[Federal Register Volume 73, Number 50 (Thursday, March 13, 2008)]
[Proposed Rules]
[Pages 13620-13689]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E8-4018]
[[Page 13619]]
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Part II
Department of Energy
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10 CFR Part 430
Energy Conservation Program: Energy Conservation Standards for General
Service Fluorescent Lamps and Incandescent Reflector Lamps; Proposed
Rule
Federal Register / Vol. 73, No. 50 / Thursday, March 13, 2008 /
Proposed Rules
[[Page 13620]]
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DEPARTMENT OF ENERGY
10 CFR Part 430
[Docket No. EE-2006-STD-0131]
RIN 1904-AA92
Energy Conservation Program: Energy Conservation Standards for
General Service Fluorescent Lamps and Incandescent Reflector Lamps
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Advance notice of proposed rulemaking.
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SUMMARY: The Energy Policy and Conservation Act authorizes the
Department of Energy (DOE) to establish energy conservation standards
for various consumer products and commercial and industrial equipment,
including general service fluorescent lamps and incandescent reflector
lamps, for which DOE determines that energy conservation standards
would be technologically feasible and economically justified, and would
result in significant energy savings. In this advance notice of
proposed rulemaking (ANOPR), DOE is considering amendment of existing
energy conservation standards for general service fluorescent lamps and
incandescent reflector lamps, and it is also considering whether
standards should apply to additional general service fluorescent lamps.
In addition, this ANOPR considers various amendments to lighting-
related definitions DOE previously developed and incorporated into the
CFR.
DATES: DOE held a public meeting in Washington, DC, that began on March
10, 2008. The agenda for the public meeting covered first the
concurrent test procedure rulemaking for general service fluorescent,
incandescent reflector, and general service incandescent lamps (see
proposal in today's Federal Register), and then this energy
conservation standards rulemaking for these lighting products.
DOE began accepting comments, data, and information regarding the
ANOPR at the public meeting and will continue to accept comments until,
but no later than April 14, 2008. See section V, ``Public
Participation,'' of this ANOPR for details.
ADDRESSES: The public meeting was held at the U.S. Department of
Energy, Forrestal Building, Room 8E-089, 1000 Independence Avenue, SW.,
Washington, DC 20585-0121.
Any comments submitted must identify the ANOPR for Lighting
Standards, and provide the docket number EE-2006-STD-0131 and/or
Regulatory Information Number (RIN) 1904-AA92. Comments may be
submitted using any of the following methods:
Federal eRulemaking Portal: http://www.regulations.gov.
Follow the instructions for submitting comments.
E-mail: [email protected]. Include the docket number EE-2006-STD-0131
and/or RIN number 1904-AA92 in the subject line of the message.
Postal Mail: Ms. Brenda Edwards, U.S. Department of
Energy, Building Technologies Program, Mailstop EE-2J, 1000
Independence Avenue, SW., Washington, DC 20585-0121. Please submit one
signed paper original.
Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department
of Energy, Building Technologies Program, 6th Floor, 950 L'Enfant
Plaza, SW., Washington, DC 20024. Telephone: (202) 586-2945. Please
submit one signed paper original.
For detailed instructions on submitting comments and additional
information on the rulemaking process, see section V of this document
(Public Participation).
Docket: For access to the docket to read background documents or
comments received, visit the U.S. Department of Energy, 6th Floor, 950
L'Enfant Plaza, SW., Washington, DC 20024, (202) 586-2945, between 9
a.m. and 4 p.m., Monday through Friday, except Federal holidays. Please
call Ms. Brenda Edwards at (202) 586-2945 for additional information
regarding visiting the Resource Room.
FOR FURTHER INFORMATION CONTACT: Ms. Linda Graves, U.S. Department of
Energy, Office of Energy Efficiency and Renewable Energy, Building
Technologies Program, EE-2J, 1000 Independence Avenue, SW., Washington,
DC 20585-0121. Telephone: (202) 586-1851. E-mail:
[email protected].
Ms. Francine Pinto or Mr. Eric Stas, U.S. Department of Energy,
Office of the General Counsel, GC-72, Forrestal Building, Mail Station
GC-72, 1000 Independence Avenue, SW., Washington, DC 20585. Telephone:
(202) 586-9507. E-mail: [email protected] or
[email protected].
For information on how to submit or review public comments and on
how to participate in the public meeting, contact Ms. Brenda Edwards,
U.S. Department of Energy, Office of Energy Efficiency and Renewable
Energy, Building Technologies Program, EE-2J, 1000 Independence Avenue,
SW., Washington, DC 20585-0121. Telephone: (202) 586-2945. E-mail:
[email protected].
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Introduction
A. Purpose of the Advance Notice of Proposed Rulemaking
B. Authority
C. Summary of Proposed Coverage for Lamps
D. Overview of the Analyses Performed
1. Engineering Analysis and Product Price Determination
2. Energy-Use Characterization
3. Life-Cycle Cost and Payback Period Analyses
4. National Impact Analysis
E. Background
1. History of Standards Rulemaking for General Service
Fluorescent Lamps, Incandescent Reflector Lamps, and General Service
Incandescent Lamps
2. Energy Independence and Security Act of 2007
a. General Service Fluorescent Lamps
b. General Service Incandescent Lamps
c. Incandescent Reflector Lamps
d. Off Mode and Standby Mode Energy Consumption
3. Test Procedures
II. Consideration Regarding the Scope of Energy Conservation
Standards Coverage
A. Introduction
B. Additional General Service Fluorescent Lamps Being Considered
Under EPCA Section 325(i)(5)
1. Scope
2. Rationale for Coverage
3. Analysis of Individual General Service Fluorescent Lamps
C. Amended Definitions
1. ``Rated Wattage''
2. ``Colored Fluorescent Lamp''
III. Energy Conservation Standards Analyses for Fluorescent and
Incandescent Reflector Lamps
A. Market and Technology Assessment
1. Market Assessment
2. Product Classes
a. General Service Fluorescent Lamps
i. Class Setting Factors
ii. Other Potential Class-setting Factors Considered, But Not
Adopted
iii. Product Class Results
b. Incandescent Reflector Lamps
i. Class Setting Factors
ii. Other Potential Class-setting Factors Considered, But Not
Adopted
iii. Product Class Results
3. Technology Assessment
a. General Service Fluorescent Lamps
b. Incandescent Reflector Lamps
B. Screening Analysis
1. Technology Options Screened Out
a. Multi-photon Phosphors
b. Microcavity Filaments
c. Novel Filament Materials
d. Crystallite Filament Coatings
e. Luminescent Gases
f. Non-Tungsten-Halogen Regenerative Cycles
[[Page 13621]]
g. Infrared Phosphor Glass Coatings
h. Integrally Ballasted Low Voltage Lamps
i. Trihedral Corner Reflectors
2. Design Options Considered Further in Analysis
C. Engineering Analysis
1. Approach
2. Representative Product Classes and Baseline Lamps
a. General Service Fluorescent Lamps
b. Incandescent Reflector Lamps
3. Lamp and Lamp-and-Ballast Designs
a. General Service Fluorescent Lamps
b. Incandescent Reflector Lamps
4. Candidate Standard Levels
a. General Service Fluorescent Lamps
b. Incandescent Reflector Lamps
5. Engineering Analysis Results
a. General Service Fluorescent Lamps
b. Incandescent Reflector Lamps
6. Scaling to Product Classes Not Analyzed
a. General Service Fluorescent Lamps
b. Incandescent Reflector Lamps
D. Energy-Use Characterization
1. Operating Hours
2. Results
E. Product Price Determination
1. Introduction and Methodology
a. Overview
b. General Service Fluorescent Lamps
c. Incandescent Reflector Lamps
2. End-User Price Results
a. General Service Fluorescent Lamps
b. Incandescent Reflector Lamps
3. Sales Taxes
F. Rebuttable Presumption Payback Periods
G. Life-Cycle Cost and Payback Period Analyses
1. Approach
2. Life-Cycle Cost Inputs
a. Total Installed Cost Inputs
b. Operating Cost, Replacement Cost, and Residual Value Inputs
i. Electricity Prices
ii. Lamp Lifetime
iii. Discount Rates
iv. Analysis Period
v. Effective Date
3. Payback Period Inputs
4. Lamp Purchasing Events
5. Life-Cycle Cost and Payback Period Results
a. General Service Fluorescent Lamps
b. Incandescent Reflector Lamps
H. Shipment Analysis
1. Historical Shipments
2. Shipment Projections to 2011 and Calculations of Stock of
Lamps in 2011
3. Base-Case and Standards-Case Shipment Forecasts to 2042
4. Market-Share Matrices
a. General Service Fluorescent Lamps
b. Incandescent Reflector Lamps
5. Shipment Forecast Results
I. National Impact Analysis
1. Approach
2. Base-Case and Standards-Case Forecasted Efficacies
3. National Impact Analysis Inputs
4. National Impact Analysis Results
J. Life-Cycle Cost Subgroup Analysis
K. Manufacturer Impact Analysis
1. Cumulative Regulatory Burden
2. Preliminary Results of the Manufacturer Impact Analysis
a. Retooling Equipment to Produce Standards-Compliant Lamps
b. Availability of Materials to Produce Standards-Compliant
Lamps
c. Maintaining Product Availability and Features
L. Utility Impact Analysis
M. Employment Impact Analysis
N. Environmental Assessment
O. Regulatory Impact Analysis
IV. Candidate Energy Conservation Standards Levels
V. Public Participation
A. Submission of Comments
B. Issues on Which DOE Seeks Comment
1. Consideration of Additional General Service Fluorescent Lamps
2. Amended Definitions
3. Product Classes
4. Scaling to Product Classes Not Analyzed
5. Screening of Design Options
6. Operating Hours
7. General Service Fluorescent Energy Consumption
8. Life-Cycle Cost Calculation
9. Installation Costs
10. Base-Case Market-Share Matrices in 2012
11. Shipment Forecasts
12. Base-Case and Standards-Case Forecasted Efficiencies
13. Trial Standard Levels
14. Lamp Production Equipment Conversion Timeframe
VI. Regulatory Review and Procedural Requirements
VII. Approval of the Office of the Secretary
Acronyms and Abbreviations
AEO Annual Energy Outlook
ANOPR advance notice of proposed rulemaking
ANSI American National Standards Institute
BEF ballast efficacy factor
BF ballast factor
BR bulged reflector (reflector lamp shape)
CBECS Commercial Buildings Energy Consumption Survey
CCT correlated color temperature
CEC California Energy Commission
CEE Consortium for Energy Efficiency
CFR Code of Federal Regulations
CFL compact fluorescent lamp
CIE International Commission on Illumination
CO2 carbon dioxide
CRI color rendering index
CSL candidate standard level
DOE U.S. Department of Energy
E26 Medium screw-base (incandescent lamp base type)
EIA Energy Information Administration
EISA 2007 Energy Independence and Security Act of 2007
EPACT 1992 Energy Policy Act of 1992
EPACT 2005 Energy Policy Act of 2005
EPCA Energy Policy and Conservation Act
ER elliptical reflector (reflector lamp shape)
FEMP Federal Energy Management Program
FR Federal Register
FTC Federal Trade Commission
GE General Electric Lighting and Industrial
GRIM Government Regulatory Impact Model
GSFL general service fluorescent lamp
GSIL general service incandescent lamp
HIR halogen infrared reflector
HO high output
HVAC Heating, Ventilating and Air-Conditioning
IESNA Illuminating Engineering Society of North America
ImSET Impact of Sector Energy Technologies
I-O input-output
IR Infrared
IRL incandescent reflector lamp
K degrees Kelvin
LCC life-cycle cost
Lm lumens
LMC U.S. Lighting Market Characterization Volume I
Lm/W lumens per watt
MECS Manufacturer Energy Consumption Survey (MECS)
MIA Manufacturer Impact Analysis
NAICS North American Industry Classification System
NEEP Northeast Energy Efficiency Partnership
NEMA National Electrical Manufacturers Association
NEMS National Energy Modeling System
NES national energy savings
NIA National Impact Analysis
NOPR notice of proposed rulemaking
NOX nitrogen oxides
NPV net present value
OIRA Office of Information and Regulatory Affairs
OMB U.S. Office of Management and Budget
PAR parabolic aluminized reflector (reflector lamp shape)
PBP payback period
PG&E Pacific Gas and Electric
R reflector (reflector lamp shape)
RECS Residential Energy Consumption Survey
SBA Small Business Administration
SO2 sulfur dioxide
T5, T8, T10, T12 tubular fluorescent lamps, diameters of 0.625, 1, 1.25
or 1.5 inches, respectively
TSD technical support document
TSL trial standard level
U.S.C. United States Code
UV ultraviolet
V volts
W watts
I. Introduction
This advance notice of proposed rulemaking (ANOPR) serves two
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primary purposes: (1) Providing a preliminary determination regarding
additional general service fluorescent lamps (GSFL) that DOE is
considering for coverage and standards; and (2) initiating rulemaking
to consider amending DOE's energy conservation standards related to
coverage of GSFL and incandescent reflector lamps (IRL). The ANOPR is
intended to help DOE satisfy two statutory directives, namely to make a
preliminary determination representing the Secretary's initial
assessment of additional GSFL to consider for energy conservation
standards under section 325(i)(5) of the Energy Policy and Conservation
Act (hereinafter ``EPCA'') (42 U.S.C. 6295(i)(5)), and to conduct an
energy conservation standards rulemaking for general service
fluorescent lamps and incandescent reflector lamps under Section
325(i)(3) of EPCA (42 U.S.C. 6295(i)(3)). Because the preliminary
determination for certain additional lamps is positive, DOE is
including such lamps in the ANOPR analyses for standard-setting
purposes.
DOE welcomes comment on any relevant issue related to this ANOPR.
However, throughout this Federal Register notice, DOE identifies
specific areas and issues on which it specifically invites comment.
These critical issues are summarized in section V.E of this notice.
A. Purpose of the Advance Notice of Proposed Rulemaking
The purpose of the ANOPR is to provide interested parties with an
opportunity to comment on:
1. The preliminary determination of additional GSFL being
considered for energy conservation standards;
2. The product classes DOE is planning to analyze in this
rulemaking;
3. The analytical framework, methodology, inputs, and models (e.g.,
life-cycle cost (LCC) and national impact analysis (NIA) spreadsheets)
that DOE developed to evaluate energy conservation standards for GSFL
and IRL (collectively referred to in this ANOPR as the ``two categories
of lamps'');
4. The analyses conducted for the ANOPR, including the preliminary
results for the engineering analysis, product price determination, LCC
and payback period (PBP) analysis, and NIA. These analyses are
summarized in this ANOPR and presented in detail in the ANOPR technical
support document (TSD), Energy Conservation Standards for General
Service Fluorescent Lamps and Incandescent Reflector Lamps,\1\
published in tandem with this ANOPR; and
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\1\ To view the technical support document for this rulemaking,
visit DOE's website at: http://www.eere.energy.gov/buildings/appliance_standards/residential/incandescent_lamps.html.
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5. The candidate standard levels (CSLs) that DOE developed for the
ANOPR.
B. Authority
Title III of EPCA (42 U.S.C. 6291 et seq.) sets forth a variety of
provisions designed to improve energy efficiency. Part B of Title III
(42 U.S.C. 6291-6309) established the ``Energy Conservation Program for
Consumer Products Other Than Automobiles,'' which includes major
household appliances. Subsequent amendments expanded Title III of EPCA
to include additional consumer products and certain commercial and
industrial equipment, including certain fluorescent and incandescent
lamps--the products that are the focus of this document. In particular,
amendments to EPCA in the Energy Policy Act of 1992 (EPACT 1992), P.L.
102-486, established energy conservation standards for certain classes
of GSFL and IRL, and authorized DOE to amend these standards if such
amendments were warranted. (42 U.S.C. 6291(1), 6295(i)(1) and (3)-(4))
The same EPACT 1992 amendments to EPCA also authorized DOE to adopt
standards for additional GSFL and general service incandescent lamps
(GSIL), if such additional standards were warranted. (42 U.S.C.
6295(i)(5)) Subsequent amendments to EPCA in the Energy Independence
and Security Act of 2007 (EISA 2007), P.L. 110-140, amended the
existing energy conservation standards for IRL and removed DOE's
authority under 42 U.S.C. 6295(i)(5) to adopt standards for additional
GSIL.
Before DOE establishes any new or amended energy conservation
standards, it must first solicit public comments on a proposed
standard. EPCA, as amended, specifies that any new or amended energy
conservation standard that DOE prescribes for consumer products shall
be designed to ``achieve the maximum improvement in energy efficiency *
* * which the Secretary [of Energy] determines is technologically
feasible and economically justified.'' (42 U.S.C. 6295(o)(2)(A))
Moreover, EPCA states that the Secretary of Energy (the Secretary) may
not establish an amended standard if such standard would not result in
``significant conservation of energy,'' or ``is not technologically
feasible or economically justified.'' (42 U.S.C. 6295(o)(3)(B)) To
determine whether a proposed standard is economically justified, DOE
must, after receiving comments on the proposed standard, determine
whether the benefits of the standard exceed its burdens to the greatest
extent practicable, weighing the following seven statutory factors:
(1) The economic impact of the standard on manufacturers and
consumers of the product subject to the standard;
(2) 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, initial charges, or maintenance expenses for the
covered product that are likely to result from the imposition of the
standard;
(3) The total projected amount of energy savings (or, as
applicable, water savings) likely to result directly from the
imposition of the standard;
(4) Any lessening of the utility or the performance of the covered
product likely to result from the imposition of the standard;
(5) The impact of any lessening of competition, as determined in
writing by the Attorney General, that is likely to result from the
imposition of the standard;
(6) The need for national energy and water conservation; and
(7) Other factors the Secretary considers relevant. (42 U.S.C.
6295(o)(2)(B)(i))
C. Summary of Proposed Coverage for Lamps
DOE's regulations currently set energy efficiency standards for
certain classes of general service fluorescent lamps and incandescent
reflector lamps. 10 CFR 430.32(n). However, section 325(i)(5) of EPCA
directs the Secretary of Energy to consider whether the standards in
effect for GSFL should be amended so as to apply to ``additional
general service fluorescent lamps.'' (42 U.S.C. 6295(i)(5)).
Accordingly, in section II of this notice, DOE presents its preliminary
determination regarding additional lamps that may be considered as part
of the standards rulemaking. Section II provides a summary of DOE's
authority under EPCA to consider additional lamps for coverage. In
addition, because the preliminary determination was positive, section
II also presents, by lamp type, the additional lamps for which DOE
intends to consider setting standards.
[[Page 13623]]
D. Overview of the Analyses Performed
As noted above, EPCA authorizes DOE to consider establishing or
amending energy conservation standards for various consumer products
and commercial and industrial equipment, including the two categories
of lamps that are the subject of this ANOPR. For each of these
products, DOE conducted key technical analyses for this ANOPR in the
following areas: (1) Engineering; (2) energy-use characterization; (3)
product price determination; (4) LCC and PBP analyses; and (5) NIA. DOE
performed a separate set of the requisite analyses for each of the two
categories of lamps examined in this rulemaking. This ANOPR presents
the methodology and results of each of these analyses (first an
overview, followed by a more in-depth discussion).
For each type of analysis, Table I.1 identifies the sections in
this document that summarize the methodologies, key inputs, and
assumptions for the analysis. In addition, DOE conducted several other
analyses that either support the five analyses discussed above or are
preliminary analyses that will be expanded upon during the NOPR stage
of this rulemaking. These analyses include the market and technology
assessment, a screening analysis which contributes to the engineering
analysis, and the shipments analysis which contributes to the national
impacts analysis. In addition to these analyses, DOE has begun some
preliminary work on the life-cycle cost subgroup analysis, manufacturer
impact analysis, utility impact analysis, employment impact analysis,
environmental assessment analysis, and the regulatory impact analysis
for the ANOPR. These analyses will be expanded upon during the NOPR
stage of this rulemaking.
DOE consulted with interested parties as part of its process for
conducting all of the analyses for the ANOPR and invites further input
from the public on these topics. While obtaining such input is the
primary purpose of this stage of the rulemaking, this notice also
contains a synopsis of the preliminary analytical results. (The TSD
contains a complete set of results.) The purpose of publishing these
preliminary results in this notice is to: (1) Facilitate public comment
on DOE's analytical methodology; (2) illustrate the level of detail
found in the TSD; and (3) invite comment on the structure and the
presentation of those results. The preliminary analytical results
presented in the ANOPR are subject to revision following review and
input from the public.
Table I.--1 Key Technical Analyses Conducted for the ANOPR
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ANOPR section and
Analysis area Methodology Key inputs \2\ Key assumptions TSD chapter
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Engineering Analysis............ Design option Published catalog Analysis can be Section III.C and
analysis to data on extended to TSD Chapter 5.
establish lamp performance product classes
and lamp-and- values such as and efficiency
ballast designs operating life, levels for which
at each CSL. rated power, DOE did not
efficacy, and conduct analysis;
light output. ballast system
power varies
linearly by
ballast factor.
Energy-Use Characterization..... Multiply lamp Annual operating Data sources are Section III.D and
power, or lamp- hours by lamp indicative of TSD Chapter 6.
and-ballast type; lamp, or current lighting
system power, by lamp and ballast, use.
annual operating energy
hours. consumption.
Energy
Information
Administration
(EIA) 2001, 2002,
and 2003 survey
data and 2002
U.S. Lighting
Market
Characterization
Study Vol. I.
Product Price Determination..... Mark up Manufacturer price Future pricing for Section III.E and
manufacturer schedules. more efficacious TSD Chapter 7.
price schedules Publicly products will
to develop low, available reflect discounts
medium, and high discount used with today's
end-user retail schedules from commodity
prices. State procurement products.
contracts and
other users.
Life-cycle Cost and Payback Use Monte Carlo Lamp and ballast AEO 2007 basis for Section III.G and
Period Analyses. simulation in installation energy price TSD Chapter 8.
combination with costs; annual forecasts and EIA
inputs that are energy 2005 basis for
characterized consumption; distribution of
with probability electricity electricity
distributions to prices and future prices; average
establish a trends; product discount rate is
distribution of lifetimes; 5.6% for the
consumer economic discount rates; residential
impacts (i.e., consumer ``lamp sector, 6.2% for
LCC savings and purchasing the commercial
PBP); capture events'' that sector, and 7.5%
variability in cause purchase of for the
annual energy a new lamp / industrial sector.
use; correlate system; building
electricity samples based on
prices with the EIA's
building samples Commercial
to capture Building Energy
regional and Consumption
sector-specific Survey (CBECS),
variability; use EIA's Residential
residual value to Energy
account for any Consumption
remaining life of Survey (RECS),
a lamp at the end and EIA's
of the analysis Manufacturing
period; report Energy
LCC savings by Consumption
event type and Survey (MECS) and
CSL. the U.S. Lighting
Market
Characterization
Vol. I (LMC).
[[Page 13624]]
National Impact Analysis and Forecasts of Historical and Annual shipments; Sections III.H and
Shipment Analysis. national GSFL and forecasted annual forecasted base- III.I; TSD
IRL costs and shipments; lamp case and Chapters 9 and
energy stock; total standards-case 10.
consumption; installed product efficacy
forecast costs; unit improvements
shipments through annual energy based on market-
the use of a consumptions; share matrices
stock accounting AEO2007 energy and historical
model. DOE used price forecasts; trends; AEO2007
the lamp purchase site-to-source basis for site-to-
events to divide conversion source conversion
the market into factors for factors; discount
segments--new electricity; rates are 3
construction, discount rate; percent and 7
replacements, and HVAC interaction, percent real;
early retrofit and rebound future costs
(only for GSFL); effect. discounted to
use multiple present year
scenarios to (2007).
forecast the
technology mix of
lamps (and
ballasts) sold at
each CSL.
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1. Engineering Analysis and Product Price Determination
DOE uses the engineering analysis and product price determination
together to characterize the relationship between the end-user
(consumer) price and the efficiency of the product DOE evaluates for
standards. The relationship between the efficiency of a product and the
price of that product is essential in determining the relative cost of
a more efficient product over its lifetime (i.e., the purchase price of
the product plus maintenance and operating costs) as compared to a less
efficient product. This calculation is necessary to determine whether
individual consumers and the nation will benefit under an efficiency
standard. DOE's approach to these analyses is explained briefly below.
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\2\ The data sources cited in this table were the most current
available at the time DOE prepared this ANOPR. In the future, should
more up-to-date sources become available, DOE will incorporate those
more up-to-date sources into its analysis.
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The engineering analysis identifies the representative baseline
lamps, or lamp-and-ballast combinations, that DOE will evaluate in the
engineering analysis. The term ``baseline'' refers to a lamp (or lamp-
and-ballast system) that has features and technologies typically found
in equipment currently offered for sale and is representative of the
characteristics of products in a given product class; for products
which are already subject to an energy efficiency standard, the
baseline unit is typically one which just meets the current regulatory
requirement.
DOE based the product price determination for lamps and ballasts on
marked-up manufacturer price schedules, developing low, medium, and
high end-user retail prices. Section III.C and Chapter 5 of the TSD
discuss the engineering analysis, and section III.E and Chapter 7 of
the TSD discuss the product price determination in further detail.
2. Energy-Use Characterization
The energy-use characterization provides estimates of annual energy
use for the two categories of lamps which are the subject of the
present rulemaking. DOE uses these estimates in the LCC and PBP
analyses, as well as the NIA. To develop annual energy use estimates,
DOE multiplied annual usage (in hours per year) by the system power
estimates (in watts). In order to obtain the inputs for these
calculations, DOE took the following steps. DOE developed the system
power estimates in the engineering analysis. To derive annual energy
usage, DOE used data published in the U.S. Lighting Market
Characterization: Volume I (LMC) \3\, the Residential Energy
Consumption Survey (RECS) \4\, the Commercial Building Energy
Consumption Survey (CBECS) \5\, and the Manufacturer Energy Consumption
Survey (MECS) \6\. More detail on the calculation of operating hours is
available in section III.D.1 of this notice, and Chapter 6 of the TSD.
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\3\ U.S. Department of Energy. Office of Energy Efficiency and
Renewable Energy, Energy Conservation Program for Consumer Products:
Final Report: U.S. Lighting Market Characterization, Volume I:
National Lighting Inventory and Energy Consumption Estimate (2002).
Available at: www.eere.energy.gov/buildings/info/documents/pdfs/lmc_vol1_final.pdf.
\4\ U.S. Department of Energy. Energy Information Agency,
Residential Energy Consumption Survey: File 1: Housing Unit
Characteristic (2006). Available at: http://www.eia.doe.gov/emeu/recs/recs2001/publicuse2001.html.
\5\ U.S. Department of Energy. Energy Information Agency,
Commercial Building Energy Consumption Survey: Micro-level data,
file 2 Building Activities, Special Measures of Size, and Multi-
building Facilities (2003). Available at: http://www.eia.doe.gov/emeu/cbecs/public_use.html.
\6\ U.S. Department of Energy. Energy Information Agency,
Manufacturing Energy Consumption Survey, Table 1.4: Number of
Establishments by First Use of Energy for All Purposes (Fuel and
Nonfuel) (2002). Available at: http://www.eia.doe.gov/emeu/mecs/mecs2002/data02/shelltables.html.
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3. Life-Cycle Cost and Payback Period Analyses
The LCC and PBP analyses determine the economic impact of potential
standards on individual consumers. The LCC is the total consumer
expense for a product over the life of the product (i.e., purchase
price plus maintenance and operating costs). The LCC analysis compares
the LCC of products and equipment designed to meet possible energy
conservation standards with the LCC of the products and equipment
likely to be installed in the absence of standards.
The PBP represents the number of years required to recover the
increase in purchase price (including installation cost) of a more-
efficient product through savings in the operating cost of the product.
The PBP is calculated by dividing the change in total installed cost
due to increased efficacy by the change in annual operating cost from
increased efficacy. More detail on the calculation of LCC and PBP is
available in section III.G of this notice and Chapter 8 of the TSD.
4. National Impact Analysis
The NIA estimates the national energy savings (NES) and the net
present value (NPV) of total customer costs and savings expected to
result to the nation from new standards at specific efficiency levels.
Stated another way, in the NIA, DOE calculates NES and NPV for any
given potential standard level for each of the two categories of lamps
as the difference between a base-case forecast (i.e., without new
standards) and the standards-case forecast (i.e., with new standards).
To start, DOE determines national annual energy consumption by
multiplying the
[[Page 13625]]
number of units in use which are expected to be purchased after the
standard takes effect by their average unit energy consumption. Using
that input, the NES is calculated as the sum of the cumulative annual
energy savings over the analysis period (2012-2042).\7\ The national
NPV is then calculated from the discounted net savings each year for
the products purchased over that same analysis period. The NPV sums the
discounted net savings each year, consisting of the difference between
the savings in total operating costs and increases in total installed
costs. More detail on the NIA is available in sections III.H and III.I
of this notice and Chapters 9 and 10 of the TSD.
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\7\ DOE uses 31 years as the time period of analysis for its NES
calculations in many of its rulemakings, in order to enable
stakeholders to understand the relative magnitude of energy savings
potentials of the various products and standard levels being
considered.
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E. Background
1. History of Standards Rulemaking for General Service Fluorescent
Lamps, Incandescent Reflector Lamps, and General Service Incandescent
Lamps
As noted above, EPCA established energy conservation standards for
GSFL, requiring that certain fluorescent lamps meet prescribed minimum
efficacy levels and minimum color rendering index (CRI) levels. EPCA
also established efficacy standards for certain IRL. (42 U.S.C.
6295(i)(1)) For both categories of lamps, EPCA requires that DOE
conduct two cycles of rulemakings to determine whether the standards
should be amended. (42 U.S.C. 6295(i)(3)-(4)) In addition, EPCA
provides that within 24 months after U.S. Federal Trade Commission
(FTC) labeling requirements become effective for GSFL and GSIL, DOE
must initiate a rulemaking to determine if the standards in effect for
fluorescent and incandescent lamps should be amended so that they would
be applicable to additional general service fluorescent lamps. (42
U.S.C. 6295(i)(5)) Within 18 months of initiating the rulemaking, EPCA
further requires DOE to publish a final rule containing such amendment,
if any. (42 U.S.C. 6295(i)(5)) The FTC published a final rule
establishing labeling requirements for covered lamps on May 13, 1994,
with an effective date of May 15, 1995. 59 FR 25176.
In this rulemaking, DOE is addressing two statutory directives
under 42 U.S.C. 6295(i). First, DOE is reviewing and deciding whether
to amend EPCA's prescribed energy conservation standards for GSFL and
IRL. (42 U.S.C. 6295(i)(3)) Second, DOE is reviewing whether energy
conservation standards should be made applicable to additional GSFL.
(42 U.S.C. 6295(i)(5))
To initiate the current energy conservation standards rulemaking,
on May 31, 2006, DOE published on its Web site the Rulemaking Framework
Document for General Service Fluorescent Lamps, Incandescent Reflector
Lamps, and General Service Incandescent Lamps \8\ (``Framework
Document''), which describes the procedural and analytical approaches
it anticipated using to evaluate potential energy conservation
standards for these products.\9\ DOE published a notice to announce the
availability of the Framework Document, to schedule a public meeting on
the planned analytical framework for this rulemaking (hereafter,
``Public Meeting''), and to invite written comments concerning this
analytical framework. The title of that Federal Register notice
published on May 31, 2006 is ``Energy Conservation Standards for
General Service Fluorescent Lamps, Incandescent Reflector Lamps, and
General Service Incandescent Lamps: Notice of Public Meeting and
Availability of the Framework Document,'' \10\--71 FR 30834.
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\8\ A PDF copy of the framework document published in May 2006
is available at: http://www.eere.energy.gov/buildings/appliance_standards/residential/pdfs/lamps_framework.pdf.
\9\ At the time of publication of the Framework Document, EPCA
gave DOE authority to consider energy conservation standards for
additional GSIL under 42 U.S.C. 6295(i)(5). However, subsequent
amendments to EPCA in EISA 2007 removed that authority.
\10\ This rulemaking notice is available at: http://www.eere.energy.gov/buildings/appliance_standards/residential/incandescent_lamps.html.
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A Public Meeting was held on June 15, 2006, whose purpose was to
discuss the analyses and issues identified in various sections of the
Framework Document. At the Public Meeting, DOE described the different
analyses it would conduct, such as the LCC and PBP analyses, the
methods it planned to employ when conducting them, and the relationship
among the various analyses.\11\ Manufacturers, trade associations,
environmental advocates, and other interested parties attended the
Public Meeting. Issues discussed included: (1) The rulemaking's scope
of coverage and definition of exclusions; (2) the development of
product classes; (3) lamp-life variation; (4) selection of
representative lamps for analysis and baseline models; (5) appropriate
methods and sources for developing end-user price estimates; (6) test
procedures; (7) the methodology for developing shipment estimates; (8)
the need for systems analysis for GSFL (i.e., analyzing a lamp and a
ballast in some scenarios); (9) the impact of higher efficacy lamps on
building space conditioning loads; and (10) the use of average
electricity rates. Comments submitted during the Framework Document
comment period elaborated upon these major issues raised at the June
2006 Public Meeting. DOE worked with its contractors to address these
issues in the ANOPR analyses.
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\11\ PDF copies of the slides and other material associated with
the public meeting are available at: http://www.eere.energy.gov/buildings/appliance_standards/residential/lamps_meeting_061506.html.
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Comments received in response to the Framework Document helped
identify further issues involved in this rulemaking, and such input
contributed to the overall analytical process. This document summarizes
the comments DOE has received to date, each with a parenthetical
reference at the end citing the location of the item in the docket for
this rulemaking (i.e., the public record).
2. Energy Independence and Security Act of 2007
On December 19, 2007, during the ANOPR phase of this rulemaking,
the Energy Independence and Security Act of 2007 was signed into law.
In relevant parts, EISA 2007 amends various EPCA provisions regarding
GSFL, IRL, and GSIL, and considerably changes the scope of this
rulemaking and the structure of DOE's ANOPR analyses. Accordingly, DOE
has incorporated these changes in both the preliminary determination
and energy conservation standards analyses contained in this ANOPR. DOE
notes that the relevant amendments in EISA 2007 are effective on the
date prescribed by the legislation, not on the effective date of this
rulemaking.
As stated earlier, in May 2006 DOE published a Framework Document
outlining the procedural and analytical approaches it anticipated using
for this rulemaking. In addition, DOE received both written and oral
comments in response to the Framework Document. Due to the recent
amendments to EPCA in EISA 2007, the scope of coverage and analytical
approach presented in this ANOPR by necessity differs from that which
was previously outlined in the Framework Document. In addition, given
these latest legislative amendments, numerous comments submitted no
longer hold relevance to this rulemaking and, therefore, are not
addressed in this ANOPR. The following section summarizes various
sections of EISA 2007 relevant to this rulemaking and discusses their
effect on the preliminary determination and
[[Page 13626]]
ANOPR analyses contained in this notice.
a. General Service Fluorescent Lamps
Regarding GSFL, section 316(b) of EISA 2007 amends section
321(30)(B)(viii) of EPCA (42 U.S.C. 6291(30)(B)(viii)) by modifying the
definition of ``general service fluorescent lamp'' so as to exclude
lamps with a CRI of 87 or greater (as compared to the previous
exclusion for lamps with a CRI of 82 or greater). This amendment
effectively changes the scope of coverage of energy conservation
standards for GSFL to now include additional fluorescent lamps with a
CRI rating from 82 up to 87. The ANOPR analyses reflect this change in
scope of coverage by analyzing lamp designs with CRI ratings up through
86 and also by accounting for the national impacts due to the
regulation of this full range of GSFL.
In addition, section 322(b) of EISA 2007 amends section 325(i) of
EPCA (42 U.S.C. 6295(i)) by moving the table of efficacy requirements
for fluorescent lamps from section 325(i)(1)(A) to section
325(i)(1)(B). However, every aspect of the table is identical to the
previous standard as enacted by EPACT 1992, including the product
groupings, and the minimum efficacy and CRI requirements.\12\
Therefore, the amendment in section 322(b) of EISA 2007 results in no
substantive change in DOE's approach toward GSFL. Furthermore, the
legislation does not modify the authority to consider extending
coverage to additional GSFL under section 325(i)(5) of EPCA (42 U.S.C.
6295(i)(5)).
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\12\ These CRI requirements reflect minimum CRI standards for
covered fluorescent lamps. These minimum requirements are not
affected by the exclusion in the definition of ``general service
fluorescent lamp'' for lamps with a CRI of 87 or greater, as amended
by EISA 2007.
---------------------------------------------------------------------------
b. General Service Incandescent Lamps
Regarding GSIL, section 321(a)(1) of EISA 2007 amends section
321(30) of EPCA (42 U.S.C. 6291(30)) by deleting the existing
definition and inserting a new definition for ``general service
incandescent lamp.'' In the context of redefining ``general service
incandescent lamp,'' this section also introduces new definitions for
several lighting-related terms, some of which were previously defined
by DOE in the CFR. Definitions contained in section 321(a)(1) of EISA
2007 relevant to this rulemaking include the following terms: (1)
``Modified spectrum;'' (2) ``rough service lamp;'' (3) ``vibration
service lamp;'' and (4) ``colored incandescent lamp.'' The effect that
the incorporation of these definitions has on this rulemaking will be
discussed in section I.E.2.c of this notice.
In addition, section 321(a)(3) amends section 325 of EPCA (42
U.S.C. 6295) by prescribing separate energy conservation standards and
minimum rated lifetimes for general service incandescent lamps and
modified spectrum general service incandescent lamps, with effective
dates ranging from January 1, 2012 to January 1, 2014. In addition,
this section also directs DOE to conduct two future standards
rulemakings to review and possibly amend the standards. Furthermore,
although EPACT 1992 gave DOE authority under 42 U.S.C. 6295(i)(5) to
consider additional general service incandescent lamps for energy
conservation standards coverage, section 321(a)(3) of EISA 2007 amends
section 325(i)(5) of EPCA and removes this provision. Accordingly, DOE
has terminated its preliminary determination regarding the expansion of
scope to additional GSIL. In addition, as EISA 2007 prescribed energy
conservation standards for GSIL, this ANOPR does present any analyses
or candidate standard levels related to GSIL.
c. Incandescent Reflector Lamps
Regarding IRL, section 322(a)(1) of EISA 2007 amends section
321(30)(C)(ii) of EPCA (42 U.S.C. 6291(30)(C)(ii)) by modifying the
portion of the definition of ``incandescent lamp'' which is applicable
to reflector lamps so as to expand that definition to include lamps
with a diameter between 2.25 and 2.75 inches, as well as BPAR-, ER-,
and BR-shaped lamps. In addition, section 322(a)(2) of EISA 2007 adds
new statutory definitions for a BPAR incandescent reflector lamp, a BR
incandescent reflector lamp, and an ER incandescent reflector lamp.
These new statutory definitions supersede the existing CFR definitions
for ``ER incandescent reflector lamp'' and ``BR incandescent reflector
lamp'' that were developed by DOE (62 FR 29221 (May 29, 1997)), and
thereby remove DOE's authority to amend these definitions.
In addition, section 322(b) of EISA 2007 amends section 325(i) of
EPCA (42 U.S.C. 6295(i)) by moving the table of minimum average lamp
efficacy requirements for IRL from section 325(i)(1)(A) to section
325(i)(1)(B). However, as noted above for GSFL, every aspect of this
table of IRL efficacy requirements is identical to the previous
standard as enacted by EPACT 1992. Section 322(b) also amends EPCA to
incorporate several new exemptions to the IRL standards in a newly-
adopted section 325(i)(1)(C) of EPCA. These exemptions are as follows:
(1) Lamps rated at 50 watts or less that are ER30, BR30, BR40, and
ER40; (2) lamps rated at 65 watts that are BR30, BR40, or ER40 lamps;
and (3) R20 incandescent reflector lamps rated 45 watts or less. DOE
notes that the expanded scope of IRL, as presented in EISA 2007, is
consistent the proposal contained in a joint comment submitted by the
American Council for an Energy Efficient Economy (ACEEE) and the
National Electrical Manufacturers Association (NEMA) regarding this
rulemaking. (ACEEE and NEMA, No. 14 at pp. 3-8) The effective date of
energy conservation standards for BPAR, ER, and BR shaped lamps as
prescribed by EISA 2007 is January 1, 2008. The effective date of
standards for smaller diameter IRL as prescribed by EISA 2007 (i.e.,
diameter of more than 2.25 inches, but not more than 2.75 inches) is
the later of January 1, 2008 or 180 days after the date of enactment of
EISA 2007. Given that EISA 2007 was enacted on December 19, 2007, the
effective date of these standards for smaller diameter IRL is June 16,
2008. In both of these cases, the EISA 2007 standards come into effect
well before an amended IRL standard (as would be prescribed by this
rulemaking) would come into effect. DOE's draft ANOPR analyses were
modified to account for this expanded scope of IRL coverage by
selecting IRL baselines which DOE expects to be the least efficacious
covered lamp design that would comply with the amended standard. In
addition, DOE updated its IRL shipment forecasts in response to EISA
2007 to account for both the expansion of scope for Federally-regulated
reflector lamps and the exemptions to the standards.
In addition, it is also important to note that, as previously
discussed, EISA 2007 introduced statutory definitions for ``rough
service lamp,'' ``vibration service lamp,'' and ``colored incandescent
lamp,''--lamp types which are explicitly excluded from the definition
of ``incandescent reflector lamp,'' as contained in the referenced
definition of ``incandescent lamp.'' DOE had previously developed and
adopted into the CFR definitions for these three terms in the context
of IRL; however, as previously mentioned, these DOE definitions are now
superseded by the statutory definitions in EISA 2007. As these terms
are used to define that portion of the definition of ``incandescent
lamp'' that corresponds to the definition of ``incandescent reflector
lamp,'' any amendments to these terms affect the scope of energy
[[Page 13627]]
conservation standards coverage of IRL. In examining the new
definitions for ``rough service lamp'' and ``vibration service lamp,''
DOE recognizes that they differ from the earlier CFR definitions DOE
had adopted. In response to the changes to these definitions, DOE
attempted to account for these changes in the ANOPR analyses.
Similarly, the new EISA 2007 definition for ``colored incandescent
lamp'' effectively expands the scope of coverage for IRL. That is, IRL
containing five percent or more of neodymium content and plant light
IRL are now subject to energy conservation standards. DOE accounts for
this expanded coverage of IRL by creating a separate product class for
these lamps, termed ``modified spectrum lamps.'' This decision to treat
modified spectrum lamps separately is consistent with the approach
taken in EISA 2007 with respect to GSIL.
Finally, although EPACT 1992 gave DOE authority under U.S.C.
6295(i)(5) to consider additional general service incandescent lamps
(which included IRL) for energy conservation standards coverage,
section 321(a)(3) of EISA 2007 has amended section 325(i)(5) of EPCA to
remove this provision. Accordingly, DOE has terminated its preliminary
determination regarding the expansion of scope to additional GSIL and
IRL. However, as discussed above, in the ANOPR analyses, DOE accounts
for the new scope of coverage for IRL for purposes that remain relevant
to this rulemaking (i.e., considering amended efficacy standards for
all covered IRL).
d. Off Mode and Standby Mode Energy Consumption
In addition to the specific relevant actions described above, EISA
2007 also places various requirements on all covered products. Of
particular note here, section 310(3) of EISA 2007 amends section 325 of
EPCA (42 U.S.C. 6295) by mandating that any final rule establishing or
revising a standard for a covered product that is adopted after July 1,
2010 shall incorporate standby mode and off mode energy use into the
standard, if feasible. DOE notes that final rule for this energy
conservation standards rulemaking on fluorescent and incandescent lamps
is scheduled for publication by June 2009. In addition, after careful
review, DOE has preliminarily determined that for the GSFL and IRL
which are the subjects of this rulemaking, current technologies for
these products do not employ a standby mode or off mode, so a
determination of the energy consumption of such features is
inapplicable. Given EISA 2007's definitions of ``active mode,'' ``off
mode,'' and ``standby mode'' \13\ applicable to both GSFL and IRL, the
lamp must be entirely disconnected from the main power source (i.e.,
the lamp is switched off) in order not to provide any active mode
function (i.e., emit light), thereby meeting the second provision in
the definition of ``off mode.'' However, if the lamp is disconnected
from the main power source, the lamp clearly does not satisfy the
requirements of operating in off mode. In addition, DOE believes that
all covered products that meet the definitions of ``GSFL'' and ``IRL''
are single-function products and do not offer any secondary user-
oriented or protective functions. Therefore, DOE has tentatively
concluded that it is not feasible to incorporate off mode or standby
mode energy use into the energy conservation standards for GSFL and
IRL. DOE welcomes comment on its understanding of off mode and standby
mode energy consumption for the products addressed by this rulemaking.
---------------------------------------------------------------------------
\13\ In amending 42 U.S.C. 6295(gg)(1)(a)(i), (ii), and (iii),
EISA 2007 defines ``active mode,'' ``off mode,'' and ``standby
mode'' as follows: `` The term `active mode' means the condition in
which an energy-using product--(I) is connected to a main power
source; (II) has been activated; and (III) provides 1 or more main
functions.'' ``The term `off mode' means the condition in which an
energy-using product--(I) is connected to a main power source; and
(II) is not providing any stand-by or active mode function.'' ``The
term `standby mode' means the condition in which an energy-using
product--(I) is connected to a main power source; and (II) offers 1
or more of the following user-oriented or protective functions: (aa)
To facilitate the activation or deactivation of other functions
(including active mode) by remote switch (including remote control),
internal sensor, or timer. (bb) Continuous functions including
information or status displays (including clocks) or sensor-based
functions.''
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3. Test Procedures
DOE test procedures outline the method by which manufacturers must
determine the efficiency of their products and equipment, and thereby
assess and certify compliance with the energy conservation standards
adopted pursuant to EPCA. DOE established test procedures for
fluorescent and incandescent lamps in a final rule published in the
Federal Register on May 29, 1997 (hereafter ``1997 Test Procedure Final
Rule''). 62 FR 29222 (adopting 10 CFR part 430, Subpart B, Appendix R
\14\). In addition, the test procedures incorporate by reference
American National Standards Institute (ANSI), Illuminating Engineering
Society of North America (IESNA), and International Commission on
Illumination (CIE) standards to measure lamp efficacy and CRI. In their
totality, the DOE test procedures provide detailed instructions for
measuring the performance of GSFL and IRL and certain performance
attributes of GSIL.
---------------------------------------------------------------------------
\14\ ``Uniform Test Method for Measuring Average Lamp Efficiency
(LE) and Color Rendering Index (CRI) of Electric Lamps.''
---------------------------------------------------------------------------
The National Electrical Manufacturers Association (NEMA) submitted
a comment identifying what it perceived to be problems with several of
the industry standards incorporated in DOE's test procedures.
Specifically, NEMA stated that many of the standards referenced in the
test procedures are outdated, have been replaced, or are no longer
available. (NEMA, No. 12 at pp. 2-4) \15\
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\15\ A notation in the form ``NEMA, No. 12 at pp. 2-4''
identifies a written comment that DOE has received and has included
in the docket of this rulemaking. This particular notation refers to
a comment (1) by the National Electrical Manufacturers Association
(NEMA), (2) in document number 12 in the docket of this rulemaking,
and (3) appearing on pages 2 through 4.
---------------------------------------------------------------------------
Prompted by the NEMA comment, DOE reviewed the DOE test procedures
for GSFL, IRL, and GSIL, and DOE has tentatively concluded that they
should be revised because many of industry standards cited in the test
procedures are out of date, are not available for purchase, or are no
longer maintained. Therefore, DOE has initiated a test procedure
rulemaking, in parallel with this energy conservation standards
rulemaking, to review and revise the test procedures for these three
categories of lamps--GSFL, IRL and GSIL (even though GSIL is no longer
part of this ANOPR). To this end, DOE is publishing a notice of
proposed rulemaking (NOPR) in today's Federal Register that proposes to
amend the lighting test procedures. The following briefly summarizes
the major points in the test procedures NOPR; however, for a complete
discussion on these and other points, please consult the NOPR.
In the test procedure NOPR, DOE is proposing primarily to update
the references to outdated industry standards for fluorescent and
incandescent lamps. DOE believes this update is necessary in order to
ensure that stakeholders and testing laboratories are able to follow
DOE's test procedures, which require obtaining and using several
industry standards incorporated by reference. DOE believes that the
proposed test procedure amendments would not impact the measured
efficacy of a lamp.
In the test procedure NOPR, DOE is also proposing a few
definitional and procedural modifications to accommodate technological
migrations in the GSFL market and approaches DOE is considering in this
energy
[[Page 13628]]
conservation standards rulemaking. Specifically, DOE is proposing to
mandate that GSFL testing continue to be conducted on low-frequency
ballasts whenever possible. By maintaining fluorescent lamp testing on
low-frequency ballasts when possible, DOE's proposed updates to more
current ANSI standards would not alter the measured efficacy of
fluorescent lamps and maintain consistent testing across manufacturers.
In addition, DOE is proposing amendments related to the calculation of
``lamp efficacy'' for GSFL. Presently, manufacturers are directed to
report efficacies to differing degrees of accuracy for fluorescent and
incandescent lamps. For example, fluorescent lamp efficacies are
rounded off to the nearest whole number, while incandescent lamp
efficacies are reported to the tenths decimal place. DOE is proposing
to revise the reporting requirements for GSFL, such that all covered
lamp efficacies are reported with an accuracy to the tenths decimal
place. DOE believes that such change would not only promote consistency
among the various lamp categories, but also would coincide with the
significant digits presented in the EPCA efficacy standard. In addition
DOE found that in order to have standard levels for GSFL that are best
able to maximize energy savings, it must utilize the tenths decimal
place in its energy conservation standards analysis.
DOE is also proposing in the test procedure NOPR to adopt a testing
and calculation method for measuring the correlated color temperature
(CCT) of fluorescent and incandescent lamps, a provision that is not
currently contained in the test procedure. DOE is considering using CCT
to differentiate between product classes for GSFL, and DOE notes that
the definitions of ``colored fluorescent lamp'' and ``colored
incandescent lamp'' both incorporate CCT ranges, which, in part,
determine whether lamps are subject to regulation.
The test procedure NOPR also recognizes that DOE is considering the
possibility of extending coverage to certain additional GSFL (see
section II of this notice). In addition, the test procedure NOPR
recognizes and accounts for the fact that EISA 2007 has extended
statutorily-prescribed energy conservation standards to specified types
of GSIL. Thus, the NOPR informs the public that DOE intends to amend
the test procedures to accommodate these additional lamps, and to
provide appropriate test methods, should DOE adopt standards for them.
Overall, and as stated in the NOPR, DOE believes that most of the
proposed revisions to the test procedures would not significantly
change the reported efficacy of covered lamps or result in a
significant increase in testing burden. For any that do have an
appreciable impact on the reported efficacy, DOE is proposing to delay
the effectiveness of such test procedure revision until the effective
date of any new energy conservation standard for these products.
DOE held a public meeting to discuss both the test procedure NOPR
and energy conservation standards ANOPR for fluorescent and
incandescent lamps. DOE intends to issue a final rule for the lamps
test procedure prior to issuing the NOPR for the energy conservation
standards rulemaking.
II. Consideration Regarding the Scope of Energy Conservation Standards
Coverage
A. Introduction
As noted previously, section 325(i)(5) requires DOE to consider
whether to adopt energy efficiency standards for additional GSFL beyond
those already covered by the statutorily-prescribed standard. (42
U.S.C. 6295(i)(5)) More specifically, EPCA directs that the Secretary
``shall initiate a rulemaking procedure to determine if the standards
in effect for fluorescent lamps should be amended so that they would be
applicable to additional general service fluorescent [lamps] * * * ''
Id. Pursuant to this mandate and as explained in this section of the
notice, DOE has made a preliminary determination that expanded coverage
would be appropriate. The public is invited to review and comment on
the initial findings and analyses, as set forth below, regarding which
additional fluorescent lamps should be evaluated for possible coverage
by energy conservation standards.
Furthermore, DOE was urged to make this preliminary determination
by comments received at the Public Meeting. For example, the Appliance
Standards Awareness Project (ASAP) recommended that DOE should permit
the public to comment on consideration of the scope of additional
product coverage, and that DOE should define that scope of coverage
early in the rulemaking process in order to prevent any scheduling
delays. (Public Meeting Transcript, No. 4.5 at pp. 34-36) DOE agrees
with the ASAP comment, and consequently, this notice provides the
public with the opportunity to submit comments regarding DOE's
preliminary determination.
Below, DOE discusses the range of additional lamps that EPCA
authorizes DOE to consider. Then, DOE identifies those additional GSFL
that it believes warrant further consideration for possible energy
conservation standards, and why. DOE requests comment on these
subjects. After consideration of these comments, DOE may propose
additional lamps to be covered, along with proposed standard levels for
these lamps, during the NOPR stage of this standards rulemaking. After
further public comment, DOE will publish a final rule which includes
its final decision regarding coverage of additional lamps (and
applicable standards levels, as appropriate).
In addition, the following sections also discuss modifications of
various existing lighting-related definitions DOE developed and
incorporated into the CFR. These modifications reflect market
migrations or changes in industry standards and often have the effect
of increasing or decreasing DOE's scope of energy conservation
standards coverage.
B. Additional General Service Fluorescent Lamps Being Considered Under
EPCA Section 325(i)(5)
1. Scope
Prior to embarking on a discussion of additional coverage of
general service fluorescent lamps, it is first necessary to explain the
extent of coverage under the present standard. Section 325(i)(1) of
EPCA established energy conservation standards for certain 4-foot
medium bipin lamps, 2-foot U-shaped lamps, 8-foot recessed double
contact high output lamps, and 8-foot single pin slimline lamps. (42
U.S.C. 6295(i)(1)) The relevant standard levels for the products can be
found in DOE's regulations at 10 CFR 430.32(n).
As the next step in this inquiry, DOE notes that section 325(i)(5)
of EPCA directs DOE to determine if the standards in effect should be
amended so as to apply to ``additional general service fluorescent
[lamps] * * *'' (42 U.S.C. 6295(i)(5)) There are currently a wide
variety of fluorescent lamps being used in broad, general service
lighting applications \16\ that are not covered by
[[Page 13629]]
existing energy conservation standards. Accordingly, these lamps are
potential candidates for expanded coverage pursuant to 42 U.S.C.
6295(i)(5).
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\16\ A key provision in the statutory definitions of ``general
service fluorescent lamp'' is that the lamp must satisfy ``the
majority of fluorescent applications.'' (42 U.S.C. 6291(B)) DOE
interprets these phrases to mean that these lamps have broad utility
in various fluorescent or lighting applications. In general, these
lamps will not represent products used solely in niche applications
(such as those specifically excluded in the definition of ``general
service fluorescent lamp''), but rather will represent products that
often fulfill general illumination purposes (casting light over a
broad area), such as in the following common locations: Office
space, warehouses, call centers, schools, health care, government
buildings, residential housing, and retail stores.
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In addition, DOE received a joint comment from several stakeholders
(hereafter referred to as ``Joint Comment'') concerning the extent of
DOE's authority to expand coverage of its energy conservation standard
for lighting products. The Joint Comment was submitted by the Alliance
to Save Energy, ACEEE, ASAP, Natural Resources Defense Council,
Northeast Energy Efficiency Partnerships, Northwest Power and
Conservation Council, and PG&E (Pacific Gas and Electric). Given the
stakeholders involved, it should be noted that the Joint Comment
reflects views of both energy efficiency advocates and utilities.
The Joint Comment asserted that section 325(i)(5) of EPCA
authorizes DOE to adopt standards for any fluorescent lamp not
currently covered by standards so long as standards for that lamp would
be technologically feasible, economically justified, and would achieve
significant energy savings. The comment seems to argue that in
implementing section 325(i)(5), DOE should interpret its mandate
broadly to include any GSFL that meet these statutory criteria. (Joint
Comment, No. 9 at pp. 1-2; Public Meeting Transcript, No. 4.5, pp. 38-
39, and 45)
Given that EPCA's statutory definitions of ``general service
fluorescent lamp'' contains a number of express exclusions for certain
categories of fluorescent lamps, DOE finds no basis in the language of
EPCA to support commenters' assertions that the agency's authority to
act under section 325(i)(5) of EPCA is unlimited. As discussed below,
DOE believes section 325(i)(5) covers additional GSFL that are not one
of the enumerated specialized products that EPCA excludes from coverage
(see 42 U.S.C. 6291(30)(B)). EPCA defines ``general service fluorescent
lamp'' as follows:
[F]luorescent lamps which can be used to satisfy the majority of
fluorescent applications, but does not include any lamp designed and
marketed for the following non-general lighting applications:
(i) Fluorescent lamps designed to promote plant growth.
(ii) Fluorescent lamps specifically designed for cold temperature
installations.
(iii) Colored fluorescent lamps.
(iv) Impact-resistant fluorescent lamps.
(v) Reflectorized or aperture lamps.
(vi) Fluorescent lamps designed for use in reprographic equipment.
(vii) Lamps primarily designed to produce radiation in the ultra-
violet region of the spectrum.
(viii) Lamps with a color rendering index of 87 or greater.
(42 U.S.C. 6291(30)(B)) Both key elements of this definition--i.e.,
that the lamps can satisfy the majority of lighting applications and
the exclusion of certain specialized fluorescent lamps--are consistent
with the mandate of section 325(i)(5) that DOE consider and adopt
standards for GSFL that currently are not covered by standards. That
would allow DOE to cover a broad range of additional products used and
viewed as general service fluorescent lamps.
In determining which GSFL would be suitable for consideration under
42 U.S.C. 6295(i)(5), DOE limited its inquiry to those fluorescent
lamps with generic physical and operational features closely matching
the IESNA's widely accepted definition of ``fluorescent lamp,'' as
contained in ``The IESNA Lighting Handbook: Reference and
Application,'' Ninth Edition, 2000, p. G-14.\17\ Because only lamps
with these features are commonly understood to be fluorescent or
general service fluorescent lamps, DOE would apply standards to only
such fluorescent lamps, provided that such lamps are not expressly
excluded under 42 U.S.C. 6291(30)(B).
---------------------------------------------------------------------------
\17\ The definition of fluorescent lamp in the IESNA handbook is
a ``low-pressure mercury electric-discharge lamp in which a
fluorescing coating (phosphor) transforms some of the UV energy
generated by the discharge into light.''
---------------------------------------------------------------------------
In summary, in considering whether to amend the standards in effect
for fluorescent lamps to apply to ``additional'' GSFL under section
325(i)(5) of EPCA, DOE has considered all lamps that meet the general
description of a ``fluorescent lamp'' in the introductory language of
42 U.S.C. 6291(30)(A), that can be used to satisfy the majority of
fluorescent lighting applications, for which EPCA does not prescribe
standards, and that are not within the exclusions specified in 42
U.S.C. 6291(30)(B).
2. Rationale for Coverage
In considering which additional GSFL to cover, DOE considered lamps
other than those specifically excluded. Among the lamps considered, DOE
used potential energy savings of the lamps as the primary criterion in
considering preliminarily which should be covered by the standards
program. After selecting the lamps for consideration, DOE then
conducted a preliminary assessment of whether a standard on those lamps
would have the potential to meet the two remaining criteria for
prescribing new or amended standards--i.e., being technologically
feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) In the
ANOPR (as described in section III below) and NOPR, each lamp selected
for coverage would then be the subject of a more comprehensive analysis
to determine if there is a reasonable likelihood that standards are
justified.
DOE assessed the potential to achieve significant energy savings by
extending coverage to particular lamps from market-share estimates and
from potential incremental energy savings that could result from more-
efficacious lamp designs. DOE has quantitative shipment or market share
information for certain lamps, such as 8-foot T8 single pin slimline
lamps, which it considered and cites in this notice. However, DOE has
little to no information on shipments or market share for other lamp
types which DOE is considering, such as 8-foot very high output (VHO)
fluorescent lamps. In the absence of data, DOE has relied on
qualitative assessments of market share (based on discussions with
lighting industry experts) to gauge the potential for significant
energy savings. DOE invites the public to present further shipment or
market share data relevant to consideration of coverage for additional
lamps.
In addition, DOE assessed the potential to achieve significant
energy savings for particular lamps by considering whether these lamps
serve as potential substitutes to other regulated lamps. By leaving
potential substitutes unregulated, DOE risks that regulating one lamp
shape may lead to rapid increased sales of other, unregulated
substitutable shapes. This shift of installed stock towards unregulated
lamps may result in decreased energy savings, or even the possibility
of increased energy use, from energy conservation standards on
regulated lamps. In order to avoid this consequence, DOE plans to
consider coverage of GSFL lamps that are potential substitutes for any
lamps that have high energy savings potential and are likely to be
regulated. Though the shipments of these substitute lamps may not
currently be high-volume, DOE believes that if the lamps are left
unregulated, the shipments have the potential to grow in market share.
As long as efficacy improvements are technologically feasible, coverage
of these additional substitute lamps has the potential to not only
provide energy
[[Page 13630]]
savings in their own right, but to also prevent potentially significant
losses in energy savings through substitution effect.
In addition to independently conducting its preliminary
determination analysis, DOE considered comments on the additional GSFL
it should cover. The following subsections provide a discussion of the
GSFL being considered and not considered as expanded coverage, a
summary of comments relating to the preliminary determination, and
DOE's response to these comments. DOE invites comment on the rationale
for coverage presented in this preliminary determination. DOE also
invites comment on the scope of coverage defined in this preliminary
determination.
In addition, the following sections also discuss modifications to
various existing lighting-related definitions DOE developed and
incorporated into the CFR, which would have the effect of increasing
the scope of coverage under applicable energy conservation standards.
The new and amended definitions under consideration are discussed and
presented in section II.C.
3. Analysis of Individual General Service Fluorescent Lamps
Current DOE regulations set standards for the following types of
fluorescent lamps: (1) 4-foot, medium bipin, straight-shaped lamps,
rated wattage >= 28W; (2) 2-foot, medium bipin, U-shaped lamps, rated
wattage of >= 28W; (3) 8-foot, recessed double contact, rapid start,
high output lamps, 0.800 nominal amperes (as defined in ANSI C78.1-
1991); and (4) 8-foot, single pin, instant start, slimline lamps, rated
wattage of >= 52 (as defined in ANSI C78.3-1991). Based on an
investigation of available products in manufacturer catalogs, DOE
identified various, currently-unregulated general service fluorescent
lamps that could be considered for additional coverage under section
325(i)(5) of EPCA, while maintaining the exclusions specified in the
definition of ``general service fluorescent lamp.'' These lamps are as
follows:
4-foot, medium bipin, straight-shaped lamps, rated wattage
of < 28W;
2-foot, medium bipin, U-shaped lamps, rated wattage of <
28W;
Additional 8-foot, recessed double contact, rapid start,
high output lamps;
Additional 8-foot single pin, instant start, slimline
lamps;
Very High Output (VHO) straight-shaped lamps;
T5 miniature bipin straight-shaped lamps;
Additional straight-shaped and U-shaped lamps, other than
those listed above (e.g., alternate lengths, diameters, or bases); and
Additional fluorescent lamps with alternate shapes (e.g.,
circline, pin-based CFL).
The following section discusses DOE's rationale for considering or not
considering expansion of coverage to the above-listed lamps. In
addition, in section II.C, DOE considers revisions to the definitions
of ``rated wattage'' and ``colored fluorescent lamp'' which may further
affect DOE's scope of energy conservations standards coverage.
DOE is considering extension of the standard's coverage to certain
4-foot, medium bipin, GSFL to which standards do not currently apply.
Presently, DOE's regulations do not cover or set standards for any 4-
foot medium bipin lamp with a wattage less than 28W. As part of this
preliminary determination, DOE is considering extension of coverage to
4-foot, medium bipin, straight-shaped fluorescent lamps with wattages
between 25W and 28W. DOE understands that 25W, 4-foot medium bipin, T12
fluorescent lamps are manufactured and used primarily in the
residential sector for general purpose illumination applications,
providing additional opportunity for energy savings. Although DOE
received no quantitative shipment information on the market share of
these wattages of 4-foot medium bipin lamps, DOE has found that
manufacturers currently market and sell 25W, 4-foot medium bipin, T8
fluorescent lamps as replacements for higher-wattage, 4-foot medium
bipin, T8 fluorescent lamps. As discussed earlier, by expanding
standards coverage to substitute lamps of currently regulated lamps,
DOE mitigates the risk of 25W lamps becoming a potential loophole (that
decreases energy savings) to the current and pending amended standards
on 4-foot medium bipin lamps.
For these reasons, DOE believes that 25W 4-foot medium bipin lamps
(both T8 and T12) are suitable candidates to be considered for coverage
under this rulemaking. In addition, as the technology and incremental
costs associated with increased efficiency of 25W lamps are similar to
their already regulated 28W counterparts, DOE has tentatively concluded
that standards on these lamps have the potential to meet the statutory
criteria of being technologically feasible and economically justified.
Therefore, in this ANOPR, DOE analyzes these lamps as part of the 4-
foot medium bipin product class in the life-cycle cost (LCC) and
national impact analysis (NIA) (sections III.G and III.I,
respectively). DOE invites comment on this potential expansion of
coverage to 4-foot medium bipin lamps with wattages greater than or
equal to 25W, including whether T12 lamps (commonly referred to as
``residential straight-shaped lamps'') should be covered.
Similar to 4-foot medium bipin lamps, DOE's current regulations do
not cover or set standards for any 2-foot U-shaped lamp with a wattage
less than 28W. In its research of available product in manufacturer
catalogs, DOE found no commercially-available 2-foot U-shaped GSFL with
wattages less than 28W. Therefore, DOE believes that the current
standards cover the majority of the U-shaped general service lighting
products available in the market today. Consequently, DOE's preliminary
assessment is that lowering the minimum wattage threshold of U-shaped
lamps will most likely not result in significant additional energy
savings. For this reason, DOE is not considering expanded coverage of
2-foot, medium bipin, U-shaped lamps in this preliminary determination.
In this preliminary determination, DOE is considering extension of
the standard's coverage to certain 8-foot, recessed double contact,
rapid start, high output fluorescent lamps to which energy conservation
standards do not currently apply. DOE's definition of ``fluorescent
lamp,'' adopted in accordance with EPCA, includes only those 8-foot
recessed double contact HO lamps with 0.800 nominal amperes and which
are listed in ANSI Standard C78.1-1991. 10 CFR 430.2. Due to the ampere
specification in the definition, the current standards applicable to
GSFL (10 CFR 430.32(n)(1)), cover only T12, 8-foot recessed double
contact HO lamps but none of the T8, 8-foot recessed double contact HO
lamps (which usually have 0.400 nominal amperes). ACEEE and Osram
Sylvania (hereafter ``Osram'') commented that DOE should cover T8, 8-
foot lamps. (Public Meeting Transcript, No. 4.5 at p. 59) According to
Osram, T8, 8-foot recessed double contact HO lamps are currently
available, and are replacing the older T12 technology. Osram stated its
belief that this trend will continue. (Osram, No. 15 at p. 5)
Furthermore, DOE is aware that T8, 8-foot lamps are substitutes for
T12, 8-foot lamps. As discussed earlier, by not regulating substitutes
(e.g., T8, 8-foot recessed double contact HO lamps) of regulated lamps
(e.g., T12, 8-foot recessed double contact HO lamps), DOE risks losing
the potential energy savings of the current energy
[[Page 13631]]
conservation standards for T12, 8-foot lamps, as well as any revised
standard that may be adopted pursuant to this rulemaking. In addition,
because T8, 8-foot recessed double contact HO lamps are predicted to
replace the T12 market, the shipments of T8 lamps may increase
considerably.
For the reasons above, DOE believes that regulating T8, 8-foot
recessed double contact HO lamps has the potential to achieve
significant energy savings. DOE analyzes these T8 lamps as part of the
8-foot recessed double contact HO product class in the NIA. From this
analysis, DOE estimates that the energy savings achieved due to
regulation of T8, 8-foot recessed double contact HO lamps could be as
high as 0.30 quads over the analysis period. (See section III.I of this
notice.)
In addition, in this preliminary determination, DOE tentatively
plans to expand its coverage of 8-foot recessed double contact, rapid
start, high output fluorescent lamps to those not listed in ANSI
Standard C78.1-1991. As discussed in the fluorescent and incandescent
lamps test procedure NOPR published in today's Federal Register, many
of the ANSI standards currently referenced in DOE regulations (e.g.,
ANSI Standard C78.1-1991) are outdated. DOE understands that as the
fluorescent lamp market moves forward and evolves, new 8-foot recessed
double contact, rapid start, high output lamps (with 0.800 nominal
amperes or other currents) may be introduced into the market. As these
lamps would not be listed in the 1991 ANSI standard, they would not be
covered under paragraph (3) of the definition of fluorescent lamp, and,
therefore, would not be subject to current energy conservation
standards. However, DOE understands that though these newly introduced
lamps might have different wattages than those listed in ANSI Standard
C78.1-1991, they serve as replacements and substitutes for the
regulated 8-foot recessed double contact high output lamps. As
discussed earlier, by leaving these potential substitute lamps
unregulated, DOE risks not achieving the maximum energy savings from
its established energy conservation standards.
Given the potential energy savings, in this preliminary
determination, DOE is considering extension of coverage to T8, 8-foot
recessed double contact HO lamps, thereby adding lamps previously
restricted by the 0.800 nominal ampere limitation. In addition, DOE is
considering extension of coverage to 8-foot recessed double contact HO
lamps not listed in ANSI Standard C78.1-1991. As the technologies of
T8, 8-foot recessed double contact HO lamps and the 8-foot recessed
double contact HO lamps not listed in ANSI Standard C78.1-1991 are
similar to the technologies of their already-regulated T12
counterparts, DOE has tentatively concluded that standards on these
lamps have the potential to meet the statutory criterion of being
technologically feasible. With regards to the statutory criterion of
being economically justified, DOE analyzes T8, 8-foot recessed double
contact HO lamps in the LCC analysis and NIA. Preliminary results show
that regulation of these lamps would be expected to achieve LCC savings
up to $3.15 (discounted at 6.2 percent) per lamp system and net present
value (NPV) up to $0.73 billion to the nation (discounted at 3 percent)
over the analysis period. Also, 8-foot recessed double contact HO lamps
not listed in ANSI Standard C78.1-1991 should incur similar economic
effects as their already-covered counterparts. Therefore, for the
purpose of this preliminary determination, DOE has tentatively
concluded that energy conservation standards on these lamps have the
potential of being economically justified.
Similar to 8-foot recessed double contact HO lamps, in this
preliminary determination, DOE is considering extension of the
standard's coverage to certain 8-foot, single pin, instant start,
slimline lamps to which energy conservation standards do not currently
apply. DOE's definition of ``fluorescent lamp,'' adopted in accordance
with EPCA, includes only those 8-foot, single pin, instant start,
slimline lamps, with a rated wattage greater than or equal to 52W and
listed in ANSI Standard C78.3-1991. 10 CFR 430.2. Under this
definition, because they are not listed in ANSI Standard C78.3-1991, no
T8, 8-foot single pin slimline lamps would be subject to energy
conservation standards. However, as indicated by their inclusion in the
updated ANSI Standard C78.81-2005, DOE understands that since the
publication of ANSI Standard C78.3-1991, T8, 8-foot single pin slimline
lamps have penetrated the GSFL market. Shipment information submitted
by NEMA indicates that T8 lamps comprise approximately 15 percent of
the total 8-foot single pin slimline market. (NEMA, No. 12 at p. 2) In
addition, ACEEE and Osram commented that DOE should cover T8, 8-foot
single pin slimline lamps. (Public Meeting Transcript, No. 4.5 at p.
59) For similar reasons as discussed with regard to T8, 8-foot recessed
double contact HO lamps, DOE believes that the regulation of T8, 8-foot
single pin slimline lamps has the potential to achieve significant
energy savings. DOE analyzes these T8 lamps as part of the 8-foot
single pin slimline product class in the NIA. From this analysis, the
energy savings achieved due to the regulation of T8, 8-foot single pin
slimline lamps would be expected to be as high as 0.25 quads over the
analysis period (i.e., from the year 2012 to 2042). (See section III.I
of this notice.)
As such, in this preliminary determination, DOE is considering
expanding the standards' scope of coverage of 8-foot single pin
slimline lamps with a rated wattage greater than or equal to 52W to
those not listed in ANSI Standard C78.3-1991. This would include T8
lamps and any additional 8-foot single pin slimline lamps that might be
introduced into the fluorescent lamp market in the future. As the
technologies of T8, 8-foot single pin slimline lamps and the 8-foot
single pin slimline lamps not listed in ANSI Standard C78.3-1991 are
similar to the technologies of their already-regulated T12
counterparts, DOE has tentatively concluded that standards on these
lamps have the potential to meet the statutory criterion of being
technologically feasible. With regards to the statutory criterion of
being economically justified, DOE analyzes T8, 8-foot single pin
slimline lamps in the LCC analysis and NIA. Preliminary results show
that regulation of these lamps has the potential to achieve LCC savings
up to $8.27 per lamp system (discounted at 6.2 percent) and NPV of
$1.15 billion to the nation (discounted at 3 percent) over the analysis
period (i.e., from the year 2012 to 2042). Also, 8-foot single pin
slimline lamps not listed in ANSI Standard C78.1-1991 would be expected
to incur similar economic effects as their already covered
counterparts. Therefore, for the purpose of this preliminary
determination, DOE has tentatively concluded that energy conservation
standards for these lamps have the potential to be economically
justified.
DOE also observed that some 8-foot, single pin, slimline lamps with
wattages below 52W are available on the market today. These include 51W
and 50W versions. However, DOE notes that published catalogs offered
very few models at these wattages. Also, DOE believes that these lower-
wattage slimline lamps are used for niche applications and would likely
not be used as a substitute for higher-wattage versions. In particular,
these lamps offer different lumen packages from their higher-wattage
counterparts and are not currently marketed as substitutes.
Consequently, DOE believes that the
[[Page 13632]]
market share of such lamps is and will remain relatively small, thereby
making the potential energy savings that would be achieved from their
regulation small as well. Therefore, DOE has tentatively decided not to
extend coverage of the energy conservation standards to T8, 8-foot
single pin slimline lamps with wattages below 52W. DOE requests comment
on this approach.
In this preliminary determination, DOE also considered whether or
not to expand coverage to include very high output (VHO) fluorescent
lamps. Philips Lighting (hereafter ``Philips'') commented that DOE
should set standards for VHO, T12 fluorescent lamps, asserting that
these lamps consume a large amount of energy. (Philips, No. 5 at p. 1)
DOE research involving review of manufacturer catalog data corroborated
the Philips comment, as common VHO fluorescent lamps can have rated
wattages ranging from 115W to 215W, while corresponding HO lamps have
rated wattages ranging from 60W to 110W. However, in considering the
Philips comment, DOE learned from discussions with manufacturers that
many VHO lamps are used in outdoor applications, such as parking lot or
other area illumination, where high-intensity discharge (HID) lamps are
rapidly gaining market share. Research also indicated that shipments of
VHO, T12 lamps have been and are continuing to decline rapidly.
Overall, DOE understands that these lamps constitute a very low-volume
share of the relevant market, and these products will likely further
decrease in terms of market share. As such, although these lamps may
individually have a per-lamp energy savings potential larger than that
of a typical GSFL, DOE believes that the total energy savings from
regulating these lamps would be small and decreasing as that these
lamps are naturally disappearing from the market in the absence of
regulation. Therefore, DOE does not plan to extend coverage of the
energy conservation standard to VHO lamps.
DOE also considered whether to include T5 fluorescent lamps in its
expansion of energy conservation standards coverage. At the Public
Meeting on the Framework Document, ACEEE and PG&E commented that DOE
should cover T5 lamps. (Public Meeting Transcript, No. 4.5 at pp. 39
and 59) However, ACEEE and PG&E did not provide a rationale for
consideration of these lamps, and DOE did not receive any written
comments recommending that it consider T5 lamps for coverage. To
further investigate this issue, DOE evaluated the market and typical
applications for T5 lamps, and has tentatively decided to not extend
coverage to T5 lamps, for the reasons that follow.
DOE found that T5 systems are used in a wide variety of indoor
general illumination applications where T8 and T12 systems could also
be used. However, DOE understands that T5 systems are always operated
with higher-efficiency, high-frequency electronic ballasts (versus
lower-efficiency, low-frequency ballasts). In addition, it was found
that these lamps tend to have higher efficacies and that the systems
tend to have lower energy consumption than the corresponding T8 and T12
lamps and systems. Therefore, DOE believes that the regulation of T5
lamps may not have the potential for significant per-unit energy
savings. In addition, DOE understands that the current GSFL market
share of T5 lamps is relatively small, representing low total energy
savings potential. DOE also notes that T5 systems tend to be higher in
cost than T8 or T12 systems. Thus, DOE believes that excluding T5 lamps
from this rulemaking would be unlikely to undermine any energy savings
that would result from a T12 and T8 standard, even if the standard
caused increased sales of T5 systems.\18\ To the contrary, not
regulating T5 lamps could provide market incentives for and result in
energy savings by encouraging greater end-user use of highly
efficacious T5 lamps. For the above stated reasons, DOE does not plan
to extend the standards' coverage to T5 lamps. DOE solicits further
comment on whether it should extend coverage to T5 lamps, as well as
the rationale for doing so.
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\18\ At CSLs four and five, some T8 systems are more efficacious
than their T5 counterparts. However, DOE notes that the average cost
of a T5 system is more expensive than a T8 system. The fact that T5
lamps are less efficacious and more expensive at these standard
levels indicates that there is little or no incentive for
stakeholders to migrate to T5 lamps from T8 or T12 lamps in an
effort to avoid the fluorescent lamp standard.
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Furthermore, DOE does not intend to extend coverage to fluorescent
lamps that have alternate lengths, diameters, bases, or shapes (or a
combination thereof) than the lamps discussed in the preceding section.
DOE believes that the lamps currently covered and the additional lamps
described above that DOE is considering for coverage (i.e., ones which
have lengths and bases the same as those currently regulated) represent
the significant majority of the market for GSFL, and, thus, the bulk of
potential energy savings. Furthermore, DOE believes that there is
limited potential for lamps with miscellaneous lengths and bases to
grow in market share, given the constraint of fixture lengths and
socket compatibility. DOE requests comment on this approach.
In summary, the following list represents the ``additional general
service fluorescent lamps'' which DOE is considering for expanded
coverage under the energy conservation standards:
4-foot, medium bipin lamps with wattages >= 25 and < 28;
8-foot recessed double contact, rapid start, HO lamps not
defined in ANSI Standard C78.1-1991;
8-foot recessed double contact, rapid start, HO lamps
(other than 0.800 nominal amperes) defined in ANSI Standard C78.1-1991;
and
8-foot single pin instant start slimline lamps, with a
rated wattage >= 52, not defined in ANSI Standard C78.3-1991.
C. Amended Definitions
As part of the examination of the scope of coverage of GSFL, DOE is
considering amendments to existing DOE-adopted definitions in order to
more clearly and accurately define the scope of GSFL and IRL. The
following section describes these planned amendments and requests
comment.
1. ``Rated Wattage''
One element of EPCA's definitions for ``fluorescent lamp'' and
``incandescent reflector lamp'' is a lamp's ``rated wattage,'' which
helps to delineate the lamps for which the statute set prescriptive
standards. (42 U.S.C. 6291(30)(A), (C)(ii) and (F)). For example, the
definition of ``fluorescent lamp'' includes certain 4-foot medium bipin
lamps with ``a rated wattage of 28 or more'' (42 U.S.C.
6291(30)(A)(i)), and EPCA prescribes standards for these particular
lamps (42 U.S.C. 6295(i)(1)(B)). In addition, EISA 2007 prescribed
energy conservation standards for general service incandescent lamps
that require lamps of particular lumen outputs to have certain maximum
rated wattages. (section 321(a)(3) of EISA 2007 amending section 325(i)
of EPCA) EPCA does not, however, define ``rated wattage.'' Therefore,
DOE adopted a definition of ``rated wattage'' for 4-foot medium bipin
T8, T10, and T12 fluorescent lamps when it established test procedures
for fluorescent and incandescent lamps in 1997. 62 FR 29222 (May 29,
1997). This definition, located in 10 CFR 430.2, references an ANSI
guide from 1991, specifically ANSI Standard C78.1-1991, ``for
Fluorescent Lamps--Rapid-Start Types--Dimensional and Electrical
Characteristics.'' Although EPCA also
[[Page 13633]]
uses the term ``rated wattage'' when referring to ``2-foot U-shaped
lamps'' (42 U.S.C. 6291(30)(A)(ii)), ``8-foot slimline lamps,'' (42
U.S.C. 6291(30)(A)(iv)), and ``incandescent lamps'' (i.e., the portion
of that definition pertaining to IRL) (42 U.S.C. 6291(30)(C)), DOE did
not define ``rated wattage'' for these lamps in 1997. In this
rulemaking, DOE plans to update its existing definition of ``rated
wattage'' to cite the current version of ANSI Standard C78.1-1991, and
to apply this definition to those lamps where rated wattage is a key
characteristic but is not currently defined.
DOE's current definition of ``rated wattage'' for 4-foot medium
bipin T8, T10, or T12 lamps, in effect, contains three definitions of
``rated wattage'': One for those lamps listed in the ANSI Standard
C78.1-1991 standard; another for residential straight-shaped lamps; and
a third for all other lamps. The definition of ``rated wattage''
currently contained in DOE regulations is as follows:
Rated wattage, with respect to 4-foot medium bi-pin T8, T10 or T12
lamps, means:
(1) If the lamp is listed in ANSI C78.1-1991, the nominal wattage
of a lamp determined by the lamp designation in Annex A.2 of ANSI
C78.1-1991; or
(2) If the lamp is a residential straight-shaped lamp, the wattage
a lamp consumes when operated on a reference ballast for which the lamp
is designed; or
(3) If the lamp is neither listed in ANSI C78.1-1991 nor a
residential straight-shaped lamp, the wattage a lamp consumes when
using reference ballast characteristics of 236 volts, 0.43 amps and 439
ohms for T10 or T12 lamps or reference ballast characteristics of 300
volts, 0.265 amps and 910 ohms for T8 lamps. (10 CFR 430.2)
Annex A.2 of ANSI Standard C78.1-1991, referenced in the first part
of the definition, discusses how to designate lamps according to
industry procedure. It indicates that the lamp abbreviation may include
either the rated wattage or nominal wattage for a particular lamp. The
most current equivalent industry standard corresponding to ANSI
Standard C78.1-1991 is ANSI Standard C78.81-2005, which also includes
an equivalent section on lamp abbreviations. However, this equivalent
section specifies that lamp abbreviations are to incorporate only the
nominal wattage. DOE believes that a different section of ANSI Standard
C78.81-2005 more appropriately defines ``rated wattage.'' Specifically,
Clause 11.1 of ANSI Standard C78.81-2005 deals more directly with rated
wattage when it refers to rated values in the lamp data sheets of Part
IV of the standard and notes the margin that manufacturer's average
values must maintain from rated values. In relevant part, Clause 11.1
of ANSI Standard C78.81-2005 states: The values of lamp voltage,
current and wattage shown on the individual lamp data sheets in Part IV
are rated values that apply after the lamps have been aged for 100
hours. These values were chosen by consensus to represent the industry
average at the time of publication. No manufacturer's average wattage
shall exceed the rated value by more than 5% plus 0.5 watts * * *
Therefore, DOE tentatively plans to update the ``rated wattage''
definition's reference to ANSI Standard C78.81-2005 and to reference
Clause 11.1 of that ANSI standard in place of Annex A.2 of ANSI
Standard C78.1-1991.
The second part of the ``rated wattage'' definition addresses
residential straight-shaped lamps. DOE adopted a definition for
``residential straight-shaped lamp'' in 10 CFR 430.2 at the same time
it defined ``rated wattage'' and established the applicable test
procedures. 62 FR 29222 (May 29, 1997). This definition applies only to
4-foot medium bipin lamps. The provisions on residential straight-
shaped lamps reflect DOE's understanding that lamp wattage differs when
a lamp operates on a low-power-factor ballast (typically residential
applications) versus a high-power-factor ballast (typically commercial
applications). (The measured wattage of a residential straight-shaped
lamp could be different depending on the ballast on which it is
operated.) \19\ Thus, these provisions effectively ensure that lamps
designed for residential applications are tested on ballasts typically
used for residential applications. Defining ``rated wattage'' for these
lamps is significant, as it clarifies whether DOE's standards are
applicable to them. DOE believes that the clarification is still
relevant. However, DOE notes that ANSI Standard C78.81-2005 lists a
rated wattage value for a 25-Watt, 4-foot T12 rapid start medium bipin
fluorescent lamp, operating on a low-power-factor ballast. Thus, it
appears that some lamps which could be classified as a residential
straight-shaped lamp have rated wattage values listed in ANSI Standard
C78.81-2005. Therefore, DOE intends to update the second portion of the
definition to state that if a residential straight-shaped lamp is not
listed in ANSI, then rated wattage should be based on the wattage a
lamp consumes when operated on a reference ballast for which the lamp
is designed.
---------------------------------------------------------------------------
\19\ If a lamp is not listed in ANSI C78.1-1991, its ``rated
wattage'' would depend on test measurements.
---------------------------------------------------------------------------
The third part of the definition for ``rated wattage'' (applicable
if neither of the first two parts applies) states that the rated
wattage is that which results when the lamp is tested under specified
testing conditions. DOE is updating the test procedures for fluorescent
and incandescent lamps in a concurrent test procedures rulemaking. The
NOPR for that rulemaking is published in today's Federal Register. As
part of the test procedures rulemaking, DOE is also developing testing
methods for lamps not currently listed in ANSI standards which will be
included as part of the DOE test procedure. DOE believes that it is
preferable to reference these more detailed test procedures, rather
than the current approach of specifying testing conditions in the
definitions section of 10 CFR 430.2. Therefore, DOE intends to replace
the third part of the ``rated wattage'' definition with a reference to
the test procedures that will be set forth in 10 CFR Part 430, Subpart
B, Appendix R.
EPCA's definition of ``fluorescent lamp'' uses the term ``rated
wattage'' not only in describing 4-foot medium bipin lamps, but also in
describing 2-foot U-shaped and 8-foot single pin slimline lamps. (42
U.S.C. 6291(30)(A)(ii) and (iv)) To clarify rated wattage for 2-foot U-
shaped, and 8-foot single pin slimline lamps, DOE has tentatively
decided to utilize the same framework to define ``rated wattage'' as
was used for 4-foot medium bipin lamps. In particular, DOE plans to
reference ANSI industry standards where they have defined the rated
wattage for particular lamps, and to reference DOE's test procedures
(as amended) where ANSI has not defined the rated wattage for
particular lamps. Thus, DOE intends to modify the current definition of
``rated wattage'' that applies to 4-foot medium bipin lamps and make it
applicable to all covered fluorescent lamps. Because ANSI Standard
C78.81-2005 does not include ratings for U-shaped lamps, DOE plans to
incorporate by reference and to cite to ANSI Standard C78.901-2005,
``for Electric Lamps--Single-Based Fluorescent Lamps--Dimensional and
Electrical Characteristics'', which does. ANSI Standard C78.901-2005
also contains Clause 11.1, using text similar to that noted above.
The statutory definition for ``incandescent lamp'' also contains
the term ``rated wattage,'' and the definition for ``incandescent
reflector lamp'' similarly references a portion of the definition of
``incandescent lamp'' which contains that term. In addition,
[[Page 13634]]
EISA 2007 set energy conservation standards for general service
incandescent lamps which require the lamps to meet a maximum rated
wattage for a particular lumen output. For incandescent reflector lamps
and general service incandescent lamps, the rated wattage is the same
as measured wattage. Therefore, DOE believes that the test procedures
outlined in 10 CFR Part 430, Subpart B, Appendix R suffice for
determining rated wattage for incandescent lamps.
The following summarizes the modified definition of ``rated
wattage'' that DOE intends to consider making applicable to all covered
lamps and updated to reference current industry standards:
Rated wattage means:
(1) With respect to fluorescent lamps and general service
fluorescent lamps:
(i) If the lamp is listed in ANSI C78.81-2005 or ANSI C78.901-2005,
the rated wattage of a lamp determined by the lamp designation of
Clause 11.1 of ANSI C78.81-2005 or ANSI C78.901-2005;
(ii) If the lamp is a residential straight-shaped lamp, and not
listed in ANSI C78.81-2005, the wattage of a lamp when operated on a
reference ballast for which the lamp is designed; or
(iii) If the lamp is neither listed in one of the ANSI guides
referenced in (1)(i) nor a residential straight-shaped lamp, the
wattage of a lamp when measured according to the test procedures
outlined in Appendix R to subpart B of this part.
(2) With respect to general service incandescent lamps and
incandescent reflector lamps, the wattage measured according to the
test procedures outlined in Appendix R to subpart B of this part.
DOE requests comment on its above-discussed modification of the
definition of ``rated wattage,'' applicable to both covered fluorescent
and incandescent lamps. DOE recognizes that changes to the definition
could affect coverage for fluorescent lamps. However, DOE believes that
the modifications would have a relatively minor, if any, impact on the
scope of coverage.
2. ``Colored Fluorescent Lamp''
With regard to the definition of ``colored fluorescent lamp'' that
was codified in the CFR as part of the 1997 Test Procedure Final Rule,
DOE is requesting comment on the definition for this type of
fluorescent lamp which is excluded from energy conservation standards.
The current definition of that term reads as follows:
Colored fluorescent lamp means a fluorescent lamp designated and
marketed as a colored lamp, and with either of the following
characteristics: A CRI less than 40, as determined according to the
method given in CIE Publication 13.2 (see 10 CFR 430.22), or a lamp
correlated color temperature less than 2,500K or greater than 6,600K.
10 CFR 430.2.
In its market research, DOE observed that one of the major lamp
manufacturers that operates in the European market recently introduced
a fluorescent lamp with a correlated color temperature (CCT) of
17,000K. The product literature associated with this new lamp indicates
that it is intended for general illumination applications. In the
``Product Application'' section of the literature, it suggests that
this lamp be used for ``Indoor working areas (call centers, industry,
schools, healthcare etc.), especially where an energizing environment
needs to be created.'' \20\ Even though DOE is unaware of any general
purpose fluorescent lamps like this one being introduced into the U.S.
market, there is the potential that the current definition of ``colored
fluorescent lamp'' would provide an exclusion for new products being
introduced in general illumination lighting applications. Therefore,
DOE is considering revising the definition, possibly by adding a phrase
such as ``and not designed or marketed for general illumination
applications.'' DOE invites comment on this issue.
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\20\ Philips Lighting Product Specification Document, MASTER TL5
ActiViva Active 54W SLV (published June 29, 2007).
---------------------------------------------------------------------------
III. Energy Conservation Standards Analyses for Fluorescent and
Incandescent Reflector Lamps
This section addresses the analyses DOE has performed and intends
to perform for GSFL and IRL under consideration in this rulemaking and
discusses the underlying assumptions applied to the analyses. For both
GSFL and IRL, DOE will perform a set of analyses, including: (1) An
engineering analysis; (2) a product price determination; (3) an energy-
use determination; (4) an LCC and PBP analysis; (5) an NIA; and (6) an
MIA. A full description of how these analyses are performed is
contained in the TSD.\21\ However, this section of the ANOPR provides
an overview of these analyses, while focusing on how these analyses are
being tailored to this rulemaking and on their underlying assumptions.
It also discusses comments received from interested parties since DOE
published the lighting products Framework Document.
---------------------------------------------------------------------------
\21\ Available at: http://www.eere.energy.gov/buildings/appliance_standards/residential/incandescent_lamps.html.
---------------------------------------------------------------------------
A. Market and Technology Assessment
The market assessment provides an overall picture of the market for
the products concerned, including the nature of the products, the
industry structure, and market characteristics for the products. The
technology assessment identifies available technologies for these
products, which will be considered in the screening analysis. The
subjects addressed in the market and technology assessment include
product classes, technology options, manufacturers, quantities and
types of products sold and offered for sale, retail market trends, and
regulatory and non-regulatory programs. DOE considers both quantitative
and qualitative information from publicly available sources and
stakeholders in this assessment. The information DOE gathers for the
market and technology assessment serves as resource material for use
throughout the rulemaking.
1. Market Assessment
Issues addressed in the market assessment include: (1) Information
about lamp manufacturers; (2) existing regulatory and non-regulatory
initiatives; (3) historical shipments and (4) product classes. Each of
these topics will be discussed in turn below.
NEMA is the trade association that represents many GSFL and IRL
manufacturers. NEMA provides an organization framework for
manufacturers of lighting products to work together on projects that
affect their industry and business.
The majority of the domestic market share of GSFL and IRL is held
by three manufacturers: (1) GE Lighting (General Electric, Inc.); (2)
OSRAM Sylvania (Siemens AG); and (3) Philips Lighting (Royal Philips
Electronics). In addition to lamps listed under this rulemaking, the
lighting divisions of all three companies manufacture other products,
such as lamp ballasts, high intensity discharge lamps, LED lighting,
GSIL (already regulated by EISA 2007) and compact fluorescent lamps
(CFL).
It is noted that DOE is required to consider whether small
businesses are likely to be particularly affected by the promulgation
of minimum efficacy standards for lamps. (5 U.S.C. 601 et seq.) The
Small Business Administration (SBA) defines ``small business''
manufacturing enterprises for manufacturers of GSFL and IRL as ones
having 1,000 or fewer employees.\22\
[[Page 13635]]
More specifically, SBA lists small business size standards that are
matched to industries as they are described in the North American
Industry Classification System (NAICS). A small business size standard
is the largest that a for-profit entity can be and still qualify as a
small business for Federal Government programs. These size standards
are generally related to the average annual receipts or the average
employment of a firm. For lamp products, the size standard is matched
to NAICS code 335110, Electric Lamp Bulb and Part Manufacturing, which
has a size standard of 1,000 employees. DOE identifies several small
business manufacturers of GSFL and IRL in Chapter 3 of the TSD. DOE
will study the potential impacts on small businesses in detail during
the MIA, which it will conduct as a part of the analyses for the notice
of proposed rulemaking.
---------------------------------------------------------------------------
\22\ Small Business Administration, Table of Small Business Size
Standards: Matched to North American Industry Classification System
Codes. (Feb. 2007). Available at: http://www.sba.gov/services/contractingopportunities/sizestandardstopics/part121sects/index.html.
---------------------------------------------------------------------------
Furthermore, DOE is aware of several Federal, State, and
international regulatory programs that impact the GSFL and IRL markets.
Amendments to EPCA in EPACT 1992 established Federal energy
conservation standards for residential, commercial, and industrial GSFL
and IRL. (42 U.S.C. 6295(i)(1)) In addition to the Federal regulations,
the following States have established appliance efficiency regulations
for other lamps for which there are no Federal standards (and thus are
not preempted): Arizona, California, Connecticut, Maryland,
Massachusetts, Minnesota, New Jersey, New York, Oregon, Rhode Island,
Vermont, and Washington.
DOE also reviewed several voluntary programs promoting the use of
energy-efficient GSFL in the United States, including the Federal
Energy Management Program's (FEMP) program for energy-efficient
lighting, the Consortium for Energy Efficiency (CEE)'s High Performance
Commercial Lighting Initiative, the Energy Efficient Commercial
Buildings Deduction, and various regional initiatives that work with
State utilities to offer rebates for installation of higher efficacy
GSFL systems. See Chapter 3 of the TSD for more information regarding
regulatory and non-regulatory initiatives.
DOE received historical shipment data from NEMA for the years 2001
to 2005 for the two categories of lamps. (NEMA, No. 12 at pp. 5-6)
Overall, NEMA's historical lamp shipment data that was incorporated by
DOE into the analytical tools for the ANOPR had three main purposes.
First, the shipment data and market trend information contributed to
the shipments analysis and base-case forecast for each of the two
categories of lamps (see Chapter 9 of the TSD). By using recent
shipment data and expert opinion on market trends, DOE believes that
the shipments model and base-case forecasts are based on a sound
dataset. Second, DOE used the data to select the representative product
classes and representative units for analysis. Generally, DOE selected
representative product classes and units for analysis to reflect the
highest volume, most common lamp types and wattages used in the U.S.
today (see Chapter 3 of the TSD). And thirdly, DOE used these data to
develop the market-share matrices for the NIA (see Chapter 10 of the
TSD). Based on its understanding of trends in the market, DOE estimated
how the market would respond to the various CSLs.
Additional detail on the market assessment can be found in Chapter
3 of the TSD.
2. Product Classes
In general, when evaluating and establishing energy conservation
standards, DOE divides covered products into classes by the type of
energy used, capacity, or other performance-related features that
affect efficiency, and factors such as the utility of the product to
users. (See 42 U.S.C. 6295(q)) DOE normally establishes different
energy conservation standards for different product classes based on
these criteria. However, classification of lamps into product classes
presents a challenge, because, for example, a fluorescent lamp is a
component of a system, and the lamp's performance is directly related
to the ballast on which it operates. The following section describes
and discusses the product classes of lamps that DOE is considering for
this rulemaking.
a. General Service Fluorescent Lamps
EPCA established eight product classes for GSFL based on the four
fluorescent lamp types EPCA describes in its definition for
``fluorescent lamp'' and based on nominal lamp wattage. (42 U.S.C.
6295(i)(1)(B)) These product classes are outlined in Table III.1.
Table III.1.--EPCA Product Classes for GSFL
------------------------------------------------------------------------
Nominal Min. avg.
Lamp type lamp Min. CRI efficacy lm/
wattage W W
------------------------------------------------------------------------
4-ft Medium Bipin................ >35W 69 75.0
<=35W 45 75.0
2-ft U-Shaped.................... >35W 69 68.0
<=35W 45 64.0
8-ft Single Pin.................. >65W 69 80.0
Slimline......................... <=65W 45 80.0
8-ft High Output................. >100W 69 80.0
<=100W 45 80.0
------------------------------------------------------------------------
In the Framework Document for this rulemaking, DOE presented a
preliminary discussion of potential revisions to the prescriptive
standards established by EPCA. ((42 U.S.C. 6295(i)(1)(B); see 10 CFR
430.32(n)(1)). Specifically, DOE considered subdividing the product
categories in EPCA's table of efficacy requirements for fluorescent
lamps, nearly doubling the number of product classes by introducing
lamp tube diameter as a differentiating variable (i.e., ``>T8'' and
``<=T8''). In presenting this potential modification, DOE used the same
wattage divisions and minimum color rendering index (CRI) requirements
that EPCA uses for these lamps, with T8 and T12 lamps in the same
product class. Several stakeholders provided comment on the draft
product classes discussed in
[[Page 13636]]
the Framework Document, as discussed below.
For 4-foot medium bipin lamps, Philips suggested combining all
lamps with diameters greater than T8 into one category. Philips then
suggested creating a category for T8 and smaller diameters with
wattages less than or equal to 32W. (Philips, No. 11 at p. 1) GE and
Osram both supported DOE's suggestion for lamps with diameters greater
than T8, but they suggested that DOE should change the wattage division
from 35W to 31W, and include a correlated color temperature (CCT)
division for lamps with diameters less than or equal to T8. (GE, No. 13
at pp. 1-2; Osram, No. 15 at pp. 2-3) The Joint Comment recommended
that DOE combine the T8 and T12 product classes, because there are few
T8 lamps above 35W, and, therefore, the existing wattage bins could be
analyzed by maintaining some separation of T8 and T12 lamps. (Joint
Comment, No. 9 at p. 8)
For 2-foot U-shaped lamps, Philips suggested modifying the draft
product classes by combining wattage ranges, and the commenter also
recommended having just two product classes, based upon lamp diameter,
that apply to any wattage 2-foot U-shaped lamps. GE and Osram both
supported DOE's approach for considering lamps with diameters greater
than T8, and these commenters suggested that DOE should change the
wattage division from 35W to 31W, and include a CCT division for lamps
with diameters less than or equal to T8. (GE, No. 13 at pp. 1-2; Osram,
No. 15 at pp. 2-3)
For the 8-foot single pin slimline lamps, Philips suggested
combining all lamps with diameters greater than T8 into one product
class, and then establishing a separate product class for lamps with T8
and narrower diameters, regardless of wattage. (Philips, No. 11 at pp.
1-2) GE and Osram both suggested keeping the T12 category of high
output lamps, and creating a separate class for diameters less than
T12. For this new separate class, GE and Osram both proposed dividing
it further into two subclasses, one including T12 8-foot single pin
slimline lamps with wattages greater than 58W and another including T12
8-foot single pin lamps with wattages less than or equal to 58W. (GE,
No. 13 at pp. 1-2; Osram, No. 15 at pp. 2-3)
For the 8-foot high output lamps, Philips suggested combining all
lamps with diameters greater than T8 into one product class, and then
establishing a separate product class for lamps with T8 and narrower
diameters with a nominal lamp wattage of 86W and below. (Philips, No.
11 at pp. 1-2) GE and Osram both suggested keeping the T12 category of
high output lamps, and creating a separate class for lamps with
diameters less than T12. (GE, No. 13 at pp. 1-2; Osram, No. 15 at pp.
2-3) GE argued that this class of lamps with diameters less than T12
should encompass all wattages, whereas Osram recommended that the class
should encompass only lamps greater than 85W. (GE, No. 13 at pp. 1-2;
Osram, No. 15 at pp. 2-3)
DOE considered all these comments, and continued to research
appropriate product classes for the general service fluorescent lamps
being considered for coverage under this rulemaking. DOE identified
differential utility and physical attributes of fluorescent lamps
around which the development of separate product classes would be based
on the statutory criteria. (42 U.S.C. 6295(q)) \23\ In this notice, DOE
is considering establishing product classes based upon the following
three lamp attributes that have differential utility and impact
efficacy: (1) Physical constraints of lamps (i.e., lamp shape and lamp
length); (2) lumen package (i.e., regular versus high output); and (3)
CCT. Following that discussion, this document also analyzes other
potential factors that DOE considered as potential product class
determinants (i.e., ballast interoperability, lamp wattage, lamp
diameter, and color rendering index), but which were not adopted for
reasons indicated below.
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\23\ (q) Special rule for certain types or classes of products
(1) A rule prescribing an energy conservation standard for a
type (or class) of covered products shall specify a level of energy
use or efficiency higher or lower than that which applies (or would
apply) for such type (or class) for any group of covered products
which have the same function or intended use, if the Secretary
determines that covered 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 from that which applies
(or will apply) to other products within such type (or class).
In making a determination under this paragraph concerning
whether a performance-related feature justifies the establishment of
a higher or lower standard, the Secretary shall consider such
factors as the utility to the consumer of such a feature, and such
other factors as the Secretary deems appropriate.
---------------------------------------------------------------------------
i. Class Setting Factors
Physical Constraints of Lamps. The physical constraints of the lamp
relate to the shape of the lamp (e.g., U-shaped versus linear) and the
fact that these lamps could not be substitutes for each other, unless
the entire fixture is changed. The lamp shapes provide unique utility
because the shapes of these lamps prevent them from being used as
replacements, even with a ballast replacement, in a given fixture.
However, the shape and geometry of a lamp also impact its efficacy. For
example, a 2-foot U-shaped lamp, while having the same overall tube
length, is less efficacious than a 4-foot linear lamp due in part to
the fact that the electrical arc within the tube has to bend to conform
to the shape of the lamp. Similarly, a 4-foot lamp has a different
utility than an 8-foot lamp, as these lamps generally require different
fixtures. And, efficacy tends to increase with length, such that all
else being equal, 8-foot lamps generally have higher efficacy values
than 4-foot lamps. Given the impact that geometry has on both utility
and efficacy, DOE proposes maintaining the division of product classes
by lamp geometry.
Lumen Package. In addition to the physical constraints of a lamp,
DOE also recognizes that the lumen package a lamp provides to consumers
is another potential differentiating factor for product classes,
because it provides utility in the form of a quantity of light per unit
lamp length. In this way, lamps that have high lumen output may be
installed in certain high-ceiling or outdoor installations, where large
quantities of light are needed. Lamps that have standard levels of
light output might be installed in lower-ceiling installations such as
offices or hospitals, where distance between the light source and the
illuminated surfaces is not as large. DOE notes, however, that efficacy
decreases as a fluorescent lamp is driven harder to increase its light
output. For example, the efficacy of high output 8-foot lamps are
approximately 7 to 10 percent lower than that of slimline 8-foot lamps.
Because 8-foot lamps are not already subdivided according to physical
constraints, DOE plans to further subdivide the 8-foot linear lamps
into slimline and high output.
Considering the fluorescent lamps currently covered under EPCA and
the additional general service fluorescent lamps discussed in section
II which DOE is considering for coverage, DOE is considering
establishment of the following four differentiating categories of
lamps: (a) 4-foot medium bipin; (b) 2-foot U-shaped; (c) 8-foot single
pin slimline; and (d) 8-foot recessed double contact high output. DOE
notes that these are the same four categories of lamps that were
established by EPCA in section 325(i)(1). (42 U.S.C. 6295(i)(1)(B))
Correlated Color Temperature. Finally, within each of these four
categories of fluorescent lamps, DOE
[[Page 13637]]
recognizes that the CCT of the fluorescent lamps provides a distinct
utility (i.e., the light emitted by the fluorescent lamp has different
qualities), which impacts the efficacy of the lamp. The CCT describes,
in part, how the white light emitted from a fluorescent lamp is
perceived. Lower color temperatures correspond to ``warmer'' light,
with more red content in the spectrum, and higher color temperatures
correspond to ``cooler'' light, with more blue content. As the spectral
emission of the light radiated from the fluorescent lamp is modified to
change the CCT, the light emitted may contain more red light (and less
blue) or more blue light (and less red). The measured efficacy of these
lamps with different CCT will be different, because efficacy is
measured in lumens \24\ per watt, and light emitted across the visible
spectrum is not given equal weighting under this metric. Lumens are
determined using the human eye's sensitivity function, and due to the
fact that the human eye is less responsive to blue light, those
fluorescent lamps that shift their spectral emission profiles to
contain more blue light will have lower efficacies. In sum, the metric
that DOE will establish as the minimum performance requirement for
fluorescent lamps--efficacy, measured in lumens per watt--may need to
be adjusted to account for differences in the CCT of light emitted from
a fluorescent lamp. Today, lamps with a ``warmer'' CCT (4,100K)
represent the majority of the fluorescent lamp market, and therefore
this is the CCT of the lamps analyzed in this ANOPR. Fluorescent lamps
having a ``cooler'' CCT (e.g., >5,000K) are growing in popularity in
the market, perhaps because they have been found to allow for better
color discrimination and improved visual performance.\25\
---------------------------------------------------------------------------
\24\ A ``lumen'' is a measurement of the radiometric energy
emission from a light source weighted by the response function of a
human eye, referred to as the ``photopic spectral luminous
efficiency function'' (V([lgr])).
\25\ ``Full Spectrum Q&A,'' National Lighting Product
Information Program, Vol. 7 Issue 5 (March 2005). Available at:
http://www.lrc.rpi.edu/programs/nlpip/lightingAnswers/fullSpectrum/claims.asp.
---------------------------------------------------------------------------
GE and Osram both requested that DOE establish separate product
classes for T8 lamps with CCT above and below 4,500K. (GE, No. 13 at
pp. 1-2; Osram, No. 15 at p. 1 and p. 3) Osram commented that higher
CCT lamps have a lower lumen output because lamps with higher CCT
contain more blue light, which causes the lumen measurement to be
lower. Osram argued that it is important for DOE to differentiate
certain fluorescent lamps by CCT in the analysis to account for this
difference in performance. (Osram, No. 15 at p. 1) GE also stated that
should DOE decide to regulate lamps with high CCT values (e.g.,
5,000K), then these types of lamps would require a different and lower
lumen-per-watt threshold, because of the slightly lower lumen rating
due to the increased energy in the blue part of the light emission
spectrum. (GE, No. 13 at p. 1) Philips commented that if DOE decides to
adopt efficacy levels higher than those proposed by Philips, then DOE
should place higher CCT lamps in a separate product class because they
tend to have slightly lower efficacies. (Philips, No. 11 at p. 2)
In response, DOE believes that for fluorescent lamps, the
differences in CCT of the light emission can be sufficiently large that
they constitute a performance-related feature that affects the efficacy
of the lamp. Therefore, DOE is planning to establish separate product
classes for GSFL in part based upon CCT. Related to this preliminary
decision are two critical, associated issues--(1) How many groups
should be established? and (2) Where should the separator(s) between
product classes be set? DOE's initial thoughts on this matter are set
forth below.
Presently, EPCA does not cover colored fluorescent lamps (i.e.,
such lamps are excluded under 42 U.S.C. 6291(30)(B)(iii)) and these
lamps are defined, in part by their CCT (both terms defined at 10 CFR
430.2). Lamps with a CCT less than 2,500K or greater than 6,600K are
considered ``colored fluorescent lamps'' and are not subject to the
minimum efficacy standards (note: See discussion in this section
pertaining to a potential revision to coverage of colored fluorescent
lamps). DOE is considering dividing GSFL, (with CCTs ranging from
2,500K to 6,000K) into two product classes. DOE believes that
establishing two groups does not make the product classification overly
complex, and yet such approach acknowledges the primary issue raised
about the different utility provided by the cooler lamps. To this end,
DOE is considering adoption of a CCT divider at 4,500K, as recommended
by industry. (Osram, No. 15 at p. 1, GE, No. 13 at p. 2) The most
common CCTs found on the market are 3,500K, 4,100K, 5,000K, and 6,500K.
Thus, having a divider at 4,500K will establish separate product
classes for those lamps with ``warmer'' CCTs (3,500K and 4,100K) and
``cooler'' CCTs (5,000 and 6,500K). Although in this proceeding, DOE is
considering establishing two separate CCT groups for GSFL, if the trend
toward much higher CCT lamps continues (discussed in section II.B.3),
then DOE may need to establish multiple CCT groups, as the spectral
emission (and thus, efficacy) of these general service lamps will vary
as the CCT increases.
DOE is requesting comment on all aspects of this potential CCT
division, but particularly: (1) Whether there should be a CCT product
class divider; (2) how many groupings of CCT are appropriate; and (3)
what the CCT divider or dividers should be. In addition, DOE welcomes
technical perspectives on how DOE might scale the efficacy level from
the representative unit of analysis of 4,100K to higher CCT product
classes. In addition, DOE also notes that if comments indicate that the
definition of a colored fluorescent lamp warrants some revision such
that certain very high CCT lamps would be covered (e.g., over 17,000K),
then perhaps it would be appropriate to consider several CCT groupings
(which would manifest themselves as minimum efficacy steps). DOE
requests further comment on this issue, including technical
perspectives.
ii. Other Potential Class-Setting Factors Considered, But Not Adopted
As stated above, DOE did not choose to establish product classes
based upon any of the following four factors: (1) Ballast
interoperability; (2) lamp wattage; (3) lamp diameter (i.e., T8 vs.
T12); and (4) color rendering index (CRI). Each of these factors is
discussed below, along with DOE's rationale for not further considering
them for class-setting purposes.
Ballast Interoperability. DOE did not consider interoperability of
lamps on the same ballast system as a differentiating factor for
product classes. DOE acknowledges that there is a difference between
lamps and lamp-and-ballast systems, and that certain lamps may have the
same form factor but may not operate on the same ballast. However, DOE
treats these constraints as an economic issue in its LCC analysis,
rather than a utility issue. In other words, in the LCC analysis, DOE
considered a T8 lamp as a more-efficacious replacement for a T12
baseline lamp. In its economic analysis, DOE accounts for the need to
install a new ballast to operate the T8 lamp by including the installed
cost of a new lamp and ballast for the T8 replacement. This
consideration of T8 lamps as substitutes for T12 lamps is consistent
with DOE's understanding of the market, and with manufacturers'
marketing literature. Had DOE elected to differentiate these lamps on
ballast interoperability, or indeed, lamp diameter, this direct
comparison may not have been made. DOE believes this
[[Page 13638]]
approach is appropriate for this rulemaking, because there is no unique
functionality or service rendered by, for example, one T8 lamp and an
equivalent T12 lamp.
Lamp Wattage. With respect to lamp wattage, DOE observed in the
product literature published by manufacturers that lower-wattage lamps
are marketed and promoted as energy-saving versions of the more popular
wattages. For example, lamps with 25W, 28W, and 30W are marketed as
energy-efficient alternatives to the 32W T8. For this reason, DOE does
not believe it is appropriate to establish divisions based upon wattage
within the product classes, because wattage does not have utility in
and of itself, but rather is a measure of energy use. For example, if a
30W T8 lamp can deliver the same (or very similar) performance as a 32W
T8, then there is no reason to establish an arbitrary wattage divide at
31W, forcing these two lamps into separate product classes. If two
product classes were set, the 30W T8 lamp could not be considered as an
efficient alternative for the 32W T8 lamp, which conflicts with how
these lamps are treated by the market. DOE understands that these
reduced-wattage lamps are marketed and used by consumers as energy-
efficient substitutes, and therefore, should be considered as such when
DOE establishes product classes for these lamp types. Therefore, DOE
plans to consider eliminating wattage-based dividers, because this
attribute by itself does not provide utility. Fluorescent lamps of
different wattages are generally capable of being substituted for each
other, and provide the same or similar service. DOE also believes that
a product classification system that eliminates wattage dividers would
be more representative of how these lamps are currently being installed
and used in the market.
Lamp Diameter. With respect to lamp diameter, DOE had expressed in
the Framework Document its intention to consider lamps with diameters
of T8 and smaller in one product class and lamps with diameters greater
than T8 in a separate product class. On further consideration, DOE has
tentatively decided that the lamp diameter does not provide unique
utility to end-users. As an example, a consumer can choose to use a 4-
foot medium bipin lamp and be able to obtain similar lumen packages
from either a T12 or T8 model. The T8 lamp may need to be operated on a
different ballast with a higher ballast factor (BF), but the system can
be modified to account for the differences in lamp diameter, so the
resultant systems are approximately equivalent. DOE recognizes that the
diameter of the lamp will impact the efficacy, but the utility provided
to the end-user is comparable and/or equivalent. Therefore, DOE has
tentatively decided not to separate product classes by lamp diameter.
However, recognizing that both T12 and T8 lamps operate on
different ballasts and in order to consider separately the impact of
standards on consumers of both types of lamps, DOE structured the
analytical tools (including the LCC and NIA spreadsheets) so that each
consumer subgroup could be analyzed separately. Thus, for example, the
LCC results are reported separately for T8 and T12 baseline lamps.
Color Rendering Index. The Color Rendering Index (CRI) is the
ability of a light source to produce color in objects. The CRI is
expressed on a scale from 0-100, where 100 is the best in producing
vibrant color in objects. Relatively speaking, a source with a CRI of
80 will produce more vibrant color in the same object than a source
with a CRI of 60. Generally, fluorescent lamps with higher efficiency
phosphors exhibit both a higher efficacy and higher CRI, although this
is not always the case. EPCA establishes an upper and lower bound on
the CRI of GSFL. Specifically, EPCA states that lamps with a CRI equal
to or greater than 87 are excluded from coverage. (42 U.S.C.
6291(30)(B)(viii)) EPCA also establishes two minimum CRI requirements
for each of the four groups of fluorescent lamps, one at 69 CRI and one
at 45 CRI. Within one group of fluorescent lamps (e.g., 4-foot medium
bipin), EPCA requires that lamps nominally rated at greater than 35W
have a minimum CRI of 69 and that lamps nominally rated at 35W or lower
have a minimum CRI of 45. (42 U.S.C. 6295(i)(1)(B); see 10 CFR
430.32(n)(1))
Several manufacturers suggested that DOE should make changes to the
minimum CRI required for GSFL. (Philips, No. 11 at p. 1; GE, No. 13 at
p. 2; Osram, No. 15 at p. 3) These manufacturers recommended that the
T8 lamp diameter product classes should have minimum CRI values of 75.
Philips also recommended that DOE should adopt minimum CRI values of 75
or greater for all fluorescent lamp product classes, given today's
technology. (Philips, No. 11 at p. 1)
DOE considered these comments, but believes it lacks the authority
to accommodate this request to adjust minimum CRI values in this way.
While 75 CRI may be a reasonable level for fluorescent lamps, DOE's
mandate from Congress is to focus on advancing energy efficiency and
energy conservation in the marketplace. DOE does not set standards by
regulating specific performance attributes of products, such as the CRI
rating of a lamp. Furthermore, if DOE were to simply adopt the higher
CRI level, it might be eliminating lamps from the market without
conducting a rulemaking analysis to determine whether this action was
cost-justified or not. For all of these reasons, DOE is not increasing
the minimum CRI requirement to 75, but is inviting further comment and
rationale on possible approaches to handling the issue of CRI.
DOE recognizes that in removing the wattage distinctions for GSFL
product classes, the metric that differentiated by CRI is no longer
present. Therefore, some possible solutions would be to: (1) Eliminate
the CRI minimum requirement for all regulated fluorescent lamps; (2)
adopt the lower of the two CRI minimum requirements (i.e., 45 CRI) as
applying to all regulated fluorescent lamps; (3) adopt the higher of
the two CRI requirements (i.e., 69 CRI) as applying to all regulated
fluorescent lamps; (4) adopt the CRI of the representative lamp that is
determined to be cost-justified as the minimum CRI for that product
class; and (5) maintain the CRI requirements in EPCA for the product
classes established by EPACT 1992 while setting efficacy standards for
the product classes established in this notice.
DOE recognizes that each of these approaches for addressing the CRI
minimum requirement has its own advantages and disadvantages. The first
option, eliminating the CRI requirement, risks the potential for a
back-sliding in performance. That said, for the products offered in the
market today, the CRI generally increases with the efficacy levels
considered in this rulemaking. Thus, the CRI values of future
standards-compliant lamps would naturally be higher than the two
existing minimum requirements. The second option suggests that DOE
simply apply the minimum 45 CRI requirement to all fluorescent lamps.
This approach would not eliminate any lamps now covered between 45 and
69 CRI, however as with the first option, carries a certain risk that
there may be some backsliding for lamps that previously required to
meet would have had to have been 69 CRI, but which now could be as low
as 45 CRI.
The third option, to simply require all lamps to have a minimum of
69 CRI, would eliminate certain lamps that are presently manufactured
between 45 and 69 CRI. DOE notes that through this
[[Page 13639]]
energy conservation standards rulemaking, it may be increasing the
efficacy requirements on those lamps anyway, which may have the effect
of preventing further use of those phosphors that supply light with a
45 to 69 CRI performance. However, to simply change the CRI requirement
without analysis, and thereby eliminate product, appears to be in
conflict with DOE's authority under EPCA. The fourth option identified
above concerns DOE simply adopting the CRI requirement of the cost-
justified lamp considered in the rulemaking analysis. That is to say,
if DOE determines that a particular lamp with a certain efficacy is the
cost-justified level at which it will set the mandatory standard for
that product class, DOE would also adopt the CRI of that lamp as the
minimum CRI requirement for all lamps in that product class. Finally,
the fifth option maintains the current minimum requirements in EPCA for
the product classes established in EPACT 1992 while setting efficacy
requirements for the additional product classes established in this
notice. Because this option requires no change in the CRI requirement
for fluorescent lamps, there is no risk of eliminating product from the
marketplace nor does it allow for backsliding in performance.
DOE requests comment on these five alternative approaches or others
that would address the issue of the minimum CRI requirement for
fluorescent lamps.
iii. Product Class Results
For the reasons discussed above, DOE has tentatively decided to
consider the following product classes for GSFL (see Table III.2).
These draft product classes are more aggregated than those originally
presented in the Framework Document. For each of the eight product
classes, DOE anticipates that it would develop a point efficacy value
(lumens per watt), which would apply to all the lamps covered within
each class.
Table III.2.--DOE ANOPR Product Classes for GSFL
----------------------------------------------------------------------------------------------------------------
For CCT <= 4,500K, For CCT > 4,500K, minimum lamp efficacy lm/
Lamp type minimum lamp efficacy lm/W W
----------------------------------------------------------------------------------------------------------------
4-foot medium bipin.................... Product Class 1.. Product Class 5.
2-foot U-shaped........................ Product Class 2.. Product Class 6.
8-foot single pin slimline............. Product Class 3.. Product Class 7.
8-foot recessed double contact HO...... Product Class 4.. Product Class 8.
----------------------------------------------------------------------------------------------------------------
b. Incandescent Reflector Lamps
EPCA established minimum efficacy requirements by wattage for IRL,
as presented in Table III.3. (42 U.S.C. 6295(i)(1)(B))
Table III.3.--EPCA Product Classes and Efficacy Requirements for IRL
------------------------------------------------------------------------
Min. average
Wattage W efficacy lm/W
------------------------------------------------------------------------
40-50................................................... 10.5
51-66................................................... 11.0
67-85................................................... 12.5
86-115.................................................. 14.0
116-155................................................. 14.5
156-205................................................. 15.0
------------------------------------------------------------------------
In its Framework Document, DOE stated its preliminary intention to
keep the same six product classes. DOE requested comment on this
approach, including whether any modifications to the six product
classes was warranted.
Several stakeholders commented that these potential product classes
for IRL seemed reasonable and appropriate for this rulemaking. (NEMA,
No. 4.5 at p. 75; ACEEE, No. 4.5 at p. 75; PG&E, No. 4.5 at p. 75; EEI,
No. 4.5 at p. 76; NEMA, No. 8 at p. 2; Joint Comment, No. 9 at p. 5)
DOE's additional research, however, has identified a problem with the
potential product classes presented in the Framework Document,
particularly as DOE considered standard levels with higher efficacy
values. The existing wattage groups are problematic because the wattage
rating of the lamp is a property about the lamp that the regulation is
working to reduce, and yet it is also being used as the basis of
classification. This issue is further complicated by the fact that some
consumers (particularly in the residential sector) think of and
purchase IRL based on the rated wattage, which is associated with an
expected level of light output. The following discussion outlines DOE
analyses in determining preliminary product classes for incandescent
reflector lamps and the rationale therefore.
i. Class Setting Factors
Modified-Spectrum. As discussed in section I.E.2, EISA 2007 adopted
a new definition for ``colored incandescent lamp'' \26\ which
supersedes DOE's definition previously incorporated at 10 CFR
430.2.\27\ This new statutory definition effectively increases the
scope of energy conservation standards coverage of IRL to include any
IRL that has a lens containing five percent or more neodymium oxide or
is a plant light lamp. As both of these types of IRL filter out
portions of the emitted spectrum of the lamp, DOE believes that many of
these lamps would fall under the definition of ``modified spectrum''
which was also adopted by the new energy legislation. The EISA 2007
definition of ``modified spectrum'' reads as follows:
---------------------------------------------------------------------------
\26\ EISA 2007's definition of ``colored incandescent lamp''
reads as follows: ``The term `colored incandescent lamp' means an
incandescent lamp designated and marketed as a colored lamp that
has--(i) a color rendering index of less than 50, as determined
according to the test method given in CIE publication 13.3-1995; or
(ii) a correlated color temperature of less than 2,500K or greater
than 4,600K, where correlated temperature is computed according to
the Journal of Optical Society of America, Vol. 58, pages 1528-1595
(1986).''
\27\ The definition of ``colored incandescent lamp'' adopted by
the 1997 Lamps Test Procedure Final Rule 62 FR 29221, 29228 (May 29,
1997) reads as follows: ``Colored incandescent lamp means an
incandescent lamp designated and marketed as a colored lamp that has
a CRI less than 50, as determined according to the method given in
CIE Publication 13.2 (see 10 CFR 430.22); has a correlated color
temperature less than 2,500K or greater than 4,600K; has a lens
containing 5 percent or more neodymium oxide; or contains a filter
to suppress yellow and green portions of the spectrum and is
specifically designed, designated and marketed as a plant light.''
---------------------------------------------------------------------------
``The term `modified spectrum' means, with respect to an
incandescent lamp, an incandescent lamp that--
(i) Is not a colored incandescent lamp; and
(ii) When operated at the rated voltage and wattage of the
incandescent lamp--
I. Has a color point with (x,y) chromaticity coordinates on the
Commission Internationale de l'Eclairage (C.I.E.) 1931 chromaticity
diagram that lies below the black-body locus; and
II. has a color point (x,y) chromaticity coordinates on the C.I.E.
1931 chromaticity diagram that lies at least 4
[[Page 13640]]
MacAdam steps (as referenced in IESNA LM16) distant from the color
point of a clear lamp with the same filament and bulb shape, operated
at the same rated voltage and wattage.'' (42 U.S.C. 6291(30)(W))
Modified-spectrum lamps provide unique utility to consumers, in
that they offer a different spectrum of light from the typical
incandescent lamp, much like two fluorescent lamps with different CCT
values. These lamps offer the same benefits as fluorescent lamps with
``cooler'' CCTs in that they may ensure better color discrimination and
improved visual performance.\28\ In addition to providing a unique
utility, DOE also understands that the technologies that modify the
spectral emission from these lamps also decrease their efficacy (i.e.,
the ability of the lamp to convert watts of energy into lumens of
visible light). This is because a portion of the light emission is
absorbed by the coating. Neodymium coatings or other coatings on
modified-spectrum lamps absorb some of the visible emission from the
incandescent filament (usually red), creating a modified, reduced
spectral emission. Since the neodymium or other coatings absorb some of
the lumen output from the filament, these coatings decrease the
efficacy of the lamp.
---------------------------------------------------------------------------
\28\ ``Full Spectrum Q&A,'' National Lighting Product
Information Program, Vol. 7 Issue 5 (March 2005). Available at:
http://www.lrc.rpi.edu/programs/nlpip/lightingAnswers/fullSpectrum/claims.asp.
---------------------------------------------------------------------------
DOE is concerned that, given the newly-adopted definition of
``colored incandescent lamp,'' if DOE were to subject modified-spectrum
IRL to the same standard as standard-spectrum IRL, then these IRL with
modified-spectrum glass or coatings may not be able to achieve the
mandatory standard, which could in turn lead to this type of product
being lost from the market. Therefore, consistent with EISA 2007's
approach on general service incandescent lamp standards, DOE is
planning to establish separate product classes for regular IRL (i.e.,
those without modification to the spectral emission) and modified-
spectrum IRL (i.e., ones which have some portion of the spectral
emission absorbed). However, to ensure that a suitable standard level
is set for these lamps (such that they are neither disadvantaged nor
advantaged compared to standard-spectrum lamps), DOE plans to establish
an appropriately scaled efficacy requirement for them, based on DOE's
analysis of standard-spectrum IRL and then adjusted to account for the
portions of the spectrum that are absorbed by the neodymium or
spectrally-enhancing coating. DOE discusses how this scaling would be
accomplished in the Engineering Analysis (see section III.C.6).
ii. Other Potential Class-Setting Factors Considered, but Not Adopted
Wattage. As DOE started to structure the analytical framework for
the IRL analysis, DOE increasingly found that the initial approach of
six wattage groups for product classes was not reasonable. Particularly
as more-efficacious IRL with equivalent light output were considered,
the approach presented in the Framework Document would have resulted in
these replacement lamps being placed in a separate product class, and
as such, would no longer be considered a ``replacement.'' For example,
consider a 75W reflector lamp at 14.0 lm/W and an equivalent, more-
efficacious replacement at 60W at 17.5 lm/W. These two lamps are
essentially equivalent products, with equal levels of light output,
operating lives, and customer utility (e.g., both operate in the same
socket). However, under the Framework Document's approach for potential
IRL product classes, these lamps would appear in different product
classes. (42 U.S.C. 6295(i)(1)(B); see 10 CFR 430.32(n)(2)) Thus, DOE
realized that wattage is not a suitable product class divider because
it does not provide a unique utility; instead, it merely provides a
measure of power consumption.
On further examination and consideration of the standard
established by EPCA for reflector lamps, DOE is now interpreting the
wattage groups in the existing standard as equivalent to a mathematical
step-function equation that applies to all regulated IRL. DOE believes
EPCA, in effect, establishes different minimum average lamp efficacies
at each ``step'' or range of wattages for a single product class, which
encompasses all IRL. This function recognizes that IRL incorporating
the same technological feature, like a halogen capsule, are less
efficacious at lower wattages than higher wattages. Therefore, lamps at
lower wattages are subject to a lower standard than lamps at higher
wattages even though lamps at all wattages are in the same product
class.
As DOE considers more-efficacious substitute lamps in the analysis
for this rulemaking, it must decrease the nominal lamp wattage range in
order to keep the light output of the substitute lamps to within ten
percent of the light output of the baseline lamp. Thus, as DOE presents
the CSLs for the ANOPR, DOE plans to use a mathematical function that
would establish the efficacy requirement at any wattage. Like the step
function in EPCA, this mathematical function accounts for the fact that
lamps at lower wattages are inherently less efficacious than lamps at
higher wattages. See TSD Chapter 5 for a detailed discussion on the
development of the CSLs for IRL.
Spot Versus Flood Incandescent Reflector Lamps. With respect to the
issue of spot versus flood reflector lamps, several stakeholders
commented that they did not believe DOE should establish separate
product classes on this basis. (NEMA, No. 4.5 at p. 75; ACEEE, No. 4.5
at p. 75; PG&E, No. 4.5 at p. 75; EEI, No. 4.5 at p. 76; NEMA, No. 8 at
p. 2) DOE considered these comments and reviewed technical reports on
the performance of spot versus flood reflector lamps. Based upon this
information, DOE has tentatively concluded that while there might be a
differentiating utility afforded to consumers through the light
distribution patterns of a spot reflector lamp versus a flood reflector
lamp, that differentiating utility would not be expected to impact the
efficacy of the lamp. Thus, DOE does not plan on creating separate
product classes for spot and flood reflector lamps.
iii. Product Class Results
In sum, as discussed previously, DOE is considering all wattages of
reflector lamps to be part of the same product class, with the standard
level for any given lamp being a function of lamp wattage. As DOE
considers more-efficacious replacement lamps, the rated wattages must
decrease in order to maintain consistent levels of light output (i.e.,
within ten percent of the baseline lamp). Additionally, DOE is planning
to consider efficacy standards for full-spectrum IRL separately from
modified-spectrum IRL. Table III.4 summarizes the two product classes
DOE is considering for the ANOPR. (For ease of commenting on IRL
product classes, DOE has continued the product class numbering from
where the GSFL classes left off.)
[[Page 13641]]
Table III.4.--DOE ANOPR Product Classes for IRL
----------------------------------------------------------------------------------------------------------------
Standard-spectrum minimum Modified-spectrum minimum lamp efficacy lm/
Lamp type lamp efficacy lm/W W
----------------------------------------------------------------------------------------------------------------
Incandescent Reflector Lamps........... Product Class 9.. Product Class 10.
----------------------------------------------------------------------------------------------------------------
3. Technology Assessment
In the technology assessment, DOE identifies technology options
that appear to be feasible means of improving product efficacy. This
assessment provides the technical background and structure on which DOE
bases its screening and engineering analyses. The following discussion
provides an overview of the salient aspects of the technology
assessment, including issues on which DOE seeks public comment. For a
more complete discussion, Chapter 3 of the TSD provides detailed
descriptions of the basic construction and operation of GSFL and IRL,
followed by a discussion of technology options to improve the efficacy
of that lamp type.
a. General Service Fluorescent Lamps
Table III.5 lists the technology options that DOE has identified
for improving the efficacy of GSFL. Table III.5 also provides TSD
citations to each of the options listed, in order to enable the public
to learn more about what is encompassed under each of the options.
Table III.5.--General Service Fluorescent Lamp Technology Options
------------------------------------------------------------------------
Name of technology option Description TSD reference
------------------------------------------------------------------------
Highly Emissive Electrode Improved electrode Chapter 3, Section
Coatings. coatings to 3.3.1.1.
increase electron
emission.
Higher Efficiency Lamp Fill Gas Fill gas Chapter 3, Section
Composition. compositions to 3.3.1.2.
improve cathode
thermionic
emission or
increase mobility
of ions and
electrons in the
lamp plasma.
Higher Efficiency Phosphors..... Techniques to Chapter 3, Section
increase the 3.3.1.3.
conversion of
ultraviolet light
into visible
light.
Glass Coatings.................. Coatings that Chapter 3, Section
enable the 3.3.1.4.
phosphors to
absorb more UV
energy, so that
they emit more
visible light.
Higher Efficiency Lamp Diameter. Vary the lamp Chapter 3, Section
diameter to 3.3.1.5.
improve its
efficacy.
Multi-Photon Phosphors.......... Emitting more than Chapter 3, Section
one visible 3.3.1.6.
photon for each
incident UV
photon.
------------------------------------------------------------------------
Philips commented that some lamps use an extra thick layer of
expensive phosphors to improve efficacy. However, Philips commented
that the global supply of these high-quality phosphors is unknown, and
there may be some issues associated with higher manufacturing cost if a
standard level were set such that it required the use of this
technology. (Philips, No. 11 at p. 2) DOE will keep this comment in
mind during the manufacturer impact analysis interviews it will conduct
at the NOPR stage of this rulemaking.
b. Incandescent Reflector Lamps
Table III.6 lists the technology options DOE has identified to
improve the efficacy of IRL. Some of the technology options listed in
Table III.6 are incorporated into commercially-available products
today. For example, higher-temperature operation is utilized (usually
in conjunction with halogen lamps) to improve the efficacy of the
tungsten filament. Additionally, coiling of the tungsten filament is
currently practiced widely by lamp manufacturers to increase its
surface area, thereby improving filament efficacy.
Table III.6.--Incandescent Reflector Lamp Technology Options
------------------------------------------------------------------------
Name of technology option Description TSD reference
------------------------------------------------------------------------
Higher-Temperature Operation.... Operating the Chapter 3, Section
filament at 3.3.2.1.
higher
temperatures, the
spectral output
shifts to lower
wavelengths,
increasing its
overlap with the
eye sensitivity
curve. This
measure may
shorten the
operating life of
the lamp.
Microcavity Filaments........... Texturing, surface Chapter 3, Section
perforations, 3.3.2.2.
microcavity holes
with material
fillings.
Novel Filament Materials........ More-efficacious Chapter 3, Section
filament alloys. 3.3.2.3.
Thinner Filaments............... Thinner filaments Chapter 3, Section
to increase 3.3.2.4.
operating
temperature. This
measure may
shorten the
operating life of
the lamp.
Efficient Filament Coiling...... Coiling of the Chapter 3, Section
filament to 3.3.2.5.
increase surface
area.
Crystallite Filament Coatings... Layers of micron Chapter 3, Section
or submicron 3.3.2.6.
crystallites
deposited on the
filament surface.
Efficient Filament Orientation.. Positioning the Chapter 3, Section
incandescent 3.3.2.7.
filament to
increase light
emission out of
the lamp.
Higher Efficiency Inert Fill Gas Filling lamps with Chapter 3, Section
alternative 3.3.2.8.
gases, such as
Krypton, to
improve efficacy
by reducing heat
conduction.
[[Page 13642]]
Luminescent Gas................. Gaseous fills that Chapter 3, Section
react with 3.3.2.9.
certain
wavelengths of
the filament
emission to
generate visible
light.
Tungsten-Halogen Lamps.......... Small diameter Chapter 3, Section
fused quartz 3.3.2.10.
envelope with a
halogen molecule
to re-deposit
tungsten on the
filament.
Commonly referred
to as a
``halogen'' lamp.
Higher Pressure Tungsten-Halogen Increased pressure Chapter 3, Section
Lamps. of the halogen 3.3.2.11.
capsule by
increasing the
density of
halogen elements.
Non-Tungsten Regenerative Cycles Novel filament Chapter 3, Section
materials that 3.3.2.12.
incorporate a
regenerative
cycle.
Infrared Glass Coatings......... Infrared coatings Chapter 3, Section
(both phosphor 3.3.2.13.
and thin-film) to
reflect some of
the radiant
energy back onto
the filament.
When used in
conjunction with
a halogen
capsule, this
technology option
is referred to as
a halogen
infrared
reflector (HIR)
lamp.
Integrally Ballasted Low Voltage The ballast Chapter 3, Section
Lamps. converts the 3.3.2.14.
operating voltage
of the lamp from
line voltage to a
lower voltage.
Higher Efficiency Reflector Alternative Chapter 3, Section
Coatings. internal coatings 3.3.2.15.
with higher
reflectivity.
Trihedral Corner Reflectors..... Individual corner Chapter 3, Section
reflectors in the 3.3.2.16.
cover glass that
reflect light
directly back in
the direction
from which it
came.
Efficient Filament Placement.... Positioning the Chapter 3, Section
filament to 3.3.2.17.
increase light
emission out of
the lamp.
------------------------------------------------------------------------
Additional detail on the technology assessment can be found in
Chapter 3 of the TSD.
In summary, DOE invites comments on all of the technology options
it considered for GSFL and IRL, including any omissions or revisions
necessary to have a more comprehensive technology assessment. In the
context of commenting on technology options, DOE also requests
information on the feasibility, performance improvement, and cost of
the technology options, as well as any recent developments in their
technical maturity.
B. Screening Analysis
The purpose of the screening analysis is to evaluate the technology
options identified as having the potential to improve the efficiency of
a product, to determine which options to consider further and which
options to screen out. DOE consults with industry, technical experts,
and other interested parties in developing a list of technology options
for consideration. Section III.A.3 discusses the lists of identified
technology options for the products being considered for coverage under
this rulemaking. DOE then applies the following set of screening
criteria to determine which design options are unsuitable for further
consideration in the rulemaking:
(1) Technological Feasibility. DOE will consider technologies
incorporated in commercial products or in working prototypes to be
technologically feasible.
(2) Practicability to Manufacture, Install, and Service. If mass
production and reliable installation and servicing of a technology in
commercial products could be achieved on the scale necessary to serve
the relevant market at the time the standard comes into effect, then
DOE will consider that technology practicable to manufacture, install,
and service.
(3) Adverse Impacts on Product Utility or Product Availability. If
DOE determines a technology would have significant adverse impact on
the utility of the product to significant subgroups of consumers, or
would result in the unavailability of any covered product type with
performance characteristics (including reliability), features, sizes,
capacities, and volumes that are substantially the same as products
generally available in the United States at the time, it will not
consider this technology further.
(4) Adverse Impacts on Health or Safety. If DOE determines that a
technology will have significant adverse impacts on health or safety,
it will not consider this technology further.
10 CFR part 430, Subpart C, Appendix A, (4)(a)(4) and (5)(b).
1. Technology Options Screened Out
Applying the four screening criteria discussed above to the
identified technology options for GSFL and IRL, DOE developed the list
of technology options shown in Table III.13 that will not be considered
further in this rulemaking analysis, because they do not meet one or
more of the aforementioned screening criteria. In the text following
Table III.13, DOE discusses each of these technology options and
provides the rationale for screening them out. Chapter 4 of the TSD
provides further information on the Screening Analysis.
Table III.7.--Summary of Technology Options Screened Out of DOE's
Analysis
------------------------------------------------------------------------
Screening criteria
Lamp category Technology option failed on
------------------------------------------------------------------------
GSFL............................ Multi-Photon Technological
Phosphors. feasibility;
Practicability to
manufacture,
install, and
service.
IRL............................. Microcavity Product utility to
Filaments. consumers;
Practicability to
manufacture,
install, and
service.
IRL............................. Novel Filament Practicability to
Materials. manufacture,
install, and
service; Product
utility to
consumers.
IRL............................. Crystallite Practicability to
Filament Coatings. manufacture,
install, and
service.
IRL............................. Luminescent Gas... Technological
feasibility.
[[Page 13643]]
IRL............................. Non-Tungsten- Practicability to
Halogen manufacture,
Regenerative install, and
Cycles. service; Product
utility to
consumers.
IRL............................. Infrared Phosphor Practicability to
Glass Coating. manufacture,
install, and
service.
IRL............................. Integrally Technological
Ballasted Low feasibility.
Voltage Lamps.
IRL............................. Trihedral Corner Practicability to
Reflectors. manufacture,
install, and
service.
------------------------------------------------------------------------
a. Multi-Photon Phosphors
For GSFL, DOE screened out the use of multi-photon phosphors, even
though they have the potential to significantly improve lamp efficacy.
By emitting more than one visible photon for each incident ultraviolet
photon, a lamp employing this technology would be able to emit more
light for the same amount of power. However, development of this
technology remains in the research phase, and DOE is unaware of any
prototypes or commercialized products that incorporate multi-photon
phosphors. Thus, DOE screened out this technology option based on the
first criterion, technological feasibility. Additionally, because this
technology is still in the research phase, DOE believes that it would
not be practicable, or even possible, to manufacture, install, and
service this technology on the scale necessary to serve the relevant
market at the time of the effective date of an amended standard. As
discussed below in section III.C, DOE based the GSFL engineering
analysis on commercially-available lamps, deriving efficacy values for
these lamps from manufacturer catalogs and specifications. Therefore,
DOE considered the technology options contained in Table III.5
implicitly as incorporated into commercially available lamps at the
efficacy levels it evaluated.
b. Microcavity Filaments
DOE also screened out several technologies that could potentially
improve the efficacy of IRL. First, DOE screened out the use of
microcavity filaments. Microcavity filaments increase an incandescent
lamp's efficacy by reducing the amount of energy converted to infrared
light emitted by the filament while increasing the amount of energy
converted to visible light. The TSD's market and technology assessment
(TSD Chapter 3) notes that Sandia National Laboratories researchers
examined microcavity resonance in a tungsten photonic lattice, and a
literature search revealed multiple patents referencing this
technology. Since research prototypes of microcavity filaments do
exist, DOE determined that this technology option is technologically
feasible. However, research indicates that materials patterned at the
submicron level may experience problems with stability. Because such
instability could negatively affect lamp function and life, DOE
believes that it is not yet practicable to implement this technology in
general service lamps. For this reason, DOE screened out this
technology option based on the third criterion, impacts on product
utility to consumers. Furthermore, DOE is unaware of any commercialized
lamps that incorporate microcavity filaments, so we are concerned that
mass-manufacturing techniques for this technology would be problematic.
For this reason, DOE does not believe that this technology would be
practicable to manufacture, install, and service. Therefore, DOE is not
considering filaments with microcavities as a design option for
improving the efficacy of IRL.
c. Novel Filament Materials
Second, DOE screened out the use of novel filament materials, such
as nitrides and carbides, that have the potential to improve lamp
efficacy by emitting more light in the visible spectrum at a given
temperature than traditional tungsten filaments. Because several
patents on such filaments exist, DOE believes that this technology
option is technologically feasible. However, DOE is unaware of any
lamps available today that use such filaments. Furthermore, DOE
understands that technological barriers, such as prohibitive
brittleness of the filament, limit implementation of this technology.
Finding a practical way to incorporate novel filament materials into
commercially-viable incandescent lamps would require further research,
as would making such lamps practical for general service applications.
Thus, DOE believes this option must be screened out due to its
potential negative impacts on consumer utility. Furthermore, DOE
believes that it would not be practicable to manufacture this
technology on the scale necessary to serve the relevant market at the
time of the effective date of an amended standard. Therefore, DOE is
not considering novel filament materials as a design option for
improving the efficacy of IRL.
d. Crystallite Filament Coatings
Third, DOE screened out crystallite filament coatings, which are
oxide-covered micron or sub-micron crystallites comprised of thorium,
tantalum, or niobium. These coatings can be used to increase the light
emissivity of an incandescent lamp's filament. Because several patents
on such filament coatings exist, DOE believes that this technology
option is technologically feasible. However, DOE was unable to locate
any data on the incorporation of crystallite filament coatings into
prototypes or commercially available products. Using crystallite
filament coatings in incandescent lamps may require additional
manufacturing techniques, such as chemical vapor deposition. DOE
understands that these techniques are not in use in the mass-production
of incandescent lamps. In addition, DOE believes that it would not be
practicable to manufacture this technology on the scale necessary to
serve the relevant market of incandescent lamps before the effective
date of an amended standard. Therefore, DOE is not considering
crystallite filament coatings as a design option for improving the
efficacy of IRL.
e. Luminescent Gases
Fourth, DOE screened out luminescent gases. These gases, placed
inside the envelope of an incandescent lamp, react with certain
wavelengths of the filament emission and generate visible light. DOE is
unaware of any existing commercially-available products or prototypes
of incandescent lamps incorporating luminescent gases. Accordingly, DOE
screened out luminescent gases based on the first criterion,
technological feasibility. Therefore, DOE is not considering
luminescent gas fills as a design option for improving the efficacy of
IRL.
f. Non-Tungsten-Halogen Regenerative Cycles
Fifth, DOE screened out non-tungsten-halogen regenerative cycles.
[[Page 13644]]
Regenerative cycles allow a filament to burn at a higher temperature
(and thus higher efficacy) than conventional incandescent lamps, while
maintaining a useful service life. Non-tungsten-halogen regenerative
cycles are regenerative cycles that do not employ the use of the
tungsten filament or halogen gas fill. DOE understands that
regenerative cycles other than tungsten-halogen may be possible for
other filament materials. However, as noted above, DOE screened out the
use of novel filament materials on the basis of the second and third
screening criteria. Due to the fact that use of the non-tungsten-
halogen regenerative cycles would depend on the incorporation of a non-
tungsten filament (already screened out), DOE is screening out such
cycles from consideration based on the same two criteria. DOE believes
that it would not be practicable, and maybe not even possible, to
manufacture novel filament materials lamps with associated regenerative
cycles on the scale necessary to serve the relevant market at the time
of the effective date of an amended standard. Also, the use of other
filament materials, and therefore their associated regenerative cycles,
may have an adverse impact on consumer utility. Therefore, DOE is not
considering non-tungsten-halogen regenerative cycles as a design option
for improving the efficacy of IRL.
g. Infrared Phosphor Glass Coatings
For IRL, DOE screened out infrared phosphor glass coatings. When
used as a coating on the bulb surface, infrared phosphors harvest the
emitted infrared energy and convert it to visible light, thereby
potentially increasing lamp efficacy. Because patents on such infrared
phosphor coatings exist, DOE determined that this technology option is
technologically feasible. However, DOE does not believe infrared
phosphor glass coatings would be practicable to manufacture because
making hundreds of millions of incandescent lamps annually with
infrared phosphor coatings would require significant changes to current
manufacturing processes and DOE has no data to indicate that such
manufacturing processes are feasible or could be made ready to serve
the relevant market at the time of the effective date of an amended
standard. Therefore, DOE is not considering infrared phosphor coatings
as a design option for improving the efficacy of IRL.
h. Integrally Ballasted Low Voltage Lamps
Incandescent filaments that are designed to operate at a lower
voltage are both shorter in length and thicker in cross-sectional area
than incandescent filaments designed to operate at a line voltage from
115 to 130V. Increasing the thickness of the filament can improve its
efficacy by allowing the lamp to be operated at higher temperatures.
Therefore, using an integral ballast allows one to increase the
efficacy of a lamp by operating its filament at a lower voltage (e.g.,
12 volts) than standard U.S. household line voltage (i.e., 120 volts).
Although this technology is commercially available in Europe \29\ and
elsewhere in the world where the standard household line voltage is
220-240 volts, DOE is unaware of any commercially-available products or
prototypes of this same technology option that operate on U.S.
household line voltage of 120 volts. Accordingly, DOE is screening out
integrally ballasted low voltage lamps based on the first criterion,
technological feasibility. Therefore, DOE is not considering integrally
ballasted low voltage lamps as a design option for improving the
efficacy of IRL.
---------------------------------------------------------------------------
\29\ Philips Electronics Press Release (2007). Available at:
http://www.lighting.philips.com/gl_en/news/press/product_innovations/archive_2007/press_new_masterclassic_lamp.php.
---------------------------------------------------------------------------
i. Trihedral Corner Reflectors
For IRL, DOE screened out trihedral corner reflectors, which could
be incorporated into the cover glass of IRL and have the potential to
increase lamp efficacy by redirecting infrared radiation back onto the
filament. Because patents on trihedral corner reflectors exist, DOE
determined that this technology option is technologically feasible.
However, manufacturer data have not provided any indication as to the
incorporation of this technology into prototypes or commercially-
available products. Using trihedral corner reflectors, which entail an
additional disc requiring external fabrication and installation in the
lamp, is likely to necessitate manufacturing techniques not currently
available for mass production. For this reason, DOE believes that it
would not be practicable to implement this technology on the scale
necessary to serve the relevant IRL market at the time of the effective
date of an amended standard. Therefore, DOE is not considering
trihedral corner reflectors as a design option for improving the
efficacy of IRL.
2. Design Options Considered Further in Analysis
After screening out technologies in accordance with the policies
set forth in 10 CFR part 430, Subpart C, Appendix A, (4)(a)(4) and
5(b), DOE is considering the technologies, or ``design options,''
listed in the table below as viable means of improving the efficacy of
lamps covered under this ANOPR. The market and technology assessment
(TSD Chapter 3) provides a detailed description of these design
options.
Table III.8.--GSFL and IRL Design Options
----------------------------------------------------------------------------------------------------------------
GSFL design options IRL design options
----------------------------------------------------------------------------------------------------------------
Highly Emissive Electrode Coatings....... Higher-Temperature Operation.
Higher Efficiency Lamp Fill Gas Thinner Filaments.
Composition.
Higher Efficiency Phosphors.............. Efficient Filament Coiling.
Glass Coatings........................... Efficient Filament Orientation.
Higher Efficiency Lamp Diameter.......... Higher Efficiency Inert Fill Gas.
Tungsten-Halogen Lamps.
Higher Pressure Tungsten-Halogen Lamps.
Infrared Glass Coatings (thin-film).
Higher Efficiency Reflector Coatings.
Efficient Filament Placement.
----------------------------------------------------------------------------------------------------------------
The above listed ``design options'' will be considered by DOE in
the engineering analysis. As discussed in section III.C, to the
greatest extent possible, DOE based its engineering analysis on
commercially-available products, which incorporate one or more of the
design options listed above. In this way, DOE is better able to apply
[[Page 13645]]
these features of more-efficacious lamps in a manner consistent with
real world application. To this end, DOE has used catalog data,
including price and performance information, where available.
DOE invited comment on DOE's selection of these design options.
Previously, manufacturers have expressed some concern about certain
technologies impacting the manufacturing of high-volume IRL. DOE
understands that infrared reflective coatings require time to deposit
on the capsules/lamps. While lamps with this technology option are
commercially available today in small production runs, DOE is
requesting comment on whether these technologies could be applied in
the volumes necessary to meet the market demand for IRL in the three-
year compliance period mandated under the law authorizing DOE to
conduct this rulemaking. In particular, DOE requests comment on whether
this technology (or other technology options listed above) indeed meet
DOE's screening criterion related to whether a technology can be ``mass
manufactured.''
For more detail on how DOE developed the technology options and on
the process DOE used to screen these options, refer to Chapter 3 and
Chapter 4 of the TSD.
C. Engineering Analysis
The engineering analysis identifies, for each product class,
potential increasing efficiency levels above the level of the baseline
model. As key inputs in this process, the engineering analysis
considers technologies not eliminated in the screening analysis. DOE
considers these technologies either explicitly as design options or
implicitly as incorporated into commercially-available lamps at the
efficiency levels evaluated. For more information on the technologies
used in commercially-available lamps, refer to Chapter 5 of the TSD.
In the engineering analysis for this rulemaking, DOE concentrated
its efforts on developing product efficacy levels associated with
``lamps designs,'' based upon commercially-available lamps that
incorporate a range of design options. ``Design options'' consist of
discrete technologies (e.g., infrared reflective coatings). However,
where necessary, DOE supplemented commercially-available product
information with an examination of the incremental costs and improved
performance of discrete technologies. In this way, DOE's standards
development analyses can appropriately assess the technologies
identified as candidates for improving lamp efficacy.
In energy conservation standard rulemakings for other products, DOE
often develops cost-efficiency relationships in the engineering
analysis. However, for this lamps rulemaking, DOE derived efficacy
levels in the engineering analysis and end-user prices in the product
price determination. By combining the results of the engineering
analysis and the product price determination, DOE derived typical
inputs for use in the LCC and NIA. Section III.E of this notice
discusses the product price determination (see TSD Chapter 7 for
further detail).
1. Approach
To the extent possible, DOE based the analysis on commercially-
available lamps that incorporate the design options identified by the
Technology Assessment and Screening Analysis. For GSFL, all lamp-and-
ballast designs are commercially available and have publicly available
performance and price information. The majority of the engineering
analysis for IRL is also based on commercially-available lamps.
However, where needed, DOE supplemented these lamps with additional
model lamps which use commercially-available technologies so that a
substitute lamp at each CSL was available for each baseline lamp. For
both GSFL and IRL, instead of using manufacturer cost data, DOE elected
to follow suggestions to derive price information using observed market
prices for existing products. For more information on the rationale for
this approach, refer to section III.E of this notice.
The engineering analysis follows on the same general approach for
both categories of lamps analyzed in this rulemaking. The steps below
more fully describe this approach:
Step 1: Select Representative Product Classes. DOE reviewed covered
lamps and their associated product classes. DOE identified and selected
certain product classes as ``representative'' product classes where DOE
would concentrate its analytical effort. DOE chose these representative
product classes primarily because of their high market volumes. Section
III.C.2 of this notice provides detail on the representative product
classes selected for the analysis. Section III.C.6 of this notice
provides detail on how DOE extrapolates from the representative product
class to other product classes.
Step 2: Select Baseline Lamps. DOE selected baseline lamps from the
representative product classes on which it conducted the engineering
analysis (and subsequent analyses). These baseline lamps were selected
to represent the characteristics of typical lamps in a given product
class. Generally, a baseline lamp is one that just meets existing
mandatory energy conservation standards or one that represents the
typical lamp sold. Specific characteristics such as CCT, operating
life, and light output were all selected to characterize the most
common lamps purchased by consumers today. For all the representative
product classes, DOE selected multiple baseline lamps, in order to
ensure consideration of different high-volume lamps and associated
consumer economics. Baseline lamps are discussed in section III.C.2 of
this notice.
Step 3: Identify Candidate Lamp or Lamp-and-Ballast Designs. DOE
selected a series of more-efficacious lamps for each of the baseline
lamps considered within each representative product class. DOE
considered technologies not eliminated in the screening analysis. DOE
considered these technologies either explicitly as design options or
implicitly as design options incorporated into commercially-available
lamps at the efficiency levels evaluated. In identifying more
efficacious lamp or lamp-and-ballast designs, DOE recognizes that the
lumen package and performance characteristics of a system are important
design criteria for consumers. For example, if consumers do not have
the option to purchase substitution lamps or lamp-and-ballast systems
with similar lumen packages under an energy conservations standard,
consumers would need to renovate the lighting design in a particular
building in order to maintain a similar light output. Therefore, lamp
and lamp-and-ballast designs for the LCC analysis were established such
that potential substitutions maintained light output above a maximum 10
percent decrease from the baseline lamp system's light output. In
addition, substitute lamps were chosen to have performance
characteristics (e.g., CCT) similar to those of the baseline lamp.
In identifying more-efficacious substitutes for GSFL, DOE utilized
a database of commercially-available lamps. For the LCC, DOE developed
the engineering analysis based on the two substitution scenarios where
a consumer can maintain light output while decreasing energy
consumption. In the first scenario, the consumer maintains light output
while decreasing energy by replacing the baseline lamp with a more
efficacious lower-wattage lamp that operates on the existing
[[Page 13646]]
ballast. In the second scenario, the consumer maintains light output
while decreasing energy consumption by replacing the lamp-and-ballast
system with a more efficacious lamp and a different ballast. For
example, a lamp-and-ballast system with a more efficacious same-wattage
lamp and lower ballast factor ballast will consume less energy and
maintain light output.
For IRL, DOE used some commercially-available lamps, but also
developed ``model'' lamps which incorporate design options that may not
be commercially available for certain lamp types and wattages but which
use commercially-available technologies. For example, DOE developed
efficacy estimates for reduced-wattage IRL with an improved halogen
infrared (HIR) coating. For the LCC, DOE considered only one
substitution scenario. In this scenario, consumers save energy and
maintain light output by replacing their lamp with a lower wattage more
efficacious lamp. For a more detailed discussion of lamp and ballast
designs, see section III.C.3 of this notice.
Step 4: Developed Candidate Standard Levels. Having identified the
more-efficacious substitutes for each of the baseline lamps (or lamp-
and-ballast systems), DOE developed CSLs based on a consideration of
several factors including: (1) The design options associated with the
specific lamps being studied (e.g., grades of phosphor for fluorescent
lamps, the use of infrared coatings for IRL); (2) the ability of lamps
across wattages to comply with the standard level of a given product
class; \30\ and (3) the maximum technologically-feasible level. For a
more detailed discussion of CSL development for each of the
representative product classes analyzed, see section III.C.4 of this
notice.
---------------------------------------------------------------------------
\30\ Efficacy levels span multiple lamps of different wattages.
In selecting CSLs, DOE considered whether these multiple lamps can
meet the efficacy levels.
---------------------------------------------------------------------------
A more detailed discussion of the methodology DOE followed to
perform the engineering analysis can be found in the engineering
analysis chapter of the TSD (Chapter 5).
2. Representative Product Classes and Baseline Lamps
As discussed in section III.A.2, DOE is considering establishing
eight product classes across the range of covered GSFL and two product
classes for covered IRL. Due to scheduling and resource constraints,
DOE was not able to analyze each and every product class. Instead DOE
carefully selected certain product classes that it would analyze, and
then scale its analytical findings on those representative product
classes to other product classes that were not analyzed. The
representative product classes are generally selected to encompass the
highest volume, most commonly sold lamp types.
Once DOE identifies the representative product classes for
analysis, DOE selects the representative units for analysis (i.e.,
baseline lamps) from within each product class. In the Framework
Document, DOE identified some preliminary ideas for representative
product classes and units for analysis. This section summarizes the
comments received on this topic and the related decisions DOE made in
conducting this portion of the ANOPR analysis.
ACEEE provided a cross-cutting comment about representative product
classes and units for analysis. ACEEE expressed concern that DOE may
over-simplify the analysis by analyzing lamps of a few wattages and
then generalizing to lamps of other wattages, in which case the results
may not scale well. (ACEEE, No. 4.5 at pp. 67 and 79-80) The Joint
Comment expressed this same concern, stating that analyzing too few
products risks oversimplifying the analysis and obtaining results that
cannot be extended to other products. Because such an approach could
result in the sacrifice of potential energy savings, the Joint
Commenters urged DOE to analyze multiple lamp wattages. (Joint Comment,
No. 9 at p. 2)
In response, DOE plans to establish eight product classes for GSFL.
For IRL, although DOE is considering only two product classes, DOE
defines CSLs with lamp efficacy requirements that vary by wattage to
prevent oversimplification of the analysis. In addition, for each
potential GSFL and IRL product class that is being analyzed, DOE is
analyzing more than one baseline lamp to reflect the range of
manufacturers' current lamp offerings. For example, for IRL, DOE
recognizes that an incandescent lamp with the same basic technology
exhibits higher efficacies at higher wattages. By analyzing multiple
products at several different wattages, DOE was able to define a CSL
that sets the same technology requirement for IRL, regardless of
wattage.
a. General Service Fluorescent Lamps
As discussed in section III.A.2, DOE has tentatively decided to
revise the table of product classes to reflect the utility of these
products and how they are used in the market. From this new set of
product classes, DOE generally selected as representative product
classes those that encompassed the majority of shipments and from which
efficacy values could be scaled.
DOE observed that 4-foot medium bipin lamps constitute the vast
majority of GSFL sales. These are followed in order of unit sales by 8-
foot single pin slimline lamps and 8-foot recessed double contact HO
lamps, which together constitute less than a quarter of GSFL sales.
Because 4-foot medium bipin, 8-foot single pin slimline, and 8-foot
recessed double contact HO lamps are the most common GSFL, DOE has
selected them as representative lamps for its analysis. Shipments of 2-
foot U-shaped lamps account for less than 5 percent of GSFL unit sales
historically.\31\ Given the relatively small market share of U-shaped
lamps, DOE did not explicitly analyze these lamps.
---------------------------------------------------------------------------
\31\ Source: NEMA, No. 12 at p. 7.
---------------------------------------------------------------------------
With regard to product class divisions by CCT, DOE recognizes that
lamps whose CCT is greater than 4,500K represent a small market share
of GSFL. Therefore, DOE has chosen to analyze lamps with CCT less than
or equal to 4,500K.
Although DOE is not analyzing the 2-foot U-shaped lamps or lamps
that have a CCT greater than 4,500K, DOE nevertheless plans to consider
standards for these product classes. DOE will extend its decision for
the 4-foot medium bipin product class to the 2-foot U-shaped product
class. This is possible because 2-foot U-shaped lamps generally are
operated in the same way and generally span the same wattages as 4-foot
medium bipin lamps. For lamps whose CCT is greater than 4,500K, DOE
will extrapolate its findings from the representative lamps it analyzed
that are less than or equal to 4,500K. For details on how DOE intends
to consider development of standards for product classes not analyzed,
see section III.C.6 of this notice.
Within the representative product classes for GSFL, DOE selected as
representative units for analysis those lamps with the highest volumes.
Although DOE reorganized the product classes from what it presented in
the Framework Document, the representative units selected for analysis
are generally consistent with the comments received regarding the
appropriate units for analysis. For example, several stakeholders
commented that DOE should select the cool white phosphor energy-saver
T12 as a baseline lamp. (NEMA, No. 8 at pp. 2-3; GE, No. 4.5 at pp. 63-
65 at pp. 70-71; Philips, No. 11 at p. 1; GE, No. 13 at pp. 2-4; Osram,
No. 15 at p. 3; GE, No. 4.5 at pp. 63-65). Osram commented that DOE
should also
[[Page 13647]]
consider a 700 series T8 as a baseline lamp. (Osram, No. 15 at p. 3).
In contrast, EEI and PG&E commented that the baseline lamps should be
selected in terms of when the standard will go into effect (six years
from now), and the cool white lamp may not be a good representative
baseline lamp at that time. (EEI, No. 4.5 at pp. 68-69, PG&E, No. 4.5
at p. 73). In addition, ACEEE commented that it may be better for DOE
to analyze both the energy-saver and non-energy-saver lamps as
baselines, and then later in the process DOE could decide whether one
should be removed from the analysis. (ACEEE, No. 4.5 at pp. 66-67).
After consideration of the public comments, DOE selected T8 and T12
baseline lamps for analysis. For T12 lamps, DOE selected both non-
energy-saver lamps (i.e., 40W T12 4-foot medium bipin GSFL) and energy-
saver versions (i.e., 34W T12 4-foot medium bipin GSFL), where they
were available, as baseline lamps. For non-energy-saver versions of T12
GSFL, DOE selected 700 series, non-cool-white T12 lamps. For energy-
saver versions of the T12 GSFL, DOE selected cool white models as
baseline lamps. For T8 lamps, DOE only selected the non-energy-saver
lamp (i.e., 32W T8 4-foot medium bipin GSFL) as a baseline lamp because
energy-saver versions are not prevalent in the marketplace. For the
baseline 32W T8 lamp, DOE used a rare-earth phosphor 700 series non-
energy-saving lamp as the baseline. In all cases, the phosphor
technology employed by each of these lamps is a direct reflection of
the most commonly sold lamp today. DOE also selected fluorescent lamps
with a CCT of 4,100K for all the analysis (i.e., baseline lamps and
standard-compliant replacement lamps). DOE selected this CCT value
because it is both the most popular CCT and because it falls
approximately in the middle of the range of typical GSFL, which span
from 3,000K to 6,500K.
Table III.9 presents the representative product classes and
baseline lamps that DOE has tentatively developed for GSFL.
Table III.9.--GSFL Representative Product Classes and Baseline Lamps
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline lamps
------------------------------------------------------------------------------------------------
Lamp type Representative Rated Initial
product class Descriptor Nominal CCT K efficacy* light Mean light Lifetime
wattage W lm/W output lm output lm hr
--------------------------------------------------------------------------------------------------------------------------------------------------------
4-foot medium bipin.............. CCT <=4,500K........ F40T12........... 40 4,100 80.0 3,200 2,880 20,000
F34T12........... 34 4,100 77.9 2,650 2,300 20,000
F32T8............ 32 4,100 86.2 2,800 2,520 20,000
8-foot single pin slimline....... CCT <=4,500K........ F96T12........... 75 4,100 85.6 6,420 5,906 12,000
F96T12........... 60 4,100 87.6 5,300 4,664 12,000
F96T8............ 59 4,100 94.8 5,700 5,130 15,000
8-foot recessed double contact HO CCT <=4,500K........ F96T12........... 110 4,100 80.1 9,050 8,145 12,000
F96T12........... 95 4,100 82.5 8,000 6,950 12,000
--------------------------------------------------------------------------------------------------------------------------------------------------------
*Rated efficacy is based on the rated wattage of the lamps and the initial lumen output. The rated wattage in order of baseline is 40W, 34W, 32.5W, 75W,
60.5W, 60.1W, 113W, and 97W.
As discussed in section III.C.3.a, DOE is taking a systems approach
to its analysis for GSFL. In accordance with this approach, DOE
selected typical ballasts to pair with the baseline lamps. DOE
generally paired a ``normal'' BF ballast (i.e., with a BF typically
between 0.84 and 1.0) with baseline lamp systems. These pairings are
intended to characterize the typical system used in the market. For
example, for installed T8, 4-foot medium bipin fluorescent systems, DOE
selected an instant start electronic ballast with a BF of 0.88. In
addition to ballast types, DOE also selected the number of lamps per
ballast that represent a typical system. DOE is aware that 4-foot
medium bipin ballasts are available in a variety of lamp-per-ballast
designs. According to the 2000 rule on GSFL ballasts (hereafter ``2000
Ballast Rule''), there are on average 2.8 lamps per 4-foot medium bipin
system. 62 FR 56740 (Sept. 19, 2000).\32\ To accurately represent the
market and to simplify the analysis, DOE has decided to use a 3-lamp
system for 4-foot medium bipin lamps. For 8-foot lamps, DOE selected 2-
lamp ballasts, representative of typical 8-foot systems in the market.
For further detail on the lamps and lamp-and-ballast systems DOE uses
in its analyses, see Chapters 5 and Appendix 5A of the TSD.
---------------------------------------------------------------------------
\32\ U.S. Department of Energy. Office of Energy Efficiency and
Renewable Energy, Energy Conservation Program for Consumer Products:
Technical Support Document: Energy Efficiency Standards for Consumer
Products: Fluorescent Lamp Ballast Proposed Rule. Appendix B.
Marginal Energy Prices and National Energy Savings. Table B.6. (Jan.
2000). Available at: http://www.eere.energy.gov/buildings/appliance_standards/residential/pdfs/appendix_b.pdf.
---------------------------------------------------------------------------
b. Incandescent Reflector Lamps
As discussed above, for the ANOPR, DOE decided to revise the table
of product classes to reflect the utility of these products and how
they are used in the market, including the creation of a product class
for modified-spectrum lamps. Because modified-spectrum lamps currently
make up only a small percentage of the market, DOE has selected the
standard-spectrum IRL product class for analysis and intends to
extrapolate its findings to the modified-spectrum product class.
Section III.C.6 provides detail on this extrapolation.
ACEEE commented that DOE should analyze each of the six IRL wattage
group product classes, rather than only two, as DOE presented in its
Framework Document. Otherwise, ACEEE argued that DOE would potentially
risk oversimplifying the analysis. (ACEEE, No. 4.5 at pp. 79-80) The
Joint Comment also asserted that DOE should examine each product class
for IRL since the appropriate substitute lamps in each of those classes
can vary. (Joint Comment, No. 9 at p. 2)
Given the revisions to the product class structure for IRL (i.e.,
that product classes are no longer defined by wattage), DOE now
recognizes that the discrete utility of IRL is based on the lumen
package, not the wattage rating. For this reason, the discrete IRL
representative wattage groups that were discussed in the Framework
Document,
[[Page 13648]]
and upon which DOE received comment, are being merged into one product
class. However, to prevent oversimplification of the analysis, DOE has
chosen to analyze three different lamps of multiple wattages (and lumen
packages) in the standard-spectrum product class. DOE has tentatively
decided to concentrate its resources on conducting analysis of the most
popular reflector lamps--in terms of lamp size, wattage, and lumen
package. Accordingly, DOE examined existing products on the market at
multiple wattages to select baseline lamps which it used to derive
efficacy equations that span wattage. Therefore, DOE was able to apply
the analysis performed on the most popular lamps to the other, less
common lamps. Further detail on the CSLs DOE has developed for IRL
follows in section III.C.6.
With regard to baseline lamps, NEMA commented that DOE should
conduct more analysis on the 75W and the 150W parabolic aluminized
reflector (PAR) lamp, and clarify whether these are ``blown PAR''
lamps. (NEMA, No. 8 at pp. 2-3) EEI commented that given the market
penetration of halogen PAR lamps, DOE might consider them as some of
the baseline lamps for the analyses. (EEI, No. 4.5 at p. 77) GE
commented that blown PAR38 lamps are very common in the market (both
75W and 150W), and that they may represent a good baseline because they
are the least efficient type of PAR technology currently sold. (GE, No.
4.5 at p. 79)
In response, DOE selected three baseline lamps of varying wattage
and shapes to provide a comprehensive understanding of consumer
economics. Specifically, DOE included PAR halogen baseline lamps of
three different wattages: 50, 75, and 90 Watts. Average wattage
information of PAR lamps acquired from NEMA and a review of
manufacturer product catalogs indicate that these are the highest
volume wattages. These baseline lamps are currently regulated by EPCA
and, therefore, meet the EPCA standard.
DOE identified three lumen packages that are popular in the
commercial and residential sectors, and then identified lamps that
provided that service. These three packages are in the range of
approximately 600 to 1,300 lumens. DOE analyzed PAR baseline lamps in
each of the lumen packages as DOE believes that these lamps represent a
good cross-section of the most common reflector lamps that will be sold
and used at the effective date of the standard (the year 2012). Since
these lamps capture a range of wattages and lumen packages, they cover
a range of applications.
Table III.10 presents the representative product class and baseline
lamps that DOE has selected for the ANOPR IRL analyses.
Table III.10.--IRL Representative Product Class and Baseline Lamps
----------------------------------------------------------------------------------------------------------------
Representative product class baseline lamps
------------------------------------------------------------------
Lamp category Representative Initial
product class Descriptor Wattage W Efficacy light Lifetime
lm/W output lm hr
----------------------------------------------------------------------------------------------------------------
IRL......................... IRL Standard- PAR30........ 50 11.6 580 3,000
Spectrum.
PAR38........ 75 14.0 1,050 2,500
PAR38........ 90 14.6 1,310 2,500
----------------------------------------------------------------------------------------------------------------
DOE requests comment on its preliminary selection of representative
product classes and baseline lamps for GSFL and IRL.
3. Lamp and Lamp-and-Ballast Designs
In the market and technology assessment (see TSD Chapter 3), DOE
identifies a range of technology options that improve the efficacy of
the two categories of lamps considered in this rulemaking. In the
screening analysis (see TSD Chapter 4), DOE screened out certain
technology options because they fail to satisfy the requirements of all
four screening criteria. Those technology options not screened out by
the four criteria are called ``design options,'' and DOE considered
them in the engineering analysis.
The Joint Comment suggested that, when deciding how many potential
standard levels to examine, DOE should look at natural divisions in the
market, by product class, rather than selecting an arbitrary number of
standard levels. (Joint Comment, No. 9 at p. 4)
For the lamps considered in this rulemaking, DOE's selection of
design options guided its selection of CSLs. Because products spanned a
large range of efficacies for GSFL and IRL, DOE looked at natural
divisions in the market when selecting lamp designs. For example, for
GSFL, DOE noted groupings around the types of phosphor used and the
wall thickness of those phosphors. With regard to IRL, DOE identified
natural ``technology-based'' divisions in the market around the type of
incandescent technology used (i.e., halogen, or HIR).
DOE also took into account lumen output when it established lamp
designs for its analyses. In the Framework Document, DOE stated its
intention to hold the lamp lumen output constant at the level of the
baseline model. Thus, as the lamps become more efficacious, they will
consume less energy rather than produce more light. Holding lumen
output constant across the efficacy levels is necessary to ensure that
products supply equivalent service under the base-case and standards-
case scenarios.
The Joint Comment agreed with DOE's intention in this regard and
suggested that DOE avoid structuring the standard so that compliant
lamps would noticeably reduce light output. The Joint Comment also
expressed concern about a standard that might result in the use of
efficiency gains to over-illuminate certain installations or to install
longer-life lamps instead of capturing energy savings. (Joint Comment,
No. 9 at p. 6) EEI stated that there are some energy-saving
incandescent lamps that use a slightly lower wattage and produce fewer
lumens, but do so at a higher efficacy. Therefore, to allow for energy
savings, and as a sensitivity to the analysis, EEI recommended that DOE
should evaluate a 10-percent lumen band of equivalency for incandescent
lamps. (EEI, No. 4.5 at pp. 117-118)
In response, it is noted that for the LCC, DOE considered those
lamps (or lamp-and-ballast systems) which: (1) Emit lumens equal to the
lumen output of the baseline lamp or lamp-and-ballast system, or below
that lamp by no more than 10 percent, and (2) result in energy savings.
Lamp or lamp-and-ballast designs that under-illuminate and over-
illuminate are considered in the NIA. For the LCC, DOE also chose to
consider only energy-saving options. For GSFL, energy savings can
either be achieved through lamp replacements or lamp-and-ballast
replacements. For GSFL,
[[Page 13649]]
energy savings can only be achieved through lamp replacements. For the
NIA, DOE analyzed a range of energy saving and non-energy-saving
options. The non-energy-savings lamps, as well as more-efficient lamps
that increase or decrease light output by more than 10 percent of the
base case, can be found in Appendix 5A of the TSD.
a. General Service Fluorescent Lamps
EEI recommended that DOE should take a systems approach when
analyzing GSFL in the NES and LCC, because the ballast is the piece of
the system that determines the energy usage overall. (EEI, No. 7 at p.
1) DOE agrees with this comment and did apply a systems approach for
the fluorescent lamp analysis because DOE recognizes that both lamps
and ballasts determine a system's energy use and the overall system
lumen output. By using a systems approach, DOE was able to demonstrate
the actual energy consumption and light output of an operating lamp in
a given end-user installation. DOE is cognizant of the fact, however,
that it is not regulating fluorescent lamp ballasts in this rulemaking,
and, therefore, while it selected ballasts with different ballast
factors (BF) \33\ in order to obtain the appropriate level of system
lumen output, DOE did not necessarily select the most energy-efficient
versions of those ballasts with different BF. (Note: DOE is initiating
a separate rulemaking on fluorescent lamp ballasts, in which it will
evaluate whether new and amended efficiency standards should be applied
to fluorescent lamp ballasts.\34\) So although DOE is not setting
minimum performance standards for fluorescent systems in this
rulemaking, DOE's analysis does consider the operation of fluorescent
lamps in a lamp-and-ballast system while evaluating efficacy standards
for these lamps.
---------------------------------------------------------------------------
\33\ The ``ballast factor'' of a ballast is the ratio of the
light output of a fluorescent lamp or lamps operated on a ballast to
the light output of the lamp(s) operated on a standard (reference)
ballast. Ballast factor depends on both the ballast and the lamp
type; a single ballast can have several ballast factors depending on
lamp type. The light output of a single fluorescent lamp is measured
on a ballast with a ballast factor of 1.0. One can reduce the light
output of a lamp-and-ballast system by operating a lamp on a ballast
with a lower ballast factor.
\34\ Energy efficient ballasts are characterized as having
higher ballast efficacy factors (BEF). The BEF is directly related
to the quotient of the BF and the power consumed by the ballast,
such that a ballast maintaining BF while reducing power consumption
will have a higher BEF, and be a more energy-efficient ballast. In
its ANOPR analysis, DOE varied the ballast BF, not the BEF, in its
assessment of standards for fluorescent lamps. DOE will be
considering new and amended BEF standards in the separate
fluorescent lamp ballast rulemaking.
---------------------------------------------------------------------------
This systems approach allows DOE to select a variety of energy-
saving lamp-and-ballast designs that meet a given CSL. In general, DOE
chose its potential design options by selecting commercially-available
fluorescent lamps at higher efficacies than the baseline lamps. These
higher efficacies are achieved through a variety of technologies. As
discussed in the screening analysis (section III.B.2), DOE considered
commercially-available GSFL that use highly emissive electrode
coatings, higher efficiency lamp fill gas composition, higher
efficiency phosphors, glass coatings, or higher efficiency lamp
diameter to achieve a higher efficacy. After selecting these higher
efficacy lamps, DOE selected lamp-ballast combinations for the LCC that
both save energy and maintain comparable lumen output. For instances in
which the consumer is replacing only the lamp, DOE selected a reduced-
wattage, higher-efficacy lamp for use on the existing ballast. For
instances in which the consumer is replacing both the lamp and the
ballast, DOE was able to obtain energy savings and maintain comparable
lumen output using a variety of lamp-and-ballast combinations.
GE argued that DOE can only control a lamp for lamp replacement in
this rulemaking, and that the ballast type is not regulated as part of
this rulemaking. (GE, No. 4.5 at pp. 110-111) GE also commented that an
increase in lumens would suffice for the lamp replacement events. (GE,
No. 4.5 at p. 122)
ACEEE and GE commented that DOE should consider replacement lamps
that have the same wattage but higher efficacy coupled with a lower
ballast factor (BF) ballast as energy-efficient substitutes for the
baseline lamp. Similarly, ACEEE recommended that DOE should consider
technology options that use a lower BF ballast with a higher-efficiency
lamp to achieve energy savings. (ACEEE, No. 4.5 at p. 113) GE stated
that the energy use for fluorescent lamps is driven primarily by the
BF, and that this should be a part of the energy savings analysis. (GE,
No. 4.5 at pp. 116-117) DOE agrees with these comments, and followed
the recommendations of these stakeholders in its analysis. As the
efficacies of the fluorescent lamps being considered increased, DOE
selected and used ballasts with lower ballast factors, such that the
system lumen output was within ten percent of the baseline system lumen
output.
In this rulemaking, DOE considers reduced-wattage lamp options
(i.e., ones which emit lumens equal to the lumen output of the baseline
lamp, or below that lamp by no more than 10 percent, and result in
energy savings). In the NIA, DOE also considers substitute lamps which
produce more light but do not save energy. This reflects the fact that
DOE cannot require consumers to change their ballast along with their
lamps. However, in situations where a consumer has the opportunity to
replace a ballast, DOE allows consumers to change both their ballast
and lamp. For example, consumers can select a lamp with a higher
efficacy and a ballast with a lower BF to obtain a system that would
result in approximately the same system light output as the baseline
system. This new lamp-and-ballast combination would have a lower-
wattage consumption due to the lower BF.
In the Framework Document, DOE identified several technology
options that it intended to consider analyzing in this rulemaking. In
response to that list of technology options, stakeholders provided
feedback on certain options. Upon reviewing some of the fluorescent
lamp-and-ballast pairings, GE commented that DOE should not assume that
as lamp efficacy increases, one could always reduce wattage to achieve
a constant light output with fluorescent lamps. GE points out that
going below the 34W energy savings lamp, for example, is not possible,
because lower-wattage lamps would not work on available ballasts. (GE,
No. 4.5 at pp. 106-107)
In response, DOE has sought to create lamp and lamp-and-ballast
designs that are practical and realistic in this engineering analysis.
For example, for the 34W 4-foot medium bipin T12 GSFL, DOE did not
consider reduced-wattage substitutes. Rather, DOE paired higher
efficacy 34W 4-foot medium bipin T12 GSFL with lower BFs to capture
energy savings while maintaining lumen output.
GE also stated that it is not always possible to use a 28W
fluorescent lamp as a replacement for a 32W lamp on all the available
ballasts. GE recommends that DOE decide what an acceptable range of
reduced-wattage lamps might be, given that restrictions on use increase
as the wattage decreases. (GE, No. 4.5 at pp. 126-127).
DOE understands that one of the ways manufacturers build lower-
wattage fluorescent lamps is through the addition of krypton gas into
the mix to change the resistance of the lamp. In the manufacturer
interviews DOE held to prepare for the ANOPR, DOE was told that as the
proportion of krypton gas increases, the fluorescent lamp has more
[[Page 13650]]
difficulty starting, being dimmed, and operating in cold-temperature
environments. However, in other manufacturer interviews, DOE was
informed that technological improvements were such that 28W fluorescent
lamps should no longer have problems starting nor issues with features
such as dimming or frequent on-off (often caused by motion sensors).
DOE also reviewed publicly-available manufacturer literature and found
at least one major lamp manufacturer stating that its 28W fluorescent
lamp does not have restrictions on use.\35\ For these reasons, DOE did
consider the 28W lamp as an energy-saving replacement for a 32W T8
baseline lamp. However, DOE is aware that consumers should not be
subject to any decrease in utility and performance and that not all
consumers would choose a lower-wattage lamp if DOE established
standards for T8 lamps. The NIA analysis contains technology option
market-share matrices which contain assumptions about the relative
proportion of consumers who would elect a particular lamp (or lamp and
ballast) option in response to a standard. These matrices are described
in section III.H of this notice, and Chapter 9 of the TSD. DOE invites
further comment on the use of 28W, as well as 25W, replacement
fluorescent lamps in the analysis and the expected market share these
lamps would capture at the various CSLs. DOE intends to continue the
dialogue with the public on this issue to better understand the
capability of these reduced-wattage fluorescent lamps.
---------------------------------------------------------------------------
\35\ This catalog states the following about 25W, 28W, and 30W
T8 lamps: ``Operates on: Any Instant Start Ballast; Programmed Start
Ballast that supplies equal to or greater than 550 starting
voltage.'' Source: Philips Lamp Specification and Application Guide
(2006), p. 72.
---------------------------------------------------------------------------
b. Incandescent Reflector Lamps
For IRL, DOE has observed natural efficacy divisions in the
marketplace which correspond to the use of halogen capsules, HIR
technology, and improved reflector coatings to increase lamp efficacy.
DOE considers these efficacy divisions in selecting CSLs by using the
efficacy levels of commercially-available lamps as a guide.
Commercially-available products do not exist at all of the CSLs for all
of the baseline lamps, however. For example, the 75W PAR38 baseline
lamp with 1,050 lumens has commercially-available products at all three
CSLs, but the 50W PAR30 baseline lamp with 580 lumens only has
commercially-available products at one of the three CSLs. Because DOE
believes it is technically feasible to incorporate the commercially-
available technologies in lamp types that correspond to all of the
baseline lamps, and in order to have a continuous range of efficacies
to analyze, DOE is developing some model IRL which it bases on lamp
lumen packages which are commercially available. In particular, using
efficacy information for the commercially-available lamp designs (that
are substitutes for certain baseline lamps), DOE is able to develop a
relationship of efficacy to wattage. This then allows DOE to develop
lamp designs that are not commercially available for certain wattages,
but that would be substitutes for other baseline lamps. DOE assumes
that lamps of similar diameters may substitute for one another (e.g.,
PAR38 IRL will be substituted with another PAR38 IRL). Generally, the
lamp design substitutes for baseline lamps are based around the lumen
output of the baseline lamp, plus or minus 10 percent.
In reviewing published catalog data, DOE observed that higher
efficacy, reduced-wattage IRL (which maintain light output within 10
percent) are available as substitutes for a number of baseline lamps.
Furthermore, these reduced-wattage designs span a range of design
options available for consideration in this rule. These design options,
discussed in the screening analysis portion of this notice (section
III.B), include the tungsten-halogen regenerative cycle (hereafter
``Halogen'') and halogen infrared technologies (hereafter ``HIR''), a
technology that uses both Halogen and glass coatings that reflect
infrared light. DOE observed that the commercially-available halogen
IRL fall within two tiers of efficacy. To distinguish the efficacies of
these halogen IRL, DOE is designating them as Halogen and Improved
Halogen. DOE also observes two tiers of efficacy for HIR IRL. To
distinguish the efficacies of these IRL, DOE is designating them as HIR
and Improved HIR. DOE believes Improved HIR and Improved Halogen can be
achieved by using the additional design options discussed in the
screening analysis. These design options include higher-efficiency
filaments, efficient filament coiling, filament configuration, capsule
design, high pressure capsules, or higher efficiency reflector coating.
DOE observed lifetime changes across these ``naturally-occurring''
reduced-wattage IRL. (That is, a halogen reduced-wattage IRL typically
has a lifetime of around 2,000 to 3,000 hours, whereas an HIR IRL
typically lives for 3,000 to 4,000 hours.) DOE has maintained the
lifetime attributes of the commercially-available product for its
analysis.
In summary, DOE seeks comment on its selection of lamp and lamp-
and-ballast designs for GSFL and IRL.
4. Candidate Standard Levels
a. General Service Fluorescent Lamps
Table III.20 and Table III.22 present a summary of the candidate
standard levels (CSLs) for each of the representative product classes
for the lamps covered under this rulemaking. In general, the CSLs for
GSFL (presented in Table III.20) follow a general trend of increasing
efficacy through the use of higher-quality phosphors. The CSLs also
represent a move from higher-wattage T12 technologies to lower-wattage,
higher-efficacy T8 technologies. CSL5 represents the most efficacious
fluorescent lamp (i.e., ``max tech''). In all product classes,
fluorescent lamps that meet CSL5 are T8 lamps which use 800 series
phosphors.
The following paragraph presents a detailed discussion of the
design options used to meet each CSL for the 4-foot medium bipin
product class. For more information on design options used to meet each
CSL for the 8-foot single pin slimline product class and the 8-foot
recessed double contact HO product class, refer to Chapter 5 of the
TSD.
A standard at CSL1 impacts the two 4-foot medium bipin T12 baseline
lamps. Because the baseline T8 lamp is above this efficacy level,
consumers using the T8 lamp are not impacted. This CSL can be met with
a 34W T12 lamp using 700 series rare earth phosphors or a 40W T12 lamp
using improved 700 series or 800 series rare earth phosphors. A
standard at CSL2 also only impacts T12 lamps. This CSL can be met by
both the 34WT12 and 40W T12 lamp using an 800 series rare earth
phosphor. A standard at CSL3 impacts all three baseline lamps. To meet
this level, the 32W T8 lamp must use an 800 series rare earth phosphor.
The T12 lamps must use an 800 series rare earth phosphor and possibly
other design options such as a different gas fill or increased
thickness of the bulb-wall phosphor to increase the lamp's efficacy. A
standard at CSL4 also impacts all three baseline lamps. However, there
are no T12 lamps commercially available that can meet this efficacy
requirement. Therefore, users of T12 lamps would be forced to replace
their ballasts and operate T8 lamps instead. For the T8 lamps, this
level requires the use of higher-efficacy 800 series rare earth
phosphor. A 30W T8 lamp that produces an equivalent amount of light as
the baseline unit on a similar ballast meets this CSL. CSL5,
[[Page 13651]]
which also impacts all three baseline lamps, represents the most
efficacious 4-foot medium bipin lamps. Again, there are no T12 lamps
commercially available that can meet this efficacy requirement.
Therefore, users of T12 lamps would be forced to replace their ballasts
and operate T8 lamps instead. 32W T8 lamps which meet this efficacy
level must use 800 series rare earth phosphor and may incorporate other
efficacy improvements to the lamp, such as a different gas fill or
increased thickness of the bulb-wall phosphor. A 28W and a 25W T8 lamp
that produces an equivalent amount of light on the same ballast as the
baseline unit meets this CSL.
Philips commented that there is more than one kind of reference
ballast that can be used to test GSFL, and that the same lamp operated
on two different ballasts can have a different efficacy. Because a
given lamp can exhibit different efficacies based on the testing method
use, Philips commented that DOE should use a standard test procedure
based on ANSI requirements to develop lamp efficacy values. (Philips,
No. 11 at p. 3)
In response, DOE's current test procedure for fluorescent lamps is
based on ANSI standards and evaluates the performance of lamps on a
single, low-frequency reference ballast. As noted previously, DOE is
currently conducting a rulemaking on the test procedures for
fluorescent and incandescent lamps in tandem to this energy standards
rulemaking. In that rulemaking, DOE is proposing to continue to use
low-frequency ballast testing for all GSFL except those which can only
be tested on a high-frequency ballast. Further detail on the ANSI
standards incorporated by reference that are used to evaluate lamps is
available in 10 CFR Part 430, Subpart B, Appendix R and in the Test
Procedures NOPR. DOE does note, however, that while it uses the test
procedure values to set efficacy levels, it considers the operation of
lamps on several different ballast types in the LCC and NIA analyses.
This way, the economic evaluation of the CSLs more accurately reflects
how users actually operate these lamps.\36\ DOE calculated system power
data using published catalog information. Further detail on this
calculation is available in Chapter 5 of the TSD.
---------------------------------------------------------------------------
\36\ This approach is similar to other rulemakings where DOE
bases product efficacy levels on the test procedure measurements,
while design options analyzed in the NIA are adjusted with operating
hour data to reflect energy use in the marketplace.
---------------------------------------------------------------------------
A more detailed discussion on how DOE selected these CSLs for each
product class, which technologies they represent, and which design
option lamps DOE used at these CSLs for each of the representative
units, can be found in Chapter 5 of the TSD.
Table III.11.--Summary of the Candidate Standard Levels for Fluorescent
Lamps With CCT <= 4,500K
------------------------------------------------------------------------
4-Foot 8-Foot 8-Foot
medium single pin recessed
bipin slimline double
Candidate standard level -------------------------- contact HO
------------
lm/W lm/W lm/W
------------------------------------------------------------------------
CSL1............................. 82.4 87.3 83.2
CSL2............................. 85.0 92.0 86.1
CSL3............................. 90.0 94.8 87.6
CSL4............................. 92.3 98.2 91.9
CSL5............................. 95.4 101.5 95.3
------------------------------------------------------------------------
b. Incandescent Reflector Lamps
Table III.22 presents the CSLs for IRL. For IRL, the increasing
CSLs represent shifts in technology, including shifts from halogen to
HIR technology. As the baseline lamps are generally already utilizing
halogen technology, CSL1 for IRL is met through improved halogen
technologies which are achieved with an improved reflective coating or
higher pressure halogen capsules. CSL2 for IRL can be met with HIR
technology (i.e., a technology that uses a halogen capsule with an
infrared reflective coating.) CSL3 for IRL can be met with improved HIR
technologies; this level can be achieved with an HIR lamp that has an
improved reflective coating, better HIR coatings or higher pressure
halogen capsules.
The CSLs for IRL use an efficacy equation which calculates minimum
average efficacy (in lumens per watt) based on the rated wattage of the
lamp (denoted by the variable P in the equation). As an example,
consider a baseline 50W PAR30 lamp with an efficacy of 11.6 lm/W. The
minimum required efficacies of a 50W lamp under the CSLs would be 14.4
lm/W at CSL1, 15.8 lm/W at CSL2, and 17.8 lm/W at CSL3. Plots of these
CSLs are presented in Chapter 5 of the TSD.
Table III.12.--Summary of the Candidate Standard Levels for Standard-
Spectrum IRL
------------------------------------------------------------------------
Standard-
spectrum
incandescent
Candidate standard level reflector
lamps
---------------
lm/W
------------------------------------------------------------------------
CSL1.................................................... 5.0P\0.27\
CSL2.................................................... 5.5P\0.27\
CSL3.................................................... 6.2P\0.27\
------------------------------------------------------------------------
A more detailed discussion on how these CSLs were derived, which
technologies they represent, and which design option lamps are used at
these CSLs for each of the representative units can be found in Chapter
5 of the TSD. DOE invites comment on the CSLs for GSFL and IRL.
5. Engineering Analysis Results
The following section presents partial results from the engineering
analysis for GSFL and IRL. The results include detail on the
characteristics of lamp and lamp-and-ballast designs DOE used in its
analyses and the CSL which they meet. The full set of results for the
lamps and lamp-and-ballast systems DOE analyzed, including additional
product classes and baselines, are available in Chapter 5 and Appendix
5A of the TSD. DOE is presenting the partial results here to facilitate
comment on the methodology of DOE's analyses, and on the presentation
of its results.
a. General Service Fluorescent Lamps
Engineering analysis results for GSFL include descriptions of the
lamp-and-ballast systems DOE selected for the analyses. Because the
CSLs are based on lamps, and at some CSLs DOE has analyzed multiple
lamps, in some
[[Page 13652]]
instances DOE presents multiple systems per CSL.
Table III.13 presents the engineering analysis results for a 34W
T12 baseline lamp system. Building from the baseline system, the table
presents each of the engineering analysis lamp-and-ballast designs DOE
used for each of the five CSLs. At each CSL, DOE generally considered
both a replacement lamp that had the same wattage as the baseline lamp
and operates on a new (lower BF) ballast, and a replacement lamp that
had a reduced wattage. This difference between the design lamps
considered is evident in the ``rated wattage'' column. Then, for each
of those design lamps, DOE provides the rated efficacy, the initial and
mean light outputs, and the average operating life of the lamp. The
table is sorted by efficacy, such that each lamp represents a higher
efficacy, and thus constitutes a more-efficient lamp design in the
engineering analysis. The table also presents the type of ballast DOE
pairs with each lamp, including the BF for that ballast, the resultant
system power rating of the lamp operating on that ballast, and the
system initial and the system mean light outputs. The BF was selected
so that the new system does not reduce light output by more than 10
percent of the baseline lamp system. The system performance of the
more-efficacious lamps is utilized in the LCC, where an economic
analysis is conducted to determine whether a more-efficacious lamp or
lamp-and-ballast system is cost-justified. For details on the LCC, see
section III.G and Chapter 8 of the TSD.
4-Foot T8 lamp and ballast replacements are considered as
substitutes for the baseline lamp. The highest energy-saving system
uses a 0.88 BF electronic ballast with a reduced-wattage T8 lamp and
maintains lumen output within 10 percent. Additional engineering
analysis results for GSFL are available in Chapter 5 and Appendix 5A of
the TSD.
Table III.13.--Lamp-and-Ballast Replacement Engineering Analysis 4-Foot Medium Bipin GSFL With a CCT <= 4,500K
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Nominal Rated Rated Initial Mean Life System System System
wattage wattage efficacy light light ---------- power initial mean
Lamp ------------------------------ output output Ballast rating light light
Candidate standard level diameter -------------------- Ballast type factor ---------- output output
W W lm/W hr -------------------
lm lm W lm lm
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline...................................... T12 34 34 77.9 2,650 2,300 20,000 Magnetic.......................... 0.88 108.0 6,996 6,072
Baseline...................................... T12 34 34 77.9 2,650 2,300 20,000 Electronic........................ 0.88 91.7 6,996 6,072
CSL1.......................................... T12 34 34 82.4 2,800 2,460 20,000 Electronic........................ 0.88 91.7 7,392 6,494
CSL1.......................................... T12 34 34 82.4 2,800 2,460 20,000 Electronic........................ 0.86 90.3 7,224 6,347
CSL2.......................................... T12 34 34 85.3 2,900 2,610 20,000 Electronic........................ 0.86 90.3 7,482 6,734
CSL2.......................................... T8 32 32.5 86.2 2,800 2,520 20,000 Electronic........................ 0.88 87.5 7,392 6,653
CSL3.......................................... T8 32 32.5 90.8 2,950 2,710 20,000 Electronic........................ 0.78 78.5 6,903 6,341
CSL3.......................................... T12 34 34 91.2 3,100 2,790 24,000 Electronic........................ 0.86 90.3 7,998 7,198
CSL4.......................................... T8 32 32.5 92.3 3,000 2,850 24,000 Electronic........................ 0.75 75.9 6,750 6,413
CSL4.......................................... T8 30 30 95 2,850 2,680 18,000 Electronic........................ 0.78 72.4 6,669 6,271
CSL5.......................................... T8 32 32.5 95.4 3,100 2,915 24,000 Electronic........................ 0.75 75.9 6,975 6,559
CSL5.......................................... T8 28 28 97.3 2,725 2,560 18,000 Electronic........................ 0.78 63.3 6,377 5,990
CSL5.......................................... T8 25 25 96 2,400 2,280 24,000 Electronic........................ 0.88 66.8 6,336 6,019
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
*This table includes the systems DOE analyzed for 3-lamp 34W T12, 4,100K systems. These lamp-and-ballast designs apply to situations where consumers purchase both a lamp and a ballast.
Additional results for other baselines and purchasing events are available in Chapter 5 of the TSD.
b. Incandescent Reflector Lamps
Engineering analysis results for IRL describe the baseline lamps
DOE selected for the analyses. Table III.14 presents the engineering
analysis results for the 75W PAR38 IRL. This baseline lamp and its lamp
design substitutes are based around a 1,050 lumen-output lamp. The max-
tech option (CSL3) offers a 36 percent improvement in efficacy, with
longer life. Additional engineering analysis results are available in
Chapter 5 and Appendix 5A of the TSD. Discussion on the CSL efficacy
values (derived from observed and extrapolated lamp efficacy values)
are also available in Chapter 5 and Appendix 5A of the TSD.
Table III.14.--Engineering Analysis for Standard-Spectrum IRL*
--------------------------------------------------------------------------------------------------------------------------------------------------------
Wattage Initial Efficacy Lamp
------------- light ------------- lifetime
Candidate standard level Design option Lamp descriptor output ------------
W ------------- lm/W
lm Hr
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline................................. Halogen..................... PAR38...................... 75 1050 14.0 2,500
CSL1..................................... Improved Halogen............ PAR38...................... 66 1050 15.9 3,000
CSL2..................................... HIR......................... PAR38...................... 60 1050 17.5 3,000
CSL3..................................... Improved HIR................ PAR38...................... 55 1050 19.1 4,000
--------------------------------------------------------------------------------------------------------------------------------------------------------
*The results in this table are for 75W PAR38 IRL. Additional results are available in Chapter 5 of the TSD.
6. Scaling to Product Classes Not Analyzed
As discussed above, DOE identified and selected certain product
classes as ``representative'' product classes where DOE would
concentrate its analytical effort. DOE chose these representative
product classes primarily because of their high market volumes. The
following section discusses how DOE intends to scale CSLs from those
product classes that it analyzed to those product classes that it did
not analyze.
a. General Service Fluorescent Lamps
As discussed in section III.C.2, above, DOE did not analyze GSFL
with a correlated color temperature (CCT) above 4,500K and 2-foot U-
shaped lamps. As discussed in section III.A, the efficacy of lamps with
cooler CCTs (i.e.,
[[Page 13653]]
higher CCT values) is lower due to the quality of blue light emitted by
lamps with cooler CCT. DOE compared commercially-available T8 lamps at
4,100K and 6,500K, and found that the efficacy of the 6,500K lamps was
between 4 and 7 percent lower than that of the 4,100K lamps. In order
not to overly penalize current product offered in the market, DOE is
considering adopting the larger of the two scaling factors, namely 7
percent, when determining the minimum efficacy requirement for lamps
greater than 4,500K. This would mean, for example, that if 82.4 lm/W
(i.e., CSL1) were selected for the 4-foot medium bipin product class of
4,500K CCT and below, the scaled minimum efficacy requirement for the
product class greater than 4,500K CCT would be 76.6 lm/W. DOE invites
comment on this preliminary decision, including other approaches the
public suggests, and any mathematical or other technical scaling
factors that could be applied.
Similarly, DOE observed that 2-foot U-shaped lamps generally are
less efficacious than 4-foot medium bipin lamps due to the bend of a 2-
foot U-shaped lamp. This drop in efficacy appears to be dependent on
the wattage and diameter of the lamp in question. DOE has observed that
40W T12 2-foot U-shaped lamps are on average 6 percent less efficacious
than a 40W T12 medium bipin lamp of the same phosphor series and
manufacturer, while 34W T12 or 32W T8 2-foot U-shaped lamps are
generally 3 percent less efficacious than the 34W T12 or 32W T8 medium
bipin lamp of the same phosphor series and manufacturer. In order not
to overly penalize T12 lamps, DOE is considering applying a 6 percent
decrease to the CSLs for 4-foot medium bipin lamps for 2-foot U-shaped
lamps. DOE invites comment on this preliminary decision, including
other approaches, and any mathematical or other technical scaling
factors that could be applied.
b. Incandescent Reflector Lamps
DOE has analyzed standard-spectrum lamps in its analysis, but DOE
intends to set separate minimum efficacy requirements for standard-
spectrum and modified-spectrum IRL, utilizing the approach discussed
below. Modified-spectrum IRL filter out portions of the light spectrum
emitted by the filament in order to obtain a particular spectral
emission. Modified-spectrum lamps achieve their particular spectral
emission through either a coating applied to the outer glass of the
lamp or through the incorporation of neodymium (or other additives)
into the outer glass bulb. Because this filtering of light reduces the
lumen output of the lamp, DOE plans to establish a separate minimum
efficacy requirement, appropriately scaled, for modified-spectrum
lamps. As there is considerable variability in the modification of the
spectrum (i.e., with some lamp coatings or glass additives adsorbing
more light, others less), DOE plans to scale standard levels based on
the degree of spectral modification.
In order to scale appropriately, manufacturers would be required to
measure the lumen output of both their modified-spectrum lamp, as well
as the lumen output of an equivalent, standard-spectrum reference lamp
(i.e., a lamp with equivalent: (1) Rated wattage; (2) rated voltage;
(3) gas fill pressure and composition; (4) bulb shape and size; (5)
filament type and orientation; (6) finish; and (7) other design
features of the modified-spectrum lamp except for the coating or
neodymium (or other additives) which produces the modified-spectrum. In
order to determine the appropriate minimum efficacy requirement for the
modified-spectrum lamp, manufacturers would measure the lumen output of
both the modified-spectrum lamp and the equivalent standard-spectrum
reference lamp, and then multiply the ratio of lumen outputs (i.e., the
lumen output of the modified spectrum lamp divided by the lumen output
of the standard-spectrum reference lamp) by the minimum efficacy
requirement for the standard-spectrum reference lamp. This lumen-
output-adjusted minimum efficacy requirement would be scaled
appropriately for exactly the coating or neodymium (or other additives)
content producing the modified spectrum. In this way, the consumer
would be assured that any minimum efficacy standard the Secretary may
establish for standard-spectrum lamps would also be incorporated into
the covered modified-spectrum lamps. DOE invites comment on this method
of establishing a lumen-output-adjusted efficacy requirement, including
other approaches, and any mathematical or other scaling factors for
modified-spectrum lamps.
Additional detail on the engineering analyses can be found in the
Engineering Chapter (Chapter 5) of the TSD.
D. Energy-Use Characterization
The purpose of the energy-use characterization is to estimate the
energy consumption of the baseline and higher efficacy lamps and lamp
systems considered in this analysis. DOE determines the energy
consumption of the lamps and lamp systems through the rated power
(i.e., rated in watts) and the way consumers use the lamp (i.e.,
operating hours per year). This analysis, which is meant to represent
typical energy consumption in the field, is an input to both the LCC
and PBP analyses and the NIA. The energy-use characterization enables
DOE to determine the LCC and the PBP of more-efficacious lamps relative
to the baseline lamp.
DOE derives the annual energy consumption of lighting systems by
multiplying the power rating by the number of hours of operation per
year. The following sections discuss the inputs and calculations DOE
used to develop annual operating hours and the energy consumptions for
the various lamps and lamp systems considered in this analysis. For
more information on the representative classes analyzed for these lamp
and lamps systems refer to section III.C.2 of this notice. Comments
provided on issues related to the energy-use characterization are also
summarized in these sections.
1. Operating Hours
In the Framework Document, DOE sought data on the typical
applications and end-use profiles of GSFL and IRL. EEI recommended that
DOE take into account the distribution of operating hours (i.e., the
number of hours a lamp is in use) by both lamp category and sector.
(Public Meeting Transcript, No. 4.5 at pp. 158-159)
DOE structured the analysis in a manner consistent with this
comment, developing operating hours by both lamp category and sector.
In addition, for the LCC analysis, DOE accounted for variability of
operating hours by developing a distribution of operating hours for the
LCC spreadsheet. The operating hour distributions capture variation
across census divisions, building types, and lamp categories for all
sectors. Within the commercial and industrial sectors, the
distributions capture variation across ``applications,'' and within the
residential sector, the distribution captures variation across ``room
types.'' A list of these applications and room types is available in
Chapter 6 of the TSD.
EEI and the Northwest Power and Conservation Council (NWPCC)
suggested several sources (such as Electric Power Research Institute,
New York State Energy Research and Development Authority, California
Energy Commission, CalMac, Florida Solar Energy Center) that DOE could
use to obtain operating hour distribution data. (Public Meeting
Transcript, No. 4.5 at pp. 158-164) NEMA recommended that DOE should
use data from the 2002
[[Page 13654]]
study, U.S. Lighting Market Characterization Volume I (LMC). (Public
Meeting Transcript, No. 4.5 at p. 160; NEMA, No. 8 at p. 3)
After reviewing other data sources, DOE selected the LMC for this
analysis because it is the most complete source of operating hour data
and because it is generally consistent with other sources. The LMC,
which is based on thousands of building audits and surveys, provides
national-level data on operating hours by building type and lamp
category for all sectors. These operating hours are broken down by
application for the commercial and industrial sectors, and room type
for the residential sector.
EEI suggested that DOE should update the operating hour
distributions to account for lighting controls in the commercial sector
(Public Meeting Transcript, No. 4.5 at p. 158). EEI was not specific
whether the lighting controls should encompass occupancy sensors,
daylight dimming, or demand-responsive dimming systems that are
activated during peak demand periods.
While DOE recognizes that there probably are more lighting controls
being used today, DOE does not believe the level of penetration is
likely to be significantly different from LMC, which was published in
2002. Furthermore, DOE believes the overall national level of
penetration of lighting controls at the individual level (i.e., those
that would respond to one individual's office) is still relatively low.
Finally, DOE is unsure how it would account for lighting controls, as
there is uncertainty about which control systems are being recommended
and nationally-representative data sources on the impact of lighting
controls were not identified. Therefore, DOE has not modified the
operating hour data from LMC for the ANOPR. However, DOE invites
comment on this issue. In particular, DOE invites comment on the type,
prevalence, and operating hour reductions due to lighting controls used
separately in the commercial, industrial, and residential sectors.
In conjunction with data from the LMC, DOE used data from the
Energy Information Administration's (EIA) CBECS (2003), RECS (2001),
and the MECS (2002). These EIA studies provide information on the
distribution of buildings within the U.S., by building type and census
division. DOE associated the LMC's operating hour data by building type
with the EIA's data by building type and census division to derive
operating hours by census division. This allowed DOE to correlate the
electricity price distribution (see TSD Chapter 8) and sales tax
distribution (see TSD Chapter 7) with the operating hour distribution
by census division in the LCC spreadsheet. The following describes data
sources used to develop operating hours, by sector.
For the residential sector, DOE used RECS building data and LMC
residential sector operating hour data. The 2001 RECS data indicate the
probability that a certain building type is within a census division.
The LMC indicates the occurrence of certain room types within a given
building type and the operating hour characteristics of typical lamps
in these rooms. By using probabilities derived from RECS, the LCC model
selects a building of a certain type and census division. The model
then selects a room within that building type using LMC data and
presents operating hour data for a typical lamp in that room.
DOE used a similar approach to the one described for the
residential sector to develop a distribution of operating hours in the
commercial sector. However, in lieu of room type, the model selects
operating hours based on application. The 2003 CBECS data indicate the
probability a certain building type is located in a certain census
division. Once the LCC model selects a building, DOE used the LMC to
indicate the probability a lamp is installed in a certain application
in that building. The LMC then estimates the operating hour
characteristics of a typical lamp for that application. A sample of the
diversity of operating hour characteristics can be found in Chapter 6
of the TSD.
To develop a distribution of operating hours in the industrial
sector, DOE used an approach similar to that used for the commercial
sector. The 2002 MECS data indicate the probability a certain building
type exists. Once the model selects a building, DOE uses LMC to
ascertain the probability a GSFL or IRL is installed in a certain
application in that building. LMC then gives the operating hour
characteristics of a typical lamp for that application. Because MECS
does not provide the location of industrial sector buildings, DOE used
population information from the 2007 census to establish the
probability that a certain industrial building exists in a certain
census division. Table III.15 summarizes the weighted-average operating
hours per lamp category per sector.
DOE has not developed the weighted-average operating hours for GSFL
in the residential sector because shipment information and manufacturer
interviews indicate that the vast majority of the GSFL market resides
in the commercial and industrial sectors. However, if analysis of GSFL
in the residential sector were deemed necessary, DOE could use the
distribution of operating hours of IRL, as this may approximate the
operating hour profile of GSFL in the residential sector.
Alternatively, DOE could develop a distribution of operating hours from
an alternative data source.
DOE invites comment on the average operating hours for the use of
GSFL and IRL in the commercial, residential, and industrial sectors.
DOE also invites comment on how DOE should develop an operating hour
distribution for GSFL in the residential sector.
Table III.15.--Average Operating Hours by Sector and Lamp Category
------------------------------------------------------------------------
Average annual
Sector Lamp category operating hours
hrs/year
------------------------------------------------------------------------
Residential..................... IRL 884.2
Commercial...................... GSFL 3435.0
IRL 3450.0
Industrial...................... GSFL 4795.1
IRL 4664.0
------------------------------------------------------------------------
2. Results
For GSFL, energy consumption by sector is based on the system power
rating derived by DOE and the average annual operating hours of that
lamp. As an illustration of how DOE determined energy consumption,
Table III.16 and Table III.17 list the system power ratings and annual
energy consumption of the 4-foot medium bipin product class. Additional
detail on the energy-use
[[Page 13655]]
characterization of other GSFL can be found in Chapter 6 of the TSD.
Table III.16.--Four-Foot Medium Bipin T8 GSFL 3-Lamp System Power Consumption Rating and Annual Energy
Consumption
----------------------------------------------------------------------------------------------------------------
System power Annual energy consumption
rating -------------------------------
Lamp & ballast designs ---------------- Commercial Industrial
-------------------------------
W kWh kWh
----------------------------------------------------------------------------------------------------------------
1.18BF32 Elec \37\.............................................. 114.5 393.2 548.9
1.18BF25 Elec................................................... 93.0 319.5 446.1
1.0BF32 Elec.................................................... 98.3 337.7 471.4
1.0BF30 Elec.................................................... 90.2 309.8 432.5
1.0BF28 Elec.................................................... 80.5 276.5 386.0
0.88BF32 Elec................................................... 87.5 300.6 419.7
0.88BF30 Elec................................................... 80.5 276.5 386.0
0.88BF28 Elec................................................... 71.1 244.2 340.9
0.88BF25 Elec................................................... 66.8 229.6 320.5
0.78BF32 Elec................................................... 78.5 269.8 376.6
0.78BF30 Elec................................................... 72.4 248.8 347.3
0.78BF28 Elec................................................... 63.3 217.3 303.3
0.75BF32 Elec................................................... 75.9 260.5 363.7
----------------------------------------------------------------------------------------------------------------
Table III.17.--Four-Foot Medium Bipin T12 GSFL 3-Lamp System Power Rating and Annual Energy Consumption
----------------------------------------------------------------------------------------------------------------
System power Annual energy consumption
rating -------------------------------
Lamp-and-ballast designs ---------------- Commercial Industrial
-------------------------------
W kWh kWh
----------------------------------------------------------------------------------------------------------------
0.95BF40 Mag.................................................... 129.0 443.1 618.6
0.88BF34 Mag.................................................... 108.0 371.0 517.9
0.88BF40 Elec................................................... 107.7 369.8 516.2
0.88BF34 Elec................................................... 91.7 314.8 439.5
0.87BF40 Elec................................................... 107.0 367.5 512.9
0.86BF40 Elec................................................... 90.3 310.2 433.0
----------------------------------------------------------------------------------------------------------------
Because the lamp system for IRL consists only of the lamp, the
system's rate of energy use is simply the rated power of the lamp.
Table III.18 details the lamp power rating and annual energy
consumption for the 75W PAR38 reference lamp and its lamp designs.
Additional detail on the energy-use characterization of IRL can be
found in Chapter 6 of the TSD.
---------------------------------------------------------------------------
\37\ A notation of the form ``1.18BF32Elec'' indicates a lamp-
ballast system consisting of a 32W lamp paired with an electronic
ballast of a 1.18 ballast factor. ``0.95VF40 Mag'' refers to a lamp-
ballast system of a 40W lamp paired with a magnetic ballast of a
0.95 ballast factor.
Table III.18.--IRL Power Rating and Annual Energy Consumption, 75PAR38
----------------------------------------------------------------------------------------------------------------
Lamp efficacy Lamp power Annual energy consumption
rating -----------------------------------------------
Technology option -------------------------------- Commercial Industrial Residential
-----------------------------------------------
lm/W W kWh kWh kWh
----------------------------------------------------------------------------------------------------------------
Baseline........................ 14.0 75.0 258.8 349.8 66.3
CSL1............................ 15.9 66.0 227.7 307.8 58.4
CSL2............................ 17.5 60.0 207.0 279.8 53.1
CSL3............................ 19.1 55.0 189.8 256.5 48.6
----------------------------------------------------------------------------------------------------------------
E. Product Price Determination
This section explains how DOE developed end-user prices for
baseline products as well as higher-efficacy products, and how DOE
developed the sales tax figures it used in the analyses. To derive the
total, installed end-user cost of products, DOE added sales tax and
installation costs, where appropriate, to end-user prices. Please see
section III.G for a discussion of installation costs.
1. Introduction and Methodology
a. Overview
In the Framework Document, DOE suggested the approach of deriving
end-user prices by applying distributor and contractor mark-ups to
manufacturer-selling-price estimates. DOE had
[[Page 13656]]
planned to derive manufacturer selling prices by applying manufacturer
mark-ups to the manufacturer costs of production. At the Public
Meeting, GE and NEMA commented that manufacturer cost data is
proprietary information and is therefore unlikely to be shared by
manufacturers. (Public Meeting Transcript, No. 4.5 at pp. 133-135).
As an alternative to deriving manufacturer selling price from
manufacturer cost, GE suggested that DOE obtain manufacturer selling
prices from distributors, State procurement contracts and other
publicly-available information sources. GE further recommended that if
DOE seeks to derive manufacturer costs, DOE could work backwards
through the distribution chain from the publicly-available product list
prices. (Public Meeting Transcript, No. 4.5 at p. 133) ACEEE and
several stakeholders supported the same methodology recommended by GE.
(NEMA, No. 8 at p. 3, Public Meeting Transcript, No. 4.5, p. 129 and p.
136; Joint Comment, No. 9 at p. 3).
As suggested by stakeholders, DOE obtained manufacturer's published
end-user price schedules for lamps (hereafter called the manufacturer's
``blue book'' or ``lamp price schedules'') as well as information on
discounts applied to those price schedules from distributors, State
contracts, and other publicly-available information sources. In
addition, DOE also obtained information on distributor pricing (i.e.,
what a distributor would pay) for commercial, industrial, and
institutional consumers of lamps. Thus, in response to comments on the
Framework Document, and due to the availability of pricing information,
DOE revised its approach for developing lamp prices from what was
presented in the Framework Document.
Starting from a consistent set of prices in the blue books, DOE
looked at publicly-available prices in State procurement contracts, at
large electrical supply distributors, home-improvement/hardware stores,
and other sources of publicly-available end-user prices, such as
Internet retailers. In its review of publicly-available market prices,
DOE observed a range of end-user prices paid for a given lamp,
depending on the distribution channel through which it is purchased and
the volume at which it is purchased. DOE observed that State
procurement contracts typically negotiated a discount of around 70 to
90 percent off the blue book. In the vast majority of instances, these
discounts apply uniformly to all products on a price schedule
irrespective of the volume of a particular lamp.
Internet retailers, electrical supply distributors, and home-
improvement/hardware stores generally reflected prices paid by
consumers in the medium-to-high range of prices. Furthermore, these
channels usually apply different discounts to lamps depending on their
sales volume. Since many high-efficacy lamps are ``niche'' products,
DOE observed that they were generally less discounted than commodity
lamps.
ACEEE commented that State procurement contracts represent prices
with low mark-ups. (Public Meeting Transcript, No. 4.5 at pp. 129-130)
GE and the Joint Comment stated that mark-ups vary by volume, with GE
stating that higher volume lamps have lower mark-ups and lower volume
lamps have higher mark-ups. (Public Meeting Transcript, No. 4.5 at p.
133; Joint Comment, No. 9 at p. 3).
In response to comments and in line with its observations of public
pricing, DOE developed three sets of discounts from the blue books,
representing the range of low, medium, and high lamp prices for GSFL
and IRL. For IRL, commercially-available products did not span the full
range of efficacies considered. For those lamps where commercial
pricing was not available, DOE extrapolated pricing from available
lamps. The development of the low, medium, and high prices specific to
each lamp category is described below in subsection III.E.1.b.
Several stakeholders commented that the manufacturer costs DOE
derives should reflect the production of commodity-type products.
(Joint Comment, No. 9 at pp. 2-3). To reflect future commoditization of
higher-efficacy lamps when they become the minimum complying products,
the discounts DOE applied to blue books to derive the low, medium, and
high prices are a constant markdown across all lamps. (Baseline
incandescent lamps received a slightly larger discount, as reflected in
State procurement contracts.) DOE also accounted for the future
commoditization of high-efficacy residential IRL by using the
incremental pricing of PAR 38 IRL. In particular, DOE notes that the
market for high-efficacy PAR 38 IRL is well developed in comparison to
the high-efficacy PAR 30 IRL market. Furthermore, DOE notes that the
products themselves use the same fundamental technologies. Although DOE
did not estimate manufacturer costs directly, DOE notes that the use of
a single markdown across efficacies and types of PAR 38 IRL and the use
of PAR38 IRL incremental pricing for PAR30 IRL accounts for
commoditization of high-efficacy products.
Once DOE calculated end-user prices, DOE added sales tax and, if
appropriate, installation costs to derive the total, installed end-user
cost. Please see section III.G for a discussion of installation costs.
For the reference case in the LCC, DOE used the medium lamp prices, but
it also conducted analysis at the low and high lamp prices, to
ascertain the impact of these other price points (see TSD Chapter 8).
In the NIA, DOE used only the medium prices in that analysis because
this price best represents the average purchase price for a variety of
consumers nationwide (see TSD Chapter 10). DOE also developed a single
average end-user price for the new and replacement ballasts used, to
which it added sales tax and installation costs. DOE requests comment
on the approach to developing end-user prices for GSFL and IRL
considered in this rulemaking.
b. General Service Fluorescent Lamps
To develop low-range prices for GSFL, DOE calculated a discount off
the blue book consistent with prices found in State procurement
contracts. DOE mirrored the procurement discount schedule by using a
constant discount across lamp efficacies. As noted above, DOE believes
that using this discount schedule is appropriate for the rulemaking
analyses, as it reflects currently-available pricing and because it
takes into account commoditization of standard-compliant lamps.
Consistent with State procurement contracts, DOE assumed that these
low-range prices include a distributor mark-up but no contractor mark-
up. As such, this is truly a lower bound of pricing which assumes the
most favorable conditions.
For medium-range prices, DOE took a discount off the blue book that
is consistent with the distributor pricing it received and that
represents a typical discount for commercial institutions on high-
volume (commodity) lamps. Again, DOE used a single discount across
efficacies. DOE added a contractor mark-up of 13 percent so that the
resulting price would encompass both a contractor and distributor mark-
up. DOE obtained this contractor mark-up estimate from the 2000 Ballast
Rule.\38\
---------------------------------------------------------------------------
\38\ U.S. Department of Energy. Office of Energy Efficiency and
Renewable Energy, Energy Conservation Program for Consumer Products:
Technical Support Document: Energy Efficiency Standards for Consumer
Products: Fluorescent Lamp Ballast Proposed Rule (Jan. 2000).
Available at: http://www.eere.energy.gov/buildings/appliance_standards/residential/gs_fluorescent_0100_r.html.
---------------------------------------------------------------------------
[[Page 13657]]
For the high-range prices, DOE deduced discounts on commodity lamps
from blue book prices for small quantity purchasers by observing high-
range pricing and obtaining distributor quotes. These prices also
encompass both a contractor and a distributor mark-up. DOE was able to
obtain data on actual prices for all GSFL it considered in the
analyses.
For the replacement ballasts considered in the analysis, DOE
gathered prices from publicly-available manufacturer price schedules
and applied a uniform discount that is customary for pricing to large
customers. All ballast prices represent contractor net price plus
contractor mark-up for ballasts purchased from a distributor. DOE
computed a simple average end-user price by applying a 50-percent mark-
up above the lowest price paid in large multi-year State procurement
contracts. Based on conversations with industry experts, DOE believes
these prices are representative of average end-user sales prices. DOE
was able to obtain data on actual prices for ballasts it considered in
the analyses.
c. Incandescent Reflector Lamps
For IRL, DOE modeled PAR30 and PAR38 IRL. DOE calculated the low-
range price for PAR38 IRL as it did for GSFL given their large range of
higher-efficacy products commercially available. Specifically, DOE
compared State procurement contracts to blue books to develop an
average discount. Again, DOE mirrored State contract pricing by
following the discount schedule used in State contracts. For the
medium-range price, DOE took a discount off the blue book to represent
shipment weighted-average prices paid by consumers for commonly
available lamps. For the high-range prices, DOE took a discount off the
blue book that represents prices that are higher-than-average but in
line with observed high-range pricing. This medium-range price is
equidistant from the low-range and high-range prices.
For PAR30 IRL, DOE used a slight variation to the methodology
followed for GSFL and PAR38 IRL. In particular, to develop the PAR30
baseline lamp price, DOE used the price differential between an
incandescent (non-halogen) BR40 lamp and halogen PAR38 lamp. DOE added
this price differential to a incandescent (non-halogen) BR30 lamp price
to obtain the baseline halogen PAR30 lamp price. By developing prices
for the baseline lamps from the incandescent replacement lamps (BR30
and BR40 lamps), DOE is recognizing that the high-volume product
currently being shipped may be a lower-efficacy (non-halogen)
incandescent lamp.\39\ Therefore, basing prices off of this lamp will
most accurately represent the commoditization of the halogen PAR30 by
2012 (the effective date of the amended standard). Similarly for
higher-efficacy lamp designs, DOE developed a list price to discount
from based on the incremental blue book prices of PAR38 IRL. As such,
DOE added the incremental end-user blue book price of PAR38 lamps to
the baseline PAR30 lamp price to derive higher-efficacy PAR30 lamp list
prices. DOE chose this methodology for PAR30 IRL because for PAR30
lamps, two of the standards-compliant lamps were not commercially
available. In addition, PAR30 lamps use the same fundamental
technologies as PAR38 lamps, which serve a more developed market.
---------------------------------------------------------------------------
\39\ Although currently the BR40 non-halogen IRL may be the
higher-volume product, DOE expects that, with the prescription of
energy conservation standards for certain ER and BR lamps by EISA
2007, by 2012 (the effective date of this rulemaking's amended
standards) the PAR30 halogen baseline lamp price will reflect the
effects of further commoditization.
---------------------------------------------------------------------------
2. End-User Price Results
The following section presents partial results from the product
price determination. The tables summarize the end-user prices DOE
developed through the product price determination. (The figures in the
tables do not include tax or installation costs). They follow in order
of lamp category. Additional results for the product price
determination are available in Chapter 7 of the TSD.
a. General Service Fluorescent Lamps
Table III.19 lists the low, medium, and high end-user prices DOE
used for the 4-foot medium bipin T12 GSFL considered in the analyses.
Results for 4-foot medium bipin T8 GSFL and 8-foot GSFL are available
in Chapter 7 of the TSD. In reviewing market prices, DOE observed that
prices generally increased with increasing efficacy. However, other
lamp characteristics such as lifetime, wattage, and CRI likely also
affected price, but these variables cannot be completely isolated. To
the extent feasible, DOE considered non-efficacy characteristics that
affect installed or operating costs in the LCC.
Table III.19.--End-User Prices for 4-Foot Medium Bipin GSFL*
--------------------------------------------------------------------------------------------------------------------------------------------------------
Mean lamp
Lamp Lamp Lamp light Low price Medium High
CSL efficacy power W lifetime CRI output $ price $ price $
lm/W hr lm
--------------------------------------------------------------------------------------------------------------------------------------------------------
T12 40W Baseline................................................ 80.0 40 20,000 70 2,880 1.41 2.35 3.28
T12 34W Baseline................................................ 77.9 34 20,000 62 2,300 0.89 1.49 2.09
1............................................................... 82.5 40 20,000 80 3,000 2.64 4.41 6.17
1............................................................... 82.4 34 20,000 70 2,460 1.58 2.64 3.70
2............................................................... 85.0 40 24,000 80 3,060 3.51 5.86 8.20
2............................................................... 85.3 34 20,000 80 2,610 2.90 4.83 6.76
3............................................................... 90.0 40 24,000 85 3,250 3.57 5.95 8.33
3............................................................... 91.2 34 24,000 85 2,790 3.50 5.83 8.16
--------------------------------------------------------------------------------------------------------------------------------------------------------
* This table presents results for T12 4-foot medium bipin GSFL. Results for additional product classes, and T8 4-foot medium bipin GSFL are available in
Chapter 7 of the TSD.
As noted above, DOE derived one end-user price for the GSFL
ballasts it considered in the analysis. DOE did not develop end-user
prices for magnetic ballasts operating with 4-foot medium bipin lamps
(rapid start magnetic ballasts), 8-foot single pin slimline lamps
(instant start magnetic ballasts), and 8-foot recessed double contact
high output lamps (rapid start magnetic ballasts). This is because the
LCC and NIA analyses do not model any purchases of these ballasts after
2012. The energy conservation standards set by the 2000 Ballast Rule
and the EPACT 2005, Pub. L. 109-58, are effective for all covered
ballasts in 2010. These standards ban the sale of magnetic 4-
[[Page 13658]]
foot medium bipin and 8-foot single pin slimline ballasts. In addition,
DOE believes that sales of magnetic ballasts that operate 8-foot
recessed double contact high output lamps will be minimal after 2012.
Again, for all of these reasons, DOE did not consider magnetic ballasts
in either the LCC or NIA analyses.
In its review of market prices for ballasts, DOE observed that
prices tended to be constant within two groupings of BFs: (1) Low and
normal BFs (a BF typically under 1.0); and (2) high BFs (a BF typically
over 1.0). Table III.20 presents end-user prices for ballasts used in
the LCC and NIA analysis.
Table III.20.--End-User Prices for Instant Start Electronic Fluorescent
Lamp Ballasts
------------------------------------------------------------------------
Ballast factor Ballast
Lamp type range price
------------------------------------------------------------------------
4-foot T8 Medium Bipin...... Normal and Low 0.75-0.88 $18.31
BF.
4-foot T8 Medium Bipin...... High BF....... 1.0-1.18 25.49
4-foot T12 Medium Bipin..... Normal BF...... 0.86-0.88 24.36
8-foot T8 Single Pin Normal and Low 0.78-0.88 25.86
Slimline. BF.
8-foot T8 Single Pin High BF....... 1.18 47.51
Slimline.
8-foot T12 Single Pin Normal BF..... 0.85-0.88 24.73
Slimline.
8-foot T8 Recessed Double Normal BF..... 0.81-0.88 48.17
Contact HO.
8-foot T12 Recessed Double Normal BF..... 0.88-0.90 30.40
Contact HO.
------------------------------------------------------------------------
b. Incandescent Reflector Lamps
For IRL, within the range of lamp wattages analyzed, DOE observed
that lamp price did not vary significantly by wattage. As a result, DOE
did not vary price by wattage in its analysis. However, DOE did observe
price differentials between larger- and smaller-diameter IRL and,
therefore, analyzed the two lamp shapes (PAR38 and PAR30) separately.
Table III.21 presents the end-user price results for PAR38 IRL. Results
for the PAR30 IRL are available in Chapter 7 of the TSD.
Table III.21.--End-User Prices for PAR38 IRL
----------------------------------------------------------------------------------------------------------------
Lamp
Lamp type Lamp shape CSL lifetime Low price Medium High
hr $ price $ price $
----------------------------------------------------------------------------------------------------------------
Halogen....................... PAR38............ Baseline......... 2,500 3.20 4.80 6.40
Improved Halogen.............. PAR38............ 1............... 3,000 4.07 6.10 8.13
HIR........................... PAR38............ 2................ 3,000 4.18 6.26 8.35
Improved HIR.................. PAR38............ 3................ 4,000 5.00 7.50 10.00
----------------------------------------------------------------------------------------------------------------
DOE requests feedback on its approach to developing lamp or lamp-
and-ballast prices for GSFL and IRL. Furthermore, DOE requests comment
on its end-user prices results for fluorescent lamp ballasts.
3. Sales Taxes
The sales tax figure represents State and local sales taxes that
are applied to the consumer product price. It is a multiplicative
factor that increases the consumer product price. DOE derived State and
local taxes from data provided by the Sales Tax Clearinghouse.\40\
These data represent weighted averages that include county and city
rates. DOE then derived population-weighted average tax values for each
Census division and large State. The distribution of sales tax rates
ranges from a minimum of 0 percent to a maximum of 9.4 percent, with a
weighted-average value of 6.9 percent.
---------------------------------------------------------------------------
\40\ Sales Tax Clearinghouse, Aggregate State Tax Rates (2007).
Available at: http://thestc.com/STrates.stm. Specifically, DOE
utilized the relevant material from this website as posted on May
25, 2007; that material is available in Docket EE-2006-STD-
0131.
---------------------------------------------------------------------------
Additional detail on the derivation of the product prices used in
this analysis can be found in Chapter 7 of the TSD, product price
determination.
F. Rebuttable Presumption Payback Periods
A more energy-efficient device will usually cost more to purchase
than a device of standard energy efficiency. However, the more-
efficient device will usually cost less to operate due to reductions in
operating costs (i.e., lower energy bills). The payback period (PBP) is
the time (usually expressed in years) it takes to recover the
additional installed cost of the more-efficient device through energy
cost savings. Section 325(o)(2)(B)(iii) of EPCA establishes a
rebuttable presumption that a standard for GSFL or IRL 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)) This rebuttable
presumption test is an alternative path to establishing economic
justification, as compared to consideration of the seven factors set
forth in 42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII).
DOE's lamp test procedures measure the rate of light output per
unit power consumption of a lamp (i.e., lumens per watt) rather than a
measurement of energy consumption (i.e., a measurement over a duration
or operating time period). Therefore, in order to calculate energy
savings for the rebuttable presumption payback period, one would need
to multiply the rate of power consumption of a lamp times the usage
profile of that lamp. For IRL, energy savings calculations in the LCC
and PBP analyses use both the relevant test procedures as well as the
relevant usage profile. Because DOE calculates payback periods using a
methodology consistent with the rebuttable presumption test for IRL in
the LCC and payback period analysis, DOE is not performing a stand-
alone rebuttable presumption analysis for IRL, as it is already
embodied in the LCC and PBP
[[Page 13659]]
analyses. For GSFL, DOE believes that the rate of energy consumption of
the lamp-and-ballast system is a more accurate measure of real world
power consumption than the rate of power consumption of the lamp as
measured on a reference ballast, as specified in the test
procedure.\41\ Because calculations of energy savings in the LCC are
based on real-world conditions, DOE will also rely on payback periods
calculated in the LCC for GSFL. See section III.G of this notice or
Chapter 8 of the TSD for further detail on the LCC and payback period
calculation.
---------------------------------------------------------------------------
\41\ For example, T8 lamps which are often operated on high-
frequency electronic ballasts would be tested and measured on a
line-frequency (60 Hz) reference ballast using DOE's test procedure,
resulting in different performance characteristics than this lamp
would exhibit in the field, operated on an electronic ballast.
---------------------------------------------------------------------------
G. Life-Cycle Cost and Payback Period Analyses
The life-cycle cost (LCC) and payback period (PBP) analyses
determine the economic impact of potential standards on consumers. The
effects of standards on individual or commercial consumers include
changes in operating expenses (usually lower) and changes in total
installed cost (usually higher). DOE analyzed the net effect of these
changes GSFL and IRL first by calculating the changes in consumers'
LCCs likely to result from CSLs as compared to a base case (no new
standards). The LCC calculation considers total installed cost (which
includes manufacturer selling price, sales taxes, distribution chain
mark-ups, and any installation cost), operating expenses (energy,
repair, and maintenance costs), product lifetime, and discount rate.
DOE performed the LCC analysis from the perspective of the consumer of
a lamp.
DOE also analyzed the effect of changes in operating expenses and
installed costs by calculating the PBP of potential standards relative
to a base case. The PBP estimates the amount of time it would take the
individual or commercial consumer to recover the assumed higher
purchase expense of more energy efficient product through lower
operating costs. The PBP is based on the total installed cost and the
operating expenses, the same approach used in calculating the LCC.
However, unlike in the LCC analysis, DOE considers only the first-year
operating expenses in the calculation of the PBP. Because the PBP does
not account for changes in operating expense over time or the time
value of money, it is also referred to as a simple PBP. Usually the
consumer benefits of a regulation exceed the consumer costs of that
regulation if the service life of the covered product is substantially
longer than the PBP.
The following discussion provides an overview of the approach and
inputs for the LCC and PBP analyses performed by DOE, as well as a
summary of the preliminary results generated for the lamps under
consideration in this rulemaking. However, for a more detailed
discussion on the LCC and PBP analyses please refer to Chapter 8 of the
ANOPR TSD.
1. Approach
The LCC analysis estimates the impact on consumers of potential
energy conservation standards by calculating the net cost of a lamp (or
lamp-ballast system) under two scenarios: (1) A ``base case'' of no new
standard; and (2) a ``standards case'' under which lamps must comply
with a new energy efficiency standard. The first step in calculating
the LCC is specifying the installed costs associated with each design,
which includes the lamp (or lamp-and-ballast system) price, sales
taxes, and any installation cost. (The development of total installed
costs is explained more fully in sections III.E of this notice and
Chapters 7 and 8 of the TSD.) After developing the installed costs, DOE
used operating hour data and electricity price data to develop
operating costs of the base-case and standards-case lamps over the
analysis period. (The development of operating costs is explained in
section III.D.1. of this notice and Chapters 6 and 8 of the TSD.)
DOE calculated the LCC value for each design and each customer
using a discount rate that represents the average cost of capital for
that customer. After repeating the calculation for many customers and
many designs,\42\ DOE calculated the distribution of net LCC impacts of
each design. A distinct advantage of this approach is that DOE can
identify the proportion of lamp installations achieving LCC savings or
attaining certain payback values due to a new energy conservation
standard, in addition to the average LCC savings or average payback for
that standard. Refer to Chapter 8 of the ANOPR TSD for detailed
discussion of the LCC analysis method.
---------------------------------------------------------------------------
\42\ For each design, DOE calculated the LCC results for 1,000
consumers using Monte Carlo simulations. These results are presented
in Appendix 8B of the TSD.
---------------------------------------------------------------------------
During the Public Meeting on the Framework Document, DOE stated its
intention to use Monte Carlo analysis in the LCC to consider end-user
variability and conduct sensitivity analyses. Reinforcing this
decision, stakeholders commented that conducting such analyses using a
Monte Carlo approach would provide useful information on the number of
purchasers who benefit from or are disadvantaged by the standard, and
by how much. (Joint Comment, No. 9 at p. 4) Accordingly, DOE has
incorporated in its LCC and PBP spreadsheet model both Monte Carlo
simulation and probability distributions by using Microsoft Excel
spreadsheets with Crystal Ball (a commercially-available add-in
program). DOE's Monte Carlo simulation considers variability in
electricity prices, sales taxes, operating hours, and discount rates.
See section III.G.2 for a discussion of LCC inputs. For a detailed
discussion on the average annual energy use of lamps and the
methodology used to calculate the distribution of annual energy use,
please refer to section III.D of this ANOPR and Chapter 6 of the TSD.
In order to accurately compare the life cycle cost of two different
products, one must evaluate the life cycle cost of each product over
the same fixed period of time (i.e., the analysis period). For the
life-cycle cost analysis, the analysis period is the lifetime of the
covered product. For most covered products that DOE analyzes, the
lifetimes of the more efficient products are the same as the lifetimes
of baseline products being analyzed. For this rulemaking, given the
unequal lifetimes of the baseline and higher efficacy lamp designs, DOE
has chosen to establish its analysis period on the lifetime of the
baseline lamp. In situations where a lamp lifetime is shorter than the
analysis period, DOE assumes that the lamp is replaced during the
analysis period. To account for any remaining lifetime at the end of
the analysis period, DOE calculates a ``residual value'' for that
lamp.\43\
---------------------------------------------------------------------------
\43\ The ``residual value'' represents the remaining value of a
lamp or a ballast from the end of the period of analysis to the end
of the service life of the lamp or ballast. The equation for
residual value is as follows: (see equation above)
Where IC = total installed cost of the product, n = the number
of replacements within the analysis period, SL = the service life of
the product, and PAnalysis = the analysis period.
[GRAPHIC] [TIFF OMITTED] TP13MR08.000
The residual value is an estimate of the product's value to the
consumer at the end of the life-cycle cost analysis period. In
addition, this residual value must recognize that a lamp system
continues to function beyond the end of
[[Page 13660]]
the analysis period. DOE calculates the residual value by linearly
prorating the product's initial cost consistent with the methodology
described in the Life-Cycle Costing Manual for the Federal Energy
Management Program.\44\ More information discussing the residual value
is given in Chapter 8 of the TSD.
---------------------------------------------------------------------------
\44\ National Institute of Standards and Technology Handbook
135, 1996 Edition, 210 pages (Feb. 1996), p. 4-6.
---------------------------------------------------------------------------
ACEEE commented that a residual value calculation or a 50-year
analysis period would yield similar results. (Public Meeting
Transcript, No. 4.5 at p. 188) DOE agrees that using a long analysis
period, such as 50 years, and discounting cash flows would normalize
for differences in lifetimes of different lamps. However, the statute
explicitly directs DOE to consider the increased first costs and
operating cost savings over ``the estimated average life of the covered
product.'' (42 U.S.C. 6295(o)(2)(B)(i)(II)) The life-cycle costs over a
50 year analysis period would be significantly larger than those over a
typical lamp lifetime. For this reason, DOE believes that the residual
value approach is more consistent with the statute and with the concept
of life-cycle costing, and elected to use the lifetime of the baseline
lamp as the period of analysis. DOE invites comment on its usage of
residual values in the life-cycle cost analysis as well as any other
possible approaches to calculating life-cycle costs for products with
different lifetimes.
2. Life-Cycle Cost Inputs
For each efficacy level analyzed, the LCC analysis requires input
data for the total installed cost of the product, the operating cost,
and the discount rate. Table III.22 summarizes the inputs and key
assumptions DOE used to calculate the consumer economic impacts of
various energy efficacy levels for each product. A more detailed
discussion of the inputs follows.
Table III.22.--Summary of Inputs and Key Assumptions Used in the LCC
Analyses
------------------------------------------------------------------------
Input Description
------------------------------------------------------------------------
Consumer Equipment Price..... As discussed in section III.E, DOE
started with manufacturer catalog
(``blue-book'') pricing, and used
different discounts to represent low,
medium, and high prices for all lamp
categories.
Sales tax.................... Sales tax is then applied to convert the
consumer equipment price to a final
consumer price including sales tax. The
sales tax mark-up is described in detail
in section III.E.
Installation cost............ This input represents the cost to the
commercial or industrial customers of
installing the lamps or lamp systems.
The installation price represents all
costs required to install the lamp or
lamp system but does not include the
customer equipment price. The
installation price includes labor and
overhead. Thus, the total installed cost
equals the consumer equipment price
including sales tax plus the
installation price.
Annual operating hours....... The annual operating hours are the
estimated hours that a lamp is in use
during the time span of one year.
Section III.D, Energy-Use
Characterization, details how DOE
determined the lamp operating hours as a
function of end-user sector, geographic
region, and application.
Product energy consumption The product energy consumption is the
rate. site-energy usage rate associated with
operating the lamp system. Section
III.D, Energy-Use Characterization,
details how DOE determined the product
energy consumption rate.
Electricity prices........... Electricity prices used in the analysis
are the average price per kilowatt-hour
(i.e., $/kWh) paid by customers. DOE
determined electricity prices using
national average residential,
commercial, and industrial electricity
prices for the sample calculation, while
for the Monte Carlo distribution, DOE
used average residential, commercial,
and industrial values for 13 regions and
large States. All electricity price data
are obtained from the EIA, 2005.
Electricity price trends..... DOE used the EIA's AEO2007 \45\ to
forecast electricity prices. For the
results presented in this notice, DOE
used the AEO2007 reference case to
forecast future electricity prices.
Lifetime..................... The total hours in operation after which
the consumer retires the lamp or
components of a lamp system from
service.
Discount rate................ The discount rate is the rate at which
DOE discounts future expenditures to
establish their present value.
Analysis Period.............. Analysis period is the time span over
which DOE calculated the LCC.
------------------------------------------------------------------------
a. Total Installed Cost Inputs
The following sections describe the total installed cost inputs. As
described previously, to account for variability in pricing, DOE
estimated three product prices per lamp design, which correspond to
variation in purchasing power. DOE applied sales tax to each product
price to create a set of end-user prices for these system components.
---------------------------------------------------------------------------
\45\ U.S. Department of Energy. Energy Information
Administration, Annual Energy Outlook 2007 with Projections to 2030
(Feb. 2007). Available at: http://www.eia.doe.gov/oiaf/aeo/index.html.
---------------------------------------------------------------------------
The installation cost represents all costs associated with
installing the lamp or lamp-and-ballast system, other than the end-user
lamp price. Thus, the total installed cost equals the consumer lamp
price (which includes mark-ups and taxes) plus the installation cost.
In its Framework Document, DOE noted that installation costs are
negligible for the residential sector but important in the commercial
and industrial sectors. NEMA commented that there are generally no
repair or maintenance costs for incandescent lamps, but only
installation costs. (Public Meeting Transcript, No. 4.5 at p. 174;
NEMA, No. 8 at p. 3)
DOE is aware that installation costs for incandescent lamps are
applicable by sector and not by lamp type. For example, consumers in
the residential sector typically do not incur installation costs, as
these consumers typically change their own lamps. Therefore, for IRL
analyzed in the residential sector, DOE assumed no installation costs.
Rather, the cost the user pays is simply that of the product.
Purchasers in the commercial and industrial sectors, on the other hand,
do incur installation costs because they usually employ a maintenance
worker to install their incandescent lamps. Therefore, DOE applied
installation costs for IRL analyzed in the commercial and industrial
sectors.
DOE stated in the Framework Document that it would consider
installation costs but not maintenance costs in its analysis. According
to NEMA, installation costs are important
[[Page 13661]]
for fluorescent lamps, but there are also some maintenance costs.
(Public Meeting Transcript, No. 4.5 at p. 174) DOE presumes that the
maintenance costs to which NEMA referred are the costs of re-lamping a
lighting system (i.e., replacing the lamp in a lighting system at end
of lamp life). For GSFL, DOE assumed installation costs for lamp-and-
ballast systems, and re-lamping costs for lamps.
DOE requested comment in the Framework Document on whether it
should consider group and spot re-lamping practices in its analysis of
installation costs. NEMA commented that, for GSFL, a small percentage
of fluorescent lamps are group re-lamped rather than spot re-lamped.
(Public Meeting Transcript, No. 4.5 at pp. 174-176; NEMA, No. 8 at p.
3) GE commented that group re-lamping should not be considered for
incandescent or incandescent reflector lamps, but could be considered
for fluorescent lamps; however, GE did not provide further explanation
for its opinion. (Public Meeting Transcript, No. 4.5 at pp. 176-177)
The approach DOE is following for the ANOPR is consistent with
these comments. For GSFL, DOE obtained estimates of the prevalence of
group versus spot re-lamping from the 2000 Ballast Rule. DOE then
weighted the spot and group re-lamping times by the percent occurrence
of spot versus group re-lamping to derive weighted-averaged re-lamping
times. To account for installation costs for IRL in the commercial
sector, DOE used re-lamping time estimates from the RS Means Electrical
Cost Data, 2007 \46\ (hereafter ``RS Means'').
---------------------------------------------------------------------------
\46\ R.S. Means Company, Inc., 2007 RS Means Electrical Cost
Data (2007).
---------------------------------------------------------------------------
For ballasts, DOE derived labor rates for electricians and helpers
from RS Means. Labor rates are the sum of the wage rate, employer-paid
fringe benefits (i.e., vacation pay, employer-paid health, and welfare
costs), and any appropriate training and industry advancement funds
costs. DOE assumed that the labor rate for installing a ballast is a
composite that equals 50 percent of the electrician labor rate plus 50
percent of the electrician-helper labor rate. For re-lamping (only lamp
replacement), DOE assumed that the task was performed by a general
maintenance worker at a labor rate DOE obtained from the U.S. Bureau of
Labor Statistics for a General Maintenance worker.\47\ Using these
labor rates and labor times, DOE derived the average cost to install a
lamp and the average cost to install a lamp and ballast.
---------------------------------------------------------------------------
\47\ U.S. Department of Labor Bureau of Labor Statistics.
Occupational Employment and Wage Estimates. National Cross-Industry
Estimates (May 2005). Available at: http://www.bls.gov/oes/oes_dl.htm.
---------------------------------------------------------------------------
DOE recognizes that labor times for replacing a ballast may change
because of changes in the 2005 National Electric Code.\48\
Specifically, the addition of Part XIII, Section 410.73(G) to the 2005
National Electric Code requires a means for disconnecting luminaires
installed in an indoor location so that electrical contractors will not
work on energized equipment while replacing or servicing ballasts. This
change applies to both commercial and industrial installations.\49\
This requirement goes into effect January 1, 2008, and it is expected
to significantly increase the labor time required for ballast
installations. Therefore, DOE is requesting comment on how labor times
and related installation costs for ballasts will be affected by this
change in the National Electric Code.
---------------------------------------------------------------------------
\48\ National Fire Protection Association, National Electric
Code 2005. CENGAGE Delmar Learning: 2004.
\49\ Ode, Mark C., ``Unplugging Fluorescents,'' Electrical
Contractor (July 2005). Available at: www.ul.com/regulators/ode/0705.pdf.
---------------------------------------------------------------------------
Additional details on the development of installation costs can be
found in Chapter 8 of the ANOPR TSD.
b. Operating Cost, Replacement Cost, and Residual Value Inputs
The following sections describe additional inputs used in
calculating the LCC. These include inputs used to develop operating
costs, replacement costs, and residual values. The operating cost of a
lamp system is a function of the annual energy consumption, energy
cost, repair and maintenance costs, analysis period, and the discount
rate. Annual energy consumption is the site-energy use (i.e.,
electricity use) associated with operating a lamp or lamp-and-ballast
system. The inputs for estimating annual energy consumption are
discussed in section III.D of this ANOPR. Electricity prices are the
prices paid by consumers for electricity. DOE used electricity price
trends to forecast electricity prices into the future. Multiplying the
annual energy consumption by the electricity prices yields the annual
energy cost. Because DOE assumed no repair or maintenance costs, costs
associated with repairing or replacing components that have failed, the
only operating costs associated with lamps are energy costs. The
analysis period is the time span over which the LCC is calculated. For
the purpose of this rulemaking, DOE based the analysis period on the
baseline lamp's service lifetime (i.e., the lamp's operating lifetime
in hours divided by annual operating hours). The discount rate is the
rate at which DOE discounted future expenditures to establish their
present value. The replacement cost (i.e., the costs associated with a
lamp replacement) is dependent on the installed cost, discount rate,
analysis period, and service life. The product service life is the age
at which the product is retired from service. The residual value (also
dependent on the four inputs used to develop replacement costs) is the
discounted total installed cost of a lamp (or lamp and ballast)
multiplied by the percentage of remaining life for that lamp (or lamp
and ballast) past the analysis period.
i. Electricity Prices
With regard to electricity prices, DOE derived average prices for
13 geographic areas consisting of the nine U.S. Census divisions, with
four large States (New York, Florida, Texas, and California) treated
separately. For Census divisions containing one of these large States,
DOE calculated the regional average values leaving out data for the
large State--for example, the Pacific region average does not include
California, and the West South Central region does not include Texas.
DOE estimated residential, industrial, and commercial electricity
prices for each of the 13 geographic areas based on data garnered from
EIA Form 861, Annual Electric Power Industry Report. DOE's calculation
methodology uses the most recently available EIA data (2005). For
further details of the methodology that DOE used for deriving energy
prices, see Chapter 8 of the ANOPR TSD.
DOE stated in the Framework Document that it would use price
forecasts by the EIA to estimate the trends in electricity prices. In
response, ACEEE and the Joint Comment argued that current EIA energy
price forecasts are too low and will likely be revised upwards over the
next few years. (Joint Comment, No. 9 at p. 3; Public Meeting
Transcript, No. 4.5 at p. 216) Therefore, the Joint Comment requested
that DOE use the latest available price forecasts from EIA to conduct
the analyses. (Joint Comment, No. 9 at p. 3) Taking into account these
comments, DOE used EIA's AEO2007, containing the latest available price
forecasts from EIA to estimate future energy prices. For the analyses
to be conducted for the NOPR and Final Rule, DOE intends to update its
energy price forecasts to be based on the latest available version of
AEO.
[[Page 13662]]
DOE did not explicitly discuss demand charges \50\ in the Framework
Document, but stakeholders identified this as an issue and submitted
comments. For example, ACEEE commented that DOE should consider demand
charges in its electricity pricing rather than averaging prices because
lighting tends to be ``peakier'' than the average use. (Public Meeting
Transcript, No. 4.5 at pp. 169-171) PG&E commented that DOE should
account for the marginal consumer cost of electricity in its analysis
and that the marginal cost of electricity is significantly different
than the average cost of electricity in certain regions (Public Meeting
Transcript, No. 4.5 at pp. 215) PG&E also commented that in addition to
using a single average price, DOE should look at a range of electricity
prices. EEI commented that separating out demand charges could lead to
similar results, except, possibly, for the residential sector. (Public
Meeting Transcript, No. 4.5 at pp. 172 and 215) The Joint Comment
stated that utility rate structures have been changing over time, and
it recommended that DOE conduct a sensitivity analysis to evaluate
whether changes in pricing structure would significantly impact the
rulemaking analyses. The Joint Comment also suggested that DOE should
consider basic electricity tariff evolutions in the structure of the
LCC and NIA, if the sensitivity analysis shows that expected changes to
electricity price structures are influential. (Joint Comment, No. 9 at
p. 4)
---------------------------------------------------------------------------
\50\ Typically consumers pay a premium for electricity consumed
during times in the day when the demand for electricity is at its
peak. These additional charges are called ``demand charges.''
---------------------------------------------------------------------------
DOE notes that in the analysis performed for the fluorescent
ballast rulemaking, DOE found that the reduction in ballast energy
consumption results in a correspondingly lower reduction in peak power.
In other words, the lighting load improves a building's load profile.
Thus, the marginal rate of electricity for lighting was found to be
slightly lower than the average utility rate. In relative terms, DOE
assumed in the ballast rulemaking that the demand reduction was 80
percent of the energy savings. For the case study analyzed in the
ballast rule, a 5-percent energy savings resulted in a 4-percent demand
reduction of the peak kW, and at the consumption weighted mean of the
differences, the electricity marginal prices were found to be 5.2
percent lower than average prices.\51\
---------------------------------------------------------------------------
\51\ U.S. Department of Energy, Office of Energy Efficiency and
Renewable Energy, Energy Conservation Program for Consumer Products:
Technical Support Document: Energy Efficiency Standards for Consumer
Products: Fluorescent Lamp Ballast Proposed Rule: Appendix B,
Marginal Energy Prices and National Energy Savings p. B-10 (Jan.
2000). Available at: http://www.eere.energy.gov/buildings/appliance_standards/residential/pdfs/appendix_b.pdf.
---------------------------------------------------------------------------
Consistent with a number of other current DOE rulemakings, DOE has
tentatively decided to use average regional electricity prices for its
analyses. DOE believes that using average regional EIA prices would not
underestimate operating cost savings. In addition, the approach will
include the regional variations in energy prices, while reducing
analytical complexity.
In addition to accounting for regional variability, DOE also
addressed future variability by incorporating three separate
projections from AEO2007 into the spreadsheet models for calculating
LCC and PBP: (1) Reference; (2) low economic growth; and (3) high
economic growth. These three cases reflect the uncertainty of economic
growth in the forecast period (from 2005 to 2030). The high- and low-
growth cases show the projected effects of alternative growth
assumptions on energy markets. The development and use of regional
average electricity prices are described below and in more detail in
Chapter 8 of the TSD.
ii. Lamp Lifetime
With regard to lamp lifetime, DOE stated in the Framework Document
that it would consider published catalog data, as well as literature
sources and inputs from manufacturers and other stakeholders in its
analysis. GE and NEMA commented that DOE should use published catalog
data for lamp lifetimes. (Public Meeting Transcript, No. 4.5 at p. 176;
NEMA, No. 8 at p. 3) In response, DOE did use published manufacturer
literature for lamp lifetimes, where available. However, for some IRL,
published manufacturer literature on lamp lifetimes is not available.
Therefore, where applicable, DOE derived lamp lifetimes as part of the
engineering analysis, in the manner discussed in section III.C.
For GSFL, the manufacturer literature provides lamp lifetimes for
both lamps operated three hours per start and those operated 12 hours
per start. Therefore, in the Framework Document, DOE invited comment as
to which lifetime value is more appropriate for use in the LCC
analysis. GE and EEI commented that by referencing studies on lighting
controls, DOE could develop a weighted lamp lifetime by estimating the
proportion of the installed base that is operated at 12 hours per start
and the proportion that is operated at three hours per start. (Public
Meeting Transcript, No. 4.5 at p. 179, Public Meeting Transcript, No.
4.5 at pp. 179-180) In its comments, EEI opined that using 3 hours per
start in the base case and standards case would be sufficient for this
analysis (Public Meeting Transcript, No. 4.5 at p. 180). After
considering public comments, DOE has tentatively decided on the
following approach in this area. Because published manufacturer
literature on lamp lifetimes for 12 hours per start is not available
for all lamps in the base case and the standards case, and because the
lifetimes are shorter in three-hours-per-start data, DOE decided to
base its calculation of lamp lifetimes for both base- and standards-
case lamps on three hours per start data. Thus, under this approach,
DOE would not risk overstating energy savings. DOE welcomes comment on
this approach.
Lamp lifetime is not only affected by the number of hours per start
but also by the type of relamping practiced. For example, lamps
replaced through group relamping, in contrast to spot relamping, will
be replaced before the end of their rated life. In the Framework
Document, DOE invited comment on whether the effect on lamp lifetime of
group and/or spot re-lamping practices should be taken into account. GE
commented that group re-lamping practices should be taken into account
for GSFL and that this practice usually occurs at 70 percent of the
rated lifetime. (Public Meeting Transcript, No. 4.5 at pp. 176-177)
Like the calculation of re-lamping costs, DOE averaged the group versus
spot re-lamping impact on lifetime by their percent occurrence for
GSFL. DOE assumed a lamp subject to group re-lamping practices operates
for 75 percent of its rated life, an estimate obtained from the 2000
Ballast Rule.\52\ DOE then applied this life impact factor to the rated
lifetimes from the manufacturing literature for the GSFL it analyzed.
For 4-foot medium bipin lamps, the average lifetime used in the
analysis was 94 percent of the rated lifetime. For 8-foot single pin
slimline lamps, the average lifetime was 91 percent of the rated
lifetime, and for 8-foot recessed double contact HO lamps, the average
lifetime was 92 percent of the rated lifetime. For the reasons
discussed in section III.G.2.a, DOE
[[Page 13663]]
agrees with GE that group re-lamping should not be considered for IRL.
(Public Meeting Transcript, No. 4.5 at pp. 176-177). Therefore, DOE did
not assume an impact on lamp lifetime due to group re-lamping for IRL.
---------------------------------------------------------------------------
\52\ U.S. Department of Energy, Office of Energy Efficiency and
Renewable Energy, Energy Conservation Program for Consumer Products:
Technical Support Document: Energy Efficiency Standards for Consumer
Products: Fluorescent Lamp Ballast Proposed Rule: Appendix A, p. A-
19 (Jan. 2000). Available at: http://www.eere.energy.gov/buildings/appliance_standards/residential/pdfs/appendix_a.pdf.
---------------------------------------------------------------------------
iii. Discount Rates
As noted in the Framework Document, DOE planned to develop an
analysis on discount rates similar to prior rulemaking analyses that
evaluated the impact of standards on products or equipment installed in
the residential, commercial, and industrial sectors. NWPCC commented
that DOE should use discount rates from prior rulemakings, because
these rates do not vary appreciably over the long term. (Public Meeting
Transcript, No. 4.5 at pp. 183-184) In response, DOE reviewed the
discount rate analyses from several recent rulemakings, and decided to
use the same residential discount rates as it did for the 2007 ANOPR
for the Residential Electric and Gas Ranges and Microwave Ovens,
Dishwashers, Dehumidifiers, and Commercial Clothes Washers (hereafter
``Home Appliance ANOPR''). 72 FR 64432 (November 15, 2007). For the
commercial sector, DOE used the same discount rates for the categories
of lamp users as it used for those same categories in the 2006 NOPR for
Electrical Distribution Transformers (hereafter ``Transformer NOPR'').
71 FR 44356 (August 4, 2006). However, DOE adjusted the aggregate
commercial sector discount rate to account for differences in the
proportions of types of owners of each lamp type.
For residential replacement lamps, DOE identified all possible debt
or asset classes that would be sources of funds used to purchase
replacement lamps, including household assets that might be affected
indirectly. The mean real effective rate across all types of household
debt and equity, weighted by the shares of each class, is 5.6 percent.
For the commercial and industrial sectors, DOE derived the discount
rate from the cost of capital of publicly-traded firms in the sectors
that purchase lamps. To obtain an average discount rate value for the
commercial sector, DOE used data from CBECS 2003, which provides
market-share data by type of owner. Weighting each ownership type by
its market share, DOE estimated the average discount rate for the
commercial sector to be 6.2 percent. Similarly, the industrial sector
discount rate was derived to be 7.5 percent. For further details on
DOE's method for estimating discount rates, see Chapter 8 of the ANOPR
TSD.
iv. Analysis Period
The analysis period is the time span over which the LCC is
calculated. DOE bases the analysis period on the longest baseline lamp
life in a certain product class divided by the annual operating hours
of that lamp. If the user chooses to run the LCC using weighted average
values, then the analysis period is based on the longest baseline lamp
life divided by the average annual operating hours for that lamp in a
chosen sector, or a multiple thereof. For example, the longest lived
baseline IRL lamp is 3,000 hrs. If the user chooses to analyze this
lamp in the commercial sector, then the analysis period is the lamp
lifetime of 3,000 hours divided by the average annual operating hours
for IRL in the commercial sector of 3,450 hrs/yr, which yields an
analysis period of 0.9 years. In order to allow users to compare the
cost of IRL lamps over multiple lamp lifetimes, one can select a
multiple of this analysis period (i.e., 1.8, 2.7, or 3.6 years). If the
user chooses to run the LCC using Crystal Ball[supreg] software (a tool
used to do the Monte Carlo analysis), the analysis period is based on
the longest baseline lamp life divided by the annual operating hours
chosen by Crystal Ball[supreg]. For example, the user may choose to run
IRL in the commercial sector using Monte Carlo analysis. If Crystal
Ball[supreg] selects a building that is used for religious worship, the
analysis period for IRL for that selection will be based on a lamp
lifetime of 3,000 hours divided by the annual operating hours for IRL
in a building used for religious worship of 1,609 hrs/yr, which yields
an analysis period of 1.9 years. However, users cannot select a
multiple of this analysis period when using Crystal Ball[supreg] due to
the nature of the LCC spreadsheet. For detail on additional results,
please see Chapter 8 and Appendix 8B of the TSD.
v. Effective Date
For purposes of this discussion, the ``effective date'' is the
future date when a new standard becomes operative (i.e., the date by
and after which lamp manufacturers must manufacture products that
comply with the standard). DOE publication of a final rule in this
standards rulemaking is scheduled for completion in June 2009. Pursuant
to sections 325(i)(3) and (5) of EPCA, the effective date of any new or
amended energy conservation standards for these lamps must be three
years after the final rule is published, which would be June 2012. (42
U.S.C. 6295(i)(3) and (i)(5)) DOE calculated the LCCs for all
consumers, based upon an assumption that each would purchase the new
product in the year the standard takes effect.
3. Payback Period Inputs
As explained above, the PBP is the amount of time it takes the
consumer to recover the estimated additional installed cost of more-
efficient products through energy cost savings only. Payback analysis
is a technique used to obtain a rough indication of whether an
investment is worthwhile. This type of calculation is known as a
``simple'' payback period because it does not take into account other
changes in operating expenses over time or the time value of money.
The inputs to the calculation of the PBP are the total installed
cost of the product to the customer for each efficacy level and the
annual (represented by first-year) operating expenditures for each
efficacy level. The PBP calculation uses the same inputs as the LCC
analysis, except that energy price trends and discount rates are not
needed. The calculation needs energy prices only for the year in which
a new standard is expected to take effect, in this case 2012.
4. Lamp Purchasing Events
GE, ACEEE, and PG&E all recommended that DOE should divide the lamp
market into three market segments: (1) New construction; (2) major
retrofit; and (3) replacement lamps; such an approach would allow DOE
to differentiate between the options facing consumers for those three
scenarios. (GE, No. 4.5 at p. 112; ACEEE, No. 4.5 at p. 113; PG&E, No.
4.5 at p. 113) GE, for example, commented that lumens can be kept
constant with the baseline system for new construction, whereas for the
replacement lamp market segment, lumens may be higher than the baseline
system. (GE, No. 4.5 at p. 122) In response, DOE agrees with
stakeholders on this point and has broken the LCC and NIA into several
market segments or ``lamp purchasing events'' to represent the lamp-
and-ballast designs facing consumers under each scenario. These ``lamp
purchasing events'' are described below. Although DOE considers in the
LCC only those energy-saving design options which reduce lumen output
by 10 percent or less, all other design options facing consumers are
considered in the NIA.
To further explain, DOE designed the LCC analysis for this
rulemaking around scenarios where consumers have a need to replace a
lamp; these are collectively referred to as ``lamp purchasing events.''
Each of these events may present the consumer with a different set of
technology options and, therefore, a
[[Page 13664]]
different set of LCC savings for a certain CSL. For GSFL, DOE
identified five possible scenarios under which consumers would purchase
a lamp and potentially be affected by a minimum energy conservation
standard. These scenarios are: (1) Lamp failure; (2) standards-induced
retrofit; (3) ballast failure; (4) ballast retrofit; and (5) new
construction/renovation. These five lamp purchasing events are
described in more detail below. (It is noted that for IRL, due to the
fact that there is no ballast involved, the scenario for the
incandescent lamp product classes is simply a lamp failure.) In
addition to the descriptions below, Table III.23 and Table III.24
summarize the lamp purchasing events considered in this analysis.
Lamp Failure (Event I): This event reflects a scenario in
which a lamp either fails (spot-relamping) or is about to fail (group
relamping) and must be replaced. In the absence of the energy
conservation standard, the analysis assumes an identical lamp would
have been installed as a replacement. However, under a lamp energy
conservation standards scenario, a standards-compliant lamp is required
which operates on the existing ballast. Thus, the first consumer
response to a lamp failure is expected to be a simple lamp replacement
with the same type of lamp. A second response occurs for owners of T12
systems. Unlike T8 lamps, there are certain lamp standard levels which
a T12 lamp cannot meet. These users would be required to purchase both
new lamps and ballasts in order to meet the lamp energy conservation
standard.
Standards-Induced Retrofit (Event II): This event reflects
a scenario in which an increase in the energy conservation standard for
lamps prompts end-users to retrofit both lamps and ballasts, whereas,
in the base case, they would otherwise have installed only a lamp due
to a lamp failure. This lamp purchasing event only applies to users
with T12 lamps because, unlike T8 lamps, there are certain lamp
standard levels which a T12 lamp cannot meet. This event contemplates a
scenario where users, under a lamp energy conservation standard, can no
longer purchase a T12 replacement lamp for their T12 ballast. For this
scenario, DOE assumes a uniform age distribution of T12 lamps
throughout the nation. Therefore, based on this age distribution, the
average T12 lamp is halfway through its lifetime. Consumers in the base
case purchase only a lamp after the average T12 lamp has died (i.e.,
after it has lived through the second half of its lifetime). Consumers
in the standards case choose to change both the lamp and the ballast
early, instead of waiting for their T12 lamps to fail. Therefore, in
the standards case, a lamp-and-ballast purchase would occur at the
beginning of the analysis, before the average lamp being replaced has
failed.
Ballast Failure (Event III): This event reflects a
scenario in which the installed ballast has failed. DOE recognizes that
energy conservation standards for ballasts set by the 2000 Ballast Rule
and EPACT 2005 are effective in 2010. These standards ban the sale of
magnetic 4-foot medium bipin and 8-foot single pin slimline ballasts.
In addition, DOE believes that sales of magnetic ballasts that operate
8-foot recessed double contact high output lamps will be minimal after
2012. Therefore, in the baseline, users who had a magnetic T12 ballast
would be expected to replace it with an electronic T12 ballast. Users
who had a T8 ballast installed would be expected to replace it with a
T8 ballast. However, in the standards case, end-users would select a
standards-compliant lamp-ballast combination such that the system light
output never drops below 10 percent of the baseline system.
Ballast Retrofit (Event IV): This event applies only to
T12 users because, according to industry experts, the majority of
ballasts that are retrofitted are T12 lamp-and-ballast systems. As
opposed to the standards-induced retrofit event where end-users replace
only their lamps in the base case, end-users under this event replace
both their lamps and ballasts in the base case in order to save energy.
With standards, end-users will also retrofit their old lamps and
ballasts, but with standards-compliant lamps. DOE assumes that end-
users continue to use the existing fixture and replace only the
ballast. Because the spatial layout in the building space is
constrained by the number of fixtures, light output of the replacement
lamp-and-ballast system is maintained.
New Construction and Renovation (Event V): This lamp
purchasing event encompasses all the new fixture installations where
the lighting design will be completely new or can be completely
changed. This scenario is only applicable to those baseline lamps that
are usually used in new construction and renovation (4-foot T8s, 8-foot
single pin slimline T8s, and 8-foot recessed double contact HO T12s).
In this scenario, the spatial layout of fixtures in the building space
is not constrained to any previous configuration. Because new fixtures
can be installed, consumers could install a lamp-and-ballast system
that would not maintain the light output of the baseline system. For
instance, if light output of the standards case system is lower than
the base case system, consumers can increase the number of standards
case lamp-and-ballast systems installed in the building by a certain
percentage to maintain the light output of base case lamp-and-ballast
systems.
Table III.23 and Table III.24 outline the events and actions taken
by consumers in response to those events both in the base case and the
standards case.
Table III.23.--Framework of Event-Type Scenarios for T12 Lamps
------------------------------------------------------------------------
Event Base-case action Standards-case action
------------------------------------------------------------------------
Event I. Lamp Failure......... (a) Installs a Installs a lower-
T12 lamp. wattage, higher
efficacy lamp, where
the system light
output never drops
below 10 percent of
the baseline system.
(b) Installs a Installs a T12 or T8
T12 lamp. electronic ballast
and lamp, where the
system light output
never drops below 10
percent of the
baseline system.
Event II. Standards-Induced Replace T12 lamp Installs a new T12 or
Retrofit. halfway through T8 electronic
analysis ballast and lamp,
period.\53\ where the system
light output never
drops below 10
percent of the
baseline system.
Event III. Ballast Failure.... Installs a T12 Installs a new T12 or
electronic T8 ballast and
ballast and lamps, where the
lamps in the system light output
existing fixture. never drops below 10
percent of the
baseline system.
[[Page 13665]]
Event IV. Ballast Retrofit.... Installs a T8 Installs a new T12 or
electronic T8 ballast and
ballast and lamps, where the
lamps in the system light output
existing fixture. never drops below 10
percent of the
baseline system.
Event V. New Construction and Installs a new Installs a new T12 or
Renovation. T12 system. T8 system that is
where the system
light output never
drops below 10
percent of the
baseline system.
Light output can be
maintained through
spacing.
------------------------------------------------------------------------
Table III.24.--Framework of Event-Type Scenarios for T8 Lamps
------------------------------------------------------------------------
Event Base-case action Standards-case action
------------------------------------------------------------------------
Event I. Lamp Failure......... Installs a T8 Installs a lower-
lamp. wattage, higher
efficacy lamp, where
the system light
output never drops
below 10 percent of
the baseline system.
Event III. Ballast Failure.... Installs a T8 Installs a new T8
electronic ballast and lamps,
ballast and where the system
lamps in the light output never
existing fixture. drops below 10
percent of the
baseline system.
Event V. New Construction and Installs a new T8 Installs a new T8
Renovation. system. system, where the
system light output
never drops below 10
percent of the
baseline system.
Light output can be
maintained through
spacing.
------------------------------------------------------------------------
5. Life-Cycle Cost and Payback Period Results
---------------------------------------------------------------------------
\53\ Event Type II represents a standards-induced retrofit where
lamps are substituted before the end of their lifetime. DOE assumed
that lamps lived to half of their average lifetime when substituted
under this scenario.
---------------------------------------------------------------------------
DOE calculated the average LCC savings relative to the base-case
forecast for each product class. As mentioned above, the base case
consists of the projected pattern of product purchases that would occur
in the absence of new energy conservation standards.
DOE did not explicitly discuss aggregating results of the LCC and
PBP analyses in the Framework Document, but stakeholders identified
this as a critical issue and submitted comment thereon. For example,
ACEEE commented that DOE should weigh its results for the three market
segments it considered--new construction, retrofit, and lamp
replacement--by their percentage of sales. (Public Meeting Transcript,
No. 4.5 at pp. 118-119) The Joint Comment also recommended that DOE
should weigh its results by market segment. (Joint Comment, No. 9 at p.
5) In addition, ACEEE commented that some of the higher efficacy lamp
substitutes could have higher wattages than their replacement. (Public
Meeting Transcript, No. 4.5 at pp. 118-119)
DOE recognizes that different lamp consumers will be impacted
differently by a new standard depending on the market segment to which
they belong. To model these different situations, the LCC analysis is
designed around scenarios--the ``lamp purchasing events''--where
consumers have a need to replace a lamp. The LCC spreadsheet calculates
the LCC impacts for each of these scenarios separately. Looking at the
impacts on each scenario separately allows one to view the results of
many subgroup populations in the LCC analyses.
For the ANOPR, DOE decided not to aggregate the results of the
various event scenarios together into a single LCC at each CSL. To do
so would have required too many assumptions, such as: (1) The relative
occurrence of each event over time, or (2) the market share of each
lamp in the base case and each standards case. Another argument against
aggregating the LCC results stems from the fact that the LCC analysis
only considers energy-saving lamp or lamp-and-ballast designs. As ACEEE
commented, consumers may elect options that save no energy or perhaps
consume more energy. (Public Meeting Transcript, No. 4.5 at pp. 118-
119) Finally, aggregating the results of the LCC analysis events blurs
the lines with the NIA analysis. DOE believes it is more appropriate to
incorporate assumptions about consumer decisions and long-term market
trends in the NIA, and leave the LCC as a direct head-to-head
comparison between lamp and lamp-and-ballast designs under different
scenarios or ``events.'' Note further that the LCC savings results help
DOE estimate consumer behavior decisions for the NIA.
DOE recognizes that the large number of LCC and PBP results can
make it difficult to draw conclusions about the cost-effectiveness of
CSLs. The following presents partial results from the LCC analysis. The
LCC results are presented according to the lamp purchasing events that
culminate in purchase of lamp-and-ballast designs. These results are
for a subset of all of the possible events, although they represent the
most prevalent purchasing events (events I(b) and IV have been omitted
in this notice but are presented in the TSD). A range of the LCC
savings and PBP are given for each CSL. The range reflects the results
of multiple systems (i.e., multiple lamp-ballast pairings) which
consumers could purchase to meet a CSL. In addition, DOE has chosen not
to present detailed PBP results by CSL in this ANOPR because DOE
believes that, given the drawbacks to PBP discussed earlier, the short
lifetime of IRL and the systems nature of GSFL, LCC results are a
better measure of cost-effectiveness. However, a full set of both LCC
and PBP results for the systems DOE analyzed are available in Chapter 8
of the TSD. DOE is presenting the partial results here to facilitate
comment on DOE's methodology of its analyses, and on the presentation
of its results.
a. General Service Fluorescent Lamps
Table III.25 through Table III.27 lists the result for one baseline
lamp in each of the three product classes DOE analyzed (i.e., 4-foot
medium bipin, 8-foot single pin slimline and 8-foot recessed double
contact HO). Throughout this section, the terms ``positive LCC
savings'' and ``negative LCC savings'' are used. When a standard
results in ``positive LCC savings,'' the life cycle cost of the
standards-compliant lamp is less than the life cycle cost of the
baseline lamp, and therefore, the consumer benefits. A
[[Page 13666]]
consumer is adversely affected when a standard results in ``negative
LCC savings'' (i.e., when the life cycle cost of the standards-
compliant lamp is higher than the life cycle cost of the baseline
lamp). The range of values given represents the multiple ways a
consumer can meet a certain CSL under each lamp purchasing event. For
example, at CSL3, a consumer in need of a lamp and ballast can either
purchase a high-efficacy T12 lamp on an electronic ballast or a high-
efficacy T8 lamp on an electronic ballast. While both these choices are
available to the consumer, the selection of a T8 system offers positive
LCC savings.
Table III.25 presents the findings of an LCC analysis on the 34W
T12 4-foot medium bipin GSFL baseline operating in the commercial
sector. Key inputs consist of using AEO2007 reference case electricity
prices, an analysis period of 5.5 years, and medium-range lamp and
ballast prices. Note that any standard level beyond CSL3 for this
baseline lamp would require a lamp and ballast replacement, since no
T12 lamp currently meets the efficacy requirements of CSL4. In
addition, because DOE is only presenting energy-saving options in the
LCC and because there are no energy-saving (or reduced wattage) lamp
replacement options for the 34W T12 lamp, Event I(a) which would
require only a lamp replacement is not shown. In general, one finds
that consumers who do switch from T12 to T8 lamps experience positive
LCC savings at all CSLs.
The positive LCC results for Event II are due to consumers that
replace a functioning 34W T12 lamp on a magnetic ballast with a high
efficacy T8 lamp on an electronic ballast. This situation occurs at
CSLs three through five. Negative LCC savings (i.e., increases in life-
cycle costs) are generally due to replacement of a functioning 34W T12
lamp on a magnetic ballast with a higher-efficacy T12 lamp on a T12
electronic ballast. This situation occurs at CSLs one through three.
(Both the T12 and T8 electronic substitutions result in negative LCC
savings at CSL2) These LCC results explain why consumers are electing
to replace their T12 magnetic systems with T8 electronic systems
instead of choosing T12 electronic ballast systems.
Event III represents consumers who are already faced with replacing
both a lamp and a ballast. The baseline ballast for this event is
assumed to be an electronic T12, since the ballast standards from the
2000 Ballast Rule and EPACT 2005 would be effective in 2010. Consumers
prompted by this event would experience positive LCC savings if they
purchase a high efficacy 4-foot T8 lamp on an electronic ballast at all
CSL levels. Negative LCC savings would occur if consumers replace a
functioning 34W T12 lamp on an electronic ballast with a high efficacy
T12 lamp. The LCC savings of Event III are greater than those of Event
II because in the base case of Event III consumers were faced with a
ballast replacement cost.
PBP results for Event II and III range from zero to 37.7 years. The
systems nature of the lamp LCC makes the payback period results
difficult to interpret. For example, LCC savings are positive for many
CSLs where the payback period exceeds the lifetime of the baseline lamp
which is approximately five years. When these paybacks are compared to
the lifetime of a lamp-ballast system of 15 years (spanning the life of
one ballast and three lamp replacements), the payback periods appear
much more acceptable. Payback periods longer than the lifetime of the
system are associated with negative LCC savings. The zero-year payback
(or instantaneous payback) also results from the systems nature of
these LCC results. For example, zero payback periods that appear for
Event III are due to the replacement of a more expensive electronic T12
ballast with a less expensive T8 electronic ballast. For more
information on PBP results refer to Chapter 8 of the TSD.
Table III.25.--LCC Results for a 3-Lamp 4-Foot Medium Bipin System Operating in the Commercial Sector*
----------------------------------------------------------------------------------------------------------------
LCC savings 2006$
-----------------------------------------------------
Candidate standard level Rated lamp efficacy lm/ Event II: standards-induced Event III: ballast
W retrofit (lamp & ballast failure (lamp &
replacement) ballast replacement)
----------------------------------------------------------------------------------------------------------------
CSL1............................ 82.4 -18.00 -2.02
CSL2............................ 85.3 to 86.2 -23.36 to -6.31 -9.05 to 8.01
CSL3............................ 90.8 to 91.2 -23.66 to 1.60 -9.34 to 15.92
CSL4............................ 92.3 to 95.0 5.01 to 6.26 19.33 to 20.58
CSL5............................ 95.4 to 97.3 4.88 to 16.96 19.19 to 31.28
----------------------------------------------------------------------------------------------------------------
* The results displayed are for the 34W T12 baseline lamp with a 5.5 yr analysis period. Additional results are
available in Chapter 8 of the TSD.
Table III.26 presents the findings of an LCC analysis on the 60W
T12 8-foot single pin slimline GSFL baseline lamp operating in the
commercial sector. Key inputs consist of using AEO2007 reference case
electricity prices, an analysis period of 4.0 years and medium-range
lamp and ballast prices. Note that any standard level beyond CSL3 for
this baseline lamp would require a lamp-and-ballast replacement, since
no T12 lamp currently meets the efficacy requirements of CSL3. In
general, consumers who do switch from a 60W T12 to a T8 lamp experience
positive LCC savings only if their ballast has already failed.
Event I is not shown because there are no energy-saving lamp
replacement options for a 60W T12 lamp. Event II represents consumers
who respond to higher lamp standards by replacing a functioning 60W T12
system with a new lamp and ballast. For this event, consumers
experience increased LCC at all CSLs. Event III represents consumers
who are already faced with replacing both a lamp and a ballast. The
baseline ballast for this event is assumed to be an electronic T12,
since the ballast standards from the 2000 Ballast Rule and EPACT 2005
would be effective in 2010. Consumers prompted by this event would
experience positive LCC savings if they purchase a high-efficacy 8-foot
single pin slimline T8 lamp on an electronic ballast. Negative LCC
savings would occur because some consumers who replace a functioning
60W T12 lamp on an electronic ballast with a high-efficacy T12 lamp on
an electronic ballast.
[[Page 13667]]
PBP results for Event II and III range from 2.7 to 20.7 years. For
more information on PBP results refer to Chapter 8 of the TSD.
Table III.26.--LCC Results for a 2-Lamp 8-Foot Single Pin Slimline System Operating in the Commercial Sector*
----------------------------------------------------------------------------------------------------------------
LCC savings 2006$
-----------------------------------------------------
Candidate standard level Rated lamp efficacy lm/W Event II: standards-induced Event III: ballast
retrofit (lamp & ballast failure (lamp & ballast
replacement) replacement)
----------------------------------------------------------------------------------------------------------------
CSL1\54\........................ 87.6 N/A N/A
CSL2............................ 92.6 -24.78 -3.04
CSL3............................ 94.8 to 97.5 -24.31 to -23.55 -2.56
CSL4............................ 98.2 -16.42 5.33
CSL5............................ 101.5 to 101.8 -15.68 to -13.73 6.06 to 8.02
----------------------------------------------------------------------------------------------------------------
*The results displayed are for the 60W T12 baseline lamp with a 6.0 yr analysis period. Additional results are
available in Chapter 8 of the TSD.
\\Table III.27 presents the findings of an LCC analysis for a 95W
T12 8-foot recessed double contact GSFL baseline lamp operating in the
industrial sector. Key inputs consist of using AEO2007 reference case
electricity prices, an analysis period of 2.3 years, and medium-range
lamp and ballast prices. Note that any standard level beyond CSL2 for
this baseline lamp would require a lamp and ballast replacement, since
no T12 lamp currently meets the efficacy requirements of CSL3. In
general, DOE's research indicates that consumers who do switch from a
95W T12 to a T8 lamp would experience positive LCC savings only if
their ballast has already failed or if they are renovating or
constructing a new building.
---------------------------------------------------------------------------
\54\ Because the 60W T12 baseline exceeds CSL1, there are no
energy saving design options at this level. There are, however,
energy saving design options at CSL1 for the 75W T12 baseline.
---------------------------------------------------------------------------
Event I is not shown because there are no energy-saving lamp
replacement options for a 95W T12 lamp. The positive LCC results for
Event II occur because some consumers replace a functioning 95W T12
lamp on an electronic ballast with a high-efficacy T8 lamp on an
electronic ballast. Negative LCC results are due to consumer
replacement of a functioning 95W T12 lamp on a magnetic ballast with a
high-efficacy T12 lamp on an electronic ballast. Events III and V
represent consumers who are already faced with replacing both a lamp
and a ballast. Consumers, prompted by these events, would experience
positive LCC savings if they purchase a high-efficacy T8 lamp on an
electronic ballast. Consumers would experience higher LCCs if they
replace a functioning 95W T12 lamp on an electronic ballast with a
high-efficacy T12 lamp on an electronic ballast. Under this scenario,
the lowest LCC occurs at CSL4.
PBP results for Event II, III, and V range from 3.2 to 64.8 years.
For more information on PBP results refer to Chapter 8 of the TSD.
Table III.27.--LCC Results for a 2-Lamp 8-Foot Recessed Double Contact HO System Operating in the Industrial
Sector*
----------------------------------------------------------------------------------------------------------------
LCC savings 2006$
-----------------------------------------------------
Event III: ballast
Candidate standard level Rated lamp efficacy lm/W Event II: standards-induced failure and event V:
retrofit (lamp & ballast new construction and
replacement) renovation (lamp &
ballast replacement)
----------------------------------------------------------------------------------------------------------------
CSL1............................ N/A \55\ N/A N/A
CSL2............................ 85.5 to 86.1 -36.86 -3.43
CSL3............................ 87.6 to 88.9 -47.10 to -46.48 -13.67 to -13.05
CSL4............................ 91.9 to 93.0 -24.12 to -21.19 9.32 to 12.25
CSL5............................ 95.3 -20.53 12.9
----------------------------------------------------------------------------------------------------------------
*The results displayed are for the 95W T12 baseline lamp with a 2.3-yr analysis period. Additional results are
available in Chapter 8 of the TSD.
\\Results for all GSFL events and baselines are presented in Table
8.5.1 to Table 8.5.16 of Chapter 8 in the TSD.
---------------------------------------------------------------------------
\55\ Because the 95W T12 baseline is only slightly below CSL1,
there are no energy saving design options at this level. There are,
however, energy saving design options at CSL1 for the 110W T12
baseline.
---------------------------------------------------------------------------
b. Incandescent Reflector Lamps
Table III.28 provides the LCC results for a 75W PAR38 IRL operating
in the commercial sector. These results are based on the AEO2007
reference case electricity prices, an analysis period of 0.9 years,\56\
and use of medium-range
[[Page 13668]]
lamp prices. Note that the lowest LCC (and highest LCC savings) occurs
at CSL3. PBP results for IRL range from 0.4 to 0.6 years. LCC and PBP
results for all IRL baseline lamps are available in Chapter 8 in the
TSD. More information about the lamps that meet each CSL are provided
in Chapter 5 of the TSD.
---------------------------------------------------------------------------
\56\ The service life of commercial IRL is shorter than GSFL
because the longest lived baseline IRL lamp is 3,000 hrs while the
baseline lamps for GSFL vary between 12,000 and 20,000 hours. In
addition, operating hours for commercial IRL are comparable to the
operating hours for commercial and industrial GSFL (3,450 for
commercial IRL and 3,435 for commercial GSFL or 4,795 for industrial
GSFL).
Table III.28.--LCC Results for a 75W PAR38 Operating in the Commercial
Sector*
------------------------------------------------------------------------
Rated lamp LCC savings
Candidate standard level efficacy lm/W 2006$
------------------------------------------------------------------------
CSL1.................................... 15.9 2.71
CSL2.................................... 17.5 3.92
CSL3.................................... 19.1 5.89
------------------------------------------------------------------------
*These results are for the 75W PAR38 baseline lamp. Additional results
are available in Chapter 8 of the TSD.
In summary, DOE presents these findings to facilitate public review
of the LCC and PBP analyses for this rulemaking. DOE seeks information
and comments relevant to the assumptions, methodology, and results for
all of these analyses. See Chapter 8 of the TSD for additional detail
on the LCC and PBP analyses and results. For results of the Monte-Carlo
model and other sensitivities refer to Appendix 8B of the TSD.
H. Shipment Analysis
This section presents the shipment analysis, which is an input into
the national impact analysis (NIA) (section III.I) and manufacturer
impact analysis (section III.K). DOE will undertake revisions to the
NIA, conduct the final manufacturer impact analysis (MIA), and then
report the findings from both in the NOPR.
As indicated above and in the NIA section below, DOE developed a
base-case shipment forecast for each analyzed lamp type to depict what
would happen to energy use, and to consumer costs for purchase and
operation of lamps, in the absence of new or revised energy
conservation standards. To evaluate the impacts of such standards for
these lamps, DOE compares the estimated base-case projection against
forecasted estimates of what would happen if DOE were to promulgate
standards for GSFL and IRL. One common element in the base-case and
standards-case forecasts is product shipments. In determining the base
case, DOE considered historical shipments, the mix of efficacies sold
in the absence of any new standards, and how that mix might change over
time.
DOE developed separate shipment models for GSFL and IRL. The GSFL
shipment model projects lumen growth by forecasting lumen demand
serviced by GSFL lamp type in the commercial and industrial sectors. In
accordance with historical shipment data, annual shipments are
forecasted for 8-foot recessed double contact HO lamps in the
industrial sector, and 4-foot medium bipin and 8-foot single pin
slimline lamps in the commercial sector. Due to their relatively small
shipment-based market share (approximately four percent) of the total
GSFL market, DOE decided--for the ANOPR only--not to forecast shipments
of or analyze the national impacts of standards on 2-foot U-shaped
lamps. However, for the NOPR, DOE does intend to scale the NIA results
from other product classes that were analyzed to the 2-foot U-shaped
lamp product classes, to develop estimates of the NES and NPV for this
lamp type. DOE may base the extrapolation of NIA results on relative
market shares, average incremental prices for each lamp design, or
average changes in energy consumption between lamp-and-ballast designs.
DOE invites comment on which of these or other scaling relationships it
should use for the NOPR.
The shipment model for IRL is based on the growth in the number of
sockets using these light sources in the commercial and residential
sectors. Based on manufacturer interviews, DOE forecasted shipments of
IRL in both the commercial and residential sectors. DOE invites comment
on the various sectors used to establish shipment forecast estimates
for GSFL and IRL.
DOE followed a consistent four-step process to forecast shipments
for GSFL and IRL. First, DOE used NEMA's historical shipment data from
2001 to 2005 to estimate total historical (NEMA member and non-NEMA
members) shipments of each analyzed lamp type in the sectors described
above. Second, using these historical shipments, DOE projected
shipments to 2011. Then, based on average service lifetimes, DOE
estimated a stock of lamps in 2011 for each lamp type. Third, DOE
forecasted lamp (and ballast for GSFL) shipments from 2012 to 2042 (the
analysis period for the NIA) by modeling various events, such as lamp
replacement or new construction. Because these shipments are dependent
on lamp and lamp-system properties (e.g., lifetime and lumen output),
as a fourth step, DOE developed base-case and standards-case market-
share matrices. These market-share matrices determine the forecasted
technology mixes in the lamp stock and shipments. Each of these
analytical steps in the shipment analysis is discussed in further
detail below.
1. Historical Shipments
GE and NEMA both commented that historical shipment data should be
used as an input to the fluorescent and incandescent lamp shipment
models. (Public Meeting Transcript, No. 4.5 at p. 198; NEMA, No. 12 at
p. 2) NEMA provided shipment data on GSFL and IRL spanning 2001 to
2005. Recognizing that these shipment figures cover only NEMA members,
based on manufacturer interviews DOE increased these estimates slightly
to account for the volume of fluorescent and incandescent lamps that
are imported and/or manufactured by non-NEMA lamp companies. A list of
lighting-related NEMA member companies and several lists including
various lighting-related non-NEMA member companies can be found in
Chapter 3 of the TSD.
Because certain ER and BR shaped IRL (BR 30 and BR40 65 Watt) are
statutorily exempted from energy conservation standards, DOE used
manufacturer product catalogs to estimate the market share of those
exempted products. As research indicated that these exempted products
constitute approximately 60 percent of all incandescent (non-halogen)
IRL shipments, DOE accounted for this when using the NEMA historical
shipments data. In addition, to model
[[Page 13669]]
IRL operated in the commercial sector separately from those operated in
the residential sector, DOE used a reflector lamp study conducted by
the New York State Energy Research and Development Authority \57\ with
additional shipment data submitted by NEMA (NEMA, No. 17 at p. 2) \58\
to estimate the percentage of incandescent and halogen IRL shipments by
sector.
---------------------------------------------------------------------------
\57\ New York State Energy Research and Development Authority,
Incandescent Reflector Lamps Study of Proposed Energy Efficiency
Standards for New York State (2006). (Last accessed October 7, 2006
at: http://www.nyserda.org/publications/Report%2006-07-Complete%20report-web.pdf.) The October 7, 2006 material from this
Web site is available in Docket EE-2006-STD-0131.
\58\ This written comment, document number 17, was submitted in
response to the Energy Conservation Program for Commercial and
Industrial Equipment: High-Intensity Discharge (HID) Lamps and is
available in Docket EE-DET-03-001.
---------------------------------------------------------------------------
In addition, because GSFL of different correlated color
temperatures (CCTs) were not segregated in the NEMA historical shipment
data, DOE decided to analyze and forecast shipments of each lamp type,
aggregating across the lamps of low (less than or equal to 4,500K) and
high (greater than 4,500K) CCT. Similarly, DOE forecasts IRL shipments
by aggregating across the standard-spectrum and modified-spectrum
lamps. In both of these cases of aggregation, DOE used a representative
product class to evaluate lamp designs and believes that the national
impacts will be similar for those product classes not directly
analyzed. Specifically, for GSFL, DOE used lamp designs with CCT less
than or equal to 4,500K to represent both low-CCT and high-CCT lamps.
For IRL, DOE used standard-spectrum lamp designs to represent the
markets of both standard-spectrum and modified-spectrum reflector
lamps. In addition, by aggregating the previously-discussed product
classes, DOE assumes that there will be no significant migration of
shipments or stock between lamps of different CCTs or spectrums. DOE
invites comment on this aggregation of product classes in the shipment
analysis and NIA. Details regarding scaling and usage of NEMA's
historical shipments can be found in Chapter 9 of the TSD.
2. Shipment Projections to 2011 and Calculations of Stock of Lamps in
2011
DOE estimated shipments to 2011 for GSFL and IRL by linearly
extrapolating historical shipment data (from 2001 to 2005) of each lamp
type. In addition, DOE also accounts for efficacy standards (effective
in 2008) for small diameter and ER and BR shaped lamps prescribed by
EISA 2007. DOE expects that the result of these standards is that by
2008, all IRL shipments covered in this rulemaking will be of products
using halogen technology. Because halogen lamps generally have longer
lifetimes than their incandescent counterparts, and are therefore
replaced (and shipped) less often, DOE has applied a reduction to its
projection of IRL shipments after 2007. DOE invites comment on the
shipment projections to 2011 for GSFL and IRL.
The stock of lamps in 2011 was estimated by summing annual
shipments backward from 2011. For each lamp type, DOE summed shipments
for the number of years that corresponds to the average lifetime of
that lamp type. For GSFL, this initial lamp stock is converted into an
initial lamp-and-ballast system stock. DOE extrapolated the ballast age
profile of each lamp system type by considering historical shipments
from census data for electronic and magnetic ballasts and historical
growth in lumen demand. Since DOE determined that the 2011 lamp stock
of 8-foot T8 recessed double contact HO are a small minority of the
total GSFL stock, DOE disregarded this initial lamp stock in its
shipment forecast. However, as discussed later, DOE did capture future
shipments of these lamps as they replace 8-foot T12 recessed double
contact HO systems. DOE invites comment on the methodology and data
sources used to estimate initial lamp stocks in the year 2011, in
particular its treatment on 8-foot T8 recessed double contact HO lamps.
3. Base-Case and Standards-Case Shipment Forecasts to 2042
The shipment models DOE developed for the ANOPR each consider
specific market segments in developing their estimate of annual
shipments. For all lamp types, DOE accounts for two lamp purchase
events (corresponding to those discussed in Section III.G): (1) Lamp
replacement following a lamp failure (Event I); and (2) new
construction (Event V). In addition, for the GSFL shipment models, DOE
models two additional lamp purchase events--lamp-and-ballast systems
installed following a ballast failure (Event III), and lamp-and-ballast
systems installed due to lamp system retrofit (an aggregation of Events
II and IV).
ACEEE and the Joint Comment recommended that DOE should weigh the
analytical results for GSFL by market segment. (Public Meeting
Transcript, No. 4.5 at pp. 118-119; Joint Comment, No. 9 at p. 5) In
response, DOE implicitly weighs the occurrence of new construction,
retrofit, and replacement lamp sales based on stock turnover in the
shipment model. DOE's determination of shipments due to new
construction assumes a 1.6 percent per year lumen growth rate. DOE
estimated a 1.6 percent per year lumen growth rate based on the latest
CBECS data on growth of building floor space. Shipments due to ballast
replacement are based on a ballast inventory model with a 14-year
ballast lifetime in the commercial sector and a 10-year ballast
lifetime in the industrial sector. To account for consumer reactions in
response to higher total installed costs of certain systems, DOE
assumes that the retrofit rates (or rates of early ballast retirement)
of these systems increase as the CSLs increase. Finally, DOE calculated
the market share of lamp replacements in the GSFL shipment model as a
function of the average lamp lifetime of the lamp designs chosen. For
more information, see Chapter 9 of the TSD.
GE and NEMA both recommended that DOE should develop its lamp
shipment forecast based on lamp shipments, rather than a ballast
inventory model. (Public Meeting Transcript, No. 4.5 at pp. 193-194;
NEMA, No. 8 at p. 3) In response, DOE did use the lamp shipment data
provided by NEMA and has calibrated its shipment models using
historical shipment data. However, for the fluorescent lamp shipment
analysis (and NIA), based on this historical lamp shipment data and
2002 and 2005 U.S. Census Bureau data, DOE developed a ballast
inventory model for several reasons. For example, DOE needs to capture
and track the anticipated decline in BF that would occur in the ballast
inventory (or stock) in standards cases as discussed earlier. This
decline in BF is critical to tracking the NIA calculations and results.
Also, by modeling the ballast stock and its turnover, DOE was able to
model the occurrence of lamp-and-ballast purchase events, as described
earlier.
In their comments on the Framework Document, GE and the Joint
Commenter emphasized the importance of accounting for wider fixture
spacing of higher-lumen-output systems in the new construction/
remodeling market. (Joint Comment, No. 9 at p. 5; Public Meeting
Transcript, No. 4.5 at pp. 119-120) In response, DOE notes that the
fluorescent shipment model's base-case and standards-case forecasts
account for this effect by allowing installed systems to have a range
of light outputs. DOE then normalizes the total lumen output due to new
construction by decreasing or increasing the number of shipments
[[Page 13670]]
based on the average lumen output per system.
For IRL, the shipment forecasts are based on a stock turnover
(i.e., lamp replacements upon lamp failure) and growth in the number of
sockets in use (through new construction). DOE assumed a 1.6 percent
growth rate in lamp sockets per year for the commercial sector and 1.3
percent growth rate per year for the residential sector. DOE based
these estimates on the latest CBECS and RECS forecasts of square
footage growth in these respective sectors. The rate of stock turnover
from one lamp technology to another and the total number of shipments
depend upon operating hours and the lifetimes of shipped lamps.
DOE also received comments from ACEEE and NEMA remarking that DOE
should be aware of any clear trends in historical shipment data and
that these trends should be reflected in the base-case shipment model.
(Public Meeting Transcript, No. 4.5 at p. 194; NEMA, No. 12 at p. 2)
DOE took these comments into account when developing its analytical
approach, using the data on market trends provided by NEMA as well as
manufacturer and expert interviews to establish base-case trends. For
example, for GSFL, DOE mimicked historical trends and modeled a shift
from magnetic to electronic ballasts in both the 4-foot medium bipin
and 8-foot single pin slimline markets. For the 8-foot T12 recessed
double contact HO lamp, DOE modeled it as having no new construction,
because historical shipments have indicated that its market is
relatively flat. In addition, DOE incorporated historical market trends
in the GSFL model by controlling the types of systems shipped to
account for new construction and retrofits. DOE invites further
comments on other trends that should be modeled in its shipment
forecasts, particularly for GSFL.
For IRL, a significant source of uncertainty in the base-case lamp
forecasts involves the potential for rapidly-emerging new lighting
technologies to enter the market. For example, the residential market
is already being transformed by the rapid increase in reflector CFL
sales. CFL can be three to four times more efficient and last several
times longer than the incandescent lamps they are replacing.
Assumptions made in the base-case lamp forecast about any change in
market share for CFL greatly impact the energy savings and NPV benefits
that could result from standards. Yet in comparison to solid-state
lighting (SSL) sources,\59\ CFL are a ``mature'' technology, with
relatively predictable price, efficacy, and lifetime attributes.
Technology forecasts about the potential attributes of SSL sources
suggest that they may achieve efficacies twice that of CFL and may last
up to ten times longer. Clearly, if SSL technology achieved such
promise, it would radically impact the benefits calculations from
potential standards. However, in order to calculate the energy savings
and NPV benefits, DOE would need to accurately forecast the anticipated
price and performance points of an emerging technology such as SSL,
which would be extremely difficult and speculative.
---------------------------------------------------------------------------
\59\ ``SSL source'' refer to a lighting technology using light-
emitting diodes (LEDs).
---------------------------------------------------------------------------
Therefore, in this rulemaking, DOE plans to account for the market
impact of these emerging technologies in the NIA by deducting the
anticipated emerging technology market share from the installed base.
DOE would estimate the market shares of these technologies in the
future (absent standards) by deducting that market share from the base
case of impacted customers. This methodology would effectively reduce
the size of the market impacted by energy conservation standards,
without requiring DOE to prepare estimates of the price and efficacy of
those emerging technologies for the NIA model. Thus, DOE could
incorporate the impact of emerging technologies in the base-case and
standards-case, without having to prepare uncertain forecasts for those
emerging technologies. DOE believes that reducing the number of
affected consumers is the most appropriate approach for this rulemaking
because: (1) the efficacies of the emerging technologies are projected
to be much higher than those that can be achieved by incandescent-based
lamps; and (2) the emerging technology lamps are not yet subject to any
DOE regulation, and, therefore, consumers would be migrating to non-
covered, substitute lamps.
For the ANOPR, DOE is estimating that the market penetration of
these emerging technologies (e.g., SSL, Ceramic Metal Halide, CFL) will
be 50% of the IRL sockets in the installed base by the year 2042. DOE
requests comment on this methodology used in the ANOPR for
incorporating emerging technologies in the base-case forecasts. In
addition, DOE seeks input on reasonable market-share estimates for GSFL
and IRL in order to properly bound the range of potential energy
savings and NPV that would result from standards.
4. Market-Share Matrices
As discussed in the engineering analysis (Section III.C) and the
LCC analysis (section III.G), consumers have available to them a
variety of choices in terms of lamps and lamp systems. When choosing
lighting systems, consumers often make their choice after considering
lamp attributes such as lifetime, efficacy, price, lumen output, rated
wattage, and total system power. As discussed earlier, the shipments
for GSFL and IRL depend on input assumptions, including lamp lifetime
and system lumen output. In addition, other lamp or lamp-system
properties such as price and energy consumption are key inputs to the
NES and NPV calculations. Therefore, within each product class, DOE
believes it necessary to directly account for the mix of technologies
which consumers select in the base case and standards case. In order to
account for the range of possible consumer choices, DOE developed and
populated technology market-share matrices. These market-share matrices
allocate percentage market shares to each of the lamp technologies for
the base case and standards case, either by proportioning lamp
shipments or lamp stocks. As discussed in the NIA (Section III.I), the
base-case and standards-case efficacy forecasts are also dependent on
the market-share matrices.
a. General Service Fluorescent Lamps
The GSFL shipment model incorporates several separate market-share
matrices to characterize shipments of lamps and lamp-and-ballast
systems at different times during the analysis period. For each
analyzed system type (e.g., 4-foot T8 medium bipin), DOE defines
market-share matrices for the ballasts installed before 2012 versus new
ballasts installed in 2012 and later. This enables the GSFL shipment
model to capture a migration to different lamp-and-ballast designs over
time in both the base and standards cases.
At the Public Meeting, PG&E commented that, by the effective date
of the standard, it is expected that commercial fluorescent lighting
fixtures will be considerably improved. (Public Meeting Transcript, No.
4.5 at p. 113) In addition, NWPCC generally commented that typical BFs
may change between the current stock and the stock in 2012. (Public
Meeting Transcript, No. 4.5 at p. 175) In response, DOE recognizes that
fluorescent lighting systems will likely improve and that the ballast
factors (BFs) may change over time. DOE populated the 2012 base-case
market-share matrix (including BFs) based on
[[Page 13671]]
discussions with industry experts, manufacturer interviews, and a
review of available products. DOE can alter the inputs into the base-
case market-share matrix (the technology mix in 2012) to reflect any
level of improvement in lighting fixtures by 2012. In addition, the
base-case GSFL shipment forecast has the ability to model improvement
in lighting systems and shifts in BFs after 2012. Furthermore, if the
public were to present alternative forecast scenarios to those
considered for the ANOPR, the matrices are designed such that these
alternative scenarios could be modeled for the NOPR.
In addition, for the standards-case market-share matrices, DOE
implemented two shipment scenarios for fluorescent lamps: (1) ``roll-
up,'' and (2) ``shift.'' The ``roll-up'' scenario represents the
standards case assuming all product efficacies in the base case which
do not meet the standard would ``roll-up'' to meet the new standard
level. Those that were above the standard level are considered
unaffected and continue to purchase the same base-case lamp or lamp
system. The ``roll-up'' scenario characterizes consumers primarily
driven by the first-cost of the lamp, and they are restricted to
replacing their base-case lamp with an equal wattage lamp when
possible. The ``roll-up'' scenario, therefore, represents a lower bound
of energy-savings scenario.
The ``shift'' scenario models the standards case assuming all
product efficacies are affected by the standard (whether or not their
base-case efficacy meets the standard). This scenario, in which
consumers are driven by both lamp cost and energy savings, results in
an upper bound energy-savings scenario. A detailed description of the
two fluorescent standards-case scenarios can be found in Chapter 9 of
the TSD. DOE invites comment on the populated GSFL market-share
matrices in the base-case and both standards-case scenarios.
To illustrate the above approach, Table III.29 presents an example
of a market-share matrix for the GSFL shipment model. This matrix
characterizes the technology mix of new 4-foot T8 medium bipin lamp-
and-ballast systems shipped in 2012 and 2042 in the base case and at
CSL 3 under the shift scenario. Shipments of new systems in the
intermediate years can be characterized by a linear progression from
the 2012 technology mix to the 2042 technology mix. A separate market-
share matrix exists for 4-foot T8 medium bipin lamp purchases on pre-
existing ballasts. For this new system market-share matrix, the lamp-
and-ballast designs were generated by pairing each lamp with the three
ballasts with the most common BFs (0.88, 0.78, and 0.75) in the 4-foot
T8 medium bipin market. This produces both energy-saving and non-
energy-saving options. In the standards-case scenario shown, consumers
then shift to reduced-wattage lamps and/or lower BFs.
Table III.29.--Four-Foot T8 Medium Bipin Market-Share Matrix Under the Shift Scenario
----------------------------------------------------------------------------------------------------------------
Mix of New Lamp-and-Ballast Systems Purchased
-----------------------------------------------------------------------------------------------------------------
Base case CSL3
-----------------------------------------------
CSL Lamp-and-ballast design 2012 2042 2012 2042
(percent) (percent) (percent) (percent)
----------------------------------------------------------------------------------------------------------------
Electronic Ballast Factor
----------------------------------------------------------------------------------------------------------------
0.88
2............................. 32.5 W, 86.2 lm/W........... 43 8 .......... ..........
3............................. 32.5 W, 90.8 lm/W........... 29 10 0 0
4............................. 32.5 W, 92.3 lm/W........... 11 14 0 0
4............................. 30 W, 92.3 lm/W............. 0 3 11 14
5............................. 32.5 W, 95.4 lm/W........... 7 12 7 12
5............................. 28 W, 97.3 lm/W............. 0 3 0 3
5............................. 25 W, 96 lm/W............... 0 4 0 0
0.78
2............................. 32.5 W, 86.2 lm/W........... 0 4 .......... ..........
3............................. 32.5 W, 90.8 lm/W........... 0 0 43 8
4............................. 32.5 W, 92.3 lm/W........... 0 6 29 10
4............................. 30 W, 92.3 lm/W............. 2 6 0 0
5............................. 32.5 W, 95.4 lm/W........... 0 6 0 0
5............................. 28 W, 97.3 lm/W............. 3 7 0 4
5............................. 25 W, 96 lm/W............... 0 4 3 7
0.75
2............................. 32.5 W, 86.2 lm/W........... 0 0 .......... ..........
3............................. 32.5 W, 90.8 lm/W........... 0 0 0 10
4............................. 32.5 W, 92.3 lm/W........... 0 0 0 9
4............................. 30 W, 92.3 lm/W............. 2 6 0 0
5............................. 32.5 W, 95.4 lm/W........... 0 0 0 0
5............................. 28 W, 97.3 lm/W............. 3 7 7 19
5............................. 25 W, 96 lm/W............... 0 0 0 4
-----------------------------------------------
Total..................... ............................ 100 100 100 100
----------------------------------------------------------------------------------------------------------------
b. Incandescent Reflector Lamps
Similar to the GSFL model, the IRL shipment model use market-share
matrices to project shipments. The IRL commercial and residential
shipment models separately designate stock technology mixes in the
years 2012 and 2042. These market-share matrices also present the
available lamp designs in the standards case for which the stock
technology mix is also characterized in one intermediate year. DOE
developed percentage inputs for the IRL market-share matrices based on
an examination of manufacturer product catalogs,
[[Page 13672]]
historical shipment information, and interviews with manufacturers.
Table III.30 presents an example of a market-share matrix for the
commercial IRL shipment model. This matrix characterizes the stock
technology mix of IRL in the years 2011 and 2042 in the base case, and
in the years 2013 and 2042 at CSL 2. DOE chooses to characterize the
stock in 2013 because DOE projects that by then the majority of the
base-case commercial IRL stock would have turned over to be standards
compliant. In the base case, DOE predicts a decline in halogen
technology lamps and a rise in more-efficient HIR lamps. At CSL 2, all
IRL must meet an HIR standard.
Table III.30.--Market-Share Matrix for Commercial IRL Sockets
----------------------------------------------------------------------------------------------------------------
Percentage of
Percentage stock in 2013
Candidate standard level Lamp design stock in 2011 (Standards Percentage of
(Base case case input stock in 2042
input only) only)
----------------------------------------------------------------------------------------------------------------
Base Case.......................... 90 W, 14.6 lm/W, 2500 hrs, 33 .............. 21
Halogen.
75 W, 14.0 lm/W, 2500 hrs, 26 .............. 16
Halogen.
50 W, 11.6 lm/W, 3000 hrs, 22 .............. 14
Halogen.
70 W, 18.0 lm/W, 3000 hrs, 8 .............. 21
HIR.
60 W, 17.5 lm/W, 3000 hrs, 6 .............. 16
HIR.
41.3 W, 15.0 m/W, 3000 hrs, 5 .............. 14
HIR.
-----------------------------------------------
Total..................... 100 .............. 100
-----------------------------------------------
CSL2............................... 70 W, 18.0 lm/W, 3000 hrs, .............. 41 41
HIR.
60 W, 17.5 lm/W, 3000 hrs, .............. 32 32
HIR.
41.3 W, 15.0 m/W, 3000 hrs, .............. 27 27
HIR.
-----------------------------------------------
Total..................... .............. 100 100
----------------------------------------------------------------------------------------------------------------
In addition to modeling one main scenario for IRL shipments, in
order to capture the range of NES and NPV results possible, DOE created
two sensitivity scenarios in the IRL shipments analysis. In one
sensitivity scenario (termed ``65 Watt BR lamp substitution'') in the
standards case, DOE models a migration away from covered IRL toward
exempted 65 Watt BR 30 and 65 Watt BR 40 lamps. As discussed earlier,
EISA 2007 extended energy conservation standards coverage to certain ER
and BR while exempting others. DOE believes that as the efficacy
standards for IRL increase, some consumers who would normally purchase
a covered IRL may instead choose to purchase a higher-wattage, lower-
first-cost, exempted 65 Watt BR lamp. Although these exempted lamps do
not fall under the scope of this rulemaking, DOE has included a
sensitivity scenario incorporating this potential outcome, because it
affects NES and NPV results. Further discussion of this 65 Watt BR lamp
substitution sensitivity scenario can be found in Chapter 9 and
Appendix 9A of the TSD.
Regarding the second standards-case sensitivity scenario modeled,
EEI commented that consumers may choose to purchase a higher-wattage
lamp rather than a reduced-wattage lamp. (EEI, No. 7 at p. 1) If this
were to happen, consumers would operate lamps in the standards case
that gave them more lumens than they are modeled to be using in the
base case. To represent this scenario, DOE created a ``10-percent lumen
increase'' sensitivity scenario, which assumes that the residential IRL
market, on average, would produce ten percent more lumens under
standards scenarios. To achieve this increase in lumens, DOE models a
portion of IRL purchases at reduced wattages and others at constant or
higher wattages. Appendix 9A of the TSD presents both the market-share
matrix and results associated with this scenario.
Chapter 9 and Appendix 9A of the TSD presents all of the market-
share matrices used in the shipment models for GSFL and IRL. DOE
requests specific comment on the detailed matrices which represent the
underlying input assumptions for each of the shipment scenarios and
lamp types.
5. Shipment Forecast Results
Table III.31 and Table III.32 present the results of the base-case
shipment forecasts for GSFL and IRL, respectively. In those tables,
values provided for the years 2001 to 2005 present historical shipment
data, whereas the 2006 to 2011 shipments are linear extrapolations from
the historical shipments. The shipments estimated for 2012 to 2042 are
the projected unit shipments generated by the shipment models. This
section includes a general discussion of the market dynamics impacting
shipments in the standards cases. Chapter 9 of the TSD provides the
detailed numerical output of the standards-case shipment forecasts.
For GSFL, in accordance with historical shipment data, shipments of
4-foot T12 medium bipin and 8-foot T12 single pin slimline lamps in the
base case are expected to decline as the magnetic ballasts on which
those lamps are installed are no longer sold. These retired 4-foot T12
medium bipin and 8-foot T12 single pin slimline systems are expected to
be replaced with 4-foot T8 medium bipin lamp-and-ballast systems,
respectively. In addition, DOE forecasts that 90 percent of 8-foot T12
single pin slimline systems will be replaced with 4-foot T8 medium
bipin lamp systems, and 10 percent will be replaced with 8-foot T8
single pin slimline systems. This effect, along with the 4-foot T8
systems purchased for new construction, account for the expected
increase in 4-foot T8 and 8-foot T8 shipments. The base-case shipment
forecasts of 8-foot T12 recessed double contact HO are depicted as
constant, similar to the historical shipments.
The standards-case forecasts experience similar trends, though at
modified rates. At CSL1, CSL2, and CSL3, the early retrofit rates of 4-
foot T12 medium bipin and 8-foot T12 single pin slimline systems are
expected to increase, thereby accelerating the reduction in those
shipments while increasing shipments of 4-foot T8 medium bipin and 8-
foot T8 single pin slimline shipments. Because voluntary retrofits are
not incorporated in the 8-foot T12 recessed double contact HO model,
the standards-case shipment forecasts of these lamps at CSL1, CSL2,
[[Page 13673]]
and CSL3 are similar to the base-case forecast. In addition, because at
CSL 4 and CSL 5, 4-foot T12 medium bipin, 8-foot T12 single pin
slimline, and 8-foot T12 recessed double contact HO lamps are no longer
standards-compliant, these systems are automatically retrofitted upon
lamp failure.
Table III.31.--GSFL Shipments in the Base Case
[Millions]
----------------------------------------------------------------------------------------------------------------
8-foot T12
4-foot T12 4-foot T8 8-foot T12 8-foot T8 recessed
Year medium medium single pin single pin double
bipin bipin slimline slimline contact HO
----------------------------------------------------------------------------------------------------------------
2001........................................... 236 182 48 5 27
2003........................................... 202 191 41 6 27
2005........................................... 181 240 37 6 28
2007........................................... 151 262 32 7 27
2009........................................... 122 292 26 7 27
2012........................................... 111 425 17 9 31
2015........................................... 71 479 10 9 31
2020........................................... 22 584 3 10 31
2025........................................... ........... 657 ........... 10 31
2030........................................... ........... 705 ........... 10 31
2035........................................... ........... 775 ........... 10 31
2040........................................... ........... 874 ........... 10 31
2042........................................... ........... 889 ........... 10 31
Cumulative (2012-2042)......................... 556 20,812 78 305 971
----------------------------------------------------------------------------------------------------------------
The forecasted shipments beyond the year 2011 of covered IRL
(exempted BR and ER lamps are not included) are shown in Table III.32.
As demonstrated below, the shipments shown decrease over the analysis
period. There are two reasons why DOE projects shipments to decrease:
(1) Increased penetration of CFL and other long-lived emerging
technologies; and (2) historical growth in IRL stock (approximately 8
to 10 percent annually) which is significantly higher than the
historical growth rate in building floor space (i.e., 1.6 percent
annually in the commercial sector and 1.3 percent annually in the
residential sector). Given this inconsistency in growth rates, DOE
believes this high historical growth rate in IRL stock is unsustainable
in the long term, so DOE has tentatively decided to instead base IRL
socket growth after 2011 on the historical growth in building floor
space. This decrease in stock growth contributes to the expected
decline in IRL shipments.
In the standards case, shipments of IRL in both the commercial and
residential sectors are generally expected to decrease relative to the
base case, as longer-lived HIR and improved HIR lamps are incorporated
into the installed stock. In addition, for the 65 Watt BR lamp
substitution scenario, shipments of covered IRL decrease relative to
the base case due to the migration to exempted 65 Watt BR lamps.
Table III.32.--IRL Shipments in the Base Case
[Millions]
------------------------------------------------------------------------
Year Commercial Residential
------------------------------------------------------------------------
2001.................................... 67 66
2003.................................... 71 70
2005.................................... 83 85
2007.................................... 89 93
2009.................................... 92 85
2012.................................... 98 99
2015.................................... 98 98
2020.................................... 96 96
2025.................................... 94 93
2030.................................... 90 88
2035.................................... 86 83
2040.................................... 80 76
2042.................................... 77 74
Cumulative (2012-2042).................. 2,814 2,770
------------------------------------------------------------------------
Additional detail on the shipments analyses can be found in Chapter
9 of the TSD.
I. National Impact Analysis
The national impact analysis (NIA) assesses cumulative national
energy savings (NES) and the cumulative national economic impacts of
candidate standards levels. The analysis measures economic impacts
using the net present value (NPV) metric, which represents the net
present value (i.e., future amounts discounted to the present) of total
customer costs and savings expected to result from new standards at
specific efficacy levels. For a given CSL, DOE calculated the NPV, as
well as the NES, as the difference between a base case and the
standards-case forecasts. Detailed information on the national impacts
analysis can be found in Chapter 10 of the TSD.
[[Page 13674]]
DOE determined national annual energy consumption as the product of
the annual energy consumption per unit lamp system and the number of
total units in the installed stock. The per-unit annual energy
consumption is a function of lamp efficacy and lamp wattage (and BF in
the case of the GSFL). TSD Chapter 6, Energy-Use Characterization,
describes how the per-unit energy consumption varies as a function of
efficacy for each of the considered lamps. Cumulative energy savings
are the sum of the annual NES determined over a specified time period.
DOE calculated net economic savings each year as the difference between
total operating cost savings and increases in total installed costs.
Cumulative economic savings are the sum of the annual NPVs determined
over a specified time period.
1. Approach
In the standards case, more-efficacious products gradually replace
less-efficacious products over time. This affects calculations of both
the NES and NPV, which are both a function of the total number of units
in use and their efficacies, and thus depend on annual shipments and
the lifetime of a product. Both calculations start by first estimating
the installed lamp stock. As discussed in section III.H (Shipments
Analysis), new lamps (or, for GSFL, new lamp-and-ballast systems)
shipped over time are specified by market-share matrices. These
shipments are tracked through the analysis period to establish the
installed stock of lamps.
In the standards case, given that most consumers are likely to
install lamp systems with energy consumption less than or equal to
their base-case systems, the energy consumption per unit of capacity
used by the products in service gradually decreases in the standards
case relative to the base case. To estimate the resulting national
energy savings at each CSL, DOE followed a four-step process. First,
DOE calculated the national site-energy \60\ consumption for GSFL and
IRL for each year, beginning with the expected effective date of the
standards (2012) for the base-case forecast and each standards-case
forecast. Second, DOE determined the annual site-energy savings,
consisting of the difference in site-energy consumption between the
base case and the standards case. DOE also estimated and reported
additional heating, ventilating, and air conditioning (HVAC)
interaction savings associated with increased lamp efficacy in the
commercial sector. Third, DOE converted the annual site-energy savings
into the annual amount of energy saved at the source of electricity
generation (i.e., primary energy), using a site-to-source conversion
factor that varies by year (calculated from AEO 2007 projections).
Finally, DOE summed the annual source-energy savings from 2012 to 2042
to calculate the total NES for that period.
---------------------------------------------------------------------------
\60\ ``Site energy'' is the energy consumed by the lamp systems
directly as they are operated at the end-use site.
---------------------------------------------------------------------------
To estimate NPV, DOE calculated the net impact each year as the
difference between total operating cost savings (or the electricity
cost savings) and increases in total installed costs (which consist of
manufacturer selling price, sales taxes, and installation cost). DOE
calculated the national NPV at each CSL using a three-step process.
First, DOE determined the total product costs under the standards case
and the base case from the total installed cost (including product
prices, installation, and replacement costs as discussed in section
III.G.2.a) and shipments of lamps (or lamp-and-ballast systems).
Second, DOE determined the total operating costs in the base case and
standards case from electricity prices and the stock of lamps and lamp
systems. Third, DOE determined the difference between the net operating
cost savings and the net product cost increase to get the net savings
(or expense) for each year. DOE then discounted the annual net savings
(or expenses) to 2007 for lamps bought during the analysis period (2012
to 2042) and summed the discounted values to provide the NPV of a CSL.
An NPV greater than zero shows net savings (i.e., the CSL would reduce
customer expenditures relative to the base case in present-value
terms). An NPV that is less than zero indicates that the CSL would
result in a net increase in customer expenditures in present-value
terms.
2. Base-Case and Standards-Case Forecasted Efficacies
A key aspect of the estimates of NES and NPV is the proportion of
future lamp shipments meeting different efficacies for the base case
(without new standards) and each of the standards cases (with new
standards). Because key inputs to the calculation of the NES and NPV
are dependent on the estimate of the efficacies shipped, it is
important to know the projected efficacy-distribution of lamp
shipments. However, with regard to the calculation of the NES, it is
also important to note that the total energy savings per unit is not
solely dependent on the lamp efficacy, but also on the lamp wattage
(and BF for fluorescent lamps). Because most consumers select lamp
wattage when purchasing lamps, per-unit energy consumption for a
particular standards-case purchase is not necessarily less than per-
unit energy consumption for the corresponding base-case purchase. For
example, a higher-efficacy lamp can be purchased at the same wattage
under the standards case, thereby increasing lumen output without
reducing energy consumption. On the other hand, by installing an
equally-efficacious fluorescent lamp on a ballast with a lower BF, the
outcome can be a positive energy savings for that system. As discussed
in section III.H, the lamp systems available in the shipments forecast,
and ultimately in the NIA, incorporate consumer choices that encompass
both energy-saving and non-energy-saving options.
Also discussed in the shipments analysis (section III.H), the base-
case and standards-case forecasted efficacies are primarily determined
by inputs into the market-share matrices in both the fluorescent and
incandescent NIA models. As exemplified in Table III.33, the base-case
efficacy forecast of 4-foot medium bipin and 8-foot single pin slimline
lamps show a gradual increase in average efficacy due to both the
phasing out of T12 ballasts and the penetration of higher-efficacy T8
lamps. As T12 lamps are generally less efficacious than their T8
counterparts, the market shift toward T8 lamp-and-ballast systems
causes an overall increase in efficacies of shipped fluorescent lamps.
In addition, as T12 magnetic ballasts generally have higher system
powers than their electronic T8 counterparts, average system power
decreases overall. Due to the banning of magnetic ballasts by the 2000
Fluorescent Ballast rulemaking, by the year 2025, all magnetic T12
ballasts are expected to have retired from the installed stock, and the
increase in average lamp efficacy and decrease in average system power
slows. Because the installed stock of the 8-foot recessed double
contact HO lamp market is already predominantly operating on electronic
ballasts, the increase in average lamp efficacy and decrease in average
system power is solely due to the penetration of more-efficacious or
reduced-wattage lamps being installed on lower ballast factor ballasts.
[[Page 13675]]
Table III.33.--Base-Case Average Lamp Efficacy and System Power of the GSFL Stock
----------------------------------------------------------------------------------------------------------------
4-foot medium bipin 8-foot single pin 8-foot recessed double
-------------------------- slimline contact HO
---------------------------------------------------
Year Average Average Average
efficacy system Average Average Average system
lm/W power * W efficacy lm/ system efficacy lm/ power
W power ** W W [dagger] W
----------------------------------------------------------------------------------------------------------------
2012.............................. 87.9 93 91.3 135 83.0 198
2015.............................. 88.9 89 92.6 129 83.0 197
2020.............................. 90.0 85 95.7 116 83.3 197
2025.............................. 90.7 84 97.5 110 83.7 196
2030.............................. 91.3 82 98.0 109 84.1 194
2035.............................. 91.9 81 98.4 108 84.5 193
2042.............................. 92.8 79 99.1 107 85.0 192
----------------------------------------------------------------------------------------------------------------
* 4-foot medium bipin systems are lamp systems composed of either one or two ballasts and three lamps.
** 8-foot single pin slimline systems are lamp systems composed of one ballast and two lamps.
[dagger] 8-foot recessed double contact systems are lamp systems composed of one ballast and two lamps.
Improvement in stock efficacy for IRL is driven by shifts to more-
efficacious HIR technologies. For IRL, as discussed in the Shipments
Analysis (see section III.H.3), DOE reports only the improvement in
efficacy of the lamp sockets not migrating to non-IRL emerging
technologies such as solid-state lighting or ceramic metal halide. As
demonstrated in Table III.34 the average efficacy of the installed
stock of IRL is expected to increase during the analysis period.
Table III.34.--Base-Case Average Lamp Efficacy of the IRL Stock
------------------------------------------------------------------------
Average
Year efficacy lm/W
------------------------------------------------------------------------
2012.................................................... 13.7
2015.................................................... 13.8
2020.................................................... 13.8
2025.................................................... 13.8
2030.................................................... 13.9
2035.................................................... 13.9
2042.................................................... 13.9
------------------------------------------------------------------------
DOE invites comment on the base-case efficacy forecasts of GSFL and
IRL.
3. National Impact Analysis Inputs
Table III.35 summarizes the major inputs to the NES and NPV
spreadsheet models. For each input, the table provides a brief
description of the data source. For details on the entire national
impact analysis, see Chapter 10 of the ANOPR TSD.
Table III.35.--National Energy Saving and Net Present Value Inputs
------------------------------------------------------------------------
Input data Data description
------------------------------------------------------------------------
Shipments............................ Annual shipments from the GSFL
and IRL shipment models (see TSD
Chapter 9, Shipments Analysis).
Stock of Lamps....................... Established based on the 2011
lamp stock, the service life of
lamps and/or ballasts, and the
annual shipments. The initial
stock is based on historical
shipments and projected
shipments from 2006 to 2011.
(See TSD Chapter 9, Shipments
Analysis).
Effective Date of Standard........... 2012.
Analysis Period...................... 2012 to 2042.
Unit Energy Consumption (kWh/yr)..... Established in the Energy-Use
Characterization, TSD Chapter 6,
by lamp or lamp-and-ballast
design and sector.
Total Installed Cost................. Established in the Product Price
Determination, TSD Chapter 7 and
the LCC Analysis, TSD Chapter 8,
by lamp-and-ballast designs.
Electricity Price Forecast........... 2007 EIA Annual Energy Outlook
forecasts (to 2030) and
extrapolation for beyond 2030
(see TSD Chapter 8).
Electricity Site-to-Source Conversion Conversion varies yearly and is
generated by 2007 EIA Annual
Energy Outlook forecasts (to
2030) of electricity generation
and electricity-related losses.
Conversion factors for beyond
2030 are extrapolated.
HVAC Interaction Savings............. 6.25% of total energy savings in
the commercial sector.
Rebound Effect....................... 1% of total energy savings in the
commercial sector.
8.5% of total energy savings in
the residential sector.
Discount Rate........................ 3 and 7 percent real.
Present Year......................... Future costs and savings are
discounted to the year 2007.
------------------------------------------------------------------------
Inputs for the calculation of NES identified in Table III.35
include the analysis period, per-unit annual energy consumption,
shipments, lamp stock, site-to-source conversion factors, rebound
effect, and heating/ventilating/air conditioning (HVAC) interaction
savings. The following discussion provides further context and
information on these inputs.
One of the critical inputs to the NES and NPV calculations is the
analysis period. DOE received several comments at the Framework Meeting
regarding the appropriateness of 30 years as the duration of the
analysis period for a fluorescent and incandescent lamp NES. Both GE
and PG&E commented that because the life-cycle of fluorescent lighting
systems is approximately 15 or 20 years, a 30-year analysis period is
too long in the commercial sector. In addition, GE commented that
although incandescent lamps are often upgraded much sooner than 20
years, a 20-year analysis period could be used for
[[Page 13676]]
consistency with the GSFL analysis. (Public Meeting Transcript, No. 4.5
at pp.204-205) ACEEE commented that DOE should use a 30-year analysis
period for consistency with other rulemaking analyses. (Public Meeting
Transcript, No. 4.5 at pp. 205-206) In response, DOE recognizes that
the life-cycle of GSFL systems and IRL are all estimated to be less
than 30 years; however, DOE has tentatively decided to use an analysis
period from 2012 to 2042 for consistency with the shipment and national
impact analyses of other rulemakings.
Annual energy consumption per lamp system is used to calculate the
annual national energy consumption. For IRL, the lamp system is solely
composed of the incandescent lamp. For GSFL, DOE received a comment
from EEI urging DOE to consider system energy consumption in the
fluorescent lamp national impact analysis. EEI emphasized that the
ballast determines the energy savings in many situations. (EEI, No. 7
at p. 1) DOE recognizes the significance of EEI's comment and has
incorporated this approach into its analysis. Accordingly, for the
ANOPR, DOE considered GSFL lamp-and-ballast pairs, or systems, in
constructing its national impact analysis. Section III.D, Energy-Use
Characterization, provides the energy consumption of each lamp-and-
ballast pairing used in the national impact analysis.
The lamp stock in a given year is the number of lamps shipped from
earlier years to the present and which survive in the given year. The
NIA spreadsheet model keeps track of the number of units shipped each
year. As discussed in Section III.H, Shipments Analysis, DOE develops
its forecasted shipments for the base case from the initial stock of
fluorescent and incandescent lamps in the year before the effective
date of the standard (i.e., 2011).
For both GSFL and IRL, DOE developed market-share matrices
illustrating the technology migration of the stock. The growth in
stocks (either by lumen demand or by number of sockets in the field)
and the average lumen output per lamp result in a forecasted lumen
output for the commercial GSFL, industrial GSFL, commercial IRL, and
residential IRL markets over the analysis period. If DOE receives
comment that over-lighting or under-lighting in any of the markets will
result in a decrease in total shipments and total stock, DOE may make
such a stock adjustment for the NOPR. DOE invites comment on this
issue.
The site-to-source conversion factor is the multiplicative factor
DOE uses for converting site-energy consumption (the energy used at the
end-use site) into primary or source energy consumption (the energy
used at the source before transmission or conversion losses). For
electricity, the conversion factors vary over time due to projected
changes in generation sources (i.e., the power plant types projected to
provide electricity to the country). For the ANOPR, DOE calculated
annual average site-to-source conversion factors using EIA's AEO2007.
The conversion factors were derived by dividing the total energy used
to produce electricity in each forecast year in the United States, as
indicated in AEO2007, by the total electricity delivered for each
forecasted year. For example, the site-to-source conversion factor in
2012 is calculated to be 10,680 BTU/kWh.
DOE received multiple comments regarding the HVAC system
interaction with fluorescent lighting fixtures in the commercial
sector. EEI commented that DOE should account for this interaction
(both the reduction of AC loads and increase in heating loads) as an
effect of the standard in its national impacts analysis. (EEI, No. 7 at
p. 1; Public Meeting Transcript, No. 4.5 at p. 242) In addition, EEI
noted that a trend toward higher-efficacy HVAC systems may lower this
HVAC interaction with lighting. (Public Meeting Transcript, No. 4.5 at
pp. 159-160) Based on this comment, DOE has decided to include HVAC
interaction in its calculation of the NES (but not in the NPV
calculation). To account for HVAC energy savings, DOE used the analysis
completed by the 2000 Fluorescent Ballast rulemaking, which calculates
an HVAC interaction energy savings of 6.25 percent of total energy
savings.\61\ As EEI suggested, this analysis incorporates changes in
both heating and cooling loads as a result of the standard. The
analysis also involved calculating the lighting HVAC interaction energy
savings on buildings built before 1989 (5 percent of total energy
savings) and ones built from 1990 to 1995 (10 percent of total energy
savings). The ballast analysis assumed that over the analysis period,
the building stock would move from the 5 percent interaction factor
towards the 10 percent interaction factor. Using simple scaling
methods, 6.25 percent was used as an average interaction over the
entire analysis period. Using this same methodology for lamps, an
analysis period ranging from 2012 to 2042 would have a slightly higher
HVAC energy savings. However, DOE acknowledges EEI's comment that the
overall HVAC savings with lighting may also decrease due to more-
efficient heating and cooling systems. Considering these competing
factors, DOE believes it is reasonable to use 6.25 percent of total
energy savings as the HVAC energy savings in commercial sector for both
GSFL and IRL.
---------------------------------------------------------------------------
\61\ U.S. Department of Energy Office of Energy Efficiency and
Renewable Energy, Energy Conservation Program for Consumer Products:
Technical Support Document: Energy Efficiency Standards for Consumer
Products: Fluorescent Lamp Ballast Proposed Rule: Appendix B, pp. B-
23-B-30 (Jan. 2000). Available at: http://www.eere.energy.gov/buildings/appliance_standards/residential/pdfs/appendix_b.pdf
---------------------------------------------------------------------------
NWPCC commented that due to the increasing prevalence of air
conditioning systems, it would be worthwhile to analyze the heating
load of incandescent lamps on the HVAC systems in the residential
sector. (Public Meeting Transcript, No. 4.5 at pp. 162-163) GE then
responded that incandescent lamps have a minor effect on HVAC energy
usage, so such an analysis is not warranted. (Public Meeting
Transcript, No. 4.5 at p. 163) While DOE appreciates NWPCC's comment,
DOE believes that IRL will have a minor effect on HVAC energy usage in
the residential sector. Therefore, DOE has not included that
interaction in the NES analysis. DOE invites further comment on the
issue of HVAC interaction in both the commercial and residential
sectors.
In its analysis, DOE considered the rebound effect \62\ that occurs
after installation of energy-efficient lighting equipment. DOE examined
a summary of the literature regarding the rebound effect in relation to
lighting equipment.\63\ Based on four studies, the summary estimated
that, for a 100 percent increase in energy efficiency, values of
''take-back'' or rebound for residential lighting are between five and
twelve percent of the energy consumption savings. In addition, with
regards to a firm's response to higher-efficiency lighting, the summary
estimated zero to two percent for values of rebound for lighting.
Therefore, in the calculation of national energy savings due to energy
conservation standards on lighting, DOE used a rebound rate of 8.5
percent in the residential sector and one percent in the commercial and
industrial sectors. However, DOE notes that the summary of the
literature reports that the results of rebound due
[[Page 13677]]
to lighting are inconclusive. Thus, DOE invites comments on both the
inclusion and magnitude of the rebound effect for purposes of analyzing
the expected effects of this regulation.
---------------------------------------------------------------------------
\62\ Under economic theory, ``rebound effect'' refers to the
tendency of a consumer to respond to the cost savings associated
with more efficient equipment in a manner that actually leads to
marginally greater product usage, thereby diminishing some portion
of anticipated energy savings related to improved efficiency.
\63\ Greening, L.A., D.L. Greene, and C. Difiglio, ``Energy
efficiency and consumption--the rebound effect--a survey,'' 28
Energy Policy (2000), pp. 389-401.
---------------------------------------------------------------------------
The take-back in energy consumption associated with the rebound
effect provides consumers with increased value (e.g., increased lighted
hours, since the increased efficiency enables consumers to use their
lighting equipment for longer periods of time). The impact on consumers
is, thus, the sum of the change in the cost of owning the lighting
equipment (i.e., life-cycle cost) and the increased value for the
longer lit hours. However, DOE is unable to monetize this increase in
consumer value in the LCC analysis. DOE believes that, if it were able
to monetize the increased value to consumers added by the rebound
effect, this value would be at least as great as the value of the
foregone energy savings. For this analysis, DOE estimates that this
value is equivalent to the monetary value of the energy savings that
would have occurred without the rebound effect. Therefore, the economic
impacts on consumers with or without the rebound effect, as measured in
the LCC and NPV analyses, are the same.
The inputs to the NPV calculation are total installed cost per
unit, annual operating cost savings per unit, total annual installed
cost increases, total annual operating cost savings, discount factor,
present value of increased installed costs, and present value of
operating cost savings.
As discussed in section III.E, DOE has collected prices for GSFL
and IRL with varying wattages, efficacies, and lifetimes. In addition,
for GSFL, ballast prices are included in the analysis. The total
installed cost per unit, as described in section III.G, consists of
these manufacturer selling prices, labor costs, and sales tax.
The annual operating cost savings per unit incorporates changes in
electricity costs due to a standard efficacy level and lower energy
consumption per unit. As described previously, DOE forecasted the per-
unit annual electricity consumption. DOE forecasted electricity prices
based on EIA's AEO2007. By using both of these values, DOE is able to
establish the annual operating cost savings per unit.
The total annual installed cost increase is equal to the annual
change between the base case and standards case in the product of per-
unit total installed cost multiplied by the shipments forecasted of
each lamp or lamp-and-ballast design. The total annual operating cost
savings are equal to the change in the product of annual operating
costs per unit and the total lamp stock by lamp or lamp-and-ballast
design.
DOE multiplies monetary values in future years by the discount
factor to determine the present value. DOE estimated national impacts
using both a three-percent and a seven-percent real discount rate as
the average real rate of return on private investment in the U.S.
economy. DOE uses these discount rates in accordance with Office of
Management and Budget (OMB) guidance to Federal agencies on the
development of regulatory analysis (OMB Circular A-4, September 17,
2003), and section E, ``Identifying and Measuring Benefits and Costs,''
therein. DOE defines the present year as 2007.
The present value of increased installed costs is the annual
installed cost increase in each year (i.e., the difference between the
standards case and base case), discounted to the present, and summed
for the time period over which DOE is considering the installation of
product (i.e., from the effective date of standards, 2012, to the year
2042). The increase in total installed cost refers to both product cost
and installation cost associated with the higher energy efficacy of
product purchased in the standards case compared to the base case.
The present value of operating cost savings is the annual operating
cost savings (i.e., the difference between the base case and standards
case) discounted to the present, and summed over the period from the
effective date, 2012, to the time when the last unit installed in 2042
is retired from service. Savings are decreases in operating costs
associated with the higher energy efficacy of products purchased in the
standards case compared to the base case. Total annual operating cost
savings is the savings per unit multiplied by the number of units
surviving in a particular year.
4. National Impact Analysis Results
Tables III.36 through Table III.38 present the NES results
(including rebound effect and HVAC interactions where applicable) for
each CSL considered for GSFL and IRL. As mentioned in Section III.H,
due to the relatively small shipments-based market share of 2-foot U-
shaped lamps, national impact results for 2-foot U-shaped lamps are not
presented in the ANOPR. However, DOE does intend to estimate NES and
NPV results for these product classes in the NOPR. In addition, the
following NES and NPV values provide results for lamps of all covered
CCT for GSFL. For IRL, the results are representative for both the
standard-spectrum and modified-spectrum lamps.
As mentioned earlier in sections III.H.3 and III.H.4, in the GSFL
shipment model, when 8-foot T12 single pin slimline lamp-and-ballast
systems are retired, consumers have the option to replace those systems
with 4-foot T8 medium bipin lamp-and-ballast systems. For this reason,
it is necessary that DOE considers pairs of CSLs when reporting the
results for the ANOPR. For the ANOPR, when DOE reports the 4-foot
medium bipin NES and NPV results, these values represent only the
savings accrued from new construction and the replacements of the
initial 2011 4-foot medium bipin stock. It does not include savings
that may be accumulated due to the added shipments and installed stock
of 4-foot medium bipin systems replacing 8-foot single pin slimline
systems. In addition, DOE reports the 8-foot single pin slimline NES
and NPV as the savings accrued from the replacements of the initial
2011 8-foot single pin slimline stock. This assumes that 4-foot medium
bipin lamps that replace the 8-foot single pin slimline lamps are still
at the base-case efficacies. However, when reporting the total NES and
NPV for the entire linear GSFL market, DOE assumes that all product
classes (4-foot medium bipin, 8-foot single pin slimline, and 8-foot
recessed double contact HO) are at the same CSL and all savings are
accounted for.
DOE invites comment on appropriate CSL pairings that should be
reported as trial standard levels in the NOPR, including additional
pairings not presented in this ANOPR. The NIA spreadsheet has the
flexibility to compute results for all combinations of CSLs at the
product class level and even at the level of baseline lamps for GSFL.
For example, in the GSFL NIA model, it is possible to specify different
efficacy requirements for 4-foot T12 medium bipin and 4-foot T8 medium
bipin lamps. More detailed discussion regarding these CSL pairs can be
found in Chapter 9 of the TSD.
Table III.36 and Table III.37 present the national energy savings
for GSFL under both the ``shift'' (upper bound) and ``roll-up'' (lower
bound) scenarios. The highest energy savings result from CSL 5 for both
scenarios and all lamp types. In addition, note that at CSL 1 and CSL 2
(and CSL 3 for only 8-foot recessed double contact HO lamps), all
energy savings originate from shifts to higher-efficacy T12 lamps and,
in the 4-foot medium bipin and 8-foot single pin slimline models, early
retrofits to the more-efficacious T8 systems. At these CSLs, all T8
lamps are standards-
[[Page 13678]]
compliant and, therefore, unaffected in both scenarios. At CSL 3, a
large increase in total energy savings of GSFL can be observed,
stemming from the saving associated with 4-foot T8 lamps (the majority
of the stock) being affected by the regulations. It is also important
to note that at CSL 4 and CSL 5 for all GSFL product classes, all T12
lamp systems are automatically retrofitted to T8 lamp systems because
no T12 standards-compliant lamps are available as lamp designs.
Table III.36.--Cumulative National Energy Savings for GSFL Under the Shift Scenario
[2012-2042] [quads] \64\
----------------------------------------------------------------------------------------------------------------
NES quads
-----------------------------------------------
Candidate standard level Product class Discounted at Discounted at
Undiscounted 7% 3%
----------------------------------------------------------------------------------------------------------------
1.................................. 4-foot medium bipin........ 0.27 0.14 0.20
8-foot single pin slimline. 0.05 0.03 0.04
8-foot recessed double 0.48 0.15 0.27
contact HO.
-----------------------------------------------
Total..................... 0.80 0.31 0.51
----------------------------------------------------------------------------------------------------------------
2.................................. 4-foot medium bipin........ 0.45 0.24 0.34
8-foot single pin slimline. 0.09 0.05 0.06
8-foot recessed double 0.65 0.20 0.37
contact HO.
-----------------------------------------------
Total..................... 1.19 0.49 0.78
----------------------------------------------------------------------------------------------------------------
3.................................. 4-foot medium bipin........ 6.79 1.98 3.81
8-foot single pin slimline. 0.13 0.07 0.10
8-foot recessed double 0.67 0.20 0.38
contact HO.
-----------------------------------------------
Total..................... 7.94 2.35 4.49
----------------------------------------------------------------------------------------------------------------
4.................................. 4-foot medium bipin........ 8.17 2.54 4.72
8-foot single pin slimline. 0.41 0.15 0.25
8-foot recessed double 2.16 0.63 1.21
contact HO.
-----------------------------------------------
Total..................... 11.09 3.43 6.39
----------------------------------------------------------------------------------------------------------------
5.................................. 4-foot medium bipin........ 12.69 3.62 7.05
8-foot single pin slimline. 0.41 0.16 0.26
8-foot recessed double 2.19 0.64 1.23
contact HO.
-----------------------------------------------
Total..................... 15.86 4.59 8.86
----------------------------------------------------------------------------------------------------------------
Table III.37.--Cumulative National Energy Savings for GSFL Under the Roll-Up Scenario
[2012-2042] [quads] \64\
----------------------------------------------------------------------------------------------------------------
NES quads
-----------------------------------------------
Candidate standard level Product class Discounted at Discounted at
Undiscounted 7% 3%
----------------------------------------------------------------------------------------------------------------
1.................................. 4-foot medium bipin........ 0.27 0.14 0.20
8-foot single pin slimline. 0.05 0.03 0.04
8-foot recessed double 0.35 0.12 0.21
contact HO.
-----------------------------------------------
Total..................... 0.67 0.28 0.45
----------------------------------------------------------------------------------------------------------------
2.................................. 4-foot medium bipin........ 0.45 0.24 0.34
8-foot single pin slimline. 0.09 0.05 0.06
8-foot recessed double 0.61 0.19 0.35
contact HO.
-----------------------------------------------
Total..................... 1.15 0.48 0.76
----------------------------------------------------------------------------------------------------------------
3.................................. 4-foot medium bipin........ 2.88 0.92 1.68
8-foot single pin slimline. 0.13 0.07 0.10
8-foot recessed double 0.63 0.19 0.36
contact HO.
-----------------------------------------------
Total..................... 3.79 1.23 2.23
----------------------------------------------------------------------------------------------------------------
4.................................. 4-foot medium bipin........ 3.71 1.16 2.14
8-foot single pin slimline. 0.17 0.09 0.13
8-foot recessed double 1.89 0.55 1.06
contact HO.
-----------------------------------------------
[[Page 13679]]
Total..................... 5.92 1.85 3.42
----------------------------------------------------------------------------------------------------------------
5.................................. 4-foot medium bipin........ 6.62 1.90 3.68
8-foot single pin slimline. 0.23 0.11 0.16
8-foot recessed double 2.05 0.60 1.15
contact HO.
-----------------------------------------------
Total..................... 9.26 2.72 5.20
----------------------------------------------------------------------------------------------------------------
Table III.38 presents the national energy savings for IRL in the
commercial and residential sectors. As shown in the table, energy
savings for both commercial and residential IRL are greatest at CSL3.
Appendix 10B of the TSD presents NES results for both the ``65 Watt BR
lamp substitution'' and the ``10 percent lumen increase'' sensitivity
scenarios. Because both of these scenarios involve the purchasing of
either higher-wattage or same-wattage lamps, the two sensitivity
scenarios generally present lower NES results than that of the main
scenario presented in this notice.
---------------------------------------------------------------------------
\64\ Results of 4-foot medium bipin energy savings and NPV are
calculated assuming there is no 8-foot single pin slimline standard
while the 8-foot single pin slimline results assume no 4-foot medium
bipin standard. Total results assume 4-foot medium bipin lamps and
8-foot single pin slimline lamps are subject to the same CSL.
Table III.38.--Cumulative National Energy Savings IRL
[2012-2042] [quads]
----------------------------------------------------------------------------------------------------------------
NES quads
-----------------------------------------------
Candidate standard level Sector Discounted at Discounted at
Undiscounted 7% 3%
----------------------------------------------------------------------------------------------------------------
1..................................... Commercial.............. 0.48 0.15 0.28
Residential............. 0.60 0.18 0.34
-----------------------------------------------
Total.................. 1.08 0.33 0.62
----------------------------------------------------------------------------------------------------------------
2..................................... Commercial.............. 0.83 0.27 0.49
Residential............. 1.03 0.30 0.58
-----------------------------------------------
Total.................. 1.86 0.57 1.07
----------------------------------------------------------------------------------------------------------------
3..................................... Commercial.............. 1.13 0.36 0.66
Residential............. 1.27 0.37 0.71
-----------------------------------------------
Total.................. 2.40 0.73 1.37
----------------------------------------------------------------------------------------------------------------
Below are the NPV results for the CSLs considered for GSFL and IRL.
Results are cumulative and are shown as the discounted value of these
savings in dollar terms. The present value of increased total installed
costs is the total installed cost increase (i.e., the difference
between the standards case and base case), discounted to the present,
and summed over the time period in which DOE evaluates the impact of
standards (i.e., from the effective date of standards, 2012, to 2042).
Savings are decreases in operating costs associated with the higher
energy efficacy of each product purchased in the standards case
compared to the base case. Total operating cost savings are the savings
per unit multiplied by the number of units surviving in a particular
year. Each product consumes energy and must be maintained over its
entire lifetime. For a unit that survives after 2042, DOE calculates a
residual value in both the base case and standards case to account for
its remaining life. The cost savings associated with this residual
value are incorporated into the total NPV result. A detailed
description of this calculation can be found in Chapter 10 of the TSD.
The NPV results for the CSLs analyzed for each of the lamp types
are based on discount rates of 7 and 3 percent.
Table III.39 and Table III.40 provide the NPV for GSFL under both
the shift and roll-up scenarios. As seen below, CSL 4, for 8-foot
recessed double contact HO lamps and 8-foot single pin slimline lamps,
and CSL 5 for 4-foot medium bipin, achieve the highest NPV for the
shift scenario. For the roll-up scenario, CSL 5 achieves the highest
NPV for all types of fluorescent lamps analyzed. Also, for both
scenarios and at all CSLs, the 4-foot medium bipin lamp results in
positive NPV, because increasingly efficacious lamp-and-ballast designs
generally have higher LCC savings relative to each other and
[[Page 13680]]
the base-case lamp-and-ballast designs. For all GSFL, at CSL 4 and CSL
5, large and positive NPV generally result due to the integration of
more-efficacious T8 design options into both commercial and industrial
lamp stocks. As 4-foot T8 medium bipin lamps are the majority of stock
of all GSFL, an increase in lamp efficacy and a decrease in energy
consumption result in large operating cost savings and, therefore, high
NPV.
Table III.39.--Cumulative NPV Results for GSFL Under the Shift Scenario
[Billion 2006$]
----------------------------------------------------------------------------------------------------------------
NPV billion 2006$
-------------------------------
Candidate standard level Product class Discounted at Discounted at
7% 3%
----------------------------------------------------------------------------------------------------------------
1.......................................... 4-foot medium bipin................ 0.20 0.52
8-foot single pin slimline......... -0.03 0.02
8-foot recessed double contact HO.. 0.94 1.86
-------------------------------
Total............................. 1.11 2.40
----------------------------------------------------------------------------------------------------------------
2.......................................... 4-foot medium bipin................ 0.24 0.74
8-foot single pin slimline......... 0.01 0.11
8-foot recessed double contact HO.. 1.42 2.73
-------------------------------
Total............................. 1.67 3.58
----------------------------------------------------------------------------------------------------------------
3.......................................... 4-foot medium bipin................ 9.33 19.92
8-foot single pin slimline......... 0.13 0.31
8-foot recessed double contact HO.. 0.05 0.20
-------------------------------
Total............................. 10.15 21.66
----------------------------------------------------------------------------------------------------------------
4.......................................... 4-foot medium bipin................ 13.75 27.03
8-foot single pin slimline......... 0.69 1.52
8-foot recessed double contact HO.. 3.64 8.08
-------------------------------
Total............................. 18.78 37.92
----------------------------------------------------------------------------------------------------------------
5.......................................... 4-foot medium bipin................ 20.37 42.62
8-foot single pin slimline......... 0.68 1.51
8-foot recessed double contact HO.. 3.63 8.06
-------------------------------
Total............................. 25.74 54.26
----------------------------------------------------------------------------------------------------------------
Table III.40.--Cumulative NPV Results for GSFL Under the Roll-Up Scenario
[Billion 2006$]
----------------------------------------------------------------------------------------------------------------
NPV billion 2006$
-------------------------------
Candidate standard level Product class Discounted at Discounted at
7% 3%
----------------------------------------------------------------------------------------------------------------
1.......................................... 4-foot medium bipin................ 0.20 0.52
8-foot single pin slimline......... -0.03 0.02
8-foot recessed double contact HO.. 0.56 1.01
-------------------------------
Total............................. 0.73 1.55
----------------------------------------------------------------------------------------------------------------
2.......................................... 4-foot medium bipin................ 0.24 0.74
8-foot single pin slimline......... 0.01 0.11
8-foot recessed double contact HO.. 1.15 2.13
-------------------------------
Total............................. 1.40 2.98
----------------------------------------------------------------------------------------------------------------
3.......................................... 4-foot medium bipin................ 2.60 6.15
8-foot single pin slimline......... 0.13 0.31
8-foot recessed double contact HO.. 0.00 0.07
-------------------------------
Total............................. 2.98 7.00
----------------------------------------------------------------------------------------------------------------
4.......................................... 4-foot medium bipin............... 5.37 10.63
8-foot single pin slimline......... 0.07 0.26
8-foot recessed double contact HO.. 3.27 7.33
-------------------------------
[[Page 13681]]
Total............................. 9.00 18.74
----------------------------------------------------------------------------------------------------------------
5.......................................... 4-foot medium bipin............... 8.19 17.29
8-foot single pin slimline......... 0.24 0.66
8-foot recessed double contact HO.. 3.40 7.61
-------------------------------
Total............................. 12.47 26.72
----------------------------------------------------------------------------------------------------------------
Table III.41 presents the NPV for IRL in the commercial and
residential sectors. As shown in Table III.41, the NPV for IRL is
greatest at CSL3, consistent with trends in LCC savings. Appendix 10B
of the TSD presents NPV results for both the ``65 Watt BR lamp
substitution'' and the ``10 percent lumen increase'' sensitivity
scenarios.
Table III.41.--Cumulative NPV Results for IRL
[Billion 2006$]
----------------------------------------------------------------------------------------------------------------
NPV billion 2006$
-------------------------------
Candidate standard level Sector Discounted at Discounted at
7% 3%
----------------------------------------------------------------------------------------------------------------
1.......................................... Commercial......................... 0.82 1.53
Residential........................ 1.20 2.47
-------------------------------
Total............................. 2.02 4.00
----------------------------------------------------------------------------------------------------------------
2.......................................... Commercial......................... 1.54 2.86
Residential........................ 2.31 4.64
-------------------------------
Total............................. 3.85 7.50
----------------------------------------------------------------------------------------------------------------
3.......................................... Commercial......................... 2.88 5.40
Residential........................ 3.34 6.76
-------------------------------
Total............................. 6.22 12.16
----------------------------------------------------------------------------------------------------------------
J. Life-Cycle Cost Subgroup Analysis
The LCC subgroup analysis evaluates impacts of standards on
identifiable groups of customers, such as different population groups
of consumers (e.g., consumers part of low income households) or
different business types (e.g., educational facilities), which may be
disproportionately affected by any national energy conservation
standard level. In the NOPR phase of this rulemaking, DOE will analyze
the LCCs and PBPs for consumers that fall into such groups. The
analysis will determine whether any particular group of consumers would
be adversely affected by any of the trial standard levels.
DOE plans to examine variations in energy prices and energy use
that might affect the NPV of a standard for customer subpopulations. To
this end, DOE intends to perform additional analyses to consider how
differences in energy use will affect subgroups of customers. DOE will
determine the effect on customer subgroups using the LCC spreadsheet
model. As described in Section III.G, the ANOPR LCC analysis includes
various customer types that use the lamps being considered under this
rulemaking. This analysis includes consumers purchasing lamps in
different sectors, purchasing lamps for different building types,
replacing different baseline lamps or lamp/ballast systems, and
undergoing different purchasing events.
For IRL, DOE can estimate LCC savings and payback periods for
consumers in the residential, commercial, and industrial sectors. For
GSFL, DOE can perform an LCC analysis for consumers in the commercial
and industrial sectors. A subgroup analysis for consumers of GSFL in
the residential sector could also be performed if DOE assumes GSFL
residential lamps have the same operating hour profile as IRL
residential lamps. DOE requests comment on this assumption.
DOE can also analyze the LCC impacts on consumers living in
different buildings in the commercial and residential sectors. For
example, DOE can analyze the impact of standards for people running
educational facilities and for those who live in a mobile home. DOE
also has the ability to analyze the impacts on consumers living in
different regions of the country.
For both GSFL and IRL, DOE has the ability to evaluate the LCC
impacts on consumers who purchase different baseline lamps or lamp-and-
ballast systems. For example, the economic impacts of a standard will
be different for a consumer who owns a typical 4-foot T8 lamp-and-
ballast system than for a consumer who owns a typical 4-foot T12 lamp-
and-ballast system. For GSFL, DOE also has the ability to analyze the
LCC impact of a standard on consumers
[[Page 13682]]
faced with a variety of different lamp-purchasing events. The LCC
impacts on a consumer who must replace a lamp for their existing system
are very different from those impacts on a consumer who must purchase a
lamp because they are constructing a new building.
DOE received one comment in response to the Framework Document
pertaining to the LCC subgroup analysis. PG&E argued that consumers
will experience differential LCCs impacts, particularly for low-income
households. (PG&E, No. 4.5 at p.218) DOE will consider analyzing the
impacts of candidate standards on low-income subgroups for the NOPR.
DOE invites comment on these and other consumer subgroups that it
should consider for the NOPR. DOE also invites comments on how LCC
inputs might change for each consumer subgroup.
K. Manufacturer Impact Analysis
The purpose of the MIA is to identify the likely impacts of energy
conservation standards on manufacturers. DOE has begun and will
continue to conduct this analysis with input from manufacturers and
other interested parties. During the MIA, DOE considers financial
impacts and a wide range of other quantitative and qualitative industry
impacts that might occur following the adoption of a standard. For
example, if DOE adopts a particular standard level, it could require
changes to manufacturing practices. DOE will identify and understand
these impacts through interviews with manufacturers and other
stakeholders during the NOPR stage of its analysis.
More specifically, DOE will conduct each MIA in this rulemaking in
three phases, and will further tailor the analytical framework for each
MIA based on comments. In Phase I, DOE creates an industry profile to
characterize the industry and identify important issues that require
consideration. In Phase II, DOE prepares an industry cash flow model
and an interview questionnaire to guide subsequent discussions. In
Phase III, DOE interviews manufacturers, and assesses the impacts of
standards, both quantitatively and qualitatively. It assesses industry
and sub-group cash flow and NPV through use of the Government
Regulatory Impact Model (GRIM). DOE then assesses impacts on
competition, manufacturing capacity, employment, and regulatory burden
based on manufacturer interview feedback and discussions.
Until recently, DOE reported MIA results in its standards
rulemakings only after the ANOPR phase of the rulemaking. However, DOE
is now evaluating and reporting preliminary MIA information in its
ANOPRs. For a detailed discussion on the MIA, refer to Chapter 12 of
the ANOPR TSD.
From a comment received at the Framework Document public meeting,
DOE is aware that manufacturer cost data may be difficult to obtain
from industry. (Public Meeting Transcript, No. 4.5 at pp. 133-135)
Therefore, as recommended, DOE may approximate manufacturer costs by
working backwards through the distribution chain from publicly-
available prices by using estimated manufacturer and supply chain mark-
ups. (Public Meeting Transcript, No. 4.5 at pp. 129 and 133-136; NEMA,
No. 8 at p. 3; Joint Comment, No. 9 at p. 3). For more information on
the industry cash flow analysis, refer to Chapter 12 of the ANOPR TSD.
1. Cumulative Regulatory Burden
DOE recognizes and seeks to mitigate the overlapping effects on
manufacturers of new or revised DOE standards and other regulatory
actions affecting the same product. In response to the Framework
Document, several stakeholders submitted comments concerning the
cumulative impact of regulation on lamp manufacturers. Specifically,
NEMA commented that a number of companies face regulations in other
countries, and that some of these products are manufactured globally
for sale around the world. Therefore, NEMA commented that there are
some regulatory burdens and issues that may play a factor here. (NEMA,
No. 4.5 at p. 229) EEI commented that DOE should take into account
State regulations in assessing the impacts of different requirements
for manufacturers. (EEI, No. 4.5 at p. 233) PG&E commented that DOE
should take into account trade impacts in the industry. However, PG&E
does not expect this would have a large impact for manufacturers of
lighting products. (PG&E, No. 4.5 at pp. 239-240) In response, DOE
recognizes that both States and foreign countries are already
regulating certain lamp categories or contemplating doing so. As
discussed in section III.A.1, many States are currently regulating IRL
primarily used in the commercial sector, and a few are beginning to
regulate lamp types used more often in the residential sector.
Regulations are also pending in both Mexico and Canada.
DOE will analyze and consider the impact on manufacturers of
multiple, product-specific regulatory actions in the NOPR. DOE invites
comment on regulations applicable to lamp manufacturers that contribute
to their cumulative regulatory burden.
2. Preliminary Results of the Manufacturer Impact Analysis
DOE conducted a series of preliminary interviews with manufacturers
to assess their concerns about potential impact of changes to the
requirements or coverage of the regulatory standard for fluorescent and
incandescent lamps. In general, manufacturers identified the following
major issues of concern: (a) Sufficient time to retool in response to
the standards; (b) availability of materials to produce standards-
compliant lamps; and (c) maintaining product availability and features
that consumers use. Each of these concerns is discussed in further
detail below.
a. Retooling Equipment To Produce Standards-Compliant Lamps
All of the manufacturers interviewed expressed concern regarding
the adequacy of the time periods specified under EPCA for developing
standards-compliant lamps. For GSFL, some manufacturers expressed
concern about the time period necessary to retool to produce standards-
compliant lamps (e.g., converting from a T12 product line to a T8
product line at certain standard levels). For IRL, manufacturers
commented that, depending on the timeframe for transition, they could
face production capacity problems if DOE were to raise standards such
that the use of halogen capsules or infrared reflective (IR) coatings
on halogen capsules were required. Manufacturers believe there could be
a production capacity problem due to the process time involved in
layering dozens of thin, IR-reflective film coatings on the capsule.
The high volumes associated with both GSFL and IRL were cited
frequently as the underlying cause for concern.
b. Availability of Materials To Produce Standards-Compliant Lamps
Manufacturers interviewed expressed concern about the availability
of materials to manufacture standards-compliant lamps. More
specifically, concern was expressed about potential shortages of
certain materials (e.g., the phosphor that produces blue light), which
could in turn drive up the production cost.
c. Maintaining Product Availability and Features
Manufacturers expressed concern to DOE about the potential impact
the regulation may have on their ability to continue to supply a wide
diversity of
[[Page 13683]]
products with attributes and features that their customers require.
Depending on the mandatory standard level, manufacturers expressed
concern that certain lamp shapes and sizes may be eliminated from the
market, or that significant market shifts could occur (e.g., from
incandescent technology to compact fluorescent lamps).
As discussed above, DOE will be conducting the manufacturer impact
analysis for the NOPR stage of this rulemaking. As part of this
inquiry, DOE will be investigating this preliminary list of issues in
more depth, as well as discussing other impacts that manufacturers may
experience. DOE invites comment on these and other issues, relating to
the regulatory impacts on manufacturers.
Furthermore, DOE considered the possible effect of energy
conservation standards for GSFL and IRL on small businesses. At this
time, DOE is not aware of any small manufacturers of the lamps being
considered in this rulemaking. Should any small business manufacturers
be identified, DOE will study the potential impacts in greater detail
during the MIA, which DOE will conduct as a part of the NOPR analysis.
L. Utility Impact Analysis
For the NOPR, the utility impact analysis will estimate the effects
on the utility industry of reduced energy consumption due to any new or
amended energy conservation standards for fluorescent and incandescent
lamps. For GSFL and IRL, the utility impact analysis will compare the
differences between each lamp type's forecasted base and standards
cases for electricity generation, installed capacity, sales, and
prices.
To estimate the effects of potential standards on the electric
utility industry, DOE intends to use a variant of the EIA's National
Energy Modeling System (NEMS).\65\ NEMS, which is available in the
public domain, is a large, multi-sectoral, partial equilibrium model of
the U.S. energy sector. DOE/EIA uses NEMS to produce a widely
recognized baseline energy forecast for the U.S. DOE uses a variant of
NEMS known as NEMS-Building Technologies (NEMS-BT) to supply key inputs
to its utility impact analysis.
---------------------------------------------------------------------------
\65\ For more information on NEMS, please refer to the U.S.
Department of Energy, Energy Information EIA documentation; a useful
summary is National Energy Modeling System: An Overview 2003, Report
number: DOE/EIA-0581(2003), March 2003 (available at: http://tonto.eia.doe.gov/FTPROOT/forecasting/05812003.pdf). DOE/EIA
approves use of the name ``NEMS'' to describe only an official
version of the model without any modification to code or data.
Because the present analysis entails some minor code modifications
and the model is run under various policy scenarios that are
variations on DOE/EIA assumptions, in this analysis, DOE refers to
it by the name ``NEMS-BT.''
---------------------------------------------------------------------------
For electrical end uses, NEMS-BT utilizes predicted growth in
demand for each end use to build up a projection of the total electric
system load growth for each of fifteen electricity market module supply
regions, which it uses in turn to predict necessary additions to
capacity. For electrical end uses, NEMS-BT accounts for the
implementation of energy conservation standards by decrementing the
appropriate reference case load shape. DOE will determine the size of
the decrement using the per-unit energy savings data developed in the
LCC and PBP analyses (see Chapter 8 of the ANOPR TSD) and the forecast
of shipments developed for the NIA (see Chapter 9 of the ANOPR TSD).
For more information on the utility impact analysis, refer to Chapter
13 of the ANOPR TSD.
The use of NEMS for the utility impact analysis offers several
advantages. As the official DOE energy forecasting model, NEMS relies
on a set of assumptions that are transparent and have received wide
exposure and commentary. NEMS allows an estimate of the interactions
between the various energy supply and demand sectors and the economy as
a whole. The utility impact analysis will determine the changes for
electric utilities in installed capacity and in generation by fuel type
produced by each CSL, as well as changes in electricity sales.
DOE plans to conduct the utility impact analysis as a variant of
AEO2007, applying the same basic set of assumptions. For example, the
utility impact analysis uses the operating characteristics (e.g.,
energy conversion efficacy, emissions rates) of future electricity
generating plants.
DOE will also explore deviations from some of the reference case
assumptions to represent alternative future outcomes. Two alternative
scenarios use the high- and low-economic-growth cases of AEO2007. (The
reference case corresponds to medium growth.) The high-economic-growth
case assumes higher projected growth rates for population, labor force,
and labor productivity, resulting in lower predicted inflation and
interest rates relative to the reference case. The opposite is true for
the low-growth case. While DOE varies supply-side growth determinants
in all three of these different economic-growth cases, AEO2007 assumes
the same reference case energy prices for all three economic growth
cases so that the impact of differences in the three scenarios are
comparable, referenced against a consistent set of energy prices. The
three different economic growth cases all affect the rate of growth of
electricity demand.
Since the AEO2007 version of NEMS forecasts only to the year 2030,
DOE must extrapolate results to 2042. It is not feasible to extend the
forecast period of NEMS-BT for the purposes of this analysis, nor does
EIA have an approved method for extrapolation of many outputs beyond
2030. While it might seem reasonable in general to use simple linear
extrapolations of results, in practice this is not advisable, because
outputs could be contradictory. For example, changes in the fuel mix
implied by extrapolations of those outputs could be inconsistent with
the extrapolation of marginal emissions factors. An analysis of the
various trends to a sufficiently detailed degree to guarantee
consistency among the extrapolations is not conducted as part of this
analysis. Further, even it were, the extrapolations would still involve
a great deal of uncertainty. Therefore, for all extrapolations beyond
2030, DOE intends to simply repeat the results from the year 2030
results, until it reaches the end of the analysis period, 2042. While
this simplified extrapolation technique and the resulting values may
seem unreasonable in some instances, results are nevertheless
guaranteed to be consistent. As with the AEO reference case in general,
the implicit premise is that the regulatory environment does not
deviate from the current known situation during the extrapolation
period. Only changes that have been announced with date-certain
introduction are included in NEMS-BT.
In comments on the Framework Document, EEI requested that DOE
provide an explanation of the calculations conducted using the NEMS-BT
model. EEI believes such explanation would enable the public to more
easily comment on the plausibility of the output. (EEI, No. 4.5 at pp.
236-237) In response, when DOE conducts the utility impact analysis for
the NOPR, it will endeavor to improve the clarity and presentation of
the calculations conducted using the NEMS-BT model.
M. Employment Impact Analysis
At the NOPR stage, DOE estimates the impacts of standards on
employment for equipment manufacturers, relevant service industries,
energy suppliers, and the economy in general. The following discussion
explains the methodology DOE plans to use in conducting the employment
impact analysis for this rulemaking. Both indirect and direct
employment impacts are analyzed. Direct employment impacts would
[[Page 13684]]
result if standards led to a change in the number of employees at
manufacturing plants and related supply and service firms. Direct
impact estimates are covered in the MIA.
Indirect employment impacts are impacts on the national economy
other than in the manufacturing sector being regulated. Indirect
impacts may result both from expenditures shifting among goods
(substitution effect) and changes in income which lead to a change in
overall expenditure levels (income effect). DOE defines indirect
employment impacts from standards as net jobs eliminated or created in
the general economy as a result of increased spending driven by the
increased equipment prices and reduced spending on energy.
DOE expects new standards to increase the total installed cost of
equipment (includes manufacturer's selling price, distribution channel
mark-ups, sales taxes, and installation cost). DOE also expects the new
standards to decrease energy consumption, and, thus, expenditures on
energy. Over time, increased total installed cost is paid back through
energy savings. The savings in energy expenditures may be spent on new
commercial investment and other items.
Using an input/output model of the U.S. economy, this analysis
seeks to estimate the effects on different sectors and the net impact
on jobs. DOE will estimate national employment impacts for major
sectors of the U.S. economy in the NOPR, using public and commercially
available data sources and software. DOE will make all methods and
documentation pertaining to the employment impact analysis available
for review in the Technical Support Document published in conjunction
with the NOPR.
DOE developed Impact of Sector Energy Technologies (ImSET), a
spreadsheet model of the U.S. economy that focuses on 188 sectors most
relevant to industrial, commercial, and residential building energy
use.\66\ ImSET is a special-purpose version of the U.S. Benchmark
National Input-Output (I-O) model, which has been designed to estimate
the national employment and income effects of energy-saving
technologies that are considered by the DOE Office of Energy Efficiency
and Renewable Energy. In comparison with previous versions of the model
used in earlier rulemakings, the current version allows for more
complete and automated analysis of the essential features of energy
efficiency investments in buildings, industry, transportation, and the
electric power sectors.
---------------------------------------------------------------------------
\66\ Roop, J. M., M. J. Scott, and R. W. Schultz, ``ImSET:
Impact of Sector Energy Technologies,'' PNNL-15273. (Pacific
Northwest National Laboratory, Richland, WA)(2005).
---------------------------------------------------------------------------
The ImSET software includes a personal computer-based I-O model
with structural coefficients to characterize economic flows among the
188 sectors. ImSET's national economic I-O structure is based on the
1997 Benchmark U.S. table (Lawson, et al. 2002),\67\ specially
aggregated to 188 sectors. The time scale of the model is 50 years.
---------------------------------------------------------------------------
\67\ Lawson, Ann M., Kurt S. Bersani, Mahnaz Fahim-Nader, and
Jiemin Guo, ``Benchmark Input-Output Accounts of the U. S. Economy,
1997,'' Survey of Current Business (Dec. 2002), pp. 19-117.
---------------------------------------------------------------------------
The model is a static I-O model, which means that the model is able
to accommodate a great deal of flexibility concerning the types of
effects the energy conservation standards can have on the national
employment and income effects. For example, certain economic effects of
energy-efficiency improvements require an assessment of inter-industry
purchases, which is handled in the model. Some energy-efficiency
investments will not only reduce the costs of energy in the economy but
the costs of labor and other goods and services as well, which is
accommodated through a recalculation of the I-O structure in the model.
Output from the ImSET model can be used to estimate changes in
employment, industry output, and wage income in the overall U.S.
economy resulting from changes in expenditures in the various sectors
of the economy.
Although DOE intends to use ImSET for its analysis of employment
impacts, it welcomes input on other tools and factors it might
consider. For more information on the employment impacts analysis,
refer to Chapter 14 of the TSD.
N. Environmental Assessment
For the NOPR, DOE will assess the environmental effects of energy
conservation standards for GSFL and IRL. DOE anticipates that the
primary environmental effects will be reduced power plant emissions
resulting from reduced electricity consumption. DOE will assess these
environmental effects by using NEMS-BT to provide key inputs to the
analysis. The environmental assessment produces results in a manner
similar to those provided in the AEO.
The intent of the environmental assessment is to provide emissions
results estimates, and to fulfill legislative requirements that DOE
quantify and consider the environmental effects of all new Federal
rules. The environmental assessment that will be produced by NEMS-BT
considers potential environmental impacts from three pollutants (sulfur
dioxide (SO2), nitrous oxide (NOX), mercury (Hg))
and from carbon dioxide (CO2) emissions. For each of the
trial standard levels, DOE will calculate total undiscounted and
discounted power plant emissions using NEMS-BT.
DOE will conduct each portion of the environmental assessment
performed for this rulemaking as an incremental policy impact (i.e., an
energy conservation standard imposed on the product being evaluated, in
this case general service fluorescent lamps and incandescent reflector
lamps) of the AEO2007 forecast, applying the same basic set of
assumptions used in AEO2007. For example, the emissions characteristics
of an electricity generating plant will be exactly those used in
AEO2007. Also, forecasts conducted with NEMS-BT consider the supply-
side and demand-side effects on the electric utility industry. Thus,
the analysis will account for any factors affecting the type of
electricity generation and, in turn, the type and amount of airborne
emissions generated by the utility industry.
The NEMS-BT model tracks carbon emissions with a specialized carbon
emissions estimation subroutine, producing reasonably accurate results
due to the broad coverage of all sectors and the inclusion of
interactive effects. Past experience with carbon results from NEMS
suggests that emissions estimates are somewhat lower than emissions
based on simple average factors. One of the reasons for this divergence
is that NEMS tends to predict that energy conservation measures will
slow generating capacity growth in future years, and new generating
capacity is expected to be more efficient than existing capacity. On
the whole, NEMS-BT provides carbon emissions results of reasonable
accuracy, at a level consistent with other Federal published results.
In addition to providing estimates of the quantitative impacts of GSFL
and IRL standards on carbon emissions, DOE may consider the use of
monetary values to represent the potential value of such emissions
reductions. DOE invites comment on how to estimate such monetary values
or on any widely accepted values that might be used in DOE's analyses.
NEMS-BT also reports on SO2 and NOX, which
DOE has reported in past analyses. The Clean Air Act
[[Page 13685]]
Amendments of 1990 \68\ set an SO2 emissions cap on all
power generation. The attainment of this target, however, is made
flexible among generators through the use of emissions allowances and
tradable permits. Although NEMS includes a module for SO2
allowance trading and delivers a forecast of SO2 allowance
prices, accurate simulation of SO2 trading implies that
physical emissions effects will be zero because emissions will always
be at or near the ceiling. However, there may be an SO2
economic benefit from energy conservation in the form of a lower
SO2 allowance price. Since the impact of any one standard on
the allowance price is likely small and highly uncertain, DOE does not
plan to monetize the SO2 benefit.
---------------------------------------------------------------------------
\68\ The Clean Air Act Amendments of 1990 were signed into law
as Pub. L. 101-549 on November 15, 1990. The amendment can be viewed
at: http://www.epa.gov/air/caa/.
---------------------------------------------------------------------------
NEMS-BT also has an algorithm for estimating NOX
emissions from power generation. The impact of these emissions,
however, will be affected by the Clean Air Interstate Rule (CAIR),
which the EPA issued on March 10, 2005. 70 FR 25162 (May 12, 2005).
CAIR will permanently cap emissions of NOX in 28 eastern
States and the District of Columbia. As with SO2 emissions,
a cap on NOX emissions means that product energy
conservation standards may have no physical effect on these emissions.
When NOX emissions are subject to emissions caps, DOE's
emissions reduction estimate corresponds to incremental changes in the
prices of emissions allowances in cap-and-trade emissions markets
rather than physical emissions reductions. Therefore, while the
emissions cap may mean that physical emissions reductions will not
result from standards, standards could produce an environmental-related
economic benefit in the form of lower prices for emissions allowance
credits. However, as with SO2 allowance prices, DOE does not
plan to monetize this benefit because the impact on the NOX
allowance price from any single energy conservation standard is likely
small and highly uncertain.
With regard to mercury emissions, NEMS-BT has an algorithm for
estimating these emissions from power generation, and, as it has done
in the past, DOE is able to report an estimate of the physical quantity
of mercury emissions reductions associated with an energy conservation
standard. DOE assumed that these emissions would be subject to EPA's
Clean Air Mercury Rule \69\ (CAMR), which would permanently cap
emissions of mercury for new and existing coal-fired plants in all
States by 2010. Similar to SO2 and NOX, DOE
assumed that under such system, energy conservation standards would
result in no physical effect on these emissions, but would be expected
to result in an environmental-related economic benefit in the form of a
lower price for emissions allowance credits. DOE's plan for addressing
analysis does not include monetizing the benefits of reduced mercury
emissions, because DOE considered that valuation of such impact from
any single energy conservation standard would likely be small and
highly uncertain.
---------------------------------------------------------------------------
\69\ 70 FR 28606 (May 18, 2005).
---------------------------------------------------------------------------
On February 8, 2008, the U.S. Court of Appeals for the District of
Columbia Circuit (D.C. Circuit) issued its decision in State of New
Jersey, et al. v. Environmental Protection Agency,\70\ in which the
Court, among other actions, vacated the CAMR referenced above.
Accordingly, DOE is considering whether changes are needed to its plan
for addressing the issue of mercury emissions in light of the D.C.
Circuit's decision. DOE invites public comment on addressing mercury
emissions in this rulemaking.
---------------------------------------------------------------------------
\70\ No. 05-1097, 2008 WL 341338, at *1 (D.C. Cir. Feb. 8,
2008).
---------------------------------------------------------------------------
With regard to particulates, these emissions are a special case
because they arise not only from direct emissions, but also from
complex atmospheric chemical reactions that result from NOX
and SO2 emissions. DOE does not intend to analyze or report
on the particulate emissions from power stations because of the highly
complex and uncertain relationship between particulate emissions and
particulate concentrations that impact air quality. In sum, the results
for the environmental assessment are similar to a complete NEMS run as
published in the AEO2007. These results include power-sector emissions
for SO2, NOX, mercury, and carbon in five-year
forecasted increments extrapolated to 2042. The outcome of the analysis
for each CSL is reported as a deviation from the AEO2007 reference
(base) case.
The Joint Comment stated that DOE should evaluate mercury and
particulate emissions as part of the environmental assessment due to
their potential impacts on public health. (Joint Comment, No. 9 at p.
4) As discussed above, DOE will analyze and report on mercury emission
reductions; however it does not intend to report on particulate
emissions.
For more detail on the environmental assessment, refer to the
environmental assessment in the ANOPR TSD.
O. Regulatory Impact Analysis
DOE will prepare a draft regulatory impact analysis in compliance
with Executive Order 12866, ``Regulatory Planning and Review,'' which
will be subject to review by the Office of Management and Budget's
Office of Information and Regulatory Affairs (OIRA). 58 FR 51735 (Oct.
4, 1993).
As part of the regulatory impact analysis, and as discussed in
Section III.K, ``Manufacturer Impact Analysis,'' DOE will identify and
seek to mitigate the overlapping effects on manufacturers of new or
revised DOE standards and other regulatory actions affecting the same
products. Through manufacturer interviews and literature searches, DOE
will compile information on burdens from existing and impending
regulations affecting the lamps covered under this rulemaking. DOE also
seeks input from the public about regulations whose impacts it should
consider.
The regulatory impact analysis also will address the potential for
non-regulatory approaches to supplant or augment energy conservation
standards to improve the efficacy of GSFL and IRL. The NOPR will
include a complete quantitative analysis of alternatives to the
proposed conservation standards. DOE will use the NES spreadsheet model
(as discussed in section III.I, ``National Impact Analysis'') to
calculate the NES and NPV for the alternatives to the proposed
conservation standards. For more information on the regulatory impact
analysis, refer to the regulatory impact analysis report in the ANOPR
TSD.
IV. Candidate Energy Conservation Standards Levels
In terms of process, DOE specifies candidate standards levels in
the ANOPR, but does not propose a particular standard at this stage of
the rulemaking. Table IV.1 and Table IV.2 present the CSLs that are
discussed in today's ANOPR for the fluorescent and incandescent
reflector lamps product classes directly analyzed. As mentioned
earlier, in this ANOPR, DOE analyzes four of the ten product classes of
lamps. Section III.C.6 discusses DOE's considered approach for
extrapolation of CSLs to other product classes not analyzed.
[[Page 13686]]
Table IV.1.--Summary of the Candidate Standard Levels for GSFL
----------------------------------------------------------------------------------------------------------------
4-Foot medium 8-Foot single 8-Foot
bipin lamps pin slimline recessed
with CCT <= amps with CCT Double contact
Candidate standard level 4,500K <= 4,500K HO lamps with
-------------------------------- CCT <= 4,500K
---------------
lm/W lm/W lm/W
----------------------------------------------------------------------------------------------------------------
CSL1............................................................ 82.4 87.3 83.2
CSL2............................................................ 85.0 92.0 86.1
CSL3............................................................ 90.0 94.8 87.6
CSL4............................................................ 92.3 98.2 91.9
CSL5............................................................ 95.4 101.5 95.3
----------------------------------------------------------------------------------------------------------------
Table IV.2.--Summary of the Candidate Standard Levels for IRL
------------------------------------------------------------------------
Standard-
spectrum
incandescent
Candidate standard level reflector
lamps
---------------
lm/W
------------------------------------------------------------------------
CSL1.................................................... 5.0P \0.27\
CSL2.................................................... 5.5P \0.27\
CSL3.................................................... 6.2P \0.27\
------------------------------------------------------------------------
where P = rated wattage of the incandescent lamp
DOE will review the public input it receives in response to this
ANOPR and update the analyses appropriately for each product class
before issuing the NOPR. DOE also will consider any comments it
receives on the CSLs set forth above for GSFL and IRL, and on whether
alternative levels would satisfy the EPCA criteria.
For the NOPR, DOE will develop trial standard levels (TSL) for GSFL
and IRL from the above CSLs or other higher or lower levels after
consideration of public comments. In previous rulemakings, DOE has
considered several criteria in developing the TSLs, such as requiring
that a CSL have a minimum LCC, maximum NPV, and maximum
technologically-feasible efficacy. DOE invites comment on whether any
of these criteria are appropriate for this rulemaking, or whether other
TSLs are appropriate, perhaps based on technologies or applications
that are specific to the lamps being regulated. DOE seeks feedback on
the criteria it should use as the basis for the selection of TSLs. This
is identified as Issue 10 under ``Issues on Which DOE Seeks Comment''
in Section 0 of this ANOPR.
V. Public Participation
DOE will make the entire record of this proposed rulemaking,
including the transcript from the public meeting, available for
inspection at the U.S. Department of Energy, Resource Room of the
Building Technologies Program, Sixth Floor, 950 L'Enfant Plaza, SW.,
Washington, DC, (202) 586-2945, between 9 a.m. and 4 p.m., Monday
through Friday, except Federal holidays. Any person may buy a copy of
the transcript from the transcribing reporter.
A. Submission of Comments
DOE began accepting comments, data, and other relevant information
regarding all aspects of this ANOPR at the public meeting and will
continue to accept comments until no later than April 14, 2008. Please
submit comments, data, and information electronically to the following
e-mail address: [email protected]. Please submit electronic comments in
WordPerfect, Microsoft Word, PDF, or text (ASCII) file format and avoid
the use of special characters or any form of encryption. Comments in
electronic format should be identified by the Docket Number EE-2006-
STD-0131 and/or RIN number 1904-AA92, and whenever possible carry the
electronic signature of the author. Absent an electronic signature,
comments submitted electronically must be followed and authenticated by
submitting the signed original paper document. No telefacsimiles
(faxes) will be accepted.
Under 10 CFR 1004.11, any person submitting information that he or
she believes to be confidential and exempt by law from public
disclosure should submit two copies. One copy of the document shall
include all the information believed to be confidential, and the other
copy of the document shall have the information believed to be
confidential deleted. DOE will make its own determination about the
confidential status of the information and treat it according to its
determination.
Factors that DOE considers when evaluating requests to treat
submitted information as confidential include: (1) A description of the
items; (2) whether and why such items are customarily treated as
confidential within the industry; (3) whether the information is
generally known by, or available from, other sources; (4) whether the
information has previously been made available to others without
obligation concerning its confidentiality; (5) an explanation of the
competitive injury to the submitting person which would result from
public disclosure; (6) when such information might lose its
confidential character due to the passage of time; and (7) why
disclosure of the information would be contrary to the public interest.
B. Issues on Which DOE Seeks Comment
DOE is interested in receiving comments on all aspects of this
ANOPR. DOE especially invites comments or data to improve the analyses,
including data or information that will respond to the following
questions or concerns that were addressed in this ANOPR:
1. Consideration of Additional General Service Fluorescent Lamps
EPCA directs DOE to consider additional GSFL for coverage under 42
U.S.C. 6295(i)(5). In this notice, DOE outlines its preliminary
consideration of the expansion of coverage for GSFL under 42 U.S.C.
6295(i)(5), keeping in mind the express exclusions contained in the
definitions of ``general service fluorescent lamp'' (42 U.S.C.
6291(30)(B)). DOE requests comment on its planned expansion of
coverage. See section II for details on this issue.
2. Amended Definitions
EPCA directs DOE to consider additional GSFL for coverage under 42
U.S.C. 6295(i)(5). In the definition of ``general service fluorescent
lamp,'' (42 U.S.C. 6291(30)(B)) EPCA identifies ``colored fluorescent
lamps'' as expressly excluded from coverage. Although DOE defined
``colored fluorescent lamp'' in the 1997 test Procedure Final Rule, DOE
believes this definition requires updating and, therefore, presents a
draft amended definition for comment. DOE also invites comment on
whether other
[[Page 13687]]
exclusions are ambiguous or require modification.
One element of EPCA's definitions for ``fluorescent lamp'' and
``incandescent reflector lamp'' is a lamp's ``rated wattage,'' which
helps to determine which lamps are subject to standards. (42 U.S.C.
6291(30)((A), (C)(ii) and (F), and 6295(i)(1)) In addition, energy
conservation standards for general service incandescent lamps
prescribed by EISA 2007 require lamps of particular lumen outputs to
have certain maximum rated wattages. (42 U.S.C. 6295(i)(1)(B) In this
rulemaking, DOE plans to update its definition of rated wattage to
current industry references, and to apply this definition to those
lamps where rated wattage is not defined (e.g., 8-foot single pin
slimline lamps and incandescent lamps). DOE seeks comment on its
planned modification to the definition of ``rated wattage,'' a term
which applies to both covered fluorescent and incandescent lamps. See
section II for details on all of these issues.
3. Product Classes
DOE requests comment on its planned revisions to the product
classes for GSFL and IRL, including the use of CCT in the GSFL product
classes and the separate treatment of modified-spectrum lamps for IRL.
Details about DOE's planned product classes are presented in section
III.A.2.
4. Scaling to Product Classes Not Analyzed
DOE is inviting comment on the selected representative product
classes where it concentrates its analytical effort (see section
III.C.2), and on the extrapolation of findings from the representative
product classes to others that were not analyzed (see section III.C.6).
DOE invites comment on appropriate scaling methods it should follow,
particularly for the draft scaling factors discussed in section III.C.6
for 2-foot U-shaped GSFL, GSFL with a higher CCT, and modified-spectrum
IRL.
5. Screening of Design Options
In determining which design options to consider for the engineering
analysis, DOE applies four statutory screening criteria to a set of
potential technologies that may improve efficacy (i.e., technology
options). One of those screening criteria is ``practicability to
manufacture, install, and service.'' DOE invites comment on whether
certain technology options discussed in section III.B fail to meet this
criterion. Some manufacturers have expressed some concern about
integrating certain technology options into high-volume production
lines within a limited time-frame (i.e., the statutory three-year
compliance period). DOE invites comment on this issue and, if
appropriate, to provide possible solutions to help resolve the issue.
See section III.B and section III.K for details.
6. Operating Hours
DOE used the U.S. Lighting Market Characterization Volume I and the
EIA's RECS, CBECS, and MECS to develop a national distribution of
average operating hours for lamp types and end-use sectors. DOE
requests comment on whether the average operating hours derived are a
reasonable representation of these end-uses. See section III.D.1 for
details.
7. General Service Fluorescent Energy Consumption
In today's Federal Register, DOE is also publishing a test
procedure NOPR for fluorescent and incandescent lamps. In that NOPR,
DOE proposes to continue to use low-frequency ballast testing for all
GSFL except for those lamp types that can only be tested on high-
frequency ballasts. While DOE uses the test procedure to confirm that
manufacturers have met the minimum requirements, in this ANOPR, DOE
considers the operation of fluorescent lamps on several different
ballast types for the LCC and NIA analyses (i.e., DOE uses average
system power ratings of GSFL operating on electronic and magnetic
ballasts). This approach enables the economic evaluation of the CSLs to
more accurately reflect how fluorescent lamps are operated in the
field. DOE invites comment on this approach, as well as the calculated
system power ratings it derived for the lamp-and-ballast combinations
using published data. Detail on the system power ratings can be found
in Chapter 5 of the TSD.
8. Life-Cycle Cost Calculation
In order to determine the life-cycle cost savings of lamp designs
with unequal lifetimes, DOE used an analysis period corresponding to
the lifetime of the baseline lamp. To account for the remaining life of
the equipment at the end of the analysis period, DOE calculated a
residual value by linearly prorating the initial cost of the equipment.
DOE invites comment on its usage of residual values in the life-cycle
cost analysis and on other possible approaches to calculating life-
cycle costs for product with different lifetimes.
9. Installation Costs
In order to determine the complete installed cost for the LCC
analysis, DOE developed estimates of commercial sector installation
costs for IRL and GSFL. DOE seeks comment on the average labor rates
and times for each lamp type. See Chapter 8 of the TSD for details.
10. Base-Case Market-Share Matrices in 2012
DOE has developed a base-case to represent the distribution of lamp
systems and their efficacies currently in the marketplace, and thereby
determine the proportion of consumers affected by a particular energy
conservation standard level. DOE developed base-case efficacy
distributions for GSFL and IRL based on a combination of interviews
with lighting experts, historical shipments information, and available
product data. DOE requests comment on the resultant base-case product
distributions. See section III.H for details.
11. Shipment Forecasts
A key input into the shipment forecasts of GSFL and IRL is the
assumed market growth. For commercial GSFL and IRL, DOE uses a growth
rate of 1.6 percent based on CBECS floor space growth projections. For
residential IRL, DOE uses a 1.3 percent growth rate from the RECS
residential building growth projection. DOE invites comment on the data
sources, estimates, and implementation of these growth rates. In
addition, the shipment forecasts impact the total national lumen output
of each lamp type. DOE invites comment on the national lumen output
projection in both the base case and standards case. Specifically, DOE
invites comment on whether any adjustments are necessary to respond to
consumer actions resulting in over-lighting or under-lighting. See
Chapter 9 of the TSD and section III.H for details.
12. Base-Case and Standards-Case Forecasted Efficiencies
Forecasts of average market efficacy and energy consumption, in
both the base case and standards case, are fundamental inputs to the
NES and NPV calculations. Estimates of the market's selection of lamp
and lamp-and-ballast designs, in turn, drive the forecasts for average
efficacy and energy consumption. As a sensitivity to the NES and NPV
calculations, DOE developed standards-case scenarios to test the upper
and lower bounds of the NES and NPV results. DOE invites comment on
these standards-case
[[Page 13688]]
scenarios it developed estimating market behavior in response to a
standard, such as roll-up and shift in the GSFL market or the 65W BR
lamp substitution scenario. See section III.H for details.
13. Trial Standard Levels
For the NOPR, DOE will develop trial standard levels (TSLs) based
on the candidate standard levels for GSFL and IRL. DOE is considering
several criteria in developing the TSLs, including, but not limited to,
minimum LCC, maximum NPV, and maximum technologically-feasible
efficacy. These TSLs may include combinations of CSLs and the
interaction between product classes such as 4-foot medium bipin and 8-
foot single pin slimline fluorescent lamps or standard-spectrum and
modified-spectrum IRL. From the list of TSLs developed, DOE will select
one as its proposed standard for the NOPR. DOE invites comment on the
criteria it should use as the basis for the selection of TSLs. See
section III.H for details.
14. Lamp Production Equipment Conversion Timeframe
Manufacturers of high-volume lamps expressed concern as to their
ability to retool, invest in, or replace equipment within the
statutorily-required three-year compliance period, such that they may
continue to offer the volume lamps for sale at a new standard level.
DOE invites comment on this issue, and welcomes recommendations on how
best to mitigate any equipment conversion issues.
VI. Regulatory Review and Procedural Requirements
DOE submitted this ANOPR for review to OMB under Executive Order
12866, ``Regulatory Planning and Review.'' 58 FR 51735 (October 4,
1993). If DOE later proposes new or revised energy conservation
standards for GSFL or IRL, and if the proposed rule constitutes a
significant regulatory action, DOE would prepare and submit to OMB for
review the assessment of costs and benefits required by section 6(a)(3)
of the Executive Order. The Executive Order requires agencies to
identify the specific market failure or other specific problem that it
intends to address that warrants new agency action, as well as assess
the significance of that problem, to enable assessment of whether any
new regulation is warranted. (Executive Order 12866, Sec. 1(b)(1)).
DOE presumes that a perfectly functioning market would result in
efficiency levels that maximize benefits to all affected persons.
Consequently, without a market failure or other specific problem, a
regulation would not be expected to result in net benefits to consumers
and the nation. However, DOE also notes that whether it establishes
standards for these products is determined by the statutory criteria
expressed in EPCA. Even in the absence of a market failure or other
specific problem, DOE nonetheless may be required to establish
standards under existing law.
DOE's preliminary analysis for GSFL and IRL explicitly accounts for
the percentage of consumers that already purchase more efficient
equipment and takes these consumers into account when determining the
national energy savings associated with various candidate standard
levels. The preliminary analysis suggests that accounting for the
market value of energy savings alone (i.e., excluding any possible
``externality'' benefits such as those noted below) would produce
enough benefits to yield net benefits across a wide array of products
and circumstances. DOE requests additional data on, and suggestions for
testing the existence and extent of potential market failure to
complete an assessment of the significance of these failures and, thus,
the net benefits of regulation. In particular DOE seeks to verify the
estimates of the percentage of consumers of all product types
purchasing efficient equipment and the extent to which consumers will
continue to purchase more-efficient equipment in future years.
DOE believes that there is a lack of consumer information and/or
information processing capability about energy efficiency opportunities
in the lighting market. If this is in fact the case, DOE would expect
the efficiency for lighting products to be randomly distributed across
key variables such as electricity prices and usage levels. Although DOE
has already identified the percentage of consumers that already
purchase more efficient lighting products, DOE does not correlate the
consumer's usage pattern and electricity price with the efficiency of
the purchased product. Therefore, DOE seeks data on the efficiency
levels of existing lamps in use by how often it is utilized (e.g., how
many hours the product is used) and its associated electricity price
(and/or geographic region of the country). DOE plans to use these data
to test the extent to which purchasers of this equipment behave as if
they are unaware of the costs associated with their energy consumption.
Specifically, with respect to lighting products, DOE believes
several factors contribute to the lack of consumer information. In the
residential sector, consumer purchases are often based on wattage
rather than lumen output which may result in consumers not purchasing,
or rejecting higher-efficacy or energy-saving lamp designs. For
example, consumers may not recognize a higher-efficacy, reduced-wattage
lamp as fulfilling the same utility as their higher-wattage lamp though
both lamps may have similar lumen outputs. For this reason, these
higher-efficiency products may be unduly rejected in the marketplace.
In addition, in the commercial and industrial sectors, the complexity
of GSFL systems may introduce high information costs. GSFL systems are
composed of both lamps and ballasts that may have a multitude of
varying properties such as lamp wattage, lumen output, lifetime, and
ballast factor. These many numerous variables impose high information
costs which may prevent purchasers from selecting the most cost-
effective GSFL system. DOE seeks comment on additional knowledge of the
Federal Energy Star program, and the program's potential as a resource
for increasing knowledge of the availability and benefits of energy-
efficient lamps in the lighting consumer market.
A related issue is the problem of asymmetric information (one party
to a transaction has more and better information than the other) and/or
high transactions costs (costs of gathering information and effecting
exchanges of goods and services). In the case of lamps, in many
instances the party responsible for the lamp purchase may not be the
one who pays the cost to operate it. For example, in the commercial and
industrial sectors, building owners and developers may make purchase
decisions about lighting fixtures which include ballasts and lamps, but
it may be the tenants who pay the utility bills. Although renters often
have the opportunity to purchase the replacement lamps, they are
severely limited in their choices by prior fixture and ballast
selections. If there were no transactions costs, it would be in the
building developers' and owners' interests to install lighting fixtures
that renters would choose on their own. For example, a tenant who
knowingly faces higher utility bills from low-efficiency lighting would
be willing to pay less in rent, and the building owner would indirectly
bear the higher utility cost. However, this information is not
costless, and it may not be in the interest of the renter to take the
time to develop it, or, in the case of the building owner who installs
the lamp system, to convey that information to the renter.
[[Page 13689]]
To the extent that asymmetric information and/or high transactions
costs are problems, one would expect to find certain outcomes with
respect to commercial and industrial lighting energy efficiency. For
example, other things equal, one would not expect to see higher rents
for office space with high-efficiency lighting systems. Conversely, if
there were symmetric information, one would expect higher energy
efficiency lighting in commercial space where the rent includes
utilities, as compared to those where the tenant pays the utility bills
separately.
Of course, there are likely to be certain ``external'' benefits
resulting from the improved efficiency of units that are not captured
by the users of such equipment. These include both environmental and
energy security-related externalities that are not already reflected in
energy prices, such as reduced emissions of greenhouse gases and
reduced use of natural gas and oil for electricity generation. DOE
invites comments on the weight that should be given to these factors in
DOE's determination of the maximum efficiency level at which the total
benefits are likely to exceed the total costs resulting from a DOE
standard.
As previously stated, DOE generally seeks data that might enable it
to conduct tests of market failure for products under consideration for
standard-setting. For example, given adequate data, there are ways to
test for the extent of market failure for commercial GSFL. One would
expect the owners of fluorescent lamps who also pay for their
electricity consumption to purchase lamps that exhibit higher energy
efficiency compared to lamps whose owners do not pay for the
electricity usage, other things equal. To test for this form of market
failure, DOE needs data on energy efficiency of such units and whether
the owner of the equipment is also the one who pays the operating
costs. DOE is also interested in other potential tests of market
failure and data that would enable such tests.
In addition, various other analyses and procedures may apply to
such future rulemaking action, including those required by the National
Environmental Policy Act (Pub. L. 91-190, 42 U.S.C. 4321 et seq.); the
Unfunded Mandates Act of 1995 (Pub. L. 104-4); the Paperwork Reduction
Act (44 U.S.C. 3501 et seq.); the Regulatory Flexibility Act (5 U.S.C.
601 et seq.); and certain Executive Orders.
The draft of today's action and any other documents submitted to
OMB for review are part of the rulemaking record and are available for
public review at the U.S. Department of Energy, Resource Room of the
Building Technologies Program, Sixth Floor, 950 L'Enfant Plaza, SW.,
Washington, DC (202) 586-2945, between 9 a.m. and 4 p.m., Monday
through Friday, except Federal holidays.
VII. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of today's advance
notice of proposed rulemaking.
Issued in Washington, DC, on February 21, 2008.
Alexander A. Karsner,
Assistant Secretary, Energy Efficiency and Renewable Energy.
[FR Doc. E8-4018 Filed 3-12-08; 8:45 am]
BILLING CODE 6450-01-P