The Department of Energy’s Office of Energy Efficiency and Renewable Energy (EERE) is proposing to revise the energy conservation standards for general service fluorescent lamps (GSFL) and incandescent reflector lamps (IRL). Depending on lamp type, the proposed standards would increase energy efficiency for GSFLs by between 1.2 percent and 12.9 percent and for IRLs by between 3.4 percent and 5.1 percent. Over a 30-year period (2017 to 2046), the proposed changes would save 3.5 quads (quadrillion Btus; in the 1990s, total U.S. consumption of all forms of energy averaged about 83 quads annually).
The environmental benefits of the proposed standards include “significant” reductions in greenhouse gas (GHG) emissions. Industry will lose money under the proposed standards, and the IRL amendments in particular may force manufacturers to close existing U.S. plants.
EPCA requirement
The GSFL and IRL standards are being proposed under the authority of the Energy Policy and Conservation Act of 1975 (EPCA), which established the Energy Conservation Program for Consumer Products Other Than Automobiles. Pursuant to EPCA, any new or amended energy conservation standard the EERE proscribes for certain products must be designed to achieve the maximum improvement in energy efficiency that is technologically feasible and economically justified. Further, the new or amended standards must result in a significant conservation of energy.
Lamp types
The proposed standards are expressed as the minimum lumen output per watt. The GSFL types included in the proposal are 4-foot (ft) medium bipin, 2-ft U-shaped, 8-ft slimline, 8-ft recessed double contact high output, 4-ft miniature bipin standard output, and 4-ft miniature bipin high output. The IRL types covered by the proposal are standard spectrum rated 40 W to 205 W and modified spectrum rated 40 W to 205 W.
Small businesses disadvantaged
The proposal would have a significant impact on manufacturers. The EERE estimates that GSFL manufacturers may lose up to 2.6 of their industry net present value (INPV), or about $39.9 million in 2012$ if the standards are implemented as proposed. No plant closings are anticipated by the EERE for this sector. A far greater impact is predicted for IRL manufacturers, who face the potential of losing as much as 29.5 percent of their INPV, or approximately $51 million in 2012$.
The repercussions are expected to be particularly hard for small businesses.
According to the EERE, most small businesses are not the original manufacturers of GSFLs or IRLs, nor do they own the equipment used to produce GSFLs and IRLs. Therefore, most small businesses will not have any capital conversion costs due to standards. However, since all small businesses have lower sales volumes, their product conversion costs are estimated to be significantly larger on a percentage of revenue basis compared to large manufacturers. Some small businesses may not be able to pass on these higher per-unit product conversion costs since market competition forces them to keep prices low. Therefore, some small businesses might not be able to or might choose not to make the investments necessary to meet the proposed standards, says the EERE.
Environmental benefits
At the environmental end, the EERE anticipates that the proposed GSFL amendments would result in cumulative emissions reductions of 170 million metric tons (Mt) of CO2; 730,000 tons of methane; 250,000 tons of sulfur dioxide (SO2); 210,000 tons of nitrogen oxide (NOx); 2,800 tons of nitrous oxide (N2O); and 0.32 tons of mercury. The IRL revisions would result in cumulative emissions reductions of 0.70 Mt of CO2: 2,700 tons of methane; 690 tons of SO2; 790 tons of NOx; 100 tons of N2O, and 0.001 tons of mercury. Based on the current social cost of carbon used by federal agencies, the anticipated CO2 reductions are valued at between $1.3 and 17 billion.
The EERE is accepting public comments on its proposal until June 30, 2014.
The proposal was published in the April 29, 2014, FR.