6450-01-P

DEPARTMENT OF ENERGY

Office of Energy Efficiency and Renewable Energy

10 CFR Part 430

(Docket No. EE-RM-94-220-IF)

RIN: 1904-AA61

RIN: 1904-AA70

Energy Conservation Standards Program for Consumer Products: Test Procedures for

Fluorescent and Incandescent Lamps

AGENCY: Office of Energy Efficiency and Renewable Energy, Department of Energy

ACTION: Notice reopening comment period.

SUMMARY: On September 28, 1994, the Department of Energy (Department or DOE)

published an interim final rule and a proposed rule regarding energy conservation test procedures

for fluorescent and incandescent lamps. Based on the public responses, the Department is

considering certain revisions of the interim final rule and proposed rule and seeks public comment

on options it is considering. The options involve the following topics: determining the wattage of

a fluorescent lamp for purposes deciding whether the energy conservation standards and test

procedures apply to it; the confidence limit, "derating factor" and statistical test used in the test

procedure sampling plan; definition of colored lamps; determining the rated voltage or rated

voltage range of an incandescent lamp for purposes of deciding whether the energy conservation

EE-RM-94-220-IF COMMENT 27
standards and test procedures apply to it; defining rated voltage for testing incandescent lamps;

and defining the bulb shapes for elliptical reflector (ER) and bulged reflector (BR) incandescent

lamps.

DATES: Written comments in response to this notice must be received by the Department by

[Insert date 45 days after publication in the Federal Register . The Department requests 10

copies of the written comments and, if possible, a computer disk. (The Department uses

WordPerfect.)

There will be a public meeting to gather input on these issues in Washington, D.C., on

March 5, 1996. The meeting will begin at 9:30 a.m. and will be held at the U.S. Department of

Energy, Forrestal Building, Room 2E-069, 1000 Independence Avenue, S.W., Washington, D.C.

ADDRESSES: Written comments are to be submitted to: U.S. Department of Energy, Office of

Energy Efficiency and Renewable Energy, Ms. Sandy Beall, "Energy Conservation Standards

Program for Fluorescent and Incandescent Lamps, Docket No. EE-RM-94-220-IF," EE-43 1,

Forrestal Building, 1000 Independence Avenue, SW, Washington, DC 20585-0121. Telephone:.

(202) 586-7574; Telefax: (202) 586-4617.

Copies of the transcript of the July 19, 1995 lamp workshop and of the public comments

on the interim final rule may be read at the Department of Energy Freedom of Information

Reading Room, U.S. Department of Energy, Forrestal Building, Room 1E-190, 1000

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February 21, 1996

EE-RM-94-220-IF COMMENT 27
Independence Avenue, S.W., Washington, D.C. 20585, (202) 586-6020, between the hours of

9:00 a. m. and 4 :00 p.m., Monday through Friday, except Federal holidays.

FOR FURTHER INFORMATION CONTACT:

Terrence L. Logee

U. S. Department of Energy

Office of Energy Efficiency and Renewable Energy

Mail Station EE-431

Forrestal Building

1000 Independence Avenue, S.W.

Washington, DC 20585-0121

(202) 586-1689

Edward Levy, Esq.

U. S. Department of Energy

Office of General Counsel

Mail Station GC-72

Forrestal Building

1000 Independence Avenue, S.W.

Washington, DC 20585-0103

(202) 586-2928

SUPPLEMENTARY INFORMATION:

1. Authority

Part B of Title III of the Energy Policy and Conservation Act, Pub. L. 94-163, as amended

(EPCA) or the Act, created the Energy Conservation Program for Consumer Products other than

Automobiles (Program). The products currently subject to this Program include certain

fluorescent and incandescent lamps and medium based compact fluorescent lamps. EPCA sets

minimum energy conservation standards for general service fluorescent and incandescent reflector

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Febmary 21, 1996

EE-RM-94-220-IF COMMENT 27
lamps and requires the Department to develop test procedures.

2. Background

On September 28, 1994, the Department published an interim final rule establishing test

procedures for general service fluorescent and incandescent lamps and for medium based compact

fluorescent lamps, 59 FR 49468, and a Notice of Proposed Rule for definitions of rough and

vibration service incandescent reflector lamps and colored fluorescent and incandescent lamps, 59

FR 49478. In addition DOE held a hearing on the proposed rule on November 15, 1994 and a

workshop on these issues on July 19, 1995. The Departoment received many comments on the

interim final rule and on the proposed rule including comments from manufacturers, a national

trade association, a professional society, a utility, and a Federal agency. The comments included

requests that the Department: (1) modify its test procedure sampling plan to.change the

confidence limit, "derating factor," and statistical test used to determine compliance of certain

lamps with the energy conservation standards; (2) permit testing and compliance for incandescent

lamps at a lamp's design voltage, and expand the voltage range from the statutory requirement of

115 through 130 volts to 100- through 150 volts; (3) define the exemption for the bulged reflector

(BR) and elliptical reflector (ER) incandescent reflector lamp by reference to the American

National Standards Institute (ANSI) C79.1-1994; (4) determine that a new product coming on the

market, a fluorescent lamp rated at 25 watts, which is below.the 28 watt threshold for coverage

under EPCA, is actually a 40 watt fluorescent that is covered by the statutory standards and test

procedures; and (5) revise its proposed definition of colored fluorescent and incandescent lamps.

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EE-RM-94-220-IF COMMENT 27
In response to the foregoing suggestions, the Department is considering various options to

alter the Interim Final and Proposed Rules. Because the issues raised by these options were not

expressly considered in either the preamble to the Interim Final or Proposed Rules, the

Department is now seeking comment from interested parties on these options. In particular, the

Department seeks any new factual information and data that will assist it in addressing these

issues.

3. Discussion

a. Revision of the sampling plan. DOE's Energy Conservation Program for Consumer

Products has been developed and refined since its inception in 1978. Compliance with energy

efficiency standards has been assured in part by having each manufacturer certify that its covered

products comply with the applicable energy efficiency standard. The certification must be based

on tests of the product in accordance with test procedures prescribed by DOE.

In promulgating test procedures applicable to certification, one of the major goals has

been to provide a statistically valid approach so that there is a high probability that products

which have been tested and certified as being in compliance with the applicable efficiency

standards actually comply with those standards. Each DOE test procedure incorporates a

sampling plan, and that sampling plan is designed to give reasonable assurance that the true mean

performance of the product being manufactured and sold meets or exceeds the DOE energy

efficiency standard.

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EE-RM-94-220-IF COMMENT 27
DOE recognizes that units of a product may vary in energy efficiency for a number of

valid reasons, including differences in component parts, production and testing. The risk to the

public of purchasing a non-complying product, the risk to manufacturers of selling such a product,

and the burdens of performing representative testing, are reduced through the application of a

statistically meaningful sampling plan and basing the certification decision on the mean energy

performance of the sample units.

There are several critical elements of a sampling plan. One is the selection of units for

testing. Units must be representative of the product, and be selected randomly from a batch.

Sample size is also a critical element of a sampling plan. The results yielded by energy efficiency

testing of a product, consisting of tests conducted on a sample of units, will be increasingly more

reliable as the size of the test sample increases. This, however, increases the testing burden on the

manufacturers. Also, as the variability in performance increases among individual tested units of a

product, the reliability of the test results decreases. As a result, DOE's test procedures require

sampling plans based on a confidence limit approach. This approach is designed to minimize the

manufacturers' testing burden while ensuring accurate determination of compliance within a

specified level of confidence.

The interim final rule prescribing test procedures for lamps requires a minimum sample

size of 20 units for each model, which must be randomly selected during seven out of 12 months

of production. The rule further provides in essence that the lamp efficacy for a given model of

lamp shall be the average efficacy for the tested lamps of that model, and "shall be no greater than

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EE-RM-94-220-IF COMMENT 27
the lower of (i) the mean of the sample or (ii) the lower 99 percent confidence limit of the true

mean divided by 0.99." DOE views the latter calculation as being a one-sided confidence interval

using the t-statistic, with the 0.99 divisor constituting a "derating" factor. The confidence limit

would be calculated using generally accepted methods found in statistics textbooks, based on the

sample mean and sample standard deviation.

DOE included the derating factor to take into account variability in the efficiency of.

products due to many factors, including manufacturing variability, variations in the material (e.g.,

phosphors), and testing errors, including reference lamp calibration errors. Furthermore, this

format (confidence limit divided by a derating factor) is similar to the format required for other

appliance products for which DOE has authority to require testing.

The National Electrical Manufacturers Association (NEMA) has proposed loosening the

confidence interval to 95 percent, and changing the derating factor to 0.97, which increases its

derating effect. It justifies this proposal on the basis of typical production variations and

,measurement uncertainties, including calibration issues. NEMA submitted estimates of the

magnitude of these variations and their effect on compliance determinations. They estimated an

uncertainty of 2 percent due to the reference lamps used in the measurement process, with

additional variability among different laboratories.

NEMA has also proposed substituting the z-statistic procedure for the t-statistic

procedure. The z-statistic procedure is similar to the t-statistic procedure, except that, for each

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EE-RM-94-220-IF COMMENT 27
model of a product, it uses the standard deviation, Q, that applies to the entire population of

manufactured units for that model. That standard deviation is assumed to be known from

previous measurements. The t-statistic procedure, by contrast, uses the standard deviation, s, of

the sample units tested. The z-test also replaces the factor t with another factor z, both of which

are found in standard tables.

The effect of going to a 95 percent confidence limit will be to make it slightly easier to

demonstrate compliance, while also slightly increasing the chance that a noncompliant product

will be judged to be in compliance. In other words, when testing demonstrates compliance at the

95 percent confidence level, there would be a one in twenty chance that a non-tested unit of the

product may not meet the standards instead of a one in one hundred chance under the procedure

promulgated by the interim final rule.

The effect of using the z procedure instead of the t procedure will be to produce lower

confidence limit values which are more favorable to the manufacturers, because the value of the z

factor from the tables is less than the value of the t factor, unless the number of sample units, n, is

very large. However, the z procedure is more representative than the t procedure because the

standard deviation in the z method is determined from a larger population than the standard

deviation in the t method. Use of the z procedure requires an accurate measurement of the

population standard deviation for each model. Accurate measurement would appear to require,

for example, prior tests of a large number of units-of that model selected at random, conduct of

the prior testing in accredited laboratories, and prior testing conducted under conditions and using

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EE-RM-94-220-IF COMMENT 27
test procedures that are comparable to current conditions and procedures.

The Department is considering the option of permitting a manufacturer to use the

"z"statistic as an alternative to the "t" statistic, for tests of any product for which the following

criteria are met: 1) the standard deviation used in the test procedure was derived from a minimum

sample of 60 or more randomly selected lamps of the same basic model; 2) the statistical data

was measured by accredited laboratories; 3) the prior testing was conducted under conditions and

using test procedures comparable to current conditions and procedures. When these criteria are

not met, a manufacturer would be required to use the "t-statistic." The Department specifically

seeks input on whether lamp manufacturers can derive standard deviations for their products from

historic test experience. The Department is seeking comment on this approach or other possible

uses of the "z" statistic. The Department is also considering, and seeks comments on,

modification of the derating factor and confidence interval, as suggested by NEMA.

b. Definition of Rated Voltage, Determination of Test Voltage and Determination of

Voltage Range. When the Department considered test procedures for incandescent lamps in the

interim final rule, it noted that neither the definition of incandescent lamp in Section 321(30)(C) of

the Act, 42 U.S.C. 6291(30)(C), nor Illumination Engineering Society LM-20, "Approved

Method for Photometric Testing of Reflector-Type Lamps" defined the test voltage. Therefore,

in the interim final rule, the Department requires testing of all incandescent lamps at 120 volts to

be consistent with the statutory requirements for labeling. 10 CFR Part 430, Subpart B,

Appendix R, Section 4.2.1.

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EE-RM-94-220-IF COMMENT 27
In its comments, NEMA requested that the Department allow testing of incandescent

lamps at their design voltage. Otherwise, NEMA claimed that certain 125 and 130 volt lamps

would be banned from the market by failing to meet the standards if tested at 120 volts. The

industry and NEMA also claim that 125 and 130 volt lamps serve two market niches: regions in

the country where power line voltage is greater than the nominal 120 volts and applications

requiring long life lamps. Manufacturers claim that they would be forced to sell lamps with

decidedly shorter lives than the 125 and 130 volt lamps currently in the marketplace if DOE

requires compliance with the standards at 120 volts.

In response to queries by NIST, Philips proposed that the Department consider requiring

testing of incandescent lamps at the rated voltage marked on the lamp. Furthermore, when a lamp

is marked with a voltage range, Philips proposed that the rated voltage should be taken as the

mean of the voltage range . This wording is based on text taken from the International

Electrochemical Commission Standard 432-1.

The Department believes that requiring compliance for incandescent lamps at 120 volts

will reduce lamp life for some consumers and may also remove most 125 and 130 volt lamps from

the marketplace. However, none of the manufacturers define what is meant by design voltage.

Therefore, since the statute uses rated voltage, the Department is considering adopting the

definition of rated voltage from the Institute of Electrical and Electronics Engineers Standard

Dictionary of Terms which defines rated voltage as "the voltage to which operating and

performance characteristics are referred." Furthermore, the Department is considering a

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EE-RM-94-220-IF COMMENT 27
requirement to test incandescent lamps at the rated voltage, as marked on the lamp, or at the

mean of rated voltage range, as marked on the lamp. This approach would provide for testing.

incandescent lamps at a known reference voltage for certification to the energy efficiency

standards while agreeing with the Federal Trade Commission (FTC) requirements for labeling.

The Department is also considering the option of requiring that lamps not marked with a voltage

will be tested at 120 volts.

With respect to the issue of "fated voltage range" the definition of "incandescent reflector

lamp" in the Act, refers to a "rated voltage or rated voltage range at least partially within 115 to

130 volts." Section 321(30)(C)(ii), 42 U.S.C. 6291(30)(C)(ii). NEMA recommended expansion

of the voltage range in the statute to 100 to 150 volts, asserting that the statutory limit could

unintentionally allow evasion of the standards requirements for certain products. Under the

language in the statute, for example, a product could be rated at 131 volts, thereby removing it

from the standard. Yet this product would perform acceptably in a 130 volt environment and

could be sold for such applications.

The interim final rule incorporates the statutory definition of incandescent lamp including

the voltage range. The Department will continue to use this definition. The Department notes

that only one manufacturer currently markets lamps with design voltages greater than 130 volts.

However, in response to queries by NIST, several manufacturers agreed that the nominal

tolerance for incandescent lamp voltage is t10 percent . The Department believes that the

statutory range of 115 to 130 volts may also be subject to this tolerance. Therefore, the

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EE-RM-94-220-IF COMMENT 27
Department is considering the option of treating lamps with voltages greater than 103.5 volts and

less than 143.0 volts as being "at least partially within a rated voltage range of 115 to 130 volts,"

and subject to the energy efficiency standards.

The Department is seeking comments on the acceptability and workability of these options.

for rated voltage, test voltage and rated voltage range. Alternative proposals are welcome but the

Department requests that these proposals be supported by references to existing or draft industry

standards or that the proposals be supported by data.

c. ER and BR Reflector Lamp Definitions. The Act contains exemptions for several types

of incandescent reflector lamps including those for ER (elliptical reflector) and BR (bulged

reflector) bulb shapes. Section 321(30)(C)(ii), 42 U.S.C. 6291(30)(C)(ii). However, these lamps

are not defined in the statute or the interim final rule and DOE is concerned that the exemption

may be abused without a clear definition of what constitutes an ER or BR bulb.

One commenter provided copies of ANSI Standard C79.1-1994 which contain

descriptions of the ER and BR bulb shapes. Another commented that if the ANSI definition was

different than what some manufacturers have been using, there would be tooling costs to conform

the lamp envelope to the new shape definition and DOE should provide time for manufacturers to

implement the new ANSI requirements. In its comments to the workshop, NEMA claimed that

there was a consensus to define ER and BR lamps by reference to ANSI Standard C79.1-1994.

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EE-RM-94-220-IF COMMENT 27
An Osram-Sylvania Inc. (OSI) comment claims that: 1) the BR lamp is not marketed for

recessed applications; 2) BR lamps are more efficient than rough/vibration service R lamps; 3)

the BR lamp is less costly for the residential market than the halogen PAR lamp; 4) OSI has

introduced a 65 watt BR lamp which meets the efficiency standards; and 5) the ANSI C79.1-

1994 bulb shape standard is a result of the mandatory ANSI 5-year revision cycle and it is

fundamental to all lamp/fixture interchangeability. The Department notes, however, that the

previous ANSI revision to the bulb shape standard was published in 1984.

During the workshop, the American Council for an Energy Efficient Economy (ACEEE)

commented that this exemption was placed in the statute to protect one small manufacturer and

that the drafters of the Energy Policy Act of 1992 (EPACT) believed that. these products were not

sold in large quantities and were expected to disappear from the market. Furthermore, ACEEE

comments suggested that the exemption was meant to apply to lamps that are rated with lower

wattage than their reflector (R) or parabolic aluminized reflector (PAR) counterparts. In its

written comments, ACEEE requested that DOE define ER and BR lamps in a way that would

limit exemptions for these lamps as originally intended in EPACT.

The Department believes. the definitions of ER and BR bulb shapes in

ANSI Standard C79.1-1994 (Figure 1 on page' 7) are new definitions of the ER and BR bulb

shapes because earlier versions of ANSI Standard C79.1 did not include definitions for either ER

or BR bulb shapes in their current form. ANSI C79.1-1984 discusses the bulged (B) and

elliptical (E) shape designations as basic bulb shapes of general service incandescent lamps. The

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EE-RM-94-220-IF COMMENT 27
"RE" elliptical reflector shape in the 1994 ANSI C79.1 standard could be described as cutting off

the top half of the basic "E" bulb shape in the 1984 document since the elliptical portion of the

"E" bulb forms that part of the "RE" bulb below the major axis .or lens of the reflector bulb.

However, the bulged reflector bulb would represent a greatly diminished "B" shaped bulb with a

reflector bulb connected to the top of this small "B" shaped bulb. For these reasons, the

Department believes the 1994 ANSI document represents a major modification of elliptical and

bulged bulbs from the 1984 document.

ER and BR reflector bulb shapes typically have a long neck, a characteristic which is not

addressed in ANSI C79. 1. This is presumably to extend the lens closer to the end of recessed

ceiling fixtures in the ER bulb. Therefore, the Department believes the ANSI C79.1-1994

definitions of the ER and BR bulb shapes are subject to interpretation, and questions whether

these definitions agree with the commonly understood bulb shapes being manufactured and which

were contemplated by exclusion of ER and BR bulbs from EPCA coverage.

Although the Department believes the ANSI Standard C79.1-1994 does not fully prescribe

the ER and BR bulb shapes, the Department is considering adopting ANSI Standard C79.1-1994

as part of the definition of an ER or BR bulb shape, subject to additional criteria, to capture the

characteristics of ER and BR bulbs in the marketplace at the time the exemptions were

established. One criterion being considered is a longer neck than an R or PAR lamp with either a

specified dimension or a dimension stated as a comparison, such as 25 percent longer than similar

wattage R or PAR lamps. An additional criterion under consideration for the BR lamp is to

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EE-RM-94-220-IF COMMENT 27
require that the bulged shape must be reflectively coated and large enough to redirect light

emitted by the filament to the side and rear of the lamp toward the lens. The Department is also

considering a requirement for a reduced wattage filament for both ER and BR lamps. The

Department is seeking comment on whether to specify a certain wattage reduction or to state this

reduction as a percentage comparison to standard R or PAR lamps.

The Department invites comments on the definitions for ER and BR lamps it is

considering. The Department also requests copies of catalog listings and other data to help it

determine the extent of reduced wattage ER and BR lamps offered in the market.

d. Determination of rated wattage for a fluorescent lamp. EPCA sets standards for

fluorescent lamps 48 inches long with rated wattages of 28 watts or more, 96 inches long with

rated wattages of 52 watts or more, and 2 foot U-tube lamps with rated wattages of 28 watts or

more. Sections 321(30)(A) and 325(i)(1), 42 U.S.C. 6291(30)(A) and 6295(i)(1). The standard

levels have the effect of prohibiting the sale, after October 31, 1995, of certain lamps previously

on the market, including 4-foot, 40 watt cool white fluorescent lamps.

The 4-foot, 40 watt cool white fluorescent lamp consumes 40 watts of power when used

with a conventional high power factor ballast. High power factor ballasts are used in over 85

percent of the fluorescent fixtures using four foot lamps. Such high power factor ballasts are

typically used in commercial applications. If a 40-watt cool white lamp is used with the type of

low power factor ballast generally used in residential applications, the lamp will consume about 25

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EE-RM-94-220-IF COMMENT 27
watts, which is below the 28 watt threshold that defines the lower limit of coverage in the

standards.

Neither the statute nor DOE's existing regulations specify the type of ballast to be used in

determining the rated wattage of lamps. In the absence of a specification, some have argued that

4-foot lamps could have their rated wattage determined using a low power factor ballast and if,

using this testing method, the rated wattage was less than 28 watts, the lamp would be exempt

from the standard.

DOE believes that it is unreasonable to apply this statute so as to permit the continued

manufacture and sale of lamps that when used with the most common types of ballasts (i.e., high

power factor) would consume 28 or more watts, but fail to meet the standards prescribed by the

statute. In an attempt to address this concern, DOE sent a letter on August 30, 1995, to lamp

manufacturers indicating that it would consider any lamp that was electrically the same as the 40-

watt cool white lamp to be subject to the same statutory standards. However, manufacturers have

since begun to introduce, or indicated that they plan to introduce, slight variations on the 40-watt

cool white lamp that would be rated at 25 watts based on use of low power factor ballasts.

Despite these modifications, the lamps being marketed or developed would still perform like 40

watt cool white lamps when used in high power factor ballasts.

The Department believes that Congress intended the rated wattage of fluorescent lamps,

for purposes of defining the universe of lamps covered by the standards, to be determined by

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EE-RM-94-220-IF COMMENT 27
using a high power factor ballast. The wattages included in the table that now appears in section

325(i) of the Energy Policy and Conservation Act appear to assume the use of high power factor

ballasts. 42 U.S.C. 6295(i). In addition, when Congress had previously set efficiency standards

for ballasts, those standards were only applied to high power factor ballasts.

The Department is now considering a requirement that the rated wattage of a fluorescent

lamp, for purposes of determining coverage by the standards, is the measured wattage when the

lamp is used with a high power factor ballast. The Department is soliciting public comment on

the possibility of requiring the use of high power factor ballasts in determining the rated wattage

of fluorescent lamps. Before making a final determination on this matter, the Department also

intends to consider other possible means to achieve comparable objectives.

For example, the Department is considering the approach used in the Canadian lamp

regulations issued in the November 29, 1995 Canada Gazette, Part II, Volume 129, No. -24, pg

3073. Under this possible approach, the Department would add an additional phrase to the

definition for general service fluorescent lamp specifying that, "General service fluorescent lamp

means any fluorescent lamp that is a physical and electrical equivalent of a lamp described in

paragraph (a), (b), (c), or (d)." However, the Department believes that this approach may suffer

the same weakness as DOE's attempt to elaborate, on the definition of basic model discussed in the

DOE letter of August 30, 1995.

The Department also will consider determining whether a particular lamp is covered by the

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EE-RM-94-220-IF COMMENT 27
standards by requiring that its measured wattage be compared to the measured wattage of a

similar covered lamp using the same ballast. The wattage of the covered lamp divided by the

wattage of the lamp in question would be multiplied by the wattage marked on the covered lamp

to determine the rated wattage of the lamp in question. However, this approach may not work for

new products.

The Department is concerned, however, that if it requires rated wattage to be determined

using a high power factor ballast, manufacturers might be inhibited from producing certain

products designed and marketed for use exclusively with low power factor ballasts. Even though

there are now available a number of lamps that can be safely used in low power factor ballasts,

and which would be unaffected by this proposal, the Department does not want to restrict

unnecessarily the choices that might be available to users of low power factor ballasts in the

future. For this reason, the Department is soliciting public comment and proposals on how it

might use its discretionary regulatory authority or its authority to grant certain waivers or

exemptions to address this possible problem. Specifically, DOE is interested in identifying

specific technical features or performance or other characteristics of lamps that would provide

reasonable assurance that such lamps would be used exclusively in low power factor ballasts.

At least one manufacturer has indicated that it believes that a substantially reduced lamp

life (e.g., 6,000 hours compared to the industry norm of 20,000 hours) should restrict the usage of

such lamps to low power factor ballasts in the residential sector. But DOE is concerned that

lamps with useful lives-of -6,000 hours may still be widely used with high power factor ballasts.

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DOE is also concerned that accurately determining average lamp life can be difficult and time

consuming and questions the utility to consumers of a requirement that may discourage

manufacturers from increasing product life.

The Department recognizes that one of the motivations for introducing modified 40 watt

lamps is industry concern that residential and other users of low power factor ballasts might use

34 watt lamps in their fixtures, which would increase the risk of overheating and fires. While

consumers have a range of safe alternatives to the 34 watt lamp, and 34 watt lamps are being

labeled to warn consumers against their use with low power factor ballasts, DOE believes that

these industry concerns may be valid. DOE solicits public comment. on these concerns and how

DOE might best use its regulatory authorities to ensure consumers are adequately protected.

Finally, in order to better assess these issues, the Department is seeking more information

on the size and characteristics of the market for lamps used in low power factor ballasts.

e. Definition of colored fluorescent and incandescent lamp. In the Notice ofProposed

Rulemaking, the Department defined colored fluorescent and colored incandescent lamps because

Sections 321(30)(B)(iii), 321(30)(C)(ii), 42 U.S.C. 6291 (30)(B)(iii) and 42 U.S.C.

6291(30)(C)(ii) of the Act contain exemptions for these lamps without defining them. The

Department is seeking definitions of colored lamps which can be determined by measurement of

certain characteristics. Therefore, the Department proposed to define colored incandescent and

fluorescent lamps by using suitable minimum values of the Color Rendering Index (C RI) or

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EE-RM-94-220-IF COMMENT 27
correlated color temperatures (CCT). (59 FR 49478).

Several manufacturers suggested that the upper limit for CRY for colored fluorescent

lamps be increased to 40. Phillips Lighting states that a CRI of 40 will prevent the exclusion of

gold fluorescent lamps which are used in printing applications. OSI also recommends that the

acceptable CRI for amber and red incandescent lamps be raised but DOE believes that this is not

necessary with the proposed revisions to the colored incandescent lamp definition because these

lamps have a low CCT.

In its comments to the July 19, 1995 lamp workshop, Durotest suggests that CCT limits

for colored fluorescent lamps be less than 2,500°K or greater than 6,600°K or with a CRI less

than 40. For incandescent lamps, Durotest suggests that the CCT parameters should be less than

2,500°K or greater than 4,600°K or CRI less than 50. NEMA also suggests using the same CCT

and CRI parameters as Durotest. It asks DOE to clarify in the preamble that a lamp is considered

colored if its CCT falls outside the range above or if its CRI falls below the values above.

The Department appreciates the industry suggestions for revised limits on CCT and CRI.

DOE's original proposal would have defined certain green lamps as white lamps based on their

CRI. This problem is caused by the difficulty of choosing a reference lamp of equal CCT to the

lamp in question and because CRI was originally intended to characterize non-colored lamps.

As a result of industry suggestions and comments, one option the Department is

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considering is to revise its proposed definition of a colored lamp by using a maximum value of

CRI or a suitable band of CCT. Therefore, the Department is considering a definition of colored

fluorescent lamp.as a lamp with a CRI value less than 40 or a color correlated temperature not

above 2,500°K for red and yellow colors or not below 6,600°K for blue and green colors. The

Department is also considering a definition of colored incandescent lamp as a lamp with CRI

values below 50 or a lamp color correlated temperature either not above 2,500°K for red and

yellow colors or not below 4,600°K for blue and green 'colors. The Department believes that the

measurements required to determine if a lamp is colored by the above definitions are minimal.

The CRI is a required measurement for fluorescent lamps and manufacturers would only have to

make a CRI measurement for lightly tinted incandescent lamps. The color temperature is derived

from spectroradiometric measurements and this data already exists for most lamps.

However, at the July 19, 1995 lamp workshop, NEMA proposed an alternative definition

of colored lamps which depends on the excitation purity of a colored source. Excitation purity is

defined as the ratio of two collinear distances (NC/ND) on the Commission Internationale de

L'eclairage (CIE) chromaticity diagram. NC is the distance between the point representing the

sample lamp and a specified reference point. ND is the distance between the point locating the

dominant wavelength of the sample lamp and the specified reference point. NEMA suggests that

a value of excitation purity greater than 50 percent would be a reasonable lower limiting value

defining a colored lamp. NEMA claims that a single definition will suffice for all colors. Plotting

one number on the x,y chromaticity diagram which shows the 50 percent. excitation purity area

marked on it will quickly determine whether a lamp is colored. Furthermore, NEMA requested

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that the Department not finalize the colored lamp definition until they complete their specification

of chromaticity coordinate boundaries.

NEMA notes that the excitation purity method proposed will not discriminate between

clear and colored lamps with CCT's from slightly above 2,856°K and lower. This is an inherent

drawback of the chromaticity diagram and redefining the excitation purity limit will not correct it.

NEMA suggests that the Department define a colored region around the black body locus on the

chromaticity diagram.as white. The area within the 50 percent excitation purity area is called

pastel and lamps in this area must be marked for a specific application to be called colored.

Although the excitation purity method fits DOE's criteria for a measurable colored lamp

definition, the Department is not inclined to adopt this method because it is complicated to

describe due to the use of three zones on the chromaticity diagram.

As a second option, the Department is considering a colored lamp definition using x, y

chromaticity coordinates which lie outside of the area bounded by the following points:

(0.285,0.332); (0.453,0.440); (0.500,0.440); (0.500,0.382); (0.440,0.382); (0.285,0.264). These

boundaries are taken from CIE Publication No. 2.2, Colors of Light Signals.

The Department believes that defining a colored lamp by using the chromaticity

coordinates above will satisfy manufacturers' concerns that lamps of low color temperature but

near the black body locus should be considered white. Likewise, this method satisfies a DOE

concern that valid orange and red colored lamps on or near the black body locus would not be

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considered colored.

Since an incandescent lamp creates light by heating a filament "white hot," some lightly

tinted incandescent lamps lie very near the black body curve on the x-y chromaticity diagram.

The Department believes that the x-y chromaticity definition of colored lamps will apply to nearly

all colored lamps with a few significant exceptions. Very lightly tinted incandescent lamps, such

as jeweler's blue and plant grow lamps, may not meet the colored lamp definitions as they are

currently proposed. NEMA recommends an exemption for colored incandescent plant lamps

because there is a filter in these lamps which affects the yellow and green parts of the spectrum.

NEMA also suggests that DOE require manufacturers provide a generic description of a plant

lamp's features and require that these lamps be marketed and designated for plant lighting

applications., In addition to the above, GE Lighting proposes to add that colored lamps are not

suitable for general lighting applications. Therefore, the Department is considering an additional

criteria in the definition of colored incandescent lamps that would require application specific

incandescent colored lamps to be designated as such on the lamp and in marketing materials.

Additionally, Durotest has urged the Department to provide an explicit exemption for

neodymium lamps because they claim that the color is doped directly into the glass bulb.

Therefore, the Department is considering specifying.that incandescent lamps with lens filters

containing 5 percent or more neodymium are colored lamps. The neodymium filter adjusts the

light spectrum for reptile lighting applications.

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4. Public Meeting Procedure

At the public meeting, DOE will seek discussion of the points discussed in this notice.

Should any party wish to raise any other matter addressed in the Interim Final or Proposed Rules,

they should so notify DOE by February 29, 1996.

The meeting will be conducted in an informal, conference style. A court reporter will be

present to record the minutes of the meeting. There shall be no discussion of proprietary

information, costs or prices, market shares, or other commercial matters regulated by antitrust

law. After the meeting and period for written statements, the Department will consider the views

presented in formulating a Final Rule regarding fluorescent and incandescent lamp test

procedures.

Issued in Washington, DC,

Brian T. Costelli

Chief of Staff

Energy Efficiency and Renewable Energy

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