The lighting (r)evolution continues

In March, the Department of Energy (DOE) proposed new lighting efficiency standards that would accelerate the transition to light-emitting diode (LED) technology, producing tremendous savings over current lighting standards. The standards would apply to the most common type of lighting in our homes (known as general service lamps or GSLs) and would include incandescent lamps, compact fluorescent lamps (CFLs), light-emitting diode (LED) lamps, and organic LED (OLED) lamps. It would also include candelabra and intermediate base lamps and some of the pin-based lamps.

All GSLs would be required to meet an efficiency standard of at least 45 lumens per watt (lpw) (more than three times the current standard) or higher. This is a legally required minimum according to a 2007 law (Energy Independence and Security Act) signed by President Bush. It states that new standards must “produce savings that are greater than or equal to the savings from a minimum efficiency standard of 45 lpw….” If not, then a backstop standard of 45 lumens per watt (lpw) for all GSLs is triggered. Since DOE has been prohibited from working on general service incandescent lamp standards because of an appropriations rider, the backstop has been triggered.

This proposed rule would significantly increase the energy efficiency of GSLs sold in the United States. However, there are a number of important ways in which the proposed standards could be strengthened to ensure the intended savings are achieved.

Timing

Manufacturers of GSLs covered by the minimum 45 lpw backstop would need to comply with the new efficiency levels by January 1, 2020. Manufacturers of GSLs covered by more stringent standards would need to meet the standards three years after the date that the final rule is issued (probably in early-2020). There would be at least a year of sell-through of remaining stock of non-complying GSLs at retail following the effective date.

Standby

In the Notice of Proposed Rulemaking (NOPR), DOE anticipates that “smart” lamps, which incorporate control, communication and sensor technologies, will eventually account for a significant share of the US GSL market. The NOPR creates a separate product category for smart GSLs and proposes an efficiency standard for GSLs operating in active mode that is about 5% less stringent than for conventional GSLs. 

Potential Loopholes

There are currently, and would continue to be, an additional 22 types of lamps exempted from the definition of GSLs. Some of these exempted lamps could become loopholes that could reduce the effectiveness of the proposed standard. Many of these 22 lamps are already available in efficient LED versions. DOE should re-evaluate the 22 exempt lamps, including only those which truly merit exemption.

Stringency

DOE’s own analysis shows that an even higher efficiency standard for LEDs and CFLs would be more cost effective than the one that DOE proposes. DOE also acknowledges the rapid evolution of LED technology, and the fact that the proposed standards would not necessarily be reflected in GSLs being sold until 2021 or later, at which point even more efficient and less expensive LEDs will be available. Given the continued rapid improvement in LED efficiency and cost, DOE has ample reason to propose standards at the higher standard level now.