-205 W, modified spectrum, diameter greater than 2.5 inches, and rated voltage of “greater than or equal to 125 V” rather than “less than or equal to 125 V.” The revised table will read as follows:
Table II.4—IRL Standards Adopted by the 2009 Lamps Rule
Rated lamp wattage
Lamp spectrum
Lamp diameter
inches
Rated voltage
Minimum average lamp efficacy
lm/W
40-205
Standard Spectrum
>2.5
≥125 V
<125 V
6.8*P
0.27
5.9*P
0.27
≤2.5
≥125 V
<125 V
5.7*P
0.27
5.0*P
0.27
40-205
Modified Spectrum
>2.5
≥125 V
<125 V
5.8*P
0.27
5.0*P
0.27
≤2.5
≥125 V
<125 V
4.9*P
0.27
4.2*P
0.27
3. History of Standards Rulemaking for General Service Fluorescent Lamps and Incandescent Reflector Lamps
As mentioned in the previous section, EPCA, as amended, established energy conservation standards for certain classes of GSFLs and IRLs, and required DOE to conduct two rulemaking cycles to determine whether these standards should be amended. (42 U.S.C. 6295(i)(1) and (3)-(4)) EPCA also authorized DOE to adopt standards for additional GSFLs if such standards were warranted. (42 U.S.C. 6295(i)(5))
DOE completed the first cycle of amendments by publishing a final rule in the
Federal Register
in July 2009. 74 FR 34080 (July 14, 2009). The 2009 Lamps Rule amended existing GSFL and IRL energy conservation standards and adopted standards for additional GSFLs. That rule also amended the definition of “colored fluorescent lamp” and “rated wattage,” and adopted test procedures applicable to the newly covered GSFLs.
The Energy Policy Act of 1992 (EPAct 1992, Pub. L. 102-486) amendments to EPCA added as covered products IRLs with wattages of 40 watts (W) or higher. In defining the term “incandescent reflector lamp,” EPAct 1992 excluded lamps with elliptical reflector (ER) and bulged reflector (BR) bulb shapes, and with diameters of 2.75 inches or less. Therefore, such IRLs were neither included as covered products nor subject to EPCA's standards for IRLs.
Section 322(a)(1) of the EISA 2007 subsequently amended EPCA to expand the Act's definition of “incandescent reflector lamp” to include lamps with a diameter between 2.25 and 2.75 inches, as well as lamps with ER, BR, bulged parabolic aluminized reflector (BPAR), or similar bulb shapes. (42 U.S.C. 6291(30)(C)(ii) and (F)) Section 322(b) of EISA 2007, in amending EPCA to set forth revised standards for IRLs in new section 325(i)(1)(C), exempted from these standards the following categories of IRLs: (1) Lamps rated 50 W or less that are ER30, BR30, BR40, or ER40; (2) lamps rated 65 W that are BR30, BR40, or ER40 lamps; and (3) R20 IRLs rated 45 W or less. (42 U.S.C. 6295(i)(C)) DOE refers to these three categories of lamps collectively as certain R, ER, and BR IRLs.
DOE has concluded, for the reasons that follow, that it has the authority under EPCA to adopt standards for these
R, ER, and BR IRLs, and that these lamps are covered by the directive in 42 U.S.C. 6295(i)(3) to amend EPCA's standards for IRLs. First, by amending the definition of “incandescent reflector lamp” (42 U.S.C. 6291(30)(C)(ii) and (F)), EISA 2007 effectively brought these R, ER, and BR IRLs into the federal energy conservation standards program as covered products, thereby subjecting them to DOE's regulatory authority. Second, although 42 U.S.C 6295(i)(1)(C) exempts these R, ER, and BR IRLs from the standards specified in 42 U.S.C. 6295(i)(1)(B), EPCA directs that DOE amend the standards laid out in 42 U.S.C 6295(i)(1), which includes subparagraph (C). As a result, the statutory text exempted these bulbs only from the standards specified in 42 U.S.C. 6295(i)(1), not from future regulation. Consequently, DOE began considering energy conservation standards for these R, ER, and BR IRLs. DOE initiated a new rulemaking for these products by completing a framework document and publishing a notice announcing its availability. 75 FR 23191 (May 3, 2010). DOE held a public meeting on May 26, 2010 to seek input from interested parties on its methodologies, assumptions, and data sources.
To initiate the second rulemaking cycle to consider amended energy conservation standards for GSFLs and IRLs (other than the certain R, ER, and BR IRLs discussed in the preceding paragraphs), on September 14, 2011, DOE published a notice announcing the availability of the framework document, “Energy Conservation Standards Rulemaking Framework Document for General Service Fluorescent Lamps and Incandescent Reflector Lamps,” and a public meeting to discuss the proposed analytical framework for the rulemaking. 76 FR 56678. DOE also posted the framework document on its Web site, in which DOE described the procedural and analytical approaches DOE anticipated using to evaluate the establishment of energy conservation standards for GSFLs and IRLs.
DOE held the public meeting for the framework document on October 4, 2011
13
to present the framework document, describe the analyses it planned to conduct during the rulemaking, seek comments from stakeholders on these subjects, and inform stakeholders about and facilitate their involvement in the rulemaking. At the public meeting, and during the comment period, DOE received many comments that both addressed issues raised in the framework document and identified additional issues relevant to this rulemaking.
13
DOE published a notice announcing the availability of the framework document, “Energy Conservation Standards Rulemaking Framework Document for General Service Fluorescent Lamps and Incandescent Reflector Lamps,” and a public meeting in the
Federal Register
on September 14, 2011. 76 FR 56678. The framework document and public meeting information are available at regulations.gov under docket number EERE-2011-BT-STD-0006.
DOE issued the preliminary analysis for this rulemaking on February 20, 2013 and published it in the
Federal Register
on February 28, 2013. 78 FR 13563 (February 28, 2013). DOE posted the preliminary analysis, as well as the complete preliminary technical support document (TSD), on its Web site. The preliminary TSD included the results of the following preliminary analyses: (1) Market and technology assessment; (2) screening analysis; (3) engineering analysis; (4) energy-use characterization; (5) product price determinations; (6) LCC and PBP analyses; (7) shipments analysis; and (8) national impact analysis (NIA). In the preliminary analysis, DOE described and sought comment on the analytical framework, models, and tools (
e.g.,
LCC and national energy savings [NES] spreadsheets) DOE used to analyze the impacts of energy conservation standards for GSFLs and IRLs. DOE held a public meeting on April 9, 2013, to present the methodologies and results for the preliminary analyses. Manufacturers, trade associations, and environmental advocates attended the meeting. The participants discussed multiple issues, including the methodology and results of the market and technology assessment, screening analysis, engineering analysis, product price determination, energy use, LCC analysis, shipments analysis, and NIA.
In April 2014, DOE published a notice of proposed rulemaking (NOPR) in the
Federal Register
proposing new and amended energy conservation standards for GSFLs and IRLs. 79 FR 24068 (April 29, 2014). In conjunction with the NOPR, DOE also published on its Web site the complete TSD for the proposed rule.
14
The NOPR TSD included updated results of the analyses conducted in the preliminary analysis stage as well as the following additional analyses: 1) LCC subgroup analysis, 2) manufacturer impact analysis (MIA), 3) employment impact analysis, 4) utility impact analysis, 5) emissions analysis, 6) monetization of emission reduction benefits, and 7) regulatory impact analysis (RIA). The NOPR TSD was accompanied by the LCC spreadsheet, the NIA spreadsheet, and the MIA spreadsheet—all of which are available on regulations.gov.
15
In the NOPR DOE invited comment on these analyses and related issues. DOE held a NOPR public meeting on May 1, 2014, to hear oral comments on and solicit information relevant to the proposed rule (hereafter the NOPR public meeting). DOE considered the comments received in response to the NOPR after its publication and at the NOPR public meeting when developing this final rule, and responds to these comments in this rule.
14
The NOPR TSD is available at regulations.gov under docket number EERE-2011-BT-STD-0006.
15
Supporting spreadsheets for the NOPR TSD are available at regulations.gov under docket number EERE-2011-BT-STD-0006.
4. Test Procedure
EPCA sets forth generally applicable criteria and procedures for DOE's adoption and amendment of test procedures. (42 U.S.C. 6293) Manufacturers of covered products must use these test procedures to certify to DOE that their product complies with EPCA energy conservation standards and to quantify the efficiency of their product. Similarly, DOE uses the test procedure to determine compliance with energy conservation standards. DOE's test procedures for fluorescent and incandescent reflector lamps are set forth in title 10 of the CFR, part 430, subpart B, appendix R. These test procedures provide instructions for measuring GSFL and IRL performance, largely by incorporating industry standards. The test procedures were updated in a final rule published in July 2009. 74 FR 31829 (July 6, 2009). The rule updated citations to industry standards and made several other modifications. DOE further amended the test procedures to update references to industry standards for GSFLs in a final rule published in January 2012. 77 FR 4203 (January 27, 2012).
a. Standby and Off Mode Energy Consumption
EPCA requires energy conservation standards adopted for a covered product after July 1, 2010 to address standby mode and off mode energy use. (42 U.S.C. 6295(gg)(3)) EPCA defines active mode as the condition in which an energy-using piece of equipment is connected to a main power source, has been activated, and provides one or more main functions. (42 U.S.C. 6295)(gg)(1)(A)) Standby mode is defined as the condition in which an energy-using piece of equipment is connected to a main power source and offers one or more of the following user-oriented or protective functions: Facilitating the activation or
deactivation of other functions (including active mode) by remote switch (including remote control), internal sensor, or timer; or providing continuous functions, including information or status displays (including clocks) or sensor-based functions.
Id.
Off mode is defined as the condition in which an energy-using piece of equipment is connected to a main power source, and is not providing any standby or active mode function.
Id.
To satisfy the EPCA definitions of standby mode and off mode (42 U.S.C. 6295(gg)(1)), the lamp must not be providing any active mode function (
i.e.,
emitting light). However, to reach such a state, the lamp must be entirely disconnected from the main power source (
i.e.,
switched off), thereby not satisfying the requirements of operating in off mode or standby mode. Further, neither GSFLs nor IRLs covered under this rulemaking provide any secondary user-oriented or protection functions or continuous standby mode functions. Thus, these lamps do not satisfy the EPCA definition of standby mode. While EPCA allows DOE to amend the mode definitions (42 U.S.C. 6295(gg)(1)(B)), DOE believes that the energy use of GSFLs and IRLs is accounted for entirely in the active mode. Therefore, DOE is not addressing lamp operation in the standby and off modes in this rulemaking.
III. General Discussion
A. Product Classes and Scope of Coverage
When evaluating and establishing energy conservation standards, DOE divides covered products into product classes by the type of energy used or by capacity or other performance-related features that justifies a different standard. In making a determination whether a performance-related feature justifies a different standard, DOE must consider such factors as the utility to the consumer of the feature and other factors DOE determines are appropriate. (42 U.S.C. 6295(q)) For further details on the scope of coverage for this rulemaking, see section V. For further details on product classes, see section VI.C and chapter 3 of the final rule TSD.
B. Technological Feasibility
1. General
In each energy conservation standards rulemaking, DOE conducts a screening analysis based on information gathered on all current technology options and prototype designs that could improve the efficiency of the products or equipment that are the subject of the rulemaking. As the first step in such an analysis, DOE develops a list of technology options for consideration in consultation with manufacturers, design engineers, and other interested parties. DOE then determines which of those means for improving efficiency are technologically feasible. DOE considers technologies incorporated in commercially available products or in working prototypes to be technologically feasible. 10 CFR part 430, subpart C, appendix A, section 4(a)(4)(i).
After DOE has determined that particular technology options are technologically feasible, it further evaluates each technology option in light of the following additional screening criteria: (1) Practicability to manufacture, install, and service; (2) adverse impacts on product utility or availability; and (3) adverse impacts on health or safety. 10 CFR part 430, subpart C, appendix A, section 4(a)(4)(ii)-(iv). Section VI.B of this notice discusses the results of the screening analysis for GSFLs and IRLs, particularly the designs DOE considered, those it screened out, and those that are the basis for the trial standard levels (TSLs) in this rulemaking. For further details on the screening analysis for this rulemaking, see chapter 4 of the final rule TSD.
2. Maximum Technologically Feasible Levels
When DOE proposes to adopt an amended standard for a type or class of covered product, it must determine the maximum improvement in energy efficiency or maximum reduction in energy use that is technologically feasible for such product. (42 U.S.C. 6295(p)(1)) Accordingly, in the engineering analysis, DOE determined the maximum technologically feasible (“max-tech”) improvements in energy efficacy for GSFLs and IRLs, using the design parameters for the most efficient products available on the market or in working prototypes. (See chapter 5 of the final rule TSD.) The max-tech levels that DOE determined for this rulemaking are described in section VI.D.2.f and VI.D.3.d, respectively for GSFLs and IRLs, of this final rule.
C. Energy Savings
1. Determination of Savings
For each TSL, DOE projected energy savings from the products that are the subject of this rulemaking purchased in the 30-year period that begins in the year of compliance with amended standards (2018-2047).
16
The savings are measured over the entire lifetime of products purchased in the 30-year analysis period.
17
DOE quantified the energy savings attributable to each TSL as the difference in energy consumption between each standards case and the base case. The base case represents a projection of energy consumption in the absence of amended mandatory efficiency standards and the standards case represents a projection of energy consumption if amended standards take effect. As described in section VI.I of this notice, the projections start from the current efficiency distribution on the market and consider various market forces, in addition to amended standards, that may affect future demand for more efficient products.
16
DOE also presents a sensitivity analysis that considers impacts for products shipped in a 9-year period.
17
In the past DOE presented energy savings results for only the 30-year period that begins in the year of compliance. In the calculation of economic impacts, however, DOE considered operating cost savings measured over the entire lifetime of products purchased in the 30-year period. DOE has chosen to modify its presentation of national energy savings to be consistent with the approach used for its national economic analysis.
DOE used its NIA spreadsheet model to estimate energy savings from amended standards for the products that are the subject of this rulemaking. The NIA spreadsheet model (described in section VI.J of this notice) calculates energy savings in site energy, which is the energy directly consumed by products at the locations where they are used. For electricity, DOE reports national energy savings in terms of the savings in the energy that is used to generate and transmit the site electricity. For electricity and natural gas and oil, DOE also calculates full-fuel-cycle (FFC) energy savings. As discussed in DOE's statement of policy and notice of policy amendment, the FFC metric includes the energy consumed in extracting, processing, and transporting primary fuels (
i.e.,
coal, natural gas, petroleum fuels), and thus presents a more complete picture of the impacts of energy-efficiency standards. 76 FR 51281 (August 18, 2011), as amended at 77 FR 49701 (August 17, 2012).
To calculate this quantity, DOE derives annual conversion factors from the model used to prepare the Energy Information Administration's (EIA) most recent Annual Energy Outlook (AEO). For FFC energy savings, DOE's approach is based on the calculation of an FFC multiplier for the electricity used by covered products or equipment. For more information, see section VI.L.
2. Significance of Savings
To adopt standards for a covered product, DOE must determine that such action would result in “significant” energy savings. 42 U.S.C. 6295(o)(3)(B). Although the term “significant” is not defined in the Act, the U.S. Court of Appeals, in
Natural Resources Defense Council
v.
Herrington,
768 F.2d 1355, 1373 (D.C. Cir. 1985), indicated that Congress intended “significant” energy savings in the context of EPCA to be savings that were not “genuinely trivial.” The energy savings for these adopted standards of 2.5 quads over a 30-year product purchase period (presented in section VII.B.3) are nontrivial, and, therefore, DOE considers them “significant” within the meaning of section 325 of EPCA.
D. Economic Justification
1. Specific Criteria
EPCA provides seven factors to be evaluated in determining whether a potential energy conservation standard is economically justified. (42 U.S.C. 6295(o)(2)(B)(i)) The following sections discuss how DOE has addressed each of those seven factors in this rulemaking.
a. Economic Impact on Manufacturers and Consumers
In determining the impacts of a potential amended standard on manufacturers, DOE conducts a MIA, as discussed in section VI.K. DOE first uses an annual cash-flow approach to determine the quantitative impacts. This step includes both a short-term assessment—based on the cost and capital requirements during the period between when a regulation is issued and when entities must comply with the regulation—and a long-term assessment over a 30-year period. The industry-wide impacts analyzed include INPV, which values the industry based on expected future cash flows; cash flows by year; changes in revenue and income; and other measures of impact, as appropriate. Second, DOE analyzes and reports the impacts on different types of manufacturers, including impacts on small manufacturers. Third, DOE considers the impact of standards on domestic manufacturer employment and manufacturing capacity, as well as the potential for standards to result in plant closures and loss of capital investment. Finally, DOE takes into account cumulative impacts of various DOE regulations and other regulatory requirements on manufacturers.
For individual consumers, measures of economic impact include the changes in LCC and payback period (PBP) associated with new or amended standards. These measures are discussed further in the following section. For consumers in the aggregate, DOE also calculates the national net present value of the economic impacts applicable to a particular rulemaking. DOE also evaluates the LCC impacts of potential standards on identifiable subgroups of consumers that may be affected disproportionately by a national standard.
b. Savings in Operating Costs Compared to Increase in Price
EPCA requires DOE to consider the savings in operating costs throughout the estimated average life of the covered product compared to any increase in the price of the covered product that are likely to result from the imposition of the standard. (42 U.S.C. 6295(o)(2)(B)(i)(II)) DOE conducts this comparison in its LCC and PBP analysis.
The LCC is the sum of the purchase price of a product (including its installation) and the operating expense (including energy, maintenance, and repair expenditures) discounted over the lifetime of the product. To account for uncertainty and variability in specific inputs, such as product lifetime and discount rate, DOE uses a distribution of values, with probabilities attached to each value. For its analysis, DOE assumes that consumers will purchase the covered products in the first year of compliance with amended standards.
The LCC savings and the PBP for the considered efficacy levels are calculated relative to the baseline. DOE's LCC and PBP analysis is discussed in further detail in section VI.G.
c. Energy Savings
Although significant conservation of energy is a separate statutory requirement for adopting an energy conservation standard, EPCA requires DOE, in determining the economic justification of a standard, to consider the total projected energy savings that are expected to result directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) As discussed in section VI.J, DOE uses the NIA spreadsheet to project national site energy savings.
d. Lessening of Utility or Performance of Products
In establishing classes of products, and in evaluating design options and the impact of potential standard levels, DOE evaluates standards that would not lessen the utility or performance of the considered products. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) Based on data available to DOE, the standards adopted in this rule would not reduce the utility or performance of the products under consideration in this rulemaking.
e. Impact of Any Lessening of Competition
EPCA directs DOE to consider the impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to result from a proposed standard. (42 U.S.C. 6295(o)(2)(B)(i)(V) It also directs the Attorney General to determine the impact, if any, of any lessening of competition likely to result from a standard and to transmit such determination to the Secretary within 60 days of the publication of a proposed rule, together with an analysis of the nature and extent of the impact. (42 U.S.C. 6295(o)(2)(B)(ii)) DOE transmitted a copy of its proposed rule to the Attorney General with a request that the Department of Justice (DOJ) provide its determination on this issue. DOJ's response, that the proposed energy conservation standards are unlikely to have a significant adverse impact on competition, is reprinted at the end of this notice.
f. Need for National Energy Conservation
In evaluating the need for national energy conservation, DOE expects that the energy savings from amended standards are likely to provide improvements to the security and reliability of the nation's energy system. Reductions in the demand for electricity also may result in reduced costs for maintaining the reliability of the nation's electricity system. DOE conducts a utility impact analysis to estimate how standards may affect the nation's needed power generation capacity.
The amended standards also are likely to result in environmental benefits in the form of reduced emissions of air pollutants and greenhouse gases primarily associated with fossil-fuel based energy production. DOE reports the emissions impacts from these standards, and from each TSL it considered, in section VII.B.6 of this notice. DOE also reports estimates of the economic value of emissions reductions resulting from the considered TSLs, as discussed in section VII.B.7.
g. Other Factors
EPCA allows the Secretary of Energy, in determining whether a standard is economically justified, to consider any other factors that the Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII))
2. Rebuttable Presumption
As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA creates a rebuttable presumption that an energy conservation standard is economically justified if the additional cost to the consumer of a product that meets the standard is less than three times the value of the first year's energy savings resulting from the standard, as calculated under the applicable DOE test procedure. DOE's LCC and PBP analyses generate values used to calculate the effect potential amended energy conservation standards would have on the payback period for consumers. These analyses include, but are not limited to, the 3-year payback period contemplated under the rebuttable-presumption test. In addition, DOE routinely conducts an economic analysis that considers the full range of impacts to consumers, manufacturers, the nation, and the environment, as required under 42 U.S.C. 6295(o)(2)(B)(i). The results of this analysis serve as the basis for DOE's evaluation of the economic justification for a potential standard level (thereby supporting or rebutting the results of any preliminary determination of economic justification). The rebuttable-presumption payback calculation is discussed in section VII.B.1.a of this final rule.
IV. Issues Affecting Rulemaking Schedule
DOE received several comments on the rulemaking schedule. Appliance Standards Awareness Project (ASAP) and the Energy Efficiency Organizations (EEOs) supported the rulemaking schedule as presented in the NOPR. However, ASAP noted that DOE missed the legally required legislative deadline and urged DOE not to push the rulemaking any later than planned. (ASAP, Public Meeting Transcript, No. 49 at p. 29;
18
EEOs, No. 55 at p. 2)
18
A notation in this form provides a reference for information that is in the docket of DOE's rulemaking to develop energy conservation standards for GSFLs and IRLs (Docket No. EERE-2011-BT-STD-0006), which is maintained at
www.regulations.gov.
This notation indicates that the statement preceding the reference is document number 49 in the docket for the GSFL and IRL energy conservation standards rulemaking, and appears at page 29 of that document.
Sofie E. Miller commented that the 2009 Lamps Rule required compliance on July 14, 2012 and for certain GSFL product classes, many manufacturers were granted a stay of enforcement, which is still in effect. Therefore, the full impact of the 2009 Lamps Rule on the lighting market is unknown. Further, Miller noted that manufacturers have expressed concern that the short period between the rulemakings will have a severe and negative impact on manufacturers, who may not be able to recover investments in new technologies or to develop products meeting even higher standards than those in the 2009 Lamps Rule. While DOE is statutorily required to make a determination about whether to update these standards, it may make the most sense for DOE to delay proposing new standards until the full effect of its previous standards is known, and DOE should initiate that process by conducting a retrospective review of the 2009 Lamps Rule. (Miller, No. 50 at p. 10)
DOE is conducting this rulemaking to satisfy the EPCA requirement for a second review of the GSFL and IRL standards that were finalized in the 2009 Lamps Rule and required compliance July 2012. DOE understands that Office of Hearing and Appeals (OHA) has granted 16 manufacturers 2-year waivers from standards for their 700 series T8 products that expire in 2014. Because standards from this rulemaking would become effective after these waivers granted to individual manfacturers have expired and the products granted waivers would be subject to standards, DOE has conducted its analysis assuming that the waivers will not be in place. Further, at the time of the analysis of the final rule, most of the waivers had expired and not been renewed.
Regarding this rulemaking assessing the full impact of the 2009 Lamps Rule, the analysis in this final rule was updated and finalized almost two years after the July 2012 standards required compliance, reflecting the most recent data available. DOE conducted a survey of product offerings for this final rule and identified a few new covered products since the NOPR analysis which were included in this final rule analysis. Therefore, DOE finds that the analysis in this final rule adequately assesses and captures the impacts of the July 2012 standards for these products and sees no reason to delay in adopting the appropriate standards resulting from it and requiring compliance three years after the publication of the final rule.
V. Issues Affecting Scope
A. Clarifications of General Service Fluorescent Lamp Definition
The scope of this rulemaking for GSFLs is defined by the terms “fluorescent lamp” and “general service fluorescent lamp.” 10 CFR 430.2 The definition of general service fluorescent lamp includes certain exemptions. DOE has received several questions on the application of these exemptions. Therefore, DOE evaluated each exemption and determined that the following exemption categories could be further clarified: “impact-resistant fluorescent lamps,” “reflectorized or aperture lamps,” “fluorescent lamps designed for use in reprographic equipment,” and “lamps primarily designed to produce radiation in the ultraviolet region of the spectrum.” For these exemption categories, the terminology was either not defined elsewhere or the application of the exemption could be further clarified. Using product literature and industry reference sources, DOE proposed clarifications of these exemptions in the NOPR. DOE did not receive any comments on the proposed clarifications. However, the National Electrical Manufacturers Association (NEMA) did state that they support all existing exemptions for fluorescent products. (NEMA, No. 54 at p. 11) DOE therefore is maintaining the clarifications to the exemption definitions.
Additionally, DOE proposed clarifications of the terms “designed” and “marketed” as applied to definitions of lighting products covered under DOE standards. These terms are generally used to ensure that exemptions from applicable standards apply only to lamps used in certain intended applications and/or functions. Therefore, DOE considered the terms “designed,” “designated,” “designation,” “designated and marketed,” and “designed and marketed,” for covered lighting products to mean that manufacturers explicitly state the intended application of the lamp in a publicly available document (
e.g.,
product literature, catalogs, packaging labels, and labels on the product itself). In the NOPR DOE had specified the lamp types to which the proposed definition should apply as follows: Fluorescent lamp ballasts; fluorescent lamps; general service fluorescent lamps; general service incandescent lamps; incandescent lamps; incandescent reflector lamps; medium base compact fluorescent lamps; and specialty application mercury vapor lamp ballasts. In this final rule, in addition to these lamp types, the definition will also apply to “general service lamps” which are also a lamp type covered by DOE.
The term “designed and marketed” is also used in the general service fluorescent lamp definition which specifies that all lamp types exempted must be “designed and marketed” for the nongeneral application they are
intended to serve. One of these exemptions is lamps with a CRI of 87 or greater (hereafter “high CRI lamps”).
The California Investor Owned Utilities (CA IOUs) commented that the definition of “designed and marketed” should relate to the way products are represented in the marketplace and might be utilized. (CA IOUs, Public Meeting Transcript, No. 49 at p. 28) EEOs predicted that DOE's method of adding a definition of “designed and marketed,” as proposed in the NOPR, would do nothing to prevent or dissuade manufacturers from continuing to sell high CRI lamps as inexpensive, extremely inefficient alternatives to GSFLs subject to federal standards. (EEOs, No. 55 at pp. 2-4) EEOs and the National Energy Efficiency Partnership (NEEP) commented that the exemption for high CRI GSFLs is a loophole that is undercutting the current federal standards and, if not addressed, would undercut the standards ultimately adopted by this rulemaking. EEOs, NEEP, and Earthjustice reported that they have encountered numerous examples of high CRI lamps that are being marketed as suitable general service lamps. NEEP noted that the market responded to the 2009 Lamps Rule by increased offerings of high CRI T12 lamps. These products offer no energy savings and in the case of full-wattage 40 W lamps, actually increase energy usage. EEOs found that almost all of the 4ft T12 bipin GSFLs sold online were high CRI, costing as little as $1.50 per lamp when sold in multi-packs and having efficacy ratings as low as 54 lm/W. Compared to the 92.4 lm/W proposed in the NOPR for lamps at or below a correlated color temperature (CCT) of 4,500 K, EEOs calculated that a single high CRI 2600 lumen lamp, with an average rated life of 36,000 hours, could use 720 kWh more than a regulated lamp over the course of its life. (EEOs, No. 55 at pp. 2-4; NEEP, No. 57 at pp. 2-3; Earthjustice, Public Meeting Transcript, No. 49 at p. 27; Earthjustice, No. 52 at pp. 1-3)
ASAP commented that DOE consider what modifications to the high CRI definition could be made to address the use of high CRI lamps in general service applications. (ASAP, Public Meeting Transcript, No. 49 at pp. 28-29) Earthjustice also noted that a high CRI lamp marketed for general lighting applications but fails to meet federal minimum efficacy levels would be violating energy conservation standards and the marketing claims may constitute an unfair or deceptive act or practice in violation of section 5(a)(1) of the Federal Trade Commission Act, 15 U.S.C. 45(a)(1). Earthjustice stated that DOE should work with the Federal Trade Commission to develop guidance on the appropriate marketing of high CRI fluorescent lamps. Earthjustice suggested that DOE should also investigate whether high CRI lamps meet EPCA's thresholds for coverage and energy conservation standards. (Earthjustice, No. 52 at pp. 3-4)
The definition of “designed and marketed” adopted in this rule refers to how the lamp is represented in the market and should be utilized by consumers. DOE believes that within the scope of this rulemaking it is implementing the appropriate changes in the CFR to clarify the exemption of high CRI products. It is not within the scope of DOE's authority in this rulemaking to modify the thresholds set by the current CRI exemptions for GSFLs.
Earthjustice commented the proposed definition of “designed and marketed” states that the intended application must be specified in a public document rather than all public documents. Earthjustice noted this as a problem specifically for high CRI lamps as it would allow manufacturers to explain the high CRI application in one document while still marketing the product as for general lighting applications in other documents. Earthjustice suggested, and EEOs concurred, that DOE should revise the definition of “designed and marketed” to provide that “the intended application of the lamp is clearly and conspicuously stated in all publicly available documents (
e.g.,
product literature, catalogs, packaging labels, and labels on the product itself).” (Earthjustice, No. 52 at pp. 3-4; EEOs, No. 55 at pp. 2-4)
DOE agrees that the definition proposed in the NOPR for “designed and marketed” can be strengthened and therefore, in this final rule will add the word “clearly,” and specify “all publicly available documents” so it reads “means that the intended application of the lamp is clearly stated in all publicly available documents (
e.g.,
product literature, catalogs, and packaging labels).” DOE believes that it is important that all public disclsures be consistent about the intended use or application of the lamp. In addition, DOE notes that the Federal Trade Commision prescribes certain energy-related labels for lighting products, such as general service fluorescent lamps and DOE will also consider those labels along with any other voluntary marking the manufacturers currently put on their lamps when determining whether a particular lamp is “designed” and “marketed” for a specific application. DOE reiterates that it is not adopting any new labeling requirements for lamps covered by this rulemaking.
B. General Service Fluorescent Lamp Scope of Coverage
1. Additional General Service Fluorescent Lamp Types
In this rulemaking, DOE evaluated energy-efficiency standards for additional GSFLs beyond those for which standards have already been established. (42 U.S.C. 6295(i)(5)) Any additional GSFLs considered for coverage under standards must meet the definition of a fluorescent lamp in 42 U.S.C. 6291(30)(A); satisfy the majority of fluorescent lighting applications; not be within the exclusions specified in 42 U.S.C. 6291(30)(B); and not already be subject to energy conservation standards. 73 FR 13620, 13629 (March 13, 2008). For each additional GSFL that meets these criteria, DOE then assessed whether standards could result in significant energy savings and are technologically feasible and economically justified. Standards for any applicable additional GSFLs are adopted based on the same criteria used to set new or amended standards for products pursuant to 42 U.S.C. 6295(o).
Using these criteria, DOE evaluated whether the following GSFL types warranted coverage under standards: 1) pin base compact fluorescent lamps (CFLs); 2) non-linear fluorescent lamps (
e.g.,
circline); and 3) fluorescent lamps with alternate lengths (
e.g.,
2-, 3-, and 5-foot lamps).
For pin base CFLs, DOE determined that these lamp types fall within the definition of “general service lamps,” which excludes GSFLs. (42 U.S.C. 6291(30)(BB)) Therefore, these lamp types cannot be considered under this rulemaking. DOE is evaluating these lamp types in the rulemaking for general service lamps. Documents related to this rulemaking can be found on regulations.gov, docket number EERE-2013-BT-STD-0051.
For non-linear fluorescent lamps, DOE considered circline fluorescent lamps, the primary shape not currently covered under standards. Using the miscellaneous category of fluorescent lamps reported by the 2010 U.S. Lighting Market Characterization
19
(2010 LMC), DOE determined that the market share and energy consumption for these lamps was not substantive. The 2010 LMC's miscellaneous category composed 2.1 percent of lighting and
consumed 4 terrawatt-hours (TWh) of electricity in 2010. Circline lamps are only a portion of the miscellaneous category, which also includes all fluorescents other than T5 linear and T8 and T12 linear and U-shaped lamps, as well as fluorescent lamps with unknown characteristics. Interviews with manufacturers also confirmed the low market share of these lamp types. Therefore, DOE concluded that coverage should not be expanded to non-linear fluorescent lamps as standards would not likely result in significant energy savings.
19
U.S. Department of Energy.
2010 U.S. Lighting Market Characterization.
January 2012. Available at
http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf
.
For linear lengths not already covered by standards, DOE focused on linear medium bipin (MBP) fluorescent lamps ranging from 1 to 6 feet, with the exception of the 4-foot MBP, which is already subject to standards. DOE's analysis showed that 5- and 6-foot lengths comprise a very low percentage of the linear MBP product offerings. For the T8 MBP lamps with lengths less than 4 feet, according to the 2010 LMC, these lamps comprised about 0.7 percent of the linear fluorescent lamp market and 0.2 percent of all installed lighting and consumed 1 TWh of electricity in 2010. Feedback from manufacturers also indicated a low market share for these lamp types.
NEMA supported DOE's decision not to include additional lamp types, such as 2-foot linear lamps, in the scope of the regulation agreeing that such lamps have low sales volume and low energy use. (NEMA, No. 54 at p. 11) ASAP stated it understood DOE's reasoning for not covering 2-foot linear fluorescent lamps based on the 2010 LMC. However, ASAP noted and CA IOUs concurred that 2-foot lamps is a growing market and that DOE should address this in the final rule. (ASAP, Public Meeting Transcript, No. 49 at pp. 19-20; CA IOUs, Public Meeting Transcript, No. 49 at p. 20)
EEOs and CA IOUs commented that DOE should include and set efficacy standards for 2-foot linear lamps as part of the rulemaking, finding DOE's assertion that linear fluorescent lamps shorter than 4 feet do not comprise a sufficiently large share of annual lamp sales and energy use to warrant coverage unconvincing. EEOs argued that DOE used outdated shipment data from the 2010 LMC, which was not specific to 2-foot linear GSFLs, to estimate sales and energy savings potential. EEOs and CA IOUS stated as this data was gathered prior to the effective date of the last round of GSFL standards it does not include the market impact from these standards. Further, EEOs and CA IOUs voiced concern over DOE's continued use of the 2010 LMC data instead of the newer shipment data from Vermont and California. CA IOUs noted that in Vermont study (
2011 Vermont Market Characterization and Assessment Study
20
),
2-foot lamps were by far the most common lamp length behind 4-foot lamps, and more common than many of the other product classes currently being covered by standards. While EEOs recognized that this data only represents a small portion of the overall lighting market, EEOs stated that using the field survey is better than relying on unreliable and outdated information from the 2010 LMC. (EEOs, No. 55 at pp. 5-6; CA IOUs, No. 56 at p. 4)
20
Navigant Consulting, Inc.
2011 Vermont Market Characterization and Assessment Study.
October 2012. Available at
http://publicservice.vermont.gov/sites/psd/files/Topics/Energy_Efficiency/EVT_Performance_Eval/VT%20CI%20Existing%20Buildings%20Market%20Assessment%20and%20Characterization_2012-10-6_FINAL.pdf.
DOE found using the 2010 LMC data to determine whether the 2-foot linear fluorescent lamps have a substantial market share and could result in significant energy savings is more accurate than relying on data from the Vermont study. The Vermont study is specific to a region and states that it was intended to develop the baseline data that characterizes the existing building and equipment stock in the Vermont business sector and covers the period of July 2011 to July 2012.
21
The study uses on-site surveys of 120 existing buildings for its primary data.
22
The 2010 LMC study captures all lighting installed in the U.S. in stationary applications during 2010.
23
The 2010 LMC groups linear fluorescent lamps by shape and length, and DOE used the T8 lamps with lengths less than 4 feet category to assess the 2-foot linear fluorescent market. Therefore, because this category includes more than just the 2-feet lengths, DOE's market estimates for the 2-foot linear fluorescent lamps are likely conservative. Further, the 2009 Lamps Rule became effective September 14, 2009 and required compliance July 14, 2012. Therefore, the Vermont study that was executed before compliance was required does not offer any added benefit.
21
2011 Vermont Study, 1.
22
2011 Vermont Study, 3.
23
2010 LMC Study, 2.
CA IOUs noted that when using the 2010 LMC data, DOE excluded 2-foot T12 lamps from its total on the premise that the market will likely shift away from T12s due to strengthened ballast standards. CA IOUs agreed that the market will shift away from T12s, however, they predicted that all of these lamp sales would likely become 2-foot T8 sales. DOE therefore should have counted 2-foot T12 shipments towards the total 2-foot lamp estimates. (CA IOUs, No. 56 at p. 4)
DOE excluded T12 lamps from this analysis to reflect future market trends. The 2011 final rule amending energy conservation standards for fluorescent lamp ballasts (hereafter the “2011 Ballast Rule”), which will require compliance on November 14, 2014, set standards difficult for T12 ballasts to meet.
24
76 FR 70548 (Nov. 14, 2011). Due to these standards and because historical shipments of most T12 lamps have been decreasing steadily, a trend confirmed in manufacturer feedback from interviews, DOE determined the market will likely shift away from T12 lamps. However, even if there were a shift from 2-foot linear T12 to 2-foot linear T8 lamps it would not be significant, as the T12 lamps with lengths less than 4 feet comprise only 0.6 percent of the linear fluorescent market and 0.2 percent of all installed lighting.
24
The full text and all related documents of the 2011 Ballast Rule can be found on regulations.gov, docket number EERE-2007-BT-STD-0016 at
www.regulations.gov/#!docketDetail;D=EERE-2007-BT-STD-0016
.
EEOs reflected further on DOE's argument that 2-foot linear GSFLs are uncommon and not a large percentage of the lighting market. While EEOs agreed it is undoubtedly true that 2-foot linear GSFLs sell in much smaller volumes than 4-foot GSFLs, EEOs contended and CA IOUs agreed that regulating 2-foot linear GSFLs sales that are a small fraction of the volume of the 4-foot GSFLs lamps could still yield significant energy savings, especially as the baseline 2-foot linear lamps are extremely inefficient. Specifically, for 2-foot linear fluorescent lamps, EEOs found efficacies of 58 lm/W for T12 lamps, 77 lm/W for standard T8 lamps, and 88 lm/W for more efficient T8 lamps. By comparison, 2-foot U-shaped GSFLs which are subject to current standards have efficacies that range from 85 to 94 lm/W. (EEOs, No. 55 at pp. 5-6; CA IOUs, No. 56 at p. 4) EEOs noted that in interviews, manufacturers told DOE that 2-foot linear GSFLs are used in kitchens, bathrooms, vanity lighting, hospitality applications, cabinets, and to round out edges of ceilings in commercial spaces, and the Edison Electric Institute had noted that these lamps are used in task lighting. EEOs and CA IOUs additionally argued that many 2x2 fixtures are retrofitted to 2-foot linear lamps, replacing existing U-bend lamps. EEOs also cautioned that following the exemption of certain ER and BR IRLs from standards, the sales of
ER, BR lamps increased. EEOs suggested that DOE may be making the same mistake by not covering 2-foot linear GSFLs. (EEOs, No. 55 at pp. 5-6)
In order to extend the scope to an additional lamp type, DOE must consider the potential energy savings that would result from regulating the lamp type under consideration. (42 U.S.C. 6295(o)) Based on its assessment of market share, trends, and product offerings, DOE does not find that significant energy savings will result from a standard for 2-foot linear fluorescent lamps.
DOE's review of 2-foot fluorescent lamp product offerings indicated that the majority of T8 products are offered in 17 W with minimal reduced wattage options and the T12 products are offered in 20 W. Therefore, any likely savings from standards would come from more efficacious T8 systems replacing T12 systems. However, as noted previously, the 2011 Ballast Rule enacts standards that will be difficult for T12 ballasts to meet and likely result in a shift away from T12 products.
As mentioned, using the relevant data in the 2010 LMC and observing the limited product offerings, DOE determined that the market share for 2-foot linear fluorescents is very low. Additionally, DOE compared the market share reported for the less than 4 feet T8 lamps in 2000 LMC compared to the 2010 LMC. From 2000 to 2010 the market of less than 4 feet T8 lamps declined from 1.5 to 0.7 percent of the linear fluorescent market and 0.5 to 0.2 percent of the entire lighting market. Further, the inventory of less than 4 feet T8 lamps declined by about 52 percent from 2000 to 2010 based on the LMC reports for those years. Therefore, DOE finds that the 2-foot linear lamps not only currently comprise a low market share but will likely not experience growth and therefore, will not result in significant energy savings.
Regarding a potential shift to the 2-foot linear lamps, while manufacturer feedback noted the applications in which 2-foot linear lamps can be utilized, it also indicated that the market share of the 2-foot linear fluorescent lamps was not likely to increase. Further, the noted applications such as cabinets or hospitality lighting indicate that this lamp type is used in specific spaces and therefore would likely have limited growth in market share.
Therefore, DOE maintains its conclusion not to include the 2-foot linear fluorescent lamp type in the scope of this rulemaking.
2. Additional General Service Fluorescent Lamp Wattages
DOE specifies a certain minimum wattage for lamp types included in the definition of “fluorescent lamp.” In this rulemaking, DOE also evaluates whether coverage should be extended to additional wattages of these lamp types. (42 U.S.C. 6295(i)(5)) As part of this assessment, DOE reviewed product offerings for covered lamp types to determine if any new, lower wattage products had been introduced since publication of the 2009 Lamps Rule. In the NOPR, DOE proposed extending coverage to the following reduced wattage lamps: 49 W, 50 W, 51 W 8-foot SP slimline, 25 W 4-foot T5 MiniBP standard output (SO), and 44 W, 47 W 4-foot T5 MiniBP HO lamps. 79 FR at 24085 (April 29, 2014) DOE currently covers 8-foot SP slimline lamps with wattages of 52 W or more; 4-foot T5 MiniBP SO lamps with wattages of 26 W or more; and 4-foot T5 MiniBP HO lamps with wattages of 49 W or more. These reduced wattage lamps are generally more efficacious than their full-wattage counterparts are and offer the potential for increased energy savings. DOE did not receive any comments regarding the proposed additional wattages for inclusion in GSFL scope in response to the NOPR.
Therefore, DOE is extending coverage to the following GSFLs in the final rule:
• 8-foot SP slimline lamps with wattages ≥ 49 W and < 52 W;
• 4-foot T5 MiniBP SO lamps with wattages ≥ 25 W and < 26 W; and
• 4-foot T5 MiniBP HO lamps with wattages ≥ 44 W and < 49 W.
C. Incandescent Reflector Lamp Scope of Coverage
1. Incandescent Reflector Lamp Types
In this rulemaking, DOE does not consider the following IRL types: (1) lamps rated 50 W or less that are ER30, BR30, BR40, or ER40; (2) lamps rated 65 W that are BR30, BR40, or ER40 lamps; and (3) R20 IRLs rated 45 W or less. (42 U.S.C. 6295(i)(C)) These IRLs referred to collectively as certain R, ER, and BR IRLs are the subject of a separate rulemaking on which further information can be found on regulations.gov under docket ID EERE-2010-BT-STD-0005 at
www.regulations.gov/#!docketDetail;D=EERE-2010-BT-STD-0005
. DOE has suspended activity on this rulemaking as a result of section 322 of Public Law (Pub. L.) 113-76 (January 17, 2014) (hereafter, “Consolidated Appropriations Act, 2014”), which prohibits DOE from using appropriated funds to implement or enforce standards for ER, BR, and BPAR IRLs. DOE received several comments on the exclusion of the certain R, ER, BR lamps from this rulemaking and DOE's interpretation of the Consolidated Appropriations Act, 2014.
NEMA stated its support for all existing exemptions for IRL products and agreed with DOE's approach to address exempted BR lamps in a separate rulemaking when funding is available. (NEMA, No. 54 at p. 10-11) Earthjustice, however, commented DOE is obligated to include the certain R, ER, and BR IRLs in this rulemaking. Earthjustice remarked that DOE's determination that these IRLs are covered by the directive in 42 U.S.C. 6295(i)(3) to amend EPCA's standards should extend to 42 U.S.C. 6295(i)(4) under which this rulemaking is being concluded. Therefore, the exempt lamps should be a part of this rulemaking. (Earthjustice, No. 52 at p. 4) Earthjustice further commented that because the Consolidated Appropriations Act, 2014 is clearly inapplicable to R20 IRLs rated 45 W or less, DOE should adopt standards for those lamps. (Earthjustice, No. 52 at p. 5)
DOE is not including the certain R, ER, and BR IRLs in this rulemaking as it has commenced another rulemaking to address standards for these lamps. At the time DOE determined that it has the authority under EPCA to adopt standards for these R, ER, and BR IRLs, as they are covered by the directive in 42 U.S.C. 6295(i)(3), the first cycle of rulemaking to amend standards for IRLs per 42 U.S.C. 6295(i)(3) was already underway. Therefore, DOE initiated a separate rulemaking for the R, ER, and BR IRLs which included publishing a framework document and holding a public meeting, prior to the initiation of this rulemaking. Additionally, the Consolidated Appropriations Act, 2014 precludes DOE from engaging in a rulemaking involving certain ER, and BR IRLs. While DOE agrees that implementation or enforcement of standards for R IRLs are not prohibited by the Consolidated Appropriations Act, 2014, the R20 IRLs rated 45 W or less are already the subject of a separate rulemaking. Due to the progress of that rulemaking, DOE did not find it appropriate to remove the R20 IRLs rated 45 W or less from the scope of that rulemaking.
CA IOUs, NEEP, Earthjustice and EEOs noted that they do not agree with DOE's interpretation of the Consolidated Appropriations Act, 2014 and urged DOE to include all covered IRLs in this rulemaking, including the ER, BR, and BPAR lamps noted in the Act. (CA IOUs, No. 56 at p. 5; NEEP, No. 57 at
p. 1; EEOs, No. 55 at p.7; Earthjustice, No. 52 at p. 5) Earthjustice commented that nothing in the text of the Act prevents DOE from using appropriated funds to adopt standards that are different from those shown in the tables in section 325(i)(1)(B). Earthjustice stated that even if DOE believes that adopting standards stronger than those in the tables would implicitly also apply standard levels blocked by the Act (in that DOE would be applying standards to remove from the market lamps that Congress allegedly sought to protect), DOE could certainly adopt standards weaker than those applied in EPAct 1992. Such standards would still represent a significant improvement in efficacy, and under the current funding constraints, may represent the maximum improvement in energy efficiency that is feasible. (Earthjustice, No. 52 at p. 5)
EEOs stated that the Consolidated Appropriations Act, 2014 only prevents DOE from using funds to implement or enforce standards contained in the tables in section 325(i)(1)(B) and not from implementing or enforcing standards developed in response to a separate congressionally required rulemaking. (EEOs, No. 55 at p. 7) CA IOUs stated that EISA 2007 requires DOE to consider revising standards for these products. (CA IOUs, No. 56 at p. 5)
CA IOUs also noted that by omitting these products, the total savings potential from IRL standards is greatly minimized as standards for covered IRLs may result in more expensive, higher performing covered products and low cost, low efficacy unregulated products. CA IOUs and NEEP commented that these unregulated lamps would result in major loopholes as consumers could be incented to utilize less efficient IRLs, ultimately sacrificing significant energy savings to the country. (CA IOUs, No. 56 at p. 5; NEEP, No. 57 at p. 1) ASAP stated and was supported by CA IOUs that consumers currently have a choice between a very efficient light-emitting diode (LED), a very efficient incandescent covered lamp or a very inefficient 65 W BR or equivalent lamp. Therefore, addressing this loophole could lead to annual savings of half a billion dollars. (ASAP, Public Meeting Transcript, No. 49 at pp. 16-17)
The Consolidated Appropriations Act, 2014 prohibits expenditure of funds appropriated by that law to implement or enforce standards for BPAR, BR, and ER IRLs. Thus, DOE is not considering these specific lamps in this rulemaking.
2. Incandescent Reflector Wattages
In this rulemaking, DOE also did not consider IRLs with wattages lower than 40. EPCA defines an incandescent reflector lamp as a lamp that “has a rated wattage that is 40 watts or higher.” (42 U.S.C. 6291(30)(C), (C)(ii), and (F)) Additionally, while the definition of IRLs does not provide an upper wattage limit, DOE did not assess covered IRLs higher than 205 W in the NOPR. DOE research indicated that wattages greater than 205 W comprise a very small portion of the market and are typically designed for specialty uses, and therefore, do not represent significant energy savings. DOE did not receive any comments on this assessment in response to the NOPR and therefore, analyzes the same wattage range for IRLs in this final rule.
D. Summary of Scope of Coverage
In conclusion, in this rulemaking DOE is extending the scope of coverage for GSFLs to certain wattages including 8-foot SP slimline lamps with wattages ≥49 W and <52 W, 4-foot T5 MiniBP SO lamps with wattages ≥25 W and <26 W, and 4-foot T5 MiniBP HO lamps with wattages ≥44 W and <49 W but not to additional GSFL types. Further, DOE is clarifying certain exemptions noted under the definition of “general service fluorescent lamp.” DOE is not considering IRLs less than 40 W or greater than 205 W and is also not considering the following IRL types: (1) Lamps rated 50 W or less that are ER30, BR30, BR40, or ER40; (2) lamps rated 65 W that are BR30, BR40, or ER40 lamps; and (3) R20 IRLs rated 45 W or less. DOE is also adopting a definition for “designed and marketed” as it applies to all covered lighting products.
VI. Methodology and Discussion
In the NOPR phase of this rulemaking, DOE conducted the following analyses: a market and technology assessment, screening analysis, engineering analysis, product price determination, energy-use characterization, LCC and PBP analyses, an LCC subgroup analysis, shipments analysis and NIA, a complete MIA, a utility impact assessment, an employment impact assessment, an emissions analysis, a determination of monetization of reduced emissions from proposed standard levels, and an RIA. These analyses were then updated and revised as appropriate based on feedback received for this final rule.
DOE used four spreadsheet tools to estimate the impact of standards analyzed in the NOPR. The first tool (“Life-Cycle Cost [LCC] Analytical Tool”) calculates LCCs and payback periods of potential new energy conservation standards. The second tool (“National Impact Analysis [NIA] Analytical Tool”) is a spreadsheet that provides shipments forecasts and a framework that calculates national energy savings and net present value resulting from potential amended energy conservation standards. DOE assessed manufacturer impacts, largely through use of the “Government Regulatory Impact Model (GRIM)”, the third tool. Additionally, DOE used output from the latest version of EIA's National Energy Modeling System (NEMS) for the emissions and utility impact analyses. NEMS is a public domain, multi-sector, partial equilibrium model of the U.S. energy sector. EIA uses NEMS to prepare its
Annual Energy Outlook
(
AEO),
a widely known energy forecast for the United States.
NEMA voiced concerns about the number of assumptions that DOE uses in the NOPR that are not being tested by retrospectively evaluating predictions made in the 2009 Lamps Rule in order to improve DOE's predictive analysis and to tune DOE's models. (NEMA, No. 54 at p. 17)
As needed, DOE makes assumptions based on the current relevant data and research available, feedback from manufacturer interviews, and stakeholder comments, information that is informed by the impacts of the 2009 Lamps Rule. Further, in the NOPR analysis and in this final rule analysis DOE has taken appropriate steps to ensure that its models provide the most accurate assessment of standards and their impacts. In the following sections, DOE discusses its methodology and responds to comments specific to each analysis. DOE further provides details regarding its analysis including assumptions in the final rule TSD.
A. Market and Technology Assessment
In the energy conservation standards rulemaking process, DOE conducts a market and technology assessment to provide an overall picture of the market for products concerned. Based primarily on publicly available information, the analysis provides both qualitative and quantitative information. The market and technology assessment includes the major manufacturers, product classes, retail market trends, shipments of covered products, regulatory and non-regulatory programs, and technologies that could be used to improve the efficacy of GSFLs and IRLs. DOE identified several technology options after conducting this assessment for the NOPR analysis. 79 FR at 24087-24090 (April 29, 2014). For further details on
the technology options and the screening process, see, respectively, chapters 3 and 4 of the NOPR TSD.
Osram Sylvania (OSI) commented that many of the GSFL and IRL technology options are already being used by manufacturers, so they should not be considered technology options. (OSI, Public Meeting Transcript, No. 49 at pp. 46-47) Based on DOE research, the technology options put forth in this rulemaking for GSFLs and IRLs all remain tools manufacturers can use to increase the efficacy of the lamp. Because lamps are present on the market at different efficacy levels, it is evident that not all the technology options are being used by all manufacturers and/or are not being used to their optimal performance. Therefore, with the exception of the IRL technology options of efficient filament orientation and efficient filament coiling, which are discussed in greater detail in section VI.A.2, DOE continues to consider the technology options put forth in the NOPR as means to improve the efficacy of GSFLs and IRLs.
1. General Service Fluorescent Lamp Technology Options
DOE received comments specific to the GSFL technology options put forth in the NOPR analysis. Specifically, DOE received a comment on highly emissive coatings, fill gas compositions, and higher efficiency phosphors.
a. Highly Emissive Coatings
DOE identified highly emissive coatings as a technology option to increase GSFL efficacy in the NOPR. When electrons are more easily emitted from the fluorescent lamp electrodes, a lower voltage is needed to maintain the arc. Therefore, any improvement in electrode coating that would allow electrons to be more easily removed from the electrodes would reduce the lamp power and increase the overall efficacy of the lamp. See chapter 3 of the final rule TSD for further details.
General Electric (GE) commented that highly emissive coatings are already being used to meet the current requirements of the 2009 Lamps Rule, so it is not logical to cite this as a technology options again. (GE, Public Meeting Transcript, No. 49 at pp. 48-49)
DOE found that there are various coatings and combinations that can be used to increase lamp efficacy. Conventional coatings include barium oxide (BrO), calcium oxide (CaO), and strontium oxide (SrO), sometimes paired with the addition of zirconium oxide (ZrO) which is used to extend lamp lifetime, and silicon carbide (SiC) which removes more electrons from the electrode. Because lamps are present on the market at more than one level of efficacy, and highly emissive electrode coating technology can be optimized in different variations, it provides a mechanism to improve the efficacy of less efficacious products (see chapter 3 of the final rule TSD for more information). Therefore, DOE retained highly emissive electrode coating as a technology option for this final rule.
b. Higher Efficiency Lamp Fill Gas Composition
DOE also identified higher efficiency lamp fill gas composition as a technology option to increase GSFL efficacy in the NOPR. Lamp fill gases in fluorescent lamps increase mobility of mercury ions and electrons, facilitating recombination and resulting in increased ultraviolet (UV) output and higher lamp efficacy. See chapter 3 of the final rule TSD for further details.
GE commented that higher efficiency gas fill composition is already being used to meet the current requirements of the 2009 Lamps Rule, so it is not logical to cite this as a technology option again. (GE, Public Meeting Transcript, No. 49 at pp. 48-49)
Based on feedback from manufacturers in interviews, there are different types and ratios of fill gases that can be used to improve lamp efficacy. Because lamps are present on the market at more than one level of efficacy, and fill gas compositions can be optimized in different combinations, they provide a mechanism to improve the efficacy of less efficacious products. Therefore, DOE retained higher efficiency fill gas composition as a technology option for this final rule.
c. Higher Efficiency Phosphors
DOE also identified higher efficiency phosphors as a technology option to increase GSFL efficacy in the NOPR. 79 FR at 24088 (April 29, 2014). Triband phosphors which contain rare earth elements are more efficient phosphors that allow a lamp to emit light at the wavelengths to which human eyes are most sensitive which increases lamp efficacy. This effect is impacted by the relationship between the efficiency losses in the phosphor's conversion of light, wavelengths sensitive to the human eye, and measurement of lamp efficacy. Generally, as thickness of the phosphor layer (also called phosphor weight) increases, lamp light output increases until it slightly decreases or stays flat. (See chapter 3 of the final rule TSD for further details).
NEMA stated that options to increase phosphor weight are essentially exhausted at the proposed efficacy level because it is near the peak of the coating weight/light output curve shown in figure 3.4.5 of chapter 3 of the NOPR TSD. (NEMA, No. 54 at pp. 22-23)
As noted, phosphor weight utilized in a lamp impacts the efficacy achieved. Because lamps are present on the market at more than one level of efficacy, varying weights of higher efficiency phosphor coatings is an option that can be utilized to improve the efficacy of less efficacious products. Therefore, DOE maintained higher efficiency phosphors as a technology option for this final rule.
d. Summary of GSFL Technology Options
In summary, in this final rule analysis, DOE identified technology options for GSFLs listed in Table VI.1.
Table VI.1—GSFL Technology Options in the Final Rule Analysis
Name of technology option
Description
Highly Emissive Electrode Coatings
Improved electrode coatings allow electrons to be more easily removed from electrodes, reducing lamp power and increasing overall efficacy.
Higher Efficiency Lamp Fill Gas Composition
Fill gas compositions improve cathode thermionic emission or increase mobility of ions and electrons in the lamp plasma.
Higher Efficiency Phosphors
Phosphors increase the conversion of ultraviolet light into visible light.
Glass Coatings
Coatings on inside of bulb enable the phosphors to absorb more UV energy, so that they emit more visible light.
Higher Efficiency Lamp Diameter
Optimal lamp diameters improve lamp efficacy.
Multi-Photon Phosphors
Phosphors emit more than one visible photon for each incident UV photon.
2. Incandescent Reflector Lamp Technology Options
DOE received comments specific to the IRL technology options put forth by DOE in the NOPR.
Id.
at 24088-24090. Specifically, DOE received comments on thinner filaments, efficient filament coiling, efficient filament orientation, higher efficiency inert fill gases, higher pressure tungsten-halogen lamps, infrared glass coatings, efficient filament placement, and integrally ballasted low voltage lamps.
a. Thinner Filaments
In the NOPR analysis, DOE proposed thinner filaments as a technology option for increasing IRL efficacy.
Id.
at 24089. A thinner filament has an increased resistance and therefore an increased operating temperature, which increases the lamp efficacy. (See chapter 3 of the final rule TSD for further details.) NEMA commented that thinner filaments mean longer filaments, which reduce efficacy by defocusing the light source inside the reflector. (NEMA, No. 54 at p. 20)
DOE's research did not find any information indicating that the loss in efficacy due to the potentially defocused light with a longer filament outweighs the gain obtained by running a thinner filament at a higher temperature. Additionally, a longer filament would increase lumen output. DOE acknowledges that when utilizing a thinner filament as a technology option, other factors must be considered, such as the length of the filament required to implement the technology in its most optimal form. However, this does not preclude it as a technology option as use of it in the appropriate manner can increase IRL efficacy. Therefore, DOE maintained the use of thinner filaments as a technology option that can be manipulated to increase lamp efficacy for this final rule.
b. Efficient Filament Coiling
DOE proposed efficient filament coiling in the NOPR analysis as a technology option to increase lamp efficacy.
Id.
at 24089. Coiling of the incandescent lamp filament can increase luminous efficacy. The light output of an incandescent lamp is directly proportional to the light-emitting surface area of the light source. By coiling the filament, a longer filament can be used, increasing luminous output and therefore lamp efficacy. (See chapter 3 of the final rule TSD for further details.) NEMA stated that efficient filament coiling, which is necessary for efficient optics and beam patterns, is already common practice in the majority of halogen IRLs. Thus, no further efficacy increase is possible with this technology option. (NEMA, No. 54 at p. 20)
DOE research indicates that specifications of commercially available IRLs covered in this rulemaking state that the optimal coiling configuration, the CC (coiled coil) is being used. Therefore, DOE removed efficient filament coiling as a technology option that can be used to improve the efficacy of lamps on the market for this final rule.
c. Efficient Filament Orientation
DOE proposed efficient filament orientation in the NOPR analysis as a technology option to increase lamp efficacy.
Id.
Tungsten filaments in incandescent lamps can be positioned horizontally or vertically with respect to the base of the bulb. By positioning the filament in vertical alignment, only a small portion of the light is emitted towards the base, allowing more light to escape the bulb and be used for illumination, thereby increasing lamp efficacy. (See chapter 3 of the final rule TSD for further details.) NEMA commented that efficient filament orientation, which is necessary for efficient optics and beam patterns, is already common practice in the majority of halogen IRLs, noting that manufacturers already strive to accomplish this and thus, no further efficacy increase is possible with this technology option. (NEMA, No. 54 at p. 20)
DOE recognizes that filaments are placed in the vertical position which is optimal for commercially available IRLs covered in this rulemaking. Therefore, DOE removed efficient filament orientation as a technology option that can be used to improve the efficacy of lamps on the market for this final rule.
d. Higher Efficiency Inert Fill Gas
DOE proposed high-efficiency inert fill gas as another technology option to increase IRL efficacy in the NOPR analysis.
Id.
Fill gases such as krypton and xenon have low thermal conductivity that decreases the convective cooling of the filament, allowing for higher temperature operation and therefore higher efficacy. These gas molecules are larger relative to other gases, and can more effectively slow down the evaporation of tungsten and thereby extend the life of the lamp. Xenon, having even lower heat conductivity and larger mass than krypton, can more drastically change efficacy and life, but has a higher cost. Most lamps compliant with the July 2012 standards use xenon as a fill gas. (See chapter 3 of the final rule TSD for further details.) NEMA commented that higher efficiency inert fill gas is already common practice in the majority of halogen IRLs and therefore, no further efficacy increase is possible with this technology option. (NEMA, No. 54 at p. 20)
Based on feedback from manufacturer interviews, DOE confirmed that the majority of covered standards-compliant IRLs are utilizing xenon. However, DOE also learned that the amount of xenon used in a lamp can vary based on several factors. Because lamps are present on the market at more than one level of efficacy, higher efficiency inert fill gas is one option that can be utilized to improve the efficacy of less efficacious products. Therefore, DOE maintained high-efficiency inert fill gas as a technology option for this final rule.
e. Higher Pressure Tungsten-Halogen Lamps
DOE proposed the use of higher pressure tungsten-halogen as a technology option in the NOPR analysis.
Id.
Increasing the pressure of the halogen burner by increasing the density of halogen elements can indirectly raise the efficacy of the tungsten-halogen lamp. The increased density of halogen elements raises the probability that an evaporated tungsten element combines with a halogen element in a gaseous compound. Adding more of this gaseous compound in the burner effectively increases the amount of tungsten re-deposited on the tungsten filament. The lamp efficacy can be increased by using higher pressure to maintain the evaporation rate while increasing the filament temperature. (See chapter 3 of the final rule TSD for further details.) NEMA stated that the higher pressures in higher pressure tungsten-halogen lamps increase life but reduce efficacy due to the faster convective cooling of the filament. (NEMA, No. 54 at p. 21)
DOE understands that maintaining the filament temperature and increasing the pressure, thereby decreasing the evaporation rate of tungsten result in a gain in lifetime. However, a combination of higher pressure and increased temperature can be used to achieve both an increase in efficacy and lifetime. Therefore, DOE maintains high-efficiency inert fill gas as a technology option in this final rule.
f. Infrared Glass Coatings
DOE proposed infrared glass coatings as a technology option in the NOPR analysis.
Id.
at 24090. Infrared coatings on incandescent lamps are used to
reflect some of the radiant energy emitted back onto the filament. This infrared radiation then supplies heat to the filament and the operating temperature increases. An increase in operating temperature results in higher light output and therefore an increase in efficacy. (See chapter 3 of the final rule TSD for further details.) NEMA commented that infrared glass coatings on burners and reflectors have been in use since the mid-1980s and have been developed to the maximum technologically feasible level. More efficient coatings with 80 or more layers have been tested, but these coatings fail due to cracking under repeated thermal expansion and contraction. Therefore, no further efficacy increase is possible with this technology option. (NEMA, No. 54 at p. 21)
Based on feedback from manufacturer interviews, DOE determined that different IR coating formulas are used on different halogen burners. Because lamps are present on the market at more than one level of efficacy, and infrared glass coating technology can be optimized in different variations, it provides a mechanism to improve the efficacy of less efficacious products. Therefore, DOE maintained infrared glass coatings as a technology option for the final rule.
g. Efficient Filament Placement
Efficient filament placement was one of the technology options presented in the preliminary analysis (see chapter 3 of the preliminary analysis TSD), but DOE did not propose it in the NOPR phase. An optimally placed filament allows a portion of the spectrum emitted by the filament to focus back onto it. The additional heat provided to the filament increases the operating temperature and thereby increases lamp efficacy. In the NOPR phase, NEMA commented that manufacturers already use efficient filament placement and that no further efficacy gains due to this technology option are possible. (NEMA, No. 54 at p. 20)
DOE had received similar comments regarding efficient filament placement in the preliminary analysis. Based on these comments and further research as well as manufacturer interviews, DOE determined that the optimal filament placement design is theoretically well understood and is being applied in commercially available IRLs covered under the scope of this rulemaking. Therefore, DOE did not propose efficient filament placement as a technology option in the NOPR analysis and maintained this decision for the final rule.
h. Integrally Ballasted Low Voltage Lamps
DOE also presented integrally ballasted low voltage lamps as a technology option in the preliminary analysis but did not propose it in the NOPR phase.
79 FR
at 24089 (April 29, 2014) The use of an integral ballast in an incandescent lamp allows an increase in the efficacy because it converts the line voltage to lower lamp operating voltages, thereby reducing the lamp wattage. In the NOPR phase, NEMA commented that integrally ballasted low voltage lamps use electronics that are thermally limited to 30 W or less due to American National Standards Institute/International Electrotechnical Commission (ANSI/IEC) form constraints. Further, most IRLs are burned base-up. Therefore, this is not viable for higher power PAR lamps. (NEMA, No. 54 at p. 21)
DOE received similar comments in the preliminary analysis and reviewed feedback from manufacturer interviews and conducted further research regarding issues with this technology option. In interviews, manufacturers stated that the use of an integral ballast to lower voltage is not a feasible technology in higher wattage lamps due to issues with dissipating heat generated by the electronic components. Manufacturers indicated that heat dissipation becomes a problem at wattages ranging from 20 to 35 W. DOE research also indicated that in converting to a lower voltage, current is increased and greater heat is generated from the filament. In higher wattage IRLs, the resulting increased temperature can be damaging to the voltage conversion circuitry. Further, based on manufacturer interviews there are no covered IRLs that currently utilize this technology option. Because the lower limit of IRL wattages covered under standards is 40 W, DOE did not propose integrally ballasted low voltage lamps as a technology option in the NOPR analysis and maintained this decision for the final rule.
i. Summary of IRL Technology Options
In summary, in this final rule analysis, DOE identified technology options for IRLs listed in Table VI.2.
Table VI.2—IRL Technology Options in the Final Rule Analysis
Name of technology option
Description
Higher Temperature Operation
Operating the filament at higher temperatures, the spectral output shifts to lower wavelengths, increasing its overlap with the eye sensitivity curve.
Microcavity Filaments
Texturing, surface perforations, microcavity holes with material fillings, increasing surface area and thereby light output.
Novel Filament Materials
More efficient filament alloys that have a high melting point, low vapor pressure, high strength, high ductility, or good radiating characteristics.
Thinner Filaments
Thinner filaments to increase operating temperature. This measure may shorten the operating life of the lamp.
Crystallite Filament Coatings
Layers of micron or submicron crystallites deposited on the filament surface that increases emissivity of the filament.
Higher Efficiency Inert Fill Gas
Filling lamps with alternative gases, such as Krypton, to reduce heat conduction.
Higher Pressure Tungsten-Halogen Lamps
Increased halogen bulb burner pressurization, allowing higher temperature operation.
Non-Tungsten-Halogen Regenerative Cycles
Novel filament materials that regenerate.
Infrared Glass Coatings
When used with a halogen burner, this is referred to as an HIR lamp. Infrared coatings on the inside of the bulb to reflect some of the radiant energy back onto the filament.
IR Phosphor Glass Coatings
Phosphor coatings that can absorb IR radiation and re-emit it at shorter wavelengths (visible region of light), increasing the lumen output.
UV Phosphor Glass Coatings
Phosphor coatings that convert UV radiation into longer wavelengths (visible region of light), increasing the lumen output.
Electron Stimulated Luminescence
A low voltage cathodoluminescent phosphor that emits green light (visible region of light) upon impingement by thermally ejected electrons, increasing the lumen output.
Higher Efficiency Reflector Coatings
Alternative reflector coatings such as silver, with higher reflectivity increase the amount of directed light.
Corner Reflectors
Individual corner reflectors in the cover glass that reflect light directly back in the direction from which it came.
High Reflectance Filament Supports
Filament supports that include a reflective face that reflects light to another filament, the reflective face of another filament support, or radially outward.
Permanent Infrared Reflector Coating Shroud
Permanent shroud with an IR reflector coating and a removable and replaceable lamp can increase efficiency while reducing manufacturing costs by allowing IR reflector coatings to be reused.
Higher Efficiency Burners
A double-ended burner that features a lead wire outside of the burner, where it does not interfere with the reflectance of energy from the burner wall back to the burner filament in HIR lamps.
B. Screening Analysis
After DOE identifies the technologies that improve the efficacy of GSFLs and IRLs, DOE conducts the screening analysis. The purpose of the screening analysis is to determine which options to consider further and which options to screen out. DOE consults with industry, technical experts, and other interested parties in developing a list of technology options. DOE then applies the following set of screening criteria to determine which options are unsuitable for further consideration in the rulemaking (10 CFR part 430, subpart C, appendix A at 4(a)(4) and 5(b)):
•
Technological Feasibility:
DOE will consider technologies incorporated in commercially available products or in working prototypes to be technologically feasible.
•
Practicability to Manufacture, Install, and Service:
If mass production of a technology and reliable installation and servicing of the technology could be achieved on the scale necessary to serve the relevant market at the time the standard comes into effect, then DOE will consider that technology practicable to manufacture, install, and service.
•
Adverse Impacts on Product Utility or Product Availability:
If DOE determines a technology to have significant adverse impact on the utility of the product to significant subgroups of consumers, or to result in the unavailability of any covered product type with performance characteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as products generally available in the United States at the time, it will not further consider this technology.
•
Adverse Impacts on Health or Safety:
If DOE determines that a technology will have significant adverse impacts on health or safety, it will not further consider this technology.
Those technology options not screened out by the above four criteria are called “design options” and are considered as possible methods of improving efficacy in the engineering analysis. DOE received several comments on technology options not screened out and retained as design options in the NOPR analysis for GSFLs and IRLs.
1. General Service Fluorescent Lamp Design Options
DOE received a general comment on the screening methodology as it relates to GSFLs. Philips commented that the screening analysis is not comprehensive enough because it is only looking at efficacy and does not consider other market requirements such as lifetime, dimmability, and CRI. (Philips, Public Meeting Transcript, No. 49 at p. 49)
One of the screening criteria is determining if a technology option would result in adverse impacts on the utility or availability of the product. DOE determined that of the design options considered for GSFLs, none would have a negative impact on the utility of the lamp (since lumen output is improved or maintained) nor would they eliminate the common lifetimes and CRI currently being offered. DOE acknowledges that krypton, a high-efficiency fill gas, seems to affect dimmability of reduced wattage lamps (
i.e.,
energy saver lamp model). Because of the issues related to dimming associated with reduced wattage lamps, DOE's analysis requires that full-wattage lamps, which do not experience these problems, meet any proposed level. Therefore, because the use of high-efficiency fill gas would only impact the dimmability of certain product options available at a standard level (
i.e.,
reduced wattage lamps), this design option is retained.
In summary, in this final rule analysis DOE identified as design options the following GSFL technologies that have met the screening criteria:
• Highly Emissive Electrode Coatings
• Higher Efficiency Lamp Fill Gas Composition
• Higher Efficiency Phosphors
• Glass Coatings
• Higher Efficiency Lamp Diameter
See chapter 4 of the final rule TSD for further details on the GSFL screening analysis.
2. Incandescent Reflector Lamp Design Options
DOE received feedback on several IRL design options put forth in the NOPR analysis, including higher temperature operation, thinner filaments, and higher efficiency reflector coatings.
a. Higher Temperature Operation
In the NOPR, DOE proposed higher temperature operation as a design option. 79 FR at 24091 (April 29, 2014). By operating the filament at higher temperatures, the spectral output shifts to shorter wavelengths, increasing its overlap with the photopic spectral eye sensitivity. This, in effect, increases the luminous output for a given power input and consequently increases the lamp efficacy. NEMA stated that higher temperature operation leads to a drastic and disproportionate loss in lifetime (
e.g.,
6-7 percent efficacy gain results in about 50 percent reduction in lifetime). (NEMA, No. 54 at p. 20)
DOE understands that there may be a tradeoff between operation at higher temperature and a decrease in lifetime. However, DOE believes the use of higher temperature operation can be tuned to achieve a gain in efficacy while maintaining a reasonable lifetime. Therefore, DOE maintained higher temperature operation as a design option for this final rule.
b. Thinner Filaments
DOE proposed thinner filaments as a design option in the NOPR analysis. A thinner filament has an increased resistance and therefore an increased operating temperature, which increases the lamp efficacy. NEMA commented that thinner filaments lead to a drastic loss in lifetime. (NEMA, No. 54 at p. 20)
DOE is aware that an incandescent lamp with a thinner filament cannot withstand as much tungsten evaporation as a thicker filament before failing,
resulting in a shorter lifetime. However, a thinner filament design can be implemented to achieve a gain in efficacy while preserving a reasonable lifetime. Therefore, DOE maintained the use of thinner filaments as a design option for this final rule.
c. Higher Efficiency Reflector Coatings
DOE proposed higher efficiency reflector coatings with the exception of gold reflector coatings, as a design option in the NOPR analysis. 79 FR at 24091 (April 29, 2014). IRLs are incandescent lamps with a reflective coating, most commonly composed of aluminum or silver applied directly to the reflector surface. The reflector coating allows these lamps to place the same illuminance on a specific area with reduced watts, thereby increasing efficacy. (Note: In the NOPR and in this final rule, DOE screened out gold reflector coating due to impact on product utility as gold reflectivity diminishes at and below blue-green wavelengths, which may decrease the color quality of light. See chapter 4 of the final rule TSD for further details.)
NEMA stated that silver, the best higher efficiency reflector coating, is already in use and cannot be used in glue-sealed lamps (such as PAR20, PAR30, PAR30LN) due to extreme oxidation issues. (NEMA, No. 54 at p. 21)
DOE research indicates that it is possible to use silver reflector coatings with an epoxy (glue-based) seal. For example, DOE identified a patent that uses aluminum as an inner reflective coating extending from the rim to the base of the lamp and then a second coating consisting of silver spaced from the rim. The silver layer is heat-treated in an oven with a controlled environment prior to fusing the lens to the reflector body, which allows a seal to form without further diminishing the reflective characteristic of the silver.
25
Because there are methods to apply higher efficiency reflector coatings to all products covered by this rulemaking, DOE maintained the use of higher efficiency reflector coatings as a design option for this final rule.
25
Woodward, David R. and Walter A. Boyce, Jack R. Sheppard.
High efficiency sealed beam reflector lamp with reflective surface of heat treated silver.
U.S. Patent No. 5789847A, filed October 24, 1995, and issued August 4, 1998.
d. Higher Pressure Tungsten-Halogen Lamps
DOE proposed the use of high pressure tungsten-halogen as a technology option in the NOPR analysis. 79 FR at 24091 (April 29, 2014). Increasing the pressure of the halogen burner by increasing the density of halogen elements can indirectly raise the efficacy of the tungsten-halogen lamp. NEMA stated that there are practical manufacturing process limitations and key consumer safety concerns with higher pressure tungsten-halogen lamps. (NEMA, No. 54 at p. 21)
DOE notes that this design option is being used in commercially available lamps. Further, DOE did not find information indicating any manufacturing or safety concerns with the use of higher pressure tungsten-halogen lamps. Therefore, DOE maintained the use of higher pressure tungsten-halogen lamps as a design option for this final rule.
In summary, in this final rule analysis DOE identified as design options the following IRL technologies that have met the screening criteria:
• Higher Temperature Operation
• Thinner Filaments
• Higher Efficiency Inert Fill Gas
• Higher Pressure Tungsten-Halogen Lamps
• Infrared Glass Coatings
• Higher Efficiency Reflector Coatings (with the exception of gold reflector coatings)
• Higher Efficiency Burners
See chapter 4 of the final rule TSD for further details on the IRL screening analysis.
C. Product Classes
DOE divides covered products into classes by: (a) the type of energy used; (b) the capacity of the product; or (c) other performance-related features that justify different standard levels, considering the consumer utility of the feature and other relevant factors. (42 U.S.C. 6295(q)) DOE received several comments regarding product classes proposed for GSFLs and IRLs in the NOPR analysis.
1. General Service Fluorescent Lamp Product Classes
In the NOPR analysis DOE considered product classes for GSFLs based on the following three factors: (1) Correlated color temperature; (2) physical constraints of lamps (
i.e.,
lamp shape and length); and (3) lumen package. 79 FR at 24091 (April 29, 2014). DOE received comments regarding establishing additional product classes based on the different spacing of 2-foot U-shaped lamps and lamp lifetime.
a. Two-Foot U-Shaped Lamps
DOE received several comments that separate product classes based on the spacing of the 2-foot U-shaped lamps may be needed. Spacing refers to the length between the two legs of the U-shaped lamp. The 2-foot U-shaped GSFLs come in 1
5/8
-inch spacing and 6-inch spacing. OSI commented that the 2-foot U-shaped lamps with 1
5/8
-inch spacing and 6-inch spacing should be in different product classes based on DOE's analysis in the NOPR. (OSI, Public Meeting Transcript, No. 49 at pp. 33-34) OSI stated that the reduced wattage 2-foot U-shaped lamps with 1
5/8
-inch spacing are typically used in retail applications and would be eliminated by the rulemaking, resulting in an increase in energy use. OSI added that full-wattage 6-inch lamps would be eliminated by the rulemaking, removing dimming utility. (OSI, Public Meeting Transcript, No. 49 at pp. 60-61) GE noted that this issue could partially be due to the scaling of the 2-foot U-shaped product class from the 4-foot MBP product class and could be an issue specific to the scaling factor or the 4-foot MBP product class efficacy levels. (GE, Public Meeting Transcript, No. 49 at p. 61) NEMA explained that consumers have switched to reduced wattage 1
5/8
-inch 2-foot U-shaped lamps, which serve retail applications and full-wattage 6-inch 2-foot U-shaped lamps are mainly used in offices for dimming purposes. (NEMA, No. 54 at p. 15)
EEOs recommended that DOE only create separate product classes for 6-inch and 1
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-inch spacing of 2-foot U-shaped if a technical barrier impacting efficacy potential is identified. (EEOs, No. 55 at p. 6) CA IOUs commented that DOE should not create separate product classes for U-shaped lamps with different spacing. CA IOUs supported this statement by identifying commercially available full and reduced wattage U-shaped lamps with 6-inch spacing that would meet the proposed standard in the NOPR for these products. CA IOUs also noted that of the 2-foot U-shaped offerings with 1
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-inch spacing, the majority of products were 31 W lamps, many of which met the standard level proposed in the NOPR analysis. Further, CA IOUs stated that there has to be a clear technical reason for design limitations for U-bend lamps of specific spacing to create separate product classes. They also noted that the 2-foot U-shaped lamps comprise a low market share that is shrinking as 2x2 fixtures are being converted to straight linear 2-foot lamps and therefore, manufacturers may not have developed an array of lamp offerings of varying efficacies. (CA IOU, No. 56 at p. 3)
DOE determines efficacy levels for 2-foot U-shaped lamps by reducing the efficacy levels of comparable 4-foot MBP lamps by an appropriate scaling
factor. DOE updated this scaling factor for the final rule analysis, see section VI.D.2.h for addition detail. In response to stakeholder comments, DOE reviewed the ability of 2-foot U-shaped lamps to comply with the highest efficacy level analyzed in this final rule, paying particular attention to the ability of both lamp spacings to comply. DOE determined that full wattage and reduced wattage versions of both lamp spacings are able to meet the highest efficacy level analyzed in the 2-foot U-shaped product class. Therefore, in this final rule, DOE did not establish separate product classes for the 1
5/8
-inch 2-foot U-shaped and 6-inch 2-foot U-shaped lamps.
b. Long-Life Lamps
DOE received comments that a separate product class for GSFLs with longer lifetimes than the standard lifetime may be needed. The longer life products are new on the market and mainly prevalent among the 4-foot MBP lamp types. NEMA commented that DOE should ensure that long-life lamps could meet the proposed standards or create a new product class for long-life lamps and report the associated analysis. (NEMA, No. 54 at p. 18) NEMA emphasized that the issue is that consumers are willing to pay a premium for long life (
e.g.,
80,000 hour) fluorescent lamps to avoid frequent lamp replacement. NEMA added that for many consumers long-life LEDs might not be an option due to first cost. (NEMA, Public Meeting Transcript, No. 49 at pp. 72-73) NEMA stated that long-life products offer utility for areas that are difficult to relamp, such as areas over assembly lines, or bridges and tunnels. Further, NEMA contended that design changes that permit much longer lifetimes have a net reduction in lumens/watt. When lumens per watt are increased lifetime is reduced and that increases the frequency of replacement, which in turn increases labor costs for replacement, increases the use of rare earth oxides in manufacturing, and increases mercury release. (NEMA, No. 54 at pp. 13-14)
GE noted that more lamps would be required to support lifetimes that may be half as long as common lifetimes for fluorescent lamps and this would also increase waste and costs to the manufacturer. GE also noted that elimination of long-life GSFLs would not result in energy savings as fluorescent lamps consume a steady amount of power from initial to mean to end life. (GE, Public Meeting Transcript, No. 49 at pp. 68-69, 73-74) Regarding a question on the market share of long-life GSFLs, OSI responded that because these products have only been recently introduced in the market it is difficult to determine and NEMA noted that it would try to obtain this data for DOE. (OSI, Public Meeting Transcript, No. 49 at p. 74; NEMA, Public Meeting Transcript, No. 49 at pp. 75-76)
EEOs remarked that although industry members proposed a separate product class for extra-long-life GSFLs with lifetimes of around 80,000 hours, these products are new on the market and it is unclear if a technical barrier exists preventing these lamps from meeting proposed standards. EEOs added that CA IOUs provided examples of reduced wattage extra-long-life 4-foot MBP lamps that would meet proposed levels. Further, EEOs agreed that extra-long-life lamps are cost effective, however, the negative impacts of a proposed level on life could be captured in DOE's economic analysis. (EEOs, No. 55 at pp. 6-7) The Northwest Energy Efficiency Alliance (NEEA) stated that it had not observed consumer concern for lifetime, noting more sales of less efficacious, long-life products. NEEA also noted that it was not possible to have both an efficacious and a good long lifetime product and expected this rulemaking to address the lifetime in the life-cycle cost analysis of the product. (NEEA, Public Meeting Transcript, No. 49 at pp. 77-79)
CA IOUs commented that a separate product class might be warranted for extra-long-life GSFLs if DOE finds a technical justification for reduced efficacy among these products. CA IOUs identified a variety of commercially available reduced wattage extra-long-life products with catalog efficacies that would pass DOE's proposed standard for 4-foot MBP lamps. Noting that these were reduced wattage lamps, CA IOUs added that if DOE is not able to identify full-wattage extra-long-life lamps that meet the proposed standards, and stakeholders present a technical justification with respect to design limitations preventing such products from being developed, a separate product class might be appropriate for this product type. However, CA IOUs noted that a standard for such a product class should be sufficiently stringent to avoid becoming a loophole. (CA IOU, No. 56 at pp. 3-4)
In response to stakeholder comments, DOE reviewed information about long life GSFLs from manufacturer interviews, product catalogs, and DOE's certification database. Manufacturer interviews indicated that it may be possible to increase the lifetime of fluorescent lamps by increasing the gas pressure, but that this may also decrease efficacy. DOE reviewed manufacturer catalog offerings and found that several manufacturers offered lamps that were marketed as “standard life” and also offered lamps that were marketed as “long life.” Catalog information generally indicated that the marketed long life lamps were less efficacious than comparable standard life lamps. Where available, certification data supported this trend. However, DOE notes that there is inconsistency in the industry regarding what actually constitutes a “long life” lamp. When comparing lamps offered by different manufacturers, one manufacturer's “long life” product may be offered with a lifetime very similar to that of another manufacturer's “standard life” product. Further, while DOE is aware that lifetime is a feature valued by consumers, DOE's analysis ensures that the lifetimes typically available at the baseline level are also available at higher efficacy levels (see section VI.D.2.g for more details). In this way, DOE's higher efficacy levels do not impact consumer utility and DOE accounts for any differences in lifetime as economic impacts in the LCC and NIA. Therefore, DOE did not establish separate product classes for long life GSFLs in this final rule analysis.
c. Summary of GSFL Product Classes
In this final rule analysis, DOE established product classes for GSFLs as summarized in Table VI.3. See chapter 3 of the final rule TSD for further details on each GSFL product class.
Table VI.3—GSFL Product Classes in Final Rule Analysis
Lamp type
CCT
4-foot medium bipin
≤4,500 K
>4,500 K
2-foot U-shaped
≤4,500 K
>4,500 K
8-foot single pin slimline
≤4,500 K
>4,500 K
8-foot recessed double contact high output
≤4,500 K
>4,500 K
4-foot T5, miniature bipin standard output
≤4,500 K
>4,500 K
4-foot T5, miniature bipin high output
≤4,500 K
>4,500 K
2. Incandescent Reflector Lamp Product Classes
In the NOPR analysis, DOE proposed product classes for IRLs based on the following three factors: (1) Rated voltage, separating lamps less than 125 V from lamps greater than or equal to 125 V; (2) lamp spectrum, separating lamps with a standard spectrum from lamps with a modified spectrum; and
(3) lamp diameter, separating lamps with a diameter greater than 2.5 inches from lamps with a diameter less than or equal to 2.5 inches. 79 FR at 24092 (April 29, 2014). DOE received comments on the rated voltage and modified spectrum product class setting factors. DOE did not receive feedback on the other product class divisions proposed for IRLs in the NOPR analysis.
a. Rated Voltage
In the NOPR analysis, DOE proposed rated voltage as a class setting factor, establishing a product class for IRLs with voltages less than 125 V and a product class for IRLs with voltages greater than or equal to 125 V. NEMA stated that DOE's reasoning for a separate 130 V product class was out of concern that consumers would shift to 130 V options that are less efficient than 120 V lamps resulting in increased energy consumption. However, NEMA noted that when operated at 120 V, a 60 W 130 V PAR38 uses less energy, approximately 54-55 W. Further, NEMA stated that since this decreases light output, consumers would not choose 130 V IRLs to `cheat' on energy conservation standards. (NEMA, No. 54 at p. 30)
DOE agrees that the 130 V lamp described by NEMA would use less energy when operated at 120 V. However, in the NOPR analysis and in this final rule DOE concludes that the corresponding decrease in light output would result in consumers purchasing additional lamps to maintain sufficient light.
79 FR
at 24093 (April 29, 2014). Therefore, setting higher standards for IRLs without accounting for voltage differences could result in increased energy consumption.
Westinghouse remarked that the absence of 130 V IRLs on the market has resulted in a loss in utility as 130 V IRLs were used to maintain product lifetimes in areas with transients, voltage spikes, and other power issues, and that consumers in those markets will have to buy more light bulbs due to voltage issues. Citing the 130 V lamps as an example, Westinghouse noted that in this rulemaking DOE has to be careful when setting new IRL standards that such unintended consequences do not happen as they cannot be fixed in the future due to the backsliding provision. (Westinghouse, Public Meeting Transcript, No. 49 at pp. 43-44)
DOE is aware that the 130 V lamps can provide a certain utility by lasting longer than 120 V lamps in certain areas that are susceptible to voltage spikes. However, based on its assessment that most consumers operate 130 V IRLs at 120 V and differences in efficacy when they are operated at 120 V versus tested at 130 V, DOE determined that there would be a potential migration to 130 V IRLs if they were subject to the same standards as 120 V IRLs and further that there would be additional purchases of 130 V IRLs by the consumer. Hence, in order to preserve energy savings, DOE maintained the rated voltage class division that separates covered IRLs less than 125 V from those that are greater than or equal to 125 V in this rulemaking. (See chapter 3 of the final rule TSD for further information.)
b. Modified Spectrum
Modified spectrum IRLs provide unique utility to consumers by providing a different type of light than standard spectrum lamps, much like fluorescent lamps with different CCT values. However, the same technologies (
i.e.,
coatings) that modify the spectral emission of a lamp also decrease lamp efficacy. Therefore, in the NOPR DOE proposed a product class division separating standard spectrum IRLs from modified spectrum IRLs. 79 FR at 24093 (April 29, 2014).
EEOs added that a separate product class for modified spectrum lamps may not be needed as more efficient technologies, such as CFLs and LEDs, are able to achieve the same utility and also due to the lack of commercially available modified spectrum lamps covered by the rulemaking. (EEOs, No. 55 at pp. 7-8) CA IOUs agreed that due to the limited number of modified spectrum IRLs on the market, the category should be eliminated. (CA IOUs, Public Meeting Transcript, No. 49 at p. 20) ASAP and CA IOUs concluded that there is no need to make an exemption or have a less efficacious standard for modified spectrum lamps. (ASAP, Public Meeting Transcript, No. 49 at pp. 17-18; CA IOUs, Public Meeting Transcript, No. 49 at p. 20) NEMA commented that modified spectrum lamps, like 130 V lamps, cannot remain both cost effective and compliant and referred DOE to manufacturer interviews for additional details. (NEMA, No. 54 at p. 31)
As in the NOPR, DOE continues to believe that modified spectrum lamps offer unique utility by providing a different spectrum of light. 79 FR at 24093 (April 29, 2014). Although more efficient technologies, such as CFLs and LEDs, may offer similar spectrums, DOE must maintain consumer utility for the products that are within the scope of this rulemaking. Modified spectrum IRLs modify the spectral emission of a lamp in such a way that lamp efficacy decreases. DOE acknowledges that there are currently no modified spectrum products on the market. However, DOE maintains that there are no technological barriers to creating these products. DOE does not consider cost when establishing product classes. Because modified spectrum lamps offer unique utility but at lower efficacy compared to standard spectrum products, DOE maintained the class division for lamp spectrum in this final rule.
c. Summary of IRL Product Classes
In this final rule analysis, DOE established product classes for IRLs as summarized in Table VI.4. See chapter 3 of the final rule TSD for further details on each IRL product class.
Table VI.4—IRL Product Classes in Final Rule Analysis
Lamp type
Diameter
(in inches)
Voltage
Standard Spectrum
>2.5
≥125 V
<125 V
≤2.5
≥125 V
<125 V
Modified Spectrum
>2.5
≥125 V
<125 V
≤2.5
≥125 V
<125 V
D. Engineering Analysis
1. General Approach
The engineering analysis is generally based on commercially available lamps that incorporate the design options identified in the technology assessment and screening analysis. (See chapters 3 and 4 of the final rule TSD for further information on technology and design options.) The methodology consists of the following steps: (1) Selecting representative product classes, (2) selecting baseline lamps, (3) identifying more efficacious substitutes, and (4) developing efficacy levels by directly analyzing representative product classes and then scaling those efficacy levels to non-representative product classes. The details of the engineering analysis are discussed in chapter 5 of the final rule TSD. The following discussion summarizes the general steps of the engineering analysis:
Representative product classes:
DOE first reviews covered lamps and the associated product classes. When a product has multiple product classes, DOE selects certain classes as “representative” and concentrates its analytical effort on these classes. DOE selects representative product classes primarily because of their high market volumes.
Baseline lamps:
For each representative product class, DOE selects a baseline lamp as a reference point against which to measure changes resulting from energy conservation standards. Typically, a baseline model is the most common, least efficacious lamp sold in a given product class. DOE also considers other lamp characteristics in choosing the most appropriate baseline for each product class such as wattage, lumen output, and lifetime.
More efficacious substitutes:
DOE selects higher efficacy lamps as replacements for each of the baseline models considered. When selecting higher efficacy lamps, DOE considers only design options that meet the criteria outlined in the screening analysis (see section VI.B or chapter 4 of the final rule TSD). For GSFLs, DOE pairs each lamp with an appropriate ballast because fluorescent lamps are a component of a system, and their performance is related to the ballast on which they operate.
Efficacy levels:
After identifying the more efficacious substitutes for each baseline lamp, DOE develops ELs. DOE bases its analysis on three factors: (1) The design options associated with the specific lamps studied; (2) the ability of lamps across wattages to comply with the standard level of a given product class;
26
and (3) the max tech EL. DOE then scales the ELs of representative product classes to those classes not directly analyzed.
26
ELs span multiple lamps of different wattages. In selecting ELs, DOE considered whether these multiple lamps can meet the standard levels.
DOE received a comment regarding the general methodology of the IRL engineering. GE recommended that DOE conduct two separate analyses for the commercial sector and residential sector. GE noted that lamps in the residential sector have shorter lifetimes, such as 1,500 hours, as they are used less frequently and therefore need to be replaced less often, especially if the lamps are on a dimmer. GE continued that the commercial sector requires longer lifetimes of 3,000 to 4,000 hours because lamps in commercial applications can be used up to 16 hours a day. GE stated that the analyses would be skewed between the two markets and that it would have a negative effect on the residential market as residential consumers with their shorter hours of operation are less likely to see the cost savings and payback that commercial consumers would be able to accrue. GE proposed the idea that the commercial and residential lamps could be differentiated by the typical applications, wattages, and technical aspects for each sector. For example, the PAR30 lamps could be treated as residential and PAR38 lamps as commercial. GE further commented that they understood that separating the lamps by sector could be difficult, but that the separation is necessary, as the proposed max tech levels applied across sectors would have the unintended consequences of removing certain utility and entire products from the market. (GE, Public Meeting Transcript, No. 49 at pp. 105-106, 116-117) NEEA agreed that separate analyses could be done for the commercial sector and for the residential sector. Alternatively, NEEA also suggested segregating the large commercial sector from the residential and small commercial sectors, such as independent, family-owned businesses and other consumers that purchase lighting similarly to homeowners. (NEEA, Public Meeting Transcript, No. 49 at p. 131)
DOE acknowledges that lamps have varying levels of penetration in different market sectors. However, there is nothing that would limit the use of a covered IRL in a specific sector. Therefore, DOE does not conduct sector-based assessments in the engineering analysis. Rather, the LCC analysis and NIA consider lamp use in different market sectors. The LCC analysis provides results for each analyzed lamp in each relevant sector. See section VII.B.1 for results of the IRL LCC analysis. The shipments analysis accounts for the number of shipments by sector and the popularity of analyzed lamps in each sector. The results are subsequently used in the NIA. See section VII.B.3 for results of the NIA. Further, as part of the engineering analysis, when selecting more efficacious substitutes and establishing efficacy levels, DOE ensures that products at higher efficacy levels meet baseline consumer needs. DOE's analysis of IRLs addresses the concerns regarding lifetime and product availability. See section VI.D.3 for further details. Therefore, DOE did not conduct separate engineering analyses by sector for IRLs.
Stakeholders had several comments specific to the GSFL and IRL engineering analyses presented in the NOPR. The following sections discuss and address feedback received from stakeholders for each product.
2. General Service Fluorescent Lamp Engineering
For GSFLs, DOE received several comments on the engineering analysis presented in the NOPR. The following sections summarize the comments and responses received on these topics, and present the GSFL engineering methodology for this final rule analysis.
a. Data Approach
Usability of Certification Data and Catalog Data
Because not all commercially available products had associated certification data, DOE was unable to rely solely on certification data in the preliminary analysis. At the time of the NOPR analysis, DOE's Compliance Certification Management System (CCMS) database
27
only contained data for 68 percent of the covered commercially available lamps. Therefore, in the NOPR analysis, DOE continued to utilize catalog data to identify baseline products and develop initial efficacy levels. DOE then used available certification data to adjust the initial efficacy levels so that the proposed levels could be met with efficacies submitted for certification.
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The publicly available compliance information for GSFLs can be found in DOE's compliance Certification Database available here:
www.regulations.doe.gov/certification-data/
.
NEMA commented that while catalog data is reviewed on a regul
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