November 28, 2
February 23, 2015
VIA EMAIL TO: GSL2013STD0051@ee.doe.gov
Ms. Brenda Edwards
US Department of Energy
Buildings Technologies Program
Mail Stop EE-2J
1000 Independence Ave, SW
Washington, DC 20585-0121
NEMA Comments on Energy Conservation Program: Energy Conservation Standards
Rulemaking Preliminary Technical Support Document for General Service Lamps
Docket Number: EERE-2013-BT-STD-0051
RIN: 1904-AD09
Dear Ms. Edwards,
The National Electrical Manufacturers Association (NEMA) appreciates the opportunity to
provide the attached comments on the Department of Energy’s Preliminary TSD (pTSD) for
Energy Conservation Standards for General Service Lamps. These comments are submitted
on behalf of NEMA Light Source Section member companies.
As you may know, NEMA is the association of electrical equipment and medical imaging
manufacturers, founded in 1926 and headquartered in Arlington, Virginia. The National
Electrical Manufacturers Association (NEMA) represents nearly 400 electrical and medical
imaging manufacturers. Our combined industries account for more than 400,000 American jobs
and more than 7,000 facilities across the U.S. Domestic production exceeds $117 billion per
year.
Please find our detailed comments below. We look forward to working with you further on this
important project. If you have any questions on these comments, please contact Alex
Boesenberg of NEMA at 703-841-3268 or alex.boesenberg@nema.org.
Sincerely,
Kyle Pitsor
Vice President, Government Relations
National Electrical Manufacturers Association
1300 North 17th Street, Suite 900 - Rosslyn, VA 22209
NEMA Comments on Energy Conservation Program: Energy Conservation Standards
Rulemaking Preliminary Technical Support Document for General Service Lamps
We are pleased to address the specific issues that the DOE posed to the public in the workshop
and in the pTSD. NEMA has overarching concerns that form common themes underlying
several of our comments to the specific questions. Specifically, as we discuss in response to
ES.3.21 below, this is not the rulemaking that Congress contemplated in section 320 of the
Energy Independence and Security Act of 2007 (EISA-2007). As we acknowledge below,
NEMA appreciates the explanation provided by DOE that the Consolidated Appropriations Act
of 2014 (and similar predecessor legislation) makes it difficult to consider the real baseline in
this rulemaking and other issues. But we disagree fundamentally with DOE’s approach to
product classes in this rulemaking and the proposal for technology neutral energy conservation
standards. NEMA cannot help but conclude that the present congressional appropriations
directive has influenced DOE’s selection of this approach in a manner not intended by Congress
in EISA-20071.
ES.3 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT
DOE is interested in receiving comment on all aspects of this preliminary analysis. DOE
especially invites comment or data to improve DOE’s analyses, including information that will
respond to the following questions and concerns raised in the development of this preliminary
TSD.
ES.3.1 GSL Definitions
DOE developed definitions for several terms in support of the scope of the rulemaking. DOE
requests comment on the definitions under consideration including “integrated lamp,” “nonintegrated lamp,” “general service LED lamp,” “OLED lamp,” “colored lamp,” “reflector lamp,”
“non-reflector lamp,” “light fixture,” “pin base lamp,” and “GU24 base.”
Integrated lamp means a lamp that contains all components necessary for the starting and stable
operation of the lamp, does not include any replaceable or interchangeable parts, and is connected
directly to a branch circuit through an ANSI base and corresponding ANSI standard lamp-holder
(socket).
NEMA Comment: We disagree with the DOE’s proposed definition of Integrated Lamp. The
bases on integrated lamps mentioned in the definition should be limited to those bases most
commonly used with the lamps covered within the scope rulemaking. Currently these bases
would be limited to medium screw bases and GU-24 bases for integrated lamps. If the scope of
the regulation changes in the future, this definition can be adjusted at that time. Following is our
suggested definition change:
“Integrated lamp means a CFL or LED lamp that contains all components necessary for the
starting and stable operation of the lamp, does not include any replaceable or interchangeable
1
For a discussion of EISA-2007 provisions pertaining to this rulemaking, see NEMA comments to DOE Framework
for GSL section “General Comments” at pages 2-7,
http://www.regulations.gov/contentStreamer?objectId=0900006481557fe6&disposition=attachment&contentTyp
e=pdf
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parts, and is intended to be connected directly to a branch circuit through a Medium Screw Base
or a GU24 base.”
Non-integrated lamp means a lamp that is not an integrated lamp.
NEMA Comment: We disagree with the DOE’s proposed definition of non-integrated lamp.
Many of the lamps that would be covered by this broad definition are not within the scope of the
rulemaking. This definition needs to be limited to the lamps covered by the scope. We suggest
the following:
“Non-integrated lamp means a lamp that requires additional external components for starting
and stable operation of the lamp such as a ballast or a driver and has a single-ended 2-pin or 4pin base.”
General service light-emitting diode (LED) lamp means an integrated or non-integrated LED lamp
designed for use in general lighting applications (as defined in 430.2).
NEMA Comment: We suggest the addition of wording to clarify the use of LEDs in a GSL LED
and proposed the words “that uses light emitting diodes as the primary source of light” be added
to the end of DOE’s proposed definition:
General service light-emitting diode (LED) lamp means an integrated or non-integrated LED
lamp designed for use in general lighting applications (as defined in 430.2) that uses light
emitting diodes as the primary source of light.
Organic light-emitting diode or OLED lamp means an integrated or non-integrated lamp that uses
OLEDs as the primary source as light.
NEMA Comment: We note a typo in DOE’s proposed definition for OLED lamps and also
suggest it be modified for clarity as follows:
Organic light-emitting diode or OLED lamp means an integrated or non-integrated lamp
designed for use in general lighting applications that uses OLEDs as the primary source of light.
Colored lamp means a colored fluorescent lamp, a colored incandescent lamp, or a lamp designed
and marketed as a colored lamp and not designed or marketed for general lighting applications with
either of the following characteristics (if multiple modes of operation are possible [such as variable
CCT], either of the below characteristics must be maintained throughout all modes of operation):
(1) A CRI less than 40, as determined according to the method set forth in CIE Publication
13.3 (incorporated by reference; see §430.3); or
(2) A correlated color temperature less than 2,200 K or greater than 7,000 K as determined
according to the method set forth in IES LM-66 or IES LM-79 as appropriate (incorporated
by reference; see §430.3).
NEMA Comment: We agree with the proposed definition
Reflector lamp means a lamp that has an R, PAR, BPAR, BR, ER, MR, or similar bulb shape as
defined in ANSI C78.20 (incorporated by reference; see §430.3) and ANSI C79.1 (incorporated by
reference; see §430.3) and is used to direct light.
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NEMA Comment: We agree with the proposed definition
Non-reflector lamp means a lamp that is not a reflector lamp.
NEMA Comment: This definition can be deemed vague, and we suggest the following wording
in the interest of clarity:
Non-reflector lamp means an integrated or non-integrated lamp that is not a reflector lamp.
Light Fixture means a complete lighting unit consisting of lamp(s) and ballast(s) (when applicable)
together with the parts designed to distribute the light, to position and protect the lamps, and to
connect the lamp(s) to the power supply.
NEMA Comment: We agree with the proposed definition
Hybrid compact fluorescent lamp means a compact fluorescent lamp that incorporates one or more
supplemental light sources of different technology.
NEMA Comment: DOE’s proposed definition is vague. We suggest the following changes in the
interest of clarity:
Hybrid compact fluorescent lamp means a compact fluorescent lamp that incorporates one or
more supplemental light sources of different technology, such as halogen or LED, which are
energized and operated independently and may or may not operate simultaneously.
Pin base lamp means a lamp that uses a base type designated as a single pin base or multiple pin base
system in Table 1 of ANSI C81.61, Specifications for Electrics Bases (incorporated by reference; see
§430.3).
NEMA Comment: We agree with the proposed definition
GU24 base means the GU24 base standardized in ANSI C81.61 (incorporated by reference; see
§430.3).
NEMA Comment: We agree with the proposed definition
ES.3.2 Specialty Application MBCFLs and LED Lamps
DOE identified MBCFLs and LED lamps that are designed for specialty applications and are not
able to provide overall illumination including: black light lamps, bug lamps, colored lamps, plant
light lamps, and silver bowl lamps. DOE is considering providing exemptions for these specialty
applications. DOE requests comment on the MBCFLs identified for specialty applications that
cannot provide overall illumination and if there are other MBCFLs that should be considered.
DOE requests comment on the LED lamps identified for specialty applications that cannot
provide overall illumination and if there are other LED lamps that should be considered.
NEMA Comment: We agree that black light lamps, bug lamps, colored lamps, plant light lamps,
and silver bowl lamps are designed for specialty applications and do not provide overall
illumination.
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ES.3.3 GSL Exemptions
DOE assessed the full list of exemptions that apply to GSILs to determine if the lamp types
provide overall illumination and therefore can be used in general lighting applications. Of the
exemptions provided for GSILs, DOE has preliminarily determined that appliance lamps, black
lights, bug lamps, colored lamps, infrared lamps, marine signal lamps, mine service lamps, plant
lights, sign service lamps, silver bowl lamps, showcase lamps, and traffic signal lamps cannot
provide overall illumination and therefore cannot be used in general lighting applications. DOE
is considering not establishing standards for these lamp types under the GSL rulemaking because
the lamps are intended for use in non-general applications. DOE requests comment on the
exemptions that DOE is considering providing for GSLs based on its assessment that the lamp
types are intended for non-general applications.
NEMA Comment: We agree that specialty lamp exemptions are needed for CFL and LED lamps
to cover the development of future energy efficient specialty lamps as potential substitutes for
incandescent technology in specialty lamps if feasible. We agree with the DOE that: Appliance,
Plant, Black Light, Sign Service, Bug, Silver Bowl, Colored, Showcase, Infrared, Traffic signal,
Marine Signal and Mine Service lamps should be exempted from efficiency regulations as low
volume specialty lamps that are designed for specialty applications and that do not provide
overall illumination. They would not provide an acceptable substitute for lamps commonly used
in general service lighting applications.
DOE has preliminarily determined that 3-way lamps, vibration service lamps, rough service
lamps, and shatter-resistant lamps are able to provide overall illumination and therefore can be
used in general lighting applications. For these reasons, DOE believes that 3-way lamps,
vibration service lamps, rough service lamps, and shatter-resistant lamps are general service
lamps and do not require an exemption from standards. DOE requests comment on this decision.
NEMA Comment: If the CFL or LED replacement lamps for these traditional incandescent
specialty product categories are regulated, special considerations may be required which will
vary depending on the specialty product.
If 3-way CFL or LED lamps are regulated, the efficiency requirements should be evaluated
based on the highest, most energy consuming setting. As 3-way CFL lamps will operate at
different efficiencies when operated at different light levels, it is important that DOE base
compliance on operating only at the most efficient level, which is the highest light output
level. Forcing the lower light output settings to meet high efficiency levels would be very
problematic for industry and may remove this product utility from the market. This approach of
testing only at the highest level is also used in other current standards (ENERGY STAR) for
these products.
Shatter resistant lamps normally contain a coating which absorbs a small portion of the light
output. Light absorption factors would have to be considered when setting efficiency regulations
covering this technology.
Rough Service and Vibration Service lamp definitions are unique to incandescent technology
and are not applicable to CFL or LED technology because they are more shock resistant by
design.
5
During the public meeting, DOE also discussed Left-Hand Thread, Marine, Reflector and
Specific lamp shapes. NEMA agrees that Left-hand Thread and Marine exemptions are no
longer necessary for CFL or LED technology.
NEMA believes that it would be inappropriate to include Reflector lamps as covered products in
this rulemaking which is concerned with omnidirectional general service lamps. Lamps with a
built-in reflector are designed for very specific applications and offer a unique product class with
unique performance and efficiency features. Such lamps are not appropriate replacements for
general service omnidirectional lamps and should not be analyzed in the same rulemaking.
The specific lamp shapes exempted in the current incandescent rule primarily provide
decorative illumination and are not purely functional as with most general service lamps.
Decorative lamp shapes provide unique technical challenges for both CFL and LED technology
and they cannot be assumed to be capable of reaching similar efficiency levels. The technical
effort necessary to mimic the consumer-demanded performance attributes of some decorative
products will come with corresponding tradeoffs in efficiency potential. Because manufacturers
are only beginning to develop these types of lamps the size of this efficiency impact is not wellknown. Because of these unknowns, NEMA does not recommend regulating decorative LED or
CFL lamp shapes at this time because of the lack of information and understanding of the cost
and technical impacts of their performance demands. Regulating this emerging product
category (primarily B, BA, CA, F, G16-1/2, G25, G30, G40, S and long T Lamps) at this time will
slow product innovation and slow the development and consumer acceptance of energy efficient
decorative lamps. When a regulatory specification is established – say for energy efficiency – at
an early stage of a product’s life, it inhibits the manufacturer’s flexibility to experiment with other
product specifications that may relate to consumer acceptance of that product or the product’s
utility. As acceptable decorative energy efficient replacement lamps are developed, DOE can
further assess this product category in the future.
ES.3.4 OLED Lamps
DOE requests comment on its consideration to continue to not establish standards for OLED
lamps in this rulemaking.
NEMA Comment: We agree that it is premature to establish standards for OLED products at this
time. Among the reasons for our agreement is our overarching concern with regulating
emerging product categories, creating a substantial risk of product slowing innovation and the
development and consumer acceptance of this product category.
ES.3.5 Lamps Addressed in Other Rulemakings
DOE has the authority to consider additional lamp types that it determines are used to satisfy
lighting applications traditionally served by GSILs. To limit the probability that one lamp type
might be subject to two different standards, DOE is not considering including self-ballasted
mercury vapor lamps in the scope of this rulemaking. DOE requests comment on its
consideration to exclude from the scope of the GSL rulemaking lamps that are addressed in other
rulemakings.
NEMA Comment: We agree that self-ballasted mercury vapor lamps should not be included in
this rulemaking.
ES.3.6 Other Integrated Lamps
6
DOE does not believe that LED technology is currently able to provide the same utility as
halogen technology in the MR16 lamp shape. Because more efficient replacements that maintain
the same utility are not currently available, DOE has tentatively decided to not establish energy
conservation standards for reflector pin base integrated lamps at this time. DOE requests
comment on whether LED MR16 lamps are suitable replacements for incandescent/halogen
reflector integrated MR16 lamps.
NEMA Comment: We agree that current MR16 LED lamps cannot provide all the functionality
of currently available Halogen MR16 lamps. As this is a developing product category, MR16
lamps should not be regulated during this rulemaking.
DOE also requests comment on whether there are any integrated lamps with other bases than
screw bases that have a significant market share.
NEMA comment: We believe that the market share for integrated CFLs with GU24 bases is
insignificant (less than 4%), and that GU24 based CFL products should be excluded from
scope. There are no additional bases used at this time for common general service lamps that
have a significant market share.
ES.3.7 Other Non-Integrated Lamps
Due to low market share and to avoid stifling innovation with LED non-reflector pin base nonintegrated lamps, DOE is not considering establishing standards for these products. DOE
requests comment on the market share and technological feasibility of increasing the efficacy of
non-reflector pin base non-integrated lamps.
NEMA Comment: We do not believe that there will be any innovation in LED non-reflector pin
base non-integrated lamps. These lamps are the same wattage as the CFL pin base lamps
they look to replace and they are not dimmable (which represents a loss of functionality). Also
the lamp-ballast pairings we have investigated do not have UL listing and we consider this to be
significant. This lamp is not as simple in practice as a T8 replacement; there are multiple bases,
multiple wattages, multiple sizes and multiple ballasts. We believe that if one is going to retrofit
one’s CFL pin base lamps, there are more efficacious choices than the LED non-reflector pin
base non-integrated lamps. Additionally, compatibility problems with reduced wattage lamps
are not well understood in the DOE analysis, and could result in field issues if pursued.
DOE identified screw base and pin base non-integrated lamps that meet the definition of GSL.
DOE requests comment on whether there are any non-integrated lamps with other bases that
meet the definition of GSL and the market share of these lamps.
NEMA Comment: There are no non-integrated lamps with other bases that meet the definition of
General Service lamp as defined with NEMA’s updated definitions.
ES.3.8 MBCFL Metrics
DOE has the authority to revise the existing metrics and consider additional metrics for MBCFLs
in this rulemaking and requests comment on several topics related to this. Regarding metrics that
DOE is not considering revising, DOE requests comment on maintaining the current lumen
maintenance requirements. Regarding metrics that DOE is considering revising, DOE requests
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comment on the rapid cycle stress performance of commercially available MBCFLs and the
appropriateness of requiring an increased lifetime of 10,000 hours for MBCFLs. Regarding
metrics that DOE is considering adding, DOE requests comment on adding a requirement for
power factor and its consideration of a standard for power factor of 0.5 or greater; CRI and its
consideration of a standard for CRI of 80 or greater; and the start time of MBCFLs and its
consideration to require a start time of within one second of the application of electrical power.
Regarding metrics that DOE is not considering adding, DOE requests comment on the
consideration to not set a separate requirement for THD; the consideration to not set a CCT
requirement for MBCFLs; and the consideration to not set requirements for operating frequency.
NEMA Comment: We note that the ENERGY STAR requirements are voluntary standards for
premium products and should not be considered as baseline requirements for medium base
compact fluorescent lamps. There are energy efficient MBCFL products on the market that do
not meet the ENERGY STAR specification. NEMA agrees with DOE that requirements for THD,
CCT and operating frequency should not be considered.
For compact fluorescent lamps, the current statutory and regulatory requirements for Lumen
Maintenance, Rapid Cycle Stress testing and Life are acceptable. Besides minimum energy
efficiency requirements (the primary focus of DOE regulations) these requirements were
introduced by Congress to address poor quality products that damaged the reputation of CFLs
and hindered consumer adoption of CFLs. This was a major issue when EPAct 2005 was
enacted. These very poor quality products are now gone. These quality requirements were not
introduced and are not intended as a mechanism to set ENERGY STAR-type levels for premium
products through DOE energy efficiency regulations. Many of these metrics have nothing to do
with energy efficiency.
Increasing the Rapid Cycle Stress test to current ENERGY STAR standards is not necessary to
set a minimum Energy Efficiency Standard.
Increasing the minimum life standard to the ENERGY STAR level of 10,000 hours is also not
necessary for energy efficiency standards. If the minimum life is increased, industry would
recommend no more than 8000 hours as a national minimum to enter the market. By definition,
not all products are intended to meet ENERGY STAR performance levels.
Of the remaining items for consideration to add to the regulation, including Power Factor, CRI
and Start Time, NEMA believes that adding power factor, CRI, or start time requirements is not
necessary.
NEMA does not agree with DOE’s assertion (TSD at 2-40) that ”a minimum power factor
requirement could decrease energy use”. This conclusion appears to be based on a document
that is not relevant to a discussion of general service lamps. In the document referenced in the
TSD regarding “Reducing Power Factor Cost” the power factor scenario described is a specific
case involving HID lighting systems used in industrial complexes where the lighting system
represents a major portion of the power consumed. HID lamp technology is not part of the GSL
rulemaking and the power factor associated with an HID lighting system is directly related to the
ballast used, not the HID lamp itself.
Contrary to DOE’s statement in the TSD, there are trade-offs associated with increasing the
power factor in CFL and LED lamps that will reduce lamp efficiency and increase energy use.
Unlike the HID system application referenced in the TSD, GSL lamps do not typically represent
8
a ‘major portion’ of the power used. More to the point, in any scenario where CFL or LED lamps
are used to replace traditional incandescent lamps the substantially lower wattage of these
replacement lamps will result in a reduced lighting load regardless of power factor. Based on
these facts DOE should refrain from including a power factor requirement for general service
lamps in the final rule.
NEMA does not agree that Start Time has any effect on energy efficiency and therefore it
should not be included in this standard.
NEMA believes that CRI is not an appropriate characteristic for a minimum energy efficiency
standard.
ES.3.9 GSL Technology Options
DOE requests comment on the technology options under consideration for GSLs. Specifically,
DOE also requests comment on the addition of reduced current density as a technology option.
NEMA Comment:
CFL
 Highly Emissive Electrode Coatings – Has been looked at in the past but overall
performance of existing emitters are already designed for energy conservation and long life.
Further changes could have a dramatic effect on shortening lamp life. Any potential
improvements would be minimal.
 Higher Efficiency Lamps Fill Gas Composition – Based on current technologies, the limits of
gas fill technology has been reached by manufacturers.
 High Efficiency Phosphors – Current technology has reached its limit. A breakthrough is
needed to improve and none is foreseen in the near future. Because of REO availability and
cost issues, all coating resources are being used to reduce losses and optimize current
technology performance.
 Glass Coatings – Improvements have been made in this area over the years. A
breakthrough is needed to improve – no actions underway that would result in major
improvements.
 Cold Spot Optimization - The effectiveness of any cold spot design is limited by the ambient
temperature of a lamp in operation, for example, in fixtures. The cold spot temperature can
never be lower than ambient temperature next to the cold spot. This limits the light output
gains through cold spot optimization.
 Active cooling approaches have been studied, but are absolutely cost prohibitive, and may
lower efficacy due to the power needs of the active cooling system.
 Higher Efficiency Diameters – Manufacturers are already producing lamps within the ideal
diameters for maximum efficiency.
 Multi-Photon Phosphors – Has been reviewed in the past and no cost effective improved
performance phosphors have been identified. NEMA agrees with DOEs decision to screen
out Multi-Photon Phosphors.
 NEMA agrees that the use of higher grade components could slightly reduce energy loss
and that the cost impact of such improvements must be evaluated in determining
requirements.
 NEMA’s position is that for residential ballasts, increasing the power factor will raise ballast
losses which will more than offset any gains in distribution efficiency and could have a
negative impact on system reliability. In addition, compact fluorescent lamps used in the
9

home have a leading power factor which tends to offset the lagging power factor of motor
loads and helps to balance the overall power factor of the home.
NEMA is also unaware of any emerging technology that promises to lower ballast losses
while maintaining the same level of performance compared to today’s state of the art ballast
designs.
DOE believes “[t]hese design options are being utilized in commercially available lamps and
have demonstrated that they are technologically feasible, practicable to manufacture, install,
and service, and do not result in adverse impacts on product utility/availability or health and
safety.2” NEMA disagrees. Some of the proposals listed are not practical or are impossible in
mass production, or are so cost-prohibitive that the lamps would become very unaffordable.
And the technology options that truly are “...technologically feasible, practicable to
manufacture...“, are currently in use. Put another way, these ideas are not new, and any that
are beneficial to this mature technology are in use today. Revisiting these proposals would not
only involve significant R&D, but result in few if any benefits. See our comments on
Manufacturer Impact Analysis at page 29, infra.
It would be incorrect for DOE to assume that the apparent differences in efficacies are the result
of superior design. Those differences are more likely the consequences of differing
manufacturing processes employed by different sources of CFL.
LED
 Efficient Down Converters - These are not in use today due to the following: technical
challenges surrounding narrow-band phosphors that enable high spectral efficiency include
robust packaging for lumen maintenance, while achieving high quantum efficiency under
high temperature and flux.
 Improved Package Architectures - Reliable die attachment methods are needed to enable
high temperature operation and there is a need for polymer optical encapsulants to improve
color stability and emitter lifetime, and high thermal conductivity to reduce downconverting
layer temperatures. Another challenge is the development of high index encapsulants to
increase photon extraction. Further challenges may be different depending on the
architecture approach; e.g. mixed-color solutions may require additional controls increasing
the cost of the package.
 Improved Emitter Materials - At least 4 colors, including green and yellow, are required to
achieve high color quality. There is no clear development path towards efficient direct green
and yellow emitters. Also, multi-color modules need more sophisticated drivers to maintain
color stability (due to different degradation rates of different colors). NEMA agrees with
DOEs decision to screen out this technology.
 Alternative Substrate Materials - The cost of GaN substrates is high. The performance of Si
and GaN-on-Si-based devices is not significantly better than sapphire-based devices and
does not warrant a transition to these substrates.
 Improved Thermal Interface Material (TIM) – Challenges: develop TIMs that enable high
efficiency thermal transfer for long-term reliability and performance optimization of the LED
device and overall lamp product.
 Optimized Heat Sink Design - The performance of the heat sink is generally compromised
by material cost (e.g. metal vs. plastic) and geometrical constraints (e.g. in retrofit lamps).
 Active Thermal Management Systems - Reliability and cost are major concerns.
2
pTSD document item 4.4
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Device Level Optics - The package size limits the extent of beamshaping that can be done
with reasonable extraction efficiency. It may also not be desirable to integrate applicationspecific functions at a low system level for complexity management reasons.
Increased Light Utilization - This is a trade-off with system level cost.
Improved Driver Design – In addition to efficiency, drivers must meet many specifications
(cost, power quality, flicker, dimmability, isolation, line regulation, and transient / surge
protection). Optimization for specific applications often leads to a compromise in efficiency.
AC LEDs - True AC-LEDs (i.e. for bidirectional bias) by definition have < 50% utilization, and
often still need external components (for surge protection, flicker mitigation etc.).
Challenges for HV-LEDs in general include efficiency loss due to die segmentation,
increased die/package complexity to sustain the high voltage, and the wide variety of
optimum forward voltages. NEMA agrees with DOEs decision to screen out this technology.
Reduced Current Density - Current density is only one aspect in the design of an efficient
LED die and there are many tradeoffs that take place to ensure higher efficiency. Optimizing
on this one aspect will lead to lower overall efficiency.
ES.3.10 GSL Product Classes
DOE is considering establishing three product classes for this rulemaking. DOE welcomes
comments on the product class divisions it is considering for GSLs in this preliminary analysis.
Further, DOE specifically requests comments on a product class division based on lumen
package for the integrated GSLs. DOE also requests comments on its preliminary determination
that energy consumed in standby mode will be negligible and therefore a product class division
based on standby mode operation for integrated GSLs is not warranted.
NEMA Comment: NEMA disagrees with the three product classes presented for discussion by
the DOE. The overriding determination that must be used to set the product classes is the
technical capability and varying utility of differing technological approaches to produce the same
light output. Placing all general service lamp products in common lumen ranges will result in the
elimination of all technologies and all product utilities except that provided by the most
efficacious technology. Therefore determining product classes based only on lumen output is
not appropriate for general service lamps. For the variety of reasons discussed elsewhere in
our comments, NEMA does not agree that it is good public policy to adopt a technology neutral
approach to energy conservation standards for general service lamps under EPCA. This is true
for both the general service CFL and LED segments presently under consideration by DOE in
this rulemaking, and it is equally true for the halogen incandescent, CFL, and LED classes.
In addition, we do not believe that non-integrated pin-base CFLs should be included in the
scope of this rulemaking and therefore should not be given a general service lamp product
class. Pin-based compact fluorescent lamps are rarely used in residential applications (the
primary application for screw-based general service lamps) and cannot directly replace medium
screw-based general service lamps without replacing the entire fixture. Few residential fixtures
are designed to use pin-based CFLs. Fixtures using these lamp types are nearly all designed for
commercial applications. Further, these mature products are already at max tech so there is
very little opportunity to increase efficiency. Even if efficiency can be increased, it will generally
result in lamps with slightly higher lumen output, not reduced wattage, as the dedicated ballasts
will drive them at the same wattage levels. Although there are a few products designed to
operate in an energy saver reduced wattage mode, they are only available for a few product
types and they typically have similar efficacy; wattage and lumens are similarly reduced.
Reduced lumens are not acceptable in many applications. While there are some LED lamp
replacements being developed at this time, they generally have identical wattage to non11
integrated pin-base CFLs. These LEDs represent a loss of utility since they do not work with
some types of controls and dimming systems. Furthermore, there is no energy savings since
there is no reduction in wattage. We ask the DOE to afford the same recognition of the
implications of a Lamp rule on non-integrated ballast systems as they did in the General Service
Fluorescent Lamp rulemaking3 and our arguments therein regarding lamp wattage versus
ballast wattage and there being no change in overall power consumption, just more lumens from
a given lamp.
The three product classes that are appropriate based on utility and technological capability are
1) Incandescent/Halogen, 2) CFL and 3) LED; that have a medium-screw base and designed to
operate directly on 120 or 130 volts. This also represents the overwhelming majority of sockets
and applications and provides the biggest opportunity for energy savings.
INCANDESCENT/HALOGEN
While NEMA recognizes that DOE cannot address the Incandescent/Halogen efficiency class at
this time, it should be recognized as a product class with the general service lamp area which is
currently regulated. The unique utility and attributes of incandescent or halogen lamp
technology are: low initial cost, omnidirectional point source, point source provides very good
optical control, can provide high sparkle and high brightness, operation unaffected by high or
low ambient temperature, warm color appearance difficult to modify without loss of efficiency,
very high CRI, relative low efficiency, relative short life, adversely affected by vibration,
adversely affected by direct water contact, life not affected by frequent switching, good infrared
source, immediate on to full brightness, great full range dimming in all applications.
CFL
The unique utility and attributes of CFL lamp technology are: relatively low initial cost, relatively
long life, very diffuse omnidirectional source, provides very good general light distribution, very
low pleasing surface brightness, operation is affected by high or low ambient temperature, color
can be modified with some loss in efficiency at high chromaticity and high CRIs, good CRI
capability, relatively high efficiency, vibration resistant, not affected by occasional direct water
spray, life shortened by frequent switching, low heat source, natural slow start may be beneficial
for dark area eye adaptation, can be dimmed with limitations.
The CFL lamp classification should be further sub-divided by Bare-Lamp and Covered-Lamp
classes because covered lamps have meaningfully lower efficiency but provide a unique utility
in contrast to the Bare-Lamp. .
LED
LED lamps also provide unique utility vs. CFL lamps and have very different technical efficiency
capability which requires them to also be placed in a separate class from the first two classes.
The unique utility and attributes of LED lamp technology are: extremely long life, high initial
cost, directional point source, extremely high chip surface brightness, requires special optics
and diffusing materials for omnidirectional applications, operation is affected by high ambient
temperature, operation is not affected by low ambient temperatures, color can be modified with
some loss in efficiency at low chromaticity and high CRIs, good CRI capability, very high
3
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efficiency, vibration resistant, not affected by occasional direct water spray, low heat source,
instant on, can be dimmed with limitations.
Summary of Utility Differences
The three technologies offer considerable differences in performance and utility and each
provides the best solution for differing applications. There are many differences starting with the
most basic construction aspects, filament lamps are low cost omnidirectional point sources, CFL
lamps are low cost omnidirectional diffuse sources, and LED lamps are high cost directional
point sources. Consumers need to be allowed to choose the best technology for their
application and situation. DOE needs to consider separate efficiency levels for each technology
to allow each option to remain available.
LUMEN RANGE DISCUSSION
Efficiency with all technologies decreases with decreasing wattage due to inescapable power
losses from components. There are four natural lumen ranges where consumers select
products. These are a legacy of the original 40w, 60w, 75w, and 100w traditional incandescent
lamps. Lumens ranges for these products are already defined in the existing incandescent
regulations: 100w=1490-2600 lumens, 75w=1050-1489 lumens, 60w=750-1049 lumens, 40
watt= 310-749 lumens. The 100 watt and 40 watt ranges are exaggerated on the high end and
the low end to extend the regulated product range to just above 25 watt and just below 150w
traditional incandescent lamps. As DOE proposed, the higher lumen range can be limited to
2000 lumens for current LED technology.
All three product classes should be divided into these four natural lumen ranges. This will
provide DOE the opportunity to set efficiency limits that are appropriate for the technologies
being sold in each lumen range. This may be necessary as technical limitations and
performance can vary greatly depending on the wattage and technology. This approach will
allow such limits to be a single LPW or Wattage number, a linear equation, a quadratic equation
or an exponential equation as necessary within the range and technology under consideration.
This will allow the use of different approaches in different areas considering the widely different
technologies under consideration.
When complete, such as class matrix would look similar to the following:
Lumens
Standard
Inc./Hal
Mod. Spec. Inc.
Hal
Bare CFL
Covered CFL
LED
310-749
Wattage
Limit 1
Wattage
Limit1
.75xLumens
LPW no. or
equation 1
LPW no. or
equation 5
LPW no. or
equation 9
750-1049
Wattage Limit
2
Wattage
Limit2
.75xLumens
LPW no. or
equation 2
LPW no. or
equation 6
LPW no. or
equation 10
13
1050-1489
Wattage
Limit 3
Wattage
Limit 3
.75 x Lumens
LPW no. or
equation 3
LPW no. or
equation 7
LPW no. or
equation 11
1490-2000
2000-2600
Wattage Limit 4
Wattage Limit 4
.75 x Lumens
LPW no. or equation 4
LPW no. or equation 8
LPW no. or
equation 12
None
NEMA agrees that a special modified spectrum class is not needed for CFL or LED technology.
NEMA also agrees that standby power for LED products will be minimal compared to impacts of
the classifications shown above and would not require a separate class.
The existing efficiency levels are as follows:
Lumens
310-749
750-1049
1050-1489
1490-2000
2000-2600
Standard
29 w
43 w
53 w
72 w
Inc./Hal
Mod. Spec. Inc.
29 w
43 w
53 w
72 w
Hal
.75xLumens .75xLumens
.75 x Lumens .75 x Lumens
Bare CFL
45 LPW
45/60 LPW*
60 LPW
60 LPW
Covered CFL
40 LPW
48 LPW
50 LPW
55 LPW
LED
N/A
N/A
N/A
N/A
N/A
* This lumen range breaks across a jump in efficacy from 45 to 60LPW at a rated wattage of
15W.
Proposed CSL
Lumens
Standard
Inc./Hal
Mod. Spec. Inc.
Hal
Bare CFL
Covered CFL
LED
310-749
29 w
750-1049
43 w
1050-1489
53 w
1490-2000
72 w
29 w
.75xLumens
50 LPW
45 LPW
55 LPW
43 w
.75xLumens
60 LPW
50 LPW
65 LPW
53 w
.75 x Lumens
61 LPW
52 LPW
65 LPW
72 w
.75 x Lumens
62 LPW
55 LPW
65 LPW
2000-2600
None
ES.3.11 GSL Design Options
DOE requests comments on the design options it is considering for GSLs.
NEMA Comment: Integrated and non-integrated CFL designs are very mature. This technology
was first brought to market in the 1980s. All of the practical design options to improve efficiency
have been implemented over the past 20 to 30 years. There is very little room left to improve
efficiency.
White light LEDs are a much newer and evolving technology. Several of the technology options
listed are being evaluated or optimized as a means of increasing efficiency.
We note that current LED lamp designs are very efficient compared to legacy technology, and
as a result of market forces manufacturers are now focused on reducing cost versus increasing
efficiency even higher. The DOE should recognize this and NOT pursue extremely high
efficiencies above today’s average LED product, in favor of affording industry the ability to focus
on reducing cost which will directly spur increased adoption. High CSLs risk inhibiting adoption
by increasing LED product costs relative to low CSL levels. This is because at the high CSL
levels technology advancements will have to be used to increase efficiency rather than
decrease costs.
ES.3.12 GSL Data Approach
DOE welcomes comment on the data approach including any additional databases that should be
considered.
14
NEMA Comments: NEMA has serious reservations about the use of catalog data in assessing
the performance of GSLs, especially for products without published test procedures. DOE will
recall that initial or rated lumens are long term means and that rated or nominal lumens are not
necessarily measured values. Furthermore, NEMA is unaware of any databases where nonintegrated CFL pin base lamp data are available.
ES.3.13 GSL Baseline Selection
DOE is directly analyzing all product classes and has selected one baseline lamp for each
product class. DOE requests comment on its analysis of one baseline lamp for each product
class. DOE also requests comment on the baseline units selected for each product class.
NEMA Comment: We are concerned about the selection of baseline lamps for MBCFL and the
non-integrated pin-base CFL. The MBCFL baseline lamp is practically aligned with the
requirements for ENERGY STAR. CFL pin base lamps have unique base and pin
configurations and if the baseline lamp is eliminated consumers will be faced with stranded
assets because anyone with these fixtures will be forced to make fixture changes.
We also note that the CSLs proposed for CFL are NOT for two levels of performance of the
SAME product but instead for DIFFERENT products. CSL0 is clearly for a lamp with a cover,
and CSL1 is for bare spiral lamps. DOE must not eliminate the consumer preference for a utility
of a lamp with a cover, so these products should be divided into two classes for the purposes of
standards. (See our comments above in item ES.3.10 under the heading “CFL”.)
ES.3.14 More Efficacious Substitutes
DOE requests comment on the criteria used in selecting more efficacious substitute lamps in the
integrated product class, as well as the characteristics of the lamps selected. In particular, DOE
requests comment on its assumptions that more efficacious substitutes must have lumen output
within 10 percent of the baseline lamp and must be omnidirectional light sources.
NEMA Comment: We agree that to satisfy consumer expectations for replacement lamps, that
the substitute lamp must be within 10 percent (either higher or lower) of the lumen output from
the baseline lamp. The source should also be reasonably omnidirectional if it is serving a
general service lamp application. Although ENERGY STAR specifies intensity distribution
requirements for omnidirectionality, CFLs are presumed to be omnidirectional and are excluded
from the testing. Thus lamps investigated by the DOE as marketed as omnidirectional were
most likely SSL products. Because omnidirectionality has not been a topic of standards in DOE
before, requiring it in a substitute lamp may very well exclude CFLs from the discussion, which
is not acceptable.
We are concerned about DOEs choices of more efficacious substitutes for non-integrated pinbase CFL lamps. The baseline and more efficacious substitute lamps the DOE has chosen are
4-pin non-integrated lamps used in commercial, rather than residential applications. The two
CSL1 choices are problematic. The first choice offers no energy savings - it is the same
wattage as the baseline lamp. The second choice, a reduced wattage lamp, may not be
supported by the existing ballast and furthermore is not within 10% of the baseline lamp lumens.
ES.3.15 Non-Integrated Ballast Pairing
15
DOE pairs non-integrated GSLs with representative ballasts because the non-integrated GSLs
analyzed in this preliminary analysis operate on a ballast in practice. DOE requests comment on
the lamp-and-ballast systems selected for the non-integrated product class.
NEMA Comment: Non-integrated lamps must be paired with a unique ballast and a very specific
base to electrically and mechanically operate. DOE has selected only one system to analyze.
There are dozens of pin-based systems that have not been analyzed, but are included in the
scope proposal. Analyzing different lamp/ballast combinations will produce very different
results. In most cases, the DOE will determine that there is no energy saving potential with most
combinations. The area is very complex and the current analysis is far from adequate. Due to
the complexity, the limited energy savings potential, and the maturity of this product line, NEMA
strongly suggests that DOE remove this product category from the scope of this rulemaking.
These commercial products are not an acceptable replacement for traditional incandescent
general service lamps. We believe that if DOE performs a complete analysis on all product
combinations it would support NEMA’s conclusion.
ES.3.16 Candidate Standard Levels
DOE requests comment on the CSLs under consideration for the integrated and non-integrated
product classes, including the max tech levels.
NEMA Comment: Per our comments in item ES.3.13, by placing all integrated lamps into only
two categories DOE ends up with CSLs that only represent one type of technology. More
concerning is that with this approach, the standards will either be set very low so all
technologies, including covered-CFLs can meet all levels, or very high standards such that only
the most efficiency LED lamps can meet the levels. Both results are far from ideal from either
energy savings, product cost/availability or utility standpoints. To avoid either outcome, a
carefully constructed class matrix must be used with separate baseline lamps for each
technology class.
ES.3.17 CSL Equation Methodology
DOE requests comment on the methodology used to develop the CSLs equations. In particular,
DOE requests comment on the use of a lumens-based equation and the equation form itself.
NEMA Comment: We are very concerned how the CSL equation for non-integrated GSLs was
developed. These lamps are currently unregulated and have no test procedure. We are
unaware of databases for these lamps and if they exist, the veracity of the data. The DOE
cannot reasonably rely upon catalog data to determine the efficacy of pin-based CFLs. Nominal
and rated wattage are not measured watts and catalog initial lumens represent long term data,
not individual lamp photometric performance. Furthermore, since there is no defined test
procedure for non-integrated lamps, testing laboratories may not be using the same test
methods and thus the information published in individual manufacturers’ catalogs may not be
comparable.
NEMA is also concerned about how the curves will translate across the 4 lumen ranges. There
can be slight discontinuities in efficiency, up or down, depending on the technology used in the
various ranges. Although a smooth curve across all 4 lumen bins may be the final outcome for
some CSL levels. Each lumen bin should be evaluated separately as to the proper efficiency
level for that bin, and for a specific technology. It is more likely that the curve will not connect
16
smoothly across all 4 bins at every CSL. There will be fewer CSL levels for CFL technology,
whether integrated or non-integrated.
ES.3.18 Non-Integrated GSL Replacement Assumptions
DOE found that the fixtures frequently used with the non-integrated GSLs analyzed were
available in configurations for several different lamp types, and therefore assumed that fixture
compatibility would not be an issue for the vast majority of consumers. DOE requests comment
on its assumption that fixture compatibility would not be a common issue for non-integrated
GSL replacements.
NEMA Comment: What the pTSD does not acknowledge is that, while fixtures are available in
configurations for various lamps types, a particular fixture is configured for a particular base,
and with the possible exception of recessed cans, a particular length and a particular shape
(diameter) lamp. Just because a manufacturer makes fixtures that accommodate the available
bases and sizes does not mean that the available lamps complying with the standard will have
the correct base or be the correct size to fit in a customer’s existing fixture. In this situation, the
fixture (and ballast) will need to be replaced and not everyone is able to afford to replace the
fixture. Put another way, setting standards for non-integrated lamps significantly increases the
occurrence of stranded consumer assets.
DOE evaluated the impacts of CSL 1 on the individual base types in the non-integrated product
class. DOE confirmed that the vast majority of base types were still available at CSL 1, and
therefore consumers will not be forced to switch between lamps with differing base types. DOE
also requests comment on its assumption that consumer utility will not be lost with the base types
that remain at CSL 1.
NEMA Comment: Pin-based compact fluorescent lamps have either 2 pins or 4 pins. Each 2-pin
lamp has an internal starter and is designed for preheat, magnetic operation. The 4-pin lamps
are designed for electronic ballast operation and are dimmable. These lamps have no internal
starter; starting the lamps is a function of the ballast.
For choke/starter operation:
For electronic or dimming operation:
17
The fits are poke-yoked or keyed which means that one cannot mismatch the base and the
socket unless one alters the base (which has its own safety concerns). Removing a base
reduces utility.
Although many lamps are still available at CSL1, these products operate at the same wattage
as the base case, only with slightly higher lumen output; therefore, no energy is saved. This is
the same issue as discussed in the General Service Fluorescent Lamp rulemaking4; higher
efficiency at the same ballast wattage is not true energy savings, just potential over-illumination.
However if the available lamps do not fit (base, size) entire fixtures will have to be replaced for
most of these base types. This is not economically feasible. As the two options are no energy
saved, or not economically feasible, this product class should not be regulated and should be
dropped from the scope of general service lamps.
ES.3.19 Product Price Determination
DOE invites comment on the methodology and results for estimating end-user prices for GSLs in
this preliminary analysis. DOE also requests comment on the appropriateness of the distribution
channels and estimated percentage shipments through each channel used in this preliminary
analysis.
NEMA Comment: As stated in the January 20th public meeting, NEMA believes the DOE has
erred in their assumptions about the causes of change to product prices over time. The very
short amount of market exposure for LED lamps and high rate of innovation has resulted in
strong price reductions with large technology improvements. DOE’s typical analysis model
examined mature products well-along in their lifecycle, and assumes that improvements are
more incremental. In the case of LED lamps, technology improvements have been jumping
forward as new discoveries are applied, and families of products are only now evolving in a
linear method like legacy technology did. Therefore, it is incorrect to compare prices for lamps
for sale today with lamps for sale a few years ago. They are not the same lamps. They are new
4
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designs and they are not comparable.
lamps to recognize this phenomenon.
The DOE must redesign their price model for LED
ES.3.20 GSL Hours of Use
DOE requests comment on the data and methodology used to estimate operating hours for GSLs,
particularly in the residential sector. Also, DOE seeks comment on its assumption that GSL
operating hours will not vary by light source technology during the analysis period.
NEMA Comment: Our comments here are related to our comments in response to the next
question (ES.3.21). In chapter 2 of the pTSD, §2.9, DOE states: “DOE assumed that the higher
hours of use found for CFL GSLs is based on those lamps currently disproportionately filling
sockets with higher hours of use. This would not be the case during the analysis period, when
CFL and LED GSLs are expected to fill all GSL sockets.” For the reasons explained in
response to the next question, NEMA disagrees that “this would not be the case during the
analysis period.”
The sources of information cited by the DOE in chapter 2 of the pTSD, §2.9 pages 2-80 through
2-82 and the pTSD chapter 7 confirm NEMA’s own experience that CFLs and LED lamps are
predominantly installed in sockets with somewhat longer operating hours than sockets where
halogen incandescent lamps are installed.5 In residential applications, lamps with longer lives
tend to be used in fixtures with longer operating hours, and therefore, it is likely that halogen
lamps will be used in fixtures with shorter operating hours such as closets, or used on dimmers
at lower wattages, which extends lamp life. CFLs are the next longest lived lamps and can be
expected to be used in fixtures with somewhat longer operating hours, and LEDs are expected
to be used in fixtures with longest operating hours. This natural evolution of long life lamps
being matched with fixtures with long operating hours is due in no small part to consumers
reducing the inconvenience and hassle of constantly replacing lamps.6 We refer to this as a
“convenience” phenomenon, but we also do not discount that consumers also implicitly, if not
explicitly select longer operating sockets for lower wattage, higher efficacy general service
lamps due to the energy savings potential and lower total owning costs. On the other hand, a
halogen incandescent lamp that is placed in a socket that is rarely used and operated can last
just as long (or longer) and have a lower total owning cost for the consumer than a more
efficacious lamp that has longer operating hours and is used more frequently.
5
For example, the report on Northeast Residential Lighting --- Hours of Use Study by NMR reached the following
conclusion: “HOU estimates for [CFL] bulbs are significantly higher compared to those for [incandescent] bulbs.
Estimates for [incandescent] and [CFL] bulbs across the five sets of estimates obtained from the hierarchical
model are all statistically similar, meaning that use of [incandescent] bulbs does not vary much across the areas,
and neither does use of [CFL] bulbs. While the difference in HOU between [CFL] and [incandescent] bulbs is
consistent and very clear across all regions and room types, the reason for this consistency is unclear. Three
competing theories could help explain the differences: differential socket selection, shifting usage, and increased
usage (snapback). However, this evaluation did not collect any data to support one theory over the others. The
authors of the Uniform Methods Protocol suggest that measuring snapback for residential lighting programs is not
typically possible as it requires both pre- and post-metering of energy efficient lighting. The Uniform Method
Protocols do not recommend adjusting for snapback effects in hours-of-use estimates. However, as differences in
usage are observable in the data collected for this evaluation, the Team suggests assuming that the behavior
posited by the three theories are equally responsible for the difference observed (i.e. each accounts for one-third
of the difference).”
6
DOE acknowledged this behavior in chapter 2 of the pTSD, at page 2-86.
19
An energy use characterization analysis that evaluated all technologies in general service lamp
sockets would recognize the dichotomy in hours of use between incandescent and CFL (and
presumably LED) that the studies cited by the DOE in section 2.9 of the pTSD confirm.
It is also important to make a separate point about pin base CFL. These lamps are generally
used in the commercial market with common applications being hospitality, office, retail, health
care, and education where the hours of operation will be longer: many of these commercial
applications have 12-16 hour on cycles. These lamps are not typically used in residential
applications and therefore cannot be compared with medium screw base lamps which tend to
be used most in residential applications. This is important because the operating hours in the
residential sector are much lower than in the commercial sector.
In summary, operating hours should vary somewhat with technology and most dimming circuits
should be assumed to operate halogen lamps.
ES.3.21 EISA 2007 Backstop Criteria
DOE requests any data suggesting that the EISA 2007 backstop criteria will not be met.
NEMA Comment: This is a very difficult question to respond to given the legislative and legal
posture this rulemaking finds itself in. It is not the rulemaking that Congress intended in EISA
2007, and we appreciate DOE’s explanation for this circumstance.
NEMA disagrees with the premise underlying the question and the assumption that permeates
many chapters of the pTSD: that the energy consumption of general service lamps in sockets
after January 1, 2020 will exceed the energy consumption of such lamps if every installed
socket had a general service lamp with an efficacy of 45 lumens per watt. NEMA’s present view
is that by the next decade, the installed mix of halogen incandescent lamps, compact
fluorescent lamps, and light emitting diode (LED) lamps in general service lamp sockets will
consume less energy than the energy consumed by every general service lamp socket
containing a lamp with an efficacy of 45 lumens per watt. In short, it is our expectation that the
so-called “backstop” will not be triggered, but that innovation, consumer choice and the market
will bring the energy consumption of a mix of lamps in the installed base of general service lamp
sockets to a point where the heavy hand of what might be an unpopular regulatory intervention
by the Secretary of Energy is unnecessary.
The industry’s current expectation is that continuing innovation will bring about further reduction
in wattage consumed by general service LED lamps (and corresponding increase in efficacy),
will reduce the cost and initial purchase price of those lamps to be extremely competitive with
compact fluorescent and halogen incandescent lamps, and that consumers --- both in the
residential and commercial sector --- will find these lamps highly suitable for many applications,
particularly where the hours of use are longer. Furthermore, the traditional incandescent lamp
that no longer meets the energy conservation standards established by EISA-2007 will be
nearly eliminated from general service lamp sockets. The confluence of these factors will result
in the installation of general service LEDs in sockets presently occupied by a significant number
of both incandescent and compact fluorescent lamps. This expected energy savings outcome
does not require that the socket penetration of general service LED lamps represent more than
half the installations or anywhere near that figure.
NEMA’s view is not isolated. We note the report published by the DOE in August 2014 titled
Energy Savings Forecast of Solid-State Lighting in General Illumination Applications. The
20
information presented in that report at pages 13-15 effectively confirms NEMA’s own
expectations just expressed.
Another DOE published report confirms NEMA lighting manufacturers’ actual experience:
market adoption of LED lighting is occurring far more rapidly than their experience with CFLs or
even they predicted just a few years ago:
In NEMA’s view, the analysis in the pTSD that assumes that the “backstop” will be triggered is
an unrealistic, if not artificial analysis of the general service lamp market both before and during
the analysis period. Since DOE apparently cannot legally analyze a market for a mix of general
service lamps that includes the halogen incandescent lamp, it becomes arbitrary and capricious
to assume that the “backstop” will be triggered.
ES.3.22 Fraction of Dimmable GSLs in the Residential Sector
For the residential sector, DOE estimated that at the compliance year five percent of CFL GSLs
will be dimmable based on manufacturer interviews, whereas no such limit was placed on LED
GSLs (though they may not be installed in fixtures that employ dimmers). DOE requests
comment on this approach.
NEMA Comment: We agree that dimmable lamps are a SMALL portion of the CFL market. A
higher percentage of LEDs are expected to be designed with dimming circuits, although it is
difficult to estimate the exact number as this market is still evolving.
ES.3.23 Energy Savings from Lighting Controls
For this preliminary analysis, DOE estimated 30 percent energy savings for any GSL operated
with lighting controls, including dimmers and controls integrated into smart LED lamps. DOE
requests data and information to help compare the energy use implications of using dimmers as
opposed to other lighting controls.
NEMA Comment: It is important to understand that the way control systems work with ballasted
lamps and luminaires (individual control) is not the way (phase cut) circuit control systems work
with non-ballasted lamps and luminaires (simultaneous control of groups of lamps).
Dimming integrated CFLs on phase cut dimmers does not save as much energy as dimming
incandescent or halogen.
NEMA is concerned that arguments claiming energy savings on very low wattage lamps are
suspect. With respect to LED lamps, there are little energy savings to be gained from dimming
these already low-power sources.
Savings from operation on residential dimmers will vary widely depending on room use. If used
for deep dimming such as for TV viewing savings can be significant at those times. Other times
dimming will be based on mood lighting. Dimming for dining can vary significantly depending on
the occupant. While individual dimming experiences will differ significantly, a 30% overall
energy reduction for lighting systems that are dimmed is a reasonable estimate.
21
There are fewer opportunities for pin-base CFLs to operate on control systems or dimmers;
there is no dimming in retail applications and dimming is limited in hospitality applications to
meeting and banquet rooms (not hallways or lobbies). We would estimate 5% overall energy
savings for pin-based systems used in commercial applications.
Additionally, control systems associated with smart LED lamps are used for architectural and
entertainment purposes, not energy savings. For residential users, it is all about the experience
and task tuning. Currently, smart LED lamps are more common in residential use than in
commercial use. It is our understanding that utilities are working on models to determine the
potential energy savings of controls for commercial LED users.
ES.3.24 Integrated Low Lumen GSL Market Distribution Estimates
DOE seeks comment on the market distribution estimates for the four lumen ranges analyzed as
part of the integrated low lumen product class.
NEMA Comment: The market distribution analysis further illustrates the problems with putting all
technologies together in the same product classes. CSL 1 is essentially all compact fluorescent
lamps; CSL 2 and CSL3 represent older LED technology that is still on the market because LED
product evolution is occurring so rapidly. CSL 4 and 5 represent differing types of LED
technology at levels that could never be met by CFL lamps. The very strange distribution
shown here is further evidence that these products should not be analyzed using this
classification method and why NEMA has proposed an alternative classification method.
ES.3.25 Consumer Purchases in Standards Case Analyses
In each of the 10,000 sampled purchases used to determine the average LCC savings, DOE
assumes that in the standards case consumers purchase lamps that are at least as efficient as the
ones they would purchase in the absence of standards. DOE seeks comment on this assumption.
NEMA comment: In the absence of standards, products may develop on other attributes such
as color temperature, color rendering (or whichever new metric is developed) or long life that
are more important to consumers but have lower efficiencies. These products are not
developed in the standards case. However, we recognize it is difficult to predict the
development of products not currently on the market and therefore this may be the only practical
assumption possible.
ES.3.26 Commercial Hours of Use Variability
DOE invites comments and data on its approach to account for variability in hours of use in the
commercial sector.
NEMA Comment: We believe that 10-12 hours is appropriate for non-integrated pin-base CFLs.
ES.3.27 GSL Service Life Scenarios
DOE is analyzing three GSL service life scenarios in its analyses. DOE invites comment on the
lifetime scenarios considered in the LCC, PBP, and subsequent analyses.
22
NEMA Comment: We agree that Scenario 17 is the most likely scenario and that the effects of
frequent starting on CFL life should be taken into account in residential applications. In
Scenario 2, again we agree that few lighting systems will last longer than 20 years and have a
high likelihood of being replaced after two decades. Scenario 3 contains an assumption that
LED lamps may last a median of 5 years, similar to consumer electronics. At this time, there is
very little evidence to either support or contradict this assumption.
ES.3.28 Lifetime Distribution Modeling
DOE invites comments and data on the assumptions and methodology used to calculate GSL
survival probabilities as a function of GSL age.
NEMA Comment: Non-integrated pin-base CFL life is dependent of number of starts per day. If
there is frequent switching then the life can be significantly reduced. Lamps are usually rated at
3 and 12 hour starts just like GSFL.
Weibull analysis, while mathematically correct, often does not reflect the real life results for
MBCFL well – due to application conditions and cycle time variations. We note that the DOE
based the Weibull analysis on a graph of fluorescent lamp mortality from the IES Handbook
(note “e” on page 8E-8). The mortality graph in the IES Handbook represents linear fluorescent
lamps. The Weibull shape factor will be different for integrated lamps and may affect the DOE’s
conclusions.
ES.3.29 Installation Costs
For this preliminary analysis, DOE assumed that the installation costs for GSLs are identical for
all CSLs and product classes in the residential sector as well as the commercial sector (though
they may differ by sector). Therefore, DOE did not include installation costs. DOE welcomes
comment on this approach.
NEMA Comment: Many consumers will require an electrician if the non-integrated pin-base
lamp ballast fails and they need to replace the ballast or the fixture.
ES.3.30 LCC and Consumer Impacts from Potential Standards
For a potential standard at each CSL, DOE presents the resulting average LCC savings and the
percent of consumers affected by the standard using the base-case and standards-case efficiency
distributions calculated in the shipments analysis. DOE seeks comment on this approach.
NEMA has no comment.
ES.3.31 GSL Disposal Costs
DOE requests comment and relevant data on the disposal cost assumptions used in its analyses.
NEMA Comment: The Universal Waste Rule designates the generator of the waste (e.g., user
of the lamp) as the responsible party for its disposal. In Maine and Vermont, Extended
Producer Responsibility (EPR) laws have been passed, and manufacturers operate and fund
recycling programs for residential lamps through NEMA. In Minnesota, some utilities add a
small charge to utility bills to fund recycling programs. Starting in January 2015, $0.25 per lamp
7
pTSD page 2-86
23
will be added to the purchase price of mercury containing lamps sold or sold into Washington.
Some retailers (Lowes, Home Depot, IKEA) as well as drug stores, hardware stores and grocery
stores, collect and pay for recycling lamps.
ES.3.32 LCC and PBP Methodologies
DOE requests comment on the overall methodology and results of the LCC and PBP analyses.
NEMA Comment: We suggest the DOE re-run their analyses once issues regarding price
methodology are resolved, per our response to item ES.3.19
ES.3.33 GSL Shipments Data
DOE requests any representative data on GSL shipments as they become available in order to
improve the accuracy of the shipments analysis.
NEMA Comment: we are still evaluating available shipment data for use by the DOE in this
analysis.
ES.3.34 Residential Integrated High Lumen GSLs
DOE requests comment on its assumption that approximately 3 percent of all residential-sector
GSLs with integrated ballasts or drivers are brighter than 2,000 lumens.
NEMA Comment: we agree that these products are approximately 3% or less.
ES.3.35 Integrated LED Fixture Penetration
DOE assumed that integrated LED fixtures will capture 0 percent, 15 percent, and 50 percent of
the fixture market by 2049 in the low-penetration, reference, and high-penetration scenarios,
respectively. DOE invites comment and data on these scenarios.
NEMA has no comment at this time.
ES.3.36 Non-Integrated CFL GSLs
DOE assumed that non-integrated CFL GSLs will remain a constant fraction of the installed GSL
stock in the commercial sector, after accounting for the incursion from integrated LED fixtures
into the commercial building stock. DOE seeks comment and data on this assumption.
NEMA Comment: We do not agree with the assumption that CFL pin in commercial will remain
constant. We anticipate a significant decline over the analysis period. The CFL pin recessed
cans have lower efficiencies relative to LED. The trend has already started to move to LED
retrofit kits (NOT non-integrated pin-base LED) in existing commercial applications and new
LED fixtures in new construction. We anticipate that this product area will be significantly
replaced by new LED fixtures over the next 30 years.
ES.3.37 Rare Earth Price Scenarios
DOE invites comment on the two rare earth materials price scenarios considered in its analyses.
24
NEMA Comment: A rare earth price spike hurts everyone not just industry but consumers as
well. We refer the DOE to our comments on the GSFL rulemaking8.
ES.3.38 Electricity Price Scenarios
DOE invites comment on the electricity price projection scenarios considered in its analyses.
NEMA has no comment at this time.
ES.3.39 LED Learning Rate Scenarios
In its reference scenario for this preliminary analysis, DOE assumed that the LED GSL learning
rate will slow in the near future to equal the historical learning rate for CFL GSLs. In an
alternative scenario, DOE assumed that the LED GSL learning rate will remain at the faster
value observed in recent years. DOE invites comment on these scenarios.
NEMA Comment: We again recommend the DOE use multiple product classes as suggested in
item ES.3.13 so as to separate the two technologies and allow different learning rates. This is
because we believe that high efficiency requirements from DOE and other entities such as the
California Energy Commission will cause prices to remain at current levels as manufacturers are
forced to pursue efficiency over other tradeoffs. Alternatively, lower CSLs will allow
manufacturers to continue to pursue cost-savings and result in lower prices and increased
adoption. We suggest the DOE explore both scenarios, and we believe that the lower CSLs
with lower cost are capable of achieving a higher national energy savings.
ES.3.40 Incremental Price of Brighter LED GSLs
DOE is assuming that both the price of LED GSLs and the incremental price of brighter LED
GSLs are falling. DOE requests comment and data on this assumption.
NEMA Comment: While both prices may be falling, a price differential between high and low
brightness LED products will still remain because more lumens come at a cost of more
materials; more LED dies or larger drivers, or both. We recommend the DOE investigate
material and other cost contributors to pricing in a family of products. As we recommended at
the DOE Public Meeting of January 20th, the DOE should avoid comparing separate generations
of lamp designs, which has contributed to the mistaken conclusion that higher lumen lamps are
cheaper or of equal price. The misunderstanding results from first generation LED lamps of low
lumen being the first to market at high prices. Innovation has allowed brighter, cheaper LED
lamps in relatively short time. These lamps are different generations and cannot be compared.
ES.3.41 Pre-Compliance Year Shift Away from Incandescent GSLs
DOE assumed in its shipments projections that some fraction of the market for GSILs shifts to
CFL or LED GSLs in each year prior to 2020, with the remainder shifting to CFL or LED GSLs
in 2020. DOE assumed that the remaining market for GSILs in the commercial sector is already
negligible, so this shift was assumed to occur entirely within the residential market. DOE
requests comment and data on this assumption.
8
See page 34:
http://www.regulations.gov/contentStreamer?objectId=0900006480f75c3e&disposition=attachment&contentTyp
e=pdf
25
NEMA Comment: We agree that there will be some shift from GSILs to CFL or LED GSLs as
well as some shift from CFL to LED each year up to 2020. We expect this shift to be significant,
and increasing over the time period. LED products purchased between now and 2020 will still
be expected to be installed in 2020. For the reasons explained in our response to Question
ES.3.21, NEMA does not expect the entire market or substantially the entire market to shift
suddenly to CFL and/or LED in 2020, and we submit this is an erroneous assumption.9 The
DOE cannot assume the shift in shipments as it has without consideration given to the
probability that the current enforcement prohibition may continue into 2020 and beyond.
Because the DOE lacks analysis on this issue, this is still an open question.
Table 9.5.3 of the pTSD shows decreasing sales of the combination of CFL sales plus LED
sales from 2015 to 2020. With projected declining LED lamp prices, industry believes that the
number of LED sales will significantly increase, more than offsetting the reduction in CFL sales
such that the combined total of both technologies will continue to increase, not decrease, from
2015 to 2020.
Table 9.5.3 also shows a sales spike that is both unrealistic and impossible to achieve.
Production capability is scaled to market demand. Manufacturers, individually and collectively,
could not economically justify an enormous increase in production capability for one year,
especially if it was known, as represented in the Table, that the entire market would return to
“normal” the following year. If this were to occur, there would be severe product shortages and
disruption in the market. This is illustrative of the artificiality of the analysis that we mentioned
in our response to ES.3.21.
ES.3.42 GSL Market Data
DOE requests comment and data on current market shares and market trends for GSLs in the
commercial sector.
NEMA Comment: Most of the products covered under this rulemaking are used in the residential
sector. The exception is pin-based lamps which are used almost entirely in the commercial
sector. However, pin-based CFL lamps represent a very small percentage of the commercial
market. Their use has been flat to declining over the past 5 years and a continued decline in
their use is expected. As this is a declining market area with very little potential for energy
savings, NEMA believes these products should be removed from this rulemaking. (See our
chart in item ES.3.7)
ES.3.43 GSL Rebound Effect Scenarios
DOE analyzed three rebound effect scenarios in the NIA: 1) 0 percent rebound for both the
residential and commercial sectors (the reference scenario), 2) 8.5 percent rebound and 1 percent
rebound for the residential and commercial sectors, respectively, and 3) 15 percent rebound for
both the residential and commercial sectors. DOE requests data that can be used to further refine
the rebound effect assumptions used in the NIA.
9
It is anybody’s guess, but the statutory basis for the DOE’s inability to conduct a full analysis of the general service
lamp market brought about by the Consolidated Appropriations Act of 2014 can equally be assumed to remain in
place in 2020 and beyond and that fact alone would render the DOE’s premise and assumptions unrealistic.
26
NEMA Comment: While we believe there will be little to no rebound effect in the commercial
sector, we do not rule out some rebound effect with the growing presence of LED products in
the residential sector as their extremely long life and low energy use could lead some
consumers to operate their lamps for longer periods of time without producing nuisance
replacements or high energy bills. An 8.5% to 15% rebound effect for LED lamps used in the
residential sector is foreseeable.
ES.3.44 Penetration of LED GSLs with Standby Functionality
DOE assumed that residential LED GSLs with standby functionality will represent 0 percent, 50
percent, and 100 percent of residential LED GSLs in the market by 2049 in the low-penetration,
reference, and high-penetration scenarios, respectively. DOE invites comment and data on these
assumptions.
NEMA Comment: While use of standby functionality will increase, it is very unlikely that it will
ever reach 100% because adding this functionality will add cost, and there will always be a
market for the lowest cost, no-features product.
ES.3.45 Penetration of Commercial GSLs with Controls
DOE analyzed two scenarios to account for the fraction of GSL shipments with controls in the
commercial sector: 1) The current fraction of GSLs with controls remains constant over the
analysis period, and 2) The fraction of commercial floor space utilizing various types of controls
grows from 30 percent today to a projected value of 80 percent by the end of the analysis period
(the reference scenario). DOE invites comment and data on these scenarios.
NEMA Comment: Assuming that ASHRAE 90.1 continues to be the national energy code
throughout the analysis period (or IECC equivalent), it would be reasonable to assume that
most commercial floor space as well as other qualifying spaces will have controls. Almost any
renovation will necessitate the use of a control system and these controls would include manual
on or partial automatic on, bi-level dimming, automatic off or scheduled shutoff, and automatic
daylight responsive controls where appropriate.
ES.3.46 Shipments Analysis and NIA Scenarios
DOE is considering a number of scenarios in its shipments and NIA analyses. DOE asks for
comment on whether there are other scenarios which should be considered.
NEMA Comment: DOE should consider a parallel scenario where halogen lamps remain on the
market.
ES.3.47 Consumer Subgroup Analysis
DOE welcomes input regarding which, if any, consumer subgroups should be considered when
developing potential energy conservation standards for GSLs.
NEMA Comment: Low income consumer groups will be most affected if low cost halogen or low
cost CFL lamps are no longer available in 2020. We refer to our comments in item ES.3.40
above about the tradeoff of efficiency versus cost and adoption rates.
ES.3.48 Emissions Analysis
27
DOE requests comment on its approach to conducting the emissions analysis for GSLs.
NEMA has no comment at this time.
ES.3.49 Monetization of Emissions Reductions Benefits
DOE invites input on the proposed approach for estimating monetary benefits associated with
emissions reductions.
NEMA Comment: As we have previously noted in appliance efficiency proceedings under the
Energy Policy and Conservation Act:
Given the enormous uncertainty in the IAMs models, these models --- even
“averaged” as the Interagency Working Group has done --- are poor tools for
agency decision-making, particularly with respect to products regulated by EPCA
that are not themselves a source of emissions. Reliance on the SCC to justify a
standard could be socially counterproductive: An agency could very well end up
justifying the imposition of enormous costs upon a non-polluting, energy-saving
product that it wants to see penetrate the market in greater numbers that could not
otherwise be justified without the uncertain benefits attributed to the SCC. NEMA
believes that DOE should base its net benefit determination for justifying a particular
energy conservation on the traditional criteria relied upon by DOE --- impacts on
manufacturers, consumers, employment, energy savings, and competition. If there
are estimated benefits from reduced carbon emissions, they should be noted --subject to the inherent uncertainty and difficulty in monetizing those benefits --- as
benefits over and above the net benefits from DOE’s traditional analysis under
EPCA.
We incorporate by reference our entire comment on this subject in the recently completed
incandescent reflector lamp and general service fluorescent lamp rulemaking,10 which the DOE
acknowledged in the Final Rule published in that rulemaking. 80 Fed.Reg. 4042, 4099 (January
26, 2015).
ES.3.50 Utility Impact Analysis
DOE seeks comment on the planned approach to conduct the utility impact analysis.
NEMA has no comment at this time.
ES.3.51 Employment Impact Analysis
DOE welcomes input on its proposed approach for assessing national employment impacts.
NEMA has no comment at this time.
ES.3.52 Regulatory Impact Analysis
10
Energy Conservation Program: Energy Conservation Standards for General Service Fluorescent
Lamps and Incandescent Reflector Lamps, Docket No. EERE-2011-BT-STD-0006. NEMA Comments dated June 30,
2014, pages 38-44.
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DOE requests any available data or reports that would contribute to the analysis of alternatives to
standards for GSLs. In particular, DOE seeks information on the effectiveness of existing or past
efficiency improvement programs for these products.
NEMA Comment: Millions of dollars have been spent by Utilities through their rebate programs
to reduce the price of energy efficient products within this product scope. Depending on the
standard level selected the Utilities may, or may not, continue these programs to reduce product
price, thus adoption could actually slow under a given pricing scenario. We again refer to our
comments about efficiency, price and adoption in item ES.3.40.
Manufacturer Impact Analysis
NEMA Comment: The DOE should appraise the fact that the lighting manufacturing industry
has been and is undertaking a significant amount of investment that is integral to a market
transformation, developing a wide-range of new and innovative solid-state lighting products.
This innovation and investment is expected to continue for several years to come. Innovation
has been and continues to occur rapidly, making products previously introduced to the market
quickly obsolete. Investment will continue to be directed in the future at making these products
even more affordable to consumers and possibly delivering energy savings beyond what energy
conservation standards under consideration will deliver. The amount of this investment directed
at one segment of general service lamps, LEDs, makes it very difficult to justify any significant
new investment in other segments of the general service lamp definition that represent the more
mature product lines. Stated another way, regulatory action that forces manufacturers to make
incremental investments in mature products that generate only modest benefits can make it
more difficult to invest in the future. Given the intense competition that is occurring in
developing new and better solid-state lighting products, it is unlikely that manufacturers will
invest in old technology at this point of the transformation. Therefore DOE should only be
evaluating the efficiencies of the products that are on the market today and not assume
manufacturers will invest to make these even incrementally more efficient. Mandatory
investment in the mature energy-efficient products can hinder competition and American
competitiveness. DOE should not lose sight of the market transformation and trend that has
already occurred and will continue to occur and avoid unintended consequences that could
impact competitiveness, American workers and consumers in this time of change.
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