NRDC and CA IOUs commented that special treatment lamps such as shatter-resistant and vibration service lamps can be used in general applications. (NRDC, Public Meeting Transcript, No. 29 at pp. 12-13; CA IOUs, No. 33 at p. 2) EEAs agreed that energy-efficient CFLs and LED lamps already exist on the market to meet the needs of each of these lamp types, and in some cases provide superior functionality. As LED lamps are not filament based, they are more robust than vibration service incandescent lamps. (EEAs, No. 32 at pp. 5-7) NEMA commented that the rough service lamp definition and vibration service lamp definition are unique to incandescent technology and are not applicable to CFL or LED lamp technology as those lamps are more shock resistant by design. NEMA further noted that shatter-resistant lamps normally contain a coating that absorbs a small portion of the light output; and therefore, light absorption factors would have to be considered when setting efficacy regulations covering this technology. (NEMA, No. 34 at p. 5) However, as LED lamps capable of operating in shatter-resistant applications exist at the highest ELs, DOE finds there is no technological reason to separate them into their own product class, let alone exempt them from standards.
In the preliminary analysis, as stated, DOE made slight adjustments to capture the efficacy of lamps with those design options across the entire lumen output range. In particular, DOE ensured that lamps of different base types were represented at the CSL. DOE evaluated the impacts of CSL 1 on the individual base types in the Non-Integrated product class. DOE confirmed that the vast majority of base types were still available at CSL 1, and thus consumers would not be forced to switch between lamps with differing base types. Further, DOE concluded that because the different bases are maintained at CSL 1 and base type dictates the required ballast, consumers will not be required to change ballasts.
DOE also evaluated whether replacing the baseline lamp with more efficacious substitutes at the higher CSL would require a fixture change. DOE understands the concern regarding the lack of available test data for non-integrated CFLs; however, industry standards for testing efficacy have been in place for several years for these products. Therefore, manufacturers are likely using existing industry standard test methods to determine performance values published in catalogs.
Further, catalog data are the most comprehensive data source currently available for this product class. DOE notes that EPCA directs DOE to establish test procedures for covered products in advance of prescribing an energy conservation standard. (42 U.S.C. 6295) Thus, DOE plans to finalize test procedures for GSLs for which DOE is proposing standards prior to the completion of this rulemaking. In the preliminary analysis, one CSL was considered for the Non-Integrated representative product class.
The baseline represented a basic CFL with an efficacy near the lowest performing non-integrated GSLs currently available on the market. The first representative unit at CSL 1 was a full wattage, improved CFL with more-efficient phosphors and thus more light output. The second representative unit at CSL 1 was a more efficacious reduced wattage CFL that produced similar lumen output as the baseline unit. The full wattage representative lamp unit was used to set the minimum efficacy requirements of EL 1 because it represented the maximum technologically feasible level that applied across all lumen packages within the product class. The reduced wattage CFL gave consumers the option to replace their current full wattage lamp with one that saves energy. In the preliminary analysis, DOE assessed whether each specified lamp type provides overall illumination and therefore can be used in general lighting applications.
DOE found the lumen output of some of these lamps was insufficient to provide overall illumination. DOE received comments regarding these potential exemptions and definitions for these lamp types. In addition, DOE requests comment on if there are any other lamp types that do not serve in general lighting applications and should be exempted from general service lamp standards. (42 U.S.C. 6291) Pursuant to the definition of GSL, DOE has the authority to consider additional lamps that it determines are used to satisfy lighting applications traditionally served by GSILs. In the preliminary analysis, DOE took a broad interpretation of what lamps can be considered GSLs. DOE determined GSLs are lamps intended to serve in general lighting applications (as defined in 10 CFR 430.2) by providing an interior or exterior area with overall illumination.
The lamp demand module first estimates the national demand for GSLs in each year. The demand calculation assumes that sector-specific lighting capacity remains fixed per square foot of floor space over the analysis period. Floor space changes over the analysis period according to the EIA's AEO 2015 projections of residential and commercial floor space. Further details on the assumptions used to model these market transitions are presented in chapter 9 of the NOPR TSD.
Therefore, for this NOPR analysis, DOE continued to utilize the criterion of maintaining 10 percent of the mean lumen output when possible in developing lamp-and-ballast replacement scenarios. As stated, DOE paired the non-integrated GSLs with representative ballasts because the non-integrated GSLs operate on a ballast in practice. For the NOPR analysis, DOE again paired the non-integrated GSLs with a one-lamp electronic, programmed start ballast to represent the lamp and ballast combinations present in the market. In assessing light output of the representative systems for the Non-Integrated product class, DOE made a distinction between mean and initial lumen output. DOE used catalog initial lumen output to calculate efficacy when determining ELs.
As noted by stakeholders, the light output of a lamp decreases over time. To account for this real-world depreciation in lumens, DOE analyzed more efficacious systems that maintain mean lumen output within 10 percent of the baseline system, when possible. Mean lumen output is a measure of light output midway through the rated life of a lamp, and a 10 percent change is a common parameter used by lighting designers to specify acceptable substitute products on the basis of light output. Although non-reflector pin base non-integrated lamps are available in incandescent/halogen, CFL, and LED technologies, CFLs are by far the most common type.
DOE determined that the term compact fluorescent includes both integrated and non-integrated CFLs and therefore DOE considered non-integrated, or pin base, CFLs in the scope of this rulemaking. DOE notes that the market share of pin base CFLs is not insignificant given the vast number of product offerings and common use in commercial applications. Further, DOE's analysis of non-integrated pin base lamps within the non-integrated product class has shown that there are levels of efficacy as well as reduced wattage options and therefore, a standard for these lamps is technologically feasible. DOE's analysis showed that the proposed efficacy levels for these lamp types would retain almost all the different base type options for non-integrated pin-base base CFLs.
See section V.C for further details regarding the engineering analysis for the non-integrated product class. For these reasons, DOE continues to consider standards for non-integrated pin base lamps. Once DOE identifies the representative product classes for analysis, it selects baseline lamps to analyze in each class.
Typically, a baseline lamp is the most common, least efficacious lamp that meets existing energy conservation standards. Specific lamp characteristics were used to characterize the most common lamps purchased by consumers (e.g., wattage, CCT, CRI, and light output). Because certain products within the scope of this rulemaking have existing standards, GSLs that fall within the same product class as these lamps must meet the existing standard in order to prevent backsliding. (See 42 U.S.C. 6295) Thus, DOE only considered baseline lamps in the Integrated Low-Lumen and Integrated High-Lumen product classes that meet the existing standards for bare MBCFLs. The Non-Integrated product class does not have any applicable existing standards.
DOE analyzed commercially available lamps and found that a continuous equation best describes the relationship between efficacy and lumens rather than lumen bins. Further, DOE assessed equations of the ELs analyzed to ensure that consumer utility would be met by GSLs across all lumen ranges. In doing so, in the preliminary analysis, DOE determined that higher lumen output products cannot achieve the same levels of efficacy as lower lumen output products, specifically LED lamp replacements for incandescent lamps of wattages higher than 100 W. Because DOE determined that higher lumen packages offer a consumer utility, DOE considered a product class division based on lumen package.
Therefore, in this NOPR analysis, within the integrated lamp product classes, DOE is continuing to propose separate product classes for lumen outputs from 310 to less than 2,000 and from 2,000 to 2,600. By definition, GSL does not apply to any lighting application or bulb shape excluded from the "general service incandescent lamp" definition. (42 U.S.C. 6291) Therefore, based on the GSL definition, the 22 incandescent lamps that are excluded in EPCA from the definition of GSIL would not be GSLs. It is the case, however, that DOE could determine under the authority in 42 U.S.C. 6295 to discontinue the exemption for the 22 types of lamps exempted from EPCA's definition of GSIL.
Rather, the formerly exempted lamp types would have to be considered GSILs in order for DOE to regulate the lamps under its authority to promulgate standards for GSLs. Since the Appropriations Rider prohibits the expenditure of funds to implement or enforce standards for GSILs, DOE would not be able to establish or amend energy conservation standards for any of these lamps. As a result, making a determination about discontinuing the exemption from the GSIL definition for any of the 22 types of lamps would make no difference in the GSL rulemaking, and DOE declines to address the exemptions at the present time. Table VI-2 through Table VI-7 show the LCC and PBP results for the ELs considered for each product class.
The results in the first of each pair of tables represent the average values if all consumers in the sample make a purchase at the specified EL, and the simple payback for each EL is measured relative to the baseline product . In addition, the lifetime operating cost of each EL is calculated for the LCC analysis period, which is the lifetime of the baseline product in each product class. The savings refer only to consumers who are affected by a standard at a given TSL.
Those whose purchasing decision is not affected are not included in the calculation. Consumers for whom the LCC increases under a given TSL experience a net cost. The NES analysis involves a comparison of national energy consumption of the considered products in each TSL with consumption in the case with no new or amended energy conservation standards.
DOE calculated the annual national energy consumption by multiplying the number of units of each lamp option by the unit energy consumption for each year in the analysis. The NES is based on the difference in annual national energy consumption for the no-new-standards case and each of the standards cases. DOE estimated the energy consumption and savings based on site energy and converted to the electricity consumption and savings at the power plant using annual conversion factors derived from AEO 2015. Cumulative energy savings are the sum of NES for each year over the analysis period, taking into account the full lifetime of lamps shipped in 2049.
DOE found that LED downlight retrofit kits are designed to directly replace traditional downlights that use technologies such as incandescent or halogen lamps or CFLs. DOE also determined that LED downlight retrofit kits generally use an ANSI lamp base and are certified to the UL 1598C standard for LED Retrofit Luminaire Conversion Kits. The retrofit kits integrate the light source and trim and therefore require the existing trim and lamp to be removed before installing in the existing fixture housing. DOE does not consider LED downlight retrofit kits to be GSLs because the kits integrate additional components such as the trim and require the existing trim to be removed. LED downlight retrofit kit does not include integrated lamps or non-integrated lamps." DOE requests comment on the definition proposed. At TSL 4, the projected change in INPV ranges from a decrease of $245.1 million to a decrease of $179.6 million, which represent decreases of 26.9 percent and 19.7 percent, respectively.
As discussed in section V.C.4, the representative lamp unit at TSL 4 in the Integrated Low-Lumen product class is a modeled LED lamp. DOE modeled the lamp based on a commercially available 3-way LED lamp that, when tested at its middle setting of 8 W, was more efficacious than other commercially available LED lamps that could be considered an adequate replacement for the baseline lamp. DOE concluded that the efficacy achieved by the 8 W setting of this lamp demonstrated the potential for a standard, non 3-way 8 W LED lamp to achieve the same efficacy level. Because TSL 4 is based on a modeled product, a commercially available lamp suitable for a direct lamp replacement that complies with TSL 4 is not currently commercially available.
Although new LED products are introduced into the market at a rapid pace, DOE is uncertain as to whether such a lamp would be commercially available at the time manufacturers must comply with the proposed standard. DOE understands the concerns regarding lamp and ballast compatibility for non-integrated GSLs. DOE ensured that the more efficacious substitutes analyzed as representative in the Non-Integrated product class were compatible with the existing ballast paired with the baseline lamp. DOE used publicly available ballast specifications published by manufacturers to confirm compatibility and to ensure a ballast replacement would not be required.
For the NOPR analysis, DOE also ensured that consumers with non-integrated GSLs installed typically would not be forced to switch to a lamp of a different base type by confirming that the vast majority of base types were still available at EL 1. Additionally, DOE is not aware of a technological reason why the base type of a non-integrated CFL would prevent a lamp from achieving EL 1. Because DOE ensured that the vast majority of base types were available at EL 1 and is not aware of technological limitations for increasing the efficacy of the others, DOE does not believe that consumers would be forced to change fixtures. Therefore, DOE considered fixture replacement to be an unlikely replacement scenario. Consequently, DOE did not evaluate ballast or fixture replacement scenarios for this NOPR analysis.
DOE requests comment on the assumption that the efficacy of non-integrated CFLs can be improved for those lamps with base types that potentially cannot meet EL 1. For non-integrated GSLs, DOE considered more efficacious lamps that did not increase energy consumption relative to the baseline and had light output within 10 percent of the baseline lamp-and-ballast system when possible. Due to potential physical and electrical constraints associated with switching base types, DOE selected substitute lamps that had the same base type as the baseline lamp.
DOE identified substitute lamps that were the same wattage as the baseline but produced more light and were therefore more efficacious or lamps that were lower wattage than the baseline but produced similar light and were therefore more efficacious. DOE paired each representative lamp with an appropriate ballast because non-integrated GSLs are a component of a system, and their performance is related to the ballast on which they operate. DOE received comments on these requirements and the more efficacious substitutes analyzed for the Non-Integrated product class. DOE conducted efficacy testing in accordance with the LED Test Procedure SNOPR on multiple integrated LED lamps that exceeded the max-tech level identified in the preliminary analysis. Specifically, DOE tested 8.5 W, 8 W, 7 W, and 6.5 W LED lamps with rated lumen output within the range of 750-1,049 lumens (i.e., 60 W equivalent replacements). The 7 W LED lamp tested below the minimum lumen output DOE considered as suitable for 60 W equivalent replacements and therefore was not considered as a more efficacious substitute.
Additionally, in order to maintain more efficacious substitutes across all lumen packages of the Integrated Low-Lumen product class, DOE did not analyze the 6.5 W LED lamp. For integrated GSLs, DOE identified more efficacious substitute lamps that saved energy and had light output within 10 percent of the baseline lamp's light output. DOE selected more efficacious substitutes with the same base type as the baseline lamp since replacing an integrated lamp with a lamp of a different base type would potentially require a fixture or socket change and thus is considered an unlikely replacement. For the preliminary analysis, DOE also ensured that the more efficacious substitutes were marketed as omnidirectional, thus maintaining the even light distribution of the baseline lamp. DOE received comments on these requirements and the more efficacious substitutes analyzed for the Integrated Low-Lumen and Integrated High-Lumen product classes. In the preliminary analysis, DOE identified the baseline lamp in the Non-Integrated product class as the most common, least efficacious lamp.
The Non-Integrated product class does not have applicable existing standards and therefore the lowest efficacy lamps on the market were considered for the baseline. DOE found that the base types of non-integrated CFLs typically correspond to certain wattages and lumen outputs, and thus DOE concentrated on a common wattage and its associated base type. In the preliminary analysis, DOE considered including integrated and non-integrated GSLs with GU24 bases. NEMA commented that they believe the market share for integrated CFLs with GU24 bases is insignificant , and that GU24 base CFL products should be excluded from scope. Additionally, NEMA commented that currently there are no additional bases besides medium screw base used for GSLs that have a significant market share. Further, DOE found that of the integrated pin bases considered, lamps with GU24 bases compose the vast majority of the market.
Given their expected market share, DOE proposes to include GU24 base integrated lamps in the GSL rulemaking. In the preliminary analysis, DOE considered including lamps with lumen output between 310 and 2,600 lumens. DOE maintains this lower bound because lamps with lumen output less than 310 lumens do not provide sufficient overall illumination. Regarding lamps with a lumen output greater than 2,600 lumens, DOE believes that these lamps can be used in overall illumination and therefore meet the definition of GSL. However, in the preliminary analysis DOE considered not establishing standards for GSLs with lumens greater than 2,600 due to a potential shift to incandescent technologies.
As noted previously, due to the Appropriations Rider, DOE is unable to consider modifying the existing exemption for GSILs with lumen output greater than 2,600 lumens. Therefore, as further discussed in section V.A.1, DOE is evaluating standards in a technology-neutral approach in this rulemaking in order to carry out the more expansive analysis of lamps that serve general service lighting applications intended by EPCA. While DOE may not analyze GSILs in this rulemaking, DOE has taken a broad interpretation for what can be considered a GSL, analyzing non-GSIL lamps intended to serve in general lighting applications. The output of this analysis is a set of time-dependent coefficients that capture the change in electricity generation, primary fuel consumption, installed capacity and power sector emissions due to a unit reduction in demand for a given end use.
These coefficients are multiplied by the stream of electricity savings calculated in the NIA to provide estimates of selected utility impacts of new or amended energy conservation standards. DOE seeks comment on its approach to conducting the utility impact analysis (see issue 53 in section VIII.E). NEMA stated that because of the uncertainty in modeling the value of emissions reductions, DOE should use manufacturer impacts, consumer impacts, employment impacts, energy savings, and competition as the sole metrics for justifying an energy efficiency standard. (NEMA, No. 34 at p. 28) DOE acknowledges that there is uncertainty regarding the value of emissions reductions, and it uses a wide range of SCC values to estimate the value of CO2 emissions reductions. Regarding the inclusion of emissions impacts, the need for national energy and water conservation is one of the factors that DOE must evaluate in determining whether a potential energy conservation standard is economically justified. DOE conducted an MIA for GSLs to estimate the financial impact of proposed standards on manufacturers of GSLs.
The quantitative part of the MIA relies on the GRIM, an industry cash-flow model customized for the GSLs covered in this rulemaking. The key GRIM inputs are data on the industry cost structure, manufacturer production costs , shipments, and assumptions about manufacturer markups, and manufacturer conversion costs. The GRIM calculates annual cash flows using standard accounting principles. DOE used the GRIM to compare changes in INPV between a no-new-standards case and various TSLs . The difference in INPV between the no-new-standards case and standards cases represents the financial impact of new and amended energy conservation standards on GSL manufacturers.
