24068 Federal Register / Vol. 79, No. 82 / Tuesday, April 29, 2014 / Proposed Rules

DEPARTMENT OF ENERGY into the Forrestal Building will be A link to the docket Web page can be required to obtain a property pass. found at: www1.eere.energy.gov/ 10 CFR Part 430 Visitors should avoid bringing laptops, buildings/appliance_standards/ [Docket Number EERE–2011–BT–STD– or allow an extra 45 minutes. Persons rulemaking.aspx/ruleid/24. This Web 0006] can attend the public meeting via page contains a link to the docket for webinar. For more information, refer to this notice on the regulations.gov site. RIN 1904–AC43 the Public Participation section near the The regulations.gov Web page contains end of this notice. instructions on how to access all Energy Conservation Program: Energy Any comments submitted must Conservation Standards for General documents, including public comments, identify the NOPR for Energy in the docket. See section IX for further Service Fluorescent Lamps and Conservation Standards for general Incandescent Reflector Lamps information on how to submit service fluorescent lamps and comments through AGENCY: Office of Energy Efficiency and incandescent reflector lamps and www.regulations.gov. Renewable Energy, Department of provide docket number EE–2011–BT– For further information on how to Energy. STD–0006 and/or regulatory submit a comment, review other public information number (RIN) number ACTION: Notice of proposed rulemaking comments and the docket, or participate (NOPR) and public meeting. 1904–AC43. Comments may be in the public meeting, contact Ms. submitted using any of the following Brenda Edwards at (202) 586–2945 or by SUMMARY: The Energy Policy and methods: email: [email protected]. Conservation Act of 1975 (EPCA), as 1. Federal eRulemaking Portal: FOR FURTHER INFORMATION CONTACT: amended, prescribes energy www.regulations.gov. Follow the Ms. Lucy deButts, U.S. Department of conservation standards for various instructions for submitting comments. _ Energy, Office of Energy Efficiency commercial and industrial equipment 2. Email:GSFL-IRL 2011-STD- and Renewable Energy, Building and certain consumer products, [email protected]. Include the docket Technologies Program, EE–2J, 1000 including general service fluorescent number and/or RIN in the subject line Independence Avenue SW., lamps (GSFLs) and incandescent of the message. Washington, DC 20585–0121. reflector lamps (IRLs). EPCA also 3. Mail: Ms. Brenda Edwards, U.S. Telephone: (202) 287–1604. Email: requires the U.S. Department of Energy Department of Energy, Building General_Service_Fluorescent_Lamps@ (DOE) to determine whether more- Technologies Program, Mailstop EE–2J, ee.doe.gov. stringent, amended standards would be 1000 Independence Avenue SW., Ms. Elizabeth Kohl, U.S. Department of technologically feasible and Washington, DC 20585–0121. If Energy, Office of the General Counsel, economically justified, and would save possible, please submit all items on a GC–71, 1000 Independence Avenue a significant amount of energy. In this CD. It is not necessary to include SW., Washington, DC 20585–0121. notice, DOE proposes amended energy printed copies. Telephone: (202) 586–7796. Email: 4. Hand Delivery/Courier: Ms. Brenda conservation standards for GSFLs and [email protected]. Edwards, U.S. Department of Energy, IRLs. The notice also announces a SUPPLEMENTARY INFORMATION: Building Technologies Program, 950 public meeting to receive comment on L’Enfant Plaza SW., Suite 600, these proposed standards and associated Table of Contents Washington, DC 20024. Telephone: analyses and results. I. Summary of the Proposed Rule (202) 586–2945. If possible, please A. Benefits and Costs to Consumers DATES: DOE will hold a public meeting submit all items on a CD, in which case on Thursday, May 1, 2014, from 9 a.m. B. Impact on Manufacturers it is not necessary to include printed C. National Benefits to 4 p.m., in Washington, DC. The copies. II. Introduction meeting will also be broadcast as a Written comments regarding the A. Authority webinar. See section IX Public burden-hour estimates or other aspects B. Background Participation for webinar registration of the collection-of-information 1. Current Standards information, participant instructions, requirements contained in this proposed 2. Corrections to Codified Standards and information about the capabilities 3. History of Standards Rulemaking for rule may be submitted to Office of General Service Fluorescent Lamps and available to webinar participants. Energy Efficiency and Renewable DOE will accept comments, data, and Incandescent Reflector Lamps Energy through the methods listed 4. Test Procedure Standby and Off Mode information regarding this NOPR before above and by email to Chad_S_ Energy Consumption and after the public meeting, but no [email protected]. III. General Discussion later than June 30, 2014. See section IX For detailed instructions on A. Product Classes and Scope of Coverage Public Participation for details. submitting comments and additional B. Technological Feasibility ADDRESSES: The public meeting will be information on the rulemaking process, 1. General held at the U.S. Department of Energy, see section IX of this document (Public 2. Maximum Technologically Feasible Levels Forrestal Building, Room 8E–089, 1000 Participation). C. Energy Savings Independence Avenue SW., Docket: The docket, which includes 1. Determination of Savings Washington, DC 20585. To attend, Federal Register notices, public meeting 2. Significance of Savings please notify Ms. Brenda Edwards at attendee lists and transcripts, D. Economic Justification (202) 586–2945. Please note that foreign comments, and other supporting 1. Specific Criteria nationals visiting DOE Headquarters are documents/materials, is available for a. Economic Impact on Manufacturers and subject to advance security screening review at regulations.gov. All Consumers procedures. Any foreign national documents in the docket are listed in b. Savings in Operating Costs Compared to wishing to participate in the meeting the regulations.gov index. However, Increase in Price c. Energy Savings should advise DOE as soon as possible some documents listed in the index, d. Lessening of Utility or Performance of by contacting Ms. Edwards to initiate such as those containing information Products the necessary procedures. Please also that is exempt from public disclosure, e. Impact of Any Lessening of Competition note that those wishing to bring laptops may not be publicly available. f. Need for National Energy Conservation

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g. Other Factors 9. Lamp Purchase Events e. Indirect Impacts on Employment 2. Rebuttable Presumption 10. Product Lifetime 4. Impact on Utility or Performance IV. Issues Affecting Rulemaking Schedule a. Lamp Lifetime 5. Impact of Any Lessening of Competition V. Issues Affecting Scope b. Ballast Lifetime 6. Need of the Nation To Conserve Energy A. Clarifications of General Service 11. Discount Rates 7. Summary of National Economic Impacts Fluorescent Lamp Definition 12. Analysis Period 8. Other Factors B. General Service Fluorescent Lamp 13. Compliance Date of Standards C. Proposed Standards Scope of Coverage 14. General Service Fluorescent Lamp Life- 1. Benefits and Burdens of Trial Standard 1. Additional General Service Fluorescent Cycle Cost Results in the Preliminary Levels Considered for General Service Lamp Types Analysis Fluorescent Lamps 2. Additional General Service Fluorescent 15. Incandescent Reflector Lamp Life-Cycle 2. Summary of Benefits and Costs Lamp Wattages Cost Results in the Preliminary Analysis (Annualized) of the Proposed Standards C. Incandescent Reflector Lamp Scope of H. Consumer Subgroup Analysis for General Service Fluorescent Lamps Coverage I. Shipments Analysis 3. Benefits and Burdens of Trial Standard 1. Incandescent Reflector Lamp Types J. National Impact Analysis–National Levels Considered for Incandescent 2. Incandescent Reflector Lamp Wattages Energy Savings and Net Present Value Reflector Lamps D. Summary of Scope of Coverage Analysis 4. Summary of Benefits and Costs VI. Methodology and Discussion 1. National Energy Savings (Annualized) of the Proposed Standards A. Market and Technology Assessment 2. Net Present Value of Consumer Benefit for Incandescent Reflector Lamps 1. General Service Fluorescent Lamp a. Total Annual Installed Cost VIII. Procedural Issues and Regulatory Technology Options b. Total Annual Operating Cost Savings Review 2. Incandescent Reflector Lamp K. Manufacturer Impact Analysis A. Review Under Executive Orders 12866 Technology Options 1. Overview and 13563 B. Screening Analysis 2. GRIM Analysis and Key Inputs B. Review Under the Regulatory Flexibility 1. General Service Fluorescent Lamp a. Capital and Product Conversion Costs Act Design Options b. Manufacturer Production Costs 1. Description and Estimated Number of 2. Incandescent Reflector Lamp Design c. Shipment Scenarios Small Entities Regulated Options d. Markup Scenarios a. Methodology for Estimating the Number C. Product Classes 3. Discussion of Comments of Small Entities 1. General Service Fluorescent Lamp a. Potential Shift to Other Lighting b. Manufacturer Participation Product Classes Technologies c. General Service Fluorescent Lamp and 2. Incandescent Reflector Lamp Product b. Cumulative Regulatory Burden Incandescent Reflector Lamp Industry Classes c. Potential Decrease in Competition Structures and Nature of Competition D. Engineering Analysis 4. Manufacturer Interviews d. Comparison Between Large and Small 1. General Approach a. Rare Earth Oxides in General Service Entities 2. General Service Fluorescent Lamp Fluorescent Lamps 2. Description and Estimate of Compliance Engineering b. Unknown Impacts of the 2009 Lamps Requirements a. Data Approach Rule 3. Duplication, Overlap, and Conflict With b. Representative Product Classes c. Technology Shift Other Rules and Regulations c. Baseline Lamps d. Impact on Residential Sector 4. Significant Alternatives to the Proposed d. More Efficacious Substitutes L. Emissions Analysis Rule e. General Service Fluorescent Lamp M. Monetizing Carbon Dioxide and Other 5. Significant Issues Raised by Public Systems Emissions Impacts Comments f. Maximum Technologically Feasible 1. Social Cost of Carbon C. Review Under the Paperwork Reduction g. Efficacy Levels a. Monetizing Carbon Dioxide Emissions Act h. Scaling to Other Product Classes b. Social Cost of Carbon Values Used in D. Review Under the National i. Rare Earth Phosphors Past Regulatory Analyses Environmental Policy Act of 1969 3. Incandescent Reflector Lamp c. Current Approach and Key Assumptions E. Review Under Executive Order 13132 Engineering 2. Valuation of Other Emissions F. Review Under Executive Order 12988 a. Metric Reductions G. Review Under the Unfunded Mandates b. Representative Product Classes N. Utility Impact Analysis Reform Act of 1995 c. Baseline Lamps O. Employment Impact Analysis H. Review Under the Treasury and General d. More Efficacious Substitutes P. Other Comments Government Appropriations Act, 1999 e. Maximum Technologically Feasible VII. Analytical Results I. Review Under Executive Order 12630 f. Efficacy Levels A. Trial Standard Levels J. Review Under the Treasury and General g. Scaling to Other Product Classes B. Economic Justification and Energy Government Appropriations Act, 2001 h. Xenon Savings K. Review Under Executive Order 13211 L. Review Under the Information Quality i. Proposed Standard 1. Economic Impacts on Individual Bulletin for Peer Review E. Product Pricing Determination Consumers IX. Public Participation F. Energy Use a. Life-Cycle Cost and Period A. Attendance at the Public Meeting 1. Operating Hours b. Consumer Subgroup Analysis B. Procedure for Submitting Prepared 2. Lighting Controls c. Rebuttable Presumption Payback General Statements for Distribution a. General Service Fluorescent Lamp 2. Economic Impacts on Manufacturers C. Conduct of the Public Meeting Lighting Controls a. Industry Cash-Flow Analysis Results D. Submission of Comments b. Incandescent Reflector Lamp Lighting b. Impacts on Employment E. Issues on Which DOE Seeks Comment Controls c. Impacts on Manufacturing Capacity X. Approval of the Office of the Secretary G. Life-Cycle Cost Analysis and Payback d. Impacts on Sub-Groups of Period Analysis Manufacturers I. Summary of the Proposed Rule 1. Consumer Product Price e. Cumulative Regulatory Burden 1 2. Sales Tax 3. Shipments Analysis and National Impact Title III, Part B of the Energy Policy 3. Installation Cost Analysis and Conservation Act of 1975 (EPCA or 4. Annual Energy Use a. Significance of Energy Savings the Act), Public Law 94–163 (42 U.S.C. 5. Product Energy Consumption Rate b. Net Present Value of Consumer Costs 6291–6309, as codified), established the 6. Electricity Prices and Benefits 7. Electricity Price Projections c. Impact of Product Class Switching 1 For editorial reasons, upon codification in the 8. Replacement and Disposal Costs d. Alternative Scenario Analyses U.S. Code, Part B was redesignated Part A.

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Energy Conservation Program for I.2. These proposed standards, if of the funds made available by the Act Consumer Products Other Than adopted, would apply to all products may be used to implement or enforce Automobiles. Pursuant to EPCA, any listed in Table I.1 and manufactured in, standards for BPAR incandescent new or amended energy conservation or imported into, the United States on reflector lamps, BR incandescent standard that DOE prescribes for certain or after the date three years after the reflector lamps, and ER incandescent products, such as GSFLs and IRLs, must publication of the final rule for this reflector lamps. The majority of IRLs in be designed to achieve the maximum rulemaking. this rulemaking are PAR IRLs and improvement in energy efficiency that is With the exception of certain IRLs, therefore do not fall into category of technologically feasible and these proposed standards, if adopted, lamps prohibited by section 322. The economically justified. (42 U.S.C. would apply to all products listed in small number of lamps that are BPAR, 6295(o)(2)(A)). Furthermore, the new or Table I.2 and manufactured in, or ER, and BR IRLs are not included in this amended standard must result in a imported into, the United States on or rulemaking pursuant to section 322. significant conservation of energy. (42 after the date three years after the DOE had initiated a separate rulemaking U.S.C. 6295(o)(3)(B)). In accordance publication of the final rule for this for lamps rated 50 watts or less that are with these and other statutory rulemaking. The Consolidated ER30, BR30, BR40, or ER40; lamps rated provisions discussed in this notice, DOE Appropriations Act, 2014 (Public Law 65 watts that are BR30, BR40, or ER40 proposes amended energy conservation 113–76, Jan. 17, 2014), in relevant part, lamps; and R20 IRLs rated 45 watts or standards for GSFLs and IRLs. The restricts the use of appropriated funds less, but has suspended activity on this proposed standards, which are the in connection with several aspects of rulemaking as a result of section 322 of minimum lumen output per watt of a DOE’s incandescent lamps program. Public Law 113–76. (See section II.B.3 lamp, are shown in Table I.1 and Table Specifically, section 322 states that none for further details.)

TABLE I.1—PROPOSED ENERGY CONSERVATION STANDARDS FOR GENERAL SERVICE FLUORESCENT LAMPS

Percent Correlated increase over Lamp type color Proposed level current temperature lm/W standards or baseline

4-Foot Medium Bipin ...... ≤4,500 K 92.4 3.8 >4,500 K 90.6 3.0 2-Foot U-Shaped ...... ≤4,500 K 86.9 3.5 >4,500 K 84.3 4.1 8-Foot Slimline ...... ≤4,500 K 99.0 2.1 >4,500 K 94.1 1.2 8-Foot Recessed Double Contact High Output ...... ≤4,500 K 97.6 6.1 >4,500 K 95.6 8.6 4-Foot Miniature Bipin Standard Output ...... ≤4,500 K 97.1 12.9 >4,500 K 91.3 12.7 4-Foot Miniature Bipin High Output ...... ≤4,500 K 82.7 8.8 >4,500 K 78.6 9.2

TABLE I.2—PROPOSED ENERGY CONSERVATION STANDARDS FOR INCANDESCENT REFLECTOR LAMPS

Percentage increase over Diameter Voltage Proposed current Lamp type inches V level * standards or lm/W baseline %

Standard Spectrum 40 W—205 W ...... >2.5 ≥125 7.1P0.27 4.4 <125 6.2P0.27 5.1 ≤2.5 ≥125 6.0P0.27 5.3 <125 5.2P0.27 4.0 Modified Spectrum 40 W—205 W ...... >2.5 ≥125 6.0P0.27 3.4 <125 5.2P0.27 4.0 ≤2.5 ≥125 5.1P0.27 4.1 <125 4.4P0.27 4.8 * P = lamp rated wattage. Note 1: BPAR, ER, and BR IRLs and R20 IRLs rated 45 watts or less are not subject to the proposed standards for IRLs.

A. Benefits and Costs to Consumers I.3 presents DOE’s evaluation of the double contact high output (HO) economic impacts of the proposed product class. Table I.4 presents DOE’s DOE calculates a range of life-cycle standards on consumers of GSFLs, as evaluation of economic impacts of the cost (LCC) savings and mean payback measured by the weighted average LCC proposed standards on consumers of period (PBP) results for various savings and the weighted average mean IRLs, as measured by the weighted purchasing events and sectors. These PBP. The weighted average LCC savings average LCC and mean PBP. The results are presented in section VII.B.1 are positive for all product classes with weighted average LCC savings are and chapter 8 of the NOPR TSD. Table the exception of the 8-foot recessed positive for all product classes.

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TABLE I.3—IMPACTS OF PROPOSED STANDARDS ON CONSUMERS OF GENERAL SERVICE FLUORESCENT LAMPS

Weighted Weighted average mean Product class average LCC payback savings period * 2012$ years

4-foot medium bipin ≤4,500 K ...... 3.14 3.6 4-foot T5 miniature bipin standard output ≤4,500 K ...... 2.76 4.3 4-foot T5 miniature bipin high output ≤4,500 K ...... 2.28 3.0 8-foot single pin slimline ≤4,500 K ...... 2.08 4.5 8-foot recessed double contact HO ≤4,500 K ...... ¥16.76 NER * Does not include weighting for ‘‘NER’’ Scenarios. ‘‘NER’’ indicates standard levels that do not reduce operating costs, which prevents the consumer from recovering the increased purchase cost.

TABLE I.4—IMPACTS OF PROPOSED STANDARDS ON CONSUMERS OF INCANDESCENT REFLECTOR LAMPS

Weighted Weighted average mean Product class average LCC payback savings period 2012$ years

Standard spectrum, >2.5 inches, <125 V ...... 2.95 5.4

B. Impact on Manufacturers save a significant amount of energy. The (SO2), 210 thousand tons of nitrogen The industry net present value (INPV) lifetime savings for GSFLs purchased in oxides (NOX), 2.8 thousand tons of is the sum of the discounted cash flows the 30-year period that begins in the nitrous oxide (N2O), and 0.32 tons of to the industry from the base year year of compliance with amended mercury (Hg). The energy savings would standards (2017–2046) amount to 3.5 result in cumulative emission through the end of the analysis period quads. reductions of 98 Mt of CO through (2013 to 2046). Using a real discount 2 DOE’s analyses indicate that the 2030. rate of 9.2 percent, DOE estimates that proposed standards for IRLs would save The proposed standards for IRL the INPV for manufacturers of GSFLs is a significant amount of energy. The would also have significant $1,542.5 million in 2012$. Under the lifetime savings for IRLs purchased in environmental benefits. The energy proposed standards, DOE expects that the 30-year period that begins in the savings would result in cumulative manufacturers may lose up to 2.6 year of compliance with amended emission reductions of 0.70 Mt of CO2, percent of their INPV, which is standards (2017–2046) amount to 0.013 2.7 thousand tons of methane, 0.69 approximately $39.9 million in 2012$. quads. thousand tons of SO2, 0.79 thousand Additionally, based on DOE’s The cumulative net present value tons of NOX, 0.01 thousand tons of N2O, interviews with the manufacturers of (NPV) of total consumer costs and and 0.001 tons of Hg. The energy GSFLs, DOE does not expect any plant savings of the proposed standards for savings would result in cumulative closings or significant loss of GSFLs ranges from $3.1 billion (at a 7- emission reductions of 1 Mt of CO2 employment based on the energy percent discount rate) to $8.1 billion (at through 2030. conservation standards proposed for a 3-percent discount rate). This NPV The value of the CO2 reductions for GSFLs. expresses the estimated total value of the proposed standards for GSFLs is For IRLs, DOE estimates that the INPV future operating-cost savings minus the calculated using a range of values per for manufacturers of IRLs is $176.0 estimated increased product costs for metric ton of CO2 (otherwise known as million in 2012$ using a real discount products purchased in 2017–2046. the Social Cost of Carbon, or SCC) rate of 9.2 percent. Under the proposed The NPV of total consumer costs and developed by an interagency process. standards, DOE expects that savings of the proposed standards for The derivation of the SCC values is manufacturers may lose up to 29.5 IRLs ranges from $0.18 billion (at a 7- discussed in section VI.M. Using percent of their INPV, which is percent discount rate) to $0.28 billion discount rates appropriate for each set approximately $51.8 million in 2012$. (at a 3-percent discount rate). This NPV of SCC values, DOE estimates the Additionally, manufacturers of IRLs expresses the estimated total value of present monetary value of the CO2 stated in interviews with DOE that there future operating-cost savings minus the emissions reduction is between $1.3 is the potential for IRL manufacturers to estimated increased product costs for billion and $17 billion. DOE also close existing U.S. manufacturing plants products purchased in 2017–2046. estimates the present monetary value of or for a potential loss of domestic IRL In addition, the proposed standards the NOX emissions reduction, is $200 manufacturing employment based on for GSFLs would have significant million at a 7-percent discount rate and the energy conservation standards environmental benefits. The energy $340 million at a 3-percent discount proposed for IRLs. savings would result in cumulative rate.4 C. National Benefits 2 emission reductions of 170 million The value of the CO2 reductions for metric tons (Mt) 3 of carbon dioxide the proposed standards of IRL is DOE’s analyses indicate that the (CO2), 730 thousand tons of methane, calculated using the same SCC values proposed standards for GSFLs would 250 thousand tons of sulfur dioxide and discount rates used for GSFLs. DOE

2 All monetary values in this section are 3 A metric ton is equivalent to 1.1 short tons. 4 DOE is currently investigating monetary expressed in 2012$ and are discounted to 2013. Results for NOX and Hg are presented in short tons. valuation of avoided Hg and SO2 emissions.

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estimates the present monetary value of value of the NOX emissions reduction, Table I.5 and Table I.6 summarize the the CO2 emissions reduction is between is $1.1 million at a 7-percent discount national economic costs and benefits $0.0062 billion and $0.076 billion. DOE rate and $1.6 million at a 3-percent expected to result from the proposed also estimates the present monetary discount rate.4 standards for GSFLs and IRLs.

TABLE I.5—SUMMARY OF NATIONAL ECONOMIC BENEFITS AND COSTS OF PROPOSED ENERGY CONSERVATION STANDARDS FOR GENERAL SERVICE FLUORESCENT LAMPS *

Present value Discount rate Category Billion 2012$ (percent)

Benefits

Operating Cost Savings ...... 12 7 22 3 CO2 Reduction Monetized Value ($11.8/t case) ** ...... 1.3 5 CO2 Reduction Monetized Value ($39.7/t case) ** ...... 5.6 3 CO2 Reduction Monetized Value ($61.2/t case) ** ...... 8.9 2.5 CO2 Reduction Monetized Value ($117/t case) ** ...... 17 3 NOX Reduction Monetized Value (at $2,639/ton) ** ...... 0.2 7 0.3 3 Total Benefits † ...... 18 7 28 3

Costs

Incremental Installed Costs ...... 8.8 7 13 3

Total Net Benefits

Including Emissions Reduction Monetized Value † ...... 9.0 7 14 3 * This table presents the costs and benefits associated with GSFL shipped in 2017–2046. These results include benefits to consumers which accrue after 2046 from the products purchased in 2017–2046. The results account for the incremental variable and fixed costs incurred by manu- facturers due to the standard, some of which may be incurred in preparation for the rule. ** The CO2 values represent global monetized values of the SCC, in 2012$, in 2015 under several scenarios of the updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 3%, and 2.5% discount rates, respectively. The fourth case rep- resents the 95th percentile of the SCC distribution calculated using a 3% discount rate. The SCC time series used by DOE incorporate an esca- lation factor. The value for NOX is the average of the low and high values used in DOE’s analysis. † Total Benefits for both the 3% and 7% cases are derived using the series corresponding to average SCC with 3-percent discount rate.

TABLE I.6—SUMMARY OF NATIONAL ECONOMIC BENEFITS AND COSTS OF PROPOSED ENERGY CONSERVATION STANDARDS FOR INCANDESCENT REFLECTOR LAMPS

Present value Discount rate Category Billion 2012$ (Percent)

Benefits

Operating Cost Savings ...... 0.07 7 0.11 3 CO2 Reduction Monetized Value ($11.8/t case) ** ...... 0.006 5 CO2 Reduction Monetized Value ($39.7/t case) ** ...... 0.03 3 CO2 Reduction Monetized Value ($61.2/t case) ** ...... 0.04 2.5 CO2 Reduction Monetized Value $117/t case) * ...... 0.08 3 NOX Reduction Monetized Value (at $2,639/ton) ** ...... 0.001 7 0.002 3 Total Benefits† ...... 0.10 7 0.13 3

Costs

Incremental Installed Costs‡ ...... ¥0.11 7 ¥0.17 3

Total Net Benefits

Including Emissions Reduction Monetized Value† ...... 0.20 7 0.31 3 * This table presents the costs and benefits associated with IRLs shipped in 2017–2046. These results include benefits to consumers which ac- crue after 2046 from the products purchased in 2017–2046. The results account for the incremental variable and fixed costs incurred by manu- facturers due to the standard, some of which may be incurred in preparation for the rule.

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** The CO2 values represent global monetized values of the SCC, in 2012$, in 2015 under several scenarios of the updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 3%, and 2.5% discount rates, respectively. The fourth case rep- resents the 95th percentile of the SCC distribution calculated using a 3% discount rate. The SCC time series used by DOE incorporate an esca- lation factor. The value for NOX is the average of the low and high values used in DOE’s analysis. † Total Benefits for both the 3% and 7% cases are derived using the series corresponding to average SCC with 3-percent discount rate. ‡ This reduction in product costs occurs because the more efficacious products have substantially longer lifetimes than the products that would be eliminated by the proposed standard.

The benefits and costs of today’s climate-related impacts resulting from Estimates of annualized benefits and proposed standards, for products sold in the emission of one ton of CO2 in each costs of the proposed standards for IRLs 2017–2046, can also be expressed in year. These impacts continue well are shown in Table I.8. The results terms of annualized values. The beyond 2100. under the primary estimate are as annualized monetary values are the sum Estimates of annualized benefits and follows. Using a 7-percent discount rate costs of the proposed standards for of (1) the annualized national economic for benefits and costs other than CO2 value of the benefits from consumer GSFLs are shown in Table I.7. The reduction, for which DOE used a 3- operation of products that meet the results under the primary estimate are percent discount rate along with the as follows. Using a 7-percent discount proposed standards (consisting average SCC series that uses a 3-percent primarily of operating cost savings from rate for benefits and costs other than discount rate, the annualized cost of using less energy, minus increases in CO2 reduction, for which DOE used a 3- today’s proposed standards is negative product purchase and installation costs, percent discount rate along with the average SCC series that uses a 3-percent $10.4 million per year in reduced which is another way of representing 6 consumer NPV), and (2) the annualized discount rate, the cost of the standards product costs, and the annualized monetary value of the benefits of proposed in today’s rule is $873 million benefits are $7.2 million per year in reduced product operating costs, $1.4 emission reductions, including CO2 per year in increased product costs; emission reductions.5 while the estimated benefits are $1,180 million per year in CO2 reductions, and Although combining the values of million per year in reduced product $0.11 million per year in reduced NOX operating savings and CO2 emission operating costs, $314 million per year in emissions. In this case, the net benefit reductions provides a useful CO2 reductions, and $19.3 million per would amount to $19 million per year. perspective, two issues should be year in reduced NOX emissions. In this Using a 3-percent discount rate for all considered. First, the national operating case, the net benefit would amount to benefits and costs and the average SCC savings are domestic U.S. consumer $642 million per year. Using a 3-percent series, the estimated annualized cost of monetary savings that occur as a result discount rate for all benefits and costs the standards proposed in today’s rule of market transactions while the value and the average SCC series, the is negative $9.7 million per year in of CO2 reductions is based on a global estimated cost of the standards reduced product costs, and the value. Second, the assessments of proposed in today’s rule is $751 million annualized benefits of the standards operating cost savings and CO2 savings per year in increased product costs; proposed in today’s rule are $5.9 are performed with different methods while the estimated benefits are $1,200 million per year in reduced operating that use different time frames for million per year in reduced operating costs, $1.4 million per year in CO2 analysis. The national operating cost costs, $314 million per year in CO 2 reductions, and $0.09 million per year savings is measured for the lifetime of reductions, and $18.9 million per year in reduced NOX emissions. In this case, GSFLs and IRLs shipped in 2017–2046. in reduced NOX emissions. In this case, The SCC values, on the other hand, the net benefit would amount to the net benefit would amount to reflect the present value of some future approximately $783 million per year. approximately $17 million per year.

TABLE I.7—ANNUALIZED BENEFITS AND COSTS OF PROPOSED ENERGY CONSERVATION STANDARDS FOR GENERAL SERVICE FLUORESCENT LAMPS

Low net benefits High net benefits Discount rate Primary estimate * estimate * estimate *

million 2012$/year

Benefits

Operating Cost Savings ...... 7% ...... 1,180 1,160 1,220 3% ...... 1,200 1,170 1,250 CO2 Reduction Monetized Value ($11.8/t case) ** ..... 5% ...... 98 98 98 CO2 Reduction Monetized Value ($39.7/t case) ** ..... 3% ...... 314 314 314 CO2 Reduction Monetized Value ($61.2/t case) ** ..... 2.5% ...... 456 456 456 CO2 Reduction Monetized Value ($117/t case) ** ...... 3% ...... 968 968 968 NOX Reduction Monetized Value (at $2,639/ton) ** ... 7% ...... 19.3 19.3 19.3 3% ...... 18.9 18.9 18.9 Total Benefits† ...... 7% plus CO2 range ...... 1,300 to 2,160 1,280 to 2,140 1,340 to 2,210 7% ...... 1,520 1,490 1,560

5 DOE used a two-step calculation process to the latter, DOE used a range of discount rates, as the annualized values were determined is a steady convert the time-series of costs and benefits into shown in Table I.5 and Table I.6. From the present stream of payments. annualized values. First, DOE calculated a present value, DOE then calculated the fixed annual 6 This negative cost represents a reduction in value in 2013, the year used for discounting the payment over a 30-year period (2017 through 2046) product costs compared to the base case, because NPV of total consumer costs and savings, for the that yields the same present value. The fixed annual time-series of costs and benefits using discount payment is the annualized value. Although DOE the more efficacious products have substantially rates of three and seven percent for all costs and calculated annualized values, this does not imply longer lifetimes than the products that would be benefits except for the value of CO2 reductions. For that the time-series of cost and benefits from which eliminated by the proposed standard.

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TABLE I.7—ANNUALIZED BENEFITS AND COSTS OF PROPOSED ENERGY CONSERVATION STANDARDS FOR GENERAL SERVICE FLUORESCENT LAMPS—Continued

Low net benefits High net benefits Discount rate Primary estimate * estimate * estimate *

million 2012$/year

3% plus CO2 range ...... 1,320 to 2,180 1,290 to 2,160 1,370 to 2,230 3% ...... 1,530 1,510 1,580

Costs

Incremental Product Costs ...... 7% ...... 873 910 873 3% ...... 751 785 751

Net Benefits

Total † ...... 7% plus CO2 range ...... 426 to 1,291 367 to 1,232 469 to 1,330 7% ...... 642 583 685 3% plus CO2 range ...... 567 to 1,432 505 to 1,370 615 to 1,480 3% ...... 783 722 831 * This table presents the annualized costs and benefits associated with GSFLs shipped in 2017¥2046. These results include benefits to con- sumers which accrue after 2046 from the products purchased in 2017¥2046. The results account for the incremental variable and fixed costs in- curred by manufacturers due to the standard, some of which may be incurred in preparation for the rule. The Primary Benefits Estimate assumes the central energy prices from AEO 2013 and a decreasing incremental product cost, due to price learning. The Low Benefits Estimate assumes the low estimate of energy prices from AEO 2013 and constant real product prices. The High Benefits Estimate assumes the high energy price estimates from AEO 2013 and decreasing incremental product costs, due to price learning. ** The CO2 values represent global monetized values of the SCC, in 2012$, in 2015 under several scenarios of the updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 3%, and 2.5% discount rates, respectively. The fourth case rep- resents the 95th percentile of the SCC distribution calculated using a 3% discount rate. The SCC time series used by DOE incorporate an esca- lation factor. The value for NOX is the average of the low and high values used in DOE’s analysis. † Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to average SCC with 3-percent discount rate. In the rows labeled ‘‘7% plus CO2 range’’ and ‘‘3% plus CO2 range,’’ the operating cost and NOX benefits are calculated using the labeled discount rate, and those values are added to the full range of CO2 values.

TABLE I.8—ANNUALIZED BENEFITS AND COSTS OF PROPOSED ENERGY CONSERVATION STANDARDS FOR INCANDESCENT REFLECTOR LAMPS

Low net benefits High net benefits Discount rate Primary estimate * estimate * estimate *

million 2012$/year

Benefits

Operating Cost Savings ...... 7% ...... 7.2 7.1 10 3% ...... 5.9 5.8 5.8 CO2 Reduction Monetized Value ($11.8/t case) ** ..... 5% ...... 0.5 0.5 0.5 CO2 Reduction Monetized Value ($39.7/t case) ** ..... 3% ...... 1.4 1.4 1.4 CO2 Reduction Monetized Value ($61.2/t case) ** ..... 2.5% ...... 2.0 2.0 2.0 CO2 Reduction Monetized Value ($117/t case) * ...... 3% ...... 4.2 4.2 4.2 NOX Reduction Monetized Value (at $2,639/ton) ** ... 7% ...... 0.11 0.11 0.16 3% ...... 0.09 0.09 0.09 Total Benefits † ...... 7% plus CO2 range ...... 7.8 to 12 7.7 to 11 7.8 to 12 7% ...... 8.7 8.6 8.7 3% plus CO2 range ...... 6.4 to 10 6.4 to 10 6.4 to 10 3% ...... 7.4 7.3 7.3

Costs

Incremental Product Costs ‡ ...... 7% ...... ¥10.4 ¥10.5 ¥10.4 3% ...... ¥9.7 ¥9.8 ¥9.7

Net Benefits

Total † ...... 7% plus CO2 range ...... 18 to 22 18 to 22 18 to 22 7% ...... 19 19 19 3% plus CO2 range ...... 16 to 20 16 to 20 16 to 20 3% ...... 17 17 17 * This table presents the annualized costs and benefits associated with IRLs shipped in 2017¥2046. These results include benefits to con- sumers which accrue after 2046 from the products purchased in 2017¥2046. The results account for the incremental variable and fixed costs in- curred by manufacturers due to the standard, some of which may be incurred in preparation for the rule. The Primary Benefits Estimate assumes the central energy prices from AEO 2013 and a decreasing incremental product cost, due to price learning. The Low Benefits Estimate assumes the low estimate of energy prices from AEO 2013 and constant real product prices. The High Benefits Estimate assumes the high energy price estimates from AEO 2013 and decreasing incremental product costs, due to price learning.

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** The CO2 values represent global monetized values of the SCC, in 2012$, in 2015 under several scenarios of the updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 3%, and 2.5% discount rates, respectively. The fourth case rep- resents the 95th percentile of the SCC distribution calculated using a 3% discount rate. The SCC time series used by DOE incorporate an esca- lation factor. The value for NOX is the average of the low and high values used in DOE’s analysis. † Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to average SCC with 3-percent discount rate. In the rows labeled ‘‘7% plus CO2 range’’ and ‘‘3% plus CO2 range,’’ the operating cost and NOX benefits are calculated using the labeled discount rate, and those values are added to the full range of CO2 values. ‡ This reduction in product costs occurs because the more efficacious products have substantially longer lifetimes than the products that would be eliminated by the proposed standard.

DOE has tentatively concluded that Register, which completed the first to achieve the maximum improvement the proposed standards represent the rulemaking cycle to amend energy in energy efficiency that is maximum improvement in energy conservation standards for GSFLs and technologically feasible and efficiency that is technologically IRLs (hereafter the ‘‘2009 Lamps Rule’’). economically justified. (42 U.S.C. feasible and economically justified, and 74 FR 34080. That rule adopted 6295(o)(2)(A)) Furthermore, DOE may would result in the significant standards for additional GSFLs, not adopt any standard that would not conservation of energy. DOE further amended the definition of ‘‘colored result in the significant conservation of notes that products achieving these fluorescent lamp’’ and ‘‘rated wattage,’’ energy. (42 U.S.C. 6295(o)(3)) Moreover, standard levels are already and also adopted test procedures DOE may not prescribe a standard: (1) commercially available. Based on the applicable to the newly covered GSFLs. for certain products, including GSFLs analyses described above, DOE has Information regarding the 2009 Lamps and IRLs, if no test procedure has been tentatively concluded that the benefits Rule can be found on regulations.gov, established for the product, or (2) if DOE of the proposed standards to the nation docket number EERE–2006–STD–0131 determines by rule that the proposed (energy savings, positive NPV of at www.regulations.gov/ standard is not technologically feasible consumer benefits, consumer LCC #!docketDetail;D=EERE-2006-STD-0131. or economically justified. (42 U.S.C. savings, and emission reductions) This rulemaking encompasses DOE’s 6295(o)(3)(A)–(B)) In deciding whether a would outweigh the burdens (loss of second cycle of review to determine proposed standard is economically INPV for manufacturers and LCC whether the standards in effect for justified, DOE must determine whether increases for some consumers). GSFLs and IRLs should be amended, the benefits of the standard exceed its Based on consideration of the public including whether the standards should burdens. (42 U.S.C. 6295(o)(2)(B)(i)) comments DOE receives in response to be applicable to additional GSFLs. DOE must make this determination after this notice and related information Pursuant to EPCA, DOE’s energy receiving comments on the proposed collected and analyzed during the conservation program for covered standard, and by considering, to the course of this rulemaking effort, DOE products consists essentially of four greatest extent practicable, the following may adopt energy efficiency levels parts: (1) testing; (2) labeling; (3) the seven factors: presented in this notice that differ from establishment of Federal energy 1. The economic impact of the the proposed standards, or some conservation standards; and (4) standard on manufacturers and combination of level(s) that incorporate certification and enforcement consumers of the products subject to the the proposed standards in part. procedures. The Federal Trade standard; Commission (FTC) is primarily 2. The savings in operating costs II. Introduction responsible for labeling, and DOE throughout the estimated average life of The following section briefly implements the remainder of the the covered products in the type (or discusses the statutory authority program. Subject to certain criteria and class) compared to any increase in the underlying today’s proposal, as well as conditions, DOE is required to develop price, initial charges, or maintenance some of the relevant historical test procedures to measure the energy expenses for the covered products that background related to the establishment efficiency, energy use, or estimated are likely to result from the imposition of standards for GSFLs and IRLs. annual operating cost of each covered of the standard; product. (42 U.S.C. 6293) Manufacturers 3. The total projected amount of A. Authority of covered products must use the energy, or as applicable, water, savings Title III, Part B of the EPCA, Public prescribed DOE test procedure as the likely to result directly from the Law 94–163 (42 U.S.C. 6291–6309, as basis for certifying to DOE that their imposition of the standard; codified) established the Energy products comply with the applicable 4. Any lessening of the utility or the Conservation Program for Consumer energy conservation standards adopted performance of the covered products Products Other Than Automobiles,7 a under EPCA and when making likely to result from the imposition of program covering most major household representations to the public regarding the standard; appliances (collectively referred to as the energy use or efficiency of those 5. The impact of any lessening of ‘‘covered products’’), which includes products. (42 U.S.C. 6293(c) and competition, as determined in writing the types of GSFLs and IRLs that are the 6295(s)) Similarly, DOE must use these by the Attorney General, that is likely to subject of this rulemaking. (42 U.S.C. test procedures to determine whether result from the imposition of the 6292(a)(14)) EPCA prescribed energy the products comply with standards standard; conservation standards for these adopted pursuant to EPCA. Id. The DOE 6. The need for national energy and products (42 U.S.C. 6295(i)(1)), and test procedures for GSFLs and IRLs water conservation; and directed DOE to conduct two cycles of currently appear at title 10 of the Code 7. Other factors the Secretary of rulemakings to determine whether to of Federal Regulations (CFR) part 430, Energy (Secretary) considers relevant. amend these standards. (42 U.S.C. subpart B, appendix R. (42 U.S.C. 6295(o)(2)(B)(i)(I)–(VII)) 6295(i)(3)–(5)) On July 14, 2009, DOE DOE must follow specific statutory EPCA, as codified, also contains what published a final rule in the Federal criteria for prescribing amended is known as an ‘‘anti-backsliding’’ standards for covered products. As provision, which prevents the Secretary 7 For editorial reasons, upon codification in the indicated above, any amended standard from prescribing any amended standard U.S. Code, Part B was redesignated Part A. for a covered product must be designed that either increases the maximum

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allowable energy use or decreases the explanation of the basis on which such cumulative regulations; (3) select, in minimum required energy efficiency of higher or lower level was established. choosing among alternative regulatory a covered product. (42 U.S.C. (42 U.S.C. 6295(q)(2)) approaches, those approaches that 6295(o)(1)) Also, the Secretary may not Federal energy conservation maximize net benefits (including prescribe an amended or new standard requirements generally supersede state potential economic, environmental, if interested persons have established by laws or regulations concerning energy public health and safety, and other a preponderance of the evidence that conservation testing, labeling, and advantages; distributive impacts; and the standard is likely to result in the standards. (42 U.S.C. 6297(a)–(c)) DOE equity); (4) to the extent feasible, specify unavailability in the United States of may, however, grant waivers of federal performance objectives, rather than any covered product type (or class) of preemption for particular state laws or specifying the behavior or manner of performance characteristics (including regulations, in accordance with the compliance that regulated entities must reliability), features, sizes, capacities, procedures and other provisions set adopt; and (5) identify and assess and volumes that are substantially the forth under 42 U.S.C. 6297(d)). available alternatives to direct same as those generally available in the Any final rule for new or amended regulation, including providing United States. (42 U.S.C. 6295(o)(4)) energy conservation standards economic incentives to encourage the Further, EPCA, as codified, promulgated after July 1, 2010, must desired behavior, such as user fees or also address standby mode and off mode establishes a rebuttable presumption marketable permits, or providing energy use. (42 U.S.C. 6295(gg)(3)) that a standard is economically justified information upon which choices can be Specifically, when DOE adopts a if the Secretary finds that the additional made by the public. cost to the consumer of purchasing a standard for a covered product after that product complying with an energy date, it must, if justified by the criteria DOE emphasizes as well that conservation standard level will be less for adoption of standards under EPCA Executive Order 13563 requires agencies than three times the value of the energy (42 U.S.C. 6295(o)), incorporate standby to use the best available techniques to savings during the first year that the mode and off mode energy use into the quantify anticipated present and future consumer will receive as a result of the standard, or, if that is not feasible, adopt benefits and costs as accurately as standard, as calculated under the a separate standard for such energy use possible. In its guidance, the Office of applicable test procedure. See 42 U.S.C. for that product. (42 U.S.C. Information and Regulatory Affairs has 6295(o)(2)(B)(iii). 6295(gg)(3)(A)–(B)) DOE has determined emphasized that such techniques may Additionally, 42 U.S.C. 6295(q)(1) that standby mode and off mode do not include identifying changing future specifies requirements when apply to GSFLs and IRLs and that their compliance costs that might result from promulgating a standard for a type or energy use is accounted for entirely in technological innovation or anticipated class of covered product that has two or the active mode. Therefore, DOE is not behavioral changes. For the reasons more subcategories. DOE must specify a addressing standby and off modes, and stated in the preamble, DOE believes different standard level than that which will only address active mode in this that today’s NOPR is consistent with applies generally to such type or class rulemaking. these principles, including the of products for any group of covered DOE has also reviewed this regulation requirement that, to the extent products that have the same function or pursuant to Executive Order 13563, permitted by law, benefits justify costs intended use if DOE determines that issued on January 18, 2011. 76 FR 3281 and that net benefits are maximized. products within such group (A) (Jan. 21, 2011). EO 13563 is Consistent with EO 13563, and the consume a different kind of energy from supplemental to and explicitly reaffirms range of impacts analyzed in this that consumed by other covered the principles, structures, and rulemaking, the energy efficiency products within such type (or class); or definitions governing regulatory review standard proposed herein by DOE (B) have a capacity or other established in Executive Order 12866. achieves maximum net benefits. performance-related feature which other To the extent permitted by law, agencies products within such type (or class) do are required by Executive Order 13563 B. Background not have and such feature justifies a to: (1) Propose or adopt a regulation 1. Current Standards higher or lower standard. (42 U.S.C. only upon a reasoned determination 6294(q)(1)) In determining whether a that its benefits justify its costs In the 2009 Lamps Rule, DOE performance-related feature justifies a (recognizing that some benefits and prescribed the current energy different standard for a group of costs are difficult to quantify); (2) tailor conservation standards for GSFLs and products, DOE must consider such regulations to impose the least burden IRLs manufactured on or after July 14, factors as the utility to the consumer of on society, consistent with obtaining 2012 (hereafter the ‘‘July 2012 the feature and other factors DOE deems regulatory objectives, taking into standards’’). 74 FR 34080. The current appropriate. Id. Any rule prescribing account, among other things, and to the standards are set forth in Table II.1 and such a standard must include an extent practicable, the costs of Table II.2.

TABLE II.1—JULY 2012 STANDARDS FOR GENERAL SERVICE FLUORESCENT LAMPS

Minimum average lamp Lamp type Correlated color temperature efficacy lm/W

Four-Foot Medium Bipin ...... ≤4,500 K ...... 89 >4,500 K and ≤7,000 K ...... 88 Two-Foot U-Shaped ...... ≤4,500 K ...... 84 >4,500 K and ≤7,000 K ...... 81 Eight-Foot Slimline ...... ≤4,500 K ...... 97 >4,500 K and ≤7,000 K ...... 93 Eight-Foot High Output ...... ≤4,500 K ...... 92

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TABLE II.1—JULY 2012 STANDARDS FOR GENERAL SERVICE FLUORESCENT LAMPS—Continued

Minimum average lamp Lamp type Correlated color temperature efficacy lm/W

>4,500 K and ≤7,000 K ...... 88 Four-Foot Miniature Bipin Standard Output ...... ≤4,500 K ...... 86 >4,500 K and ≤7,000 K ...... 81 Four-Foot Miniature Bipin High Output ...... ≤4,500 K ...... 76 >4,500 K and ≤7,000 K ...... 72

TABLE II.2—JULY 2012 STANDARDS FOR INCANDESCENT REFLECTOR LAMPS

Minimum average Rated lamp Lamp spectrum Lamp diameter Rated voltage lamp efficacy wattage inches lm/W

40–205 ...... Standard Spectrum ...... >2.5 ≥125 V 6.8*P0.27 <125 V 5.9*P0.27 ≤2.5 ≥125 V 5.7*P0.27 <125 V 5.0*P0.27

40–205 ...... Modified Spectrum ...... >2.5 8 ≥125 V 5.8*P0.27 <125 V 5.0*P0.27 ≤2.5 ≥125 V 4.9*P0.27 <125 V 4.2*P0.27 Note 1: P is equal to the rated lamp wattage, in watts. Note 2: Standard Spectrum means any incandescent reflector lamp that does not meet the definition of modified spectrum in 430.2.

2. Corrections to Codified Standards standards specified in EPCA and the IRL shaped lamp type. For 8-foot SP standards established by the 2009 slimline product class with a minimum In this rulemaking, DOE is proposing Lamps Rule. Specifically, for the GSFL color rendering index (CRI) of 45 and a to correct errors in the codified standards codified at 10 CFR minimum average lamp efficacy of 80.0 standards for GSFLs and IRLs. In 430.32(n)(1), the ‘‘less than or equal to lumens per watt (lm/W), the rated particular, DOE is proposing to correct 35 W’’ associated with the 8-foot single wattage should be less than or equal to the typographical errors in the sections pin (SP) slimline lamp type should 65 W, not greater than 65 W. The of the CFR that lay out the GSFL instead be associated with the 2-foot U- revised table should read as follows:

TABLE II.3—GSFL STANDARDS PRESCRIBED BY EPACT

Minimum average lamp Lamp type Nominal lamp wattage Minimum CRI efficacy Effective date lm/W

4-foot medium bipin ...... >35 W ...... 69 75.0 Nov. 1, 1995. ≤35 W ...... 45 75.0 Nov. 1, 1995. 2-foot U-shaped ...... >35 W ...... 69 68.0 Nov. 1, 1995. ≤35 W ...... 45 64.0 Nov. 1, 1995. 8-foot slimline ...... >65 W ...... 69 80.0 May 1, 1994. ≤65 W ...... 45 80.0 May 1, 1994. 8-foot high output ...... >100 W ...... 69 80.0 May 1, 1994. ≤100 W ...... 45 80.0 May 1, 1994.

For the IRL standards adopted by the rated wattage of 40–205 W, modified than or equal to 125 V.’’ The revised 2009 Lamps Rule that are codified in 10 spectrum, diameter greater than 2.5 table should read as follows: CFR 430.32(n)(5), the minimum lamp inches, and rated voltage of ‘‘greater efficacy of 5.8P0.27 is for lamps with a than or equal to 125 V’’ rather than ‘‘less

8 Shown correctly in this table; erroneously written as ‘‘≤125V’’ in the CFR.

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TABLE II.4—IRL STANDARDS ADOPTED BY THE 2009 LAMPS RULE

Minimum Rated lamp Lamp diameter average lamp wattage Lamp spectrum inches Rated voltage efficacy lm/W

40–205 ...... Standard Spectrum ...... >2.5 ≥125 V 6.8*P0.27 <125 V 5.9*P0.27 ≤2.5 ≥125 V 5.7*P0.27 <125 V 5.0*P0.27 40–205 ...... Modified Spectrum ...... >2 .5 ≥125 V 5.8*P0.27 <125 V 5.0*P0.27 ≤2.5 ≥125 V 4.9*P0.27 <125 V 4.2*P0.27

3. History of Standards Rulemaking for IRLs: (1) lamps rated 50 W or less that IRLs (other than the certain R, ER, and General Service Fluorescent Lamps and are ER30, BR30, BR40, or ER40; (2) BR IRLs discussed in the preceding Incandescent Reflector Lamps lamps rated 65 W that are BR30, BR40, paragraphs), on September 14, 2011, or ER40 lamps; and (3) R20 IRLs rated DOE published a notice announcing the As mentioned in the previous section, 45 W or less. (42 U.S.C. 6295(i)(C)) DOE availability of the framework document, EPCA, as amended, established energy refers to these three categories of lamps ‘‘Energy Conservation Standards conservation standards for certain collectively as certain R, ER, and BR Rulemaking Framework Document for classes of GSFLs and IRLs, and required IRLs. General Service Fluorescent Lamps and DOE to conduct two rulemaking cycles DOE has concluded, for the reasons Incandescent Reflector Lamps,’’ and a to determine whether these standards that follow, that it has the authority public meeting to discuss the proposed should be amended. (42 U.S.C. 6291(1), under EPCA to adopt standards for these analytical framework for the 6295(i)(1) and (3)–(4)) EPCA also R, ER, and BR IRLs, and that these rulemaking. 76 FR 56678. DOE also authorized DOE to adopt standards for lamps are covered by the directive in 42 posted the framework document on its additional GSFLs if such standards were U.S.C. 6295(i)(3) to amend EPCA’s Web site, in which DOE described the warranted. (42 U.S.C. 6295(i)(5)) standards for IRLs. First, by amending procedural and analytical approaches DOE completed the first cycle of the definition of ‘‘incandescent reflector DOE anticipated using to evaluate the amendments by publishing a final rule lamp’’ (42 U.S.C. 6291(30)(C)(ii) and establishment of energy conservation in the Federal Register in July 2009. 74 (F)), EISA 2007 effectively brought these standards for GSFLs and IRLs. FR 34080 (July 14, 2009). The 2009 R, ER, and BR IRLs into the federal DOE held the public meeting for the Lamps Rule amended existing GSFL and energy conservation standards program framework document on October 4, IRL energy conservation standards and as covered products, thereby subjecting 2011,10 to present the framework adopted standards for additional GSFLs. them to DOE’s regulatory authority. document, describe the analyses it That rule also amended the definition of Second, although 42 U.S.C. 6295(i)(1)(C) planned to conduct during the ‘‘colored fluorescent lamp’’ and ‘‘rated exempts these R, ER, and BR IRLs from rulemaking, seek comments from wattage,’’ and adopted test procedures the standards specified in 42 U.S.C. stakeholders on these subjects, and applicable to the newly covered GSFLs. 6295(i)(1)(B), EPCA directs that DOE inform stakeholders about and facilitate The Energy Policy Act of 1992 (EPAct amend the standards laid out in 42 their involvement in the rulemaking. At 1992, Pub. L. 102–486) amendments to U.S.C. 6295(i)(1), which includes the public meeting, and during the EPCA added as covered products IRLs subparagraph (C). As a result, the comment period, DOE received many with wattages of 40 watts (W) or higher. statutory text exempted these bulbs only comments that both addressed issues In defining the term ‘‘incandescent from the standards specified in 42 raised in the framework document and reflector lamp,’’ EPAct 1992 excluded U.S.C. 6295(i)(1), not from future identified additional issues relevant to lamps with elliptical reflector (ER) and regulation. Consequently, DOE began this rulemaking. bulged reflector (BR) bulb shapes, and considering energy conservation DOE issued the preliminary analysis with diameters of 2.75 inches or less. standards for these R, ER, and BR IRLs. for this rulemaking on February 20, Therefore, such IRLs were neither DOE initiated a new rulemaking for 2013 and published it in the Federal included as covered products nor these products by completing a Register on February 28, 2013. 78 FR subject to EPCA’s standards for IRLs. framework document and publishing a 13563 (February 28, 2013). DOE posted Section 322(a)(1) of the Energy notice announcing its availability. 75 FR the preliminary analysis, as well as the Independence and Security Act of 2007 23191 (May 3, 2010). DOE held a public complete preliminary technical support (EISA 2007) subsequently amended meeting on May 26, 2010 to seek input document (TSD), on its Web site.11 The EPCA to expand the Act’s definition of from interested parties on its preliminary TSD includes the results of ‘‘incandescent reflector lamp’’ to methodologies, assumptions, and data the following DOE preliminary analyses: include lamps with a diameter between sources.9 (1) market and technology assessment; 2.25 and 2.75 inches, as well as lamps To initiate the second rulemaking (2) screening analysis; (3) engineering with ER, BR, bulged parabolic cycle to consider amended energy analysis; (4) energy use characterization; aluminized reflector (BPAR), or similar conservation standards for GSFLs and bulb shapes. (42 U.S.C. 6291(30)(C)(ii) 10 The framework document and public meeting and (F)) Section 322(b) of EISA 2007, in 9 DOE has suspended activity on this rulemaking information are available at regulations.gov under amending EPCA to set forth revised as a result of section 315 of Public Law (Pub. L.) docket number EERE–2011–BT–STD–0006. 112–74 (Dec. 23, 2011), which prohibits DOE from 11 The preliminary analysis, preliminary TSD, standards for IRLs in new section using appropriated funds to implement or enforce and preliminary analysis public meeting 325(i)(1)(C), exempted from these standards for ER, BR, and bulged parabolic reflector information are available at regulations.gov under standards the following categories of IRLs. docket number EERE–2011–BT–STD–0006.

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(5) product price determinations; (6) comments received during the public is not providing any standby or active LCC and PBP analyses; (7) shipments meeting, along with the written mode function. Id. analysis; and (8) national impact comments submitted to DOE since To satisfy the EPCA definitions of analysis (NIA). publication of the preliminary analysis, standby mode and off mode (42 U.S.C. In the preliminary analysis, DOE have contributed to DOE’s proposed 6295(gg)(1)), the lamp must not be described and sought comment on the resolution of the issues in this providing any active mode function analytical framework, models, and tools rulemaking. This NOPR responds to the (i.e., emitting light). However, to reach (e.g., LCC and national energy savings issues raised in these public comments. such a state, the lamp must be entirely [NES] spreadsheets) DOE used to disconnected from the main power analyze the impacts of energy 4. Test Procedure source (i.e., switched off), thereby not conservation standards for GSFLs and EPCA sets forth generally applicable satisfying the requirements of operating IRLs. Specifically, DOE invited criteria and procedures for DOE’s in off mode or standby mode. Further, comment on the following issues: (1) adoption and amendment of test neither GSFLs nor IRLs covered under consideration of additional GSFLs; (2) procedures. (42 U.S.C. 6293) this rulemaking provide any secondary amended definitions; (3) market trends; Manufacturers of covered products must user-oriented or protection functions or (4) technology options; (5) product use these test procedures to certify to continuous standby mode functions. classes; (6) market and technology DOE that their product complies with Thus, these lamps do not satisfy the assessment methodology; (7) screening EPCA energy conservation standards EPCA definition of standby mode. of design options; (8) representative and to quantify the efficiency of their While EPCA allows DOE to amend the product classes; (9) baseline lamps; (10) product. Similarly, DOE uses the test mode definitions (42 U.S.C. more efficacious substitutes; (11) lamp- procedure to determine compliance 6295(gg)(1)(B)), DOE believes that the and-ballast systems; (12) 4-foot T5 with energy conservation standards. energy use of GSFLs and IRLs is miniature bipin (MiniBP) HO model DOE’s test procedures for fluorescent accounted for entirely in the active lamp; (13) candidate standard levels and incandescent reflector lamps are set mode. Therefore, DOE is not addressing (CSLs); (14) compliance requirements; forth in title 10 of the CFR, part 430, lamp operation in the standby and off (15) scaling to product classes not subpart B, appendix R. These test modes in this rulemaking. analyzed; (16) engineering analysis procedures provide instructions for III. General Discussion methodology; (17) product price measuring GSFL and IRL performance, determination; (18) GSFL ballast prices; largely by incorporating industry A. Product Classes and Scope of (19) dimmed GSFL systems; (20) standards. The test procedures were Coverage lighting controls market penetration; updated in a final rule published in July When evaluating and establishing (21) lighting controls performance 2009. 74 FR 31829 (July 6, 2009). The energy conservation standards, DOE characteristics; (22) operating profiles rule updated citations to industry divides covered products into product for energy use characterization; (23) standards and made several other classes by the type of energy used or by residential GSFL LCC analysis; (24) modifications. DOE further amended the capacity or other performance-related sales tax in the LCC analysis; (25) test procedures to update references to features that justifies a different spacing adjustments in the LCC industry standards for GSFLs in a final standard. In making a determination rule published in January 2012. 77 FR analysis; (26) LCC analysis overall whether a performance-related feature 4203 (January 27, 2012). methodology and results; (27) T5s in the justifies a different standard, DOE must residential market; (28) the shipments Standby and Off Mode Energy consider such factors as the utility to the and national impact analyses; (29) LCC Consumption consumer of the feature and other subgroups; (30) small businesses that EPCA requires energy conservation factors DOE determines are appropriate. manufacture GSFLs and IRLs; (31) (42 U.S.C. 6295(q)) For further details manufacturer subgroup analysis; (32) standards adopted for a covered product after July 1, 2010 to address standby on the scope of coverage for this key issues and data for the manufacturer rulemaking, see section V. For further impact analysis (MIA); (33) valuing mode and off mode energy use. (42 U.S.C. 6295(gg)(3)) EPCA defines active details on product classes, see section airborne emission reductions; (34) data VI.C and chapter 3 of the NOPR TSD. and programs for the regulatory impact mode as the condition in which an analysis (RIA); and (35) TSLs. (See energy-using piece of equipment is B. Technological Feasibility connected to a main power source, has executive summary and chapter 2 of the 1. General preliminary TSD.) been activated, and provides one or DOE held a public meeting on April more main functions. (42 U.S.C. In each standards rulemaking, DOE 9, 2013, to present the methodologies 6295)(gg)(1)(A)) Standby mode is conducts a screening analysis based on and results for the preliminary analyses. defined as the condition in which an information gathered on all current Manufacturers, trade associations, and energy-using piece of equipment is technology options and prototype environmental advocates attended the connected to a main power source and designs that could improve the meeting. The participants discussed offers one or more of the following user- efficiency of the products or equipment multiple issues, including the oriented or protective functions: that are the subject of the rulemaking. methodology and results of the market facilitating the activation or deactivation As the first step in such an analysis, and technology assessment, screening of other functions (including active DOE develops a list of technology analysis, engineering analysis, product mode) by remote switch (including options for consideration in price determination, energy use, LCC remote control), internal sensor, or consultation with manufacturers, design analysis, shipments analysis, and NIA. timer; or providing continuous engineers, and other interested parties. Other issues brought up during the functions, including information or DOE then determines which of those public meeting included regulatory status displays (including clocks) or means for improving efficiency are authority and rulemaking schedule. sensor-based functions. Id. Off mode is technologically feasible. DOE considers Finally, the MIA and additional defined as the condition in which an technologies incorporated in analyses that are undertaken during the energy-using piece of equipment is commercially available products or in NOPR stage were discussed. The connected to a main power source, and working prototypes to be

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technologically feasible. 10 CFR 430, projection of energy consumption in the a. Economic Impact on Manufacturers subpart C, appendix A, section 4(a)(4)(i) absence of amended mandatory and Consumers After DOE has determined that efficiency standards, and considers In determining the impacts of an particular technology options are market forces and policies that affect amended standard on manufacturers, technologically feasible, it further demand for more efficient products. DOE first uses an annual cash-flow evaluates each technology option in DOE used its NIA spreadsheet model approach to determine the quantitative light of the following additional to estimate energy savings from impacts. This step includes both a short- screening criteria: (1) practicability to amended standards for the products that term assessment—based on the cost and manufacture, install, or service; (2) are the subject of this rulemaking. The capital requirements during the period adverse impacts on product utility or NIA spreadsheet model (described in between when a regulation is issued and availability; and (3) adverse impacts on section VI.J of this notice) calculates when entities must comply with the health or safety. Section VI.B of this energy savings in site energy, which is regulation—and a long-term assessment notice discusses the results of the the energy directly consumed by over a 30-year period. The industry- screening analysis for GSFLs and IRLs, products at the locations where they are particularly the designs DOE wide impacts analyzed include INPV, used. For electricity, DOE reports NES which values the industry on the basis considered, those it screened out, and in terms of the savings in the energy that those that are the basis for the TSLs in of expected future cash flows; cash is used to generate and transmit the site flows by year; changes in revenue and this rulemaking. For further details on electricity. To calculate this quantity, the screening analysis for this income; and other measures of impact, DOE derives annual conversion factors as appropriate. Second, DOE analyzes rulemaking, see chapter 4 of the NOPR from the model used to prepare the U.S. TSD. and reports the impacts on different Energy Information Administration’s types of manufacturers, including 2. Maximum Technologically Feasible (EIA’s) Annual Energy Outlook (AEO). impacts on small manufacturers. Third, Levels DOE also estimates full-fuel-cycle DOE considers the impact of standards (FFC) energy savings. 76 FR 51282 (Aug. on domestic manufacturer employment When DOE proposes to adopt an 18, 2011), as amended at 77 FR 49701 amended standard for a type or class of and manufacturing capacity, as well as (August 17, 2012). The FFC metric the potential for standards to result in covered product, it must determine the includes the energy consumed in maximum improvement in energy plant closures and loss of capital extracting, processing, and transporting investment. Finally, DOE takes into efficiency or maximum reduction in primary fuels (i.e., coal, natural gas, energy use that is technologically account cumulative impacts of various petroleum fuels), and thus presents a DOE regulations and other regulatory feasible for such product. (42 U.S.C. more complete picture of the impacts of 6295(p)(1)) Accordingly, in the requirements on manufacturers. For this energy efficiency standards. DOE’s rulemaking, these impacts include those engineering analysis, DOE determined approach is based on calculation of an the maximum technologically feasible resulting from the 2009 Lamps Rule. FFC multiplier for each of the energy For individual consumers, measures (‘‘max tech’’) improvements in energy types used by covered products. For efficiency for GSFLs and IRLs, using the of economic impact include the changes more information on FFC energy in LCC and PBP associated with new or design parameters for the most efficient savings, see section VI.J. products available on the market or in amended standards. These measures are working prototypes. (See chapter 5 of 2. Significance of Savings discussed further in the following section. For consumers in the aggregate, the NOPR TSD.) The max tech levels As noted above, 42 U.S.C. DOE also calculates the national NPV of that DOE determined for this 6295(o)(3)(B) prevents DOE from the economic impacts applicable to a rulemaking are described in section adopting a standard for a covered particular rulemaking. DOE also VI.D.2.f for GFSLs and VI.D.3.e for IRLs product unless such standard would evaluates the LCC impacts of potential of this proposed rule. result in ‘‘significant’’ energy savings. standards on identifiable subgroups of Although the term ‘‘significant’’ is not C. Energy Savings consumers that may be affected defined in the Act, the U.S. Court of disproportionately by a national 1. Determination of Savings Appeals, in Natural Resources Defense standard. For each TSL, DOE projected energy Council v. Herrington, 768 F.2d 1355, savings from the products that are the 1373 (D.C. Cir. 1985), indicated that b. Savings in Operating Costs Compared subject of this rulemaking purchased in Congress intended ‘‘significant’’ energy to Increase in Price the 30-year period that begins in the savings in this context to be savings that EPCA requires DOE to consider the year of compliance with any amended were not ‘‘genuinely trivial.’’ The energy savings in operating costs throughout standards (2017–2046). The savings are savings for all of the TSLs considered in the estimated average life of the covered measured over the entire lifetime of this rulemaking (presented in section product compared to any increase in the products purchased in the 30-year VII.A) are nontrivial, and, therefore, price of the covered product that is 12 period. DOE quantified the energy DOE considers them ‘‘significant’’ likely to result from the imposition of savings attributable to each TSL as the within the meaning of section 325 of the standard. (42 U.S.C. difference in energy consumption EPCA. 6295(o)(2)(B)(i)(II)) DOE conducts this between each standards case and the D. Economic Justification comparison in its LCC and PBP analysis. base case. The base case represents a The LCC is the sum of the purchase 1. Specific Criteria price of a product (including its 12 DOE previously presented energy savings installation) and the operating expense results for the 30-year period that begins in the year EPCA provides seven factors to be of compliance. In the calculation of economic evaluated in determining whether a (including energy, maintenance, and impacts, however, DOE considered operating cost potential energy conservation standard repair expenditures) discounted over savings measured over the entire lifetime of is economically justified. (42 U.S.C. the lifetime of the product. To account products purchased in the 30-year period. DOE has for uncertainty and variability in modified its presentation of NES to be consistent 6295(o)(2)(B)(i)) The following sections with the approach used for its national economic discuss how DOE has addressed each of specific inputs, such as product lifetime analysis. those seven factors in this rulemaking. and discount rate, DOE uses a

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distribution of values, with probabilities f. Need for National Energy discussed in section III.D of this attached to each value. For its analysis, Conservation proposed rule. DOE assumes that consumers will The energy savings from the proposed IV. Issues Affecting Rulemaking purchase the covered products in the standards are likely to provide Schedule first year of compliance with amended improvements to the security and standards. In the schedule presented in the reliability of the nation’s energy system. framework document of this The LCC savings and the PBP for the Reductions in the demand for electricity rulemaking, the preliminary analysis considered efficacy levels (ELs) are also may result in reduced costs for was scheduled to be published in calculated relative to a base case that maintaining the reliability of the September 2012, the NOPR in August reflects projected market trends in the nation’s electricity system. DOE 2013, and the final rule establishing any absence of amended standards. DOE conducts a utility impact analysis to amended standards in 2014. During the identifies the percentage of consumers estimate how standards may affect the framework stage, stakeholders expressed estimated to receive LCC savings or nation’s needed power generation concerns that because the 2009 Lamps experience an LCC increase, in addition capacity. Rule standards would require to the average LCC savings associated The proposed standards also are compliance July 14, 2012, the with a particular standard level. likely to result in environmental preliminary analysis published in benefits in the form of reduced September 2012 would not be able to c. Energy Savings emissions of air pollutants and account for the impacts of the July 2012 greenhouse gases (GHGs) associated Although significant conservation of standards. DOE noted these concerns with energy production. DOE reports energy is a separate statutory and extended the schedule, publishing the emissions impacts from today’s the preliminary analysis in February requirement for imposing an energy standards, and from each TSL it conservation standard, EPCA requires 2013. DOE received additional considered, in section VI.L of this comments regarding the timing of this DOE, in determining the economic notice. DOE also reports estimates of the justification of a standard, to consider rulemaking in the preliminary analysis economic value of emissions reductions phase. the total projected energy savings that resulting from the considered TSLs. Philips questioned whether this are expected to result directly from the g. Other Factors rulemaking is statutorily required to be standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) completed at this time, specifically As discussed in section VI.J, DOE uses EPCA allows the Secretary, in asking if EPAct 1992 provided a date by the NIA spreadsheet to project NES. determining whether a standard is which the final rule of the second cycle d. Lessening of Utility or Performance of economically justified, to consider any of energy conservation standards for Products other factors that the Secretary deems to GSFLs and IRLs has to be published. be relevant. (42 U.S.C. (Philips, Public Meeting Transcript, No. In establishing classes of products, 6295(o)(2)(B)(i)(VII)) 30 at pp. 27–28) In a Joint Comment, the Appliance and in evaluating design options and 2. Rebuttable Presumption the impact of potential standard levels, Standards Awareness Project (ASAP), DOE evaluates standards that would not As set forth in 42 U.S.C. the Natural Resources Defense Council lessen the utility or performance of the 6295(o)(2)(B)(iii), EPCA creates a (NRDC), the Alliance to Save Energy, considered products. (42 U.S.C. rebuttable presumption that an energy the American Council for an Energy- 6295(o)(2)(B)(i)(IV)) The standards conservation standard is economically Efficient Economy (ACEEE), the proposed in today’s notice will not justified if the additional cost to the Consumer Federation of America, and reduce the utility or performance of the consumer of a product that meets the the National Consumer Law Center, products under consideration in this standard is less than three times the (hereafter the ‘‘Joint Comment’’) and rulemaking. value of the first year’s energy savings Northeast Energy Efficiency resulting from the standard, as Partnerships (NEEP) emphasized that e. Impact of Any Lessening of calculated under the applicable DOE EPAct 1992 requires DOE to complete Competition test procedure. DOE’s LCC and PBP two rounds of rulemakings for IRLs and analyses generate values used to GSFLs. The Joint Comment noted that EPCA directs DOE to consider the calculate the effects that proposed final rule of the first cycle was required impact of any lessening of competition, energy conservation standards would to be published by April 1997. (42 as determined in writing by the have on the payback period for U.S.C. 6295(i)(3)) DOE was required to Attorney General, that is likely to result consumers. These analyses include, but publish the final rule of the second from the imposition of a standard. (42 are not limited to, the 3-year payback cycle five years later. (42 U.S.C. U.S.C. 6295(o)(2)(B)(i)(V) It also directs period contemplated under the 6295(i)(4)) NEEP and the Joint Comment the Attorney General to determine the rebuttable-presumption test. In addition, stated that as DOE failed to publish a impact, if any, of any lessening of DOE routinely conducts an economic final rule for the first cycle until July competition likely to result from a analysis that considers the full range of 2009, it is not possible for DOE to meet proposed standard and to transmit such impacts to consumers, manufacturers, the required deadline date for the determination to the Secretary, together the nation, and the environment, as second cycle. Therefore, NEEP and the with an analysis of the nature and required under 42 U.S.C. Joint Comment agreed that the second extent of the impact. (42 U.S.C. 6295(o)(2)(B)(i). The results of this cycle should occur within the interval 6295(o)(2) (B)(ii)) DOE will transmit a analysis serve as the basis for DOE’s contemplated by Congress when it set copy of today’s proposed rule to the evaluation of the economic justification out the original deadlines, and a final Attorney General with a request that the for a potential standard level (thereby rule should be issued no later than U.S. Department of Justice (DOJ) supporting or rebutting the results of 2014. (NEEP, No. 33 at p. 1; Joint provide its determination on this issue. any preliminary determination of Comment, No. 35 at pp. 1–2) ASAP DOE will address the Attorney General’s economic justification). The rebuttable agreed stating that given that the 2009 determination in the final rule. presumption payback calculation is Lamps Rule was complete, it was not

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discretionary for DOE to have any other reason to proceed within the five-year based on changes that took place after schedule than the one currently in place timeframe. They stated that according to the compliance date on July 14, 2012. for this rulemaking. (ASAP, Public the 2010 U.S. Lighting Market Additionally, for the preliminary Meeting Transcript, No. 30 at pp. 192– Characterization (2010 LMC),13 the U.S. analysis stage, DOE obtained 193) inventory of installed IRLs was information during interviews with General Electric (GE) stated its estimated to be in excess of 641 million manufacturers regarding new product concern that this rulemaking is lamps, representing almost 8 percent of lines they were preparing to launch to occurring too soon after the 2009 Lamps the total installed lighting base, ensure that DOE’s analysis captured the Rule, making it difficult for consuming an estimated 39 terawatt initial market impacts of the July 2012 manufacturers to recover investments in hours (TWh) annually. The 2010 LMC standards. The analysis presented in new technologies or to develop products estimated an inventory of nearly 2.4 this NOPR was updated and finalized meeting even higher standards. GE billion GSFLs, representing 29 percent more than a year after the July 2012 indicated that the close proximity of the of the total installed base, consuming standards required compliance, rulemakings will have a severe and approximately 294 TWh annually. reflecting the most recent data available. negative impact on manufacturers. (GE, While the Joint Comment recognized Further, in manufacturer interviews Public Meeting Transcript, No. 30 at p. that these numbers will likely begin to conducted for this NOPR, DOE learned 192) National Electrical Manufacturers decrease over time with the increased that most manufacturers were not Association (NEMA) noted that for prevalence of light-emitting diode (LED) planning to introduce any additional certain GSFL product classes, Office of alternatives, they noted that IRLs and covered products to market. Therefore, Hearing and Appeals (OHA) issued GSFLs will still likely command a DOE believes that the revised schedule waivers providing a stay of enforcement significant portion of the lighting market for this GSFL and IRL rulemaking has for many manufacturers due to the for decades to come, as a perceived allowed the preliminary analysis and limited availability of rare earth cheaper alternative to LEDs. Due to this NOPR analysis to be conducted so as to phosphors. NEMA pointed out that as a and the findings of the preliminary have adequately captured the impacts of result, the July 2012 standards still have analysis that this rulemaking offers the the July 2012 standards for these not been fully implemented. (Philips, potential for significant, cost-effective products. Any additional data received Public Meeting Transcript, No. 30 at pp. savings for U.S. consumers and will be considered in the development 27–28; NEMA, No. 36 at p. 1) Therefore, businesses, the Joint Comment urged of any final rule. NEMA stated that the market has not DOE to place this rulemaking’s V. Issues Affecting Scope fully shifted to reflect the impacts of the completion as a high priority. (Joint July 2012 standards and there is little to Comment, No. 35 at p. 2) A. Clarifications of General Service no accurate information available DOE is obligated to conduct this Fluorescent Lamp Definition regarding future market shares and second review of GSFL and IRL technology capability. Hence, NEMA The scope of this rulemaking for standards. EPCA required DOE to GSFLs is defined by the terms concluded that as it is too soon after the initiate the first review of standards no 2009 Lamps Rule to set new energy ‘‘fluorescent lamp’’ and ‘‘general service earlier than three years after October 24, fluorescent lamp.’’ 10 CFR 430.2 The conservation standards, DOE and the 1992, and publish a final rule no later Secretary should declare no new definition of general service fluorescent than four years and six months after that lamp includes certain exemptions. DOE standard in this rulemaking. (NEMA, date. 42 U.S.C. 6295(i)(3) The second No. 36 at p. 1) Further, NEMA called has received several questions on the review of standards was to be initiated application of these exemptions. attention to DOE’s newer authority to no earlier than eight years after October review energy conservation standards Therefore, in the preliminary analysis 24, 1992, and the final rule published DOE evaluated each exemption and six years after a final rule is published. no later than nine years and six months NEMA found that this review will determined that the following after that date. 42 U.S.C. 6295(i)(4) DOE exemption categories could be further provide an opportunity to better assess published the final rule for the first standards for GSFLs and IRLs. (NEMA, clarified: ‘‘impact-resistant fluorescent review of standards in July 2009. DOE lamps,’’ ‘‘reflectorized or aperture No. 36 at pp. 1–2) is conducting this rulemaking to satisfy The California investor-owned lamps,’’ ‘‘fluorescent lamps designed for the EPCA requirement for a second utilities, including Pacific Gas and use in reprographic equipment,’’ and review of the standards. Applying the Electric Company (PG&E), Southern ‘‘lamps primarily designed to produce California Gas Company (SCGC), San schedule DOE developed for the second radiation in the ultra-violet region of the Diego Gas and Electric (SDG&E), and review of standards would result in an spectrum.’’ For these exemption Southern California Edison (SCE), interval of five years between the categories, the terminology was either (hereafter the ‘‘CA IOUs’’) approved of publications of the final rules for the not defined elsewhere or the application the current timeline for this rulemaking. first and second review of standards, of the exemption could be further They commented that because DOE and any final rule for this rulemaking clarified. DOE examined product waited until after the July 2012 would be published in 2014. literature and industry reference sources To address comments that product standards required compliance before to determine language that would availability, product pricing, and completing the preliminary analysis and further explain these exemptions. DOE investment decisions in response to the due to the amount of time before determined that the exemptions should July 2012 standards would not be standards promulgated by this be clarified as follows: rulemaking would require compliance, finalized within the proposed Impact-resistant fluorescent lamp now is the correct time to proceed with scheduled, DOE delayed the publication means a lamp that: the second cycle of energy conservation of the preliminary analysis to update its a. Has a coating or equivalent standards for these products. (CA IOUs, product databases and assessments technology that is compliant with NSF/ ANSI 51 (incorporated by reference; see Public Meeting Transcript, No. 30 at pp. 13 U.S. Department of Energy. 2010 U.S. Lighting § 430.3) and designed to contain the 30–31) Market Characterization. January 2012. Available at The Joint Comment emphasized the http://apps1.eere.energy.gov/buildings/ glass if the glass envelope of the lamp significance of this rulemaking as a publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf. is broken; and

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b. Is designated and marketed for the negative effect on the lamps’ efficacy Hence, DOE is not proposing any further intended application, with: and not intended to be exempt from clarification for the exemption category i. The designation on the lamp standards. The CA IOUs stated their of fluorescent lamps designed for cold packaging; and understanding that the exemption for temperature applications. ii. Marketing materials that identify cold temperature lamps has been DOE did not receive any further the lamp as being impact-resistant, preserved to accommodate uncommon comment on definitions considered in shatter-resistant, shatter-proof, or lamps designed to be used outdoors in the preliminary analysis. In this NOPR, shatter-protected. extreme, sub-freezing temperatures that DOE is also considering providing a Reflectorized or aperture lamp means cannot meet the efficacy requirements definition for 700 series fluorescent a fluorescent lamp that contains an established for GSFLs. (CA IOUs, No. 32 lamps. OHA has granted several inner reflective coating on the bulb to at p. 12) manufacturers waivers from standards direct light. The Northwest Energy Efficiency for their 700 series T8 products. (See Fluorescent lamp designed for use in Alliance (NEEA) and Northwest Power section VI.D.2.a for further discussion reprographic equipment means a and Conservation Council (NPCC) regarding OHA waivers.) A definition fluorescent lamp intended for use in agreed with the CA IOUs and found the for 700 series lamps would provide equipment used to reproduce, reprint, descriptor ‘‘designed for cold clarification regarding these lamp types. or copy graphic material. temperature applications’’ to be too The term ‘‘700 series’’ is widely used Lamps primarily designed to produce vague to adequately differentiate in industry when referring to radiation in the ultra-violet region of the between products that are covered fluorescent lamps with a CRI in the spectrum mean fluorescent lamps that currently and those that have design range of 70 to 79. The Illuminating primarily emit light in the portion of the features that make it impossible for Engineering Society of North America electromagnetic spectrum where light them to meet the standards. NEEA and (IESNA) Lighting Handbook 14 presents has a wavelength between 10 and 400 NPCC commented that this lack of fluorescent lamp nomenclature and nanometers. clarity seems to create a significant states that color is represented by a In the preliminary analysis, DOE also loophole. (NEEA and NPCC, No. 34 at three digit number (i.e., 735 or 835) considered clarifications of the terms p. 3) In addition to clearly defining the beginning with the first digit of the ‘‘designed’’ and ‘‘marketed’’ as applied exempt cold temperature lamps, the CA lamp’s CRI (i.e., 7 or 8) and followed by to definitions of lighting products IOUs asked DOE to revisit the market the first two digits of the lamp’s covered under DOE standards. These share and performance of these lamps to correlated color temperature (CCT) (e.g., terms are generally used to ensure that confirm that they do in fact justify an 30, 35, 41). DOE explained this exemptions from applicable standards exemption. (CA IOUs, No. 32 at p. 12) nomenclature in chapter 3 of the 2009 apply only to lamps used in certain The exemption for cold temperature Lamps Rule TSD,15 stating that typically intended applications and/or functions. lamps is stated in the CFR as lamps with a CRI in the 60s use only Therefore, DOE considered the terms ‘‘Fluorescent lamps specifically less efficient halophosphors, while ‘‘designed,’’ ‘‘designated,’’ designed for cold temperature lamps with a CRI in the 70s (700 series ‘‘designation,’’ ‘‘designated and applications.’’ Further the CFR provides phosphor) and in the 80s (800 series marketed,’’ and ‘‘designed and a definition for ‘‘cold temperature phosphor) use more efficient rare earth marketed,’’ for covered lighting fluorescent lamp’’ stated as follows: phosphors. The DOE test procedure at products to mean that manufacturers Cold temperature fluorescent lamp 10 CFR part 430, subpart B, appendix R explicitly state the intended application means a fluorescent lamp specifically requires CRI to be measured and of the lamp in a publicly available designed to start at ¥20 °F when used reported to demonstrate compliance document (e.g., product literature, with a ballast conforming to the with standards. Thus, the measured CRI catalogs, packaging labels, and labels on requirements of American National of a lamp is used to determine if the the product itself). Standards Institute (ANSI) C78.81 lamp qualifies as a 700 series lamp. NEMA agreed with the proposed (incorporated by reference; see § 430.3) Hence DOE is proposing to define 700 clarifications to definitions for GSFLs. and ANSI C78.901 (incorporated by series fluorescent lamps to mean a (NEMA, Public Meeting Transcript, No. reference; see § 430.3), and is expressly fluorescent lamp with a CRI that is in 30 at p. 45; NEMA, No. 36 at pp. 4–5) designated as a cold temperature lamp the range of 70 to 79. NEMA noted that the definitions have both in markings on the lamp and in In this NOPR, DOE is proposing the been in use since the early 1990s and marketing materials, including catalogs, definitions as previously specified in are well understood within the industry; sales literature, and promotional this section and in the preliminary the additional clarification suggested is material. 10 CFR 430.2 analysis for ‘‘impact-resistant in line with current industry practice. Cold weather starting is accomplished fluorescent lamps,’’ ‘‘reflectorized or NEMA stated that no further definitions through both the lamp and ballast aperture lamps,’’ ‘‘fluorescent lamps are required beyond this clarification. design. Product literature indicates that designed for use in reprographic (NEMA, No. 36 at pp. 4–5) cold temperature fluorescent lamps equipment,’’ and ‘‘lamps primarily The CA IOUs agreed that DOE should paired with the appropriate ballast can designed to produce radiation in the clearly define the lamp types exempted be started at temperatures as low as ultra-violet region of the spectrum.’’ from standards. Specifically, the CA -20 °F. Therefore, the existing DOE is also proposing a definition of IOUs recommended further clarifying definition, which includes the specific ‘‘designed and marketed.’’ This the definition for fluorescent lamps starting temperature and the definition is intended to apply to the ‘‘designed for cold temperature requirement of being marketed and use of these and similar terms (i.e., applications.’’ (CA IOUs, Public Meeting designed for cold temperature designated or labeled) in any Transcript, No. 30 at pp. 31–32; CA applications, is a sufficient description IOUs, No. 32 at p. 12) The CA IOUs of fluorescent lamps designed to be 14 DiLaura, D. L., K. W. Houser, R. G. Mistrick, expressed concern that that many operated in cold temperatures. and G. R. Steffy. Lighting Handbook: Reference and Application, 10th Edition. New York: IESNA, 2011. common GSFLs are currently being Additionally, product offerings of cold 15 The 2009 Lamps Rule TSD is available at designed with amalgam to be operated temperature fluorescent lamps remain www.regulations.gov/#!documentDetail;D=EERE– in lower temperatures, but without a limited, indicating their specialty use. 2006–STD–0131–0147.

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grammatical form or combination. In TWh of electricity in 2010. Interviews lamp type and the energy savings addition, DOE is proposing a definition with manufacturers also confirmed the potential of standards for the lamp type. for ‘‘700 series fluorescent lamp.’’ low market share of these lamp types. In the NOPR, DOE also evaluated Therefore, DOE tentatively concluded market share relative to the entire B. General Service Fluorescent Lamp that coverage should not be expanded to fluorescent lamp market. Based on the Scope of Coverage non-linear fluorescent lamps as 2010 LMC, T8 MBP lamps less than 4 1. Additional General Service standards would not likely result in feet comprised 0.7 percent of the Fluorescent Lamp Types significant energy savings. fluorescent lamp market versus 0.2 For linear lengths not already covered In this rulemaking, DOE evaluates percent of the entire lighting market. by standards, DOE focused on linear energy efficiency standards for Therefore, the evaluation of these lamps medium bipin (MBP) fluorescent lamps relative to the fluorescent lamp market additional GSFLs beyond those for ranging from 1 to 6 feet, with the also indicates that 2-foot MBP linear which standards have already been exception of the 4-foot MBP, which is lamps have a very low market share. established. (42 U.S.C. 6295(i)(5)) Any already subject to standards. DOE’s DOE excluded T12 lamps from this additional GSFLs considered for analysis showed that 5- and 6-foot analysis to reflect future market trends. coverage under standards must meet the lengths comprise a very low percentage The 2011 final rule amending energy definition of a fluorescent lamp in 42 of the linear MBP product offerings. For conservation standards for fluorescent U.S.C. 6291(30)(A); satisfy the majority the T8 16 MBP lamps with lengths less lamp ballasts (hereafter the ‘‘2011 of fluorescent lighting applications; not than 4 feet, according to the 2010 LMC, Ballast Rule’’), which will require be within the exclusions specified in 42 these lamps comprised about 0.2 compliance on November 14, 2014, set U.S.C. 6291(30)(B); and not already be percent of all installed lighting and standards difficult for T12 ballasts to subject to energy conservation consumed 1 TWh of electricity in 2010. meet.17 76 FR 70548 (Nov. 14, 2011). standards. 73 FR 13620, 13629 (March Feedback from manufacturers also Therefore, the market will likely shift 13, 2008). For each additional GSFLs indicated a low market share for these away from T12 lamps. Additionally, that meets these criteria, DOE then lamp types. Therefore, DOE tentatively historical shipments of most T12 lamps assesses whether standards could result concluded that coverage should not be have been decreasing steadily and in significant energy savings and are expanded to linear fluorescents of manufacturer feedback from interviews technologically feasible and lengths not covered by standards as suggests that this trend will continue. economically justified. Standards for standards would not likely result in Therefore, DOE focused on T8 lamps any applicable additional GSFLs are significant energy savings. when evaluating the energy savings of adopted based on the same criteria used DOE received several comments on its additional GSFL types to include under to set new or amended standards for assessment not to extend coverage to coverage of standards. products pursuant to 42 U.S.C. 6295(o). linear fluorescent lamps of lengths not The CA IOUs also asserted that in the Using these criteria, DOE evaluated already covered. In particular, several 2010 LMC, T8 and T12 lamps less than whether the following GSFL types stakeholders asserted that the 2-foot 4 feet have GSFL market shares very warranted coverage under standards: (1) linear fluorescent lamps comprised a similar to the market shares for three pin base compact fluorescent lamps market share that warranted coverage other product types currently subject to (CFLs); (2) non-linear fluorescent lamps under standards. The CA IOUs urged DOE standards: T8 lamps greater than 4 (e.g., circline); and (3) fluorescent lamps DOE to reassess the 2-foot linear feet (1.4 percent of the linear fluorescent with alternate lengths (e.g., 2-, 3-, and 5- fluorescent lamp market share and market), T8 U-shaped lamps (2 percent foot lamps). recommended that they be included in of the linear fluorescent market), and For pin base CFLs, DOE determined the scope of coverage of this T12 U-shaped lamps (0.5 percent of the that these lamp types fall within the rulemaking. (CA IOUs, Public Meeting linear fluorescent market). (CA IOUs, definition of ‘‘general service lamps,’’ Transcript, No. 30 at pp. 32–33; CA No. 32 at pp. 11–12; NEEA and NPCC, which excludes GSFLs. (42 U.S.C. IOUs, No. 32 at pp. 11–12) NEEA and No. 34 at pp. 2–3) 6291(30)(BB)) Therefore, these lamp NPCC advised that 2-foot linear The standards for GSFL types cited by types cannot be considered under this fluorescent lamps be included under the CA IOUs, specifically, the 2-foot U- rulemaking. DOE is evaluating these scope of coverage and in their own shaped lamps, 8-foot SP slimline lamps, lamp types in the rulemaking for general product class, if appropriate. (NEEA and and 8-foot recessed double contact service lamps. Documents related to this NPCC, No. 34 at pp. 2–3) Specifically, (RDC) HO lamps, were established in rulemaking can be found on the CA IOUs asserted that DOE should EPAct 1992. (42 U.S.C. 6295(i)(1)) As regulations.gov, docket number EERE– have considered the proportion of GSFL noted, for this rulemaking, in 2013–BT–STD–0051. determining whether additional GSFL market share that these lamps represent For non-linear fluorescent lamps, types should be covered under and also included T12 lamps in its DOE considered circline fluorescent standards pursuant to 42 U.S.C. assessment, as these lamps would be lamps, the primary shape not currently 6295(i)(5) DOE considers several covered by standards for 2-foot linear covered under standards. DOE used the criteria. In particular, DOE assesses lamps. (CA IOUs, No. 32 at pp. 11–12) miscellaneous category of fluorescent In assessing whether additional GSFL whether a potential standard for an lamps reported by the 2010 LMC to types should be included under additional GSFL type would result in determine market share and energy coverage of standards in the preliminary significant energy savings. Therefore, DOE examined parameters such as consumption of circline fluorescent analysis, DOE evaluated the market market share and energy consumption lamps. This category included share and energy consumption of the of each lamp type under consideration fluorescent lamps other than the T5, T8, lamp type relative to the entire lighting relative to the fluorescent lighting T12 linear lamps, and T8 and T12 U- market. DOE’s analysis provided a shaped lamps, and is therefore mainly comprehensive representation of the comprised of circline lamps and lamps 17 The full text and all related documents of the with unknown characteristics. The 2010 2011 Ballast Rule can be found on regulations.gov, 16 The majority of T12 MBP lamps with lengths docket number EERE–2007–BT–STD–0016 at LMC reported this category made up 2.1 less than 4 feet do not comply with the July 2012 www.regulations.gov/#!docketDetail;D=EERE-2007- percent of lighting and consumed 4 standards. BT-STD-0016.

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market. DOE believes that this 12; NEEA and NPCC, No. 34 at pp. 2– that will either stay the same or decline. evaluation of each potential additional 3) Further, manufacturers noted in GSFL provides the most useful NEMA, however, stated that the 2010 interviews that the 2-foot linear lamps indication of whether significant energy LMC showed a low market share 19 for are generally used for kitchens, savings could be gained from regulation these products, which does not justify bathrooms, vanity lighting, hospitality of the lamp type. standards for these lamps. (NEMA, No. applications, cabinets, and to round out Stakeholders also cited data sources 36 at p. 4) Edison Electric Institute (EEI) edges of ceilings in commercial spaces. in addition to the 2010 LMC indicating stated its belief that 2-foot linear lamps Given the above, DOE finds that 2-foot linear lamps should be were mainly installed in task lighting insufficient evidence to indicate that the included under coverage of standards. applications. (EEI, Public Meeting market share or energy consumption of The CA IOUs asserted that an anecdotal Transcript, No. 30 at p. 34) GE advised 2-foot linear fluorescent lamps would survey from their lighting audit teams that 2-foot linear lamps should not be result in significant energy savings if suggest 2-foot linear lamps may be 5 to included in the scope of this DOE established standards for these 10 percent of lamps installed in the CA rulemaking. While installing these lamps. DOE is not proposing standards for any additional GSFL types that are IOUs’ service territory, which is higher lamps may be customary in California, not currently covered. than suggested by the 2010 LMC. The GE stated that they are not very common CA IOUs also reported that the vast across the nation. Further, GE 2. Additional General Service majority of commercial buildings in commented that DOE had received Fluorescent Lamp Wattages California have some two-by-two shipment data in preliminary manufacturer interviews that showed DOE specifies a certain minimum fixtures, and many of these have been wattage for each lamp type included in retrofitted from U-shaped to 2-foot the sales of 2-foot straight lamps to be significantly less than the sales of 4-foot the definition of ‘‘fluorescent lamp.’’ In linear lamps within the last several this rulemaking, DOE also evaluates lamps. (GE, Public Meeting Transcript, years, indicating a growing trend toward whether coverage should be extended to No. 30 at pp. 35–36) ASAP requested 2-foot linear lamps over U-shaped additional wattages of these lamp types. DOE make the shipment data publicly lamps. (CA IOUs, Public Meeting (42 U.S.C. 6295(i)(5)) As part of this available so stakeholders could Transcript, No. 30 at pp. 32–34; CA assessment, DOE reviewed product determine the significance. (ASAP, IOUs, No. 32 at pp. 11–12) NEEA and offerings for covered lamp types to Public Meeting Transcript, No. 30 at pp. NPCC stated that they would submit determine if any new, lower wattage 36–39) field data to DOE and asserted that products had been introduced since DOE did not receive shipment data currently available data indicates 2-foot publication of the 2009 Lamps Rule. specifically for 2-foot linear lamps and linear GSFLs make up a notably larger DOE found the following reduced based its assessment of market share fraction of the market than the wattage lamps not covered under and energy consumption provided in preliminary analysis suggests. (NEEA standards: 49 W, 50 W, 51 W 8-foot SP the 2010 LMC report and feedback and NPCC, No. 34 at pp. 2–3) slimline, 25 W 4-foot T5 MiniBP received in manufacturer interviews. The CA IOUs and NEEA and NPCC standard output (SO), and 44 W, 47 W The anecdotal survey and the Vermont referred to a Navigant Consulting, Inc. 4-foot T5 MiniBP HO lamps. DOE study cited by the CA IOUs are focused (Navigant) study published in October currently covers 8-foot SP slimline on very specific areas of the nation, 2012 that surveyed existing commercial lamps with wattages of 52 W or more; while the 2010 LMC is the most recent and industrial building stock in 4-foot T5 MiniBP SO lamps with assessment of installed stock and energy Vermont, the 2011 Vermont Market wattages of 26 W or more; and 4-foot T5 use of fluorescent lighting at the Characterization and Assessment MiniBP HO lamps with wattages of 49 national level. The Vermont study Study.18 The raw data from the Navigant W or more. Therefore, in the collected primary data through on-site study, obtained in May 2013 from the preliminary analysis, DOE considered visits from a random selection of 120 state of Vermont by NEEP, shows that of extending coverage to the following commercial and industrial buildings in more than 136,000 lamps surveyed, 2- GSFLs: specific regions in Vermont. Therefore, foot lamps represented 6.3 percent of • 8-foot SP slimline lamps with DOE found the 2010 LMC provided a installed fluorescent lamps. This wattages ≥49 W and <52 W; more comprehensive basis for its included 3.6 percent of high • 4-foot T5 MiniBP SO lamps with assessment. A comparison of the performance T8s, 9.3 percent of wattages ≥25 W and <26 W; and installed stock provided in the 2000 • standard efficiency T8s, 3.9 percent of 4-foot T5 MiniBP HO lamps with LMC report 20 and the 2010 LMC report ≥ T12s, and 5.2 percent of T5s. Behind 4- wattages 44 W and <49 W. shows that installed stock for both T8 foot lamps, 2-foot lamps were by far the These reduced wattage lamps are and T12 lamps less than 4 feet has most common lamp length in these generally more efficacious than their declined by about 50 percent over that sectors. The CA IOUs stated that 6.3 full wattage counterparts and offer the 10-year period. DOE also received percent of fluorescent lamp sales potential for increased energy savings. feedback from manufacturers in represent a significant amount of energy Philips commented that if a product interviews stating that 2-foot linear and, as explained in previous comments is already highly efficacious, DOE does lamps, both in the MBP and MiniBP submitted by the CA IOUs, 2-foot lamps not need to consider standards for the categories, comprise a low market share are available in a wide range of product. (Philips, Public Meeting efficacies. (CA IOUs, No. 32 at pp. 11– Transcript, No. 30 at pp. 44–45) 19 DOE’s assessment indicated that the T8 MBP The emergence of these new reduced lamps less than 4 feet comprised 0.2 percent of the 18 Navigant Consulting, Inc. 2011 Vermont Market entire lighting market. NEMA’s written comment wattage lamps on the market since the Characterization and Assessment Study. October had incorrectly quoted this number as 0.02 percent. 2009 Lamps Rule and the number of 2012. Available at http://publicservice.vermont.gov/ 20 U.S. Department of Energy. U.S. Lighting product offerings indicate that there is sites/psd/files/Topics/Energy_Efficiency/ Market Characterization Volume I: National significant consumer demand for these EVT_Performance_Eval/ Lighting Inventory and Energy Consumption VT%20CI%20Existing%20Buildings%20Market Estimate. September 2002. Available at http:// lamps. Further, because reduced %20Assessment%20and%20Characterization apps1.eere.energy.gov/buildings/publications/pdfs/ wattage lamps are often incentivized by _2012-10-6_FINAL.pdf ssl/lmc_vol1_final.pdf. utilities and promoted as an easy

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pathway to energy savings, they are DOE received several comments on this small portion of the market and are likely to increase in market share. DOE’s lower limit on wattage for IRLs. EEI typically designed for specialty uses, review of product catalogs indicated reported that highly efficacious 39 W and therefore, do not represent that lamps with these wattages generally halogen IRLs capable of replacing less significant energy savings. efficacious 60 W IRLs are on the market. have a range of efficacies. The lower D. Summary of Scope of Coverage wattages of these lamps and their (EEI, Public Meeting Transcript, No. 30 potential to achieve higher efficacies at pp. 24–25) The CA IOUs considered In conclusion, in this rulemaking DOE indicate that including these wattages the presence of commercially available is proposing extending the scope of under energy conservation standards 39 W lamps to suggest that DOE should coverage for GSFLs to certain wattages have the potential to realize significant extend the IRL wattage range covered. but not additional GSFL types. Further, energy savings. (CA IOUs, Public Meeting Transcript, DOE is proposing clarifying certain NEMA agreed with expanding the No. 30 at p. 33) EEI also noted that the exemptions noted under the definition GSFL wattages covered by this 39 W IRLs are close to covered lamps in of ‘‘general service fluorescent lamp.’’ rulemaking, but cautioned DOE that efficacy and serve as replacements for DOE is not considering IRLs less than 40 reduced wattage GSFLs are often IRLs of higher wattages, possibly W or greater than 205 W and is also not ‘‘energy saver’’ models. These lamps do increasing efficacy by 30 to 40 percent. considering the following IRL types: (1) not have the same performance as full (EEI, Public Meeting Transcript, No. 30 Lamps rated 50 W or less that are ER30, wattage GSFLs. Specifically, NEMA at pp. 34–35) The CA IOUs responded BR30, BR40, or ER40; (2) lamps rated 65 stated that reduced wattage GSFLs have that in the California market there is a W that are BR30, BR40, or ER40 lamps; difficulty operating in low-temperature wide range of efficacy for the 39 W and (3) R20 IRLs rated 45 W or less. applications and do not have full products. (CA IOUs, Public Meeting VI. Methodology and Discussion dimming functionality, a performance Transcript, No. 30 at p. 35) In the preliminary phase of this feature that is highly desired GE stated that EPAct 1992 gave 40 W rulemaking, DOE conducted a market considering the proliferation of as the lower wattage limit for IRLs and and technology assessment, screening dimming systems. (NEMA, Public that this limit is appropriate. GE analysis, engineering analysis, product Meeting Transcript, No. 30 at pp. 23–24; asserted that there was no need to cover price determination, energy-use NEMA, No. 36 at p. 4) lower wattage IRLs as they use less characterization, LCC and PBP analyses, DOE acknowledges there are certain energy, and a market shift to them shipments analysis and NIA, as well as issues related to dimming associated would still fulfill the purpose of this a preliminary MIA. These analyses were with ‘‘energy saver’’ or reduced wattage rulemaking. (GE, Public Meeting then updated and revised as appropriate lamps. Therefore, in this rulemaking, Transcript, No. 30 at p. 36) ASAP based on feedback received for this DOE has ensured that full wattage lamps questioned whether DOE had the NOPR. Further, in this NOPR DOE can achieve the levels proposed for authority to cover lower wattages if the conducted an LCC subgroup analysis, a GSFLs. See section VI.D.2.g for further 40 W limit was a statutorily defined complete MIA, a utility impact details on this issue. scope. (ASAP, Public Meeting Transcript, No. 30 at p. 39) NEMA assessment, an employment impact C. Incandescent Reflector Lamp Scope asserted that because the CFR stipulates assessment, an emissions analysis, a of Coverage coverage for 40 W IRLs and above, DOE determination of monetization of reduced emissions from proposed 1. Incandescent Reflector Lamp Types does not have the authority to expand the scope to lower wattages. (NEMA, standard levels, and an RIA. In this rulemaking, DOE does not No. 36 at p. 2) DOE used three spreadsheet tools to consider the following IRL types: (1) NEEA noted that if the 40 W limit was estimate the impact of standards Lamps rated 50 W or less that are ER30, statutory, it is doubtful DOE would proposed in this NOPR. The first BR30, BR40, or ER40; (2) lamps rated 65 change it. However, NEEA found that a spreadsheet calculates LCCs and W that are BR30, BR40, or ER40 lamps; lower wattage limit is an increasingly payback periods of potential new energy and (3) R20 IRLs rated 45 W or less. (42 less useful way to describe coverage as conservation standards. The second U.S.C. 6295(i)(C)) These IRLs are the technologies shift. Additionally, NEEA provides shipments forecasts and then subject of a separate rulemaking on noted that a wattage limit was not an calculates NES and NPV impacts of which further information can be found appropriate qualifier for products potential new energy conservation on regulations.gov under docket ID subject to a lm/W standard that drives standards. The Department also EERE–2010–BT–STD–0005 at products to use fewer watts to deliver a assessed manufacturer impacts, largely www.regulations.gov/ certain lumen output, such as a 20 W through use of the Government #!docketDetail;D=EERE-2010-BT-STD- IRL that has the same lumen output as Regulatory Impact Model (GRIM). 0005. DOE has suspended activity on a 60 W IRL. NEEA commented that it DOE used a version of EIA’s National this rulemaking as a result of section had seen a similar shift occur in the Energy Modeling System (NEMS) for the 315 of Public Law (Pub. L.) 112–74 (Dec. market for street lighting. (NEEA, Public utility and environmental analyses. The 23, 2011), which prohibits DOE from Meeting Transcript, No. 30 at pp. 43–44) NEMS model simulates the energy using appropriated funds to implement As described by commenters, the 40 sector of the U.S. economy. EIA uses or enforce standards for ER, BR, and W limit is included in the EPCA NEMS to prepare its AEO, a widely bulged parabolic reflector IRLs. definition of IRLs. (42 U.S.C. known baseline energy forecast for the 6291(30)(C), (C)(ii), and (F)) Therefore, United States. The version of NEMS 2. Incandescent Reflector Lamp proposed standards in this notice apply used for appliance standards analysis is Wattages only to covered IRLs 40 W or higher. called NEMS–BT 21, and is based on the In this rulemaking, DOE also does not Additionally, while the definition of consider IRLs with wattages lower than IRLs does not provide an upper wattage 21 The EIA approves the use of the name ‘‘NEMS’’ 40. EPCA defines an incandescent limit, DOE did not assess covered IRLs to describe only an AEO version of the model without any modification to code or data. Because reflector lamp as a lamp that ‘‘has a higher than 205 W in this proposed rule. the present analysis entails some minor code rated wattage that is 40 watts or higher.’’ DOE research indicated that wattages modifications and runs the model under various (42 U.S.C. 6291(30)(C), (C)(ii), and (F)) greater than 205 W comprise a very policy scenarios that deviate from AEO

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AEO 2013 version with minor a stay of enforcement from the July 2012 optimum diameters. Further, NEMA and modifications. The NEMS–BT accounts standards. (NEMA, No. 36 at p. 6) GE stated that the market has already for the interactions between the various As explained in II.A, EPCA directs shifted to the most efficient diameters. energy supply and demand sectors and DOE to complete a rulemaking that (NEMA, Public Meeting Transcript, No. the economy as a whole. examines whether current GSFL and 30 at pp. 73; NEMA, No. 36 at p. 5; GE, NEEA and NPCC stated that analyses IRL standards should be amended and Public Meeting Transcript, No. 30 at pp. presented in the preliminary analysis if so, amend them as appropriate based 71–72) While NEMA did not believe phase need further development before on its analysis. Further, in any higher efficiency diameter should be stakeholders will be able to comment in rulemaking DOE must adopt standard retained as a technology option, NEMA depth. NEEA and NPCC also offered to levels that achieve the maximum energy and Philips requested additional provide DOE field data from 2012–2013 savings that is technologically feasible clarifying information about DOE’s on lamp and fixture types from their (see chapter 3 of the NOPR TSD) and underlying analysis of this option. Residential Building Stock Assessment economically justified (see chapters 8 (NEMA, No. 36 at p. 5; Philips, Public (RBSA) and the survey data from their and 12 of the NOPR TSD). Additionally, Meeting Transcript, No. 30 at p. 70) Commercial Building Stock Assessment as noted previously, DOE understands In small diameter lamps, an increase (CBSA). (NEEA and NPCC, No. 34 at p. that OHA has granted numerous in diameter decreases the number of 6) NEEA and NPCC strongly support the manufacturers 2-year waivers from electrons and mercury ion comments provided by the CA IOUs for standards for their 700 series T8 recombination at the bulb wall, this rulemaking. (NEEA and NPCC, No. products that expire in 2014. Because increasing ultraviolet (UV) output and 34 at p. 2) standards from this rulemaking would lamp efficacy. In large diameter lamps, In the preliminary analyses, DOE become effective in 2017, DOE conducts this recombination may already be assessed the products that are the its analysis assuming that the waivers minimal and a further enlargement in subject of this rulemaking, as well as the will not be in place. diameter causes a greater imprisonment achievable levels of efficiency and their NEMA also added that whether there of radiation within the lamp, decreasing impacts. As noted, DOE has updated are any technological innovations that light output and efficacy. Therefore, these analyses with more recent data have happened since the 2009 Lamps DOE understands this technology option and, where appropriate, made Rule is a valid point of discussion, but should be applied only in cases where adjustments based on comments each potential technology would have to there is a potential to optimize the lamp received from stakeholders in the be given the same level of rigor diameter in order to achieve higher preliminary analysis phase. DOE will regarding whether it is a feasible lamp efficacy gain. Based on DOE’s also consider any additional data pathway or not. (NEMA, Public Meeting assessment there are less efficacious submitted by commenters in response to Transcript, No. 30 at pp. 178–179) DOE lamps on the market that can be the NOPR. examines the latest industry literature improved by using a higher efficiency and patents, and receives feedback from diameter. For example, standards- A. Market and Technology Assessment manufacturers to develop viable compliant T12 diameter product In the energy conservation standards technology options that can increase the offerings remain in the 4-foot MBP and rulemaking process, DOE conducts a efficacy of GSFLs and IRLs. The 8-foot SP slimline product classes. market and technology assessment to identified technology options are then Therefore, DOE continues to consider provide an overall picture of the market subjected to rigorous screening criteria higher efficiency lamp diameter as a for products concerned. Based primarily before they can be considered as design technology option to increase the on publicly available information, the options in the engineering analysis (see efficacy of GSFLs. analysis provides both qualitative and section VI.B). For further details on the Higher Efficiency Lamp Fill Gas quantitative information. The market technology options and the screening Composition and technology assessment includes the process, see, respectively, chapters 3 major manufacturers, product classes, and 4 of the NOPR TSD. Higher efficiency lamp fill gas retail market trends, shipments of composition was another technology covered products, regulatory and non- 1. General Service Fluorescent Lamp option identified in the preliminary regulatory programs, and technologies Technology Options analysis. Lamp fill gases in fluorescent that could be used to improve the DOE received comments specific to lamps increase mobility of mercury ions efficacy of GSFLs and IRLs. DOE the GSFL technology options put forth and electrons, facilitating recombination identified several technology options in the preliminary analysis. Specifically, and resulting in increased UV output after conducting this assessment for the stakeholders provided feedback on and higher lamp efficacy. Gases with preliminary analysis. higher efficiency lamp diameters, higher lower molecular weight, such as argon, DOE received a general comment from efficiency lamp fill gas composition, generally result in higher lamp efficacy. NEMA on the market and technology and higher efficiency phosphors. Full wattage lamps generally use argon assessment questioning why a gas. Reduced wattage lamps use a Higher Efficiency Lamp Diameters rulemaking is justified given the lack of mixture of krypton and argon. Krypton, technological innovations and changes DOE considered more efficient lamp while a higher molecular weight gas, since the 2009 Lamps Rule, the steep diameters as one of the technology lowers the wattage of the lamp, thereby decline in GSFL and IRL sales expected, options to increase GSFL efficacy in the resulting in a higher lamp efficacy. as shown in DOE’s projections, and the preliminary analysis. This option is NEMA stated that GSFLs are already waivers still providing certain products considered as there is an optimum optimized for the tradeoff of argon and design diameter for a specific krypton mixes and further efficacy gains assumptions, the name ‘‘NEMS–BT’’ refers to the fluorescent lamp type that can increase are not possible using krypton. (NEMA, model as used here. (BT stands for DOE’s Building lamp efficacy. No. 36 at p. 14) Technologies Program.) For more information on NEMA stated that strictly speaking Based on DOE’s research and NEMS, refer to The National Energy Modeling the reduction of lamp diameter does not feedback from manufacturers in System: An Overview, DOE/EIA–0581 (2009), available at: http://www.eia.gov/oiaf/aeo/overview/ necessarily increase efficacy and that T5 interviews, the type and ratios of fill index.html. and T8 lamps are already at their gases remain a mechanism to increase

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lamp efficacy. Because lamps are TABLE VI.1—GSFL TECHNOLOGY OP- manufacturers do not know how to present on the market at more than one TIONS IN THE NOPR ANALYSIS— place filaments any more precisely than level of efficacy, DOE believes lamp fill Continued they are now, although there is gas is one option that can be utilized to manufacturing variation. (Philips, improve the efficacy of less efficacious Name of tech- Public Meeting Transcript, No. 30 at pp. products. Therefore, DOE continues to nology option Description 82–83) consider higher efficiency lamp fill gas DOE acknowledges that it is as a means to improve the efficacy of Glass Coatings Coatings on inside of bulb theoretically well understood where the fluorescent lamps covered under this enable the phosphors to filament should be placed to achieve absorb more UV energy, rulemaking. higher efficacy in IRLs. Additionally, so that they emit more the above comments and feedback Higher Efficiency Phosphors visible light. Higher Effi- Optimal lamp diameters im- during manufacturer interviews indicate DOE also identified higher efficiency ciency Lamp prove lamp efficacy. that lamps are being designed so that the filament is placed in the most phosphors as an option for increasing Diameter. optimal position. Therefore, because the efficacy in GSFLs. The main purpose of Multi-Photon Phosphors emit more than Phosphors. one visible photon for optimal filament placement design has phosphor in a fluorescent lamp is to each incident UV photon. been identified and is being applied in absorb the UV radiation and reemit it as all commercially available products, visible radiation. In particular, the lamp 2. Incandescent Reflector Lamp DOE proposes to not consider efficient efficacy can be improved in this manner Technology Options filament placement as a technology by using triband phosphors containing option. rare earth elements, which can greatly DOE received comments specific to increase UV absorption and emission of the IRL technology options put forth by Higher Efficiency Inert Fill Gas radiation in the visible spectrum DOE in the preliminary analysis. DOE presented high efficiency inert relative to other phosphors. In response Specifically, stakeholders provided fill gas as another technology option to to this technology option, NEMA stated feedback on efficient filament increase IRL efficacy in the preliminary that GSFLs are already optimized for placement, higher efficiency inert fill analysis. Fill gases such as krypton and rare earth phosphors. (NEMA, No. 36 at gas, and integrally ballasted low voltage xenon have low thermal conductivity p. 14) lamps. that decreases the convective cooling of Based on DOE’s research and Efficient Filament Placement the filament, allowing for higher feedback from manufacturers in temperature operation and therefore interviews, the blend, weight, and Efficient filament placement is one of higher efficacy. These gas molecules are thickness of rare earth phosphors in the technology options presented in the larger relative to other gases, and can fluorescent lamps is a key element in preliminary analysis that can increase more effectively slow down the increasing the lamp efficacy. Because the efficacy of IRLs. An optimally evaporation of tungsten and thereby lamps are present on the market at more placed filament allows a portion of the extend the life of the lamp. Xenon, than one level of efficacy, DOE believes spectrum emitted by the filament to having even lower heat conductivity higher efficiency phosphor is one option focus back onto it. The additional heat and larger mass than krypton, can more that can be utilized to improve the provided to the filament increases the drastically change efficacy and life, but efficacy of less efficacious products. operating temperature and thereby has a higher cost. Most lamps compliant Therefore, DOE continues to consider increases lamp efficacy. with the July 2012 standards use xenon higher efficiency phosphors as a means NEMA disagreed that efficient as a fill gas. to improve the efficacy of fluorescent filament placement should be NEEA and NPCC indicated that xenon lamps covered under this rulemaking. considered a technology option for fill gas should not be considered a improving efficacy. NEMA commented technology option as it is already used Summary of GSFL Technology Options that filament placement determines the in all, or nearly all, halogen-based beam spread of a lamp, which is technologies, including those at the In summary, DOE has developed the considered a performance characteristic, lower end of the efficacy scale. list of technology options shown in not a degree of efficacy. If the filament Comparatively, there is an Table VI.1 to increase efficacy of GSFLs. placement were changed to make a lamp approximately 3 percent drop in more efficacious, it would also change efficacy when using a fill gas like TABLE VI.1—GSFL TECHNOLOGY the beam spread, thereby altering a krypton, and accordingly the market has OPTIONS IN THE NOPR ANALYSIS lamp’s utility. (NEMA, Public Meeting clearly adopted xenon and uses it Transcript, No. 30 at pp. 74–75) almost exclusively. (NEEA and NPCC, Name of tech- Understanding that efficient filament nology option Description No. 34 at p. 2, 5) The CA IOUs also placement refers to the placement of the stated that their research indicated that Highly Improved electrode coatings filament in an infrared (IR) capsule, the most, if not all, commercially available Emissive allow electrons to be more CA IOUs stated that filament placement parabolic aluminized reflector (PAR) Electrode easily removed from elec- impacts the amount of reflected lamps, including those that are lower Coatings. trodes, reducing lamp radiation that hits the filament, which efficacy products or minimally power and increasing in turn impacts the amount of light compliant with the 2009 Lamps Rule, overall efficacy. emitted by the lamp. (CA IOUs, Public are already using xenon as their fill gas. Higher Effi- Fill gas compositions im- Meeting Transcript, No. 30 at p. 81–82) The CA IOUs, therefore, concluded that ciency Lamp prove cathode thermionic GE responded that filaments must be Fill Gas emission or increase mo- additional xenon would not be required Composition. bility of ions and electrons placed as close to the center of IR to meet higher standards. (CA IOUs, No. in the lamp plasma. capsules as possible, and their 32 at pp. 9–10) Higher Effi- Phosphors increase the con- placement has already been optimized. Based on feedback from manufacturer ciency Phos- version of ultraviolet light (GE, Public Meeting Transcript, No. 30 interviews, DOE confirmed that the phors. into visible light. at pp. 82) Philips noted that majority of covered standards-compliant

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IRLs are utilizing xenon. However, DOE voltage and may operate at too high of than or equal to 2.5 inches), DOE also learned that the amount of xenon a temperature for an integral ballast, a applied a 3.5 percent reduction when used in lamp can vary based on several lamp less than 50 W is better suited for scaling efficacy levels from large factors. Because lamps are present on low voltage operation and run at diameter lamps (i.e., all diameters the market at more than one level of temperatures compatible with an greater than 2.5 inches) that could efficacy, higher efficiency inert fill gas integral transformer. Particularly, as utilize a double-ended burner to small is one option that can be utilized to halogen lamps are designed to be more diameter lamps. (For further discussion improve the efficacy of less efficacious efficacious, lower reduced wattage on IRL scaling factor see section VI.D.3.g products. Therefore, DOE continues to products will be more common; for this and chapter 5 of the NOPR TSD.) consider high efficiency inert fill gas as reason, the CA IOUs envisioned Based on further research and a technology option. integrally ballasted low voltage halogen interviews with manufacturers, DOE products to be the predominant design confirmed in the NOPR analysis that a Integrally Ballasted Low Voltage Lamps strategy for very high efficacy halogen key aspect of higher efficiency IRLs is DOE also considered integrally products going forward. (CA IOUs, No. HIR technology. Because the type of ballasted low voltage lamps as a 32 at p. 9) burner utilized is an important technology option in the preliminary In interviews, manufacturers stated component of an HIR lamp, in this analysis. The use of an integral ballast that the use of an integral ballast to NOPR analysis, DOE is considering in an incandescent lamp allows an lower voltage is not a feasible higher efficiency burners as a increase in the efficacy because it technology in higher wattage lamps due technology option to increase IRL converts the line voltage to lower lamp to issues with dissipating heat generated efficacy. Single-ended burners feature a operating voltages, thereby reducing the by the electronic components. lead wire inside of the capsule that lamp wattage. Manufacturers indicated that heat carries current between the filament and NEMA stated that integrally ballasted dissipation becomes a problem at the electrical connection in the base of low voltage lamps are not viable at high wattages ranging from 20 to 35 W. DOE the lamp. The presence of this wire wattages, and the technology is research also indicated that in inside of the capsule prevents a certain expensive and rarely used. Therefore, converting to a lower voltage, current is amount of energy from reaching the NEMA asserted that this technology is increased and greater heat generated capsule wall and being reflected for a niche product, and cannot be from the filament. In higher wattage (recycled) back to the capsule filament. applied across the board. (NEMA, IRLs, the resulting increased However, double-ended burners have a Public Meeting Transcript, No. 30 at p. temperature can be damaging to the lead wire outside of the capsule that 74–75; NEMA, No. 36 at p. 7) voltage conversion circuitry. Further, does not interfere with the reflectance of While the technology is not based on manufacturer interviews there energy back to the filament, allowing for appropriate for higher wattage products, are no covered IRLs that currently a more efficacious lamp. Hence, DOE is the CA IOUs argued that it is still a valid utilize this technology option. Because proposing higher efficiency burner as a design option for reduced wattage the lower limit of IRL wattages covered technology option that can increase lamps. The CA IOUs explained that in under standards is 40 W, DOE is no efficacy of IRLs. halogen infrared reflector (HIR) lamps, longer considering integrally ballasted Summary of IRL Technology Options making the filament a denser target low voltage lamps as a technology increases the amount of radiation that is option for improving lamp efficacy. Of the IRL technology options successfully reflected back to it, thereby presented in the preliminary analysis, increasing the lamp efficacy. At line Higher Efficiency Burner DOE is no longer considering integrally voltage, a higher wattage halogen burner DOE did not consider a higher ballasted low voltage lamps as a incorporates a relatively large diameter efficiency halogen burner as a technology option. In addition to the filament; however a lower wattage technology option in the preliminary IRL technology options identified in the capsule must use a finer filament. For analysis. DOE acknowledged that use of preliminary analysis, DOE is proposing these low wattage lamps, reducing the a double-ended burner in an IRL can the inclusion of the higher efficiency line voltage to low voltage allows the increase the efficacy compared to a burner as a technology option. In use of a shorter, fatter filament, which single-ended burner. Further, because summary, in this NOPR analysis, DOE is is ideal for HIR technology. While a double-ended burners could not fit into proposing the IRL technology options lamp greater than 50 W is suited for line small diameter IRLs (i.e., diameters less listed in Table VI.2.

TABLE VI.2—IRL TECHNOLOGY OPTIONS IN THE NOPR ANALYSIS

Name of technology option Description

Higher Temperature Operation ...... Operating the filament at higher temperatures, the spectral output shifts to lower wavelengths, increasing its overlap with the eye sensitivity curve. Microcavity Filaments ...... Texturing, surface perforations, microcavity holes with material fillings, increasing surface area and thereby light output. Novel Filament Materials ...... More efficient filament alloys that have a high melting point, low vapor pressure, high strength, high ductility, or good radiating characteristics. Thinner Filaments ...... Thinner filaments to increase operating temperature. This measure may shorten the operating life of the lamp. Efficient Filament Coiling ...... Coiling the filament to increase surface area, thus increasing light output. Crystallite Filament Coatings ...... Layers of micron or submicron crystallites deposited on the filament surface that increases emissivity of the filament. Efficient Filament Orientation ...... Positioning (horizontal or vertical) the incandescent filament to increase light emission from the lamp. Vertical orientation, used by majority of lamps, allows for greater light emission. Higher Efficiency Inert Fill Gas ...... Filling lamps with alternative gases, such as Krypton, to reduce heat conduction. Higher Pressure Tungsten-Halogen Lamps ...... Increased halogen bulb capsule pressurization, allowing higher temperature operation.

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TABLE VI.2—IRL TECHNOLOGY OPTIONS IN THE NOPR ANALYSIS—Continued

Name of technology option Description

Non-Tungsten-Halogen Regenerative Cycles .... Novel filament materials that regenerate. Infrared Glass Coatings ...... When used with a halogen capsule, this is referred to as a HIR lamp. Infrared coatings on the inside of the bulb to reflect some of the radiant energy back onto the filament. IR Phosphor Glass Coatings ...... Phosphor coatings that can absorb IR radiation and re-emit it at shorter wavelengths (visible region of light), increasing the lumen output. UV Phosphor Glass Coatings ...... Phosphor coatings that convert UV radiation into longer wavelengths (visible region of light), increasing the lumen output. Electron Stimulated Luminescence ...... A low voltage cathodoluminescent phosphor that emits green light (visible region of light) upon impingement by thermally ejected electrons, increasing the lumen output. Higher Efficiency Reflector Coatings ...... Alternative reflector coatings such as silver, with higher reflectivity increase the amount of di- rected light. Corner Reflectors ...... Individual corner reflectors in the cover glass that reflect light directly back in the direction from which it came. High Reflectance Filament Supports ...... Filament supports that include a reflective face that reflects light to another filament, the reflec- tive face of another filament support, or radially outward. Permanent Infrared Reflector Coating Shroud ... Permanent shroud with an IR reflector coating and a removable and replaceable lamp can in- crease efficiency while reducing manufacturing costs by allowing IR reflector coatings to be reused. Higher Efficiency Burners ...... A double-ended burner that features a lead wire outside of the capsule, where it does not interfere with the reflectance of energy from the capsule wall back to the capsule filament in HIR lamps.

B. Screening Analysis at the time, it will not further consider wattage lamps because it lowers lamp this technology. wattage, thereby resulting in higher After DOE identifies the technologies • that improve the efficacy of GSFLs and Adverse Impacts on Health or lamp efficacy. NEMA noted that the IRLs, DOE conducts the screening Safety: If DOE determines that a resulting reduced wattage lamps have technology will have significant adverse analysis. The purpose of the screening issues with cold temperature impacts on health or safety, it will not analysis is to determine which options applications, striations, and further consider this technology. dimmability due to the use of krypton to consider further and which options to Those technology options not screen out. DOE consults with industry, and pointed out that these items are screened out by the above four criteria performance characteristics that should technical experts, and other interested are called ‘‘design options’’ and are parties in developing a list of be considered in the screening analysis. considered as possible methods of NEMA encouraged DOE to explore the technology options. DOE then applies improving efficacy in the engineering trade-offs to ensure the right balance is the following set of screening criteria to analysis. DOE received several obtained. (NEMA, Public Meeting determine which options are unsuitable comments on technology options not Transcript, No. 30 at pp. 78–79) for further consideration in the screened out and retained as design rulemaking (10 CFR Part 430, subpart C, options in the preliminary analysis for Based on previous manufacturer appendix A at 4(a)(4) and 5(b)): feedback, DOE is aware that the • GSFLs and IRLs. Technological Feasibility: DOE will presence of krypton in reduced wattage consider technologies incorporated in 1. General Service Fluorescent Lamp lamps causes issues with lamp starting Design Options commercially available products or in and striations in cold temperature working prototypes to be In the preliminary analysis, of the applications below 60–65 °F. Feedback technologically feasible. GSFL technology options identified, • from manufacturers in interviews has Practicability to Manufacture, DOE did not consider screening out also indicated that problems Install, and Service: If mass production higher efficiency lamp fill gas encountered with dimming linear of a technology and reliable installation composition and glass coatings; fluorescent lamps, including lamp and servicing of the technology could be however, DOE received several starting, striations, and dropout, are achieved on the scale necessary to serve comments on these two design options. exacerbated by the use of krypton in the relevant market at the time the DOE did not receive any feedback on reduced wattage lamps. Krypton, which standard comes into effect, then DOE the other GSFL design options put forth lowers the wattage of a fluorescent will consider that technology in the preliminary analysis. lamp, is the primary fill gas used in practicable to manufacture, install, and reduced wattage fluorescent lamps. service. Higher Efficiency Lamp Fill Gas • Adverse Impacts on Product Utility Composition Based on feedback from manufacturers or Product Availability: If DOE In the preliminary analysis, DOE the use of any amount of krypton will determines a technology to have determined that higher efficiency lamp result in dimming issues and increase significant adverse impact on the utility fill gas composition met the screening with the amount of krypton. of the product to significant subgroups criteria and considered it as a design Philips noted that issues with of consumers, or to result in the option. As previously described, lamp dimming reduced wattage lamps could unavailability of any covered product fill gases such as argon increase also be related to the ballast as well as type with performance characteristics mobility of mercury ions and electrons, compatibility with the dimmer and (including reliability), features, sizes, facilitating recombination and thereby lamp. Philips further noted that they capacities, and volumes that are increasing UV output and resulting in had observed that a lamp-ballast system substantially the same as products higher lamp efficacy. Krypton is would dim successfully in one building generally available in the United States primarily used as a fill gas in reduced but fail when put in a different building.

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(Philips, Public Meeting Transcript, No. reflects UV radiation that has passed proposing higher efficiency burners as a 30 at p. 225) through the luminescent material of the design option only for IRLs with Despite the issues with dimming and lamp back onto the material for diameters greater than 2.5 inches. operation in cold temperatures, DOE has increased visible light output and also In summary, in this NOPR analysis determined that reduced wattage lamps reduces the contaminants in the lamp. DOE is proposing as design options the using krypton can be found on the A patent relevant to this technology following IRL technologies that have market in various wattages. Feedback notes that such undercoating is a met the screening criteria: from manufacturers in interviews also common feature of modern fluorescent • Higher Temperature Operation indicates that reduced wattage lamps lamps.23 • Thinner Filaments comprise a significant portion of their Because this technology option is • Efficient Filament Coiling • GSFL shipments. Additionally, being used in commercially available Efficient Filament Orientation • Higher Efficiency Inert Fill Gas consumers have other options, as more fluorescent lamps, DOE considers it to • reliable dimming can be attained using be practicable to manufacture. DOE is Higher Pressure Tungsten-Halogen full wattage lamps and fluorescent not aware of any evidence indicating Lamps • Infrared Glass Coatings lamps designed to be operated in cold that the technology has adversely • temperature applications exist on the impacted product utility or health and Higher Efficiency Reflector Coatings market. safety. Therefore, DOE proposes to (with the exception of gold reflector Therefore, DOE has determined that maintain glass coatings as a design coatings) • Higher Efficiency Burner higher efficiency lamp fill gas option for GSFLs. composition, specifically in the form of In summary, in this NOPR analysis See chapter 4 of the NOPR TSD for krypton, meets the criteria of being DOE is proposing as design options the further details on the IRL screening technologically feasible and practicable following GSFL technologies that have analysis. to manufacture as it is used in met the screening criteria: C. Product Classes commercially available products. DOE • Highly Emissive Electrode Coatings DOE divides covered products into has found no evidence to indicate it has • Higher Efficiency Lamp Fill Gas classes by: (a) The type of energy used; adverse impacts on health and safety. Composition (b) the capacity of the product; or (c) Because DOE is considering standard • Higher Efficiency Phosphors other performance-related features that levels that ensure the availability of • Glass Coatings justify different standard levels, both full and reduced wattage lamps, • Higher Efficiency Lamp Diameter considering the consumer utility of the DOE has determined that the use of this See chapter 4 of the NOPR TSD for feature and other relevant factors. (42 technology does not have an adverse further details on the GSFL screening U.S.C. 6295(q)) In a general comment, impact on product utility or availability. analysis. NEMA requested that DOE ensure CSLs Therefore, DOE proposes to maintain do not potentially eliminate utility from higher efficiency lamp fill gas as a 2. Incandescent Reflector Lamp Design the market. (NEMA, No. 36 at p. 20) As design option for GSFLs. Options DOE did not receive any feedback on noted, when assessing factors for Glass Coatings IRL design options put forth in the product class divisions, DOE considers In the preliminary analysis, DOE preliminary analysis. consumer utility. determined that glass coatings met the DOE received several comments screening criteria and considered them Higher Efficiency Burners regarding product classes considered in as a design option. To increase the UV As mentioned previously, in this the preliminary analysis. absorption by the phosphors, the lamp NOPR analysis DOE is proposing the 1. General Service Fluorescent Lamp glass can be covered with an additional technology option of a higher Product Classes efficiency burner as a means to improve antireflective coating. This coating is a In the preliminary analysis DOE IRL efficacy. DOE evaluated the higher refractory oxide, such as aluminum considered product classes for GSFLs efficiency burner technology against the oxide (Al2O3), silicon oxide (SiO2), and based on the following three factors: (1) screening criteria. DOE found that titanium oxide (TiO2) that reflects any CCT; (2) physical constraints of lamps higher efficiency burners, such as the UV radiation that passes through the (i.e., lamp shape and length); and (3) double-ended burner, are currently phosphor back onto the phosphor, lumen package. DOE received being utilized in commercially available allowing a greater portion of UV to be comments regarding the CCT product lamps and have demonstrated that they absorbed, thereby increasing light class division and a suggestion to are technologically feasible, practicable output and lamp efficacy. NEMA stated establish a product class division based to manufacture, install, and service on that glass coatings should be screened on a lamp’s dimming functionality. DOE a commercial scale by the compliance out as the techniques are not feasible, did not receive feedback on the other date of any amended standards, and do which is the reason they are not already product class divisions put forth for not result in adverse impacts on product widely used. (NEMA, No. 36 at p. 7; GSFLs in the preliminary analysis. NEMA, Public Meeting Transcript, No. utility or availability, or health and 30 at pp. 70) safety. DOE acknowledges that double- CCT DOE determined that most modern ended burners cannot be used in small In the preliminary analysis, DOE lamps utilize glass coatings that diameter lamps without changing the considered CCT, noted in degrees minimize the absorption of mercury and physical shape of the lamp, which may Kelvin (K), as a class setting factor, 22 act as reflectors of UV radiation. An impact whether the lamp can fit specifically, product classes for GSFLs undercoat layer, preferably composed of standard fixtures, and thereby affect with a CCT less than or equal to 4,500 aluminum oxide and a getter material, product utility. Therefore, DOE is K and a product class for GSFLs with a CCT greater than 4,500 K. NEEA and 22 DiLaura, D. L., K. W. Houser, R. G. Mistrick, 23 Trushell, Charles and Liviu Magean. Method of and G. R. Steffy. IESNA Lighting Handbook: manufacturing a fluorescent lamp having getter on NPCC noted that while DOE stated that Reference and Application, 10th Edition. New York: a UV reflective base coat. U.S. Patent No. 7,500,896 GSFLs with a CCT greater than 4,500 K IESNA, 2011. B2, filed May 9, 2005, and issued Mar 10, 2009. show a decline in efficacy, DOE did not

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state the degree of the decline of substantially the same as those generally TABLE VI.3—GSFL PRODUCT efficacy, whether it was consistent available in the United States at the time CLASSES IN NOPR ANALYSIS across manufacturers, or if the decline of the Secretary’s finding.’’ (42 U.S.C. was inherent in the phosphor mixes 6295(o)(4)) NEMA emphasized that as Lamp type CCT required to produce the higher CCT dimmability and uniformity of light values. NEEA and NPCC noted that they (absence of flicker or striation) are all 4-foot medium bipin ...... ≤4,500 K >4,500 K may support having a separate product performance characteristics highly ≤ class for these lamps, but that additional 2-foot U-shaped ...... 4,500 K desirable in the marketplace, they must >4,500 K data is needed. (NEEA and NPCC, No. be maintained. (NEMA, No. 36 at p. 4) 8-foot single pin slimline ...... ≤4,500 K 34 at p. 3) Further, NEMA stated that potential >4,500 K CCT is a measure of the perceived energy savings from dimming will be 8-foot recessed double con- color of white light emitted from a lamp. reduced or lost if DOE eliminates full tact high output ...... ≤4,500 K The lower CCTs correspond to warm wattage 32 W GSFLs from the market. >4,500 K light and are in the red wavelengths (NEMA, No. 36 at p. 15) Lutron agreed 4-foot T5, miniature bipin while the higher CCTs correspond to standard output ...... ≤4,500 K that elimination of full wattage lamps >4,500 K cooler light and are in blue wavelengths. that are argon-filled would also get rid The human eye is less responsive to 4-foot T5, miniature bipin of dimming. (Lutron, Public Meeting high output ...... ≤4,500 K light in the blue wavelengths and Transcript, No. 30 at pp. 25) >4,500 K therefore, efficacy decreases in lamps with higher CCTs. The phosphor blend EEI noted that the increase of lighting 2. Incandescent Reflector Lamp Product used in a lamp substantially impacts the controls requirements in building codes Classes lamp’s CCT. For example, the use of rare such as those put out by American earth phosphors results in light emitted Society of Heating, Refrigerating and In the preliminary analysis, DOE at wavelengths to which the human eye Air-Conditioning Engineers (ASHRAE) considered product classes for IRLs is most sensitive, thereby increasing the and International Energy Conservation based on the following three factors: (1) lamp efficacy. Therefore, different Code (IECC) means that dimmability is Rated voltage, separating lamps less phosphor blends in lamps achieve a performance characteristic necessary than 125 V from lamps greater than or different CCTs. (See chapter 3 of the for operation in commercial buildings. equal to 125 V; (2) lamp spectrum, NOPR TSD for further details on (EEI, Public Meeting Transcript, No. 30 separating lamps with a standard fluorescent lamp technology.) at p. 79–80) The CA IOUs reiterated the spectrum from lamps with a modified DOE determined through analysis and importance of not eliminating dimming spectrum; and (3) lamp diameter, confirmed with manufacturers that products from the market. They separating lamps with a diameter greater lamps with CCTs greater than 4,500 K suggested that if there are two sets of than 2.5 inches from lamps with a start showing a decline in efficacy. products, one with dimming capability diameter less than or equal to 2.5 Feedback from manufacturers varied and one with higher efficacy, there may inches. DOE received several comments regarding the exact efficacy reduction be grounds to create separate product on the rated voltage class setting factor. correlated with CCT and whether it was classes so that covered products will DOE did not receive feedback on the consistent across GSFL types. DOE’s comply with standards either by having other product class divisions put forth evaluation of catalog and compliance higher efficacy or by dimming. (CA for IRLs in this preliminary analysis. efficacies for similar lamp types at IOUs, Public Meeting Transcript, No. 30 Rated Voltage different CCTs for various at pp. 135) In the preliminary analysis, DOE manufacturers has shown that in DOE acknowledges that there are general, there is a reduction in the range considered rated voltage as a class issues with dimming reduced wattage setting factor, establishing a product of 2–6 percent going from a CCT of lamps that do not typically manifest in 4,500 K or less to a CCT greater than class for IRLs with voltages less than full wattage lamps. DOE is aware that 125 V and a product class for IRLs with 4,500 K. (See section VI.D.2.h and unreliable dimming is in part due to the chapter 5 of the NOPR TSD for scaling voltages greater than or equal to 125 V. use of krypton as the fill gas in reduced IRLs mainly come in rated voltages of to higher CCT product classes.) wattage lamps as well as other factors. Therefore, because consumers are 120 or 130. This product class division (See the discussion on higher efficiency afforded a different perception of light establishes two separate product classes lamp fill gas composition in VI.A.1.) at different CCTs and efficacy is for the 120 V IRLs and the 130 V IRLs. Therefore, DOE is ensuring that any impacted with varying CCTs, DOE NEEA and NPCC stated that DOE proposed level can be met by full proposes to maintain CCT as a product should maintain separate product wattage lamps. Because the utility of class division factor. Specifically DOE is classes for lamps that are less than 125 dimming is being preserved in the proposing to establish a product class of V and those that are greater than or existing product class structure and for lamps with CCTs less than or equal to equal to 125 V. They indicated that if the analyzed standard levels, DOE is not 4,500 K and a product class with CCTs there were demand for 130 V lamps, it proposing fill gas that allows for reliable greater than 4,500 K. would be highly likely that standards dimming as a product class setting compliant 130 V lamps would enter the Dimming Utility factor. (See section VI.D.2.g and chapter market, as there is nothing inherent in NEMA noted that DOE may not set 5 of the NOPR TSD for the GSFL the standard levels that would eliminate standards that would eliminate full engineering analysis.) 130 V lamps. (NEEA and NPCC, No. 34 wattage GSFLs because the Secretary Summary of GSFL Product Classes at p. 4) may not prescribe standards ‘‘likely to Advanced Lighting Technologies result in the unavailability in the United In this NOPR analysis, DOE is (ADLT) agreed, pointing out that States in any covered product type (or proposing the product classes for GSFLs combining lamps less than 125 V and class) of performance characteristics summarized in Table VI.3. See chapter greater than or equal to 125 V lamps (including reliability), features, sizes, 3 of the NOPR TSD for further details into one product class would allow 130 capacities, and volumes that are on each GSFL product class. V lamps on the market that fall below

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the July 2012 efficacy requirement of be tested at 120 V. However, DOE is lamps instead of the 120 V lamps. When 5.9P0.27 when operated at 120 V. ADLT aware that a large number of consumers consumers operate these lamps at 120 V, gave the example that a 130 V 70 W actually operate 130 V lamps at 120 V, they may need to purchase more lamps lamp would be required to produce 19.5 which results in longer lifetime but to obtain sufficient light output, thereby lm/W under DOE’s CSL 1 of 6.2P0.27 for lower efficacy. With a single EL for increasing energy consumption. Hence, less than 125 V lamps. However, lamps rated at each voltage, this in order to preserve energy savings, DOE operating the same 130 V, 70 W lamp situation would effectively lead to a proposes to maintain the rated voltage in a 120 V socket would result in lower efficacy requirement for these 130 class division that separates covered lowering the wattage to 61.5 W and V lamps run at 120 V, compared to 120 IRLs less than 125 V from those that are efficacy to 16.8 lm/W,24 which equates V lamps run at 120 V. The 130 V lamps greater than or equal to 125 V. to 5.4P0.27. Therefore, a 130 V, 70 W would not require the same level of Summary of IRL Product Classes lamp operating at 120 V would fall well technology as 120 V lamps to meet the below the July 2012 requirement of same standard, and, thus, would be In this NOPR analysis, DOE is 5.9P0.27. (ADLT, No. 31 at p. 2) cheaper to produce. Therefore, setting proposing the product classes for IRLs Existing DOE test procedures provide higher standards for IRLs without summarized in Table VI.4. See chapter for lamps rated at 130 V to be tested at accounting for voltage differences could 3 of the NOPR TSD for further details 130 V and for lamps rated at 120 V to result in increased migration to 130 V on each IRL product class.

TABLE VI.4—IRL PRODUCT CLASSES IN NOPR ANALYSIS

Diameter Lamp type (in inches) Voltage

Standard Spectrum ...... >2.5 ≥125 V <125 V ≤2.5 ≥125 V <125 V Modified Spectrum ...... >2.5 ≥125 V <125 V ≤2.5 ≥125 V <125 V

D. Engineering Analysis primarily because of their high market specific lamps studied; (2) the ability of volumes. lamps across wattages to comply with 1. General Approach Baseline lamps: For each the standard level of a given product 25 The engineering analysis is generally representative product class, DOE class; and (3) the max tech EL. DOE based on commercially available lamps selects a baseline lamp as a reference then scales the ELs of representative that incorporate the design options point against which to measure changes product classes to those classes not identified in the technology assessment resulting from energy conservation directly analyzed. and screening analysis. (See chapters 3 standards. Typically, a baseline model DOE received a general comment on and 4 of the NOPR TSD for further is the most common, least efficacious the methodology used in this rulemaking to develop efficacy levels for information on technology and design lamp sold in a given product class. DOE both GSFLs and IRLs. NEMA noted that options.) The methodology consists of also considers other lamp characteristics additional adjustments for variation of the following steps: (1) Selecting in choosing the most appropriate baseline for each product class such as product performance for manufacturing representative product classes, (2) wattage, lumen output, and lifetime. and testing variations must be afforded selecting baseline lamps, (3) identifying More efficacious substitutes: DOE not only to compliance but to more efficacious substitutes, and (4) selects higher efficacy lamps as interpretations of published catalog developing efficacy levels by directly replacements for each of the baseline data. NEMA referred DOE to NEMA analyzing representative product classes models considered. When selecting LSD–63 Measurement Methods and and then scaling those efficacy levels to higher efficacy lamps, DOE considers Performance Variation for Verification non-representative product classes. The only design options that meet the Testing of General Purpose Lamps and details of the engineering analysis are criteria outlined in the screening Systems for guidance on proper discussed in chapter 5 of the NOPR analysis (see section VI.B or chapter 4 application of statistical analysis for TSD. The following discussion of the NOPR TSD). For GSFLs, DOE lighting products. (NEMA, No. 36 at pp. summarizes the general steps of the pairs each lamp with an appropriate 11–12; Philips, Public Meeting engineering analysis: ballast because fluorescent lamps are a Transcript, No. 30 at pp. 134) Representative product classes: DOE component of a system, and their DOE reviewed NEMA LSD–63 to first reviews covered lamps and the performance is related to the ballast on determine whether additional associated product classes. When a which they operate. adjustments due to manufacturing and product has multiple product classes, Efficacy levels: After identifying the testing variation were needed based on DOE selects certain classes as more efficacious substitutes for each the guidance provided in the document. ‘‘representative’’ and concentrates its baseline lamp, DOE develops ELs. DOE DOE determined that the guidance was analytical effort on these classes. DOE bases its analysis on three factors: (1) not applicable to the datasets utilized by selects representative product classes The design options associated with the DOE to conduct the analysis,

24 DiLaura, D. L., K. W. Houser, R. G. Mistrick, Reference and Application, 10th Edition. New York: 25 ELs span multiple lamps of different wattages. and G. R. Steffy. IESNA Lighting Handbook: IESNA, 2011. In selecting ELs, DOE considered whether these multiple lamps can meet the standard levels.

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specifically lamp manufacturer catalog lamp types that do not have a defined NEEA disagreed that the certification data and DOE’s certification database. ANSI rated wattage, DOE utilized the database was being misread. NEEA DOE received feedback from lamp’s nominal wattage to calculate recommended the use of a consistent set manufacturers that catalog data catalog efficacy. However, DOE also of data and requested general represents the long term average analyzed publicly available data clarification on the data utilized in the performance of products. In submitted to DOE by manufacturers to analysis. (NEEA, Public Meeting comparison, LSD–63 provides guidance demonstrate compliance with existing Transcript, No. 30 at pp. 139–140) for comparing a small sample set of test energy conservation standards.26 DOE ASAP asked if there is a discrepancy data to rated catalog values through adjusted efficacy levels to account for between catalog and certification values statistical analysis to determine if the certification data when available. for products. (ASAP, Public Meeting small sample set is part of the long term Transcript, No. 30 at pp. 146–147) rating distribution. Because the Usability of Certification Data and Philips explained that values initially guidance prescribed in LSD–63 is Catalog Data published in catalogs are based on a relevant for small sample sets and DOE The CA IOUs noted statements made small set of samples and these values is basing its analysis on catalog data during the public meeting indicated that change as the sample size increases and representing long term performance the catalog data may not be precise as is more representative of manufacturing. data, DOE did not make adjustments for it is not subject to any reporting The initially published catalog values variation using this guidance. regulations and further the certification are eventually synched with values Further, as discussed in section database may be inaccurate. The CA based on the greater sample size but VI.D.2.a, DOE considers certification IOUs asked that clarification be catalogs are updated only every two or data provided in DOE’s database to provided regarding the data used in the three years. Further there is some account for variation when establishing GSFL analysis. (CA IOUs, No. 32 at pp. allowable difference between the the minimum efficiency requirements 12–13) The CA IOUs also noted that a marketed efficacy values and the for each efficacy level. By accounting for large number of products in DOE’s certification efficacy values. (Philips, the compliance requirements when certification database did not seem to Public Meeting Transcript, No. 30 at pp. establishing efficacy levels, DOE have been included in this rulemaking 147–148) incorporates manufacturing and testing analysis for GSFLs. In particular, the CA NEEA and NPCC stated that they are variation and therefore uses values IOUs noted that there were about 20 or unable to comment extensively on the representative of the energy use of the 30 products that are above 96 lm/W for GSFL analysis due to DOE’s use of products. the representative 4-foot MBP product catalog efficacy values and ANSI rated Stakeholders had several comments class from about ten manufacturers wattages instead of measured and/or regarding the engineering analysis including MaxLite, Satco, Philips, and certified values including using test data presented in the preliminary TSD Westinghouse, as well as a product at appropriate test conditions such as ° specific to GSFLs and IRLs. The exceeding 100 lm/W. (CA IOUs, Public testing at 25 C. (NEEA and NPCC, No. following sections discuss and address Meeting Transcript, No. 30 at pp. 114– 34 at p. 2, 3) Noting that comments by feedback received from stakeholders for 115) manufacturers during the public each product. DOE requests comment GE suggested that because such high meeting indicated that catalog and on the overall methodology, measured lm/W values are not certification values will be different, assumptions, and results of the GSFL achievable, the issue may be that the NEEP as well as NEEA and NPCC and IRL engineering analyses. information in the certification database recommended DOE use measured and/ is being misread or there may be or certified values for its analysis, and 2. General Service Fluorescent Lamp not use catalog values for any part of the Engineering confusion among manufacturers about what exactly to report in each column analysis. (NEEA and NPCC, No. 34 at p. DOE received comments on the which could be resulting in false 2, 3; NEEP, No. 33 at p. 2) NEEA and engineering analysis for GSFLs calculations. (GE, Public Meeting NPCC stated that once it had seen presented in the preliminary TSD. Transcript, No. 30 at p. 115, pp. 141) GE measured and/or certified values, it Stakeholders provided feedback on noted that manufacturers have questions suspected the range of lamp DOE’s data approach, representative pending to DOE regarding certification performance will be much narrower product classes, baseline lamps, than presented in the preliminary reporting. (GE, Public Meeting selection of more efficacious substitutes, analysis. (NEEA and NPCC, No. 34 at p. Transcript, No. 30 at pp. 141) The CA lamp-and-ballast pairings, max tech 2, 3) NEEP stated that while there IOUs agreed with GE that there could be levels, CSLs, and scaling. The following appear to be significant energy savings inconsistencies or confusion with which sections summarize the comments and for GSFLs at CSL1, DOE’s use of catalog values to report and encouraged DOE to responses received on these topics, and data puts the accuracy of these estimates look into these issues further. (CA IOUs, present the proposed GSFL engineering into question. (NEEP, No. 33 at p. 2) Public Meeting Transcript, No. 30 at pp. for this NOPR analysis. DOE understands the concerns raised 115–116) ASAP pointed out that there by stakeholders regarding the difference a. Data Approach may be possible enforcement issues if between catalog and certification values For the preliminary analysis, DOE there are products in the certification and their subsequent recommendations considered commercially available database that are non-compliant. (ASAP, to utilize certification data. At the time lamps when possible. DOE used Public Meeting Transcript, No. 30 at pp. of the preliminary analysis, DOE’s performance data of the commercially 139) GE added that it could be that the certification database consisted of data available lamps presented in lamps are in compliance but the claims for only 38 percent of covered GSFLs. manufacturer catalogs to identify being made are aggressive. (GE, Public Because not all commercially available potential baseline lamps and develop Meeting Transcript, No. 30 at pp. 141) products had associated certification initial efficacy levels. DOE calculated data, DOE was unable to rely solely on 26 The publicly available compliance information efficacy as the initial lumen output for GSFLs can be found in DOE’s Compliance certification data in the preliminary published in manufacturer catalogs Certification Database available here: analysis. At the time of the NOPR divided by the ANSI rated wattage. For www.regulations.doe.gov/certification-data/. analysis, DOE’s certification database

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contained data for 68 percent of the DOE used manufacturer lamp catalogs lamps. This allowed DOE to evaluate covered commercially available lamps. to establish initial CSLs in the performance for all T5 lamps based on While this was an increase from the preliminary analysis and ELs in the data provided by manufacturers at the preliminary analysis, it still did not NOPR. To determine catalog efficacies, same operating temperature. As noted, represent a comprehensive dataset on DOE used catalog lumen output and because the DOE test procedure used to which to base an engineering analysis. ANSI rated wattage instead of the determine compliance with standards Therefore, in this NOPR analysis, DOE nominal wattage provided by requires GSFLs to be tested at 25 °C, again utilized catalog data to identify manufacturers in catalogs. ANSI rated DOE adjusted the initial efficacy levels baseline products and develop initial wattage is the result of standardized to reflect operation at 25 °C. To do this, efficacy levels. This approach ensured ANSI testing and represents an industry DOE utilized information in lamp consideration of all available products. agreed upon wattage, as explained by manufacturer catalogs that provided DOE then used available certification NEMA. If an ANSI standard did not performance characteristics for lamp data to adjust the initial efficacy levels, provide a rated wattage for a lamp type operation at both 25 °C and 35 °C. In if necessary, thereby ensuring that the analyzed, efficacy was calculated using cases where this information was not proposed levels can be met based on the the nominal wattage. available, DOE adjusted the 35 °C data certification values submitted by For the assessment of certification to reflect lamp operation at 25 °C. manufacturers to demonstrate values, DOE used the reported values Specifically, when operated at 25 °C, the compliance with standards. for efficacy, which are based on lumen output of T5 lamps is measured lumen output and measured approximately 10 percent lower than Wattage wattage as specified in DOE’s test the lumen output of such lamps when The CA IOUs asked why DOE is using procedures for GSFLs set forth at 10 operated at 35 °C. For this NOPR ANSI rated wattage to calculate efficacy CFR part 430, subpart B, appendix R. analysis, DOE has maintained this when the certification database lists Utilizing ANSI rated wattage to approach and developed efficacy levels specific wattages for products. (CA calculate catalog efficacy and reported based on performance at 25 °C. IOUs, Public Meeting Transcript, No. 30 efficacy for developing final efficacy at pp. 96) The CA IOUs stated that using levels eliminates the uncertainty Decimal Usage for lm/W a rated wattage of 32.5 W gives an associated with the wattages reported Philips stated that the CSLs analyzed expected average efficacy and for compliance. in the preliminary analysis are to the recommended looking at whether lamps tenths decimal place which provides an are performing at different levels of Using Data at 25 Degrees Celsius artificial measure of accuracy that efficacy than projected and setting NEMA stated that DOE should doesn’t even exist and Philips doesn’t baselines and standards around more conduct all its analyses, payback and think it can be measured accurately. measured data rather than a rated feasibility equations based on data (Philips, Public Meeting Transcript, No. wattage. (CA IOUs, Public Meeting referenced to and measured at 25 °C, not 30 at p. 146) Regarding this comment Transcript, No. 30 at p. 100) 35 °C, otherwise, results will be skewed that reporting lm/W to one significant NEMA noted the rated wattage is because efficiency can ‘‘appear’’ higher digit is not conducive to repeated and based on a very large number of samples at 35 °C for certain products made reliable measurements, the CA IOUs that are averaged out and manufacturers (optimized) for those conditions. NEMA stated the rulemaking must adhere to produce lamps to fall on and around noted that DOE’s test procedure, the existing DOE test procedure that that point. Therefore, the individual existing and previous rules, as well as calculates an efficacy value using a lamp tested wattage will differ from this reporting and catalogs, use 25 °C data. specific sample size and confidence rated value of that lamp. NEMA stated (NEMA, No. 36 at p. 18; NEMA, Public limit procedure. (CA IOUs, Public that it would defer to its members, but Meeting Transcript, No. 30 at p. 127) GE Meeting Transcript, No. 30 at pp. 149– in general it supported using the ANSI noted that discussions during the 2009 151) rated wattage rather than the measured Lamps Rule had concluded that T5 As specified in DOE’s test procedures wattage. (NEMA, Public Meeting lamps should be tested at 25 °C as for GSFLs set forth at 10 CFR part 430, Transcript, No. 30 at pp. 98) GE did not currently done by labs because testing subpart B, appendix R, lamp efficacy is think industry had a firm position on becomes very unreliable at 35 °C. the ratio of measured lumen output in the issue, recognizing different wattages Therefore, it is not appropriate to have lumens to the measured lamp electrical can be used. (GE, Public Meeting a lm/W level based on 35 °C. (GE, Public power input in watts rounded to the Transcript, No. 30 at pp. 99–100; Meeting Transcript, No. 30 at pp. 89–90) nearest tenth in units of lumens per NEMA, Public Meeting Transcript, No. Philips stated that lamps for which watt. In the 2009 final rule for the GSFL 30 at pp. 98–99) efficacy values are provided at 35 °C and IRL test procedure, DOE amended For the preliminary analysis and the operating temperature in catalogs are the test procedure to require reported NOPR analysis, DOE used catalog data particular amalgam lamps that were efficacy measurements for GSFLs to be to develop initial CSLs and ELs and designed specifically for that rounded to the nearest tenth of a lumen assessed certification data to make any environment. (Philips, Public Meeting per watt allowing for future energy adjustments to the levels. As noted, Transcript, No. 30 at p. 127) conservation standards to be rounded to DOE’s certification database does not In the preliminary analysis, DOE the nearest tenth of a lumen per watt. 74 include data for all covered GSFLs; developed efficacy levels based on FR 31829, 31836 (July 6, 2009). DOE therefore, the measured wattages of all performance at 25 °C because the DOE concluded this amendment to the test commercially available covered lamps test procedure for GSFLs requires the procedure was feasible because are not readily accessible. Additionally, lamps to be tested at 25 °C, including T5 manufacturers routinely generate test DOE identified inconsistencies with the lamps. However, because all results that would allow reporting to at values reported for wattage, specifically manufacturers do not provide lumen least the tenth of a lumen per watt level. in some cases nominal wattage may be output data at 25 °C for T5 lamps in 74 FR at 31836 (July 6, 2009). Therefore, reported rather than the measured their catalogs but do provide it at 35 °C, DOE is analyzing efficacy levels in this wattage in DOE’s certification database. DOE developed initial efficacy levels rulemaking rounded to the nearest tenth Therefore, as mentioned previously, based on 35 °C catalog data for T5 of a lumen per watt as DOE maintains

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that this is an achievable level of relief exempting their 700 series T8 order to ensure the analysis is accuracy. lamps from the July 2012 standards for accounting for the magnitude of a period of two years. The waiver was difference between greater than and less Using High Frequency Test Data granted due to the global supply than or equal to 4,500 K CCT products. According to NEMA, in recognition of restrictions on rare earth phosphors, the (NEEA, Public Meeting Transcript, No. the marketplace shift to electronic high rising world demand of these 30 at p. 88) frequency (HF) ballasts, the American phosphors, and the resulting impacts on As noted previously, DOE chose National Standards Institute Lighting producing higher efficacy GSFLs.28 representative product classes based on Group has drafted new standards for the Because this waiver will expire in 2014, high market volumes. DOE received electrical and photometric and any standards adopted by this feedback from manufacturers in characterization of GSFL T8 lamps that rulemaking are expected to require interviews indicating that the volume of are based on HF rather than the former compliance in 2017, DOE has conducted lamps with CCT greater than 4,500 K is low frequency 60 Hz reference ballasts. this analysis for GSFLs assuming that considerably lower than the volume of When these new standards are the waiver would not be in place and lamps with CCT less than or equal to published later in 2013, the industry has therefore not considered non- 4,500 K. In addition, DOE used will comply and begin characterizing compliant 700 series lamps in its manufacturer feedback and catalog data their products using HF-based analysis. DOE notes that the term ‘‘700 to quantify the difference in photometry. (NEMA, No. 36 at p. 2) series’’ is widely used in industry when performance between lamps with higher NEMA also stated that current test referring to fluorescent lamps with a CRI CCTs and lamps with lower CCTs. For procedures unfairly compare energy- in the range of 70 to 79. See section V.A these reasons, DOE did not directly saver lamps to standard lamps, owing to for the proposed definition of a 700 analyze lamps with CCT greater than the removal of cathode heat voltage series lamp. 4,500 K in the preliminary analysis and from the energy-efficiency calculation of this NOPR analysis. DOE scaled the energy-saver lamps, thus they cannot be b. Representative Product Classes directly analyzed product classes with compared without unfairly skewing the When a covered product has multiple CCTs less than or equal to 4,500 K to numbers in favor of low-wattage lamps. product classes, DOE identifies and those with CCTs greater than 4,500 K in High frequency measurement standards selects certain product classes as the preliminary and NOPR analyses. See account for this difference. (NEMA, No. representative and analyzes those section VI.D.2.h and chapter 5 of the 36 at pp. 14–15) Therefore, NEMA product classes directly. DOE chooses NOPR TSD for further information. recommends that this rulemaking these representative product classes EEI stated it thought that the 2-foot U- should be based on the new ANSI HF primarily due to their high market shaped lamps would have sales standards. (NEMA, No. 36 at p. 2) volumes. For GSFLs, in the preliminary comparable to some of the other product The current GSFL test procedure as analysis DOE identified all GSFLs with classes. EEI also did not agree with specified in 10 CFR part 430, subpart B, CCTs less than or equal to 4,500 K with determining the efficiency standard for appendix R requires lamps be tested at the exception of the 2-foot U-shaped the 2-foot U-shaped lamps using the 4- low frequency unless only high lamps as representative product classes foot MBP lamps as a proxy. (EEI, Public frequency ballast specifications are as shown (in gray) in Table VI.5. NEMA Meeting Transcript, No. 30 at p. 86–88) available for the lamp. The test agreed with the representative product In the preliminary analysis, DOE procedure also specifies that for high classes presented for GSFLs. (NEMA, utilized the 4-foot MBP linear frequency testing, cathode heat should No. 36 at p. 7) fluorescent products to scale to the 2- not be used when the lamp is in foot U-shaped products, as both operation. DOE acknowledges that high TABLE VI.5—GSFL REPRESENTATIVE products use the same fluorescent technology, span the same range of frequency reference specifications may PRODUCT CLASSES be in development for additional lamp wattages, and, without its bent curve, types and may consider standards based Lamp type CCT the 2-foot U-shaped lamp would be on high frequency operation after ANSI approximately the same length as the 4- publishes the revised industry standard. 4-foot medium bipin ...... ≤4,500 K foot MBP linear lamp. Thus, DOE could >4,500 K determine impact on efficacy from the 700 Series Waiver 2-foot U-shaped ...... ≤4,500 K bent curve and scale from the 4-foot NEMA also noted that 700 series >4,500 K ≤ MBP product class. Further, the market lamps are under the U.S. Office of 8-foot single pin slimline ...... 4,500 K share of 2-foot U-shaped lamps is >4,500 K Hearings and Appeals (OHA) 8-foot recessed double con- significantly lower than 4-foot MBP compliance waivers from the July 2012 tact high output ...... ≤4,500 K lamps. As indicated in the LMC, T8 4- standards. Therefore, their performance >4,500 K foot linear lamps comprise 44 percent of and market changes are still several 4-foot T5, miniature bipin all linear fluorescent lighting, whereas years away from being known. (NEMA, standard output ...... ≤4,500 K T8 2-foot U-shaped lamps make up just No. 36 at p. 1) >4,500 K 2 percent. Therefore, in this NOPR In April of 2012, several 4-foot T5, miniature bipin analysis, DOE did not directly analyze ≤ manufacturers 27 were granted exception high output ...... 4,500 K the 2-foot U-shaped lamps and scaled >4,500 K ELs from the 4-foot MBP product class 27 At the time of this analysis, the following NEEA questioned why none of the to the 2-foot U-shaped product class. manufacturers had been granted exception relief See section VI.D.2.h and chapter 5 of the exempting their 700 series T8 lamps from current products with CCT greater than 4,500 K standards: Philips, GE, OSI, Ushio America, Halco were being directly analyzed and noted NOPR TSD for further information. Lighting Technologies, Premium Quality Lighting, Inc., Tailored Lighting, Inc., Litetronics that at least one should be assessed in c. Baseline Lamps International, Inc., Satco Products, Inc., DLU Once DOE identifies the Lighting USA, Westinghouse Lighting Corporation, 28 Philips Lighting Company, et al. OHA Case Ascent Battery Supply, LLC, Eiko, Ltd, Topaz Nos. EXC–12–0001, EXC–12–0002, EXC–12–0003 representative product classes for Lighting Corporation, Technical Consumer (2012). Accessible here: http://energy.gov/sites/ analysis, it selects baseline lamps to Products, Feit Electric Company. prod/files/oha/EE/EXC-12-0001thru03.pdf. analyze in each class. Typically, a

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baseline lamp is the most common, least CA IOUs also noted that the certification have a standard, DOE should establish efficacious lamp that just meets existing database shows that there are products the baseline at the lowest level of energy conservation standards. For right at the level, particularly for the 4- efficiency commonly found in the fluorescent lamps, the most common foot MBP class. (CA IOUs, Public marketplace. (NEEA and NPCC, No. 34 lamps were determined based on Meeting Transcript, No. 30 at pp. 93–94) at p. 1, 4) In this NOPR analysis, DOE characteristics such as wattage, lumen As noted previously, DOE assesses is not considering additional types of output, lifetime, and CCT. To identify commercially available products on the GSFLs that are not subject to standards. baseline lamps, DOE reviews product market and chooses baseline lamps See section V.B for more details. representative of the common offerings in catalogs, shipment NEEP noted that the 2011 Vermont information, and manufacturer feedback characteristics within that product class Market Characterization and obtained during interviews. and just meet existing standards. Assessment Study conducted by In the preliminary analysis, DOE However, feedback from stakeholders considered commercially available and manufacturer interviews has Navigant for Vermont’s Public Service lamps as baselines. In some cases, the indicated that manufacturers will likely Department (mentioned previously in most common, least efficacious produce lamps at the existing standard this notice) established baselines for commercially available product was at level even if no products are currently certain products in the state’s an efficacy above the existing standard available. Further, after the 2009 Lamps commercial sector. NEEP urged DOE to level. Specifically, for the 8-foot RDC Rule, DOE observed the introduction of utilize the fluorescent lighting data HO, T5 MiniBP SO, and T5 MiniBP HO products that were not previously collected to corroborate DOE’s findings. product classes, DOE was unable to available at the newly adopted standard (NEEP, No. 33 at p. 3) identify a commercially available levels for some product classes. Thus, DOE reviewed the study and found product at the existing standard level. DOE believes this trend could continue that, given the level of detail provided, DOE received several comments and additional lamps may be offered it was difficult to use the results to regarding the selection of these lamps that just meet the existing standard level corroborate DOE’s baseline selections. with efficacies higher than the existing for the remaining product classes. The study aims to characterize the standard levels as baselines. Therefore, in this NOPR analysis DOE prevalence of T8 lamps, high NEMA stated that the arguments for is proposing baselines at the existing performance T8 lamps, T12 lamps, and baseline, CSL 0 in the preliminary TSD, standard levels for all product classes. T5 lamps in the state of Vermont. While are based on predictions of market shift For the 4-foot MBP product class, DOE it provides market share information for that erroneously justify a new baseline determined the baseline selected in the standard T8s and high performance T8s, higher than the minimum requirements preliminary analysis to be the least it does not provide this information by put forth by the 2009 Lamps Rule. efficient product on the market at the level of efficiency for T5 lamps. Further, (NEMA, No. 36 at p. 1) NEMA existing standards. For the 8-foot SP the lengths of these lamp types are not questioned why the baselines for slimline product class, DOE also included, and thus DOE was unable to product classes were not set at the changed the baseline lamp to be the compare the results on a product class standard level adopted in the 2009 least efficient product on the market at basis. Lamps Rule. (NEMA, Public Meeting the existing standards. For When considering general overall Transcript, No. 30 at pp. 85–85) The CA representative product classes in which trends, the study confirmed that T8 IOUs recommended DOE use the there were no commercially available lamps are significantly more prevalent efficacy levels set in the 2009 Lamps lamps at the existing standard level, than T12 lamps, and T8 standard Rule as the baselines for all GSFL DOE modeled baseline lamps. To product classes because minimum determine the performance efficiency lamps are more commonly product performance generally characteristics of these lamps, DOE took installed than high performance T8 gravitates to the minimum standards set the ANSI rated wattage of the most lamps. These high level results support for the product. (CA IOUs, No. 32 at p. common, least efficacious commercially certain aspects of the baseline 13) GE concurred, stating that the available lamp and calculated the lumen selections, namely the selection of T8 market will move to lamps at that level output required to develop an efficacy at standard performance lamps at the due to the cost of rare earth materials. the existing standard level. DOE baseline. However, the study covers a Therefore, GE asserted that it is easy to assumed the modeled baseline lamp very limited service area and therefore make the assumption that lamps will would have similar characteristics as cannot be regarded as indicative of the gravitate towards that minimum level the most common commercially most commonly installed lamp types at over time and that that should be the available lamps in each product class, a national level. analysis going forward over the next six including lifetime and lumen DOE is proposing the baseline lamps to ten years. (GE, Public Meeting depreciation. DOE modeled baseline for GSFLs specified in Table VI.6. See Transcript, No. 30 at pp. 93–94) lamps for the 8-foot RDC HO, T5 chapter 5 of the NOPR TSD for further NEEA and NPCC agreed that DOE MiniBP SO, and T5 MiniBP HO product details on this assessment. DOE requests should use products that minimally classes. comment on the baseline lamps comply with existing standards as If DOE considered additional types of analyzed in the NOPR analysis, in baselines and this would be validated GSFLs in the scope of this rulemaking, particular the modeled baseline lamps by the measured and/or certified values. NEEA and NPCC recommended that for in the 8-foot RDC HO, T5 MiniBP SO, (NEEA and NPCC, No. 34 at p. 1, 4) The product classes that do not currently and T5 MiniBP HO product classes.

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d. More Efficacious Substitutes efficacy model lamp using a more had significant concerns regarding the DOE selects more efficacious efficacious commercially available T5 MiniBP HO model lamp and the high replacements for the baseline lamps reduced wattage T5 HO lamp to efficacy of the max tech level being considered within each representative calculate the characteristics of a full considered for this product class. Noting product class. DOE considers only wattage T5 HO lamp of comparable that it had not seen DOE take this design options identified in the efficacy. The CSL considered for the T5 approach before, GE stated that DOE screening analysis. In the preliminary HO product class was set according to seems to be going from T5 efficacy analysis, these selections were made the efficacy of this modeled full wattage levels that are relatively easy to meet to such that potential substitutions lamp. efficacy levels that may not even be maintained light output within 10 DOE received several comments technically feasible. (GE, Public Meeting percent of the baseline lamp’s light regarding this approach. NEMA stated Transcript, No. 30 at pp. 125–126) output with similar performance that it could not comment on the In the preliminary analysis, DOE characteristics, when possible. DOE also manufacturability or functionality of the concluded that the higher efficacy level sought to keep other characteristics of T5 HO model lamp put forth in the achieved by reduced wattage T5 HO substitute lamps as similar as possible preliminary analysis because the lamps demonstrated the potential for a to the baseline lamps, such as rated life, product does not exist, and it is poor full wattage lamp to achieve an efficacy CRI, and CCT. In identifying the more practice to invent new products. level above the baseline. Accordingly, efficacious substitutes, DOE utilized a (NEMA, No. 36 at p. 8) NEMA stated DOE modeled the lamp efficacy of a database of commercially available that if DOE is unable to use a higher efficacy full wattage lamp using lamps. DOE received comments commercially available lamp for commercially available reduced wattage regarding its choices for more analysis for this product class it should lamps. DOE acknowledged in the efficacious substitutes in the not pursue an increased efficiency level. preliminary analysis that in determining preliminary analysis. However, in the case that DOE does whether it is appropriate to consider a intend to further regulate this product CSL based on this model lamp, DOE T5 HO Product Class class, NEMA stated DOE should arrange would gather additional information on For the preliminary analysis, in its for the construction and testing of a the manufacturability and functionality assessment of commercially available representative number of this modeled of this lamp, as well as its projected products, DOE was unable to find a full lamp to obtain information on efficacy, when measured according to wattage T5 HO lamp with an efficacy manufacturing feasibility. (NEMA, No. the DOE test procedure. DOE does not higher than the baseline. However, DOE 36 at p. 8–9) Philips agreed, stating that have the necessary information to did find several more efficacious, DOE is designing and inventing new determine whether the higher efficacy reduced wattage T5 HO lamps at higher lamps and it is not known whether they full wattage T5 HO model lamp was levels of efficacy. As discussed in are even feasible. This approach could technologically feasible, and therefore is section VI.D.2.e, DOE is only analyzing potentially result in a product class not considering the higher efficacy efficacy levels that can be met by full where there are no products available. modeled T5 HO lamp in the NOPR wattage lamps. Therefore, in the (Philips, Public Meeting Transcript, No. analysis. preliminary analysis, DOE modeled a 30 at p. 124) As noted previously, in response to more efficacious full wattage T5 HO GE stated it had to get more the stakeholder comments discussed in lamp. Specifically, DOE created a higher information but noted that its engineers section VI.D.2.c, DOE modeled a

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baseline lamp for the NOPR analysis Philips rates their reduced wattage 25 programmed start ballast with 3 hour because the T5 HO product class does and 28 W lamps at 32,000 hours (IS, 3 starts rather than an IS ballast. Therefore not have a commercially available lamp hours per start). ‘‘Extended life’’ lamps the 40–50,000 hour lifetimes cited by that just meets the existing standard. offer even longer rated lifetimes. (NEEP, NEEP do align with the rated lifetimes Because there are full wattage products No. 33 at p. 3) (programmed start, 3 hours per start) of that have demonstrated efficacy higher As noted in section VI.D.2.c, baseline the more efficacious substitutes than the existing standard, DOE believes lamps are selected in part based on the selected. Further, DOE received the modeled baseline lamp is feasible. most common characteristics of their manufacturer feedback during Based on this new baseline, in the respective product classes, and DOE interviews that the lifetime values of the NOPR analysis DOE was able to identify selects more efficacious substitutes with more efficacious substitutes were a more efficacious full wattage T5 HO representative of their respective substitute that is commercially similar performance characteristics as the baseline representative unit when product classes. Therefore, in this NOPR available. The more efficacious T5 HO analysis, DOE is maintaining the same lamps are shown in Table VI.7. possible. Thus, the baseline and more efficacious substitutes selected more efficacious substitutes as selected Lifetime Characteristics represent the most common lifetimes for in the preliminary analysis. DOE NEEP stated that Energy Efficiency each product class. In the case of the 4- requests comment on the rated lifetimes Program Administrators from Efficiency foot MBP product class, DOE found that of the GSFL baselines and more Vermont and National Grid noted that a 24,000 hour lifetime on IS ballasts efficacious substitutes. the rated life values for the lamps DOE with 3 hour starts and a 40,000 hour Summary of GSFL Representative has identified as more efficacious lifetime on programmed start ballasts Lamps substitutes (for 4-foot MBP) are low. with 3 hour starts were the most They specifically pointed out that GE’s common lifetimes for the product class. DOE received no other comments reduced wattage 25 and 28 W lamps and DOE notes that the rated lifetime values regarding the selection of more their high lumen 32 W lamps are all cited by NEEP for GE’s reduced wattage efficacious substitutes for GSFLs. The rated between 40–50,000 hours (instant 25 and 28 W lamps and high lumen 32 GSFL representative lamps analyzed in start [IS], 3 hours per start). Further W lamps represent rated lifetime on a the NOPR are shown in Table VI.7.

TABLE VI.7—GSFL REPRESENTATIVE LAMPS

Nominal Rated Rated Initial light Mean light Life Lamp wattage wattage efficacy output output Product classes EL diameter CRI W W lm/W lm lm hr

4-foot MBP ...... EL 1 ...... T8 32 32.5 90.0 2,925 2,770 21,000 85 EL 2 ...... T8 25 26.6 93.0 2,475 2,350 24,000 85 EL 2 ...... T8 32 32.5 95.4 3,100 2,945 24,000 85 EL 2 ...... T8 28 28.4 96.0 2,725 2,590 24,000 85 8-foot SP slimline .. EL 1 ...... T8 59 60.1 98.2 5,900 5,490 24,000 85 EL 2 ...... T8 59 60.1 99.0 5,950 5,650 24,000 85 EL 2...... T8 54 54.0 105.6 5,700 5,415 24,000 85 EL 2...... T8 50 50.0 108.0 5,400 5,075 24,000 85 8-foot RDC HO ...... EL 1 ...... T8 86 84.0 95.2 8,000 7,600 18,000 78 EL 2 ...... T8 86 84.0 97.6 8,200 7,800 18,000 86 T5 MiniBP SO* ...... EL 1 ...... T5 28 27.8 93.5 2,600 2,418 30,000 85 EL 2 ...... T5 28 27.8 98.2 2,730 2,594 30,000 85 EL 2...... T5 26 26.0 100.0 2,600 2,470 30,000 85 EL 2...... T5 25 25.0 104.0 2,600 2,475 35,000 85 T5 MiniBP HO* ...... EL 1 ...... T5 54 53.8 82.7 4,450 4,275 25,000 85 EL 1 ...... T5 49 49.0 90.8 4,450 4,140 35,000 85 EL 1 ...... T5 47 47.0 91.9 4,320 3,969 30,000 84 * 4-foot T5 MiniBP SO and HO rated efficacy, initial lumen output, and mean lumen output given at 25 °C.

e. General Service Fluorescent Lamp maintain mean lumen output 29 within in which the consumer selects a lamp Systems 10 percent of the baseline system, when that has the same or lower wattage possible. Further, in the preliminary compared to the baseline lamp and also Because fluorescent lamps operate on analysis, DOE selected replacement selects a new ballast with potentially a ballast in practice, in the preliminary systems that do not have higher energy different performance characteristics, analysis, DOE analyzed lamp-and- consumption than the baseline system. such as ballast factor 30 (BF) or ballast ballast systems, thereby more accurately DOE considered two different capturing real-world energy use and scenarios in the preliminary analysis: 30 BF is defined as the output of a ballast light output. In the DOE test procedure (1) A lamp replacement scenario in delivered to a reference lamp in terms of power or for GSFLs, and therefore in this light divided by the output of the relevant reference which the consumer selects a reduced ballast delivered to the same lamp (ANSI C82.13– rulemaking, lamp efficacy is based on wattage replacement lamp that can 2002). Because BF affects the light output of the the initial lumen output. However, operate on the installed ballast and (2) system, manufacturers design ballasts with a range because light output decreases over a lamp-and-ballast replacement scenario of ballast factors to allow consumers to vary the light output, and thus power consumed, of a time, in the preliminary analysis DOE fluorescent system. See the 2011 Ballast Rule final analyzed more efficacious systems that 29 Mean lumen output is a measure of light output rule TSD Chapter 3. The Ballast Rule materials are midway through the rated life of a lamp. Continued

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luminous efficiency 31 (BLE). In the ballast. (See table 8.5.3 of the Philips, Public Meeting Transcript, No. preliminary analysis, for the second preliminary TSD.) The CA IOUs noted 30 at pp. 105–106) scenario DOE attempted to select a that this retrofit results in a 7 percent GE stated that it is not typical to ballast that would result in energy increase in light output and no replace lighting systems lamp for lamp savings and still maintain the mean reduction in energy consumption. If that are more than 10 percent lower in lumen output within 10 percent of the DOE had paired a 0.78 BF ballast with light output unless the space is baseline. In cases where energy savings the more efficacious lamp, the retrofit considered overlit to begin with or the were not possible without going beyond would have resulted in a reduction in space was repurposed. (GE, Public the 10 percent threshold of the baseline light output of only 5 percent, and Meeting Transcript, No. 30 at pp. 90–91) mean lumen output, DOE gave priority would achieve some reduction in energy For a fair comparison between lighting to energy savings. This resulted in the consumption and some energy cost systems, GE recommended that DOE mean lumen output being either 10 savings for the end user. (CA IOUs, No. stay as close as possible to 10 percent percent above or below the baseline 32 at pp. 13–14) and not to go beyond this threshold as lumens for certain lamp-and-ballast In the preliminary analysis, DOE some systems do in the analysis scenarios. considered only commercially available presented. (GE, Public Meeting DOE received several comments ballasts when selecting ballasts to pair Transcript, No. 30 at pp. 119–120) regarding its methodology in identifying with lamps. The CA IOUs suggested a EEI agreed that at this time, retrofits more efficacious lamp-and-ballast ballast with a 0.77 BF for the residential are being done from T8 to T8 and systems, specifically regarding selection 2-lamp instant start replacement electronic ballast to electronic ballast of ballasts, maintenance of mean lumen scenario and a ballast with a 0.78 BF for and therefore lumen depreciation is output within 10 percent of the the 2-lamp programmed start scenario, limited, at most 10 percent versus 20 or baseline, and energy saving options not however, DOE found that these ballasts 30 percent when replacing a T12. EEI explored in the preliminary analysis. do not exist. Because there were no noted that this could make a difference residential 2-lamp instant start low BF in design for a new building and total Ballast Selection ballasts or 2-lamp programmed start low renovations that are meeting building NEMA agreed with the lamp and BF ballasts commercially available that codes. (EEI, Public Meeting Transcript, ballast pairings presented in the would also maintain mean lumen No. 30 at pp. 109–110) EEI preliminary analysis. (NEMA, No. 36 at output within 10 percent of the baseline recommended analyzing equal to or p. 8) However, NEMA also stated that system, DOE was unable to analyze higher lumen output replacement GSFL performance is highly dependent ballasts with lower BFs than those systems to maximize consumer utility in on ballast selection and pairing. NEMA selected for these scenarios. DOE terms of maintaining lumen output in pointed out that NES of lighting systems instead selected the same ballast as the retrofit scenarios. (EEI, Public Meeting will not be affected significantly by this baseline as this was the lowest BF Transcript, No. 30 at p. 121) Cooper proposed rulemaking on GSFL efficacy ballast commercially available. Lighting added that light level is due to the overwhelming influence of important in accurately and correctly ballast selection on final performance. Ten Percent Mean Lumen Output doing a task in a space and the impact (NEMA, No. 36 at p. 1) Threshold of light levels on efficiency in the As mentioned, because fluorescent NEMA explained that in the past it workplace should be given lamps operate on a ballast in practice, was common practice to reduce light consideration. (Cooper, Public Meeting DOE analyzed lamp-and-ballast systems levels by 10 percent or more when Transcript, No. 30 at pp. 110) in the engineering analysis. The impacts retrofitting from a T12 to a T8 lighting The CA IOUs agreed with DOE’s of these systems on NES were analyzed system because older lighting systems analysis of replacement systems that in the NIA. See section VI.I for more were typically designed to higher light maintained mean lumen output within information on the NES of the proposed levels. Over the years, IES light level 10 percent of the mean lumens of the GSFL systems. requirements have been reduced, baseline system. Based on experience The CA IOUs expressed concern especially in office applications where from offering rebate lamps through its regarding some of the replacement the use of computers reduces the need programs, the CA IOUs had found that systems identified, including lamps for high light levels. DOE must analyze nine times out of ten after changing the operating on residential ballasts and the future retrofit situation that will lights in a commercial space, the programmed start ballasts. The CA IOUs occur after 2018 in which 4-foot linear complaints are that it is too bright. The questioned why a residential ballast fluorescent systems will have been CA IOUs asserted that most spaces were with a ballast factor of 0.83 was selected retrofitted to a T8 or better fluorescent not designed exactly to IES standards when DOE could have chosen a ballast system already operating at the but give a little extra light initially. with a lower ballast factor of 0.77 and appropriate lower light levels. Retrofits Additionally, the CA IOUs noted that still stayed within five percent of initial beyond this 2018 time period should be lumen maintenance is a significant issue lumens. (CA IOUs, Public Meeting expected to maintain the new, lower with fluorescent systems, particularly Transcript, No. 30 at p. 253–255) The recommended IES light levels where because the replacement of older T12 CA IOUs also questioned a specific they are already in place. Therefore, systems with newer, more efficacious lamp-and-ballast replacement scenario unlike T12 to T8 conversions, projecting systems makes the space seem even considered in the preliminary analysis further light level reductions of 6 to 14 brighter after a retrofit. The CA IOUs in which a nominal 32 W lamp with an percent as is done in DOE’s analysis further stated that the scenarios where efficacy of 95 lm/W, installed with a cannot be justified against the T8 you increase light output by 5, 8, 12 0.88 BF ballast, replaced a 32 W lamp systems operating in 2018. For a fair percent are not going to work for at 89.2 lm/W, also using a 0.88 BF economic comparison, DOE should seek consumers and reducing light output by to match the existing light levels within 2, 4, 6, 8 percent will still seem too available at www.regulations.gov/ a +/– 5 percent range. (NEMA, No. 36 bright. (CA IOUs, Public Meeting #!docketDetail;D=EERE-2007-BT-STD-0016. at p. 8; GE, Public Meeting Transcript, 31 BLE is the ratio of the total lamp arc power to Transcript, No. 30 at pp. 106–108) ballast input power multiplied by the appropriate No. 30 at pp. 90–91; GE, Public Meeting As stated previously, because light frequency adjustment factor. Transcript, No. 30 at pp. 110–112; output decreases over time, DOE

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analyzed more efficacious systems that more than 10 percent but also reduced wattage. (CA IOUs, No. 32 at pp. 13–14; maintain mean lumen output within 10 energy consumption. Therefore, for NEEA and NPCC, No. 34 at p. 2, 4) The percent of the baseline when possible. certain lamp-and-ballast replacement CA IOUs stated that commercial DOE established the 10 percent scenarios, two ballast selections may occupants are sensitive to changes in threshold based on feedback from exist: (1) A ballast that maintains system workplace lighting, and react negatively manufacturers that, in general, mean lumen output within 10 percent of to light increases. Furthermore, consumers would not notice a change in the baseline; and (2) a ballast that commercial building operators are very light output that is up to 10 percent. achieves energy savings but does not sensitive to operating costs; and will Manufacturers noted during interviews maintain system mean lumen output choose the retrofit option that results in that when a space needs to be relamped, within 10 percent of the baseline. DOE energy cost savings without lumen depreciation has already added this option only if ballasts with significantly reducing the light levels typically occurred and thus lower light the required lower ballast factor were unless the space was known to be levels of a newly installed lamp would commercially available. Thus, it underlit. Therefore, where DOE is likely not be detected. Manufacturers remains possible that certain scenarios presented with a choice between a also noted that while application do not result in energy savings if a lower lighting retrofit that would result in an dependent, designing to achieve energy BF ballast or reduced wattage lamp is increase of light levels between 0–10 savings is common and a decreased not available (e.g., 8-foot RDC HO percent, with no energy savings, and lumen output as a result is generally product class). See chapter 5 of the another that would result in a decrease accepted as long as it is somewhere in NOPR TSD for more information. of light levels between 0–10 percent, the range of 10 percent of the baseline In response to the lamp-and-ballast with energy savings, DOE should model system mean lumen output. DOE system selections presented in the the energy saving option as the most concluded that selecting lamp-and- preliminary analysis, EEI commented likely scenario for consumers. (CA ballast system replacements within 10 that light output was being reduced IOUs, No. 32 at p. 14) percent of the baseline system when between 8 and 13.8 percent. EEI stated The CA IOUs and NEEA and NPCC possible ensures sufficient light levels this is important because even if it is cited the following available options for are maintained and accurately reflects possible to meet the watts per square reducing system wattage without common practices. Therefore, in this requirements in new buildings, the reducing system lumen output by more NOPR analysis, DOE is continuing to lumen output requirements on the than 10 percent: installing reduced utilize the criterion of maintaining 10 surface must also be met by putting in wattage lamps, reducing ballast factors, percent of the mean lumen output when more fixtures. Therefore, EEI argued that delamping, and installing dimming possible in developing lamp-and-ballast system input power calculations ballasts. Though some reduced wattage replacement scenarios. If it was not presented in the preliminary analysis T8 lamps currently have some difficulty possible to identify a lamp-and-ballast may show savings that disappear once dimming as well as their full wattage replacement that maintained the 10 the space is designed to put in more counterparts, this is only an issue for percent mean lumen output criterion, fixtures. (EEI, Public Meeting lamps installed with dimming ballasts. DOE prioritized energy savings and Transcript, No. 30 at pp. 103–105) (Although, they noted that this may be analyzed a lamp-and-ballast system that Philips noted that putting in more improving in the future through the use reduced light output by more than 10 fixtures is not going to help because of dimming ballasts designed to operate fixtures are mainly in the middle of the reduced wattage lamps.) The CA IOUs percent 32 but saved energy relative to room. (Philips, Public Meeting noted that reduced wattage lamps, lower the baseline system. DOE continued to Transcript, No. 30 at pp. 105–106) ballast factor ballasts, or delamping are do this in the NOPR analysis because As noted, for the lamp-and-ballast valid options, when not using a feedback during manufacturer replacement scenarios, DOE attempted dimming ballast. Further even if a interviews confirmed that changes in to select a ballast that would result in dimming ballast is installed, higher mean lumen output outside 10 percent energy savings and still maintain the efficacy (brighter), full wattage lamps of the baseline system are acceptable in mean lumen output within 10 percent of can be installed and tuned to the some applications. the baseline when possible. DOE appropriate light level, which reduces In the preliminary analysis, some determined that maintaining 10 percent system wattage. (CA IOUs, No. 32 at pp. lamp-and-ballast replacement systems of mean lumen output allows for 13–14) maintained light output within 10 changes in lumen output within an The CA IOUs and NEEA and NPCC percent of the baseline system but did acceptable range to the consumer. If this noted that using these measures to not save energy. DOE analyzed these was not possible, DOE prioritized achieve energy savings for the end user lamp and ballast combinations as the energy savings and analyzed a lamp- is a far more likely scenario for a real- only replacement option because they and-ballast system that reduced light world lighting retrofit project. (CA IOUs, met the 10 percent mean lumen output output by more than 10 percent but No. 32 at pp. 13–14; NEEA and NPCC, criterion. For the NOPR analysis, DOE saved energy relative to the baseline No. 34 at p. 2, 4) NEEA and NPCC considered additional scenarios for this system. DOE did not analyze the added that resulting energy cost savings situation based on feedback from installation of additional fixtures due to also help pay for the retrofit, and stakeholders and manufacturer feedback received from stakeholders retrofits may only infrequently result in interviews. DOE added another that spacing adjustments are not increased light levels. (NEEA and NPCC, replacement option in which the practical (for a discussion of this No. 34 at p. 2, 4) consumer could prioritize energy conclusion, see section VI.G.9). DOE acknowledges that consumers savings by selecting a lamp-and-ballast may prioritize energy savings over system that reduced lumen output by Energy Savings Over Light Output maintaining light output in some The CA IOUs and NEEA and NPCC applications. DOE also observes that 32 Light output was reduced up to 18 percent in did not agree with DOE’s consideration several options exist to reduce system some replacement scenarios. The percent reduction in light output was based on the ballast factor of of lamp-and-ballast system wattage while maintaining lumen the commercially available ballasts analyzed. For replacements where the light output output. DOE analyzed reduced wattage more information, see chapter 5 of the NOPR TSD. increases without a reduction in system lamps and low BF ballasts as

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replacement options in the engineering system by pairing a more efficacious class the 2009 Lamps Rule max tech analysis. DOE also analyzed the use of lamp with a commercially available level was 90 lm/W while the dimming ballasts paired with both ballast that had the lowest BF possible preliminary analysis CSL is 98.2 lm/W; reduced wattage and full wattage lamps that still maintained system mean for the T5 MiniBP HO product class the (for applicable product classes) to lumen output within 10 percent of the 2009 Lamps Rule max tech level was 76 achieve energy savings in a lighting baseline system. When multiple ballast lm/W and the preliminary analysis CSL controls scenario conducted as a options with the same BF existed, DOE is 86.2 lm/W. (Lutron, Public Meeting sensitivity in the LCC and NIA. See selected the most efficient ballast based Transcript, No. 30 at pp. 129–130) appendix 6A and chapter 12 of the on the BLE metric, as this was NEEA and NPCC doubted the data used NOPR TSD for further information on considered to be the most likely ballast because CSLs presented were at higher the dimming analysis. substitute in a lamp-and-ballast efficacy levels than the max tech levels In addition to the above mentioned replacement scenario designed to identified in the 2009 Lamps Rule. approaches utilized in the preliminary achieve energy savings. If it was not (NEEA and NPCC, No. 34 at p. 2, 3) analysis, DOE added scenarios in the possible to identify a lamp-and-ballast NEMA also commented that having one NOPR to incorporate the feedback from replacement that maintained the 10 CSL eliminates DOE’s ability to analyze stakeholders that some consumers percent mean lumen output criterion, standard levels other than the baseline would prioritize energy savings over DOE prioritized energy savings and and max tech and makes it more likely increasing or maintaining light output. analyzed a lamp-and-ballast system that that max tech will become the new As discussed previously, for the lamp- reduced light output by more than 10 standard. (NEMA, Public Meeting and-ballast replacement scenarios that percent 33 but saved energy relative to Transcript, No. 30 at p. 350) resulted only in increased light output, the baseline system. NEMA asked for an explanation of DOE added another replacement option In the preliminary analysis, some CSL levels higher than the max tech for this situation in which the consumer lamp-and-ballast replacement systems identified in the 2009 Lamps Rule for could prioritize energy savings by maintained light output within 10 the 8-foot lamps. (NEMA, Public selecting a lamp-and-ballast system that percent of the baseline system but did Meeting Transcript, No. 30 at pp. 12–13) reduced lumen output by more than 10 not save energy. In the preliminary Lutron stated and NEMA concurred that percent but also reduced energy analysis, DOE analyzed these lamp-and- unless there had been major consumption. DOE received feedback ballast combinations as the only technological breakthrough in from manufacturers that maintenance of replacement option because they met fluorescent lamps, adopting standards less than 10 percent of lumen output of the 10 percent mean lumen output more stringent than the max tech levels the baseline system is more likely than criterion. However, in the NOPR identified in the 2009 Lamps Rule increasing lumen output when replacing analysis, DOE added another would not be justified. (Lutron, Public systems in order to achieve energy replacement option for this situation in Meeting Transcript, No. 30 at pp. 129– savings. Thus, DOE added the option for which the consumer could prioritize 130; NEMA, Public Meeting Transcript, a consumer to select a lower BF ballast, energy savings by selecting a lamp-and- No. 30 at pp. 137) Philips and GE if commercially available, that results in ballast system that reduced lumen confirmed that there had been no recent mean lumen output outside 10 percent output by more than 10 percent but also technology changes in fluorescent lamp of the baseline system in order to reduced energy consumption. DOE technology to warrant higher levels provide an energy-saving option if added this option only if ballasts with being considered than the max tech possible. As in the preliminary analysis, the required lower BF were levels identified in the 2009 Lamps DOE did not consider delamping in this commercially available. See chapter 5 of Rule. (Philips, Public Meeting NOPR because manufacturer feedback the NOPR TSD for more information. Transcript, No. 30 at p. 130; GE, Public confirmed that delamping is not DOE welcomes comments on its Meeting Transcript, No. 30 at p. 130– common practice when retrofitting methodology for developing lamp-and- 131) NEMA concluded that because existing T8 systems. ballast systems and as well as the results there have been no noteworthy of these GSFL systems. technological breakthroughs since the Summary last rulemaking or great changes in the f. Maximum Technologically Feasible DOE maintained its overall market, the maximum-feasible methodology from the preliminary DOE received several comments on performance levels of the previous rule analysis for selecting lamp-and-ballast the max tech level presented in the have not changed (NEMA, No. 36 at p. systems with the addition of new preliminary analysis for GSFLs. Lutron 1) replacement options in some scenarios commented that with the exception of GE noted that because the 2009 for the NOPR analysis to incorporate the 4-foot MBP class, CSLs presented in Lamps Rule was moving from relatively stakeholder feedback. To develop the preliminary analysis were higher modest efficiency levels, the discussion representative lamp-and-ballast system than the max tech levels identified in did not center around what lm/W are pairings, DOE used manufacturer the 2009 Lamps Rule. Lutron noted that being reported and what is stated in feedback and information provided in for the 8-foot SP slimline product class catalogs. However, GE noted that in this the 2011 Ballast Rule to determine the the max tech level in the 2009 Lamps rulemaking because the levels being most common fluorescent lamp ballasts. Rule was 98 lm/W while the CSL level considered are at very high levels it is In the preliminary and NOPR analyses, being considered is at 99 lm/W; for the important to consider whether the lm/ DOE paired the representative ballasts 8-foot RDC HO product class the 2009 W numbers are actually achievable. GE utilized in the 2011 Ballast Rule with Lamps Rule max tech was 95 lm/W recommended that for max tech levels the representative lamps selected in this while the preliminary analysis CSL is 97 DOE use test data that show exactly analysis to characterize the most lm/W; for the T5 MiniBP SO product what these products are capable of and common lamp-and-ballast combinations not base levels on marketing claims to present in the market. 33 Light output was reduced up to 18 percent in avoid situations where the established In events where consumers needed to some replacement scenarios. The percent reduction efficacy turns out to be unachievable, in light output was based on the ballast factor of replace both the lamp and the ballast, the commercially available ballasts analyzed. For resulting in the elimination of a product DOE identified a new lamp-and-ballast more information, see chapter 5 of the NOPR TSD. class. (GE, Public Meeting Transcript,

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No. 30 at pp. 144–146) Specifically, GE commercially available lamps were able NEMA recommended revising CSL 1 noted that it was concerned that the to achieve. The baseline represented a to 97 lm/W for the 8-foot SP slimline CSLs presented were based on more standard 800 series full wattage T8 product class, which is equivalent to the aggressive marketing claims in catalogs lamp. CSL 1 (90.0 lm/W) represented an existing standard, in response to the and not on any real change in improved 800 series full wattage T8 preliminary analysis. For the NOPR technology. (GE, Public Meeting lamp in which the phosphor mix and/ analysis, as mentioned previously, DOE Transcript, No. 30 at pp. 138–139) or coating was enhanced to increase selected a new baseline lamp that just DOE identified several commercially efficacy. CSL 2 (93.0 lm/W) represented complies with the existing standard available lamps performing at efficacy an 800 series full wattage T8 high lumen level of 97 lm/W. The baseline level levels higher than the max tech levels lamp able to achieve a higher efficacy represents a less efficient 800 series full established in the 2009 Lamps Rule. with even more advanced phosphors. wattage T8 lamp. DOE then identified Thus, manufacturers appear to be Reduced wattage lamps also met CSL 2. two levels of efficacy above this baseline utilizing more advanced technologies or DOE analyzed publicly available that commercially available lamps are to be more efficiently utilizing existing certification data to determine if any able to achieve. Manufacturer-provided technologies. The efficacy values adjustments were needed to ensure that information in catalogs indicates that provided in manufacturer product proposed levels can be met based on the there are two distinct product lines catalogs and certification data supplied certification data. DOE determined that available with efficacies higher than the by manufacturers indicate that these the representative units and/or baseline product. EL 1 represents a levels are achievable. DOE welcomes equivalent lamps complied with the standard 800 series full wattage T8 comment on the max tech levels CSLs for the 4-foot MBP product class. lamp. EL 2 represents an improved 800 identified in this analysis and more DOE therefore concluded that no series full wattage T8 lamp in which the information on the accuracy of catalog adjustments were necessary in the phosphor mix and/or coating is and certification data. preliminary analysis based on the enhanced to increase efficacy. Reduced available certification data. g. Efficacy Levels wattage lamps also meet EL 2. DOE In response to the preliminary found no adjustments were necessary After identifying more efficacious analysis CSLs, NEMA proposed revising based on certification data and substitutes for each of the baseline CSL 1 to 89 lm/W for the 4-foot MBP established EL 1 at 98.2 lm/W and EL lamps, in the preliminary analysis DOE product class, which is equivalent to the 2 at 99.0 lm/W. developed CSLs based on the existing standard. In the NOPR analysis, For the 8-foot RDC HO product class, DOE continued to identify two levels of consideration of several factors, DOE had put forth CSL 1 at 97.0 lm/W efficacy above the baseline. including: (1) The design options in the preliminary analysis. The Manufacturer-provided information in associated with the specific lamps being baseline represented a 700 series full catalogs indicates that there are two studied (e.g., grades of phosphor for wattage (86 W) T8 lamp, and DOE distinct product lines available with GSFLs); (2) the ability of lamps across identified one level of efficacy above the efficacies higher than the baseline wattages to comply with the standard baseline. CSL 1 represented a shift from 34 products. The baseline level represents level of a given product class; and (3) 700 series to 800 series full wattage T8 a standard 800 series full wattage T8 the max tech level. When evaluating lamps. Based on available certification lamp. In the NOPR analysis, DOE CSLs in the preliminary analysis, DOE data for the 86 W T8 representative unit considered only CSLs at which a full maintained EL 1 (90.0 lm/W) which represents an improved 800 series full and/or equivalent lamps at CSL 1, DOE wattage version of the lamp type was adjusted CSL 1 from 97.6 lm/W to 97.0 available because reduced wattage wattage T8 lamp. DOE also maintained EL 2 (93.0 lm/W) which represents an lm/W for 800 series full wattage T8 lamps have limited utility. DOE lamps. received several comments on the CSLs 800 series high lumen output full wattage T8 lamp and the 25 W and 28 In response to the CSL proposed in considered in the preliminary analysis. the preliminary analysis for the 8-foot NEMA recommended revisions to the W reduced wattage lamps. DOE RDC HO product class, NEMA suggested CSLs presented in the preliminary analyzed available certification changing CSL 1 to 94 lm/W. DOE analysis. Specifically, NEMA proposed information and found that EL 1 did not revised its analysis for the NOPR and a level at 89 lm/W for the 4-foot MBP need to be adjusted from 90.0 lm/W. modeled a baseline that just met the product class, 97 lm/W for the 8-foot SP DOE adjusted EL 2 from the preliminary existing standard level of 92 lm/W, as slimline product class, 94 lm/W for the analysis value of 93.0 lm/W to 92.4 lm/ described in section VI.D.2.c. DOE then 8-foot RDC HO product class, 90 lm/W W based on additional certification data. identified two levels of efficacy above for the 4-foot T5 MiniBP SO product DOE considered one CSL for the 8- the baseline level. EL 1 now represents class, and 80 lm/W for the 4-foot T5 foot SP slimline product class at 99.0 a 700 series full wattage T8 lamp with MiniBP HO product class. (NEMA, No. lm/W in the preliminary analysis. The basic coating, gas composition, and 36 at p. 9) Further, in reference to T5 baseline represented a standard 800 phosphor mix. EL 2 represents a shift to lamps, NEMA noted that regardless of series full wattage T8 lamp, and DOE an 800 series full wattage T8 lamp. DOE whether DOE had presented CSLs at 25 identified one level of efficacy above the again analyzed publicly available °C or 35 °C, the efficacies of the baseline. CSL 1 represented an certification data and determined that analyzed products are too high to serve improved 800 series full wattage (59 W) EL 1 should be adjusted from 95.2 lm/ as representative products. (NEMA, No. T8 lamp in which the phosphor mix and/or coating is enhanced to increase W to 94.0 lm/W for 700 series full 36 at p. 10) wattage T8 lamps based on available In the preliminary analysis, DOE efficacy. Reduced wattage lamps also certification data. EL 2 was not adjusted considered two CSLs for the 4-foot MBP met this CSL. DOE determined through based on available certification data and product class. DOE found two levels of publicly available compliance reports remains 97.6 lm/W. DOE notes that this efficacy above the existing standard that that the 54 W representative unit and/ or equivalent lamps complied with CSL level representing the 800 series design option in the preliminary analysis 34 ELs span multiple lamps of different wattages. 1. Thus, DOE concluded that no In selecting CSLs, DOE considered whether these adjustment was necessary to CSL 1 in (previously CSL 1) was adjusted to 97.0 multiple lamps can meet the ELs. the preliminary analysis. lm/W; however, based on additional

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certification data, an adjustment is not modeled a more efficacious full wattage NEMA stated that if the efficacy level at necessary. lamp. DOE determined through publicly CSL 2 for the 4-foot MBP lamp can be In the preliminary analysis, DOE had available compliance reports that the achieved only with more efficient considered one CSL at 98.2 lm/W for the commercially available reduced wattage krypton-filled (i.e., reduced wattage) 4-foot T5 MiniBP SO product class. The representative units and/or equivalent fluorescent lamps, it will come at the baseline represented an 800 series full lamps complied with CSL 1. Therefore, cost of reliable dimming that will have wattage (28 W) T5 lamp with basic DOE did not adjust the initial CSL an impact on energy savings compared coating, gas composition, and phosphor considered for this product class. to the baseline. Lutron stated that the mix. CSL 1 represented an improved For the T5 MiniBP HO product class, full wattage lamps in both the T8 and 800 series full wattage T8 lamp in NEMA suggested revising CSL 1 to 80 T5 categories are the only ones for which the phosphor mix and/or coating lm/W. DOE agrees with NEMA that which there are dimming standards in was enhanced to increase efficacy. there is only one level of efficacy above the industry. Lutron expressed concern Reduced wattage lamps also met this the baseline level for this product class; that the CSLs being considered by DOE level. DOE then compared the however, performance based on would eliminate full wattage lamps and certification data to the initial efficacy commercially available lamps that would result in a loss of significant level at 25 °C to determine if corresponded to 76 lm/W. DOE revised energy savings, not just the theoretical adjustments were necessary. DOE its analysis for the NOPR and modeled energy savings associated with the lamp determined through publicly available a baseline that just met the existing efficacy, which may or may not result in compliance reports that the standard level of 76 lm/W, as described any actual energy savings in buildings. representative unit and/or equivalent in section VI.D.2.c. The baseline level (Lutron, Public Meeting Transcript, No. lamps complied with CSL 1. Therefore, represents a less efficient full wattage 30 at pp. 133–134) NEMA strongly DOE did not adjust the initial CSL (54 W) lamp. Manufacturer-provided cautioned DOE to bear in mind that considered for this product class. information in catalogs indicates that reduced wattage lamps are often NEMA recommended revising CSL 1 there is one distinct product line ‘‘energy saver’’ models, which lack the to 90 lm/W for the 4-foot T5 MiniBP SO available with efficacy higher than the robust performance of full wattage product class. DOE updated its analysis baseline product. EL 1 represents an 800 models. Full functionality for dimming, for the NOPR and modeled a baseline series full wattage T5 lamp with basic a desirable characteristic, is typically that just met the existing standard level coating, gas composition, and phosphor only available in full wattage models. of 86 lm/W, as described in section mix. Reduced wattage lamps also meet (NEMA, No. 36 at p. 11) VI.D.2.c. The baseline level represents a this level. DOE did not adjust this level DOE acknowledges that there are less efficient full wattage (28 W) lamp. based on certification data and is limitations with using reduced wattage Based on a review of commercially therefore evaluating EL 1 at 82.7 lm/W. available products, DOE then identified NEMA commented that having one fluorescent lamps. DOE received two levels of efficacy above the baseline CSL eliminates DOE’s ability to analyze feedback during manufacturer level at which lamps were consistently standard levels other than the baseline interviews that reduced wattage lamps performing. Manufacturer-provided and max tech and makes it more likely cannot act as replacements for full information in catalogs indicates that that max tech will become the new wattage lamps in all applications, particularly in cold temperature there are two distinct product lines standard. (NEMA, Public Meeting ° available with efficacies higher than the Transcript, No. 30 at p. 350) EEI also applications below 60–65 F. baseline product. EL 1 represents an 800 expressed concern that besides the 4- Manufacturers also noted that striations series full wattage T5 lamp with basic foot MBP product class, only one CSL remain an issue for reduced wattage coating, gas composition, and phosphor was being considered for all other lamps because not all ballasts contain mix. EL 2 represents an improved 800 product classes which was also striation control circuitry, and those series full wattage T8 lamp in which the representative of the max tech level equipped with striation control circuitry phosphor mix and/or coating is based on the criteria that full wattage do not completely eliminate striation. enhanced to increase efficacy. Reduced lamps had to meet every CSL being Further, manufacturers identified issues wattage lamps also meet this level. DOE considered. EEI further noted that it was with dimming reduced wattage lamps found that no adjustments were not aware of any other rulemaking indicating that these lamps dim necessary for EL 1 and therefore where no other levels were proposed unreliably in certain applications. established EL 1 at 93.5 lm/W. For EL between the baseline and max tech. Manufacturers noted that problems 2 representing improved 800 series full (EEI, Public Meeting Transcript, No. 30 encountered with dimming linear wattage T8 lamps, DOE adjusted EL 2 at pp. 124, 135–137) fluorescent lamps, including lamp from 98.2 lm/W to 97.1 lm/W based on As described in the preceding starting, striations, and dropout, are additional certification data. paragraphs, DOE revised its engineering exacerbated by the use of krypton in In the preliminary analysis, DOE analysis for the NOPR analysis. DOE reduced wattage lamps (see section considered one CSL for the 4-foot T5 surveyed the market, analyzed product VI.C.1 for more information). Therefore, MiniBP HO product class at 86.2 lm/W. catalogs, and took into account feedback DOE has continued to ensure that full The baseline represented an 800 series from manufacturers to develop ELs. wattage lamps can meet all ELs under full wattage (54 W) T5 lamp with basic Based on this assessment, DOE consideration in this NOPR analysis. coating, gas composition, and phosphor identified varying levels of efficacy that For the NOPR analysis, DOE used mix. CSL 1 represented reduced wattage reflected technology changes and met updated catalog and certification data, lamps, including 50 W T5 and 47 W T5 the criteria for developing ELs outlined which resulted in slightly different ELs lamps, or an improved 800 series full above. In the NOPR, DOE is considering than those considered in the wattage T8 lamp in which the phosphor two ELs in each product class with the preliminary analysis. The ELs for the mix and/or coating is enhanced to exception of the T5 MiniBP HO product representative product classes of GSFLs increase efficacy. Because there were no class. are presented in Table VI.8. For further commercially available full wattage DOE also received several comments information on the development of ELs, higher efficacy replacements for the 4- regarding full wattage lamps meeting please refer to chapter 5 of the NOPR foot T5 MiniBP HO baseline lamps, DOE efficacy levels under consideration. TSD. DOE welcomes comments on the

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methodology used to develop ELs for GSFLs as well as on the ELs.

TABLE VI.8—SUMMARY OF ELS FOR GSFL REPRESENTATIVE PRODUCT CLASSES

Efficacy level CCT Lamp type lm/W 1 2

≤4,500 K ...... 4-foot MBP ...... 90.0 92.4 8-foot SP slimline ...... 98.2 99.0 8-foot RDC HO ...... 94.0 97.6 4-foot T5 MiniBP SO ...... 93.5 97.1 4-foot T5 MiniBP HO ...... 82.7 N/A

h. Scaling to Other Product Classes CCT lamps set by the 2009 Lamps Rule Finding substantial variation in the was a significant error in the analysis. percent reduction in efficacy associated As noted previously, DOE analyzes NEMA stated that because of the with increased CCT among product the representative product classes resulting high lm/W target for the 4-foot classes, DOE is proposing a separate directly. DOE then scales the levels MBP lamps, the T8 tri-phosphor 6,500 scaling factor for each product class. developed for the representative K products were almost eliminated from DOE is proposing to maintain a 2 product classes to determine levels for the market. Further, NEMA asserted that percent scaling factor for the 4-foot MBP product classes not analyzed directly. when the waiver of standards for 700 product class in order to ensure that any For GSFLs, the representative product series lamps is lifted this product may proposed level does not allow for more classes analyzed were all lamp types be eliminated because manufacturers energy use than the current minimum with CCTs ≤4,500 K, with the exception may not be able to reliably meet current standard.35 Based on its assessment, of 2-foot U-shaped lamps. For the 2-foot regulations for the high CCT products. DOE is proposing a 3 percent scaling U shaped product class DOE scaled the (NEMA, No. 36 at pp. 12–13) factor for the 2-foot U-shaped product efficacy levels developed for the 4-foot GE stated that the 2 percent decrease class, 5 percent for the 8-foot SP MBP product class. for the high chromaticity lamps is slimline product class, 2 percent for the Therefore, efficacy levels developed probably accurate. (GE, Public Meeting 8-foot RDC HO product class, 6 percent for lamp types with CCTs less than or Transcript, No. 30 at pp. 153–154) for the T5 SO product class, and 5 equal to the 4,500 K were scaled to NEMA recommended a scaling factor percent for the T5 HO product class. obtain levels for higher CCT product that allows a decrease of at least 7 DOE also verified the scaling factors classes not analyzed. In the preliminary percent to accommodate the average developed against certification data. analysis, DOE developed this scaling performance of the higher CCT’s. These Further, DOE confirmed that lamps with factor by identifying pairs of the same highly efficient high CCT families of CCT greater than 4,500 K will meet the lamp type manufactured by the same products have been growing in scaled levels. See chapter 5 of the NOPR manufacturer, within the same product importance and sales in recent years TSD for more information on CCT family, and differed only by CCT. DOE due to results from studies (i.e., IESNA scaling. DOE welcomes comments on determined the average difference in TM–24) indicating that lighting that has the scaling factors developed to scale efficacy between these lamp pairs to be more blue component actually provides GSFL product classes from the less than 2 percent. DOE received several for better visual capabilities, especially or equal to 4,500 K CCT lamps to the comments on this approach and for the aging population. NEMA stated greater than 4,500 K CCT lamps. resulting scaling factor. that this has resulted in a noticeable 2-Foot U-Shaped Scaling CCT Scaling shift in the market to >4,500 K products. Any increase in the lm/W requirements NEMA stated that the scaling factor NEMA stated that the 2 percent for the >4,500 K lamps will eliminate for 2-foot U-shaped lamps of 2 percent decrease for lamps with CCT >4,500 K some, and possibly all, of these higher is too small. Because no technology is insufficient to reflect the actual drop performing high CCT lamps in the changes or improvements have been in lm/W that occurs. NEMA stated it is remaining classifications. While the made to U-shaped lamps during the past well known in the industry that as CCT prior ruling may have already destined three years, NEMA recommended increases above 4,500 K, the lumen the elimination of the 6,500 K tri- remaining consistent with the 2009 output and consequently the lm/W phosphor 4-foot T8–T12 linear Lamp Rule scaling factor and use 6 continues to decrease. Actual classification of GSFLs, there is still the percent. NEMA added that the performance data for the common opportunity to protect the 5,000 K tri- efficiency of these lamps cannot be F32T8 5,000 K tri-phosphor lamps phosphor family of lamps by not significantly, feasibly raised, so the indicates the decrease in lm/W to be in changing the lm/W targets for this minimum efficiency of these products the 4–6 percent range and in the 6–8 group. (NEMA, No. 36 at pp. 12–13) should remain 84 lm/W. (NEMA, No. 36 percent rage for an F32T8 6,500 K tri- Based on comments received from at p. 12) GE noted there are some phosphor lamp. NEMA noted that this stakeholders and feedback in confounding factors for which DOE reduction in lm/W at >4,500 K CCT manufacturer interviews, DOE needs to account if the scaling factor becomes more significant for higher reassessed the scaling analysis for the analysis for the 2-foot U-shaped class is targets of lm/W. (NEMA, No. 36 at pp. higher CCT lamps. DOE examined the 12–13) differences in efficacies between lower 35 Current standards for the 4-foot MBP product ≤ NEMA also noted that the 1 percent and higher CCT lamps in each product classes are 89 lm/W for CCT 4,500 K and 88 lm/ W for CCT >4,500 K. Because the difference reduction from the 4-foot MBP product class based on performance data between existing standards is small, the allowable class with ≤4,500 K CCT to the higher provided in manufacturer catalogs. scaling factor is restricted to 2 percent.

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based on catalog data and even year relief would provide time for are one way to help do so. Additionally, manufacturer to manufacturer data. GE potential development of additional the CA IOUs stated that for a specific stated that efficacy difference was more supplies outside of China, for progress product type, manufacturers are likely in the 4–6 percent range as in technology advancements and accustomed to designing to a wattage opposed to what is found in catalog development of alternative technologies because that is what consumers are used data. (GE, Public Meeting Transcript, that use lesser amounts of rare earth to (e.g., designing to 50 W regardless of No. 30 at p. 154) material, and for the expansion of the product efficacy), which produces a DOE reassessed the scaling analysis recycling and reclamation initiatives.36 volume of products giving more or less for 2-foot U-shaped lamps based on DOE understands a constrained supply light. However, the CA IOUs asserted comments received. In the preliminary of rare earth phosphors may have that efficacy should be improved by analysis, DOE had based its scaling impacts on the production of higher reducing wattage rather than increasing assessment on lamp performance data efficiency fluorescent lamps. DOE also light output. (CA IOUs, Public Meeting found in catalogs. However, DOE acknowledges that supply and demand Transcript, No. 30 at pp. 45–48) revised its analysis to utilize of rare earth phosphors should continue EEI, however, noted that the wattage certification data for the NOPR based on to be considered when evaluating equivalency provided on packaging is feedback received from manufacturers amended standards for GSFLs. Thus as useful to the consumer. They noted that indicating that confounding factors exist in the preliminary analysis, for this the standards are in lumens per watt, that are not reflected in catalog data. By NOPR analysis DOE is considering a which is a formula that provides a comparing certification data for 2-foot scenario of increased rare earth requirement for lamps to be more U-shaped lamps with equivalent 4-foot phosphor prices in the LCC and NIA. efficient on an efficacy, rather than MBP lamps, DOE determined an average See appendices 7B and 9B of the NOPR wattage, basis. However, especially for efficacy reduction of 6 percent for the 2- TSD for more information. incandescent lamps, packaging stating foot U-shaped lamps from the 4-foot that the 72 W halogen lamp is equal to MBP lamps was appropriate. DOE 3. Incandescent Reflector Lamp an old 100 W incandescent lamp lets confirmed that the technology impacts Engineering consumers know what they are getting, of the scaled ELs for the 2-foot U-shaped For IRLs, DOE received comments on including the associated light output. lamps were consistent with those of the the engineering analysis presented in Otherwise, as historically higher watts proposed ELs for the 4-foot MBP the preliminary TSD. Stakeholders produce higher lumens, consumers product class. See chapter 5 of the provided feedback on the metric used to would be confused, especially with NOPR TSD for more information on 2- measure IRL efficacy, as well as CFLs and LED lamps. (EEI, Public foot U-shaped scaling. DOE welcomes feedback on DOE’s representative Meeting Transcript, No. 30 at pp. 48–50) comments on the scaling factor product classes, selection of more Energy conservation standards must developed to scale from the 4-foot MBP efficacious substitutes, baseline lamps, prescribe either a minimum level of product class to the 2-foot U-shaped max tech level, CSLs, scaling, and energy efficiency or a maximum product class. proposing standards for IRLs. The quantity of energy use, where the former is a ratio of the useful output of services i. Rare Earth Phosphors following sections summarize the comments and responses received on to the energy use of the product. 42 NEMA restated its support of previous these topics, and present the IRL U.S.C. 6291(5)(6) The existing standard submitted comments of its concerns engineering methodology for this NOPR for IRLs is a lumens per watt, or lamp regarding the rare earth phosphor issue. analysis. efficacy, metric. Setting a standard (NEMA, No. 36 at p. 14) NEMA asked based on lumens alone would not how the analysis accounts for the a. Metric capture the efficiency of the product nor current shortage of rare earth elements Existing IRL standards are based on allow for a true comparison of efficiency and the existing practice of waivers and lamp efficacy measured as the lumen across lamp wattages. By relating the further how these factors impact output of the lamp per watt supplied to input power to the light output, this compliance capability. (NEMA, Public the lamp. Further, the scope of coverage metric appropriately measures the Meeting Transcript, No. 30 at pp. 131– for existing IRL standards includes efficiency of the lamp. 132) NEMA recommended the DOE Regarding setting standards that lamps that are equal to or greater than confer with Dr. Alan King of the Critical would drive manufacturers to meet 40 W and less than or equal to 205 W. Materials Institute of the AMES energy conservation standards by (See section V.C for further information Laboratories to fully understand and reducing wattage and not increasing on IRL scope.) Noting that wattage is a predict the availability of critical light output, DOE standards do not aim factor in defining the scope of IRLs materials, including rare earth elements. to favor any one design pathway for covered, The CA IOUs recommended He observed to the NEMA Lighting achieving energy efficiency and saving moving in the direction of lumen-based Systems Division recently that once a energy. DOE employs an equation that standards because lumens are useful to material becomes critical, it tends to relates lumens to wattage and sets a a consumer, whereas watts are no longer stay critical, with fluctuations, but no minimum efficacy requirement across a useful metric. For example, the CA slacking of demand/criticality until the all wattages for IRLs. This power law IOUs noted that lamp packaging that product demand disappears altogether. equation captures the potential efficacy says that the lamp’s rated 55 W equals (NEMA, No. 36 at p. 14) using a particular design option for all DOE notes that manufacturers, in 70 W does not make sense. The CA wattages. DOE acknowledges that their applications for exception relief, IOUs recommended that in general, manufacturers may choose to increase stated that they expected an DOE should do as much as possible to lumen output rather than decrease improvement in the rare earth market, help shift discourse to be lumen-based wattage to meet the minimum efficacy specifically noting that supplies of key instead of wattage-based, and standards requirement. Therefore, the engineering rare earth phosphors used in fluorescent analysis considers energy-saving 36 Philips Lighting Company, et al. OHA Case lamps will become more equal to Nos. EXC–12–0001, EXC–12–0002, EXC–12–0003 options. Further, lumen outputs that are estimated demand beginning in 2014. (2012). Accessible here: http://energy.gov/sites/ not within 10 percent of the baseline Manufacturers also stated that the two- prod/files/oha/EE/EXC-12-0001thru03.pdf. lumens are not considered in the

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analysis. (See chapter 5 of the NOPR appropriate measure of the energy IRLs, in the preliminary analysis DOE TSD for further details on the efficiency of IRLs and DOE considers identified standard spectrum lamps, engineering analysis.) The NIA energy savings when developing with diameters greater than 2.5 inches, considers all available options for efficacy levels, DOE is not proposing to and input voltage less than 125 V as the consumers in choosing IRLs. (See change this metric for IRLs in this representative product class, shown in section VI.J and chapter 12 of the NOPR rulemaking. gray in Table VI.9. NEMA agreed with TSD.) b. Representative Product Classes the representative product classes DOE acknowledges consumer presented for IRLs. (NEMA, No. 36 at p. understanding of the relationship When a product has multiple product 7) DOE did not receive any other between watts and lumens could be classes, DOE identifies and selects comments regarding representative improved through labeling and certain product classes as representative marketing of lamps. However, this is not and analyzes those product classes product classes for IRLs. In this NOPR, within the scope of DOE’s authority in directly. DOE chooses these DOE is maintaining the same IRL this rulemaking. Therefore, because the representative product classes primarily representative product classes as lumens per watt metric is an due to their high market volumes. For presented in the preliminary analysis.

TABLE VI.9—IRL REPRESENTATIVE PRODUCT CLASSES

Diameter Lamp type (in inches) Voltage

Standard spectrum ...... >2.5 ≥125 * <125 ≤2.5 ≥125 <125

Modified spectrum ...... >2.5 ≥125 <125 ≤2.5 ≥125 <125 * Representative.

c. Baseline Lamps The CA IOUs and NEEA and NPCC what the market ‘‘might’’ be, DOE stated that DOE should use only one should simply employ the baseline Once DOE identifies representative baseline lamp which should have an selection criteria from the 2009 Lamps product classes for analysis, it selects efficacy that just meets the current IRL Rule and use the standard from that baseline lamps to analyze in each standards, and it should provide the rulemaking as the baseline. (NEMA, No. representative product class. Typically, minimum lamp life expected of these 36 at p. 7) NEMA stated that the a baseline lamp is the most common, products. (CA IOUs, Public Meeting arguments for baseline, CSL 0 in the least efficacious lamp that meets Transcript, No. 30 at p. 163; CA IOUs, preliminary TSD, are based on existing energy conservation standards. No. 32 at p. 2; NEEA and NPCC, No. 34 predictions of market shift that To identify baseline lamps, DOE at pp. 2, 4–5) The Joint Comment stated erroneously justify a new baseline reviews product offerings in catalogs, that DOE must select the least higher than the minimum requirements shipment information, and efficacious lamp meeting current put forth by the 2009 Lamps Rule. manufacturer feedback obtained during conservation standards as its baseline (NEMA, No. 36 at p. 1) interviews. For IRLs, the most common for IRLs. (Joint Comment, No. 35 at p. The CA IOUs, NEEA and NPCC, and lamps were determined based on 2) ASAP also stated that DOE should GE agreed that the true baseline is the characteristics such as wattage, not consider two baselines and pointed less efficient product with the shorter diameter, lifetime, lumen package, and out that typically, a baseline is the lifetime (i.e., the 60 W halogen lamp efficacy. commercially available product with the with a 1,500-hour lifetime). (CA IOUs, In the preliminary analysis, DOE lowest efficiency. ASAP provided the Public Meeting Transcript, No. 30 at p. identified a PAR38 lamp as the most example of a dishwasher rulemaking, 163; NEEA and NPCC, No. 34 at p. 5; prevalent lamp shape and diameter in where the most common dishwasher GE, Public Meeting Transcript, No. 30 at the representative product class. From was an ENERGY STAR compliant pp. 159–161) The CA IOUs and the Joint all PAR38 lamps with the most common product. As this product was above the Comment noted that the 60 W halogen characteristics, DOE selected two lamps minimum of the last standard, the lamp with a 1,500-hour lifetime is that just met existing standards as previous standard itself was used as the representative of the minimum baselines. One was a 60 W halogen lamp baseline. Thus, using the most common performance that is compliant with July with a lifetime of 1,500 hours that product is different than using the least 2012 standards, which require an utilized a higher efficiency inert fill gas efficient product available. (ASAP, efficacy of 17.8 lm/W for a 60 W lamp. and a higher efficiency reflector coating, Public Meeting Transcript, No. 30 at p. (CA IOUs, No. 32 at p. 2; Joint and had an efficacy right at the existing 158) Comment, No. 35 at p. 2) standard, 5.9P 0.27. The other was a 60 NEMA also disagreed with two The CA IOUs, NEEA and NPCC, the W HIR lamp with a lifetime of 3,000 baselines for IRLs, stating that the two Joint Comment, and GE also agreed that hours that utilized IR glass coatings and baseline products being compared are the 60 W HIR lamp with a 3,000-hour had an efficacy very close to the existing not identical, and a dual-baseline will lifetime was not a baseline lamp standard. DOE received several eliminate a product class. NEMA further because it was using more advanced comments on its selection of two recommended that rather than expend technology. (CA IOUs, No. 32 at pp. 2– baselines for IRLs. numerous resources trying to interpolate 3; NEEA and NPCC, No. 34 at pp. 2, 4–

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5; Joint Comment, No. 35 at p. 2) The lifetime to 1,000 hours. (CA IOUs, No. commercial. (EEI, Public Meeting CA IOUs, ASAP, and NEEA and NPCC 32 at p. 2) Transcript, No. 30 at pp. 163–164) EEI noted there is a trade-off between DOE reviewed product offerings in also asked how the baseline lifetime and efficacy in incandescent catalogs, shipment trends, and characteristics put forth in the lamp designs and absent other design information obtained during preliminary analysis compared to those improvements, an increase in lamp life manufacturer interviews to identify the in the marketplace in terms of what is results in a decrease in efficacy, and common characteristics of lamps that actually being sold using 2012 or 2013 vice versa. (CA IOUs, No. 32 at pp. 2– meet standards. Based on DOE’s data. (EEI, Public Meeting Transcript, 3; ASAP, Public Meeting Transcript, No. analysis, the 1,500-hour lamps are much No. 30 at p. 157) Noting that it was 30 at p. 159; NEEA and NPCC, No. 34 more common than other lower lifetime difficult to determine where a lamp at pp. 4–5) Because the second lamp lamps, including 1,000-hour lamps, going through distribution channels proposed as a baseline lamp in DOE’s among the covered IRLs. Therefore, DOE such as Home Depot or Lowe’s ends up, analysis has a longer life and a higher is proposing a 1,500-hour lamp as the NEEA asked how DOE determines efficacy, it clearly includes some other baseline. which lamps are in the residential advanced design features that have Stakeholders also commented on sector and which are in the commercial allowed for improved performance in whether it was necessary to have sector (e.g., by distribution channel or both metrics. (CA IOUs, No. 32 at pp. 2– different lamp lifetimes for different socket). (NEEA, Public Meeting 3) The Joint Comment added that if the sectors. GE stated that the consumer Transcript, No. 30 at p. 164) NEMA lifetime of the second baseline lamp was market, which does not necessarily need asked if the 2010 LMC contained data reduced to 1,500 hours to allow for an the long lifetime, is looking for a less on sockets in specific sectors so as to accurate comparison to the first baseline expensive opening price point. determine what percentage of those tend lamp, its efficacy would be even greater However, the 60 W HIR with the 3,000- to be the higher technology. (NEMA, than 18.3 lm/W. (Joint Comment, No. 35 hour lifetime would be sold to a Public Meeting Transcript, No. 30 at pp. at p. 2) Further, the CA IOUs and NEEA commercial customer who is more 165–166) and NPCC pointed out that the higher concerned about long operating hours ASAP agreed that the market is cost of the HIR lamp indicated that it and does not want to replace lamps important but noted that it is factored was a more technologically advanced frequently. Therefore, the commercial into the downstream analyses. ASAP product than the halogen lamp. (CA consumer will gravitate more towards provided an example that if 100-percent IOUs, No. 32 at pp. 2–3, NEEA and the higher technology lamp, trying to of commercial shipments are already at NPCC, No. 34 at pp. 2, 4–5) reduce maintenance costs. (GE, Public this level, then this will be reflected in The CA IOUs also noted that Meeting Transcript, No. 30 at pp. 159– the shipments analysis and it would minimum product performance 161) flow through to the LCC and NIA, rather generally gravitates towards the The CA IOUs disagreed that a shorter than be built into the baseline. (ASAP, minimum standards set for a product lifetime lamp was appropriate for only Public Meeting Transcript, No. 30 at pp. and such IRL products are on the the residential sector and a longer 162–163) market. Therefore, the CA IOUs lifetime lamp for the commercial sector. DOE acknowledges that different contended it is inaccurate to define a They stated that products with shorter lamps may be popular in different baseline product that is higher than the lifetimes are commonly marketed and market sectors. The 2010 LMC provides minimum standard. (CA IOUs, No. 32 at sold into various market segments, data on the inventories of halogen p. 2) ASAP further added that by including the commercial sector. They reflector lamps in each sector. However, introducing the 60 W HIR, 3,000-hour provided the examples of Halco because there is nothing that would lifetime lamp as a baseline, DOE took Haloxen SPAR Series product line and limit the use of a covered IRL in a that first, most cost effective the Satco Xenon Halogen line,37 both of specific sector, DOE does not conduct improvement and averaged it into the which are standards-compliant 1,500- sector-based assessments in the baseline. (ASAP, Public Meeting hour life lamps specifically marketed for engineering analysis. Rather, the LCC Transcript, No. 30 at p. 161) use in the commercial sector. According and NIA consider lamp use in different DOE recognizes that the HIR baseline to the CA IOUs, this suggests that the market sectors. The LCC analysis lamp with the longer lifetime shorter lifetime products (1,000–1,500 provides results for each analyzed lamp considered in the preliminary analysis hours) are appropriate to represent the in each relevant sector. The shipments is using more advanced technology than baseline lamp for both the residential analysis accounts for the number of the halogen baseline lamp. Therefore, in and commercial sectors. (CA IOUs, No. shipments by sector and the popularity this NOPR, DOE is not proposing to 32 at p. 2) NEEA and NPCC added that of analyzed lamps in each sector. The analyze the 60 W HIR lamp with a both the 60 W halogen lamp with a results are subsequently used in the NIA 3,000-hour lifetime as a baseline lamp. 1,500-hour lifetime and the 60 W HIR analysis. Please see section VI.J for more DOE is proposing one baseline lamp with a 3,000-hour lifetime can be detail. represented by the 60 W halogen lamp found at typical do-it-yourself (DIY) with a 1,500-hour lifetime. stores and in commercial lamp catalogs. Summary of IRL Baseline Lamps The CA IOUs noted that, historically, (NEEA and NPCC, No. 34 at p. 5) DOE is proposing the baseline lamp many reflector lamps have been offered Several stakeholders asked for further for IRLs specified in Table VI.10. For with a minimum lifetime of 1,000 hours, information about the market share further information, please see chapter 5 and generally no fewer. Therefore, DOE breakdown of these lamps by sector. EEI of the NOPR TSD. DOE requests could even more accurately represent asked about the percentage of the IRL comments on its selection of baseline the baseline by lowering the baseline market that is residential versus lamps for IRLs.

37 More information on these lamps is provided in the written comment available on regulations.gov under docket number EERE–2011–BT–STD–0006.

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TABLE VI.10—IRL BASELINE LAMP

Baseline lamp Initial Representative product class Lamp Wattage Efficacy light Lifetime type Descriptor output W lm/W lm hr

Standard Spectrum, Voltage <125 V, Diameter PAR38 Improved Halogen...... 60 17.8 1,070 1,500 >2.5 Inches.

d. More Efficacious Substitutes by increasing current, but if no other believes that lifetime is a feature valued DOE selects more efficacious design options are employed, the lamp by consumers. DOE believes typical replacements for the baseline lamps will have a shorter lifetime. On the lifetimes of IRLs regulated by this considered within each representative other hand, decreasing current can rulemaking are between 1,500 and 4,400 increase lamp lifetime, but if no other product class. DOE considers only hours. The longest lifetime products are design changes are made, the resulting design options identified in the available at EL 1, the highest analyzed product would have a reduced efficacy. screening analysis. In the preliminary efficacy level in this NOPR analysis. The CA IOUs also put forth a analysis, DOE considered substitute While manufacturers can choose to relationship where life = life0 × {lpw/ introduce shorter lifetime products in lamps that saved energy and, where ¥ lpw0} 7.1 to show that the efficacy of a possible, had a light output within 10 the future, DOE does not require lamp could be improved at the expense percent of the baseline lamp’s light shortening of lamp lifetime to meet any of lamp life rather than investment or output. In identifying the more analyzed level. improvement in the lamp design.38 (CA efficacious substitutes, DOE utilized a In the preliminary analysis, DOE had IOUs, No. 32 at pp. 3–4) put forth a representative lamp with a database of commercially available DOE recognizes that there is an 4,400-hour lifetime and improved HIR lamps. In the preliminary analysis, DOE inverse relationship between efficacy technology as the more efficacious identified a higher efficacy, lower and lifetime for IRLs. The engineering substitute. For the NOPR analysis, after wattage lamp, referred to in this analysis analysis focuses on commercially reassessing updated catalog and as an improved HIR lamp with a available products. DOE is aware that to compliance information, DOE identified lifetime of 4,400 hours, as a more meet higher efficacy levels, an alternative representative lamp that efficacious substitute for the two manufacturers can choose to produce better reflected the minimum efficacy baseline lamps. DOE received several lamps with a shorter lifetime than the comments regarding its choice for a baseline lamp to achieve higher efficacy. level for lamps with improved HIR more efficacious substitute. Given that manufacturers responded to technology. This representative lamp ASAP expressed concern that two the July 2012 standards by introducing has a lifetime of 4,200 hours. Because dependent variables, lumens per watt IRLs with shorter lifetimes, DOE there is a range of lifetimes available at and lifetime, are changed so that the understands that this is a likely path a higher efficacy, in addition to the more efficacious substitute is providing manufacturers may take in response to 4,200-hour representative lamp, DOE is not just greater efficacy but also more higher standards. To capture the proposing a second representative lamp light, more hours of lighting, and greater impacts of the relationship between as a more efficacious substitute at EL 1 utility. The product is different and is lifetime and efficacy in IRLs, DOE in this NOPR analysis. The 2,500-hour designed to meet some commercial determined how much the lifetime of a lamp offers a different technology consumers’ desire for a long-lived lamp with the same wattage as the pathway to achieve EL 1, namely IR product. If the hours were reduced for baseline lamp must be shortened to glass coating without the use of higher that product to be equivalent to the achieve each efficacy level under efficiency reflector coatings. Therefore baseline lamp lifetime, it would have a consideration in the NOPR analysis. DOE analyzes the 2,500-hour lamp as a significantly higher efficacy from an (See chapter 5 of the NOPR TSD for representative lamp at EL 1. DOE engineering perspective. ASAP further information.) The impact of requests comment on the lifetimes of the concluded that lifetime is a limiting these shortened lifetime lamps are IRL baseline and more efficacious factor on the efficacies that can be used assessed as sensitivities in the LCC, substitutes. for the selection of more efficacious, NIA, and MIA. (See respectively, Summary of IRL Representative Lamps commercially available lamps. (ASAP, appendix 8B, chapter 12, and appendix Public Meeting Transcript, No. 30 at p. 13C of the NOPR TSD). DOE is proposing the representative 169) In the main engineering analysis, DOE lamps for IRLs specified in Table VI.11. The CA IOUs provided information did not model IRLs with shortened For further information please see on the relationship between lifetime and lifetimes at efficacy levels higher than chapter 5 of the NOPR TSD. DOE efficacy in incandescent lamps, noting those at which they are currently requests comments on its selection of that a lamp’s efficacy could be improved commercially available because DOE representative lamps for IRLs.

38 In the equation, ‘‘life0’’ is equal to the design the resultant life when the designed efficacy is life at the designed efficacy (lpw0), while ‘‘life’’ is altered to a new operational efficacy (lpw).

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TABLE VI.11—IRL REPRESENTATIVE LAMPS

Representative lamps Initial Representative product class Lamp Wattage Efficacy * light Lifetime type Descriptor output W lm/W lm hr

Standard Spectrum, Voltage <125 V, Diameter PAR38 HIR ...... 55 18.5 980 2,500 >2.5 Inches. PAR38 Improved HIR...... 55 18.5 1120 4,200 * Efficacy values are based on data from DOE’s certification database.

e. Maximum Technologically Feasible also noted that smaller manufacturers lab settings.39 The CA IOUs cited a DOE presented one efficacy level (CSL with products such as one with 25 November 2012 Electric Power Research 40 1) for consideration in the preliminary percent higher performance than CSL 1 Institute (EPRI) study that conducted analysis. Therefore, this level was also are not represented in the analysis. (CA extensive photometric, electrical, and the max tech level identified for IRLs. IOUs, Public Meeting Transcript, No. 30 durability testing on a 32 lm/W A-lamp, DOE received several comments on the at p. 172) ASAP stated it is important including extended lifetime max tech level presented in the that DOE analyze a max tech level measurements and testing of the lamp’s preliminary analysis. chosen from all lamps on the market ability to withstand sudden changes in The CA IOUs expressed their belief and then examine the impacts of that voltage, to assess its performance. All that DOE had not captured the total level on utility. (ASAP, Public Meeting lamps were still functional at 1,000 potential energy savings from IRL Transcript, No. 30 at pp. 181–182) hours and 70 percent of the test samples standards. They noted that according to NEEA and NPCC stated products that exceeded 2,000 hours. The independent the 2010 LMC, IRLs represent a sizable should be commercially available in study concluded that the high efficacy end use, an estimated 39 TWh of annual 2013 range in efficacy from the lamps were ‘‘a true 100 watt energy use in the United States. (CA minimum federal standard to over 30 incandescent-equivalent with respect to IOUs, No. 32 at pp. 1–2) The CA IOUs lm/W, and max tech is probably over 35 all output/performance values, lifespan.’’ The CA IOUs argued that the cited the case of Natural Resources lm/W, even at lower wattages, far above high efficiency halogen IR capsules in Defense Council v. Herrington, 768 F.2d what DOE has acknowledged. (NEEA those lamps could be inserted into 1355, 1391–92 (D.C. Cir. 1985), in which and NPCC, No. 34 at pp. 2, 5) NEMA, the D.C. Circuit Court explained the reflector lamps as well. (CA IOUs, No. however, stated that there have been no 32 at pp. 5–6) EPCA provision that requires DOE to noteworthy technological breakthroughs identify and analyze the ‘‘maximum The CA IOUs further noted that since the last rulemaking or great Venture Lighting is offering 2X halogen technology feasible level’’ to determine changes in the market. Therefore, the whether that level is both cost-effective A-lamps ($6.98, 32 lm/W, 1,500 maximum-feasible performance levels of 41 and feasible. The ruling further stated hours) and 2X halogen MR–16 lamps the previous rule have not changed. 42 that DOE must explain why a standard ($6.90, 22 lm/W, 6,000 hours) on the (NEMA, No. 36 at p. 1) achieving max tech was rejected. (CA Web site, www.2XLightDirect.com. The IOUs, No. 32 at p. 4) Specifically, CA In the preliminary analysis, DOE 2X lamps are deemed to be two times IOUs made the following assertions evaluated the latest catalogs and DOE’s as efficient as their typical incandescent regarding the max tech for IRLs certification database to identify the counterparts. (CA IOUs, No. 32 at pp. 5– presented in the preliminary analysis: most efficacious IRLs to develop the 6) CA IOUs emphasized that the 2X (1) There are commercially available max tech level. DOE selected more MR–16 is a commercially available IRLs higher than the max tech; (2) efficacious replacements with a similar product using technology that can be advanced technology being used in reflector shape (PAR38) and lumen used in other lamp form factors. The CA other lamp types can be transferred to output (within 10 percent) as the IOUs acknowledged, however, that the produce higher efficacy IRLs; and (3) baseline lamp. In the engineering MR–16 lamp, which is not a covered there are prototype IRLs that analysis, DOE considered only product, cannot be used for a direct demonstrate the feasibility of higher replacements that saved energy. Based comparison with the lamps covered efficacy IRLs. (CA IOUs, No. 32 at pp. on DOE’s analysis, the max tech under this rulemaking due to different design parameters, coatings on the 4–7) presented in the preliminary analysis lenses, and low voltage operation. The CA IOUs commented that there is represented the highest-efficacy Additionally, the CA IOUs stated that a wide array of currently, commercially commercially available lamp meeting the challenges encountered with available products that are significantly these criteria. more efficient, by 13–20 percent, than designing a smaller form factor lamp the CSL proposed by DOE. (CA IOUs, The CA IOUs noted that over the last No. 32 at p. 4) In the DOE certification few years, a number of products have 39 ETCC presentation, Dec 2010, slide 2. been designed and tested using www.etcc-ca.com/pdfs/10_2X_Incandescent_ET_ database there is a Philips 70 W PAR38 _ _ _ improved halogen IR capsules with new Open Forum 121207 R1.pptx. at 22 lm/W, which is 13 percent better 40 EPRI report # 1025779; www.epri.com/ than CSL 1; a Philips 55 W lamp at 20.1 mixes and more layers of materials in abstracts/Pages/ lm/W, which is 10 percent better than the thin-film coatings. IRLs have ProductAbstract.aspx?ProductId=0000000 CSL 1; and a GE lamp at 23 lm/W, demonstrated efficacies above 30 to 35 00001025779&Mode=download. 41 www.2xlightdirect.com/product-categories/a- which is 12 percent better. The CA IOUs lm/W, with efficacies of 45 lm/W (with a 1,000-hour lifetime) having also been line. noted that OSI’s best products are not 42 www.2xlightdirect.com/product-categories/2x- yet in DOE’s certification database. They achieved for omni-directional lamps in mr16.

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such as an MR–16 may be more easily DOE. The CA IOUs encouraged DOE to however, have the necessary overcome with PAR lamps. (CA IOUs, reach out to manufacturers of these information to do a cost analysis to Public Meeting Transcript, No. 30 at pp. products directly to understand more determine if an efficacy level based on 170–173, 179–180) The CA IOUs noted specifics about product development these lamps would be economically that the Web site schedules, manufacturing capability, justified. In appendix 5A of the NOPR www.2Xlightdirect.com, where these 2X likely cost points, technical potential, TSD, DOE provides an assessment of lamps can be found, states that PAR and to potentially obtain prototypes of these higher efficacy prototypes lamps are ‘‘coming soon.’’ 43 (CA IOUs, these lamps. (CA IOUs, No. 32 at p. 6) (including test data), conducts a further No. 32 at pp. 5–6) The CA IOUs concluded that DOE examination of the highly efficacious Philips stated that it is unknown if needs to look at max tech and then lamps relevant to this rulemaking noted IRLs utilizing the 2X lamp technology identify what is cost effective, feasible by stakeholders in comments, and are technically viable. Philips provided and can be scaled up for production. specifies the additional information it the example that a 37 lm/W lamp can The CA IOUs noted that this was not would need to consider prototypes in a be demonstrated, but that it could only adequately addressed in the preliminary rulemaking analysis. DOE welcomes last 24 hours. (Philips, Public Meeting analysis. Further, the CA IOUs comments on the max tech level as well Transcript, No. 30 at pp. 173–174) suggested that one of the CSLs should as any further information on prototype DOE acknowledges that efficacious A- be set in line with the max tech level lamps. shape and MR–16 lamps are currently and another should be set in line with While DOE received several being offered on the market. However, the maximum commercially available comments stating that the max tech DOE cannot assume that lamp designs level. NEEP agreed with this level is greater than that analyzed in the and technologies that work for certain recommendation. (CA IOUs, Public preliminary analysis, DOE also received lamp shapes (e.g., MR–16 and A-shape Meeting Transcript, No. 30 at pp. 170– comments that the max tech level is not lamps) and at low voltages will achieve 173; CA IOUs, No. 32 at pp. 6–7; NEEP, higher than the analyzed level. GE the same efficacies in the IRLs that are No. 33 at p. 3) The Joint Comment also stated that it did not believe technology the subject of this rulemaking. The stated that to properly identify the max existed that would triple the efficiency incandescent lamps studied by EPRI tech level, DOE should examine those of these lamps. GE noted that although and available from Venture Lighting (the sources referenced in the CA IOUs’ there may be a few more players in the 2X A-lamps and MR–16s) are not comments, namely, EPRI, market, the technology itself or what covered IRLs. They do not utilize the 2Xlightdirect.com, and ETCC. (Joint can be done with it has not changed in same reflector shapes and the MR–16s Comment, No. 35 at p. 3) the last three or four years. GE asserted do not operate at the same input voltage NEMA stated that if DOE chooses to that the baseline technology represents as the covered IRLs. Therefore, DOE consider higher performance levels the highest technology available today cannot consider these lamp types to based on any recently introduced that meets many different needs in the determine a max tech for IRLs. technologies, they are obligated to marketplace. As efficacy requirements The CA IOUs asserted that covered conduct actual testing of these lamps for increase, even to the CSL 1, utility is IRLs exist in prototype form that are all performance parameters, such as lost, potentially leading to only one dramatically more efficient than DOE’s reliability, lifetime, dimmability, beam product that works for one consumer proposed CSL. (CA IOUs, No. 32 at p. spread, light pattern, and any other and one application. GE stated that CSL 4) The CA IOUs stated that, in 2009, performance features expected of new/ 1 represents the max tech of what is they funded the development of a super- substitute lamps in this class. (NEMA, available today that could cover all the efficient PAR lamp achieving 37 lm/W No. 36 at p. 11) NEMA also cautioned different market needs. (GE, Public at 57 W with a lifetime of 1,500 hours. DOE that emerging technology and Meeting Transcript, No. 30 at pp. 176– The CA IOUs provided information prototype models do not reliably 178) about the lamp and its testing represent the market, only market As discussed previously, based on completed in 2009.44 (CA IOUs, No. 32 attempts. NEMA further stated that DOE’s analysis of commercially at p. 6; CA IOUs, Public Meeting technologies on which to base the future available lamps and because it does not Transcript, No. 30 at p. 173) of an entire product class must be have the adequate information to Additionally, the CA IOUs pointed demonstrated and proven for long-term conduct a full analysis on any lamp that out a presentation from the Emerging feasibility and market acceptance. represents an efficacy level higher than 0.27 Technologies Coordinating Council (NEMA, No. 36 at p. 11) EL 1, DOE is proposing 6.2P as EL (ETCC) site 45 that includes information For the NOPR analysis, DOE 1 and the max tech level. about the market potential for advanced contacted manufacturers producing high Proprietary Technology IR coatings. Several PAR lamps efficacy prototype IRLs and conducted In response to the max tech level achieving approximately 30 lm/W are independent testing of these lamps. The presented in the preliminary analysis, forecasted to be available by mid-2013, testing indicated that these lamps were DOE received several comments at a price point of $8 to $9.46 more efficacious than the max tech level The CA regarding the use of proprietary determined by DOE in this analysis.47 IOUs stated that they are tracking the technology. NEMA stated that for all DOE notes that the lamps tested were development of these products and IRLs, no further elevations in product prototype lamps and were not intend to obtain samples to submit to performance are possible. As support, manufactured during commercial scale NEMA quoted from the final rule notice 43 www.2xlightdirect.com/product-categories/2x- production runs. However, the of the 2009 Lamps Rule, in which DOE par. measured efficacy of the prototype 44 had noted that the max tech level was Appendix A is available at the end of the CA lamps greatly exceeded the efficacy of IOUs written comment in the docket for this possible with the use of the highest- commercially available lamps with rulemaking. efficiency technologically feasible 45 similar lumen packages. DOE does not, ETCC presentation, Dec 2010, slide 5. http:// reflector, halogen IR coating, and www.etcc-ca.com/pdfs/10_2X_Incandescent_ET_ Open_Forum_121207_R1.pptx 47 While DOE independently verified efficacy filament design and because this would 46 At the time of the NOPR analysis, these lamps values, the manufacturer’s testing for lifetime was require the use of proprietary were not commercially available. still ongoing at the time of the NOPR analysis. technology, DOE could not consider this

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level further in its analyses. 74 FR IR coating, and a filament design that CSLs to its IRL analysis. (CA IOUs, No. 34080, 34096 (July 14, 2009). NEMA resulted in a lifetime of 4,200 hours. 32 at p. 4) stated that if DOE proposes to raise the While DOE had determined that the The Joint Comment agreed with the CSL above the existing level set by the silver reflector was patented technology, CA IOUs, stating that DOE should add 2009 Lamps Rule, DOE must explain DOE research indicated that there were multiple high efficacy CSLs to its why the proprietary technology hurdle alternate pathways to achieve this level, analysis; ASAP suggested two or three no longer exists, and then explain how such as filament redesign to achieve additional levels. (Joint Comment, No. to achieve those higher CSLs. (NEMA, higher temperature operation (thus 35 at p. 3; ASAP, Public Meeting No. 36 at p. 11) Specifically, Philips reducing the lifetime), non-proprietary Transcript, No. 30 at pp. 171–172) NEEP expressed concern that the improved higher efficiency reflectors, and a higher noted that the higher efficacies in DOE’s reflector technology option, such as a efficiency IR coating. 74 FR 34080, certification database for standard levels silver reflector coating, was proprietary. 34133 (July 14, 2009). In interviews should be included in the analysis at (Philips, Public Meeting Transcript, No. conducted in the preliminary analysis this stage. NEEP suggested DOE 30 at p. 169) GE added that requiring for this rulemaking, manufacturers consider adding at least two additional proprietary technology could impact indicated that there were no specific CSLs to the analysis between CSL 1 and competition. (GE, Public Meeting patent or intellectual property barriers the maximum commercially available Transcript, No. 30 at pp. 169–170) to obtaining commercially available IRL level. (NEEP, No. 33 at p. 3) NEEA and EEI expressed similar concerns as technologies. Further, in the NPCC stated there is more than enough NEMA and stated that during the 2009 preliminary analysis, DOE put forth a rationale to examine at least two or Lamps Rule, the Department of Justice CSL 1 that was based on a commercially three additional CSLs, if not three or was concerned about the higher available improved HIR lamp that does four, including a ‘‘max tech’’ level, standard levels because certain not necessarily require a silverized which DOE has not included for this technologies for HIR lamps were reflector coating to achieve its efficacy. family of products. (NEEA and NPCC, proprietary and that because only a few Several manufacturers have found No. 34 at pp. 2, 5) companies made the highest efficacy means of designing more efficacious To demonstrate the feasibility of lamp, competition in the industry could IRLs that are commercially available, potential efficacy improvements beyond be impacted. EEI asked whether there such as through the use of IR glass the CSL 1 presented in the preliminary were issues with the particular coatings and higher efficiency reflector analysis, the CA IOUs provided a graph technology used in the more efficacious coatings that do not use proprietary that showed efficacy levels of substitute, such that it might be a technology. In the NOPR analysis, DOE commercially available lamps from four proprietary technology and made only confirmed during interviews that manufacturers based on catalog data, plotted against the considered CSL 1 by a very limited number or even one proprietary technology is not a barrier to and the standard from the 2009 Lamps manufacturer, which could limit its achieving the proposed max tech level, Rule. In further support, the CA IOUs availability and result in an extremely which is also EL 1. Therefore, in this provided another graph showing high price point. (EEI, Public Meeting NOPR analysis, DOE is proposing the efficacy levels of over 20 manufacturers Transcript, No. 30 at pp. 167–168) same efficacy level put forth in the from DOE’s certification database, also The CA IOUs noted that they had preliminary analysis. DOE has plotted against the considered CSL 1 provided a number of comments to that determined that this level can be and the standard from the 2009 Lamps rulemaking’s docket about alternate achieved without the use of proprietary Rule. Both graphs show a number of silverized reflector technologies, and technology. suggested that manufacturers would be lamps above the considered CSL 1. (CA IOUs, No. 32 at pp. 4–5) ASAP asked able to utilize them to improve efficacy f. Efficacy Levels how old the data DOE used in its of their lamps. The CA IOUs reported For IRLs, DOE developed a preliminary analysis was and why the that since the 2009 Lamps Rule, several continuous equation that specifies a lamps with higher efficacies in DOE’s manufacturers have begun making minimum efficacy requirement across database were not captured. (ASAP, lamps with silver reflectors, including, wattages and represents the potential Public Meeting Transcript, No. 30 at pp. but not limited to, Halco, Satco, Ushio, efficacy a lamp achieves using a 48 171–172) and Osram Sylvania. Further, the CA particular design option. DOE observed For the preliminary analysis, DOE IOUs noted that the Lawrence an efficacy division among conducted a thorough review of the Livermore Lab has a patent; GE and DSI commercially available IRL products latest catalog and certification data likely also have patents related to that corresponded to the design options provided for covered IRLs. Because reflector technology. (CA IOUs, Public utilized to increase lamp efficacy. Based PAR38 lamps are the most popular Meeting Transcript, No. 30 at pp. 170– on this efficacy division, DOE products on the market and a PAR38 171) Given the wide variety of major considered one CSL in the preliminary lamp was selected as the baseline, DOE PAR lamp manufacturers that are analysis. DOE received several considered only PAR38 lamps when utilizing silverized reflectors, the CA comments regarding the CSL presented selecting more efficacious substitutes. IOUs encouraged DOE to consider this for IRLs in the preliminary analysis. Further, DOE selected more efficacious a viable design option for all IRL The CA IOUs expressed concern that substitutes with a lumen output within manufacturers. (CA IOUs, No. 32 at pp. there is only one CSL. The CA IOUs 10 percent of the baseline lumens, as 8–9) stated that DOE is not capturing the this is the amount of change in light In the 2009 Lamps Rule, the highest huge potential in the IRL market for output deemed acceptable to level analyzed for IRLs was based on a efficacy gains, both for commercially consumers. (See section VI.D.2.e for commercially available lamp that available and non-commercially further information.) employed a silver reflector, an improved available products. The CA IOUs stated To ensure energy savings, DOE also that based on commercially available chose higher efficacy lamps with a 48 More information on associated products can be found in the written comment available on IRL products and other known high- lower wattage than the baseline lamp. regulations.gov under docket number EERE–2011– performing products, DOE should add at DOE also did not consider any lamp that BT–STD–0006. least three additional, higher efficacy could not be purchased in the United

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States. Some of the products with the Summary of IRL Efficacy Levels comments specific to the scaling factors highest efficacies in DOE’s certification For the NOPR analysis, DOE again applied to develop efficacy levels for the database were not found for sale in the reviewed the most updated catalog and product classes analyzed directly. United States. certification data available for covered Diameters Less Than or Equal to 2.5 Thus, although there are certain IRLs. As in the preliminary analysis, Inches lamps with efficacies higher than the DOE used the catalog data to determine In the preliminary analysis, DOE levels proposed by DOE, DOE did not initial efficacy levels and then adjusted scaled from the CSLs developed for the consider them in the preliminary the ELs to ensure that commercially IRLs with diameters greater than 2.5 analysis for the reasons stated above. available IRLs would meet proposed inches (hereafter ‘‘large diameter DOE maintained this methodology for levels based on compliance information lamps’’) to IRLs with diameters less than the NOPR analysis. provided in DOE’s certification or equal to 2.5 inches (hereafter ‘‘small NEMA stated that the CSL 1 presented database. In the preliminary analysis, diameter lamps’’). Based on catalog in the preliminary analysis was DOE had found there to be certification data, DOE determined the reduction in infeasible given that there have been no data for only 36 percent of covered IRL efficacy caused by the smaller lamp technological breakthroughs since the products compliant with the July 2012 diameter to be approximately 12 2009 Lamps Rule. (NEMA, No. 36 at pp. standards. For the NOPR analysis, DOE percent. DOE also determined that the 9–11) NEMA also commented that found that updates to DOE’s more efficient double-ended HIR having one CSL eliminates DOE’s ability certification database resulted in burners could not fit into small diameter to analyze standard levels other than the certification data for 51 percent of lamps. Therefore, in the preliminary baseline and max tech and makes it covered IRL products. Using analysis, DOE applied an additional 3.5 more likely that max tech will become certification data reported for the PAR38 percent reduction to account for the the new standard. (NEMA, Public 2,500 hour HIR and 4,200 hour ability of small diameter lamps to utilize Meeting Transcript, No. 30 at p. 350) improved HIR representative lamps, only less efficient single-ended HIR DOE based CSL 1 on commercially DOE adjusted EL 1. As mentioned burners. available products that achieved catalog previously, DOE developed a Asserting that double-ended burners efficacies above the existing standard. continuous equation that specifies a can be utilized in small diameter lamps, Specifically, the representative lamp for minimum efficacy requirement across NEEA and NPCC and the CA IOUs CSL 1 was a commercially available 55 wattages for IRLs. The proposed EL urged DOE not to use an additional W IRL with a catalog efficacy of 20 lm/ based on the representative lamps is a scaling factor to account for the use of W. Acknowledging that the catalog curve that represents a standard across a single-ended burner in a small efficacy of a lamp varies from its all wattages. diameter lamp. (CA IOUs, No. 32 at p. certified efficacy, DOE also reviewed Table VI.12 presents the proposed 10, NEEA and NPCC, No. 34 at p. 6) The certification data for IRLs. Based on efficacy level for IRLs. See chapter 5 of CA IOUs noted that by providing a certification data, DOE accordingly the NOPR TSD for additional PAR20 lamp with a double ended adjusted CSL 1, resulting in an efficacy information on how the engineering burner at the public meeting, they had level of 6.2P0.27. Because DOE based analysis was conducted. demonstrated that double-ended CSL 1 on a commercially available lamp burners can be used in small diameter and accounted for variances in efficacies TABLE VI.12—EFFICACY LEVELS FOR lamps. At the preliminary analysis between catalog and certification data STANDARD SPECTRUM, VOLTAGE public meeting, the CA IOUs had when establishing CSL 1, DOE believes <125 V, DIAMETER >2.5 INCHES presented two small diameter lamps that CSL 1 is technologically feasible IRLS with double-ended burners. One was a and is also the appropriate max tech commercially available Philips MR–16 lamp, which the CA IOUs level. Efficacy Efficacy level requirement acknowledged to be out of the scope of The CA IOUs recommended that DOE lm/W this rulemaking, but asserted that the revisit the slope of the candidate MR–16 burner would fit into a covered EL 1 ...... 6.2P0.27 standard lines to better reflect the IRL. The other was a PAR20 lamp performance of lamps on the market. P = rated wattage. covered under this rulemaking that was The CA IOUs provided graphs that not yet commercially available. (CA g. Scaling to Other Product Classes demonstrated three possible additional IOUs, Public Meeting Transcript, No. 30 CSLs that could be used to more When more than one product class at pp. 195–197) GE noted that the MR16 effectively evaluate potential standards exists for a covered product, DOE uses a 12 V filament, which is much at higher, technically feasible efficacy identifies and selects representative shorter than the filament at 120 V, and tiers. The CA IOUs adjusted the slopes product classes to analyze directly. NEMA stated that many technical of the curves to account for higher Efficacy levels developed for these features are not transferrable between 12 efficacy potential at higher wattage. (CA representative product classes are then V and 120 V products. (GE, Public IOUs, No. 32 at pp. 7–8) scaled to products not analyzed directly. Meeting Transcript, No. 30 at pp. 196– DOE examined the possibility of For IRLs, DOE analyzed directly 197, NEMA, No. 36 at p. 11) The CA changing the exponent of the existing standard spectrum lamps greater than IOUs acknowledged that the MR16 used equation for IRL standards to better 2.5 inches in diameter and with input a 12 V filament, but noted that the reflect the performance of lamps on the voltages less than 125 V. The efficacy PAR20 lamp with a double-ended market. DOE conducted a best fit levels developed for this representative burner was designed for operation at analysis and determined that the current product class were then scaled to 120 V. (CA IOUs, Public Meeting equation accurately reflects the wattages product classes not analyzed, using a Transcript, No. 30 at p. 197) Further, the and associated efficacies of scaling factor to adjust levels for CA IOUs noted that the PAR20 lamp commercially available products. Thus, modified spectrum lamps, smaller with a double-ended burner achieved an DOE retained the current standard diameter lamps, and lamps with higher efficacy of 16.1 lm/W, which is 12 equation. input voltages. DOE received several percent higher than the CSL proposed

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by DOE for this lamp type in the able to utilize only single-ended unnecessary because single-ended preliminary analysis. (CA IOUs, No. 32 burners. burners can be highly efficient within at p. 10) The CA IOUs questioned DOE’s small diameter reflectors. They cited the ADLT agreed with the CA IOUs, methodology for determining the scaling example of an MR–16 lamp (2 inch noting that these double-end burners factor for large diameter to small diameter reflector) utilizing single- have a length of 52 mm and new diameter lamps. The CA IOUs stated ended IR halogen burner with an 85 double-end burners are being that it understood DOE compared the percent optical efficiency compared to a introduced to the market that are 45 mm efficacies of small diameter lamps to typical PAR38 (4.75 inch diameter in length, which further mitigates larger diameter lamps on the market, reflector, aluminized) with a 78 to 80 mechanical fit problems related with and established that there was a 12 percent optical efficiency. Therefore, smaller reflectors. (ADLT, No. 31 at pp. percent difference. Under the ADLT urged DOE to consider a 12 2–3) However, NEMA contended that assumption that the single-ended burner percent reduction factor, which would double-ended burners will not fit into could not fit in small diameter lamps, equate to an efficacy requirement of existing small diameter PAR20 lamps DOE then modeled the losses of using 5.5P0.27 for small lamp diameters. without extending the lens cover. The a single-ended burner. However, the CA (ADLT, No. 31 at pp. 2–3) extension of the lens cover would lessen IOUs did not understand why these DOE cannot base its analysis on an the utility as the product would not fit losses were added to the original 12 MR–16 lamp because it is not designed into all fixtures designed to use PAR20 percent difference which represents the to operate at the same voltage as covered lamps, and therefore could not be efficacy reduction going from a large IRLs, and MR–16 lamps are not the considered as an acceptable substitute. diameter to small diameter lamp. (CA subject of this rulemaking; DOE can (NEMA, No. 36 at p. 12) GE agreed that IOUs, Public Meeting Transcript, No. 30 assess the efficiency of a single-ended there were difficulties in fitting halogen at pp. 194–195) burner only in a small diameter IRL IR burners into small PAR20 envelopes. ADLT stated that it supported a 12 covered under this rulemaking. (GE, Public Meeting Transcript, No. 30 percent scaling factor based on the With regards to scaling, NEMA stated impact of the less efficient diameter of at pp. 191–193) that DOE must ensure not only that the the reflector because it was independent filaments and halogen burners must be Regarding the PAR20 lamp with a of capsule design. ADLT noted that a able to be inserted into all lamps scaled, double-ended burner provided by the typical PAR30 aluminum-coated but also that the beam characteristics CA IOUs at the preliminary analysis reflector with a front lens is required for those lamps, a market- public meeting, DOE notes that it must approximately 75 percent optically demanded performance characteristic, also consider how the use of a design efficient while the same type of PAR20 can be met. NEMA suggested that DOE option affects product utility and reflector (aluminum coated with a front develop demonstration models to verify whether a more efficacious product is lens) is approximately 66 percent performance; otherwise, scaling is not an appropriate substitute for the existing efficient. Therefore, ADLT concluded possible. (NEMA, No. 36 at p. 12) product. DOE must also consider that the 12 percent reduction in As noted, DOE determined that whether the product can be efficiency from large to small diameter double-ended burners cannot fit into manufactured at a commercial scale by lamps corresponds to DOE’s findings small diameter lamps without changes the compliance date of any amended when comparing catalog efficacy data of to the lamp shape that could affect lamp standards. Based on feedback given by each lamp type from several lamp characteristics and thereby product manufacturers in interviews, fitting a manufacturers (all other features utility. Therefore, DOE scaled from large double-ended burner into a small remaining approximately the same). diameter lamps with double-ended diameter lamp would require changes to (ADLT, No. 31 at p. 2) burners to small diameter lamps with the physical shape of the lamp, In the preliminary analysis, DOE single-ended burners. DOE did not specifically requiring an extension of compared the catalog efficacies of create demonstration models because the reflector lens. While the modified halogen PAR20 lamps (the most the scaling was based on lamp designs lamp may still meet ANSI standards for common IRL with a diameter less than in commercially available lamps. a small diameter lamp such as a PAR20, or equal to 2.5 inches) and their PAR30 it would be larger than any PAR20 or PAR38 counterparts from several Operating Voltages Greater Than or lamps sold in the past and those lamp manufacturers (all other lamp Equal to 125 Volts currently installed. Because the lamp features remaining approximately the In the preliminary analysis, DOE shape would be different from the same). Based on these results, DOE scaled from IRLs with voltages less than standard sizes of commercially available found that the reduction in efficacy 125 V to IRLs with voltages greater than small diameter lamps, the modified caused by the smaller lamp diameter or equal to 125 V. DOE developed a lamp may not fit in existing structures. was approximately 12 percent for IRLs. scaling factor that would require 130 V Past a certain wattage threshold, heat Because only halogen lamps were used lamps tested at 130 V to use the same dissipation in lamps with a smaller (no HIR lamps were included), the 12 technology and possess the same envelope using a double-ended burner percent included the efficacy difference general performance characteristics as could also become an issue. Further, due only to lamp diameter because the 120 V lamps tested at 120 V. DOE found manufacturers stated that even if the additional impact of a single-ended that while there may be a slight decrease double-ended burner could fit into a versus double-ended burner on lamp in efficacy, the lifetime of a 130 V lamp small diameter lamp, it would be efficacy is relevant only for HIR lamps. is doubled when it is operated at 120 V, difficult to place the burner/filament in In the NOPR analysis, using the same giving it an advantage over 120 V lamps. the optimal position. methodology, DOE confirmed that the Using the IESNA Lighting Handbook Therefore, in this NOPR analysis DOE efficacy reduction from a large diameter equations that relate lifetime, lumens, continues to apply an additional 3.5 to a small diameter lamp should be 12 and wattage to voltage of incandescent percent reduction factor when scaling percent. lamps, DOE determined that a 15 efficacies of large diameter to small ADLT stated that the 3.5 percent percent scaling factor was necessary. diameter lamps to account for the scaling factor going from double-ended The CA IOUs stated that it can be limitation of small diameter lamps being to single-ended burners was also assumed the primary utility of the 130

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V lamps was long life. However, they lifetime over that of 120 V lamps were and lifetime by the same manufacturer noted that the utility has not been instead used to increase their efficacy. and confirmed a 15 percent reduction in removed from the market, as there are DOE found this increase in efficacy to efficacy from a modified spectrum lamp still many other commercially available be 15 percent. Therefore in this NOPR to a standard spectrum lamp. Therefore, long-life lamps. (CA IOUs, Public analysis, DOE is proposing a scaling in this NOPR analysis DOE is proposing Meeting Transcript, No. 30 at pp. 66–67) factor of a 15 percent efficacy increase a 15 percent efficacy reduction from a NEMA clarified that the primary utility from an IRL with voltages less than 125 standard spectrum IRL to a modified and selling point of the 130 V lamps V to voltages greater than or equal to spectrum IRL. was their ability to withstand voltage 125 V. spikes. The additional lifetime was just h. Xenon Modified Spectrum an added benefit. (NEMA, Public DOE identified higher efficiency inert Meeting Transcript, No. 30 at pp. 67) In the preliminary analysis, DOE fill gas as a design option for improving EEI agreed that in some areas where the established CSLs for modified spectrum lamp efficacy of IRLs. Specifically, line voltage can be higher than 120 V, IRLs by scaling from the CSLs xenon, due to its low thermal the 130 V lamps provided a safeguard developed for the standard spectrum conductivity, can greatly increase lamp against the lamp blowing out. (EEI, product class. DOE determined that a efficacy and is utilized in most covered Public Meeting Transcript, No. 30 at pp. reduction of 15 percent from the standards-compliant IRLs. NEMA 61–63) NEMA asserted that consumers standard spectrum CSLs would be commented that the availability of have arguably lost a utility and noted appropriate for modified spectrum IRLs. xenon is decreasing. If standards are set that elimination of a market-desired The Joint Comment urged DOE to at a level requiring the use of xenon, it performance characteristic is counter to eliminate the 15 percent allowance for will increase its use, driving up prices requirements in EPCA. (NEMA, No. 36 modified spectrum IRLs. The Joint and reducing availability, similar to the at p. 1, 5) Additionally, according to Comment noted that a 2009 Ecos rare earth phosphor shortage issue. EEI, consumers that now have to switch Consulting study 49 that found an (NEMA, Public Meeting Transcript, No. from 130 V to 120 V have to buy more average light loss of 9 to 11 percent 30 at pp. 80–81) NEMA noted that lamps. (EEI, Public Meeting Transcript, associated with modified spectrum xenon is becoming increasingly scarce, No. 30 at pp. 61–63) lenses. The study also highlighted the and its loss is an automatic 5–7 percent DOE received feedback in feasibility of modified spectrum IRLs efficacy reduction in IRLs. The loss of manufacturer interviews that in certain exceeding the highest efficacy levels in xenon will make it impossible to meet areas where voltage spikes may occur, a the 2009 Lamps Rule. Therefore, the CSL 1. NEMA referred DOE to a 130 V lamp will last longer than a 120 Joint Comment found that the 15 February 2013 article in CryoGas V lamp. DOE remains concerned, percent scaling factor should be International Magazine,50 which however, that the operation of 130 V eliminated, as there are high efficacy provides additional information on the lamps at 120 V has the potential to modified spectrum lamps, or DOE xenon supply and demand market. significantly affect energy savings. should reduce the factor to 10 percent These estimates show a 2013 increase in DOE’s research has shown that 130 V to match the findings of the Ecos demand of 15–20 percent followed by lamps are usually operated by Consulting study. (Joint Comment, No. steady 10 percent demand growth in consumers at 120 V rather than at a 35 at p. 3) outyears, with a potential for dramatic In the 2009 Lamps Rule, DOE higher voltage line. This could spike if emerging demands from assessed the efficacy differences incentivize manufacturers to design a technology related to satellites, between standard and modified less efficient and less expensive 130 V anesthesia and electronics are realized spectrum IRLs by measuring the lamp that would meet standards when as anticipated. NEMA stated that DOE efficacies of commercially available tested at 130 V. Because they would be should add an investigation of xenon standard and modified spectrum lamps. cheaper, there could be a market availability trends and pricing to its migration to 130 V lamps and due to the 74 FR 34080 (July 14, 2009). In that analysis, DOE correlated the measured analysis. (NEMA, No. 36 at p. 3) lower lumen output when 130 V lamps NEEA and NPCC disagreed, stating color point data of the lamps with lamp are operated at 120 V, consumers may that as there is no current shortage of light output reduction and lamp spectral purchase more 130 V lamps, resulting in xenon fill gas, and a standard requiring power distribution. By analyzing the increased energy consumption. it would not demand a significant data, DOE established that a reduction EEI noted that when 130 V lamps are increase in xenon use, then xenon price of 15 percent from the standard operated at 120 V, their lifetime is and supply should not be an issue for spectrum to modified spectrum lamps increased by about 2.5 times. (EEI, this rulemaking. (NEEA and NPCC, No. Public Meeting Transcript, No. 30 at pp. was necessary. In the preliminary analysis, DOE 34 at p. 2, 5) The CA IOUs further noted 61) GE noted that as 130 V lamps are that xenon is already being used as the operated on higher voltages, their confirmed this 15 percent reduction by determining the difference between the primary fill gas in virtually all IRLs, so efficacy decreases. GE stated that this a requirement of its use would not relationship was misanalysed in the catalog efficacies of the standards- compliant modified spectrum lamps to especially impact any constraints on 2009 Lamps Rule, and as a result, the supply or price instability in the market. July 2012 standards have eliminated 130 comparable standard spectrum lamps. Using the available data for standards- (CA IOUs, No. 32 at pp. 9–10) V lamps from the market. (GE, Public DOE acknowledges that xenon supply Meeting Transcript, No. 30 at pp. 60–61) compliant modified spectrum lamps on the market, DOE compared the efficacies and prices are an important factor for DOE’s research indicates that the lighting industry, including IRLs. operating 130 V lamps at 120 V of these two lamps with standard spectrum lamps with the same wattage Therefore, in the preliminary analysis increases lifetime and lowers efficacy DOE conducted a market assessment of compared to operating these lamps at xenon supply, demand, and prices as 130 V. Therefore, to develop an 49 Ecos Consulting (prepared for Pacific Gas & Electric, Natural Resources Defense Council, and appropriate scaling factor, DOE the Appliance Standards Awareness Project), 2009. 50 CryoGas International Magazine, February 4, determined the efficacy of 130 V lamps Optical Losses of Modified Spectrum Lenses on 2013 ‘‘Ever Changing Rare Gas Market’’ Richard operated at 120 V if their additional Incandescent Reflector Lamps. Betzendahl.

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well as an LCC sensitivity to determine (NEMA, No. 36 at p. 5) NEMA expanded this rulemaking. In the preliminary the impact of increased end user lamp on the 130 V IRL, asserting that these analysis, DOE estimated end-user prices prices due to increases in the price of lamps appear to have been eliminated for lamps by establishing discounts from xenon. DOE updated this assessment for by the 2009 Lamps Rule and arguing manufacturer suggested price lists the NOPR analysis. against further regulation. (NEMA, No. (hereafter ‘‘blue book prices’’). DOE For the NOPR analysis, DOE 36 at p. 1, 5) Further, NEMA found the revised its methodology for the NOPR, examined various industry sources lack of 130 V lamps on the market as as described below, to account for relevant to the xenon market including evidence that current standards for additional information that became the February 2013 article in CryoGas these lamps are technically or available after publication of the International Magazine cited by NEMA. economically infeasible. NEMA noted preliminary analysis. While, the article did forecast increases that there is still difficulty in making For this NOPR analysis, DOE gathered in xenon demand in 2013 and 2014, it these IRLs comply with the July 2012 publicly available lamp pricing data also stated that it expected this to flatten standards. (NEMA, No. 36 at p. 5) after the compliance date of the July out due to penetration of LEDs into the Therefore, NEMA strongly 2012 standards. Based on feedback from market. A 2012 CryoGas International recommended that for IRLs with manufacturer interviews, DOE Magazine article noted that xenon price voltages greater than or equal to 125 V determined that GSFLs and IRLs are increases predicted for 2012 did not the CSL be ‘‘No New Standard,’’ not sold through three main channels (state occur to the extent expected.51 DOE CSL 0, which implies there are products procurement, large distributors understands that fluctuations in xenon to regulate rather than acknowledging including DIY stores (i.e., Lowe’s and supply and price are possible and the inability to further raise efficiency Home Depot), and Internet retailers). difficult to predict. Based on its requirements. (NEMA, No. 36 at pp. 10– Using these main channels and the research, DOE did not find that there 11) pricing data, DOE developed three was currently a major shortage of xenon. GE also strongly disagreed with different end-user prices as To further inform the impact of xenon applying another 15 percent increase on representative of a range of publicly demand and prices, in the NOPR top of an already unachievable standard available prices: Low, based on the state analysis, DOE conducted an LCC for the 130 V IRLs, particularly when it procurement channel; medium, based sensitivity that determines how high the was not clear how energy savings could on large distributors and DIY stores; and xenon price would have to increase to be justified and why products that don’t high, based on Internet retailers. In the result in zero LCC savings for the meet existing standards would be preliminary analysis, the medium end- consumer at the proposed level. Based further regulated. (GE, Public Meeting user prices were used in the main on the results of this analysis, DOE Transcript, No. 30 at pp. 191–193) EEI results of the LCC and NIA analysis determined that EL 1 is achievable even asked what percentage of the lighting while the low and high end-user prices with fluctuations in xenon price. See market the 130 V lamps represent and were used in sensitivity analyses in the appendix 7C of the NOPR TSD for questioned what can be gained by LCC. DOE received several comments complete details on the xenon price additional analysis if the standards on this methodology and the resulting sensitivity conducted in the LCC. adopted by the 2009 Lamps Rule have end-user prices. NEMA deferred Additionally, for this NOPR analysis, a eliminated 130 V lamps from the comment on product price xenon price sensitivity was also market. (EEI, Public Meeting Transcript, determination to individual conducted in the NIA. Detailed results No. 30 at pp. 58–60, 68) manufacturer interviews. (NEMA, No. can be found in chapter 12 of the NOPR DOE has not found evidence that 36 at p. 13) TSD. more efficacious small diameter, Stakeholders had specific comments modified spectrum, or 130 V IRLs are regarding the IRL prices. ASAP and the i. Proposed Standard not technologically feasible or CA IOUs found the price estimates for DOE received several comments that practicable to manufacture. DOE IRL standards case lamps provided by no standards should be proposed for research indicates that the basic DOE to be higher than the typical IRLs. NEMA indicated that the CSL 1, structure, components, and operating pricing they found on the market. which was also the max tech level requirements of these lamps do not (ASAP, Public Meeting Transcript, No. presented in the preliminary analysis prevent the application of design 30 at pp. 200–201; CA IOUs, No. 32 at should be eliminated. (NEMA, No. 36 at options considered in the engineering pp. 10–11) The CA IOUs stated that low, p. 1, 9) GE suggested that the existing analysis to achieve the proposed medium, and high prices were provided standard for IRLs is appropriate, and efficacy levels. Therefore, in this NOPR for a 55 W IRL at 20 lm/W for CSL 1, DOE does not need to establish a higher analysis, DOE is proposing efficacy however, CSL 1 required an efficacy of standard. (GE, Public Meeting levels for these lamp types. DOE only 18.3 lm/W for a 55 W lamp. The Transcript, No. 30 at pp. 176–178) DOE requests comment on any technological CA IOUs suggested that DOE collect cost has identified that there are achievable barriers in manufacturing more information more representative of the efficacy levels higher than the existing efficacious small diameter, modified minimum efficacy needed for each CSL standard and has developed an EL based spectrum, or 130 V rated lamps for analyzed. The CA IOUs asserted high on the latest catalog and certification commercial production. outlier price points should not be given information. See section VI.D.3.f for equal weight in DOE’s analysis; with more details. E. Product Pricing Determination minimal shopping, consumers will find NEMA, in general, did not believe Typically, DOE develops lower priced products readily available. that any increase in efficacy for small manufacturer selling prices (MSPs) for The CA IOUs provided a table showing diameter, modified spectrum, or greater covered products and applies markups some end-user price information than 125 V IRLs would be warranted. to create end-user prices to use as inputs gathered by ASAP and the CA IOUs. to the LCC analysis and NIA. Because The information gathered includes price 51 Betzendahl, Richard. ‘‘Still Bullish on Rare GSFLs and IRLs are difficult to reverse- points for some of the higher performing Gases: A CryoGas International Market Report.’’ CryoGas International, February 2012. (Last engineer (i.e., not easily disassembled), IRLs from the major manufacturers accessed October 25, 2013.) end-user prices for the lamps covered in outlets, including both online outlets

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and brick and mortar stores, with the online sites set their own price points of consumers. (ASAP, Public Meeting highest price at $16.49 and the average and these can be very high. (GE, Public Transcript, No. 30 at pp. 202–203) price of $13.03. (CA IOUs, No. 32 at pp. Meeting Transcript, No. 30 at p. 201) Additionally, ASAP remarked that if 10–11) NEEA and NPCC also questioned For this NOPR analysis, DOE updated a consumer pays the high price, they are the high prices, specifically prices its pricing database and its blue book probably doing so by choice, as the greater than $15 for 50–70 W halogen information and developed updated medium price is accessible. ASAP lamps with an efficacy of 20 lm/W or high, medium, and low prices for the likened the scenario to purchasing a less. (NEEA and NPCC, No. 34 at p. 6) IRL representative lamps at CSL 1. book, where large online retailers and In the preliminary analysis, while the These prices were slightly lower than bookstore chains will have the book representative lamp at CSL 1 had a 20 those determined in the preliminary significantly marked down, but a lm/W catalog efficacy, its compliance analysis because of updated price data consumer could choose to pay a high values indicated a lower tested efficacy, collected from online retailers and price in order to support a small local resulting in an adjustment of CSL 1 to updated blue book prices. DOE also bookstore. ASAP reasoned that very few the 6.2P0.27 coefficient that would result received updated blue book prices for lamps would be sold at the high price in an efficacy of 18.3 lm/W for a 55 W lamps covered under this rulemaking. and suggested DOE weight the prices lamp. Therefore, in the preliminary DOE’s pricing analysis intends to accordingly. (ASAP, Public Meeting analysis, DOE determined prices of a capture a full range of available prices. Transcript, No. 30 at pp. 202–203) lamp that represented the minimum DOE believes that the medium prices Taking into consideration the above efficacy at CSL 1. Further, the used in the main results are comments, in this NOPR analysis DOE representative lamp prices at CSL 1 for representative of the average price paid developed an end-user price weighted IRLs were determined to be $9.29 for the by the consumer. by distribution channel. Using low price, $16.34 for the medium price, DOE also received comments manufacturer feedback in interviews, and $23.77 for the high price in the regarding using a weighted price in its DOE determined an aggregated preliminary analysis. These prices were main results. NEEA and ASAP urged percentage of shipments that go through based on publicly available price data, DOE to weight the high, medium, and each of the main channels for GSFLs including prices from available state low end-user prices rather than using and IRLs. The large distributors and DIY procurement contracts and a substantive sensitivities. (NEEA, Public Meeting stores channel was estimated at 85 number of Internet retailers. Any lamp Transcript, No. 30 at pp. 202–203; percent, the state procurement channel prices from only one Internet retailer or ASAP, Public Meeting Transcript, No. at 10 percent, and the Internet retail one state procurement contract were 30 at pp. 203–204) NEEA also channel at 5 percent. DOE then applied removed from the pricing analysis, as emphasized the importance of these percentages respectively to the were any extremely high prices (i.e., weighting the different market prices in average medium price determined for extreme outliers in the price trend rulemakings, such as this one, where the large distributor and DIY stores, the observed for a lamp). DOE also nature of the product prohibits the average low price determined for state examined the lamp prices cited by the typical markup analysis methodology. procurement contracts, and the average CA IOUs and ASAP by identifying (NEEA, Public Meeting Transcript, No. high price determined for Internet prices for these lamps at generally 30 at p. 232) While it may be possible retailers. The sum of these weighted known lighting retailers, such as Home for some markets sources to charge more prices was used as the average Depot, Lowe’s, Grainger, and for the product, NEEA and NPCC consumer price for GSFLs and IRLs in eLightBulbs, and found average prices contended that such pricing has nothing the main LCC analysis and NIA. DOE up to $20. Regarding the CA IOUs’ to do with the cost efficiency and continued to utilize the low prices and comment that consumers will find should not impact the analysis. An ideal high prices in a sensitivity analysis in lower-priced products, DOE conducts pricing proposal would be one based on the LCC analysis. See chapter 7 of the the high price sensitivity in the LCC in sales-weighted average pricing. NEEA NOPR TSD for further information on part to address scenarios where and NPCC urged DOE to seriously the pricing analysis. DOE welcomes consumers do not purchase lamps at the revisit this part of the analysis. (NEEA feedback on the pricing methodology lowest price. and NPCC, No. 34 at p. 6) used in this analysis. Several stakeholders provided general NEEA cautioned DOE to be careful in comments indicating that the prices determining what fraction of the market F. Energy Use based on Internet retail presented in the is paying what price at each channel, For the energy use analysis, DOE preliminary analysis were too high. and ASAP suggested DOE account for estimated the energy use of lamps in the ASAP questioned why the Internet the end-user and volume of lamps field (i.e., as they are actually used by prices were higher than the DIY store specific to a channel. (NEEA, Public consumers). The energy use analysis prices that make up DOE’s medium Meeting Transcript, No. 30 at p. 232; provided the basis for other DOE case. ASAP noted that because such ASAP, Public Meeting Transcript, No. analyses, particularly assessments of the stores also sell products online, 30 at pp. 202–203) For the state energy savings and the savings in residential consumers would find these procurement channel, NEEA noted that consumer operating costs that could medium prices on the Internet. in the lighting market in their service result from DOE’s adoption of amended Additionally, ASAP mentioned that area, state contract pricing is available standard levels. commercial customers would be for every government or semi- educated enough to avoid the higher government entity, and therefore many 1. Operating Hours Internet prices, making it unlikely for lamps are sold at the low price. (NEEA, To develop annual energy use anyone to purchase products at the high Public Meeting Transcript, No. 30 at pp. estimates, DOE multiplied annual usage prices DOE presented. (ASAP, Public 231–232) ASAP also noted that many (in hours per year) by the lamp power Meeting Transcript, No. 30 at pp. 204– lamps are being sold through each state (in watts) for IRLs and the lamp-and- 205) GE, however, noted that DOE procurement contract but cautioned that ballast system input power (in watts) for found the prices online, demonstrating accessibility to these contracts is limited GSFLs. DOE characterized that the channel does exist. GE also and therefore, the low price they offer representative lamp or lamp-and-ballast stated that some retailers, small stores or is available to only a very small number systems in the engineering analysis. To

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characterize the country’s average use of NEEA offered data from their a. General Service Fluorescent Lamp lamps for a typical year, DOE developed residential sector energy use field Lighting Controls annual operating hour distributions by survey of 2,200 lighting fixtures in 1,400 In the preliminary analysis, DOE sector, using data published in the 2010 houses. NEEA noted that DOE could use assessed the impacts of dimmers on U.S. Lighting Market Characterization the data to verify analyses and findings. GSFLs by determining the reduction in 52 report (2010 LMC), the Commercial NEEA also mentioned their commercial system lumen output and system input Building Energy Consumption Survey sector energy use field survey, but stated power as a result of using dimming 53 (CBECS), the Manufacturer Energy that they might not have those data in ballasts. Based on product research and 54 Consumption Survey (MECS), and the time for NOPR analyses. (NEEA, Public manufacturer feedback, DOE analyzed Residential Energy Consumption Survey Meeting Transcript, No. 30 at pp. 210, dimming scenarios for 2-lamp 4-foot 55 (RECS). 212) DOE examined NEEA’s Residential MBP systems, 4-lamp 4-foot MBP NEMA agreed with the considered Building Stock Assessment reports,56 systems, 2-lamp 4-foot T5 MiniBP SO operating profiles. (NEMA, No. 36 at p. but continued to use the data sources systems, and 2-lamp 4-foot T5 MiniBP 15) GE also stated that the operating described above in its analysis because HO systems operating in the commercial hours looked reasonable. (GE, Public NEEA’s data is limited to the northwest and industrial sectors. DOE determined Meeting Transcript, No. 30 at p. 212) region. DOE did not find any recent that the average reduction of system However, EEI found the similarity NEEA report regarding energy usage in lumen output for GSFLs was 33 percent between the GSFL commercial and the commercial sector at the publication based on research and manufacturer industrial operating hours to be of this notice. input. surprising. (EEI, Public Meeting 2. Lighting Controls GE asked for clarification on how Transcript, No. 30 at pp. 212–213) DOE was incorporating the percentage In the preliminary analysis, DOE DOE evaluated the impact of lighting to which the dimmed lamps were being calculated weighted average operating controls on the energy use of GSFLs and dimmed. (GE, Public Meeting hours using the probability of a building IRLs. Most lighting controls have one of Transcript, No. 30 at pp. 211) DOE type within each sector using the data two impacts: Reducing operating incorporated this assumption by sources described above. These sources wattage or reducing operating hours. decreasing the BF of the baseline ballast provide the most accurate and recent DOE refers to these two groups of by 33 percent and subsequently data available on a national scale. DOE’s controls as dimmers or light sensors, calculating the system mean lumen approach resulted in similar operating and occupancy sensors, respectively. output of the baseline lamp-and-ballast hours for the commercial and industrial The calculated operating hours used in system. DOE then assumed that each sectors. the reference case already account for higher efficacy lamp-and-ballast system DOE updated the methodology for the use of occupancy sensors because would be dimmed to equal the mean determining operating hours in the the 2010 LMC operating hour data are lumen output of the baseline system and NOPR analysis. The weighted average based on building surveys and metering adjusted the BF accordingly. DOE operating hours are based on the data. In the preliminary analysis, DOE calculated the percentage each higher probability of a GSFL or IRL within a accounted for the use of dimmers or efficacy lamp-and-ballast system was specific building type, rather than based light sensors by modeling GSFLs and dimmed by dividing the BF at the on the probability of the building type. IRLs on dimmers and developing dimmed light output by the catalog BF DOE used the average lamps per square associated energy use results for both at full light output. For more foot and the percentage of lamps that are types of covered lamps as a sensitivity information, see appendix 6A of the linear fluorescent or halogen from the analysis. See appendix 6A of the NOPR NOPR TSD. 2010 LMC to calculate these values. The TSD for further information. Several commenters supported DOE’s analysis of dimming systems for GSFLs, average operating hours using the Regarding the dimming scenarios, noting that dimming systems are revised methodology are similar to those NEMA noted that the dimming systems growing in popularity and provide the found in the preliminary analysis. For save more energy than the standards potential for significant energy savings. further details on the operating hours, considered in this rulemaking. NEMA NEMA stated that when it encourages see chapter 6 of the NOPR TSD. asserted that this furthered their high efficacy fluorescent retrofits arguments that this rulemaking is 52 through one of its marketing programs, U.S. Department of Energy, Office of Energy unnecessary and a ‘‘system approach’’ Efficiency and Renewable Energy. Energy it always tries to encourage lighting would be more advantageous for energy Conservation Program for Consumer Products: 2010 controls. Thus, when a retrofit results in efficiency. NEMA contended that DOE U.S. Lighting Market Characterization. 2012. increased brightness there is the option Washington, DC. http://apps1.eere.energy.gov/ pursues diminishing returns through to dim, which is where the largest buildings/publications/pdfs/ssl/2010-lmc-final-jan- component standards and distracts 2012.pdf. amount of savings lies. (NEMA, Public resources from more beneficial 53 U.S. Department of Energy, Energy Information Meeting Transcript, No. 30 at pp. 108– efficiency efforts. (NEMA, No. 36 at p. Administration. Commercial Building Energy 109) Further, Lutron stated that it agreed 15) DOE did not consider a system Consumption Survey: Micro-level data, file 2 that the 33 percent energy savings from Building Activities, Special Measures of Size, and approach in this rulemaking because dimming systems cited in the Multi-building Facilities. 2003. Washington, DC. EPCA directs DOE to undertake a review www.eia.gov/consumption/commercial/data/2003/ preliminary analysis is close to the of standards for GSFLs and IRLs and index.cfm?view=microdata. actual savings that can be expected as 54 determine if amended standards for U.S. Department of Energy, Energy Information opposed to the savings estimated from Administration. Manufacturing Energy these lamp types would result in energy higher lamp efficacy. (Lutron, Public Consumption Survey, Table 9.1: Enclosed savings. (42 U.S.C. 6295(i)(1) and (3)– Floorspace and Number of Establishment Buildings. Meeting Transcript, No. 30 at pp. 73–74) (5)) 2006. Washington, DC. www.eia.gov/consumption/ Commenters expressed concerns, manufacturing/data/2006/xls/Table9_1.xlsl. however, regarding the calculated 55 U.S. Department of Energy, Energy Information 56 NEEA’s Residential Building Stock Assessment Administration. RECS Public Use Microdata files. available at http://neea.org/resource-center/ energy consumption of a dimmed lamp- 2009. Washington, DC. www.eia.gov/consumption/ regional-data-resources/residential-building-stock- and-ballast system and the inclusion of residential/data/2009/. assessment. reduced wattage lamps in the dimming

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analysis. Lutron noted that GSFL light that CSLs should be set to retain the 32 Lutron commented that the lifetime output and input power do not scale W lamps. (NEMA, No. 36 at p. 14) multiplier given for IRLs appears to be perfectly linearly from zero. Lutron DOE acknowledges that reduced based on the standard incandescent explained that there is an offset at the wattage lamps may dim unreliably in formula published in the IESNA low end that accounts for the required certain applications. DOE discusses the Lighting Handbook. Lutron stated that electrode heating, typically a few dimmability of reduced wattage lamps the multiplier that should be used for percent of the total maximum rated in VI.B.1. In the preliminary analysis halogen PAR lamps, while still between power. The light output and input and this NOPR analysis, however, DOE three and four, is lower than the power scale linearly after this point. identified several manufacturers that multiplier DOE used. (Lutron, Public (Lutron, Public Meeting Transcript, No. published performance data of both 28 Meeting Transcript, No. 30 at pp. 214– 30 at p. 220) NEMA referenced their W and 25 W 4-foot MBP lamps when 215) NEMA also disagreed with DOE’s white paper LSD–345 and added that paired with dimming ballasts. This data assumption that the lamp life for the need for cathode heat skews efficacy indicates that these reduced wattage halogen products follows the calculations. The lower the light output, lamp types can be utilized in some incandescent curve of ‘‘Life ∼ V¥13,’’ the more cathode heat power increases, dimming applications. For this reason, where V is the voltage across the lowering the efficacy of the system. The DOE continues to analyze reduced filament. Based on NEMA’s research, systems are the most efficacious at full wattage 4-foot MBP lamps in its NEMA put forward the proper power, but NEMA clarified that this dimming analysis in addition to full relationship as ‘‘Life ∼ V¥10,’’ which does not mean that they do not save wattage 4-foot MBP lamps. Regarding T5 would result in a multiplier of 3 rather energy when dimmed, only that it is not lamps, DOE found that catalog than 4 for the reduction in light output a linear scale. (NEMA, No. 36 at p. 14) information generally did not indicate DOE considered. Therefore, NEMA DOE agrees that GSFL light output that reduced wattage T5 lamps should recommended a multiplier of 3, instead and input power do not scale linearly be operated on dimming ballasts. of the multiplier of 4 suggested in the from zero for dimming systems. In the Therefore, as in the preliminary preliminary TSD. (NEMA, No. 36 at p. preliminary analysis, DOE utilized analysis, DOE does not analyze reduced 15) manufacturer-published performance wattage T5 lamps in dimming systems. In the preliminary analysis, DOE did characteristics of the dimming systems As noted in section VI.D.2.g, DOE has not use an equation in the IESNA to develop the relationship between ensured that the full wattage lamps in Lighting Handbook to calculate the light output and input power. DOE all product classes meet the proposed lifetime multiplier and therefore was plotted the minimum and maximum ELs so that full wattage lamps are not employing the incandescent curve light output levels and associated available in situations where reduced referenced by NEMA or Lutron. Rather, system input powers published in wattage fluorescent lamps are DOE used Lutron’s Energy Savings catalogs, and then fit a linear equation unacceptable. Calculator, available on the Lutron Web to the points. The published system 57 b. Incandescent Reflector Lamp Lighting site. The values provided in this input power values at minimum light Controls calculator are based on experiments output reflected the presence of cathode conducted on halogen lamps, which heat at minimum light output and thus In the preliminary analysis, DOE provide the most accurate the linear equations did not originate at research indicated that, on average, representation of the lifetime increase zero. This approach was maintained in consumers using dimmers reduce lamp that occurs as a result of dimming the NOPR analysis. For more wattage by 20 percent, corresponding to halogen IRLs because they are based on information, see appendix 6A of the a lumen reduction of 25 percent and an halogen technology instead of NOPR TSD. increase in lifetime by a factor of 3.94. incandescent technology and use Regarding reduced wattage lamps, DOE analyzed two scenarios in LCC experimental data. In this NOPR commenters noted that reduced wattage sensitivity analyses: (1) The light output analysis, DOE has continued to utilize lamps, which contain krypton, did not of the baseline lamp was reduced by 25 Lutron’s Energy Savings Calculator to provide the same dimming functionality percent and more efficient lamps were determine the lifetime multiplier as full wattage lamps. GE observed that dimmed to the same light output and (2) associated with various levels of if the GSFL standard is set at a level the characteristics of the lamps analyzed dimmed light output. requiring a heavier fill gas, namely represented the distribution of dimmers krypton, then the NES would start to across the nation. For the second G. Life-Cycle Cost Analysis and Payback decrease. GE and Lutron noted that even scenario, DOE used the 2010 LMC to Period Analysis though controls and dimmers are determine that 29 percent of halogen In the preliminary analysis, DOE already becoming required in buildings, IRLs operate on dimmers or light conducted LCC and PBP analyses to the krypton eliminates the ability to sensors in the residential sector and 5 evaluate the economic impacts of control and dim the lamps, negatively percent of halogen IRLs operate on potential energy conservation standards affecting the energy savings. (GE, Public dimmers in the commercial sector and for GSFLs and IRLs on individual Meeting Transcript, No. 30 at pp. 220– used these percentages to calculate consumers. The LCC is the total 221; Lutron, Public Meeting Transcript, weighted-average performance consumer expense over the life of a No. 30 at pp. 73–74) Philips stated that characteristics. DOE received several product, consisting of purchase, there is no published testing of dimming comments on its IRL dimming analysis. installation, and operating costs with krypton fill gas and currently no Lutron stated that they did not have (operating costs are expenses for energy standards for dimming ballasts. (Philips, independent data, but the estimate of use, maintenance, and repair). To Public Meeting Transcript, No. 30 at p. five percent of lamps in the commercial compute the operating costs, DOE 222) NEMA further emphasized these sector operating on dimmers seems discounted future operating costs to the points, cautioning DOE that reduced reasonably accurate. (Lutron, Public time of purchase and summed them wattage 28 W lamps are less feasible to Meeting Transcript, No. 30 at p. 217) over the lifetime of the product. The dim than 32 W lamps. NEMA suggested However, Lutron and NEMA disagreed DOE model a 32 W lamp for their with the value used for the lifetime 57 www.lutron.com/en-US/Education-Training/ dimming analyses. NEMA further stated multiplier. Pages/Tools/EnergySavingCalc.aspx.

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PBP is the estimated amount of time (in value by linearly prorating the product’s NEMA commented on the general years) it takes consumers to recover the initial cost consistent with the LCC methodology used in the increased purchase cost (including methodology described in the Life-Cycle preliminary analysis, stating that it installation) of a more efficient product Costing Manual for the Federal Energy appears the 30-year payback period for through lower operating costs. DOE Management Program.58 LCC analysis timeline, about which they calculates the PBP by dividing the As inputs to the PBP analysis, DOE had previously expressed concern, has change in purchase cost (normally used the total installed cost of the been stretched to a 70-year period for higher) by the change in average annual product to the consumer for each this rulemaking. NEMA assumed the operating cost (normally lower) that efficacy level, as well as the first-year time period was chosen to justify results from the more efficient standard. annual operating costs for each efficacy feasibility arguments that have DOE used a ‘‘simple’’ PBP for this level. The calculation requires the same miniscule payback estimates. NEMA rulemaking, which does not take into inputs as the LCC, except for energy requested that DOE clarify the 70-year account other changes in operating price trends and discount rates; only forecasting and related analyses, and expenses over time or the time value of energy prices for the year in which explain the justification for examining money. compliance with any new standard such a long period. (NEMA, No. 36 at For any given efficacy or energy use would be required (2017, in this case) pp. 3–4) level, DOE measures the PBP and the are needed. The PBP is the amount of time it takes change in LCC relative to an estimated To account for uncertainty and the consumer to recover the assumed base-case product efficacy or energy use variability, DOE created value higher purchase cost of a more- level. The base-case estimate reflects the distributions for inputs as appropriate, efficacious product through lower market without new or amended including operating hours, electricity operating costs. DOE calculates and mandatory energy conservation prices, discount rates and sales tax rates, presents the payback period for all LCC standards, including the market for and disposal costs. For example, DOE scenarios, regardless of the value of the products that exceed the current energy created a probability distribution of payback period, including the long conservation standards. annual energy consumption in its payback periods referenced by NEMA. Inputs to the calculation of total energy use analysis, based in part on a Payback periods are one of the factors installed cost include the cost of the range of annual operating hours. The that DOE considers when weighing the product—which includes consumer operating hour distributions capture benefits and burdens of TSLs. product price and sales taxes—and variation across census divisions and In the NOPR analysis, DOE generally installation costs. Inputs to the large states, building types, and lamp or maintained the methodology from the calculation of operating expenses lamp-and-ballast systems for three preliminary analysis, with a few include annual energy consumption, sectors (commercial, industrial, and changes. Table VI.13 summarizes the energy prices and price projections, residential). approach and data DOE used to derive repair and maintenance costs, product DOE conducted the LCC and PBP inputs to the LCC and PBP calculations lifetimes, discount rates, and the year in analyses using a spreadsheet model for the preliminary analysis as well as which compliance with proposed developed in Microsoft Excel. When the changes made for this NOPR. The standards would be required. DOE also combined with Crystal Ball (a NOPR TSD chapter 8 and its appendices incorporated a residual value commercially available software provide details on the spreadsheet calculation to account for any remaining program), the spreadsheet model model and of all the inputs to the LCC lifetime of lamps at the end of the generates a Monte Carlo simulation 59 to and PBP analyses. The NOPR TSD analysis period. The residual value is an perform the analysis by incorporating appendix 8B provides results of the estimate of the product’s value to the uncertainty and variability sensitivity analyses conducted using consumer at the end of the LCC analysis considerations. The Monte Carlo Monte Carlo simulation. The period. In addition, this residual value simulations randomly sample input subsections that follow discuss the recognizes that a lamp may continue to values from the probability distributions comments regarding each initial input function beyond the end of the analysis and lamp user samples, performing and any changes made to them in the period. DOE calculates the residual 1,000 iterations per simulation run. NOPR analysis.

TABLE VI.13—SUMMARY OF INPUTS AND KEY ASSUMPTIONS IN THE LCC AND PBP ANALYSES *

Inputs Preliminary TSD Changes for the proposed rule

Consumer Product Price...... Applied discounts to manufacturer catalog Applied discounts to manufacturer catalog (‘‘blue book’’) pricing in order to represent (‘‘blue book’’) pricing in order to represent low, medium, and high prices for all lamp low, medium, and high prices for all lamp categories. Used medium prices in the main categories. Used a weighted average price analysis. in the main analysis based on the percent- age of shipments that go through the dis- tribution channel having low, medium, or high prices.

58 Fuller, Sieglinde K. and Stephen R. Peterson. Federal Energy Management Program, Office of the 59 Monte Carlo simulations model uncertainty by National Institute of Standards and Technology Assistant Secretary for Conservation and Renewable utilizing probability distributions instead of single Handbook 135 (1996 Edition); Life-Cycle Costing Energy.) February 1996. NIST: Gaithersburg, MD. values for certain inputs and variables. Manual for the Federal Energy Management Available at: http://fire.nist.gov/bfrlpubs/build96/ Program. (Prepared for U.S. Department of Energy, PDF/b96121.pdf.

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TABLE VI.13—SUMMARY OF INPUTS AND KEY ASSUMPTIONS IN THE LCC AND PBP ANALYSES *—Continued

Inputs Preliminary TSD Changes for the proposed rule

Sales Tax ...... Derived population-weighted-average tax val- Derived sector-specific average tax values ues for each census division and large based on the probability of purchasing a state 60 from data provided by the Sales GSFL or IRL in each census division and Tax Clearinghouse. large state from data provided by the Sales Tax Clearinghouse. Installation Cost ...... Derived costs using the RS Means Electrical No change. Cost Data and U.S. Bureau of Labor Statis- tics to obtain average labor times for instal- lation, as well as labor rates for electricians and helpers based on wage rates, benefits, and training costs. Annual Operating Hours...... Determined operating hours by associating Determined operating hours by associating building-type-specific operating hour data operating hours for a GSFL or IRL in a spe- with regional distributions of various build- cific building type using the average lamps ing types using the 2010 LMC and EIA’s per square foot and the percentage of 2003 CBECS, 2009 RECS, and 2006 lamps of each type with regional distribu- MECS. tions of various building types using the 2010 LMC and EIA’s 2003 CBECS, 2009 RECS, and 2006 MECS. Product Energy Consumption Rate ...... Determined lamp input power for IRLs based No change. on published manufacturer literature. Cal- culated system input power for GSFLs. Used lamp arc power, catalog BF, number of lamps per system, and tested BLE (when possible) to calculate system input power for each unique lamp-and-ballast combina- tion. Electricity Prices ...... Electricity: Based on EIA’s Form 861 data for Electricity: Based on EIA’s Form 861 data for 2011. 2011 scaled to 2012 (the dollar year of the analysis) using AEO 2013 and the con- sumer price index. Variability: Weighted average national price Variability: Weighted average national price for each sector calculated from the prob- for each sector and lamp type calculated ability of each building type within each from the probability of a GSFL or IRL pur- census division or large state. chased in each census division or large state Electricity Price Projections ...... Forecasted using AEO 2012 ...... Forecasted using AEO 2013. Replacement and Disposal Costs ...... Commercial and industrial: Included labor and No change. materials costs for lamp replacement, and disposal costs for failed GSFLs. Residential: Included only materials cost for lamps, with no lamp disposal costs. Product Lifetime ...... Ballast lifetime based on average ballast life No change. of 49,054 from 2011 Ballast Rule. Lamp lifetime based on published manufacturer literature where available. Discount Rates ...... Commercial and industrial: Derived discount No change. rates using the cost of capital of publicly traded firms in the sectors that purchase lamps, based on data in the 2003 CBECS, Damodaran Online,61 Office of Manage- ment and Budget (OMB) Circular No. A– 94,62 and state and local bond interest rates 63. Residential: Derived discount rates using the finance cost of raising funds to purchase lamps either through the financial cost of any debt incurred to purchase product or the opportunity cost of any equity used to purchase equipment, based on the Federal Reserve’s Survey of Consumer Finances data 64 for 1989, 1992, 1995, 1998, 2001, 2004, 2007, and 2010. Analysis Period ...... IRLs and commercial and industrial GSFLs: IRLs and commercial and industrial GSFLs: Based on the baseline lamp life in hours di- No change. vided by the annual operating hours of that lamp. Residential GSFLs lamp failure: Based on the Residential GSFLs lamp failure: Based on the baseline lamp life in hours divided by the lifetime of the ballast. annual operating hours of that lamp.

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TABLE VI.13—SUMMARY OF INPUTS AND KEY ASSUMPTIONS IN THE LCC AND PBP ANALYSES *—Continued

Inputs Preliminary TSD Changes for the proposed rule

Residential GSFLs ballast failure and new Residential GSFLs ballast failure and new construction/renovation: Based on the life- construction/renovation: No change. time of the ballast. Compliance Date of Standards ...... 2017 ...... No change. Lamp Purchase Events ...... Assessed three events: lamp failure, ballast No change. failure (GSFLs only), and new construction/ renovation. * References for the data sources mentioned in this table are provided in the sections following the table or in chapter 8 of the NOPR TSD.

lamps and PAR lamps reported by the probability of a lamp type purchased in U.S. Census Bureau in their Current each census division and large state. 1. Consumer Product Price Industrial Reports, DOE examined Therefore, in the NOPR analysis, DOE In the preliminary analysis, DOE used product prices trends, fitting the data to calculated a weighted average sales tax a variety of sources to develop an experience curve, as described in based on the probability of a GSFL or consumer product prices, including chapter 11 of the NOPR TSD. DOE IRL purchased for a particular building lamp prices from manufacturers’ blue found that the data are well-represented type in each census division and large books, state procurement contracts, by the experience curve and consistent state. DOE used information in the 2010 large electrical supply distributors, with price learning theory. Therefore, LMC, such as the number of lamps per hardware and home improvement consistent with the NODA, DOE square feet and the percentage of lamps stores, Internet retailers, and other incorporated price trends into this within a building that are linear similar sources. DOE then developed rulemaking. In the LCC analysis, DOE fluorescent or halogen. In combination low, medium, and high prices based on adjusts prices for each year using the with this information, DOE used its findings. Medium prices were used experience curve. CBECS, MECS, and RECS respectively, in the main analysis results. In the 2. Sales Tax for commercial, industrial, and NOPR analysis, DOE maintained the residential building data on building same methodology but calculated a In the preliminary analysis, DOE types in each census division and large weighted average price based on the obtained state and local sales tax data state. Thus, in the preliminary analysis, percentage of shipments going through from the Sales Tax Clearinghouse. The the sales tax was averaged based on the the low discount (high price), medium data represented weighted averages that number of people in a region or state, discount (medium price), and high included county and city rates. DOE whereas in the NOPR, the sales tax is discount (low price) distribution used the data to compute population- averaged based on how many people channels. Because fluorescent lamps weighted average tax values for each purchase a GSFL or IRL in a region or operate on a ballast in practice, DOE census division and four large states state. analyzed lamp-and-ballast systems in (New York, California, Texas, and the engineering analysis and therefore Florida). 3. Installation Cost also determined end-user prices for EEI asked if DOE had any information The installation cost is the total cost ballasts. DOE utilized the end-user on local sales taxes, such as city or to the consumer to install the product, prices from the 2011 Ballast Rule county taxes, which would be added to excluding the consumer product price. converted to 2012$ to develop prices for the state sales tax. EEI noted that Installation costs include labor, replacement ballasts. without considering the additional local overhead, and any miscellaneous On February 22, 2011, DOE published taxes, especially in urban areas with materials and parts. As detailed in the a notice of data availability (NODA; 76 commercial buildings, DOE may be preliminary analysis, DOE considered FR 9696) stating that DOE may consider missing relevant sales tax data. (EEI, the total installed cost of a lamp or whether its regulatory analysis would be Public Meeting Transcript, No. 30 at pp. lamp-and-ballast system to be the improved by addressing product price 230–231) NEEA added that there are consumer product price (including sales trends. Using three decades of historic some publicly available local tax data by taxes) plus the installation cost. For the data on the quantities and values of county. (NEEA, Public Meeting commercial and industrial sectors, DOE domestic shipments of fluorescent Transcript, No. 30 at p. 231) assumed consumers must pay to install In the preliminary analysis, DOE used the lamp or lamp-and-ballast system 60 The four large states are New York, California, the Sales Tax Clearinghouse for sales tax and assumed the installation cost was Texas, and Florida. data by state. Because the Sales Tax 61 the product of the average labor rate and Damodaran Online, The Data Page: Historical Clearinghouse specifies that the Returns on Stocks, Bonds, and Bills—United States the time needed to install a lamp or aggregate rates are weighted averages (2013). Available at: http://pages.stern.nyu.edu/ lamp and ballast. In the residential ∼adamodar. (Last accessed September, 2013.) that include county and city rates, DOE sector, DOE assumed that consumers 62 U.S. Office of Management and Budget, accounts for the levels of taxes must pay for only the installation of a Circular No. A–94 Appendix C (2012). Available at: described in the comments. www.whitehouse.gov/omb/circulars_a094/a94_ lamp-and-ballast system. Therefore, the In this NOPR analysis, DOE used appx-c. installation cost assumed was the 63 updated sales tax data from the Sales Federal Reserve Board, Statistics: Releases and product of the average labor rate and the Historical Data—Selected Interest Rates—State and Tax Clearinghouse.65 DOE recognized time needed to install the lamp-and- Local Bonds (2013). Available at: http:// that a population-weighted tax value www.federalreserve.gov/pubs/oss/oss2/ ballast system. DOE assumed that may not accurately represent the scfindex.html. residential consumers would install 64 The Federal Reserve Board, Survey of their own replacement lamps and, thus, Consumer Finances. Available at: 65 Sales Tax Clearinghouse. Aggregate State Tax www.federalreserve.gov/PUBS/oss/oss2/ Rates. (2013). Available at: http://thestc.com/ would incur no installation cost when scfindex.html. STrates.stm. replacing their own lamp.

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DOE did not receive any comments on a particular building type in each low (2 percent) estimated lamp the installation cost. DOE retained this census division and large state. DOE recycling rate in the residential sector, methodology for determining requests comment on its methodology of DOE assumed that residential installation costs in this NOPR analysis. determining average weighted consumers would be less likely to electricity prices. voluntarily incur the higher disposal 4. Annual Energy Use costs. Therefore, DOE excluded the As discussed in section VI.F, DOE 7. Electricity Price Projections disposal costs for lamps or ballasts from estimated the annual energy use of To estimate the trends in energy the LCC analysis for residential GSFLs. representative lamp or lamp-and-ballast prices for the preliminary analysis, DOE DOE received no comments systems by multiplying input power and used the price forecasts in AEO 2012. To concerning these assumed recycling sector operating hours. DOE maintained arrive at prices in future years, DOE rates, disposal costs, and their its methodology of determining annual multiplied current average prices by the application in the LCC analysis. DOE energy use inputs in this NOPR forecast of annual average price changes maintained this approach in the NOPR analysis. in AEO 2012. In this NOPR analysis, analysis. 5. Product Energy Consumption Rate DOE used the same approach, but 9. Lamp Purchase Events updated its energy price forecasts using As in the preliminary analysis, DOE AEO 2013. DOE intends to update its DOE designed the LCC and PBP determined lamp input power for IRLs energy price forecasts for the final rule analyses for this rulemaking around based on published manufacturer based on the latest available AEO. In scenarios where consumers need to literature. For GSFLs, DOE calculated addition, the spreadsheet tools that DOE purchase a lamp. Each of these events the system input power using published used to conduct the LCC and PBP may give the consumer a different set of manufacturer literature and test data. analyses allow users to select price lamp or lamp-and-ballast designs and, DOE used lamp arc power, catalog BF, forecasts from AEO’s low-growth, high- therefore, a different set of LCC savings number of lamps per system, and tested growth, and reference case scenarios to for a certain efficacy level. In the BLE (when possible) to calculate system estimate the sensitivity of the LCC and preliminary analysis, DOE evaluated input power for each unique lamp-and- PBP to different energy price forecasts. three types of events that would prompt ballast combination. The rated system DOE did not receive any comments on a consumer to purchase a lamp. These input power was then multiplied by the its methodology for determining events are described below. DOE annual operating hours of the system to electricity price projections. requests comments on these lamp determine the annual energy purchasing events developed for this consumption. DOE did not receive any 8. Replacement and Disposal Costs analysis. Though described primarily in comments on energy consumption rate In its preliminary analysis, DOE the context of GSFLs, lamp purchase calculations. DOE retained this addressed lamp replacements occurring events can be applied to IRLs as well. methodology for determining energy within the analysis period as part of However, considering that IRLs are not consumption in this NOPR analysis. installed costs for considered lamp or used with a ballast, the only lamp 6. Electricity Prices lamp-and-ballast system designs. purchase events applicable to IRLs are Replacement costs in the commercial lamp failure (Event I) and new For the LCC and PBP in the and industrial sectors included the labor construction and renovation (Event III). preliminary analysis, DOE derived • and materials costs associated with Lamp Failure (Event I): This event average energy prices for 13 U.S. replacing a lamp at the end of its reflects a scenario in which a lamp has geographic areas consisting of the nine lifetime, discounted to 2011$. For the failed (spot relamping) or is about to fail census divisions, with four large states residential sector, DOE assumed that (group relamping). In the base case, (New York, Florida, Texas, and consumers would install their own identical lamps are installed as California) treated separately. For replacement lamps and incur no related replacements. In the standards case, the census divisions containing one of these labor costs. consumer installs a standards compliant large states, DOE calculated the regional Some consumers recycle failed lamp that is compatible with the average excluding the data for the large GSFLs, thus incurring a disposal cost. In existing ballast. state. The derivation of prices was based • its research, DOE found average Ballast Failure (Event II): This is a on data from EIA Form 861, ‘‘Annual disposal costs of 10 cents per linear foot scenario in which the failure of the Electric Power Industry Database.’’ DOE for GSFLs.66 A 2004 report by the installed ballast triggers a lamp and calculated a weighted average national Association of Lighting and Mercury ballast purchase. electricity price for each sector using the • New Construction and Renovation Recyclers noted that approximately 30 probability of each building type within (Event III): This event encompasses all percent of lamps used by businesses and each census division or large state. DOE fixture installations where the lighting 2 percent of lamps in the residential did not receive any comments on this design will be completely new or can be sector are recycled nationwide.67 DOE approach. completely changed. During new considered the 30 percent lamp- In the NOPR analysis, DOE calculated construction and renovation, the spatial recycling rate to be significant and weighted average electricity prices layout of fixtures in a building space is incorporated GSFL disposal costs into based on the probability of a GSFL or not constrained to any previous the LCC analysis for commercial and IRL purchased in each census division configuration. However, because DOE’s industrial consumers. Given the very and large state. The same methodology higher efficacy replacements generally as noted previously for determining maintain lumen output within 10 66 Environmental Health and Safety Online’s average weighted sales tax was used to fluorescent lights and lighting disposal and percent of the baseline system, DOE did calculate average weighted electricity recycling Web page—Recycling Costs. Available at not assume that spacing was changed. prices. DOE used data published in the www.ehso.com/fluoresc.php. (Last accessed October DOE received comments stating that 2010 LMC in combination with CBECS, 11, 2013.) fixture spacing is adjusted during new 67 Association of Lighting and Mercury Recyclers, MECS, and RECS to determine an ‘‘National Mercury-Lamp Recycling Rate and construction and renovation. NEEA average weighted electricity price based Availability of Lamp Recycling Services in the related that during tenant improvement on the probability of a GSFL or IRL in U.S.’’ Nov. 2004. in their market, the ceiling is the first

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item to be stripped, and the lighting fixtures, and the fixtures’ performance. interviews that consumer behavior has system is redesigned as part of the (NEMA, Public Meeting Transcript, No. changed and group relamping now regular renovation between tenant 30 at pp. 259–260) Philips added that occurs at 85–90 percent of rated life. occupancies. Therefore, NEEA when adjusting fixture spacing, the Therefore, in the NOPR analysis DOE contended, brand new ballasts and hangers for the lights will also have to assumes that a lamp subject to group lamps are installed without regard to the be changed in many scenarios. Given relamping operates for 85 percent of its previous fixture locations. NEEA added that this modification necessitates going rated lifetime. By considering lamp that T8 lamps are the only lighting into the ceiling, and the prevalence of rated lifetimes and the prevalence of element likely to be preserved in this asbestos, it is unlikely the consumer group versus spot relamping practices, scenario, and they would be used in a would want to make this adjustment. DOE derived an average lifetime for a new fixture with a new ballast. (NEEA, (Philips, Public Meeting Transcript, No. GSFL. This ranged from 94 percent of Public Meeting Transcript, No. 30 at pp. 30 at pp. 260–261) If consumers were rated lifetime for 8-foot SP slimline 261–262) EEI commented that there are not installing new lamps, GE believed lamps to 96 percent of rated lifetime for minimum foot-candle requirements to they would more likely switch to a 4-foot MBP lamps. See chapter 8 of the light spaces, and scenarios that result in ballast with a better ballast factor rather NOPR TSD for further details. DOE lower lumen output from the baseline than respace fixtures. (GE, Public requests comment on its spot and group system will also include adjustments to Meeting Transcript, No. 30 at pp. 258– relamping assumptions, particularly the the fixture spacing to maintain those 259) percent of rated life at which group lumens. (EEI, Public Meeting Transcript, NEMA further remarked that relamping occurs. No. 30 at pp. 257–258) substantial changes in efficacy or lumen As stated above, DOE is using 15 NEEA also argued that respacing output are necessary to warrant space years as the estimated fixture and ballast would occur with a new renovation changes. (NEMA, No. 36 at p. 16) GE lifetime in the residential sector for because the space would likely gain a agreed that it would be very unlikely for purposes of its analyses. In the whole new control system with users to respace fixtures to preliminary analysis, the lifetime of the daylighting and dimming fixtures not accommodate compliant lamps’ lumen baseline GSFL in the residential sector installed previously. Due to a different output. (GE, Public Meeting Transcript, was calculated by dividing the life in number people in a different office No. 30 at pp. 258–289) hours by the average operating hours of configuration, everything would have to DOE agrees that spacing adjustments a GSFL in the residential sector (648 be redesigned, making renovation more are not practical. Ceiling grid systems hours per year), which resulted in a like new construction. (NEEA, Public typically come in fixed layouts, and lifetime of 37 years for the baseline Meeting Transcript, No. 30 at p. 263) lamp fixtures are sized to be compatible lamp. Because this lifetime of the However, Lutron stated that all the with the commonly available grid baseline lamp was longer than the elements added in the described options. Thus, DOE believes that average lifetime of a fixture and ballast, renovation were the result of design and consumers are limited in the spacing of for the lamp failure scenario, DOE technical changes unrelated to the fixtures by the ceiling grid and its assumed that residential sector GSFL lighting regulations. (Lutron, Public associated components. DOE also agrees consumers were able to realize the full Meeting Transcript, No. 30 at p. 263) that consumers would be more likely to rated lifetime of their lamps. Therefore, Lutron noted that even if the lighting change light output levels by adjusting at the average operating hours of 648 design of a space was completely altered system components such as the ballast hours per year, DOE utilized the full during renovation, there would still be factor (i.e., use a high BF or low BF lifetime of the baseline lamp (37 years) the same number of lamps and the same ballast) or lamp lumen output levels as the analysis period. DOE assumed load. (Lutron, Public Meeting (e.g., 32 W 4-foot MBP high lumen that when a ballast is removed in the Transcript, No. 30 at pp. 262–263) lamp) rather than attempting to adjust middle of the analysis period, these DOE also received several comments fixture spacing using non-standard consumers preserve their lamps, indicating that the respacing of fixtures, ceiling grids. DOE acknowledges that purchase a new ballast of the same type even in new construction or renovation, as the initial ballast, and then have the fixture spacing adjustments may be is unlikely due to ceiling grid new ballast installed with the preserved done in certain cases as cited by NEEA. constraints. NEMA stated that respacing lamps (incurring a lamp-and-ballast Based on available information and the is not a practical assumption for this system installation cost). In contrast, for other comments discussed above, rulemaking, and would not happen in the ballast failure and new construction however, such adjustments are not a practice other than to existing ready- and renovation events, DOE assumed common practice nationwide. Thus, made dimensions. Spacing is effectively that the ballast or fixture lifetime limits DOE did not include spacing constrained by existing practices and the lifetime of an average lamp in the adjustments as part of the LCC analysis. ceiling grid construction, and not residential sector. Under average determined by the lighting selected. 10. Product Lifetime operating hours of 648 hours per year, Further, NEMA clarified that spacing is DOE assumed that lamp lifetime of the a. Lamp Lifetime almost always based on the available 1 baseline-case and standards-case lamps by 1, 2 by 2, or 2 by 4 ceiling grids, and In the preliminary analysis, DOE used is limited to 9,723 hours or 15 years, that must be factored into the analysis. manufacturer literature to determine due to a ballast or fixture failure. See The likelihood of other spacing is near lamp lifetimes. DOE also considered the section VI.G.9 and chapter 5 of the zero. (NEMA, No. 36 at p. 16) GE agreed impact of group relamping practices on NOPR TSD for a description of lamp that the standard 2 by 4 ceiling grids GSFL lifetime in the commercial and purchase events. DOE requests comment make it nearly impossible to respace industrial sectors. In the preliminary on its general approach to determining fixtures in response to a change of a few analysis, DOE assumed that a lamp lamp lifetime for this analysis. lumens per watt. (GE, Public Meeting subject to group relamping operates for NEMA disagreed with the assumption Transcript, No. 30 at pp. 258–289) 75 percent of its rated lifetime, an that lamps will be retained upon ballast NEMA also noted that there is an estimate obtained from the 2011 Ballast failure. NEMA stated that the most interdependence among the ceiling Rule. However, DOE received likely thing that occurs when a light material, the modular wire strings, the information from manufacturers in fixture in the residential sector fails to

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provide light is that new lamps are products. The finance cost of raising residential discount rate was calculated purchased. The next step if the fixture funds to purchase these products can be to be lower than the industrial discount still does not work is to replace the interpreted as: (1) The financial cost of rate. Therefore, DOE believes it is whole fixture, not just the ballast. As a any debt incurred to purchase products appropriately determining discount result, NEMA contended that a failed (principally interest charges on debt), or rates for all types of consumers and has ballast will result in the lamps (new and (2) the opportunity cost of any equity maintained this methodology in this old) being scrapped (or returned) when used to purchase products (principally NOPR analysis. For further details on the entire fixture is replaced. (NEMA, interest earnings on household equity). discount rates, see chapter 8 and No. 36 at p. 16) GE explained that when Household equity is represented by appendix 8C of the NOPR TSD. a ballast fails, it can operate in such a holdings in assets such as stocks and 12. Analysis Period way that damages the lamp, especially bonds, as well as the return on the cathodes. When a lamp goes out, a homeowner equity. Much of the data The analysis period is the span of residential consumer will likely assume required, which involves determining time over which the LCC is calculated. that the problem is the lamp itself; very the cost of debt and equity, comes from In the preliminary analysis, DOE used rarely would a consumer understand the Federal Reserve Board’s triennial the longest baseline lamp life in a that only the ballast needs to be ‘‘Survey of Consumer Finances.’’ 69 For product class divided by the annual replaced and instead replace the entire the commercial and industrial sectors, operating hours of that lamp as the fixture. (GE, Public Meeting Transcript, DOE derived discount rates from the analysis period. During Monte Carlo No. 30 at pp. 235–237) cost of capital of publicly traded firms simulations for the LCC analysis, DOE DOE evaluated the likely replacement in the business sectors that purchase selected the analysis period based on scenarios suggested by stakeholders and lamps. the longest baseline lamp life divided by agrees that it is more likely for a EEI pointed out residential consumers the annual operating hours chosen by residential consumer to replace an have a lower discount rate than Crystal Ball. For GSFLs in the entire lamp-and-ballast system rather industrial customers do. EEI noted that residential sector, the analysis period is than only the ballast because consumers if residential consumers use any form of based on the useful life of the baseline would not necessarily be aware that credit, the nominal interest rate lamp for a specific event. DOE did not only the ballast failed. Thus, in the typically will be above 10 percent. receive any comments on this NOPR analysis, DOE no longer assumes Thus, EEI questioned why a well- methodology. DOE maintained this that consumers retain their lamp when capitalized industrial company would approach for determining the analysis the ballast fails. See Appendix 8B of the have a higher discount rate than period in the NOPR analysis. DOE NOPR TSD for more details. DOE residential consumers with varying requests comment on its LCC analysis requests comment on its approach to incomes and credit card interest rates. period assumptions. In particular, DOE determining lamp lifetime. (EEI, Public Meeting Transcript, No. 30 requests comment on basing the at pp. 228–229) analysis period on the baseline lamp life b. Ballast Lifetime The discount rate is the rate at which divided by the annual operating hours Chapter 8 of the preliminary analysis future expenditures are discounted to of that lamp for the IRL and commercial detailed DOE’s development of average estimate their present value. The and industrial sector GSFL analyses. ballast lifetimes, which were based on discount rate accounts for consumers DOE also requests comment on basing assumptions used in the 2011 Ballast placing a certain value on spending the analysis period on the useful life of Rule. For ballasts in the commercial and money now versus in the future. For the baseline lamp for a specific event for industrial sectors, DOE used an average residential consumers, DOE estimated residential GSFLs. ballast lifetime of 49,054 hours. the discount rate by looking across all Consistent with the 2011 Ballast Rule, possible debt or asset classes. Thus, the 13. Compliance Date of Standards DOE assumed an average ballast lifetime residential discount rate is not limited The compliance date is the date when of approximately 15 years in the to credit. The residential discount rate a covered product is required to meet a residential sector. DOE received no analysis factors in 12 different methods new or amended standard. DOE expects comments on this approach. In this to finance purchases and the rates for to publish any amended standards for NOPR analysis DOE retained the ballast these methods vary from 0 to 10.4 GSFLs and IRLs in 2014. As a result, lifetimes used in the preliminary percent. As DOE estimates the discount consistent with 42 U.S.C. 6295(i)(5), analysis. rate by looking across all 12 of these DOE expects the compliance date to be 11. Discount Rates debt and asset classes, and the discount 2017, three years after the publication of rate is not limited to credit, the average any final amended standards. DOE The calculation of consumer LCC rate is lower than 10 percent. For the received no comments on its expected requires the use of an appropriate commercial and industrial consumers, standards compliance date of 2017 and discount rate. DOE used the discount DOE estimated the cost of capital for calculated the LCC for all end users as rate to determine the present value of commercial and industrial companies if each one would purchase a new lamp lifetime operating expenses. The by examining both debt and equity in the year compliance with the discount rate used in the LCC analysis capital, and developed an appropriate standard is required. represents the rate from an individual weighted average of the cost to the consumer’s perspective.68 company of equity and debt financing. 14. General Service Fluorescent Lamp In the preliminary analysis, for the After performing these calculations and Life-Cycle Cost Results in the residential sector, DOE derived discount averaging each discount rate across Preliminary Analysis rates from estimates of the interest or various types of consumers, the NEMA and EEI noted that in the ‘‘finance cost’’ to purchase residential tables presented at the public meeting, 69 The Federal Reserve Board. Survey of the results for the GSFL LCC savings 68 The consumer discount rate is in contrast to the Consumer Finances 1989, 1992, 1995, 1998, 2001, included instances of ‘‘NR.’’ (NEMA, discount rates used in the NIA, which are intended 2004, 2007, 2010. Federal Reserve Board: to represent the rate of return of capital in the U.S. Washington, DC. Available at: No. 36 at pp. 15–16; EEI, Public Meeting economy as well as the societal rate of return on www.federalreserve.gov/pubs/oss/oss2/ Transcript, No. 30 at pp. 245–246) private consumption. scfindex.html. NEMA assumed NR indicated that the

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energy savings were zero or negative lamps are not compatible with presence of amended standards. (EEI, and stated that figures should be added dimming, their LCC savings would Public Meeting Transcript, No. 30 at pp. to the results because missing data likely be lower than shown, but would 254–256) points would skew the findings. NEMA be greater if total energy use was taken NEEA noted that delamping is a fairly stated that DOE should factor CSLs’ into account. (Lutron, Public Meeting common scenario, especially if DOE negative impacts into the analysis or Transcript, No. 30 at p. 251) DOE considers lighting retrofit as renovation, give reasons why figures should not be accounts for lighting controls in the LCC and NEEA stated they may have some included. (NEMA, No. 36 at pp. 15–16) in a sensitivity analysis. See section data on such scenarios. (NEEA, Public EEI attributed the ‘‘NR’’ to the baseline VI.F.2 and appendix 8B of the NOPR Meeting Transcript, No. 30 at pp. 256) and CSL 1 lamps having the same TSD for more details. GE agreed that delamping is a very nominal and rated wattages. EEI urged NEEP provided information that some typical situation when moving from T12 DOE to show the energy savings for of the ballast failure scenarios included to T8 systems. GE noted, however, that every event, even if they are zero. As the in the analysis are very uncommon. For in a T8 to T8 analysis, delamping would event is a possibility under standards, it example, DOE analyzed T8 programmed be much less likely. GE agreed that the will be an economic cost to the start ballasts when the vast majority of practice was common in the past, but consumer and the results need to be existing ballasts are instant start. (NEEP, did not anticipate it being that common factored into the analysis and reported No. 33 at p. 3) going forward. (GE, Public Meeting numerically rather than ‘‘NR.’’ (EEI, Although certain ballast scenarios Transcript, No. 30 at pp. 256–257) Public Meeting Transcript, No. 30 at pp. may be less common, DOE’s research DOE did not analyze delamping in the 245–246) indicates that they are already in use preliminary analysis. Available In the preliminary analysis for the and increasing in market share. In the information indicates that delamping is lamp replacement scenario, DOE 2011 Ballast Rule,70 DOE analyzed not a common retrofit for T8 fluorescent utilized ‘‘NR’’ to indicate that no programmed start ballasts for 4-foot systems. DOE received feedback during replacement option existed that reduced MBP lamps directly due to their manufacturer interviews that delamping energy consumption at a given efficacy increasing market share. Programmed was previously very common with T12 level because the lamp wattage at the start ballasts are typically used in systems as these systems were typically higher efficacy level was the same as the applications with frequent switching designed such that spaces were overlit. baseline and the higher efficacy lamp such as those with occupancy sensors. However, delamping is not common was operated on the same ballast. DOE Because lighting controls are becoming with T8 systems because lumen output revised its NOPR engineering analysis to more common, as discussed in section levels have already been reduced to consider lamps that do not reduce I.A.1.a, the use of programmed start comply with newer recommended energy consumption. These were ballasts is expected to increase. lighting levels and building codes. incorporated into the NOPR LCC Additionally, DOE notes that the start Therefore, DOE maintained its analysis. See section VI.D.2.e for further year of the analysis is 2017 and, assumption and did not considering details on lamp-and-ballast systems therefore, it was appropriate to include delamping in the NOPR analysis. developed in the engineering analysis. programmed start ballasts because of DOE also received comments Regarding the instant start 4-foot MBP their expected increase in market share. regarding rare earth oxide prices and results, EEI also noted that another lamp DOE continued to include these their impact on lamp prices and costs to at CSL 2 had the same nominal and scenarios in the LCC NOPR analysis. the consumer. NEMA stated that to rated wattage as the baseline lamp, but CA Utilities questioned why DOE had make products conforming to the 2009 shows positive energy savings. EEI not considered delamping scenarios, Lamps Rule, the most efficacious rare asked for an explanation for the using high ballast factors such as 1 or earth phosphors are used. This leaves reported positive energy savings where 1.15, adding reflectors, or other kinds of only the amount of rare earth phosphors EEI would not expect there to be any. optimized retrofits. (CA IOUs, Public in each lamp as a design option for (EEI, Public Meeting Transcript, No. 30 Meeting Transcript, No. 30 at pp. 253– achieving higher efficacy. Additionally, at pp. 245–246) For the 4-foot MBP 254) The CA IOUs stated that there NEMA noted that while the phosphor instant start lamps at CSL 2 with the would be scenarios where DOE could weight is increased linearly, the same nominal and rated wattage as the use such measures to optimize cost- correlating efficacy gain diminishes. baseline lamp, the BF of the ballast on effectiveness. (CA IOUs, Public Meeting NEMA pointed to the estimates for 4- which the higher efficacy lamp was Transcript, No. 30 at p. 254) However, foot T8 lamps, the most common GSFL operating was lower than the BF of the EEI reasoned that there are too many analyzed in this rulemaking. The ballast on which the baseline lamp was other options and materials that could estimates show that to achieve the operating. A lamp-and-ballast system be included, and some of them would proposed 1.1 percent increase in with a more efficacious, similar wattage be possibilities for the baseline lamps as efficacy from 89 lm/W (2009 Lamps lamp and lower BF ballast will consume well, such as reflectors and ballasts with Rule) to 90 lm/W (CSL 1), nearly 10 less energy while maintaining similar tandem wiring. EEI concluded that if percent more of the associated rare earth light output compared to the baseline DOE attempts to account for all possible oxide supply would be consumed. system. DOE considered ballasts with scenarios, the analysis may no longer Further, to reach the CSL 2 level of 93 varying BFs in the ballast failure event reflect what is actually happening with lm/W, more than 40 percent additional and new construction and renovation lamp efficacy or the most likely retrofit rare earth phosphors will be needed for event. or new construction scenario in the GSFLs. NEMA anticipated that the Lutron expressed concern that there increased demand for this critical were positive LCC savings only for 70 The final rule amending energy conservation material will impact rare earth oxide reduced wattage lamp replacements. standards for fluorescent lamp ballasts published in prices and increase the costs of GSFLs Lutron questioned whether DOE was 2011 with a compliance date of November 14, 2014. to U.S. consumers. (NEMA, No. 36 at p. taking into account the probable 76 FR 70548 (Nov. 14, 2011). The full text and all 14) related documents of the 2011 Ballast Rule can be increased use of dimming systems in the found on regulations.gov, docket number EERE– In the preliminary analysis, DOE future, especially in new construction 2007–BT–STD–0016 at www.regulations.gov/ conducted a sensitivity analysis in the and renovation. As reduced wattage #!docketDetail;D=EERE-2007-BT-STD-0016. LCC using low and high rare earth oxide

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prices developed based on historical considering the following subgroups for cases. DOE invites comment on this oxide price data to assess the impact on analysis: Low-income consumers, choice of analysis period. Separate the cost to consumer purchasing a institutions of religious worship, and shipments projections are calculated for GSFL. Because the rare earth oxide institutions serving low-income the residential sector and for the prices have stabilized since hitting a consumers. commercial and industrial sectors. The peak in 2011, DOE conducted a EEI generally agreed with the shipments model used to estimate GSFL sensitivity analysis using only a consumer subgroups considered, but and IRL lamp shipments for this forecasted high rare earth oxide price in noted that how the current RECS data is rulemaking has four main interacting the NOPR analysis. See section VI.I and structured would affect the analysis. EEI elements: (1) A lamp demand module appendix 11B for further information on specifically questioned whether RECS that estimates the demand for GSFL and the methodology used to develop rare broke out energy data specific to the IRL lighting for each year of the analysis earth oxide prices. DOE also utilized poverty level. (EEI, Public Meeting period; (2) a price-learning module, information provided by NEMA on how Transcript, No. 30 at pp. 352–353) DOE which projects future prices based on the amount of phosphor varies with notes that RECS data specifies whether historic price trends; (3) substitution efficacy to develop rare earth oxide consumers are at or below 100 percent matrices, which specify the product costs attributable to different ELs. The of the poverty line. DOE believes this choices available to consumers (lamps results of this sensitivity are presented data is appropriate to conduct an LCC as well as lamp-and-ballast in appendix 8B of the NOPR TSD. analysis on the low-income consumer combinations for fluorescent lamps) Further, DOE also assessed the subgroup. depending on whether they are maximum possible increase in rare earth In the NOPR analysis, DOE evaluated renovating lighting systems, installing oxide prices that would maintain low-income consumers and institutions lighting systems in new construction, or positive LCC savings for consumers at that serve low-income populations (e.g., simply replacing lamps; and (4) a each EL. See appendix 7B of the NOPR small nonprofits) as subgroups. market-share module that assigns TSD for results of this analysis. However, DOE did not evaluate shipments to product classes, ballasts, and lamp options, based on consumer 15. Incandescent Reflector Lamp Life- institutions of religious worship as a sensitivities to first costs (prices) and Cycle Cost Results in the Preliminary subgroup. In the 2009 Lamps Rule, DOE operation and maintenance costs. Analysis found that institutions of religious worship operate for fewer hours per The lamp demand module first A member of Congress commented year than any other building type in the estimates the lumen demand for GSFL that the July 2012 standards raised commercial sector according to U.S. and IRL lighting. The lumen demand consumer prices on IRLs from LMC: Volume I 71 data. DOE’s review of calculation assumes that sector-specific approximately $4.50 to $8. The member the 2010 LMC data indicated that the lighting capacity (maximum lumen anticipated that additional regulations operating hours of institutions of output of installed lamps) remains fixed would likely further increase the price religious worship are comparable to per square foot of floor space over the to $10–12, while the return on other commercial building operating analysis period. Floor space changes investment based on energy savings hours. Therefore, because they do not over the analysis period according to the would be 8 to 10 years. In this economic have inputs to the LCC that would be EIA’s AEO 2013 projections of climate, the member believed imposing different from the main LCC analysis, residential and commercial floor space; additional regulations on IRL DOE did not analyze them as subgroups. industrial floor space is assumed to manufacturers would be bad public The NOPR TSD chapter 9 presents the grow at the same rate as commercial policy. (Barr, No. 25 at p. 2) results of the consumer subgroup floor space. A lamp turnover calculation The weighted average lamp prices analysis. estimates shipments of lamps in each that DOE calculated for IRLs in this year given the initial stock, the expected NOPR analysis are similar to the prices I. Shipments Analysis lifetimes of the lamps (and ballasts for the member of Congress provided. (See DOE uses projections of product GSFLs), and sector-specific assumptions chapter 7 of the NOPR TSD for further shipments to calculate the national on operating hours. The turnover model information.) In the LCC analysis, DOE impacts of standards on energy use, attempts to meet the lumen demand as calculates the payback period, which is NPV, and future manufacturer cash closely as possible, subject to the the amount of time it takes the flows. DOE develops shipment constraint that the areal density of consumer to recover the assumed higher projections based on historical data and lighting fixtures is fixed for existing purchase cost of a more-efficacious an analysis of key market drivers for buildings that are not renovated. product through lower operating costs each product. Historical shipments data The lamp demand module accounts (i.e., energy savings). DOE considers the are used to build up an equipment stock for the penetration of LED lighting into calculated payback periods, as well as and also to calibrate the shipments the GSFL and IRL markets. The impacts on manufacturers when model. The details of the shipments reference assumption for LED market determining if a TSL is economically model are described in chapter 11 of the penetration is based on projections justified. Please see section VII.C of this developed for DOE’s Solid-State NOPR TSD. 72 NOPR for more details on the selection The shipments model projects Lighting (SSL) Program. The SSL of the proposed TSL. shipments of GSFLs and IRLs over a Program projections extend only to 2030; DOE extrapolated to the end of the H. Consumer Subgroup Analysis thirty-year analysis period for the base case (no standards) and for all standards shipments forecast period. In the In analyzing the potential impact of preliminary analysis, DOE assumed an new or amended standards on 71 U.S. Department of Energy, Office of Energy upper limit on market penetration of 80 consumers, DOE evaluates the impact Efficiency and Renewable Energy. Energy on identifiable sub-groups of consumers Conservation Program for Consumer Products: Final 72 Navigant Consulting, Inc. Energy Savings (e.g., low-income households) that a Report: U.S. Lighting Market Characterization, Potential of Solid-State Lighting in General Volume I: National Lighting Inventory and Energy Illumination Applications. U.S. DOE Solid State national standard may Consumption Estimate. 2002. Washington, DC Lighting Program, January 2012. Available at http:// disproportionately affect. In the . ssl/ssl_energy-savings-report_jan-2012.pdf.

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percent for IRLs, 70 percent for that California’s Title 24 will require all cumulative shipments are fit to an commercial GSFLs, and 60 percent for new commercial buildings, and most experience curve. They are then residential GSFLs. lighting renovations in existing augmented in each subsequent year of Philips questioned why DOE did not commercial buildings, to install the analysis based on the shipments expect LEDs to take over the entire dimming ballasts beginning January determined for the prior year by the market. (Philips, Public Meeting 2014. (CA IOUs, No. 32 at pp. 13–14) module that assigns shipments to Transcript, No. 30 at p. 270) Given that Lutron asked if DOE took California’s product classes and ELs. The current LED technology has been progressing Title 24 into account. (Lutron, Public year’s shipments, in turn, affect the faster than expected, DOE has revised Meeting Transcript, No. 30 at p. 218) subsequent year’s prices. As shown in its analysis and is now fitting the The CA IOUs noted that Title 24 would chapter 11 of the NOPR TSD, because technology adoption curve, allowing an not have been included in the 2010 fluorescent and PAR lamps have been entire market takeover by LEDs. Given LMC because the provision was passed on the market for decades, cumulative the best fit to the SSL forecast, DOE after the 2010 LMC was published. (CA shipments are changing slowly, estimates that LEDs will achieve close to IOUs, Public Meeting Transcript, No. 30 therefore experience curve effects are 100 percent penetration in both the at pp. 218–219) relatively small—an effect that is further GSFL and IRL markets by 2046. DOE is aware that current building constrained by the expected incursion The shipments model accounts for the energy codes will lead to an increase in of solid-state lighting into the GSFL and use of lighting controls, including the fraction of lamps coupled to lighting IRL markets. dimming and on-off controls, because control systems and dimming ballasts. The market-share module apportions controls affect ballast and lamp Accordingly, in the shipments analysis the lamp and ballast shipments in each requirements and therefore lifetimes and NIA, DOE included a projection of year among the different product and shipments. The reference growth in the fraction of commercial classes, ballast types, and lamp options assumption for lighting system controls floor space subject to such state codes, based on consumer sensitivities to first for the commercial sector is that state including California’s Title 24 costs and operation and maintenance building energy code requirements for requirements, as renovations and new costs. To determine the prices used as lighting controls remain constant at construction trigger compliance inputs to the market-share module, DOE current levels, as does the ratio of requirements. As mentioned previously, uses the ballast prices, weighted average voluntary to code-driven demand. the result is that the fraction of floor lamp prices, and installation costs Because code provisions are space utilizing controls grows from 30 developed in the engineering and LCC implemented only in new construction percent today to a projected value of 80 analyses. The operation and and building renovations that meet percent in 2046. DOE assumed that 26 maintenance costs are based on the certain threshold requirements, code- percent of control systems for GSFL power required to operate a particular driven implementation of lighting applications include dimming ballasts, lamp-and-ballast system, the price of controls grows in slowly over time. based on data in the 2010 LMC.73 Based electricity, and the annualized cost of GE noted that, in the future, an on assumptions of the fraction of each lamp replacements over the lifetime of increasing number of fluorescent control type that relies on a dimming that system. To enable a fair comparison systems will be controlled and dimmed ballast, DOE projects that the market between systems with different light in the commercial sector. GE pointed to share of dimming ballasts grows from an output, the module considers the prices an increase of controls requirements in estimated 8 percent at present to an and operating and maintenance costs commercial building codes and estimated 20 percent in 2046. DOE seeks computed per kilolumen of light output. suggested that the initial five percent input on the current fraction of GSFL For consumers replacing lamps on dimming population assumed in the ballast shipments that are dimming existing ballasts, only the lamp-related analysis increase over the analysis ballasts and the likely rate of growth of prices and energy costs are considered period. (GE, Public Meeting Transcript, dimming ballasts in the future. The by the market share module. For No. 30 at p. 217) EEI stated that, given details of the analysis on controls and consumers replacing an entire lamp- the amount of dimmers in office spaces, dimming are presented in chapter 11 and-ballast system, the full price of the they expected the percentage of lamps and appendix 11A of the NOPR TSD. system, as well as the energy and in the commercial sector that are on The price-learning module estimates annualized relamping costs, are controls to be higher. (EEI, Public lamp and ballast prices in each year of considered. In this case, the comparison Meeting Transcript, No. 30 at pp. 216– the analysis period using a standard between different ballast types and 217) EEI noted that the next edition of price-learning model.74 The model is product classes is made by considering ASHRAE 90.1–2013, contains more calibrated using three decades of a representative lamp-and-ballast control systems requirements for more historic data on the volume and value combination. lighting fixtures. (EEI, Public Meeting of fluorescent and PAR lamp shipments The ballast types and lamp options Transcript, No. 30 at p. 218) in the U.S. market, from which considered in the shipments model DOE is aware that current building cumulative shipments and average were determined in the engineering codes will lead to an increase in the prices are derived. Prices and analysis. Whereas the earlier analyses fraction of lamps coupled to lighting considered only lamp-and-ballast control systems. Accordingly, DOE 73 U.S. Department of Energy—Energy Efficiency combinations that save energy relative included a projection of growth in the & Renewable Energy Building Technologies to the baseline system, the shipments fraction of commercial floor space Program. 2010 U.S. Lighting Market analysis allows consumers to choose subject to such building codes. The Characterization. January 2012. Washington, DC. among all different lamp-and-ballast http://apps1.eere.energy.gov/buildings/ result is that the fraction of floor space publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf. systems. These lamp-and-ballast utilizing various types of controls grows 74 For discussion of approaches for incorporating combinations include full wattage and from 30 percent today to a projected learning in regulatory analysis, see Taylor, reduced wattage lamps coupled to value of 80 percent in 2046. Margaret, and Sydny K. Fujita. Accounting for ballasts with high, normal, or low Technological Change in Regulatory Impact The CA IOUs stated that dimming Analyses: The Learning Curve Technique. Berkeley: ballast factors, and dimming ballasts. ballasts will become more common with Lawrence Berkeley National Laboratory, 2013. Programmed start and instant start time. Specifically, the CA IOUs noted LBNL–6195E. ballasts are also considered separately,

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where appropriate. DOE limits or new construction, it accepts only lamps opportunity to save energy (which often excludes lamp-and-ballast combinations or lamp-and-ballast combinations that pays for or helps pay for the retrofit). that DOE’s research indicates would not retain lumen capacity within acceptable (NEEA and NPCC, No. 34 at pp. 2, 4) provide acceptable performance or bounds. DOE received a number of As discussed previously, based on would only do so in limited comments on what consumers would manufacturer feedback, DOE circumstances. The remaining find acceptable in terms of changes in determined that consumers would not combinations allow for a variety of light levels. notice a change in light output that is up different energy-saving and non-energy- NEMA stated that while, in the past, to 10 percent, and that some consumers saving options relative to the baseline. it was common practice to reduce light will choose to reduce light levels Details of the selection of allowable levels by 10 percent or more when beyond 10 percent to conserve energy. lamp-and-ballast combinations are given retrofitting from a T12 to a T8 lighting Accordingly, in the shipments analysis, in chapter 11 of the NOPR TSD. system, this was because the older DOE assumes that consumers choose The market-share module allows for lighting systems were typically designed between lighting systems within 10 the possibility that consumers will to higher light levels. NEMA percent of current light output by switch among the different product commented that, over the years, light considering the trade-off between first classes, ballast types, and lamp options level requirements specified by IESNA cost and operating costs, and not the over time. Substitution matrices were have been reduced, so future 4-foot relative light output. In this approach, developed to specify the product linear fluorescent systems will already systems that save energy in a cost- choices available to consumers (lamps be operating at the appropriate lower effective way will tend to be selected as well as lamp-and-ballast light levels, and further light level over systems that increase light output combinations), depending on whether reductions of 6 percent to 14 percent without saving energy. DOE further they are renovating lighting systems, cannot be justified against the T8 assumes that the fraction of the market installing lighting systems in new systems operating in 2018. NEMA stated that will accept larger reductions in construction, or simply replacing lamps, that DOE should seek to match the lumen output is fixed throughout the and depending on the particular lighting existing light levels within a plus or analysis period. The size of this market application. In this way, the module minus 5 percent range. (NEMA, No. 36 segment was estimated from the current assigns market shares to the different at p. 8) market share of reduced wattage lamps product classes, ballast types, and ELs The CA IOUs commented that that reduce light levels by more than 10 based on historical observations of scenarios in which lighting designers percent compared to the baseline lamp. consumer sensitivity to price and to would specify an increase in light The model does now allow cumulative operating and maintenance costs. output instead of a reduction in system reductions in light levels. The model The market-share module wattage will not be common in the retains national average light levels incorporates a limit on the diffusion of commercial sector because (1) within 10 percent of the average level at new technology into the market using commercial occupants are often very the beginning of the analysis period. No the widely accepted Bass adoption sensitive to changes in workplace potential standards considered in this model,75 the parameters of which are lighting and react negatively to light analysis lead to average light levels based on historic penetration rates of increases; and (2) commercial building outside of this range. new lighting technologies into the operators are very sensitive to operating The CA IOUs commented that there market. It also accounts for other costs. The CA IOUs further stated that are a number of tools available to observed deviations from purely price- commercial building operators will lighting designers to reduce system and cost-driven behavior using an prefer a retrofit option that will result in wattage while maintaining acceptable acceptance factor, which sets an upper energy cost savings (without light levels. These options include limit on the market share of certain significantly reducing the light levels) installing lower wattage lamps, reducing product classes and lamp options that over another option that increases light ballast factors, delamping, or installing DOE research indicates are acceptable and doesn’t save energy (unless the dimming ballasts. (CA IOUs, No. 32 at only to a subset of the market. The space was known to be underlit). The pp. 13–14) NEEA and NPCC commented available options depend on the case CA IOUs stated that, where DOE has a that, if a 32 W T8 lamp replacement is under consideration; in each of the standards-case modeling choice undertaken, there are options available standards cases corresponding to the between a lighting retrofit that would for maintaining acceptable light output different TSLs, only those lamp options result in an increase of light levels of while reducing energy use, such as 30 between 0 percent and 10 percent with W and 28 W T8s, ballasts with a lower at or above the particular standard level no energy cost savings, and another that ballast factor, and dimming ballasts. in each product class are considered to would result in a decrease of light levels (NEEA and NPCC, No. 34 at pp. 2, 4) be available. Because DOE executes the market- of between 0 percent and 10 percent NEMA commented that the energy share module for the base case and each with energy cost savings, DOE should consumption of GSFL systems is highly of the standards cases independently, model the energy-saving option as the dependent on ballast selection and the shipments analysis allows for the most likely scenario for consumers. (CA pairing, and asserted that NES of possibility that setting a standard on one IOUs, No. 32 at p. 14) NEEA and NPCC lighting systems will not be affected commented on the modeled lamp or significantly by this proposed product class could shift market share lighting system replacement options in rulemaking on GSFL efficacy due to the toward a different product class. The which light output levels are increased overwhelming influence of ballast costs and benefits accruing to 10 percent or more instead of selection on final performance. (NEMA, consumers from such market share maintaining light levels with an No. 36 at p. 1) shifts are fully accounted for in the NIA. DOE is aware of the substantial When the shipments model selects appropriate reduction in system power impact of the ballast and lamp choice on lamps for replacement, renovation, or use. They contended that it is highly unlikely that a lighting retrofit or lamp the energy consumption of a lamp-and- 75 Bass, F.M. A New Product Growth Model for replacement project would be ballast system. As discussed earlier in Consumer Durables. Management. 1969. 15(5): pp. undertaken that would result in a light this section, the shipments analysis 215–227. output increase without using the explicitly models the possibility that

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consumers will choose to reduce their in this analysis. Also, as discussed at the October 2012 level, but DOE ballast factor during a renovation or previously, DOE found that dimming acknowledged the uncertainty about retrofit or switch to reduced wattage ballasts for 4-foot MBP lamps are prices and included a scenario with lamps when relamping an existing commonly marketed as compatible with much higher prices. NEEP commented system. In addition, this analysis reduced wattage lamps, which are that DOE appropriately addressed the models the growth of dimming ballasts presumably krypton filled. Accordingly, variability of rare earth phosphor prices in the market and allows a variety of in the shipments analysis and the NIA, in the preliminary analysis. (NEEP, No. lamps to be coupled to dimming ballasts DOE allows all full wattage lamp 33 at pp. 2–3) NEMA commented that to achieve a fixed light output. Thus, options to be coupled to dimming rare earth phosphors are likely to when high-efficacy lamps are coupled to ballasts. DOE also allowed reduced remain critical (i.e., volatile), that prices dimming ballasts, the overall energy wattage options in the 4-foot MBP are more likely to go up than down, and savings are greater than those that are category to be coupled to dimming suggested that DOE consult Dr. Alex achieved when lower-efficacy lamps are ballasts, but, because the range of King of the Critical Materials Institute of coupled to dimming ballasts. DOE applications for this combination is the Ames Laboratory on the subject. assigns market share to these lamp-and- restricted, DOE limits its market share (NEMA, No. 36 at p. 14) ballast pairings using a model based on in the analysis. DOE welcomes input on DOE examined the rare earth market historical consumer sensitivity to price the assumption that a limited fraction of and believes that the very large and operating costs. When a particular reduced-wattage 4-foot MBP lamps may reduction in rare earth prices seen since pairing saves energy in a cost-effective be coupled to dimming ballasts. the 2011 peak may represent some manner compared to other pairings, its NEMA commented on the issue of stabilization of the market, but it still market share is increased compared to lamp replacement upon ballast failure. considers future rare earth prices less cost-effective options. Given that NEMA contends that when a residential significantly uncertain.76 DOE therefore the lamp options considered in this ballast fails, residential GSFL considered two price scenarios in its rulemaking represent a fairly narrow consumers tend to first try to replace the shipments modeling for GSFLs, as range in lumen output within each lamp, and when that fails they replace described in appendix 11B of the NOPR product class, DOE does not consider the entire fixture, discarding the lamps TSD. The reference scenario assumes delamping to be a likely means of saving from the old fixture. The effect is to that rare earth prices remain fixed at energy for consumers who are only reduce the lamp’s usage life below its their September 2013 level. The high replacing failed lamps (see section potential and therefore to increase rare earth price scenario assumes an VI.D.2.e for more information on shipments. (NEMA, No. 36 at p. 16) The average rare earth price 3.4 times the delamping). The shipments model, shipments model assumes that when a reference level, representing a value that however, allows for the possibility that residential ballast fails, all associated is half way between the low pre-2010 consumers will alter the number of lamps are assumed to be replaced. baseline price and the 2011 peak price. lamps per square foot during Rare earth oxides are used in GSFL This scenario represents the average renovations to maintain light levels. phosphors to increase their efficiency. price of regular price fluctuations NEMA commented that reduced The shipments model considers the between the peak and baseline amounts. wattage lamps have limited utility as a potential impact of changes in rare earth The impact of the latter scenario on the substitute for full wattage lamps. NEMA oxide prices on fluorescent lamp prices results is discussed in section 0. DOE noted that, while standard fluorescent and, thereby, on GSFL shipments. Large invites comment on its assumptions lamp technology dims reliably, more increases in rare earth oxide prices in about future prices of rare earth efficient krypton-filled fluorescent 2010 and 2011 raised manufacturer elements. lamps do not dim reliably in many concerns that future price increases Stakeholders also commented on the applications. (NEMA, No. 36 at p.6) The could have adverse impacts on the possibility of future scarcity in the CA IOUs stated that California’s Title 24 market. DOE developed shipments supply of xenon gas, which could affect requirement for controls in new scenarios in its preliminary analysis to future prices of IRLs. NEMA commented buildings will result in high efficacy, reflect uncertainties in the prices of rare that xenon is becoming increasingly full wattage T8s capable of dimming to earth oxides. scarce and that its loss would result in custom light levels, ensuring higher In the preliminary analysis, DOE a 5 to 7 percent reduction in IRL efficacy lamps yield greater energy assumed that the rare earth phosphor efficacy, making it impossible to meet savings. (CA IOUs, No. 32 at p. 14) The content was the same at all considered CSL 1 of the preliminary analysis (20 Northeast Energy Efficiency Partnership efficacy levels for each lamp type. lm/W). NEMA advised DOE to (NEEP) also noted that high efficacy NEMA stated that there is a relationship investigate xenon availability trends and lamps do not impede control between rare earth phosphor content future prices. (NEMA, No. 36 at p. 3) capabilities. NEEP commented that, and efficiency. Specifically, NEMA while manufacturers had said that indicated that to increase the efficacy of 76 DOE conferred with Dr. King, who indicated adding control functionality to a 4-foot MBP GSFLs from 89 to 90 lm/W that a good comparison can be made between rare fluorescent fixture was the next frontier would require 10 percent more rare earths and cobalt, which are comparable (within of efficiency for GSFLs, regional earth phosphor and to reach 93 lm/W about a factor of ten) in abundance in the earth’s crust. In 1978, world cobalt supplies were program administrators have not would require a 40 percent increase in dominated by a single source (Zaire). In 2010, rare reported concerns that high efficacy rare earth phosphor. (NEMA, No. 36 at earth supplies were dominated by a single source GSFLs sacrifice dimming capabilities. p. 14) Based on an examination of (China). In 1978, the use of cobalt was growing both (NEEP, No. 33 at p. 2) fluorescent lamp patents, DOE agrees in existing and emerging technologies. The same is true for rare earths today. Following the 1978 crisis, DOE’s research indicates that krypton with NEMA’s comment, and has new cobalt mines opened, and substitute materials gas is generally used to reduce the adjusted its analysis accordingly, as were developed. Markets are pursuing the same wattage of lamps and that full wattage described in appendix 11B of the NOPR paths for the rare earths today. DOE examined lamps can generally be dimmed reliably. TSD. inflation-adjusted cobalt prices from 1970 through 2012 and found that cobalt prices did continue to DOE notes that full wattage lamp In the preliminary analysis, DOE’s remain volatile, although later price fluctuations options are available for all product reference case assumed that rare earth were less than half of the initial price peak seen in classes at all efficacy levelss considered phosphor prices would remain constant 1978.

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The CA IOUs commented that xenon is the latter scenario on the results is projections of energy consumption already used as the primary gas fill in discussed in section 0.. DOE welcomes without the standards (the base case). most IRLs and that future efficacy input on its assumptions regarding the Because the shipments model allows standards should not be affected by future price of xenon gas. for substitutions across product classes, potential constraints on xenon supply or to understand the impact of setting a xenon price fluctuations. (CA IOUs, No. J. National Impact Analysis—National standard at any given level for any given 32 at p. 9) NEEA pointed out that there Energy Savings and Net Present Value product class, the impact on all other is no current shortage of xenon gas fill Analysis product classes must be considered. and that a new standard would not Therefore, in addition to conducting the The NIA assesses the NES and the require any significant amount of analysis for the covered products as a national NPV of total consumer costs increased xenon supply. Therefore, the whole, DOE evaluated the NPV and NES supply and price of xenon should not be and savings expected to result from by product class to determine the an issue for the rulemaking. (NEEA, No. amended standards for GSFLs and IRLs impact of consumer switching between 34 at p. 2) at specific efficacy levels. Analyzing product classes. The NIA was developed To assess the need for further impacts of potential energy conservation in a Microsoft Excel spreadsheet,77 investigation, DOE conducted a standards for GSFLs and IRLs requires allowing access to a broad range of sensitivity analysis on the potential comparing projections of U.S. energy scenario assumptions for conducting impact on the rulemaking of a ten-fold consumption with amended energy sensitivity analyses on specific input increase in xenon prices. The impact of conservation standards against values.

TABLE VI.14—INPUTS FOR THE NATIONAL IMPACT ANALYSIS

Input Description

Shipments ...... Annual shipments from shipments model. Compliance date of standard ...... January 1, 2017. Base case efficiencies ...... Estimated by market-share module of shipments model. Standards case efficiencies ...... Estimated by market-share module of shipments model. Annual energy consumption per unit ...... Calculated for each efficacy level and product class based on inputs from the energy use analysis. Total installed cost per unit ...... Lamp prices by efficacy level, ballast prices by ballast type, and lamp and ballast in- stallation costs. The weighted average prices and installation costs developed in the engineering analysis and LCC analysis were used. Electricity expense per unit ...... Annual energy use for each product class is multiplied by the corresponding average energy price. Escalation of electricity prices ...... AEO 2013 forecasts (to 2040) and extrapolation beyond 2040. Electricity site-to-primary energy conversion ...... A time series conversion factor; includes electric generation, transmission, and dis- tribution losses. Discount rates ...... 3% and 7% real. Present year ...... 2013.

1. National Energy Savings distributions developed in the LCC overall results, the calculation period The inputs for determining the NES analysis. The electricity savings are for the NIA is extended to account for for each product class are: (1) Lamp estimated from the difference in them. shipments; (2) annual energy national electricity consumption by DOE accounted for the impact of consumption per unit; (3) installed GSFL between the base case (without lighting system controls on lighting stocks of lamps (coupled to each new standards) and each of the energy use as well as on lamp analyzed ballast type for GSFLs) in each standards cases for lamps shipped shipments, as discussed in the previous year; and (4) site-to-primary energy and during the 2017–2046 period. section. NEEA noted that as many as a FFC conversion factors. The lamp stocks NEMA commented that DOE appears third of commercial building control were calculated by the shipments model to be using a new (arbitrary) 70-year systems do not achieve their design for each year of the analysis period from period in its analysis and requested performance and thus yield a smaller the prior year’s stock, minus explanation and justification for energy savings than expected. (NEEA, retirements, plus new shipments, examining such a long stretch of time. No. 30 at pp. 317–318) DOE accounting for lamp and ballast (NEMA, No. 36 at pp. 2–3) In the NIA, understands that many lighting control lifetimes. DOE calculated the national DOE accounts for the lifetime impacts of systems may not achieve the savings for electricity consumption in each year by the products shipped during a 30-year which they were designed. Accordingly, multiplying the number of units of each period. In the case of GSFLs and IRLs, the estimated average energy reduction product class and EL in the stock by most of the products are retired from the from controls is based on a meta- each unit’s power consumption and stock within five years. The lifetime analysis of studies on the performance operating hours. The power distribution used by DOE shows a small of actual lighting controls systems in the consumption is determined by the lamp number of lamps shipped for use in field.78 wattage and, for each GSFL, by the homes at the end of the 30-year NEMA pointed out that light output ballast type to which each lamp is shipments analysis period survive for and input power do not scale linearly coupled. The operating hours are given much longer. While the energy use of for dimming GSFL systems due to the by taking a weighted average of the these lamps is insignificant to the increasing importance of cathode heat

77 Available at www1.eere.energy.gov/buildings/ 78 Williams, A., B. Atkinson, K. Garbesi, E. Page, commercial buildings. Leukos 8(3): 161–180. appliance_standards/rulemaking.aspx/ruleid/24. and F. Rubinstein (2012). Lighting controls in www.ies.org/leukos/samples/1_Jan12.pdf.

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power at reduced light levels. (NEMA, energy (power sector energy in the engineering and LCC analyses. No. 36 at p. 14) DOE recognizes the consumption) using annual conversion DOE calculated the total installed cost need for cathode heating in dimming factors derived from the AEO 2013 for each lamp-and-ballast option and ballast systems and has included this version of NEMS. Cumulative energy determined annual total installed costs effect in its energy consumption savings are the sum of the NES for each based on the annual shipments of lamps calculations. In particular, the year in which product shipped during and ballasts determined in the shipments analysis and NIA use power 2017 through 2046 continue to operate. shipments model. As noted in section consumption assumptions identical to In 2011, in response to the VI.I, DOE assumed that GSFL and IRL those used in the engineering analysis, recommendations of a committee on prices decline slowly over the analysis which account for cathode heating in ‘‘Point-of-Use and Full-Fuel-Cycle period according to a learning rate dimming systems. Measurement Approaches to Energy developed from historical data. NEMA expressed concern that the Efficiency Standards’’ appointed by the As discussed in section VI.I, DOE highest considered efficacy levels would National Academy of Science, DOE considered two price scenarios in its lead to the loss of reliable dimming and announced its intention to use FFC modeling for GSFLs. The reference would have a negative impact on NES. measures of energy use and GHG and scenario assumes that rare earth prices NEMA asserted that, in future years, other emissions in the NIA and remain fixed at their September 2013 most of the energy savings from emissions analysis included in future level. The high rare earth price scenario fluorescent lighting will be achieved energy conservation standards assumes that rare earth prices are 3.4 through the increased use of lighting rulemakings. 76 FR 51281 (August 18, times higher than the reference level, controls, not through increasing the 2011). While DOE stated in that notice representing a value at the midpoint of efficacy of lamps, and that an aggressive that it intended to use the Greenhouse the low pre-2010 baseline price and the standard on lamp efficacy could make Gases, Regulated Emissions, and Energy peak 2011 price. The impact of the latter these savings unachievable. (NEMA, No. Use in Transportation (GREET) model to scenario on the NPV results is discussed 36 at p.6) NEMA further suggested that conduct the analysis, it also said it in section 0. DOE perform and report an analysis of would review alternative methods, For IRLs, DOE conducted a sensitivity the impacts of the loss of dimming including the use of EIA’s NEMS. After analysis on the potential impact on the savings for efficacy levels that they evaluating both models and the rulemaking of a ten-fold increase in claimed will drive out dimmable lamps approaches discussed in the August 18, xenon prices. The impact of the scenario in favor of low wattage versions. NEMA 2011 notice, DOE published a statement on the results is discussed in section 0. asserted that this would show a negative of amended policy in the Federal b. Total Annual Operating Cost Savings impact on the market and payback. Register in which DOE explained its They contended that increased determination that NEMS is a more The per-unit energy savings were efficiency and dimmability are inversely appropriate tool for this specific use. 77 derived as described in section VI.I. To proportional. (NEMA 36 at p.17) FR 49701 (August 17, 2012). Therefore, calculate future electricity prices, DOE As discussed in the previous section, DOE is using a NEMS-based approach to applied the projected trend in national DOE modeled the growth of dimming conduct FFC analyses. The approach average commercial and residential ballasts in the shipments analysis and used for today’s NOPR is described in electricity prices from the AEO 2013 excluded or limited, as appropriate, the appendix 12C of the NOPR TSD. Reference case, which extends to 2040, coupling of reduced wattage lamps to to the energy prices derived in the LCC these ballasts. Therefore, the issues 2. Net Present Value of Consumer and payback period analysis. DOE used discussed in the previous comment are Benefit the trend from 2030 to 2040 to accounted for, and the NES and NPV The inputs for determining the NPV extrapolate beyond 2040. In addition, results include any potential loss of of the total costs and benefits DOE analyzed scenarios that used the dimming functionality. experienced by consumers of the trends in the AEO 2013 Low Economic DOE accounts for the direct rebound considered product are: (1) Total annual Growth and High Economic Growth effect in its NES analyses. Direct installed cost; (2) total annual savings in cases. These cases have energy price rebound reflects the idea that, as operating costs; and (3) a discount factor trends that are, respectively, lower and appliances become more efficient, to calculate the present value of costs higher in the long term compared to the consumers use more of their service and savings. DOE calculated net savings Reference case. These price trends, and because their operating cost is reduced. each year as the difference between the the NPV results from the associated In the case of lighting, the rebound base case and each standards case in cases, are described in chapter 12 of the could be manifested in increased hours terms of total savings in operating costs NOPR TSD. of use or in increased lighting density versus total increases in installed costs. DOE estimated that annual (fixtures per square foot). Based on DOE calculated savings over the lifetime maintenance costs do not vary with information evaluated for the of products shipped during the period efficiency within each product class, so preliminary analysis, DOE assumed no starting January 1, 2017 and ending they do not figure into the annual rebound for the residential or December 31, 2046. DOE calculated operating cost savings for a given commercial lighting in its reference NPV as the difference between the standards case. DOE utilized the lamp scenario for the NOPR analysis. DOE present value of operating cost savings disposal costs developed in the LCC also conducted a sensitivity analysis on and the present value of total installed analysis, along with the shipments the rebound rate, which is presented in costs. model forecast of the lamp retirements chapter 12 of the NOPR TSD. DOE in each year, to estimate the annual cost welcomes comment on its assumptions a. Total Annual Installed Cost savings related to lamp disposal costs. and methodology for estimating the The total installed cost includes both In this part of the analysis, DOE rebound effect for the products covered the product price and the installation assumes that 30 percent of commercial in this NOPR, including potential cost. For each product class, DOE consumers are subject to disposal costs. magnitudes of rebound effects. utilized weighted average prices for In calculating the NPV, DOE DOE converted the site electricity each of the lamp and ballast options, as multiplies the net savings in future consumption and savings to primary well as installation costs, as developed years by a discount factor to determine

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their present value. DOE estimates the conducted interviews with a variety of standards. The GRIM uses these inputs NPV using both a 3 percent and a 7 GSFL and IRL manufacturers that to calculate a series of annual cash flows percent real discount rate, in accordance account for more than 90 percent of beginning with the base year of the with guidance provided by the Office of domestic GSFL sales and more than 80 analysis, 2013, and continuing to 2046. Management and Budget (OMB) to percent of domestic IRL sales covered DOE computes INPV by summing the federal agencies on the development of by this rulemaking. During these stream of annual discounted cash flows regulatory analysis.79 The discount rates interviews, DOE discussed engineering, during the analysis period. DOE used a for the determination of NPV are in manufacturing, procurement, and real discount rate of 9.2 percent for both contrast to the discount rates used in the financial topics specific to each GSFL and IRL manufacturers. The LCC analysis, which are designed to company and obtained each discount rate estimates were derived reflect a consumer’s perspective. The 7 manufacturer’s view of the GSFL and from industry corporate annual reports percent real value is an estimate of the IRL industries as a whole. The to the Securities and Exchange average before-tax rate of return to interviews provided information that Commission (SEC 10-Ks). During private capital in the U.S. economy. The DOE used to evaluate the impacts of manufacturer interviews GSFL and IRL 3 percent real value represents the amended standards on manufacturers’ manufacturers were asked to provide ‘‘social rate of time preference,’’ which cash flows, manufacturing capacities, feedback on this discount rate. Most is the rate at which society discounts and direct domestic manufacturing manufacturers agreed that a discount future consumption flows to their employment levels. See section rate of 9.2 was appropriate to use for present value. VII.B.2.b of this NOPR for the both GSFL and IRL manufacturers. discussion on the estimated changes in K. Manufacturer Impact Analysis Many inputs into the GRIM come from the number of domestic employees the engineering analysis, the NIA, 1. Overview involved in manufacturing GSFLs and manufacturer interviews, and other DOE conducted separate MIAs for IRLs covered by standards. See section research conducted during the MIA. The GSFLs and IRLs to estimate the financial VI.K.4 of this NOPR for a description of major GRIM inputs are described in impact of amended energy conservation the key issues manufacturers raised detail in the sections below. during the interviews. standards on manufacturers of GSFLs a. Capital and Product Conversion Costs and IRLs, respectively. The MIA has During the third phase, DOE also used both quantitative and qualitative the results of the industry DOE expects amended energy aspects. The quantitative part of the characterization analysis in the first conservation standards of GSFLs and MIA relies on the GRIM, an industry phase and feedback from manufacturer IRLs to cause manufacturers to incur cash-flow model customized for GSFLs interviews to group manufacturers that conversion costs to bring their and IRLs covered in this rulemaking. exhibit similar production and cost production facilities and product The key GRIM inputs are data on the structure characteristics. DOE identified designs into compliance with amended industry cost structure, equipment one manufacturer sub-group for a standards. For the MIA, DOE classified costs, shipments, and assumptions separate impact analysis—small these conversion costs into two major about markups and conversion costs. business manufacturers—using the groups: (1) Capital conversion costs and The key MIA output is INPV. DOE used small business employee threshold of (2) product conversion costs. Capital the GRIM to calculate cash flows using 1,000 total employees published by the conversion costs are investments in standard accounting principles and to Small Business Administration (SBA). property, plant, and equipment This threshold includes all employees compare changes in INPV between a necessary to adapt or change existing in a business’ parent company and any base case and various TSLs (the production facilities such that new other subsidiaries. Based on this standards case). The difference in INPV product designs can be fabricated and classification, DOE identified 21 GSFL between the base and standards cases assembled. Product conversion costs are manufacturers that qualify as small represents the financial impact of investments in research, development, businesses and 15 IRL manufacturers amended energy conservation standards testing, marketing, certification, and that qualify as small businesses. The on GSFL and IRL manufacturers. other non-capitalized costs necessary to complete MIA is presented in chapter Different sets of assumptions (scenarios) make product designs comply with 13 of the NOPR TSD, and the analysis produce different INPV results. The amended standards. qualitative part of the MIA addresses required by the Regulatory Flexibility Act, 5 U.S.C. 601, et seq., is presented Using feedback from manufacturer factors such as manufacturing capacity; interviews, DOE conducted both top- characteristics of, and impacts on, any in section VIII.B of this NOPR and chapter 13 of the NOPR TSD. down and bottom-up analyses to particular sub-group of manufacturers; calculate the capital and product and impacts on competition. 2. GRIM Analysis and Key Inputs conversion costs for GSFL and IRL DOE conducted the MIAs for this DOE uses the GRIM to quantify the manufacturers. DOE then adjusted these rulemaking in three phases. In the first changes in cash flows over time due to conversion costs if there were any phase DOE prepared an industry amended energy conservation discrepancies between the two methods characterization based on the market standards. These changes in cash flows to arrive at a final capital and product and technology assessment, preliminary result in either a higher or lower INPV conversion cost estimate for each GSFL manufacturer interviews, and publicly for the standards case compared to the and IRL product class at each EL. available information. In the second base case (the case where a standard is To conduct the top-down analysis, phase, DOE estimated industry cash not set). The GRIM analysis uses a DOE asked manufacturers during flows in the GRIMs using industry standard annual cash flow analysis that manufacturer interviews to estimate the financial parameters derived in the first incorporates manufacturer costs, total capital and product conversion phase and the shipment scenarios used markups, shipments, and industry costs they would need to incur to be in the NIAs. In the third phase, DOE financial information as inputs. It then able to produce each GSFL and IRL 79 OMB Circular A–4, section E (Sept. 17, 2003). models changes in costs, investments, product class at specific ELs. DOE then Available at: www.whitehouse.gov/omb/circulars_ and manufacturer margins that result summed these values provided by a004_a-4. from amended energy conservation manufacturers to arrive at total top-

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down industry conversion costs for GSFL and IRL manufacturers. Typically, c. Shipment Scenarios GSFLs and IRLs. DOE develops MPCs for the covered INPV, the key GRIM output, depends To conduct the bottom-up analysis, products and uses the prices as an input on industry revenue, which depends on DOE used manufacturer input from to the LCC analysis and NIA. However, the quantity and prices of GSFLs and manufacturer interviews regarding the because GSFLs and IRLs are difficult to IRLs shipped in each year of the types and dollar amounts of discrete reverse-engineer, DOE derived end-user analysis period. Industry revenue capital and product expenditures that prices for the lamps covered in this calculations require forecasts of: (1) would be necessary to convert specific rulemaking. DOE observed a range of Total annual shipment volume of GSFLs production lines for GSFLs or IRLs to end-user prices paid for GSFLs and IRLs and IRLs; (2) the distribution of each EL. GSFL manufacturers identified depending on the distribution channel shipments across product classes upgrading and recalibrating production through which the lamps are purchased. (because prices vary by product class); automation systems as the primary DOE then developed three sets of and, (3) the distribution of shipments capital cost that would be necessary to discounts from the manufacturer blue- across efficacy levels (because prices meet higher efficacy levels for GSFLs. book prices representing low (state vary with lamp efficacy). IRL manufacturers identified several procurement), medium (electrical In the base case shipment analysis, potential capital costs that could be distributors and big box retailers), and DOE first established a lumen capacity required to meet higher efficacy levels high (Internet retailers) lamp prices for demand per square foot for commercial for IRLs. These include purchasing new both GSFLs and IRLs. For more and residential spaces serviced by burner coating machines, increasing the information about pricing, see section GSFLs and IRLs. While this lumen capacity of existing burner machines, VI.E of this NOPR. purchasing reflector coating machines, capacity per square foot demand is To calculate the MSP, the price at assumed to remain unchanged over the and purchasing coiling machines, as which manufacturers sell lamps to their well as other retooling costs. The two analysis period, the total lumen demand customer, DOE calculated the grows proportionally with the growth of main types of product conversion costs distribution chain markup for the GSFL for GSFLs and IRLs that manufacturers new commercial and residential floor and IRL industries. DOE examined the space, as projected by AEO 2013. DOE shared with DOE during manufacturer SEC 10-Ks of publicly traded big box interviews were the engineering hours also expects the lighting demand for retail stores to determine the average GSFLs and IRLs to be eroded by necessary to redesign lamps to meet retail markup for the medium end-user higher efficacy standards and the testing increased penetration of LEDs into the price distribution chain. DOE found the market. This LED penetration rate for and certification costs necessary to typical retail markup for big box stores comply with higher efficacy standards. the reference shipment scenario is based was 1.52. DOE divided the medium end- on the rate forecasted in DOE’s Solid- Once DOE had compiled these capital user price for all GSFLs and IRLs by this and product conversion costs, DOE then State Lighting Program. (See section VI.I value to arrive at MSPs for all GSFLs took average values (i.e., average of this NOPR for further information.) and IRLs. DOE invites comment on its number of hours or average dollar Overall, while demand for lighting is methodology of using a 1.52 distribution amounts) based on the range of expected to increase for the entire chain markup in combination with the responses given by manufacturers for economy as the amount of floor space medium end-user price to estimate the each capital and product conversion increases, the demand for GSFL and IRL MSP of all GSFLs and IRLs. cost at each ELs. specific lighting is projected to decline The bottom-up conversion costs DOE also examined the SEC 10-Ks of in the base case due to the increased estimates DOE created were consistent all publicly traded GSFL and IRL penetration of alternative lighting with the manufacturer top-down manufacturers to estimate the average sources such as LEDs. estimates provided, so DOE used these GSFL and IRL manufacturer markup. In the standards case for GSFLs, DOE cost estimates as the final values for The manufacturer markup represents used a consumer choice model the each GSFL and IRL product class at the markup lamp manufacturers apply shipments analysis and NIA to analyze each EL in the MIA. to their MPCs to arrive at the MSPs. how consumers would shift between See chapter 13 of the NOPR TSD for This is different from the distribution GSFL product classes in response to a complete description of DOE’s chain markup, which is the markup standards (e.g., consumers might forgo assumptions for the capital and product retail stores apply to the MSP to arrive purchases of 4-foot MBP GSFLs in favor conversion costs. at the end user price. Based on SEC 10- of 4-foot T5 MiniBP SO GSFLs in Ks, DOE found the typical manufacturer response to a higher 4-foot MBP GSFL b. Manufacturer Production Costs markup for GSFL and IRL standard). GSFL consumers were not, Manufacturing more efficacious manufacturers on a corporate level was however, assumed to increase the GSFLs or IRLs is typically more 1.58. During manufacturer interviews, purchase of LEDs in response to expensive than manufacturing a DOE asked manufacturers if 1.58 was an increased GSFL energy conservation baseline product due to the need for appropriate markup to use for GSFLs standards. As discussed in section VI.I more costly materials and components. and IRLs. Based on manufacturer of this NOPR, the transition from GSFLs One of the primary drivers behind feedback that the 1.58 manufacturer to LEDs is accounted for in the base case increased material costs is the need for markup was too high for both GSFLs shipment analysis, and additional enhanced reflectors and/or burner and IRLs and should be lowered, DOE shifting to LEDs due to GSFL standards coatings for IRLs or rare earth oxides revised the manufacturer markup for was not modeled in the standards case (REOs) for GSFLs, as well as the need both GSFLs and IRLs to be 1.52. The shipment analysis or in the NIA. for higher volumes of these materials. 1.52 figure is the same manufacturer In the standards case for IRLs, the The higher manufacturer production markup used for these products in the change in the number of shipments from costs (MPCs) for these more efficacious 2009 Lamps Rule. the base case is mainly due to the products can affect the revenue, gross For a complete description of the end- increase in IRL lifetime at TSL 1 margin, and lifetime of the product, user prices, see the product price compared to the base case shipment which will then affect total volume of determination in section VI.E of this lifetime. IRLs that meet the efficacy future shipments, and the cash flows of NOPR. level specified at TSL 1 have a longer

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lifetime than the baseline IRLs. As a For the MIA, DOE modeled two standards case for the preservation of result, there are fewer shipments of IRLs standards case markup scenarios for operating profit markup scenario, DOE at TSL 1 than in the base case over the GSFLs and IRLs to represent the adjusted the GSFL and IRL analysis period, because the lamps at uncertainty regarding the potential manufacturer markups in the GRIM at TSL1 last longer. The NIA also modeled impacts on prices and profitability for each TSL to yield approximately the an alternative IRL shipment scenario GSFL and IRL manufacturers following same earnings before interest and taxes where the lifetime of IRLs at TSL 1 is the implementation of amended energy in the standards case in the year after shorter than the base case lifetime. DOE conservation standards. The two the compliance date of the amended examined the impacts of a shortened scenarios are: (1) A flat, or preservation GSFL and IRL standards as in the base lifetime scenario on manufacturers’ cash of gross margin, markup scenario and case. Under this scenario, while flow as a sensitivity analysis. The (2) a preservation of operating profit manufacturers are not able to yield results of the sensitivity analysis are markup scenario. Each scenario leads to additional operating profit from higher presented in appendix 13C of the NOPR different manufacturer markup values, production costs and the investments TSD. Also, similar to GSFLs, the which, when applied to the inputted that are required to comply with shipments analysis and the NIA for IRLs MPCs, result in varying revenue and amended GSFL and IRL energy did not model standards induced shifts cash flow impacts on GSFL and IRL conservation standards, they are able to to alternative lighting technologies, such manufacturers. maintain the same operating profit in as LEDs. Therefore, the MIA did not The flat, or preservation of gross the standards case that was earned in examine the revenue from LEDs in the margin, markup scenario assumes that the base case. manufacturers’ cash flows as part of the the COGS for each product is marked up The preservation of operating profit IRL MIA. While the shipments analysis by a flat percentage to cover SG&A markup scenario represents the lower and the NIA recognize that consumers expenses, R&D expenses, interest bound of industry profitability in the are shifting to alternative lighting expenses, and profit. This allows standards case. This is because technologies, which are accounted for in manufacturers to preserve the same manufacturers are not able to fully pass the base case shipments projection, the gross margin percentage in the through the additional costs shipments analysis and the NIA did not standards case as in the base case. This necessitated by GSFL and IRL energy model an accelerated shift to these markup scenario represents the upper conservation standards, as they are able alternative technologies specifically due bound of the GSFL and IRL industries’ to do in the flat (preservation of gross to increased standards of IRLs. profitability in the standards case margin) markup scenario. Therefore, For a complete description of the because GSFL and IRL manufacturers manufacturers earn less revenue in the shipments see the shipments analysis are able to fully pass through additional preservation of operating profit markup discussion in section VI.I of this NOPR. costs due to standards to their scenario than they do in the flat markup consumers. scenario. d. Markup Scenarios To derive the flat, or preservation of As discussed in the manufacturer gross margin, markup percentages for 3. Discussion of Comments production costs section above, the GSFLs and IRLs, DOE examined the SEC Interested parties commented on the MPCs for each of the product classes of 10-Ks of all publicly traded GSFL and assumptions and results of the GSFLs and IRLs are the manufacturers’ IRL manufacturers to estimate the preliminary analysis. Comments factory costs for those units. These costs industry average gross margin addressed several topics: the potential include materials, direct labor, percentage. Manufacturers were then shift to other lighting technologies in depreciation, and overhead, which are asked about the industry gross margin response to GSFL and IRL standards, the collectively referred to as the cost of percentage derived from SEC 10-Ks overall cumulative regulatory burden goods sold (COGS). The MSP is the during manufacturer interviews. GSFL facing lighting manufacturers, the price received by GSFL and IRL and IRL manufacturers stated that this potential decrease in competition due to manufacturers from their customers, average industry gross margin was too IRL standards, and the potential typically a distributor, regardless of the large and needed to be reduced. In required use of proprietary technologies downstream distribution channel response to these comments, DOE used to achieve higher efficacy levels for through which the lamps are ultimately the manufacturer markups from the IRLs. DOE addresses these comments sold. The MSP is not the cost the end- 2009 Lamps Rule for GSFLs and IRLs, below. user pays for GSFLs and IRLs because which was slightly less than the average a. Potential Shift to Other Lighting there are typically multiple sales along industry gross margin derived from SEC Technologies the distribution chain and various 10-Ks of GSFL and IRL manufacturers. markups applied to each sale. The MSP DOE included an alternative markup NEMA commented that further equals the MPC multiplied by the scenario, the preservation of operating investments in GSFL and IRL manufacturer markup. The profit markup, because manufacturers technologies due to energy conservation manufacturer markup covers all the stated they do not expect to be able to standards will divert resources away GSFL and IRL manufacturer’s non- markup the full cost of production in from LED technology development. production costs (i.e., selling, general the standards case, given the highly NEMA states that continued and administrative expenses [SG&A], competitive GSFL and IRL lighting development of LEDs could lead to research and development [R&D], and markets. The preservation of operating much great energy savings potential interest, etc.) as well as profit. Total profit markup scenario assumes that than the lighting technologies included industry revenue for GSFL and IRL manufacturers are able to maintain only in this rulemaking. NEMA recommends manufacturers equals the MSPs at each the base case total operating profit in that DOE include in the MIA for GSFLs EL for each product class multiplied by absolute dollars in the standards case, and IRLs the impact that such diversion the number of shipments at that EL. despite higher product costs and of resources will have on LED Modifying these manufacturer investment. The base case total technology if the lighting industry is markups in the standards case yields a operating profit is derived from marking required by a potential GSFL and IRL different set of impacts on GSFL and up the COGS for each product by the standard to make additional IRL manufacturers than in the base case. flat markup described above. In the investments in GSFL and IRL

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technologies that are already affect the major lighting manufacturers the cumulative regulatory burden as one experiencing diminishing returns on of this rulemaking. NEMA stated that of the potential impacts of potential investment and use. (NEMA, No. 36 at DOE does not adequately address or standard levels before ultimately p. 1) quantify the cumulative regulatory selecting an appropriate proposed DOE recognizes the opportunity cost burden. NEMA urges DOE to adopt a standard. This examination of the costs associated with any investment, and more transparent and open decision- and benefits of potential proposed agrees that manufacturers would need to making process to better address their standards is addressed in section VII.C spend capital to meet any proposed continued concerns. (NEMA, No. 30 at of this NOPR. GSFL and IRL standards that they pp. 338–340; NEMA, No. 36 at pp. 18– c. Potential Decrease in Competition would not have to spend in the base 19) The cumulative regulatory burden is case. The allocation of company explained in greater detail in section EEI commented they are concerned resources among different lighting VII.B.2.e of this NOPR, and a complete that there could be a reduction in technologies is a complex business description of the cumulative regulatory competition as a result of more stringent decision that each individual burden is included in chapter 13 of the GSFL and IRL energy conservation manufacturer will ultimately have to NOPR TSD. A complete description of standards. EEI stated they are especially make. As a result, manufacturers must the proposal selection process is concerned about any amended determine the extent to which they will provided in section VII.C of this NOPR. standards for IRLs due to the fact that balance investment in the GSFL and IRL GE commented they are concerned DOJ determined that the 2009 Lamps markets with investment in emerging about the speed of this amended GSFL Rule would have anti-competitive technologies, such as LEDs. The and IRL energy conservation standard, impacts on the IRL industry. EEI companies will have to weigh tradeoffs given that the 2009 Lamps Rule was contends that any increase in the between deferring investments and published in 2009 and required efficacy of IRLs due to amended deploying additional capital. DOE compliance in 2012. They believe that it standards could potentially increase includes the costs on manufacturers of is difficult for manufacturers to recover these anti-competitive impacts. (EEI, meeting today’s proposed standards in their previous investments made in new No. 30 at pp. 335–337) its analysis. technologies in only five and a half NEEA stated there seems to be an NEEP commented that the MIA years. This potential loss in investments increase in the number of brand names should account for any potential growth has a severe and negative manufacturer available in the marketplace for IRLs. in LED sales lighting manufacturers impact when rulemakings covering the (NEEA, No. 30 at pp. 337–338) In the might experience if the GSFL and IRL same products are so close together. 2009 Lamps Rule, DOJ had expressed markets are projected to shrink (GE, No. 30 at p. 188) concerns that the proposed TSL 4 for throughout the years of the analysis. Philips similarly commented that they IRLs could adversely affect competition Instead of only accounting for lost had invested millions of dollars in noting that only two of the three large revenues associated with a decrease in incandescent technologies to meet EISA manufacturers manufacture IRLs that GSFL and IRL sales, NEEP suggests DOE 2007’s general service lighting would meet the new standard and one also factor in the benefits those same requirements, which could become of these manufacturers uses proprietary manufacturers are potential gaining in obsolete due to amended IRL energy technology to do so. However, DOE the growing LED markets. (NEEP, No. 33 conservation standards. (Philips, No. 30 research showed that all three large at p. 3) at p. 187) EEI also made similar manufacturers had products that met Based on the shipment analysis DOE comments stating that manufacturers TSL 4 and access to alternative does not believe GSFL and IRL markets who made long-term investments to technology pathways to achieve this will increasingly migrate from comply with the 2009 Lamps Rule efficacy that did not require propriety traditional GSFL and IRL technologies might not have had time to recover their technology. Further, based on market to alternate lighting technologies, such investments in five or six years. (EEI, research, analysis of HIR burner as LEDs, in direct response to GSFL and No. 30 at p. 187) A member of Congress production, and interviews with IRL energy conservation standards. commented that the OSI facility in manufacturers and HIR burner While DOE recognizes that LEDs are Kentucky recently underwent major suppliers, DOE determined that continuing to capture more and more of retooling to bring the facility into manufacturers would not face any long- the traditional lighting markets serviced compliance with EISA’s incandescent term capacity constraints. Therefore, by GSFLs and IRLs, DOE does not lighting requirements. Bringing that DOE concluded that the proposed level believe that GSFL and IRL standards facility into compliance with even more in the 2009 Lamps rule for IRLs would will increase this shift to LEDs. stringent IRL regulations would require not result in lessening competition. 74 Therefore, this market shift to LEDs is an increased capital outlay that is FR 34080, 34160 (July 14, 2009). captured in the base case shipment unavailable to the company at this time. DOE examines the potential decrease scenario and is not a standards-induced This could result in a reduction of U.S. in competition from amended energy market shift. DOE excludes the revenue manufacturing jobs. (Barr, No. 25 at p. conservation standards in section from LEDs earned by manufacturers 1–2) As part of the cumulative VII.B.5 of this NOPR. DOE also submits who produce GSFLs and IRLs in the regulatory burden analysis in section a copy of the NOPR to DOJ for review GRIM since the revenue stream would VII.B.2.e of this NOPR, DOE examines as part of the rulemaking process and be present in both the base case and the the investments manufacturers have considers input from DOJ in developing standards case, resulting in no net made to comply with previous any final standards. impact on the change in INPV. rulemakings. Philips also commented on the 4. Manufacturer Interviews b. Cumulative Regulatory Burden cumulative regulatory burden, asking DOE conducted additional interviews NEMA, along with some individual DOE to specify the criteria that with manufacturers following the manufacturers, commented on the determines if the proposed standards preliminary analysis in preparation for cumulative regulatory burden of this constitute a cumulative regulatory the NOPR analysis. In these interviews, rulemaking given there are several DOE burden on manufacturers. (Philips, No. DOE asked manufacturers to describe energy conservation standards that 30 at pp. 339–340; 347) DOE examines their major concerns with this GSFL and

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IRL rulemaking. The following section the market. Manufacturers noted that operating hours and manufacturers are describes the key issues identified by they have developed new products to concerned that they will give up longer GSFL and IRL manufacturers during meet the 2009 Lamps Rule standards life to get a cheaper lamp. Furthermore, these interviews. and are still waiting to see which manufacturers expressed concern that consumers purchase which types of amended GSFL standards may be overly a. Rare Earth Oxides in General Service lamps. burdensome by forcing some residential Fluorescent Lamps Furthermore, manufacturers stated consumers of GSFLs to switch out their Several manufacturers are concerned they have already made significant entire lighting system (i.e., ballast and that increasing the efficacy of GSFLs in capital investments in order to be able fixture) due to replacement lamps being response to amended energy to produce the more efficacious GSFLs regulated out of production for only conservation standards will require the and IRLs required by the 2009 Lamps minimal energy savings. DOE use of significantly more REOs in Rule standards. Manufacturers are acknowledges that residential GSFLs. This could expose GSFL concerned that any additional increase consumers could be differentially manufacturers to the risk of another in the efficacy of those products due to impacted by GSFL and IRL standards significant increase in the price of REOs. amended energy conservation standards compared to commercial consumers. Over the past several years the price of could potentially strand the substantial DOE analyzed residential and REOs used in GSFLs has been extremely capital investments made to comply commercial consumers separately in the volatile. In 2011, the price of REOs with the 2009 Lamps Rule, as LCC analysis for GSFLs and IRLs. These significantly increased but has slowly manufacturers have not yet fully results are presented in section VII.B.1.a been coming down over the past couple recouped these capital investments. of this NOPR. of years. While the current price of Manufacturers stated that a five year many of these REOs has returned to time period between the compliance L. Emissions Analysis much lower levels than the peak prices date of the 2009 Lamps Rule (July 2012) In the emissions analysis, DOE experienced between 2010 and 2012, and the estimated compliance date of estimated the reduction in power sector GSFL manufacturers are concerned that the current GSFL and IRL rulemaking emissions of SO2, NOX, CO2, and Hg the price of REOs could return to those (2017) is too short for most from potential energy conservation peak prices in the future. GSFL manufacturers to recoup their capital standards for GSFLs and IRLs. In manufacturers are also concerned an investments, since manufacturing addition, DOE estimates emissions increase in the demand for REOs due to machinery typically has a much longer impacts in production activities amended energy conservation standards useful lifetime than five years. See (extracting, processing, and transporting could cause the price for these REOs to section VII.B.2 of this NOPR for an fuels) that provide the energy inputs to spike. analysis of the investments power plants. These are referred to as Several GSFL manufacturers also manufacturers must make to comply ‘‘upstream’’ emissions. Together, these noted that amended energy conservation with standards. emissions account for the FFC. standards for GSFLs could have adverse DOE conducted the emissions c. Technology Shift impacts on the domestic production of analysis using emissions factors for CO2 GSFLs. China is currently the dominant Several manufacturers contended that and other gases derived from data in the miner and producer of REOs worldwide regardless of amended energy EIA’s AEO 2013, supplemented by data and imposes quotas on the export of raw conservation standards, a technological from other sources. DOE developed REOs. This drives up the costs for shift away from GSFLs and IRLs is separate emissions factors for power manufacturers of products using REOs already occurring. They pointed out that sector emissions and upstream that manufacture these products outside the market is already moving toward emissions. EIA prepares the AEO using of China. As a result, manufacturers LEDs, especially in the commercial NEMS. Each annual version of NEMS pointed out that amended GSFL sector. Manufacturers are concerned incorporates the projected impacts of standards could make it more attractive that amended standards would force existing air quality regulations on to manufacture GSFLs in China, rather them to divert resources away from the emissions. AEO 2013 generally than domestically, because the price of R&D of more efficacious lighting represents current legislation and REOs would likely be much lower in products, such as LEDs, by forcing environmental regulations, including China. See section VI.D.2.i of this NOPR manufacturers to spend time and money recent government actions, for which for further discussion of the assessments on GSFLs and IRLs, which have implementing regulations were of rare earth phosphor impacts from diminishing market shares. This available as of December 31, 2012. The amended standards undertake in this increase in the efficacy of GSFLs and method that DOE used to derive NOPR analysis. IRLs would increase the end-user price emissions factors is described in chapter of GSFLs and IRLs which could 14 of the NOPR TSD. b. Unknown Impacts of the 2009 Lamps ultimately drive consumers to purchase SO2 emissions from affected electric Rule other lighting technologies, like LEDs. generating units (EGUs) are subject to Several manufacturers expressed This could result in a further stranding nationwide and regional emissions cap- concern that amended energy of any capital investments made for and-trade programs. Title IV of the conservation standards for GSFLs and GSFLs and IRLs. See section VI.I of this Clean Air Act sets an annual emissions IRLs would be premature given that the NOPR for discussion on the LED market cap on SO2 for affected EGUs in the 48 last round of DOE energy conservation penetration shipment scenario. contiguous states and the District of standards for GSFLs and IRLs required Columbia (D.C.). SO2 emissions from 28 compliance in July 2012. Manufacturers d. Impact on Residential Sector eastern states and D.C. were also limited are still unsure how the standards from Several manufacturers expressed under the Clean Air Interstate Rule the 2009 Lamps Rule will ultimately concern that amended energy (CAIR; 70 FR 25162 (May 12, 2005)), affect their future sales and shipments conservation standards for GSFLs and which created an allowance-based as consumer preferences shift since IRLs would not achieve substantial trading program that operates along there are a relatively large number of energy savings in the residential sector. with the Title IV program. CAIR was alternative lighting options available on Residential consumers do not have long remanded to the U.S. Environmental

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Protection Agency (EPA) by the U.S. unlikely that excess SO2 emissions expected to result from each of the TSLs Court of Appeals for the District of allowances resulting from the lower considered. To make this calculation Columbia Circuit but it remained in electricity demand would be needed or similar to the calculation of the NPV of effect. See North Carolina v. EPA, 550 used to permit offsetting increases in consumer benefit, DOE considered the F.3d 1176 (D.C. Cir. 2008); North SO2 emissions by any regulated EGU. reduced emissions expected to result Carolina v. EPA, 531 F.3d 896 (D.C. Cir. Therefore, DOE believes that efficiency over the lifetime of product shipped in 2008). On July 6, 2011 EPA issued a standards will reduce SO2 emissions in the forecast period for each TSL. This replacement for CAIR, the Cross-State 2015 and beyond. section summarizes the basis for the Air Pollution Rule (CSAPR). 76 FR CAIR established a cap on NOX monetary values used for each of these 48208 (August 8, 2011). On August 21, emissions in 28 eastern states and the emissions and presents the values 2012, the D.C. Circuit issued a decision District of Columbia. Energy considered in this rulemaking. to vacate CSAPR. See EME Homer City conservation standards are expected to For today’s NOPR, DOE is relying on Generation, LP v. EPA, No. 11–1302, have little effect on NOX emissions in a set of values for the social cost of 2012 WL 3570721 at *24 (D.C. Cir. Aug. those states covered by CAIR because carbon (SCC) that was developed by an 21, 2012). The court ordered EPA to excess NOX emissions allowances interagency process. A summary of the continue administering CAIR. The AEO resulting from the lower electricity basis for these values is provided below, 2013 emissions factors used for today’s demand could be used to permit and a more detailed description of the NOPR assumes that CAIR remains a offsetting increases in NOX emissions. methodologies used is provided in binding regulation through 2040. However, standards would be expected appendices to chapter 15 of the NOPR The attainment of emissions caps is to reduce NOX emissions in the states TSD. typically flexible among EGUs and is not affected by the caps, so DOE 1. Social Cost of Carbon enforced through the use of emissions estimated NOX emissions reductions allowances and tradable permits. Under from the standards considered in this The SCC is an estimate of the existing EPA regulations, any excess NOPR for these states. monetized damages associated with an SO2 emissions allowances resulting The MATS limit mercury emissions incremental increase in carbon from the lower electricity demand from power plants, but they do not emissions in a given year. It is intended caused by the adoption of an efficacy include emissions caps and, as such, to include (but is not limited to) changes standard could be used to permit DOE’s energy conservation standards in net agricultural productivity, human offsetting increases in SO2 emissions by would likely reduce Hg emissions. DOE health, property damages from any regulated EGU. In past rulemakings, estimated Hg emissions reduction using increased flood risk, and the value of DOE recognized that there was emissions factors based on AEO 2013, ecosystem services. Estimates of the uncertainty about the effects of which incorporates the MATS. SCC are provided in dollars per metric efficiency standards on SO2 emissions In accordance with DOE’s FFC ton of CO2. A domestic SCC value is covered by the existing cap-and-trade Statement of Policy (76 FR 51282 (Aug. meant to reflect the value of damages in system, but it concluded that negligible 18, 2011)), the FFC analysis includes the United States resulting from a unit reductions in power sector SO2 impacts on emissions of methane (CH ) change in CO2 emissions, while a global 4 SCC value is meant to reflect the value emissions would occur as a result of and nitrous oxide (N2O), both of which standards. are recognized as GHGs. For CH and of damages worldwide. 4 Under section 1(b)(6) of Executive Beginning in 2015, however, SO2 N O, DOE calculated emissions 2 Order 12866, ‘‘Regulatory Planning and emissions will fall as a result of the reductions in tons and also in terms of Review,’’ 58 FR 51735 (Oct. 4, 1993), Mercury and Air Toxics Standards units of carbon dioxide equivalent agencies must, to the extent permitted (MATS) for power plants, which were (CO eq). Gases are converted to CO eq 2 2 by law, assess both the costs and the announced by EPA on December 21, by multiplying the emissions reduction benefits of the intended regulation and, 2011. 77 FR 9304 (Feb. 16, 2012). In the in tons by the gas’ global warming recognizing that some costs and benefits final MATS rule, EPA established a potential (GWP) over a 100-year time are difficult to quantify, propose or standard for hydrogen chloride as a horizon. Based on the Fourth adopt a regulation only upon a reasoned surrogate for acid gas hazardous air Assessment Report of the determination that the benefits of the pollutants (HAP), and also established a Intergovernmental Panel on Climate intended regulation justify its costs. The standard for SO2 (a non-HAP acid gas) Change,80 DOE used GWP values of 25 purpose of the SCC estimates presented as an alternative equivalent surrogate for CH and 298 for N O. standard for acid gas HAP. The same 4 2 here is to allow agencies to incorporate controls are used to reduce HAP and M. Monetizing Carbon Dioxide and the monetized social benefits of non-HAP acid gas; thus, SO2 emissions Other Emissions Impacts reducing CO2 emissions into cost- will be reduced as a result of the control As part of the development of this benefit analyses of regulatory actions technologies installed on coal-fired proposed rule, DOE considered the that have small, or ‘‘marginal,’’ impacts power plants to comply with the MATS estimated monetary benefits from the on cumulative global emissions. The requirements for acid gas. AEO 2013 estimates are presented with an reduced emissions of CO2 and NOX assumes that, to continue operating, acknowledgement of the many coal plants must have either flue gas 80 Forster, P., V. Ramaswamy, P. Artaxo, T. uncertainties involved and with a clear desulfurization or dry sorbent injection Berntsen, R. Betts, D.W. Fahey, J. Haywood, J. Lean, understanding that they should be systems installed by 2015. Both D.C. Lowe, G. Myhre, J. Nganga, R. Prinn, G. Raga, updated over time to reflect increasing technologies, which are used to reduce M. Schulz and R. Van Dorland. 2007: Changes in knowledge of the science and Atmospheric Constituents and in Radiative Forcing. acid gas emissions, also reduce SO2 In Climate Change 2007: The Physical Science economics of climate impacts. emissions. Under the MATS, NEMS Basis. Contribution of Working Group I to the As part of the interagency process that shows a reduction in SO2 emissions Fourth Assessment Report of the Intergovernmental developed the SCC estimates, technical when electricity demand decreases (e.g., Panel on Climate Change. S. Solomon, D. Qin, M. experts from numerous agencies met on Manning, Z. Chen, M. Marquis, K.B. Averyt, as a result of energy efficiency M.Tignor and H.L. Miller, Editors. 2007. Cambridge a regular basis to consider public standards). Emissions will be far below University Press, Cambridge, United Kingdom and comments, explore the technical the cap established by CAIR, so it is New York, NY, USA. p. 212. literature in relevant fields, and discuss

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key model inputs and assumptions. The improves over time. In the meantime, process, to quantify avoided climate main objective of this process was to the interagency group will continue to change damages from reduced CO2 develop a range of SCC values using a explore the issues raised by this analysis emissions. The interagency group did defensible set of input assumptions and consider public comments as part of not undertake any original analysis. grounded in the existing scientific and the ongoing interagency process. Instead, it combined SCC estimates from economic literatures. In this way, key b. Social Cost of Carbon Values Used in the existing literature to use as interim uncertainties and model differences Past Regulatory Analyses values until a more comprehensive transparently and consistently inform analysis could be conducted. The the range of SCC estimates used in the Economic analyses for Federal outcome of the preliminary assessment rulemaking process. regulations have used a wide range of by the interagency group was a set of values to estimate the benefits a. Monetizing Carbon Dioxide Emissions five interim values: Global SCC associated with reducing CO2 emissions. estimates for 2007 (in 2006$) of $55, When attempting to assess the In the final model year 2011 CAFE rule, $33, $19, $10, and $5 per metric ton of incremental economic impacts of CO2 the U.S. Department of Transportation CO2. These interim values represented emissions, the analyst faces a number of (DOT) used both a ‘‘domestic’’ SCC the first sustained interagency effort serious challenges. A recent report from value of $2 per metric ton of CO2 and within the U.S. government to develop the National Research Council points a ‘‘global’’ SCC value of $33 per metric an SCC for use in regulatory analysis. out that any assessment will suffer from ton of CO2 for 2007 emission reductions The results of this preliminary effort uncertainty, speculation, and lack of (in 2007$), increasing both values at 2.4 were presented in several proposed and information about: (1) Future emissions percent per year. DOT also included a final rules. of GHGs; (2) the effects of past and sensitivity analysis at $80 per metric ton 81 future emissions on the climate system; of CO2. A 2008 regulation proposed by c. Current Approach and Key (3) the impact of changes in climate on DOT assumed a domestic SCC value of Assumptions the physical and biological $7 per metric ton of CO2 (in 2006$) for environment; and (4) the translation of 2011 emission reductions (with a range Since the release of the interim these environmental impacts into of $0 to $14 for sensitivity analysis), values, the interagency group economic damages. As a result, any also increasing at 2.4 percent per year.82 reconvened on a regular basis to effort to quantify and monetize the A regulation for packaged terminal air generate improved SCC estimates. harms associated with climate change conditioners and packaged terminal Specifically, the group considered will raise serious questions of science, heat pumps finalized by DOE in October public comments and further explored economics, and ethics and should be of 2008 used a domestic SCC range of the technical literature in relevant viewed as provisional. $0 to $20 per metric ton CO2 for 2007 fields. The interagency group relied on Despite the serious limits of both emission reductions (in 2007$). 73 FR three integrated assessment models quantification and monetization, SCC 58772, 58814 (Oct. 7, 2008). In addition, commonly used to estimate the SCC: estimates can be useful in estimating the EPA’s 2008 Advance Notice of Proposed The FUND, DICE, and PAGE models. social benefits of reducing CO2 Rulemaking on Regulating Greenhouse These models are frequently cited in the emissions. Most Federal regulatory Gas Emissions Under the Clean Air Act peer-reviewed literature and were used actions can be expected to have identified what it described as ‘‘very in the last assessment of the marginal impacts on global emissions. preliminary’’ SCC estimates subject to Intergovernmental Panel on Climate For such policies, the agency can revision. 73 FR 44354 (July 30, 2008). Change. Each model was given equal estimate the benefits from reduced EPA’s global mean values were $68 and weight in the SCC values that were emissions in any future year by $40 per metric ton CO2 for discount developed. multiplying the change in emissions in rates of approximately 2 percent and 3 Each model takes a slightly different that year by the SCC value appropriate percent, respectively (in 2006$ for 2007 approach to model how changes in for that year. The NPV of the benefits emissions). emissions result in changes in economic can then be calculated by multiplying In 2009, an interagency process was damages. A key objective of the the future benefits by an appropriate initiated to offer a preliminary interagency process was to enable a discount factor and summing across all assessment of how best to quantify the consistent exploration of the three affected years. This approach assumes benefits from reducing CO2 emissions. models while respecting the different that the marginal damages from To ensure consistency in how benefits approaches to quantifying damages increased emissions are constant for are evaluated across agencies, the taken by the key modelers in the field. small departures from the baseline Administration sought to develop a An extensive review of the literature emissions path, an approximation that transparent and defensible method, was conducted to select three sets of is reasonable for policies that have specifically designed for the rulemaking input parameters for these models: effects on emissions that are small Climate sensitivity, socio-economic and 81 relative to cumulative global CO2 See Average Fuel Economy Standards emissions trajectories, and discount Passenger Cars and Light Trucks Model Year 2011, emissions. For policies that have a large rates. A probability distribution for (non-marginal) impact on global 74 FR 14196 (March 30, 2009) (Final Rule); Final Environmental Impact Statement Corporate Average climate sensitivity was specified as an cumulative emissions, there is a Fuel Economy Standards, Passenger Cars and Light input into all three models. In addition, separate question of whether the SCC is Trucks, Model Years 2011–2015 at 3–90 (Oct. 2008) the interagency group used a range of (Available at: www.nhtsa.gov/fuel-economy) (Last an appropriate tool for calculating the scenarios for the socio-economic benefits of reduced emissions. This accessed December 2012). 82 See Average Fuel Economy Standards, parameters and a range of values for the concern is not applicable to this Passenger Cars and Light Trucks, Model Years discount rate. All other model features rulemaking, however. 2011–2015, 73 FR 24352 (May 2, 2008) (Proposed were left unchanged, relying on the It is important to emphasize that the Rule); Draft Environmental Impact Statement model developers’ best estimates and interagency process is committed to Corporate Average Fuel Economy Standards, Passenger Cars and Light Trucks, Model Years judgments. updating these estimates as the science 2011–2015 at 3–58 (June 2008) (Available at: and economic understanding of climate www.nhtsa.gov/fuel-economy) (Last accessed In 2010, the interagency group change and its impacts on society December 2012). selected four sets of SCC values for use

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in regulatory analyses.83 Three sets of represent higher-than-expected impacts domestic effects, although preference is values are based on the average SCC from climate change further out in the given to consideration of the global from three integrated assessment tails of the SCC distribution. The values benefits of reducing CO2 emissions. models, at discount rates of 2.5 percent, grow in real terms over time. Table VI.15 presents the values in the 3 percent, and 5 percent. The fourth set, Additionally, the interagency group 2010 interagency group report, which is which represents the 95th-percentile determined that a range of values from reproduced in appendix 15A of the SCC estimate across all three models at 7 percent to 23 percent should be used NOPR TSD. a 3 percent discount rate, is included to to adjust the global SCC to calculate

TABLE VI.15—ANNUAL SCC VALUES FROM 2010 INTERAGENCY REPORT, 2010–2050

[In 2007 dollars per metric ton CO2]

Discount rate % Year 5 3 2.5 3 Average Average Average 95th Percentile

2010 ...... 4.7 21.4 35.1 64.9 2015 ...... 5.7 23.8 38.4 72.8 2020 ...... 6.8 26.3 41.7 80.7 2025 ...... 8.2 29.6 45.9 90.4 2030 ...... 9.7 32.8 50.0 100.0 2035 ...... 11.2 36.0 54.2 109.7 2040 ...... 12.7 39.2 58.4 119.3 2045 ...... 14.2 42.1 61.7 127.8 2050 ...... 15.7 44.9 65.0 136.2

The SCC values used for today’s updated sets of SCC estimates from the SCC across models at 3 percent discount notice were generated using the most 2013 interagency update in five-year rate. However, for purposes of capturing recent versions of the three integrated increments from 2010 to 2050. the uncertainties involved in regulatory assessment models that have been Appendix 15B of the NOPR TSD impact analysis, the interagency group published in the peer-reviewed provides the full set of values. The emphasizes the importance of including literature.84 Table VI.16 shows the central value that emerges is the average all four sets of SCC values.

TABLE VI.16—ANNUAL SCC VALUES FROM 2013 INTERAGENCY UPDATE, 2010–2050

[In 2007 dollars per metric ton CO2]

Discount rate % Year 5 3 2.5 3 Average Average Average 95th Percentile

2010 ...... 11 32 51 89 2015 ...... 11 37 57 109 2020 ...... 12 43 64 128 2025 ...... 14 47 69 143 2030 ...... 16 52 75 159 2035 ...... 19 56 80 175 2040 ...... 21 61 86 191 2045 ...... 24 66 92 206 2050 ...... 26 71 97 220

It is important to recognize that a and incomplete. The National Research and problems that should be addressed number of key uncertainties remain, and Council report mentioned previously by the research community, including that current SCC estimates should be points out that there is tension between research programs housed in many of treated as provisional and revisable the goal of producing quantified the federal agencies participating in the since they will evolve with improved estimates of the economic damages from interagency process to estimate the SCC. scientific and economic understanding. an incremental ton of carbon and the The interagency group intends to The interagency group also recognizes limits of existing efforts to model these periodically review and reconsider that the existing models are imperfect effects. There are a number of concerns those estimates to reflect increasing

83 Social Cost of Carbon for Regulatory Impact inforeg/for-agencies/Social-Cost-of-Carbon-for- Cost of Carbon, United States Government. May Analysis Under Executive Order 12866. Interagency RIA.pdf. 2013; revised November 2013. http:// Working Group on Social Cost of Carbon, United 84 Technical Update of the Social Cost of Carbon www.whitehouse.gov/sites/default/files/omb/assets/ States Government, February 2010. for Regulatory Impact Analysis Under Executive inforeg/technical-update-social-cost-of-carbon-for- www.whitehouse.gov/sites/default/files/omb/ Order 12866. Interagency Working Group on Social regulator-impact-analysis.pdf.

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knowledge of the science and changes in installed electricity capacity expenditure on power plants are a economics of climate impacts, as well as and generation that would result for benefit to society.88 improvements in modeling. each trial standard level. The utility O. Employment Impact Analysis In summary, in considering the impact analysis uses a variant of potential global benefits resulting from NEMS,86 which is a public domain, Employment impacts from new or reduced CO2 emissions resulting from multi-sectored, partial equilibrium amended energy conservation standards today’s rule, DOE used the values from model of the U.S. energy sector. DOE include direct and indirect impacts. the 2013 interagency report, adjusted to uses a variant of this model, referred to Direct employment impacts are any 2012$ using the Gross Domestic Product as NEMS–BT, to account for selected changes in the number of employees of price deflator. For each of the four SCC utility impacts of new or amended manufacturers of the product subject to cases specified, the values used for energy conservation standards. DOE’s standards; the MIA addresses those emissions in 2015 were $11.8, $39.7, analysis consists of a comparison impacts. Indirect employment impacts $61.2, and $117 per metric ton avoided between model results for the most are changes in national employment (values expressed in 2012$). DOE recent AEO Reference Case and for cases that occur due to the shift in derived values after 2050 using the in which energy use is decremented to expenditures and capital investment relevant growth rates for the 2040–2050 reflect the impact of potential standards. caused by the purchase and operation of period in the interagency update. DOE The energy savings inputs associated more efficient product. Indirect invites comment on the methodology with each TSL come from the NIA. employment impacts from standards used to estimate the social cost of Chapter 16 of the NOPR TSD describes consist of the jobs created or eliminated carbon. the utility impact analysis in further in the national economy, other than in DOE multiplied the CO2 emissions detail. the manufacturing sector being reduction estimated for each year by the NEEP urged DOE to quantify the regulated, due to: (1) Reduced spending SCC value for that year in each of the economic benefits of electricity demand by end users on energy; (2) reduced four cases. To calculate a present value reductions for this rulemaking. (NEEP, spending on new energy supply by the of the stream of monetary values, DOE No. 51 at p. 3) utility industry; (3) increased consumer discounted the values in each of the For the NOPR, DOE used NEMS–BT, spending on the purchase of new four cases using the specific discount along with EIA data on the capital cost product; and (4) the effects of those rate that had been used to obtain the of various power plant types, to estimate three factors throughout the economy. SCC values in each case. the reduction in national expenditures One method for assessing the possible for electricity generating capacity due to 2. Valuation of Other Emissions effects on the demand for labor of such potential GSFL–IRL energy efficiency Reductions shifts in economic activity is to compare standards. The method used and the sector employment statistics developed As noted previously, DOE has taken results are described in chapter 16 of the by the Labor Department’s Bureau of into account how new or amended NOPR TSD. Labor Statistics (BLS). BLS regularly energy conservation standards would DOE is evaluating whether parts of publishes its estimates of the number of reduce NOX emissions in those 22 states the cost reduction are a transfer and, jobs per million dollars of economic not affected by the CAIR. DOE estimated thus, according to guidance provided by activity in different sectors of the the monetized value of NOX emissions OMB to Federal agencies, should not be economy, as well as the jobs created reductions resulting from each of the included in the estimates of the benefits elsewhere in the economy by this same TSLs considered for today’s NOPR and costs of a regulation.87 Transfer economic activity. Data from BLS based on estimates found in the relevant payments are monetary payments from indicate that expenditures in the utility scientific literature. Estimates of one group to another that do not affect sector generally create fewer jobs (both monetary value for reducing NOX from total resources available to society (i.e., directly and indirectly) than stationary sources range from $468 to exchanges that neither decrease nor expenditures in other sectors of the 85 $4,809 per ton in 2012$. DOE increase total welfare). Benefits occur economy. There are many reasons for calculated monetary benefits using a when savings to consumers result from these differences, including wage medium value for NOX emissions of real savings to producers, which differences and the fact that the utility $2,639 per short ton (in 2012$) and real increase societal benefits. Cost savings sector is more capital-intensive and less discount rates of 3 percent and 7 from reduced or delayed capital labor-intensive than other sectors. percent. expenditure on power plants are a Energy conservation standards have the DOE is evaluating appropriate benefit, and not a transfer, to the extent effect of reducing consumer utility bills. monetization of avoided SO2 and Hg that the reduced expenditure provides Because reduced consumer emissions in energy conservation savings to both producers and expenditures for energy likely lead to standards rulemakings. It has not consumers without affecting other increased expenditures in other sectors included monetization in the current groups. There would be a transfer to the of the economy, the general effect of analysis. extent that the delayed construction efficiency standards is to shift economic caused some other group (e.g., product N. Utility Impact Analysis activity from a less labor-intensive suppliers or landowners who might The utility impact analysis estimates have assets committed to the projects) to 88 Although delayed investment implies a savings several effects on the power generation realize a lower return on those assets. in total cost, the savings may be less than the industry that would result from the DOE is evaluating these issues to savings in capital cost because the delay may also adoption of new or amended energy determine the extent to which the cost cause increases in other costs. For example, if the conservation standards. In the utility savings from delayed capital delayed investment was the replacement of an existing facility with a larger, more efficient facility, impact analysis, DOE analyzes the the increased cost of operating the old facility 86 For more information on NEMS, refer to the during the period of delay might offset much of the 85 U.S. Office of Management and Budget, Office U.S. Department of Energy, Energy Information savings from delayed investment. That the project of Information and Regulatory Affairs, 2006 Report Administration documentation. A useful summary was delayed is evidence that doing so decreased to Congress on the Costs and Benefits of Federal is National Energy Modeling System: An Overview overall cost, but it does not indicate that the Regulations and Unfunded Mandates on State, 2003, DOE/EIA–0581 (2003) (March, 2003). decrease was equal to the entire savings in capital Local, and Tribal Entities, Washington, DC. 87 OMB Circular A–4 (Sept. 17, 2003), p. 38. cost.

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sector (i.e., the utility sector) to more NEMA stated that existing voluntary SO lamps relative to the base case is at labor-intensive sectors (e.g., the retail incentives are already shifting the the expense of 4-foot MBP lamps, not and service sectors). Based on the BLS market to higher-efficiency products LEDs. data, DOE expects that net national and systems. (NEMA, No. 36 at p. 17) VII. Analytical Results employment may increase because of Trends in the GSFL and IRL market are shifts in economic activity resulting accounted for in DOE’s projection of the A. Trial Standard Levels base case. The impacts estimated for from amended standards. At the NOPR stage, DOE develops potential standards are above movement For the standard levels considered in trial standard levels (TSLs) for toward higher efficiency in the base the NOPR, DOE estimated indirect consideration. The GSFL and IRL TSLs case. national employment impacts using an are formed by grouping different input/output model of the U.S. economy NEMA commented that standards are not justified for IRLs. Specifically, efficacy levels, which are potential called Impact of Sector Energy NEMA stated that the miniscule energy standard levels for each product class. Technologies, Version 3.1.1 (ImSET). savings estimated for IRLs, combined TSL 5 is composed of the max tech ImSET is a special-purpose version of with elimination of their market share efficacy levels. TSL 4 is composed of the the ‘‘U.S. Benchmark National Input- by 2025, demonstrate why this class efficacy levels that, in combination, Output’’ (I–O) model, which was should not be further regulated and DOE yield the maximum NPV. TSL 3 is designed to estimate the national should not adopt a new standard. composed of the efficacy levels that employment and income effects of (NEMA, No. 36 at pp. 2, 17) DOE’s yield the maximum energy savings energy-saving technologies. The ImSET analysis indicates that the market share without using any of the EL 2 levels. software includes a computer-based I–O of IRLs would decline under the TSL 2 is composed of the efficacy levels model having structural coefficients that proposed standards, but the product that would bring all product classes to characterize economic flows among the would not be eliminated. The reasons approximately the same level of rare 187 sectors. ImSET’s national economic for DOE’s decision to propose standards earth phosphor. TSL 1 is composed of I–O structure is based on a 2002 U.S. for IRLs are explained in section VII.C the levels that represent the least benchmark table, specially aggregated to of this notice. efficacious lamps currently available on the 187 sectors most relevant to NEMA also stated that, if DOE were the U.S. market; currently there are no industrial, commercial, and residential to proceed with a higher standard for T5 products in the market at the baseline building energy use. DOE notes that SO lamps, the projected shipments go (EL 0) for 8-foot RDC HO lamps or T5 ImSET is not a general equilibrium up (compared with the base case). It lamps. For IRLs, DOE considered one forecasting model, and understands the noted that, as the only competitor for T5 TSL because only one efficacy level was uncertainties involved in projecting SO is LED, increasing the demand for analyzed (Table VII.2). employment impacts, especially T5 SO takes market share away from DOE used data on the representative changes in the later years of the LED, a technology that is on the rise for product classes from the engineering analysis. Because ImSET does not reasons of popularity, lifetime, and and pricing analyses described in incorporate price changes, the efficiency. It stated that decreasing section VI.D.2.b for GSFLs and section employment effects predicted by ImSET demand for LED technology in favor of VI.D.3.b for IRLs to evaluate the benefits may over-estimate actual job impacts an obsoleting technology that relies on and burdens of each of the GSFL and over the long run. For the NOPR, DOE critical materials (rare earth phosphors) IRL TSLs. DOE analyzed the benefits used ImSET only to estimate short-term and mercury is not a sound decision. and burdens by conducting the analyses employment impacts. For more details (NEMA, No. 36 at p. 17) As discussed described in section VI for each TSL. on the employment impact analysis, see in chapter 11 of the NOPR TSD, the Table VII.1 presents the GSFL TSLs chapter 17 of the NOPR TSD. model accounts for the progressive and analyzed and the corresponding efficacy P. Other Comments large incursion of LEDs into the GSFL level for each GSFL representative market. The model then apportions the product class. Table VII.2 presents the DOE received several comments that remaining demand for GSFL lamps IRL TSL analyzed and the address the overall merits of adopting among the product classes. The corresponding efficacy level for the amended standards for GSFLs and IRLs. projected increase in shipments of T5 representative IRL product class.

TABLE VII.1—COMPOSITION OF TSLS FOR GSFLSBYEFFICACY LEVEL

TSL 2 TSL 1 Same TSL 3 TSL 4 TSL 5 Representative product class Current market phosphor Best non-EL 2 Max NPV Max tech min level

1. 4-foot medium bipin, CCT ≤4,500 K ...... 0 0 1 2 2 2. 8-foot single pin slimline, CCT ≤4,500 K ...... 0 1 0 0 2 3. 8-foot RDC high output, CCT ≤4,500 K ...... 1 2 1 1 2 4. 4-foot T5, Mini bipin standard output, CCT ≤4,500 K ..... 1 1 1 1 2 5. 4-foot T5, Mini bipin high output, CCT ≤4,500 K ...... 1 1 1 1 1

TABLE VII.2—COMPOSITION OF TSLS B. Economic Justification and Energy the LCC and PBP. DOE also examined FOR IRLSBYEFFICACY LEVEL Savings the impacts of potential standards on consumer subgroups. These analyses are 1. Economic Impacts on Individual discussed below. Representative product class TSL 1 Consumers a. Life-Cycle Cost and Payback Period Standard spectrum; >2.5 DOE analyzed the economic impacts inch diameter; <125 V ...... 1 on GSFL and IRL consumers by looking Consumers affected by new or at the effects standards would have on amended standards usually experience

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higher purchase prices and lower higher than the LCC of the baseline The results for each TSL are relative operating costs. Generally, these lamp or lamp-and-ballast system, and to the energy use distribution in the impacts on individual consumers are the consumer is adversely affected base case (no amended standards), best captured by changes in LCCs and economically. The last outputs in the based on energy consumption under by the payback period. DOE’s LCC and tables are the mean PBPs for the conditions of actual product use. The PBP analyses provide key outputs for consumer that is purchasing a design rebuttable presumption PBP is based on each TSL, which are reported by compliant with the TSL. Entries of test values under conditions prescribed product class in Table VII.3–Table ‘‘NER’’ indicate standard levels that do by the DOE test procedure, as required VII.15. DOE designed the LCC analysis not reduce operating costs, which by EPCA. (42 U.S.C. 6295(o)(2)(B)(iii)) around lamp purchasing events and prevents the consumer from recovering General Service Fluorescent Lamps calculated the LCC savings relative to the increased purchase cost. The PBP the baseline for each lamp replacement cannot be calculated in those instances event separately in each lamp product Table VII.3 through Table VII.11 because the denominator of the PBP class. Each table includes the average present the results for each of the five total LCC and the average LCC savings, equation is 0. Because LCC savings and GSFL representative product classes as well as the fraction of product PBP are not relevant at the baseline that DOE analyzed. Specifically, these consumers for which the LCC will either level, results are ‘‘N/A’’ (not applicable) were the 4-foot MBP product class, 4- decrease (net benefit), or increase (net for the baselines. Chapter 8 of the NOPR foot MiniBP SO product class, 4-foot cost) relative to the base-case forecast. TSD provides a detailed description of MiniBP HO product class, 8-foot SP When an EL results in ‘‘positive LCC the LCC and PBP analysis and the slimline product class, and 8-foot RDC savings,’’ the LCC of the lamp or lamp- results. Appendix 8B of the NOPR TSD HO product class. For GSFLs, results for and-ballast system is less than the LCC presents Monte Carlo simulation results the most common sector for each of the baseline lamp or lamp-and-ballast performed by DOE as part of the LCC product class are presented. Chapter 8 system, and the consumer benefits analysis and also presents sensitivity of the NOPR TSD provides the LCC and economically. When an EL results in results, such as LCC savings under the PBP results for each product class in all ‘‘negative LCC savings,’’ the LCC of the AEO 2013 high-economic-growth and relevant sectors. lamp or lamp-and-ballast system is low-economic-growth cases. TABLE VII.3—LCC AND PBP RESULTS FOR A 2-LAMP 4-FOOT 32 W T8 MEDIUM BIPIN INSTANT START SYSTEM OPERATING IN THE COMMERCIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Baseline .... Baseline ..... 89.2 32.5 W T8 & 0.88 BF 17.19 116.96 134.33 N/A N/A N/A N/A Lamp Inst. Failure. Lamp Re- EL 1 ...... 90.0 32.5 W T8 & 0.88 BF 33.38 116.96 138.62 ¥4.29 100 0 NER place- EL 2 ...... 93.0 Inst. 29.79 98.00 127.98 6.36 0.1 99.9 3.2 ment. EL 2 ...... 95.4 26.6 W T8 & 0.88 BF 26.73 116.96 143.88 ¥9.55 100 0 NER EL 2 ...... 96.0 Inst. 23.99 105.12 129.29 5.04 0 100 2.8 32.5 W T8 & 0.88 BF Inst. 28.4 W T8 & 0.88 BF Inst. Event II: Baseline .... Baseline ..... 89.2 32.5 W T8 & 0.88 BF 59.99 115.47 158.74 N/A N/A N/A N/A Ballast Inst. Failure. Lamp & EL 1 ...... 90.0 32.5 W T8 & 0.78 BF 76.18 103.28 150.84 7.90 0 100 0.4 Ballast EL 2 ...... 93.0 Inst. 72.59 96.70 152.58 6.17 0.1 99.9 3.3 Replace- EL 2 ...... 95.4 26.6 W T8 & 0.88 BF 69.53 101.06 153.88 4.87 0.1 99.9 3.2 ment. EL 2 ...... 96.0 Inst. 66.79 101.96 152.03 6.72 0 100 2.4 32.5 W T8 & 0.77 BF Inst. 28.4 W T8 & 0.87 BF Inst. Event III: Baseline .... Baseline ..... 89.2 32.5 W T8 & 0.88 BF 62.78 115.47 160.44 N/A N/A N/A N/A New Inst. Construc- tion and Renova- tion. New Lamp EL 1 ...... 90.0 32.5 W T8 & 0.78 BF 78.97 103.28 152.53 7.90 0 100 0.4 & Ballast EL 2 ...... 93.0 Inst. 75.39 96.70 154.27 6.17 0.1 99.9 3.3 Purchase. EL 2 ...... 95.4 26.6 W T8 & 0.88 BF 72.33 101.06 155.57 4.87 0.1 99.9 3.2 EL 2 ...... 96.0 Inst. 69.58 101.96 153.72 6.72 0 100 2.4 32.5 W T8 & 0.77 BF Inst. 28.4 W T8 & 0.87 BF Inst.

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TABLE VII.4—LCC AND PBP RESULTS FOR A 2-LAMP 4-FOOT 32 W T8 MEDIUM BIPIN PROGRAMMED START SYSTEM OPERATING IN THE COMMERCIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Baseline .... Baseline ..... 89.2 32.5 W T8 & 0.88 BF 17.19 178.88 196.22 N/A N/A N/A N/A Lamp Prog. Failure. Lamp Re- EL 1 ...... 90.0 32.5 W T8 & 0.88 BF 31.26 178.88 202.33 ¥6.11 100.0 0.0 NER place- EL 2 ...... 93.0 Prog. 29.79 150.18 180.13 16.09 0.0 100.0 3.3 ment. EL 2 ...... 95.4 26.6 W T8 & 0.88 BF 26.73 178.88 205.77 ¥9.55 100.0 0.0 NER EL 2 ...... 96.0 Prog. 23.99 160.96 185.10 11.12 0.0 100.0 2.8 32.5 W T8 & 0.88 BF Prog. 28.4 W T8 & 0.88 BF Prog. Event II: Baseline .... Baseline ..... 89.2 32.5 W T8 & 0.88 BF 61.19 178.88 234.11 N/A N/A N/A N/A Ballast Prog. Failure. Lamp & EL 1 ...... 90.0 32.5 W T8 & 0.88 BF 75.27 178.88 240.22 ¥6.11 100.0 0.0 NER Ballast EL 1 ...... 90.0 Prog. 75.27 150.40 211.74 22.37 0.0 100.0 0.3 Replace- EL 2 ...... 93.0 32.5 W T8 & 0.72 BF 73.80 150.18 218.02 16.09 0.0 100.0 3.3 ment. EL 2 ...... 95.4 Prog. 70.74 178.88 243.66 ¥9.55 100.0 0.0 NER EL 2 ...... 95.4 26.6 W T8 & 0.88 BF 70.74 150.40 215.18 18.93 0.0 100.0 2.5 EL 2 ...... 96.0 Prog. 67.99 160.96 222.99 11.12 0.0 100.0 2.8 32.5 W T8 & 0.88 BF Prog. 32.5 W T8 & 0.72 BF Prog. 28.4 W T8 & 0.88 BF Prog. Event III: Baseline .... Baseline ..... 89.2 32.5 W T8 & 0.88 BF 63.98 178.88 236.52 N/A N/A N/A N/A New Prog. Construc- tion and Renova- tion. New Lamp EL 1 ...... 90.0 32.5 W T8 & 0.88 BF 78.06 178.88 242.63 ¥6.11 100.0 0.0 NER & Ballast EL 1 ...... 90.0 Prog. 78.06 150.40 214.15 22.37 0.0 100.0 0.3 Purchase. EL 2 ...... 93.0 32.5 W T8 & 0.72 BF 76.59 150.18 220.43 16.09 0.0 100.0 3.3 EL 2 ...... 95.4 Prog. 73.53 178.88 246.06 ¥9.55 100.0 0.0 NER EL 2 ...... 95.4 26.6 W T8 & 0.88 BF 73.53 150.40 217.59 18.93 0.0 100.0 2.5 EL 2 ...... 96.0 Prog. 70.79 160.96 225.40 11.12 0.0 100.0 2.8 32.5 W T8 & 0.88 BF Prog. 32.5 W T8 & 0.72 BF Prog. 28.4 W T8 & 0.88 BF Prog.

TABLE VII.5—LCC AND PBP RESULTS FOR A 4-LAMP 4-FOOT 32 W T8 MEDIUM BIPIN INSTANT START SYSTEM OPERATING IN THE COMMERCIAL SECTOR

Life-cycle cost Life-Cycle Cost Savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ Savings years 2012$ cost 2012$ Net Ben- 2012$ Net Cost efit

Event I: Baseline ...... Baseline ..... 89.2 32.5 W T8 & 0.87 27.95 225.79 254.11 N/A N/A N/A N/A Lamp Fail- BF Inst. ure. Lamp Re- EL 1 ...... 90.0 32.5 W T8 & 0.87 55.06 225.79 261.52 ¥7.41 100.0 0.0 NER placement. EL 2 ...... 93.0 BF Inst. 53.17 188.99 242.52 11.58 0.2 99.8 3.3 EL 2 ...... 95.4 26.6 W T8 & 0.87 47.05 225.79 273.20 ¥19.10 100.0 0.0 NER EL 2 ...... 96.0 BF Inst. 41.56 202.80 244.72 9.39 0.0 100.0 2.9 32.5 W T8 & 0.87 BF Inst. 28.4 W T8 & 0.87 BF Inst. Event II: Bal- Baseline ...... Baseline ..... 89.2 32.5 W T8 & 0.87 86.30 223.94 287.56 N/A N/A N/A N/A last Failure. BF Inst.

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TABLE VII.5—LCC AND PBP RESULTS FOR A 4-LAMP 4-FOOT 32 W T8 MEDIUM BIPIN INSTANT START SYSTEM OPERATING IN THE COMMERCIAL SECTOR—Continued

Life-cycle cost Life-Cycle Cost Savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ Savings years 2012$ cost 2012$ Net Ben- 2012$ Net Cost efit

Lamp & Bal- EL 1 ...... 90.0 32.5 W T8 & 0.78 113.40 202.45 273.49 14.07 0.0 100.0 0.5 last Re- EL 2 ...... 93.0 BF Inst. 111.51 187.37 276.22 11.35 0.3 99.7 3.3 placement. EL 2 ...... 95.4 26.6 W T8 & 0.87 105.39 195.81 278.53 9.03 0.2 99.8 3.3 EL 2 ...... 96.0 BF Inst. 99.90 201.09 278.32 9.24 0.0 100.0 2.9 32.5 W T8 & 0.74 BF Inst. 28.4 W T8 & 0.87 BF Inst. Event III: Baseline ...... Baseline ..... 89.2 32.5 W T8 & 0.87 89.09 223.94 289.26 N/A N/A N/A N/A New Con- BF Inst. struction and Ren- ovation. New Lamp & EL 1 ...... 90.0 32.5 W T8 & 0.78 116.20 202.45 275.18 14.07 0.0 100.0 0.5 Ballast EL 2 ...... 93.0 BF Inst. 114.31 187.37 277.91 11.35 0.3 99.7 3.3 Purchase. EL 2 ...... 95.4 26.6 W T8 & 0.87 108.19 195.81 280.23 9.03 0.2 99.8 3.3 EL 2 ...... 96.0 BF Inst. 102.70 201.09 280.02 9.24 0.0 100.0 2.9 32.5 W T8 & 0.74 BF Inst. 28.4 W T8 & 0.87 BF Inst.

TABLE VII.6—LCC AND PBP RESULTS FOR A 4-LAMP 4-FOOT 32 W T8 MEDIUM BIPIN PROGRAMMED START SYSTEM OPERATING IN THE COMMERCIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Baseline ...... Baseline ..... 89.2 32.5 W T8 & 0.89 27.95 354.89 383.16 N/A N/A N/A N/A Lamp Fail- BF Prog. ure. Lamp Re- EL 1 ...... 90.0 32.5 W T8 & 0.89 51.55 354.89 393.58 ¥10.42 100.0 0.0 NER placement. EL 2 ...... 93.0 BF Prog. 53.17 297.59 351.07 32.08 0.0 100.0 3.3 EL 2 ...... 95.4 26.6 W T8 & 0.89 47.05 354.89 402.25 ¥19.10 100.0 0.0 NER EL 2 ...... 96.0 BF Prog. 41.56 319.10 360.97 22.19 0.0 100.0 2.8 32.5 W T8 & 0.89 BF Prog. 28.4 W T8 & 0.89 BF Prog. Event II: Bal- Baseline ...... Baseline ..... 89.2 32.5 W T8 & 0.89 88.14 354.89 434.98 N/A N/A N/A N/A last Failure. BF Prog. Lamp & Bal- EL 1 ...... 90.0 32.5 W T8 & 0.87 111.73 339.09 429.60 5.38 0.4 99.6 1.0 last Re- EL 2 ...... 93.0 BF Prog. 113.36 297.59 402.90 32.08 0.0 100.0 3.3 placement. EL 2 ...... 95.4 26.6 W T8 & 0.89 107.24 339.09 438.28 ¥3.29 81.9 18.1 9.0 EL 2 ...... 96.0 BF Prog. 101.75 304.62 398.32 36.66 0.0 100.0 2.0 32.5 W T8 & 0.87 BF Prog. 28.4 W T8 & 0.87 BF Prog. Event III: Baseline ...... Baseline ..... 89.2 32.5 W T8 & 0.89 90.94 354.89 437.39 N/A N/A N/A N/A New Con- BF Prog. struction and Ren- ovation. New Lamp & EL 1 ...... 90.0 32.5 W T8 & 0.87 114.53 339.09 432.01 5.38 0.4 99.6 1.0 Ballast EL 2 ...... 93.0 BF Prog. 116.15 297.59 405.30 32.08 0.0 100.0 3.3 Purchase. EL 2 ...... 95.4 26.6 W T8 & 0.89 110.03 339.09 440.68 ¥3.29 81.9 18.1 9.0 EL 2 ...... 96.0 BF Prog. 104.54 304.62 400.73 36.66 0.0 100.0 2.0 32.5 W T8 & 0.87 BF Prog. 28.4 W T8 & 0.87 BF Prog.

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TABLE VII.7—LCC AND PBP RESULTS FOR A 2-LAMP 4-FOOT 32 W T8 MEDIUM BIPIN INSTANT START SYSTEM OPERATING IN THE RESIDENTIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Baseline ...... Baseline ..... 89.2 32.5 W T8 & 0.87 10.48 46.85 57.34 N/A N/A N/A N/A Lamp Fail- BF Inst. ure. Lamp Re- EL 1 ...... 90.0 32.5 W T8 & 0.87 11.58 46.85 58.43 ¥1.09 100 0 NER placement. EL 2 ...... 93.0 BF Inst. 23.09 39.29 62.38 ¥5.05 94.8 5.2 17.6 EL 2 ...... 95.4 26.6 W T8 & 0.87 20.03 46.85 66.88 ¥9.55 100 0 NER EL 2 ...... 96.0 BF Inst. 17.29 42.13 59.41 ¥2.08 89.8 10.2 15.2 32.5 W T8 & 0.87 BF Inst. 28.4 W T8 & 0.87 BF Inst. Event II: Bal- Baseline ...... Baseline ..... 89.2 32.5 W T8 & 0.87 52.71 46.85 99.56 N/A N/A N/A N/A last Failure. BF Inst. Lamp & Bal- EL 1 ...... 90.0 32.5 W T8 & 0.83 53.80 44.48 98.28 1.28 1.1 98.9 4.9 last Re- EL 2 ...... 93.0 BF Inst. 65.32 39.29 104.61 ¥5.05 94.8 5.2 17.6 placement. EL 2 ...... 95.4 26.6 W T8 & 0.87 62.26 44.48 106.73 ¥7.17 100 0 42.5 EL 2 ...... 96.0 BF Inst. 59.51 39.99 99.50 0.06 49 51 10.5 32.5 W T8 & 0.83 BF Inst. 28.4 W T8 & 0.83 BF Inst. Event III: Baseline ...... Baseline ..... 89.2 32.5 W T8 & 0.87 55.51 46.85 102.36 N/A N/A N/A N/A New Con- BF Inst. struction and Ren- ovation. New Lamp & EL 1 ...... 90.0 32.5 W T8 & 0.83 56.60 44.48 101.08 1.28 1.1 98.9 4.9 Ballast EL 2 ...... 93.0 BF Inst. 68.11 39.29 107.40 ¥5.05 94.8 5.2 17.6 Purchase. EL 2 ...... 95.4 26.6 W T8 & 0.87 65.05 44.48 109.53 ¥7.17 100 0 42.5 EL 2 ...... 96.0 BF Inst. 62.31 39.99 102.30 0.06 49 51 10.5 32.5 W T8 & 0.83 BF Inst. 28.4 W T8 & 0.83 BF Inst.

TABLE VII.8—LCC AND PBP RESULTS FOR A TWO-LAMP 4-FOOT 54 W T5 MINIATURE BIPIN HIGH OUTPUT SYSTEM OPERATING IN THE INDUSTRIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Baseline .... Baseline ... 83.6 53.8 W T5 & 1 BF Prog 18.58 181.10 199.85 N/A N/A N/A N/A Lamp Failure. Lamp Re- EL 1 ...... 92.9 53.8 W T5 & 1 BF Prog 26.60 181.10 207.87 ¥8.02 100.0 0.0 NER place- EL 1 ...... 102.0 49 W T5 & 1 BF Prog .. 32.52 165.38 191.12 8.73 0.0 100.0 3.9 ment. EL 1 ...... 102.1 47 W T5 & 1 BF Prog .. 35.43 158.83 190.02 9.83 0.0 100.0 3.3 Event II: Baseline .... Baseline ... 83.6 53.8 W T5 & 1 BF Prog 72.69 181.10 233.62 N/A N/A N/A N/A Ballast Failure. Lamp & EL 1 ...... 92.9 53.8 W T5 & 1 BF Prog 80.72 181.10 241.65 ¥8.02 100.0 0.0 NER Ballast EL 1 ...... 102.0 49 W T5 & 1 BF Prog .. 86.64 165.38 224.89 8.73 0.0 100.0 3.9 Replace- EL 1 ...... 102.1 47 W T5 & 1 BF Prog .. 89.55 158.83 223.79 9.83 0.0 100.0 3.3 ment. Event III: Baseline .... Baseline ... 83.6 53.8 W T5 & 1 BF Prog 75.49 181.10 235.37 N/A N/A N/A N/A New Con- struction and Ren- ovation. New Lamp EL 1 ...... 92.9 53.8 W T5 & 1 BF Prog 83.51 181.10 243.39 ¥8.02 100.0 0.0 NER & Ballast EL 1 ...... 102.0 49 W T5 & 1 BF Prog .. 89.43 165.38 226.64 8.73 0.0 100.0 3.9 Purchase. EL 1 ...... 102.1 47 W T5 & 1 BF Prog .. 92.35 158.83 225.54 9.83 0.0 100.0 3.3

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TABLE VII.9—LCC AND PBP RESULTS FOR A TWO-LAMP 4-FOOT 28 W T5 MINIATURE BIPIN STANDARD OUTPUT SYSTEM OPERATING IN THE COMMERCIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Baseline ...... Baseline ..... 94.6 27.8 W T5 & 1 BF 15.30 152.84 168.31 N/A N/A N/A N/A Lamp Fail- Prog. ure. Lamp Re- EL 1 ...... 104.3 27.8 W T5 & 1 BF 19.17 152.84 172.18 ¥3.87 100.0 0.0 NER placement. EL 2 ...... 109.7 Prog. 21.52 152.84 174.54 ¥6.22 100.0 0.0 NER EL 2 ...... 111.5 27.8 W T5 & 1 BF 24.67 143.23 168.07 0.25 57.9 42.1 5.7 EL 2 ...... 116.0 Prog. 27.41 137.88 162.64 5.68 0.2 99.8 4.8 26 W T5 & 1 BF Prog. 25 W T5 & 1 BF Prog. Event II: Bal- Baseline ...... Baseline ..... 94.6 27.8 W T5 & 1 BF 68.19 152.84 205.74 N/A N/A N/A N/A last Failure. Prog. Lamp & Bal- EL 1 ...... 104.3 27.8 W T5 & 0.85 72.06 134.13 190.90 14.84 0.0 100.0 1.2 last Re- EL 2 ...... 109.7 BF Prog. 74.41 134.13 193.25 12.49 0.0 100.0 2.0 placement. EL 2 ...... 111.5 27.8 W T5 & 0.85 77.56 125.79 188.05 17.69 0.0 100.0 2.0 EL 2 ...... 116.0 BF Prog. 80.30 121.15 183.32 22.42 0.0 100.0 2.2 26 W T5 & 0.85 BF Prog. 25 W T5 & 0.85 BF Prog. Event III: Baseline ...... Baseline ..... 94.6 27.8 W T5 & 1 BF 70.99 152.84 207.72 N/A N/A N/A N/A New Con- Prog. struction and Ren- ovation. New Lamp & EL 1 ...... 104.3 27.8 W T5 & 0.85 74.86 134.13 192.88 14.84 0.0 100.0 1.2 Ballast EL 2 ...... 109.7 BF Prog. 77.21 134.13 195.23 12.49 0.0 100.0 2.0 Purchase. EL 2 ...... 111.5 27.8 W T5 & 0.85 80.35 125.79 190.03 17.69 0.0 100.0 2.0 EL 2 ...... 116.0 BF Prog. 83.10 121.15 185.30 22.42 0.0 100.0 2.2 26 W T5 & 0.85 BF Prog. 25 W T5 & 0.85 BF Prog.

TABLE VII.10—LCC AND PBP RESULTS FOR A TWO-LAMP 8-FOOT 59 W T8 SINGLE PIN SLIMLINE SYSTEM OPERATING IN THE COMMERCIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Baseline .... Baseline ..... 96.5 60.1 W T8 & 0.87 BF 26.72 219.51 246.59 N/A N/A N/A N/A Lamp Inst. Failure. Lamp Re- EL 1 ...... 98.2 60.1 W T8 & 0.87 BF 29.40 219.51 249.27 ¥2.68 100.0 0.0 NER place- EL 2 ...... 99.0 Inst. 34.52 219.51 254.39 ¥7.80 100.0 0.0 NER ment. EL 2 ...... 105.6 60.1 W T8 & 0.87 BF 43.51 208.16 252.02 ¥5.43 96.1 3.9 7.1 EL 2 ...... 108.0 Inst. 50.87 193.01 244.23 2.36 44.6 55.4 4.3 54 W T8 & 0.87 BF Inst. 50 W T8 & 0.87 BF Inst. Event II: Baseline .... Baseline ..... 96.5 60.1 W T8 & 0.87 BF 102.46 216.15 288.57 N/A N/A N/A N/A Ballast Inst. Failure. Lamp & EL 1 ...... 98.2 60.1 W T8 & 0.77 BF 105.14 193.01 268.11 20.46 0.0 100.0 0.6 Ballast EL 2 ...... 99.0 Inst. 110.25 193.01 273.23 15.34 0.0 100.0 1.6 Replace- EL 2 ...... 105.6 60.1 W T8 & 0.77 BF 119.24 183.01 272.22 16.35 0.0 100.0 2.4 ment. EL 2 ...... 108.0 Inst. 126.60 189.96 286.53 2.05 47.6 52.4 4.4 54 W T8 & 0.77 BF Inst. 50 W T8 & 0.87 BF Inst.

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TABLE VII.10—LCC AND PBP RESULTS FOR A TWO-LAMP 8-FOOT 59 W T8 SINGLE PIN SLIMLINE SYSTEM OPERATING IN THE COMMERCIAL SECTOR—Continued

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event III: Baseline .... Baseline ..... 96.5 60.1 W T8 & 0.87 BF 105.25 216.15 290.24 N/A N/A N/A N/A New Inst. Construc- tion and Renova- tion. New Lamp EL 1 ...... 98.2 60.1 W T8 & 0.77 BF 107.93 193.01 269.78 20.46 0.0 100.0 0.6 & Ballast EL 2 ...... 99.0 Inst. 113.05 193.01 274.90 15.34 0.0 100.0 1.6 Purchase. EL 2 ...... 105.6 60.1 W T8 & 0.77 BF 122.04 183.01 273.89 16.35 0.0 100.0 2.4 EL 2 ...... 108.0 Inst. 129.40 189.96 288.20 2.05 47.6 52.4 4.4 54 W T8 & 0.77 BF Inst. 50 W T8 & 0.87 BF Inst.

TABLE VII.11—LCC AND PBP RESULTS FOR A TWO-LAMP 8-FOOT 86 W T8 RECESSED DOUBLE CONTACT HO SYSTEM OPERATING IN THE INDUSTRIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Baseline ...... Baseline ..... 92.0 84 W T8 & 0.81 BF 24.45 171.55 196.38 N/A N/A N/A N/A Lamp Inst. Failure. Lamp Re- EL 1 ...... 95.2 84 W T8 & 0.81 BF 34.01 171.55 205.94 ¥9.56 100.0 0.0 NER placement. EL 2 ...... 97.6 Inst. 41.22 171.55 213.15 ¥16.77 100.0 0.0 NER 84 W T8 & 0.81 BF Inst. Event II: Baseline ...... Baseline ..... 92.0 84 W T8 & 0.81 BF 100.34 171.55 233.59 N/A N/A N/A N/A Ballast Inst. Failure. Lamp & Bal- EL 1 ...... 95.2 84 W T8 & 0.81 BF 109.90 171.55 243.15 ¥9.56 100.0 0.0 NER last Re- EL 2 ...... 97.6 Inst. 117.11 171.55 250.36 ¥16.77 100.0 0.0 NER placement. 84 W T8 & 0.81 BF Inst. Event III: Baseline ...... Baseline ..... 92.0 84 W T8 & 0.81 BF 103.14 171.55 234.96 N/A N/A N/A N/A New Inst. Con- struction and Renova- tion. New Lamp & EL 1 ...... 95.2 84 W T8 & 0.81 BF 112.70 171.55 244.52 ¥9.56 100.0 0.0 NER Ballast Pur- EL 2 ...... 97.6 Inst. 119.91 171.55 251.73 ¥16.77 100.0 0.0 NER chase. 84 W T8 & 0.81 BF Inst.

Incandescent Reflector Lamps sector LCC results for the IRL greater than 2.5 inches, input voltages Table VII.12 through Table VII.15 representative product class, the less than 125 V. present the commercial and residential standard spectrum IRLs with diameters

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TABLE VII.12—LCC AND PBP RESULTS FOR A 55 W PAR38 2,500 HOUR HIR EL 1 REPRESENTATIVE LAMP OPERATING IN THE COMMERCIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- onsumers that payback Event Response level efficacy Lamp option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Baseline ...... Baseline ..... 17.8 60W, 1500hrs, Im- 10.52 9.06 19.58 N/A N/A N/A N/A Lamp Fail- proved Halogen. ure; or Event III: New Con- struction and Ren- ovation. Lamp Re- EL 1 ...... 18.5 55W, 2500hrs, HIR 13.07 8.30 16.14 3.44 0.0 100.0 3.2 placement or New Lamp Pur- chase.

TABLE VII.13—LCC AND PBP RESULTS FOR A 55 W PAR38 2,500 HOUR HIR EL 1 REPRESENTATIVE LAMP OPERATING IN THE RESIDENTIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- onsumers that payback Event Response level efficacy Lamp option Installed counted LCC LCC experience period lm/W cost operating 2012$ avings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Baseline ...... Baseline ..... 17.8 60W, 1500hrs, Im- 9.40 10.36 19.75 N/A N/A N/A N/A Lamp Fail- proved Halogen. ure; or Event III: New Con- struction and Ren- ovation. Lamp Re- EL 1 ...... 18.5 55W, 2500hrs, HIR 11.94 9.49 17.10 2.65 0.0 100.0 5.4 placement or New Lamp Pur- chase.

TABLE VII.14—LCC AND PBP RESULTS FOR A 55 W PAR38 4,200 HOUR IMPROVED HIR EL 1 REPRESENTATIVE LAMP OPERATING IN THE COMMERCIAL SECTOR

Life-cycle cost Life-cycle cost savings

Rated Percentage of Mean Dis- consumers that payback Event Response Efficacy lamp Lamp option Installed counted LCC level efficacy cost operating LCC savings experience period lm/W 2012$ years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Lamp Baseline ...... Baseline ..... 17.8 60W, 1500hrs, 10.52 9.06 19.58 N/A N/A N/A N/A Failure; or Improved Event III: Halogen. New Con- struction and Renovation. Lamp Replace- EL 1 ...... 18.5 55W, 4200hrs, 14.94 8.30 13.64 5.94 0 100 5.6 ment or New Improved Lamp Pur- HIR. chase.

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TABLE VII.15—LCC AND PBP RESULTS FOR A 55 W PAR38 4,200 HOUR IMPROVED HIR EL 1 REPRESENTATIVE LAMP OPERATING IN THE RESIDENTIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Lamp option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Lamp Baseline ...... Baseline ..... 17.8 60W, 1500hrs, 9.40 10.36 19.75 N/A N/A N/A N/A Failure; or Improved Event III: Halogen. New Con- struction and Renovation. Lamp Replace- EL 1 ...... 18.5 55W, 4200hrs, 13.81 9.49 15.26 4.49 0 100 9.4 ment or New Improved Lamp Pur- HIR. chase.

b. Consumer Subgroup Analysis particular inputs to the LCC model. For LCC and PBP analysis to be minimal. low-income consumers, DOE only used See chapter 9 of the NOPR TSD further Certain consumer subgroups may be RECS data for consumers living below details of the consumer subgroup disproportionately affected by the poverty line. For institutions serving analysis. standards. Using the LCC spreadsheet low-income populations, DOE assumed General Service Fluorescent Lamps model, DOE determined the impact of that the majority of these institutions are the TSLs on the following consumer small nonprofits, and used a higher Table VII.16 through Table VII.24 subgroups: low-income consumers and discount rate of 9.6 percent (versus 5.1 below show the LCC impacts and institutions that serve low-income percent for the main commercial sector payback periods for the identified populations. analysis). DOE found the differences subgroups for GSFLs. Entries of ‘‘NER’’ To reflect conditions faced by the between the LCC and PBP results for the indicate standard levels that do not identified subgroups, DOE adjusted subgroups analyzed and the primary reduce operating costs. TABLE VII.16—LCC AND PBP SUBGROUP RESULTS FOR INSTITUTIONS SERVING LOW INCOME POPULATIONS FOR A 2- LAMP 4-FOOT 32 W T8 MEDIUM BIPIN INSTANT START SYSTEM OPERATING IN THE COMMERCIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Baseline ...... Baseline ..... 89.2 32.5 W T8 & 0.88 17.19 102.28 119.60 N/A N/A N/A N/A Lamp Fail- BF Inst. ure. Lamp Re- EL 1 ...... 90.0 32.5 W T8 & 0.88 31.03 102.28 124.21 ¥4.61 100 0 NER placement. EL 2 ...... 93.0 BF Inst. 29.79 85.69 115.63 3.97 4.2 95.8 3.2 EL 2 ...... 95.4 26.6 W T8 & 0.88 26.73 102.28 129.15 ¥9.55 100 0 NER EL 2 ...... 96.0 BF Inst. 23.99 91.92 116.05 3.56 0 100 2.8 32.5 W T8 & 0.88 BF Inst. 28.4 W T8 & 0.88 BF Inst. Event II: Bal- Baseline ...... Baseline ..... 89.2 32.5 W T8 & 0.88 59.99 100.97 147.99 N/A N/A N/A N/A last Failure. BF Inst. Lamp & Bal- EL 1 ...... 90.0 32.5 W T8 & 0.78 73.83 90.31 141.93 6.05 0 100 0.4 last Re- EL 2 ...... 93.0 BF Inst. 72.59 84.55 144.18 3.81 6.6 93.4 3.3 placement. EL 2 ...... 95.4 26.6 W T8 & 0.88 69.53 88.37 144.93 3.06 3.6 96.4 3.2 EL 2 ...... 96.0 BF Inst. 66.79 89.15 142.97 5.02 0 100 2.4 32.5 W T8 & 0.77 BF Inst. 28.4 W T8 & 0.87 BF Inst. Event III: Baseline ...... Baseline ..... 89.2 32.5 W T8 & 0.88 62.78 100.97 149.93 N/A N/A N/A N/A New Con- BF Inst. struction and Ren- ovation.

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TABLE VII.16—LCC AND PBP SUBGROUP RESULTS FOR INSTITUTIONS SERVING LOW INCOME POPULATIONS FOR A 2- LAMP 4-FOOT 32 W T8 MEDIUM BIPIN INSTANT START SYSTEM OPERATING IN THE COMMERCIAL SECTOR—Continued

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

New Lamp & EL 1 ...... 90.0 32.5 W T8 & 0.78 76.62 90.31 143.87 6.05 0 100 0.4 Ballast EL 2 ...... 93.0 BF Inst. 75.39 84.55 146.12 3.81 6.6 93.4 3.3 Purchase. EL 2 ...... 95.4 26.6 W T8 & 0.88 72.33 88.37 146.87 3.06 3.6 96.4 3.2 EL 2 ...... 96.0 BF Inst. 69.58 89.15 144.91 5.02 0 100 2.4 32.5 W T8 & 0.77 BF Inst. 28.4 W T8 & 0.87 BF Inst.

TABLE VII.17—LCC AND PBP SUBGROUP RESULTS FOR INSTITUTIONS SERVING LOW INCOME POPULATIONS FOR A 2- LAMP 4-FOOT 32 W T8 MEDIUM BIPIN PROGRAMMED START SYSTEM OPERATING IN THE COMMERCIAL SECTOR

Life-cycle cost Life-cycle cost savings

Rated Percentage of Mean Dis- consumers that payback Event Response Efficacy lamp Design option Installed counted LCC level efficacy cost operating LCC savings experience period lm/W 2012$ years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Lamp Baseline ...... Baseline ..... 89.2 32.5 W T8 & 17.19 146.45 163.74 N/A N/A N/A N/A Failure. 0.88 BF Prog. Lamp Re- EL 1 ...... 90.0 32.5 W T8 & 27.94 146.45 169.05 ¥5.31 100.0 0.0 NER placement. 0.88 BF Prog. EL 2 ...... 93.0 26.6 W T8 & 29.79 122.95 152.85 10.89 0.0 100.0 3.3 0.88 BF Prog. EL 2 ...... 95.4 32.5 W T8 & 26.73 146.45 173.29 ¥9.55 100.0 0.0 NER 0.88 BF Prog. EL 2 ...... 96.0 28.4 W T8 & 23.99 131.77 155.87 7.87 0.0 100.0 2.8 0.88 BF Prog. Event II: Bal- Baseline ...... Baseline ..... 89.2 32.5 W T8 & 61.19 146.45 203.56 N/A N/A N/A N/A last Failure. 0.88 BF Prog. Lamp & Bal- EL 1 ...... 90.0 32.5 W T8 & 71.94 146.45 208.87 ¥5.31 100.0 0.0 NER last Re- 0.88 BF Prog. placement. EL 1 ...... 90.0 32.5 W T8 & 71.94 123.13 185.56 18.01 0.0 100.0 0.3 0.72 BF Prog. EL 2 ...... 93.0 26.6 W T8 & 73.80 122.95 192.68 10.89 0.0 100.0 3.3 0.88 BF Prog. EL 2 ...... 95.4 32.5 W T8 & 70.74 146.45 213.11 ¥9.55 100.0 0.0 NER 0.88 BF Prog. EL 2 ...... 95.4 32.5 W T8 & 70.74 123.13 189.80 13.77 0.0 100.0 2.5 0.72 BF Prog. EL 2 ...... 96.0 28.4 W T8 & 67.99 131.77 195.69 7.87 0.0 100.0 2.8 0.88 BF Prog. Event III: New Baseline ...... Baseline ..... 89.2 32.5 W T8 & 63.98 146.45 206.09 N/A N/A N/A N/A Construction 0.88 BF Prog. and Ren- ovation. New Lamp & EL 1 ...... 90.0 32.5 W T8 & 74.73 146.45 211.40 ¥5.31 100.0 0.0 NER Ballast Pur- 0.88 BF Prog. chase. EL 1 ...... 90.0 32.5 W T8 & 74.73 123.13 188.09 18.01 0.0 100.0 0.3 0.72 BF Prog. EL 2 ...... 93.0 26.6 W T8 & 76.59 122.95 195.21 10.89 0.0 100.0 3.3 0.88 BF Prog. EL 2 ...... 95.4 32.5 W T8 & 73.53 146.45 215.64 ¥9.55 100.0 0.0 NER 0.88 BF Prog. EL 2 ...... 95.4 32.5 W T8 & 73.53 123.13 192.33 13.77 0.0 100.0 2.5 0.72 BF Prog. EL 2 ...... 96.0 28.4 W T8 & 70.79 131.77 198.22 7.87 0.0 100.0 2.8 0.88 BF Prog.

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TABLE VII.18—LCC AND PBP SUBGROUP RESULTS FOR INSTITUTIONS SERVING LOW INCOME POPULATIONS FOR A 4- LAMP 4-FOOT 32 W T8 MEDIUM BIPIN INSTANT START SYSTEM OPERATING IN THE COMMERCIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Lamp Baseline ...... Baseline ..... 89.2 32.5 W T8 & 27.95 197.44 225.67 N/A N/A N/A N/A Failure. 0.87 BF Inst. Lamp Re- EL 1 ...... 90.0 32.5 W T8 & 51.18 197.44 233.62 ¥7.95 100.0 0.0 NER placement. 0.87 BF Inst. EL 2 ...... 93.0 26.6 W T8 & 53.17 165.26 218.70 6.96 8.8 91.2 3.3 0.87 BF Inst. EL 3 ...... 95.4 32.5 W T8 & 47.05 197.44 244.76 ¥19.10 100.0 0.0 NER 0.87 BF Inst. EL 2 ...... 96.0 28.4 W T8 & 41.56 177.33 219.17 6.50 0.1 99.9 2.9 0.87 BF Inst. Event II: Bal- Baseline ...... Baseline ..... 89.2 32.5 W T8 & 86.30 195.81 264.52 N/A N/A N/A N/A last Failure. 0.87 BF Inst. Lamp & Bal- EL 1 ...... 90.0 32.5 W T8 & 109.52 177.03 253.68 10.84 0.0 100.0 0.5 last Re- 0.78 BF Inst. placement. EL 2 ...... 93.0 26.6 W T8 & 111.51 163.84 257.76 6.76 9.4 90.6 3.3 0.87 BF Inst. EL 2 ...... 95.4 32.5 W T8 & 105.39 171.22 259.02 5.50 7.9 92.1 3.3 0.74 BF Inst. EL 2 ...... 96.0 28.4 W T8 & 99.90 175.84 258.15 6.37 0.2 99.8 2.9 0.87 BF Inst. Event III: New Baseline ...... Baseline ..... 89.2 32.5 W T8 & 89.09 195.81 266.46 N/A N/A N/A N/A Construction 0.87 BF Inst. and Ren- ovation. New Lamp & EL 1 ...... 90.0 32.5 W T8 & 112.32 177.03 255.62 10.84 0.0 100.0 0.5 Ballast Pur- 0.78 BF Inst. chase. EL 2 ...... 93.0 26.6 W T8 & 114.31 163.84 259.70 6.76 9.4 90.6 3.3 0.87 BF Inst. EL 2 ...... 95.4 32.5 W T8 & 108.19 171.22 260.96 5.50 7.9 92.1 3.3 0.74 BF Inst. EL 2 ...... 96.0 28.4 W T8 & 102.70 175.84 260.09 6.37 0.2 99.8 2.9 0.87 BF Inst.

TABLE VII.19—LCC AND PBP SUBGROUP RESULTS FOR INSTITUTIONS SERVING LOW INCOME POPULATIONS FOR A 4- LAMP 4-FOOT 32 W T8 MEDIUM BIPIN PROGRAMMED START SYSTEM OPERATING IN THE COMMERCIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Lamp Baseline ...... Baseline ..... 89.2 32.5 W T8 & 27.95 290.55 318.71 N/A N/A N/A N/A Failure. 0.89 BF Prog. Lamp Re- EL 1 ...... 90.0 32.5 W T8 & 46.06 290.55 327.82 ¥9.11 100.0 0.0 NER placement. 0.89 BF Prog. EL 2 ...... 93.0 26.6 W T8 & 53.17 243.64 297.02 21.70 0.0 100.0 3.3 0.89 BF Prog. EL 2 ...... 95.4 32.5 W T8 & 47.05 290.55 337.81 ¥19.10 100.0 0.0 NER 0.89 BF Prog. EL 2 ...... 96.0 28.4 W T8 & 41.56 261.25 303.02 15.70 0.0 100.0 2.8 0.89 BF Prog. Event II: Bal- Baseline ...... Baseline ..... 89.2 32.5 W T8 & 88.14 290.55 373.19 N/A N/A N/A N/A last Failure. 0.89 BF Prog. Lamp & Bal- EL 1 ...... 90.0 32.5 W T8 & 106.25 277.61 369.36 3.83 4.6 95.4 1.0 last Re- 0.87 BF Prog. placement. EL 2 ...... 93.0 26.6 W T8 & 113.36 243.64 351.49 21.70 0.0 100.0 3.3 0.89 BF Prog. EL 2 ...... 95.4 32.5 W T8 & 107.24 277.61 379.35 ¥6.16 96.0 4.0 9.0 0.87 BF Prog. EL 2 ...... 96.0 28.4 W T8 & 101.75 249.39 345.64 27.55 0.0 100.0 2.0 0.87 BF Prog. Event III: New Baseline ...... Baseline ..... 89.2 32.5 W T8 & 90.94 290.55 375.72 N/A N/A N/A N/A Construction 0.89 BF Prog. and Ren- ovation.

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TABLE VII.19—LCC AND PBP SUBGROUP RESULTS FOR INSTITUTIONS SERVING LOW INCOME POPULATIONS FOR A 4- LAMP 4-FOOT 32 W T8 MEDIUM BIPIN PROGRAMMED START SYSTEM OPERATING IN THE COMMERCIAL SECTOR— Continued

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

New Lamp & EL 1 ...... 90.0 32.5 W T8 & 109.04 277.61 371.89 3.83 4.6 95.4 1.0 Ballast Pur- 0.87 BF Prog. chase. EL 2 ...... 93.0 26.6 W T8 & 116.15 243.64 354.02 21.70 0.0 100.0 3.3 0.89 BF Prog. EL 2 ...... 95.4 32.5 W T8 & 110.03 277.61 381.88 ¥6.16 96.0 4.0 9.0 0.87 BF Prog. EL 2 ...... 96.0 28.4 W T8 & 104.54 249.39 348.17 27.55 0.0 100.0 2.0 0.87 BF Prog.

TABLE VII.20—LCC AND PBP SUBGROUP RESULTS FOR LOW-INCOME CONSUMERS FOR A 2-LAMP 4-FOOT 32 W T8 MEDIUM BIPIN INSTANT START SYSTEM OPERATING IN THE RESIDENTIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Baseline .... Baseline ..... 89.2 32.5 W T8 & 0.87 BF 10.49 46.83 57.32 N/A N/A N/A N/A Lamp Inst. Failure. Lamp Re- EL 1 ...... 90.0 32.5 W T8 & 0.87 BF 11.59 46.83 58.42 ¥1.09 100 0 NER place- Inst. ment. EL 2 ...... 93.0 26.6 W T8 & 0.87 BF 23.11 39.27 62.38 ¥5.06 94.9 5.1 17.6 Inst. EL 2 ...... 95.4 32.5 W T8 & 0.87 BF 20.05 46.83 66.88 ¥9.56 100 0 NER Inst. EL 2 ...... 96.0 28.4 W T8 & 0.87 BF 17.30 42.11 59.41 ¥2.09 90.3 9.7 15.2 Inst. Event II: Baseline .... Baseline ..... 89.2 32.5 W T8 & 0.87 BF 52.73 46.83 99.56 N/A N/A N/A N/A Ballast Inst. Failure. Lamp & EL 1 ...... 90.0 32.5 W T8 & 0.83 BF 53.82 44.45 98.28 1.28 1.1 98.9 4.9 Ballast Inst. Replace- ment. EL 2 ...... 93.0 26.6 W T8 & 0.87 BF 65.35 39.27 104.62 ¥5.06 94.9 5.1 17.6 Inst. EL 2 ...... 95.4 32.5 W T8 & 0.83 BF 62.29 44.45 106.74 ¥7.18 100 0 42.5 Inst. EL 2 ...... 96.0 28.4 W T8 & 0.83 BF 59.54 39.97 99.51 0.05 49.9 50.1 10.5 Inst. Event III: Baseline .... Baseline ..... 89.2 32.5 W T8 & 0.87 BF 55.53 46.83 102.35 N/A N/A N/A N/A New Inst. Construc- tion and Renova- tion. New Lamp EL 1 ...... 90.0 32.5 W T8 & 0.83 BF 56.62 44.45 101.07 1.28 1.1 98.9 4.9 & Ballast Inst. Purchase. EL 2 ...... 93.0 26.6 W T8 & 0.87 BF 68.14 39.27 107.41 ¥5.06 94.9 5.1 17.6 Inst. EL 2 ...... 95.4 32.5 W T8 & 0.83 BF 65.08 44.45 109.54 ¥7.18 100 0 42.5 Inst. EL 2 ...... 96.0 28.4 W T8 & 0.83 BF 62.33 39.97 102.30 0.05 49.9 50.1 10.5 Inst.

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TABLE VII.21—LCC AND PBP SUBGROUP RESULTS FOR INSTITUTIONS SERVING LOW INCOME POPULATIONS FOR A TWO- LAMP 4-FOOT 54 W T5 MINIATURE BIPIN HIGH OUTPUT SYSTEM OPERATING IN THE COMMERCIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Lamp Baseline ...... Baseline ..... 83.6 53.8 W T5 & 1 18.57 219.84 238.55 N/A N/A N/A N/A Failure. BF Prog. Lamp Re- EL 1 ...... 92.9 53.8 W T5 & 1 26.59 219.84 246.57 ¥8.02 100.0 0.0 NER placement. BF Prog. EL 1 ...... 102.0 49 W T5 & 1 BF 32.51 200.77 227.96 10.60 0.0 100.0 3.2 Prog. EL 1 ...... 102.1 47 W T5 & 1 BF 35.42 192.81 224.90 13.65 0.0 100.0 2.7 Prog. Event II: Bal- Baseline ...... Baseline ..... 83.6 53.8 W T5 & 1 72.68 219.84 276.70 N/A N/A N/A N/A last Failure. BF Prog. Lamp & Bal- EL 1 ...... 92.9 53.8 W T5 & 1 80.70 219.84 284.72 ¥8.02 100.0 0.0 NER last Re- BF Prog. placement. EL 1 ...... 102.0 49 W T5 & 1 BF 86.62 200.77 266.11 10.60 0.0 100.0 3.2 Prog. EL 1 ...... 102.1 47 W T5 & 1 BF 89.53 192.81 263.05 13.65 0.0 100.0 2.7 Prog. Event III: New Baseline ...... Baseline ..... 83.6 53.8 W T5 & 1 75.47 219.84 278.68 N/A N/A N/A N/A Construction BF Prog. and Ren- ovation. New Lamp & EL 1 ...... 92.9 53.8 W T5 & 1 83.49 219.84 286.69 ¥8.02 100.0 0.0 NER Ballast Pur- BF Prog. chase. EL 1 ...... 102.0 49 W T5 & 1 BF 89.41 200.77 268.08 10.60 0.0 100.0 3.2 Prog. EL 1 ...... 102.1 47 W T5 & 1 BF 92.32 192.81 265.03 13.65 0.0 100.0 2.7 Prog.

TABLE VII.22—LCC AND PBP SUBGROUP RESULTS FOR INSTITUTIONS SERVING LOW INCOME POPULATIONS FOR A TWO- LAMP 4-FOOT 28 W T5 MINIATURE BIPIN STANDARD OUTPUT SYSTEM OPERATING IN THE COMMERCIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Lamp Baseline ...... Baseline ..... 94.6 27.8 W T5 & 1 15.30 130.31 145.74 N/A N/A N/A N/A Failure. BF Prog. Lamp Re- EL 1 ...... 104.3 27.8 W T5 & 1 19.17 130.31 149.61 ¥3.87 100.0 0.0 NER placement. BF Prog. EL 2 ...... 109.7 27.8 W T5 & 1 21.52 130.31 151.96 ¥6.22 100.0 0.0 NER BF Prog. EL 2 ...... 111.5 26 W T5 & 1 BF 24.67 122.12 146.91 ¥1.17 75.3 24.7 5.7 Prog. EL 2 ...... 116.0 25 W T5 & 1 BF 27.41 117.56 142.99 2.75 11.4 88.6 4.8 Prog. Event II: Bal- Baseline ...... Baseline ..... 94.6 27.8 W T5 & 1 68.19 130.31 187.13 N/A N/A N/A N/A last Failure. BF Prog. Lamp & Bal- EL 1 ...... 104.3 27.8 W T5 & 72.06 114.36 175.05 12.08 0.0 100.0 1.2 last Re- 0.85 BF Prog. placement. EL 2 ...... 109.7 27.8 W T5 & 74.41 114.36 177.40 9.73 0.0 100.0 2.0 0.85 BF Prog. EL 2 ...... 111.5 26 W T5 & 0.85 77.56 107.25 173.43 13.70 0.0 100.0 2.0 BF Prog. EL 2 ...... 116.0 25 W T5 & 0.85 80.30 103.29 170.11 17.02 0.0 100.0 2.2 BF Prog. Event III: New Baseline ...... Baseline ..... 94.6 27.8 W T5 & 1 70.99 130.31 189.32 N/A N/A N/A N/A Construction BF Prog. and Ren- ovation. New Lamp & EL 1 ...... 104.3 27.8 W T5 & 74.86 114.36 177.23 12.08 0.0 100.0 1.2 Ballast Pur- 0.85 BF Prog. chase. EL 2 ...... 109.7 27.8 W T5 & 77.21 114.36 179.59 9.73 0.0 100.0 2.0 0.85 BF Prog. EL 2 ...... 111.5 26 W T5 & 0.85 80.35 107.25 175.62 13.70 0.0 100.0 2.0 BF Prog.

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TABLE VII.22—LCC AND PBP SUBGROUP RESULTS FOR INSTITUTIONS SERVING LOW INCOME POPULATIONS FOR A TWO- LAMP 4-FOOT 28 W T5 MINIATURE BIPIN STANDARD OUTPUT SYSTEM OPERATING IN THE COMMERCIAL SECTOR— Continued

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

EL 2 ...... 116.0 25 W T5 & 0.85 83.10 103.29 172.30 17.02 0.0 100.0 2.2 BF Prog.

TABLE VII.23—LCC AND PBP SUBGROUP RESULTS FOR INSTITUTIONS SERVING LOW INCOME POPULATIONS FOR A TWO- LAMP 8-FOOT 59 W T8 SINGLE PIN SLIMLINE SYSTEM OPERATING IN THE COMMERCIAL SECTOR

Life-cycle cost Life-cycle cost savings

Rated Dis- Percentage of Mean Event Response Efficacy lamp Design option Installed counted LCC consumers that payback level efficacy cost operating LCC savings experience period lm/W 2012$ cost 2012$ 2012$ years 2012$ Net cost Net benefit

Event I: Lamp Baseline ...... Baseline ..... 96.5 60.1 W T8 & 26.72 192.30 219.30 N/A N/A N/A N/A Failure. 0.87 BF Inst. Lamp Re- EL 1 ...... 98.2 60.1 W T8 & 29.40 192.30 221.98 ¥2.68 100.0 0.0 NER placement. 0.87 BF Inst. EL 2 ...... 99.0 60.1 W T8 & 34.52 192.30 227.10 ¥7.80 100.0 0.0 NER 0.87 BF Inst. EL 2 ...... 105.6 54 W T8 & 0.87 43.51 182.36 226.14 ¥6.84 99.6 0.4 7.1 BF Inst. EL 2 ...... 108.0 50 W T8 & 0.87 50.87 169.08 220.23 ¥0.92 67.7 32.3 4.3 BF Inst. Event II: Bal- Baseline ...... Baseline ..... 96.5 60.1 W T8 & 102.46 189.36 268.51 N/A N/A N/A N/A last Failure. 0.87 BF Inst. Lamp & Bal- EL 1 ...... 98.2 60.1 W T8 & 105.14 169.09 250.92 17.59 0.0 100.0 0.6 last Re- 0.77 BF Inst. placement. EL 2 ...... 99.0 60.1 W T8 & 110.25 169.09 256.04 12.47 0.0 100.0 1.6 0.77 BF Inst. EL 2 ...... 105.6 54 W T8 & 0.77 119.24 160.33 256.27 12.24 0.0 100.0 2.4 BF Inst. EL 2 ...... 108.0 50 W T8 & 0.87 126.60 166.42 269.71 ¥1.20 68.7 31.3 4.4 BF Inst. Event III: New Baseline ...... Baseline ..... 96.5 60.1 W T8 & 105.25 189.36 270.44 N/A N/A N/A N/A Construction 0.87 BF Inst. and Ren- ovation. New Lamp & EL 1 ...... 98.2 60.1 W T8 & 107.93 169.09 252.84 17.59 0.0 100.0 0.6 Ballast Pur- 0.77 BF Inst. chase. EL 2 ...... 99.0 60.1 W T8 & 113.05 169.09 257.96 12.47 0.0 100.0 1.6 0.77 BF Inst. EL 2 ...... 105.6 54 W T8 & 0.77 122.04 160.33 258.19 12.24 0.0 100.0 2.4 BF Inst. EL 2 ...... 108.0 50 W T8 & 0.87 129.40 166.42 271.64 ¥1.20 68.7 31.3 4.4 BF Inst.

TABLE VII.24—LCC AND PBP SUBGROUP RESULTS FOR INSTITUTIONS SERVING LOW INCOME POPULATIONS FOR A TWO- LAMP 8-FOOT 86 W T8 RECESSED DOUBLE CONTACT HO SYSTEM OPERATING IN THE COMMERCIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Lamp Baseline ...... Baseline ..... 92.0 84 W T8 & 0.81 24.45 214.21 238.99 N/A N/A N/A N/A Failure. BF Inst. Lamp Re- EL 1 ...... 95.2 84 W T8 & 0.81 34.00 214.21 248.54 ¥9.56 100.0 0.0 NER placement. BF Inst. EL 2 ...... 97.6 84 W T8 & 0.81 41.21 214.21 255.75 ¥16.76 100.0 0.0 NER BF Inst. Event II: Bal- Baseline ...... Baseline ..... 92.0 84 W T8 & 0.81 100.33 214.21 280.62 N/A N/A N/A N/A last Failure. BF Inst.

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TABLE VII.24—LCC AND PBP SUBGROUP RESULTS FOR INSTITUTIONS SERVING LOW INCOME POPULATIONS FOR A TWO- LAMP 8-FOOT 86 W T8 RECESSED DOUBLE CONTACT HO SYSTEM OPERATING IN THE COMMERCIAL SECTOR—Continued

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Design option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Lamp & Bal- EL 1 ...... 95.2 84 W T8 & 0.81 109.89 214.21 290.18 ¥9.56 100.0 0.0 NER last Re- BF Inst. placement. EL 2 ...... 97.6 84 W T8 & 0.81 117.09 214.21 297.38 ¥16.76 100.0 0.0 NER BF Inst. Event III: New Baseline ...... Baseline ..... 92.0 84 W T8 & 0.81 103.13 214.21 282.16 N/A N/A N/A N/A Construction BF Inst. and Ren- ovation. New Lamp & EL 1 ...... 95.2 84 W T8 & 0.81 112.68 214.21 291.71 ¥9.56 100.0 0.0 NER Ballast Pur- BF Inst. chase. EL 2 ...... 97.6 84 W T8 & 0.81 119.89 214.21 298.92 -16.76 100.0 0.0 NER BF Inst.

Incandescent Reflector Lamps payback periods for the identified Table VII.25 through Table VII.28 subgroups for IRLs. below show the LCC impacts and TABLE VII.25—LCC AND PBP SUBGROUP RESULTS FOR INSTITUTIONS SERVING LOW INCOME POPULATIONS FOR A 55 W PAR38 2,500 HOUR HIR EL 1 REPRESENTATIVE LAMP OPERATING IN THE COMMERCIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Lamp option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Baseline ...... Baseline ..... 17.8 60W, 1500hrs, Im- 10.52 8.68 19.21 N/A N/A N/A N/A Lamp Fail- proved Halogen. ure; or Event III: New Con- struction and Ren- ovation. Lamp Re- EL 1 ...... 18.5 55W, 2500hrs, HIR 13.07 7.96 15.80 3.41 0.0 100.0 3.2 placement or New Lamp Pur- chase.

TABLE VII.26—LCC AND PBP SUBGROUP RESULTS FOR LOW-INCOME CONSUMERS FOR A 55 W PAR38 2,500 HOUR HIR EL 1 REPRESENTATIVE LAMP OPERATING IN THE RESIDENTIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Lamp option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Baseline ...... Baseline ..... 17.8 60W, 1500hrs, Im- 9.40 10.21 19.62 N/A N/A N/A N/A Lamp Fail- proved Halogen. ure; or Event III: New Con- struction and Ren- ovation.

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TABLE VII.26—LCC AND PBP SUBGROUP RESULTS FOR LOW-INCOME CONSUMERS FOR A 55 W PAR38 2,500 HOUR HIR EL 1 REPRESENTATIVE LAMP OPERATING IN THE RESIDENTIAL SECTOR—Continued

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Lamp option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Lamp Re- EL 1 ...... 18.5 55W, 2500hrs, HIR 11.95 9.36 16.98 2.64 0.0 100.0 5.5 placement or New Lamp Pur- chase.

TABLE VII.27—LCC AND PBP SUBGROUP RESULTS FOR INSTITUTIONS SERVING LOW INCOME POPULATIONS FOR A 55 W PAR38 4,200 HOUR IMPROVED HIR EL 1 REPRESENTATIVE LAMP OPERATING IN THE COMMERCIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Lamp option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Baseline ...... Baseline ..... 17.8 60W, 1500hrs, Im- 10.52 8.68 19.21 N/A N/A N/A N/A Lamp Fail- proved Halogen. ure; or Event III: New Con- struction and Ren- ovation. Lamp Re- EL 1 ...... 18.5 55W, 4200hrs, Im- 14.94 7.96 13.30 5.91 0.0 100.0 5.6 placement proved HIR. or New Lamp Pur- chase.

TABLE VII.28—LCC AND PBP SUBGROUP RESULTS FOR LOW-INCOME CONSUMERS FOR A 55 W PAR38 4,200 HOUR IMPROVED HIR EL 1 REPRESENTATIVE LAMP OPERATING IN THE RESIDENTIAL SECTOR

Life-cycle cost Life-cycle cost savings Rated Percentage of Mean Efficacy lamp Dis- consumers that payback Event Response level efficacy Lamp option Installed counted LCC LCC experience period lm/W cost operating 2012$ savings years 2012$ cost 2012$ Net 2012$ Net cost benefit

Event I: Baseline ...... Baseline ..... 17.8 60W, 1500hrs, Im- 9.40 10.21 19.62 N/A N/A N/A N/A Lamp Fail- proved Halogen. ure; or Event III: New Con- struction and Ren- ovation. Lamp Re- EL 1 ...... 18.5 55W, 4200hrs, Im- 13.82 9.36 15.13 4.48 0 100 9.5 placement proved HIR. or New Lamp Pur- chase.

c. Rebuttable Presumption Payback analyses generate values that calculate on consumers, manufacturers, the the payback period for consumers of nation, and the environment—as EPCA establishes a rebuttable potential energy conservation standards, required under 42 U.S.C. presumption that an energy which include, but are not limited to, 6295(o)(2)(B)(i). The results of this conservation standard is economically the 3-year payback period contemplated analysis serve as the basis for DOE to justified if the increased purchase cost under the rebuttable presumption test. evaluate the economic justification for a for a product that meets the standard is However, DOE routinely conducts a full potential standard level (thereby less than three times the value of the economic analysis that considers the supporting or rebutting the results of first-year energy savings resulting from full range of impacts—including those the standard. DOE’s LCC and PBP

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any preliminary determination of Table VII.29 shows the GSFL payback class. There are no IRL payback periods economic justification). periods that are less than 3 years for the less than 3 years. most common sector for each product

TABLE VII.29—GSFL EFFICACY LEVELS WITH REBUTTABLE PAYBACK PERIOD LESS THAN THREE YEARS

Rated Mean Efficacy lamp payback Lamp description Sector Event Response level efficacy Design option period lm/W years

2-Lamp 4-foot Medium Bipin Commercial ... Event I: Lamp Fail- Lamp Re- EL 2 96.0 28.4 W T8 & 2.8 Instant Start. ure. placement. 0.88 BF Inst. Event II: Ballast Lamp & Bal- EL 1 90.0 32.5 W T8 & 0.4 Failure. last Re- 0.78 BF Inst. placement. EL 2 96.0 28.4 W T8 & 2.4 0.87 BF Inst. Event III: New Con- New Lamp & EL 1 90.0 32.5 W T8 & 0.4 struction and Ballast Pur- 0.78 BF Inst. Renovation. chase. EL 2 96.0 28.4 W T8 & 2.4 0.87 BF Inst. 2-Lamp 4-foot Medium Bipin Commercial ... Event I: Lamp Fail- Lamp Re- EL 2 96.0 28.4 W T8 & 2.8 Programmed Start. ure. placement. 0.88 BF Prog. Event II: Ballast Lamp & Bal- EL 1 90.0 32.5 W T8 & 0.3 Failure. last Re- 0.72 BF placement. Prog. EL 2 95.4 32.5 W T8 & 2.5 0.72 BF Prog. EL 2 96.0 28.4 W T8 & 2.8 0.88 BF Prog. Event III: New Con- New Lamp & EL 1 90.0 32.5 W T8 & 0.3 struction and Ballast Pur- 0.72 BF Renovation. chase. Prog. EL 2 95.4 32.5 W T8 & 2.5 0.72 BF Prog. EL 2 96.0 28.4 W T8 & 2.8 0.88 BF Prog. 4-Lamp 4-foot Medium Bipin Commercial ... Event I: Lamp Fail- Lamp Re- EL 2 96.0 28.4 W T8 & 2.9 Instant Start. ure. placement. 0.87 BF Inst. Event II: Ballast Lamp & Bal- EL 1 90.0 32.5 W T8 & 0.5 Failure. last Re- 0.78 BF Inst. placement. EL 2 96.0 28.4 W T8 & 2.9 0.87 BF Inst. Event III: New Con- New Lamp & EL 1 90.0 32.5 W T8 & 0.5 struction and Ballast Pur- 0.78 BF Inst. Renovation. chase. EL 2 96.0 28.4 W T8 & 2.9 0.87 BF Inst. 4-Lamp 4-foot Medium Bipin Commercial ... Event I: Lamp Fail- Lamp Re- EL 2 96.0 28.4 W T8 & 2.8 Programmed Start. ure. placement. 0.89 BF Prog. Event II: Ballast Lamp & Bal- EL 1 90.0 32.5 W T8 & 1.0 Failure. last Re- 0.87 BF placement. Prog. EL 2 96.0 28.4 W T8 & 2.0 0.87 BF Prog. Event III: New Con- New Lamp & EL 1 90.0 32.5 W T8 & 1.0 struction and Ballast Pur- 0.87 BF Renovation. chase. Prog. EL 2 96.0 28.4 W T8 & 2.0 0.87 BF Prog. T5 Miniature Bipin Standard Commercial ... Event II: Ballast Lamp & Bal- EL 1 104.3 27.8 W T5 & 1.2 Output. Failure. last Re- 0.85 BF placement. Prog.

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TABLE VII.29—GSFL EFFICACY LEVELS WITH REBUTTABLE PAYBACK PERIOD LESS THAN THREE YEARS—Continued

Rated Mean Efficacy lamp payback Lamp description Sector Event Response level efficacy Design option period lm/W years

EL 2 109.7 27.8 W T5 & 2.0 0.85 BF Prog. EL 2 111.5 26 W T5 & 2.0 0.85 BF Prog. EL 2 116.0 25 W T5 & 2.2 0.85 BF Prog. Event III: New Con- New Lamp & EL 1 104.3 27.8 W T5 & 1.2 struction and Ballast Pur- 0.85 BF Renovation. chase. Prog. EL 2 109.7 27.8 W T5 & 2.0 0.85 BF Prog. EL 2 111.5 26 W T5 & 2.0 0.85 BF Prog. EL 2 116.0 25 W T5 & 2.2 0.85 BF Prog. T8 Single Pin Slimline ...... Commercial ... Event II: Ballast Lamp & Bal- EL 1 98.2 60.1 W T8 & 0.6 Failure. last Re- 0.77 BF placement. Prog. EL 2 99.0 60.1 W T8 & 1.6 0.77 BF Prog. EL 2 105.6 54 W T8 & 2.4 0.77 BF Prog. Event III: New Con- New Lamp & EL 1 98.2 60.1 W T8 & 0.6 struction and Ballast Pur- 0.77 BF Renovation. chase. Prog. EL 2 99.0 60.1 W T8 & 1.6 0.77 BF Prog. EL 2 105.6 54 W T8 & 2.4 0.77 BF Prog.

2. Economic Impacts on Manufacturers amended standards. Each scenario Cash-Flow Analysis Results by TSL for results in a unique set of cash flows and General Service Fluorescent Lamps DOE performed MIAs to estimate the corresponding industry values at each impact of amended energy conservation TSL. To assess the upper (less severe) end standards on manufacturers of GSFLs of the range of potential impacts on and IRLs. The section below describes In the following discussion, the INPV GSFL manufacturers, DOE modeled a the expected impacts on GSFL and IRL results refer to the difference in industry flat, or preservation of gross margin, manufacturers at each TSL. Chapter 13 value between the base case and the markup scenario. This scenario assumes of the NOPR TSD explains the MIA in standards case that result from the sum that in the standards case, further detail. of discounted cash flows from the base manufacturers would be able to pass a. Industry Cash-Flow Analysis Results year (2013) through the end of the along all the higher production costs analysis period. The results also discuss required for more efficacious products The tables below depict the financial the difference in cash flows between the to their consumers. Specifically, the impacts (represented by changes in base case and the standards case in the INPV) of amended energy standards on industry would be able to maintain its year before the compliance date for average base case gross margin (as a GSFL and IRL manufacturers as well as amended energy conservation the conversion costs that DOE estimates percentage of revenue) despite the standards. This figure represents the higher product costs in the standards GSFL and IRL manufacturers would size of the required conversion costs incur at each TSL. DOE breaks out the case. In general, the larger the product relative to the cash flow generated by price increases, the less likely impacts on GSFL and IRL manufacturers the GSFL and IRL industries in the separately. To evaluate the range of cash manufacturers are to achieve the cash absence of amended energy flow impacts on the GSFL and IRL flow from operations calculated in this conservation standards. industries, DOE modeled two markup scenario because it is less likely that scenarios that correspond to the range of manufacturers would be able to fully anticipated market responses to mark up these larger cost increases.

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To assess the lower (more severe) end impacts on manufacturers because no the flat and preservation of operating of the range of potential impacts on the additional operating profit is earned on profit markup scenarios. DOE examined GSFL manufacturers, DOE modeled the the higher production costs, eroding results for all five product classes (4-foot preservation of operating profit markup profit margins as a percentage of total MBP, 8-foot SP slimline, 8-foot RDC HO, scenario. This scenario represents the revenue. 4-foot T5 MiniBP SO, and 4-foot T5 lower end of the range of potential Table VII.30 and Table VII.31 present MiniBP HO) together. the projected results for GSFLs under

TABLE VII.30—MANUFACTURER IMPACT ANALYSIS FOR GENERAL SERVICE FLUORESCENT LAMPS—FLAT MARKUP SCENARIO

Trial standard level Units Base case 1 2 3 4 5

INPV ...... (2012$ millions) ...... 1,542.5 1,584.4 1,580.3 1,663.1 1,901.1 1,939.7 Change in INPV ...... (2012$ millions) ...... 41.8 37.8 120.5 358.5 397.1 (%) ...... 2.7% 2.5% 7.8% 23.2% 25.7% Product Conversion Costs ...... (2012$ millions) ...... 0.9 2.0 5.3 7.5 9.1 Capital Conversion Costs ...... (2012$ millions) ...... 1.0 11.0 3.0 5.5 29.5 Total Conversion Costs ...... (2012$ millions) ...... 1.9 13.0 8.3 13.0 38.6

TABLE VII.31—MANUFACTURER IMPACT ANALYSIS FOR GENERAL SERVICE FLUORESCENT LAMPS—PRESERVATION OF OPERATING PROFIT MARKUP SCENARIO

Trial standard level Units Base case 1 2 3 4 5

INPV ...... (2012$ millions) ...... 1,542.5 1,541.7 1,533.4 1,531.0 1,519.6 1,502.6 Change in INPV ...... (2012$ millions) ...... (0.9) (9.2) (11.5) (22.9) (39.9) (%) ...... ¥0.1% ¥0.6% ¥0.7% ¥1.5% ¥2.6% Product Conversion Costs ...... (2012$ millions) ...... 0.9 2.0 5.3 7.5 9.1 Capital Conversion Costs ...... (2012$ millions) ...... 1.0 11.0 3.0 5.5 29.5 Total Conversion Costs ...... (2012$ millions) ...... 1.9 13.0 8.3 13.0 38.6

TSL 1 sets the efficacy level at shipments in 2017. Meanwhile, in 2017, average MPC increases by baseline for two product classes (4-foot 33 percent of 8-foot RDC HO shipments, approximately 5 percent relative to the MBP and 8-foot SP slimline) and EL 1 45 percent of 4-foot T5 MiniBP SO, and base case MPC. Manufacturers are able for three product classes (8-foot RDC 37 percent of 4-foot T5 MiniBP HO to fully pass on this cost increase to HO, 4-foot T5 MiniBP SO, and 4-foot T5 shipments would meet the efficacy consumers by design in this markup MiniBP HO). EL 1 for the 4-foot T5 levels at TSL 1. Because these products scenario. This slight price increase MiniBP HO product class represents the comprise a very small percentage of would mitigate the $1.9 million in max tech efficacy level. At TSL 1, DOE total GSFL shipments in 2017, a very conversion costs estimated at TSL 1, estimates impacts on INPV range from small percentage of total GSFL resulting in slightly positive INPV $41.8 million to ¥$0.9 million, or a shipments would need to be converted impacts at TSL 1 under the flat markup change in INPV of 2.7 percent to ¥0.1 at TSL 1 to meet these efficacy scenario. percent. At TSL 1, industry free cash standards. Under the preservation of operating flow (operating cash flow minus capital DOE expects conversion costs to be profit markup scenario, manufacturers expenditures) is estimated to decrease small compared to the industry value earn the same operating profit as would by approximately 0.5 percent to $156.9 because most of the GSFL shipments, on be earned in the base case, but million, compared to the base case value a total volume basis, already meet or manufacturers do not earn additional of $157.7 million in 2016, the year exceed the efficacy levels analyzed at profit from their investments. The 5 leading up to proposed energy this TSL. DOE expects GSFL percent MPC increase is slightly conservation standards. manufacturers to incur $0.9 million in outweighed by a lower average markup Percentage impacts on INPV are product conversion costs for lamp of 1.51 (compared to the flat markup of slightly positive to slightly negative at redesign and testing. DOE estimates 1.52) and $1.9 million in conversion TSL 1. DOE does not anticipate that manufacturers will have minimal costs, resulting in small negative manufacturers would lose a significant capital conversion costs associated with impacts at TSL 1. portion of their INPV at this TSL. This TSL 1, as most efficacy gains will be TSL 2 sets the efficacy level at is because the vast majority of achieved through increasing the amount baseline for one product class (4-foot shipments already meets or exceeds the of REOs used to coat the lamps, not MBP), EL 1 for three product classes (8- efficacy levels prescribed at TSL 1. DOE through any major equipment upgrades foot SP slimline, 4-foot T5 MiniBP SO, projects that in the expected year of or capital investments. DOE expects $1 and 4-foot T5 MiniBP HO), and EL 2 for compliance (2017), 100 percent of 4-foot million in capital conversion costs for one product class (8-foot RDC HO). EL MBP and 8-foot SP slimline shipments manufacturers to upgrade and 1 for the 4-foot T5 MiniBP HO product would meet or exceed the efficacy levels recalibrate production line automation. class and EL 2 for the 8-foot RDC HO at TSL 1. DOE estimates that these At TSL 1, under the flat markup product class represent the max tech lamps account for 88 percent of GSFL scenario, the shipment-weighted efficacy levels. At TSL 2, DOE estimates

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impacts on INPV to range from $37.8 max tech efficacy level. At TSL 3, DOE scenario, the 16 percent MPC increase is million to ¥$9.2 million, or a change in estimates impacts on INPV to range slightly outweighed by a lower average INPV of 2.5 percent to ¥0.6 percent. At from $120.5 million to ¥$11.5 million, markup of 1.51 (compared to the flat this proposed level, industry free cash or a change in INPV of 7.8 percent to markup scenario markup of 1.52) and flow is estimated to decrease by ¥0.7 percent. At this proposed level, $8.3 million in conversion costs, approximately 4 percent to $152.1 industry free cash flow is estimated to resulting in negative impacts at TSL 3. million, compared to the base case value decrease by approximately 2 percent to TSL 4 sets the efficacy level at of $157.7 million in 2016. $154.7 million, compared to the base baseline for one product class (8-foot SP Percentage impacts on INPV are case value of $157.7 million in 2016. slimline), EL 1 for three product classes slightly positive to slightly negative at While more significant than the (8-foot RDC HO, 4-foot T5 MiniBP SO, TSL 2. DOE does not anticipate that impacts at TSL 2, the impacts on INPV and 4-foot T5 MiniBP HO), and EL 2 for manufacturers would lose a significant at TSL 3 are still relatively minor one product class (4-foot MBP). EL 1 for portion of their INPV at this TSL compared to the total industry value. the 4-foot T5 MiniBP HO product class because the vast majority of shipments Percentage impacts on INPV are slightly and EL 2 for the 4-foot MBP product already meets or exceeds the efficacy positive to slightly negative at TSL 3. class represent the max tech efficacy levels prescribed at TSL 2. DOE projects DOE does not anticipate that levels. At TSL 4, DOE estimates impacts that in 2017, 100 percent of 4-foot MBP manufacturers would lose a significant on INPV to range from $358.5 million to shipments would meet or exceed the portion of their INPV TSL 3. While less ¥$22.9 million, or a change in INPV of efficacy levels at TSL 2. DOE estimates than the previous TSLs, a large 23.2 percent to ¥1.5 percent. At this that shipments of this product classes percentage of total shipments still proposed level, industry free cash flow will comprise 86 percent of GSFL already meet or exceed the efficacy is estimated to decrease by shipments in 2017. Meanwhile, in 2017, levels prescribed at TSL 3. DOE projects approximately 3 percent to $152.9 57 percent of 8-foot SP slimline lamps that in 2016, 56 percent of the 4-foot million, compared to the base case value shipments, 10 percent of 8-foot RDC HO MBP, 100 percent of 8-foot SP slimline, of $157.7 million in the year leading up shipments, 45 percent of 4-foot T5 33 percent of 8-foot RDC HO shipments, to energy conservation standards. MiniBP SO, and 37 percent of 4-foot T5 45 percent of 4-foot T5 MiniBP SO, and Percentage impacts on INPV are MiniBP HO shipments would meet or 37 percent of 4-foot T5 MiniBP HO moderately positive to slightly negative exceed the efficacy levels at TSL 2. shipments would meet or exceed the at TSL 4. DOE projects that in 2017, 21 DOE expects conversion costs to be efficacy levels at TSL 3. percent of 4-foot MBP, 100 percent of 8- small compared to the industry value DOE expects conversion costs to foot SP slimline, 33 percent of 8-foot because most of the GSFL shipments, on remain small at TSL 3 compared to the RDC HO shipments, 45 percent of 4-foot a total volume basis, already meet or industry value because a significant T5 MiniBP SO, and 37 percent of 4-foot exceed the efficacy levels analyzed at percentage of the GSFL shipments, on a T5 MiniBP HO shipments would meet this TSL. DOE expects that product total volume basis, already meet or or exceed the efficacy levels at TSL 4. conversion costs will rise from $0.9 exceed the efficacy levels proposed at While DOE expects conversion costs million at TSL 1 to $2.0 million at TSL this TSL. TSL 3 is the first TSL that to increase from TSL 3 to TSL 4, DOE 2 for lamp redesign and testing. Capital increases the efficacy requirement for 4- estimates the costs will still be small conversion costs will increase from $1.0 foot MBP, which as previously noted, compared to the total industry value. million at TSL 1 to $11.0 million at TSL comprise a large majority of GSFL DOE expects product conversion costs 2. This is driven by the fact that both 8- shipments. Efficacy gains for these for GSFL manufacturers to increase from foot product classes would have to meet products, however, would likely be $5.3 million at TSL 3 to $7.5 million at higher efficacy levels at this TSL. DOE achieved with additional REOs, which TSL 4. DOE expects capital conversion believes this will result in higher capital would not require any significant costs to increase from $3.0 million at conversion costs related to upgrading capital investments. At TSL 3, DOE TSL 3 to $5.5 million at TSL 4. While and recalibrating production line expects product conversion costs to a higher percentage of shipments would automation. increase from TSL 2 to $5.3 million. need to be converted to meet the At TSL 2, under the flat markup DOE, however, estimates that capital efficacy requirements at TSL 4, scenario, the shipment-weighted conversion costs will decrease from TSL increasing the efficacy of GSFLs will not average MPC increases by 5 percent 2 to $3.0 million at TSL 3 since no likely be a very capital-intensive relative to the base case MPC. In this amended efficacy standards would be process. Instead, increasing GSFL scenario, INPV impacts are slightly set at TSL 3 for 8-foot SP slimline efficacy will likely be more focused positive because of manufacturers’ products and the 8-foot RDC HO around increasing the amount of REOs ability to pass the higher production product class has a lower EL at TSL 3 in the lamps. costs to consumers outweighs the $13.0 than at TSL 2. The lower ELs for these At TSL 4, under the flat markup million in conversion costs. Under the two product classes outweigh the scenario the shipment-weighted average preservation of operating profit markup increase in EL of the 4-ft MBP product MPC increases by 52 percent relative to scenario, the 5 percent MPC increase is class and would cause manufacturers to the base case MPC. In this scenario, slightly outweighed by a lower average invest less in capital conversion costs at INPV impacts are slightly positive markup of 1.51 (compared to the flat TSL 3 than at TSL 2. because of manufacturers’ ability to pass markup of 1.52) and $13.0 million in At TSL 3, under the flat markup the higher production costs to conversion costs, resulting in slightly scenario, the shipment-weighted consumers outweighs the $13.0 million negative impacts at TSL 2. average MPC increases by 16 percent in conversion costs. Under the TSL 3 sets the efficacy level at relative to the base case MPC. In this preservation of operating profit markup baseline for one product class (8-foot SP scenario, INPV impacts are slightly scenario, the 52 percent MPC increase is slimline) and EL 1 for four product positive because manufacturers’ ability slightly outweighed by a lower average classes (4-foot MBP, 8-foot RDC HO, 4- to pass the higher production costs to markup of 1.51 (compared to the flat foot T5 MiniBP SO, and 4-foot T5 consumers outweighs the $8.3 million markup scenario markup of 1.52) and MiniBP HO). EL 1 for the 4-foot T5 in conversion costs. Under the $13.0 million in conversion costs, MiniBP HO product class represents the preservation of operating profit markup resulting in negative impacts at TSL 4.

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TSL 5 sets the efficacy level at max estimates that capital conversion costs Cash Flow Analysis Results by TSL for tech for all product classes. This will be $29.5 million at TSL 5 as a result Incandescent Reflector Lamps represents EL 1 for one product class (4- of manufacturers having to upgrade all DOE incorporated the same markup foot T5 MiniBP HO) and EL 2 for five of their production lines to manufacture product classes (4-foot MBP, 8-foot SP scenarios to represent the upper and max tech products. DOE expects GSFL lower bounds of industry impacts for slimline, 8-foot RDC HO, and 4-foot T5 manufacturers to incur $9.1 million in MiniBP SO). At TSL 5, DOE estimates IRLs as was done for GSFLs: the flat, or product conversion costs for lamp preservation of gross margin, markup impacts on INPV to range from $397.1 redesigns and testing. However, these ¥ scenario and the preservation of million to $39.9 million, or a change larger total conversion costs at TSL 5, ¥ operating profit markup scenario. DOE, in INPV of 25.7 percent to 2.6 percent. $38.6 million remain relatively small At this proposed level, industry free however, analyzed one TSL for IRLs in compared to the almost $2 billion total addition to the baseline levels. DOE also cash flow is estimated to decrease by GSFL industry value at TSL 5. approximately 10 percent to $143.4 analyzed an alternative shipment million, compared to the base case value At TSL 5, under the flat markup scenario for IRLs, the shortened lifetime of $157.7 million in 2016. scenario, the shipment-weighted scenario, in addition to the reference Percentage impacts on INPV are average MPC increases by 57 percent case. DOE acknowledges that to meet significantly positive to slightly negative relative to the base case MPC. In this the proposed IRL energy conservation at TSL 5. DOE projects that in 2017, 21 scenario, INPV impacts are slightly standards, IRL manufacturers may percent of the 4-foot MBP, 25 percent of positive because of manufacturers’ choose to shorten the lifetime of some 8-foot SP slimline, 10 percent of 8-foot ability to pass the higher production of their IRLs, rather than make the RDC HO shipments, 14 percent of 4-foot costs to consumers outweighs the $38.6 investments to increase the efficacy of T5 MiniBP SO, and 37 percent of 4-foot million in conversion costs. Under the the lamps. DOE presents the results of T5 MiniBP HO shipments would meet preservation of operating profit markup this analysis in appendix 13C of the the efficacy levels at TSL 5. scenario, the 57 percent MPC increase is NOPR TSD. DOE expects conversion costs to slightly outweighed by a lower average Table VII.32 and Table VII.33 present increase from TSL 4 to TSL 5 due to the markup of 1.51 (compared to the flat the projected results for IRLs under the 8-foot slimline, 8-foot RDC HO, and 4- markup scenario markup of 1.52) and flat and preservation of operating profit foot T5 MiniBP HO product classes $38.6 million in conversion costs, scenarios. DOE examined results for one moving to max tech ELs at TSL 5. DOE resulting in negative impacts at TSL 5. representative product class for IRLs.

TABLE VII.32—MANUFACTURER IMPACT ANALYSIS FOR INCANDESCENT REFLECTOR LAMPS—FLAT MARKUP SCENARIO

Trial standard Units Base case level 1

INPV ...... (2012$ millions) ...... 176.0 128.6 Change in INPV ...... (2012$ millions) ...... (47.5) (%) ...... ¥27.0% Product Conversion Costs ...... (2012$ millions) ...... 6.1 Capital Conversion Costs ...... (2012$ millions) ...... 65.4 Total Conversion Costs ...... (2012$ millions) ...... 71.5

TABLE VII.33—MANUFACTURER IMPACT ANALYSIS FOR INCANDESCENT REFLECTOR LAMPS—PRESERVATION OF OPERATING PROFIT MARKUP SCENARIO

Trial standard Units Base case level 1

INPV ...... (2012$ millions) ...... 176.0 124.2 Change in INPV ...... (2012$ millions) ...... (51.8) (%) ...... ¥29.5% Product Conversion Costs ...... (2012$ millions) ...... 6.1 Capital Conversion Costs ...... (2012$ millions) ...... 65.4 Total Conversion Costs ...... (2012$ millions) ...... 71.5

TSL 1 sets the efficacy level at EL 1, INPV impacts are negative at TSL 1 invest in retooling burner machines, max tech, for the IRL representative regardless of the markup scenario increasing coating capacity, and unit. At TSL 1, DOE estimates impacts chosen. DOE estimates that in 2017, 41 upgrading their production lines to on INPV to range from ¥$47.5 million percent of IRL shipments would meet allow for enhanced reflector coating. to ¥$51.8 million, or a change in INPV the efficacy requirements proposed at Some manufacturers expressed concern of ¥27.0 percent to ¥29.5 percent. At TSL 1. The majority of shipments would that they do not currently possess the TSL 1, industry free cash flow is need to be converted to meet the technology required at the analyzed estimated to decrease by approximately standards proposed at this TSL. standard level and could exit the market 131 percent to ¥7.5 million, compared DOE expects substantial conversion entirely. Overall, DOE expects these to the base case value of $23.8 million costs for IRL manufacturers at TSL 1 capital conversion costs to total $65.4 in 2016. associated with increasing the efficacy million for the industry. DOE estimates of IRLs. Manufacturers would have to that IRL manufacturers will also incur

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$6.1 million in product conversion costs at each TSL from 2013 to 2046. DOE amended energy conservation standards for lamp and production line redesign, used statistical data from the U.S. when assuming that manufacturers as well as testing and certification. Census Bureau’s 2011 Annual Survey of continue to produce the same scope of At TSL 1, under the flat markup Manufacturers (ASM), the results of the covered products in the same scenario, the shipment-weighted engineering analysis, and interviews production facilities. It also assumes average MPC increases by 13 percent with manufacturers to determine the that domestic production does not shift relative to the base case MPC. In this inputs necessary to calculate industry- to lower labor-cost countries. Because scenario, INPV impacts are negative wide labor expenditures and domestic there is a real risk of manufacturers because the manufacturers’ ability to employment levels. Labor expenditures evaluating sourcing decisions in pass the higher production costs to involved with the manufacture of the response to amended energy consumers does not outweigh $71.5 product are a function of the labor conservation standards, the lower million in conversion costs. Under the intensity of the product, the sales bound of the employment results preservation of operating profit markup volume, and an assumption that wages includes the estimated total number of scenario, the 13 percent MPC increase is remain fixed in real terms over time. U.S. production workers in the industry outweighed by a lower average markup In the GRIM, DOE used the labor who could lose their jobs if some or all of 1.50 (compared to the flat markup content of each product and the existing production were moved outside scenario markup of 1.52) and $71.5 manufacturing production costs to of the United States. While the results million in conversion costs, resulting in estimate the annual labor expenditures present a range of employment impacts negative impacts at TSL 1. The in the industry. DOE used census data following 2017, the sections below also significant capital and product and interviews with manufacturers to include qualitative discussions of the conversion costs that IRL manufacturers estimate the portion of the total labor likelihood of negative employment must make at TSL 1 cause INPV to be expenditures that is attributable to impacts at the various TSLs. Finally, the domestic labor. negative regardless of the markup employment impacts shown are The production worker estimates in chosen. independent of the employment impacts this section cover only workers up to DOE also analyzed a shortened from the broader U.S. economy, lifetime sensitivity scenario where the line-supervisor level directly involved in fabricating and assembling documented in chapter 17 of the NOPR manufacturers shorten the lifetime of TSD. DOE seeks comment on the IRLs to mitigate the costs of complying a product within a manufacturing potential domestic employment impacts with the proposed standard. By facility. Workers performing services to GSFL and IRL manufacturers at the shortening the lifetime of IRLs that are closely associated with proposed efficacy levels. manufacturers reduce the capital production operations, such as material conversion costs they must make to handing with a forklift, are also Employment Impacts for General comply with the proposed standard. included as production labor. DOE’s Service Fluorescent Lamps DOE presents the INPV results of this estimates account for production analysis in appendix 13C of this NOPR workers who manufacture only the Using 2011 ASM data and interviews TSD. DOE requests comment on the $6.1 specific products covered of this with manufacturers, DOE estimates that product conversion costs and $65.4 rulemaking. For example, a worker on a approximately three quarters of the capital conversion costs necessary for fluorescent lamp ballast production line GSFLs sold in the United States are manufacturers to comply with the would not be included with the estimate manufactured domestically. With this proposed standards. of the number of GSFL or IRL workers. assumption, DOE estimates that in the The employment impacts shown in absence of amended energy b. Impacts on Employment Table VII.34 and Table VII.35 below conservation standards, there would be DOE quantitatively assessed the represent the potential production approximately 1,800 domestic impacts of potential amended energy employment that could result following production workers involved in conservation standards on direct amended energy conservation manufacturing GSFLs in 2017. The table employment. DOE used the GRIM to standards. The upper bound of the below shows the range of the impacts of estimate the domestic labor results estimates the maximum change potential amended energy conservation expenditures and number of domestic in the number of production workers standards on U.S. production workers in production workers in the base case and that could occur after compliance with the GSFL industry.

TABLE VII.34—POTENTIAL CHANGES IN THE TOTAL NUMBER OF DOMESTIC GENERAL SERVICE FLUORESCENT LAMP PRODUCTION WORKERS IN 2017

Trial standard level Base case 1 2 3 4 5

Total Number of Domestic Production Workers in 2017 (without changes in production loca- tions) ...... 1,848 1,848 1,847 1,844 1,814 1,817 Potential Changes in Domestic Production Workers in 2017 * ...... 0 (1) (4)–(1,848) (34)–(1,848) (31)–(1,848) * DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative numbers.

At the upper end of the range, all could face slight negative impacts on manufactured domestically, such as 4- examined TSLs show slight negative domestic employment levels because foot T5 MiniBP lamps, and a decrease impacts on domestic employment there would be an increase in the of products typically manufactured levels. DOE believes that manufacturers shipments of products typically not domestically, such as 4-foot MBP lamps.

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Several manufacturers emphasized there could be a loss of domestic Employment Impacts for Incandescent that it is difficult to predict employment employment at these TSLs due to the Reflector Lamps impacts of energy conservation required increase in efficacy of 4-foot standards. One potential uncertainty is MBP lamps. The potential loss of Using 2011 ASM data and interviews the future price of REOs and these domestic employment would most with manufacturers, DOE estimates that employment decisions become more likely be a result of a possible increase approximately half of the IRLs sold in complex when more REOs are required in the price of REOs. Based on the REO the United States are manufactured for higher efficacious products. prices modeled in the reference case, domestically. With this assumption, DOE does not expect any significant DOE does not estimate a significant loss DOE estimates that in the absence of changes in domestic employment at of domestic employment at TSLs 3, 4, or amended energy conservation TSLs 1 or 2 because standards would 5. Overall, manufacturers were standards, there would be not be amended for 4-foot MBP lamps, uncertain about how amended energy approximately 300 domestic production which comprise approximately 86 conservation standards would affect workers involved in manufacturing IRLs percent of GSFL shipments in 2017. domestic employment and sourcing in 2017. The table below shows the While DOE does not anticipate the decisions. Ultimately, both employment range of the impacts of potential entire, or even a large portion of, and sourcing decisions could be amended energy conservation standards domestic employment to move abroad at determined by the stability and on U.S. production workers in the IRL TSLs 3, 4 or 5, DOE acknowledges that predictability of REO prices. industry.

TABLE VII.35—POTENTIAL CHANGES IN THE TOTAL NUMBER OF DOMESTIC INCANDESCENT REFLECTOR LAMP PRODUCTION WORKERS IN 2017

Trial standard Base case level 1

Total Number of Domestic Production Workers in 2017 (without changes in production locations) ...... 308 335 Potential Changes in Domestic Production Workers in 2017 * ...... 27–(308) * DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative numbers.

At the upper end of the range TSL 1 REOs that are already difficult to come to the potential increase in IR coating shows a slight positive impact on by could trigger some capacity concerns demand. Given that DOE estimated domestic employment levels. The by creating extra volatility in the approximately 65 million IRLs may be increasing product cost at TSL 1 would market. The sharp increase in demand sold in 2017 in the preliminary analysis, result in higher labor expenditures per- for REOs could cause wide variations in ADLT believes that IR coating capacity unit, which could cause manufacturers the price and availability of REOs, in excess of 70 million units in total can to hire more domestic workers to meet making production costs more readily be made available. (ADLT, No. this added labor demand, assuming IRL unpredictable. 31 at p. 3) While this exceeds DOE’s production remains in domestic A few IRL manufacturers expressed NOPR IRL shipment estimate of facilities. concern about the capacity of their IR approximately 32 million units to be Manufacturers are concerned that coating machines and that the sold in 2017, ADLT did not provide a higher prices for IRLs will drive companies that manufacture those source for their claim that the current IR consumers to alternate technologies and machines might not be able to respond coating capacity is 50 million units it may not make economic sense for to the demand for IR coating machines annually or for the potential to increase them to continue to produce IRLs. necessary to manufacture higher this IR coating capacity to 70 million Increasing the efficacy of IRLs would efficacious IRLs. DOE, however, units annually in 2017. Therefore, it is cost manufacturers millions in capital received a comment from ADLT, a unclear if this additional IR coating conversion costs. Some stated that they company that manufactures IR coating capacity or current IR coating capacity do not have the technology to meet the machines, that they estimate the current is sufficient to meet the potential U.S. proposed energy conservation standards global capacity of IR coatings for IRLs to demand for IRLs at the higher EL. and said it is possible they would not be over 50 million units annually. ADLT d. Impacts on Sub-Groups of spend their limited resources to convert claims this IR coating capacity is Manufacturers all IRL production to meet efficacy supported by three different coating levels at TSL 1. Ultimately, the high processes and provided by at least five Using average cost assumptions to costs associated with increasing the different companies. ADLT stated they develop an industry cash-flow estimate efficacy of IRLs could cause some IRL are in a position to increase their IR may not be adequate for assessing manufacturers to exit the market. coating capacity by 20 million units differential impacts among annually using existing equipment manufacturer subgroups. Small c. Impacts on Manufacturing Capacity within a two-year time period. ADLT manufacturers, niche product GSFL manufacturers stated that they believes that additional coating capacity manufacturers, and manufacturers did not anticipate any capacity can be generated from one or more of at exhibiting cost structures substantially constraints outside of the availability of least five IR coating facilities owned and different from the industry average REOs. One manufacturer pointed out operated by other companies could be affected disproportionately. that moving the industry to max tech worldwide. Given a three-year period DOE analyzed the impacts to small efficacy levels could triple the amount between the ruling and its effective date, businesses in section VIII.B and did not of REOs demanded by GSFL ADLT believes there is ample time identify any other adversely impacted manufacturers. Tripling the demand for available for various companies to react subgroups for GSFLs or IRLs for this

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rulemaking based on the results of the GSFL and IRL manufacturers also make regulatory costs that affect the industry industry characterization. a full range of lighting products and modeled in the cash-flow analysis. To share engineering and other resources the extent DOE receives specific costs e. Cumulative Regulatory Burden with these other internal manufacturing associated with other regulations While any one regulation may not divisions for different products affecting those profit centers (GSFL and impose a significant burden on (including certification testing for IRL) modeled in the GRIM, DOE can manufacturers, the combined effects of regulatory compliance). Manufacturers incorporate that information into its recent or impending regulations may cited current DOE rulemakings for high cash-flow analysis. The cash-flow have serious consequences for some intensity discharge (HID) lamps, metal scenarios analyzed for today’s proposed manufacturers, groups of manufacturers, halide fixtures, LEDs, and CFLs. Some rule include the impacts of the 2009 or an entire industry. Assessing the manufacturers also raised concerns Lamps Rule, as the levels established in impact of a single regulation may about other existing regulations separate that rule have become the baseline for overlook this cumulative regulatory from DOE’s energy conservation the proposed standards and the lamp burden. In addition to energy standards that manufacturers of GSFLs prices estimated in the engineering conservation standards, other and IRLs must meet. These include: the analysis reflect the investments that regulations can significantly affect Restriction of Hazardous Substances manufacturers made to comply with the manufacturers’ financial operations. (RoHS) Directive, California Title 20, 2009 Lamps Rule. DOE seeks comment Multiple regulations affecting the same FTC labeling requirements, Interstate on the compliance costs of any other manufacturer can strain profits and lead Mercury Education and Reduction regulations GSFL or IRL manufacturers companies to abandon product lines or Clearinghouse (IMERC) labeling must make, especially if compliance markets with lower expected future requirements, the Minamata Convention with those regulations is required three returns than competing products. For on Mercury, and disclosure of years before or after the estimated these reasons, DOE conducts a procurement methods of conflict compliance date of these proposed cumulative regulatory burden analysis minerals mandated by the Wall Street standards (2017). as part of its rulemakings pertaining to Reform and Consumer Protection Act, 3. Shipments Analysis and National lighting efficacy. among others. DOE seeks comment on Impact Analysis During previous stages of this GSFL manufacturers potentially rulemaking, DOE identified a number of increasing the amount of mercury in Projections of shipments are an requirements, in addition to amended GSFLs in order to comply with the important input to the NIA. As energy conservation standards for proposed GSFL standards. discussed in section VI.I, DOE GSFLs and IRLs, that manufacturers will DOE discusses these and other developed a shipments model that face for products they manufacture three requirements in chapter 13 of the NOPR incorporated substitution matrixes, years prior to and three years after the TSD, which lists the estimated which specify the product choices compliance date of the amended compliance costs of those requirements available to consumers (lamps as well as standards. The following section briefly when available. In considering the lamp-and-ballast combinations for addresses comments DOE received with cumulative regulatory burden, DOE fluorescent lamps) depending on respect to cumulative regulatory burden evaluates the timing of regulations that whether they are renovating lighting and summarizes other key related impact the same product because the systems, installing lighting systems in concerns that manufacturers raised coincident requirements could strain new construction, or simply replacing during interviews. financial resources in the same profit lamps; and a module that assigns Several manufacturers expressed center and consequently impact shipments to product classes and concern that GSFLs and IRLs face capacity. DOE also identified several efficacy levels based on consumer several regulations and that they have ongoing rulemakings that could sensitivities to first costs and operation not had time to fully assess the effects potentially impact other business units and maintenance costs. The model of the 2009 Lamps Rule, compliance of GSFL and IRL manufacturers in estimates the shipments of each lamp with which was required in 2012. general, but the impacts of those type in the base case and under the Several manufacturers also expressed ongoing rulemakings remain speculative conditions set by each TSL. Table VII.36 concern about the overall volume of and are therefore not included in the and Table VII.37 present the estimated DOE’s energy conservation standards analysis for today’s proposed rule. DOE cumulative shipments in the base case with which they must comply. Most did not receive any data on other and the relative change under each TSL.

TABLE VII.36—EFFECT OF STANDARD CASES ON CUMULATIVE SHIPMENTS OF GSFL IN 2017–2046

Base case TSL 1 TSL 2 TSL 3 TSL 4 TSL 5 Change in Change in Change in Change in Change in Lamp type Cumulative shipments shipments shipments shipments shipments shipments relative to relative to relative to relative to relative to millions base case base case base case base case base case (percent) (percent) (percent) (percent) (percent)

4-foot MBP ...... 5,700 0.0 0.34 ¥2.7 ¥24 ¥18 8-foot SP slimline ...... 110 0.0 ¥13 8.6 71 24 8-foot RDC HO ...... 21 0.0 ¥8.5 0.0 0.0 ¥8.5 4-foot T5, MiniBP SO ...... 410 0.0 0.83 28 250 210 4-foot T5, MiniBP HO ...... 660 0.0 0.27 ¥0.01 ¥0.12 0.17 2-foot U-shaped ...... 230 0.0 0.0 ¥0.0 ¥0.0 ¥0.0

Total GSFL* ...... 7,100 0.0 0.13 ¥0.39 ¥3.4 ¥2.4 * May not sum due to rounding.

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As shown in the preceding Table, projecting a rapid shift from 4-foot MBP comment on the reasonableness of the depending on TSL, the consumer choice T8s to standard output T5s in the TSL shipments model projection for TSL 5. model projects significant shifts across 5 standards case. The TSL5 standards Specifically, DOE seeks comment on product classes, in particular, it projects case substantially increases first cost for whether standard output T5 lamps significant shifts to 4-foot T5 standard 4-foot MBP T8s. could increase from 3 to 4 percent of the output lamps in the TSL 4 and TSL 5 Noting that DOE projects a sharp standard output GSFL market presently, standards cases. DOE requests comment decrease in total GSFL shipments both to approximately 13 percent of the same on the reasonableness of its assumption with and without standards during the market by 2020, and to approximately that first cost is a significant driver of rulemaking period because of the 30 percent of the much attenuated consumers’ choice of product class, projected sharp incursion of LEDs into standard output GSFL market by 2046. which results in the shipments analysis the GSFL market, DOE also seeks

TABLE VII.37—EFFECT OF STANDARD CASES ON CUMULATIVE SHIPMENTS OF IRL IN 2017–2046

Base case TSL 1 Change in Lamp Type Cumulative shipments shipments relative to millions base case (percent)

Standard spectrum; >2.5 inch diameter; <125 V ...... 230 ¥20

a. Significance of Energy Savings lifetime of product purchased in the 30- estimated energy savings for each year period. DOE quantified the energy considered GSFL TSL, and Table VII.39 For each TSL, DOE projected energy savings attributable to each TSL as the presents the estimated energy savings savings for GSFLs and IRLs purchased difference in energy consumption for each IRL TSL. The approach for in the 30-year period that begins in the between each standards case and the estimating shipments and NES is further year of anticipated compliance with base case, accounting for the effects of described in sections V.I and V.J and is amended standards (2017–2046). The the standards on product switching and detailed in chapter 11 and 12 of the TSD savings are measured over the entire shipments. Table VII.38 presents the of the NOPR TSD.

TABLE VII.38—CUMULATIVE ENERGY SAVINGS FOR GSFL TRIAL STANDARD LEVELS FOR UNITS SOLD IN 2017–2046

Trial standard level 1 2 3 4 5

Quads

Primary Energy ...... (Power Sector Consumption) ...... 0.20 0.20 0.86 2.9 3.3 FFC Energy ...... 0.21 0.21 0.89 3.0 3.5

TABLE VII.39—CUMULATIVE ENERGY Circular A–4 requires agencies to revision of and compliance with such SAVINGS FOR IRL TRIAL STANDARD present analytical results, including revised standards.89 The review LEVELS FOR UNITS SOLD IN 2017– separate schedules of the monetized timeframe established in EPCA is 2046 benefits and costs that show the type generally not synchronized with the and timing of benefits and costs. product lifetime, product manufacturing Trial Circular A–4 also directs agencies to cycles, or other factors specific to GSFLs standard consider the variability of key elements and IRLs. Thus, this information is level underlying the estimates of benefits and presented for informational purposes 1 costs. For this rulemaking, DOE only and is not indicative of any change undertook a sensitivity analysis using in DOE’s analytical methodology. The Quads nine, rather than 30, years of product NES results based on nine years of shipments. The choice of a nine-year shipments are presented in Table VII.40 Primary Energy (Power Sector period is a proxy for the timeline in and Table VII.41. The impacts are Consumption) ...... 0.012 EPCA for the review of certain energy counted over the lifetime of GSFL and FFC Energy ...... 0.013 conservation standards and potential IRL purchased in 2017–2025.

89 Section 325(m) of EPCA requires DOE to review compliance date of the previous standards. While period may not be appropriate given the variability its standards at least once every 6 years, and adding a 6-year review to the 3-year compliance that occurs in the timing of standards reviews and requires, for certain products, a 3-year period after period adds up to 9 years, DOE notes that it may the fact that for some consumer products, the any new standard is promulgated before undertake reviews at any time within the 6 year compliance period is 5 years rather than 3 years. compliance is required, except that in no case may period and that the 3-year compliance date may any new standards be required within 6 years of the yield to the 6-year backstop. A 9-year analysis

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TABLE VII.40—CUMULATIVE ENERGY SAVINGS FOR GSFL TRIAL STANDARD LEVELS FOR UNITS SOLD IN 2017–2025

Trial standard level 1 2 3 4 5

Quads

Primary Energy (Power Sector Consumption) ...... 0.10 0.10 0.42 1.3 1.5 FFC Energy ...... 0.10 0.10 0.44 1.4 1.5

TABLE VII.41—CUMULATIVE ENERGY consumers that would result from the private sector. The 3 percent rate SAVINGS FOR IRL TRIAL STANDARD TSLs considered for GSFLs and IRLs. reflects the potential effects of standards LEVELS FOR UNITS SOLD IN 2017 DOE quantified the costs and benefits on private consumption (e.g., through –2025 attributable to each TSL as the higher prices for product and reduced difference in total product costs and purchases of energy). This rate Trial total operating costs between each represents the rate at which society standard standards case and the base case, discounts future consumption flows to level accounting for the effects of the their present value. It can be standards on product switching and approximated by the real rate of return 1 shipments. on long-term government debt (i.e., In accordance with OMB’s guidelines yield on United States Treasury notes), Quads on regulatory analysis,90 DOE calculated which has averaged about 3 percent for the NPV using both a 7 percent and a Primary Energy (Power Sector the past 30 years. Consumption) ...... 0.008 3 percent real discount rate. The 7 FFC Energy ...... 0.008 percent rate is an estimate of the average Table VII.42 shows the consumer NPV before-tax rate of return on private results for each TSL considered for b. Net Present Value of Consumer Costs capital in the U.S. economy; it reflects GSFLs, and Table VII.43 shows the and Benefits the returns on real estate and small consumer NPV results for each TSL business capital as well as corporate considered for IRL. In each case, the DOE estimated the cumulative NPV of capital. This discount rate approximates impacts cover the lifetime of product the total costs and savings for the opportunity cost of capital in the purchased in 2017–2046.

TABLE VII.42—NET PRESENT VALUE OF CONSUMER BENEFITS FOR GSFL TRIAL STANDARD LEVELS FOR UNITS SOLD IN 2017–2046

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Billion 2012$

7% discount rate ...... ¥0.39 ¥0.48 0.23 3.2 3.1 3% discount rate ...... ¥0.49 ¥0.63 1.0 8.1 8.1

TABLE VII.43—NET PRESENT VALUE TABLE VII.43—NET PRESENT VALUE OF CONSUMER BENEFITS FOR IRL OF CONSUMER BENEFITS FOR IRL TRIAL STANDARD LEVELS FOR UNITS TRIAL STANDARD LEVELS FOR UNITS SOLD IN 2017–2046 SOLD IN 2017–2046—Continued

TSL 1 TSL 1 Billion 2012$ Billion 2012$

7% discount rate ...... 0.18 3% discount rate ...... 0.28

90 OMB Circular A–4, section E (Sept. 17, 2003). Available at: www.whitehouse.gov/omb/circulars_ a004_a-4.

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The NPV results based on the afore- lifetime of product purchased in 2017– indicative of any change in DOE’s mentioned nine-year shipments period 2025. As mentioned previously, this analytical methodology or decision are presented in Table VII.44 and Table information is presented for criteria. VII.45. The impacts are counted over the informational purposes only and is not

TABLE VII.44—NET PRESENT VALUE OF CONSUMER BENEFITS FOR GSFL TRIAL STANDARD LEVELS FOR UNITS SOLD IN 2017–2025

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Billion 2012$

7% discount rate ...... ¥0.26 ¥0.33 0.04 1.1 1.1 3% discount rate ...... ¥0.29 ¥0.39 0.37 2.5 2.7

TABLE VII.45—NET PRESENT VALUE class switching as consumers are earth oxides rises again. As mentioned OF CONSUMER BENEFITS FOR IRL forecasted to continue purchasing the in section V.I, rare earth oxides, used in TRIAL STANDARD LEVELS FOR UNITS less costly and less efficient technology GSFL phosphors to improve lamp SOLD IN 2017–2025 (4 foot MBP). efficiency, underwent a large price spike Because of these assumed shifts in in 2010 and 2011, but their prices have TSL 1 shipments between product classes, the since lowered to almost their pre-spike NES and monetized cost and benefit level. To assess the effect of higher rare Billion 2012$ values computed for a single product earth prices on the impact of energy class, considered in isolation, may yield conservation standards for GSFLs, DOE 7% discount rate ...... 0.13 negative energy savings and associated performed an alternative analysis in 3% discount rate ...... 0.18 benefits as well as negative associated which the average price of rare earth costs . For the proposed standard level, oxides was assumed to be midway c. Impact of Product Class Switching the increased shipments of MiniBP T5 between the peak of the 2011 price As discussed at the beginning of lamps and 8-foot SP slimline lamps will spike and the pre-spike level, and was section VII.B.3, consumer switching lead to negative energy savings and assumed to remain at that elevated level between product classes yields an costs for both of those product classes, throughout the analysis period. The increase in shipments for some GSFL when viewed in isolation, simply details of the price model that DOE used product classes, with corresponding because significantly more lamps from for this analysis are given in appendix reductions in shipments in other those product classes are purchased and 11B of the NOPR TSD. The impacts of product classes (see Table VII.36). operated in the standards case than in the modeled rare earth oxide price Therefore, a portion of the energy the base case. Those negative values, increase on the NES and NPV of this savings for some of the TSLs is due to however, do not represent an actual rulemaking were small to moderate and consumers’ switching between product reduction in consumer benefit for the did not affect the ranking of the TSLs classes to more energy efficient products service being delivered to the consumer (see chapter 12 of the NOPR TSD). with lower operating costs. Similarly, since the negative values for the In the case of IRLs, DOE considered the increase in product costs for some particular product classes are more than the possibility of a significant increase of the TSLs is substantially impacted by offset by the large positive contributions in the price of xenon gas, which DOE product-class switching. For the to the aggregate energy savings and believes is now used as a fill gas in all standard level proposed for GSFL’s in monetized benefits across all product standards-compliant IRL products. this rulemaking, increases in the typical classes partially due to the Demand for xenon gas has been rising cost of 4-foot MBP GSFLs relative to 8- corresponding reduction in shipments recently, which may lead to price foot SP slimline or 4-foot MiniBP T5s is of 4-ft MBP T8s. DOE requests comment increases in the future. To assess the expected to drive some consumers to on the consumer choice model that effect of a significant xenon price shift toward the latter two product projects shifts in shipments between increase on the impact of an energy classes, yielding a reduction in energy product classes and whether there are conservation standard for IRL, DOE consumption relative to the base case, other factors (e.g. utility, costs to replace performed an alternative analysis in with a lower increase in purchase costs light fixtures, design incompatibility) which the price of xenon is assumed to than would be obtained without the that may preclude or limit that shifting increase by a factor of ten in the near product-class switching. Conversely, as that may not be considered in DOE’s future and remain at these elevated is true for TSL1, potential standard level analysis. For informational purposes, levels throughout the analysis period. that increases the typical purchase chapter 12 of the TSD presents NES and The details of the xenon market prices of the latter two product classes NPV values computed for each product assessment used to inform this analysis above would reduce migration to these class individually. are given in appendix 7C of the TSD for product classes, yielding a net reduction the NOPR. The impacts of the modeled d. Alternative Scenario Analyses in the energy savings relative to the base xenon price increase on the NES and case, with a greater increment in As discussed in section VI.I and VI.J, NPV of this rulemaking were minimal product costs. This is true for example DOE conducted several sensitivity and did not affect the ranking of the with TSL1 where the efficiency analyses to determine the potential TSLs (see chapter 12 of the NOPR TSD). requirements are increased for product impact of uncertain future prices for classes which are already relatively materials that are important to the e. Indirect Impacts on Employment efficient (e.g., 4 foot T5 miniBP) while manufacture of efficient GSFL and IRL DOE expects energy conservation not increased for product classes which products. standards for GSFLs and IRLs to reduce are relatively inefficient (e.g., 4 foot In the case of GSFLs, DOE considered energy costs for product owners, and the MBP). In this case, there is no product the possibility that the price of rare resulting net savings to be redirected to

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other forms of economic activity. Those levels are not of lesser utility or amended standards. The Attorney shifts in spending and economic activity performance than products at existing General determines the impact, if any, could affect the demand for labor. As standard levels. DOE considered several of any lessening of competition likely to described in section VI.O, DOE used an characteristics when evaluating utility result from a proposed standard, and input/output model of the U.S. economy and performance of GSFLs including transmits such determination to the to estimate indirect employment physical constraints (i.e., shape and Secretary, together with an analysis of impacts of the TSLs that DOE size), diameter, lumen package, color the nature and extent of such impact. considered in this rulemaking. DOE quality (i.e., CCT and CRI), lifetime, and understands that there are uncertainties ability to dim. DOE determined that To assist the Attorney General in involved in projecting employment these GSFL performance characteristics making such determination, DOE will impacts, especially changes in the later were not diminished for any proposed provide DOJ with copies of the NOPR years of the analysis. Therefore, DOE standard level. For IRLs, DOE and the TSD for review. DOE will generated results for near-term time considered lumen package, lifetime, consider DOJ’s comments on the frames, where these uncertainties are shape, and diameter when evaluating proposed rule in preparing the final reduced. utility and performance. DOE rule, and DOE will publish and respond The results suggest that the proposed determined that these IRL performance to DOJ’s comments in that document. standards are likely to have negligible characteristics were not diminished for impact on the net demand for labor in 6. Need of the Nation To Conserve any proposed standard level. DOE did Energy the economy. The net change in jobs is not assess CRI or CCT for IRLs because so small that it would be imperceptible they are intended as a measure of the Enhanced energy efficiency, where in national labor statistics and might be light quality of non-incandescent/ economically justified, improves the offset by other, unanticipated effects on halogen lamps when compared with nation’s energy security, strengthens the employment. Chapter 17 of the NOPR incandescent/halogen lamps. See economy, and reduces the TSD presents detailed results. section VI.D and chapter 5 of this TSD environmental impacts or costs of 4. Impact on Utility or Performance for further details on the selection of energy production. Reduced electricity more efficacious substitutes for the DOE believes that the standards it is demand due to energy conservation baseline and development of proposed proposing today will not lessen the standards is also likely to reduce the efficacy levels. utility or performance of GSFLs and cost of maintaining the reliability of the IRLs. DOE reached this conclusion DOE requests comment on its electricity system, particularly during based on the analyses conducted to assumption that there will be no peak-load periods. As a measure of this develop the proposed GSFL and IRL lessening of utility or performance such reduced demand, chapter 16 in the efficacy levels. In the engineering that the performance characteristics, NOPR TSD presents the estimated analysis, DOE considered only including physical constraints, reduction in generating capacity for the technology options that would not have diameter, lumen package, color quality, TSLs that DOE considered in this adverse impacts on product utility. See lifetime, and ability to dim, would be rulemaking. section VI.B and chapter 4 of this TSD adversely affected for the GSFL efficacy Energy savings from standards for for further details regarding the levels. Similarly, DOE also requests GSFLs and IRLs could also produce screening analysis. DOE also divided comment on its assumption that there products in to classes based on will be no lessening of utility or environmental benefits in the form of performance-related features that justify performance such that the performance reduced emissions of air pollutants and different standard levels such as those characteristics, including lumen GHGs associated with electricity impacting consumer utility. DOE then package, lifetime, shape, diameter, and production. Table VII.46 and Table developed separate standard levels for light quality, would be adversely VII.47 provide DOE’s estimate of each product class. See section VI.C and affected for the IRL efficacy levels. cumulative emissions reductions projected to result from the TSLs chapter 3 of this TSD for further details 5. Impact of Any Lessening of considered in this rulemaking. DOE regarding product classes selected and Competition consumer utility. reports annual emissions reductions for Further, DOE’s evaluation shows that DOE considers any lessening of each TSL in chapter 14 of the NOPR products meeting proposed efficacy competition that is likely to result from TSD.

TABLE VII.46—CUMULATIVE EMISSIONS REDUCTION ESTIMATED FOR GSFL TRIAL STANDARD LEVELS

Trial standard level 1 2 3 4 5

Power Sector Emissions

CO2 (million metric tons) ...... 9.9 9.7 42 140 160 SO2 (thousand tons) ...... 15 15 64 220 250 NOX (thousand tons) ...... 5.5 5.5 23 78 89 Hg (tons) ...... 0.019 0.019 0.082 0.28 0.32 N2O (thousand tons) ...... 0.16 0.16 0.69 2.4 2.7 CH4 (thousand tons)...... 1.1 1.0 4.5 15 18

Upstream Emissions

CO2 (million metric tons) ...... 0.52 0.51 2.2 7.6 8.6 SO2 (thousand tons) ...... 0.11 0.11 0.48 1.6 1.9 NOX (thousand tons) ...... 7.2 7.0 31 100 120

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TABLE VII.46—CUMULATIVE EMISSIONS REDUCTION ESTIMATED FOR GSFL TRIAL STANDARD LEVELS—Continued

Trial standard level 1 2 3 4 5

Hg (tons) ...... 0.00028 0.00028 0.0012 0.0041 0.0047 N2O (thousand tons) ...... 0.0053 0.0052 0.023 0.077 0.088 CH4 (thousand tons)...... 43 42 180 630 720

Total Emissions

CO2 (million metric tons) ...... 10 10 44 150 170 SO2 (thousand tons) ...... 15 15 65 220 250 NOX (thousand tons) ...... 13 12 54 180 210 Hg (tons) ...... 0.020 0.019 0.083 0.28 0.32 N2O (thousand tons) ...... 0.17 0.16 0.71 2.5 2.8 N2O (thousand tons CO2eq)* ...... 49 48 210 730 830 CH4 (thousand tons)...... 44 43 190 640 730 CH4 (million tons CO2eq)* ...... 1,100 1,100 4,700 16,000 18,000

*CO2eq is the quantity of CO2 that would have the same GWP.

TABLE VII.47—CUMULATIVE EMIS- TABLE VII.47—CUMULATIVE EMIS- average value from a distribution that SIONS REDUCTION ESTIMATED FOR SIONS REDUCTION ESTIMATED FOR uses a 5 percent discount rate), $39.7/ IRL TRIAL STANDARD LEVELS IRL TRIAL STANDARD LEVELS—Con- metric ton (the average value from a tinued distribution that uses a 3 percent Trial stand- discount rate), $61.2/metric ton (the ard level Trial stand- average value from a distribution that ard level uses a 2.5 percent discount rate), and 1 $117/metric ton (the 95th-percentile 1 Power Sector Emissions value from a distribution that uses a 3 percent discount rate). These values NOX (thousand tons) ...... 0.79 CO2 (million metric tons) ...... 0.66 Hg (tons) ...... 0.0012 correspond to the value of emission SO2 (thousand tons) ...... 0.69 N2O (thousand tons) ...... 0.0099 reductions in 2015; the values for later NOX (thousand tons) ...... 0.35 N2O (thousand tons CO2eq)* ..... 2.9 years are higher due to increasing Hg (tons) ...... 0.0012 CH4 (thousand tons) ...... 2.7 damages as the projected magnitude of N2O (thousand tons) ...... 0.0095 CH4 (million tons CO2eq)* ...... 68 climate change increases. CH4 (thousand tons) ...... 0.066 *CO2eq is the quantity of CO2 that would Table VII.48 and Table VII.49 present have the same GWP. Upstream Emissions the global value of CO2 emissions As part of the analysis for this rule, reductions at each TSL. For each of the CO2 (million metric tons) ...... 0.032 DOE estimated monetary benefits likely four cases, DOE calculated a present SO2 (thousand tons) ...... 0.0069 to result from the reduced emissions of value of the stream of annual values NO (thousand tons) ...... 0.45 X CO2 and NOX that DOE estimated for using the same discount rate as was Hg (tons) ...... 0.00002 each of the TSLs considered. As used in the studies upon which the N2O (thousand tons) ...... 0.00033 discussed in section VI.M.1, DOE used dollar-per-ton values are based. DOE CH (thousand tons) ...... 2.7 4 the most recent values for the SCC calculated domestic values as a range Total Emissions developed by an interagency process. from 7 percent to 23 percent of the The four sets of SCC values resulting global values, and these results are CO2 (million metric tons) ...... 0.70 from that process (expressed in 2012$) presented in chapter 15 of the NOPR SO2 (thousand tons) ...... 0.69 represented by $11.8/metric ton (the TSD.

TABLE VII.48—ESTIMATES OF GLOBAL PRESENT VALUE OF CO2 EMISSIONS REDUCTION UNDER GSFL TRIAL STANDARD LEVELS

SCC Case* TSL 2.5% discount 5% discount rate, 3% discount rate, rate, 3% discount rate, average* average* average* 95th percentile*

Billion 2012$

Power Sector Emissions

1 ...... 77 330 520 1,000 2 ...... 76 330 520 1,000 3 ...... 330 1,400 2,200 4,300 4 ...... 1,100 4,700 7,300 14,000 5 ...... 1,200 5,300 8,400 16,000

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TABLE VII.48—ESTIMATES OF GLOBAL PRESENT VALUE OF CO2 EMISSIONS REDUCTION UNDER GSFL TRIAL STANDARD LEVELS—Continued

SCC Case* TSL 2.5% discount 5% discount rate, 3% discount rate, rate, 3% discount rate, average* average* average* 95th percentile*

Upstream Emissions

1 ...... 4.0 17 27 54 2 ...... 4.0 17 27 53 3 ...... 17 74 120 230 4 ...... 57 250 390 760 5 ...... 65 280 450 870

Total Emissions

1 ...... 81 350 550 1,100 2 ...... 80 350 540 1,100 3 ...... 340 1,500 2,300 4,500 4 ...... 1,100 4,900 7,700 15,000 5 ...... 1,300 5,600 8,900 17,000 * For each of the four cases, the corresponding SCC value for emissions in 2015 is $11.8, $39.7, $61.2, and $117 per metric ton (2012$).

TABLE VII.49—ESTIMATES OF GLOBAL PRESENT VALUE OF CO2 EMISSIONS REDUCTION UNDER IRL TRIAL STANDARD LEVELS

SCC Case* TSL 5% discount rate, 3% discount rate, 2.5% discount 3% discount rate, average* average* rate, average* 95th percentile*

Billion 2012$

Power Sector Emissions

1 ...... 5.8 24 37 72

Upstream Emissions

1 ...... 0.28 1.2 1.8 3.5

Total Emissions

1 ...... 6.1 25 39 75 * For each of the four cases, the corresponding SCC value for emissions in 2015 is $11.8, $39.7, $61.2, and $117 per metric ton (2012$).

DOE is well aware that scientific and and other GHG emissions. This ongoing DOE also estimated the cumulative economic knowledge about the review will consider the comments on monetary value of the economic benefits contribution of CO2 and other GHG this subject that are part of the public associated with NOX emissions emissions to changes in the future record for this and other rulemakings, as reductions anticipated to result from global climate and the potential well as other methodological amended standards for GSFLs and IRLs. resulting damages to the world economy assumptions and issues. However, The dollar-per-ton value that DOE used continues to evolve rapidly. Thus, any consistent with DOE’s legal obligations, is discussed in section VI.L. Table value placed on reducing CO2 emissions and taking into account the uncertainty VII.50 and Table VII.51 present the in this rulemaking is subject to change. involved with this particular issue, DOE cumulative present values for each TSL DOE, together with other Federal has included in this proposed rule the calculated using 7 percent and 3 percent agencies, will continue to review most recent values and analyses discount rates. various methodologies for estimating resulting from the interagency process. the monetary value of reductions in CO2

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TABLE VII.50—ESTIMATES OF TABLE VII.51—ESTIMATES OF rulemaking. Table VII.52 presents the PRESENT VALUE OF NOX EMISSIONS PRESENT VALUE OF NOX EMISSIONS NPV values that result from adding the REDUCTION UNDER GSFL TRIAL REDUCTION UNDER IRL TRIAL estimates of the potential economic STANDARD LEVELS STANDARD LEVELS benefits resulting from reduced CO2 and NOX emissions in each of four valuation 3% 7% TSL 3% discount 7% discount scenarios to the NPV of consumer rate rate TSL discount discount savings calculated for each TSL rate rate Million 2012$ considered in this rulemaking, at both a Million 2012$ 7 percent and 3 percent discount rate. Power Sector Emissions The CO2 values used in the columns of Power Sector Emissions 1 ...... 9.6 5.8 each table correspond to the four sets of SCC values discussed above. 2 ...... 9.5 5.8 1 ...... 0.71 0.52 3 ...... 40 24 4 ...... 130 77 5 ...... 150 89 Upstream Emissions Upstream Emissions 1 ...... 0.87 0.61 1 ...... 12 6.9 Total Emissions 2 ...... 12 6.9 3 ...... 50 29 1 ...... 1.6 1.1 4 ...... 170 93 5 ...... 190 110 7. Summary of National Economic Total Emissions Impacts 1 ...... 21 13 The NPV of the monetized benefits 2 ...... 21 13 associated with emissions reductions 3 ...... 90 53 can be viewed as a complement to the 4 ...... 290 170 NPV of the consumer savings calculated 5 ...... 340 200 for each TSL considered in this

TABLE VII.52—NET PRESENT VALUE OF CONSUMER SAVINGS COMBINED WITH PRESENT VALUE OF MONETIZED BENEFITS FROM CO2 AND NOX EMISSIONS REDUCTIONS UNDER GSFL TRIAL STANDARD LEVELS

Consumer NPV at 3% discount rate added with: TSL SCC Case SCC Case SCC Case $11.8/metric ton $39.7/metric ton $61.2/metric ton SCC Case $117/ metric ton CO2* CO2* CO2* CO2*

Billion 2012$

1 ...... ¥0.39 ¥0.12 0.08 0.60 2 ...... ¥0.53 ¥0.27 ¥0.07 0.44 3 ...... 1.5 2.6 3.4 5.7 4 ...... 9.5 13 16 23 5 ...... 9.7 14 17 26

Consumer NPV at 7% discount rate added with:

TSL SCC Case SCC Case SCC Case SCC Case $117/ $11.8/metric ton $39.7/metric ton $61.2/metric ton metric ton CO2* CO2* CO2* CO2*

Billion 2012$

1 ...... ¥0.30 ¥0.03 0.17 0.70 2 ...... ¥0.38 ¥0.12 0.08 0.59 3 ...... 0.63 1.8 2.6 4.8 4 ...... 4.5 8.3 11 18 5 ...... 4.6 9.0 12 21

* These label values represent the global SCC in 2015, in 2012$. For NOX emissions, each case uses the medium value, which corresponds to $2,639 per ton.

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TABLE VII.53—NET PRESENT VALUE OF CONSUMER SAVINGS COMBINED WITH PRESENT VALUE OF MONETIZED BENEFITS FROM CO2 AND NOX EMISSIONS REDUCTIONS UNDER IRL TRIAL STANDARD LEVELS

Consumer NPV at 3% discount rate added with: TSL SCC Case SCC Case SCC Case SCC Case $11.8/metric ton $39.7/metric ton $61.2/metric ton $117/metric ton CO2* CO2* CO2* CO2*

Billion 2012$ 1 ...... 0.29 0.31 0.32 0.36 Consumer NPV at 7% discount rate added with: TSL SCC Case SCC Case SCC Case SCC Case $11.8/metric ton $39.7/metric ton $61.2/metric ton $117/metric ton CO2* CO2* CO2* CO2* Billion 2012$ 1 ...... 0.19 0.20 0.22 0.25

* These label values represent the global SCC in 2015, in 2012$. For NOX emissions, each case uses the medium value, which corresponds to $2,639 per ton.

Although adding the value of factors discussed previously. (42 U.S.C. government intervention. Much of this consumer savings to the values of 6295(o)(2)(B)(i)) The new or amended economics literature attempts to explain emission reductions provides a valuable standard must also ‘‘result in significant why consumers appear to undervalue perspective, two issues should be conservation of energy.’’ (42 U.S.C. energy efficiency improvements. This considered. First, the national operating 6295(o)(3)(B)) undervaluation suggests that regulation cost savings are domestic U.S. consumer DOE considers the impacts of promoting energy efficiency can monetary savings that occur as a result standards at each TSL, beginning with produce significant net private gains (as of market transactions, while the value the max tech level, to determine well as producing social gains by, for of CO2 reductions is based on a global whether that level met the evaluation example, reducing pollution). There is value. Second, the assessments of criteria. Where the max tech level is not evidence that consumers undervalue operating cost savings and the SCC are justified, DOE then considers the next future energy savings as a result of (1) performed with different methods that most efficient level and undertakes the a lack of information, (2) a lack of use different time frames for analysis. same evaluation until it reaches the sufficient savings to warrant The national operating cost savings is highest efficiency level that is accelerating or altering purchases (e.g., measured for the lifetime of product technologically feasible, economically an inefficient ventilation fan in a new shipped in 2017–2046. The SCC values, justified, and saves a significant amount building or the delayed replacement of on the other hand, reflect the present of energy. a water pump), (3) inconsistent value of future climate-related impacts To aid the reader in understanding weighting of future energy cost savings resulting from the emission of one the benefits and/or burdens of each TSL, relative to available returns on other metric ton of CO2 in each year. These Table VII.54 and Table VII.55 in this investments, (4) computational or other impacts continue well beyond 2100. section summarize the quantitative difficulties associated with the analytical results for each TSL, based on evaluation of relevant tradeoffs, and (5) 8. Other Factors the assumptions and methodology a divergence in incentives (e.g., renter The Secretary, in determining discussed herein. The efficacy levels versus owner; builder vs. purchaser). whether a standard is economically contained in each TSL are described in Other literature indicates that with less- justified, may consider any other factors section VI.D. In addition to the than-perfect foresight and a high degree that the Secretary deems to be relevant. quantitative results presented in the of uncertainty about the future, it may (42 U.S.C. 6295(o)(2)(B)(i)) No other tables, DOE also considers other be rational for consumers to trade off factors were considered in this analysis. burdens and benefits that affect these types of investments at a higher- economic justification. These include than-expected rate between current C. Proposed Standards the impacts on identifiable subgroups of consumption and uncertain future When considering proposed consumers who may be energy cost savings. Some studies standards, the new or amended energy disproportionately affected by a national suggest that this seeming conservation standard that DOE adopts standard (see section VI.H), and impacts undervaluation may be explained in for any type (or class) of covered on employment. DOE discusses the certain circumstances by differences product must be designed to achieve the impacts on employment in GSFL and between tested and actual energy maximum improvement in energy IRL manufacturing in section VII.B.2.b, savings, or by uncertainty and efficiency that the Secretary determines and discusses the indirect employment irreversibility of energy investments. is technologically feasible and impacts in section VI.O. There may also be ‘‘hidden’’ welfare economically justified. (42 U.S.C. As discussed in previous DOE losses to consumers if newer energy 6295(o)(2)(A)) In determining whether a standards rulemakings and the February efficient products are imperfect standard is economically justified, the 2011 NODA (76 FR 9696, Feb. 22, 2011), substitutes for the less efficient products Secretary must determine whether the DOE also notes that economics literature they replace, in terms of performance or benefits of the standard exceed its provides a wide-ranging discussion of other attributes that consumers value. In burdens, considering to the greatest how consumers trade off upfront costs the abstract, it may be difficult to say extent practicable the seven statutory and energy savings in the absence of how a welfare gain from correcting

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potential under-investment in energy potential for both welfare gains and to meet the standards in this proposed conservation compares in magnitude to losses and move toward a fuller rule that might affect the welfare, the potential welfare losses associated economic framework where all relevant positively or negatively, of consumers with no longer purchasing a machine or changes can be quantified.91 While DOE who purchase these lamps. switching to an imperfect substitute, is not prepared at present to provide a both of which still exist in this fuller quantifiable framework for this 1. Benefits and Burdens of Trial framework. discussion, DOE seeks comments on Standard Levels Considered for General The mix of evidence in the empirical how to assess these possibilities.92 In Service Fluorescent Lamps economics literature suggests that if particular, DOE requests comment on feasible, analysis of regulations whether there are features or attributes Table VII.54 and Table VII.55 mandating energy-efficiency of the more energy efficient GSFLs and summarize the quantitative impacts improvements should explore the IRLs that manufacturers would produce estimated for each TSL for GSFL.

TABLE VII.54—SUMMARY OF ANALYTICAL RESULTS FOR GSFL: NATIONAL IMPACTS

Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

National FFC Energy Savings quads 0.21 0.21 0.89 3.0 3.5 NPV of Consumer Benefits 2012$ billion 3% discount rate ...... ¥0.49 ¥0.63 1.0 8.1 8.1 7% discount rate ...... ¥0.39 ¥0.48 0.23 3.2 3.1 Cumulative Emissions Reduction (Total FFC Emissions)

CO2 (million metric tons) ...... 10 10 44 150 170 SO2 (thousand tons) ...... 15 15 65 220 250 NOX (thousand tons) ...... 13 12 54 180 210 Hg (tons) ...... 0.020 0.019 0.083 0.28 0.32 N2O (thousand tons) ...... 0.17 0.16 0.71 2.5 2.8 N2O (thousand tons CO2eq) * ...... 49 48 210 730 830 CH4 (thousand tons) ...... 44 43 190 640 730 CH4 (million tons CO2eq) * ...... 1,100 1,100 4,700 16,000 18,000 Value of Emissions Reduction (Total FFC Emissions)

CO2 2012$ million ** ...... 82 to 1,100 80 to 1,100 340 to 4,500 1,100 to 15,000 1,300 to 17,000 NOX—3% discount rate, 2012$ million ...... 21 21 90 290 340 NOX—7% discount rate, 2012$ million ...... 13 13 53 170 200

*CO2eq is the quantity of CO2 that would have the same GWP. ** Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 emissions.

TABLE VII.55—SUMMARY OF ANALYTICAL RESULTS FOR GSFL: MANUFACTURER AND CONSUMER IMPACTS

Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Manufacturer Impacts

Change in Industry NPV (2012$ million)† ...... 41.8—(0.9) 37.8—(9.2) 120.5—(11.5) 358.5—(22.9) 397.1—(39.9) Change in Industry NPV (%)† ...... 2.7—(0.1) 2.5—(0.6) 7.8—(0.7) 23.2—(1.5) 25.7—(2.6)

Consumer Mean LCC Savings 2012$

4-foot MBP ≤4,500 K...... 0.00 0.00 0.54 3.14 3.14 4-foot T5 MiniBP SO ≤4,500 K...... 2.33 2.33 2.33 2.33 2.76 4-foot T5 MiniBP HO ≤4,500 K...... 2.28 2.28 2.28 2.28 2.28 8-foot SP Slimline ≤4,500 K...... 0.00 6.88 0.00 0.00 2.08 8-foot RDC HO ≤4,500 K ...... ¥9.56 ¥16.76 ¥9.56 ¥9.56 ¥16.76 Weighted Average* ...... ¥0.68 ¥1.00 ¥0.22 1.77 1.43

Consumer Mean PBP years**

4-foot MBP ≤4,500 K ...... 0.0 0.0 0.6 3.6 3.6 4-foot T5 MiniBP SO ≤4,500 K ...... 1.2 1.2 1.2 1.2 4.3 4-foot T5 MiniBP HO ≤4,500 K ...... 3.0 3.0 3.0 3.0 3.0 8-foot SP Slimline ≤4,500 K ...... 0.0 0.6 0.0 0.0 4.5 8-foot RDC HO ≤4,500 K...... NER NER NER NER NER Weighted Average* ...... 0.1 0.1 0.6 3.2 3.7 Weighted Average Customers with Net Cost (%)* ...... 9.5 11.5 59.5 29.4 34.5

91 A good review of the literature related to this Efficiency Policy: Pipe Dream or Pipeline to the Choice,’’ proposes a broad theoretical framework on issue can be found in Gillingham, K., R. Newell, K. Future?’’ Review of Environmental Economics and which an empirical model might be based and is Palmer. (2009). ‘‘Energy Efficiency Economics and Policy. Vol. 3, No. 2: 304–320. posted on the DOE Web site along with this notice Policy,’’ Annual Review of Resource Economics, 1: 92 A draft paper, ‘‘Notes on the Economics of at www.eere.energy.gov/buildings/appliance_ 597–619; and Tietenberg, T. (2009). ‘‘Energy Household Energy Consumption and Technology standards.

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TABLE VII.55—SUMMARY OF ANALYTICAL RESULTS FOR GSFL: MANUFACTURER AND CONSUMER IMPACTS—Continued

Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

Weighted Average Customers with Net Benefit (%)* ...... 1.1 2.6 36.0 60.4 65.5 Weighted Average Customers with No Impact (%)* ...... 89.4 85.8 4.5 10.2 0.0 * Weighted by shares of each product class in total projected shipments in 2017. ** Does not include weighting for ‘‘NER’’ scenarios. Entries of ‘‘NER’’ indicate standard levels that do not reduce operating costs, which pre- vents the consumer from recovering the increased purchase cost. † Values in parentheses are negative values.

First, DOE considered TSL 5, the most SO lamps, $2.28 for the 4-foot T5 (as indicated by positive average LCC efficient level (max tech), which would MiniBP HO lamps, $2.08 for the 8-foot savings, favorable PBPs, and the large save an estimated total of 3.5 quads of SP slimline lamps, and ¥$16.76 for the percentage of consumers who would energy, an amount DOE considers 8-foot RDC HO lamps. experience LCC benefits), emission significant. TSL 5 has an estimated NPV At TSL 5, the projected change in reductions and the estimated monetary of consumer benefit of $3.1 billion using INPV ranges from a decrease of $39.9 value of the emissions reductions would a 7 percent discount rate, and $8.1 million to an increase of $397.1 million. outweigh the potential reduction in billion using a 3 percent discount rate. If the decrease is realized, TSL 5 could industry value, and increase in LCCs The cumulative emissions reductions result in a net loss of up to 2.6 percent experienced by certain consumers at at TSL 5 are 170 million metric tons of in INPV to manufacturers of covered TSL 5. The Secretary has concluded that CO , 210 thousand tons of NO , 250 GSFLs. Also at TSL 5, DOE estimates 2 X TSL 5 would save a significant amount thousand tons of SO2, 0.32 tons of Hg, industry will need to invest of energy and is technologically feasible 730 thousand tons of CH4, and 2.8 approximately $38.6 million in and economically justified. thousand tons of N2O. The estimated conversion costs. monetary value of the CO2 emissions After considering the analysis and Based on the above considerations, reductions at TSL 5 ranges from $1,300 weighing the benefits and the burdens, DOE today proposes to adopt the energy million to $17,000 million. DOE has tentatively concluded that, at conservation standards for GSFL at TSL At TSL 5, the weighted average LCC TSL 5 for GSFL, the benefits of energy 5. Table VII.56 presents the proposed savings is $3.14 for the 4-foot MBP savings, positive NPV of total consumer energy conservation standards for GSFL. lamps, $2.76 for the 4-foot T5 MiniBP benefits, positive impacts on consumers

TABLE VII.56—PROPOSED ENERGY CONSERVATION STANDARDS FOR GSFL

CCT Proposed level Lamp type K lm/W

4-Foot Medium Bipin ...... ≤4,500 92.4 >4,500 90.6 2-Foot U-Shaped ...... ≤4,500 86.9 >4,500 84.3 8-Foot Slimline ...... ≤4,500 99.0 >4,500 94.1 8-Foot High Output ...... ≤4,500 97.6 >4,500 95.6 4-Foot Miniature Bipin Standard Output ...... ≤4,500 97.1 >4,500 91.3 4-Foot Miniature Bipin High Output ...... ≤4,500 82.7 >4,500 78.6

2. Summary of Benefits and Costs emission reductions, including CO2 GSFL are shown in Table VII.57. The (Annualized) of the Proposed Standards emission reductions.93 results under the primary estimate are for General Service Fluorescent Lamps Estimates of annualized benefits and as follows. Using a 7-percent discount costs of the proposed standards for rate for benefits and costs other than The benefits and costs of today’s proposed standards, for product sold in CO2 reduction, for which DOE used a 3- 93 DOE used a two-step calculation process to percent discount rate along with the 2017–2046, can also be expressed in convert the time-series of costs and benefits into terms of annualized values. The annualized values. First, DOE calculated a present average SCC series that uses a 3-percent annualized monetary values are the sum value in 2013, the year used for discounting the discount rate, the cost of the standards of (1) the annualized national economic NPV of total consumer costs and savings, for the proposed in today’s rule is $873 million time-series of costs and benefits using discount per year in increased product costs; value of the benefits from consumer rates of 3 and 7 percent for all costs and benefits operation of product that meet the except for the value of CO2 reductions. For the while the estimated benefits are $1,180 proposed standards (consisting latter, DOE used a range of discount rates. From the million per year in reduced product present value, DOE then calculated the fixed annual operating costs, $314 million per year in primarily of operating cost savings from payment over a 30-year period (2017 through 2046) using less energy, minus increases in that yields the same present value. The fixed annual CO2 reductions, and $19.3 million per product purchase and installation costs, payment is the annualized value. Although DOE year in reduced NOX emissions. In this which is another way of representing calculated annualized values, this does not imply case, the net benefit would amount to that the time-series of cost and benefits from which consumer NPV), and (2) the annualized the annualized values were determined is a steady $642 million per year. Using a 3-percent monetary value of the benefits of stream of payments. discount rate for all benefits and costs

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and the average SCC series, the while the estimated benefits are $1,200 in reduced NOX emissions. In this case, estimated cost of the standards million per year in reduced operating the net benefit would amount to proposed in today’s rule is $751 million costs, $314 million per year in CO2 approximately $783 million per year. per year in increased product costs; reductions, and $18.9 million per year

TABLE VII.57—ANNUALIZED BENEFITS AND COSTS OF PROPOSED STANDARDS FOR GSFL (TSL 5)

Low net benefits High net benefits Discount rate Primary estimate * estimate * estimate *

...... Million 2012$/year

Benefits

Operating Cost Savings ...... 7% ...... 1,180 ...... 1,160 ...... 1,220 3% ...... 1,200 ...... 1,170 ...... 1,250 CO2 Reduction Monetized Value ($11.8/t case) ** ...... 5% ...... 98 ...... 98 ...... 98 CO2 Reduction Monetized Value ($39.7/t case) ** ...... 3% ...... 314 ...... 314 ...... 314 CO2 Reduction Monetized Value ($61.2/t case) ** ...... 2.5% ...... 456 ...... 456 ...... 456 CO2 Reduction Monetized Value ($117/t case) ** ...... 3% ...... 968 ...... 968 ...... 968 NOX Reduction Monetized Value (at $2,639/ton) ** ..... 7% ...... 19.3 ...... 19.3 ...... 19.3 3% ...... 18.9 ...... 18.9 ...... 18.9 Total Benefits † ...... 7% plus CO2 range 1,300 to 2,160 ...... 1,280 to 2,140 ...... 1,340 to 2,210 7% ...... 1,520 ...... 1,490 ...... 1,560 3% plus CO2 range 1,320 to 2,180 ...... 1,290 to 2,160 ...... 1,370 to 2,230 3% ...... 1,530 ...... 1,510 ...... 1,580

Costs

Incremental Product Costs ...... 7% ...... 873 ...... 910 ...... 873 3% ...... 751 ...... 785 ...... 751

Net Benefits

Total † ...... 7% plus CO2 range 426 to 1,291 ...... 367 to 1,232 ...... 469 to 1,330 7% ...... 642 ...... 583 ...... 685 3% plus CO2 range 567 to 1,432 ...... 505 to 1,370 ...... 615 to 1,480 3% ...... 783 ...... 722 ...... 831 * This table presents the annualized costs and benefits associated with GSFLs shipped in 2017–2046. These results include benefits to con- sumers which accrue after 2046 from the products purchased in 2017–2046. The results account for the incremental variable and fixed costs in- curred by manufacturers due to the standard, some of which may be incurred in preparation for the rule. The Primary Benefits Estimate assumes the central energy prices from AEO2013 and a decreasing incremental product cost, due to price learning. The Low Benefits Estimate assumes the low estimate of energy prices from AEO2013 and constant real product prices. The High Benefits Estimate assumes the high energy price estimates from AEO2013 and decreasing incremental product costs, due to price learning. ** The CO2 values represent global monetized values of the SCC, in 2012$, in 2015 under several scenarios of the updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 3%, and 2.5% discount rates, respectively. The fourth case rep- resents the 95th percentile of the SCC distribution calculated using a 3% discount rate. The SCC time series used by DOE incorporate an esca- lation factor. The value for NOX is the average of the low and high values used in DOE’s analysis. † Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to average SCC with 3-percent discount rate. In the rows labeled ‘‘7% plus CO2 range’’ and ‘‘3% plus CO2 range,’’ the operating cost and NOX benefits are calculated using the labeled discount rate, and those values are added to the full range of CO2 values.

3. Benefits and Burdens of Trial estimated for the potential IRL Standard Levels Considered for standards. Incandescent Reflector Lamps Table VII.58 and Table VII.59 summarize the quantitative impacts

TABLE VII.58—SUMMARY OF ANALYTICAL RESULTS FOR IRL: NATIONAL IMPACTS

Category TSL 1

National FFC Energy Savings Quads

0.013

NPV of Consumers Benefits 2012$ Billion

3% discount rate ...... 0.28 7% discount rate ...... 0.18

Cumulative Emissions Reduction (Total FFC Emissions)

CO2 (million metric tons) ...... 0.70 SO2 (thousand tons) ...... 0.69

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TABLE VII.58—SUMMARY OF ANALYTICAL RESULTS FOR IRL: NATIONAL IMPACTS—Continued

Category TSL 1

NOX (thousand tons) ...... 0.79 Hg (tons) ...... 0.0012 N2O (thousand tons) ...... 0.0099 N2O (thousand tons CO2eq) * ...... 2.9 CH4 (thousand tons) ...... 2.7 CH4 (thousand tons CO2eq) * ...... 68

Value of Emissions Reduction (Total FFC Emissions)

CO2 2012$ million ** ...... 6.1 to 75 NOX—3% discount rate 2012$ million ...... 1.6 NOX—7% discount rate 2012$ million ...... 1.1

*CO2eq is the quantity of CO2 that would have the same GWP. ** Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 emissions.

TABLE VII.59—SUMMARY OF ANALYTICAL RESULTS FOR IRL: MANUFACTURER AND CONSUMER IMPACTS

Category TSL 1

Manufacturer Impacts

Change in Industry NPV 2012$ million ** ...... (47.5) – (51.8) Change in Industry NPV % ** ...... (27.0) – (29.5)

Consumer Mean LCC Savings * 2012$

Standard spectrum; >2.5 inch diameter; <125 V ...... 2.95

Consumer Mean PBP * years

Standard spectrum; >2.5 inch diameter; <125 V ...... 5.4 Consumers with Net Cost % ...... 0.0 Consumers with Net Benefit % ...... 100.0 Consumers with No Impact % ...... 0.0 * Weighted by shares of each equipment class in total projected shipments in 2017. ** Values in parentheses are negative values.

DOE considered TSL 1, which would At TSL 1, the weighted average LCC DOE concludes that, at TSL 1 for IRLs, save an estimated total of 0.013 quads savings for the standard spectrum, > 2.5 the benefits of energy savings, positive of energy, an amount DOE considers inch diameter, < 125 V product class is NPV of consumer benefits, positive significant. TSL 1 has an estimated NPV $2.95. The LCC savings were positive impacts on consumers (as indicated by of consumer benefit of $0.18 billion for both representative lamp units in positive average LCC savings and the using a 7 percent discount rate, and each sector. large percentage of consumers who $0.28 billion using a 3 percent discount At TSL 1, the projected change in would experience LCC benefits), rate. INPV ranges from a decrease of $51.8 emission reductions and the estimated million to decrease of $47.5 million. If monetary value of the emissions The cumulative emissions reductions the larger decrease is realized, TSL 1 reductions would outweigh the at TSL 1 are 0.70 million metric tons of could result in a net loss of up to 29.5 potential reduction in industry value. CO2, 0.79 thousand tons of NOX, 0.69 percent in INPV to manufacturers of Consequently, DOE has concluded that thousand tons of SO2, 0.0012 tons of Hg, covered IRLs. Also at TSL 1, DOE TSL 1 is economically justified. 2.7 thousand tons of CH4, and 0.0099 estimates industry would need to invest Based on the above considerations, thousand tons of N2O. The estimated approximately $71.5 million in DOE today proposes to adopt the energy monetary value of the CO2 emissions conversion costs. conservation standards for IRL at TSL 1. reductions at TSL 1 ranges from $6.1 After considering the analysis and Table VII.60 presents the proposed million to $75 million. weighing the benefits and the burdens, energy conservation standards for IRL.

TABLE VII.60—PROPOSED ENERGY CONSERVATION STANDARDS FOR IRL

Diameter Voltage Proposed level Lamp type inches V lm/W

Standard Spectrum ...... 40 W¥205 W ...... >2.5 ≥125 7.1P0.27 <125 6.2P0.27 ≤2.5 ≥125 6.0P0.27 <125 5.2P0.27

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TABLE VII.60—PROPOSED ENERGY CONSERVATION STANDARDS FOR IRL—Continued

Diameter Voltage Proposed level Lamp type inches V lm/W

Modified Spectrum ...... 40 W¥205 W ...... >2.5 ≥125 6.0P0.27 <125 5.2P0.27 ≤2.5 ≥125 5.1P0.27 <125 4.4P0.27

4. Summary of Benefits and Costs emission reductions, including CO2 CO2 reductions, and $0.11 million per (Annualized) of the Proposed Standards emission reductions. year in reduced NOX emissions. In this for Incandescent Reflector Lamps Estimates of annualized benefits and case, the net benefit would amount to costs of the proposed standards for IRL $19 million per year. Using a 3-percent The benefits and costs of today’s are shown in Table VII.61. The results discount rate for all benefits and costs proposed standards for IRL, for product under the primary estimate are as and the average SCC series, the sold in 2017–2046, can also be follows. Using a 7-percent discount rate estimated annualized incremental expressed in terms of annualized values. for benefits and costs other than CO2 equipment cost of the standards The annualized monetary values are the reduction, for which DOE used a 3- proposed in today’s rule is negative $9.7 sum of (1) the annualized national percent discount rate along with the million per year,94 and the annualized economic value of the benefits from average SCC series that uses a 3-percent consumer operation of product that discount rate, the annualized benefits of the standards proposed in meet the proposed standards (consisting incremental equipment cost of the today’s rule are $5.9 million per year in primarily of operating cost savings from standards proposed in today’s rule is reduced operating costs, $1.4 million using less energy, minus increases in negative $10.4 million per year,94 and per year in CO2 reductions, and $0.09 product purchase and installation costs, the annualized benefits of the standards million per year in reduced NOX which is another way of representing proposed in today’s rule are $7.2 emissions. In this case, the net benefit consumer NPV), and (2) the annualized million per year in reduced product would amount to approximately $17 monetary value of the benefits of operating costs, $1.4 million per year in million per year.

TABLE VII.61—ANNUALIZED BENEFITS AND COSTS OF PROPOSED STANDARDS FOR IRL (TSL 1)

Low net High net Discount rate Primary estimate* benefits benefits estimate* estimate*

...... Million 2012$/year

Benefits

Operating Cost Savings ...... 7% ...... 7.2 ...... 7.1 ...... 10 3% ...... 5.9 ...... 5.8 ...... 5.8 CO2 Reduction Monetized Value ($11.8/t case)** 5% ...... 0.5 ...... 0.5 ...... 0.5 CO2 Reduction Monetized Value ($39.7/t case)** 3% ...... 1.4 ...... 1.4 ...... 1.4 CO2 Reduction Monetized Value ($61.2/t case)** 2.5% ...... 2.0 ...... 2.0 ...... 2.0 CO2 Reduction Monetized Value ($117/t case)* 3% ...... 4.2 ...... 4.2 ...... 4.2 NOX Reduction Monetized Value (at $2,639/ 7% ...... 0.11 ...... 0.11 ...... 0.16 ton)**. 3% ...... 0.09 ...... 0.09 ...... 0.09 Total Benefits † ...... 7% plus CO2 range ...... 7.8 to 12 ...... 7.7 to 11 ...... 7.8 to 12 7% ...... 8.7 ...... 8.6 ...... 8.7 3% plus CO2 range ...... 6.4 to 10 ...... 6.4 to 10 ...... 6.4 to 10 3% ...... 7.4 ...... 7.3 ...... 7.3

Costs

Incremental Product Costs ‡ ...... 7% ...... ¥10.4 ...... ¥10.5 ...... ¥10.4 3% ...... ¥9.7 ...... ¥9.8 ...... ¥9.7

Net Benefits

Total † ...... 7% plus CO2 range ...... 18 to 22 ...... 18 to 22 ...... 18 to 22 7% ...... 19 ...... 19 ...... 19 3% plus CO2 range ...... 16 to 20 ...... 16 to 20 ...... 16 to 20

94 This represents a reduction in product costs efficacious products have substantially longer lifetimes than the products that would be compared to the base case, because the more eliminated by the proposed standard.

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TABLE VII.61—ANNUALIZED BENEFITS AND COSTS OF PROPOSED STANDARDS FOR IRL (TSL 1)—Continued

Low net High net Discount rate Primary estimate* benefits benefits estimate* estimate*

3% ...... 17 ...... 17 ...... 17 * This table presents the annualized costs and benefits associated with IRLs shipped in 2017–2046. These results include benefits to con- sumers which accrue after 2046 from the products purchased in 2017–2046. The results account for the incremental variable and fixed costs in- curred by manufacturers due to the standard, some of which may be incurred in preparation for the rule. The Primary Benefits Estimate assumes the central energy prices from AEO2013 and a decreasing incremental product cost, due to price learning. The Low Benefits Estimate assumes the low estimate of energy prices from AEO2013 and constant real product prices. The High Benefits Estimate assumes the high energy price estimates from AEO2013 and decreasing incremental product costs, due to price learning. ** The CO2 values represent global monetized values of the SCC, in 2012$, in 2015 under several scenarios of the updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 3%, and 2.5% discount rates, respectively. The fourth case rep- resents the 95th percentile of the SCC distribution calculated using a 3% discount rate. The SCC time series used by DOE incorporate an esca- lation factor. The value for NOX is the average of the low and high values used in DOE’s analysis. † Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to average SCC with 3-percent dis- count rate. In the rows labeled ‘‘7% plus CO2 range’’ and ‘‘3% plus CO2 range,’’ the operating cost and NOX benefits are calculated using the la- beled discount rate, and those values are added to the full range of CO2 values. ‡ This reduction in product costs occurs because the more efficacious products have substantially longer lifetimes than the products that would be eliminated by the proposed standard.

VIII. Procedural Issues and Regulatory documents prepared for this to use the best available techniques to Review rulemaking, including the RIA, and has quantify anticipated present and future included these documents in the benefits and costs as accurately as A. Review Under Executive Orders rulemaking record. The assessments possible. In its guidance, the Office of 12866 and 13563 prepared pursuant to Executive Order Information and Regulatory Affairs has Section 1(b)(1) of Executive Order 12866 can be found in the technical emphasized that such techniques may 12866, ‘‘Regulatory Planning and support document for this rulemaking. include identifying changing future Review,’’ 58 FR 51735 (Oct. 4, 1993), DOE has also reviewed this regulation compliance costs that might result from requires each agency to identify the pursuant to Executive Order 13563, technological innovation or anticipated problem that it intends to address, issued on January 18, 2011 (76 FR 3281, behavioral changes. In this NOPR, DOE including, where applicable, the failures Jan. 21, 2011). EO 13563 is has taken particular note of the potential of private markets or public institutions supplemental to and explicitly reaffirms for future volatility in the price of rare that warrant new agency action, as well the principles, structures, and earth oxides used in the manufacture of as to assess the significance of that definitions governing regulatory review GSFLs as it affects the future costs and problem. The problems that today’s established in Executive Order 12866. benefits of the proposed standard. DOE standards address are as follows: To the extent permitted by law, agencies plans to pursue a retrospective review of (1) There is a lack of consumer are required by Executive Order 13563 rare earth prices as input for any future information and/or information to: (1) Propose or adopt a regulation updates to GSFL standards. For the processing capability about energy only upon a reasoned determination reasons stated in the preamble, DOE efficiency opportunities in the lighting that its benefits justify its costs believes that today’s NOPR is consistent market. (recognizing that some benefits and with these with the principles laid out (2) There is asymmetric information costs are difficult to quantify); (2) tailor in Executive Order 13563, including the (one party to a transaction has more and regulations to impose the least burden requirement that, to the extent better information than the other) and/ on society, consistent with obtaining permitted by law, benefits justify costs or high transactions costs (costs of regulatory objectives, taking into and that net benefits are maximized. gathering information and effecting account, among other things, and to the exchanges of goods and services). extent practicable, the costs of B. Review Under the Regulatory (3) There are external benefits cumulative regulations; (3) select, in Flexibility Act resulting from improved energy choosing among alternative regulatory The Regulatory Flexibility Act (5 efficiency of GSFLs and IRLs that are approaches, those approaches that U.S.C. 601 et seq.) requires preparation not captured by the users of such maximize net benefits (including of an initial regulatory flexibility equipment. These benefits include potential economic, environmental, analysis (IRFA) for any rule that by law externalities related to environmental public health and safety, and other must be proposed for public comment, protection and energy security that are advantages; distributive impacts; and unless the agency certifies that the rule, not reflected in energy prices, such as equity); (4) to the extent feasible, specify if promulgated, will not have a reduced emissions of GHGs. performance objectives, rather than significant economic impact on a In addition, DOE has determined that specifying the behavior or manner of substantial number of small entities. As today’s regulatory action is an compliance that regulated entities must required by Executive Order 13272, ‘‘economically significant regulatory adopt; and (5) identify and assess ‘‘Proper Consideration of Small Entities action’’ under section 3(f)(1) of available alternatives to direct in Agency Rulemaking,’’ 67 FR 53461 Executive Order 12866. Accordingly, regulation, including providing (August 16, 2002), DOE published section 6(a)(3) of the Executive Order economic incentives to encourage the procedures and policies on February 19, requires that DOE prepare a regulatory desired behavior, such as user fees or 2003, to ensure that the potential impact analysis (RIA) on today’s rule marketable permits, or providing impacts of its rules on small entities are and that the Office of Information and information upon which choices can be properly considered during the Regulatory Affairs (OIRA) in OMB made by the public. rulemaking process. 68 FR 7990. DOE review this rule. DOE presented to OIRA DOE emphasizes as well that has made its procedures and policies for review the draft rule and other Executive Order 13563 requires agencies available on the Office of the General

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Counsel’s Web site (http://energy.gov/ SBA’s definition of a small business the five IRL small business gc/office-general-counsel). manufacturer of GSFLs or IRLs. DOE manufacturers. The remaining three As a result of this review, DOE has screened out companies that do not declined DOE’s request to be prepared an IRFA for GSFLs and IRLs, offer products covered by this interviewed for this rulemaking. DOE a copy of which DOE will transmit to rulemaking, do not meet the definition also obtained information about small the Chief Counsel for Advocacy of the of a ‘‘small business,’’ or are completely business manufacturers and potential Small Business Administration (SBA) foreign owned and operated. impacts on small businesses while for review under 5 U.S.C. 605(b). As For GSFLs, DOE initially identified a interviewing large manufacturers. presented and discussed below, the total of 47 potential companies that sell GSFLs in the United States. After c. General Service Fluorescent Lamp IFRA describes potential impacts on and Incandescent Reflector Lamp GSFL and IRL manufacturers and reviewing publicly available information on these potential GSFL Industry Structures and Nature of discusses alternatives that could Competition minimize these impacts. manufacturers, DOE determined that 26 A statement of the objectives of, and were either large manufacturers, Three major manufacturers supply reasons and legal basis for, the proposed manufacturers that were completely approximately 90 percent of the GSFL rule are set forth elsewhere in the foreign owned and operated, or did not market. None of these three major GSFL preamble and not repeated here. sell GSFLs covered by this rulemaking. manufacturers are small businesses. DOE then contacted the remaining 21 DOE estimates that the remaining 10 1. Description and Estimated Number of GSFL companies to determine whether percent of the GSFL market is served by Small Entities Regulated they met SBA’s definition of a small either small businesses or a. Methodology for Estimating the business and whether they manufacturers that are completely Number of Small Entities manufactured or sold GSFLs that would foreign owned and operated. No small be affected by today’s proposal. Based business has more than a three percent For manufacturers of GSFLs and IRLs, on these efforts, DOE estimated that market share in the GSFL industry. the SBA has set a size threshold, which there are 21 small businesses that either Similarly in the IRL market, the same defines those entities classified as manufacture or sell covered GSFLs in three major GSFL manufacturers supply ‘‘small businesses’’ for the purposes of the United States. approximately 80 percent of the IRL the statute. DOE used the SBA’s small For IRLs, DOE initially identified a market. Again, none of these three major business size standards to determine total of 37 potential companies that sell IRL manufacturers is a small business. whether any small entities would be IRLs in the United States. After DOE estimates that the remaining 20 subject to the requirements of the rule. reviewing publicly available percent of the IRL market is served by 65 FR 30836, 30848 (May 15, 2000), as information on these potential IRL either small businesses or amended at 65 FR 53533, 53544 (Sept. manufacturers, DOE determined that 22 manufacturers that are completely 5, 2000) and codified at 13 CFR part were either large manufacturers, foreign owned and operated. No small 121. The size standards are listed by manufacturers that were completely business has more than three percent of North American Industry Classification foreign owned and operated, or did not the IRL market individually. Small System (NAICS) code and industry sell IRLs covered by this rulemaking. businesses that sell covered GSFLs and description available at: http:// DOE then contacted the remaining 15 IRLs tend to be companies that www.sba.gov/content/table-small- IRL companies to determine whether outsource the manufacturing to overseas business-size-standards. GSFL and IRL they met SBA’s definition of a small companies who produce the lamps manufacturing is classified under business and whether they specified by the small businesses. These NAICS code 335110, ‘‘Electric Lamp manufactured or sold IRLs that would small businesses provide the Bulb and Part Manufacturing.’’ The SBA be affected by today’s proposal. Based specifications for these lamps as well as sets a threshold of 1,000 employees or on these efforts, DOE estimated that the testing and certification to comply less for an entity to be considered as a there are 15 small businesses that either with any U.S. energy conservation small business for this category. manufacture or sell covered IRLs in the standards. To estimate the number of companies United States. that could be small business d. Comparison Between Large and Small manufacturers of GSFLs and IRLs b. Manufacturer Participation Entities covered by this rulemaking, DOE DOE contacted all 21 identified GSFL For GSFLs and IRLs, small businesses conducted a market survey using small businesses to invite them to take differ from large manufacturers in publicly available information. DOE’s part in a small business MIA interview. several ways that directly affect the research involved industry trade Of the GSFL manufacturers DOE extent to which a company would be association membership directories contacted, eight responded to DOE’s impacted by any potential energy (including NEMA), information from email and phone communications and conservation standards. The main previous rulemakings, individual 13 did not. DOE was able to reach and differences between small and large company Web sites, SBA’s database, discuss potential standards with two of entities for this rulemaking are that and market research tools (e.g., Hoover’s the eight GSFL small business small manufacturers of GSFLs and IRLs reports). DOE also asked stakeholders manufacturers that responded. The have lower sales volumes and are and industry representatives if they remaining six declined DOE’s request to frequently not the original were aware of any small manufacturers be interviewed for this rulemaking. DOE manufacturers of GSFLs and IRLs. during manufacturer interviews and also contacted all 15 identified IRL Therefore, these small businesses would DOE public meetings. DOE used small businesses to invite them to take not have any capital conversion costs to information from these sources to create part in a small business MIA interview. comply with amended standards, since a list of companies that potentially Of the IRL manufacturers DOE the machinery used to produce GSFLs manufacture or sell GSFLs or IRLs and contacted, five responded to DOE’s and IRLs is owned and operated by would be impacted by this rulemaking. email and phone communications and overseas manufacturers. The small As necessary, DOE contacted companies 10 did not. DOE was able to reach and businesses would most likely to determine whether they met the discuss potential standards with two of experience higher per-unit costs for the

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products if the conversion costs at higher efficacy levels. If the small represent a significant portion of a small experienced by the overseas business is not the original lamp business’ annual revenue. However, manufacturers are passed through to the manufacturer, the manufacturer that unlike large manufacturers, small small businesses, potentially reducing sells to the small business would have businesses will most likely not incur those small business’ manufacturer to purchase this equipment. Therefore, any capital conversion costs due to markups and profits. Small businesses undifferentiated small businesses would amended standards because small would also have product conversion face a greater per-unit cost penalty businesses usually do not own and costs associated with testing and because they must spread the operate the machinery used to certifying any lamps that would need to conversion costs over fewer units. While manufacture the covered lamps. The be redesigned due to standards. small businesses may not be directly capital conversion costs incurred by Typically the testing and certification paying these capital conversion costs, original equipment manufacturers will costs are proportional to the number of they are still responsible for selling instead be passed along indirectly to the products offered by a company and not certified products made by the original domestic small businesses. the volume of sales. Some small lamp manufacturers. The costs incurred In the GSFL market, DOE identified businesses stated they could offer up to by contracted manufacturers are passed 21 small GSFL businesses with covered 75 percent of the number of covered on to small businesses that must products affected by this rulemaking. It products that large manufacturers offer; maintain profit margins by either however, the volume of sales for each increasing product prices or decreasing is unlikely that small GSFL businesses single product offered by a small profitability. will incur any capital conversion costs business would be significantly smaller because small businesses usually do not than that of a larger manufacturer. 2. Description and Estimate of own and operate the machinery used to Consequently, the revenue associated Compliance Requirements manufacture the covered lamps; with a single product is much smaller Small GSFL and IRL businesses will however, they will likely face for small businesses than for large be affected differently by the proposed significant product conversion costs to manufacturers. Therefore, these small energy conservation standards cover R&D, certification, and testing of businesses could have product compared to large manufacturers. One products that need to be redesigned to conversion costs in the same range as of the key differences between large meet the proposed GSFL efficacy levels large manufacturers, since product manufacturers and the small businesses of today’s NOPR. DOE estimates that conversion costs scale to number of identified by DOE for this rulemaking is approximately 20 percent of the covered products offered, even though the total that small IRL and GSFL businesses products offered by small GSFL revenue is significantly lower for small typically outsource the manufacturing manufacturers meet the proposed businesses compared to large of the lamps they sell to original efficacy levels at TSL 5. As a result, an manufacturers. equipment manufacturers abroad. This, average of approximately 80 percent of Lower sales volumes are the biggest in addition to the small volume of sales products would need to be redesigned disadvantage for most small businesses. typical of small businesses, results in to meet proposed efficacy levels, A lower-volume business’ product small GSFL and IRL businesses having resulting in small GSFL businesses conversion costs are spread over fewer different types and amounts of incurring more than $1.6 million on units than a larger competitor. Thus, conversion costs compared to large average in product conversion costs or unless the small business can manufacturers. nearly seven times as much as typical differentiate its product in some way As a result of this rulemaking, small annual GSFL R&D expenses. GSFL sales that earns a price premium, the small businesses will incur product account for approximately 25 percent of business experiences a reduction in conversion costs because products that a typical small business’ annual profit per-unit relative to the large no longer meet the proposed efficacy revenue, so redesigning up to 80 percent manufacturer. Most small GSFL and IRL levels of amended energy conservation of those offerings could have a businesses operate in the same lighting standards will most likely need to be significant impact on their business. markets as large manufacturers and do redesigned, retested, and recertified. Redesigning a large majority of product not operate in niche GSFL and IRL Since small businesses have offerings that represent a significant markets. Much of the same equipment significantly less revenue and annual revenue stream will be more difficult for would need to be purchased by both R&D budgets than large manufacturers, small businesses, compared to large large manufacturers and small the product conversion costs necessary businesses, as they have less R&D and businesses to produce GSFLs and IRLs to comply with amended standards revenue.

TABLE VIII.1—ESTIMATED GSFL PRODUCT CONVERSION COSTS AS A PERCENTAGE OF ANNUAL GSFL R&D EXPENSE

Product conversion cost Total as a percentage conversion cost of annual R&D as a percentage expense of annual revenue (percent) (percent)

Typical Large Manufacturer ...... 1 0 Typical Small Manufacturer ...... 692 31

In the IRL market, DOE identified 15 business will not incur any direct own and operate the machinery used to small IRL businesses with covered capital conversion costs at TSL 1, the manufacture IRLs. The small businesses products affected by this rulemaking. proposed standard in today’s NOPR, would most likely experience higher DOE estimates that a typical small IRL since most IRL small businesses do not per-unit costs for the products if the

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conversion costs experienced by the manufacturer. As Table VIII.2 below the product conversion costs necessary overseas manufacturers are passed illustrates, small businesses would have to meet the efficacy standards at TSL 1 through to the small businesses, significant product conversion costs could be problematic for those small potentially reducing those small amounting to nearly nine times the businesses that have a large majority of business’ manufacturer markups. Small annual amount spent on IRL R&D. Small their IRLs at the baseline efficacy level. IRL businesses are expected to incur IRL businesses have much smaller Total conversion cost for a typical small product capital conversion costs of annual R&D budgets as well as smaller business could amount to nearly a third approximately $836 thousand per annual revenue streams, so incurring that small business’ annual IRL revenue.

TABLE VIII.2—ESTIMATED IRL PRODUCT CONVERSION COSTS AS A PERCENTAGE OF ANNUAL IRL R&D EXPENSE

Product Total conversion cost conversion cost as a percentage as a percentage of annual R&D of annual expense revenue (percent) (percent)

Typical Large Manufacturer ...... 387 28 Typical Small Manufacturer ...... 852 29

While some small businesses would DOE is proposing in today’s notice. comment period that there is a have some products meet the IRL Though TSLs lower than the proposed substantial cumulative effect of efficacy levels proposed in today’s TSLs are expected to reduce the impacts numerous concurrent lighting NOPR, there are a few small businesses on small entities, DOE is required by regulations being carried out in addition that may not be able to meet the IRL EPCA to establish standards that to this rulemaking and small business efficacy levels proposed in today’s achieve the maximum improvement in manufacturers are even harder hit NOPR. Not meeting TSL 1 for IRL energy efficiency that are technically because of this cumulative regulatory products may also be a strategic feasible and economically justified, and burden. NEMA believes that small decision for some small businesses result in a significant conservation of business manufacturers should not have since IRL products make up about five energy. Therefore, DOE rejected the to bear an unfair burden as a result of percent of a typical small IRL business’ lower TSLs. overly aggressive policies. (NEMA, No. revenue. Therefore, some small lighting The NOPR TSD includes a regulatory 10 at pp. 74–75) DOE agrees that there businesses may choose to not sell IRLs impact analysis in chapter 18. For is potential for small manufacturers to covered by this rulemaking and exit the GSFLs and IRLs, this report discusses be disproportionately burdened by market. the following policy alternatives in additional regulations as a result of Small businesses in both the IRL and addition to the other TSLs being additional testing and reporting costs GSFL industries expressed concern that considered: (1) Consumer rebates, (2) and from the potential of a cumulative possible manufacturing downtime, consumer tax credits, and (3) regulatory burden, DOE outlines its discontinuation of product lines, and manufacturer tax credits. DOE does not conclusions on the potential impacts of high direct and indirect conversion intend to consider these alternatives amended standards on small businesses costs resulting from amended GSFL and further because they either are not in the above section of today’s NOPR. IRL energy conservation standards feasible to implement or are not DOE’s MIA suggests that most GSFL could have a significant impact on their expected to result in energy savings as small businesses will generally be able revenue and could affect domestic large as those that would be achieved by to maintain profitability at the TSL employment decisions. Domestic the standard levels under consideration. proposed in today’s rulemaking. It is employment impacts would be DOE continues to seek input from possible, however, that small IRL especially prevalent in the GSFL market businesses that would be affected by manufacturers could incur significant where GSFL revenue accounts for this rulemaking and will consider conversion costs as a result of this approximately 25 percent of a typical comments received in the development proposed rule, and those high costs small business’ revenue. Domestic of any final rule. could endanger their IRL business. employment impacts would be seen in However, based on the fact that IRL 5. Significant Issues Raised by Public sales typically only account for a small small business’ sales forces and Comments warehouse staff that could be but non-trivial overall portion of a small potentially downsized as a result of NEMA commented during the lighting business’ sales, DOE does not amended GSFL and IRL standards. framework comment period there is an believe that any small business will go added burden of significantly more out of business due to the IRL standard 3. Duplication, Overlap, and Conflict testing and reporting of a lot of small proposed in today’s NOPR. DOE’s MIA With Other Rules and Regulations sales volume lamps which would result is based on its interviews of both small DOE is not aware of any rules or from the proposed increase in and large manufacturers, and regulations that duplicate, overlap, or regulations. This increased burden consideration of the small business conflict with the rule being considered would be much harder on small impacts explicitly enters into DOE’s today. business manufacturers, especially if choice of the TSLs proposed in today’s those small business manufacturers NOPR. 4. Significant Alternatives to the have to pay testing costs to a National DOE did not receive any public Proposed Rule Voluntary Laboratory Accreditation comments suggesting that small The discussion above analyzes Program (NVLAP) source facility. businesses would not be able to achieve impacts on small businesses that would (NEMA, No. 10 at p. 75) NEMA also the efficiency levels at TSL 5 for GSFLs result from the GSFL TSL and IRL TSL commented during the framework and at TSL 1 for IRLs. DOE seeks

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comment on the feasibility of small determination for this proposed rule is 12988 requires Executive agencies to business to achieve the efficacy levels available at http://cxnepa.energy.gov. review regulations in light of applicable for GSFLs and IRLs proposed in today’s standards in section 3(a) and section E. Review Under Executive Order 13132 NOPR. 3(b) to determine whether they are met Executive Order 13132, ‘‘Federalism.’’ or it is unreasonable to meet one or C. Review Under the Paperwork 64 FR 43255 (Aug. 10, 1999) imposes more of them. DOE has completed the Reduction Act certain requirements on federal agencies required review and determined that, to Manufacturers of GSFLs and IRLs formulating and implementing policies the extent permitted by law, this must certify to DOE that their products or regulations that preempt state law or proposed rule meets the relevant comply with any applicable energy that have Federalism implications. The standards of Executive Order 12988. conservation standards. In certifying Executive Order requires agencies to compliance, manufacturers must test examine the constitutional and statutory G. Review Under the Unfunded their products according to the DOE test authority supporting any action that Mandates Reform Act of 1995 procedures for GSFLs and IRLs, would limit the policymaking discretion Title II of the Unfunded Mandates including any amendments adopted for of the states and to carefully assess the Reform Act of 1995 (UMRA) requires those test procedures. DOE has necessity for such actions. The each Federal agency to assess the effects established regulations for the Executive Order also requires agencies of Federal regulatory actions on state, certification and recordkeeping to have an accountable process to local, and Tribal governments and the requirements for all covered consumer ensure meaningful and timely input by private sector. Public Law 104–4, sec. products and commercial equipment, state and local officials in the 201 (codified at 2 U.S.C. 1531). For a including GSFLs and IRLs. 76 FR 12422 development of regulatory policies that proposed regulatory action likely to (March 7, 2011). The collection-of- have Federalism implications. On result in a rule that may cause the information requirement for the March 14, 2000, DOE published a expenditure by state, local, and Tribal certification and recordkeeping is statement of policy describing the governments, in the aggregate, or by the subject to review and approval by OMB intergovernmental consultation process private sector of $100 million or more under the Paperwork Reduction Act it will follow in the development of in any one year (adjusted annually for (PRA). This requirement has been such regulations. 65 FR 13735. EPCA inflation), section 202 of UMRA requires approved by OMB under OMB control governs and prescribes Federal a Federal agency to publish a written number 1910–1400. Public reporting preemption of state regulations as to statement that estimates the resulting burden for the certification is estimated energy conservation for the products costs, benefits, and other effects on the to average 20 hours per response, that are the subject of today’s proposed national economy. (2 U.S.C. 1532(a), (b)) including the time for reviewing rule. States can petition DOE for The UMRA also requires a Federal instructions, searching existing data exemption from such preemption to the agency to develop an effective process sources, gathering and maintaining the extent, and based on criteria, set forth in to permit timely input by elected data needed, and completing and EPCA. (42 U.S.C. 6297) No further officers of state, local, and Tribal reviewing the collection of information. action is required by Executive Order governments on a proposed ‘‘significant Notwithstanding any other provision 13132. intergovernmental mandate,’’ and of the law, no person is required to requires an agency plan for giving notice F. Review Under Executive Order 12988 respond to, nor shall any person be and opportunity for timely input to subject to a penalty for failure to comply With respect to the review of existing potentially affected small governments with, a collection of information subject regulations and the promulgation of before establishing any requirements to the requirements of the PRA, unless new regulations, section 3(a) of that might significantly or uniquely that collection of information displays a Executive Order 12988, ‘‘Civil Justice affect small governments. On March 18, currently valid OMB Control Number. Reform,’’ imposes on Federal agencies 1997, DOE published a statement of the general duty to adhere to the policy on its process for D. Review Under the National following requirements: (1) Eliminate intergovernmental consultation under Environmental Policy Act of 1969 drafting errors and ambiguity; (2) write UMRA. 62 FR 12820. DOE’s policy Pursuant to the National regulations to minimize litigation; and statement is also available at http:// Environmental Policy Act (NEPA) of (3) provide a clear legal standard for energy.gov/gc/downloads/unfunded- 1969, DOE has determined that the affected conduct rather than a general mandates-reform-act- proposed rule fits within the category of standard and promote simplification intergovernmental-consultation. actions included in Categorical and burden reduction. 61 FR 4729 (Feb. Although today’s proposed rule does Exclusion (CX) B5.1 and otherwise 7, 1996). Section 3(b) of Executive Order not contain a Federal intergovernmental meets the requirements for application 12988 specifically requires that mandate, it may require expenditures of of a CX. See 10 CFR Part 1021, App. B, Executive agencies make every $100 million or more on the private B5.1(b); 1021.410(b) and Appendix B, reasonable effort to ensure that the sector. Specifically, the proposed rule B(1)–(5). The proposed rule fits within regulation: (1) Clearly specifies the will likely result in a final rule that the category of actions because it is a preemptive effect, if any; (2) clearly could require expenditures of $100 rulemaking that establishes energy specifies any effect on existing Federal million or more. Such expenditures may conservation standards for consumer law or regulation; (3) provides a clear include: (1) Investment in research and products or industrial equipment, and legal standard for affected conduct development and in capital for which none of the exceptions while promoting simplification and expenditures by GSFL and IRL identified in CX B5.1(b) apply. burden reduction; (4) specifies the manufacturers in the years between the Therefore, DOE has made a CX retroactive effect, if any; (5) adequately final rule and the compliance date for determination for this rulemaking, and defines key terms; and (6) addresses the new standards, and (2) incremental DOE does not need to prepare an other important issues affecting clarity additional expenditures by consumers Environmental Assessment or and general draftsmanship under any to purchase higher-efficiency GSFL and Environmental Impact Statement for guidelines issued by the Attorney IRL, starting at the compliance date for this proposed rule. DOE’s CX General. Section 3(c) of Executive Order the applicable standard.

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Section 202 of UMRA authorizes a J. Review Under the Treasury and 2664 (Jan. 14, 2005). The Bulletin Federal agency to respond to the content General Government Appropriations establishes that certain scientific requirements of UMRA in any other Act, 2001 information shall be peer reviewed by statement or analysis that accompanies Section 515 of the Treasury and qualified specialists before it is the proposed rule. 2 U.S.C. 1532(c). The General Government Appropriations disseminated by the Federal content requirements of section 202(b) Act, 2001 (44 U.S.C. 3516, note) Government, including influential of UMRA relevant to a private sector provides for Federal agencies to review scientific information related to agency mandate substantially overlap the most disseminations of information to regulatory actions. The purpose of the economic analysis requirements that the public under guidelines established bulletin is to enhance the quality and apply under section 325(o) of EPCA and by each agency pursuant to general credibility of the Government’s Executive Order 12866. The guidelines issued by OMB. OMB’s scientific information. Under the SUPPLEMENTARY INFORMATION section of guidelines were published at 67 FR Bulletin, the energy conservation the NOPR and the ‘‘Regulatory Impact 8452 (Feb. 22, 2002), and DOE’s standards rulemaking analyses are Analysis’’ section of the TSD for this guidelines were published at 67 FR ‘‘influential scientific information,’’ proposed rule respond to those 62446 (Oct. 7, 2002). DOE has reviewed which the Bulletin defines as scientific requirements. information the agency reasonably can Under section 205 of UMRA, the today’s NOPR under the OMB and DOE guidelines and has concluded that it is determine will have, or does have, a Department is obligated to identify and clear and substantial impact on consider a reasonable number of consistent with applicable policies in those guidelines. important public policies or private regulatory alternatives before sector decisions. 70 FR 2667. promulgating a rule for which a written K. Review Under Executive Order 13211 In response to OMB’s Bulletin, DOE statement under section 202 is required. conducted formal in-progress peer 2 U.S.C. 1535(a). DOE is required to Executive Order 13211, ‘‘Actions select from those alternatives the most Concerning Regulations That reviews of the energy conservation cost-effective and least burdensome Significantly Affect Energy Supply, standards development process and alternative that achieves the objectives Distribution, or Use’’ 66 FR 28355 (May analyses and has prepared a Peer of the proposed rule unless DOE 22, 2001), requires Federal agencies to Review Report pertaining to the energy publishes an explanation for doing prepare and submit to OIRA at OMB, a conservation standards rulemaking otherwise, or the selection of such an Statement of Energy Effects for any analyses. Generation of this report alternative is inconsistent with law. As proposed significant energy action. A involved a rigorous, formal, and required by 42 U.S.C. 6295(i)(4)–(5), ‘‘significant energy action’’ is defined as documented evaluation using objective today’s proposed rule would establish any action by an agency that criteria and qualified and independent energy conservation standards for promulgates or is expected to lead to reviewers to make a judgment as to the GSFLs and IRLs that are designed to promulgation of a final rule, and that: technical/scientific/business merit, the achieve the maximum improvement in (1) Is a significant regulatory action actual or anticipated results, and the energy efficiency that DOE has under Executive Order 12866, or any productivity and management determined to be both technologically successor order; and (2) is likely to have effectiveness of programs and/or feasible and economically justified. A a significant adverse effect on the projects. The ‘‘Energy Conservation full discussion of the alternatives supply, distribution, or use of energy, or Standards Rulemaking Peer Review considered by DOE is presented in the (3) is designated by the Administrator of Report’’ dated February 2007 has been ‘‘Regulatory Impact Analysis’’ section of OIRA as a significant energy action. For disseminated and is available at the the TSD for today’s proposed rule. any proposed significant energy action, following Web site: the agency must give a detailed www1.eere.energy.gov/buildings/ H. Review Under the Treasury and statement of any adverse effects on appliance_standards/peer_review.html. General Government Appropriations energy supply, distribution, or use IX. Public Participation Act, 1999 should the proposal be implemented, Section 654 of the Treasury and and of reasonable alternatives to the A. Attendance at the Public Meeting General Government Appropriations action and their expected benefits on The time, date, and location of the Act, 1999 (Pub. L. 105–277) requires energy supply, distribution, and use. public meeting are listed in the DATES Federal agencies to issue a Family DOE has tentatively concluded that and ADDRESSES sections at the beginning Policymaking Assessment for any rule today’s regulatory action, which sets of this notice. If you plan to attend the that may affect family well-being. This forth energy conservation standards for public meeting, please notify Ms. rule would not have any impact on the GSFLs and IRLs, is not a significant Brenda Edwards at (202) 586–2945 or autonomy or integrity of the family as energy action because the proposed [email protected]. As an institution. Accordingly, DOE has standards are not likely to have a explained in the ADDRESSES section, concluded that it is not necessary to significant adverse effect on the supply, foreign nationals visiting DOE prepare a Family Policymaking distribution, or use of energy, nor has it Headquarters are subject to advance Assessment. been designated as such by the Administrator at OIRA. Accordingly, security screening procedures. I. Review Under Executive Order 12630 DOE has not prepared a Statement of In addition, you can attend the public DOE has determined, under Executive Energy Effects on the proposed rule. meeting via webinar. Webinar Order 12630, ‘‘Governmental Actions registration information, participant and Interference with Constitutionally L. Review Under the Information instructions, and information about the Protected Property Rights’’ 53 FR 8859 Quality Bulletin for Peer Review capabilities available to webinar (Mar. 18, 1988), that this regulation On December 16, 2004, OMB, in participants will be published on DOE’s would not result in any takings that consultation with the Office of Science Web site at: www1.eere.energy.gov/ might require compensation under the and Technology Policy (OSTP), issued buildings/appliance_standards/ Fifth Amendment to the U.S. its Final Information Quality Bulletin rulemaking.aspx/ruleid/24. Participants Constitution. for Peer Review (the Bulletin). 70 FR are responsible for ensuring their

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systems are compatible with the other matters relevant to this CBI. Comments received through the webinar software. rulemaking. The official conducting the Web site will waive any CBI claims for public meeting will accept additional the information submitted. For B. Procedure for Submitting Prepared comments or questions from those information on submitting CBI, see the General Statements for Distribution attending, as time permits. The Confidential Business Information Any person who has plans to present presiding official will announce any section below. a prepared general statement may further procedural rules or modification DOE processes submissions made request that copies of his or her of the above procedures that may be through regulations.gov before posting. statement be made available at the needed for the proper conduct of the Normally, comments will be posted public meeting. Such persons may public meeting. within a few days of being submitted. submit requests, along with an advance A transcript of the public meeting will However, if large volumes of comments electronic copy of their statement in be included in the docket, which can be are being processed simultaneously, PDF (preferred), Microsoft Word or viewed as described in the Docket your comment may not be viewable for Excel, WordPerfect, or text (ASCII) file section at the beginning of this notice. up to several weeks. Please keep the format, to the appropriate address In addition, any person may buy a copy comment tracking number that shown in the ADDRESSES section at the of the transcript from the transcribing regulations.gov provides after you have beginning of this notice. The request reporter. successfully uploaded your comment. and advance copy of statements must be Submitting comments via email, hand received at least one week before the D. Submission of Comments delivery/courier, or mail. Comments and public meeting and may be emailed, DOE will accept comments, data, and documents submitted via email, hand hand-delivered, or sent by mail. DOE information regarding this proposed delivery, or mail also will be posted to prefers to receive requests and advance rule before or after the public meeting, regulations.gov. If you do not want your copies via email. Please include a but no later than the date provided in personal contact information to be telephone number to enable DOE staff to the DATES section at the beginning of publicly viewable, do not include it in make follow-up contact, if needed. this proposed rule. Interested parties your comment or any accompanying may submit comments, data, and other documents. Instead, provide your C. Conduct of the Public Meeting information using any of the methods contact information in a cover letter. DOE will designate a DOE official to described in the ADDRESSES section at Include your first and last names, email preside at the public meeting and may the beginning of this notice. address, telephone number, and also use a professional facilitator to aid Submitting comments via optional mailing address. The cover discussion. The meeting will not be a regulations.gov. The regulations.gov letter will not be publicly viewable as judicial or evidentiary-type public Web page will require you to provide long as it does not include any hearing, but DOE will conduct it in your name and contact information. comments accordance with section 336 of EPCA Your contact information will be Include contact information each time (42 U.S.C. 6306). A court reporter will viewable to DOE Building Technologies you submit comments, data, documents, be present to record the proceedings and staff only. Your contact information will and other information to DOE. If you prepare a transcript. DOE reserves the not be publicly viewable except for your submit via mail or hand delivery/ right to schedule the order of first and last names, organization name courier, please provide all items on a presentations and to establish the (if any), and submitter representative CD, if feasible. It is not necessary to procedures governing the conduct of the name (if any). If your comment is not submit printed copies. No facsimiles public meeting. After the public processed properly because of technical (faxes) will be accepted. meeting, interested parties may submit difficulties, DOE will use this Comments, data, and other further comments on the proceedings as information to contact you. If DOE information submitted to DOE well as on any aspect of the rulemaking cannot read your comment due to electronically should be provided in until the end of the comment period. technical difficulties and cannot contact PDF (preferred), Microsoft Word or The public meeting will be conducted you for clarification, DOE may not be Excel, WordPerfect, or text (ASCII) file in an informal, conference style. DOE able to consider your comment. format. Provide documents that are not will present summaries of comments However, your contact information secured, that are written in English, and received before the public meeting, will be publicly viewable if you include that are free of any defects or viruses. allow time for prepared general it in the comment itself or in any Documents should not contain special statements by participants, and documents attached to your comment. characters or any form of encryption encourage all interested parties to share Any information that you do not want and, if possible, they should carry the their views on issues affecting this to be publicly viewable should not be electronic signature of the author. rulemaking. Each participant will be included in your comment, nor in any Campaign form letters. Please submit allowed to make a general statement document attached to your comment. campaign form letters by the originating (within time limits determined by DOE), Otherwise, persons viewing comments organization in batches of between 50 to before the discussion of specific topics. will see only first and last names, 500 form letters per PDF or as one form DOE will allow, as time permits, other organization names, correspondence letter with a list of supporters’ names participants to comment briefly on any containing comments, and any compiled into one or more PDFs. This general statements. documents submitted with the reduces comment processing and At the end of all prepared statements comments. posting time. on a topic, DOE will permit participants Do not submit to regulations.gov Confidential Business Information. to clarify their statements briefly and information for which disclosure is According to 10 CFR 1004.11, any comment on statements made by others. restricted by statute, such as trade person submitting information that he Participants should be prepared to secrets and commercial or financial or she believes to be confidential and answer questions by DOE and by other information (hereinafter referred to as exempt by law from public disclosure participants concerning these issues. Confidential Business Information should submit via email, postal mail, or DOE representatives may also ask (CBI)). Comments submitted through hand delivery/courier two well-marked questions of participants concerning regulations.gov cannot be claimed as copies: one copy of the document

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marked confidential including all the capture real-world energy use and light modified spectrum, or 130 V rated information believed to be confidential, output. DOE requests comments on its lamps for commercial production. (See and one copy of the document marked methodology for developing lamp-and- section VI.D.3.i for further details.) non-confidential with the information ballast systems as well as the results of 12. Because GSFLs and IRLs are believed to be confidential deleted. these GSFL systems. (See section difficult to reverse-engineer (i.e., not Submit these documents via email or on VI.D.2.e for further details.) easily disassembled), DOE directly a CD, if feasible. DOE will make its own 5. For GSFLs, DOE requests comment estimated end-user prices for lamps by determination about the confidential on the max tech levels identified in this establishing discounts from status of the information and treat it analysis and more information on the manufacturer suggested price lists. DOE according to its determination. accuracy of catalog and certification requests feedback on the pricing Factors of interest to DOE when data which were used to identify these methodology used in this analysis. (See evaluating requests to treat submitted levels. (See section VI.D.2.f for further section VI.E for further details.) information as confidential include: (1) details.) 13. DOE used data published in the A description of the items; (2) whether 6. DOE develops ELs based on three 2010 LMC in combination with CBECS, and why such items are customarily factors: (1) The design options MECS, and RECS to determine an treated as confidential within the associated with the specific lamps average weighted electricity price based industry; (3) whether the information is studied; (2) the ability of lamps across on the probability of a GSFL or IRL in generally known by or available from wattages to comply with the standard a particular building type in each other sources; (4) whether the level of a given product class; and (3) census division and large state. DOE information has previously been made the max tech EL. DOE requests requests comment on its methodology of available to others without obligation comments on the methodology used to determining average weighted concerning its confidentiality; (5) an develop ELs for GSFLs as well as on the electricity prices in the LCC. (See explanation of the competitive injury to resulting ELs. (See section VI.D.2.g for section VI.G.6 for further details.) the submitting person which would further details.) 14. DOE determined LCC savings and result from public disclosure; (6) when 7. DOE develops scaling factors to PBP results for different scenarios where such information might lose its scale the levels developed directly for consumers need to purchase a lamp (i.e., confidential character due to the the representative product classes and lamp failure, ballast failure, and new passage of time; and (7) why disclosure determine levels for product classes not construction and renovation for GSFLs of the information would be contrary to analyzed directly. DOE requests and lamp failure and new construction the public interest. comments on the scaling factors and renovation for IRLs). DOE requests It is DOE’s policy that all comments developed to scale GSFL product classes comments on these lamp purchasing may be included in the public docket, from the less than or equal to 4,500 K events developed for this analysis. (See without change and as received, CCT lamps to the greater than 4,500 K section VI.G.9 for further details.) including any personal information CCT lamps. DOE also requests 15. DOE conducts the LCC and PBP provided in the comments (except comments on the scaling factor analyses over the lifetime of the information deemed to be exempt from developed to scale from the 4-foot MBP product. DOE considered the impact of public disclosure). product class to the 2-foot U-shaped group relamping practices on GSFL product class. (See section VI.D.2.h for lifetime in the commercial and E. Issues on Which DOE Seeks Comment further details.) industrial sectors. DOE requests Although DOE welcomes comments 8. In the engineering analysis, DOE comment on its spot and group on any aspect of this proposal, DOE is selects a baseline lamp as a reference relamping assumptions, particularly the particularly interested in receiving point against which to measure changes percent of rated life at which group comments and views of interested resulting from energy conservation relamping occurs. DOE also requests parties concerning the following issues: standards. DOE requests comments on comment on its general approach to 1. DOE requests comment on the the baseline lamps selected in this determining lamp lifetime for this overall methodology, assumptions, and analysis for IRLs. (See section VI.D.3.c analysis. (See section VI.G.10.a for results of the GSFL and IRL engineering for further details.) further details.) analyses. (See section VI.D for further 9. In the engineering analysis for IRLs, 16. DOE requests comment on its LCC details.) DOE observed lifetime changes for analysis period assumptions. In 2. In the engineering analysis, DOE different technologies. DOE requests particular, DOE requests comment on selects a baseline lamp as a reference comment on the rated lifetimes of the basing the analysis period on the point against which to measure changes baseline and more efficacious baseline lamp life divided by the annual resulting from energy conservation substitutes. (See section VI.D.3.d for operating hours of that lamp for the IRL standards. DOE requests comments on further details). and the commercial and industrial the baseline lamps selected in this 10. DOE requests comment on the sector GSFL analyses. DOE also requests analysis for GSFLs. (See section VI.D.2.c max tech levels identified in this comment on basing the analysis period for further details.) analysis and information on high on the useful life of the baseline lamp 3. For GSFLs, the baseline and more efficacy IRLs including prototype lamps. for a specific event for residential efficacious substitutes selected (See section VI.D.3.e for further details.) GSFLs. (See section VI.G.12 for further represent the most common lifetimes for 11. DOE has not found evidence that details.) each product class. DOE requests more efficacious small diameter, 17. For this rulemaking, DOE comment on the rated lifetimes of the modified spectrum, or 130 V IRLs are analyzed the effects of this proposal GSFL baselines and more efficacious not technologically feasible or assuming that the GSFLs and IRLs substitutes. (See section VI.D.2.d for practicable to manufacture, and would be available to purchase for 30 further details.) therefore is proposing to increase years and undertook a sensitivity 4. Because fluorescent lamps operate efficacy levels for these lamp types. analysis using 9 years rather than 30 on a ballast in practice, DOE analyzed DOE requests comment on any years of product shipments. The choice lamp-and-ballast systems in the technological barriers in manufacturing of a 30-year period of shipments is engineering analysis, to more accurately more efficacious small diameter, consistent with the DOE analysis for

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other products and commercial sensitivity analyses to evaluate other regulations. Since GSFL equipment. The choice of a 9-year alternative assumptions about rebound. manufacturers must also comply with period is a proxy for the timeline in DOE welcomes comment on its the Minimata Convention on Mercury, EPCA for the review of certain energy assumptions and methodology for DOE seeks comment on GSFL conservation standards and potential estimating the rebound effect including manufacturers potentially increasing the revision of and compliance with such potential magnitudes of rebound effects. amount of mercury in GSFLs in order to revised standards. DOE is seeking input, (See section VI.J.1for further details.) comply with the proposed GSFL information and data on whether there 23. To calculate the MSP, in the MIA, standards. (See section VII.B.2.e for are ways to further refine the analytic DOE determined the distribution chain further details.) timeline. (See section VI.I for further markup for the GSFL and IRL 29. For the proposed GSFL standards, details.) industries. DOE invites comment on its DOE requests comment on the 18. DOE assumes in its shipments and methodology of using a 1.52 distribution reasonableness of its assumption that national impacts analyses that reduced chain markup in combination with the first cost is a significant driver of wattage 4-foot MBP lamps can be medium end-user price to estimate the consumers’ choice of product class, coupled to dimming ballasts, but it MSP of all GSFLs and IRLs. (See section which results in the shipments analysis assumes that no individual reduced VI.K.2 for further details.) projecting a rapid shift from 4-foot MBP wattage lamp option will be coupled to 24. As part of the MIA, DOE estimates T8s to standard output T5s in the TSL more than 10 percent of the dimming the product and capital conversion costs 5 standards case. The TSL 5 standards ballasts in the installed stock, owing to that all manufacturers must make to case substantially increases first cost for performance problems that may arise in comply with potential standards. DOE 4-foot MBP T8s. (See section VII.B.3 for some applications. DOE welcomes input requests comment on the $6.1 product further details.) on the reasonableness and conversion costs and $65.4 capital 30. Noting that DOE projects a sharp appropriateness of these assumptions. conversion costs necessary for IRL decrease in total GSFL shipments both (See section VI.I for further details.) manufacturers to comply with the with and without standards during the 19. DOE assumes in its reference proposed standards. (See sections rulemaking period because of the shipments and national impacts VI.K.2.a and VII.B.2.a for further projected sharp incursion of LEDs into analyses that the future real price of rare details.) the GSFL market—DOE seeks comment earth oxides used in the manufacture of 25. DOE solicits comment on the on the reasonableness of the shipments GSFLs will remain near current levels application of the new SCC values used model projection for TSL 5, specifically, on average. DOE further assumes in an to determine the social benefits of CO2 that standard output T5 lamps could alternative-scenario analysis that the emissions reductions over the increase from 3 to 4 percent of the future price of rare earth oxides may rulemaking analysis period. (The standard output GSFL market presently, increase owing to market forces outside rulemaking analysis period covers from to approximately 13 percent of the same of this proposed rulemaking, but DOE 2017 to 2046 plus the appropriated market by 2020, and to approximately assumes that the future price is not number of years to account for the 30 percent of the much attenuated likely to exceed 3.4 times the current lifetime of the equipment purchased standard output GSFL market by 2046. price on average. DOE estimates that the between 2017 and 2046.) In particular, (See section VII.B.3 for further details.) standard proposed here would cause a the agency solicits comment on the 31. DOE requests comment on its maximum annual increase in demand agency’s derivation of SCC values after assumption that there will be no for rare earth oxides of 296 tons in 2017, 2050 where the agency applied the lessening of utility or performance such with lower demand increases in later average annual growth rate of the SCC that the performance characteristics, years. DOE welcomes input on the estimates in 2040–2050 associated with including lumen package, color quality, reasonableness and appropriateness of each of the four sets of values. (See lifetime, and ability to dim, would be these estimates and assumptions. (See section VI.M.1 for further details.) adversely affected for the GSFL efficacy section VI.I for further details.) 26. As part of the MIA, DOE levels. (See sections VII.B.4, VI.A, VI.B, 20. DOE assumes in its reference quantitatively assessed the impacts of VI.C, and VI.D for further details.) shipments and national impacts potential amended energy conservation 32. DOE requests comment on analyses that the future price of xenon standards on direct employment. DOE whether there are features or attributes, gas will remain near current levels on seeks comment on the potential including physical constraints such as average. DOE further assumes in an domestic employment impacts to GSFL shape or diameter, of the more energy- alternative-scenario analysis that the and IRL manufacturers at the proposed efficient GSFL lamps that manufacturers future price of xenon gas may rise but efficacy levels. (See section VII.B.2.b for would produce to meet the standards in that it is not likely to exceed ten times further details.) this proposed rule that might affect how the current price on average. DOE 27. In the cumulative regulatory they would be used by consumers. DOE welcomes input on the reasonableness burden analysis, DOE assess the requests comment specifically on how and appropriateness of these combined effects of recent or impending any such effects should be weighed in assumptions. (See section VI.I for regulations on manufacturers. DOE the choice of standards for GSFLs for further details.) seeks comment on the compliance costs the final rule. 21. To improve DOE’s estimates of the of any other regulations GSFL or IRL 33. DOE requests comment on its potential impact of lighting controls on manufacturers must make, especially if assumption that there will be no this rulemaking, DOE seeks input on the compliance with those regulations is lessening of utility or performance such current fraction of GSFL ballast required three years before or after the that the performance characteristics, shipments that are dimming ballasts and estimated compliance date of these including lumen package and lifetime, the likely rate of growth of dimming proposed standards (2017). (See section would be adversely affected for the IRL ballasts in the future. (See section VI.I VII.B.2.e for further details.) efficacy levels. (See sections VII.B.4, for further details.) 28. As part of the cumulative VI.A, VI.B, VI.C, and VI.D for further 22. DOE assumed zero direct rebound regulatory burden analysis, DOE details.) effect for efficiency improvements in examines how the proposed standards 34. DOE requests comment on GSFLs and IRLs. DOE conducted affect manufacturers complying with whether there are features or attributes,

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such as the shape or diameter, of the 430 of chapter II, subchapter D, of title (3) Any rapid start lamp (commonly more energy-efficient IRL lamps that 10 of the Code of Federal Regulations, referred to as 8-foot high output lamps) manufacturers would produce to meet as set forth below: with recessed double contact bases of the standards in this proposed rule that nominal overall length of 96 inches; might affect how they would be used by PART 430—ENERGY CONSERVATION (4) Any instant start lamp (commonly consumers. DOE requests comment PROGRAM FOR CONSUMER referred to as 8-foot slimline lamps) specifically on how any such effects PRODUCTS with single pin bases of nominal overall should be weighed in the choice of length of 96 inches and rated wattage of ■ 1. The authority citation for part 430 standards for the IRLs for the final rule. 49 or more; 35. Due to the assumed shifts in continues to read as follows: (5) Any straight-shaped lamp shipments between product classes, the Authority: 42 U.S.C. 6291–6309; 28 U.S.C. (commonly referred to as 4-foot energy savings and monetized cost and 2461 note. miniature bipin standard output lamps) benefit values computed for a single with miniature bipin bases of nominal ■ 2. In § 430.2, add the definitions for product class, considered in isolation, overall length between 45 and 48 inches ‘‘700 series fluorescent lamp’’, may yield negative energy savings but and rated wattage of 25 or more; and ‘‘Designed and marketed,’’ ‘‘Fluorescent are more than offset by the large positive (6) Any straight-shaped lamp lamp designed for use in reprographic contributions to the aggregate energy (commonly referred to 4-foot miniature equipment,’’ ‘‘Impact-resistant savings and monetized benefits across bipin high output lamps) with miniature fluorescent lamp,’’ ‘‘Lamps primarily all product classes. The expected bipin bases of nominal overall length designed to produce radiation in the switching between product classes also between 45 and 48 inches and rated ultra-violet region of the spectrum,’’ led to an aggregate negative cost wattage of 44 or more. ‘‘Reflectorized or aperture lamp,’’ in estimate for the proposed standard alphabetical order, and revise the * * * * * level. In part due to the negative cost definition for ‘‘fluorescent lamp’’ to read Fluorescent lamp designed for use in estimate for IRLs, DOE requests as follows: reprographic equipment means a comment on the consumer choice model fluorescent lamp intended for use in that projects shifts in shipments § 430.2 Definitions. equipment used to reproduce, reprint, between product classes and whether * * * * * or copy graphic material. there are other factors (e.g. utility, costs 700 series fluorescent lamp means a * * * * * to replace light fixtures, design fluorescent lamp with a color rendering Impact-resistant fluorescent lamp incompatibility) that may preclude or index (measured according to the test means a lamp that limit that shifting that may not be procedures outlined in Appendix R to (1) Has a coating or equivalent considered in DOE’s analysis. (See subpart B of this part) that is in the technology that is compliant with NSF/ section VII.3.c. and chapter 12 of the range (inclusive) of 70 to 79. ANSI 51 (incorporated by reference; see TSD for more details). * * * * * § 430.3) and is designed to contain the 36. The Regulatory Flexibility Act (5 Designed and marketed means that glass if the glass envelope of the lamp U.S.C. 601 et seq.) requires DOE to the intended application of the lamp is is broken; and analyze the impact of its proposed stated in a publicly available document (2) Is designated and marketed for the standards on small entities, as well as (e.g., product literature, catalogs, intended application, with: any alternatives that accomplish the packaging labels, and labels on the (i) The designation on the lamp stated objectives of EPCA and minimize product itself). This definition is packaging; and any significant economic impact of the applicable to terms related to the (ii) Marketing materials that identify proposed rule on small entities. DOE following covered lighting products: the lamp as being impact-resistant, requests comment on the potential fluorescent lamp ballasts; fluorescent shatter-resistant, shatter-proof, or impacts to GSFL and IRL small lamps; general service fluorescent shatter-protected. businesses at the proposed efficacy lamps; general service incandescent * * * * * levels. (See section VIII.B for further lamps; incandescent lamps; Lamps primarily designed to produce details.) incandescent reflector lamps; medium radiation in the ultra-violet region of the X. Approval of the Office of the base compact fluorescent lamps; and spectrum mean fluorescent lamps that Secretary specialty application mercury vapor primarily emit light in the portion of the lamp ballasts. electromagnetic spectrum where light The Secretary of Energy has approved has a wavelength between 10 and 400 publication of today’s proposed rule. * * * * * Fluorescent lamp means a low nanometers. List of Subjects in 10 CFR Part 430 pressure mercury electric-discharge * * * * * Administrative practice and source in which a fluorescing coating Reflectorized or aperture lamp means procedure, Confidential business transforms some of the ultraviolet a fluorescent lamp that contains an information, Energy conservation, energy generated by the mercury inner reflective coating on the bulb to Household appliances, Imports, discharge into light, including only the direct light. Intergovernmental relations, Reporting following: * * * * * and recordkeeping requirements, and (1) Any straight-shaped lamp ■ 3. Section 430.32 is amended by Small businesses. (commonly referred to as 4-foot medium revising paragraph (n) to read as bipin lamps) with medium bipin bases follows: Issued in Washington, DC, on April 11, of nominal overall length of 48 inches 2014. and rated wattage of 25 or more; § 430.32 Energy and water conservation David T. Danielson, (2) Any U-shaped lamp (commonly standards and their effective dates. Assistant Secretary, Energy Efficiency and referred to as 2-foot U-shaped lamps) * * * * * Renewable Energy. with medium bipin bases of nominal (n) General service fluorescent lamps For the reasons set forth in the overall length between 22 and 25 inches and incandescent reflector lamps. (1) preamble, DOE proposes to amend part and rated wattage of 25 or more; Except as provided in paragraphs (n)(2),

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(n)(3), and (n)(4) of this section, each of lamps manufactured after the effective exceed the following lamp efficacy and the following general service fluorescent dates specified in the table shall meet or CRI standards:

Minimum Nominal lamp average lamp Lamp type wattage Minimum CRI efficacy Effective date lm/W

4-foot medium bipin ...... >35 W 69 75.0 Nov. 1, 1995. ≤35 W 45 75.0 Nov. 1, 1995. 2-foot U-shaped ...... >35 W 69 68.0 Nov. 1, 1995. ≤35 W 45 64.0 Nov. 1, 1995. 8-foot slimline ...... >65 W 69 80.0 May 1, 1994. ≤65 W 45 80.0 May 1, 1994. 8-foot high output ...... >100 W 69 80.0 May 1, 1994. ≤100 W 45 80.0 May 1, 1994.

(2) The standards described in by reference; see § 430.3) or related following general service fluorescent paragraph (n)(1) of this section do not supplements, or not 0.800 nominal lamps manufactured after July 14, 2012, apply to: amperes; or shall meet or exceed the following lamp (i) Any 4-foot medium bipin lamp or (iii) Any 8-foot slimline lamp not efficacy standards shown in the table: 2-foot U-shaped lamp with a rated defined in ANSI C78.3 (incorporated by wattage less than 28 watts; reference; see § 430.3). (ii) Any 8-foot high output lamp not (3) Except as provided in paragraph defined in ANSI C78.81 (incorporated (n)(4) of this section, each of the

Minimum Correlated color average lamp Lamp type temperature efficacy lm/W

4-foot medium bipin ...... ≤4,500K ...... 89 >4,500K and ≤7,000K ...... 88 2-foot U-shaped ...... ≤4,500K ...... 84 >4,500K and ≤7,000K ...... 81 8-foot slimline ...... ≤4,500K ...... 97 >4,500K and ≤7,000K ...... 93 8-foot high output ...... ≤4,500K ...... 92 >4,500K and ≤7,000K ...... 88 4-foot miniature bipin standard output ...... ≤4,500K ...... 86 >4,500K and ≤7,000K ...... 81 4-foot miniature bipin high output ...... ≤4,500K ...... 76 >4,500K and ≤7,000K ...... 72

(4) Each of the following general Publication of final rule in the Federal following lamp efficacy standards service fluorescent lamps manufactured Register], shall meet or exceed the shown in the table: on or after [3 Years after Date of

Minimum Correlated color average lamp Lamp type temperature efficacy lm/W

4-foot medium bipin ...... ≤4,500K ...... 92.4 >4,500K and ≤7,000K ...... 90.6 2-foot U-shaped ...... ≤4,500K ...... 86.9 >4,500K and ≤7,000K ...... 84.3 8-foot slimline ...... ≤4,500K ...... 99.0 >4,500K and ≤7,000K ...... 94.1 8-foot high output ...... ≤4,500K ...... 97.6 >4,500K and ≤7,000K ...... 95.6 4-foot miniature bipin standard output ...... ≤4,500K ...... 97.1 >4,500K and ≤7,000K ...... 91.3 4-foot miniature bipin high output ...... ≤4,500K ...... 82.7 >4,500K and ≤7,000K ...... 78.6

VerDate Mar<15>2010 20:23 Apr 28, 2014 Jkt 232001 PO 00000 Frm 00123 Fmt 4701 Sfmt 4702 E:\FR\FM\29APP2.SGM 29APP2 mstockstill on DSK4VPTVN1PROD with PROPOSALS 24190 Federal Register / Vol. 79, No. 82 / Tuesday, April 29, 2014 / Proposed Rules

(5) Except as provided in paragraphs Minimum (6) Except as provided in paragraph (n)(6) and (n)(7) of this section, each of Nominal lamp wattage average lamp (n)(7) of this section each of the the following incandescent reflector efficacy following incandescent reflector lamps lm/W lamps manufactured after November 1, manufactured after July 14, 2012, shall 1995, shall meet or exceed the lamp 40–50 ...... 10.5 meet or exceed the lamp efficacy efficacy standards shown in the table: 51–66 ...... 11.0 standards shown in the table: 67–85 ...... 12.5 86–115 ...... 14.0 116–155 ...... 14.5 156–205 ...... 15.0

Minimum Rated lamp Lamp diameter average lamp wattage Lamp spectrum inches Rated voltage efficacy lm/W

40–205 ...... Standard Spectrum ...... >2.5 ≥125 V 6.8*P0.27 <125 V 5.9*P0.27 ≤2.5 ≥125 V 5.7*P0.27 <125 V 5.0*P0.27 40–205 ...... Modified Spectrum ...... >2 .5 ≥125 V 5.8*P0.27 <125 V 5.0*P0.27 ≤2.5 ≥125 V 4.9*P0.27 <125 V 4.2*P0.27 Note 1: P is equal to the rated lamp wattage, in watts. Note 2: Standard Spectrum means any incandescent reflector lamp that does not meet the definition of modified spectrum in 430.2.

(7) Each of the following incandescent on or after [3 Years after Date of following lamp efficacy standards reflector lamps with the exception of Publication of final rule in the Federal shown in the table: BPAR, BR, and ER lamps manufactured Register], shall meet or exceed the

Minimum Lamp diameter average lamp Rated lamp wattage Lamp spectrum inches Rated voltage efficacy lm/W

40–205 ...... Standard Spectrum ...... >2.5 ≥125V 7.1P0.27 <125V 6.2P0.27 ≤2.5 ≥125V 6.0P0.27 <125V 5.2P0.27 40–205 ...... Modified Spectrum ...... >2.5 ≥125V 6.0P0.27 <125V 5.2P0.27 ≤2.5 ≥125V 5.1P0.27 <125V 4.4P0.27 Note 1: P is equal to the rated lamp wattage, in watts. Note 2: Standard Spectrum means any incandescent reflector lamp that does not meet the definition of modified spectrum in 430.2.

(8)(i)(A) Subject to the exclusions in apply to incandescent reflector lamps (B) Lamps rated at 65 watts that are paragraph (n)(8)(ii) of this section, the with a diameter of more than 2.25 BR30, BR40, or ER40 lamps; or standards specified in this section shall inches, but not more than 2.75 inches, (C) R20 incandescent reflector lamps apply to ER incandescent reflector on and after June 15, 2008. rated 45 watts or less. lamps, BR incandescent reflector lamps, (ii) The standards specified in this BPAR incandescent reflector lamps, and section shall not apply to the following * * * * * similar bulb shapes on and after January types of incandescent reflector lamps: [FR Doc. 2014–08740 Filed 4–24–14; 8:45 am] 1, 2008. (A) Lamps rated at 50 watts or less BILLING CODE 6450–01–P (B) Subject to the exclusions in that are ER30, BR30, BR40, or ER40 paragraph (n)(8)(ii) of this section, the lamps; standards specified in this section shall

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