Energy Conservation Program: Energy Conservation Standards for General Service Lamps
Federal RegisterJan 11, 2023
Ask Donna
What actually matters in this document.
Text
DEPARTMENT OF ENERGY
10 CFR Part 430
[EERE-2022-BT-STD-0022]
RIN 1904-AF43
Energy Conservation Program: Energy Conservation Standards for General Service Lamps
AGENCY:
Office of Energy Efficiency and Renewable Energy, Department of Energy.
ACTION:
Notice of proposed rulemaking and announcement of public meeting.
SUMMARY:
The Energy Policy and Conservation Act, as amended (EPCA), directs the U.S. Department of Energy (DOE) to initiate two rulemaking cycles for general service lamps (GSLs) that, among other requirements, determine whether standards in effect for GSLs should be amended. EPCA also requires DOE to periodically determine whether more-stringent, standards would be technologically feasible and economically justified, and would result in significant energy savings. In this notice of proposed rulemaking (NOPR), DOE proposes amended standards for GSLs pursuant to its statutory authority in EPCA, and also announces a webinar to receive comments on its proposal and associated analyses and results.
DATES:
Comments:
DOE will accept comments, data, and information regarding this NOPR no later than March 27, 2023.
Comments regarding the likely competitive impact of the proposed standard should be sent to the Department of Justice contact listed in the
ADDRESSES
section on or before February 10, 2023.
Meeting:
DOE will hold a public meeting via webinar on Wednesday, February 1, 2023, from 1 p.m. to 4 p.m. See section IX, “Public Participation,” for webinar registration information, participant instructions, and information about the capabilities available to webinar participants.
ADDRESSES:
Interested persons are encouraged to submit comments using the Federal eRulemaking Portal at
www.regulations.gov,
under docket number EERE-2022-BT-STD-0022. Follow the instructions for submitting comments. Alternatively, interested persons may submit comments, identified by docket number EERE-2022-BT-STD-0022, by any of the following methods:
Email: GSL2022STD0022@ee.doe.gov.
Include the docket number EERE-2022-BT-STD-0022 in the subject line of the message.
Postal Mail:
Appliance and Equipment Standards Program, U.S. Department of Energy, Building Technologies Office, Mailstop EE-5B, 1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone: (202) 287-1445. If possible, please submit all items on a compact disc (CD), in which case it is not necessary to include printed copies.
Hand Delivery/Courier:
Appliance and Equipment Standards Program, U.S. Department of Energy, Building Technologies Office, 950 L'Enfant Plaza SW, 6th Floor, Washington, DC 20024. Telephone: (202) 287-1445. If possible, please submit all items on a CD, in which case it is not necessary to include printed copies.
No telefacsimiles (faxes) will be accepted. For detailed instructions on submitting comments and additional information on the rulemaking process, see section IX of this document.
Docket:
The docket for this activity, which includes
Federal Register
notices, 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, not all documents listed in the index may be publicly available, such as information that is exempt from public disclosure.
The docket web page can be found at
www.regulations.gov/docket/EERE-2022-BT-STD-0022.
The docket web page contains instructions on how to access all documents, including public comments, in the docket. See section IX of this document for information on how to submit comments through
www.regulations.gov.
EPCA requires the Attorney General to provide DOE a written determination of whether the proposed standard is likely to lessen competition. The U.S. Department of Justice Antitrust Division invites input from market participants and other interested persons with views on the likely competitive impact of the proposed standard. Interested persons may contact the Division at
energy.standards@usdoj.gov
on or before the date specified in the
DATES
section. Please indicate in the “Subject” line of your email the title and Docket Number of this proposed rule.
FOR FURTHER INFORMATION CONTACT:
Mr. Bryan Berringer, 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) 586-0371. Email:
ApplianceStandardsQuestions@ee.doe.gov.
Ms. Celia Sher, U.S. Department of Energy, Office of the General Counsel, GC-33, 1000 Independence Avenue SW, Washington, DC 20585-0121. Telephone: (202) 287-6122. Email:
Celia.Sher@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 the Appliance and Equipment Standards Program staff at (202) 287-1445 or by email:
ApplianceStandardsQuestions@ee.doe.gov.
SUPPLEMENTARY INFORMATION:
DOE proposes to incorporate by reference the following industry test standard into 10 CFR part 430:
Underwriters Laboratories (UL) 1598C, “UL 1598C Standard for Safety Light-Emitting Diode (LED) Retrofit Luminaire Conversion Kits,” approved January 12, 2017.
Copies of UL 1598C can be obtained by going to
https://www.shopulstandards.com/Default.aspx.
For a further discussion of this standard, see section VIII.M of this document.
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. History of Standards Rulemaking for General Service Lamps
2. Current Standards
III. General Discussion
A. Product Classes and Scope of Coverage
B. Test Procedure
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. Scope of Coverage
A. Definitions of General Service Lamp, Compact Fluorescent Lamp, General
Service LED Lamp, General Service OLED Lamp, General Service Incandescent Lamp
B. Supporting Definitions
C. GSLs Evaluated for Potential Standards in This NOPR
V. Scope of Metrics
1. Lumens per Watt (Lamp Efficacy)
2. Power Factor
3. Lifetime
4. Start Time
5. CRI
6. Summary of Metrics
VI. Methodology and Discussion
A. Market and Technology Assessment
1. Product Classes
a. Lamp Component Location
b. Standby Mode Operation
c. Directionality
d. Lamp Length
e. Product Class Summary
2. Technology Options
B. Screening Analysis
1. Screened-Out Technologies
2. Remaining Technologies
C. Engineering Analysis
1. Efficiency Analysis
2. Representative Product Classes
3. Baseline Lamps
a. Integrated Omnidirectional Short Product Class
b. Integrated Omnidirectional Long Product Class
c. Integrated Directional Product Class
d. Non-Integrated Omnidirectional Short Product Class
e. Non-Integrated Directional Product Class
4. More Efficacious Substitutes
a. Integrated Omnidirectional Short Product Class
b. Integrated Omnidirectional Long Product Class
c. Integrated Directional Product Class
d. Non-Integrated Omnidirectional Short Product Class
e. Non-Integrated Directional Product Class
5. Efficacy Levels
a. Equation Form
b. Integrated Omnidirectional Short Product Classes
c. Integrated Omnidirectional Long Product Class
d. Integrated Directional Product Class
e. Non-Integrated Omnidirectional Short Product Class
f. Non-Integrated Directional Product Class
6. Scaling to Other Product Classes
a. Scaling of Integrated Standby Mode Product Classes
b. Scaling of Non-Integrated Long Product Class
7. Summary of All Efficacy Levels
D. Cost Analysis
E. Energy Use Analysis
1. Operating Hours
a. Residential Sector
b. Commercial Sector
2. Input Power
3. Lighting Controls
F. Life-Cycle Cost and Payback Period Analysis
1. Product Cost
2. Installation Cost
3. Annual Energy Consumption
4. Energy Prices
5. Product Lifetime
6. Residual Value
7. Disposal Cost
8. Discount Rates
a. Residential
b. Commercial
9. Efficacy Distribution in the No-New-Standards Case
10. LCC Savings Calculation
11. Payback Period Analysis
G. Shipments Analysis
1. Shipments Model
a. Lamp Demand Module
b. Price-Learning Module
c. Market-Share Module
H. National Impact Analysis
1. National Energy Savings
a. Smart Lamps
b. Unit Energy Consumption Adjustment To Account for GSL Lumen Distribution for the Integrated Omnidirectional Short Product Class
c. Unit Energy Consumption Adjustment To Account for Type A Integrated Omnidirectional Long Lamps
2. Net Present Value Analysis
I. Consumer Subgroup Analysis
J. Manufacturer Impact Analysis
1. Overview
2. Government Regulatory Impact Model and Key Inputs
a. Manufacturer Production Costs
b. Shipments Projections
c. Product and Capital Conversion Costs
d. Markup Scenarios
K. Emissions Analysis
1. Air Quality Regulations Incorporated in DOE's Analysis
L. Monetizing Emissions Impacts
1. Monetization of Greenhouse Gas Emissions
a. Social Cost of Carbon
b. Social Cost of Methane and Nitrous Oxide
2. Monetization of Other Air Pollutants
M. Utility Impact Analysis
N. Employment Impact Analysis
VII. Analytical Results and Conclusions
A. Trial Standard Levels
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
a. Life-Cycle Cost and Payback Period
b. Consumer Subgroup Analysis
c. Rebuttable Presumption Payback
2. Economic Impacts on Manufacturers
a. Industry Cash Flow Analysis Results
b. Direct 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 Economic Impacts
C. Conclusion
1. Benefits and Burdens of TSLs Considered for GSLs Standards
2. Annualized Benefits and Costs of the Proposed Standards
D. Reporting, Certification, and Sampling Plan
VIII. 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 Including Differences in Cost, if Any, for Different Groups of Small Entities
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. Information Quality
M. Description of Materials Incorporated by Reference
IX. Public Participation
A. Participation in the Webinar
B. Procedure for Submitting Prepared General Statements for Distribution
C. Conduct of the Webinar
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
X. Approval of the Office of the Secretary
I. Synopsis of the Proposed Rule
Title III, Part B
1
of the EPCA,
2
established the Energy Conservation Program for Consumer Products Other Than Automobiles. (42 U.S.C. 6291-6309) These products include GSLs, the subject of this proposed rulemaking.
1
For editorial reasons, upon codification in the U.S. Code, part B was redesignated part A. All references to part B in this document refer to the redesignated part A.
2
All references to EPCA in this document refer to the statute as amended through the Energy Act of 2020, Public Law 116-260 (Dec. 27, 2020), which reflect the last statutory amendments that impact parts A and A-1 of EPCA.
DOE is issuing this NOPR pursuant to multiple provisions in EPCA. First, EPCA requires that DOE must initiate a second rulemaking cycle by January 1, 2020, to determine whether standards in effect for general service incandescent lamps (GSILs) should be amended with more stringent energy conservation standards and if the exemptions for certain incandescent lamps should be maintained or discontinued. For this second review of energy conservation standards, the scope of rulemaking is not limited to incandescent technologies. (42 U.S.C. 6295(i)(6)(B)(ii))
Second, 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 (proceeding to a final rule, as appropriate). (42 U.S.C. 6295(m)) Third, pursuant to EPCA, any new or amended energy conservation standard must be designed to achieve the maximum improvement in energy efficiency that DOE determines is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, the new or amended standard must result in a significant conservation of energy. (42 U.S.C. 6295(o)(3)(B)) Lastly, 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))
In accordance with these and other statutory provisions discussed in this document, DOE proposes energy conservation standards for GSLs. This is the second rulemaking cycle for GSLs. As a result of the first rulemaking cycle, there is currently a sales prohibition on the sale of any GSLs that do not meet a minimum efficacy standard of 45 lumens per watt. There are existing DOE energy conservation standards higher than 45 lumens per watt for medium base compact fluorescent lamps (MBCFLs), which are types of GSLs. 70 FR 60407 (Oct. 18, 2005). The standards proposed in this rulemaking, which are expressed in minimum lumens (lm) output per watt (W) of a lamp or lamp efficacy (lm/W), are shown in Table I.1. These proposed standards, if adopted, would apply to all GSLs listed in Table I.1 manufactured in, or imported into, the United States beginning on the effective date for the standard.
EP11JA23.000
A. 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 (2022-2058). Using a real discount rate of 6.1 percent, DOE estimates that the INPV for manufacturers of GSLs in the case without new and amended standards is $2,014 million in 2021$. Under the proposed new and amended standards, the change in INPV is estimated to range from −13.5 percent to −7.2 percent, which is approximately −$271 million to −$145 million. In order to bring products into compliance with new and amended standards, it is estimated that the industry would incur total conversion costs of $407 million.
DOE's analysis of the impacts of the proposed standards on manufacturers is described in section VI.J of this document. The analytic results of the manufacturer impact analysis (MIA) are presented in section VII.B.2 of this document.
B. Benefits and Costs to Consumers
Table I.2 presents DOE's evaluation of the economic impacts of the proposed standards on consumers of GSLs, as measured by the average life-cycle cost (LCC) savings and the simple payback period (PBP).
3
The average LCC savings
are positive for all product classes, and the PBP is less than the average lifetime of GSLs, which varies by product class and efficiency level (see section VI.F.5 of this document).
3
The average LCC savings refer to consumers that are affected by a standard and are measured relative to the efficiency distribution in the no-new-standards case, which depicts the market in the first full year of compliance in the absence of new or amended standards (see section VI.F.11 of this document). The simple PBP, which is designed to
compare specific efficiency levels, is measured relative to the baseline product (see section VI.F.13 of this document).
Table I.2—Impacts of Proposed Energy Conservation Standards on Consumers of GSLs
Product class
Average
LCC savings
(2021$)
Simple
payback
period
(years)
Residential:
Integrated Omnidirectional Short
0.59
0.8
Integrated Omnidirectional Long
1.82
5.4
Integrated Directional
3.01
0.0
Non-integrated Omnidirectional *
Non-integrated Directional
0.28
4.2
Commercial:
Integrated Omnidirectional Short
1.11
0.5
Integrated Omnidirectional Long
4.74
2.9
Integrated Directional
3.86
0.0
Non-integrated Omnidirectional
6.62
2.1
Non-integrated Directional
0.69
2.8
* Non-integrated Omnidirectional GSLs were only analyzed for the commercial sector.
DOE's analysis of the impacts of the proposed standards on consumers is described in section VII.B.1 of this document.
C. National Benefits and Costs
4
4
All monetary values in this document are expressed in 2021 dollars.
DOE's analyses indicate that the proposed energy conservation standards for GSLs would save a significant amount of energy. Relative to the case without new or amended standards, the lifetime energy savings for GSLs purchased in the 30-year period that begins in the anticipated first full year of compliance with the amended standards (2029-2058) amount to 4.0 quadrillion British thermal units (Btu), or quads.
5
This represents a savings of 48 percent relative to the energy use of these products in the case without amended standards (referred to as the “no-new-standards case”).
5
The quantity refers to full-fuel-cycle (FFC) energy savings. FFC energy savings includes the energy consumed in extracting, processing, and transporting primary fuels (
i.e.,
coal, natural gas, petroleum fuels), and, thus, presents a more complete picture of the impacts of energy efficiency standards. For more information on the FFC metric, see section VI.H.1 of this document.
The cumulative net present value (NPV) of total consumer benefits of the proposed standards for GSLs ranges from $7.29 billion (at a 7-percent discount rate) to $20.37 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 GSLs purchased in 2029-2058.
In addition, the proposed standards for GSLs are projected to yield significant environmental benefits. DOE estimates that the proposed standards would result in cumulative emission reductions (over the same period as for energy savings) of 130.63 million metric tons (Mt)
6
of carbon dioxide (CO
2
), 59.27 thousand tons of sulfur dioxide (SO
2
), 203.05 thousand tons of nitrogen oxides (NO
X
), 902.76 thousand tons of methane (CH
4
), 1.36 thousand tons of nitrous oxide (N
2
O), and 0.39 tons of mercury (Hg).
7
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-new-standards case, which reflects key assumptions in the
Annual Energy Outlook 2022
(
AEO2022
).
AEO2022
represents current federal and state legislation and final implementation of regulations as of the time of its preparation. See section VI.K of this document for further discussion of
AEO2022
assumptions that effect air pollutant emissions.
DOE estimates the value of climate benefits from a reduction in greenhouse gases (GHG) using four different estimates of the social cost of CO
2
(SC-CO
2
), the social cost of methane (SC-CH
4
), and the social cost of nitrous oxide (SC-N
2
O). Together these represent the social cost of GHG (SC-GHG). DOE used interim SC-GHG values developed by an Interagency Working Group on the Social Cost of Greenhouse Gases (IWG).
8
The derivation of these values is discussed in section VI.L of this document. For presentational purposes, the climate benefits associated with the average SC-GHG at a 3-percent discount rate are estimated to be $5.9 billion. DOE does not have a single central SC-GHG point estimate and it emphasizes the importance and value of considering the benefits calculated using all four SC-GHG estimates.
9
8
See
Interagency Working Group on Social Cost of Greenhouse Gases, Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide. Interim Estimates Under Executive Order 13990, Washington, DC, February 2021.
https://www.whitehouse.gov/wp-content/uploads/2021/02/TechnicalSupportDocument_SocialCostofCarbonMethaneNitrousOxide.pdf.
9
On March 16, 2022, the Fifth Circuit Court of Appeals (No. 22-30087) granted the federal government's emergency motion for stay pending appeal of the February 11, 2022, preliminary injunction issued in
Louisiana
v.
Biden,
No. 21-cv-1074-JDC-KK (W.D. La.). As a result of the Fifth Circuit's order, the preliminary injunction is no longer in effect, pending resolution of the federal government's appeal of that injunction or a further court order. Among other things, the preliminary injunction enjoined the defendants in that case from “adopting, employing, treating as binding, or relying upon” the interim estimates of the social cost of greenhouse gases—which were issued by the Interagency Working Group on the Social Cost of Greenhouse Gases on February 26, 2021—to monetize the benefits of reducing greenhouse gas emissions. As reflected in this proposed rule, DOE has reverted to its approach prior to the injunction and presents monetized greenhouse gas abatement benefits where appropriate and permissible under law.
DOE estimated the monetary health benefits of SO
2
and NO
X
emissions reductions, also discussed in section VI.L of this document. DOE estimated the present value of the health benefits would be $3.6 billion using a 7-percent discount rate, and $10.1 billion using a 3-percent discount rate.
10
DOE is currently only monetizing (for SO
2
and NO
X
) particulate matter (PM)
2.5
precursor health benefits and (for NO
X
) ozone precursor health benefits, but will
continue to assess the ability to monetize other effects such as health benefits from reductions in direct PM
2.5
emissions.
10
DOE estimates the economic value of these emissions reductions resulting from the considered TSLs for the purpose of complying with the requirements of Executive Order 12866.
Table I.3 summarizes the economic benefits and costs expected to result from the proposed standards for GSLs. There are other important unquantified effects, including certain unquantified climate benefits, unquantified public health benefits from the reduction of toxic air pollutants and other emissions, unquantified energy security benefits, and distributional effects, among others.
Table I.3—Summary of Economic Benefits and Costs of Proposed Energy Conservation Standards for GSLs (TSL 6)
Billion 2021$
3% discount rate
Consumer Operating Cost Savings
25.0
Climate Benefits *
5.9
Health Benefits **
10.1
Total Benefits †
41.0
Consumer Incremental Product Costs ‡
4.6
Net Benefits
36.4
7% discount rate
Consumer Operating Cost Savings
9.7
Climate Benefits * (3% discount rate)
5.9
Health Benefits **
3.6
Total Benefits †
19.1
Consumer Incremental Product Costs ‡
2.4
Net Benefits
16.7
Note:
This table presents the costs and benefits associated with GSLs shipped in 2029-2058. These results include benefits to consumers which accrue after 2058 from the products shipped in 2029-2058.
* Climate benefits are calculated using four different estimates of the social cost of carbon (SC-CO
2
), methane (SC-CH
4
), and nitrous oxide (SC-N
2
O) (model average at 2.5 percent, 3 percent, and 5 percent discount rates; 95th percentile at 3 percent discount rate) (see section VI.L of this rulemaking). Together these represent the global SC-GHG. For presentational purposes of this table, the climate benefits associated with the average SC-GHG at a 3 percent discount rate are shown, but DOE does not have a single central SC-GHG point estimate. On March 16, 2022, the Fifth Circuit Court of Appeals (No. 22-30087) granted the federal government's emergency motion for stay pending appeal of the February 11, 2022, preliminary injunction issued in
Louisiana
v.
Biden,
No. 21-cv-1074-JDC-KK (W.D. La.). As a result of the Fifth Circuit's order, the preliminary injunction is no longer in effect, pending resolution of the federal government's appeal of that injunction or a further court order. Among other things, the preliminary injunction enjoined the defendants in that case from “adopting, employing, treating as binding, or relying upon” the interim estimates of the social cost of greenhouse gases—which were issued by the Interagency Working Group on the Social Cost of Greenhouse Gases on February 26, 2021—to monetize the benefits of reducing greenhouse gas emissions. As reflected in this proposed rule, DOE has reverted to its approach prior to the injunction and presents monetized greenhouse gas abatement benefits where appropriate and permissible under law.
** Health benefits are calculated using benefit-per-ton values for NO
X
and SO
2
. DOE is currently only monetizing (for NO
X
and SO
2
) PM
2.5
precursor health benefits and (for NO
X
) ozone precursor health benefits, but will continue to assess the ability to monetize other effects such as health benefits from reductions in direct PM
2.5
emissions. See section VI.L of this document for more details.
† Total benefits for both the 3-percent and 7-percent cases are presented using the average SC-GHG with 3-percent discount rate, but the Department does not have a single central SC-GHG point estimate. DOE emphasizes the importance and value of considering the benefits calculated using all four SC-GHG estimates. See Table VII.27 for net benefits using all four SC-GHG estimates.
† Costs include incremental equipment costs as well as installation costs.
The benefits and costs of the proposed standards can also be expressed in terms of annualized values. The monetary values for the total annualized net benefits are (1) the reduced consumer operating costs, minus (2) the increase in product purchase prices and installation costs, plus (3) the value of climate and health benefits of emission reduction, all annualized.
11
The national operating savings are domestic private U.S. consumer monetary savings that occur as a result of purchasing the covered products and are measured for the lifetime of GSLs shipped in 2029-2058. The benefits associated with reduced emissions achieved as a result of the proposed standards are also calculated based on the lifetime of GSLs shipped in 2029-2058. Total benefits for both the 3-percent and 7-percent cases are presented using the average social costs with 3-percent discount rate. Estimates of SC-GHG values are presented for all four discount rates in section VII.B.8 of this document. Table I.4 presents the total estimated monetized benefits and costs associated with the proposed standard, expressed in terms of annualized values.
11
To convert the time-series of costs and benefits into annualized values, DOE calculated a present value in 2022, 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.,
2030), and then discounted the present value from each year to 2022. Using the present value, DOE then calculated the fixed annual payment over a 30-year period, starting in the compliance year, that yields the same present value.
Table I.4—Annualized Benefits and Costs of Proposed Energy Conservation Standards for GSLs (TSL 6)
Million 2021$/year
Primary estimate
Low-net-benefits estimate
High-net-benefits estimate
3% discount rate
Consumer Operating Cost Savings
1,521.4
1,469.8
1,586.0
Climate Benefits *
358.1
357.7
358.5
Health Benefits **
615.6
615.0
616.3
Total Benefits †
2,495.1
2,442.5
2,560.8
Consumer Incremental Product Costs ‡
280.3
291.0
270.0
Net Benefits
2,214.8
2,151.6
2,290.7
7% discount rate
Consumer Operating Cost Savings
1,171.5
1,135.9
1,215.2
Climate Benefits * (3% discount rate)
358.1
357.7
358.5
Health Benefits **
432.0
431.7
432.4
Total Benefits †
1,961.6
1,925.3
2,006.1
Consumer Incremental Product Costs ‡
289.4
299.4
279.8
Net Benefits
1,672.2
1,625.9
1,726.3
Note:
This table presents the costs and benefits associated with GSLs shipped in 2029-2058. These results include benefits to consumers which accrue after 2058 from the products shipped in 2029-2058. The Primary, Low Net Benefits, and High Net Benefits Estimates utilize projections of energy prices from the AEO2022 Reference case, Low Economic Growth case, and High Economic Growth case, respectively. In addition, LED lamp prices reflect a higher price learning rate in the Low Net Benefits Estimate, and a lower price learning rate in the High Net Benefits Estimate. See section VII.B.3.b for discussion. The methods used to derive projected price trends are explained in section VI.G.1.b of this document. Note that the Benefits and Costs may not sum to the Net Benefits due to rounding.
* Climate benefits are calculated using four different estimates of the global SC-GHG (see section VI.L of this rulemaking). For presentational purposes of this table, the climate benefits associated with the average SC-GHG at a 3 percent discount rate are shown, but the Department does not have a single central SC-GHG point estimate, and it emphasizes the importance and value of considering the benefits calculated using all four SC-GHG estimates. On March 16, 2022, the Fifth Circuit Court of Appeals (No. 22-30087) granted the federal government's emergency motion for stay pending appeal of the February 11, 2022, preliminary injunction issued in
Louisiana
v.
Biden,
No. 21-cv-1074-JDC-KK (W.D. La.). As a result of the Fifth Circuit's order, the preliminary injunction is no longer in effect, pending resolution of the federal government's appeal of that injunction or a further court order. Among other things, the preliminary injunction enjoined the defendants in that case from “adopting, employing, treating as binding, or relying upon” the interim estimates of the social cost of greenhouse gases—which were issued by the Interagency Working Group on the Social Cost of Greenhouse Gases on February 26, 2021—to monetize the benefits of reducing greenhouse gas emissions. As reflected in this proposed rule, DOE has reverted to its approach prior to the injunction and presents monetized greenhouse gas abatement benefits where appropriate and permissible under law.
** Health benefits are calculated using benefit-per-ton values for NO
X
and SO
2
. DOE is currently only monetizing (for SO
2
and NO
X
) PM
2.5
precursor health benefits and (for NO
X
) ozone precursor health benefits, but will continue to assess the ability to monetize other effects such as health benefits from reductions in direct PM
2.5
emissions. See section VI.L of this document for more details.
† Total benefits for both the 3-percent and 7-percent cases are presented using the average SC-GHG with 3-percent discount rate, but the Department does not have a single central SC-GHG point estimate.
‡ Costs include incremental equipment costs as well as installation costs
DOE's analysis of the national impacts of the proposed standards is described in sections VI.H of this document.
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. With regards to technological feasibility, products achieving these standard levels are already commercially available for all product classes covered by this proposal. As for economic justification, DOE's analysis shows that the benefits of the proposed standard exceed, to a great extent, the burdens of the proposed standards. Using a 7-percent discount rate for consumer benefits and costs and NO
X
and SO
2
reduction benefits, and a 3-percent discount rate case for GHG social costs, the estimated cost of the proposed standards for GSLs is $289.4 million per year in increased product costs, while the estimated annual benefits are $1.17 billion in reduced product operating costs, $358.1 million in climate benefits, and $432.0 million in health benefits. The net benefit amounts to $1.67 billion per year.
The significance of energy savings offered by a new or amended energy conservation standard cannot be determined without knowledge of the specific circumstances surrounding a given rulemaking.
12
For example, some covered products and equipment have most of their energy consumption occur during periods of peak energy demand. The impacts of these products on the energy infrastructure can be more pronounced than products with relatively constant demand. Accordingly, DOE evaluates the significance of energy savings on a case-by-case basis.
12
Procedures, Interpretations, and Policies for Consideration in New or Revised Energy Conservation Standards and Test Procedures for Consumer Products and Commercial/Industrial Equipment, 86 FR 70892, 70901 (Dec. 13, 2021).
As previously mentioned, the standards are projected to result in estimated national FFC energy savings of 4.0 quads, the equivalent of the primary annual energy use of 43.0 million homes. In addition, they are projected to reduce CO
2
emissions by 130.63 Mt. Based on these findings, DOE has initially determined the energy savings from the proposed standard levels are “significant” within the meaning of 42 U.S.C. 6295(o)(3)(B). A
more detailed discussion of the basis for these tentative conclusions is contained in the remainder of this document and the accompanying TSD.
DOE also considered less-stringent energy efficiency levels as potential standards, and is still considering them in this rulemaking. However, DOE has tentatively concluded that TSL 6 achieves the maximum improvement in energy efficiency that is technologically feasible and economically justified.
Based on consideration of the public comments DOE receives in response to this document and related information collected and analyzed during the course of this rulemaking effort, DOE may adopt energy efficiency levels presented in this document that are lower than the proposed standards, or some combination of level(s) that incorporate the proposed standards in part.
II. Introduction
The following section briefly discusses the statutory authority underlying this proposed rule, as well as some of the relevant historical background related to the establishment of standards for GSLs.
A. Authority
EPCA authorizes DOE to regulate the energy efficiency of a number of consumer products and certain industrial equipment. Title III, Part B of EPCA established the Energy Conservation Program for Consumer Products Other Than Automobiles. These products include GSLs, the subject of this document. 42 U.S.C. 6295(i)(6))
EPCA directs DOE to conduct two rulemaking cycles to evaluate energy conservation standards for GSLs. (42 U.S.C. 6295(i)(6)(A)-(B)) For the first rulemaking cycle, EPCA directed DOE to initiate a rulemaking process prior to January 1, 2014, to determine whether: (1) to amend energy conservation standards for GSLs and (2) the exemptions for certain incandescent lamps should be maintained or discontinued. (42 U.S.C. 6295(i)(6)(A)(i)) The rulemaking was not to be limited to incandescent lamp technologies and was required to include a consideration of a minimum standard of 45 lm/W for GSLs. (42 U.S.C. 6295(i)(6)(A)(ii)) EPCA provides that if the Secretary determined that the standards in effect for GSILs should be amended, a final rule must be published by January 1, 2017, with a compliance date at least 3 years after the date on which the final rule is published. (42 U.S.C. 6295(i)(6)(A)(iii)) The Secretary was also required to consider phased-in effective dates after considering certain manufacturer and retailer impacts. (42 U.S.C. 6295(i)(6)(A)(iv)) If DOE failed to complete a rulemaking in accordance with 42 U.S.C. 6295(i)(6)(A)(i)-(iv), or if a final rule from the first rulemaking cycle did not produce savings greater than or equal to the savings from a minimum efficacy standard of 45 lm/W, the statute provides a “backstop” under which DOE was required to prohibit sales of GSLs that do not meet a minimum 45 lm/W standard. (42 U.S.C. 6295(i)(6)(A)(v)). As a result of DOE's failure to complete a rulemaking in accordance with the statutory criteria, DOE codified this backstop requirement in a rule issued on May 9, 2022. 87 FR 27439 (May 2022 Backstop Final Rule)
EPCA further directs DOE to initiate a second rulemaking cycle by January 1, 2020, to determine whether standards in effect for GSILs (which are a subset of GSLs)) should be amended with more stringent maximum wattage requirements than EPCA specifies, and whether the exemptions for certain incandescent lamps should be maintained or discontinued. (42 U.S.C. 6295(i)(6)(B)(i)) As in the first rulemaking cycle, the scope of the second rulemaking is not limited to incandescent lamp technologies. (42 U.S.C. 6295(i)(6)(B)(ii)) As previously stated in Section I of this document, DOE is publishing this NOPR pursuant to this second cycle of rulemaking, as well as section (m) of 42 U.S.C. 6295.
The energy conservation program under EPCA consists essentially of four parts: (1) testing, (2) labeling, (3) the establishment of Federal energy conservation standards, and (4) certification and enforcement procedures. Relevant provisions of EPCA specifically include definitions (42 U.S.C. 6291), test procedures (42 U.S.C. 6293), labeling provisions (42 U.S.C. 6294), energy conservation standards (42 U.S.C. 6295), and the authority to require information and reports from manufacturers (42 U.S.C. 6296).
Federal energy efficiency requirements for covered products established under EPCA generally supersede State laws and 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 EPCA. (See 42 U.S.C. 6297(d))
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 42 U.S.C. 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 GSLs appear at title 10 of the Code of Federal Regulations (CFR) part 430, subpart B, appendices R, W, BB, and DD.
DOE must follow specific statutory criteria for prescribing new or amended standards for covered products, including GSLs. Any new or amended standard for a covered product must be designed to achieve the maximum improvement in energy efficiency that the Secretary of Energy determines is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A) and 42 U.S.C. 6295(o)(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 GSLs, if no test procedure has been established for the product, or (2) if DOE determines by rule that the standard is not technologically feasible or economically justified. (42 U.S.C. 6295(o)(3)(A)-(B)) In deciding whether a proposed standard is economically justified, DOE must determine whether the benefits of the standard exceed its burdens. (42 U.S.C. 6295(o)(2)(B)(i)) DOE must make this determination after receiving comments on the proposed standard, and by considering, to the greatest extent practicable, the following seven statutory factors:
(1) The economic impact of the standard on manufacturers and consumers of the products subject to the standard;
(2) The savings in operating costs throughout the estimated average life of the covered products in the type (or class) compared to any increase in the price, initial charges, or maintenance expenses for the covered products that are likely to result from the standard;
(3) The total projected amount of energy (or as applicable, water) savings likely to result directly from the standard;
(4) Any lessening of the utility or the performance of the covered products likely to result from the standard;
(5) The impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to result from the standard;
(6) The need for national energy and water conservation; and
(7) Other factors the Secretary of Energy (Secretary) considers relevant.
(42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))
Further, EPCA establishes a rebuttable presumption that a standard is economically justified if the Secretary finds that the additional cost to the consumer of purchasing a product complying with an energy conservation standard level will be less than three times the value of the energy savings during the first year that the consumer will receive as a result of the standard, as calculated under the applicable test procedure. (42 U.S.C. 6295(o)(2)(B)(iii))
EPCA also contains what is known as an “anti-backsliding” provision, which prevents the Secretary from prescribing any amended standard that either increases the maximum allowable energy use or decreases the minimum required energy efficiency of a covered product. (42 U.S.C. 6295(o)(1)) Also, the Secretary may not prescribe an amended or new standard if interested persons have established by a preponderance of the evidence that the standard is likely to result in the unavailability in the United States in any covered product type (or class) of performance characteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as those generally available in the United States. (42 U.S.C. 6295(o)(4))
Additionally, EPCA 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))
Finally, pursuant to the amendments contained in the Energy Independence and Security Act of 2007 (EISA), Public Law 110-140, any final rule for new or amended energy conservation standards promulgated after July 1, 2010, is required to address standby mode and off mode energy use. (42 U.S.C. 6295(gg)(3)) Specifically, when DOE adopts a standard for a covered product after that date, it must, if justified by the criteria for adoption of standards under EPCA (42 U.S.C. 6295(o)), incorporate standby mode and off mode energy use into a single standard, or, if that is not feasible, adopt a separate standard for such energy use for that product. (42 U.S.C. 6295(gg)(3)(A)-(B)) DOE determined that it is not feasible for GSLs included in the scope of this rulemaking to meet the off-mode criteria because there is no condition in which a GSL connected to main power is not already in a mode accounted for in either active or standby mode. DOE notes the existence of commercially available GSLs that operate in standby mode. DOE's current test procedures for GSLs address standby mode and off mode energy use. In this rulemaking, DOE intends to incorporate such energy use into any amended energy conservation standards that it may adopt.
B. Background
1. History of Standards Rulemaking for General Service Lamps
Pursuant to its statutory authority to complete the first cycle of rulemaking for GSLs, DOE published a notice of proposed rulemaking (NOPR) on March 17, 2016, that addressed the first question that Congress directed it to consider—whether to amend energy conservation standards for GSLs (March 2016 NOPR). 81 FR 14528, 14629-14630 (Mar. 17, 2016). In the March 2016 NOPR, DOE stated that it would be unable to undertake any analysis regarding GSILs and other incandescent lamps because of a then-applicable congressional restriction (the Appropriations Rider).
See
81 FR 14528, 14540-14541. The Appropriations Rider prohibited expenditure of funds appropriated by that law to implement or enforce: (1) 10 CFR 430.32(x), which includes maximum wattage and minimum rated lifetime requirements for GSILs; and (2) standards set forth in section 325(i)(1)(B) of EPCA (42 U.S.C. 6295(i)(1)(B)), which sets minimum lamp efficiency ratings for incandescent reflector lamps (IRLs). Under the Appropriations Rider, DOE was restricted from undertaking the analysis required to address the first question presented by Congress, but was not so limited in addressing the second question—that is, DOE was not prevented from determining whether the exemptions for certain incandescent lamps should be maintained or discontinued. To address that second question, DOE published a Notice of Proposed Definition and Data Availability (NOPDDA), which proposed to amend the definitions of GSIL, GSL, and related terms (October 2016 NOPDDA). 81 FR 71794, 71815 (Oct. 18, 2016). The Appropriations Rider, which was originally adopted in 2011 and readopted and extended continuously in multiple subsequent legislative actions, expired on May 5, 2017, when the Consolidated Appropriations Act, 2017 was enacted.
13
13
See Consolidated Appropriations Act of 2017 (Pub. L. 115-31, div. D, tit. III); see also Consolidated Appropriations Act, 2018 (Pub. L. 115-141).
On January 19, 2017, DOE published two final rules concerning the definitions of GSL, GSIL, and related terms (January 2017 Definition Final Rules). 82 FR 7276; 82 FR 7322. The January 2017 Definition Final Rules amended the definitions of GSIL and GSL by bringing certain categories of lamps that had been excluded by statute from the definition of GSIL within the definitions of GSIL and GSL. DOE determined to use two final rules in 2017 to amend the definitions of GSIL and GSLs in order to address the majority of the definition changes in one final rule and the exemption for IRLs in the second final rule. These two rules were issued simultaneously, with the first rule eschewing a determination regarding the existing exemption for IRLs in the definition of GSL and the second rulemaking discontinuing that exemption from the GSL definition. 82 FR 7276, 7312; 82 FR 7322, 7323. As in the October 2016 NOPDDA, DOE stated that the January 2017 Definition Final Rules related only to the second question that Congress directed DOE to consider, regarding whether to maintain or discontinue “exemptions” for certain incandescent lamps. 82 FR 7276, 7277; 82 FR 7322, 7324 (See also 42 U.S.C. 6295(i)(6)(A)(i)(II)). That is, neither of the two final rules issued on January 19, 2017, established energy conservation standards applicable to GSLs. DOE explained that the Appropriations Rider prevented it from establishing, or even analyzing, standards for GSILs. 82 FR 7276, 7278. Instead, DOE explained that it would either impose standards for GSLs in the future pursuant to its authority to develop GSL standards, or
apply the backstop standard prohibiting the sale of lamps not meeting a 45 lm/W efficacy standard. 82 FR 7276, 7277-7278. The two final rules were to become effective as of January 1, 2020.
On March 17, 2017, the National Electrical Manufacturer's Association (NEMA) filed a petition for review of the January 2017 Definition Final Rules in the U.S. Court of Appeals for the Fourth Circuit.
National Electrical Manufacturers Association
v.
United States Department of Energy,
No. 17-1341. NEMA claimed that DOE “amend[ed] the statutory definition of `general service lamp' to include lamps that Congress expressly stated were `not include[d]' in the definition” and adopted an “unreasonable and unlawful interpretation of the statutory definition.” Pet. 2. Prior to merits briefing, the parties reached a settlement agreement under which DOE agreed, in part, to issue a notice of data availability requesting data for GSILs and other incandescent lamps to assist DOE in determining whether standards for GSILs should be amended (the first question of the rulemaking required by 42 U.S.C. 6295(i)(6)(A)(i)).
With the removal of the Appropriations Rider in the Consolidated Appropriations Act, 2017, DOE was no longer restricted from undertaking the analysis and decision-making required to address the first question presented by Congress,
i.e.,
whether to amend energy conservation standards for GSLs, including GSILs. Thus, on August 15, 2017, DOE published a notice of data availability and request for information (NODA) seeking data for GSILs and other incandescent lamps (August 2017 NODA). 82 FR 38613.
The purpose of the August 2017 NODA was to assist DOE in determining whether standards for GSILs should be amended. (42 U.S.C. 6295(i)(6)(A)(i)(I)) Comments submitted in response to the August 2017 NODA also led DOE to re-consider the decisions it had already made with respect to the second question presented to DOE—whether the exemptions for certain incandescent lamps should be maintained or discontinued. 84 FR 3120, 3122 (See also 42 U.S.C. 6295(i)(6)(A)(i)(II)) As a result of the comments received in response to the August 2017 NODA, DOE also re-assessed the legal interpretations underlying certain decisions made in the January 2017 Definition Final Rules.
Id.
On February 11, 2019, DOE published a NOPR proposing to withdraw the revised definitions of GSL, GSIL, and the new and revised definitions of related terms that were to go into effect on January 1, 2020 (February 2019 Definition NOPR). 84 FR 3120. In a final rule published September 5, 2019, DOE finalized the withdrawal of the definitions in the January 2017 Definition Final Rules and maintained the existing regulatory definitions of GSL and GSIL, which are the same as the statutory definitions of those terms (September 2019 Withdrawal Rule). 84 FR 46661. The September 2019 Withdrawal Rule revisited the same primary question addressed in the January 2017 Definition Final Rules, namely, the statutory requirement for DOE to determine whether “the exemptions for certain incandescent lamps should be maintained or discontinued.” 42 U.S.C. 6295(i)(6)(A)(i)(II) (
See
also 84 FR 46661, 46667). In the rule, DOE also addressed its interpretation of the statutory backstop at 42 U.S.C. 6295(i)(6)(A)(v) and concluded the backstop had not been triggered. 84 FR 46661, 46663-46664. DOE reasoned that 42 U.S.C. 6295(i)(6)(A)(iii) “does not establish an absolute obligation on the Secretary to publish a rule by a date certain.” 84 FR 46661, 46663. “Rather, the obligation to issue a final rule prescribing standards by a date certain applies if, and only if, the Secretary makes a determination that standards in effect for GSILs need to be amended.”
Id.
DOE further stated that, since it had not yet made the predicate determination on whether to amend standards for GSILs, the obligation to issue a final rule by a date certain did not yet exist and, as a result, the condition precedent to the potential imposition of the backstop requirement did not yet exist and no backstop requirement had yet been triggered.
Id.
at 84 FR 46664.
Similar to the January 2017 Definition Final Rules, the September 2019 Withdrawal Rule clarified that DOE was not determining whether standards for GSLs, including GSILs, should be amended. DOE stated it would make that determination in a separate rulemaking.
Id.
at 84 FR 46662. DOE initiated that separate rulemaking by publishing a notice of proposed determination (NOPD) on September 5, 2019, regarding whether standards for GSILs should be amended (September 2019 NOPD). 84 FR 46830. In conducting its analysis for that notice, DOE used the data and comments received in response to the August 2017 NODA and relevant data and comments received in response to the February 2019 Definition NOPR, and DOE tentatively determined that the current standards for GSILS do not need to be amended because more stringent standards are not economically justified.
Id.
at 84 FR 46831. DOE finalized that tentative determination on December 27, 2019 (December 2019 Final Determination). 84 FR 71626. DOE also concluded in the December 2019 Final Determination that, because it had made the predicate determination not to amend standards for GSILs, there was no obligation to issue a final rule by January 1, 2017, and, as a result, the backstop requirement had not been triggered.
Id.
at 84 FR 71636.
Two petitions for review were filed in the U.S. Court of Appeals for the Second Circuit challenging the September 2019 Withdrawal Rule. The first petition was filed by 15 States,
14
New York City, and the District of Columbia. See
New York
v.
U.S. Department of Energy,
No. 19-3652 (2d Cir., filed Nov. 4, 2019). The second petition was filed by six organizations
15
that included environmental, consumer, and public housing tenant groups. See
Natural Resources Defense Council
v.
U.S. Department of Energy,
No. 19-3658 (2d Cir., filed Nov. 4, 2019). The petitions were subsequently consolidated. Merits briefing has been concluded, but the case has not been argued or submitted to the Circuit panel for decision. The case has been in abeyance since March 2021, pending further rulemaking by DOE.
14
The petitioning States are the States of New York, California, Colorado, Connecticut, Illinois, Maryland, Maine, Michigan, Minnesota, New Jersey, Nevada, Oregon, Vermont, and Washington and the Commonwealth of Massachusetts.
15
The petitioning organizations are the Natural Resource Defense Council, Sierra Club, Consumer Federation of America, Massachusetts Union of Public Housing Tenants, Environment America, and U.S. Public Interest Research Group.
Additionally, in two separate petitions also filed in the Second Circuit, groups of petitioners that were essentially identical to those that filed the lawsuit challenging the September 2019 Withdrawal Rule challenged the December 2019 Final Determination. See
Natural Resources Defense Council
v.
U.S. Department of Energy,
No. 20-699 (2d Cir., filed Feb, 25, 2020);
New York
v.
U.S. Department of Energy,
No. 20-743 (2d Cir., filed Feb. 28, 2020). On April 2, 2020, those cases were put into abeyance pending the outcome of the September 2019 Withdrawal Rule petitions.
On January 20, 2021, President Biden issued Executive Order (E.O.) 13990, “Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis.” 86 FR 7037 (Jan. 25, 2021). Section 1 of that Order lists a number of policies related to the
protection of public health and the environment, including reducing greenhouse gas emissions and bolstering the Nation's resilience to climate change.
Id.
at 86 FR 7041. Section 2 of the Order instructs all agencies to review “existing regulations, orders, guidance documents, policies, and any other similar agency actions promulgated, issued, or adopted between January 20, 2017, and January 20, 2021, that are or may be inconsistent with, or present obstacles to, [these policies].”
Id.
Agencies are then directed, as appropriate and consistent with applicable law, to consider suspending, revising, or rescinding these agency actions and to immediately commence work to confront the climate crisis.
Id.
In accordance with E.O. 13990, on May 25, 2021, DOE published a request for information (RFI) initiating a re-evaluation of its prior determination that the Secretary was not required to implement the statutory backstop requirement for GSLs. 86 FR 28001 (May 2021 Backstop RFI). DOE solicited information regarding the availability of lamps that would satisfy a minimum efficacy standard of 45 lm/W, as well as other information that may be relevant to a possible implementation of the statutory backstop.
Id.
On December 13, 2021, DOE published a NOPR proposing to codify in the CFR the 45 lm/W backstop requirement for GSLs. 86 FR 70755 (December 2021 Backstop NOPR). On May 9, 2022, DOE published the May 2022 Backstop Final Rule codifying the 45 lm/W backstop requirement. 87 FR 27439. In the May 2022 Backstop Final Rule, DOE determined the backstop requirement applies because DOE failed to complete a rulemaking for GSLs in accordance with certain statutory criteria in 42 U.S.C. 6295(i)(6)(A).
On August 19, 2021, DOE published a NOPR to amend the current definitions of GSL and GSIL and adopt associated supplemental definitions to be defined as previously set forth in the January 2017 Definition Final Rules. 86 FR 46611. (August 2021 Definition NOPR). On May 9, 2022, DOE published a final rule adopting definitions of GSL and GSIL and associated supplemental definitions as set forth in the August 2021 Definition NOPR. 87 FR 27461 (May 2022 Definition Final Rule).
Upon issuance of the May 2022 Backstop Final Rule and the May 2022 Definition Final Rule, DOE concluded the first cycle of GSL rulemaking required by 42 U.S.C. 6295(i)(6)(A). This NOPR initiates the second cycle of GSL rulemaking under 42 U.S.C. 6295(i)(6)(B). As detailed above, EPCA directs DOE to initiate this rulemaking procedure no later than January 1, 2020. However, DOE is delayed in initiating this second cycle because of the Appropriations Rider, DOE's evolving position under the first rulemaking cycle, and the associated delays that resulted in DOE certifying the backstop requirement for GSLs two years after the January 1, 2020, date specified in the statute.
2. Current Standards
This is the second cycle of energy conservation standards rulemakings for GSLs. As noted in section II.B of this document, in the May 2022 Backstop Final Rule, DOE codified the statutory backstop requirement prohibiting sales of GSLs that do not meet a 45 lm/W requirement. Because incandescent and halogen GSLs would not be able to meet the 45 lm/W requirement, they are not being considered in this analysis. The analysis does take into consideration existing standards for MBCFLs by ensuring that proposed levels do not decrease the existing minimum required energy efficiency of MBCFLs in violation of EPCA's anti-backsliding provision, which precludes DOE from amending an existing energy conservation standard to permit greater energy use or a lesser amount of energy efficiency (
see
42 U.S.C. 6295(o)(1)). The current standards for MBCFLs are summarized in Table II.1. 10 CFR 430.32(u).
16
The MBCFL energy conservation standards at 10 CFR 430.42(u)(1) are subject to the sales prohibition in paragraph (dd) of this same section.
Table II.1—Existing Standards for MBCFLs
Lamp configuration
Lamp power
(W)
Minimum efficacy
(lm/W)
Bare lamp
Lamp power <15
45.0
Lamp power ≥15
60.0
Covered lamp, no reflector
Lamp power <15
16
45.0
15≥ amp power <19
48.0
19≥ amp power <25
50.0
Lamp power ≥25
55.0
Lumen Maintenance at 1,000 Hours
The average of at least 5 lamps must be a minimum 90% of initial (100-hour) lumen output at 1,000 hours of rated life.
Lumen Maintenance at 40% of Rated Lifetime
80% of initial (100-hour) rating (per ANSI C78.5 Clause 4.10).
Rapid Cycle Stress Test
Per ANSI C78.5 and IESNA LM65 (clauses 2,3,5, and 6) exception: cycle times must be 5 minutes on, 5 minutes off. Lamp will be cycled once for every two hours of rated life. At least 5 lamps must meet or exceed the minimum number of cycles.
Lamp Life
≥6,000 hours as declared by the manufacturer on packaging. ≤50% of the tested lamps failed at rated lifetime. At 80% of rated life, statistical methods may be used to confirm lifetime claims based on sample performance.
MBCFLs fall within the Integrated Omnidirectional Short product class (
see
section VI.A.1 for further details on product classes). Because DOE determined that lamp cover (
i.e.,
bare or covered) is not a class-setting factor in the product class structure established in this analysis, the baseline efficacy requirements are determined by lamp
wattage. Therefore, for products with wattages less than 15 W, which fall into the Integrated Omnidirectional Short product class, DOE set the baseline efficacy at 45 lm/W (the highest of the existing standards for that wattage range) to prevent increased energy usage in violation of EPCA's anti-backsliding provision. For products with wattages greater than or equal to 15 W, which fall into the Integrated Omnidirectional Short product class, DOE set the baseline efficacy at 60 lm/W to prevent increased energy usage in violation of EPCA's anti-backsliding provision. Table II.2 shows the baseline efficacy requirements for the Integrated Omnidirectional Short product class.
Table II.2—Integrated Omnidirectional Short Current Standard Efficacy Requirements
Product class
Lamp power
(W)
Minimum
efficacy
(lm/W)
Integrated GSLs
<15
45.0
≥15
60.0
C. Deviation From Appendix A
In accordance with section 3(a) of 10 CFR part 430, subpart C, appendix A (appendix A), DOE notes that it is deviating from the provisions in appendix A regarding the pre-NOPR stages for an energy conservation standards rulemaking. Section 6(a)(1) specifies that as the first step in any proceeding to consider establishing or amending any energy conservation standard, DOE will publish a document in the
Federal Register
announcing that DOE is considering initiating a rulemaking proceeding. Section 6(a)(1) states that as part of that document, DOE will solicit submission of related comments, including data and information on whether DOE should proceed with the rulemaking, including whether any new or amended rule would be cost effective, economically justified, technologically feasible, or would result in a significant savings of energy. Section 6(a)(2) of appendix A states that if the Department determines it is appropriate to proceed with a rulemaking, the preliminary stages of a rulemaking to issue or amend an energy conservation standard that DOE will undertake will be a framework document and preliminary analysis, or an advance notice of proposed rulemaking (ANOPR). DOE finds it necessary and appropriate to deviate from this step in Appendix A and to publish this NOPR without conducting these preliminary stages. Completion of the second cycle of GSL rulemaking is overdue under the January 1, 2020 statutory deadline in 42 U.S.C. 6295(i)(6)(B), so DOE seeks to complete its statutory obligations as expeditiously as possible. Under the requirements of 42 U.S.C. 6295(i)(6)(B)(i), DOE is to initiate a second rulemaking procedure by January 1, 2020, to determine whether standards in effect for GSILs should be amended. The scope of this rule is not limited to incandescent lamp technologies and thus includes GSLs. (42 U.S.C. 6295(i)(6)(B)(ii)) Further, as discussed in section II.B.1 of this document, in settling the lawsuit filed by NEMA following the January 2017 Definition Final Rules (Petition for Review,
Nat'l Elec. Mfrs. Ass'n
v.
U.S. Dep't of Energy,
No. 17-1341 (4th Cir.)), DOE agreed to use its best efforts to issue a supplemental notice of proposed rulemaking regarding whether to amend or adopt standards for general service light-emitting diode (LED) lamps, that may also address whether to adopt standards for compact fluorescent lamps (CFLs), by May 2018. Given this context, DOE has determined that proceeding with this rulemaking as expeditiously as is reasonably practical is the appropriate approach. Additionally, while DOE is not publishing pre-NOPR documents, DOE has tentatively found that the methodologies used for the March 2016 NOPR continue to apply to the current market for GSLs. DOE has updated analytical inputs in its analysis from the March 2016 NOPR where appropriate and welcomes submission of additional data, information, and comments.
III. General Discussion
DOE developed this proposal after considering data and information from interested parties that represent a variety of interests.
A. Product Classes and Scope of Coverage
When evaluating and establishing energy conservation standards, DOE divides covered products into product classes by the type of energy used or by capacity or other performance-related features that justify differing standards. In making a determination whether a performance-related feature justifies a different standard, DOE must consider such factors as the utility of the feature to the consumer and other factors DOE determines are appropriate. (42 U.S.C. 6295(q)) For further details on product classes, see section VI.A.1 of this document and chapter 3 of the NOPR technical support document (TSD).
B. Test Procedure
EPCA sets forth generally applicable criteria and procedures for DOE's adoption and amendment of test procedures. (42 U.S.C. 6293) Manufacturers of covered products must use these test procedures to certify to DOE that their product complies with energy conservation standards and to quantify the efficiency of their product. DOE will finalize a test procedure establishing methodologies used to evaluate proposed energy conservation standards prior to publication of a NOPR proposing new or amended energy conservation standards. Section 8(d)(1) of appendix A.
DOE's test procedures for GSILs and IRLs are set forth at 10 CFR part 430, subpart B, appendix R. DOE's test procedure for CFLs is set forth at 10 CFR part 430, subpart B, appendix W. DOE's test procedure for LED lamps is set forth at 10 CFR part 430, subpart B, appendix BB. DOE's test procedure for GSLs that are not GSILs, IRLs, CFLs, or integrated LED lamps is set forth at 10 CFR part 430, subpart B, appendix DD.
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. Sections 6(b)(3)(i) and 7(b)(1) of appendix A.
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; (3) adverse impacts on health or safety, and (4) unique-pathway proprietary technologies. Sections 6(b)(3)(ii) through (v) and 7(b)(2) through (5) of appendix A. Section VI.B of this document discusses the results of the screening analysis for GSLs, particularly the designs DOE considered, those it screened out, and those that are the basis for the standards considered in this rulemaking. For further details on the screening analysis for this rulemaking, see chapter 4 of the NOPR TSD.
2. Maximum Technologically Feasible Levels
When DOE proposes to adopt an amended standard for a type or class of covered product, it must determine the maximum improvement in energy efficiency or maximum reduction in energy use that is technologically feasible for such product. (42 U.S.C. 6295(p)(1)) Accordingly, in the engineering analysis, DOE determined the maximum technologically feasible (max-tech) improvements in energy efficiency for GSLs, using the design parameters for the most efficient products available on the market or in working prototypes. The max-tech levels that DOE determined for this rulemaking are described in section VI.C.4.e of this proposed rule and in chapter 5 of the NOPR TSD.
D. Energy Savings
1. Determination of Savings
For each trial standard level (TSL), DOE projected energy savings from application of the TSL to GSLs purchased in the 30-year period that begins in the first full year of compliance with the proposed standards (2029-2058).
17
The savings are measured over the entire lifetime of GSLs purchased in the previous 30-year period. DOE quantified the energy savings attributable to each TSL as the difference in energy consumption between each standards case and the no-new-standards case. The no-new-standards case represents a projection of energy consumption that reflects how the market for a product would likely evolve in the absence of amended energy conservation standards.
17
Each TSL is composed of specific efficiency levels for each product class. The TSLs considered for this NOPR are described in section VII.A of this document. DOE conducted a sensitivity analysis that considers impacts for products shipped in a 9-year period.
DOE used its national impact analysis (NIA) spreadsheet model to estimate national energy savings (NES) from potential amended or new standards for GSLs. The NIA spreadsheet model (described in section VI.H of this document) calculates energy savings in terms of site energy, which is the energy directly consumed by products at the locations where they are used. For electricity, DOE reports national energy savings in terms of primary energy savings, which is the savings in the energy that is used to generate and transmit the site electricity. DOE also calculates NES in terms of FFC energy savings. The FFC metric includes the energy consumed in extracting, processing, and transporting primary fuels (
i.e.,
coal, natural gas, petroleum fuels), and thus presents a more complete picture of the impacts of energy conservation standards.
18
DOE's approach is based on the calculation of an FFC multiplier for each of the energy types used by covered products or equipment. For more information on FFC energy savings, see section VI.H.1 of this document.
18
The FFC metric is discussed in DOE's statement of policy and notice of policy amendment. 76 FR 51282 (Aug. 18, 2011), as amended at 77 FR 49701 (Aug. 17, 2012).
2. Significance of Savings
To adopt any new or amended standards for a covered product, DOE must determine that such action would result in significant energy savings. (42 U.S.C. 6295(o)(3)(B))
The significance of energy savings offered by a new or amended energy conservation standard cannot be determined without knowledge of the specific circumstances surrounding a given rulemaking. For example, some covered products and equipment have most of their energy consumption occur during periods of peak energy demand. The impacts of these products on the energy infrastructure can be more pronounced than products with relatively constant demand. In evaluating the significance of energy savings, DOE considers differences in primary energy and FFC effects for different covered products and equipment when determining whether energy savings are significant. Primary energy and FFC effects include the energy consumed in electricity production (depending on load shape), in distribution and transmission, and in extracting, processing, and transporting primary fuels (
i.e.,
coal, natural gas, petroleum fuels), and thus present a more complete picture of the impacts of energy conservation standards.
Accordingly, DOE evaluates the significance of energy savings on a case-by-case basis. As mentioned previously, the proposed standards are projected to result in estimated national FFC energy savings of 4.0 quads, the equivalent of the electricity use of 43 million homes in one year. DOE has initially determined the energy savings from the proposed standard levels are “significant” within the meaning of 42 U.S.C. 6295(o)(3)(B).
E. Economic Justification
1. Specific Criteria
As noted previously, 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 proposed 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 VI.J of this document. 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 PBP associated with new or amended standards. These measures are discussed further in the following
section. For consumers in the aggregate, DOE also calculates the national net present value of the consumer costs and benefits expected to result from particular standards. DOE also evaluates the impacts of potential standards on identifiable subgroups of consumers that may be affected disproportionately by a standard.
b. Savings in Operating Costs Compared to Increase in Price (LCC and PBP)
EPCA requires DOE to consider the savings in operating costs throughout the estimated average life of the covered product in the type (or class) compared to any increase in the price of, or in the initial charges for, or maintenance expenses of, the covered product that are likely to result from a standard. (42 U.S.C. 6295(o)(2)(B)(i)(II)) DOE conducts this comparison in its LCC and PBP analysis.
The LCC is the sum of the purchase price of a product (including its installation) and the operating expense (including energy, maintenance, and repair expenditures) discounted over the lifetime of the product. The LCC analysis requires a variety of inputs, such as product prices, product energy consumption, energy prices, maintenance and repair costs, product lifetime, and discount rates appropriate for consumers. To account for uncertainty and variability in specific inputs, such as product lifetime and discount rate, DOE uses a distribution of values, with probabilities attached to each value.
The PBP is the estimated amount of time (in years) it takes consumers to recover the increased purchase cost (including installation) of a more-efficient product through lower operating costs. DOE calculates the PBP by dividing the change in purchase cost due to a more-stringent standard by the change in annual operating cost for the year that standards are assumed to take effect.
For its LCC and PBP analysis, DOE assumes that consumers will purchase the covered products in the first full year of compliance with new or amended standards. The LCC savings for the considered efficiency levels are calculated relative to the case that reflects projected market trends in the absence of new or amended standards. DOE's LCC and PBP analysis is discussed in further detail in section VI.F of this document.
c. Energy Savings
Although significant conservation of energy is a separate statutory requirement for adopting an energy conservation standard, EPCA requires DOE, in determining the economic justification of a standard, to consider the total projected energy savings that are expected to result directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) As discussed in section VI.H of this document, DOE uses the NIA spreadsheet model 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 document would not reduce the utility or performance of the products under consideration in this rulemaking.
e. Impact of Any Lessening of Competition
EPCA directs DOE to consider the impact of any lessening of competition, as determined in writing by the Attorney General, that is likely to result from a proposed standard. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It also directs the Attorney General to determine the impact, if any, of any lessening of competition likely to result from a proposed standard and to transmit such determination to the Secretary within 60 days of the publication of a proposed rule, together with an analysis of the nature and extent of the impact. (42 U.S.C. 6295(o)(2)(B)(ii)) DOE will transmit a copy of this proposed rule to the Attorney General with a request that the Department of Justice (DOJ) provide its determination on this issue. DOE will publish and respond to the Attorney General's determination in the final rule. DOE invites comment from the public regarding the competitive impacts that are likely to result from this proposed rule. In addition, stakeholders may also provide comments separately to DOJ regarding these potential impacts. See the
ADDRESSES
section for information to send comments to DOJ.
f. Need for National Energy Conservation
DOE also considers the need for national energy and water 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 VI.M of this document.
DOE maintains that environmental and public health benefits associated with the more efficient use of energy are important to take into account when considering the need for national energy conservation. The proposed standards 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 VI.K; the estimated emissions impacts are reported in section VII.B.6 of this document. DOE also estimates the economic value of emissions reductions resulting from the considered TSLs, as discussed in section VI.L of this document.
g. Other Factors
In determining whether an energy conservation standard is economically justified, DOE may consider any other factors that the Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII)) To the extent DOE identifies any relevant information regarding economic justification that does not fit into the other categories described previously, 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 VI.F.11 of this proposed rule.
IV. Scope of Coverage
This section addresses the scope of coverage of this rulemaking. 42 U.S.C. 6295(i)(6)(B)(ii) of EPCA provides that this rulemaking scope shall not be limited to incandescent technologies. In accordance with this provision, the scope of this rulemaking encompasses other GSLs in addition to GSILs. Additionally, 42 U.S.C. 6295(i)(6)(B)(i)(II) of EPCA directs DOE to consider whether the exemptions for certain incandescent lamps should be maintained or discontinued. In this NOPR, DOE reviews the regulatory definitions of GSL, GSIL and supporting definitions adopted in the May 2022 Definition Final Rule and tentatively determines that no amendments are needed with regards to maintenance or discontinuation of exemptions. DOE is proposing minor updates to clarify certain supplemental definitions adopted in the May 2022 Definition Final Rule.
A. Definitions of General Service Lamp, Compact Fluorescent Lamp, General Service LED Lamp, General Service OLED Lamp, General Service Incandescent Lamp
In the September 2019 Definition Final Rule, DOE withdrew the definitions adopted in the January 2017 Definition Final Rules and maintained the existing regulatory definitions of GSL and GSIL, which are the same as the statutory definitions of those terms. 84 FR 46661, 46662. As noted in section II.B.1 of this document, in the August 2021 Definition NOPR, DOE revisited its conclusions in the September 2019 Definition Final Rule and proposed to amend the definitions of GSL and GSIL and associated supplemental definitions to be defined as previously set forth in the January 2017 Definition Final Rules. In the May 2022 Definition Final Rule, DOE discussed comments received regarding the August 2021 Definition NOPR and adopted the GSL and GSIL definitions and associated supplemental definitions as proposed in the August 2021 Definition NOPR. 87 FR 27461. The current regulatory definitions for GSL, CFL, general service LED lamp, general service OLED lamp, and GSIL are described in the following paragraphs.
A general service lamp has the following characteristics: (1) an ANSI base; (2) able to operate at a voltage of 12 volts or 24 volts, at or between 100 to 130 volts, at or between 220 to 240 volts, or of 277 volts for integrated lamps or is able to operate at any voltage for non-integrated lamps; (3) has an initial lumen output of greater than or equal to 310 lumens (or 232 lumens for modified spectrum general service incandescent lamps) and less than or equal to 3,300 lumens; (4) is not a light fixture; (5) is not an LED downlight retrofit kit; and (6) is used in general lighting applications. General service lamps include, but are not limited to, general service incandescent lamps, compact fluorescent lamps, general service light-emitting diode lamps, and general service organic light emitting diode lamps. General service lamps do not include: (1) Appliance lamps; (2) Black light lamps; (3) Bug lamps; (4) Colored lamps; (5) G shape lamps with a diameter of 5 inches or more as defined in ANSI C79.1-2002 (incorporated by reference; see § 430.3); (6) General service fluorescent lamps; (7) High intensity discharge lamps; (8) Infrared lamps; (9) J, JC, JCD, JCS, JCV, JCX, JD, JS, and JT shape lamps that do not have Edison screw bases; (10) Lamps that have a wedge base or prefocus base; (11) Left-hand thread lamps; (12) Marine lamps; (13) Marine signal service lamps; (14) Mine service lamps; (15) MR shape lamps that have a first number symbol equal to 16 (diameter equal to 2 inches) as defined in ANSI C79.1-2002 (incorporated by reference; see § 430.3), operate at 12 volts, and have a lumen output greater than or equal to 800; (16) Other fluorescent lamps; (17) Plant light lamps; (18) R20 short lamps; (19) Reflector lamps (as defined in this section) that have a first number symbol less than 16 (diameter less than 2 inches) as defined in ANSI C79.1-2002 (incorporated by reference; see § 430.3) and that do not have E26/E24, E26d, E26/50x39, E26/53x39, E29/28, E29/53x39, E39, E39d, EP39, or EX39 bases; (20) S shape or G shape lamps that have a first number symbol less than or equal to 12.5 (diameter less than or equal to 1.5625 inches) as defined in ANSI C79.1-2002 (incorporated by reference; see § 430.3); (21) Sign service lamps; (22) Silver bowl lamps; (23) Showcase lamps; (24) Specialty MR lamps; (25) T-shape lamps that have a first number symbol less than or equal to 8 (diameter less than or equal to 1 inch) as defined in ANSI C79.1-2002 (incorporated by reference; see § 430.3), nominal overall length less than 12 inches, and that are not compact fluorescent lamps (as defined in this section); (26) Traffic signal lamps. 87 FR 27461, 27480-27481.
A compact fluorescent lamp is an integrated or non-integrated single-base, low-pressure mercury, electric-discharge source. In this lamp a fluorescing coating transforms some of the ultraviolet energy generated by the mercury discharge into light. The term does not include circline or U-shaped lamps. 10 CFR 430.2.
A general service light-emitting diode (LED) lamp is an integrated or non-integrated LED lamp designed for use in general lighting applications. It uses light-emitting diodes as the primary source of light. 87 FR 27461, 27481.
A general service organic light-emitting diode (OLED) lamp is an integrated or non-integrated OLED lamp designed for use in general lighting applications. It uses organic light-emitting diodes as the primary source of light. 87 FR 27461, 27481.
A general service incandescent lamp is a standard incandescent or halogen type lamp that is intended for general service applications. It has the following characteristics: (1) medium screw base; (2) lumen range of not less than 310 lumens and not more than 2,600 lumens or, in the case of a modified spectrum lamp, not less than 232 lumens and not more than 1,950 lumens; and (3) capable of being operated at a voltage range at least partially within 110 and 130 volts. This definition does not apply to the following incandescent lamps—(1) An appliance lamp; (2) A black light lamp; (3) A bug lamp; (4) A colored lamp; (5) A G shape lamp with a diameter of 5 inches or more as defined in ANSI C79.1-2002 (incorporated by reference; see § 430.3); (6) An infrared lamp; (7) A left-hand thread lamp; (8) A marine lamp; (9) A marine signal service lamp; (10) A mine service lamp; (11) A plant light lamp; (12) An R20 short lamp; (13) A sign service lamp; (14) A silver bowl lamp; (15) A showcase lamp; and (16) A traffic signal lamp. 87 FR 27461, 27480.
As stated, this rulemaking is being conducted in accordance with 42 U.S.C. 6295(i)(6)(B). Under this provision, DOE must determine whether exemptions for certain incandescent lamps should be maintained or discontinued based, in part, on exempted lamp sales data collected by the Secretary from manufacturers.
As part of the first rulemaking cycle for GSLs, in the January 2017 Definition Final Rules and May 2022 Definition Final Rule, DOE also determined whether exemptions for certain
incandescent lamps should be maintained or discontinued based, in part, on exempted lamp sales data collected by the Secretary from manufacturers under 42 U.S.C. 6295(i)(6)(A)(i)(II). DOE conducted this analysis with the understanding that the purpose was to ensure that a given exemption would not impair the effectiveness of GSL standards by leaving available a convenient substitute that was not regulated as a GSL. Therefore, DOE based its decision for each exemption on an assessment of whether the exemption encompassed lamps that could provide general illumination and could functionally be a ready substitute for lamps already covered as GSLs. The technical characteristics of lamps in a given exemption and the volume of sales of those lamps were also considered. 82 FR 7276, 7288; 87 FR 27461, 27465-27467. Subsequently, in the May 2022 Definition Final Rule, DOE reaffirmed its conclusions in the January 2017 Definition Final Rules and discontinued the exemptions from the GSIL definition for rough service lamps; shatter-resistant lamps; three-way incandescent lamps; vibration service lamps; reflector lamps; T-shape lamps of 40 W or less or length of 10 inches or more; and B, BA, CA, F, G16-1/2, G25, G30, S, M-14 lamps of 40 W or less. 87 FR 27461, 27480-27481.
DOE has reviewed the remaining exemptions from the GSIL and GSL definitions. DOE's review of lamp specifications indicates that the exempted lamps continue to have features that do not make them suitable as substitutes for GSLs. Further review of the market indicates that they remain niche products. Hence, DOE finds that the lamps exempted in the May 2022 Definition Final Rule have not acquired technical characteristics that make them ready substitutes for GSLs or have not increased in sales. Therefore, DOE has tentatively determined that no amendments are needed to the definitions of GSIL and GSL as determined in the May 2022 Definition Final Rule.
B. Supporting Definitions
In the May 2022 Definition Final Rule, DOE adopted supporting definitions for GSLs and GSILs as proposed in the August 2021 Definition NOPR and set forth in the January 2017 Definition Final Rules. 87 FR 27461. These included definitions for “black light lamp,” “bug lamp,” “colored lamp,” “infrared lamp,” “left-hand thread lamp,” “light fixture,” “marine lamp,” “marine signal service lamp,” “mine service lamp,” “non-integrated lamp,” “pin base lamp, “plant light lamp,” “reflector lamp,” “showcase lamp,” “sign service lamp,” “silver bowl lamp,” “specialty MR lamp,” and “traffic signal lamp.”
In this NOPR, DOE is proposing minor updates to certain supplemental definitions adopted in the May 2022 Definition Final Rule. Specifically, DOE is proposing to add an industry reference to the definition of LED downlight retrofit kit by specifying that it must be a retrofit kit classified or certified to UL 1598C-2014.
19
Additionally, DOE is proposing to update the industry standards referenced in the definitions of “Reflector lamp” and “Showcase lamp.” The current definitions for “Showcase lamp” and “Reflector lamp” reference ANSI C78.20-2003
20
and ANSI C79.1-2002.
21
In this NOPR, DOE is proposing to remove the reference to ANSI C78.20-2003 from the definitions of “Showcase lamp” and “Reflector lamp.” ANSI C78.20-2003 is an industry standard for A, G, PS, and similar shapes with E26 bases and therefore is not relevant to these lamp types. Further, ANSI has replaced ANSI C79.1-2002 with ANSI C78.79-2014 (R2020).
22
ANSI 79.1-2002 is referenced in the: (1) “Specialty MR lamp” definition; (2) “Reflector lamp” definition; (3) “General service incandescent lamp” definition with respect to a G shape lamp with a diameter of 5 inches or more; and (4) “General service lamp” definition with respect to G shape lamps with a diameter of 5 inches or more; MR shape lamps that have a first number symbol equal to 16; Reflector lamps that have a first number symbol less than 16; S shape or G shape lamps that have a first number symbol less than or equal to 12.5; T shape lamps that have a first number symbol less than or equal to 8. Accordingly, DOE proposes to revise the references to ANSI C79.1-2002 to ANSI C78.79-2014 (R2020) in all the aforementioned definitions.
19
UL, UL1598C Standard for Safety Light-Emitting Diode (LED) Retrofit Luminaire Conversion Kits. Approved January 12, 2017.
20
American National Standards Institute, ANSI C78.20-2003 American National Standard for Electric Lamps—A, G, PS, and Similar Shapes with E26 Medium Screw Bases. Approved October 30, 2003.
21
American National Standards Institute, ANSI C79.1-2002 American National Standard For Electric Lamps—Nomenclature for Glass Bulbs Intended for Use with Electric Lamps. Approved September 16, 2002.
22
American National Standards Institute, ANSI C 78.79-2014 (R2020) American National Standard for Electric Lamps—Nomenclature for Envelope Shapes Intended for Use with Electric Lamps. Approved January 17, 2020.
DOE requests comments on the proposed updates to industry references in the definitions of “General service incandescent lamp,” “General service lamp,” “LED downlight retrofit kit”, “Reflector lamp,” “Showcase lamp,” and “Specialty MR lamp.”
See
section IX.E for a list of issues on which DOE seeks comment.
In this NOPR, DOE is proposing a new supporting term, “Circadian-friendly integrated LED lamp” and its definition. This lamp type will be excluded from the GSL definition. DOE has identified commercially available integrated LED lamps that are marketed as aiding in the human sleep-wake (
i.e.,
circadian) cycle by changing the light spectrum. For example, the Soraa HEALTHY
TM
lamp and the NorbSLEEP lamp specify decrease or removal of blue light from the light spectrum emitted by the lamp to ensure proper melatonin production for better sleep.
23
DOE observed that these were integrated LED lamps with efficacies ranging from 47.8 lm/W to 85.7 lm/W. Because these lamps offer a utility to consumers and do not have high efficacies, DOE is proposing to exempt them from standards. Hence, DOE is proposing to define the exempt lamp type, circadian-friendly integrated LED lamp, as an integrated LED lamp that
23
Soraa HEALTHY
TM
, available at
https://www.soraa.com/products/52-Soraa-Healthy-A19-A60.php#;
NorbSLEEP, available at
https://norblighting.com/sleep/;
accessed June 29, 2020.
(1) Is designed and marketed for use in the human sleep-wake (circadian) cycle;
(2) Is designed and marketed as an equivalent replacement for a 40 W or 60 W incandescent lamp;
(3) Has at least one setting that decreases or removes standard spectrum radiation emission in the 440 nm to 490 nm wavelength range; and
(4) Is sold in packages of two lamps or less.
The first criterion specifies the application of the lamp. For the second criterion, because these lamps are mainly available in the 500 to 800 lumen range, DOE is specifying the equivalent incandescent wattages. For the third criterion, because these lamps provide a better sleep-wake cycle by removing blue light, DOE has specified that the lamp must decrease or remove emission in the 440 to 490 nm wavelength range. In verifying a luminaire to have a certain amount of blue light content, the Underwriters Laboratories' verification method consisted of determining the amount of blue light radiation in the 440-490 nm wavelength range.
24
The fourth criterion
limits how many lamps are sold per package to ensure that lamps are not sold in bulk. This type of lamp offers a specific feature to consumers. To prevent the use of the lamp in general applications for common use, and thereby create a loophole to GSL standards, DOE is proposing the fourth criterion, which is consistent with the vibration service lamp definition intended for a specialty lamp type.
24
Ian Ashdown, Melanopic Green The Other Side of Blue, available at
https://www.ies.org/fires/melanopic-green-the-other-side-of-blue/.
Accessed
June 29, 2020; Circadian ZircLight, Inc. UL Verification Mark, available at
https://verify.ul.com/verifications/117.
DOE requests comments on the proposed definition for “Circadian-friendly integrated LED lamp,” including the packaging criterion. DOE also requests comments on the consumer utility and efficacy potential of lamps marketed to improve the sleep-wake cycle.
See
section IX.E for a list of issues on which DOE seeks comment.
C. GSLs Evaluated for Potential Standards in This NOPR
DOE is not assessing standards for general service OLED lamps and incandescent lamps, types of GSLs, in this NOPR analysis. OLED means a thin-film light-emitting device that typically consists of a series of organic layers between 2 electrical contacts (electrodes). 10 CFR 430.2. OLEDs can create diffuse light sources with direct emitters and are also thin and bendable, allowing for new form factors. DOE reviewed product offerings of manufacturers and retailers marketing OLED lighting technology and did not find any that offered integrated or non-integrated OLED lamps. Most OLED light sources are embedded within a light panel that can range from approximately 100 to 300 lumens.
25
The panels are being used in light fixtures such as desk lamps, hanging ceiling light fixtures and troffers emitting lumens ranging from 75 to 1,800 lumens (depending on the number of panels used per fixture). Due to the lack of commercially available GSLs that use OLED technology, it is unclear whether the efficacy of these products can be increased. Therefore, DOE is not evaluating standards for general service OLED lamps because DOE has tentatively determined that standards for these lamps would not be technologically feasible at this time.
25
U.S. Department of Energy, 2019 Lighting R&D Opportunities, January 2020. Available at
https://www.energy.gov/sites/prod/files/2020/01/f70/ssl-rd-opportunities2-jan2020.pdf.
As noted in section II.B.1 of this document, in the May 2022 Backstop Final Rule, DOE codified the 45 lm/W requirement for GSLs, which cannot be met by incandescent and halogen lamps. Therefore, DOE is also not analyzing standards for incandescent and halogen lamps in this proposal.
DOE is analyzing CFLs and general service LED lamps that have a lumen output within the range of 310-3,300 lumens; an input voltage of 12 volts or 24 volts, at or between 100 to 130 volts, at or between 220 to 240 volts, or of 277 volts for integrated lamps, or are able to operate at any voltage for non-integrated lamps; and do not fall into any exclusion from the GSL definition at 10 CFR 430.2 (
see
section IV.A of this document).
V. Scope of Metrics
In this section DOE discusses its proposal to use minimum lumens per watt as the metric for measuring lamp efficiency. DOE also discusses proposed updates to existing metrics and proposed addition of new metrics for GSLs.
Because CFLs are included in the definition of GSL, this proposed rulemaking satisfies the requirements under 42 U.S.C 6295(m)(1) to review existing standards for MBCFLs. The Energy Policy Act of 2005 (EPAct 2005) amended EPCA by establishing energy conservation standards for MBCFLs, which were codified by DOE in an October 2005 final rule. 70 FR 60413. Performance requirements were specified for five metrics: (1) minimum initial efficacy; (2) lumen maintenance at 1,000 hours; (3) lumen maintenance at 40 percent of lifetime; (4) rapid cycle stress; and (5) lamp life. (42 U.S.C. 6295(bb)(1)) In addition to revising the existing requirements for MBCFLs, DOE has the authority to establish requirements for additional metrics including color rendering index (CRI), power factor, operating frequency, and maximum allowable start time based on the requirements prescribed by the August 9, 2001 ENERGY STAR® Program Requirements for CFLs Version 2.0, or establish other requirements after considering energy savings, cost effectiveness, and consumer satisfaction. (42 U.S.C. 6295(bb)(2)-(3))
For MBCFLs, in this NOPR, DOE is proposing to update the existing requirements for rapid cycle stress test and lifetime and add minimum requirements for power factor, CRI, and start time. For integrated LED lamps, DOE is also proposing to add a minimum requirement for power factor and for medium screw base GSLs a minimum requirement for CRI. These proposals are discussed in the following sections.
1. Lumens per Watt (Lamp Efficacy)
As stated in section II.A, this proposed rulemaking is being conducted under 42 U.S.C. 6295(i)(6)(B). Under 42 U.S.C. 6295(i)(6)(B)(i)(I), DOE is required to determine whether standards in effect for GSILs should be amended to reflect lumen ranges with more stringent maximum wattage than the standards specified in paragraph (1)(A) [
i.e.,
standards enacted by section 321(a)(3)(A)(ii) of EISA
26
]. The scope of this analysis is not limited to incandescent lamp technologies and thus encompasses GSLs. The May 2022 Backstop Final Rule codified the statutory backstop requirement in 42 U.S.C. 6295(i)(6)(A)(v) prohibiting sales of GSLs that do not meet a 45 lm/W efficacy standard. Because incandescent and halogen GSLs would not be able to meet the 45 lm/W requirement, they are not being considered in this analysis. Regarding the efficiency metric, DOE is assessing the efficiency of GSLs based on minimum lumens per watt (
i.e.,
lamp efficacy) rather than maximum wattage of a lamp. Because the lamps covered by the scope of this rulemaking span different lighting technologies, GSLs designed to satisfy the same applications are available in a variety of wattages. The primary utility provided by a lamp is lumen output, which can be achieved through a wide range of wattages depending on the lamp technology. DOE has tentatively determined that lamps providing equivalent lumen output, and therefore intended for the same applications, should be subject to the same minimum efficacy requirements. Thus, DOE is proposing to use lumens per watt as a metric to evaluate standards in this NOPR. DOE is also proposing an equation-based approach to establish ELs so that lamps that provide the same utility (
i.e.,
lumen output) are subject to the same standard. To ensure there would be no backsliding in violation of EPCA with this approach, DOE
converted the maximum wattage standards for GSILs in paragraph (1)(A) [
i.e.,
the EISA enacted standards for GSILs] and 10 CFR 430.32(x)(1) to be expressed in terms of lumens per watt. For each lumen output, DOE used the corresponding maximum wattage to calculate the equivalent lumens-per-watt requirement and determined that the 45 lm/W sales prohibition for GSLs exceeds all maximum wattage requirements specified in paragraph (1)(A) and 10 CFR 430.32(x)(1). Thus, standards considered in this proposal that are in terms of lumens per watt would not decrease the existing minimum required energy efficiency of GSLs and do not result in backsliding.
26
This provision was to be codified as an amendment to 42 U.S.C. 6295(i)(1)(A). But because of an apparent conflict with section 322(b) of EISA, which purported to “strik[e] paragraph (1)” of 6295(i) and replace it with a new paragraph (1), neither this provision nor other provisions of section 321(a)(3)(A)(ii) of EISA that were to be codified in 42 U.S.C. 6295(i)(1) were ever codified in the U.S. Code.
Compare
EISA 321(a)(3)(A)(ii),
with
42 U.S.C. 6295(i)(1). It appears, however, that Congress's intention in section 322(b) was to replace the existing paragraph (1), not paragraph (1) as amended in section 321(a)(3). Indeed, there is no reason to believe that Congress intended to strike these new standards for GSILs. DOE has thus issued regulations implementing these uncodified provisions.
See, e.g.,
10 CFR 430.32(x) (implementing standards for GSILs, as set forth in section 321(a)(3)(A)(ii) of EISA).
2. Power Factor
In this NOPR DOE is proposing minimum power factor requirements for MBCFLs (see 42 U.S.C. 6295(bb)(2)-(3)) and integrated LED lamps. DOE considered ENERGY STAR Lamps Specification V2.1
27
requirements, industry standards, and characteristics of lamps in the current market when selecting power factor requirements for MBCFL and integrated LED lamps. DOE found the vast majority of the U.S. market reports power factors in the range of 0.5 to 0.6 for CFLs, which is consistent with ENERGY STAR Lamps Specification V2.1 (latest ENERGY STAR lamp specification) and ANSI C82.77-10-2020
28
requirement of a minimum power factor of 0.5 for integrated CFLs. Similarly, DOE found the vast majority of the U.S. market reports power factors greater than 0.7 for integrated LED lamps. DOE notes that ENERGY STAR Lamps Specification V2.1 requires a power factor of 0.6 for omnidirectional lamps with rated/reported input power of less than or equal to 10 watts and 0.7 for all other solid-state lamps. ANSI C82.77-10-2020 requires a minimum power factor of 0.57 for input powers between 5 W and 25 W (inclusive); and 0.86 for input powers greater than 25 W. DOE reviewed the lamps database developed for this analysis and determined that of integrated LED lamps with power factor data, 99.9 percent (about 16,700 lamps) had a power factor of 0.7 or greater. Further, of integrated LED lamps with wattage less than or equal to 10 W and power factor data, 99.5 percent had a power factor 0.7 or greater. Therefore, because the vast majority of LED lamps have a power factor of 0.7 or greater, DOE is proposing a minimum 0.7 power factor for integrated LED lamps.
27
ENERGY STAR Lamps Specification V2.1, ENERGY STAR Program Requirements for Lamps (Light Bulbs), January 2, 2017. Available at
https://www.energystar.gov/sites/default/files/ENERGY%20STAR%20Lamps%20V2.1%20Final%20Specification.pdf.
28
American National Standards Institute, ANSI C82.77-10-2020, “American National Standard for Lighting Equipment-Harmonic Emission Limits-Related Power Quality Requirements,” approved January 9, 2020.
DOE also conducted testing of low-cost LED products that have been increasing in popularity on the market to determine if there was a relationship between cost and power factor. In an assessment conducted in 2016, DOE tested the power factor of 25 LED lamps with a per-lamp cost of $5 or less. Of the 25 lamp models tested, 14 lamps had a power factor of 0.7 or higher. Because greater than half of the lamp models complied with a power factor requirement of 0.7, DOE tentatively concluded that low power factor is not a requirement for a low-cost LED lamp. DOE also reviewed the DOE product database developed for this analysis and found 25 integrated LED lamps with a published power factor and price of $5 or less. Of these 25 lamps, 21 lamps had a power factor of 0.7 or higher. Thus, DOE has tentatively determined the proposed power factor requirements are achievable and would not result in higher costs, nor pose physical challenges. DOE is proposing a minimum power factor for integrated lamps being analyzed for potential standards in this NOPR of 0.7 for integrated LED lamps and 0.5 for MBCFLs.
3. Lifetime
In this NOPR, DOE is proposing to update the minimum lifetime standard for MBCFLs pursuant to the authority under 42 U.S.C 6295(m)(1) to review existing MBCFL standards. Specifically, DOE is proposing to update the existing minimum 6,000-hour requirement to 10,000 hours. Based on a review of the market DOE has determined that the majority of MBCFLs on the market have lifetimes of at least 10,000 hours. Further, of the MBCFLs submitted to DOE in DOE's compliance certification database, about 94 percent have a lifetime of at least 10,000 hours.
4. Start Time
In this NOPR, DOE is proposing a minimum start time requirement for MBCFLs (
see
42 U.S.C. 6295(bb)(2)-(3)). Specifically, DOE is proposing that an MBCFL with standby mode power must meet a one second start time requirement and an MBCFL without standby mode power must meet a 750 millisecond start time requirement.
This requirement aligns with the ENERGY STAR Lamps Specification V2.1, the latest ENERGY STAR specifications regarding lamps. In ENERGY STAR Lamps Specification V2.1, the start time for connected MBCFLs is full illumination within one second of application of electrical power, and for non-connected MBCFLs it is within 750 milliseconds. ENERGY STAR defines a connected lamp as a lamp that “includes elements (hardware and software or firmware) or instructions required to enable communication in response to consumer-authorized energy or performance related commands.” Based on this description, a connected lamp would have standby mode power.
5. CRI
Section 321(a) of EISA established CRI requirements for lamps that are intended for a general service or general illumination application (whether incandescent or not); have a medium screw base or any other screw base not defined in ANSI C81.61-2006; are capable of being operated at a voltage at least partially within the range of 110 to 130 volts; and are manufactured or imported after December 31, 2011. For such lamps, section 321(a) of EISA specifies a minimum CRI of 80 for nonmodified spectrum lamps and 75 for modified spectrum lamps. Because MBCFLs meet these criteria, as they are GSLs and used in general service applications, have a medium screw base and a rated input voltage range of 115 to 130 volts (see definition of “medium base compact fluorescent lamp” at 10 CFR 430.2), they are subject to section 321(a) of EISA.
In this NOPR, DOE is proposing to codify the CRI requirements in section 321(a) of EISA. Specifically, DOE is proposing to specify that lamps with a medium screw base or any other screw base not defined in ANSI C81.61-2006; intended for a general service or general illumination application (whether incandescent or not); and capable of being operated at a voltage at least partially within the range of 110 to 130 volts, must have a minimum CRI of 80 (for non-modified spectrum lamps) and 75 (modified spectrum lamps). Because MBCFLs meet these specifications they would also be subject to the minimum CRI requirements in section 321(a) of EISA.
6. Summary of Metrics
Table V.1 summarizes the non-efficacy metrics proposed in this rulemaking (efficacy metrics are discussed in the engineering analysis; see section VI.C of this document). DOE has determined that these proposed new metrics for MBCFLs, integrated LED lamps, and medium base GSLs will provide consumers with increased
energy savings and consumer satisfaction for those products capable of achieving the proposed standard level. DOE has existing test procedures for the metrics being proposed. (See section III.B for more information on test procedures for GSLs.) Further, DOE has tentatively concluded that the new proposed metrics will not result in substantial testing burden, as many manufacturers already test their products according to these metrics. DOE requests comments on the non-efficacy metrics proposed for GSLs.
See
section IX.E for a list of issues on which DOE seeks comment.
Table V.1—Non-Efficacy Metrics for Certain GSLs
Lamp type
Metric
Minimum standard considered
MBCFLs
Lumen maintenance at 1,000 hours
90 percent of initial lumen output at 1,000 hours.
Lumen maintenance at 40 percent of lifetime *
80 percent of initial lumen output at 40 percent of lifetime.
Rapid cycle stress
MBCFL with start time >100 ms: survive one cycle per hour of lifetime * or a maximum of 15,000 cycles. MBCFLs with a start time of ≤100 ms: survive one cycle per every two hours of lifetime.*
Lifetime *
10,000 hours.
Power factor
0.5.
CRI
80.
Start time
The time needed for a MBCFL to remain continuously illuminated must be within: (1) one second of application of electrical power for lamp with standby mode power. (2) 750 milliseconds of application of electrical power for lamp without standby mode power.
Integrated LED Lamps
Power factor
0.7.
Non-modified spectrum lamps with a medium screw base or any other screw base not defined in ANSI C81.61-2006; intended for a general service or general illumination application (whether incandescent or not); capable of being operated at a voltage at least partially within the range of 110 to 130 volts
CRI
80.
Modified spectrum lamps with a medium screw base or any other screw base not defined in ANSI C81.61-2006; intended for a general service or general illumination application (whether incandescent or not); capable of being operated at a voltage at least partially within the range of 110 to 130 volts
CRI
75.
* Lifetime refers to lifetime of a CFLs as defined in 10 CFR 430.2.
VI. Methodology and Discussion
This section addresses the analyses DOE has performed for this rulemaking with regard to GSLs. Separate subsections address each component of DOE's analyses.
DOE used several analytical tools to estimate the impact of the standards proposed in this document. The first tool is a spreadsheet that calculates the LCC savings and PBP of potential amended or new energy conservation standards. The NIA uses a second spreadsheet set that provides shipments projections and calculates NES and NPV of total consumer costs and savings expected to result from potential energy conservation standards. DOE uses the third spreadsheet tool, the Government Regulatory Impact Model (GRIM), to assess manufacturer impacts of potential standards. These three spreadsheet tools are available on the DOE website for this rulemaking:
https://www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=4.
Additionally, DOE used output from the latest version of the Energy Information Administration's (EIA's)
Annual Energy Outlook
(
AEO
), a widely known energy projection for the United States, for the emissions and utility impact analyses.
In this NOPR, DOE anticipates compliance in the second half of 2028 and uses 2029 as the first full compliance year for purposes of conducting the analysis based on the requirement in 42 U.S.C. 6295(m)(4)(B) that DOE shall not require new standards for a product within 6 years of the compliance date of the previous standard. Since compliance with the statutory backstop requirement for GSLs commenced on July 25, 2022 a July 25, 2028 compliance date for any GSL standard would provide a 6-year spread between GSL compliance dates consistent with 42 U.S.C. 6295(m)(4)(B). A compliance date of July 25, 2028, is also consistent with the timespan described in 42 U.S.C. 6295(i)(6)(B), which contemplates at least a 5-year time period between any GSL rule arising out of the first cycle of rulemaking under 42 U.S.C. 6295(i)(6)(A) and the effective date of a final rule for the second cycle of rulemaking under 42 U.S.C. 6295(i)(6)(B). However, per 42 U.S.C. 6295(i)(6)(B)(iv)(I)-(II), for this proposed rulemaking, the Secretary shall consider phased-in effective dates after considering the impact of any amendments on manufacturers (
e.g.,
retiring, repurposing equipment, stranded investments, labor contracts, workers and raw materials) and the time needed to work with retailers/lighting designers to revise sales/marketing strategies. As is evident in this analysis, DOE is collecting information and evaluating the industry and market with respect to potential standards for GSLs.
DOE will be in a better position to determine whether phased-in effective dates are necessary once it receives comments from stakeholders on the potential standards for GSLs presented in this NOPR. DOE requests comments on whether or not phased-in effective dates are necessary for this rulemaking.
See
section IX.E for a list of issues on which DOE seeks comment.
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. The subjects addressed in the market and technology assessment for this rulemaking include (1) a determination of the scope of the rulemaking and product classes, (2) manufacturers and industry structure, (3) existing efficiency programs, (4) shipments information, (5) market and industry trends; and (6) technologies or design options that could improve the energy efficiency of GSLs. The key findings of DOE's market assessment are summarized in the following sections. See chapter 3 of the NOPR TSD for further discussion of the market and technology assessment.
1. Product Classes
DOE divides covered products into classes by: (a) the type of energy used; (b) the capacity of the product; or (c) other performance-related features that justify different standard levels, considering the consumer utility of the feature and other relevant factors. (42 U.S.C. 6295(q)) In evaluating product class setting factors, DOE considers their impact on both efficacy and consumer utility. In this analysis, DOE reviewed several factors including lamp component location, standby mode operation, base type, bulb shape, CRI, correlated color temperature (CCT), lumens, and length. In this NOPR, DOE proposes product class divisions based on lamp component location (
i.e.,
location of ballast/driver) and capability of operating in standby mode; directionality (
i.e.,
omnidirectional versus directional) and lamp length (
i.e.,
45 inches or longer [“long”] or less than 45 inches [“short”] as product class setting factors. In the section below, DOE discusses its proposed product class setting factors. In chapter 3 of the NOPR TSD, DOE discusses features it considered but determined to not be valid product class setting factors including lamp technology, lumen package, lamp cover, dimmability, base type, lamp spectrum, CRI and CCT.
See
chapter 3 of the NOPR TSD for further discussion.
a. Lamp Component Location
Lamp component location refers to the position of the ballast or driver. Integrated lamps have these components enclosed within the lamp, whereas non-integrated lamps have them external to the lamp. Due to the additional components and circuity enclosed within it, an integrated lamp will have an inherent difference in efficacy compared to a lamp that utilizes external components. For consumers using an integrated lamp, there is also the utility of requiring replacement of one lamp unit rather than two separate components. In certain cases, integrated lamps are also generally more compact and thus can be used in applications with size constraints. For these reasons, DOE is proposing a product class based on lamp component location.
b. Standby Mode Operation
DOE observed that some integrated lamps have standby mode functionality and conducted an analysis to determine its impact on lamp efficacy. Because this functionality seems to be increasingly incorporated in LED lamps compared to CFLs, DOE focused on LED lamps. DOE conducted active mode and standby mode testing per DOE's integrated LED lamp test procedure (see appendix BB). These lamps were designed with varying communication methods, including Zigbee, Bluetooth, Wi-Fi, and radio frequency remote controls. Almost half of the lamps tested were operated using a central hub for communication between the end-user and the lamp itself. DOE's test results, as presented in appendix 5a of the NOPR TSD, indicate that the tested standby power generally varied between 0.2 W and 0.5 W. DOE finds that these results indicate that lamps with standby power have a non-negligible standby power consumption that will likely lower their efficacy, compared to lamps without standby power, all things being equal. Therefore, based on utility and impact on efficacy, DOE is proposing a product class division based on standby mode.
c. Directionality
In this analysis, DOE assessed whether directionality should be a product class setting factor—that is, whether a lamp designed to direct light should be subject to separate standards from a lamp that is not. DOE compared pairs of integrated LED lamps from the same manufacturer with the same lumens, lifetime, range of CCT and CRI, except one was directional (
e.g.,
parabolic aluminized reflector [“PAR”]) and the other omnidirectional (
e.g.,
A-shape). DOE also ensured the pairs were of comparable size. For example, a PAR30 was compared with an A19—the numbers indicate the diameter in inches when divided by 8. DOE determined that in over 80 percent of cases, omnidirectional lamps had a higher efficacy. Additionally, by directing or not directing light, directional and omnidirectional each provide a unique consumer utility. DOE was unable to compare the efficacy impact from directionality for the non-integrated lamps due to difference in size. The non-integrated directional lamps are predominantly MR16 shape lamps and the non-integrated omnidirectional lamps are longer tube, pin base CFLs and their LED replacements, or linear LED lamps. However, based on the analysis of integrated lamps, DOE has tentatively concluded that lamps differing only in directionality, all other attributes held constant, will likely differ in lamp efficacy. Due to the impact of directionality on efficacy and consumer utility, DOE is proposing directionality as a product class setting factor in this analysis.
d. Lamp Length
Efficacy tends to increase with length. GSLs span a range of lengths. A-shape or reflector shape lamps typically have a maximum overall length (MOL) of about 1.8-7 inches. Pin base CFLs and their LED replacements typically have a MOL of about 3.7-23 inches. Linear LED lamps are 2-, 3-, 4- and 8-foot lamps. In general, of these lamps, regardless of whether compared to integrated or non-integrated lamps, DOE found a considerable jump in efficacy for the 4-foot (about 45 inches) linear T8 LED lamps. Further, because consumers must change a lamp fixture to substitute lamps of different geometries for one another, lamp length affects utility. Due to the impact of length on efficacy and utility, DOE is proposing lamp length as a product class setting factor—specifying the product class division between lamps of 45 inches or longer length (long) and less than 45 inches (short).
DOE did observe that 4-foot T5 and 8-foot T8 linear LED lamps were not reaching the same efficacies as 4-foot T8 linear LED lamps. DOE has tentatively concluded that this is not due to a technical constraint due to diameter but rather lack of product development of 4-
foot T5 and 8-foot T8 linear LED lamps. DOE requests comments and data on the impact of diameter on efficacy for linear LED lamps. Finally, DOE observed that pin base LED lamp replacements with 2G11 bases and lengths close to two feet are less efficacious than 2-foot linear LED lamps. DOE requests comments on all attributes the same, how the efficacy of pin base LED lamp replacements and linear LED lamps compare.
See
section IX.E for a list of issues on which DOE seeks comment.
e. Product Class Summary
Table VI.1 shows the product classes DOE is proposing in this NOPR. DOE requests comments on the proposed product classes.
See
section IX.E for a list of issues on which DOE seeks comment.
Table VI.1—Proposed GSL Product Classes
Lamp type
Lamp component location
Directionality
Lamp length
Standby mode operation
GSLs
Integrated
Omnidirectional
Short (<45 inches)
Standby.
Non-Standby.
Long (≥45 inches)
Non-Standby.
Directional
All Lengths
Standby.
Non-Standby.
Non-Integrated
Omnidirectional
Short (<45 inches)
Long (≥45 inches).
N/A.
Directional
All Lengths
2. Technology Options
In the technology assessment, DOE identifies technology options that are feasible means of improving lamp efficacy. This assessment provides the technical background and structure on which DOE bases its screening and engineering analyses. To develop a list of technology options, DOE reviewed manufacturer catalogs, recent trade publications and technical journals, and consulted with technical experts.
In this NOPR, DOE identified 21 technology options that would be expected to improve GSL efficacy, as measured by the applicable DOE test procedure. The technology options are differentiated by those that improve the efficacy of CFLs versus those that improve the efficacy of LED lamps. Table VI.2 provides a list of technology options being proposed in this NOPR. For further information on all technology options considered in this NOPR, see chapter 3 of the NOPR TSD. DOE requests comments on the proposed technology options.
See
section IX.E for a list of issues on which DOE seeks comment.
Table VI.2—GSL 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
Use of higher efficiency phosphors to increase the conversion of ultraviolet (UV) light into visible light.
Glass Coatings
Coatings on inside of bulb reflect UV radiation passing through the phosphor back onto the phosphor, allowing a greater portion of UV to be absorbed, and thereby emit more visible light.
Multi-Photon Phosphors
Emitting more than one visible photon for each incident UV photon absorbed.
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.
Higher Efficiency Reflector Coatings
Alternative reflector coatings such as silver, with higher reflectivity to increase the amount of directed light.
Change to LEDs
Replace CFL with LED technology.
LED
Efficient Down Converters
New wavelength conversion materials, such as novel phosphor composition and quantum dots, have the potential for creating warm-white LEDs with improved spectral efficiency, high color quality, and improved thermal stability.
Improved Package Architectures
Arrangements of color mixing and phosphor coating LEDs on the LED array that improve package efficacy.
Improved Emitter Materials
The development of efficient red, green, or amber LED emitters that 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
Emerging alternative substrates that enable high-quality epitaxy for improved device quality and efficacy.
Improved Thermal Interface Materials (TIMs)
TIMs enable high efficiency thermal transfer to reduce efficacy loss from rises in junction temperature and optimize for long-term reliability of the device.
Improved LED Device Architectures
Novel architectures for integrating LED chip(s) into a lamp, such as surface mount device and chip-on-board that improve efficacy.
Optimized Heat Sink Design
Heat sink design to improve thermal conductivity and heat dissipation from the LED package, thus reducing efficacy loss from rises in junction temperature.
Active Thermal Management Systems
Devices such as internal fans and vibrating membranes to improve thermal dissipation from the LED chip.
Improved Primary Optics
Enhancements to the primary optics of the LED package, such as surface etching, novel encapsulant formulations, and flip chip design that improve light extraction from the LED package and reduce losses due to light absorption at interfaces.
Improved Secondary Optics
Reduce or eliminate optical losses from the lamp housing, diffusion, beam shaping, and other secondary optics to increase efficacy using mechanisms such as reflective coatings and improved diffusive coatings.
Improved Driver Design
Novel and intelligent circuit design to increase driver efficiency.
AC LEDs
LEDs that operate on AC voltage, eliminating the requirement for and efficiency losses from the driver.
Reduced Current Density
Driving LED chips at lower currents while maintaining light output, and thereby reducing the efficiency losses associated with efficacy droop.
B. Screening Analysis
DOE uses the following five 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 a significant adverse impact on the utility of the product for 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.
(5)
Unique-Pathway Proprietary Technologies.
If a design option utilizes proprietary technology that represents a unique pathway to achieving a given efficiency level, that technology will not be considered further due to the potential for monopolistic concerns.
10 CFR part 430, subpart C, appendix A, sections 6(b)(3) and 7(b).
In summary, if DOE determines that a technology, or a combination of technologies, fails to meet one or more of the listed five criteria, it will be excluded from further consideration in the engineering analysis. The reasons for eliminating any technology are discussed in the following sections.
The subsequent sections include comments from interested parties pertinent to the screening criteria, DOE's evaluation of each technology option against the screening analysis criteria, and whether DOE determined that a technology option should be excluded (screened out) based on the screening criteria.
1. Screened-Out Technologies
In this NOPR, DOE is proposing to screen out multi-photon phosphors for CFLs, and quantum dots and improved emitter materials for LED lamps based on the first criterion on technological feasibility. In its review of technologies for this analysis, DOE did not find evidence that multi-photon phosphors, quantum dots, or improved emitter materials are being used in commercially available products or prototypes.
In this NOPR, DOE is proposing to screen out AC LEDs based on the second and third criteria, respectively practicability to manufacture, install, and service and adverse impacts on product utility or product. The only commercially available AC LED lamps that DOE found were G-shapes between 330 and 360 lumens or candle shapes between 220 and 400 lumens. Therefore, it is unclear whether the technology could be made for a wide range of products on a commercial scale and in particular for those being considered in this document.
2. Remaining Technologies
Through a review of each technology, DOE tentatively concludes that all of the other identified technologies listed in section VI.A.2 of this document met all five screening criteria and are examined further as design options in this 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
• Higher Efficiency Reflector Coatings
• Change to LEDs
LED Design Options
• Efficient Down Converters (with the exception of quantum dot technologies)
• Improved Package Architectures
• Alternative Substrate Materials
• Improved Thermal Interface Materials
• Improved LED Device Architectures
• Optimized Heat Sink Design
• Active Thermal Management Systems
• Improved Primary Optics
• Improved Secondary Optics
• Improved Driver Design
• Reduced Current Density
DOE has initially determined that these technology options are technologically feasible because they are being used or have previously been 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, unique-pathway proprietary technologies). For additional details, see chapter 4 of the NOPR TSD. DOE requests comments on the design options it has identified.
See
section IX.E for a list of issues on which DOE seeks comment.
C. Engineering Analysis
The purpose of the engineering analysis is to establish the relationship between the efficiency and cost of GSLs. There are two elements to consider in the engineering analysis; the selection of
efficiency levels to analyze (
i.e.,
the “efficiency analysis”) and the determination of product cost at each efficiency level (
i.e.,
the “cost analysis”). In determining the performance of higher-efficiency products, DOE considers technologies and design option combinations not eliminated by the screening analysis. For each product class, DOE estimates the baseline cost, as well as the incremental cost for the product at efficiency levels above the baseline. The output of the engineering analysis is a set of cost-efficiency “curves” that are used in downstream analyses (
i.e.,
the LCC and PBP analyses and the NIA).
1. Efficiency Analysis
DOE typically uses one of two approaches to develop energy efficiency levels for the engineering analysis: (1) relying on observed efficiency levels in the market (
i.e.,
the efficiency-level approach), or (2) determining the incremental efficiency improvements associated with incorporating specific design options to a baseline model (
i.e.,
the design-option approach). Using the efficiency-level approach, the efficiency levels established for the analysis are determined based on the market distribution of existing products (in other words, based on the range of efficiencies and efficiency level “clusters” that already exist on the market). Using the design option approach, the efficiency levels established for the analysis are determined through detailed engineering calculations and/or computer simulations of the efficiency improvements from implementing specific design options that have been identified in the technology assessment. DOE may also rely on a combination of these two approaches. For example, the efficiency-level approach (based on actual products on the market) may be extended using the design option approach to “gap fill” levels (to bridge large gaps between other identified efficiency levels) and/or to extrapolate to the max-tech level (particularly in cases where the max-tech level exceeds the maximum efficiency level currently available on the market).
In this NOPR, DOE relies on an efficiency-level approach. For GSLs, efficiency levels (ELs) are determined as lumens per watt which is also referred to as the lamp's efficacy (
see
section V.1 of this document). DOE derives ELs in the engineering analysis and end-user prices in the cost analysis. DOE estimates the end-user price of GSLs directly because reverse-engineering a lamp is impractical as the lamps are not easily disassembled. By combining the results of the engineering analysis and the cost analysis, DOE derives typical inputs for use in the LCC and NIA. Section VI.D discusses the cost analysis (
see
chapter 5 of the NOPR TSD for further details).
The engineering analysis is generally based on commercially available lamps that incorporate the design options identified in the technology assessment and screening analysis. (
See
chapters 3 and 4 of the NOPR TSD for further information on technology and design options.) The methodology consists of the following steps: (1) selecting representative product classes, (2) selecting baseline lamps, (3) identifying more efficacious substitutes, and (4) developing ELs by directly analyzing representative product classes and then scaling those ELs to non-representative product classes. The details of the engineering analysis are discussed in chapter 5 of the NOPR TSD. The following discussion summarizes the general steps of the engineering analysis:
Representative product classes:
DOE first reviews covered lamps and the associated product classes. When a product has multiple product classes, DOE selects certain classes as “representative” and concentrates its analytical effort on these classes. DOE selects representative product classes primarily because of their high market volumes and/or distinct characteristics.
Baseline lamps:
For each representative product class, DOE selects a baseline lamp as a reference point against which to measure changes resulting from energy conservation standards. The baseline model in each product class represents the characteristics of a product typical of that class (
e.g.,
wattage, lumen output, CCT, CRI, shape, and lifetime). Generally, a baseline model is one that just meets current energy conservation standards, or, if no standards are in place, the baseline is typically the most common or least efficient unit on the market.
More efficacious substitutes:
DOE selects higher efficacy lamps as replacements for each of the baseline models considered. When selecting higher efficacy lamps, DOE considers only design options that meet the criteria outlined in the screening analysis (
see
section VI.B or chapter 4 of the NOPR TSD). DOE also seeks to maintain the baseline lamp's characteristics, such as base type, CCT, and CRI among other specifications, for substitute lamps. To calculate efficacy, DOE uses the ANSI rated wattage of the lamp, or nominal wattage if the ANSI rated wattage is not available. For the Non-integrated product classes, DOE pairs each lamp with an appropriate ballast because these lamps are a component of a system, and their performance is related to the ballast on which they operate.
Efficiency levels (ELs):
After identifying the more efficacious substitutes for each baseline lamp, DOE develops ELs. DOE bases its analysis on three factors: (1) the design options associated with the specific lamps studied; (2) the ability of lamps across lumen packages to comply with the standard level of a given product class; and (3) the max-tech EL. DOE then scales the ELs of representative product classes to any classes not directly analyzed. As part of DOE's analysis, the maximum available efficacy level is the most efficacious unit currently available on the market. DOE also defines a “max-tech” efficacy level to represent the maximum possible efficacy for a given product.
For engineering analysis, DOE developed a lamps database using data from manufacturer catalogs, ENERGY STAR Certified Light Bulbs database,
29
DOE's compliance certification database,
30
and retailer websites. DOE used performance data of lamps from one of these sources in the following general order of priority: DOE's compliance certification database, manufacturer catalog, ENERGY STAR database, and retailer websites. In addition, DOE reviewed applicable lamps in the CEC's Appliance Efficiency Database.
31
29
The most recent ENERGY STAR Certified Light Bulbs database can be found at
https://www.energystar.gov/productfinder/product/certified-light-bulbs/results.
Last accessed June 17, 2020.
30
DOE's compliance certification database can be found at
https://www.regulations.doe.gov/certification-data/#q=Product_Group_s%3A*.
Last accessed by June 17, 2020.
31
The most recent CEC Appliance Efficiency Database can be found at
https://www.energy.ca.gov/appliances/.
Last accessed June 17, 2020.
2. Representative Product Classes
In the case where a covered product has multiple product classes, DOE identifies and selects certain product classes as “representative” and concentrates its analytical effort on those classes. DOE chooses product classes as representative primarily because of their high market volumes and/or unique characteristics. DOE then scales its analytical findings for those representative product classes to other product classes that are not directly analyzed.
In this NOPR, DOE is proposing to establish eight product classes: (1)
Integrated Omnidirectional Short Standby Mode, (2) Integrated Omnidirectional Short Non-standby Mode, (3) Integrated Directional Standby Mode, (4) Integrated Directional Non-standby Mode, (5) Integrated Omnidirectional Long, (6) Non-integrated Omnidirectional Short, (7) Non-integrated Omnidirectional Long, and (8) Non-integrated Directional. With the exception of the Non-integrated Omnidirectional Long product class and all the Standby Mode product classes, DOE directly analyzed all other proposed product classes.
DOE directly analyzed Directional and Omnidirectional product classes. The Directional product classes consist of reflector lamps and lamps with MRX and AR shapes. Reflector lamp is defined by DOE as a lamp that has an R, PAR, BPAR, BR, ER, MR, or similar bulb shape and is used to provide directional light. (See proposed updates to industry references in the reflector lamp definition in section IV.B) The Omnidirectional product classes consist of shapes designed to output light in a non-directional manner such as the A, B, BA, CA, F, G, T shapes. Because of the distinctive difference in design, the Directional and Omnidirectional product classes cannot be scaled from each other and were directly analyzed.
DOE also directly analyzed the Long (45 inches or longer) and Short (shorter than 45 inches) product classes. The lamps in the Short product classes are mainly the A, B, BA, CA, F, G, R, PAR, BPAR, BR, ER, MR shapes or configurations of short multiple tubes (
e.g.,
pin base CFLs). The lamps in the Long product classes are linear single tubes (
e.g.,
4-foot T8 linear LED lamps). Because of the distinctive difference in shape and size, the Short and Long product classes cannot be scaled from each other and were directly analyzed.
As noted in section VI.A.1.a of this document, integrated lamps contain all the components necessary for operation within the lamp, whereas non-integrated lamps have components such as a ballast or driver external to the lamp. Due to this distinction in design, DOE directly analyzed both the Integrated and Non-integrated product classes with the exception of the Non-integrated Omnidirectional Long product class.
In this analysis, DOE scales the Non-integrated Omnidirectional Long product class from the Integrated Omnidirectional Long product class. There are three main types of linear LED lamps and LED lamps that are replacements for pin base CFLs: (1) Type A lamps have an internal driver and connect to the existing fluorescent lamp ballast; (2) Type B lamps have an internal driver and connect to the main line voltage; and (3) Type C lamps connect to an external, remote driver. In this analysis, DOE considers Type A and Type C lamps as non-integrated lamps because they require an external component to operate, whereas Type B lamps are integrated lamps as they can be directly connected to the main line voltage. There are also hybrid lamps that are both Type A and B. DOE classifies these lamps as integrated as they can be operated without an external component. Hence, the Non-integrated Omnidirectional Long product class consists of Type A and Type C linear LED lamps and the Integrated Omnidirectional Long product class consists of Type B and Type A/B linear LED lamps. DOE determined that lamps in both these product classes are the same in shape and size, and tentatively concluded the internal versus external components would not preclude them from being scaled from or to one another. Based on manufacturer feedback, Type B lamps are a more robust replacement solution, and the professional and consumer markets are moving away from the Type A and Type C replacements. Hence, DOE directly analyzed the Integrated Omnidirectional Long product class (containing Type B, A/B lamps) and scaled the resulting ELs to derive ELs for the Non-integrated Omnidirectional Long product class (containing Type A and C lamps).
Finally, DOE is also directly analyzing product classes without standby mode functionality and scaling to product classes that have this functionality. DOE observed only integrated lamps to have standby mode functionality. Because integrated lamps with standby functionality are fundamentally the same as lamps without standby functionality but with the addition of wireless communication components, DOE did not directly analyze the integrated product classes capable of operating in standby mode, but rather scaled from the integrated lamps without standby functionality. DOE chose to directly analyze lamps without standby mode as they remain representative of the majority of the market.
In summary, DOE directly analyzed the product classes shown in grey shading in Table VI.3 as representative in this NOPR. See chapter 5 of the NOPR TSD for further discussion. DOE requests comments on the representative product classes (
i.e.,
product classes directly analyzed) identified for this analysis.
See
section IX.E for a list of issues on which DOE seeks comment.
Table VI.3—General Service Lamps Representative Product Classes
Lamp type
Lumen package
Directionality
Lamp length
Standby mode operation
GSLs
Integrated
Omnidirectional
Short (<45 inches)
Standby.
Non-Standby.
Long (≥45 inches)
Non-Standby.
Directional (reflector lamps)
All Lengths
Standby.
Non-Standby.
Non-Integrated
Omnidirectional
Short (<45 inches)
Long (≥45 inches)
N/A.
Directional (reflector lamps)
All Lengths
3. Baseline Lamps
Once DOE identifies representative product classes for analysis, it selects baseline lamps to analyze in each class. Typically, a baseline lamp is the most common, least efficacious lamp that meets existing energy conservation standards. Specific lamp characteristics were used to characterize the most common lamps purchased by consumers (
e.g.,
wattage, CCT, CRI, and lumen output). Because certain products within the scope of this rulemaking have existing standards, GSLs that fall within the same product class as these lamps must meet the existing standard in order to prevent backsliding of current standards in violation of EPCA. (
See
42 U.S.C. 6295(o)(1)) Specifically, the Integrated Omnidirectional Short product class consists of MBCFLs for
which there are existing DOE standards. The other product classes do not have existing DOE standards but are subject to the statutory backstop requirement of 45 lm/W. DOE requests comments on the baseline lamps selected for each representative product class (
i.e.,
Integrated Omnidirectional Short Non-standby Mode, Integrated Directional Non-standby Mode, Integrated Omnidirectional Long, Non-integrated Omnidirectional Short, and Non-integrated Directional). See section IX.E for a list of issues on which DOE seeks comment.
a. Integrated Omnidirectional Short Product Class
The Integrated Omnidirectional Short product class consists of the A, B, BA, CA, F, G, T shapes as well as linear and U-shape tubular LED lamps (Type B, A/B) that are less than 45 inches (
e.g.,
2-foot linear or U-shape, 3-foot linear LED lamps). Based on common characteristics of lamps in this product class, DOE identified the baseline lamp as a 15 W, 900-lumen (
i.e.,
60 W equivalent) spiral CFL with lifetime of 10,000 hours, CRI of 82, and CCT of 2,700 K. The baseline lamp for the Integrated Omnidirectional Short product class identified in this analysis is specified in Table VI.4.
Table VI.4—Baseline Lamps for Integrated Omnidirectional Short Product Class
Representative product class
Lamp shape
Base type
Lamp type
Nominal wattage
(W)
Initial lumens
(lm)
Rated
efficacy
(lm/W)
Lifetime
(hr)
CCT
(K)
CRI
Integrated Omnidirectional Short
Spiral
E26
CFL
15
900
60.0
10,000
2,700
82
b. Integrated Omnidirectional Long Product Class
The Integrated Omnidirectional Long product class consists of linear tubular LED lamps. These are Type B or Type A/B lamps that contain an internal driver and can be connected directly to the main line voltage. Based on common characteristics of lamps in this product class, DOE identified a 15 W 4-foot T8 Linear LED lamp with a medium bipin base, 1,800 lumens, lifetime of 50,000 hours, CRI of 80, and CCT of 4,000 K as the baseline lamp. The baseline lamp for the Integrated Omnidirectional Long product class identified in this analysis is specified in Table VI.5.
Table VI.5—Baseline Lamps for Integrated Omnidirectional Long Product Class
Representative product class
Lamp shape
Lamp length
Base type
Lamp type
Nominal wattage
(W)
Initial lumens
(lm)
Rated
efficacy
(lm/W)
Lifetime
(hr)
CCT
(K)
CRI
Integrated Omnidirectional Long
T8
4-Foot
Medium Bipin
LED
15
1,800
120.0
50,000
4,000
80
c. Integrated Directional Product Class
The Integrated Directional product class consists of reflector shape lamps. Based on common characteristics of lamps in this product class, DOE identified a 23 W, PAR38 shape CFL with an E26 base, 1,100 lumens, lifetime of 10,000 hours, CRI of 82, and CCT of 2,700 K as the baseline lamp. The baseline lamp for the Integrated Directional product class identified in this analysis is specified in Table VI.6.
Table VI.6—Baseline Lamps for Integrated Directional Product Class
Representative product class
Lamp shape
Base type
Lamp type
Nominal wattage
(W)
Initial lumens
(lm)
Rated
efficacy
(lm/W)
Lifetime
(hr)
CCT
(K)
CRI
Integrated directional
PAR38
E26
CFL
23
1,100
47.8
10,000
2,700
82
d. Non-Integrated Omnidirectional Short Product Class
The Non-integrated Omnidirectional Short product class mainly consists of pin base CFLs and their LED replacements as well as linear and U-shape tubular LED lamps (Type A, C) less than 45 inches (
e.g.,
2-foot linear or U-shape, and 3-foot linear LED lamps). DOE determined that base types of non-integrated lamps typically correspond to certain wattages and lumen outputs, and thus DOE concentrated on a common wattage and its associated base type. Based on a review of lamps that had the most common characteristics, DOE identified the baseline lamp as a 26 W, 1,700-lumen double tube G24q-3 CFL with lifetime of 10,000 hours, CRI of 82, and CCT of 4,100 K.
The baseline lamp for the Non-integrated Omnidirectional Short product class identified in this analysis is specified in Table VI.7.
Table VI.7—Baseline Lamps for Non-Integrated Omnidirectional Short Product Class
Product class
Base type
Lamp shape
Lamp type
Nominal wattage
(W)
Initial lumens
(lm)
Rated
efficacy
(lm/W)
Lifetime
(hr)
CCT
(K)
CRI
Non-Integrated Omnidirectional Short
G24q-3
Double Tube
CFL
26.0
1,700
65.4
10,000
4,100
82
e. Non-Integrated Directional Product Class
The Non-integrated Directional product class consists of reflector shape lamps that mainly operate at 12 V. Based on common characteristics of lamps in this product class, DOE identified an 8 W MR16 shape LED with a GU5.3 base, 500 lumens, lifetime of 25,000 hours, CRI of 80, and CCT of 2,700 K as the baseline lamp. The baseline lamp for the Non-integrated Directional product class identified in this analysis is specified in Table VI.8.
Table VI.8—Baseline Lamps for Non-integrated Directional Product Class
Product class
Base type
Lamp shape
Lamp type
Nominal wattage
(
W
)
Initial lumens
(
lm
)
Rated
efficacy
(
lm/W
)
Lifetime
(
hr
)
CCT
(
K
)
CRI
Non-Integrated Directional
GU5.3
MR16
LED
8.0
500
62.5
25,000
2,700
80
4. More Efficacious Substitutes
DOE selects a series of more efficacious replacements for the baseline lamps considered within each representative product class. DOE considered only technologies that met all five criteria in the screening analysis. These selections were made such that the more efficacious substitute lamp saved energy and had light output within 10 percent of the baseline lamp's light output, when possible. DOE also sought to keep characteristics of substitute lamps, such as CCT, CRI, and lifetime, as similar as possible to the baseline lamps. DOE selected more efficacious substitutes with the same base type as the baseline lamp since replacing an integrated lamp with a lamp of a different base type would potentially require a fixture or socket change and thus is considered an unlikely replacement. In identifying the more efficacious substitutes, DOE utilized the lamps database of commercially available GSLs it developed for this analysis (see section VI.C.1). Further details specific to the more efficacious substitutes of the representative product classes are discussed in the following sections. DOE requests comments on the more efficacious substitutes selected for each representative product class (
i.e.,
Integrated Omnidirectional Short Non-standby Mode, Integrated Directional Non-standby Mode, Integrated Omnidirectional Long, Non-integrated Omnidirectional Short, and Non-integrated Directional). See section IX.E for a list of issues on which DOE seeks comment.
a. Integrated Omnidirectional Short Product Class
For the Integrated Omnidirectional Short product class, DOE's survey of the market showed the number of 15,000-hour LED lamps were comparable to 25,000-hour LED lamps. Additionally, ENERGY STAR Lamps Specification V2.1, effective January 2, 2017, requires LED lamps to have a lifetime of at least 15,000 hours. Hence, for the Integrated Omnidirectional Short product class, DOE analyzed more efficacious substitutes with 25,000-hour lifetimes and 15,000-hour lifetimes at ELs where lamps with both lifetimes were available (
i.e.,
EL 3, EL 4). DOE analyzed lamps with each lifetime as more efficacious substitutes because they are both readily available alternatives that are part of a growing market and have unique life-cycle costs and payback periods associated with them. For the Integrated Omnidirectional Short product class, DOE also ensured that the more efficacious substitutes were marketed as omnidirectional, thus maintaining
This text is long and has been trimmed here. Open the source document for the complete record.
This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.