3

- i CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT

TABLE OF CONTENTS

3.1 INTRODUCTION ........................................................................................................... 3 -1

3.2 SCOPE OF COVERAGE ................................................................................................ 3-1

3.2.1 General Service Fluorescent Lamps .................................................................... 3 -1

3.2.1.1 Current CFR Definitions .......................................................................... 3 -1

3.2.1.2 Clarification of GSFL Definitions ........................................................... 3-2

3.2.1.3 Additional GSFL Wattages ...................................................................... 3 -3

3.2.1.4 Additional GSFL Types ........................................................................... 3 -4

3.2.2 Incandescent Reflector Lamps ............................................................................. 3 -5

3.3 MARKET ASSESSMENT .............................................................................................. 3-6

3.3.1 Trade Association ................................................................................................ 3-6

3.3.2 Manufacturers and Market Share ......................................................................... 3 -7

3.3.2.1 Small Businesses ...................................................................................... 3 -8

3.3.3 Regulatory Programs ........................................................................................... 3-9

3.3.3.1 GSFL Federal Energy Conservation Standards ....................................... 3 -9

3. 3.3.2 IRL Federal Energy Conservation Standards ........................................ 3 -10

3.3.3.3 California Energy Commission.............................................................. 3-11

3.3.3.4 Canadian Energy Efficiency Standards ................................................. 3 -12

3.3.3.5 European Energy Efficiency Standards ................................................. 3 -13

3.3.4 Non-Regulatory Initiatives................................................................................. 3 -16

3.3.4.1 Federal Energy Management Program .................................................. 3 -16

3.3.4.2 Consortium for Energy Efficiency ......................................................... 3-17

3.3.4.3 Energy Efficient Commercial Building Deduction ................................ 3-17

3.3.4.4 Efficiency Vermont – Agricultural Rebate Program ............................. 3-17

3.3.4.5 Pacific Gas and Electric Company Rebates ........................................... 3 -17

3.3.4.6 Northeast Energy Efficiency Partnerships ............................................. 3 -18

3.3.4.7 APS Rebate Programs ............................................................................ 3 -18

3.3.4.8 Cape Light Compact – Commercial, Industrial and Municipal Buildings Energy Efficiency Rebate Program ....................................................... 3-18

3.3.4.9 Central Electric Cooperative – Non-Residential Lighting Rebate ......... 3 -19

3.3.4.10 Empire – Commercial and Industrial Energy Efficiency Rebates ...... 3 -19

3.3.4.11 GVEA – Residential Rebate Program for Builders ............................ 3-19

3.3.5 Historical Shipments .......................................................................................... 3-19

3.3.5.1 GSFL Shipments .................................................................................... 3 -20

3.3.5.2 IRL Shipments ....................................................................................... 3-23

3.4 TECHNOLOGY ASSESSMENT .................................................................................. 3 -23

3.4.1 Basic Structure and Operation of General Service Fluorescent Lamps ............. 3 -23

3.4.2 GSFL Technology Options ................................................................................ 3 -25

3.4.2.1 Highly Emissive Electrode Coatings ..................................................... 3 -26

3.4.2.2 Higher Efficiency Lamp Fill Gas Composition ..................................... 3 -26

3.4.2.3 Higher Efficiency Phosphors ................................................................. 3 -28

3.4.2.4 Glass Coatings ....................................................................................... 3-31

3.4.2.5 Higher Efficiency Lamp Diameter ......................................................... 3-313

- ii 3.4.2.6 Multi-Photon Phosphors ........................................................................ 3 -32

3.4.3 Basic Structure and Operation of Incandescent Reflector Lamps ..................... 3 -33

3.4.4 IRL Technology Options ................................................................................... 3 -33

3.4.4.1 Higher Temperature Operation .............................................................. 3-34

3.4.4.2 Novel Filament Materials ...................................................................... 3 -35

3.4.4.3 Thinner Filaments .................................................................................. 3 -35

3.4.4.4 Efficient Filament Placement ................................................................. 3 -36

3.4.4.5 Efficient Filament Orientation ............................................................... 3-36

3.4.4.6 Efficient Filament Coiling ..................................................................... 3 -36

3.4.4.7 Microcavity Filaments ........................................................................... 3 -36

3.4.4.8 Crystallite Filament Coatings ................................................................ 3-36

3.4.4.9 High Reflectance Filament Supports ..................................................... 3 -37

3.4.4.10 Higher Efficiency Inert Fill Gas ......................................................... 3-37

3.4.4.11 Hi gher Pressure Tungsten-Halogen Lamps ........................................ 3 -37

3.4.4.12 Non-Tungsten-Halogen Regenerative Cycles..................................... 3 -37

3.4.4.13 Infrared Glass Coatings....................................................................... 3 -38

3.4.4.14 Higher Efficiency Reflector Coatings ................................................. 3 -38

3.4.4.15 Permanent Infrared Reflector Coating Shroud ................................... 3 -38

3.4.4.16 Infrared Phosphor Glass Coating ........................................................ 3-39

3.4.4.17 Ultraviolet Phosphor Glass Coating.................................................... 3 -39

3.4.4.18 Corner Reflectors ................................................................................ 3 -39

3.4.4.19 Electron Stimulated Luminescence..................................................... 3 -39

3.4.4.20 Integrally Ballasted Low Voltage Lamps ........................................... 3 -39

3.5 PRODUCT CLASSES ................................................................................................... 3 -40

3.5.1 General Service Fluorescent Lamps .................................................................. 3 -40

3.5.1.1 Physical Constraints of Fluorescent Lamps ........................................... 3 -41

3. 5.1.2 Lumen Package ...................................................................................... 3 -41

3.5.1.3 Diameter ................................................................................................. 3 -42

3.5.1.4 Correlated Color Temperature ............................................................... 3-43

3.5.1.5 Ballast Interoperability........................................................................... 3 -43

3.5.1.6 Wattage .................................................................................................. 3 -43

3.5.1.7 Color Rendering Index ........................................................................... 3 -44

3.5.1.8 Product Class Summary ......................................................................... 3 -44

3.5.2 Incandescent Reflector Lamps ........................................................................... 3 -44

3.5.2.1 Wattage .................................................................................................. 3 -45

3.5.2.2 Spectrum ................................................................................................ 3-46

3.5.2.3 Diameter ................................................................................................. 3 -46

3.5.2.4 Rated Voltage......................................................................................... 3-46

3.5.2.5 Beam Spread .......................................................................................... 3-47

3.5.2.6 Center Beam Candle Power ................................................................... 3 -47

3.5.2.7 Length .................................................................................................... 3 -47

3.5.2.8 Product Class Summary ......................................................................... 3 -483

- iii LIST OF TABLES

Table 3.3.1 EPAct 1992 Federal Regulations for General Service Fluorescent Lamps .............. 3 -9 Table 3.3.2 2009 Lamps Rule Federal Regulations for General Service Fluorescent Lamps ... 3 -10 Table 3.3.3 EPAct 1992 Federal Regulations for IRLs ............................................................. 3-10 Table 3.3.4 2009 Lamps Rule Federal Regulations for IRLs .................................................... 3 -11 Table 3.3.5 Canadian Energy Efficiency Regulations for Incandescent Reflector Lamps ........ 3 -13 Table 3.3.6 EU Minimum Efficacy for T8 and T5 Fluorescent Lamps ..................................... 3 -14 Table 3.3.7 EU Deduction Percentages for Efficacy Values for Fluorescent Lamps ................ 3 -15 Table 3.3.8 EU Lamp Lumen Maintenance Factors for Fluorescent Lamps ............................. 3-15 Table 3.3.9 EU Deduction Percentages for Fluorescent Lamp Lumen Maintenance Requirements

................................ .................................................................................................................... 3 -16 Table 3.3.10 EU Lamp Survival Factors for Fluorescent Lamps .............................................. 3 -16 Table 3.3.11 NEMA Shipments of Four-Foot Medium Bipin GSFLs ...................................... 3 -20 Table 3.3.12 NEMA Shipments of Eight-Foot Single Pin Slimline GSFLs .............................. 3-21 Table 3.3.13 NEMA Shipments of Two-Foot U-Shaped GSFLs .............................................. 3 -21 Table 3.3.14 NEMA Shipments of Eight-Foot Recessed Double Contact High Output GSFLs .. 3

- 22 Table 3.3.15 NEMA Shipments of Four-Foot T5 Miniature Bipin Standard Output and High Output GSFLs ............................................................................................................................ 3-22 Table 3.3.16 NEMA Shipments of IRLs ................................................................................... 3 -23 Table 3.5.1 EPAct 1992 Product Classes for General Service Fluorescent Lamps ................... 3 -40 Table 3.5.2 GSFL Product Classes from the 2009 Lamps Rule ................................................ 3 -40 Table 3.5.3 GSFL Preliminary Analysis Product Classes ......................................................... 3-44 Table 3.5.4 EPAct 1992 Product Classes for Incandescent Reflector Lamps ........................... 3-45 Table 3.5.5 IRL Product Classes from the 2009 Lamps Rule ................................................... 3 -45 Table 3.5.6 IRL Preliminary Analysis Product Classes ............................................................. 3-48

LIST OF FIGURES

Figure 3.4.1 Lamp Length Effects on Efficacy.......................................................................... 3 -25 Figure 3.4.2 Lamp Fill Gas Effect on UV Output for T12 Lamps ............................................ 3 -27 Figure 3.4.3 Lamp Fill Gas Effect on Thermionic Emission for T12 Lamps ............................ 3-28 Figure 3.4.4 Human Eye Photopic Spectral Luminous Efficiency Function, V(λ) ................... 3 -29 Figure 3.4.5 Light Output versus Phosphor Thickness .............................................................. 3-30 Figure 3.4.6 Sample Power Spectrum Distribution ................................................................... 3 -30 Figure 3.4.7 Bulb Diameter versus Efficacy .............................................................................. 3 -32 Figure 3.4.8 Radiating Characteristics of Tungsten................................................................... 3 -34 Figure 3.4.9 Luminous Efficacy versus Color Temperature...................................................... 3 -353

- 1 CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT

3.1 INTRODUCTION

This chapter consists of four sections: scope of coverage, market assessment, the

tec hnology assessment, and product classes. The scope of coverage describes the products covered under this rulemaking and discusses certain amendments to the definitions of these products being considered by the U.S. Department of Energy ( DOE ). The market assessment provides an overall picture of the market for the products concerned, including the nature of the products, industry structure, and manufacturer market shares; regulatory and non-regulatory efficiency improvement programs; market trends; and quantities of products sold. The

tec hnology assessment identifies a preliminary list of technologies to consider in the screening analysis. The product classes section discusses the class-setting factors DOE considered for this

rule making.

The information DOE gathers from the market and technology assessment serves as resource material for use throughout the rulemaking. DOE considers both quantitative and qualitative information from public ly available sources and interested parties.

3.2 SCOPE OF COVERAGE

The following sections describe in more detail the definitions for both general service

fluor escent lamps (GSFLs) and incandescent reflector lamps (IRLs) that are covered in this rulemaking. Further, DOE evaluates clarifications of certain exemptions in the definition of “general service fluorescent lamp,” extending standards to additional GSFL types; and including

a dditional IRLs in the scope of coverage.

3.2.1 General Service Fluorescent Lamps

Section 321 of the Energy Policy and Conservation Act (EPCA; 42 U.S.C. 6291 et seq. ) contains definitions for fluorescent lamps and associated terms. DOE codified the statutory definitions and definitions of supplementary terms for fluorescent lamps in the Code of Federal Regulations (CFR). 10 CFR 430.2. These definitions are provided below and also listed in appendix 3A of this preliminary technical support document (TSD).

3.2.1.1 Current CFR Definitions

10 CFR 430.2 defines a fluorescent lamp and general service fluorescent lamp as follows :

Fluorescent lamp means a low pressure mercury electric-discharge source in which a fluorescing coating transforms some of the ultraviolet energy generated by the mercury discharge into light, including only the following: (1) Any straight-shaped lamp (commonly referred to as 4-foot medium bipin lamps) with medium bipin bases of nominal overall length of 48 inches and rated wattage of 25 or

more; (2) Any U-shaped lamp (commonly referred to as 2-foot U-shaped lamps) with medium bipin bases of nominal overall length between 22 and 25 inches and rated wattage of 25

or more; (3) Any rapid start lamp (commonly referred to as 8-foot high output lamps) with recessed double contact bases of nominal overall length of 96 inches;3

- 2 (4) Any instant start lamp (commonly referred to as 8-foot slimline lamps) with single pin bases of nominal overall length of 96 inches and rated wattage of 52 or more; (5) Any straight-shaped lamp (commonly referred to as 4-foot miniature bipin standard output lamps) with miniature bipin bases of nominal overall length between 45 and 48 inches and rated wattage of 26 or more; and (6) Any straight-shaped lamp (commonly referred to 4-foot miniature bipin high output lamps) with miniature bipin bases of nominal overall length between 45 and 48 inches and rated wattage of 49 or more.

General service fluorescent lamp means any fluorescent lamp which can be used to satisfy the majority of fluorescent lighting applications, but does not include any lamp designed and marketed for the following nongeneral application: (1) Fluorescent lamps designed to promote plant growth; (2) Fluorescent lamps specifically designed for cold temperature applications; (3) Colored fluorescent lamps; (4) Impact-resistant fluorescent lamps; (5) Reflectorized or aperture lamps; (6) Fluorescent lamps designed for use in reprographic equipment; (7) Lamps primarily designed to produce radiation in the ultra-violet region of the spectrum; and (8) Lamps with a Color Rendering Index of 87 or greater.

10 CFR 430.2

3.2.1.2 Clarification of GSFL Definitions

DOE received several queries from the general public on the application of the exemptions listed in the GSFL definition. DOE is considering whether further clarity should be provided for these exemptions. DOE evaluated each one and found that “impact-resistant fluorescent lamps” and “reflectorized or aperture lamps” were the only two exemptions and “use in reprographic material” and “the ultra-violet region of the spectrum” were the only two terms not defined elsewhere or the application of the exemption was not clearly stated. For example, “colored fluorescent lamps” are already defined separately within the CFR and “fluorescent lamps designed to promote plant growth” clearly specifies the function of the lamps such thattheir identification is unambiguous. To provide further clarification on the terms “impactresistant,” “reflectorized or aperture,” “reprographic equipment,” and “ultra-violet region of the spectrum,” DOE examined industry bulletins, product literature, and other online publications.

Thr ough this research and manufacturer interviews, DOE has found “impact-resistant” to be synonymous with “shatter-resistant” and is considering a definition for “impact-resistant fluorescent lamp” based on the existing definition of “shatter-resistant lamp” in 10 CFR 430.2 as

follows:

Impact-resistant fluorescent lamp means a lamp that:

a. Has a coating or equivalent technology that is compliant with NSF/ANSI 51 (incorporated by reference; see §430.3) and is designed to contain the glass if the glass envelope of the lamp is broken; and

b. Is designated and marketed for the intended application, with

i. The designation on the lamp packaging; and3

- 3 ii. Marketing materials that identify the lamp as being impact-resistant, shatter-resistant, shatter-proof, or shatter-protected.

Product literature, industry bulletins, and online publications indicated that “reflectorized or aperture lamp” refers to lamps that contain an inner reflective coating on the bulb to direct emitted light. Therefore, DOE is considering defining “reflectorized or aperture lamp” as

follows:

Reflectorized or aperture lamp means a fluorescent lamp that contains an inner reflective coating on the bulb to direct the light.

Addtionally, DOE is considering adding more detail for “use in reprographic material”

an d “the ultra-violet region of the spectrum” to provide a better understanding of DOE ’s interpretation of these terms. DOE has found that “fluorescent lamp[s] designed for use in reprographic equipment” are intended for use in equipment that is used to reproduce, reprint, or copy graphic material. Therefore, DOE is considering defining “fluorescent lamps designed for

use in r eprographic equipment” as follows:

Fluorescent lamps designed for use in reprographic equipment means fluorescent lamps incorporated i n equipment used to reproduce, reprint, or copy graphic material.

Concerning “lamps primarily designed to produce radiation in the ultra-violet region of the spectrum,” DOE determined that the term “ultra-violet region of the spectrum” refers to the portion of the electromagnetic spectrum where light has a wavelength between 10 and 400 nanometers. Therefore, DOE is considering adding detail to the exemption as follows:

Lamps primarily designed to produce radiation in the ultra-violet region of the spectrum mean fluorescent lamps that primarily emit light in the portion of the electromagnetic spectrum where light has a wavelength between 10 and 400 nanometers.

DOE is also considering clarification of references to “designed” and “marketed” as applied to definitions of lighting products covered under DOE standards. These terms are generally used to restrict lamps to use in certain intended applications and/or functions and to limit potential loopholes. Therefore, DOE is considering the terms “designed,” “ de sig nated,” “designation,” “designated and marketed,” and “designed and marketed” for covered lighting products to mean that in a publicly available document ( e.g. , product literature, catalogs, labels), manufacturers explicitly state the application for which the lamp is intended.

Please see chapter 2 of this TSD for more discussion on DOE’s consideration o f additional fluorescent lamps and its interpretation of EPCA’s definitions.

3.2.1.3 Additional GSFL Wattages

I n its review of the market, DOE determined that there are fluorescent lamps with lower wattages than those specified in DOE’s definition. Specifically, DOE found lower wattage lamps for the 8-foot single pin ( SP ) slimline, 4-foot T5 miniature bipin (MiniBP) standard output ( SO ),

and 4 -foot T5 MiniBP high output ( HO ) lamp types. DOE currently covers 8-foot SP slimline3

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lamps with wattages of 52 W or more. The 8-foot SP slimline lamps are now being offered in lower wattages of 49 W, 50 W, and 51 W. DOE currently covers 4-foot T5 MiniBP SO lamps

with wa ttages of 26 W or more. The 4-foot T5 MiniBP SO lamps are now being offered at a lower wattage of 25 W. DOE currently covers 4-foot T5 MiniBP HO lamps with wattages of 49 W or more. The 4-foot T5 MiniBP HO lamps a re now being offered at lower wattages of 44 W and 47 W. These reduced-wattage lamps are generally more efficacious than their full wattage counterparts and, because of their lower wattage, offer the potential for increased energy savings. Further, manufacturer feedback indicated that the lower wattage lamp market will only grow in

siz e. Therefore, DOE is considering extending coverage to the following GSFLs:

 8 -foot SP slimline lamps with wattages ≥ 49 W and < 52 W;

 4 -foot MiniBP SO lamps with wattages ≥ 25 W and < 26 W; and

 4 -foot MiniBP HO lamps with wattages ≥ 44 W and < 49 W.

3.2.1.4 Additional GSFL Types

As part of this energy conservation standards rulemaking, DOE is directed to evaluate energy efficiency standards for additional GSFLs beyond those already covered. 42 U.S.C. 6295 (i) (5) To identify the potential additional GSFLs, DOE first review ed the fluorescent lighting

market and identified lamps that meet the general description of a “fluorescent lamp” in the

int roductory language of 42 U.S.C. 6291(30)(A), that can be used to satisfy the majority of fluorescent lighting applications, that are not within the exclusions specified in 42 U.S.C. 6291(30)(B), and for which EPCA does not already prescribe standards. 73 FR 13629, 13620 (March 13, 2008). For each additional GSFL identified, DOE then assessed whether standards for such lamps would result in significant energy savings and, further, if such standards are

tec hnologically feasible and economically justified. Standards for any applicable additional GSFL are adopted based on the same criteria used to set new or amended standards for products per 42 U.S.C. 6295(o).

Fluorescent lamps come in three primary shapes: linear, U-shaped, and circline. Current standards cover certain linear and U-shaped lamps. There is little publicly available information on the installed stock and energy consumption of circline lamps. The 2010 U.S. Lighting Market Characterization (LMC) report includes these lamps under the miscellaneous category for fluorescent lamps, which composed 2.1 percent of lighting and consumed 4 terrawatt-hour (TWh) of electricity in 2010. a Circline lamps would only be a small portion of the installed stock and energy consumption of this category, which includes all fluorescents other than T5 linear and T8 and T12 linear and U-shaped lamps, as well as fluorescent lamps with unknowncharacteristics. The low levels of installed stock and energy consumption for these alternateshaped fluorescent lamps indicate limited potential for energy savings. Additionally, feedback from manufacturer interviews confirmed that fluorescent lamps in shapes not covered do not comprise a significant portion of the market. Based on this analysis DOE is not considering extending coverage to fluorescent lamps with shapes not currently covered.

a U.S. Department of Energy. 2010 U.S. Lighting Market Characterization . January 2012. Available at http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf

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DOE’s assessment of linear fluorescent lamps with lengths not covered shows that standards for these lamp types would not likely result in significant energy savings. Linear medium bipin (MBP) lamps come in lengths ranging from 1 to 6 feet and are mainly T8 and T12 diameters. Currently only 4-foot MBP linear lamps are covered by standards. DOE’s analysis

shows that 5- and 6 -foot linear fluorescent lamps compose a very low percentage of the linear

MB P product offerings. For the T8 MBP lamps with lengths less than 4 feet, according to the 2010 LMC, these lamps composed about 0.2 percent of all installed lighting and consumed 1

TW h of electricity in 2010. b The installed inventory of T12 MBP lamps with lengths less than 4 feet is even less than the T8 lamps. The low levels of installed stock and energy consumption of these lamps indicate limited potential for energy savings. Further, in interviews manufacturers confirmed that linear fluorescent lamps with alternate lengths do not represent a significant portion of the market. Based on this analysis, DOE is not considering extending coverage to linear fluorescent lamps with lengths not currently covered.

Additionally, DOE determined that compact fluorescent lamps (CFLs) are included in the “general service lamps” definition, which also mentions general service incandescent lamps, general service light-emitting diode lamps, and organic light-emitting diode lamps, but excludes

a ny general service fluorescent lamp. DOE has determined that the term “compact fluorescent lamps” in this definition includes both pin base and medium base CFLs. Under 42 U.S.C. 6295(i)(6), DOE is required to initiate a rulemaking for general service lamps no later than January 2014. This requirement indicates that it was intended for DOE to establish standards for lamps categorized as general service lamps, including CFLs, in a rulemaking separate from GSFLs. Therefore, DOE has determined that CFLs do not fall within the scope of this rulemaking.

3.2.2 Incandescent Reflector Lamps

As with GSFLs, DOE codified the statutory definitions and definitions of supplementary terms for IRLs in the CFR. The definition of “incandescent reflector lamp” contains several

ter ms that limit the scope of IRLs. Appendix 3A of this TSD contains statutory and CFR definitions for many of these terms. 10 CFR 430.2 defines an incandescent reflector lamp a s:

Incandescent reflector lamp (commonly referred to as a reflector lamp) means any lamp in which light is produced by a filament heated to incandescence by an electric current, which: is not colored or designed for rough or vibration service applications that contains an inner reflective coating on the outer bulb to direct the light; has an R, PAR, ER, BR,

BPAR c , or similar bulb shapes with an E26 medium screw base; has a rated voltage or voltage range that lies at least partially in the range of 115 and 130 volts; has a diameter

that exceeds 2.25 inches; and has a rated wattage that is 40 watts or higher.

b U.S. Department of Energy. 2010 U.S. Lighting Market Characterization . January 2012. Available at http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf

.
c Lamp shapes: R (reflector), PAR (parabolic aluminized reflector), ER (elliptical reflector); BR (bulged reflector)

, BPAR (bulged parabolic aluminum reflector)3

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Certain reflector (R), elliptical reflector (ER), and bulged reflector (BR) IRLs are covered by this definition but are not included in this rulemaking. Section 322(b) of EISA 2007, in

a mending EPCA to set forth revised standards for IRLs in new section 325(i)(1)(C), exempted from these standards the following categories of IRLs: (1) lamps rated 50 watts or less that are ER30, BR30, BR40, or ER40; (2) lamps rated 65 watts that are BR30, BR40, or ER40 lamps; and (3) R20 incandescent reflector lamps rated 45 watts or less. (42 U.S.C. 6295(i)(C)) (DOE refers to these three categories of lamps collectively as “certain R, ER, and BR IRLs.”) DOE subseque ntly determined that this EISA 2007 amendment exempted these lamps from

re gulations that existed at that time but did not preclude them from future regulations. However, because the rulemaking process for the first cycle of amendments to GSFL and IRL standards

pe r 42 U.S.C. 6295(i)(5) (hereafter “2009 Lamps Rule”) d was already underway, DOE decided to initiate a separate rulemaking for these certain R, ER, and BR IRLs. Therefore, DOE is not considering amending standards for these products in this rulemaking. (See chapter 2 of the TSD for further discussion.)

With respect to wattage, while the definition requires IRLs to have a “rated wattage that

is 40 watts or higher, ” current IRL standards are set for the 40-205 W range. DOE assessed this upper limit of the wattage range for covered IRLs. Based on a review of manufacturer catalogs,

DO E determined that IRLs with rated wattages greater than 205 W compo se a very small portion of the market and, therefore, do not represent substantial potential energy savings. Furthermore,

man y of these products are designed for specialty uses such as heating and drying in industrial and commercial applications, or for use in swimming pools. For these reasons, DOE is not considering coverage for IRL s with rated wattages greater than 205 W.

3.3 MARKET ASSESSMENT

For both GSFLs and IRLs, the following market assessment identifies the relevant

manuf acturer trade association and domestic manufacturers; discusses manufacturer market share, regulatory programs, and non-regulatory initiatives; defines product classes; and p rovides historical shipment data.

3.3.1 Trade Association

The National Electrical Manufacturers Association (NEMA) is the trade association for GSFLs and IRLs. NEMA’s Lighting Systems Division is one of ten product divisions, and is

fur ther divided into six product sections. The Lamp Section’s 27 member companies compo se ,

a ccording to manufacturer interviews, about 90 percent of the U.S. GSFL and IRL markets. In

a ddition to GSFLs and IRLs, NEMA’s Lighting Systems Division also oversees products such as ballasts, emergency lighting, lighting controls, luminaires, solid state lighting, and other

e merging lighting technologies. NEMA provides an organization through which manufacturers of lighting equipment can work together on projects that affect their industry and business es

. NEMA’s activities relating to energy efficiency include: 1

d The final rule for this first cycle of amendments to GSFL and IRL standards was published in July 2009. 74 FR 34080 (July 14, 2009)

.3

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 “[a]dvising the U.S. Department of Energy ( DOE ) and U.S. Environmental Protection Agency (EPA) on lighting research and market transformation needs;

 engaging in legislative work on energy and lighting issues;

 monitoring energy-efficiency rulemakings and standards affecting lighting products by

fe deral and state agencies;

 supporting adoption of ASHRAE/IESNA 90.1 lighting provisions;

 working with market transformation and environmental groups to advance market use of energy-efficient lighting technologies;

 advising DOE and EPA on ENERGY STAR Buildings and ENERGY STAR voluntary product labeling programs; and

 advocating market-based approaches to enhance the use and penetration of energyefficient technologies.”

3.3.2 Manufacturers and Market Share

The following list contains the names of manufacturers that produce GSFLs:

 Atlas Lighting Products, Inc.

 Bulbrite Industries, Inc.

 EiKO, Ltd.

 Feit Electric Company, Inc.

 GE Consumer & Industrial

 Halco Lighting Technologies

 Havells USA

 Litetronics International, Inc.

 MaxLite

 OSRAM SYLVANIA Inc.

 OttLite Technologies Inc.

 Philips Lighting Company

 Plusrite Electric (China) Co., Ltd.

 Satco Products, Inc.

 SL I Lighting

 Technical Consumer Products, Inc.

 Topaz Lighting Corp.

 Universal Lighting Technologies

 Ushio America, Inc.

 Westinghouse Lighting Corporation

The following list contains the names of manufacturers that produce IRLs:

 Advanced Lighting Technologies Inc.

 Bulbrite Industries, Inc.

 EiKO, Ltd.

 EYE Lighting International of N.A., Inc.

 Feit Electric Company, Inc.3

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 GE Consumer & Industrial

 Green Energy Lighting Corp.

 Halco Lighting Technologies

 Havells USA

 Howard Industries Inc.

 Litetronics International, Inc.

 OSRAM SYLVANIA Inc.

 Philips Lighting Company

 Premium Quality Lighting, Inc.

 RAB Lighting

 Satco Products, Inc.

 SLi Lighting

 Technical Consumer Products, Inc.

 Ushio America, Inc.

 Venture Lighting International

 Westinghouse Lighting Corporation

The GSFL and IRL industries are characterized by both domestic and international manufacturers. The majority of covered GSFLs and IRLs are manufactured by three large

c ompanies. The three manufacturers that hold the majority of the domestic market share of GSFLs and IRLs are the following:

 GE Consumer and Industrial of General Electric, Inc. (hereafter “GE”)

 OSRAM SYLVANIA of Siemens AG (hereafter “OSI ”)

 Philips Lighting Company of Philips Electronics North America Corporation (hereafter

“ Philips”)

In addition to lamps listed under this rulemaking, the lighting divisions of all threecompanies manufacture other products, such as ballasts, high intensity discharge lamps, lighte mitting diodes (LEDs), and CFL s.

3.3.2.1 Small Businesses

Small businesses may be particularly affected by the promulgation of minimum energy conservation standards for GSFLs and IRLs. The Small Business Administration (SBA) lists

small business size standards that are matched to industries as they are described in the North American Industry Classification System (NAICS). A size standard is the largest that a for-profit

c oncern can be and still qualify as a small business for Federal Government programs. These size

standa rds are generally the average annual receipts or the average employment of a firm. For lamps, t he size standard is matched to NAICS code 335110, Elec tric Lamp Bulb and Part Manufacturing , which has a size standard of 1,000 employees or fewer. 2

DOE studies the potential impacts on these small businesses in detail as part of the manufacturer impact analysis.3

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3.3.3 Regulatory Programs

Several federal and international regulatory programs affect the markets for GSFLs and

I RLs. The following section summarizes U.S., Canadian, and European regulatory initiatives relevant to the lamps covered by this rulemaking. While the following discussion is not exhaustive in describing all regulatory action related to GSFLs and IRLs, it provides detail on

some nota

ble initiatives that characterize recent developments in the lighting market.

3.3.3.1 GSFL Federal Energy Conservation Standards

EPCA established an energy conservation program for major household appliances.

Additi onal amendments to EPCA gave DOE the authority to regulate the energy efficiency of several products, including certain GSFLs. Specifically, the Energy Policy Act of 1992 (EPAct 1992), Pub. L. 102 -486, established energy conservation standards for 4 -foot MBP, 2-foot Ushape d, 8-foot SP slimline, and 8-foot recessed double contact (RDC) HO GSFLs. The standards mandate that lamps manufactured on or after the specified effective dates must meet the

mi nimum color rendering index (CRI) and minimum average lamp efficacy requirements. (42

U.S.C . 6295(i)(1)); 10 CFR Section 430.32(n)(1) Table 3.3. 1 presents thes e Federal standards.

Table 3.3. 1 EPAct 1992 Federal Regulations for General Service Fluorescent Lamps

Lamp Type Nominal Lamp Wattage

W Minimum

CRI Minimum Average Lamp Efficacy
lm/W Effective

Date

4

- f oot medium

b ipin > 35 W 69 75.0 Nov. 1, 1995
≤ 35 W 45 75.0 Nov. 1, 1995

2

- f oot U

- s haped > 35 W 69 68.0 Nov. 1, 1995
≤ 35 W 45 64.0 Nov. 1, 1995

8

- f oot s limline e > 65 W 69 80.0 May 1, 1994
≤ 65 W f 45 80.0 May 1, 1994

8

- f oot h igh o utput > 100 W 69 80.0 May 1, 1994
≤ 100 W 45 80.0 May 1, 1994

EPCA directs DOE to conduct two cycles of rulemakings to determine whether to amend GSFL standards, and to determine whether to adopt standards for additional types of GSFLs. (42

U.S.C . 6295(i)(3)–(5)) Today’s rulemaking represents the second rulemaking to evaluate

a mending the GSFL energy conservation standards. The first rulemaking, the 2009 Lamps Rule,

re sulted in a final rule published in the Federal Register on July 14, 2009, which, as directed by 42 U.S.C. 6295(i)(3), altered EPAct 1992 standards and, as directed by 42 U.S.C. 6295(i)(5),

a lso adopted energy conservation standards for additional GSFLs. 74 FR 34080. The 2009

L amps Rule adopted the lamp efficacy standards shown in Ta ble 3.3

. 2 for GSFLs ma nufactured after July 14, 2012. 10 CFR Section 430.32(n)(3)

e Shown correctly in this table; as written in the CFR, the ≤ 35W class was misattributed to 8-foot slimline lamps.

f Shown correctly in this table; as written in the CFR, “ ˃ 65W” is erroneously repeated in this cell.3

- 10

Table 3.3. 2 2009 Lamps Rule Federal Regulations for General Service Fluorescent Lamps

Lamp T ype Correlated Color T emperature Minimum Average Lamp Efficacy
lm/W

4

- foot medium b ipin ≤4,500 K 89 >4,500 K and ≤7,000 K 88

2

- foot U

- s haped ≤4,500 K 84

> 4,500 K and ≤7,000 K 81

8

- foot s limline ≤4,500 K 97 >4,500 K and ≤7,000 K 93

8

- foot high o utput ≤4,500 K 92 >4,500 K and ≤7,000 K 88

4

- foot miniature bipin

standard o utput ≤4,500 K 86 >4,500 K and ≤7,000 K 81

4

- foot miniature bipin high o utput ≤4,500 K 76 >4,500 K and ≤7,000 K 72

3.3.3.2 IRL Federal Energy Conservation Standards

As with GSFLs, amendments to EPCA in EPAct 1992 established energy conservation

standa rds for IRLs. (42 U.S.C. 6291(1) and 42 U.S.C. 6295(i)(1)) In addition, subsequent amendments to EPCA in the Energy Independence and Security Act of 2007 (EISA 2007), Pub. L. 110-140, amended the existing standards for IRLs. Table 3.3

. 3 outlines these amended standards. EPCA mandated that all lamps manufactured after November 1, 1995 meet six

e fficacy requirements with minimum lamp efficacy varying by nominal lamp wattage. EISA

2007 a mended EPCA’s definition for IRL and amended the standard in 42 U.S.C. 6295(i)(1). Prior to EISA 2007, the statutory definition for IRLs excluded ER- and BR-shaped lamps andlamps with a diameter less than 2.75 inches. EISA 2007 amended this definition to include ERand BR-shaped lamps and lamps with diameters greater than 2.25 inches. EISA 2007 also

a mended 42 U.S.C. 6295(i)(1) to exempt the following lamps from the minimum efficacy requirements: (1) lamps rated at 50 watts or less that are ER30, BR30, BR40, and ER40; (2) lamps ra ted at 65 watts that are BR30, BR40, or ER40 lamps; and (3) R20 incandescent reflector lamps rated 45 watts or less.

Table 3.3. 3 EPAct 1992 Federal Regulations for IRLs

Nomi nal Lamp Wattage

W Minimum Average Lamp Efficacy
lm/W

40

- 50 10.5

51

- 66 11.0

67

- 85 12.5

86

- 115 14.0

116

- 155 14.5

156

- 205 15.0

Along with GSFL standards, EPCA directs DOE to conduct two cycles of rulemakings to determine whether to amend IRL standards. (42 U.S.C. 6295(i)(3)–(5)) Today’s rulemaking

re presents the second rulemaking to evaluate amending the IRL energy conservation standards.3

- 11

The first rulemaking, the 2009 Lamps Rule, resulted in a final rule that, as directed by 42 U.S.C. 6295( i)(3), amended EPAct 1992 standards for covered IRLs manufactured after July 14, 2012,

as shown in Table 3.3

. 4 . 10 CFR Section 430.32(n)(5)

T able 3.3. 4 2009 Lamps Rule Federal Regulations for IRLs

Rated Lamp

W attage Lamp S pectrum Lamp Diameter
inches Rated V oltage Minimum Average

L amp Efficacy
lm/W

40

– 205 Standard Spectrum >2.5 ≥125 V 6.8*P 0.27

<125 V 5.9*P 0.27

≤2.5 ≥125 V 5.7*P 0.27

<125 V 5.0*P 0.27

40

– 205 Modified Spectrum >2.5 ≥ 125 V g 5.8*P 0.27

<125 V 5.0*P 0.27

≤2.5 ≥125 V 4.9*P 0.27

<125 V 4.2*P 0.27

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.

3.3.3.3 California Energy Commission

California’s Office of Administrative Law (OAL) enacts statewide regulatory programs published in the California Code of Regulations (CCR). CCR Title 20, Division 2, Chapter 4,

Article 4, Section 1605.3 contains state regulations for IRLs in accordance with the WarrenAlquist State Energy Resources Conservation and Development Act, last revised in May 2012. This law requires that lighting standards be set to achieve a 50 percent reduction in energy

c onsumption from 2007 levels for indoor residential lighting and a 25 percent reduction from 2007 levels for indoor commercial and outdoor lighting by 2018. Current CCR standards for IRLs are identical to EPAct 1992 standards including the EISA 2007 exemptions.

CCR Title 24, Part 6 contains the 2013 Building Energy Efficiency Standards, Section 110.9 of which mandates requirements for lighting control devices and systems, ballasts, and luminaires. These regulations were approved in May 2012 and go into effect on January 1, 2014, replacing the 2008 Building Energy Efficiency Standards. The 2013 Building Energy Efficiency Standards are 25 percent more efficient than the previous standards for residential construction and 30 percent more efficient for non -residential construction. 3 Products regulated by Title 24 include those that can be used with GSFLs and IRLs, such as automatic time-switch control devices, occupancy sensors, multilevel occupancy sensors, automatic daylighting control devices, interior photosensors, multilevel and outdoor astronomical time-switch controls,

g Shown correctly in this table; erroneously written as “≤125V” in the CFR. See chapter 2 for further discussion.3

- 12

manual-on occupancy sensors, dimmers, integral current limiters, ballasts for residential recessed luminaires, and dimming fluorescent ballasts. The regulations mandate that the products have specific features and capabilities in order to be installed.

3.3.3.4 Canadian Energy Efficiency Standards

The Natural Resources Canada (NRCan) Office of Energy Efficiency regulates the energy efficiency of GSFLs and IRLs in Canada. h In 1992, the Canadian Parliament passed the Energy Efficiency Act (S.C. 1992, c. 36), which concerns minimum performance levels for energy-using products, effective February 1995. In November 1995, Canada’s Energy Efficiency Regulations (SOR/94-651) were amended to include GSFLs and IRLs.

Canada’s approach to the regulation of GSFLs closely resembles the U.S. Federal Efficiency Standards established by EPAct 1992 discussed in section 3.3.3.1 . Though there are minor variations in definitions between the U.S. and Canadian standards, they effectively cover the same product. The Canadian minimum average CRI and lamp efficacy levels for GSFLs

established in the 1995 amendments are identical to those shown in Table 3.3

. 1 . In May 2010, NRCan published a bulletin proposing amendments to the regulations in order to modify GSFL definitions and to harmonize standards with the 2009 Lamps Rule, with the proposed amendments applying to those products manufactured on or after July 14, 2012. At the time of

thi s analysis these proposed amendments had not been adopted.

Regarding IRLs, the 1995 amendments to SOR/94-651 included general service IRLs i
with minimum performance requirements consistent with EPAct 1992. However, differing

sli ghtly from the U.S. approach, an amendment in April 2003 revised the Regulations to include certain ER and BR IRLs. Specifically, NRCan amended the Regulations to apply to general

service IRLs with:

 an R, PAR, BR, ER or bulb shape similar to R, PAR, BR or ER as described by ANSI C79.1;

 an E26/24 single contact, or E26/50x39 skirted, medium screw base;

 a nominal voltage or voltage range that lies at least partially between 100 and 130 V;

h News and information on NRCan energy efficiency regulations and standards can be found at http://oee.nrcan.gc.ca/regulations/11239.

i The current definition of “general service incandescent reflector lamp” in SOR/94-651 is as follows: “general service incandescent reflector lamp” means an incandescent reflector lamp with a bulb shape as described in ANSI C79.1 or similar shape that has (a) an E26/24 single contact or E26/50 × 39 skirted, medium screw base, (b) a nominal voltage or voltage range that lies at least partially between 100 V and 130 V, (c) a diameter greater than 57 mm, and (d) a nominal power of not less than 40 W and not more than 205 W;

but does not include (e) a coloured lamp, (f) a BR30 lamp or BR40 lamp with a nominal power of up to 50 W, or 65 W, (g) a R20 lamp with a nominal power of not more than 45 W, (h) a silver bowl lamp, or (i) a lamp for heat-sensitive applications”3

- 13

 a diameter greater than 70 mm (2.75 in.); and

 a nominal power of not less than 40 W and not more than 205 W.

The amendment also exempted BR30 lamps of 66 W or less; 85 W BR30 lamps and BR38 to BR40 lamps with a rated power of less than 121 W. In October 2011 , NRCan published

an amendment to the existing Regulations to harmonize with EISA 2007; the amendment came

int o force April 12, 2012.

In April 2010, NRCan had proposed an amendment to harmonize with the 2009 Lamps

Rule. NRCan’s amendment wa s proposed to become effective July 14, 2012. In November 2011, NRCan revised the definition of IRLs in the April 2010 proposed amendment to match the definition ultimately published in the October 2011 amendment. At the time of this analysis this

pr oposed amendment had not been adopted. The current Canadian Regulations are shown in

Ta ble 3.3. 5

.

Table 3.3. 5 Canadian Energy Efficiency Regulations for Incandescent Reflector Lamps
Rated Wattage

W Minimum Average Efficacy

lm/W

ER30 or ER40 IRLs
≤ 50 7.0

Other ER IRLs

50 7.0

75 6.5

120 10.0

All O ther Covered IRLs

40

- 50 10.5

51

- 59 11.0

60

- 85 12.5

86

- 115 14.0

116

- 155 14.5

156

- 205 15.0

3.3.3.5 European Energy Efficiency Standards

Commission Regulation (EU) No 347/2010 (April 21, 2010) amended Commission Regulation (EC) No 245/2009 (March 18, 2009), which implemented Directive 2005/32/EC (July 6, 2005) of the European Parliament and the Council of the European Union and amended Council Directive 92/42/EEC and Directives 96/57/EC and 2000/55/EC (September 18, 2000) to establish a framework for setting energy efficiency requirements for energy-using equipment, including fluorescent lamps and the ballasts and luminaires that are used with these lamps. The energy efficiency requirements apply to equipment available on the market and do not

diff erentiate requirements by lamp application. Lamps that are not white light sources, are directional, or intended for use in applications other than general lighting are exempted from standards. Additionally, the EU exempts lamps having:

 Six percent or more of total radiation of the range 250-780 nm in the range of 250- 400 nm;

 Eleven percent of total radiation of the range 250-780 nm in the range of 630-780 nm;3

- 14

 Five percent or more of total radiation of the range 250-780 nm in the range of 640- 700 nm; and

 The peak of the radiation between 315 -400 nm or 280-315 nm.

The EU also exempts double-capped fluorescent lamps having:

 A diameter of 7 mm (T2) and less;

 A diameter of 16 mm (T5) and lamp power P ≤ 13 W or P ˃ 80 W;

 A diameter of 38 mm (T12), lamp cap G-13 medium bipin (MBP) base, +/- 5 m color

c ompensating filter value limit (cc). International Commission on Illumination

c oordinates x = 0.330, y = 0.335 and x = 0.415, y = 0.377; and

 A diameter of 38 mm (T12) and equipped with an external ignition strip. 4 5

The European energy efficiency requirements regulate the covered equipment in stages.

F irst stage requirements began in 2010 and required double-capped fluorescent lamps of 16mm and 26mm ( i.e. , T5 and T8 lamps) without integrated ballasts to comply with the efficacies listed

in Table 3.3. 6 at 25 °C. Second stage requirements begin in 2013, requiring double-capped fluorescent lamps of other diameters than those covered in the first stage to meet the minimum efficacy requirement for T8 lamps given in the first stage. Third stage requirements begin in 2018, requiring minimum compatible ballast efficiencies for all fluorescent lamps without an integrated ballast.

Table 3.3. 6 EU Minimum Efficacy for T8 and T5 Fluorescent Lamps

T8 (26 mm Ø) T5 (16 mm Ø) High Efficiency T5 (16 mm Ø) High Output

Nominal wattage (W) Rated luminous

efficacy (lm/W),

100 h initial

value Nominal wattage

(W) Rated luminous

efficacy (lm/W)

100 h initial

value Nominal wattage

(W) Rated luminous

efficacy (lm/W),

100 h initial

value

15 63 14 86 24 73

18 75 21 90 39 79

25 76 28 93 49 88

30 80 35 94 54 82

36 93 80 77

38 87

58 90

70 89

Source: 245/2009/EC

2010/347/EU amended the efficacy deductions given in 2009/245/EC for fluorescent lamps with high color temperature, high color rendering, second lamp envelope, or long life, so that required efficacy is cumulatively reduced as shown in Table 3.3

. 7

.3

- 15

Table 3.3. 7 EU Deduction Percentages for Efficacy Values for Fluorescent Lamps

Lamp parameter Deduction from luminous efficacy at 25 °C

Tc ≥ 5,000 K

- 10%
95 ≥ Ra > 90

- 20%

Ra > 95

- 30% Second lamp envelope

- 10% Lamp Survival Factor ≥ 0.50 after 40,000 burning hours

- 5%

Source: 2010/347/EU

In addition to lamp efficacy, the EU standards contain requirements for lamp

pe rforman ce , including lamp lumen maintenance factor (LLMF) and lamp survival factor (LSF). The LLMF describes how bright a lamp remains as a percentage of the original brightness after a

g iven period of time, while the LSF describes how long a lamp lasts before ceasing to function

a nd requiring replacement, and is expressed as a percentage of the number of lamps still working after a specified period of time. 2010/347/EU amended the LLMF and LSF requirements given

in 2009/ 245/EC, and added cumulative LLMF deductions for certain lamps. Under current

standa rds, for the first stage requirements, T5 and T8 lamps must have a minimum 80 CRI. For the second stage requirements, all covered fluorescent lamps without an integrated ballast must have a minimum CRI of 80, an LLMF as shown in Table 3.3. 8 and Table 3.3

. 9 , and an LSF as
shown in Table 3.3

. 10

.

Table 3.3. 8 EU Lamp Lumen Maintenance Factors for Fluorescent Lamps

Lamp lumen maintenance factor Burning hours

Lamp types 2,000 4,000 8,000 16,000

Double

- Capped Fluorescent lamps operating on non

- high frequency ballasts 0.95 0.92 0.90

--

T8 Double

- Capped Fluorescent lamps on high frequency

ballast with warmstart 0.96 0.92 0.91 0.90

Other Double

- Capped Fluorescent lamps on high frequency

ballast with warmstart 0.95 0.95 0.90 0.90

Circular Single

- Capped Fluorescent lamps operating on

non

- h igh frequency ballasts, T8 U

- shaped double

- capped fluorescent lamps and spiral

- shaped double

- capped fluorescent lamps of all daimeters equal to or larger than 16 mm (T5) 0.80 0.74

-- --

0.72 at 5,000 burning hours

Circular Single

- Capped Fluorescent lamps operating on high frequency ballasts 0.85 0.83 0.80

-- 0.75 at 12,000 burning hours Other Single

- Capped Fluorescent lamps operating on non

high frequency ballasts 0.85 0.78 0.75

--
Other Single

- Capped Fluorescent lamps operating on high frequency ballast with warmstart 0.90 0.84 0.81 0.78

Source: 2010/347/EU3

- 16

Table 3.3. 9 EU Deduction Percentages for Fluorescent Lamp Lumen Maintenance

Re quirements

Lamp parameter Deduction from lamp lumen maintenance requirement

Lamps with 95 ≥ Ra > 90 At burning hours ≤ 8,000 h:

- 5% At burning hours > 8,000 h:

- 10%

Lamps with Ra > 95 At burning hours ≤ 4,000 h:

- 10% At burning hours > 4,000 h:

- 15% Lamps with a colour temperature ≥ 5,000 K

- 10%

Source: 2010/347/EU

Table 3.3. 10 EU Lamp Survival Factors for Fluorescent Lamps

Lamp survival factor Burning hours Lamp types 2,000 4,000 8,000 16,000

Double

- Capped Fluorescent lamps operating on non

- high frequency ballasts 0.99 0.97 0.90

--

Double

- Capped Fluorescent lamps on ghihg frequency

ballast with warmstart 0.99 0.97 0.92 0.90

Circular Single

- Capped Fluorescent lamps operating on non

high frequency ballasts, T8 U

- shaped double

- capped fluorescent lamps and spiral

- shaped double

- capped fluorescent lamps of all diameters equal to or larger than 16 mm (T5) 0.98 0.77

-- --

0.50 at 5,000 burning hours

Circular Single

- Capped Fluorescent lamps operating on high frequency ballasts 0.99 0.97 0.85

-- 0.50 at 12,000 burning hours Other Single

- Capped Fluorescent lamps operating on non

high frequency ballasts 0.98 0.90 0.50

--
Other Single

- Capped Fluorescent lamps on high frequency

ballast with warmstart 0.99 0.98 0.88

--

Source: 2010/347/EU

3.3.4 Non-Regulatory Initiatives

DOE reviewed several national, regional, and local voluntary programs that promote the use of energy efficient lighting in the United States. The following section summarizes these

pr ograms for the lamps covered by this rulemaking. While it is not an exhaustive list, the discussion provides detail on some notable initiatives that characterize recent developments in the lighting market.

3.3.4.1 Federal Energy Management Program

The Federal Energy Management Program (FEMP) helps Federal buyers identify and purchase energy efficient products including certain GSFLs. Section 161 of EPAct 1992 encourages energy efficient Federal procurement. Executive Order 12902 and FAR section 23.704 direct agencies to purchase products in the upper 25 percent of energy efficiency. FEMP typically provides recommendations of total light output (in lumens) and the best available models of fluorescent lamps. However, at the time of publishing, FEMP has temporarily suspende d its energy efficiency requirements for fluorescent lamps as it evaluates the market impact of the standards adopted by the 2009 Lamps Rule (hereafter “the July 2012 standards”). The program will issue updated energy efficiency requirements when the GSFL market distribution stabilizes. FEMP continues to offer buyer support tools, such as efficiency3

- 17

guidelines, cost-effectiveness examples, and a cost calculator. FEMP also offers training, on-site audits, demonstrations, and design assistance. 6

3.3.4.2 Consortium for Energy Efficiency

The Consortium for Energy Efficiency (CEE) has both a Residential Lighting Initiative and a High Performance Commercial Lighting Initiative. The Residential Lighting Initiative primarily promotes high efficiency fixtures and CFLs, neither of which are covered under this rulemaking. The purpose of CEE’s High Performance Commercial Lighting Initiative is to define what constitutes “high performance,” and the initial efforts have focused on efficient T8 fluorescent lighting pr oducts. On May 1, 2007, CEE updated its specification for high performance T8 lamps as a T8 lamp not greater than 32W, with minimum initial lamp lumens of 3,100 lumens or greater. 7 On January 23, 2007, CEE released its specification for reducedwattage T8 lamps as a lamp of 28W or 25W with minimum initial lumen output greater than or equal to 2,585 lumens or 2,400 lumens, respectively. CEE also provides a database of detailed

infor mation on over 160 utilities and efficiency program administrators that offer prescriptive

ince ntives towards the purchase of high efficiency commercial lighting equipment. The

infor mation was compiled in April 2011 and includes information on measures specifically

invol ving fluorescent lamps and ballasts, fluorescent fixtures, other lighting technologies, and lighting controls. 8

3.3.4.3 Energy Efficient Commercial Building Deduction

The Energy Policy Act of 2005 (Pub. L. 109-58 ; EPAc t 2005 ) created the Energy Efficient Commercial Buildings Deduction (26 U.S.C 179D), which establishes a tax deduction for building owners who incur expenses for energy efficiency upgrades. Originally effective for property in service from January 1, 2006 through December 31, 2008, the measure allows partial deductions for improvement in interior lighting. Projects must be certified to reduce total annual energy and power costs solely through changes to the building’s lighting, HVAC/hot water, and building envelope to at least 50 percent less than a reference building satisfying the requirements

of ASHRAE/IESNA 90.1-2001, or to at least 10-20 percent less energy consumption through lighting alone. Though the statute does not specify required lamp types or efficacies, it does call for an overall reduction in lighting power density. The Emergency Economic Stabilization Act of 2008 (HR-1424), approved and signed on October 3, 2008, extends the benefits of EPAct 2005 throug h December 31, 2013.

3.3.4.4 Efficiency Vermont – Agricultural Rebate Program

In Vermont, agricultural operations are eligible for prescriptive and customized incentives on equipment proven to help make farms more efficient. Efficiency Vermont gives prescriptive rebates for a variety of equipment and for lighting. Efficiency Vermont will rebate $ 5 0 to $100 per T12 fluorescent system replaced with a high performance T8 fluorescent system,

or a T5 HO fluorescent system. This version of the rebate expires at the end of 2013. 9

3.3.4.5 Pacific Gas and Electric Company Rebat es

Thr ough the Rebates for Multi-Family Properties Program, Pacific Gas and Electric Company (PG&E) offers prescriptive rebates for owners and managers of multi-family

C alifornia properties of two or more units. Fluorescent lighting improvements are among the3

- 18

eligible products for rebates. All equipment must meet program requirements listed on the PG&E program web site or application forms. Owners or managers can receive rebates of $25 to $45

pe r T8 or T5 fluorescent lamp-and -ballast system. 10 PG&E also offers rebates and other incentives to businesses and non-residential customers to increase their energy efficiency. To this effect, PG&E offers incentives for efficient building design and other energy efficient

im provements, including high performance GSFLs. PG&E will give rebates of $4.50 to $9 per

T5 or T8 lamp installed, $1 to $1.50 per full wattage T8 lamp replaced with a lower wattage lamp, and $6 to $20 per T12 lamp removed from a fixture ( i.e. , delamping). 11 These rebates expire March 1, 2013.

3.3.4.6 Northeast Energy Efficiency Partnerships

Northeast Energy Efficiency Partnerships (NEEP) is a regional nonprofit organization that promotes energy efficiency in the Northeast United States. NEEP currently runs both a Commercial Lighting Technologies initiative and a Hig h Efficiency Residential Lighting initiative. Through these programs, NEEP coordinates with and sponsors multiple local and state governments, utilities, and other initiatives, such as Efficiency Vermont and the Long Island Power Authority, to promote efficient lighting products. NEEP’s involvement in the commercial

se ctor is focused on whole building energy use and using efficacious lamps, including certain fluorescent lamps, to meet various lower energy use goals, moving toward net zero energy buildings. 12 NEEP’s residential lighting work aims to accelerate market adoption of high efficiency residential lighting by encouraging its members to implement their regional

R esidential Lighting Strategy (RLS), which includes the support of halogen IRLs, along with other efficacious technologies. 13

3.3.4.7 APS Rebate Programs

In Arizona, APS offers a number of incentives and rebate programs. Solutions for

Business offers incentives that help businesses increase energy efficiency and reduce energy use.

APS non-residential customers (including schools, small businesses, industrial facilities and publi c agencies) can choose energy efficiency measures with rebates for existing buildings and

ne w construction. For this program, APS provides a rebate for T8 and T5 fluorescent lamps and electronic ballasts at $5 to $12 per lamp-and-ballast system. APS also offers energy efficiency incentives to multi-family building residents. The program provides incentives for new construction and major renovation multi-family projects. Through this program, APS offers a

re bate of $5 to $10 per T8 and T5 fluorescent lamp.These programs expire at the end of 2012, but they are expected to be renewed pending Commission approval. 14

, 15

3.3.4.8 Cape Light Compact – Commercial, Industrial and Municipal Buildings

E nergy Efficiency Rebate Program

Through a multi-member partnership, Cape Light Compact (CLC) and Masssave offer a variety of financial incentives for commercial, industrial, and municipal facilities in

Massa chusetts. Custom rebate options are available for both new construction and retrofit measures in commercial/industrial buildings, as well as for small businesses and municipal projects. There are prescriptive rebates through the partnership on sensors and fluorescent

li ghting equipment and controls for el igible new and existing buildings. Rebates vary depending on whether projects are retrofit or new construction. Through this program, CLC offers $10 to $50 per fluorescent fixture in retrofits, and $10 to $35 per high efficiency fluorescent system3

- 19

along with $0.40 to $1.00 per watt saved through lighting in new construction. This program

e xpires October 31, 2015. 16

3.3.4.9 Central Electric Cooperative – Non-Residential Lighting Rebate

In Oregon, the Central Electric Cooperative offers a commercial lighting system improvement incentive for any customer not on a residential utility rate. The Central Electric Cooperative will give rebates of $10 to $40 per T12 fluorescent lamp-and-ballast replaced with a

T5 or T8 fluorescent lamp-and-ballast, $120 to $180 per high bay fixture of other lighting

tec hnology ( e.g. , mercury vapor, high pressure sodium, metal halide, incandescent) replaced with

a T8 or T5 fluorescent high bay fixture, and $50 to $100 per T12 fluorescent lamp fixture replaced with a T5 fluorescent lamp fixture. This rebate will continue through October 1, 2013and is expected to be extended past that date. The Central Electric Cooperative will give a sixmonth notice of alterations to the program. 17

3.3.4.10 Empire – Commercial and Industrial Energy Efficiency Rebates

The Empire District Electric Company (Empire) offers a Commercial/Industrial Prescriptive Rebate Program to its non-residential customers in Arkansas who purchase certain high efficiency equipment for eligible facilities. A variety of prescriptive rebates are available to customers served under any non-residential rate schedule in the Empire service territory. The rebates, which can be applied to both new construction and retrofit projects, are offered for certain equipment meeting the program’s energy efficiency standards. Empire offers a rebate of $0.50 to $16 per fluorescent lamp-and-ballast system, $9 to $18 per high performance T8

fluor escent lamp system, $40 to $125 per high bay fluorescent lamp-and-ballast system, $16 to $24 pe r pendant, wall mount, or recessed indirect fixture, and $50 per high intensity fluorescent lamp fixture. There are no expiration dates for these rebates at this time. 18

3.3.4.11 GVEA – Residential Rebate Program for Builders

Alaska’s Golden Valley Electric Association’s (GVEA) Builder $ense program targets home builders who install electrical energy efficiency measures during construction of residential buildings. Newly constructed residential buildings or residential buildings that have had major remodeling or additions are eligible for the rebate. The program gives a $20 rebate for all linear fluorescent lamps, except for T12s. In most cases, the applicant must have a minimum of four hard-wired fluorescent fixtures to be eligible. There is no expiration date for this program

a t this time. 19

3.3.5 Historical Shipments

Shipment data and market trend information are used to conduct the shipment analysis and develop base-case forecasts in the shipment analysis (see chapter 9 of this TSD). DOE also uses shipm ent data to identify and analyze representative product classes and lamps to ensure the analysis is representative of the market (see chapter 5 of this TSD ). Shipment data also feeds into the national impact analysis (see chapter 10 of this TSD). Based on its understanding of trends in the market, DOE estimated how the market would respond to the various CSLs. The following section outlines the publicly available historical data and trends for GSFLs and IRLs. For the

2009 Lamps Rule, NEMA provided historical shipments of GSFLs and IRLs from 2001 to 20053

- 20

in a public comment, 20 and for this rulemaking, NEMA provided GSFL and IRL historical shipments for 2006 through 2011 to DOE upon request.

3.3.5.1 GSFL Shipments

For GSFLs, the historical shipment data is broken down by lamp length (2-foot, 4-foot,

and 8 -foot), diameter (T12, T8, and T5), shape (linear and U-shaped), and in some cases, lumen output (SO or HO). Four-foot MBP lamps have consistently constituted the vast majority of GSFL sales. These have been followed, in order of unit sales, by 8-foot SP slimline lamps, then

8 -foot RDC HO lamps, with shipments of 2-foot U-shaped lamps consistently making up the

small est portion (less than five percent) of unit sales. After 2005, 8-foot RD C HO lamp shipments declined to less than five percent as well, nearly equaling 2-foot U-shaped lamp shipm ents. For this rulemaking, NEMA provided DOE with combined shipment data for 4-foot

T5 Mini BP SO and HO lamps from 2006 through 2011, showing an increasing share of unit

sa les that reached a little over eight percent of shipments in 2011.

GSFLs in the categories of 4-foot MBP, 8-foot SP slimline, 8-foot RDC HO, 2-foot Ushape d, and T5 SO and HO lamps are primarily used in the commercial and industrial sectors. As

Ta ble 3.3. 11 shows, 4 -foot MBP fluorescent lamp shipments show a clear decrease in the T12 market share and an increase in the T8 market share. These shipments, coupled with information obtained from NEMA and feedback from interviews with manufacturers, suggest that consumers are moving away from 4-foot T12 fluorescent lamps and toward 4-foot T8 fluorescent lamps. This trend is reflected both in the popularity of T8 lamps in new construction and in lighting

s ystem retrofits and renovations where the ballast is replaced. The vast majority of ballasts are electronic, with instant start (IS) technology composing about 85 to 90 percent of the market.

Th e decline of 4-foot T12 shipments was compounded by energy conservation standards for T12

fluor escent ballasts, requiring compliance in 2009 and 2010. (See 10 CFR 430.32(m)(4)(ii) and 430.32(m)(5)-(6))

Table 3.3. 11 NEMA Shipments of Four-Foot Medium Bipin GSFLs

T12 4

- Foot MBP T8 4

- Foot MB P Total 4

- Foot MB PUnit Sales by Yearthousands 2001 212,564 164,129 376,593

2002 205,998 163,632 369,630

2003 181,931 172,294 354,225

2004 175,850 195,698 371,548

2005 162,664 215,530 378,194

2006 150,522 230,988 381,510

2007 131,584 247,331 378,915

2008 115,064 253,705 368,769

2009 111,500 219,101 330,601

2010 103,300 233,798 337,098

2011 92,588 265,889 358,477

As Table 3.3

. 12 shows, historical shipments of 8-foot SP slimline GSFLs reflect a decline

in shi pments of T12 lamps through 2009 , but not an increased market share in T8 lamps that

c ompensates for th is decrease. There was a brief increase in shipments of 8-foot SP slimline3

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lamps in 2010, however, shipments began to show a decrease again in 2011. Manufacturer feedback indicated that a portion of the 8-foot T12 market is being transferred to the 4-foot T8

mar ket as two 8-foot T12 lamps can be replaced by four 4-foot T8 lamps.

T able 3.3. 12 NEMA Shipments of Eight-Foot Single Pin Slimline GSFLs

T12 8

- Foot SP Slimline T8 8

- Foot SP Slimline Total 8

- Foot SP SlimlineUnit Sales by Yearthousands 2001 43,265 4,405 47,670

2002 41,443 5,300 46,743

2003 37,170 5,183 42,353

2004 36,263 5,727 41,990

2005 33,636 5,176 38,812

2006 27,030 5,721 32,751

2007 25,400 4,718 30,118

2008 22,208 4,480 26,688

2009 20,944 4,902 25,846

2010 30,396 5,112 35,508

2011 26,210 4,306 30,516

Table 3.3

. 13 shows the historical shipments of 2-foot U-shaped GSFLs. While U-shaped T12 lamp shipments are declining, no clear trend can be seen in the market share progression of U-shaped T8 lamps. Nonetheless, the market share of U-shaped lamps has remained small

c ompared to that of 4-foot MBP and 8-foot SP slimline lamps.

Table 3.3. 13 NEMA Shipments of Two-Foot U-Shaped GSFLs

T12 2

- Foot U

- Shaped T8 2

- Foot U

- Shaped Total 2

- Foot U

- ShapedUnit Sales by Yearthousands 2001 9,672 8,014 17,686

2002 9,314 6,784 16,098

2003 9,460 7,018 16,478

2004 7,014 9,224 16,238

2005 8,839 8,659 17,496

2006 5,803 12,086 17,889

2007 5,169 11,502 16,671

2008 4,626 9,382 14,008

2009 3,882 8,455 12,337

2010 3,683 8,786 12,469

2011 3,574 9,012 12,586

While 4-foot MBP, 8-foot SP slimline, and 2-foot U-shaped lamps are primarily used in the commercial sector, 8-foot RDC HO lamps are primarily used in the industrial sector for applications such as high bay lighting. Ta ble 3.3

. 14 shows the historical shipments of 8-foot RDC HO lamps. The market share of 8-foot RDC HO is relatively small compared to that of 4-

foot MB P and 8-foot SP slimline lamps. As seen in NEMA’s historical shipment data, T12 8- foot RDC HO lamps had the majority of the RDC HO market. After 2005, NEMA reported T123

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and T8 8-foot RDC HO data as combined totals for disclosure purposes. Discussions with manufacturers indicate that they expect any migration of the 8-foot RDC HO market to go

toward T5 HO lamps.

Table 3.3. 14 NEMA Shipments of Eight-Foot Recessed Double Contact High Output

GSFLs

T12 8

- Foot RDC HO T8 8

- Foot RDC HO Total 8

- Foot RDC HOUnit Sales by Yearthousands 2001 23,887 691 24,578

2002 24,398 647 25,045

2003 24,206 467 24,673

2004 24,591 674 25,265

2005 25,442 420 25,862

2006

-- -- 18,828

2007

-- -- 19,741

2008

-- -- 18,575

2009

-- -- 15,799

2010

-- -- 15,408

2011

-- -- 15,286

Table 3.3

. 15 shows NEMA’s 2006 through 2011 combined HO and SO 4-foot T5 MiniBP lamp shipments. While 4-foot MBP lamps have always held the definitive majority of

the ma rket, 4-foot T5 MiniBP lamps are gaining an increasing market share and have become the

ne xt most prevalent lamp type, surpassing 8-foot SP slimline lamps in 2011. Still less than 10 percent of the market, 4-foot T5 MiniBP shipments (according to manufacturer interviews,

spec ifically T5 HO shipments) have grown due to commercial applications using the higher

e fficacy lamps and industrial high bay applications switching from less-controllable technologies ( e .g. , high-intenisty discharge [HID] lamps). Additionally, the increase of 4-foot T5 MiniBP shipm ents has also been influenced by non-regulatory incentives such as utility rebates. Several programs offer rebates to commercial, non-residential, and multi-family customers for the installation of T5 lamps in both new construction and renovation applications (see section 3.3.4 for examples). As mentioned previously, 4-foot T5 MiniBP HOs are also expected to capture a portion of the 8-foot RDC HO market.

Table 3.3. 15 NEMA Shipments of Four-Foot T5 Miniature Bipin Standard Output and High Output GSFLs

Total 4

- Foot T5

MiniBP SO and HOUnit Sales by Yearthousands 2006 21,465

2007 26,318

2008 28,784

2009 24,815

2010 32,508

2011 37,9303

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3.3.5.2 IRL Shipments

As Tabl e 3.3

. 16 shows, both halogen and non-halogen IRL shipments have been declining since 2006. However, the halogen reflector lamp types are generally maintaining their

pe rcentage of total shipments.

T abl e 3.3

. 16 NEMA Shipments of IRLs

PAR

Incandescent R Incandescent PAR 38 Halogen PAR 30 and PAR 20 Halogen Total IRLsUnit Sales by Yearthousands 2001 8,900 89,465 40,804 32,523 171,692

2002 6,697 96,218 45,938 27,128 175,961

2003 5,090 103,407 45,673 30,506 184,676

2004 5,308 111,720 49,937 35,567 202,532

2005 15,018 124,641 46,329 39,985 225,973

2006 4,800 121,308 43,265 36,054 205,427

2007 3,658 114,521 40,377 36,390 194,946

2008 3,228 99,446 36,209 34,320 173,203

2009 2,237 89,288 39,039 30,483 161,047

2010 2,778 86,681 36,106 30,872 156,437

2011 2,100 85,293 35,372 27,815 150,580

3.4 TECHNOLOGY ASSESSMENT

The purpose of the technology assessment is to develop a preliminary list of technologies that could be used to improve the efficacy of GSFLs and IRLs. The following assessment

pr ovides a description of the basic construction and operation of GSFLs and IRLs, followed by technology options to improve efficacy.

3.4.1 Basic Structure and Operation of General Service Fluorescent Lamps

The fluorescent lamp is a low pressure gas discharge source. The lamp consists of a glass bulb or tube, filled with low pressure mercury vapor and inert gas, with electrodes sealed onto both ends of the tube. Once voltage is applied, the electrodes emit large quantities of electrons that then collide with gaseous mercury atoms, exciting electrons within those atoms. As the electrons decay to their stable or ground state, they emit ultraviolet (UV) radiation. The phosphors coating the bulb’s inner wall then absorb this UV radiation and emit light in the visible spectrum. The fluorescent lamp has five major components in its construction: bulb, electrodes, base, gas fill, and phosphors.

Two electrodes are hermetically sealed to both ends of the bulb. The electrodes are usually constructed from coiled tungsten wires coated with a mixture of alkaline oxides. A base provides an electrical connection to these electrodes and also supports the lamp. Depending on the start method and operational properties of the lamp ( e.g. , dimming, wattage), lamp designs

ma y use different bases such as SP , MBP, MiniBP, and RDC. Once voltage is applied to the electrodes, the tungsten coil and coatings emit large quantities of electrons when the coating is at the proper temperature (1,000– 1,300 K). These electrons then collide with gaseous mercury3

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atoms, exciting electrons within those atoms. As the electrons decay to their stable or ground state, they emit UV radiation primarily at 254 nanometers (nm). In addition to the mercury vapor, an inert gas or a combination of gases is added to the lamp primarily to moderate the collisions of mercury ions and minimize evaporation of the electrode coating. As discussed above, the UV radiation is then absorbed by the phosphors and reemitted as light.

A fluorescent lamp must be operated in series with a current-limiting device, which is usually a magnetic or electronic ballast. The 2011 Ballast Rule set standards difficult for magnetic ballasts to meet (76 FR 70548 [Nov. 14, 2011]); while electronic ballasts, the more

e fficient technology, will be able to meet standards. While this rulemaking covers only the

fluor escent lamp, it does evaluate the lamp-and-ballast system when evaluating energy savings

of a particular GSFL efficacy level.

In addition to limiting current, ballasts also supply starting and operating voltages required by the lamp. Some ballasts also preheat the electrodes before initiating the arc. Electronic ballasts can use a variety of starting methods, including IS , rapid start (RS), and

pr ogrammed start (PS). j RS ballasts heat the electrodes for a limited time before lamp ignition which leads to a longer lamp life than an IS ballast. However, RS ballasts have difficulty complying with standards set in the 2011 Ballast Rule. 76 FR 70548 (Nov. 14, 2011). PS ballasts, like RS

, heat the lamp filaments before igniting the lamp and some remove all power to the electrodes after ignition ( i.e. cathode cut-out) resulting in more energy savings compared to

RS ballasts. IS ballasts apply a higher voltage to initiate the lamp ignition rather than applying a steady filament voltage.

Because different starting methods result in changes in lamp efficacy, the test procedure for GSFLs requires that the efficacy of each lamp is measured using a common starting method

a nd ballast. However, DOE considers different starting methods in its analysis. For example, DOE pairs 4-foot T8 MBP lamps with electronic, IS ballasts and electronic, PS ballasts. Electronic ballasts are also available in a variety of lamp-per-ballast designs. For example, electronic ballasts are typically manufactured in 1-, 2-, 3-, 4
- and 6-lamp versions. In its analysis for this rulemaking, DOE is focusing on the more prevalent 2- and 4-lamp systems.

Some of the performance parameters used to characterize a ballast include ballast factor (BF), ballast luminous efficiency (BLE) , and power factor. Each ballast has a BF

, which is the output of the ballast delivered to a reference lamp in terms of power or light divided by th e output of the relevant reference ballast delivered to the same lamp (ANSI C82.13-2002). To calculate the light output of a lamp-and-ballast system, one would multiply the light output of the lamp by both the number of lamps operated by the ballast and it s BF

. BLE , a new metric for fluorescent lamp ballasts, means the total lamp arc power divided by the ballast input power

mul tiplied by the appropriate frequency adjustment factor. BLE describes the percentage of ballast input power that is used by the lamp to produce light. The power factor is calculated by

de termining the ratio of the active power to the apparent power.

j Programmed start ballasts delay the starting voltage until the electrodes are heated to an optimum temperature. Then, they may reduce the voltage on the electrodes.3

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Fluorescent lamp bulbs can be manufactured in a variety of shapes and sizes. The GSFLs in this rulemaking include 4-foot and 8-foot linear lamps and 2-foot U-shaped lamps. Changing the shape of the lamp can alter the overall efficacy as the lamp may require a different voltage to

maintain the discha rge and UV radiation. In addition, the length of a lamp also influences its efficacy. As Figure 3.4

. 1 shows, the greater the length, the higher the efficacy, since losses associated with the electrodes are essentially constant. Therefore, a longer arc length will have less electrode power loss es relative to the total losses. However, because different lamp shapes and lengths may provide different utility to the consumer and also depend on the fixture, DOE is not considering these properties as technology options. Rather, as indicated in the discussion of product classes in section 3.5.1 , product classes differentiate lamps by their shape and length. In its analysis, DOE was unable to determine if base type alone impacted efficacy and therefore did not consider this as a technology option.

F igure 3.4. 1 Lamp Length Effects on Efficacy Source: IESNA Lighting Handbook: Reference & Application 21

3.4.2 GSFL Technology Options

This section outines the technology options DOE is considering for improving efficacy of GSFLs. In discussing each of the following technology options, it is important to note that the efficacy of a lamp, in terms of lumens per watt (lm/W), can be affected in two major ways. One method is by affecting the total light output at a given wattage. This generally refers to changing the spe ctral output of the lamp to result in a larger overlap with the spectral eye sensitivity. k The second method of changing lamp efficacy is requiring a different electrical wattage input to maintain a given lumen output. This method involves tweaking the processes that convert

e lectrical energy to visible radiation.

k A “lumen” is a measurement of the radiometric energy emission from a light source weighted by the response function of a human eye, called the photopic spectral luminous efficiency function, V(λ). See Figure 3.4.4 for a graph of this function.3

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3.4.2.1 Highly Emissive Electrode Coatings

Fluorescent lamp electrodes are generally tungsten filaments coated with a mixture of alkaline earth oxides. The purpose of the electrodes is to emit a sufficient number of electrons to ionize the gas and maintain the lamp discharge. When electrons are more easily emitted from the

e lectrodes, a lower voltage is needed to maintain the arc. Therefore, any improvement in electrode coating that would allow electrons to be more easily removed from the electrodes would reduce the lamp power and increase the overall efficacy of the lamp. This technology option essentially addresses the efficiency of the conversion of electrical input power to visible radiation. In addition to raising efficacy, the electrode coatings can result in an increased lamp lifetime. Without sufficient electron emission from the electrode, a large voltage gradient is created in front of the electrode during the cathode cycle, which is emitting negatively charged ions and receiving positively charged ions. This high electric field accelerates these ions into the electrode at a high velocity, causing electrode damage. The damage shortens the lifetime of the lamp. C onventional emissive coatings include barium oxide (BaO), calcium oxide (CaO), and strontium oxide (SrO). Additional materials have been mixed with existing conventional oxides to coat fluorescent lamp electrodes. These materials include zirconium oxide (ZrO), which extends lamp lifetime, and silicon carbide (SiC), which more effectively removes electrons from

the electrode.

3.4.2.2 Higher Efficiency Lamp Fill Gas Composition

Fluorescent lamps contain mercury vapor, which when ionized produces UV radiation. They also contain a rare gas or combination of gases to facilitate ignition. These “lamp fill gases” affect the mobility of the mercury ions and electrons in the lamp plasma based on their molecular weight. Lower molecular weight gases generally result in higher lamp efficacy. As lighter gases are used, the mobility of mercury ions and electrons increases, allowing them to

re ach greater velocities. This causes a rise in electron temperature of the plasma, facilitating recombination and ultimately raising the UV radiation to saturation level. However, if the mobility of the ions and electrons exceeds a certain optimal point, they are then able to reach the lamp glass surface, which prevents emission and effectively reduces UV output.

S tandard lamps generally use argon gas. Energy-saver lamps may use a mixture of

kr ypton and argon. In addition, neon and xenon are sometimes blended with argon. As Figure

3.4

. 2 shows, given a linear power density of 25 watts/foot (W/ft), both neon and argon result in similar UV radiation. However, given a high linear power density of 50 W/ft, neon clearly allows

for higher UV radiation, and therefore higher efficacy.3

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Figure 3.4. 2 Lamp Fill Gas Effect on UV Output for T12 Lamps Source: Electric Discharge Lamps 22

These gases are usually at low pressures, ranging from 100 to 400 Pascals. As the pressure exceeds a certain point, elastic scattering increases, decreasing the mobility of the ions and electrons. This decreased mobility lowers the total UV radiation of the lamp, thereby decreasing lamp efficacy. Because fluorescent lamp ballasts are often current-controlled devices, the use of higher efficiency lamp fill gases, such as krypton, results in lower power. DOE research and interviews with manufacturers have indicated that these lower power lamps, often called energy-saver lamps, have some restrictions on usage, such as operation in less than 65 °F

a mbient temperature, with some dimming ballasts, etc.

L amp fill gas composition can also affect lamp lifetime due to collisions between the lamp fill gas and the evaporated electrode coatings. As discussed earlier, one common emissive coating used on electrodes is barium oxide (BaO). During lamp operation the BaO coating slowly evaporates from the surface of the electrode. However, some of these escaped barium

a toms then collide with the lamp fill gas, propelling them back toward the electrode and redepositing them. As Figure 3.4. 3 shows, the relative thermionic emission for the cathode, a measure of the number of electrons emitted, is much greater for a larger molecular weight gas,

such as krypton, than for a lighter gas, such as neon. This is because a larger mass atom can more effectively collide with and change the trajectory of the barium atoms, providing a lower diffusion rate of the barium atoms away from the electrode. This redeposition of the electrode

c oating results in a longer lamp lifetime as less of the electron emissive material is lost.3

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Figure 3.4. 3 Lamp Fill Gas Effect on Thermionic Emission for T12 Lamps Source: Electric Discharge Lamps 23

3.4.2.3 Higher Efficiency Phosphors

As described earlier, the main purpose of phosphor in a fluorescent lamp is to absorb the UV radiation and reemit it as visible radiation. Therefore, one method of improving lamp efficacy is to increase phosphor efficiency. The two groupings of phosphors used in fluorescent lamps are halophosphors and triband phosphors, the latter of which contain rare earth elements. Initially, halophosphors, typically composed of group 17 elements from the periodic table of elements, were predominantly used in fluorescent lamps. Then, in the late 1980s, rare earth phosphors, which are generally considered to have higher phosphor efficiencies, better color rendering properties, and improved lumen maintenance, were integrated into the lamps. Specifically, these narrow-band rare earth phosphors (containing the rare earth elements terbium, europium, and yttrium), emit light in the short, middle, and long wavelength ranges of the visible spectrum. Lamps that meet the July 2012 standards predominately use triband phosphors, which include rare earth phosphors. 24 However, t he more efficient fluorescent lamps on the market today exclusively use triband phosphors.

Therefore, lamp efficacy can be improved by using triband phosphors, which can

incr ease UV absorption and emission of radiation in the visible spectrum relative to other phosphors. Typically, there are efficiency losses in the phosphor’s conversion of UV radiation to

visi ble radiation, or light. Some of these losses are related to the extent to which the phosphors emit light in the visible spectrum ( i.e. , radiation with wavelengths between 400 to 750 nm) and the extent that they radiate at visually sensitive wavelengths. Triband phosphors allow a lamp to emit light at the wavelengths to which human eyes are most sensitive which increases lamp efficacy. To understand this effect it is important to note the relationship between the efficiency losses in the phosphor’s conversion of light, wavelengths sensitive to the human eye, and measurement of lamp efficac y.

Lumens, used to calculate lamp efficacy, measure the radiometric energy emission from a light source weighted by the response function of the human eye, V(λ) (also referred to as the3

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photopic luminous efficiency function). Figure 3.4. 4 depicts V(λ). The human eye does not have the same level of sensitivity to all wavelengths of light. For example, the eye is highly sensitive to light emission around 550 nm, but less sensitive to emission at 450 nm or 650 nm.

F igure 3.4. 4 Human Eye Photopic Spectral Luminous Efficiency Function, V(λ)

Therefore, the specific wavelengths that a lamp emits will affect the lamp’s calculated efficacy. In other words, because the human eye is less responsive to certain wavelengths of light, such as those in the blue spectrum, those lamps that contain these less sensitive wavelengths will have lower efficacies. As such, every watt of radiometric energy emitted from a fluorescent lamp is not equal under a lm/W metric. Therefore, by allowing a lamp to emit greater light at wavelengths to which the human eye is more sensitive, triband phosphors are able to

incr ease lamp efficacy.

Lamp efficacy can also be improved by increasing the thickness of the phosphor layer,

a lso called phosphor weight. Generally, as phosphor thickness increases, lamp light output increases until it slightly decreases or stays flat. Figure 3.4. 5 illustrates this point, where coating weight is indicative of phosphor thickness.3

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Figure 3.4. 5 Light Output versus Phosphor Thickness Source: Journal of the Electrochemical Society 25

Different types of phosphor emit light with different spectral power distributions (SPDs), and the choice of phosphor or blend of phosphors greatly affects the color of the lamp. The SPD of light emitted from a lamp characterizes the amount of power radiated at each wavelength in the visible spectrum. Figure 3.4. 6 illustrates a sample SPD. It is apparent that the light source emits more radiation at certain wavelengths than others.

Figure 3.4. 6 Sample Power Spectrum Distribution Source: www.gelighting.com 26

This SPD determines the correlated color temperature (CCT) and the CRI, both important properties for measuring the color quality of light. CRI, a single value with no units, is a measure

of the color rendering properties of a light source, or the ability of a light source to show the3

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“true” color of an object as compared to a reference source. l 27 The maximum CRI is 100. Lower CRI values indicate greater variation in an object’s apparent color compared to when lit by the reference source. DOE has observed that higher efficiency phosphors on the market typically offer higher CRIs. While CRI is not necessarily positively correlated to efficacy, the majority of phosphors offered in the market currently reflect this relationship. Typically lamps with a CRI in the 60s use only less efficient halophosphors, while lamps with a CRI in the 70s (700-series phosphor) and in the 80s (800-series phosphor) use more efficient rare earth phosphors. Currently, the majority of lamps compliant with the July 2012 standards are 800 series.

CCT, a single value with units of degrees Kelvin (K), is a measure of the color appearance of light emitted from a lamp. m n 28 Lower CCT values correspond to warmer light, with more red content in the spectrum, and higher CCTs correspond to cooler light, with more blue content. As the spectral emission from the lamp is modified to change the CCT, the light emitted often contains more red or blue light. Given the shift in the wavelengths of light emitted

fr om lamps with different CCTs, and the fact that lumens account for the amount of light emitted at particular wavelengths, the efficacy of lamps with different CCTs can vary.

3.4.2.4 Glass Coatings

To increase the UV absorption by the phosphors, the bulb glass can be covered with an antireflective coating. This coating, also referred to as the undercoat or base coat layer, is a

re fractory oxide, such as aluminum oxide (Al 2 O 3 ), silicon oxide (SiO 2 ), and titanium oxide (TiO 2 ). This layer is used to reflect any UV radiation that passes through the phosphor back onto the phosphor, allowing a greater portion of UV to be absorbed. As the phosphors absorb more UV radiation, they will emit more visible light, thereby increasing the overall efficacy of the lamp. When these coatings are used with rare earth phosphors, a good CRI can be achieved while

mi nimizing the phosphor thickness necessary to absorb maximum UV radiation. A recent

pa tent 29 by Philips was issued in 2005 for an improved undercoat that reduces the amount of lamp contaminant resulting from the manufacture process. The improved coating covered under the patent contains an aluminum oxide material and a getter material which reacts with contaminants. This reduction or elimination of contaminants results in improved lamp arc

stabil ity.

3.4.2.5 Higher Efficiency Lamp Diameter

Similar to lamp length, lamp diameter is another design parameter of a fluorescent lamp that can affect efficacy. As Figure 3.4

. 7 shows, there exists an optimum design diameter for a specific fluorescent lamp type resulting from two opposing effects. First, in small diameter

l According to the IESNA Lighting Handbook, the CRI of a light source is “a measure of the degree of color shift objects undergo when illuminated by the light source as compared with those same objects when illuminated by a reference source of comparable color temperature.”

m According to the IESNA Lighting Handbook, the CCT of a light source is “the absolute temperature of a blackbody whose chromaticity most nearly resembles that of the light source.”

n While CCT is a single value, light with the same CCT value may have slightly different properties. Therefore, the lighting industry has defined elliptical regions in chromaticity space (called 4 MacAdam color steps) for specific CCT values ( e.g. , 2,700K, 3,000K, 3,500K, 4,000K/4,100K, 5,000K, and 6,500K) in ANSI C78.376- 2001. These regions act as a tolerance for the color properties of the lamp.3

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lamps, an increase in diameter decreases the number of electrons and mercury ions that recombine at the bulb wall and produce no light. This lessening of non-radiative recombination results in an increase of optical power output and subsequently a rise in lamp efficacy. However,

whe n the lamp diameter is sufficiently large as to result in minimal non-radiative recombination, a second opposing effect begins to influence the efficacy-diameter relation. With these larger diameter lamps, a further enlargement in diameter causes a greater imprisonment of radiation

withi n the lamp. As the total light output is reduced, the lamp efficacy declines as well. In addition to affecting lamp efficacy, changing the lamp diameter alters the inner surface area of the fluorescent tube. With a larger diameter and therefore surface area, more phosphor is needed to coat the glass, subsequently increasing the cost of the lamp.

Figure 3.4. 7 Bulb Diameter versus Efficacy Source: IESNA Lighting Handbook: Reference & Application 30

DOE only considered lamp diameter as a design option in relation to the migration from T12 to T8 lamps. DOE’s research indicated T8 lamps are common replacements for T12 lamps,

a nd though the lumen packages for T8 lamps are often less than that of T12 lamps, in this situation, it does not seem to be significant enough to affect consumer utility. Conversely, DOE’s research indicated that T5 lamps have more limited utility as replacements for T8 or T12 lamps due to the fewer available lumen packages for T5 lamp-and-ballast sytems

. As suc h, T5 lamps are not considered a design option to improving the efficacy of T8 and T12 lamps. See section

3.5.1.3 for more information.

3.4.2.6 Multi-Photon Phosphors

The use of multi-photon phosphors, or quantum-splitting phosphors, can significantly improve lamp efficacy. Because these phosphors emit more than one visible photon for each

incident UV photon, a lamp would be able to emit more light in the visible spectrum for the same

a mount of power. However, there are technical drawbacks with the technology such as light color output, color stability, and phosphor lifetime. 313

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3.4.3 Basic Structure and Operation of Incandescent Reflector Lamps

An incandescent lamp is a light source in which an electrical current passes through a filament, thermally exciting electrons, which then radiate energy in the form of light and heat. Incandescent lamps consist of a bulb, generally composed of glass such as regular lead, soda lime, or borosilicate heat-resisting glass. Within the bulb, an incandescent lamp contains a filament, filament supports, and sometimes a lamp fill gas. Though early incandescent lamps often used carbon, osmium, and tantalum filaments, current lamps generally use tungsten filaments. Tungsten’s low vapor pressure and high melting point allows for high operating temperatures, and consequently high lamp efficacies. The lamp fill gas, though not included in all incandescent lamps, is used to extend the lifetime of the lamp.

IRLs are incandescent lamps with a reflective coating, most commonly composed of aluminum or silver applied directly to the reflector surface. Sealed to the bulb of the IRLs

c overed in this rulemaking is an E26 medium screw base. By improving directional lighting, reflector lamps place the same illuminance on a specific area with reduced watts. The most common bulb shapes of reflector lamps are R, PAR, BR, and ER. R-, ER- and BR-shaped lamps

a re primarily for indoor applications, while PAR lamps are usually used outdoors or for
spot lighting in retail applications. IRLs can have spot or flood beams. Flood IRL s, which provide a greater distribution of light, typically have a beam spread of 16 to 40 degrees. Spot IRLs usually have a beam spread from 9 to 16 degrees. The ranges change with lamp type, with PAR lamps typically having smaller beam spreads than other IRLs.

Most IRLs on the market today are tungsten-halogen lamps. Tungsten-halogen lamps use a halogen element such as bromine, chlorine, fluorine, or iodine to help increase lifetime of the lamp. In a tungsten-halogen lamp, a small diameter fused quartz envelope, commonly known as a capsule or burner, filled with a halogen molecule surrounds the filament. Above 500 degrees

F ahrenheit (F), when tungsten evaporates from the filament, the tungsten molecules combine

with t he halogen into a gaseous compound. This compound circulates within the envelope until it contacts the filament again. The heat of the filament breaks the compound, freeing the halogen and redepositing the tungsten on the filament. This regenerative process greatly extends the life of incandescent lamps by reducing the loss of tungsten material. Further, because tungsten is not being deposited on the surface, lamp blackening is greatly reduced. Ho wever, there is aminimum temperature threshold for the halogen cycle to continue, so if dimmed tungstenha logen lamps, which employ low-voltage operation, become blackened, they should periodically be operated at full power in order to induce the halogen cycle that will remove the tungsten off the capsule wall. One drawback to using halogen is that the halogen capsule is often under high pressure and therefore susceptible to non-passive failure. For this reason, halogen IRLs often employ a thicker protective glass.

3.4.4 IRL Technology Options

The following assessment is a discussion of technology options that improve the efficacy of IRLs. In discussing methods to affect the efficacy of an incandescent lamp, it is important to recognize the interrelation of a lamp’s wattage, luminous output, and lifetime. Often the most efficacious incandescent lamps have very low lifetimes and therefore become useless to the consumer. However, it is possible to optimize both efficacy and lifetime so that the lamp still provides utility to the consumer.3

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3.4.4.1 Higher Temperature Operation

In the operation of an incandescent lamp, a current is passed through a tungsten filament, which when heated, emits light. However, an incandescent light source’s spectrum does not fall exclusively in the visible region of the electromagnetic spectrum. This overlap is shown by Curve B, representing the radiant flux from one square centimeter of tungsten at 3,000 K, in Figure 3.4. 8

. o By operating the filament at higher temperatures, the spectral output shifts to shorter wavelengths, increasing its overlap with the photopic spectral eye sensitivity. This, in effect, increases the luminous output for a given power input and consequently increases the lamp efficacy. One way to increase the filament temperature is by increasing the wattage of the lamp. As a higher current passes through and a high voltage drop occurs over the filament, the amount of energy released in the form of heat increases, thereby raising the temperature. However, this significantly changes the luminous output of the lamp and may not meet the consumer’s needs. Other technologies that address a lamp’s ability to operate at high temperatures are filament thickness, inclusion of inert gas fills, and the use of halogen fills, all discussed below. In addition to efficacy, the change in operating temperature also affects color appearance and lifetime of the lamp. A s Figure 3.4. 9 shows, increasing color temperature is a direct effect of, but not equivalent to, raising operating temperature and also causes an increase in luminous efficacy.

Figure 3.4. 8 Radiating Characteristics of Tungsten Source: IESNA Lighting Handbook: Reference & Application 32

o In this graph, Curve A and Curve B’ are not strictly relevant to this point, and represent the radiant flux from one square centimeter of a blackbody at 3,000 K and the radiant flux from 2.27 square centimeters of tungsten at 3,000 K, respectively.3

- 35

Figure 3.4. 9 Luminous Efficacy versus Color Temperature Source: IESNA Lighting Handbook: Reference & Application 33

At the melting temperature of tungsten, 6,120 °F, the maximum efficacy of an

inca ndescent lamp with an uncoiled tungsten filament is 53 lm/W. However, to obtain long life in an incandescent lamp, the filament temperature should be significantly below its melting point. As the filament burns hotter, more tungsten evaporates from the filament. When the filament eventually breaks, the lamp fails. This is an example of the clear tradeoff between lamp efficacy and lamp lifetime. Also, to maintain the cool bulb surface, high temperature incandescent lamps often require larger bulbs. This affects the fixtures in which they fit.

3.4.4.2 Novel Filament Materials

Tungsten is a commonly used filament material. However, other filament materials can be considered. In choosing a filament, some advantageous properties are high melting point, low vapor pressure, high strength, high ductility, and good radiating characteristics. While tungsten is primarily used for incandescent lamps, manufacturers also incorporate other metals such as rhenium to improve ductility. However, these lamps are most commonly used for applications requiring vibration-resistant lamps. Novel filament materials, such as nitrides and carbides, have the potential to improve lamp efficacy by emitting more light in the visible spectrum at a given temperature than traditional tungsten filaments. However, these novel filaments can also be brittle, an attribute that can shorten the lamp lifetime.

3.4.4.3 Thinner Filaments

A thinner filament has an increased resistance and therefore an increased operating temperature. As previously discussed, a higher operating temperature results in a higher lamp efficacy. However, as an adverse effect, an incandescent lamp with a thinner filament cannot withstand as much tungsten evaporation as a thicker filament before failing, resulting in a shorter

lifetime.3

- 36

3.4.4.4 Efficient Filament Placement

Placement of the filament is an important aspect of incandescent reflector design. The plac ement of the filament is optimal when a portion of the spectrum emitted by the filament is focused back onto the filament. This additional radiation supplies heat to the filament and the operating temperature increases. As discussed earlier, an increase in operating temperature results in a higher light output and therefore an increase in efficacy.

3.4.4.5 Efficient Filament Orientation

Tungsten filament in incandescent lamps can be positioned horizontally or vertically with respect to the base of the bulb. Because the light emitted from the filament is distributed in all directions, one way to improve efficacy is by designing the lamp in a way such that the most amount of light is able to escape the bulb. By positioning the filament in a horizontal orientation, the base of the lamp absorbs much of the emitted light along the length of the coil. However, by positioning the filament in vertical alignment, only a small portion of the light is emitted towards the base. Consequently, more light escapes the bulb and is used for illumination. This can increase the efficacy of an incandescent lamp by approximately eight percent. In most IRLs on

the ma rket, the filament is vertically positioned.

3.4.4.6 Efficient Filament Coiling

Coiling of the incandescent lamp filament can increase luminous efficacy. The light output of an incandescent lamp is directly proportional to the light-emitting surface area of the light source. By coiling the filament, a longer filament can be used, increasing luminous output and therefore lamp efficacy. Coiling of the tungsten also affects the heat loss from the filament. The more the filament is coiled, the less the effective area for convective cooling, thereby increasing filament temperature and lamp efficacy. IRLs covered in this rulemaking generally contain filaments of the type C (coiled) or CC (coiled coil). The highly efficacious CC type filament, which is more commonly used, consists of the coil wound into another helical coil.

3.4.4.7 Microcavity Filaments

Texturing of the filament surface can increase surface area and therefore emissivity. Filament surface perforations also can act as waveguides for visible light. One technology includes the creation of microcavity holes in the filament surface. The cavities may then be filled with materials such as tantalum, rhenium, molybdenum, tungsten, SiC, rare earth elements, glass

be ads, or any combination thereof. Depending on their fabrication, this technology can result in a variety of effects such as greater control of emissive direction, reduction of infrared radiation, and increased emission efficiency over a certain bandwidth of wavelengths. Ultimately, these effects produce a higher overall efficacy. Research indicates that materials patterned at the

subm icron level may experience problems with stability. 34

3.4.4.8 Crystallite Filament Coatings

A variety of filament coatings may be used to increase the efficacy of incandescent lamps. Layers of micron or submicron crystallites, comprised of thorium, tantalum, and/or niobium, are deposited on the filament surface. The crystallites are coated with a protective layer of at least one oxide of thorium, hafnium, scandium, yttrium, cerium, or zirconium. This coating increases the emissivity of the filament in the visible part of the spectrum without increasing the3

- 37

infrared radiation. However, as the operating temperature of the filament increases, the emissivity improvement due to the crystallites decreases. Iridium may also be used as a coating to recycle wasted heat.

3.4.4.9 High Reflectance Filament Supports

In a tungsten-halogen capsule, tungsten filament supports can include a reflective face that reflects light to another filament, the reflective face of another filament support, or radially outward, thereby increasing light output/emissivity, and thus efficacy, by providing light that otherwise would have been wasted. The filament supports could also include grooves or an emissive coating with a high emissivity to increase heat dissipation or be formed of a porous ceramic material to increase efficiency.

3.4.4.10 Higher Efficiency Inert Fill Gas

IRLs covered in this rulemaking typically are filled with an inert fill gas whose primary purpose is to reduce the evaporation of tungsten, preventing bulb blackening and increasing lifetime. In addition, this fill gas increases the pressure inside the bulb or halogen capsule. The fill gas also provides a means of convective heat transfer between the heated filament and cool bulb surface. This cooling of the filament represents a power loss and an efficacy reduction due to low temperature operation. Krypton’s low thermal conductivity decreases the convective cooling of the filament, allowing for higher temperature operation and therefore higher efficacy. In addition, because the krypton molecule is larger than other elements, such as argon, krypton more effectively slows the evaporation of tungsten and therefore extends the life of the lamp.

Xe non, having even lower heat conductivity and larger mass than krypton, can more drastically change efficacy and life but also at a greater cost. Most lamps compliant with the July 2012

standards use xenon as a fill gas.

3.4.4.11 Higher Pressure Tungsten-Halogen Lamps

Increasing the pressure of the halogen capsule by increasing the density of halogen elements can indirectly raise the efficacy of the tungsten-halogen lamp. The increased density of halogen elements raises the probability that an evaporated tungsten element combines with a halogen element in a gaseous compound. Adding more of this gaseous compound in the capsule effectively increases the amount of tungsten re-deposited on the tungsten filament. This can be used to lengthen the lifetime of the tungsten-halogen lamp by decreasing the evaporation rate of tungsten if the filament temperature is unchanged, or raise its efficacy by increasing the filament temperature while maintaining the evaporation rate of tungsten. A combination of increased lifetime and efficacy may be achieved if the temperature is partially increased and the tungsten

e vaporation rate is partially decreased.

3.4.4.12 Non-Tungsten-Halogen Regenerative Cycles

The regenerative cycle of filament evaporation and redeposition (where the filament

mate rial evaporates and combines with halogen into a gaseous compound and then redeposits on the filament when it contacts it again because the heat of the filament breaks the compound) can be used to greatly increase the life of an incandescent lamp. The filament can burn at a higher temperature than conventional incandescent lamps while maintaining a useful service life.3

- 38

Implementation of a non-tungsten-halogen regenerative cycle depends on incorporating a nontungsten filament.

3.4.4.13 Infrared Glass Coatings

Infrared coatings on incandescent lamps are used to reflect some of the radiant energy emitted back onto the filament. This infrared radiation then supplies heat to the filament and the operating temperature increases. As discussed earlier, an increase in operating temperature results in a higher light output and therefore an increase in efficacy. In addition, the spectrum of the incandescent lamp shifts toward shorter wavelengths, increasing its overlap with th e photopic spectral eye sensitivity and subsequently increasing efficacy for a given power input. These

infr ared coatings can be in many forms, with new coating types continuing to be developed. Examples include multilayer dichroic filters and crystal lattice structures whose spacing defines a photoni c bandgap. They can be applied directly to the glass halogen capsule for tungsten-halogen lamps. However, they are most commonly used in the coating of the halogen capsule, which achieves the greatest directed reflection back onto the filament for the lowest infrared coating

usage . Because the halogen capsule is most traditionally in the shape of a cylind er , when infrared coatings are applied to a halogen lamp, the cylindrical shape helps direct the light reflected from

the c oatings.

3.4.4.14 Higher Efficiency Reflector Coatings

As mentioned previously, IRLs are incandescent lamps with a reflective coating, most commonly composed of aluminum or silver applied directly to the reflector surface. The reflector coating allows these lamps to place the same illuminance on a specific area with reduced watts, thereby increasing efficacy. Though aluminum is most prevalent as a reflector coating in IRLs, silver coatings can also be applied. While aluminum coatings are applied internally by condensation of vaporized aluminum on the inner surface of the bulb, silver can be applied both on the interior and exterior surfaces of the bulb. When applied externally, the silver coating is protected by a copper coating and aluminum finish. Silver coatings are generally preferred over aluminum due to their lower light loss. Gold is also extremely reflective and can be used to increase the amount of directed light and therefore efficacy of the lamp. Mentioned previously as a technology option, an infrared glass coating that reflects the infrared radiation back toward the lamp’s filament is also a type of high er efficiency reflector coating. This infrared reflector coating, in the form of multilayer dichroic filters or crystal lattice structures, ultimately increases lamp efficacy by limiting the amount of energy lost through infrared radiation and by increasing lamp operating temperature.

3.4.4.15 Permanent Infrared Reflector Coating Shroud

Infrared glass coatings on capsules can represent a significant portion of manufacturing costs and are usually disposed of when the lamp dies. However, use of a permanent shroud with an infrared reflector coating and a removable and replaceable lamp can increase efficiency while reducing manufacturing costs. The shroud contains a substrate and infrared reflector coating to reflect light back to the filament, thereby increasing efficacy by increasing the operating temperature and shifting the spectrum toward shorter wavelengths, as discussed previously. The shroud and lamp can be configured to be optimally aligned with the lamp reflector.3

- 39

3.4.4.16 Infrared Phosphor Glass Coating

Salts of the rare earths and other transition group elements contain ions at energy levels that are particularly suited to emit visible light when in transition. 35 In the presence of infrared light, these ions will jump to higher energy levels. In some cases, when the ions fall to lower energy levels, light in the visible spectrum is emitted. When used as a coating on a bulb surface, infrared phosphors are able to harvest the emitted infrared energy and convert it to visible light, potentially increasing lamp efficacy.

3.4.4.17 Ultraviolet Phosphor Glass Coating

Similar to infrared phosphor glass coatings, phosphor materials exist that are capable of

a bsorbing high energy radiation and reemitting it at a lower energy level. Specifically, these phosphors convert radiation in shorter wavelengths (UV, violet, and blue spectrums) into longer wavelengths (green and yellow spectrums) of light. The human eye is most responsive to green and yellow visible light, so lumen output is increased by approximately three percent since

lum ens are weighted by the photopic spectral eye sensitivity. 36 37

3.4.4.18 Corner Reflectors

Due to the shape of many reflector lamps, infrared lens technologies can be incorporated in the cover glass to direct infrared radiation back onto the filament. Conventional infrared coatings on reflector lamps direct the infrared light back into the bulb, but not directly onto the filament. Other parts of the lamp absorb some of this heat, which is therefore a source of energy

loss . A corner reflector is a technology that incorporates individual corner reflectors into the cover glass. These reflectors’ shapes provide the unique ability to reflect light directly back in the direction it came. Therefore any light coming from the filament and impinging on the cover glass will be directed straight back to the filament. These reflectors are covered with a dichroic coating, allowing visible light to pass through and escape while causing infrared radiation to

re flect back on the filament. As this radiation heats the filament, the lamp requires less input power to operate at a higher operating temperature, and therefore operates more efficaciously.

3.4.4.19 Electron Stimulated Luminescence

I n a process known as cathodoluminescence, visible light can be generated when accelerated electrons strike a phosphor surface. Incandescent filaments produce electrons by thermionic emission. A low voltage cathodoluminescent phosphor that emits green light upon impingement by these thermally ejected electrons may be applied to the lamp. The technology increases light ouput by utilizing electrons to emit visible light, which otherwise would not have been produced. This phenomenon can be enhanced by the presence of a lamp fill gas, which may increase the available current for cathode-ray excitation of the phosphor.

3.4.4.20 Integrally Ballasted Low Voltage Lamps

The use of an integral ballast in an incandescent lamp allows an increase in the efficacy

be cause it operates at low voltages, though it is used in a socket with main line voltage ( i.e. , it converts the operating voltage of the lamp to a lower wattage from line voltage). The conversion of line voltage to lower lamp operating voltages has associated energy losses. However, modern integral ballast technologies allow efficacy gains from low-voltage operation to outweigh any

such conversion losses.3

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3.5 PRODUCT CLASSES

W hen evaluating and establishing energy conservation standards, DOE divides covered products into classes by (a) the type of energy used; (b) the capacity of the product; or (c) other performance-related features that justify different standard levels, such as features affecting consumer utility. (See 42 U.S.C. 6295(q)) DOE then conducts its analysis and considers separate

standa rd levels for each product class. DOE applied the criteria of 42 U.S.C. 6295(q) to GSFLs and IRLs to develop product classes in this preliminary analysis. This section of the TSD

de scribes the factors DOE examined in considering product classes for GSFLs and IRLs.

3.5.1 General Service Fluorescent Lamps

In setting energy conservation standards for fluorescent lamps, EPAct 1992 established

pr oduct classes based on its definition for fluorescent lamps and on nominal lamp wattages.

EPAct 1992 set two classes for each lamp type, making a total of eight product classes, as shown

in Table 3.5. 1 . (42 U.S.C. 6295(i)(1)(B))

Table 3.5. 1 EPAct 1992 Product Classes for General Service Fluorescent Lamps

Lamp Type Nominal Lamp Wattage

4

- foot medium b ipin > 35 W

4

- foot medium b ipin ≤ 35 W

2

- foot U

- s haped > 35 W

2

- foot U

- s haped ≤ 35 W

8

- foot s in gle pin s limline > 65 W

8

- foot single pin s limline ≤ 65 W

8

- foot recessed double contact high o utput > 100 W

8

- foot recessed double contact high o utput ≤ 100 W

The 2009 Lamps Rule redefined these product classes, establishing divisions based on physical constraints of lamps ( i.e. , lamp shape and lamp length), lumen package ( i.e.

, SO versus HO), and CCT, as shown in Table 3.5

. 2

.

Table 3.5. 2 GSFL Product Classes from the 2009 Lamps Rule

Lamp Type CCT

4

- foot medium bipin ≤4

, 500 K

>4

, 500 K

2

- foot U

- shaped ≤4

, 500 K

>4

, 500 K

8

- foot single pin slimline ≤4

, 500 K

>4

, 500 K

8

- foot recessed double contact high output ≤4

, 500 K

>4

, 500 K

4

- foot T5, miniature bipin standard output ≤4

, 500 K

>4

, 500 K

4

- foot T5, miniature bipin high output ≤4

, 500 K

>4

, 500 K

For this preliminary analysis DOE examined several possible characteristics or features of

GSF Ls that could warrant separation of covered products into different product classes, including :3

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 physical constraints of lamps ( i.e. , lamp shape and lamp length),

 lumen package ( i.e. , r egular versus HO),

 diameter,

 CCT,

 interoperability of lamps on the same ballast system,

 wattage, and

 CRI.

The following subsections discuss these lamp attributes and how they pertain to product

class divisions.

3.5.1.1 Physical Constraints of Fluorescent Lamps

The physical constraints of the lamp relate to its shape and length. Because consumers must change a lamp fixture to substitute lamps of different geometries for one another, lamp shape affects utility. DOE research and interviews with manufacturers found that these physical differences prohibit direct replacement. For example, a U-shaped lamp c an n ot substitute for a linear-shaped lamp in the same fixture. Similarly, given their metric lengths, T5 lamps cannot be used as direct replacements for T8 lamps in some applications. These lamps require different lamp holders (due to differences in length and base type). Further, a 4-foot lamp may have a different utility than an 8-foot lamp, as these lamps generally require different fixtures.

In addition, a lamp’s geometry also affects its efficacy. For example, efficacy tends to increase with length. All else being equal, 8-foot lamps generally have higher efficacy values than 4-foot lamps. Also, a 2-foot U-shaped lamp, while having the same overall tube length, is less efficacious than a 4-foot linear lamp, partly because the electrical arc within the tube has to bend to conform to the lamp shape. Given the impact that geometry has on both utility and efficacy, DOE is considering establishing separate product classes based on lamp geometry.

DO E also conducted an analysis to determine if different lamp base types affect efficacy.

DO E found that it was unable to isolate base type alone while holding all other characteristics equal. This is because base type is dependent on a combination of lamp characteristics,

spec ifically length, diameter, and lumen package. Therefore, DOE was unable to determine if base type alone impacted efficacy. However, because base type is already accounted for when

c onsidering the product class divisions of length and lumen package, DOE determined no further

division is needed.

3.5.1.2 Lumen Package

Lumen package refers to the quantity of light that a lamp-and-ballast system provides to a

c onsumer. DOE observed that consumers tend to use systems with different lumen packages fordifferent applications. For example, high-lumen-output systems may be installed in certain highceiling or outdoor applications, where large quantities of light are needed. Alternatively, standard-lumen-output systems might be installed in lower-ceiling applications such as offices or hospitals, where, for example, distance between the light source and the illuminated surfaces is3

- 42

not as large. These notable differences in the application of SO versus HO lamps indicate a

diff erence in utility.

To obtain a high lumen package, certain lamps are designed to operate with ballasts that run the lamps at high currents. For example, 8-foot RDC HO lamps and 4-foot MiniBP HO lamps tend to operate at higher currents than 8-foot SP slimline lamps and 4-foot MiniBP SO lamps, respectively. This difference in operating design increases the quantity of light per unit lamp length for the 8-foot RDC HO and 4-foot MiniBP HO lamps. Operating lamps at a higher

c urrent also decreases efficacy. For example, the efficacy of an 8-foot RDC HO lamp is as much as 10 percent lower than that of a comparable 8-foot SP slimline lamp. Given the observed utility distinctions and notable efficacy differences between SO and HO lamps, DOE is considering

e stablishing separate product classes based on lumen package.

3.5.1.3 Diameter

As discussed in section 3.4.2.5 , lamp diameter is a feature of a lamp which impacts efficacy. In general, DOE considers lamp diameter as a design option, and did not consider using it as a basis for developing product classes. Manufacturer marketing literature and general

g uidance on lighting design and installation often promote T8 lamp-and -ballast systems as higher efficacy, energy-saving substitutes for T12 lamp-and-ballast systems. Such substitute systems have the same lengths and bases, offer comparable lumen output, and can fit within the same fixtures. Therefore, DOE recognizes that although the diameter of the lamp will affect the efficacy, the utility provided to the end-user is comparable and/or equivalent.

As stated earlier, DOE generally considers lamp diameter a design option when there is no associated decrease in utility. However, DOE will consider separate product classes for different diameter lamps when there is a decrease in utility, such as with the T5 MiniBP lamps. DOE’s test procedure for GSFLs requires lamps to be tested using low frequency reference ballast settings unless only high frequency settings are available. Because only high frequency settings are available for T5 lamps, these lamps are tested under different conditions than T8 lamps. High frequency operation increases lamp lumen output; thus, T5 lamps appear to be more efficacious than similar T8 lamps. If T5 and T8 lamps were included in the same product class, T8 lamps could be eliminated due to this difference in efficacy. T8 lamps, however, provide

con sumer utility because more lumen packages are available for T8 than for T5 lamp-and-ballast

s ystems. Consumers tend to use systems with different lumen packages for different applications.

Most of the commercially available 4-foot T5 MiniBP SO lamps offer the same initial lumen output. Specifically, 80 percent of standards-compliant 4-foot T5 MiniBP SO lamps have an initial lumen output of 2900 lumens. p On the other hand, 4-foot MBP T8 lamps offer a much wider range of initial lumen outputs. Additionally, fluorescent lamps are a component of a system and their performance characteristics are related to the ballast on which they operate.

Ea ch fluorescent lamp ballast has a specified BF , which is typically used to adjust the lumen

pa ckage of a lamp-and -ballast system. The vast majority of ballasts designed to operate 4-foot T5 MiniBP SO lamps have normal BFs, which further limits lumen package options for these systems. Ballasts that operate 4-foot MBP T8 lamps, however, are available with a larger range

p Data in catalogs is often reported at 35 °C.3

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of BF options ( i.e. , low, normal, and high). Thus, a standard that eliminates 4-foot MBP T8 lamps would result in a substantial decrease in available lumen package options and negatively impact consumer utility.

Further, a standard which eliminates 4-foot T8 MBP lamps could result in increased system energy consumption. As mentioned above, the vast majority of commercially available ballasts designed to operate 4-foot T5 MiniBP SO lamps are normal BF PS ballasts with a typical

B F of 1.0. The most common BF for ballasts of the same starting method (PS) designed to operate 4-foot T8 MBP lamps is 0.88. Although the high frequency reference arc power of full wattage 4-foot T5 MiniBP SO lamps is lower than the high frequency reference arc power of full wattage 4-foot T8 MBP lamps (27.8 W and 29.0 W, respectively), the higher BF of T5 SO ballasts results in higher overall system energy consumption compared to the typical T8 MBP
system.

Therefore, due to the effect of diameter on both efficacy and utility, and the potential for

incr eased energy consumption, DOE establishes separate product classes for 4-foot T5 MiniBP lamps.

3.5.1.4 Correlated Color Temperature

As discussed in section 3.3.1.3, in general terms, the CCT is a measure of the perceived color of the white light emitted from the lamp. The perception of light affords consumers a different utility for lamps with different CCT values. Additionally, as the SPD of the lamp is modified to change the CCT, the lamp efficacy can vary. Due to their greater blue light content, higher CCT fluorescent lamps tend to have lower efficacies.

For covered fluorescent lamps, CCT ranges span between 2,500 K and 7,000 K.

F eedback from manufacturer interviews indicates that lamps with CCTs greater than 4,500 K begin to show a considerable decline in efficacy. Given the impact on efficacy and utility, DOE

is co nsidering establishing separate product classes for lamps with CCT less than or equal to

4500 K and greater than 4500 K.

3.5.1.5 Ballast Interoperability

Not all lamps operate on the same ballast. Even if lamps have similar geometries, different ballasts may be required for their operation. However, DOE treats ballast interoperability as an economic issue (in the life-cycle cost and national impact analyses) rather

than a product class issue. In other words, if a consumer needs to change the ballast to replace a lamp, then the installed cost of both the lamp and ballast are factored into the net present value equation. Therefore, DOE will not be establishing a product class division based on ballast interoperatbility.

3.5.1.6 Wattage

The main function of a lamp is to provide lumen output, while other attributes such as CCT, for example, contribute to utility. Wattage measures the power consumed by a lamp in providing its service. Therefore, DOE does not construe wattage as a direct measurement of

uti lity, which is the criteria prescribed by 6295(q) for structuring product classes.3

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Furthermore, d ividing product classes by wattage locks the standards for GSFLs to a static wattage structure. While this structure may reflect current product availability, the market may evolve over time, shifting to different wattages. Therefore, DOE will not be establishing

pr oduct classes based on wattage.

3.5.1.7 Color Rendering Index

DOE also considered setting product classes for GSFLs based on CRI. DOE analyzed the impact of CRI on efficacy when keeping all other lamp characteristics constant. DOE found no correlation between CRI and efficacy and therefore concluded that CRI did not have a direct impact on efficacy. DOE did confirm, however, that the majority of lamps with higher efficiency phosphors a lso offered higher CRIs as discussed in section 3.4.2.3 . For example, lamps with

800 -series rare earth phosphors, considered the most efficient combination of phosphors, had the highest CRI values typically ranging from 80 to 86. However, there was no indication of consistently increasing efficacy with increasing CRI values for the lamps within each specific phosphor series.

DOE recognizes that CRI provides utility because a high CRI light source renders colors well and can be required for color sensitive applications. Although CRI is associated with a

c hange in utility, because DOE found no direct impact on efficacy associated with CRI, DOE will not be establishing separate product class es based on CRI.

3.5.1.8 Product Class Summary

DOE is considering maintaining the same product class divisions as those established in the 2009 Lamps Rule. The GSFL product class es being considered in this preliminary analysis

are summarized in Table 3.5. 3

.

Table 3.5. 3 GSFL Preliminary Analysis Product Classes

Lamp Type CCT

4

- foot medium bipin ≤4

, 500 K

>4

, 500 K

2

- foot U

- shaped ≤4

, 500 K

>4

, 500 K

8

- foot single pin slimline ≤4

, 500 K

>4

, 500 K

8

- foot recessed double contact high output ≤4

, 500 K

>4

, 500 K

4

- foot T5, miniature bipin standard output ≤4

, 500 K

>4

, 500 K

4

- foot T5, miniature bipin high output ≤4

, 500 K

>4

, 500 K

3.5.2 Incandescent Reflector Lamps

In setting energy conservation standards for IRLs, EPAct 1992 differentiated IRLs by

wa ttage and established six nominal wattage ranges or “bins,” shown in Table 3.5. 4 . (42 U.S.C.

6 295(i)(1)(B))3

- 45

Table 3.5. 4 EPAct 1992 Product Classes for Incandescent Reflector Lamps
Nominal Lamp Wattage

40

- 50

51

- 66

67

- 85

86

- 115

116

- 155

156

- 205

The 2009 Lamps Rule redefined these product classes, establishing divisions based on lamp diameter, voltage, and spectrum. DOE is considering maintaining these divisions, as shown in

Table 3.5. 5

.

For this preliminary analysis DOE examined several possible characteristics or features of

I RLs that could warrant separation of covered products into different product classes, including:

 wattage,

 spectrum,

 diameter,

 voltage,

 beam spread,

 center beam candle power, and

 length.

The following subsections discuss these lamp attributes and how they pertain to product

class divisions.

Table 3.5. 5 IRL Product Classes from the 2009 Lamps Rule

Lamp Type Diameter

(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

3.5.2.1 Wattage

Lamp wattage does impact efficacy. However, a s with GSFLs, DOE does not consider wattage as a direct measure of utility. Furthermore, a pr oduct class structure that encompasses all
wattages can better keep pace with the market should it shift to new wattages over time. As

wa ttage increases for incandescent lamps, efficacy also generally increases. To use a single range

of wattages while taking into account variation in efficacy by wattage, DOE has developed a3

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single standard per product class as an equation that relates lumens to wattage and sets a mi nimum efficacy requirement that varies by wattage. Chapter 5 of th is TSD provides more information on the selection of candidate standard levels using this equation.

3.5.2.2 Spectrum

Modified spectrum q IRLs provide unique utility to consumers by providing a different type of light than standard spectrum lamps, much like fluorescent lamps with different CCT

va lues. However, the same technologies that modify the spectral emission of a lamp also

de crease lamp efficacy. To modify the spectrum, the coating absorbs a portion of the light emission from the filament. Neodymium coatings or other coatings on modified spectrum lamps

a bsorb some of the visible emission from the incandescent filament (usually red), creating a modified, reduced spectral emission. Since the neodymium or other coatings absorb some of the lumen output from the filament, these coatings decrease the efficacy of the lamp.

Because of the impact on both efficacy and utility, DOE is considering establishing separate product classes based on spectrum. DOE is planning to establish separate product classes for standard spectrum IRLs (those without modification to the spectral emission) and

modi fied spectrum IRLs (some portion of the spectral emission is absorbed).

3.5.2.3 Diameter

IRL diameter provides a distinct utility to the consumer, such as the ability to be installed in smaller fixtures. The diameter of an IRL also has an impact on its efficacy. Smaller diameter lamp s have an inherently lower optical efficiency than larger diameter lamps with similar

filame nts. Additionally, technology options that improve efficacy that are available to larger lamps are not necessarily available to small diameter lamps given the spatial constraints. Therefore, because of the impact on both efficacy and consumer utility, DOE is considering

e stablishing separate product classes for lamps with a diameter of 2.5 inches or less and lamps

with a dia meter greater than 2.5 inches.

3.5.2.4 Rated Voltage

Existing DOE test procedures provide for lamps rated at 130 V to be tested at 130 V and

for lamps rated at 120 V to be tested at 120 V. However, DOE is aware that a large number of consumers actually operate 130 V lamps at 120 V, which results in longer lifetime but lower efficacy. With a single efficacy level (EL) for lamps rated at each voltage, this situation would

qAs found in 10 CFR 430.2: Modified spectrum means, with respect to an incandescent lamp, an incandescent lamp that— (1) Is not a colored incandescent lamp; and (2) When operated at the rated voltage and wattage of the incandescent lamp— (A) Has a color point with (x,y) chromaticity coordinates on the C. I.E. 1931 chromaticity diagram, figure 2, page 3 of IESNA LM-16 (incorporated by reference; see § 430.3) that lies below the black-body locus; and (B) Has a color point with (x,y) chromaticity coordinates on the C. I.E. 1931 chromaticity diagram, figure 2, page 3 of IESNA LM-16 (incorporated by reference; see § 430.3) that lies at least 4 MacAdam steps, as referenced in IESNA LM-16, distant from the color point of a clear lamp with the same filament and bulb shape, operated at the same rated voltage and wattage.3

- 47

effectively lead to a lower efficacy requirement for these 130 V lamps that are run at 120 V, compared to 120 V lamps run at 120 V. The 130 V lamps would not require the same level of technology as 120 V lamps to meet the same standard, and, thus, they would be cheaper to produce. Therefore, setting higher standards for IRLs without accounting for voltage differences could result in increased migration to 130 V lamps instead of the 120 V lamps, which could increase energy consumption.

For example, if DOE were to adopt a minimum efficacy requirement that would effectively require improved halogen infrared reflector (HIR) technology for 120 V lamps, due to

diff erences in the test procedures for lamps rated at 130 V, a 130 V lamp may only need to employ an improved halogen technology, which would be less costly. If DOE does not establish a separate standard for lamps rated at 130 V, more consumers may purchase 130 V lamps

be cause they are less expensive. When consumers operate these lamps at 120 V, they may need
to purc hase more lamps to obtain sufficient light output, thereby increasing energy consumption.

The refore, to preserve the energy savings intended by these standards, DOE is considering establishing two separate product classes: (1) lamps with a rated voltage less than 125 V, and (2) lamps wit h a rated voltage greater than or equal to 125 V.

3.5.2.5 Beam Spread

DOE considered setting product classes for IRLs based on beam spread values or beam spread categories (spot, flood, narrow flood, etc.). DOE conducted an analysis to determine if beam spread impacted efficacy by comparing lamps with the same characteristics but different beam spreads. DOE concluded that while there might be different utility for consumers through the light distribution patterns of lamps with different beam spreads, the beam spread does not affect the efficacy of the lamp. Thus, DOE does not plan to establish separate product classes for beam spread.

3.5.2.6 Center Beam Candle Power

Center beam candle power (CBCP) provides a measure of the light intensity at the center

of an angle and is correlated to beam spread. DOE conducted an analysis to determine if CBCP impacted efficacy by comparing lamps with the same characteristics but different CBCP values. DOE concluded that while there might be different utility for consumers through the variation in light intensity between lamps with different CBCP values, the CBCP does not affect the efficacy of the lamp. Thus, DOE does not p la n to establish separate product classes for CBCP.

3.5.2.7 Length

DOE considered setting product classes for IRLs based on maximum overall length of the lamp . DOE conducted an analysis to determine if length impacted efficacy by comparing lamps with the same characteristics, but different lengths. DOE was unable to confirm a relationship between length and efficacy. DOE concluded that while there may be a certain consumer utility

for lamps with different lengths, the efficacy impact did not justify establishing product classes

ba sed on length.3

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3.5.2.8 Product Class Summary

DO E is considering maintaining the same product class divisions as those established in the 2009 Lamps Rule. The IRL product class es being considered in this preliminary analysis are

summarized in Table 3.5 .6

.

Table 3.5. 6 IRL Preliminary Analysis Product Classes

Lamp Type Diameter

(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 V3

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23 Ibid.

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>

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27 Illuminating Engineering Society of North America. “The IESNA Lighting Handbook: Reference and Applications.” Ninth Edition. 2000. p. G-7.

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32 Rea, Mark S., ed. The IESNA Lighting Handbook: Reference & Application, 9 th Edition . 2000. The Illuminating Engineering Society of America: New York, New York.

33 Ibid.

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37 Patton, R.J., et al. “Fluorescent Incandescent Lamp.” United States Patent Office. June 1992.