Energy Conservation Program: Energy Conservation Standards for Ceiling Fan Light Kits
Federal RegisterAug 13, 2015
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DEPARTMENT OF ENERGY
10 CFR Part 430
[Docket Number EERE-2012-BT-STD-0045]
RIN 1904-AC87
Energy Conservation Program: Energy Conservation Standards for Ceiling Fan Light Kits
AGENCY:
Office of Energy Efficiency and Renewable Energy, Department of Energy.
ACTION:
Notice of proposed rulemaking (NOPR) and announcement of public meeting.
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 ceiling fan light kits (CFLKs). EPCA also requires the U.S. Department of Energy (DOE) to periodically determine whether more-stringent, amended standards would be technologically feasible and economically justified, and would save a significant amount of energy. In this notice, DOE proposes amended energy conservation standards for CFLKs, and also announces a public meeting to receive comment on these proposed standards and associated analyses and results.
DATES:
Meeting:
DOE will hold a public meeting on Tuesday, August 18, 2015 from 9:00 a.m. to 4:00 p.m., in Washington, DC. The meeting will also be broadcast as a webinar. See section VII, “Public Participation,” for webinar registration information, participant instructions, and information about the capabilities available to webinar participants.
Comments:
DOE will accept comments, data, and information regarding this NOPR before and after the public meeting, but no later than October 13, 2015. See section VII, “Public Participation,” for details.
ADDRESSES:
The public meeting will be held at the U.S. Department of Energy, Forrestal Building, Room 4A-104, 1000 Independence Avenue SW., Washington, DC 20585. Any foreign national wishing to participate in the meeting should advise DOE as soon as possible by contacting
regina.washington@ee.doe.gov
to initiate the necessary procedures. Please also note that any person wishing to bring a laptop into the Forrestal Building will be required to obtain a property pass. Visitors should avoid bringing laptops, or allow an extra 45 minutes. Persons may also attend the public meeting via webinar.
Instructions:
Any comments submitted must identify the NOPR on Energy Conservation Standards for ceiling fan light kits, and provide docket number EE-2012-BT-STD-0045 and/or regulatory information number (RIN) 1904-AC87. Comments may be submitted using any of the following methods:
1.
Federal eRulemaking Portal: www.regulations.gov.
Follow the instructions for submitting comments.
2.
Email: CeilingFanLightKits2012STD0045@ee.doe.gov.
Include the docket number and/or RIN in the subject line of the message. Submit electronic comments in WordPerfect, Microsoft Word, PDF, or ASCII file format, and avoid the use of special characters or any form of encryption.
3.
Postal Mail:
Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Office, Mailstop EE-5B, 1000 Independence Avenue SW., Washington, DC 20585-0121. If possible, please submit all items on a compact disc (CD), in which case it is not necessary to include printed copies.
4.
Hand Delivery/Courier:
Ms. Brenda Edwards, U.S. Department of Energy, Building Technologies Office, 950 L'Enfant Plaza, SW., Suite 600, Washington, DC 20024. Telephone: (202) 586-2945. If possible, please submit all items on a CD, in which case it is not necessary to include printed copies.
Written comments regarding the burden-hour estimates or other aspects of the collection-of-information requirements contained in this proposed rule may be submitted to Office of Energy Efficiency and Renewable Energy through the methods listed above and by email to
Chad_S_Whiteman@omb.eop.gov.
No telefacsimilies (faxes) will be accepted. For detailed instructions on submitting comments and additional information on the rulemaking process, see section VII of this document (“Public Participation”).
Docket:
The docket, which includes
Federal Register
notices, public meeting attendee lists and transcripts, comments, and other supporting documents/materials, is available for review at
www.regulations.gov.
All documents in the docket are listed in the
www.regulations.gov
index. However, some documents listed in the index may not be publicly available, such as those containing information that is exempt from public disclosure.
A link to the docket Web page can be found at:
www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/66.
This Web page contains a link to the docket for this notice on the
www.regulations.gov
site. The
www.regulations.gov
Web page contains simple instructions on how to access all documents, including public comments, in the docket. See section VII, “Public Participation,” for further information on how to submit comments through
www.regulations.gov.
FOR FURTHER INFORMATION CONTACT:
Ms. Lucy deButts, U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Building Technologies Office, EE-5B, 1000 Independence Avenue SW., Washington, DC 20585-0121. Telephone: (202) 287-1604. Email:
ceiling_fan_light_kits@ee.doe.gov.
Ms. Elizabeth Kohl, U.S. Department of Energy, Office of the General Counsel, GC-33, 1000 Independence Avenue SW., Washington, DC 20585-0121. Telephone: (202) 586-7796. Email:
Elizabeth.Kohl@hq.doe.gov.
For further information on how to submit a comment, review other public comments and the docket, or participate in the public meeting, contact Ms. Brenda Edwards at (202) 586-2945 or by email:
Brenda.Edwards@ee.doe.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Synopsis of the Proposed Rule
A. Benefits and Costs to Consumers
B. Impact on Manufacturers
C. National Benefits and Costs
D. Conclusion
II. Introduction
A. Authority
B. Background
1. Current Standards
2. History of Standards Rulemaking for CFLKs
III. General Discussion
A. Product Classes and Scope of Coverage
B. Test Procedure
1. Standby and Off-Mode Energy Consumption
C. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
D. Energy Savings
1. Determination of Savings
2. Significance of Savings
E. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Consumers
b. Savings in Operating Costs Compared to Increase in Price (LCC and PBP)
c. Energy Savings
d. Lessening of Utility or Performance of Products
e. Impact of Any Lessening of Competition
f. Need for National Energy Conservation
g. Other Factors
2. Rebuttable Presumption
IV. Methodology and Discussion of Related Comments
A. Market and Technology Assessment
1. Product Classes
2. Metrics
3. 190 W Limitation
4. Technology Options
B. Screening Analysis
1. Screened-Out Technologies
2. Remaining Technologies
C. Engineering Analysis
1. General Approach
2. Representative Product Classes
3. Baseline Lamps
4. More Efficacious Substitutes
5. Efficacy Levels
6. Scaling to Other Product Classes
D. Product Price Determination
E. Energy Use Analysis
1. Operating Hours
a. Residential Sector
b. Commercial Sector
2. Input Power
3. Lighting Controls
F. Life-Cycle Cost and Payback Period Analysis
1. Product Cost
2. Disposal Cost
3. Electricity Prices
4. Electricity Price Trends
5. Lamp Replacements
6. Product Lifetime
7. Residual Value
8. Discount Rates
9. Efficacy Distributions
10. LCC Savings Calculation
11. Payback Period Analysis
G. Shipments Analysis
H. National Impact Analysis
1. National Energy Savings
2. Net Present Value Analysis
I. Consumer Subgroup Analysis
J. Manufacturer Impact Analysis
1. Overview
2. GRIM Analysis and Key Inputs
a. Capital and Product Conversion Costs
b. Manufacturer Production Costs
c. Shipment Scenarios
d. Markup Scenarios
3. Discussion of Comments
4. Manufacturer Interviews
a. Duplicative Regulation
b. Shift to Air Conditioning
K. Emissions Analysis
L. Monetizing Carbon Dioxide and Other Emissions Impacts
1. Social Cost of Carbon
a. Monetizing Carbon Dioxide Emissions
b. Development of Social Cost of Carbon Values
c. Current Approach and Key Assumptions
2. Social Cost of Other Air Pollutants
M. Utility Impact Analysis
N. Employment Impact Analysis
V. 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. Indirect Impacts on Employment
4. Impact on Utility or Performance of Products
5. Impact of Any Lessening of Competition
6. Need of the Nation To Conserve Energy
7. Other Factors
8. Summary of National Economic Impacts
C. Conclusion
1. Benefits and Burdens of TSLs Considered for CFLK Standards
2. Summary of Annualized Benefits and Costs of the Proposed Standards
VI. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
1. Description on Estimated Number of Small Entities Regulated
2. Description and Estimate of Compliance Requirements
3. Duplication, Overlap, and Conflict With Other Rules and Regulations
4. Significant Alternatives to the Rule
C. Review Under the Paperwork Reduction Act
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Review Under the Information Quality Bulletin for Peer Review
VII. Public Participation
A. Attendance at the Public Meeting
B. Procedure for Submitting Prepared General Statements for Distribution
C. Conduct of the Public Meeting
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
VIII. Approval of the Office of the Secretary
I. Synopsis of the Proposed Rule
Title III, Part B
1
of the Energy Policy and Conservation Act of 1975 (EPCA or the Act) (42 U.S.C. 6291,
et. seq.
), established the Energy Conservation Program for Consumer Products Other Than Automobiles.
2
These products include CFLKs, the subject of this document.
1
For editorial reasons, upon codification in the U.S. Code, Part B was re-designated Part A.
2
All references to EPCA in this document refer to the statute as amended through the Energy Efficiency Improvement Act of 2015, Pub. L. 114-11 (Apr. 30, 2015).
Pursuant to EPCA, any new or amended energy conservation standard must be designed to achieve the maximum improvement in energy efficiency that is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, the new or amended standard must result in a significant conservation of energy. (42 U.S.C. 6295(o)(3)(B)) EPCA also provides that not later than 6 years after issuance of any final rule establishing or amending a standard, DOE must publish either a notice of determination that standards for the product do not need to be amended, or a notice of proposed rulemaking including new proposed energy conservation standards. (42 U.S.C. 6295(m)(1))
In accordance with these and other statutory provisions discussed in this document, DOE proposes amended energy conservation standards for CFLKs. The proposed standards, which are expressed in minimum lumen output per watt (lm/W) of a lamp, or lamp efficacy, are shown in Table I.1. These proposed standards, if adopted, would apply to all CFLKs listed in Table I.1 and manufactured in, or imported into, the United States on and after the date three years after the publication of any final rule for this rulemaking.
Table I.1—Proposed Energy Conservation Standards for Ceiling Fan Light Kits
Product type
Lumens
Proposed level
(lm/W)
All CFLKs
<120
50
>120
74−29.42 × 0.9983
lumens
A. Benefits and Costs to Consumers
Table I.2 presents DOE's evaluation of the economic impacts of the proposed standards on consumers of CFLKs, as measured by the average life-cycle cost (LCC) savings and the simple payback period (PBP).
3
The average LCC savings are positive for the product class, and the PBP is less than the average lifetime of CFLKs, which is estimated to be 13.8 years (see section IV.F).
3
The average LCC savings are measured relative to the no-standards case efficacy distribution, which depicts the market in the compliance year in the absence of standards (see section IV.F.9). The simple PBP, designed to compare specific efficacy levels, is measured relative to the least efficient model on the market (see section IV.F).
Table I.2—Impacts of Proposed Energy Conservation Standards on Consumers of CFLKs (TSL 2)
Product class
Average LCC
savings
(2014$)
Simple
payback
period
(years)
Residential Sector
All CFLKs
24.3
1.2
Commercial Sector
All CFLKs
53.4
0.3
DOE's analysis of the impacts of the proposed standards on consumers is described in section IV.F of this notice.
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 2048). Using a real discount rate of 7.4 percent, DOE estimates that the INPV for manufacturers of CFLKs in the no-standards case is $94.8 million in 2014$. Under the proposed standards, DOE expects that manufacturers may lose up to 8.4 percent of this INPV, which is approximately $7.9 million. Additionally, based on DOE's interviews with the manufacturers of CFLKs, DOE does not expect significant impacts on manufacturing capacity or loss of employment for the industry as a whole to result from the proposed standards for CFLKs.
DOE's analysis of the impacts of the amended standards on manufacturers is described in section IV.J of this notice.
C. National Benefits and Costs
4
4
All monetary values in this section are expressed in 2014 dollars and, where appropriate, are discounted to 2015 unless explicitly stated otherwise. Energy savings in this section refer to the full-fuel-cycle savings (see section IV.H for discussion).
DOE's analyses indicate that the proposed energy conservation standards for CFLKs would save a significant amount of energy. Relative to the case where no amended energy conservation standard is set (hereinafter referred to as the “no-standards case”), the lifetime energy savings for CFLKs purchased in the 30-year period that begins in the anticipated year of compliance with the amended standards (2019-2048) amount to 0.047 quadrillion Btu (quads).
5
This represents a savings of 3.6 percent relative to the energy use of these products in the no-standards case.
5
A quad is equal to 10
15
British thermal units (Btu).
The cumulative net present value (NPV) of total consumer costs and savings of the proposed standards for CFLKs ranges from $0.65 billion (at a 7-percent discount rate) to $0.82 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 CFLKs purchased in 2019-2048.
In addition, the proposed standards for CFLKs would have significant environmental benefits. DOE estimates that the proposed standards would result in cumulative emission reductions of 3.3 million metric tons (Mt)
6
of carbon dioxide (CO
2
), 3.5 thousand tons of sulfur dioxide (SO
2
), 4.7 thousand tons of nitrogen oxides (NO
X
), 11.2 thousand tons of methane (CH
4
), 0.037 thousand tons of nitrous oxide (N
2
O), and 0.011 tons of mercury (Hg).
7
The cumulative reduction in CO
2
emissions through 2030 amounts to 3.08 Mt, which is equivalent to the emissions resulting from the annual electricity use of almost 400 thousand homes.
6
A metric ton is equivalent to 1.1 short tons. Results for emissions other than CO
2
are presented in short tons.
7
DOE calculated emissions reductions relative to the no-standards case, which reflects key assumptions in the
Annual Energy Outlook 2014
(
AEO 2014
) Reference case.
AEO 2014
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.
8
The derivation of the SCC values is discussed in section IV.L. Using discount rates appropriate for each set of SCC values (see Table I.3), DOE estimates the present monetary value of the CO
2
emissions reduction (not including CO
2
equivalent emissions of other gases with global warming potential) is between $0.03 billion and $0.40 billion, with a value of $0.13 billion using the central SCC case represented by $41.2/t in 2015. DOE also estimates the present monetary value of the NO
X
emissions reduction to be $0.02 billion at a 7-percent discount rate and $0.03 billion at a 3-percent discount rate.
9
8
Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866,
Interagency Working Group on Social Cost of Carbon, U.S. Government (May 2013; revised November 2013) (Available at:
http://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbon-for-regulator-impact-analysis.pdf).
9
DOE is currently investigating valuation of avoided SO
2
and Hg emissions.
Table I.3 summarizes the national economic benefits and costs expected to result from the proposed standards for CFLKs.
Table I.3—Summary of National Economic Benefits and Costs of Proposed Energy Conservation Standards for CFLKs (TSL 2) *
Category
Present value
(billion 2014$)
Discount rate
(%)
Benefits
Consumer Operating-Cost Savings
0.56
0.73
7
3
CO
2
Reduction Monetized Value ($12.2/t case) **
0.03
5
CO
2
Reduction Monetized Value ($41.2/t case) **
0.13
3
CO
2
Reduction Monetized Value ($63.4/t case) **
0.21
2.5
CO
2
Reduction Monetized Value ($121/t case) **
0.40
3
NO
X
Reduction Monetized Value
0.02
0.02
7
3
Total Benefits †
0.71
0.89
7
3
Costs
Consumer Incremental Installed Costs
0.06
0.07
7
3
Total Net Benefits:
Including Emissions Reduction Monetized Value †
0.65
0.82
7
3
* This table presents the costs and benefits associated with CFLKs shipped in 2019-2048. These results include benefits to consumers which accrue after 2048 from the products purchased in 2019-2048. The results account for the incremental variable and fixed costs incurred by manufacturers due to the standard, some of which may be incurred in preparation for the rule.
** The CO
2
values represent global monetized values of the SCC, in 2014$, 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 ($41.2/t case).
The benefits and costs of the proposed standards, for CFLKs sold in 2019-2048, can also be expressed in terms of annualized values. The annualized monetary values are the sum of: (1) The annualized national economic value of the benefits from consumer operation of products that meet the new or amended standards (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 2015, the year used for discounting the NPV of total consumer costs and savings. For the benefits, DOE calculated a present value associated with each year's shipments in the year in which the shipments occur (
e.g.,
2020 or 2030), and then discounted the present value from each year to 2015. The calculation uses discount rates of 3 and 7 percent for all costs and benefits except for the value of CO
2
reductions, for which DOE used case-specific discount rates, as shown in Table I.3. Using the present value, DOE then calculated the fixed annual payment over a 30-year period, starting in the compliance year, that yields the same present value.
Although combining the values of operating savings and CO
2
emission reductions is relevant to DOE's determination, two issues should be considered. First, the national operating savings are domestic U.S. consumer monetary savings that occur as a result of market transactions, 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 CFLKs shipped in 2019-2048. Because CO
2
emissions have a very long residence time in the atmosphere,
11
the SCC values after 2050 reflect future climate-related impacts resulting from the emission of CO
2
that continue beyond 2100.
11
The atmospheric lifetime of CO
2
is estimated of the order of 30-95 years. Jacobson, MZ (2005), “Correction to `Control of fossil-fuel particulate black carbon and organic matter, possibly the most effective method of slowing global warming,' ”
J. Geophys. Res.
110. pp. D14105.
Estimates of annualized benefits and costs of the proposed standards are 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 average SCC series that has a value of $41.2/t in 2015), the estimated cost of the standards proposed in this rule is $6.0 million per year in increased equipment costs, while the estimated annual benefits are $55 million in reduced equipment operating costs, $7.5 million in CO
2
reductions, and $1.6 million in reduced NO
X
emissions. In this case, the net benefit amounts to $59 million per year. Using a 3-percent discount rate for all benefits and costs and the average SCC series that has a value of $41.2/t in 2015, the estimated cost of the proposed CFLK standards is $4.0 million per year in increased equipment costs, while the estimated annual benefits are $41 million in reduced operating costs, $7.5 million in CO
2
reductions, and $1.3 million in reduced NO
X
emissions. In this case, the net benefit amounts to $46 million per year.
Table I.4—Annualized Benefits and Costs of Proposed Energy Conservation Standards for CFLKs (TSL 2)
Discount rate
(million 2014$/year)
Primary
estimate *
Low net
benefits
estimate *
High net
benefits
estimate *
Benefits
Consumer Operating-Cost Savings
7%
3%
55
41
36
24
59
43
CO
2
Reduction Monetized Value ($12.2/t case) *
5%
2.6
1.4
2.7
CO
2
Reduction Monetized Value ($41.2/t case) *
3%
7.5
3.9
7.9
CO
2
Reduction Monetized Value ($63.4/t case) *
2.5%
11
5
11
CO
2
Reduction Monetized Value ($112.1/t case) *
3%
22
12
24
NO
X
Reduction Monetized Value
7%
3%
1.6
1.3
0.90
0.65
1.6
1.3
Total Benefits †
7% plus CO
2
range
60 to 79
38 to 48
63 to 85
7%
65
40
69
3% plus CO
2
range
45 to 64
26 to 36
47 to 68
3%
49
28
53
Costs
Consumer Incremental Installed Product Costs
7%
3%
6.0
4.0
3.5
2.3
6.4
4.2
Net Benefits
Total †
7% plus CO
2
range
54 to 73
34 to 44
57 to 78
7%
59
37
62
3% plus CO
2
range
41 to 60
24 to 34
43 to 64
3%
46
26
48
* This table presents the annualized costs and benefits associated with CFLKs shipped in 2019-2048. These results include benefits to consumers which accrue after 2048 from the products purchased in 2019-2048. The results account for the incremental variable and fixed costs incurred by manufacturers due to the standard, some of which may be incurred in preparation for the rule. The Primary Estimate assumes the reference case electricity prices and housing starts from
AEO 2015
and decreasing product prices for LED CFLKs, due to price learning. The Low Benefits Estimate uses the Low Economic Growth electricity prices and housing starts from
AEO 2015
and a faster decrease in product prices for LED CFLKs. The High Benefits Estimate uses the High Economic Growth electricity prices and housing starts from
AEO 2015
and the same product price decrease for LED CFLKs as in the Primary Estimate.
** The CO
2
values represent global monetized values of the SCC, in 2014$, in 2015 under several scenarios of the updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 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 the average SCC with a 3-percent discount rate ($41.2/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.
DOE's analysis of the national impacts of the proposed standards is described in sections IV.H, IV.K and IV.L of this notice.
D. Conclusion
DOE has tentatively concluded that the proposed standards represent the maximum improvement in energy efficiency that is technologically feasible and economically justified, and would result in the significant conservation of energy. DOE further notes that products achieving these standard levels are already commercially available for all product classes covered by this proposal. Based on the analyses described above, DOE has tentatively concluded that the benefits of the proposed standards to the nation (energy savings, positive NPV of consumer benefits, consumer LCC savings, and emission reductions) would outweigh the burdens (loss of INPV for manufacturers and LCC increases for some consumers).
DOE also considered more- and less-stringent efficacy levels (EL)s as trial standard levels, and is still considering them in this rulemaking. However, DOE has tentatively concluded that the potential burdens of the more-stringent ELs would outweigh the projected benefits. Based on consideration of the public comments DOE receives in response to this notice and related information collected and analyzed during the course of this rulemaking effort, DOE may adopt ELs presented in this notice that are either higher or lower than the proposed standards, or some combination of level(s) that incorporate the proposed standards in part.
II. Introduction
The following section briefly discusses the statutory authority underlying this proposed rule, as well as some of the relevant historical background related to the establishment of standards for CFLKs.
A. Authority
Title III, Part B of EPCA, 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 CFLKs that are the subject of this rulemaking. (42 U.S.C. 6295(ff)) EPCA, as amended, authorized DOE to conduct future rulemakings to determine whether to amend these standards. (42 U.S.C. 6295(ff)(5)-(6)) Under 42 U.S.C. 6295(m), DOE must also periodically review its already established energy conservation standards 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. 6295(o)(3)(A) and (r)) Manufacturers of covered products must use the prescribed DOE test procedure as the basis for certifying to DOE that their products comply with the applicable energy conservation standards adopted under EPCA and when making representations to the public regarding the energy use or efficiency of those products. (42 U.S.C. 6293(c) and 6295(s)) Similarly, DOE must use these test procedures to determine whether the products comply with standards adopted pursuant to EPCA. (42 U.S.C. 6295(s)) The DOE test procedures for CFLKs appear at title 10 of the Code of Federal Regulations (CFR) part 430, subpart B, appendix V.
DOE must follow specific statutory criteria for prescribing new or amended standards for covered products, including CFLKs. Any new or amended standard for a covered product must be designed to achieve the maximum improvement in energy efficiency that is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A) and (3)(B)) Furthermore, DOE may not adopt any standard that would not result in the significant conservation of energy. (42 U.S.C. 6295(o)(3)) Moreover, DOE may not prescribe a standard: (1) For certain products, including CFLKs, if no test procedure has been established for the product, or (2) if DOE determines by rule that the standard is not technologically feasible or economically justified. (42 U.S.C. 6295(o)(3)(A)-(B)) In deciding whether a proposed standard is economically justified, DOE must determine whether the benefits of the standard exceed its burdens. (42 U.S.C. 6295(o)(2)(B)(i)) DOE must make this determination after receiving comments on the proposed standard, and by considering, to the greatest extent practicable, the following seven statutory factors:
(1) The economic impact of the standard on manufacturers and consumers of the products subject to the standard;
(2) The savings in operating costs throughout the estimated average life of the covered products in the type (or class) compared to any increase in the price, initial charges, or maintenance expenses for the covered products that are likely to result from the standard;
(3) The total projected amount of energy (or as applicable, water) savings likely to result directly from the standard;
(4) Any lessening of the utility or the performance of the covered products likely to result from the standard;
(5) The impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to result from the standard;
(6) The need for national energy and water conservation; and
(7) Other factors the Secretary of Energy (Secretary) considers relevant. (42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))
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. (42 U.S.C. 6295(o)(2)(B)(iii))
Additionally, 42 U.S.C. 6295(q)(1) specifies requirements when promulgating an energy conservation standard for a covered product that has two or more subcategories. DOE must specify a different standard level for a type or class of product that has the same function or intended use, if DOE determines that products within such group: (A) Consume a different kind of energy from that consumed by other covered products within such type (or class); or (B) have a capacity or other performance-related feature which other products within such type (or class) do not have and such feature justifies a higher or lower standard. (42 U.S.C. 6295(q)(1)) In determining whether a performance-related feature justifies a different standard for a group of products, DOE must consider such factors as the utility to the consumer of the feature and other factors DOE deems appropriate.
Id.
Any rule prescribing such a standard must include an explanation of the basis on which such higher or lower level was established. (42 U.S.C. 6295(q)(2))
Federal energy conservation requirements generally supersede state laws or regulations concerning energy conservation testing, labeling, and standards. (42 U.S.C. 6297(a)-(c)) DOE may, however, grant waivers of Federal preemption for particular state laws or regulations, in accordance with the procedures and other provisions set forth under 42 U.S.C. 6297(d)).
EPCA also requires that any final rule for new or amended energy conservation standards promulgated after July 1, 2010, is required to address standby mode and off-mode energy use. (42 U.S.C. 6295(gg)(3)) Specifically, when DOE adopts a standard for a covered product after that date, it must, if justified by the criteria for adoption of standards under EPCA (42 U.S.C. 6295(o)), incorporate standby mode and off-mode energy use into a single standard, or, if that is not feasible, adopt a separate standard for such energy use for that product. (42 U.S.C. 6295(gg)(3)(A)-(B)) In a test procedure NOPR for ceiling fan light kits (hereafter “CFLK TP NOPR”), DOE proposed that the energy use from standby mode and off mode associated with CFLKs be attributed to the ceiling fan to which they are attached, and thus any standby mode energy use is accounted for in the ceiling fan test procedure. Therefore, the CFLK metric accounts for energy consumption only in active mode. 79 FR 64688 (October 31, 2014). DOE will account for active mode energy use in any final amended energy conservation standards.
B. Background
1. Current Standards
The current energy conservation standards apply to CFLKs with medium screw base and pin-based sockets manufactured on and after January 1, 2007, and CFLKs with all other socket types manufactured on or after January 1, 2009. 70 FR 60407, 60413 (October 18, 2005). These standards are set forth in DOE's regulations at 10 CFR 430.32(s) as follows:
(2)(i) Ceiling fan light kits with medium screw base sockets manufactured on or after January 1, 2007, must be packaged with screw-based lamps to fill all screw base sockets.
(ii) The screw-based lamps required under paragraph (2)(i) of this section must—
(A) Be compact fluorescent lamps that meet or exceed the following requirements or be as described in paragraph (2)(ii)(B) of this section:
Factor
Requirements
Rated Wattage (Watts) & Configuration
1
Minimum Initial Lamp Efficacy (lumens per watt).
2
Bare Lamp:
Lamp Power <15
45.0.
Lamp Power ≥15
60.0.
Covered Lamp (no reflector):
Lamp Power <15
40.0.
15 ≤ Lamp Power <19
48.0.
19 ≤ Lamp Power <25
50.0.
Lamp Power ≥25
55.0.
With Reflector:
Lamp Power <20
33.0.
Lamp Power ≥20
40.0.
Lumen Maintenance at 1,000 hours
≥90.0%.
Lumen Maintenance at 40 Percent of Lifetime
≥80.0%.
Rapid Cycle Stress Test
At least 5 lamps must meet or exceed the minimum number of cycles.
Lifetime
≥6,000 hours for the sample of lamps.
1
Use rated wattage to determine the appropriate minimum efficacy requirements in this table.
2
Calculate efficacy using measured wattage, rather than rated wattage, and measured lumens to determine product compliance. Wattage and lumen values indicated on products or packaging may not be used in calculation.
(B) Light sources other than compact fluorescent lamps that have lumens per watt performance at least equivalent to comparably configured compact fluorescent lamps meeting the energy conservation standards in paragraph (2)(ii)(A) of this section.
(3) Ceiling fan light kits manufactured on or after January 1, 2007, with pin-based sockets for fluorescent lamps must use an electronic ballast and be packaged with lamps to fill all sockets. These lamp ballast platforms must meet the following requirements:
Factor
Requirement
System Efficacy per Lamp Ballast Platform in Lumens per Watt (lm/w)
≥50 lm/w for all lamps below 30 total listed lamp watts.
≥60 lm/w for all lamps that are ≤24 inches and ≥30 total listed lamp watts.
≥70 lm/w for all lamps that are >24 inches and ≥30 total listed lamp watts.
(4) Ceiling fan light kits with socket types other than those covered in paragraphs (2) and (3) of this section, including candelabra screw base sockets, manufactured on or after January 1, 2009—
(i) Shall not be capable of operating with lamps that total more than 190 watts; and
(ii) Shall be packaged to include the lamps described in clause (i) with the ceiling fan light kits. 10 CFR 430.32(s)
2. History of Standards Rulemaking for CFLKs
Current energy conservation standards for CFLKs (42 U.S.C. 6295(ff)) were established by the Energy Policy Act of 2005 (EPAct 2005) (Title I, Subtitle C, section 135(c)), which were later amended by EPCA. Specifically, EPAct 2005 established individual energy conservation standards for three groups of CFLKs: (1) Those having medium screw base sockets (hereafter “Medium Screw Base product class”); (2) those having pin-based sockets for fluorescent lamps (hereafter “Pin-Based product class”); and (3) any CFLKs other than those included in the Medium Screw Base product class or the Pin-Based product class (hereafter “Other Base Type product class”). (42 U.S.C. 6295(ff)(2)-(4)) In a technical amendment published on October 18, 2005, DOE codified the statute's requirements for the Medium Screw Base and Pin-Based product classes. 70 FR 60413. EPAct 2005 also specified that if DOE failed to issue a final rule on energy conservation standards for Other Base Type product class CFLKs by January 1, 2007, a 190 W limit would apply to those products. (42 U.S.C. 6295(ff)(4)(C)) Because DOE did not issue a final rule on standards for CFLKs by that date, on January 11, 2007, DOE published a technical amendment that codified the statute's requirements for Other Base Type product class CFLKs, which applied to Other Base Type product class CFLKs manufactured on or after January 1, 2009. 72 FR 1270. Another technical amendment final rule published on March 3, 2009 (74 FR 12058), added a provision that CFLKs with sockets for pin-based fluorescent lamps must be packaged with lamps to fill all sockets. (42 U.S.C. 6295(ff)(4)(C)(ii)) These standards for CFLKs are codified in 10 CFR 430.32(s)(2)-(4).
To initiate the rulemaking cycle to consider amended energy conservation standards for ceiling fans and CFLKs, on March 15, 2013, DOE published a notice announcing the availability of the framework document, “Energy Conservation Standards Rulemaking Framework Document for Ceiling Fans and Ceiling Fan Light Kits,” 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 ceiling fans and CFLKs.
DOE held the public meeting for the framework document on March 22, 2013,
12
to present the framework document, describe the analyses DOE 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.
12
The framework document and public meeting information are available at regulations.gov under docket number EERE-2012-BT-STD-0045-0001.
DOE issued the preliminary analysis for the CFLK energy conservation standards rulemaking on October 27, 2014, and published it in the
Federal Register
on October 31, 2014. 78 FR 13563. DOE posted the preliminary analysis, as well as the complete preliminary technical support document (TSD), on its Web site.
13
The preliminary TSD includes the results of the following DOE preliminary analyses: (1) Market and technology assessment; (2) screening analysis; (3) engineering analysis; (4) energy use analysis; (5) product price determination; (6) LCC and PBP analyses; (7) shipments analysis; (8) national impact analysis (NIA); and (9) preliminary manufacturer impact analysis (MIA).
13
The preliminary analysis, preliminary TSD, and preliminary analysis public meeting information are available at regulations.gov under docket number EERE-2012-BT-STD-0045-0072.
III. General Discussion
DOE developed this proposal after considering comments, data, and information from interested parties that represent a variety of interests. The following discussion addresses issues raised by these commenters.
A. Product Classes and Scope of Coverage
EPCA defines a “ceiling fan light kit” as “equipment designed to provide light from a ceiling fan that can be: (1) Integral, such that the equipment is attached to the ceiling fan prior to the time of retail sale; or (2) attachable, such that at the time of retail sale the equipment is not physically attached to the ceiling fan, but may be included inside the ceiling fan at the time of sale or sold separately for subsequent attachment to the fan.”
14
(42 U.S.C. 6291(50)(A), (B)) In the CFLK TP NOPR, DOE proposed to withdraw the current guidance
15
on accent lighting and to consider all lighting packaged with any CFLK to be subject to energy conservation requirements. 79 FR 64688, 64692 (October 31, 2014). Additionally, in the ceiling fan test procedure NOPR published on October 17, 2014, DOE proposed to reinterpret the definition of a ceiling fan to include hugger fans. 79 FR 62521, 62525-26 (October 17, 2014). For additional details on DOE's reasoning for proposing these changes, please see the proposed rulemaking documents.
14
Ceiling fan is defined as “a nonportable device that is suspended from a ceiling for circulating air via the rotation of fan blades.” (42 U.S.C. 6291(49))
15
Guidance on accent lighting is available at
www1.eere.energy.gov/guidance/detail_search.aspx?IDQuestion=470&pid=2&spid=1.
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 of the feature to the consumer and other factors DOE determines are appropriate. (42 U.S.C. 6295(q)) For further details on product classes, see section IV.A.1 and chapter 3 of the NOPR TSD.
B. Test Procedure
EPCA sets forth generally applicable criteria and procedures for DOE's adoption and amendment of test procedures. (42 U.S.C. 6293) Manufacturers of covered products must use these test procedures to certify to DOE that their product complies with energy conservation standards and to quantify the efficiency of their product. As noted, the test procedures for CFLKs are provided in appendix V. As noted, DOE published a NOPR to amend these test procedures on October 31, 2014. 79 FR 64688.
With respect to the process of establishing test procedures and standards for a given product, DOE notes that, while not legally obligated to do so, it generally follows the approach laid out in guidance found in 10 CFR part 430, subpart C, Appendix A (Procedures, Interpretations and Policies for Consideration of New or Revised Energy Conservation Standards for Consumer Products). That guidance provides, among other things, that, when necessary, DOE will issue final, modified test procedures for a given product prior to publication of the NOPR proposing energy conservation standards for that product. While DOE strives to follow the procedural steps outlined in its guidance, there may be circumstances in which it may be necessary or appropriate to deviate from it. In such instances, the guidance indicates that DOE will provide notice and an explanation for the deviation. Accordingly, DOE is providing notice that it continues to develop the final test procedure for CFLKs. DOE received comment on the proposed test procedure regarding the applicability of the CFLK test procedures and energy conservation standards to accent lighting. DOE also received comments on the appropriate metric for CFLKs with integrated SSL circuitry. DOE continues to consider those comments in the development of the final test procedure rule. DOE will attempt to issue the final test procedure within the comment period provided for this proposed standards rule. In the event that additional time to comment on the proposed standards in light of the final test procedure rule is desired, interested parties can seek an extension or reopening of the comment period upon issuance of the final test procedure.
1. Standby and Off-Mode Energy Consumption
EPCA directs DOE to update its test procedures to account for standby mode and off-mode energy consumption, with such energy consumption integrated into the overall energy efficiency, energy consumption, or other energy descriptor, unless the current test procedure already accounts for standby mode and off-mode energy use. (42 U.S.C. 6295(gg)(2)(A)) Furthermore, if an integrated test procedure is technically infeasible, DOE must prescribe a separate standby mode and off-mode test procedure for the covered product, if technically feasible.
In the preliminary analysis, DOE determined that energy use from standby mode and off mode associated with CFLKs be attributed to the ceiling fan to which they are attached. DOE's research indicates that standby power is relevant only to combined ceiling fan and light kit systems operated by remote control. The remote control receiver, which is almost always installed in the ceiling fan housing and used to receive signals for both the ceiling fan and the CFLK, is the component that constitutes the standby power consumption in the ceiling fan and light kit system. DOE therefore proposed to account for standby power in the ceiling fan test procedures. 79 FR 64688, 64690 (October 31, 2014). DOE further notes if standby mode were included into a single metric for CFLKs with remote controls, the CFLK would have a different efficacy than its lamps. Therefore, DOE has proposed to only include active mode energy
consumption in the CFLK test procedure. Id. See the preliminary analysis TSD or the CFLK TP NOPR for further details.
Based on its review of products currently on the market, DOE concludes that CFLKs do not consume power in off mode. Therefore DOE did not propose to measure off-mode power consumption in the ceiling fan light kit test procedure rulemaking.
C. Technological Feasibility
1. General
In each energy conservation standards rulemaking, DOE conducts a screening analysis based on information gathered on all current technology options and prototype designs that could improve the efficiency of the products or equipment that are the subject of the rulemaking. As the first step in such an analysis, DOE develops a list of technology options for consideration in consultation with manufacturers, design engineers, and other interested parties. DOE then determines which of those means for improving efficiency are technologically feasible. DOE considers technologies incorporated in commercially available products or in working prototypes to be technologically feasible. 10 CFR part 430, subpart C, appendix A, section 4(a)(4)(i).
After DOE has determined that particular technology options are technologically feasible, it further evaluates each technology option in light of the following additional screening criteria: (1) Practicability to manufacture, install, and service; (2) adverse impacts on product utility or availability; and (3) adverse impacts on health or safety. 10 CFR part 430, subpart C, appendix A, section 4(a)(4)(ii)-(iv). Additionally, it is DOE policy not to include in its analysis any proprietary technology that is a unique pathway to achieving a certain EL. Section IV.B of this notice discusses the results of the screening analysis for CFLKs, 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 NOPR TSD.
2. Maximum Technologically Feasible Levels
When DOE proposes to adopt an amended standard for a type or class of covered product, it must determine the maximum improvement in energy efficiency or maximum reduction in energy use that is technologically feasible for such product. (42 U.S.C. 6295(p)(1)) Accordingly, in the engineering analysis, DOE determined the maximum technologically feasible (“max-tech”) improvements in energy efficiency for CFLKs, using the design parameters for the most efficient products available on the market or in working prototypes. The max-tech levels that DOE determined for this rulemaking are described in section IV.C.5 of this proposed rule and in chapter 5 of the NOPR TSD.
D. Energy Savings
1. Determination of Savings
For each TSL, DOE projected energy savings from the CFLKs that are the subject of this rulemaking purchased in the 30-year period that begins in the year of compliance with any amended standards (2019-2048).
16
The savings are measured over the entire lifetime of CFLKs purchased in the above 30-year period. DOE quantified the energy savings attributable to each TSL as the difference in energy consumption between each standards case and the no-standards case. The no-standards case represents a projection of energy consumption in the absence of amended energy conservation standards, and it considers market forces and policies 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.
DOE used its NIA spreadsheet model to estimate energy savings from potential amended standards for CFLKs. The NIA spreadsheet model (described in section IV.H 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 calculates national energy savings on an annual basis in terms of primary energy savings, which is the savings in the energy that is used to generate and transmit the site electricity. To calculate primary energy savings from site electricity savings, DOE derives annual conversion factors from data provided in the Energy Information Administration's (EIA) most recent
Annual Energy Outlook
(
AEO
).
In addition to primary energy savings, DOE also calculates full-fuel-cycle (FFC) energy savings. As discussed in DOE's statement of policy, the FFC metric includes the energy consumed in extracting, processing, and transporting primary fuels (
i.e.,
coal, natural gas, petroleum fuels), and thus presents a more complete picture of the impacts of energy conservation standards. 76 FR 51282 (August 18, 2011), as amended at 77 FR 49701 (August 17, 2012). DOE's approach is based on the calculation of an FFC multiplier for each of the energy types used by covered products or equipment. For more information, see section IV.H.1.
2. Significance of Savings
To adopt any new or amended standards for a covered product, DOE must determine that such action would result in “significant” energy savings. (42 U.S.C. 6295(o)(3)(B)) Although the term “significant” is not defined in the Act, the U.S. Court of Appeals for the District of Columbia Circuit, in
Natural Resources Defense Council
v.
Herrington,
768 F.2d 1355, 1373 (D.C. Cir. 1985), opined that Congress intended “significant” energy savings in the context of EPCA to be savings that were not “genuinely trivial.” The energy savings for all of the TSLs considered in this rulemaking, including the proposed standards (presented in section IV.H.1), are nontrivial, and, therefore, DOE considers them “significant” within the meaning of section 325 of EPCA.
E. 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)(I)-(VII)) The following sections discuss how DOE has addressed each of those seven factors in this rulemaking.
a. Economic Impact on Manufacturers and Consumers
In determining the impacts of a potential amended standard on manufacturers, DOE conducts an MIA, as discussed in section IV.J. DOE first uses an annual cash-flow approach to determine the quantitative impacts. This step includes both a short-term assessment—based on the cost and capital requirements during the period between when a regulation is issued and when entities must comply with the regulation—and a long-term assessment over a 30-year period. The industry-wide impacts analyzed include: (1) INPV, which values the industry on the basis of expected future cash flows; (2) cash flows by year; (3) changes in revenue and income; and (4) other measures of impact, as appropriate. Second, DOE analyzes and reports the impacts on different types of manufacturers, including impacts on small manufacturers. Third, DOE considers the impact of standards on domestic manufacturer employment and
manufacturing capacity, as well as the potential for standards to result in plant closures and loss of capital investment. Finally, DOE takes into account cumulative impacts of various DOE regulations and other regulatory requirements on manufacturers.
For individual consumers, measures of economic impact include the changes in LCC and payback period (PBP) associated with new or amended standards. These measures are discussed further in the following section. For consumers in the aggregate, DOE also calculates the national NPV of the consumer costs and benefits expected to result from particular standards. DOE also evaluates the impacts of potential standards on identifiable subgroups of consumers that may be affected disproportionately by a standard.
b. Savings in Operating Costs Compared to Increase in Price (LCC and PBP)
EPCA requires DOE to consider the savings in operating costs throughout the estimated average life of the covered product in the type (or class) compared to any increase in the price of, or in the initial charges for, or maintenance expenses of, the covered product that are likely to result from a standard. (42 U.S.C. 6295(o)(2)(B)(i)(II)) DOE conducts this comparison in its LCC and PBP analysis.
The LCC is the sum of the purchase price of a product (including its installation) and the operating expense (including energy, maintenance, and repair expenditures) discounted over the lifetime of the product. The LCC analysis requires a variety of inputs, such as product prices, product energy consumption, energy prices, maintenance and repair costs, product lifetime, and consumer discount rates. 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. The PBP is the estimated amount of time (in years) it takes consumers to recover the increased purchase cost of a more-efficient product through lower operating costs. DOE calculates the PBP by dividing the change in purchase cost by the initial change in annual operating cost for the year that standards are assumed to take effect.
For its LCC and PBP analysis, DOE assumes that consumers will purchase the covered products in the first year of compliance with amended standards. The LCC savings for the considered ELs are calculated relative to a no-standards case that reflects projected market trends in the absence of amended standards. DOE's LCC and PBP analysis is discussed in further detail in section IV.F.
c. Energy Savings
Although significant conservation of energy is a separate statutory requirement for adopting an energy conservation standard, EPCA requires DOE, in determining the economic justification of a standard, to consider the total projected energy savings that are expected to result directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) As discussed in section III.D.1, DOE uses the NIA spreadsheet models to project national energy savings.
d. Lessening of Utility or Performance of Products
In establishing product classes and in evaluating design options and the impact of potential standard levels, DOE evaluates potential standards that would not lessen the utility or performance of the considered products. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) Based on data available to DOE, the standards proposed in this notice would not reduce the utility or performance of the products under consideration in this rulemaking.
e. Impact of Any Lessening of Competition
EPCA directs DOE to consider the impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to result from a proposed standard. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It also directs the Attorney General to determine the impact, if any, of any lessening of competition likely to result from a proposed standard and to transmit such determination to the Secretary within 60 days of the publication of a proposed rule, together with an analysis of the nature and extent of the impact. (42 U.S.C. 6295(o)(2)(B)(ii)) DOE will transmit a copy of this proposed rule to the Attorney General with a request that the Department of Justice (DOJ) provide its determination on this issue. DOE will publish and respond to the Attorney General's determination in the final rule.
f. Need for National Energy Conservation
DOE also considers the need for national energy conservation in determining whether a new or amended standard is economically justified. (42 U.S.C. 6295(o)(2)(B)(i)(VI)) The energy savings from the proposed standards are likely to provide improvements to the security and reliability of the nation's energy system. Reductions in the demand for electricity also may result in reduced costs for maintaining the reliability of the nation's electricity system. DOE conducts a utility impact analysis to estimate how standards may affect the nation's needed power generation capacity, as discussed in section IV.M.
The proposed standards also are likely to result in environmental benefits in the form of reduced emissions of air pollutants and greenhouse gases (GHGs) associated with energy production and use. DOE conducts an emissions analysis to estimate how potential standards may affect these emissions, as discussed in section IV.K; the emissions impacts are reported in section V.C.2 of this notice. DOE also estimates the economic value of emissions reductions resulting from the considered TSLs, as discussed in section IV.L.
g. Other Factors
EPCA allows the Secretary of Energy, in determining whether a standard is economically justified, to consider any other factors that the Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII)) To the extent interested parties submit any relevant information regarding economic justification that does not fit into the other categories described above, DOE could consider such information under “other factors.”
2. Rebuttable Presumption
As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA creates a rebuttable presumption that an energy conservation standard is economically justified if the additional cost to the consumer of a product that meets the standard is less than three times the value of the first year's energy savings resulting from the standard, as calculated under the applicable DOE test procedure. DOE's LCC and PBP analyses generate values used to calculate the effects that proposed energy conservation standards would have on the payback period for consumers. These analyses include, but are not limited to, the 3-year payback period contemplated under the rebuttable-presumption test. In addition, DOE routinely conducts an economic analysis that considers the full range of impacts to consumers, manufacturers, the nation, and the environment, as required under 42 U.S.C. 6295(o)(2)(B)(i). The results of this analysis serve as the basis for DOE's evaluation of the economic justification for a potential standard level (thereby supporting or rebutting the results of any preliminary determination of
economic justification). The rebuttable-presumption payback calculation is discussed in section IV.F of this proposed rule.
IV. Methodology and Discussion of Related Comments
This section addresses the analyses DOE has performed for this rulemaking with regard to CFLKs. Separate subsections address each component of DOE's analyses.
DOE used several analytical tools to estimate the impact of the standards proposed in this document. The first tool is a spreadsheet that calculates the LCC and PBP of potential amended or new energy conservation standards. The NIA uses a second spreadsheet set that provides shipments forecasts and calculates national energy savings and NPV resulting from potential energy conservation standards. DOE uses the third spreadsheet tool, the Government Regulatory Impact Model (GRIM), to assess manufacturer impacts of potential standards. These three spreadsheet tools are available on the DOE Web site for this rulemaking:
http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/66.
Additionally, DOE used output from the latest version of EIA's
AEO,
a widely known energy forecast for the United States, for the emissions and utility impact analyses.
A. Market and Technology Assessment
DOE develops information in the market and technology assessment that provides an overall picture of the market for the products concerned, including the purpose of the products, the industry structure, manufacturers, market characteristics, and technologies used in the products. This activity includes both quantitative and qualitative assessments, based primarily on publicly available information. (See chapter 3 of the NOPR TSD for further discussion of the market and technology assessment.) DOE received comments regarding product classes, the metric to determine the energy efficiency of CFLKs, and technology options identified that can improve the efficiency of CFLKs. Responses to these comments are discussed in the following sections.
1. Product Classes
DOE divides covered products into classes by: (a) The type of energy used; (b) the capacity of the product; or (c) other performance-related features that justify different standard levels, considering the consumer utility of the feature and other relevant factors. (42 U.S.C. 6295(q)) The current product class structure for CFLKs, which was established by EPACT 2005, divides CFLKs into three product classes: CFLKs with medium screw base (E26) sockets (Medium Screw Base product class), CFLKs with pin-based sockets for fluorescent lamps (Pin-Based product class), and any CFLKs other than those in the Medium Screw Base or Pin-Based product classes (Other Base Type product class). In the preliminary analysis, DOE restructured the current three CFLK product classes to the following two product classes: (1) CFLKs with Externally Ballasted or Driven Lamps and (2) All Other CFLKs. DOE received several comments related to the restructuring of product classes.
ASAP noted that they support DOE's proposed adjustments to the product class structure. (ASAP, Public Meeting Transcript, No. 82 at p. 85)
17
In a joint comment, ASAP, the American Council for an Energy-Efficient Economy, the National Resources Defense Council, and the Northwest Energy Efficiency Alliance (hereafter the “Joint Comment”) specified that changing the product class structure in this way would correct unintended market distortions caused by the original CFLK standards. The Joint Comment continued that as CFLKs all use the same type of energy, do not have different capabilities requiring different energy conservation standards, and can provide a full range of illumination with different socket types equipped with light-emitting diode (LED) lamps or compact fluorescent lamps (CFLs), they support DOE's redefinition of product classes. (Joint Comment, No. 95 at pp. 1-2) Available information indicates that all CFLKs use the same type of energy and different socket types do not represent dissimilar capacities or require different standard levels. Therefore, as in the preliminary analysis, DOE proposes not to define CFLK product classes by socket type.
17
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 CFLKs (Docket No. EERE-2012-BT-STD-0045), which is maintained at
www.regulations.gov.
This notation indicates that the statement preceding the reference was made by ASAP, is included in a public meeting transcript, is from document number 82 in the docket, and appears at page 85 of that document.
The Joint Comment did recommend, however, that DOE reconsider establishing a separate product class for externally ballasted or driven CFLKs. The Joint Comment noted that the market share of these products is small and is unlikely to grow due to the difficulty for consumers in diagnosing ballast or driver failure and finding the correct replacements. (Joint Comment, No. 95 at p. 2) The Minka Group and Lamps Plus agreed that with externally driven CFLKs, consumers will replace the entire CFLK rather than change a failed ballast. (The Minka Group, Public Meeting Transcript, No. 82 at p. 155; Lamps Plus, Public Meeting Transcript, No. 82 at p. 156) Emerson Electric noted that consumers are often unable to replace a ballast because the model is no longer available from the manufacturer, and thus consumers select a new CFLK instead. (Emerson Electric, Public Meeting Transcript, No. 82 at p. 156)
DOE also received comments that externally driven solid-state lighting (SSL) CFLKs (
i.e.,
with LED module and driver systems) typically do not come with consumer replaceable parts. Emerson Electric commented that they offer an LED array with an integrated driver and heat sink as a repair part. (Emerson Electric, Public Meeting Transcript, No. 82 at pp. 105-106) Hunter Fans commented that only the serviceable driver can be replaced in the SSL CFLKs that they offer. (Hunter Fans, Public Meeting Transcript, No. 82 at p. 219) Westinghouse Lighting (Westinghouse) commented that their limited offerings of integrated SSL CFLKs did not include consumer replaceable parts. Westinghouse noted that in the commercial marketplace, while there is interest in replaceable drivers and modules, it is unclear if manufacturers are planning to offer drivers and modules as consumer replaceable parts instead of repair parts. (Westinghouse, Public Meeting Transcript, No. 82 at pp. 106; 218-219) Further, Westinghouse noted that replacing an externally driven fluorescent lamp with an externally driven LED lamp would require an entire CFLK change, as they were unaware of any retrofit LED lamps for pin-based lamps. (Westinghouse, No. 82 at p. 157) Westinghouse added that this product class is only 1 percent or less of the market. (Westinghouse, No. 82 at p. 157) As a result of the market's reluctance to embrace externally ballasted or driven products, The Joint Comment questioned whether this product group provides a distinct utility. (Joint Comment, No. 95 at p. 2)
In the preliminary analysis, DOE placed externally ballasted or driven lamps in a separate product class based on their unique utility in that they allow consumers to replace the lamp, and potentially the ballast or driver, separately if one fails independently of the other. However, feedback from stakeholders and interviews with manufacturers indicated that most consumers of CFLKs will typically replace both the lamp and ballast/driver
system or the entire CFLK rather than a failed component. Thus, DOE no longer identified the externally ballasted or driven lamps as providing a unique utility to consumers, and is not proposing a separate product class for these lamp types in the NOPR.
DOE received comments regarding maintaining a separate product class for CFLKs with sockets other than medium screw base lamps and pin-based fluorescent lamps. The Joint Comment noted that most CFLKs used medium screw base lamps prior to the previous CFLK standards, but once the existing standard set separate product classes and thereby different requirements for CFLKs with medium screw base sockets, those with pin-based sockets, and those with all other sockets, manufacturers switched to producing CFLKs with all other sockets, specifically candelabra and intermediate-base sockets. The Joint Comment stated that the switch to these small bases has decreased the anticipated savings of the previous CFLK standards, and also the impact of the previous general service lamp (GSL) standards. The Joint Comment noted that current CFLK sales are 80 percent intermediate and candelabra based sockets, even though there is no utility advantage over medium screw base sockets. (Joint Comment, No. 95 at p. 1)
Westinghouse disagreed, stating that the two product classes considered in the preliminary analysis make sense from the lamp manufacturer perspective, but limit design options for fan manufacturers. (Westinghouse, Public Meeting Transcript, No. 82 at pp. 117, 129) Westinghouse asserted that consumers look for fashion and style in CFLKs and therefore design is a utility that is met by different types of CFLKs. Westinghouse reported that medium screw base lamps are usually A-shape lamps and physically larger, whereas candelabra-base lamps are typically bullet, flame, or B-shape lamps, which fulfill a decorative purpose rather than providing improved efficacy or light output. Westinghouse also noted that halogen lamps with specialty bases, such as E11 and bipin, are able to provide a lot of light in very small spaces. (Westinghouse, Public Meeting Transcript, No. 82 at pp. 121-123)
Finally, American Lighting Association (ALA) commented that the All Other CFLKs product class would eliminate incandescent and halogen lamps in CFLKs. ALA and Westinghouse asserted that more efficacious substitutes, such as CFLs and LED lamps, currently do not serve as adequate replacements for the halogen lamps, especially those with smaller or specialty bases. Specifically, ALA and Westinghouse noted that it is difficult for LED lamps to have the same lumen package and lifetime as existing candelabra based lamps in CFLKs in the same small space without issues such as heat dissipation, especially while also meeting proposed efficacy standards. (ALA, No. 93 at p. 8; Westinghouse, Public Meeting Transcript, No. 82 at p. 100) Westinghouse noted that to use the LED lamps currently on the market, an entire luminaire design would be required to adequately dissipate heat. (Westinghouse, Public Meeting Transcript, No. 82 at pp. 121-123)
While Westinghouse noted that LED lamps will soon be able to meet these challenges, they expressed concern about finalizing a rulemaking that requires products that are not yet equivalent to existing lamps. (Westinghouse, Public Meeting Transcript, No. 82 at p. 100) Hunter Fans commented that they agree with Westinghouse's concerns with design utility being adversely affected by the use of more efficacious light sources in CFLKs. (Hunter Fans, Public Meeting Transcript, No. 82 at p. 124) ALA noted that CFLK manufacturers have no control over the rate of LED technology advancement. (ALA, No. 93 at p. 8) NEMA stated that there can be a predilection towards moving to solely LED technology due to ELs, but while LED technology is feasible in the smaller lamp sizes, the market is very small and few manufacturers have moved to supply LED options. NEMA continued that this may be the same issue with the ceiling fan industry. (NEMA, Public Meeting Transcript, No. 82 at pp. 115-116) Westinghouse commented that DOE needs to make sure that less efficient candelabra bases and small profile SSL options are viable for manufacturers and priced at an acceptable level for consumers if DOE stays with a two product class system. (Westinghouse, Public Meeting Transcript, No. 82 at pp. 116-177, 138)
Based on an evaluation of lamp efficacies reported in manufacturer catalogs, DOE has determined that small base LED lamps are currently available at the highest ELs proposed. (See section IV.C.4 for further details on this analysis.) DOE has found that these small base lamps have lifetimes at or above that of the baseline lamp selected in the engineering analysis. (See section IV.C.3 for further details on the baseline lamp selected.) While the lumen package of these small base LED lamps may not be comparable to small base halogen lamps, modifications in the CFLK design (
e.g.,
number of sockets) can achieve the targeted light output regardless of the lamp used. DOE also confirmed, based on information in manufacturer catalogs and product specifications, that there are commercially available small base lamps available at the highest proposed efficacy level and these lamps are marketed as being suitable for use in enclosed spaces. Thus, issues such as heat dissipation should not be a concern.
In this NOPR, DOE is proposing one product class for CFLKs, including CFLKs packaged with all lamp types, regardless of socket type, and CFLKs with consumer replaceable or non-consumer-replaceable LED modules and drivers.
Summary of CFLK Product Classes
In summary, DOE is no longer considering a separate product class for externally ballasted or driven lamps in CFLKs, as the ability to change the ballast/driver or lamp when one of these components fail rather than replacing the entire system is not a utility to consumers. Upon further analysis, DOE did not identify any class setting factors for CFLKs that use a different type of energy, offer a different capacity of the product, or provide unique performance-related features to consumers, and thereby warrant a separate product class. Therefore, in this NOPR analysis, DOE is proposing a single “All CFLKs” product class. (See chapter 3 of the NOPR TSD for further details on the CFLK product class.) DOE requests comment on the product class structure proposed in this document.
2. Metrics
In the preliminary analysis, DOE indicated that it is considering using luminous efficacy as the efficiency metric for all CFLKs. DOE considered using lamp efficacy where possible, and using luminaire efficacy where the lamp component in the CFLK is not designed to be consumer replaceable from the CFLK (
i.e.,
for CFLKs with SSL circuitry, such as those with inseparable LED lighting).
ASAP expressed support for the use of lamp efficacy as the primary metric. (ASAP, Public Meeting Transcript, No. 82 at p. 85) Westinghouse initially agreed with using lamp efficacy as the efficiency metric for CFLKs and luminaire efficacy for CFLKs with integrated SSLs. Specifically, Westinghouse approved of the method for this rulemaking, given current practices and test procedures, and suggested that DOE wait until industry or ENERGY STAR developed an alternative to adopt something else. (Westinghouse, Public Meeting Transcript, No. 82 at p. 59) However,
upon further reflection, Westinghouse remarked that integrated SSLs should use the system efficacy, or “light engine efficacy,” based on IES LM-79. Westinghouse noted that this method would be less expensive and burdensome for manufacturers. Westinghouse added that products without existing test procedures would still use luminaire efficacy. (Westinghouse, No. 82 at pp. 81-82)
In the NOPR, DOE continued to base its analysis on luminous efficacy as the efficiency metric for CFLKs. DOE used lamp efficacy where possible and luminaire efficacy where the lamp component in the CFLK is not designed to be consumer replaceable from the CFLK. As proposed in the CFLK TP NOPR (79 FR 64688, 64694 [October 31, 2014]), IES LM-79-08 would be used to test the luminaire efficacy of CFLKs with integrated SSL circuitry (
i.e.,
light sources, drivers, or intermediate circuitry that is not consumer replaceable). DOE determined that for CFLKs with integrated SSL circuitry, luminaire efficacy was an appropriate metric because either destructive disassembly would be required to determine the lamp efficacy or, where non-destructive disassembly was possible, lamp efficacy measurements may not be consistent or accurate. 79 FR 64688, 64693, 64703-64704 (October 31, 2014).
Westinghouse noted that while an efficacy metric was acceptable, due to the combination of the existing product classes, the proposed standards may need to allow for more flexibility. (Westinghouse, Public Meeting Transcript, No. 82 at pp. 58-59) The proposed standards account for the effects of the product class combination. DOE established the baseline level as discussed in section IV.C.3. DOE then evaluated each efficacy level to determine if it is technologically feasible and economically justified.
ALA stated that DOE's position to not include the energy savings potential of lighting controls might not be valid. ALA noted that lighting controls can be as powerful as efficacy in generating energy savings. ALA followed that DOE should be open to new test procedures for incorporating the energy savings of lighting controls. (ALA, Public Meeting Transcript, No. 82 at pp. 118-119)
DOE notes that CFLKs are not typically integrated with and/or sold with all components necessary to utilize lighting controls. Further, when a CFLK is set up to function with lighting controls, the use of controls is dependent on various factors, thereby making it difficult to generate consistent and repeatable results across product types that can be measured to a single standard. Therefore, DOE is not proposing to include lighting controls in the efficacy metric for CFLKs. However, DOE did assess various factors related to the use of controls and conducted an analysis to determine potential energy savings from controls. See section IV.E.3 for further information on energy savings from lighting controls.
Westinghouse commented that lifetime testing is burdensome for CFLK manufacturers because of the time associated with the testing, especially because product development of CFLKs trails the development of lamps. (Westinghouse, Public Meeting Transcript, No. 82 at pp. 141-142) Additionally, ALA remarked that lifetime should not be a metric because CFLK manufacturers have limited control over lamp performance, but that if it is included, the standard should be 10,000 hours. ALA added that DOE can harmonize with ENERGY STAR Program Requirements for Lamps version 1.1, which specifies 10,000 hours for all CFLs and 15,000 hours for decorative LED lamps. (ALA, No. 93 at pp. 9, 12)
Current standards specify that CFLKs packaged with medium screw base CFLs must also meet the ENERGY STAR Program requirements for Compact Fluorescent Lamps, version 3.0. The additional requirements specify a minimum lifetime of 6,000 hours. DOE is proposing to maintain this requirement for medium screw base CFLs packaged with CFLKs.
3. 190 W Limitation
Current standards require that CFLKs with medium screw base sockets, or pin-based sockets for fluorescent lamps, be packaged with lamps that meet certain efficiency requirements. All other CFLKs must not be capable of operating with lamps that exceed 190 W. In the final rule for energy conservation standards for certain CFLKs published on January 11, 2007, DOE interpreted this 190 W limitation requirement as a statutory requirement to incorporate an electrical device or measure that ensures the light kit is not capable of operating with a lamp or lamps that draw more than a total of 190 W. 72 FR 1270, 1271 (Jan. 11, 2007).
Westinghouse questioned whether the 190 W limitation was needed in CFLKs with candelabra or intermediate-base lamps, noting that EPACT limits candelabra lamps to 60 W and intermediate-base lamps to 40 W, and thus a CFLK with three or fewer sockets would never have a total wattage exceeding 190 W. (Westinghouse, Public Meeting Transcript, No. 82 at pp. 50-51) CFLKs, however, can have more than three sockets, and there are socket adapters available that can enable the use of medium base lamps in sockets intended for candelabra lamps. As a result, DOE has determined that the EPACT wattage restrictions on candelabra and intermediate-base lamps provides an insufficient basis for DOE to remove the 190 W limit requirement.
ALA stated that DOE should eliminate the 190 W limit for CFLKs with SSL technology or recognize that as such CFLKs use a fixed number of LEDs and a current-limiting device, they meet the 190 W limitation requirement by design. (ALA, Public Meeting Transcript, No. 82 at pp. 16, 42) The Minka Group asked for clarification on whether an LED driver counts as a wattage limiting device. (The Minka Group, Public Meeting Transcript, No. 82 at p. 39) ALA requested that DOE clarify that the design of a CFLK, with such an SSL system that (1) has an SSL driver and/or SSL light source that is not designed to be consumer replaceable; (2) has a rated wattage of 190 W or fewer; and (3) does not use any other light source, meets the requirement of an electrical device or measure that renders the CFLK incapable of operating lamps that total more than 190 W. (ALA, No. 93 at pp. 1-2, 4; ALA, No. 102 at pp. 1-4)
ALA provided several arguments supporting its recommendation. Noting that SSL technology is highly efficient, ALA stated that a 190 W SSL system in a CFLK would provide too much light for a typical consumer and manufacturers generally offer CFLKs with SSL systems rated at no more than 50 W. ALA also stated that the SSL driver, light source, and thermal management system are designed to operate together at the rated wattage and attempts to operate the system at a higher wattage would result in failure of these parts. Specifically, ALA commented that the thermal management system cannot be modified to handle the additional heat from operating at higher wattages. Thus, ALA concluded the SSL electrical and thermal system design acts as an electrical device or measure that limits the power the CFLK can draw, and the systems inherently limit the power that can be consumed during operation. (ALA, No. 93 at pp. 1-2, 4; ALA, No. 102 at p. 2)
ALA also argued that as long as either the SSL driver and/or light source are not consumer replaceable, the CFLK cannot be operated at a wattage higher than the rated wattage. ALA explained that the SSL light source and driver must match in terms of the design wattage or the system will fail.
Therefore, if the consumer replaceable part is replaced to operate the system above the rated wattage, the non-consumer replaceable part must also be replaced, which would require destructive disassembly. ALA stated that this would be beyond the capability of a typical consumer and would invalidate the CFLK's manufacturer warranty and Underwriters Laboratories (UL) listing. (ALA, No. 93 at pp. 1-2; ALA, No. 102 at p. 3) ALA also provided figures of a CFLK with SSL technology that consumes fewer than 20 W. In these figures, ALA noted that the CFLK has a non-consumer replaceable thermal management system that is customized for the CFLK and a consumer replaceable LED driver that is customized for the CFLK. (ALA, No. 93 at pp. 2-3; ALA, No. 102 at pp. 3-4)
Available information indicates that in some scenarios, CFLKs with only SSL technology could be considered to be inherently current limiting. These scenarios are (1) neither SSL drivers and nor SSL light sources are consumer replaceable, (2) SSL drivers are non-replaceable but SSL light sources are replaceable, and (3) SSL light sources are non-replaceable but SSL drivers are replaceable. In the scenario where the CFLK has a consumer replaceable SSL light source, once the light source is replaced with one that can operate at a higher wattage, the non-replaceable SSL driver would act as a limiting device and not allow the system to operate higher than the rated wattage. In the scenario where the consumer replaceable SSL driver is replaced with a driver that can operate at a higher wattage, rapid failure of the SSL light source would likely occur as it would be operated beyond the current, voltage, and/or temperature design limits. Moreover, significant increases in the rated wattage of drivers result in significant size increases in the drivers and the physical constraints of CFLK designs would not allow for such modification. Further, requiring that no other light source besides the SSL system be included in the CFLK would prevent any other means of operating the CFLK at a wattage higher than the rated wattage. Therefore, DOE proposes that CFLKs with SSL circuitry that (1) have SSL drivers and/or light sources that are not consumer replaceable, (2) do not have both an SSL driver and light source that are consumer replaceable, (3) do not include any other light source, and (4) include SSL drivers with a maximum operating wattage of no more than 190 W are considered to incorporate some electrical device or measure that ensures they do not exceed the 190 W limit. DOE proposes to incorporate this clarification in this rulemaking.
DOE is also considering whether all CFLKs with SSL circuitry should be determined to not exceed the 190 W limit. DOE seeks comment on this approach.
4. Technology Options
The technology assessment identifies technology options that improve CFLK efficacy. This assessment provides the technical background and structure on which DOE bases its screening and engineering analyses. The technology assessment begins with a description of the basic structure and operation of CFLKs and then develops a list of technology options considered in the screening analysis.
In the preliminary analysis, DOE identified more efficacious light sources as the technology option that could increase CFLK efficacy. In the preliminary analysis, DOE considered but decided not to include lighting controls and luminaire designs as technology options. Regarding lighting controls, DOE determined that CFLK controls are mostly manual (dimming or multi-level) that can be operated by remote control or at the wall switch and are usually combined with those of the ceiling fan into a single device. The CFLK TP does not provide test procedures for measuring energy savings from controls used on CFLKs, nor is such data available at a comprehensive level for the residential sector. DOE decided not to consider luminaire designs as a technology option because the metric of efficiency for CFLKs proposed in this rulemaking is lamp efficacy, and only in certain cases where lamp efficacy test procedures cannot be used is luminaire efficacy required (see section IV.A.2 for further details.) ALA and Westinghouse agreed with DOE's decision to consider more efficacious lamps as a technology option, and not to include lighting controls. (ALA, No. 93 at p. 8; Westinghouse, Public Meeting Transcript, No. 82 at pp. 113-115) ALA also agreed with DOE's decision not to include luminaire design as a technology option. (ALA, No. 93 at p. 8)
In the NOPR analysis, DOE broke down the more efficacious light sources technology option into specific technology options to identify the different mechanisms for increasing the efficacy of lamps packaged with CFLKs. DOE reviewed manufacturer catalogs, recent trade publications, technical journals, and patent filings to identify these technology options.
For CFLs, DOE is considering technology options related to improvements in electrode coatings, fill gas, phosphors, glass coatings, cold spot optimization, and ballast components. For LED lamps, DOE is considering technology options related to improvements in down converters, package architectures, emitter materials, substrate materials, thermal interface materials, heat sink design, thermal management, device-level optics, light utilization, driver design, and electric current.
Summary of CFLK Technology Options
In summary, DOE has developed the list of technology options shown in Table IV.1 to increase efficacy of CFLKs. See chapter 3 of the NOPR TSD for more information on the proposed CFLK technology options. DOE requests comment on the CFL and LED technology options being proposed for CFLKs and any additional options that should be included.
Table IV.1—CFLK Technology Options
Lamp type
Name of technology option
Description
CFL
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
Techniques to increase the conversion of ultraviolet (UV) light into visible light.
Glass Coatings
Coatings on inside of bulb enable the phosphors to absorb more UV energy, so that they emit more visible light.
Multi-Photon Phosphors
Emitting more than one visible photon for each incident UV photon.
Cold Spot Optimization
Improve cold spot design to maintain optimal temperature and improve light output.
Improved Ballast Components
Use of higher-grade components to improve efficiency of integrated ballasts.
Improved Ballast Circuit Design
Better circuit design to improve efficiency of integrated ballasts.
Change in Technology
Replace CFL with LED technology.
LED
Efficient Down Converters
New high-efficiency wavelength conversion materials, including optimized phosphor conversion, quantum-dots and nano-phosphors, have the potential for creating warm-white LED emitters with improved spectral efficiency, high color quality, and improved thermal stability.
Improved Package Architectures
Novel package architectures such as RGB+, system-in-package, hybrid color, and chip-on-heat-sink have the potential to improve thermal management, color-efficiency, and optical distribution, as well as electrical integration to greatly improve overall lamp and luminaire efficacy.
Improved Emitter Materials
The development of efficient red, green, or amber LED emitters, will allow for optimization of spectral efficiency with high color quality over a range of CCT and which also exhibit color and efficiency stability with respect to operating temperature.
Alternative Substrate Materials
Alternative substrates such as gallium nitride (GaN), silicon (Si), GaN-on-Si, and silicon carbide to enable high-quality epitaxy for improved device quality and efficacy.
Improved Thermal Interface Materials (TIM)
Develop TIMs that enable high-efficiency thermal transfer for long-term reliability and performance optimization of the LED device and overall lamp product.
Optimized Heat Sink Design
Improve thermal conductivity and heat dissipation from the LED chip, thus reducing efficacy loss from rises in junction temperature.
Active Thermal Management Systems
Devices such as internal fans, vibrating membranes, and circulated liquid cooling systems to improve thermal dissipation from the LED chip.
Device-Level Optics
Enhancements to the primary optic of the LED package that would simplify or remove entirely the secondary optic, and thereby reduce losses due to absorption at interfaces.
Increased Light Utilization
Reduce optical losses from the lamp housing, diffusion, beam shaping and color-mixing to increase the efficacy of the LED lamp.
Improved Driver Design
Increase driver efficiency through novel and intelligent circuit design.
AC LEDs
Reduce or eliminate the requirements of a driver and therefore the effect of driver efficiency on lamp efficacy.
Reduced Current Density
Increase the number of LEDs in a lamp to reduce current density while maintaining lumen output. This reduces the efficiency losses associated with higher current density.
B. Screening Analysis
DOE uses the following four screening criteria to determine which technology options are suitable for further consideration in an energy conservation standards rulemaking:
1.
Technological feasibility.
Technologies that are not incorporated in commercial products or in working prototypes will not be considered further.
2.
Practicability to manufacture, install, and service.
If it is determined that mass production and reliable installation and servicing of a technology in commercial products could not be achieved on the scale necessary to serve the relevant market at the time of the projected compliance date of the standard, then that technology will not be considered further.
3.
Impacts on product utility or product availability.
If it is determined that a technology would have significant adverse impact on the utility of the product to significant subgroups of consumers or would 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 be considered further.
4.
Adverse impacts on health or safety.
If it is determined that a technology would have significant adverse impacts on health or safety, it will not be considered further.
10 CFR part 430, subpart C, appendix A, 4(a)(4) and 5(b).
If DOE determines that a technology, or a combination of technologies, fails to meet one or more of the above four criteria, it will be excluded from further consideration in the engineering analysis.
1. Screened-Out Technologies
In the preliminary analysis, DOE did not screen out more efficacious light sources as a technology option because more efficacious light sources were found to be commercially available products that met the four screening criteria. ALA stated that they agreed with the screening analysis, and DOE did not receive any further comments on retaining more efficacious light sources as a design option. (ALA, No. 93 at p. 9)
In the NOPR, as noted, DOE identified the specific technologies underlying more efficacious light sources. Of these technology options, several technology options were screened out based on the four screening criteria. Table IV.2 summarizes the technology options DOE is proposing to screen out and the associated screening criteria.
Table IV.2—CFLK Technology Options Screened Out of the Analysis
Technology
Design option excluded
Screening criteria
CFL
Multi-Photon Phosphors
Technological feasibility.
LED
Colloidal Quantum Dot Phosphors
Technological feasibility.
Improved Emitter Materials
Technological feasibility.
2. Remaining Technologies
Through a review of each technology, DOE tentatively concludes that all of the other identified technologies listed in section IV.A.3 meet all four screening criteria to be examined further as design options in DOE's NOPR analysis. In summary, DOE did not screen out the following technology options:
CFL Design Options
• Highly Emissive Electrode Coatings
• Higher-Efficiency Lamp Fill Gas Composition
• Higher-Efficiency Phosphors
• Glass Coatings
• Cold Spot Optimization
• Improved Ballast Components
• Improved Ballast Circuit Design
LED Design Options
• Efficient Down Converters (with the exception of colloidal quantum-dots phosphors)
• Improved Package Architectures
• Alternative Substrate Materials
• Improved Thermal Interface Materials
• Optimized Heat Sink Design
• Active Thermal Management Systems
• Device-Level Optics
• Increased Light Utilization
• Improved Driver Design
• AC LEDs
• Reduced Current Density
DOE determined that these technology options are technologically feasible because they are being used in commercially available products or working prototypes. DOE also finds that all of the remaining technology options meet the other screening criteria (
i.e.,
practicable to manufacture, install, and service and do not result in adverse impacts on consumer utility, product availability, health, or safety). (See chapter 4 of the NOPR TSD for further details on the CFLK screening analysis.)
C. Engineering Analysis
DOE derives ELs in the engineering analysis and consumer prices in the product price determination. By combining the results of the engineering analysis and the product price determination, DOE derives typical inputs for use in the LCC and NIA.
1. General Approach
The engineering analysis is generally based on commercially available lamps that incorporate the design options identified in the technology assessment and screening analysis. (See chapters 3 and 4 of the NOPR TSD for further information on technology and design options.) The methodology consists of the following steps: (1) Selecting representative product classes, (2) selecting baseline lamps, (3) identifying more efficacious substitutes, and (4) developing ELs by directly analyzing representative product classes and then scaling those ELs to non-representative product classes. The details of the engineering analysis are discussed in chapter 5 of the NOPR TSD. The following discussion summarizes the general steps of the engineering analysis:
Representative product classes:
DOE first reviews CFLKs covered under the scope of the rulemaking and the associated product classes. When a product has multiple product classes, DOE selects certain classes as “representative” and concentrates its analytical effort on these classes. DOE selects representative product classes primarily because of their high market volumes and/or distinct characteristics.
Baseline lamps:
For each representative product class, DOE selects a baseline lamp as a reference point against which to measure changes resulting from energy conservation standards. Typically, a baseline lamp is the most common, least efficacious lamp in a CFLK 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 lamps considered. When selecting higher efficacy lamps, DOE considers only design options that meet the criteria outlined in the screening analysis (see section IV.B or chapter 4 of the NOPR TSD).
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 (or lumen outputs) to comply with the standard level of a given product class;
18
and (3) the max-tech EL. DOE then scales the ELs of representative product classes to any classes not directly analyzed.
18
ELs span multiple lamps of different wattages. In selecting ELs, DOE considered whether these multiple lamps can meet the standard levels.
2. Representative Product Classes
In the preliminary analysis, DOE established two product classes and identified both the CFLKs with Externally Ballasted or Driven Lamps and the All Other CFLKs product classes as representative. Although the All Other CFLKs product class constituted the majority of CFLKs sold, DOE also considered the CFLKs with Externally Ballasted or Driven Lamps product class as representative because the CFLKs in this class offered a unique utility in their ability to allow the consumer to replace the lamp or ballast/driver. DOE did not receive any comments on the representative product classes identified in the preliminary analysis.
As discussed in section IV.A.1, DOE is no longer establishing a separate product class for products that are externally ballasted or driven and proposes to include all CFLKs in one product class. Therefore, in this NOPR DOE analyzes one product class as representative.
3. Baseline Lamps
Once DOE identifies the representative product classes for analysis, it selects baseline lamps to analyze in each product class. DOE selects baseline lamps that are typically the most common, least efficacious lamps in a CFLK that meet existing energy conservation standards. Specific lamp characteristics are used to characterize the most common lamps packaged with CFLKs today (
e.g.,
wattage and light output). To identify baseline lamps, DOE reviews product offerings in catalogs and manufacturer feedback obtained during interviews.
In the preliminary analysis, DOE selected lamps representative of the most common, least efficacious lamps packaged with CFLKs that just meet existing CFLK standards. To calculate efficacy for lamps in the All Other CFLKs product class, DOE used the catalog lumens and the catalog wattage of the lamp. DOE used the catalog lumens and the American National Standards Institute (ANSI) rated wattage, or the catalog wattage if the ANSI rated wattage was not available, to calculate the efficacy for externally ballasted or driven lamps. (For further detail on the baseline lamps selected in the preliminary analysis, see chapter 5 of the preliminary TSD.) DOE received several comments regarding these baseline selections.
For the CFLKs with Externally Ballasted or Driven Lamps product class, Westinghouse commented that the selected circline fluorescent baseline lamp is accurate because it represents the only product used in externally ballasted or driven CFLKs. (Westinghouse, Public Meeting Transcript, No. 82 at p. 175) For the All Other CFLKs product class, Westinghouse remarked that the baseline lamp DOE selected is not the least efficacious lamp used in CFLKs because the least efficacious lamp is not currently subject to an efficiency standard. (Westinghouse, Public
Meeting Transcript, No. 82 at pp. 134-135)
DOE notes that incandescent lamps, such as those that have candelabra bases, are commonly used in CFLKs, and are subject to a maximum wattage standard rather than an efficacy standard. As stated by Westinghouse, these lamps have lower efficacy values than the CFL used as the baseline lamp in DOE's analysis. As explained in the paragraphs that follow, DOE selected the baseline lamps consistent with the revised product class structure for the NOPR.
In the product class structure analyzed in the preliminary analysis, DOE determined that lamps in the All Other CFLKs product class, such as the candelabra-base lamps, must comply with a minimum standard of 45.0 lm/W for lamps less than 15 W and 60.0 lm/W for lamps greater than or equal to 15 W. The Joint Comment agreed with DOE's determination of the 45 lm/W minimum efficacy for the All Other CFLKs product class. (Joint Comment, No. 95 at p. 2).
DOE revised the product class structure in the NOPR and determined that, consistent with 42 U.S.C. 6295(o)(1) lamps packaged with CFLKs must comply with a minimum standard of 50.0 lm/W for lamps less than 15 W, 60.0 lm/W for lamps greater than or equal to 15 W and less than 30 W, and 70.0 lm/W for lamps greater than or equal to 30 W. The following discussion provides further detail on this change.
Existing standards for CFLKs, codified at 10 CFR 430.32(s), are currently divided into three product classes: (1) Ceiling fan light kits with medium screw base sockets (Medium Screw Base product class); (2) Ceiling fan light kits with pin-based sockets for fluorescent lamps (Pin-Based product class); and, (3) Ceiling fan light kits with socket types other than those covered in the previous two product classes, including candelabra screw base sockets (Other Base Type product class). In the preliminary analysis, DOE combined these three product classes for CFLKs and conducted a product class analysis that identified the following two product classes for consideration: CFLKs with Externally Ballasted or Driven Lamps product class and All Other CFLKs product class. See section IV.A.1 for further details.
Current standards require lamps in the Medium Screw Base product class to “meet the ENERGY STAR Program requirements for Compact Fluorescent Lamps, version 3.” 10 CFR 430.32(s). In the preliminary analysis, DOE determined that the products in the All Other CFLKs product class are subject to the same efficacy standards as the existing Medium Screw Base product class. These minimum efficacy standards are specific to wattage bins and whether the lamp is bare or covered. Because DOE determined that lamp cover was not a class setting factor in the preliminary analysis product class structure, the minimum efficacy requirements for this product class were determined by lamp wattage. Therefore, for products less than 15 W, DOE determined that the minimum efficacy for products in the All Other CFLKs product class is 45 lm/W, the highest of the existing standards for that wattage bin. For products greater than or equal to 15 W, DOE determined that the minimum efficacy is 60 lm/W, the highest of the existing standards for that wattage bin.
Current standards require lamps in the Pin-Based product class to “meet the ENERGY STAR Program Requirements for Residential Light Fixtures version 4.0.” 10 CFR 430.32(s) In the preliminary analysis, DOE determined that the products in the CFLKs with Externally Ballasted or Driven Lamps product class are subject to the same efficacy standards as the existing Pin-Based product class. These minimum efficacy standards are specific to wattage bins and lamp length. Because DOE determined that lamp length was not a class setting factor in the preliminary analysis product class structure, the minimum efficacy requirements for this product class were determined by lamp wattage. DOE determined that lamps in the CFLKs with Externally Ballasted or Driven Lamps product class must comply with a minimum standard of 50 lm/W for lamps less than 30 W and 70 lm/W for lamps greater than or equal to 30 W.
In the NOPR, DOE is proposing a single product class, and thus re-evaluated the minimum standard efficacy. Products in the All CFLKs product class are subject to either ENERGY STAR Program Requirements for Residential Light Fixtures version 4.0 (10 CFR 430.32(s)) or ENERGY STAR Program requirements for Compact Fluorescent Lamps, version 3. (10 CFR 430.32(s)). ENERGY STAR Program Requirements for Residential Light Fixtures version 4.0 minimum efficacy requirements are specific to wattage and length and ENERGY STAR Program requirements for Compact Fluorescent Lamps version 3 are specific to wattage and whether the lamp is bare or covered. Because DOE is not proposing length or lamp cover as product class setting factors, minimum efficacy requirements for this product class were determined by lamp wattage. Consistent with 42 U.S.C. 6295(o)(1), DOE determined that products in the All CFLKs product class are subject to the highest of the existing standards for each wattage bin. Therefore, for products less than 15 W, DOE set the minimum baseline efficacy at 50 lm/W. For products greater than or equal to 15 W and less than 30 W, DOE set the baseline efficacy at 60 lm/W. For products greater than or equal to 30 W, DOE set the baseline efficacy at 70 lm/W. The combined minimum efficacy requirements based on wattage are shown in Table IV.3.
Table IV.3—All CFLKs Product Class Current Standard Efficacy Requirements
Lamp power
(W)
Minimum
efficacy
(lm/W)
<15
50.0
≥15 and <30
60.0
≥30
70.0
In the preliminary analysis, DOE identified a 14 W spiral CFL with 730 lumens as the baseline lamp. However, DOE found product literature indicating that the lamp is marketed for rough service applications, a feature DOE did not find to be utilized in CFLKs. DOE also received feedback that CFLK manufacturers typically purchase the least expensive lamp available and a rough service lamp would command a premium. Further, market information indicated that many 14 W CFLs with low lumen outputs typically had an additional feature (
e.g.,
a cover or a coating for rough service operation) that was not used for lamps packaged in CFLKs. Thus, in the NOPR analysis, DOE modeled a 14 W CFL as the baseline lamp without these additional features and a light output of 800 lumens, which is a common lumen output for this lamp. DOE assumed the modeled baseline lamp would have the same characteristics (spiral shape, 82 Color Rendering Index [CRI], 2,700 kelvin [K] correlated color temperature [CCT], and 10,000-hour lifetime) as the most common commercially available lamps. The modeled baseline that DOE is proposing for the All CFLKs product class is specified in Table IV.4. (See chapter 5 of the NOPR TSD for further details.) DOE requests comment on the baseline lamp analyzed in the NOPR analysis.
Table IV.4—All CFLKs Product Class Baseline Lamp
Bulb shape
Base
type
Lamp
type
Lamp wattage
(W)
Initial
light
output
(lm)
Efficacy
(lm/W)
Lamp
lifetime
(hr)
CRI
CCT
(K)
Spiral
E26
CFL
14
800
57.1
10,000
80
2,700
4. More Efficacious Substitutes
After choosing a baseline lamp, DOE identifies commercially available lamps that can serve as more efficacious substitutes. DOE utilized a database of commercially available lamps and selected substitute lamps that both save energy and maintain comparable light output to the baseline lamp. Specifically, in the preliminary analysis, DOE ensured that potential substitutions maintained light output within 10 percent of the baseline lamp lumen output for the lamp replacement scenario and within 10 percent of the baseline fixture lumen output for the light kit replacement scenario. Further, DOE considered only technologies that met all four criteria in the screening analysis. Regarding the lamp characteristics of the substitutes, DOE selected replacement lamp units with lifetimes greater than or equal to that of the lifetime of the baseline lamp. DOE also selected replacement lamp units with a CRI, CCT, and bulb shape comparable to that of the baseline representative lamp unit. (For further detail on the more efficacious substitutes selected in the preliminary analysis, see chapter 5 of the preliminary TSD.)
In the preliminary analysis, DOE considered more efficacious lamps under two different substitution scenarios: (1) A lamp replacement scenario and (2) a light kit replacement scenario. DOE selected the baseline light kit for both scenarios as a two-socket medium base light kit because it was representative of the most common basic CFLK product. In the lamp replacement scenario, DOE assumed that manufacturers would maintain the original fixture design, including the number of sockets, and only replace the lamp. Thus, DOE selected the base types of the more efficacious substitutes to be the same as that of the baseline lamp. In the light kit replacement scenario, DOE accounted for the possibility that manufacturers may change fixture designs. Thus, the base types of the more efficacious substitutes were not required to be the same as that of the baseline lamp and the number of sockets could be changed. Specifically, DOE considered replacement light kits with between one and four sockets and non-medium screw base types. For example, the candidate standard level (CSL) 1 light kit replacement option utilized one medium screw base 23 W CFL, and the CSL 3 light kit replacement option included four medium screw base 5 W LED lamps in the preliminary analysis.
DOE received several comments on the two substitution scenarios. Westinghouse and Hunter Fans commented that the lamp replacement scenario is preferred to the light kit replacement scenario because it is less cumbersome in terms of design changes and product cost. (Westinghouse, Public Meeting Transcript, No. 82 at pp. 132-133; Hunter Fans, Public Meeting Transcript, No. 82 at p. 173) Further, Westinghouse commented that the lamp replacement scenario is the primary method used by manufacturers, but that an increase in integrated SSL CFLKs might make the light kit replacement scenario more popular. In the short term, however, Westinghouse stated that the split between manufacturers replacing lamps versus changing light kits to meet standards is unlikely to be equal. (Westinghouse, Public Meeting Transcript, No. 82 at p. 173) When it was clarified that the light kit replacement scenario referred to a change in the number of sockets, and not replacement with integrated LED CFLKs, however, Westinghouse indicated that an even split between the lamp replacement and light kit replacement scenarios would be a reasonable estimate. (Westinghouse, Public Meeting Transcript, No. 82 at p. 175)
While comments from some stakeholders indicated that the light kit replacement scenario may not be the likely choice taken by manufacturers, it remains an option and one that may become more common in the future. A change in the number of sockets allows for a wider variety of lamp types, wattages, and lumen packages to be considered, including CFLKs that utilize integrated LEDs. Therefore, DOE retained the light kit replacement scenario for the NOPR because changing the light kit is a path that manufacturers may take to comply with standards. For further discussion of the percentage allocated to the likelihood of manufacturers choosing each scenario, see section IV.G.
DOE also received several comments from stakeholders on the more efficacious substitute lamps selected for CFLKs in the preliminary analysis. ALA agreed with the criteria used to select more efficacious substitute lamps, and with the proposed substitute lamps that DOE selected. (ALA, No. 93 at p. 9) The Joint Comment noted that many CFLKs on the market already exceed the minimum standard of 45 lm/W, and that there are ample CFL and LED CFLK options already offered by retailers. (Joint Comment, No. 95 at p. 2)
Westinghouse noted that the medium base, 800 lumen, 60 W equivalent product used as the basis for DOE's analysis is not used in 70 percent of CFLKs. (Westinghouse, Public Meeting Transcript, No. 82 at pp. 231-232) DOE acknowledges that the majority of CFLKs currently reside in the existing Other Base Type product class, typically using lamps with candelabra bases. However, as a result of the revised product class structure discussed in section IV.C.3, DOE selected an 800-lumen baseline lamp because it was the most common lamp with an efficacy near the baseline level of the revised product class structure. DOE selects more efficacious substitutes with lumens within 10 percent of the baseline, but does not limit these substitutes to products found in CFLKs.
The Minka Group commented that the LED representative lamp units are not omnidirectional. (The Minka Group, Public Meeting Transcript, No. 82 at pp. 149-150) ALA stated that it is not currently aware of an LED lamp that offers the omnidirectional lighting of halogen lamps at a comparable size to halogens. (ALA, No. 93 at pp. 8) DOE performed a review of lamp catalog data and confirmed that the A-shape general service LED lamps used as more efficacious substitutes are marketed as omnidirectional.
Westinghouse commented that medium base A19 LED lamps are more efficacious than LED lamps with other base types and sizes, noting that candelabra-base LED lamps are about 10 percent lower in efficacy than medium base A-shape LED lamps. Further, Westinghouse stated that medium base
A-shape LED lamps would not fit in CFLKs with candelabra sockets or be aesthetically pleasing. (Westinghouse, Public Meeting Transcript, No. 82 at pp. 137-140) Westinghouse recommended that DOE ensure that the standard would allow products with small bases to comply. (Westinghouse, Public Meeting Transcript, No. 82 at pp. 145-147) The Minka Group commented that LED lamps are not suitable replacements from a decorative perspective. (The Minka Group, Public Meeting Transcript, No. 82 at pp. 149-150) The Minka Group specifically recommended that DOE analyze G9 bases in the analysis and Westinghouse urged DOE to include base types smaller than G9 bases. (The Minka Group, Public Meeting Transcript, No. 82 at p. 140; Westinghouse, Public Meeting Transcript, No. 82 at p. 140) The Joint Comment, however, remarked that LED lamps provide the same amenities as incandescent lamps, and that LED lamps will only improve by the 2019 compliance date of this rulemaking. (Joint Comment, No. 95 at p. 2) Hunter Fans noted that it is not possible to estimate the efficacies of future LED lamps, especially externally driven LED CFLKs, but the market does have potential. (Hunter Fans, Public Meeting Transcript, No. 82 at pp. 158, 207-208)
DOE performed a survey of lamps with small bases (
e.g.,
E12, E17, and G9) and small form factors (
e.g.,
candle, flame tip, torpedo) based on catalog data and concluded that these lamp types are available at all ELs. For example, DOE identified a 3 W LED with a G9 base, a light output of 275 lm, and an efficacy of 91.7 lm/W, and also a 2 W LED with an E12 base, a light output of 200 lm, and an efficacy of 100 lm/W, with T4 and B11 shapes, respectively. These lamps meet the max-tech level, EL 4, which is discussed further in section IV.C.5.
Further, DOE notes that CFLKs with LED modules and driver systems can offer similar modular design options as CFLKs that use lamps with small bases. DOE applied thermal and driver losses estimated from the DOE Multi-Year Program Plan for Solid-State Lighting Research and Development
19
to commercially available LED modules and drivers to determine their lamp efficacy if they were incorporated as a consumer replaceable system in a CFLK. Per the CFLK test procedure NOPR, lamp efficacy is used to measure the efficiency of SSL CFLKs unless a CFLK has any light sources, drivers, or intermediate circuitry, such as wiring between a replaceable driver and a replaceable light source, that are not consumer replaceable. 79 FR 64688, 64693 (October 31, 2014). DOE determined that these CFLKs would meet EL 4, the max-tech level.
19
U.S. Department of Energy. Solid-State Lighting Research and Development Multi-Year Program Plan. April 2013. <
http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/ssl_mypp2013_web.pdf
>.
The Minka Group commented that the warranty of LED lamps labeled as 50,000 hours is actually 25,000 hours, which is an industry standard. (The Minka Group, Public Meeting Transcript, No. 82 at p. 142) ALA agreed, remarking that the 50,000 hour lifetimes for LED lamps are very optimistic and do not hold in the field. ALA noted that ENERGY STAR life ratings would be more appropriate. (ALA, Public Meeting Transcript, No. 82 at pp. 140-141)
In the preliminary analysis, LED replacement lamps selected at higher CSLs had lifetimes of 50,000 hours. DOE revised its selection of more efficacious substitutes for the NOPR analysis. DOE performed a review of data from lamp catalogs and the ENERGY STAR database of certified products
20
and determined that the lifetime of the LED lamps selected as representative lamp units in the NOPR is between 25,000 and 30,000 hours.
20
ENERGY STAR
. ENERGY STAR Certified Bulbs.
Last accessed February 20, 2015. <
http://www.energystar.gov/productfinder/product/certified-light-bulbs/
>.
Several stakeholders commented on dimming. ALA commented that dimmable CFLs are unacceptable for CFLKs because they have a larger form factor, a slower startup time, and poor dimming performance. (ALA, No. 93 at p. 7) Westinghouse agreed, commenting that CFLs usually do not dim well, and the ones that do are more expensive. (Westinghouse, Public Meeting Transcript, No. 82 at pp. 110-111) ALA added that CFLK controls are not typically designed for use with dimmable CFLs. (ALA, No. 93 at p. 7) DOE notes that although dimmable CFLs are not available at all levels, dimmable LED lamps are available at higher ELs; thus this functionality is maintained in the analysis.
ALA remarked that there are issues with dimmable LED compatibility with controls, but it expects this to change over time. ALA projected that LED CFLKs will increase to 15 percent of the market in five years, and that 25-50 percent of these CFLKs will be dimmable, with 7.5 percent having acceptable dimming functionality. (ALA, No. 93 at p. 8) Fanimation also commented that a high percentage of LED lamps will have dimming functionality. (Fanimation, Public Meeting Transcript, No. 82 at p. 112) Westinghouse commented that dimmable LED lamps are more functional than dimmable CFLs, but noted that their cost is very high compared to incandescent and halogen technologies, which represent 80 percent of the CFLK market. Westinghouse added that dimmable LED lamps may be unsatisfactory to the consumer compared to incandescent lamps. Westinghouse opined that if a rule is promulgated that creates consumer dissatisfaction, the consumer will switch to less efficient products that are not currently regulated. (Westinghouse, Public Meeting Transcript, No. 82 at pp. 110-111)
In response to these comments, DOE reviewed catalog data and feedback from stakeholders. Through this research, DOE confirmed that dimmable lamps are available at all of the analyzed levels, and that the ability to dim has a negligible impact on efficacy. Based on feedback from manufacturers and DOE's research, DOE has found that current issues regarding dimming mainly relate to compatibility with controls originally intended to be used with incandescent lamps. Further, NEMA is actively addressing the issue with SSL 7A-2013,
21
which seeks to minimize compatibility issues by providing design and testing guidelines for both LED dimmers and lamps. Therefore, DOE agrees that issues with dimming LED lamps in conjunction with controls will be minimal at the time of compliance with any amended standards, and that the proposed ELs will not result in a loss of dimming functionality in CFLKs. Further, because all of the representative lamp units analyzed are dimmable, the consumer prices determined for these representative lamp units include the cost of dimming functionality and are used as inputs to determine the first cost of these lamps in the LCC analysis and NIA. Hence, the results of these analyses incorporate any additional costs due to dimming functionality.
21
National Electrical Manufacturers Association.
Phase Cut Dimming for Solid State Lighting—Basic Compatibility
. April 22, 2013. <
http://www.nema.org/Standards/Pages/Phase-Cut-Dimming-for-Solid-State-Lighting-Basic-Compatibility.aspx
>.
DOE made several key changes in the NOPR analysis that impacted the selection of more efficacious substitutes. First, using the baseline updated for the NOPR, DOE selected more efficacious substitute lamps that have a light output within 10 percent of 800 lumens, the light output of the new baseline lamp. Second, at EL 2, DOE analyzed two
representative lamp units (a CFL and LED lamp) because DOE found that efficacies meeting this level were common for both CFLs and LED lamps, but there was a difference in price between the two options. Third, using updated catalog information, DOE found commercially available lamps at levels of efficacy higher than the max-tech level identified in the preliminary analysis. DOE also found that for representative lamp units above EL 2 (which are LED lamps), the end-user price decreased as efficacy increased. Therefore, DOE analyzed the most efficient commercially available LED lamp as a more efficacious substitute because it was at the lowest incremental first cost for an available product above EL 2: an 8.5 W LED lamp with 94.1 lm/W at EL 3. Finally, as described in the paragraph that follows, DOE also modeled an 8 W LED lamp with 102.5 lm/W at the max-tech level, EL 4.
At the time of this NOPR analysis, DOE has determined that a commercially available 3-way LED lamp when operated at its middle setting is more efficacious than any other commercially available lamp that could be considered an adequate replacement for the baseline lamp (
i.e.,
has a non-reflector shape, a lumen output within 10 percent of the baseline lamp, a CCT around 2,700 K, a CRI greater than or equal to 80, a lifetime greater than or equal to that of the baseline, and a medium screw base). Specifically, the 3-way lamp is 8 W at its middle setting, and has a light output of 820 lumens, an efficacy of 102.5 lm/W, and a lifetime of 25,000 hours. DOE concluded that the higher efficacy level achieved by the middle setting demonstrated the potential for a standard, non-3-way, 8 W LED lamp to achieve this efficacy level. Therefore, DOE modeled an 8 W lamp with 820 lumens and an efficacy of 102.5 lm/W. DOE assumed the modeled lamp would have similar characteristics to the most common commercially available LED lamps in the 800-lumen range. Hence, DOE modeled the lamp to have an A19 shape, medium base type, 25,000-hour lifetime, 2,700 K CCT, 80 CRI, and dimming functionality. DOE requests comment on the 3-way lamp used as a basis for the modeled max-tech LED lamp and information on whether such a lamp would meet DOE's screening criteria and should be maintained for the final rule analysis.
As EL 4 is based on a modeled product, a lamp suitable for direct replacement that complies with EL 4 is not currently commercially available. DOE learned through interviews that most CFLK manufacturers do not manufacture lamps, but rather purchase lamps from another supplier or manufacturer to package in CFLKs. As lamp manufacturers are not required to comply with standards promulgated by this rulemaking, DOE is uncertain as to whether such a lamp meeting EL 4 would be commercially available at the time CFLK manufacturers would need to comply with any amended standards.
DOE has determined that EL 4 can be met by other methods available to CFLK manufacturers; however, most of these options require redesigns of existing fixtures. Some commercially available lamps with smaller base types meet EL 4, but these are available with low lumen outputs and would therefore require several lamps to be incorporated into a new CFLK to provide the same amount of light. Some commercially available lamps with the same base type as the baseline lamp are available at EL 4, but these have higher lumen outputs such that a CFLK would have to be redesigned with fewer sockets to maintain the same light output. Alternatively, a few LED modules and drivers with a similar lumen output as the baseline lamp could be incorporated as consumer replaceable parts in CFLKs. However, all of these methods of meeting EL 4 reflect the fact that, for most situations, direct lamp replacement would not be a means of meeting the efficacy level.
The representative lamp unit at EL 3 is the most efficacious commercially available LED lamp that could be considered an adequate substitute for the baseline lamp (
i.e.,
has a non-reflector shape, a lumen output within 10 percent of the baseline lamp, a CCT around 2,700 K, a CRI greater than or equal to 80, a lifetime greater than or equal to that of the baseline, and a medium screw base). Small base lamps are only available with low lumen outputs at EL 3 and LED modules and drivers are only available in a limited lumen range.
The representative lamp units at EL 2 are a commercially available LED lamp and CFL and the representative lamp unit at EL 1 is a commercially available CFL, all of which are considered adequate substitutes for the baseline lamp (
i.e.,
have a non-reflector shape, a lumen output within 10 percent of the baseline lamp, a CCT around 2,700 K, a CRI greater than or equal to 80, a lifetime greater than or equal to that of the baseline, and a medium screw base). At EL 2 and EL 1, CFLK manufacturers can choose from a large number of suitable options for direct lamp replacements, as well as fixture redesigns to meet this level. In particular, LED modules and drivers are available with lumen outputs that are not an option at higher ELs.
The CFLK representative lamp units that DOE analyzed in the NOPR are shown in Table IV.5 for the lamp replacement scenario and in Table IV.6 for the light kit replacement scenario. DOE requests comment on the criteria used in selecting more efficacious substitute lamps, as well as the characteristics of the lamps selected.
Table IV.5—All CFLKs Product Class Design Options: Lamp Replacement Scenario
Efficacy level
Lamp type
Base type
Bulb shape
Wattage
(W)
Initial light output
(lm)
Efficacy
(lm/W)
CRI
CCT
(K)
Lamp
lifetime
(hr)
Baseline
CFL
E26
Spiral
14
800
57.1
80
2,700
10,000
EL 1
CFL
E26
Spiral
13
800
61.5
80
2,700
10,000
EL 2
CFL
LED
E26
E26
Spiral
A19
11
12
730
800
66.4
66.7
82
82
2,700
2,700
10,000
25,000
EL 3
LED
E26
A19
8.5
800
94.1
81
2,700
25,000
EL 4
LED
E26
A19
8
820
102.5
80
2,700
25,000
Table IV.6—All CFLKs Product Class Design Options: Light Kit Replacement Scenario
Efficacy level
Lamp type
Base type
Bulb shape
Fixture sockets
Lamp wattage
(W)
Fixture wattage
(W)
Lamp
initial
light
output
(lm)
Fixture
initial
light
output
(lm)
Efficacy
(lm/W)
CRI
CCT
(K)
Lamp life
(hr)
Baseline
CFL
E26
Spiral
2
14
28
800
1,600
57.1
80
2,700
10,000
EL 1
CFL
E26
Spiral
3
9
27
520
1,560
57.8
80
2,700
10,000
EL 2
LED
E26
G25
3
8
24
500
1,500
62.5
82
2,700
25,000
EL 3
LED
E26
A21
1
16
16
1,600
1,600
100.0
80
2,700
25,000
EL 4
LED
E26
A21
1
15
15
1,600
1,600
106.7
82
2,700
25,000
5. Efficacy Levels
DOE adopted an equation-based approach to establish ELs for CFLKs. In the preliminary analysis, DOE developed the general form of the equation by evaluating lamps with similar characteristics, such as technology, bulb shape, and lifetime, across a range of wattages. The continuous equations specified a minimum lamp efficacy requirement across wattages and represented the efficacy a lamp achieves. DOE received several comments regarding the EL equations.
The Joint Comment agreed with the equation-based lm/W standard, remarking that it is the most effective metric for establishing lighting standards for CFLKs. (Joint Comment, No. 95 at pp. 2-3) The Joint Comment opposed the use of lumen bins, and remarked that for general service incandescent lamps (GSILs), lumen bins have resulted in manufacturers selecting the lowest allowable light output within a bin. (Joint Comment, No. 95 at p. 3) However, Westinghouse commented that wattage-based efficacy equations would be confusing for CFLK manufacturers because they do not manufacture lamps. (Westinghouse, Public Meeting Transcript, No. 82 at pp. 144-145) The Joint Comment suggested that, similar to the European Union, DOE should use an equation-based approach to establish minimum ELs as a function of light output. (Joint Comment, No. 95 at p. 3)
DOE analyzed commercially available lamps and found that a continuous equation best describes the relationship between efficacy and lamp wattage rather than bins. In the NOPR analysis, DOE altered its approach to base ELs on continuous equations as a function of light output rather than wattage. Available information indicates that the primary utility provided by a lamp is lumen output, which can be achieved through a range of wattages depending on the lamp technology. Further, fixed losses in lamps, such as power consumed by the integrated ballast/driver, become proportionally smaller at higher lumen outputs, thereby increasing efficacy proportionally to light output. For these reasons, DOE believes that lamps providing equivalent lumen output should be subject to the same minimum efficacy requirements.
Westinghouse commented that while DOE is setting an energy conservation standard, consumers value utility, and price points have been set for certain aspects, such as lamp size, dimmability, and lifetime. If the standard is too high, CFLK manufacturers trying to balance efficacy and utility at a consumer price point may not have any suitable products. (Westinghouse, Public Meeting Transcript, No. 82 at pp. 148-149) DOE analyzed each EL to maintain the products' existing utility to the consumer including lifetime, dimming functionality, and availability of CFLK design options. DOE then analyzed the cost associated with each EL in the LCC analysis; see section IV.F for discussion on the cost effectiveness to consumers.
ALA suggested that DOE use minimum LCC as a criterion in developing its TSLs and selecting its proposed standard, and that DOE propose a standard that is no more stringent than CSL 2. (ALA, No. 93 at p. 11) ALA recommended that DOE propose a standard level that permits both CFLs and LED lamps, allowing CFLK manufacturers to select the best lighting technology to meet necessary utilities. (ALA, No. 93 at pp. 9-10, 12) DOE developed TSLs as described in section V.A. When proposing a standard, DOE weighs a variety of factors, including the maximum energy savings and NPV to the nation, as well as product availability and the costs and benefits to the individual consumer. See section V.C.1 for more information on the rationale used in selecting the proposed level.
As mentioned previously, DOE considered two scenarios: A lamp replacement scenario and a light kit replacement scenario. DOE selected ELs that could be met by the more efficacious substitutes identified in the lamp replacement scenario. DOE also identified more efficacious lamp substitutes for the light kit replacement scenario that had efficacies equal to or greater than the efficacies of the corresponding EL based on the lamp replacement scenario.
In the preliminary analysis, DOE had considered one CSL for the CFLKs with Externally Ballasted or Driven Lamps product class and five CSLs for the All Other CFLKs product class. (For further details, see chapter 5 of the preliminary TSD.) In the NOPR analysis, DOE analyzed all covered CFLKs in one product class. DOE surveyed the market, analyzed product catalogs, and took into account feedback from manufacturers to develop ELs. Based on this assessment, DOE identified varying levels of efficacy that reflected technology changes and met the criteria for developing ELs previously outlined. In the NOPR, DOE is considering four ELs.
Table IV.7 presents the ELs for CFLKs. See chapter 5 of the NOPR TSD for additional information on the methodology and results of the engineering analysis.
Table IV.7—Summary of Efficacy Levels for All CFLKs
Representative product class
Efficacy level
Light output
(lm)
Minimum required efficacy
(lm/W)
All CFLKs
EL 1
<260
50
≥260 and ≤2040
69−29.42 × 0.9983
lumens
>2040 and <2100
>(
1/30
) × lumens
≥2100
70
EL 2
<120
50
≥120
74−29.42 × 0.9983
lumens
EL 3
All
101−29.42 × 0.9983
lumens
EL 4
All
106−29.42 × 0.9983
lumens
As shown in Table IV.7, DOE made adjustments to EL 1 and EL 2 to ensure that, consistent with 42 U.S.C. 6295(o), the efficacy remains above the current minimum standards summarized in Table IV.3. See Sections II.A and IV.C.3 for further discussion of this issue. For lamps less than 15 W, the minimum efficacy is 50 lm/W. For a light output of less than 260 lumens, DOE found that the EL 1 equation could potentially allow lamps that are less than 50 lm/W to meet standards and therefore set the minimum efficacy requirement at 50 lm/W for lamps in this lumen range. For a light output of less than 120 lumens, DOE found that the EL 2 equation could potentially allow lamps that are less than 50 lm/W to meet standards and therefore set the minimum efficacy requirement at 50 lm/W for lamps in this lumen range. DOE determined that no adjustments to any ELs were necessary to meet the 60 lm/W current standard applicable to lamps
greater than
15 W and less than 30 W.
For lamps
greater than
30 W, DOE determined that the minimum efficacy is 70 lm/W. DOE found that the equation for EL 1 could potentially allow lamps that are less than 70 lm/W to meet standards. Therefore, for lumens greater than 2040 and less than 2100, DOE set the minimum efficacy requirement at greater than (
1/30
) × lumens for EL 1. For lumens greater than or equal to 2100, DOE set the minimum efficacy requirement at 70 lm/W. DOE requests comment on the equations used to define the efficacy requirements at each EL. See chapter 5 of the NOPR TSD for further information on the anti-backsliding adjustments that DOE made to the ELs.
6. Scaling to Other Product Classes
Typically DOE determines ELs for product classes that were not directly analyzed (“non-representative product classes”) by scaling from the ELs of the representative product classes. As DOE only identified one product class for CFLKs, no scaling was required.
D. Product Price Determination
Because the efficiency of a CFLK is based on the efficacy of the lamps with which it is packaged, DOE developed a product price determination for the lamp component of the CFLK. Typically, DOE develops manufacturer selling prices (MSPs) for covered products and applies markups to create consumer prices to use as inputs to the LCC analysis and NIA. Because lamps are difficult to reverse-engineer (
i.e.,
not easily disassembled), DOE directly derives consumer prices for the lamps in this rulemaking.
In the preliminary analysis, DOE determined premiums on CFLKs by comparing distributor net prices
22
to the retail prices of these products in each distribution channel. DOE identified three main distribution channels for CFLKs: Electrical/specialty centers, home centers (
e.g.,
Home Depot, Lowes), and lighting showrooms. DOE then developed an average premium weighted by estimated shipments that go through each distribution channel. DOE applied the average shipment-weighted premium to the distributor net prices of CFLKs packaged with the representative lamp unit to obtain the average CFLK consumer price. Based on manufacturer feedback received during the preliminary analysis, DOE determined that a fluorescent lamp, CFL, or LED in a CFLK comprises 15 percent of the CFLK consumer price. DOE applied this percentage to the CFLK consumer price to obtain the consumer price of the representative lamp unit packaged with the CFLK. DOE received several comments on the pricing methodology.
22
Prices suggested by manufacturers that distributors pay for a product.
ALA agreed that for CFLKs packaged with ceiling fans, a CFL would comprise 15 percent of the CFLK price. (ALA, No. 93 at p. 10) Hunter Fans also agreed with the 15 percent estimate for CFLs in a CFLK. (Hunter Fans, Public Meeting Transcript, No. 82 at p. 164) Hunter Fans, Westinghouse, Lamps Plus, and The Minka Group remarked that the percentage of consumer price attributable to an LED in a CFLK was too low, and that it is actually closer to 30 percent. (Hunter Fans, Public Meeting Transcript, No. 82 at p. 164; Westinghouse, Public Meeting Transcript, No. 82 at p. 165; Lamps Plus, Public Meeting Transcript, No. 82 at p. 165; The Minka Group, Public Meeting Transcript, No. 82 at p. 165) ALA commented that for CFLKs packaged with ceiling fans, an LED would comprise 30 percent of the consumer CFLK price and for a CFLK sold alone, an LED would comprise over 50 percent of the consumer price. (ALA, No. 93 at p. 10)
In the preliminary analysis, DOE used the methodology of applying a percentage of the CFLK consumer price attributable to the lamp only for CSL 1 because the representative lamp unit at this level is sold with CFLKs for which distributor net prices were available. Specifically, DOE applied 15 percent to CFLK consumer prices to obtain the consumer lamp price for a 13 W spiral CFL, the representative lamp unit at CSL 1. The CFL representative lamp unit at the baseline is also sold with CFLKs, but distributor net prices were not available for these CFLKs. The LED representative lamp units at all other levels are not sold with CFLKs. For these cases, DOE developed a ratio between the consumer price of the 13 W spiral CFL representative lamp unit when sold with a CFLK to the blue-book
23
price of the lamp when sold alone. DOE then applied this ratio to the blue-book price of the representative lamp unit when sold alone to obtain the consumer price of the lamp if it were sold with a CFLK. Therefore, with the exception of the 13 W spiral CFL representative lamp unit, the consumer lamp prices for the other CFL representative lamp units are not necessarily 15 percent of the total CFLK consumer price nor 30 percent for the LED representative lamp units. Maintaining this same methodology, in the NOPR analysis, DOE also analyzed an 11 W spiral CFL at EL 2, a lamp that is also not sold with CFLKs. In this case DOE applied the methodology described above except used retail prices instead of blue-book prices, a change in the analysis that is expanded on further in this section.
23
Blue-book prices refer to suggested retail prices issued by lamp manufacturers and are usually specified for bulk quantity purchases.
Westinghouse noted that assuming that an LED lamp is 15 or 30 percent of the CFLK consumer price, the consumer price of the lamp at CSL 5, which requires an LED lamp, would imply that a CFLK at that level costs about $100. Westinghouse stated that $100 for a CFLK was unreasonably high, especially when compared to CFLKs packaged with CFLs sold at Home Depot for $25-$30, and could potentially put manufacturers out of business. (Westinghouse, Public Meeting Transcript, No. 82 at pp. 204-207) However, Westinghouse commented that it is difficult to know whether the considered LED lamp price is too high or not, as price projections for LED lamps are difficult to estimate. (Westinghouse, Public Meeting Transcript, No. 82 at pp. 210-211) Lamps Plus stated that regardless, if the price of a CFLK attributable to an LED was higher than 27 percent, sales would be significantly affected. (Lamps Plus, Public Meeting Transcript, No. 82 at p. 217) Lamps Plus added that at the $100 price point, consumers may choose to buy a lower cost light fixture instead of the CFLK. (Lamps Plus, Public Meeting Transcript, No. 82 at pp. 213-214)
In the preliminary analysis, DOE calculated the remaining CFLK consumer price (
i.e.,
CFLK price excluding the lamps and sockets) based on the lamp and socket prices
24
and total CFLK consumer price determined for CSL 1. DOE assumed that this remaining CFLK consumer price was the same at all levels, and the only changes in the total CFLK consumer price were a function of the lamp and socket consumer prices at a particular level. DOE maintained this approach in the NOPR analysis using the lamp, socket, and total CFLK consumer prices determined for EL 1. The total CFLK consumer price at all ELs for both the lamp and light kit replacement scenario remained under approximately $60. For further clarity, DOE presents the consumer prices for the lamp, socket, remaining CFLK consumer price, and total CFLK consumer price at each level in chapter 7 of the NOPR TSD.
24
For consumer prices of sockets, DOE estimated the manufacturer production cost of different socket types based on feedback received in manufacturer interviews and then applied the appropriate manufacturer and distributor markups.
Noting that lamps meeting higher CSLs were not currently sold in CFLKs, Westinghouse commented that the consumer lamp price and socket price were not being analyzed correctly because the analysis leaves out the current cost to consumers. (Westinghouse, Public Meeting Transcript, No. 82 at pp. 182) Westinghouse commented that DOE did not determine the price of an incandescent lamp packaged with a CFLK in this analysis. (Westinghouse, Public Meeting Transcript, No. 82 at p. 167) Westinghouse added that the baseline price for a CFLK uses a medium base CFL, but that this product is more expensive than a CFLK with incandescent lamps. (Westinghouse, Public Meeting Transcript, No. 82 at p. 117)
Because representative lamp units at the baseline and ELs under consideration did not utilize incandescent technology, DOE did not develop prices for incandescent lamps. For further information on the selection of the representative lamp units, see section IV.C.
Overall, DOE maintained the general methodology used in the preliminary analysis to determine consumer prices of lamps sold with CFLKs in the NOPR analysis. However, in addition to updating the price data used, to more accurately reflect prices consumers will pay, DOE made the following modifications.
When developing consumer prices for representative lamp units not currently sold in CFLKs, in the NOPR analysis DOE used home center channel retail prices of the representative lamp units when sold alone instead of using the blue-book prices of the lamps. Because the home center channel has the highest volume of CFLKs, DOE determined that these prices more closely represent prices paid by CFLK consumers.
As noted, an average shipment-weighted premium on distributor net prices is used to calculate the consumer price of a CFLK packaged with the 13 W spiral CFL representative lamp unit. DOE updated the CFLK retail prices used to determine this premium for the NOPR analysis. Additionally, because DOE did not have distributor net price lists from all manufacturers, DOE adjusted the premium to ensure that it reflected the majority of the CFLK market. DOE based this adjustment on a ratio of CFLK retail prices from manufacturers that represent a majority of the market to the manufacturers for which DOE had distributor net prices.
In the preliminary analysis, to determine the consumer price of the 13 W spiral CFL representative lamp unit sold with a CFLK, DOE applied 15 percent to the consumer price of CFLKs sold with a ceiling fan and CFLKs sold alone. While comments from stakeholders verified that 15 percent should be applied to obtain the price of a CFL packaged with a CFLK sold with a ceiling fan, it is not clear that the same percentage would apply to CFLKs sold alone. Further CFLKs are primarily sold with ceiling fans. Therefore, in the NOPR analysis DOE only used consumer prices of CFLKs sold with ceiling fans to determine the consumer price of the 13 W spiral CFL representative lamp unit. (See chapter 7 of the NOPR TSD for further information on the methodology and results of the pricing analysis.) DOE welcomes feedback on the pricing methodology and results.
E. Energy Use Analysis
The purpose of the energy use analysis is to determine the annual energy consumption of CFLKs at different efficacies in representative U.S. homes and commercial buildings, and to assess the energy savings potential of increased CFLK efficacy. To develop annual energy use estimates, DOE multiplied CFLK input power by the number of hours of use (HOU) per year. The energy use analysis estimates the range of operating hours of CFLKs in the field (
i.e.,
as they are actually used by consumers). The energy use analysis provides the basis for other analyses that DOE performed, particularly assessments of the energy savings and the savings in consumer operating costs that could result from adoption of amended standards.
1. Operating Hours
a. Residential Sector
To determine the average HOU of CFLKs in the residential sector, DOE collected data from a number of sources. Consistent with the approach taken in the GSL preliminary analysis,
25
DOE used data from various field metering studies of GSL operating hours in the residential sector. To account for any difference in CFLK HOU compared to GSL HOU, DOE considered two factors: (1) The relative HOU for GSLs installed in ceiling light fixtures compared to all GSLs based on data from the Residential Lighting End-Use Consumption Study (RLEUCS),
26
and (2) the HOU associated with the specific room types in which CFLKs are installed based on installation location data from a Lawrence Berkeley National Laboratory survey of ceiling fan and CFLK owners
(LBNL survey)
27
and room-specific HOU data from RLEUCS. As in the GSL preliminary analysis, DOE assumed that CFLK operating hours do not vary by light source technology.
25
DOE has published a framework document and preliminary analysis for amending energy conservation standards for general service lamps. Further information is available at
www.regulations.gov
under Docket ID: EERE-2013-BT-STD-0051.
26
DNV KEMA Energy and Sustainability and Pacific Northwest National Laboratory.
Residential Lighting End-Use Consumption Study: Estimation Framework and Baseline Estimates.
2012.
http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2012_residential-lighting-study.pdf
.
27
Kantner, C.L.S., S.J. Young, S.M. Donovan, and K. Garbesi.
Ceiling Fan and Ceiling Fan Light Kit Use in the U.S.—Results of a Survey on Amazon Mechanical Turk.
2013. Lawrence Berkeley National Laboratory: Berkeley, CA. Report No. LBNL-6332E.
http://www.escholarship.org/uc/item/3r67c1f9
.
DOE determined the regional variation in average HOU using average HOU data from regional metering studies, all of which are listed in the energy use chapter (chapter 6 of the NOPR TSD). DOE organized regional variation in HOU by each EIA Residential Energy Consumption Survey (RECS) reportable domain (
i.e.,
state, or group of states). For regions without HOU metered data, DOE used data from adjacent regions.
To estimate the variability in CFLK HOU by room type, DOE developed HOU distributions for each room type using data from the Northwest Energy Efficiency Alliance's Residential Building Stock Assessment Metering Study (RBSAM),
28
which is a metering study of 101 single-family houses in the Northwest. DOE assumed that the shape of the HOU distribution for a particular room type would be the same across the United States, even if the average HOU for that room type varied by geographic location. To determine the room and geographic location-specific HOU distributions, DOE scaled the HOU distribution for a given room type from the RBSAM study by the average HOU in a given region, adjusted based on the geographic location-specific variability in HOU between different room types from RLEUCS.
28
Ecotope Inc.
Residential Building Stock Assessment: Metering Study.
2014. Northwest Energy Efficiency Alliance: Seattle, WA. Report No. E14-283.
http://neea.org/docs/default-source/reports/residential-building-stock-assessment-metering-study.pdf?sfvrsn=6
.
Based on the approach described in this section, DOE estimated the national weighted-average HOU of CFLKs to be 2.0 hours per day. For more details on the methodology DOE used to estimate the HOU for CFLKs in the residential sector, see chapter 6 of the NOPR TSD. DOE requests comment on the data and methodology used to estimate operating hours for CFLKs in the residential sector, as well as on the assumption that CFLK operating hours do not vary by light source technology (see section VII.E).
b. Commercial Sector
The HOU for CFLKs in commercial buildings were developed using lighting data for 15 commercial building types obtained from the 2010 U.S. Lighting Market Characterization (LMC).
29
For each commercial building type presented in the LMC, DOE determined average HOU based on the fraction of installed lamps utilizing each of the light source technologies typically used in CFLKs and the HOU for each of these light source technologies. A national-average HOU for the commercial sector was then estimated by weighting the building-specific HOU for lamps used in CFLKs by the relative floor space of each building type as reported in in the 2003 EIA Commercial Buildings Energy Consumption Survey (CBECS).
30
To capture the variability in HOU for individual consumers in the commercial sector, DOE applied a triangular distribution to each building type's weighted-average HOU with a minimum of 80 percent and a maximum of 120 percent of the weighted-average HOU value. For further details on the commercial sector operating hours, see chapter 6 of the NOPR TSD.
29
Navigant Consulting, Inc.
Final Report: 2010 U.S. Lighting Market Characterization.
2012.
http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf
.
30
U.S. Department of Energy-Energy Information Administration.
2003 CBECS Survey Data.
(Last accessed October 6, 2014.)
http://www.eia.gov/consumption/commercial/data/2003/index.cfm?view=microdata
.
2. Input Power
DOE developed its estimate of the power consumption of CFLKs by scaling the input power and lumen output of the representative lamp units for CFLKs characterized in the engineering analysis to account for the lumen output of CFLKs in the market. DOE estimated average CFLK lumen output based on a weighted average of CFLK models from data collected in 2014 from in-store shelf surveys and product offerings on the Internet. DOE estimated the market share of each identified CFLK model based on price. See chapter 6 of the NOPR TSD for details on the price-weighting market share adjustment and how DOE estimated average weighted lumen output for all CFLKs
3. Lighting Controls
In response to the energy use analysis presented in the preliminary analysis, stakeholders provided comment only on DOE's handling of dimmable CFLKs. In the preliminary analysis, DOE did not account for energy savings resulting from dimming. Fanimation expects that a high percentage of CFLKs will have dimming functionality in the future. (Fanimation, Public Meeting Transcript, No. 82 at p. 112) ALA and Westinghouse added that dimmable CFLs are not a viable option for use in CFLKs due to their size, slow startup time, insufficient dimming capability, and cost, which leads to consumer dissatisfaction. (ALA, No. 93 at p. 7; Westinghouse, Public Meeting Transcript, No. 82 at pp. 110-111) ALA and Westinghouse also believe that the current control incompatibility issues associated with dimmable LED CFLKs prevent dimmable LEDs from being a viable option, but ALA believes that in five years LED CFLKs with acceptable dimming functionality could represent up to 7.5 percent of the CFLK market. (Id.)
Based on the technical issues ALA and Westinghouse raised, as well as the significant price premium for dimmable CFLs, DOE assumed that CFLKs are not likely to feature dimmable CFL lamps. DOE requests comments on this assumption (see section VII.E). In the NOPR analyses, DOE did not assume CFL CFLKs were operated with controls. On the other hand, DOE does believe that some fraction of LED and incandescent CFLKs are likely to be operated with a dimmer, which DOE considers to be the only relevant lighting control for CFLKs. For the NOPR analyses, DOE used the results of an LBNL survey
31
to estimate that 11 percent of CFLKs are operated with dimmers. DOE assumed that the fraction of CFLKs used with dimmers is the same in the residential sector and the commercial sector, and DOE requests comment on this assumption (see section VII.E). Furthermore, DOE has assumed that an equal fraction of LED and incandescent CFLKs are operated with dimmers, based on the increasing fraction of commercially available dimmers that are now compatible with LEDs, the increase in LED lamps that are being designed to operate on legacy dimmers, and the assumption that integral LEDs have built-in dimming capability with no compatibility issues. DOE used the 2010 LMC
32
and the aforementioned LBNL survey to account for the likelihood that a CFLK with a dimmer will be installed in a given room type. This affec
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