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Lane Burt’s Blog

DOE’s proposed rule on lamps: This is a big deal.

Lane Burt

Posted January 26, 2009 in Solving Global Warming

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DOE recently released the Notice of Proposed Rulemaking for general service fluorescent (GSFL) and incandescent reflector lamps (IRL). See the actual document here, press release here, and general fact sheet here.

GSFLs are the tube shaped fluorescent lights hanging in every office, while IRLs are the recessed "can" lights that are so popular in homes right now. Lamps = bulbs in geek speak. If you consider how often you see these types of lights, maybe the potential energy savings will be a little less shocking.

This is largest potential energy savings of any appliance standard in history.

The standard as proposed is projected to save by 2042,

  • 9.6 quadrillion BTUs of energy
  • $39.7 billion of consumer dollars spent on energy
  • 3850 MW of generating capacity
  • 509 million metric tons of CO2
  • 804 kilotons of NOx
  • 8.6 tons of mercury


That is a lot. 9.6 quads of energy would power 101 of the 111 million homes in the country. Did the Bush Administration finally do something right on the way out the door?

No. The savings left on the table are just as astounding. Higher standards would net additional savings of,

  • 6.2 quadrillion BTUs of energy
  • $25.6 billion of consumer dollars spent on energy
  • 2050 MW of generating capacity
  • 290 million metric tons of CO2
  • 461 kilotons of NOx
  • 2.4 tons of mercury


I know we have all been desensitized by bailouts and stimulus, but that is an absurd amount of money and energy. Our government would have good reasons for not setting the standards to achieve these benefits, right? Not so much.

Incandescent Reflector Lamps (Cans or IRLs)

The incandescent reflector lamp standard as proposed is actually pretty good. The Department did a good job sorting through some thorny technological issues to make their decision. The savings potential in IRLs is around 2.6 quads and the proposal captures the 2.3 of them. The problem here is entirely in scope of coverage.

Lamps can come in all shapes and sizes and be used for a multitude of applications, making the standards levels and scope of coverage difficult to determine. How do you regulate different technologies (LED, incandescent, fluorescent, halogen, etc), different sizes and shapes, different wattages, and different uses? It is tough. The best approach is to treat all possible lighting options for a particular use equally. You don't want to set lower standards for inherently less efficient technologies if there are more efficient alternatives.

Then there are the countless niche lighting products. The intent of the standard is to save energy and money, not to ban certain specialty lights (like theater or aquarium lights) and cause headaches for users of those products without saving any energy.

So DOE sets standards for most lamp types for general applications, but exempts niche products. Most niche products are not manufactured in high volume (so they are expensive) and aren't well suited to general lighting applications (would you want a super intense theater light in your living room?), so there are no problems. But if they are cheap and look good in your living room, then we have a loophole that could undermine the standard entirely.

A well know and generally acknowledged loophole in IRLs is BR type lamps. BR is a bulb shape (R, PAR, ER, and BPAR are the other options) with a slight bulge designed to focus light where needed. Epact in 1992 first regulated IRLs, but exempted BRs because the sales were negligible. This exemption stands and BR lamps are now 40% of the IRL market. Clearly, these are no longer niche products but are a low cost way to get around the standard.

This loophole must be closed. ACEEE estimates an additional 1.3 quads of energy savings (and 4 billion dollars) from regulating BR lamps, but the amount of savings that will be lost if BR lamps are allowed to stay unregulated is unquantifiable. That 40% of sales could easily balloon when the new standards take effect in 2012.

And as you might expect, DOE has decided it does not have the authority to regulate these lamps. This is unacceptable. By covering these lamps but refusing to set a standard, DOE also pre-empts the states from regulating BR lamps. The new administration can make an immediate impact by reviewing this rule and reconsidering their position.

Fluorescent Tube Lamps (GSFL)

Fluorescent tube lamps are about as ubiquitous as it gets. If you are at work in an office there is probably one above your head right now, but they are sometimes used in kitchens and basements as well. Unlike IRLs, the Department has not done a good job of selecting an appropriate standard level, leaving half of the savings on the table.

In standards rulemakings, DOE is required to identify the maximum level of efficiency possible and then analyze the life cycle cost to consumers. They must analyze the highest levels of efficiency and move down until they find a level that is economically justified. The odd thing here is that in this rulemaking, every level they looked at generated positive consumer savings. The dollar savings just kept going up with the efficiency levels. Level 5 was shown to save massive amounts of energy and money while Level 4 achieved 88% of the potential energy savings and 95% of the potential dollar savings. Level 3 (the level selected by DOE) only achieves 55% of the potential energy savings and 45% of the potential dollar savings.

So why set the standard there? Well, DOE decided that the impacts on certain subgroups would be too large and outweigh the larger national benefits. I really dislike this reasoning because it is no way to set national policy (special interests anyone?), and it is inconsistently applied. All of the benefits that DOE quantifies are to "consumers" defined as purchasers of the product. But the benefits of standards aren't only felt on this "sub-group" as even folks who do not purchase the item benefit from lower electricity prices, increased energy security, less pollution, and less CO2 emissions. None of those benefits are quantified, so the decision to set lower standards based on a particular subgroup of a subgroup, while not counting the largest benefits explains a bit about the success of our national energy policy. It would be cheaper for taxpayers to just buy all these disadvantaged folks new lights.

In reality, it is not the subgroups that are really driving this decision, since most of these same subgroups still have negative impacts at Level 3. In fact, the percentage of users of certain lamp types and sizes that are disadvantaged varies from only 2 to 33%. DOE is really trying to avoid eliminating T12 lights (versus T8 or T5, where the number corresponds to the width of the bulb). No one buys T12 lights anymore unless they are replacing a bulb or just completely unconcerned with energy costs, but manufacturers still make them and converting these production facilities to T8s will cost money. Millions of dollars.

So rather than force manufacturers to stop selling T12s, DOE has passed up 26 billion dollars in consumer savings, plus the aforementioned uncounted benefits to all consumers. The savings from purchasers alone would cover the industry cost 141 times. Not exactly a good investment strategy.

Its not over yet...

The Obama Administration needs to review the decisions made by the outgoing administration and respond to stakeholder comments before the final rule is issued in June. The final rule must be based on comments to the NOPR unless a new NOPR is issued, some some issues may be unfixable.  Regardless, there is still a lot that can done. 

We can't let cost effective energy savings slip through our fingers now, of all times, when we face a global recession, an insecure energy infrastructure, and looming global climate change. This rule is simply too important to screw up.

Addition 1/27/09 - I forgot to mention that the hearing for this rulemaking is scheduled for Feb 3 and I will be attending for NRDC.  I will also make available draft comments that can be submitted by interested folks before the comment deadline, which will be sometime in March.  Stay tuned.

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Cliff MajersikJan 27 2009 12:19 AM

Excellent post on an important opportunity! What can readers do to help the Obama Administration fix the problems you've described in DOE's proposed rules? Should we submit comments as part of the official rulemaking process? If so, what is the best way to do so?
Cliff Majersik

LaneJan 27 2009 08:50 AM

Thanks Cliff. I have added a note about the hearing and the draft comments I will make available to interested folks for submitting to the docket. More info coming soon.

Marianne DiMascioJan 29 2009 10:01 AM

You can also check out our website for info on this and other appliance standard activity. You can send an alert to DOE from our page (though you might want to wait a week for an updated letter)
Marianne DiMascio
Appliance Standards Awareness Project

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