Energy Conservation Program: Test Procedures for Integrated Light-Emitting Diode Lamps, 32019-32048 [2014-12127]
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Vol. 79
Tuesday,
No. 106
June 3, 2014
Part II
Department of Energy
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10 CFR Parts 429 and 430
Energy Conservation Program: Test Procedures for Integrated LightEmitting Diode Lamps; Proposed Rule
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Federal Register / Vol. 79, No. 106 / Tuesday, June 3, 2014 / Proposed Rules
DEPARTMENT OF ENERGY
10 CFR Parts 429 and 430
[Docket No. EERE–2011–BT–TP–0071]
RIN 1904–AC67
Energy Conservation Program: Test
Procedures for Integrated LightEmitting Diode Lamps
Office of Energy Efficiency and
Renewable Energy, Department of
Energy.
ACTION: Supplemental notice of
proposed rulemaking.
AGENCY:
On April 9, 2012, the U.S.
Department of Energy (DOE) published
a notice of proposed rulemaking (NOPR)
in which DOE proposed a test procedure
for light-emitting diode (LED) lamps
(hereafter referred to as LED lamps).
This supplemental notice of proposed
rulemaking (SNOPR), revises DOE’s
proposal for a new test procedure for
LED lamps. This SNOPR supports
implementation of labeling provisions
by the Federal Trade Commission (FTC)
and implementation of DOE’s energy
conservation standards for general
service lamps that includes general
service LED lamps. The SNOPR
continues to define methods for
measuring the lumen output, input
power, and relative spectral distribution
(to determine correlated color
temperature, or CCT). Further, the
SNOPR revises the method for
calculating the lifetime of LED lamps,
and defines the lifetime as the time
required for the LED lamp to reach a
lumen maintenance of 70 percent (that
is, 70 percent of initial light output).
Additionally, the SNOPR adds
calculations for lamp efficacy as well as
the color rendering index (CRI) of LED
lamps, which were not proposed in the
test procedure NOPR.
DATES: DOE will accept comments, data,
and information regarding this SNOPR,
but no later than August 4, 2014. See
section V, ‘‘Public Participation,’’ for
details.
ADDRESSES: Any comments submitted
must identify the SNOPR for Test
Procedures for LED lamps, and provide
docket number EE–2011–BT–TP–0071
and/or regulatory information number
(RIN) number 1904–AC67. Comments
may be submitted using any of the
following methods:
1. Federal eRulemaking Portal:
www.regulations.gov. Follow the
instructions for submitting comments.
2. Email: LEDLamps-2011-TP-0071@
ee.doe.gov. Include the docket number
and/or RIN in the subject line of the
message.
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SUMMARY:
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3. Mail: Ms. Brenda Edwards, U.S.
Department of Energy, Building
Technologies Office, Mailstop EE–5B,
1000 Independence Avenue SW.,
Washington, DC, 20585–0121. If
possible, please submit all items on a
CD. It is not necessary to include
printed copies.
4. Hand Delivery/Courier: Ms. Brenda
Edwards, U.S. Department of Energy,
Building Technologies Program, 950
L’Enfant Plaza SW., Suite 600,
Washington, DC, 20024. Telephone:
(202) 586–2945. If possible, please
submit all items on a CD. It is not
necessary to include printed copies.
For detailed instructions on
submitting comments and additional
information on the rulemaking process,
see section V of this document (Public
Participation).
Docket: The docket is available for
review at regulations.gov, including
Federal Register notices, public meeting
attendee lists and transcripts,
comments, and other supporting
documents/materials. All documents in
the docket are listed in the
regulations.gov index. However, not all
documents listed in the index may be
publicly available, such as information
that is exempt from public disclosure.
A link to the docket Web page can be
found at: www1.eere.energy.gov/
buildings/appliance_standards/
rulemaking.aspx/ruleid/18. This Web
page will contain a link to the docket for
this notice on the regulations.gov site.
The regulations.gov Web page contains
simple instructions on how to access all
documents, including public comments,
in the docket. See section V for
information on how to submit
comments through regulations.gov.
For further information on how to
submit a comment, review other public
comments and the docket, or participate
in the public meeting, contact Ms.
Brenda Edwards at (202) 586–2945 or by
email: Brenda.Edwards@ee.doe.gov.
FOR FURTHER INFORMATION CONTACT: Ms.
Lucy deButts, U.S. Department of
Energy, Office of Energy Efficiency and
Renewable Energy, Building
Technologies Office, EE–5B, 1000
Independence Avenue SW.,
Washington, DC, 20585–0121.
Telephone: (202) 287–1604. Email:
light_emitting_diodes@ee.doe.gov.
Ms. Celia Sher, U.S. Department of
Energy, Office of the General Counsel,
GC–71, 1000 Independence Avenue
SW., Washington, DC, 20585–0121.
Telephone: (202) 287–6122. Email:
Celia.Sher@hq.doe.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Authority and Background
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II. Summary of the Supplemental Notice of
Proposed Rulemaking
III. Discussion
A. Scope of Applicability
B. Standby and Off-Mode
C. Proposed Approach for Determining
Lumen Output, Input Power, Lamp
Efficacy, Correlated Color Temperature,
and Color Rendering Index
1. NOPR Proposals
2. Test Conditions
3. Test Setup
4. Test Method
D. Proposed Approach for Lifetime
Measurements
1. LED Lamp Lifetime Definition
2. NOPR Proposals
3. SNOPR Proposed Lifetime Method
E. Proposed Approach for Standby Mode
Power
F. Basic Model, Sampling Plan, and
Reported Value
1. Basic Model
2. Sampling Plan
3. Reported Value
G. Rounding Requirements
1. Lumen Output
2. Input Power
3. Lamp Efficacy
4. Correlated Color Temperature
5. Color Rendering Index
6. Annual Energy Cost
7. Lifetime
8. Life
9. Standby Mode Power
H. Acceptable Methods for Initial
Certification or Labeling
I. Laboratory Accreditation
J. State Preemption for Efficiency Metrics
K. Effective and Compliance Date
IV. Procedural Issues and Regulatory Review
A. Review Under Executive Order 12866
B. Review under the Regulatory Flexibility
Act
1. Estimated Small Business Burden
2. Duplication, Overlap, and Conflict With
Other Rules and Regulations
3. Significant Alternatives to the Proposed
Rule
C. Review Under the Paperwork Reduction
Act of 1995
D. Review Under the National
Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates
Reform Act of 1995
H. Review Under the Treasury and General
Government Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under Treasury and General
Government Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Review Under Section 32 of the Federal
Energy Administration Act of 1974
V. Public Participation
A. Submission of Comments
B. Issues on Which DOE Seeks Comment
VI. Approval of the Office of the Secretary
I. Authority and Background
Title III of the Energy Policy and
Conservation Act of 1975 (42 U.S.C.
6291, et seq.; ‘‘EPCA’’) sets forth a
variety of provisions designed to
improve energy efficiency. (All
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references to EPCA refer to the statute
as amended through the American
Energy Manufacturing Technical
Corrections Act (AEMTCA), Public Law
112–210 (Dec. 18, 2012)). Part B of title
III, which for editorial reasons was
redesignated as Part A upon
incorporation into the U.S. Code (42
U.S.C. 6291–6309, as codified),
establishes the ‘‘Energy Conservation
Program for Consumer Products Other
Than Automobiles.’’
Under EPCA, this program consists of
four parts: (1) testing, (2) labeling, (3)
Federal energy conservation standards,
and (4) certification and enforcement
procedures. This SNOPR proposes test
procedures that manufacturers of
integrated LED lamps (hereafter referred
to as ‘‘LED lamps’’) would use to meet
two requirements, namely, to: (1) satisfy
any future energy conservation
standards for general service LED lamps,
and (2) meet obligations under labeling
requirements for LED lamps
promulgated by the Federal Trade
Commission (FTC).
First, this SNOPR would be used to
assess the performance of LED lamps
relative to any potential energy
conservation standards in a future
rulemaking that includes general service
LED lamps. DOE is currently developing
energy conservation standards for
general service lamps (GSLs), a category
of lamps that includes general service
LED lamps. See 78 FR 73737 (Dec. 9,
2013).
Second, the LED lamp SNOPR
supports obligations under labeling
requirements promulgated by FTC
under section 324(a)(6) of EPCA (42
U.S.C. 6294(a)(6)). The Energy
Independence and Security Act of 2007
(EISA 2007) section 321(b) amended
EPCA (42 U.S.C. 6294(a)(2)(D)) to direct
FTC to consider the effectiveness of
lamp labeling for power levels or watts,
light output or lumens, and lamp
lifetime. This SNOPR supports FTC’s
determination that LED lamps, which
had previously not been labeled, require
labels under EISA section 321(b) and 42
U.S.C. 6294(a)(6) in order to assist
consumers in making purchasing
decisions. 75 FR 41696, 41698 (July 19,
2010).
FTC published a final rule for light
bulb 1 labeling (Lighting Facts) that
required compliance on January 1, 2012.
75 FR 41696 (July 19, 2010). The FTC
Lighting Facts label covers three types
of medium screw base lamps: general
service incandescent lamps (GSIL),
compact fluorescent lamps (CFL), and
1 FTC uses the term ‘bulb,’ while DOE uses the
term ‘lamp.’ Bulb and lamp refer to the same
product.
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general service LED lamps.2 The label
requires manufacturers to disclose
information about the lamp’s
brightness 3 (lumen output), estimated
annual energy cost, life 4 (lifetime), light
appearance (CCT), and energy use
(input power). FTC requires
manufacturers to calculate the estimated
annual energy cost by multiplying
together the energy used, annual
operating hours, and an estimate for
energy cost per kilowatt-hour. FTC
references DOE test procedures, when
available, for testing lamps for the FTC
Lighting Facts label. See 42 U.S.C.
6294(c). This SNOPR would enable FTC
to reference a DOE test procedure for
LED lamps. DOE invites comments on
all aspects of the SNOPR for LED lamps.
II. Summary of the Supplemental
Notice of Proposed Rulemaking
In this SNOPR, DOE proposes test
procedures for determining the lumen
output, input power, lamp efficacy,
CCT, CRI, lifetime, and standby mode
power of an LED lamp. DOE proposes to
define an LED lamp using the ANSI 5/
IESNA 6 RP–16–2010 7 definition of an
integrated LED lamp. DOE pursued an
SNOPR for two main reasons: (1) to
revise the method of measuring lifetime
based on public comment and (2) to add
directions for calculating the metrics
lamp efficacy and CRI and standby
mode power to support the ongoing
general service lamp rulemaking. To
determine lumen output, input power,
CCT, and CRI, DOE proposes to
incorporate by reference IES LM–79–
2008.8 DOE reviewed several potential
approaches to testing lamp lumen
output, input power, CCT, and CRI, and
determined that this IES standard is the
most appropriate based on discussions
with industry experts. IES LM–79–2008
2 FTC defines general service LED lamps as a
lamp that is a consumer product; has a medium
screw base; has a lumen range not less than 310
lumens and not more than 2,600 lumens; and is
capable of being operated at a voltage range at least
partially within 110 and 130 volts. This proposed
test procedure rulemaking could be applied to
general service LED lamps as defined by FTC as
well as all other integrated LED lamps as discussed
in section 0 of this SNOPR.
3 Although ‘light output’ is the technically correct
term, FTC uses the term ‘brightness’ on the Lighting
Facts label because FTC’s research indicated that
consumers prefer the term ‘brightness’ to ‘light
output.’
4 FTC uses the term ‘life’ while DOE uses the term
‘lifetime.’ Life and lifetime have the same meaning.
5 American National Standards Institute.
6 Illuminating Engineering Society of North
America (also abbreviated as IES).
7 ‘‘Nomenclature and Definitions for Illuminating
Engineering.’’ Approved by ANSI on October 16,
2009. Approved by IES on November 15, 2009.
8 ‘‘Approved Method: Electrical and Photometric
Measurements of Solid-State Lighting Products.’’
Approved by IES on December 31, 2007.
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appears to yield reliable results, and
industry generally uses it to measure
photometric characteristics of LED
lamps. To determine the standby mode
power, DOE proposes to incorporate by
reference International Electrotechnical
Commission (IEC) 62301.9 In addition,
DOE proposes to calculate the efficacy
of an LED lamp in units of lumens per
watt by dividing the measured initial
lamp lumen output in lumens by the
measured lamp input power in watts.
Lastly, no industry standards are
available for determining the lifetime of
LED lamps. Therefore, the SNOPR
proposes a method for measuring and
projecting LED lamp lifetime that uses
a continuous equation based on the
underlying exponential decay function
in the ENERGY STAR Program
Requirements for Lamps (Light Bulbs):
Eligibility Criteria—Version 1.0.10
III. Discussion
A. Scope of Applicability
EISA 2007 section 321(a)(1)(B) added
the definition for LED as a p-n
junction 11 solid state device, the
radiated output of which, either in the
infrared region, the visible region, or the
ultraviolet region, is a function of the
physical construction, material used,
and exciting current 12 of the device. (42
U.S.C. 6291(30)(CC)) In the NOPR,
published on April 9, 2012, DOE stated
that this rulemaking applies to LED
lamps that meet DOE’s proposed
definition of an LED lamp, which is
based on the term as defined by ANSI/
IESNA RP–16–2010, ‘‘Nomenclature
and Definitions for Illuminating
Engineering.’’ This standard defines
integrated LED lamps as an integrated
assembly that comprises LED packages
(components) or LED arrays (modules)
(collectively referred to as an LED
source), LED driver, ANSI standard
base, and other optical, thermal,
mechanical and electrical components
(such as phosphor layers, insulating
materials, fasteners to hold components
within the lamp together, and electrical
wiring). The LED lamp is intended to
connect directly to a branch circuit
through a corresponding ANSI standard
9 ‘‘Household electrical appliances—
Measurement of standby power.’’ Edition 2.0 2011–
01.
10 ‘‘ENERGY STAR Program Requirements for
Lamps (Light Bulbs): Eligibility Criteria—Version
1.0.’’ U.S. Environmental Protection Agency,
August 28, 2013.
11 P-n junction is the boundary between p-type
and n-type material in a semiconductor device,
such as LEDs. P-n junctions are active sites where
current can flow readily in one direction but not in
the other direction—in other words, a diode.
12 Exciting current is the current passing through
an LED chip during steady state operation.
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socket. 77 FR 21038, 21041 (April 9,
2012)
The National Electrical Manufacturers
Association (hereafter referred to as
NEMA) agreed with the proposed scope
and incorporation of ANSI/IESNA RP–
16–2010 for the definition of LED
lamps. (NEMA, Public Meeting
Transcript, No. 7 at p. 2 13) DOE
received no adverse comment on this
proposal. Thus, in this SNOPR, DOE
proposes to maintain the scope and
definition of LED lamps.
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B. Standby and Off-Mode
EPCA directs DOE to amend test
procedures ‘‘to include standby mode
and off mode energy consumption . . .
with such energy consumption
integrated into the overall energy
efficiency, energy consumption, or other
energy descriptor for each covered
product, unless the Secretary
determines that—(i) the current test
procedures for a covered product
already fully account for and
incorporate the standby and off mode
energy consumption of the covered
product . . .’’ 42 U.S.C. 6295(gg)(2)(A(i)
Because LED lamps are placed in Part A
of EPCA, they are covered consumer
products, and thus the standby and off
mode applicability of these products
must be reviewed.
First, to provide context for standby
and off-modes, active mode is defined
as the condition in which an energyusing product—is connected to a main
power source; has been activated; and
provides one or more main functions.10
CFR 430.2 DOE’s proposals for active
mode test metrics include lumen
output, input power, lamp efficacy,
CCT, CRI, and lifetime.
Standby mode is defined as the
condition in which energy-using
product—is connected to a main power
source; and offers one or more of the
following user-oriented or protective
functions: to facilitate the activation or
deactivation of other functions
(including active mode) by remote
switch (including remote control),
internal sensor, or timer; or continuous
functions, including information or
status displays (including clocks) or
sensor-based functions.10 CFR 430.2
Some LED lamps can be operated by a
remote control to activate active mode
or to change the appearance of the light
13 A notation in the form ‘‘NEMA, Public Meeting
Transcript, No. 7 at p. 2’’ identifies a statement
made in a public meeting that DOE has received
and has included in the docket of this rulemaking.
This particular notation refers to a comment: (1)
submitted during the public meeting on May 3,
2012; (2) in document number 7 in the docket of
this rulemaking; and (3) appearing on page 2 of the
transcript.
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(color or dimming). Therefore, standby
mode applies to LED lamps.
Off mode is defined as the condition
in which an energy using product—is
connected to a main power source; and
is not providing any standby or active
mode function.10 CFR 430.2 LED lamps
do not operate in off mode because
when connected to a main power
source, the LED lamp is either in active
mode or standby mode. No other modes
of operation exist for LED lamps beyond
active and standby mode.
EPCA directs DOE to amend its test
procedures for all covered products to
integrate measures of standby mode and
off mode energy consumption, if
technically feasible. (42 U.S.C.
6295(gg)(2)(A)) Standby mode and off
mode energy must be incorporated into
the overall energy efficiency, energy
consumption, or other energy descriptor
for each covered product unless the
current test procedures already account
for and incorporate standby and off
mode energy consumption or such
integration is technically infeasible. If
an integrated test procedure is
technically infeasible, DOE must
prescribe a separate standby mode and
off mode energy use test procedure for
the covered product, if technically
feasible. Id. Any such amendment must
consider the most current versions of
IEC Standard 62301, ‘‘Household
electrical appliances—measurement of
standby power,’’ and IEC Standard
62087, ‘‘Methods of measurements for
the power consumption of audio, video,
and related equipment,’’ 14 as
applicable.
DOE proposes separate test methods
for standby and active mode metrics.
This proposal is consistent with other
lighting products (fluorescent lamp
ballasts and metal halide ballasts) which
use separate test methods for active and
standby modes. Any future energy
conservation standards that cover LED
lamps will consider the most effective
method of addressing both active and
standby mode energy use. DOE proposes
a method of measuring standby mode
power in section III.E.
DOE requests comment on its
characterization of the modes of
operation that apply to LED lamps.
C. Proposed Approach for Determining
Lumen Output, Input Power, Lamp
Efficacy, Correlated Color Temperature,
and Color Rendering Index
1. NOPR Proposals
The NOPR proposed to incorporate
IES LM–79–2008 for determining lumen
output, input power, and CCT, with
14 IEC standards are available online at
www.iec.ch.
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some modifications. 77 FR at 21041
(April 9, 2012) IES LM–79–2008
specifies the test setup and conditions at
which the measurements and
calculations must be performed. These
include ambient conditions, power
supply characteristics, lamp orientation,
and stabilization methods for LED
lamps, and instrumentation and
electrical settings. These requirements,
and any related comments, are further
discussed in the sections III.C.1 through
III.C.4.
Kristopher Kritzer (hereafter referred
to as Kritzer) expressed support for
adopting the complete NOPR test
method and backed DOE’s efforts to
adopt industry practices for testing LED
lamps. (Kritzer, No. 3 at p. 1) Lutron
Electronics Company, Inc. (hereafter
referred to as Lutron) and NEMA did
not support all test methods proposed in
the NOPR, but did agree that IES LM–
79–2008 should be used to determine
lumen output, input power, and CCT.
(Lutron, Public Meeting Transcript, No.
7 at p. 25; NEMA, Public Meeting
Transcript, No. 7 at p. 2) However,
several interested parties expressed
concern with the overall proposal. Delft
University of Technology (which refers
to itself as TUD) and an anonymous
commenter had reservations about
adopting the test methods proposed in
the NOPR. TUD indicated that the
NOPR proposal will not guarantee
tested LED products are well-qualified.
(Anonymous, No. 8 at p. 1; TUD, No. 15
at p. 1) NEMA, the California Investor
Owned Utilities (hereafter referred to as
CA IOUs), and Philips Lighting
Electronics N.A. (hereafter referred to as
Philips) urged that DOE not modify or
supplement any industry standard.
(NEMA, No. 16 at p. 2, 7; CA IOUs, No.
19 at p. 5, 6; Philips, Public Meeting
Transcript, No. 7 at p. 114) Finally, the
Appliance Standards Awareness Project,
the American Council for an Energy
Efficient Economy, and the Natural
Resources Defense Council (hereafter
referred to as the Joint Comment) stated
that test procedures need to mimic real
world installations whenever possible
and, when knowledge of real world
installations is not available, the test
method needs to approximate a worstcase installation scenario. (Joint
Comment, No. 18 at p. 1)
IES is the recognized technical
authority on illumination, and the IES
LM–79–2008 standard was prepared by
the IES subcommittee on Solid-State
Lighting Sources of the IESNA Testing
Procedure Committee. IES LM–79–2008
was also developed in collaboration
with the ANSI Solid State Lighting Joint
Working Group C78–09 and C82–09
comprising individuals from several
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organizations. DOE believes that the
committee members who worked on
developing the IES LM–79–2008
standard represent relevant industry
groups and interested parties. Based on
an independent review by DOE and
general acceptance by industry, DOE
proposes that IES LM–79–2008 specifies
much of the information that is required
for providing a complete test procedure
for determining lumen output, input
power, CCT, and CRI of LED lamps.
DOE agrees that the LED lamp test
procedure needs to mimic real world
installations and believes that the
procedures described in the IES LM–79–
2008 standard are representative of such
conditions. IES LM–79–2008 specifies
the test conditions and setup at which
the measurements and calculations
must be performed. However, DOE
proposes some clarifications to establish
a repeatable procedure for all LED lamp
testing. These clarifications to IES LM–
79–2008 include mounting orientation
and electrical setting requirements.
These requirements, and any
clarifications proposed by DOE, are
further discussed in the sections III.C.2
through III.C.4.
2. Test Conditions
In the NOPR, DOE proposed that the
ambient conditions for testing LED
lamps be as specified in section 2.0 15 of
IES LM–79–2008. 77 FR at 21041. These
conditions include setup and ambient
temperature control, as well as air
movement requirements. Both are
discussed in further detail below.
Section 2.2 of IES LM–79–2008
specifies that photometric
measurements shall be taken at an
ambient temperature of 25 degrees
Celsius (°C) ±1 °C. In the NOPR, DOE
indicated that a tolerance of 1°C for the
ambient temperature is practical, limits
the impact of ambient temperature on
measurements, and would not be
burdensome because the instruments
used to measure the temperature
provide greater accuracy than required,
allowing the test laboratories to
maintain the temperature within the
required tolerance for testing. Id.
Section 2.2 of IES LM–79–2008 further
specifies that the temperature shall be
measured at a point not more than one
meter from the LED lamp and at the
same height as the lamp. The standard
requires that the temperature sensor that
is used for measurements be shielded
from direct optical radiation from the
lamp or any other source to reduce the
15 IES standards use the reference 2.0, 3.0, etc. for
each primary section heading. Sub-sections under
each of these sections are referenced as 2.1, 2.2, 3.1,
3.2, etc. This SNOPR refers to each IES section
exactly as it is referenced in the standard.
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impact of radiated heat on the ambient
temperature measurement. The NOPR
stated that this setup for measuring and
controlling ambient temperature is
appropriate for testing because it
requires that the lamp be tested at room
temperature and in an environment that
is commonly used for testing other
lighting technologies. Id. DOE did not
receive adverse comments, and
therefore maintains this proposal for
ambient temperature conditions in the
SNOPR.
In the NOPR, DOE proposed that the
requirement for air movement around
the LED lamp be as specified in section
2.4 of IES LM–79–2008, which requires
that the air flow around the LED lamp
be such that it does not affect the lumen
output measurements of the tested
lamp. Id. DOE also considered
specifying a method for determination
of a draft-free environment, such as that
in section 4.3 of IES LM–9–2009,16
which requires that a single ply tissue
paper be held in place of the lamp to
allow for visual observation of any
drafts.
Philips, Osram Sylvania, Inc.
(hereafter referred to as OSI), and NEMA
all indicated that the surrounding air
temperature and airflow for LED lamps
does not have a noticeable impact on
long-term lumen degradation. Based on
this, DOE believes that the IES LM–79–
2008 air movement requirements
proposed in the NOPR are more than
adequate to ensure the accuracy of test
data. (Philips, Public Meeting
Transcript, No. 7 at p. 27; OSI, Public
Meeting Transcript, No. 7 at pp. 27–28;
NEMA, Public Meeting Transcript, No.
7 at pp. 2–3; NEMA, No. 16 at p. 2–3)
However, other stakeholders suggested
adding quantitative requirements for air
movement. The People’s Republic of
China (hereafter referred to as P.R.
China) suggested that air movement in
the vicinity of the luminaire not exceed
0.2 m/s. For lamps designed with a
larger tolerance for ambient temperature
changes, faster air movement may be
acceptable. (P.R. China, No. 12 at p. 3)
The Joint Comment noted that the air
movement procedures in IES LM–79–
2008 are informative, but not very
specific. Therefore, they recommended
that DOE investigate a quantitative
approach so that air flow around the
device is better understood. However,
the Joint Comment expressed concern
that direct measurement of the airflow
(anemometry) would increase the
testing burden to manufacturers
substantially; instead, they
16 ‘‘IES Approved Method for the Electrical and
Photometric Measurement of Fluorescent Lamps.’’
Approved January 31, 2009.
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recommended DOE investigate a
suitable proxy measure to judge the
stability of the airflow around the lamp.
As an example, they suggested DOE may
want to consider stability criteria on a
measurement of the case temperature.
The Joint Comment noted that it is
likely that other parameters may also
provide valuable information about the
airflow while minimizing testing
burden. (Joint Comment, No. 18 at p. 3)
Although DOE agrees that the air
movement requirement in IES LM–79–
2008 could be more precise, DOE is
maintaining its proposal from the NOPR
not to modify the surrounding air
temperature and airflow specifications
provided in IES LM–79–2008. DOE does
not believe that additional requirements
to establish a draft-free environment
would improve measurement accuracy
relative to current industry practice.
Furthermore, specifying a quantitative
procedure for measuring air movement
would result in an unnecessary increase
to testing burden. Therefore, in this
SNOPR, DOE maintains its proposal to
retain the requirements in IES LM–79–
2008 to ensure that air movement is
minimized to acceptable levels. These
requirements would apply to lamps
measured in both active mode and
standby mode.
3. Test Setup
a. Power Supply
In the NOPR, DOE proposed that
section 3.1 and 3.2 of IES LM–79–2008
be incorporated by reference to specify
requirements for both alternating
current (AC) and direct current (DC)
power supplies. 77 FR at 21042. Section
3.1 specifies that an AC power supply
shall have a sinusoidal voltage
waveshape at the input frequency
required by an LED lamp such that the
root mean square (RMS) 17 summation
of the harmonic components does not
exceed three percent of the fundamental
frequency 18 while operating the LED
lamp. Section 3.2 of IES LM–79–2008
also requires that the voltage of an AC
power supply (RMS voltage) or DC
power supply (instantaneous voltage)
applied to the LED lamp be within ±0.2
percent of the specified lamp input
voltage (see section III.C.3.d for
discussion of the proposed electrical
settings, including input voltage). These
requirements are achievable with
17 Root mean square (RMS) voltage/current is a
statistical measure of the magnitude of a voltage/
current signal. RMS voltage/current is equal to the
square root of the mean of all squared instantaneous
voltages/currents over one complete cycle of the
voltage/current signal.
18 Fundamental frequency, often referred to as
fundamental, is defined as the lowest frequency of
a periodic waveform.
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minimal testing burden and provide
reasonable stringency in terms of power
quality based on their similarity to
voltage tolerance requirements for
testing of other lighting technologies.
DOE did not receive adverse comment
on this proposal and, therefore, this
proposal remains unchanged for the
SNOPR. These power supply
requirements would apply to lamps
measured in both active mode and
standby mode.
b. Instrumentation
In the NOPR, DOE proposed that
instrumentation requirements for the
AC power meter and the AC and DC
voltmeter and ammeter, as well as the
acceptable tolerance for these
instruments, be as specified in section
8.0 of IES LM–79–2008. Id. Section 8.1
of IES LM–79–2008 specifies that for
DC-input LED lamps, a DC voltmeter
and DC ammeter shall be connected
between the DC power supply and the
LED lamp under test. The DC voltmeter
shall be connected across the electrical
power input of the LED lamp, and the
input electrical power shall be
calculated as the product of the
measured input voltage and current.
Section 8.2 of IES LM–79–2008 specifies
that the tolerance for the DC voltage and
current measurement instruments shall
be ±0.1 percent. For AC-input LED
lamps, section 8.1 of IES LM–79–2008
further specifies that an AC power meter
shall be connected between the AC
power supply and the LED lamp under
test. The AC power, input voltage, and
current shall be measured. Section 8.2
of IES LM–79–2008 specifies that the
tolerance of the AC voltage and current
measurement instruments shall be ±0.2
percent and the tolerance of the AC
power meter shall be ±0.5 percent. In
the NOPR, DOE concluded that the
electrical instrumentation requirements
set forth in section 8.0 of IES LM–79–
2008 are achievable and provide
reasonable stringency in terms of
measurement tolerance based on their
similarity to instrument tolerance
requirements for testing of other lighting
technologies. Id. DOE did not receive
adverse comment on these electrical
instrumentation requirements and,
therefore, this proposal remains
unchanged for the SNOPR.
Regarding photometric
instrumentation used for measuring
lumen output, CCT, and CRI, DOE
proposed in the NOPR that either a
sphere-spectroradiometer, spherephotometer, or goniophotometer system
be used for lumen output measurement
of the LED lamp as specified in IES LM–
79–2008. DOE requested comment on
the differences in values measured by
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an integrating sphere (via photometer or
spectroradiometer) versus a
goniophotometer. 77 FR at 21042 NEMA
commented that both systems are
appropriate for lumen determination,
but acknowledged that a perfect
correlation between the two techniques
is not possible. (NEMA, No. 16 at p. 3)
While DOE recognizes that the
integrating sphere and goniophotometer
(a goniometer fitted with a photometer
as the light detector) are both valid
means of photometric measurement,
DOE is concerned about the potential
for a difference in the measured values.
A test procedure that yields more than
one possible value depending on
instrumentation presents problems for
certification and enforcement. If DOE
and the manufacturer use different test
methods, DOE could find that a lamp
certified as compliant could be tested as
non-compliant during a verification or
enforcement proceeding. IES LM–79–
2008 does not explicitly specify the
scanning resolution (i.e., quantity and
location of measurements around the
lamp), and instead provides guidance
that must be implemented differently
for each lamp. DOE also determined that
further specification of the
goniophotometer method is
unreasonable, because the scanning
resolution specification would need to
be adequate for the lamp that requires
the finest resolution. This would likely
present an overly burdensome test
method for many other lamps that could
be measured at a lower resolution. In
contrast, use of an integrating sphere
enables photometric characteristics of
the LED lamp to be determined with a
single measurement. Therefore,
integrating spheres are the preferred
method for photometric measurement
due to the reduction in time required for
testing.
In consideration of the lack of
measurement correlation between
integrating spheres and
goniophotometers and the reduced
burden and much higher incidence of
use of integrating spheres, DOE
proposes in the SNOPR to require all
photometric measurements, including
lumen output, CCT, and CRI to be
carried out in an integrating sphere and
that goniometer systems must not be
used. Therefore, DOE proposes that the
instrumentation used for lumen output
measurements be as described in
sections 9.1 and 9.2 of IES LM–79–2008,
and CCT and CRI measurements be as
described in section 12.0 of IES LM–79–
2008 with the exclusion of section 12.2
of IES LM–79–2008, as goniometers
must not be used. DOE invites
interested parties to comment on the
proposal to require all photometric
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values be measured by an integrating
sphere (via photometer or
spectroradiometer). These
instrumentation requirements would
apply to lamps measured in both active
mode and standby mode.
c. Lamp Mounting and Orientation
In the NOPR, DOE considered testing
LED lamps as specified in section 6.0 of
IES LM–79–2008, which states that LED
lamps shall be tested in the operating
orientation recommended by the lamp
manufacturer for the intended use of the
LED lamp. Id. As discussed in the
NOPR, DOE determined that
manufacturers do not typically specify
the operating orientation for an LED
lamp in their product literature. Further,
DOE indicated that it is possible
manufacturers would recommend an
orientation for testing that provides the
highest lumen output rather than the
orientation in which the lamp is most
frequently operated in practice.
Therefore, the NOPR proposed that an
LED lamp be mounted as specified in
section 2.3 of IES LM–79–2008 and be
positioned in the base-up, base-down,
and horizontal orientations for testing.
Numerous commenters raised
concerns about DOE’s proposal. General
Electric Lighting (hereafter referred to as
GE), Philips, NEMA, Samsung
Electronics (hereafter referred to as
Samsung), and P.R. China commented
that the base-up and base-down
orientations constitute the best and
worst-case scenarios. (GE, Public
Meeting Transcript, No. 7 at p. 29;
Philips, Public Meeting Transcript, No.
7 at pp. 29–30; NEMA, No. 16 at p. 3;
Samsung, No. 14 at p. 1; China, No. 12
at p. 3) Samsung stated that testing in
the base up and base down positions is
also consistent with ENERGY STAR test
procedures. (Samsung, No. 14 at p. 1) In
addition, GE and NEMA commented
that testing in the horizontal position
with either type of sphere will add
uncertainty to the lumen output
measurement, and that testing in the
horizontal position with a
goniophotometer is very difficult or
even impossible. (GE, Public Meeting
Transcript, No. 7 at pp. 42–43; NEMA,
No. 16 at p. 3) Underwriter Laboratories
(hereafter referred to as UL) indicated
that shadowing is an issue with testing
in the horizontal position. Lamps are
usually supported from above or below,
and if tested horizontally the support
structure could interfere with the light
measurement. (UL, Public Meeting
Transcript, No. 7 at p. 54) NEMA
commented that current FTC instruction
for CFLs does not require testing in
multiple orientations, only that the
manufacturer specify if an orientation
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change will result in a greater than five
percent difference in measured
performance. (NEMA, No. 16 at p. 6)
The Republic of Korea (hereafter
referred to as South Korea) suggested
that DOE be consistent with both
International Electrotechnical
Commission (IEC) 62612 19 and IES LM–
79–2008, which require that the
orientation of lamps during testing
follow the manufacturer’s
recommendations. (South Korea, No. 17
at p. 2) Finally, P.R. China noted that
testing in the horizontal position will
increase the cost of the testing as well
as the total time required for testing.
(P.R. China, No. 12 at p. 3)
Other commenters supported DOE’s
proposals and suggested further
research. The Joint Comment and the
CA IOUs agreed with DOE’s proposal to
include the horizontal position for
lumen output testing because it is likely
a worst-case condition. This is because
heat sink fins are most effective at
dissipating heat when air flow is
parallel to the direction of the fins,
rather than when air flow is
perpendicular to the fins. Because most
heat sink fins are parallel to the body of
the lamp, they are likely to dissipate
heat differently when the lamp is
oriented vertically than when oriented
horizontally. When heat is not
dissipated effectively in a lamp, lumen
output generally decreases. (Joint
Comment, No. 18 at p. 4; CA IOUs, No.
19 at p. 6) In addition, the CA IOUs
indicated that they expect to have LED
lamp performance data collected in all
three orientations by the end of 2012
(subsequently published in February
2013).20 The CA IOUs further
commented that manufacturer concerns
about testing in the horizontal position
are not an issue for testing in a spherespectroradiometer or spherephotometer. The CA IOUs stated that
accurate horizontal measurements are
regularly taken for other lamp
technologies, and they do not believe
any unique challenge exists for
measuring LED lamps that do not exist
for other lamps of similar shapes and
base types. (CA IOUs, No. 19 at p. 6)
The Joint Comment suggested that DOE
investigate whether shadowing is a
significant concern in a
goniophotometer when the lamp is
19 IEC/PAS 62612: Self-ballasted LED-lamps for
general lighting services—Performance
requirements.
20 CLTC, ‘‘Omni-Directional Lamp Testing’’
Prepared for PG&E and CLASP, February 25th,
2013. https://www.energy.ca.gov/appliances/
2013rulemaking/documents/responses/Lighting_12AAER-2B/California_IOUs_Response_to_the_
Invitation_to_Participate_for_LED_Lamps_
REFERENCE/PGandE_2013a_Omni-Directional_
Lamp_Testing-Report_Draft.pdf.
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configured horizontally. (Joint
Comment, No. 18 at p. 4) The Joint
Comment also suggested that DOE
consider the appropriateness of testing
at intermediate angles for certain types
of lamps that contain heat pipes, noting
that heat pipes often have the best heat
transfer performance at inclinations of
60–70 degrees. (Joint Comment, No. 18
at p. 4)
In light of commenters’ varying
opinions about the impact of lamp
orientation on lamp performance, DOE
collected test data for several LED lamps
tested in each of the three orientations.
DOE investigated two sets of
photometric test data, the first provided
by ENERGY STAR and the second
(mentioned by the CA IOUs in the
previous paragraph) from a collaborative
testing effort between the Pacific Gas
and Electric Company (hereafter
referred to as PG&E), California Lighting
Technology Center (hereafter referred to
as CLTC), and the Collaborative
Labeling and Appliance Standards
Program (hereafter referred to as
CLASP). Id. These test data represent 10
samples each of 47 different LED lamp
products. Of the 47 lamp products
tested, 36 were mounted in base-up,
base-down, and horizontal
configurations, and 11 were mounted in
base-up and base-down configurations.
DOE analyzed the data to determine the
variation of input power, lumen output,
CCT, and CRI in each of the three
orientations. The analysis of the test
data revealed that some lamp models
exhibited variation between the three
orientations. Of the three orientations,
analysis indicated that the base-up and
base-down orientations represent the
best (highest lumen output) and worst
(lowest lumen output) case scenarios.
Therefore, DOE believes that there is no
need to test horizontally.
The Joint Comment stated that other
lamp orientations may represent the
best-case scenario and suggested that
DOE investigate testing at intermediate
angles, such as 60 to 70 degrees. DOE
notes that intermediate angles could
represent a best-case scenario for some
lamps; however, testing LED lamps at
these angles is not common industry
practice. Although there is no data
available for testing LED lamps at
intermediate angles, DOE consulted an
LED lamp manufacturer as to whether
intermediate angle testing could be a
best-case scenario for some LED lamps.
The manufacturer indicated that this
could improve efficiency theoretically;
however, this possible improvement
would be negligible and likely within
the measurement error of the lumen
output measuring equipment. From this,
DOE has determined that these
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performance gains would not be
measureable. Therefore, DOE is not
proposing testing of LED lamps at
intermediate angles.
As mentioned above, DOE also
received comments about whether it
was possible to test LED lamps in all
potential orientations. GE, NEMA, and
UL indicated that testing in the
horizontal position could interfere with
the lumen output measurement. (GE,
Public Meeting Transcript, No. 7 at pp.
42–43; NEMA, No. 16 at p. 3; UL, Public
Meeting Transcript, No. 7 at p. 54) DOE
researched this concern by consulting
with the Lighting Research Center
(LRC), which has extensive lamp testing
experience, and believes that testing
lumen output in the horizontal position
does not lead to significant
measurement error when using the
majority of sphere-spectroradiometer,
sphere-photometer, and
goniophotometer systems. For either a
sphere-spectroradiometer or spherephotometer system, the bracket, which
secures the lamp in place, can be
designed and configured to eliminate
any significant measurement error due
to shadowing. For large
goniophotometer systems, there would
be sufficient space to make a bracket to
hold the lamp in any orientation
without risk of significant shadowing. It
is possible that smaller goniophotometer
systems could have mounting and
bracket limitations that result in error
when testing in the horizontal
orientation due to shadowing. However,
as discussed in section III.C.3.b, DOE
proposes in the SNOPR to require all
photometric measurements to be carried
out in an integrating sphere and that
goniometer systems must not be used.
In the SNOPR, DOE proposes that
LED lamps be positioned such that an
equal number of units are oriented in
the base-up and base-down orientations.
This proposal specifies two commonly
used orientations for LED lamps that
span the highest and lowest light-output
scenarios, creating a dataset that
represents average performance in
practice. These lamp mounting and
orientation requirements would apply to
lamps measured in both active mode
and standby mode. DOE requests
comment on the proposal for an equal
number of lamps to be operated in the
base-up and base-down orientations
during lumen output, input power, CCT,
and CRI testing.
d. Electrical Settings
In the NOPR, DOE proposed requiring
testing of LED lamps at the rated voltage
as specified in IES LM–79–2008. For
lamps with multiple operating voltages,
DOE proposed that lamps be tested at
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120 volts because 120 volts is the most
common operating voltage of available
lamps. However, if the lamp is not rated
at 120 volts, DOE proposed that it be
tested at the highest rated voltage. Id.
NEMA disagreed with DOE’s proposal
to test at rated voltage only, arguing the
proposal was in conflict with FTC
regulations that require testing lamps at
120 volts and the rated voltage. (NEMA,
No. 16 at p. 3)
In this SNOPR, DOE maintains the
NOPR proposal but, in addition,
indicates that manufacturers may also
test at other operating voltages as long
as the final DOE test procedure is used
for making energy representations.
These electrical settings would apply to
lamps measured in both active mode
and standby mode. To ensure the
SNOPR proposal is not in conflict with
the FTC Lighting Facts label
requirements, as was suggested by
NEMA, DOE reviewed the FTC
regulations detailed in 16 CFR 305.15.
The FTC regulation states that a general
service lamp shall be measured at 120
volts, regardless of the lamp’s design or
rated voltage. If a lamp’s design voltage
is 125 volts or 130 volts, the disclosures
of the wattage, light output, energy cost,
and lifetime must disclose the voltage at
which these metrics were measured.
DOE’s proposal is not in conflict with
FTC’s Lighting Facts requirements
because manufacturers must test at 120
volts as required by FTC and, if the LED
lamp is rated for additional voltages, the
lamp may also be tested at the highest
rated voltage. This supports FTC’s
program and does not provide
conflicting instructions.
In the NOPR, DOE proposed
incorporating section 7.0 of IES LM–79–
2008, which specifies electrical settings
for LED lamps with multiple modes of
operation, such as variable CCT and
dimmable lamps. 77 FR at 21043.
Section 7.0 of IES LM–79–2008
indicates LED lamps with variable CCT
shall be tested in each mode of
operation, and for dimmable lamps,
directs that they be tested at the
maximum input power.
Philips commented that when
specifying electrical settings for variable
CCT lamps it is important that DOE
consider the scenario that the testing is
intended to reflect (i.e., worst-case
versus most common operating
conditions) because lumen output can
change based on the CCT mode.
(Philips, Public Meeting Transcript, No.
7 at p. 32) OSI agreed with this point
and indicated that in the future it is
foreseeable that LED lamps with
variable CCT, CRI, and lumen output
will be available. (OSI, Public Meeting
Transcript, No. 7 at pp. 32–33) Both P.R.
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China and Samsung stated that LED
lamps with multiple modes of operation
are currently available. (P.R. China, No.
12 at p. 4; Samsung, No. 14 at p. 1) GE
and Samsung indicated that multiple
mode lamps in the future could operate
at continuously variable CCT making
testing at a distinct CCT impossible.
(GE, Public Meeting Transcript, No. 7 at
p. 32; Samsung, No. 14 at p. 1) OSI
commented that testing at the worstcase scenario could be a possible option
for LED lamps with variable CCT, while
Samsung suggested requiring both a
best- and worst-case scenario. (OSI,
Public Meeting Transcript, No. 7 at pp.
33; Samsung, No. 14 at p. 1) P.R. China
suggested DOE follow international
standard IEC/PAS 62717–2011,21 which
states that LED modules with adjustable
color point must be adjusted/set to one
fixed value as indicated by the
manufacturer or responsible vendor.
(P.R. China, No. 12 at p. 3) At the May
3, 2012 NOPR public meeting (hereafter
the May 2012 public meeting), NEMA
argued against testing at a CCT, CRI, or
lumen output setting that would rarely
be used in the field. For lamps that can
vary CCT over the power range, NEMA
suggested testing the lamps only at the
CCT that occurs at full power. (NEMA,
Public Meeting Transcript, No. 7 at p.
33; NEMA, No. 16 at p. 3) Finally,
regarding dimming, NEMA agreed with
DOE’s proposal to measure dimmable
lamps at full power as this will reflect
the rating on the packaging. (NEMA, No.
16 at p. 3)
DOE believes that LED lamps with
multiple modes of operation, including
variable CCT and CRI as well as
dimmable lamps, should be tested at
maximum input power because this is
the highest energy consuming state.
Therefore, DOE proposes to require
testing for such lamps at the mode that
occurs at maximum input power, since
this is the highest energy consuming
state. When multiple modes (such as
multiple CCTs and CRIs) occur at the
same maximum input power, the
manufacturer can select any of these
modes for testing. Manufacturers may
also test at other modes as long as the
final DOE test procedure is used for
making representations about the energy
consumption of an LED lamp. All
measurements (lumen output, input
power, efficacy, CCT, CRI, lifetime, and
standby mode power) must be
conducted at the same mode of
operation. DOE invites comment on its
proposals for testing lamps for which
multiple modes (such as multiple CCTs
21 IEC/PAS 62717: LED modules for general
lighting—Performance requirements.
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and CRIs) can occur at the same
maximum input power.
4. Test Method
a. Lamp Seasoning
In the NOPR, DOE proposed requiring
energizing and operating LED lamps for
1,000 hours to season them before
beginning photometric measurements.
77 FR at 21043. DOE proposed a 1,000
hour seasoning time because it has been
indicated by industry 22 23 that light
output of an LED source (and therefore,
potentially the lamp) can change during
the first 1,000 hours of operation. DOE
also noted that IES TM–21–2011 24
specifies that the data obtained from the
first 1,000 hours of operating an LED
source shall not be used to project the
lifetime of an LED source.
Cree, Philips, Feit Electric Company,
NEMA, P.R. China, the Joint Comment,
CA IOUs, Northwest Energy Efficiency
Alliance (hereafter referred to as NEEA),
and South Korea all commented that
LED lamps not be seasoned for 1,000
hours prior to collecting lumen output
data. They argued that due to the
evolving nature of these products, there
is no common seasoning time. (Cree,
Public Meeting Transcript, No. 7 at pp.
34–35; Philips, Public Meeting
Transcript, No. 7 at p. 35, 36; Feit,
Public Meeting Transcript, No. 7 at p.
45; NEMA, Public Meeting Transcript,
No. 7 at p. 36; P.R. China, No. 12 at p.
4; NEMA, No. 16 at p. 3; Joint Comment,
No. 18 at pp. 5–6; CA IOUs, No. 19 at
p. 5; NEEA, No. 20 at p. 2; South Korea,
No. 17 at p. 2) Cree indicated that
sudden increases or decreases in light
output in the first 1,000 hours of
operation depend on several factors in
the construction of the LED lamp. (Cree,
Public Meeting Transcript, No. 7 at pp.
36–37) P.R. China, NEEA, and the CA
IOUs stated that DOE should remain
consistent with the specifications of IES
LM–79–2008, and require no seasoning
prior to photometric measurements.
(P.R. China, No. 12 at p. 4; NEEA, No.
20 at p. 2; CA IOUs, No. 19 at p. 5)
The Joint Comment indicated that
when taking photometric
measurements, it is not obvious if
seasoning is necessary. They suggested
that DOE investigate and report on the
22 Cheong, Kuan Yew. ‘‘LED Lighting Standards
Update.’’ CREE, August 5, 2011. Page 31.
www.nmc.a-star.edu.sg/LED_050811/Kuan_
CREE.pdf
23 Richman, Eric. ‘‘Understanding LED Tests: IES
LM–79, LM–80, and TM–21.’’ DOE SSL Workshop,
July 2011. Page 13. https://apps1.eere.energy.gov/
buildings/publications/pdfs/ssl/richman_tests_
sslmiw2011.pdf
24 ‘‘Projecting Long Term Lumen Maintenance of
LED Light Sources.’’ Approved by IES on July 25,
2011.
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necessity of seasoning lamps prior to
photometric measurements, as this
seasoning is in direct conflict with
procedures established in IES LM–79–
2008. Should DOE decide that there is
sufficient variability in devices that can
be mitigated by seasoning; they
recommend that DOE collaborate with
industry to minimize testing burden and
potential re-testing of current LED
sources/lamps. (Joint Comment, No. 18
at pp. 5–6) The National Institute of
Standards and Technology (hereafter
referred to as NIST) and Samsung,
however, commented that seasoning
LED lamps for 1,000 hours prior to
collecting lumen output data is
reasonable. (NIST, Public Meeting
Transcript, No. 7 at p. 47; Samsung, No.
14 at p. 1) NIST argued that including
a seasoning time of 1,000 hours would
help identify faulty products. (NIST,
Public Meeting Transcript, No. 7 at p.
47)
In the SNOPR, DOE proposes to
eliminate the requirement to season
lamps for 1,000 hours prior to taking
photometric measurements. Although
some LED lamps do experience changes
in light output during the first 1,000
hours of operation, independent
research and manufacturer comments
indicate that this is not true for all LED
lamps. Each LED lamp is unique, and as
a result, initial trends in light output are
not consistent from lamp to lamp.
Therefore, seasoning all lamps for a
predetermined duration does not
provide a more accurate initial test
measurement, though it does increase
testing burden. The current industryaccepted test procedure, IES–79–2008,
reflects this understanding by not
allowing lamp seasoning. Therefore, the
SNOPR proposes to remain consistent
with section 4.0 of IES LM–79–2008,
which indicates LED lamps shall not be
seasoned before beginning photometric
measurements. These seasoning
requirements would apply to lamps
measured in both active mode and
standby mode. DOE requests comment
on this proposal.
b. Lamp Stabilization
In the NOPR, DOE proposed
stabilizing lamps for the time specified
in section 5.0 of IES LM–79–2008. DOE
further proposed that stability of the
LED lamp is reached when the variation
[(maximum—minimum)/minimum] of
at least three readings of light output
and electrical power over a period of 30
minutes, taken 15 minutes apart, is less
than 0.5 percent. 77 FR at 21043. This
calculation was included to add
clarification to the method specified in
section 5.0 of IES LM–79–2008. For
stabilization of a number of products of
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the same model, section 5.0 of IES LM–
79–2008 suggests that preburning 25 of
the product may be used if it has been
established that the method produces
the same stabilized condition as when
using the standard method described
above.
NEMA agreed that the lamp
stabilization method in IES LM–79–
2008 be used for the LED lamp test
procedure but argued that the standard
did not need further clarification.
(NEMA, Public Meeting Transcript, No.
7 at pp. 38–39; NEMA, No. 16 at p. 3)
However, GE advocated for presenting
the lamp stabilization equation as a
percent. (GE, Public Meeting Transcript,
No. 7 at p. 39)
DOE reconsidered its NOPR proposal,
but came to the same conclusion for the
SNOPR. IES LM–79–2008 does not
clearly specify the calculation for
determining the stabilization value,
leaving this requirement open to
interpretation. Therefore, DOE
continues to propose in the SNOPR that
variation of at least three readings of
light output and electrical power over a
period of 30 minutes, taken 15 minutes
apart is calculated as [maximum—
minimum]/minimum. DOE expects this
proposal is the same or very similar to
the stabilization calculation methods
already used in practice. As in the
NOPR, DOE continues to propose in this
SNOPR that stabilization of multiple
products of the same model can be
carried out as specified in section 5.0 of
IES LM–79–2008. These stabilization
requirements would apply to lamps
measured in both active mode and
standby mode.
c. Lumen Output Metric
In the NOPR, DOE proposed that the
test method for measuring the lumen
output of an LED lamp be as specified
in section 9.0 of IES LM–79–2008 and
proposed the same lumen output
measurement method for all LED lamps,
including directional 26 LED lamps. Id.
For directional LED lamps, DOE
suggested measuring total lumen output
from the lamp rather than beam
lumens 27 because other directional
25 IES LM–79–2008 defines preburning as the
operation of a light source prior to mounting on a
measurement instrument, to shorten the required
stabilization time on the instrument.
26 Directional lamps are designed to provide more
intense light to a particular region or solid angle.
Light provided outside that region is less useful to
the consumer, as directional lamps are typically
used to provide contrasting illumination relative to
the background or ambient light.
27 Please refer to the NOPR Test Procedures for
Light-Emitting Diode Lamps (Docket No. EERE–
2011–BT–TP–0071) for a detailed explanation of
why DOE is not proposing to measure beam lumens
for directional LED lamps (77 FR at 21043; April 9,
2012).
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lamp technologies currently measure
and report total lumen output on the
FTC Lighting Facts label.
As discussed in section III.C.3.b, DOE
proposes in the SNOPR that
goniometers may not be used for
photometric measurements. As a result,
DOE proposes that the method for
measuring lumen output in the SNOPR
be as specified in sections 9.1 and 9.2
of IES LM–79–2008. Section 9.3 of IES
LM–79–2008 discusses usage of
goniometers, and DOE is not including
that method in the SNOPR proposal.
Regarding directional lamps, NEMA
commented that industry has not yet
reached consensus regarding a light
output metric for directional lamps.
(NEMA, Public Meeting Transcript, No.
7 at p. 43; NEMA, No. 16 at p. 4)
Furthermore, NEMA highlighted that
DOE has other rulemakings specifically
for reflector lamps that specify the use
of total lumens. Therefore, a deviation
from measuring total lumens in the LED
lamp test procedure would have a
significant impact on all types of
directional lamps. (NEMA, Public
Meeting Transcript, No. 7 at p. 44) The
CA IOUs commented that if measuring
beam lumens is only required for the
LED lamp test procedure and not all
general service reflector lamps, this
could hinder the industry’s ability to
compare lamps across technologies. (CA
IOUs, No. 19 at p. 7) However, the CA
IOUs supported DOE’s efforts to develop
a beam efficacy metric and
recommended that this metric be
applied to all directional lamp
technologies. (CA IOUs, No. 19 at p. 7)
In contrast, P.R. China argued that
testing total lumen output instead of the
beam lumen output and center-beam
candle power might bring inconsistency
and confusion to the industry.
Therefore, they recommended that DOE
reference the Energy Star Program
Requirements for Integral LED Lamps:
Eligibility Criteria—Version 1.4 28
which specifies that the center-beam
candle power and beam angle be tested
for directional lamps. (P.R. China, No.
12 at p. 4)
Because total lumen output is the
measurement reported on the FTC
Lighting Facts label for other directional
lamp technologies, DOE agrees with
NEMA and the CA IOUs comments not
to include measurements for beam
lumens in this test procedure.
Therefore, DOE maintains its proposal
from the NOPR to measure the total
lumen output for LED lamps. Measuring
the total lumen output for LED lamps
28 ‘‘Energy Star Program Requirements for Integral
LED Lamps: Eligibility Criteria—Version 1.4.’’ U.S.
Environmental Protection Agency, August 28, 2013.
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will enable industry and consumers to
compare general service lamp products
across different technologies.
d. Input Power
Following seasoning and stabilization,
input power to the LED lamp is
measured using the instrumentation
specified in section III.C.3.b. All test
conditions and test setup requirements
from sections III.C.2 and III.C.3 should
also be followed.
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e. Lamp Efficacy Metric
In the NOPR, DOE proposed test
procedures for measuring lumen output
and input power, and also specified
testing dimmable lamps at full light
output. 77 FR at 21041. However,
commenters noted that efficacy may
appear in future mandates, and
therefore recommended it be included
in DOE’s test procedure for LED lamps.
The CA IOUs commented that a test
procedure with an efficacy metric
would be needed in the future to
comply with federal legislative
mandates, and for this reason they urged
DOE to include an efficacy metric in the
test procedure. Both the CA IOUs and
NEEA recommended that DOE adopt
IES LM–79–2008, which defines
luminous efficacy as the quotient of the
measured total luminous flux (in
lumens) and the measured electrical
input power (in watts), or lumens per
watt. (CA IOUs, No. 19 at p. 3; NEEA,
No. 20 at p. 1)
As discussed in section I, this
proposed test procedure will support
any potential future energy conservation
standards for general service LED lamps,
which may include efficacy as a metric
for setting standards. Accordingly, for
the SNOPR, DOE proposes that the
efficacy of an LED lamp be calculated by
dividing measured initial lamp lumen
output in lumens by the measured lamp
input power in watts, in units of lumens
per watt. DOE believes that providing a
calculation for efficacy of an LED lamp
does not increase testing burden
because the test procedure already
includes metrics for input power and
lumen output. DOE requests comment
on the proposal to add a calculation for
efficacy of an LED lamp.
f. Measuring Correlated Color
Temperature
In the NOPR, DOE proposed that the
CCT of an LED lamp be calculated as
specified in section 12.4 of IES LM–79–
2008. 77 FR at 21044. The CCT is
determined by measuring the relative
spectral distribution, calculating the
chromaticity coordinates, and then
matching the chromaticity coordinates
to a particular CCT of the Planckian
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radiator. The setup for measuring the
relative spectral distribution, which is
required to calculate the CCT of the LED
lamp, shall be as specified in section
12.0 of IES LM–79–2008. That section
describes the test method to calculate
CCT using a sphere-spectroradiometer
system and a spectroradiometer or
colorimeter system. Section 12.0 of IES
LM–79–2008 also specifies the
spectroradiometer parameters that affect
CCT and the method to evaluate spatial
non-uniformity of chromaticity.
South Korea disagreed with the
proposal in the NOPR and
recommended that DOE follow industry
standard IEC/PAS 62612 which states
that nominal CCT values shall be
reported (South Korea, No. 17 at pp. 3–
4). Nominal CCT values are defined by
a region of the chromaticity diagram and
any lamp that falls in a certain region is
assigned a single CCT value. However,
nominal CCT values do not address all
regions of the chromaticity diagram.
Although manufacturers in the
marketplace may choose to design
lamps that fall within regions defined
by nominal CCT, DOE’s goal is to
establish one test method that applies to
all LED lamps. Therefore, DOE is not
proposing to follow a nominal CCT
methodology and maintains its proposal
in the NOPR regarding the method to
calculate the CCT of an LED lamp.
Furthermore, as discussed in section
III.C.3.b, DOE also proposes in the
SNOPR to require all photometric
measurements (including CCT) be
carried out in an integrating sphere, and
that goniometer systems must not be
used. Therefore, DOE proposes that the
instrumentation used for CCT
measurements be as described in section
12.0 of IES LM–79–2008 with the
exclusion of section 12.2 of IES LM–79–
2008.
g. Measuring Color Rendering Index
In the SNOPR, DOE proposes to add
a requirement that the CRI of an LED
lamp be determined as specified in
section 12.4 of IES LM–79–2008. As
discussed in section III.C.3.b, DOE also
proposes in the SNOPR to require all
photometric measurements (including
CRI) be carried out in an integrating
sphere. Therefore, the setup for
measuring the relative spectral
distribution, which is required to
calculate the CRI of the LED lamp, must
be as specified in section 12.0 of IES
LM–79–2008 with the exclusion of
section 12.2 of IES LM–79–2008, as
goniometer systems must not be used.
Section 12.4 of IES LM–79–2008 also
specifies that CRI be calculated
according to the method defined in the
International Commission on
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Illumination (CIE) 13.3–1995.29 DOE
proposes that the test procedure for LED
lamps include measurement methods
for CRI in order to support the
upcoming general service lamps energy
conservation standard rulemaking. DOE
requests comment on the proposal to
add CRI to the test procedure for LED
lamps.
D. Proposed Approach for Lifetime
Measurements
1. LED Lamp Lifetime Definition
There are currently no industry
standards that define or provide
instructions for measuring the
lifetime 30 of LED lamps. Thus, for the
NOPR, DOE conducted literature
research and interviewed several subject
matter experts to understand how
industry characterized lifetime for these
products. Based on the information
gathered, DOE proposed to measure
lumen maintenance to determine the
lifetime of LED lamps. Although other
lighting technologies define lamp
lifetime as the time at which 50 percent
of tested samples stop producing light,
industry believes that an LED lamp has
reached the end of its useful life when
it achieves a lumen maintenance of 70
percent (i.e. 70 percent of initial lumen
output, or L70). 77 FR at 21046.
Philips, OSI, and Cree agreed that
currently no industry accepted
procedure exists for measuring the
lifetime of LED-based lighting products.
(Philips, Public Meeting Transcript, No.
7 at p. 64; OSI, Public Meeting
Transcript, No. 7 at pp. 74–75; Cree,
Public Meeting Transcript, No. 7 at p.
65) However, Litecontrol and NEMA
disagreed with DOE’s proposal, stating
that the report LED Luminaire Lifetime:
Recommendation for Testing and
Reporting 31 explicitly argues that lumen
maintenance alone cannot be used as a
proxy for the lifetime of LED-based
lighting products. (Litecontrol, No. 11 at
p. 1; NEMA, No. 16 at p. 5) Radcliffe
Advisors and the CA IOUs emphasized
that color shift be considered when
determining the lifetime because this
could also render a lamp un-usable or
undesirable to a consumer before the
lamp reaches L70. (Radcliffe Advisors,
29 ‘‘Method of Measuring and Specifying Colour
Rendering Properties of Light Sources.’’ Approved
by CIE in 1995.
30 In the NOPR, DOE used the term ‘‘rated
lifetime.’’ For the SNOPR, DOE replaces the term
‘‘rated lifetime’’ with ‘‘lifetime’’ to refer to the same
parameter.
31 U.S. Department of Energy, ‘‘LED Luminaire
Lifetime: Recommendation for Testing and
Reporting,’’ June 2011. https://
apps1.eere.energy.gov/buildings/publications/pdfs/
ssl/led_luminaire-lifetime-guide_june2011.pdf.
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No. 13 at p. 1; CA IOUs, No. 19 at p.
4)
In the absence of industry consensus
regarding a definition or test procedure
for lifetime, NEMA, Lutron, the CA
IOUs, and Radcliffe Advisors
emphasized that DOE should wait for
industry to develop new and revised
standards that address lifetime and then
reference them for the purposes of the
FTC Lighting Facts label. (NEMA, No.
16 at p. 2; Lutron, Public Meeting
Transcript, No. 7 at p. 80; CA IOUs, No.
19 at p. 5; Radcliffe Advisors, No. 13 at
p. 1) NEMA indicated that this includes
revisions of IES LM–79–2008, IES LM–
80–2008,32 and emerging standards IES
LM–84 33 and IES TM–26.34 (NEMA, No.
16 at p. 2, 5, 7) The Joint Comment,
NEMA, NEEA, and the CA IOUs
encouraged DOE to work with industry
to develop a test procedure that would
quantify the lifetime of an LED lamp
system. (Joint Comment, No. 18 at p. 1;
NEMA, No. 16 at p. 4; NEEA, No. 20 at
pp. 2–3; CA IOUs, No. 19 at p. 5)
NEMA, Philips, and Radcliffe Advisors
pointed out that there are several
industry groups working on this issue,
such as the LED Systems Reliability
Consortium. (NEMA, No. 16 at p. 4;
Philips, Public Meeting Transcript, No.
7 at p. 64; Radcliffe Advisors, No. 13 at
p. 1) Other interested parties cited
additional efforts; the CA IOUs
commented that DOE should coordinate
efforts with ENERGY STAR while the
Joint Comment recommended that DOE
coordinate test procedure development
with work in the European Union. (CA
IOUs, No. 19 at p. 5; Joint Comment, No.
18 at p. 5)
DOE recognizes that there are
degradation mechanisms other than
lumen maintenance, such as color shift,
that can affect the useful lifetime of LED
lamps. However, color shift is not very
well-understood, well-studied, or
commonly used even for traditional
incandescent lamps and CFLs.31 After
conducting thorough research of
existing test procedures for all lighting
products and industry literature
regarding LED lamp lifetime, DOE has
tentatively concluded that there is no
industry consensus for how to
32 ‘‘Measuring Lumen Maintenance of LED Light
Sources.’’ Approved by IES on September 22, 2008.
33 LM–84 ‘‘IES Approved Method for Measuring
Lumen and Color Maintenance LED Lamps,
Lighting engines, and Luminaires,’’ will provide the
method for measurement of lumen and color
maintenance of LED lamps, light engines, and LED
luminaires.
34 TM–26 ‘‘Projecting Long-Term Lumen
Maintenance for LED Lamps and Luminaires,’’ will
provide an LED lamp and luminaire level
counterpart to IES TM–21–2011 using the IES LM–
80–2008 (revision) and LM–84 testing data for
projecting long-term lumen maintenance.
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characterize lifetime of LED lamps in
terms of performance metrics other than
lumen maintenance. Therefore, DOE is
not proposing to use metrics such as
color shift to determine the lifetime of
LED lamps.
Although industry may be working to
develop new and revised standards to
define lifetime and establish test
procedures for measuring this quantity,
the timeframe for their development is
unknown. DOE reviewed the efforts of
other working groups, as suggested by
interested parties, but was unable to
find any U.S. or international standard
that provides a test procedure for
measuring and/or projecting LED lamp
lifetime. The only publicly available
approach for measuring LED lamp
lifetime is ENERGY STAR Program
Requirements for Lamps (Light Bulbs):
Eligibility Criteria—Version 1.0,10
which uses a lumen maintenance of 70
percent (i.e. 70 percent of initial lumen
output, or L70) as an estimate for
lifetime. Therefore, in this SNOPR, DOE
proposes to continue to define lifetime
as the time at which the lumen output
of the LED lamp falls below 70 percent
of the initial lumen output.
2. NOPR Proposals
As mentioned above, there are
currently no industry standards that
address how to measure lifetime for LED
lamps. Therefore, DOE reviewed
methods to measure lifetime that were
contained in industry standards for
related components and also
investigated recent efforts in DOE and
ENERGY STAR working groups. In the
NOPR, DOE presented four potential
lifetime measurement approaches, all of
which characterized the lifetime of LED
lamps as the time required to reach a
lumen maintenance of 70 percent. 77 FR
at 21044–5. Three of these approaches
tested an LED lamp to determine the
lifetime and the fourth approach tested
the LED source as a proxy for the
lifetime of the lamp. Ultimately, DOE
determines in this SNOPR that the test
procedure for lifetime must directly
measure the performance of an LED
lamp and not the LED source, and
proposes the revised lifetime
measurement detailed in section III.D.3.
Approach 1, based largely on the
procedures in IES LM–79–2008,
directed manufacturers to measure the
lumen output of the LED lamp until it
reaches 70 percent of its initial lumen
output. In the NOPR, DOE stated that
Approach 1 is advantageous because it
does not project the time at which the
lamp reaches L70 and therefore measures
the actual performance of the lamp over
its useful life. However, DOE
determined that Approach 1 was not
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practical because it may require up to
six years of testing, by which time the
LED lamp may be obsolete. Id.
Approach 2 called for measuring
lumen output of the LED lamp for a
specified period of time, 6,000 hours,
and then projecting the time at which
the lamp reached L70 based on the
minimum lumen maintenance at 6,000
hours. This method was largely based
on the ENERGY STAR Specification for
Integral LED Lamps Version 1.4 (see
supra note 28). In addition, DOE
proposed in the NOPR that a rapid-cycle
stress test be performed to assess
catastrophic lamp failure (e.g. when a
lamp immediately ceases to emit light,
rather than gradually decreasing in light
output). Approach 2 also enabled
lifetime claims to be based on the
performance of an LED lamp, but was
less time consuming than Approach 1
because it only required 6,000 hours of
testing and then projected the lifetime
based on the lumen maintenance at
6,000 hours. However, DOE noted in the
NOPR that the method used to develop
the ENERGY STAR lifetime projection is
unverified and purely theoretical.
Furthermore, Approach 2 did not
account for catastrophic lamp failure
beyond the 6,000 hour testing time. Id.
Similar to Approach 2, Approach 3,
based on IES LM–79–2008, directed
measuring the lumen output of the LED
lamp for a minimum of 6,000 hours. In
the NOPR, DOE stated that the collected
lumen output data would then be used
to project the L70 lifetime of the LED
lamp using an alternative procedure that
would be developed by DOE. This
method would project lifetime based on
the performance of an LED lamp, but
would not necessarily be based on a
standardized method for projecting
lifetime. 77 FR at 21045.
Finally, Approach 4 required
measuring the lumen output of LED
sources (the component of the LED lamp
that produces light) at regular intervals
for a minimum of 6,000 hours, based
largely on the procedures in IES LM–
80–2008. DOE would then project the
time at which the lumen output of the
source reached 70 percent of its initial
lumen output using the projection
method in IES TM–21–2011. In the
NOPR, DOE indicated that, although the
preferred methodology is to project the
lifetime of an LED lamp rather than an
LED source, an industry standardized
method only exists for projecting the
lifetime of an LED source and not an
LED lamp. For this reason, DOE
tentatively concluded in the NOPR that
Approach 4 was the most appropriate
and proposed that this method be used
for estimating the lifetime of an LED
lamp. Id.
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DOE received many comments
regarding its proposal for measuring
lifetime. Both Kritzer and Samsung
agreed with NOPR Approach 4, as
written, for measuring the lifetime of
LED lamps. (Kritzer, No. 3 at p. 1,
Samsung, No. 14 at p. 1) Kritzer
commented that it would be expected
that the proposed method would reduce
the amount of time needed for testing
LED lamps and hence also reduce costs.
(Kritzer, No. 3 at p. 1) However, NEMA,
Radcliffe Advisors, and the Joint
Comment disagreed with all suggested
approaches within the NOPR document,
including Approaches 1, 2, and 3 which
DOE did not adopt as its proposal.
(NEMA, No. 16 at p. 4; Radcliffe
Advisors, No. 13 at p. 1; Joint Comment,
No. 18 at p. 1)
Despite their disagreement, NEMA
did offer an interim solution to use until
new and revised industry standards are
released. Their proposal combined
NOPR Approach 2 and 4. They
indicated that NOPR Approach 2 could
be used by those manufacturers who do
not have IES LM–80–2008 data for the
LED source within the lamp and that
NOPR Approach 4 could be used for
those products for which IES LM–80–
2008 data does exist. (NEMA, No. 16 at
p. 4, 8) In addition, they suggested that
DOE not include the rapid cycle stress
testing suggested in Approach 2. They
indicated that rapid cycle stress testing
is practiced for some lighting
technologies; however, this technique is
not widely practiced by the LED
industry and has not been verified as
relevant to LED lifetime and
performance. (NEMA, No. 16 at p. 9)
DOE appreciates NEMA’s interim
proposal, but notes that combining
Approaches 2 and 4 would result in
some manufacturers reporting lifetime
based on testing of an LED lamp and
others reporting lifetime based on
testing of an LED source. The
differences between Approaches 2 and 4
would lead to different results for
lifetime. DOE cannot adopt alternative
test methods that yield different results
as there would be no basis for
establishing any future energy
conservation standards. Furthermore,
this combined approach still contains
many of the drawbacks related to the
individual approaches.
Regarding Approach 4, DOE received
several comments that outlined the
disadvantages of the NOPR proposal for
determining the lifetime of LED lamps.
NEMA, Philips, OSI, TUD, the Joint
Comment, the CA IOUs, NEEA,
Radcliffe Advisors, the Appliance
Standards Awareness Project (hereafter
referred to as ASAP), and Litecontrol
advocated basing the lifetime on
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measurements of the whole LED lamp
and not the LED source component.
They commented that it is undesirable
for the lifetime of LED lamps to be
approximated by the lumen
maintenance of the LED source and
stated that other components may cause
lamp failure before the LED source falls
below 70 percent of its initial light
output. (NEMA, Public Meeting
Transcript, No. 7 at p. 83, 84–85, 85;
NEMA, No. 16 at p. 2, 4, 5, 8, 9; Philips,
Public Meeting Transcript, No. 7 at pp.
63–64, 83; OSI, Public Meeting
Transcript, No. 7 at p. 69, 100–101;
TUD, No. 15 at p. 1; Joint Comment, No.
18 at p. 1, 2, 4; CA IOUs, No. 19 at p.
4; NEEA, No. 20 at p. 2, 3; Radcliffe
Advisors, No. 13 at p. 1; ASAP, Public
Meeting Transcript, No. 7 at pp. 83–84;
Litecontrol, No. 11 at p. 1)
Some interested parties suggested
additional considerations for a
procedure that measured the
performance of an LED lamp rather than
an LED source. The Joint Comment
stated that the test procedure for LED
lamp lifetime include measurements
and projections of driver lifetime. They
explained that industry has developed
reliability models to predict theoretical
failure rates of LED drivers, and DOE
should investigate these models to
determine if using them would help
better capture system effects of an LED
lamp. (Joint Comment, No. 18 at p. 1, 4–
5) The CA IOUs also suggested that DOE
use accelerated testing based on
elevated temperatures, such as the
method being explored by the LRC. (CA
IOUs, No. 19 at p. 5)
DOE has considered all comments
received about the four approaches
discussed in the NOPR and has decided
to significantly change its approach for
determining the lifetime of LED lamps
in this SNOPR. DOE agrees that there
are several potential issues with
requiring lumen maintenance testing of
the LED source component, as proposed
in Approach 4. DOE has preliminarily
concluded in this SNOPR that the test
procedure for lifetime must directly
measure the performance of an LED
lamp. DOE acknowledges that LED
driver degradation and interactions
between the LED sources and other
components are known to affect the
lifetime of integrated LED lamps.
Regarding the proposal by the Joint
Comment, DOE conducted research of
existing driver reliability modeling and
test procedures, including those
specified in the military handbook MIL–
HDBK–217F,35 to determine whether
35 Society of Reliability Engineers, Reliability
Prediction of Electronic Equipment, December
1991. https://www.sre.org/pubs/Mil-Hdbk-217F.pdf.
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driver failure could be included in the
projection of LED lamp lifetime.
However, DOE determined that no test
procedures are available that use the
expected failure of the LED driver to
predict the failure of the complete LED
lamp system. The CA IOUs suggested
that DOE consider accelerated testing
based on elevated temperatures for the
lifetime test procedure. However, DOE
research of existing literature and
industry test procedures indicates that
accelerated test methods for LED lamp
lifetime are not available, and therefore,
are not ready for inclusion in the
SNOPR.
As mentioned above, DOE has
decided to measure directly the
performance of an LED lamp and does
not propose requiring testing of LED
sources or any individual lamp
component. The complete SNOPR
method is described in section III.D.3.
Although DOE has decided to make this
change, DOE did receive comments on
specific aspects of the NOPR proposal.
These comments are discussed in
further detail below.
a. Industry Standards
In the NOPR, DOE proposed
measuring the lumen output of LED
sources based on IES LM–80–2008 and
then projecting the time at which the
lumen output of the source reached 70
percent of the initial lumen output
based on IES TM–21–2011. 77 FR at
21045 NEMA, Cree, Radcliffe Advisors,
the CA IOUs, and Philips commented
that the NOPR proposal modifies and
misapplies industry standards, and
argued that both IES LM–80–2008 and
IES TM–21–2011 provide procedures to
measure lumen maintenance of the LED
source and should not be used to
estimate the lifetime of LED lamps.
(NEMA, No. 16 at p. 2, 5, 7; Cree, Public
Meeting Transcript, No. 7 at pp. 95–96,
109; Radcliffe Advisors, No. 13 at p. 1;
CA IOUs, No. 19 at p. 5, 6; Philips,
Public Meeting Transcript, No. 7 at p.
114) NEMA specified that DOE only
reference IES LM–79–2008 because this
standard applies to LED lamps, which
are the subject of this rulemaking.
(NEMA, No. 16 at p. 6)
DOE understands that both IES LM–
80–2008 and IES TM–21–2011 are
industry standards for measuring and
predicting the lumen maintenance of an
LED source. In the NOPR, DOE
proposed referencing these standards to
measure the lumen maintenance of an
LED source because DOE believed it
would be an adequate approximation for
determining the lifetime of LED lamps.
However, based on the comments
received in response to the NOPR, DOE
has changed its proposed procedure to
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measure the lifetime of LED lamps. In
this SNOPR, DOE proposes assessing
the lumen maintenance of an LED lamp
and does not require testing of LED
sources. DOE’s lifetime proposal,
described in section III.D.3, uses the
procedures of IES LM–79–2008 to
measure the lumen output of an LED
lamp.
b. LED Source In-Situ Temperature
In the NOPR, DOE proposed
performing an in-situ temperature
measurement test (ISTMT) to determine
the case temperature at which the
lumen maintenance data shall be
obtained to project the lifetime of the
LED source. 77 FR at 21047 DOE
proposed that the test setup, conditions,
test equipment, instrumentation, and
test box material and construction for
the ISTMT be as specified in UL 1993–
2009.36 UL, GE, Cree, NEMA, and Feit
argued that the test setup specified in
UL 1993–2009 is designed to represent
a worst-case installation scenario. (UL,
Public Meeting Transcript, No. 7 at p.
110; GE, Public Meeting Transcript, No.
7 at p. 91; Cree, Public Meeting
Transcript, No. 7 at p. 93; NEMA, No.
16 at p. 5; Feit, Public Meeting
Transcript, No. 7 at p. 93) Specifically,
NEMA expressed concern that the test
setup described in UL 1993–2009 would
elevate the ambient air to a temperature
greater than 25 °C, which conflicts with
the requirement to measure photometric
characteristics at 25 °C. This increase in
temperature could also lead to changes
in the photometric performance of the
LED sources. Furthermore, NEMA
commented that using UL 1993–2009
would force LED lamp manufacturers to
increase design margins for lumens and
other lamp characteristics to account for
the temperature increase of the UL test
conditions. This would lead to the overdesign of LED lamps. (NEMA, No. 16 at
p. 7) GE and NEMA concluded that UL
1993–2009 should not be used as part of
the instruction for the ISTMT. (GE,
Public Meeting Transcript, No. 7 at p.
91; NEMA, No. 16 at p. 5, 7) The Joint
Comment indicated that DOE should
carefully consider whether UL 1993–
2009 represents an average installation
or a worst-case scenario. (Joint
Comment, No. 18 at p. 3) However,
Intertek argued that UL 1993–2009 is
designed to represent typical
installation conditions. (Intertek, Public
Meeting Transcript, No. 7 at p. 92, 93).
The Joint Comment explained that
temperature plays a critical role in the
failure of LED lamps. They commented
that an appropriate lifetime test method
36 ‘‘Self-Ballasted Lamps and Lamp Adapters.’’
Published by UL on August 28, 2009.
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would take careful account of all the
real-world installation parameters that
could impact the natural operating
temperature of the device. The Joint
Comment indicated that this would
include orientation, natural air
circulation around the device, and all
the effects from other physical
connections/thermal pathways. In
contrast with the manufacturers’
recommendation, the Joint Comment
supported a test procedure that
approximates a worst-case installation
scenario if knowledge about field
installations is missing or insufficient.
(Joint Comment, No. 18 at p. 2–3) The
Joint Comment recommended that DOE
carefully consider whether UL 1993–
2009 represents an average U.S.
installation or a worst-case scenario and
provide justification as to why its use is
appropriate. (Joint Comment, No. 18 at
p. 3)
In this SNOPR, DOE has proposed a
new test procedure for measuring the
lifetime of LED lamps that does not
require determining the in-situ
temperature of the LED source. The test
conditions for the new proposal are
discussed in section III.D.3.b.
c. LED Source Lumen Maintenance
IES LM–80–2008 requires
manufacturers to test LED sources at
three temperatures: 55 °C, 85 °C, and a
third temperature suggested by the
source manufacturer. A lamp
manufacturer can then interpolate the
performance of the source at any
temperature bounded by those three
temperatures, avoiding the need to
conduct additional LED source testing
for their specific LED lamp. However,
IES LM–80–2008 does not provide a
method for extrapolating LED source
performance at an in-situ temperature
that is not bounded by those three
temperatures. In this case (an
uncommon situation), DOE proposed in
the NOPR that LED lamp manufacturers
would need to test the LED sources at
the in-situ temperature of their lamp to
obtain the lumen maintenance data to
project the lifetime. 77 FR at 21046
DOE’s NOPR proposal did not modify
IES LM–80–2008, instead it provided
additional test methods for situations
outside the applicability of IES LM–80–
2008.
DOE received several comments
requesting that DOE not modify IES
LM–80–2008 and stating that proposed
testing of LED sources would be costly.
NEMA, the CA IOUs, and NEEA
commented that DOE should not modify
the test procedures specified in IES LM–
80–2008. (NEMA, No. 16 at p. 5; CA
IOUs, No. 19 at pp. 5–6; NEEA, No. 20
at p. 2). Furthermore, NEEA commented
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that aligning DOE’s test procedure and
IES LM–80–2008 will reduce the testing
burden on manufacturers. (NEEA, No.
20 at p. 2) The CA IOUs elaborated that
LED source testing at the case
temperature identified during the
ISTMT would be impractical and/or
costly for industry because LED sources
are often brought to market with their
IES LM–80–2008 testing already
complete. (CA IOUs, No. 19 at pp. 5–6)
Two commenters requested further
clarification of IES LM–80–2008.
Regarding the temperature
requirements, South Korea commented
that international standards do not
prescribe any specific temperatures at
which to measure the lumen
maintenance of the LED source. If DOE
determines it is important to test the
sources at 55 °C and 85 °C, DOE should
seek scientific justification for these
requirements. (South Korea, No. 17 at p.
3) Samsung also requested that DOE
specify the location on the LED source
where temperature is measured.
(Samsung, No. 14 at p. 1)
DOE also received several comments
indicating that DOE’s proposal for
procurement of LED source lumen
maintenance data could require
disassembly of a lamp in some cases.
GE, OSI, and NEMA commented that
manufacturers would need to extract the
LED source from the finished lamp
product if IES LM–80–2008 data is
unavailable. (GE, Public Meeting
Transcript, No. 7 at p. 94, 95, 100; OSI,
Public Meeting Transcript, No. 7 at pp.
100–101; NEMA, No. 16 at p. 6) To
avoid extracting the LED source, GE
recommended that DOE consider
multiple lifetime measurement
approaches depending on the
availability of IES LM–80–2008 data.
(GE, Public Meeting Transcript, No. 7 at
pp. 78–79)
In the NOPR, DOE also proposed
using the relevant guidelines from an
ENERGY STAR specification document
to measure the lumen maintenance for
LED sources.37 77 FR at 21048 Cree
commented that for lamps that use both
white and red LED sources there is
uncertainty as to whether the IES LM–
80–2008 data from the individual
sources can be added together to
accurately represent their combined
performance. Cree also noted ENERGY
STAR is currently accepting this
practice. (Cree, Public Meeting
37 ENERGY STAR Program Guidance Regarding
LED Package, LED Array and LED Module Lumen
Maintenance Performance Data Supporting
Qualification of Lighting Products, September 9,
2011. www.energystar.gov/ia/partners/prod_
development/new_specs/downloads/luminaires/
ENERGY_STAR_Final_Lumen_Maintenance_
Guidance.pdf.
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Transcript, No. 7 at p. 106) Both NEMA
and Radcliffe Advisors stated that this is
not an issue because DOE’s test
procedure should not require testing of
any individual component of an LED
lamp. All testing procedures should
measure performance of the complete
lamp product. (NEMA, No. 16 at p. 4–
5; Radcliffe Advisors, No. 13 at p. 1)
DOE agrees there are drawbacks
(including disassembly of the lamp to
extract an LED source) to testing the
LED source component as a proxy for
estimating the lifetime of an LED lamp
as outlined in IES LM–80–2008.
Therefore, DOE has developed a new
proposal that only requires testing of an
LED lamp and is no longer using the test
procedures in IES LM–80–2008 or IES
TM–21–2011. The new test procedure
for LED lamps indicates that after the
test duration, lumen output must be
measured as specified in IES LM–79–
2008. The lifetime of the LED lamp can
then be projected using an equation.
The proposed method for lifetime
testing is discussed in more detail in
section III.D.3.
d. Test Conditions
In the NOPR, DOE proposed that the
temperature of the surrounding air
during testing be maintained between
the case temperature and 5 °C below the
case temperature as specified in section
4.4.2 of IES LM–80–2008. DOE also
proposed that airflow around the LED
sources be as specified in section 4.4.3
of IES LM–80–2008, which states that
the airflow shall be maintained to
minimize air drafts but allow some
movement of the air to avoid thermal
stratification. 77 FR at 21046 NEMA and
Cree commented that the upcoming IES
LM–80–2008 revisions will include
recommendations on best practices for
measuring and monitoring air flow
through the test system. (NEMA, Public
Meeting Transcript, No. 7 at p. 97; Cree,
Public Meeting Transcript, No. 7 at p.
97) However, NEMA indicated that
current test methods have led industry
to believe that the surrounding air
temperature and airflow do not have
noticeable impact on long-term LED
lumen degradation. They suggested that
current IES LM–79–2008 air movement
requirements are more than adequate to
ensure the accuracy of test data. (NEMA,
No. 16 at p. 5) TUD disagreed with the
specified test conditions, indicating that
they cannot sufficiently simulate all real
world conditions. (TUD, No. 15 at p. 1)
As previously mentioned, for this
SNOPR, DOE has developed a test
procedure that only requires testing of
an LED lamp. Therefore, DOE no longer
references IES LM–80–2008, which
applies to LED sources. The SNOPR has
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proposed less stringent ambient
temperature and airflow conditions for
periods when a lamp is operating but
measurements are not being taken.
These requirements are discussed in
more detail in section III.D.3.b.
e. LED Source Orientation
In the NOPR, DOE proposed that the
LED sources be operated in accordance
with section 4.4.4 of IES LM–80–2008,
which requires operating LED sources in
the orientation specified by the source
manufacturer. Id. DOE noted that it is
not specifying the orientation for testing
LED sources and invited interested
parties to comment on whether the
operating orientation of the LED sources
during testing affects the lumen
depreciation over time. Cree, Samsung,
and NEMA commented that DOE should
not require additional marking or testing
based on orientation. (Cree, Public
Meeting Transcript, No. 7 at p. 98;
Samsung, No. 14 at p. 1; NEMA, No. 16
at p. 6) NEMA stated that the orientation
specified in IES LM–80–2008 is only
provided to establish a common testing
protocol, not because there is any
evidence that orientation affects
performance. In this SNOPR, DOE is not
referencing the test procedures provided
in IES LM–80–2008, which apply to
LED sources. Instead, DOE is proposing
a new test procedure for lifetime which
measures the performance of LED
lamps. Because DOE believes that
orientation impacts the performance of
LED lamps, DOE is proposing that
lamps be tested in both the base-up and
base-down positions. The orientation
requirements for lifetime are discussed
in section III.C.3.b.
f. External Driver Requirements
As specified in IES LM–80–2008, in
the NOPR, DOE proposed using an
external driver that is compliant with
manufacturer’s guidance to drive the
LED source. 77 FR at 21047 Both Cree
and NEMA opposed using external
drivers to test LED sources, while
Samsung thought the use of an external
driver was appropriate. (Cree, Public
Meeting Transcript, No. 7 at p. 99;
NEMA, No. 16 at p. 6; Samsung, No. 14
at p. 1) NEMA indicated that the FTC
label only regulates medium screw-base
products (as defined in CFR 430.2).
Therefore, if the lamp is to connect to
the power supply via an ANSI base,
there must be an integrated driver rather
than an external driver. (NEMA, No. 16
at p. 6) In this SNOPR, DOE is
proposing a new test procedure that
measures the performance of an LED
lamp and is no longer utilizing the test
procedures provided in IES LM–80–
2008. The new proposal does not
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require the use of an external driver
because an internal driver is included in
an integrated LED lamp. The SNOPR
proposal for determining the lifetime of
LED lamps is detailed in section III.D.3.
g. Lumen Maintenance Measuring
Equipment
IES LM–80–2008 specifies using a
spectroradiometer to measure the lumen
output of an LED source. In the NOPR,
DOE proposed using a spherespectroradiometer, sphere-photometer,
or a goniophotometer to measure the
lumen output of the LED source. 77 FR
at 21043 Cree agreed that all three
instruments are appropriate to measure
the lumen output of LED sources. Cree
indicated that IES LM–80–2008 does not
specify the use of a goniophotometer
because this equipment cannot be used
to measure many of the other
photometric and electrical
characteristics that the standard
requires. (Cree, Public Meeting
Transcript, No. 7 at p. 103) NEMA
disagreed with DOE’s proposal and
recommended that DOE not modify the
IES LM–80–2008 procedures. (NEMA,
Public Meeting Transcript, No. 7 at p.
104; NEMA, No. 16 at p. 6) Samsung
commented that requiring only a
sphere-spectroradiometer would be
suitable. (Samsung, No. 14 at p. 1)
For this SNOPR, DOE is no longer
proposing to use the test procedures
provided in IES LM–80–2008. Because
DOE proposes to measure the lifetime of
LED lamps rather than LED sources, the
SNOPR proposes the use of the lumen
output measuring equipment described
in IES LM–79–2008. As discussed in
section III.C.3.b, DOE proposes that the
instrumentation used for lumen output
measurement of LED lamps be as
described in sections 9.1 and 9.2 of IES
LM–79–2008 and that goniometer
systems not be used.
h. LED Source Seasoning
Regarding seasoning of the LED
source for lifetime measurements, the
Joint Comment argued that if DOE
proposes a lifetime test method that
involves projection of the LED source
using the Arrhenius equation as the
functional form of lumen degradation,
the proposal should include seasoning.
(Joint Comment, No. 18 at pp. 5–6)
DOE’s proposal in the SNOPR
(discussed in section III.D.3) involves
measurements of the LED lamp, not the
LED source. Therefore, DOE is not
proposing a seasoning requirement for
LED sources in the SNOPR.
i. Maximum Lifetime
In the NOPR, DOE proposed
projecting the lifetime as specified in
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section 5.0 of IES TM–21–2011. DOE
also proposed that if the projected rate
lifetime is greater than 25,000 hours, the
maximum lifetime is 25,000 hours. If
the projected lifetime is less than 25,000
hours, the lifetime is the projected
value. 77 FR at 21048
Litecontrol, Radcliffe Advisors, South
Korea, Kritzer, an Anonymous
commenter, the CA IOUs, NEMA, and
Philips disagreed with the proposal to
cap lifetime at 25,000 hours, stating that
applying an arbitrary cap discourages
manufacturer improvements to lifetime.
(Litecontrol, No. 11 at p. 1; Radcliffe
Advisors, No. 13 at p. 2; South Korea,
No. 17 at p. 3; Kritzer, No. 8 at p. 1;
Anonymous, No. 8 at p. 1; CA IOUs, No.
19 at p. 4; NEMA, Public Meeting
Transcript, No. 7 at p. 65, 72–74;
NEMA, No. 16 at p. 5; Philips, Public
Meeting Transcript, No. 7 at p. 111)
NEMA commented that applying a cap
of 25,000 hours is contrary to FTC
instruction, contradicts the recent LPrize winning lamp’s lifetime rating,38
and limits payback analysis for rebate
programs. (NEMA, No. 16 at p. 5) The
Joint Comment indicated that the
lifetime cap leaves little incentive for
manufacturers to test for longer periods
of time with larger samples to reduce
measurement uncertainty. (Joint
Comment, No. 18 at p. 5) Kritzer
pointed out that LED lamps are rapidly
improving in performance and limiting
these products to a lifetime of 25,000
hours would affect their ability to
compete with fluorescent technologies,
which advertise lifetimes as long as
40,000 hours. (Kritzer, No. 8 at p. 1)
Some interested parties suggested
alternate proposals for limiting
maximum lifetime claims. South Korea
proposed that the lifetime cap be raised
to 36,000 hours to be consistent with
IES TM–21–2011, which specifies that if
the LED sources are tested beyond 6,000
hours they can report up to 36,000
hours. (South Korea, No. 17 at p. 3)
NIST commented that the lifetime cap
should only be raised if manufacturers
can provide statistics to prove their
reported values. (NIST, Public Meeting
Transcript, No. 7 at p. 78) Alternatively,
NEMA suggested that methods for
projecting lifetime beyond 25,000 hours
could be drawn from the ENERGY
STAR solid-state lighting (hereafter
referred to as SSL) program and other
products such as electronic fluorescent
ballasts. (NEMA, No. 16 at p. 7) The
ENERGY STAR test procedure for
lifetime includes a projection method
38 The Philips L-Prize Winning LED Bulb is rated
at 30,000 hours and has undergone over 7,000 hours
of lumen maintenance testing.
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based on lumen maintenance testing of
an integrated lamp and does not require
testing of the embedded LED source. In
addition, their projection method
specifies that an LED lamp has the
potential to be rated at a lifetime greater
than 25,000 hours if additional testing
beyond the minimum required 6,000
hours of lumen maintenance testing is
conducted (see supra note 28). The Joint
Comment agreed with the need to limit
unreasonable lifetime claims and asked
DOE to work with industry to
investigate a set of confidence criteria to
define a lifetime metric. (Joint
Comment, No. 18 at p. 5) The Joint
Comment argued that the goal of the
FTC Lighting Facts label should be to
give customers the most accurate
information possible regarding the
quality and lifetime of this product, and
that establishing proper test procedures
will help ensure this happens. (Joint
Comment, No. 18 at p. 5)
After considering the comments about
the NOPR lifetime cap proposal, DOE
has removed the 25,000 hour lifetime
cap and developed a proposal where the
maximum lifetime of LED lamps
depends on the test duration. To
prevent unreasonable lifetime claims
based on a limited amount of test data,
DOE proposes that lifetime claims be
limited to no more than four times the
duration of the test period. This limit
reflects ENERGY STAR’s requirements
to support lifetime claims beyond
25,000 hours, which require a test
duration that is 25 percent of the
maximum projection. For example, to
report a projected L70 lifetime of 30,000
hours, at least 7,500 hours of testing
(and a lumen maintenance of at least 70
percent at that time) would be required.
Requiring four times the duration of the
test period is more conservative than
industry standard IES TM–21–2011 for
LED sources, which limits the L70
projection to no more than 5.5 or 6
times the testing time (depending on
sample size). A more conservative
approach is reasonable because this test
procedure applies to integrated LED
lamps rather than LED sources. DOE
invites comment on the proposed
requirement to limit lifetime claims to
four times the duration of the test
period.
j. Market Introduction
TUD commented that requiring a
minimum test duration of 6,000 hours
could delay the market introduction of
LED lamp products. (TUD, No. 15 at p.
1) In this SNOPR, DOE is proposing a
new test method which does not require
a minimum duration of testing. Rather,
DOE allows the manufacturer to
determine the test duration and then
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limits lifetime claims to four times the
test duration.
3. SNOPR Proposed Lifetime Method
In this SNOPR, DOE proposes a new
test procedure for lifetime that
addresses many of the stakeholder
concerns regarding the NOPR proposal
for measuring the lifetime of LED lamps.
This proposal is simple, straightforward,
and allows significant flexibility if
lifetimes of LED products change in the
future. As stated in section III.D.1, DOE
defines the lifetime of an LED lamp as
the time at which a lamp reaches a
lumen maintenance of 70 percent (i.e.,
70 percent of initial lumen output, or
L70). In this SNOPR, DOE proposes to
measure the lumen output of an LED
lamp rather than the LED source
contained in the lamp. Thus, the test
procedure directly measures the
performance of the actual product rather
than an internal component. This
considerably simplifies compliance
testing and provides a consistent
procedure to be used for all products.
The methodology proposed in the
SNOPR consists of four main steps: (1)
measuring the initial lumen output; (2)
operating the lamp for a period of time
(test duration); (3) measuring the lumen
output at the end of the test duration;
and (4) projecting L70 using an equation
adapted from the underlying
exponential decay function in ENERGY
STAR’s most recent specification for
integrated LED lamps, Program
Requirements for Lamps (Light Bulbs):
Eligibility Criteria—Version 1.0. (see
supra note 10) The equation projects
lifetime using the test duration and the
lumen maintenance at the end of the
test duration as inputs. The following
sections discuss the methodology in
greater detail.
a. Initial Lumen Output
Initial lumen output is the measured
amount of light that a lamp provides at
the beginning of its life, after it is
initially energized and stabilized using
the stabilization procedures in section
III.C.4.b. An initial lumen output
measurement is required to calculate
lumen maintenance, which is an input
for the lifetime projection. The test
procedure for lumen output is described
in section III.B. The methodology, test
conditions, and setup requirements are
unchanged when measuring initial
lumen output for the lifetime test
procedure.
b. Test Duration
The period of time starting
immediately after the initial lumen
output measurement and ending when
the final lumen output measurement is
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recorded, is referred to as the ‘‘test
duration’’ or time ‘‘t.’’ The test duration
does not include any time when the
lamp is not energized. If lamps are
turned off (possibly for transport to
another testing area or during a power
outage), DOE proposes that the time
spent in the off-state not be included in
the test duration. DOE does not specify
a minimum test duration or
measurement interval, so manufacturers
can customize the test duration based
on the expected lifetime of the LED
lamp. During this time, the LED lamps
are turned on (energized) and operated
for a period of time determined by the
manufacturer. To reduce test burden,
the operating conditions required
during the test duration while
measurements are not being taken are
less stringent than those required when
taking photometric measurements (e.g.,
ambient temperature). The following
sections discuss the required operating
conditions for lamp operation between
lumen output measurements in more
detail.
Ambient Temperature and Air Flow
DOE recognizes that while operating
an LED lamp, lumen output can vary
with changes in ambient temperature,
air flow, vibration, and shock. For this
reason, DOE proposes specific
requirements for quantities such as
ambient temperature and air flow for
photometric measurements in section
III.C.2. However, because lamps may
need to be operated for an extended
period of time for the purpose of
lifetime testing, DOE proposes less
stringent requirements when
measurements are not being taken. DOE
proposes that ambient temperature be
maintained between 15 °C and 40 °C.
DOE also proposes minimizing air
movement surrounding the test racks,
and that the LED lamps not be subject
to excessive vibration or shock. These
test conditions will enable reliable,
repeatable, and consistent test results
without significant test burden and are
discussed in further detail below:
To determine ambient temperature
requirements, DOE reviewed industry
standard IES LM–65–10 ‘‘Approved
Method Life Testing of Compact
Fluorescent Lamps.’’ 39 Section 4.3 of
IES LM–65–10 requires that ambient
temperature be controlled between
15 °C and 40 °C. Although industry
standard IES LM–65–10 is intended for
compact fluorescent lamps, DOE
proposes that this ambient temperature
range is appropriate for the operation of
39 ‘‘Approved Method Life Testing of Compact
Fluorescent Lamps.’’ Approved by IES on December
13, 2010.
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LED lamps because NEMA commented
that current test methods have led
industry to believe that the surrounding
air temperature and airflow does not
have a noticeable impact on long-term
LED lumen degradation. (NEMA, Public
Meeting Transcript, No. 7 at pp. 2–3;
NEMA, No. 16 at p. 2–3) DOE believes
that an ambient temperature range
between 15 °C and 40 °C encompasses
the majority of possible room
temperature conditions while limiting
test burden. Therefore, in this SNOPR,
DOE proposes that ambient temperature
be controlled between 15 °C and 40 °C.
DOE requests comments on this
proposal.
DOE proposes that LED lamp testing
racks be open and designed with
adequate lamp spacing and minimal
structural components to maintain
ambient temperature conditions.
Furthermore, similar to the
requirements in section 4.2 of IES LM–
65–10, DOE proposes minimizing
airflow surrounding the LED lamp
testing racks and that the lamps not be
subjected to excessive vibration or
shock. DOE believes that these
requirements would minimize the
impact of airflow and the physical
environment while minimizing test
burden. DOE invites comments on the
minimization of vibration, shock, and
air movement, as well as the
requirement for adequate lamp spacing
during lamp operation in order to
maintain ambient temperature
conditions.
Power Supply
DOE proposes that section 3.1 of IES
LM–79–2008 be incorporated by
reference to specify requirements for
both AC and DC power supplies. This
section specifies that an AC power
supply shall have a sinusoidal voltage
waveshape at the input frequency
required by the LED lamp such that the
RMS summation of the harmonic
components does not exceed three
percent of the fundamental frequency
while operating the LED lamp. Section
3.2 of IES LM–79–2008 also requires
that the voltage of an AC power supply
(RMS voltage) or DC power supply
(instantaneous voltage) applied to the
LED lamp shall be within ±0.2 percent
of the specified lamp input voltage.
However, DOE determined that the IES
LM–79–2008 voltage tolerances are too
burdensome to maintain for the
extended time period for which a lamp
may need to be operated to determine
lifetime. When not taking
measurements, DOE proposes to adopt
provisions similar to section 5.3 of IES
LM–65–10 which requires that the input
voltage be monitored and regulated to
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within ±2.0 percent of the rated RMS
voltage. DOE believes that this
requirement is achievable with minimal
test burden and provides reasonable
stringency in terms of power quality
based on its similarity to voltage
tolerance requirements for other lamp
types. DOE invites comments on the
proposal to adopt section 3.1 of IES LM–
79–2008 requirements for both AC and
DC power supplies. DOE also requests
comment on the requirement that input
voltage be monitored and regulated to
within ±2.0 percent of the rated RMS
voltage as specified in section 5.3 of IES
LM–65–2010.
Lamp Mounting and Orientation
DOE proposes that the LED lamps be
tested in the base-up and base-down
orientations for lumen maintenance
testing. Section III.C.3.b notes that LED
lamp test data provided by ENERGY
STAR, as well as PG&E, CLASP, and
CLTC, has revealed that there was
variation between the base-up, basedown and horizontal orientations (see
supra note 20). Of the three orientations,
analysis revealed that the base-up and
base-down orientations represent the
best (highest lumen output) and worst
(lowest lumen output) case scenarios.
Electrical Settings
DOE proposes adopting the electrical
settings in section 7.0 of IES LM–79–
2008. Section III.C.3.d details the
required electrical settings for input
voltage and how to operate lamps with
multiple modes of operation, such as
variable CCT and dimmable lamps.
Operating Cycle
Lifetime test procedures for other
lamp types sometimes require
‘‘cycling,’’ which means turning the
lamp on and off at specific intervals
over the test period. However, industry
has stated that unlike other lighting
technologies, the lifetime of LED lamps
is minimally affected by power
cycling.40 Therefore, in this SNOPR,
DOE proposes to operate the LED lamp
continuously and requests feedback on
the appropriateness of not requiring
cycling in the test procedure for
lifetime.
c. Lumen Output at the End of the Test
Duration
Any lumen output measurement after
the measurement of initial lumen
output, including that at the end of the
test duration, is measured under the
40 NEMA Comments on ENERGY STAR Program
Requirements Product Specification for Lamps
(Light Bulbs) Version 1.0, Draft 2https://
energystar.gov/products/specs/sites/products/files/
NEMA.pdf.
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d. Lumen Maintenance Calculation and
Lifetime Projection
As discussed in section III.D.1, DOE
proposes to define LED lamp lifetime as
the time required to reach a lumen
maintenance of 70 percent (L70). Lumen
maintenance is the measure of lumen
output after an elapsed operating time,
expressed as a percentage of the initial
lumen output (the definition of initial
lumen output is provided in section
III.D.3.a). DOE proposes that the lumen
maintenance at the end of the test
duration equal the lumen output at the
end of the test duration (see section
III.D.3.c) divided by the initial lumen
output.
DOE developed an equation to project
the time at which an LED lamp reaches
L70 based on the underlying exponential
decay function used in the ENERGY
STAR Program Requirements for Lamps
(Light Bulbs): Eligibility Criteria—
Version 1.0 (see supra note 10).
ENERGY STAR utilizes an exponential
decay function to calculate maximum
L70 life claims between 15,000 and
50,000 hours at increments of 5,000
hours. The ENERGY STAR procedure
requires a 6,000 hour test duration and
provides lumen maintenance thresholds
for each incremental L70 lifetime claim.
Unlike ENERGY STAR, DOE does not
have minimum lifetime requirements
for LED lamps. Therefore, to enable
reporting of lifetimes less than 15,000
hours and greater than 50,000 hours,
DOE has reorganized the underlying
ENERGY STAR equation to calculate L70
given the initial lumen output ‘‘x0’’, the
test duration ‘‘t’’, and the final lumen
output at the end of the test duration
‘‘xt’’ as inputs. DOE’s equation is
detailed below.
L70 = Time to Reach 70% Lumen
Maintenance
t = Test Duration
x0 = Initial Lumen Output
xt = Final Lumen Output at time ‘‘t’’
DOE requests comment on the
proposed equation for projecting the L70
lifetime of LED lamps.
DOE proposes that lifetime claims be
limited to no more than four times the
test duration ‘‘t.’’ For example, if an LED
lamp is tested for 6,000 hours and has
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a lumen maintenance value of 93.1
percent at that time, the L70 projection
equation indicates that the L70 lifetime
is about 30,000 hours. However, the
maximum that could be reported based
on the DOE proposal is only 24,000
hours (four times the testing time of
6,000 hours). For lumen maintenance
values less than 70 percent, including
lamp failures that result in complete
loss of light output, the SNOPR
proposes that lifetime must not be
projected; instead, the lumen
maintenance is equal to the previously
recorded lumen output measurement at
the test duration where the lumen
maintenance is greater than or equal to
70 percent. DOE also recognizes that it
is possible that the calculated lumen
maintenance at time ‘‘t’’ could be greater
than or equal to 100 percent. When this
occurs, DOE proposes that lifetime
claims be determined by the maximum
projection limit. Due to the similarity of
the DOE and ENERGY STAR lifetime
test procedures, manufacturers may
choose to utilize lumen maintenance
measurements collected for the
ENERGY STAR specification. However,
measurements must adhere to DOE’s
electrical setting requirements proposed
in section III.C.3.d and manufacturers
must include all LED lamps within the
10 lamp sample in the reported results
including lamp failures. DOE requests
comments on its proposal to limit the
maximum lifetime to four times the test
duration with no minimum test
duration.
Finally, DOE also notes that a
manufacturer can report the test
duration as measured without applying
the projection equation. This approach
applies to two scenarios. In the first
scenario, a manufacturer can test the
lamp until it reaches 70 percent lumen
maintenance and use that test duration
as the lifetime of the lamp. This is
equivalent to using the projection
equation, because the output of the
projection equation would be the same
as the test duration when lumen
maintenance of 70 percent is reached. In
the second scenario, a manufacturer can
use the test duration associated with a
lumen maintenance greater than 70
percent. This scenario is equivalent to a
manufacturer using the projection
equation, but electing to report a more
conservative value for business reasons.
Reporting of conservative values is
permitted and is also discussed in
section III.F.3.
E. Proposed Approach for Standby
Mode Power
EPCA section 325(gg)(2)(A) in part
directs DOE to establish test procedures
to include standby mode, ‘‘taking into
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consideration the most current versions
of Standards 62301 and 62087 of the
International Electrotechnical
Commission . . .’’ (42 U.S.C.
6295(gg)(2)(A)) IEC Standard 62087
applies only to audio, video, and related
equipment, but not to lighting
equipment. Thus, IEC Standard 62087
does not apply to this rulemaking, so
DOE developed this SNOPR consistent
with procedures outlined in IEC
Standard 62301, which applies
generally to household electrical
appliances. However, to (1) develop a
test method that would be familiar to
LED lamp manufacturers and (2)
maintain consistent requirements to the
active mode test procedure, DOE
referenced language and methodologies
presented in IES LM–79–2008 for test
conditions and test setup requirements.
A standby mode power measurement
is an input power measurement made
while the LED lamp is connected to the
main power source, but not generating
light (active mode). All test condition
and test setup requirements used for
active mode measurements (e.g., input
power) (see sections III.C.2 and III.C.3)
also apply to standby mode power
measurements. Once the test conditions
and setup have been implemented, the
LED lamp should be seasoned and
stabilized in accordance with the
requirements in sections III.C.4.a and
III.C.4.b of this SNOPR. After the lamp
has stabilized, the technician should
send a signal to the LED lamp
instructing it to enter standby mode
(which is defined as providing zero light
output). Standby power is then
measured in accordance with section 5
of IEC 62301.
F. Basic Model, Sampling Plan, and
Reported Value
1. Basic Model
In this SNOPR, DOE proposes
amendments to the term ‘‘basic model’’
to include LED lamps. ‘‘Basic model’’ is
currently defined (with some
exceptions) to mean all units of a given
type of covered product (or class
thereof) manufactured by one
manufacturer, having the same primary
energy source, and which have
essentially identical electrical, physical,
and functional (or hydraulic)
characteristics that affect energy
consumption, energy efficiency, water
consumption, or water efficiency; and
with respect to general service
fluorescent lamps, general service
incandescent lamps, and reflector
lamps: Lamps that have essentially
identical light output and electrical
characteristics—including lumens per
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conditions and setup described in
section III.B. DOE proposes stabilizing
the LED lamp before measuring lumen
output at the end of the test duration.
Section III.C.4.b details the LED lamp
stabilization procedure.
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watt (lm/W) and color rendering index
(CRI). 10 CFR 430.2
DOE proposes to add a specification
for LED lamps in the definition of basic
model in order to provide further
guidance on the electrical, physical, and
functional characteristics that constitute
a basic model. Specifically, DOE
proposes that a basic model for an
integrated LED lamp should represent
lamps that have essentially identical
light output and electrical
characteristics including lumens per
watt, CRI, CCT, and lifetime. Because
these are the general characteristics by
which manufacturers identify their
lamps in catalogs and marketing
material, DOE believes these parameters
should be used to group lamps of the
same type.
DOE proposes to qualify the term
‘‘basic model’’ in 10 CFR 430.2 for LED
lamps as lamps that have essentially
identical light output and electrical
characteristics—including lumens per
watt (lm/W), color rendering index
(CRI), correlated color temperature
(CCT), and lifetime.
DOE requests comments on the
revision to the definition of ‘‘basic
model’’ to address LED lamps.
2. Sampling Plan
In the NOPR, DOE proposed a
sampling plan for LED lamps to
determine input power, lumen output,
and CCT, and a separate sampling plan
for LED sources to determine lifetime.
DOE proposed testing a minimum of 21
LED lamps to determine the input
power, lumen output, and CCT. DOE
proposed that manufacturers select a
minimum of three lamps per month for
seven months of production out of a 12
month period. If lamp production
occurs in fewer than seven months of
the year, three or more lamps must be
selected for each month that production
occurs, distributed as evenly as possible
to meet the minimum 21 unit
requirement. The seven months need
not be consecutive and could be a
combination of seven months out of the
12 months. Sample sizes greater than 21
must be multiples of three so that an
equal number of lamps were tested in
each orientation (based on the lamp
orientation requirements in the NOPR).
77 FR at 21049 (April 9, 2012)
To determine the lifetime of LED
lamps, DOE proposed in the NOPR that
the sample size for testing LED sources
be as specified in section 4.2 of IES TM–
21–2011. The IES TM–21–2011 industry
standard requires a minimum of ten
units to be tested, but recommends a
sample set of 20 units for projecting the
lifetime of the LED sources. The method
of projection specified in IES TM–21–
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2011 cannot be used for less than ten
units. 77 FR at 21049
Regarding the sampling plan proposal
for lumen output, CCT, and wattage
testing, NEMA and P.R. China
commented that the sampling plan
should be based on the ENERGY STAR
specification for integral LED lamps,
which requires a sample size of 10: five
base-up and five base-down. (NEMA,
Public Meeting Transcript, No. 7 at p.
49; NEMA, No. 16 at p. 8; P.R. China,
No. 12 at pp. 4–5) In addition, ENERGY
STAR has no requirements for how
lamps are selected for testing. NEMA
opposed gathering product samples over
the course of a year because the
associated time to gather and test
samples is much greater than a year.
(NEMA, No. 16 at p. 8) NEMA
recommended that DOE not copy the
sampling requirements from other
lighting technology rules. (NEMA, No.
16 at p. 9) In addition, NEMA, Cree,
OSI, and South Korea commented that
solid-state lighting is still an emerging
technology and requiring large test
samples and long testing time will
significantly delay market introduction.
(NEMA, Public Meeting Transcript, No.
7 at p. 51; Cree, Public Meeting
Transcript, No. 7 at p. 52; OSI, Public
Meeting Transcript, No. 7 at p. 53;
South Korea, No. 17 at pp. 2–3) Philips
added that LED lamp designs are
evolving rapidly and often product
models are produced for less than a year
before they are replaced by more
efficient designs. (Philips, Public
Meeting Transcript, No. 7 at p. 53)
Lutron and Cree also commented that it
is very important that the LED lamp test
procedure comply with FTC labeling
requirements, which allow for
provisional labeling prior to completing
all testing. (Lutron, Public Meeting
Transcript, No. 7 at pp. 51–52; Cree,
Public Meeting Transcript, No. 7 at p.
52) Alternatively, GE suggested that
DOE could retain the 21 lamp sample
size, remove the requirement to collect
products for testing over the course of
a year, and only test product samples
from initial production. (GE, Public
Meeting Transcript, No. 7 at pp. 52–53)
Radcliffe Advisors commented that a 21
lamp sample size is small and does not
have a rational basis. They
recommended that DOE give
consideration to the relationship
between accuracy and the choice of
sample size. (Radcliffe Advisors, No. 13
at p. 1)
In reference to the sampling plan for
determining the lifetime of LED lamps,
NEMA agreed with DOE’s summary of
IES TM–21–2011 stating that it
recommends a minimum of 20 LED
sources be used during IES LM–80–2008
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testing to allow for lifetime projections
of up to 36,000 hours. IES TM–21–2011
allows fewer LED sources to be used,
but reduces the maximum projection
value to 25,000 hours. (NEMA, Public
Meeting Transcript, No. 7 at pp. 113–
114) An Anonymous commenter
suggested allowing manufacturers to
exclude from the overall average one
unit that fails during lifetime testing.
(Anonymous, No. 8 at p. 1)
In this SNOPR, DOE proposes a new
test procedure for lifetime that measures
the performance of an LED lamp and not
its subcomponents (i.e., the LED
source). Therefore, DOE determined it
did not need different sampling
requirements for lifetime relative to the
non-lifetime metrics. These sampling
requirements proposed in the SNOPR
for all metrics are described below.
In order to address concerns regarding
the sample size requirements in the
NOPR proposal, DOE collected
photometric test data from two sources,
the first data set was provided by
ENERGY STAR, and the second from a
collaborative effort between PG&E,
CLASP, and CLTC (see supra note 20).
These test data, combined, represent 10
samples of 47 different LED lamp
products each. Statistical analysis of the
LED lamp test data indicates that a
minimum sample size of 10 lamps is
appropriate to estimate the average
input power, initial lumen output,
efficacy, CCT, and CRI given the
variation present in the data set.
Standby mode power is assumed to vary
to the same degree as input power
(active mode). In addition, 37 LED
lamps from the data set were tested for
lumen output after 3,000 hours of
operation. DOE used this data to help
determine the sample size required for
estimating the lifetime of the LED lamp.
Analysis of the test data revealed that a
minimum sample size of 10 should also
be sufficient to estimate lumen output
for the LED lamp after an elapsed
operating time. In addition, requiring a
minimum sample size of 10 LED lamps
aligns with ENERGY STAR’s sampling
procedure. Therefore, the SNOPR
proposes testing a minimum of 10 LED
lamps to determine the input power,
lumen output, efficacy, CCT, CRI,
lifetime, and standby mode power. DOE
also proposes that all LED lamps within
the sample, including those that fail
prematurely, be included in the
reported results for input power, lumen
output, efficacy, CCT, CRI, lifetime, and
standby mode power. DOE’s view is that
LED lamp failure should not be exempt
from reporting, because this would
potentially mislead consumers,
particularly with respect to lamp
lifetime. Furthermore, DOE proposes
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¯
and, x is the sample mean; n is the
number of units; and xi is the ith unit.
The LED lamp test data provided by
ENERGY STAR as well as PG&E,
CLASP, and CLTC (see supra note 20)
indicates variability within a sample for
measured lumen output, both at the
initial lumen output reading and after
an elapsed operating time. Therefore,
DOE proposes that the reported value of
lumen output as well as the reported
value of lifetime be equal to the lower
of the average lumen output of the
sample set and the lower 99 percent
confidence limit (LCL) of the sample
mean divided by 0.97.41 Additionally,
the LED lamp test data indicates that
variability in the CRI and efficacy
should be expected within a sample.
Therefore, DOE proposes that the
reported value of CRI be equal to the
lower of the average CRI of the sample
set and the lower 99 percent confidence
limit of the sample mean divided by
0.99, and that the reported value of
efficacy be equal to the lower of the
average efficacy of the sample set and
the lower 99 percent confidence limit of
the sample mean divided by 0.98.42
41 Based on the collected LED lamp test data,
provided by ENERGY STAR as well as PG&E,
CLASP, and CLTC, DOE expects that the variability
for measured lumen output is within a margin of
3 percent. Thus, DOE proposes to divide the LCL
value by 0.97 to adjust for this expected variation.
For example, if the mean lumen output of 10 LED
lamp units is 100 lumens with a standard deviation
of three, the LCL value will be three percent lower
than the mean, and dividing by 0.97 would result
in a value that is equal to the lumen output mean
of 100 lumens. In this case, the LCL divided by 0.97
is equal to the sample mean, and 100 lumens would
be reported. If the variation within a sample set
exceeds DOE’s expectation, the sample set would
have a smaller LCL, such that a value less than 100
lumens would be reported.
42 Based on the collected LED lamp test data,
provided by ENERGY STAR as well as PG&E,
CLASP, and CLTC, DOE expects that variability for
CRI is within a margin of 1 percent and for efficacy
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¯
where, x is the sample mean; s is the
sample standard deviation; n is the
number of samples; and t0.99 is the t
statistic for a 99 percent one-tailed
confidence interval with n ¥ 1 degrees
of freedom.
Similarly, the LED lamp test data
provided by ENERGY STAR as well as
PG&E, CLASP, and CLTC (see supra
note 20) indicates variability within a
sample for measured input power.
Therefore, DOE proposes that the
reported value of input power and
standby mode power be equal to the
greater of the average lumen output of
the sample set and the upper 99 percent
confidence limit (UCL) of the sample
mean divided by 1.01.43 DOE proposes
the following equation to calculate UCL:
¯
where, x is the sample mean; s is the
sample standard deviation; n is the
number of samples; and t0.99 is the t
statistic for a 99 percent one-tailed
confidence interval with n ¥ 1 degrees
of freedom.
The proposed reported value
requirements for lumen output, input
power, CRI, lamp efficacy, lifetime, and
standby mode power represent the
‘‘best’’ value that manufacturers may
report. For lumen output, CRI, lamp
efficacy, and lifetime, the reported value
may be rounded to a lower value. For
input power and standby mode power,
the reported value may be rounded to
higher values. CCT must be reported as
calculated, as the concept of a
conservative value does not apply to
these metrics. If conservative rounding
is used, manufacturers must report the
conservatively rounded value to DOE so
that values reported to DOE match those
used in all representations.
DOE invites interested parties to
comment on the proposed reported
value requirements.
is within a margin of 2 percent. Thus, DOE
proposes to divide the LCL value for CRI by 0.99
and the LCL value for efficacy by 0.98 to adjust for
this expected variation.
43 Based on the collected LED lamp test data,
provided by ENERGY STAR as well as PG&E,
CLASP, and CLTC, DOE expects that the variability
for measured input power is within a margin of 1
percent. Thus, DOE proposes to divide the UCL
value by 1.01 to adjust for this expected variation.
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G. Rounding Requirements
In the SNOPR, DOE proposes
rounding requirements for determining
lumen output, input power, efficacy,
CCT, CRI, estimated annual energy cost,
lifetime, and standby mode power. Each
of these is discussed in the following
sections.
1. Lumen Output
In the NOPR, DOE proposed that the
lumen output of all units be averaged
and the value be rounded to the nearest
tens digit. 77 FR at 21044 NEMA, OSI,
and Cooper Lighting indicated that tight
tolerances on rounding requirements are
undesirable. (NEMA, No. 16 at p. 4; OSI,
Public Meeting Transcript, No. 7 at pp.
55–56; Cooper, Public Meeting
Transcript, No. 7 at p. 56) NEMA
commented that this will only set up
unrealistic expectations of accuracy and
repeatability. (NEMA, No. 16 at p. 4) In
their written comment, NEMA
suggested that for lumen output DOE
round values of 0–499 to the nearest five
lumens, 500–999 to the nearest ten
lumens, and 1000–9999 lumens to three
significant digits. If the lumen output is
greater than or equal to 10,000, NEMA
recommended that DOE round to two
significant digits. (NEMA, No. 16 at p.
4) ASAP offered another solution,
suggesting that DOE determine
appropriate rounding requirements
based on the resolution of the test
measurement. (ASAP, Public Meeting
Transcript, No. 7 at p. 56)
DOE agrees that rounding
requirements should reflect realistic
expectations of accuracy and
repeatability. Based on a review of
commercially available LED lamp
products as well as testing equipment
measurement capabilities, DOE
determined that three significant figures
is an achievable level of accuracy for
LED lamps. Therefore, for this SNOPR,
DOE proposes rounding of three
significant figures 44 so that lumen
outputs of all sizes are provided a
similar level of specificity.
2. Input Power
In the NOPR, DOE proposed that the
input power of all test units be averaged
and the average value be rounded to the
nearest tenths digit. 77 FR at 21044
NEMA agreed that this is acceptable.
(NEMA, No. 16 at p. 4) In the SNOPR,
DOE maintains its proposal for the
rounding requirements for input power.
44 If the number 3,563 is rounded to three
significant digits it becomes 3,560—with the 3, 5,
and 6 being the significant digits.
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3. Reported Value
As in the NOPR (77 FR at 21049),
DOE proposes that the CCT of the units
be averaged and that average be rounded
as specified in section III.G. The average
CCT is calculated using the following
equation:
DOE proposes the following equation to
calculate LCL for lumen output,
lifetime, CRI, and efficacy:
EP03JN14.012</GPH>
that no selection process be required for
the LED lamp test procedure. Lamps for
testing can be selected at any time from
production units. DOE invites interested
parties to comment on the
appropriateness of adopting a minimum
sample size of 10 LED lamps for input
power, lumen output, efficacy, CCT,
CRI, lifetime, and standby mode power.
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3. Lamp Efficacy
In the SNOPR, DOE proposes that the
efficacy of LED lamps be rounded to the
nearest tenth as this is consistent with
rounding for other lighting technologies
and is achievable with today’s
equipment.
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4. Correlated Color Temperature
In the NOPR, DOE proposed that the
CCT of all units be averaged and the
value be rounded to the tens digit. 77 FR
at 21044 However, NEMA argued that
most consumers can only distinguish
lamp color temperature variations on
the order of 100 K. Therefore, NEMA
suggested that any CCT rating be
rounded to the nearest hundreds digit.
They stated that DOE’s proposal of
rounding CCT values to the nearest tens
digit would cause undue consumer
confusion when comparing products.
(NEMA, No. 16 at p. 4)
In rulemakings for other lamp types,
DOE established CCT rounding
requirements to the nearest tens place
based on the precision of the test
procedure. In a rulemaking for general
service fluorescent lamps, DOE
consulted with NIST and concluded
that, because all laboratories are able to
measure CCT to three significant figures
(a typical value is four digits), DOE
should require manufacturers to round
CCT to the nearest ten kelvin. 74 FR
31829, 31835 (July 6, 2009). In this
SNOPR, DOE continues this
requirement and proposes rounding to
the nearest tens digit for measurements
of individual lamp units.
However, DOE also recognizes
NEMA’s comment that consumers may
not be able to distinguish changes in
CCT as small as 10 K. By using CCT
values rounded to the nearest 10 K,
consumers could be confused, since
products with different CCT values may
not have a perceptible difference in
appearance. DOE does not have data or
market studies quantifying the smallest
difference in CCT that can be perceived
by consumers, but welcomes comment
on this topic. DOE has observed that the
vast majority of CCT values provided in
LED product literature are rounded to
the nearest hundreds place. DOE
proposes to round the reported value
(i.e., certified or rated value) of the
entire sample (all lamp units
collectively) to the nearest hundreds
place to avoid consumer confusion
around any representations of CCT. DOE
seeks comment on this proposal.
5. Color Rendering Index
In the SNOPR, DOE proposes that the
CRI of LED lamps be rounded to the
nearest whole number as this is
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consistent with rounding for other
lighting technologies.
6. Annual Energy Cost
Consistent with FTC’s final rule that
established the Lighting Facts label (75
FR 41702 (July 19, 2010)), in the NOPR
DOE proposed calculating the estimated
annual energy cost for LED lamps,
expressed in dollars per year, as the
product of the average input power, in
kilowatts, the electricity cost rate of 11
cents per kilowatt-hour, and the
estimated average annual use at three
hours per day, which is 1,095 hours per
year. 77 FR at 21044 DOE proposed that
the estimated annual energy cost be
rounded to the nearest cent because the
cost of electricity is specified to the
nearest cent.
Although NEMA pointed out that the
usage patterns and associated hours
used in the NOPR do not agree with
DOE’s 2010 U.S. Lighting Market
Characterization,45 NEMA agreed with
DOE’s proposed formula to calculate
annual energy cost and the associated
rounding to the nearest cent. (NEMA,
No. 16 at p. 4) For consistency with
FTC’s calculations for other lamp types,
DOE proposes to maintain the rounding
requirements for estimated annual
energy cost.
7. Lifetime
In the SNOPR, DOE proposes that
lifetime be rounded to the nearest whole
hour. This is consistent with the unit of
time used for lifetime metrics for other
lamp technologies and is a level of
accuracy a laboratory is capable of
measuring with a standard time-keeping
device.
8. Life
In the NOPR, DOE proposed that the
life of LED lamps be calculated in terms
of years based on three hours per day of
operation. 77 FR at 21048 This is
consistent with the FTC Lighting Facts
label requirements for other lamp
technologies. DOE also proposed that
the resulting value be rounded to the
nearest tenth of a year. Cooper Lighting
recommended that DOE consider
rounding to two significant digits rather
than to tenths of a year to better capture
the range in product lifetimes across the
different lighting technologies. (Cooper,
Public Meeting Transcript, No. 7 at p.
109) NEMA stated that tight rounding
tolerances only set up unrealistic
expectations for the performance of LED
lamps and indicated that rounding the
45 Navigant Consulting, Inc., ‘‘2010 U.S. Lighting
Market Characterization’’ Prepared for the DOE
Solid-State Lighting Program, January, 2012. https://
apps1.eere.energy.gov/buildings/publications/pdfs/
ssl/2010-lmc-final-jan-2012.pdf.
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lifetime to the nearest tenth of a year
can be confusing to customers if they do
not realize that the lifetime values are
based on three hours of use per day.
(NEMA, No. 16 at p. 4, 8) Furthermore,
both NEMA and the CA IOUs argued
that lifetime be reported in hours,
because year-ratings are confusing to
consumers, who might assume a
calendar lifetime rather than a lifetime
based on hourly use. (NEMA, No. 16 at
p. 8; CA IOUs, No. 19 at p. 4) DOE
proposes to retain the rounding
requirements provided in the NOPR
which states that the life of LED lamps
be calculated in terms of years based on
three hours per day of operation and
that the resulting value be rounded to
the nearest tenth of a year. As stated
previously, this is consistent with the
FTC Lighting Facts label requirements
for other lamp technologies. FTC
determines how the prescribed metrics
appear on its Lighting Facts label, as
well as the overall format of the label.
Interested parties may contact FTC for
concerns regarding the Lighting Facts
label.
9. Standby Mode Power
In the SNOPR, DOE proposes
rounding standby mode power to the
nearest tenths place, consistent with its
proposal for rounding input power for
active mode in section III.G.2.
H. Acceptable Methods for Initial
Certification or Labeling
Because testing for lifetime could
require six months or more from start to
finish, DOE anticipates the potential
need for initial certification
requirements (such as those currently
provided in 10 CFR 429.12(e)(2)) or
early or interim labeling requirements.
Any initial certification requirements, if
adopted, would be established by the
ongoing general service lamp energy
conservation standard rulemaking. See
78 FR 73737 (Dec. 9, 2013) Early
labeling requirements, if adopted,
would be established by FTC. However,
to support these potential needs, DOE
considered acceptable methods for use
with initial certification or labeling.
Test methods with shorter overall
start to finish time requirements are not
available for measuring or projecting
lifetime. Therefore, initial certification
and labeling is best substantiated by
comparisons to similarly designed
lamps produced by the same
manufacturer. A future rulemaking
addressing standards for LED lamps
could require manufacturers to provide
a description of why the comparison to
another lamp is valid, including a
description of the expected impact of
design differences on lifetime (if any).
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DOE requests comment on the notion of
early certification and labeling, and the
acceptable methods for substantiating
those claims.
I. Laboratory Accreditation
In the NOPR, DOE did not require
testing LED lamps by an accredited
laboratory. DOE received several
comments during the May 2012 public
meeting as well as written comment
submissions inquiring whether DOE
plans to require using accredited
laboratory facilities.
Cree commented that DOE should
consider requiring certification of
laboratories that are performing these
tests as this is a requirement for the
ENERGY STAR program. (Cree, Public
Meeting Transcript, No. 7 at p. 57) OSI
clarified that DOE should consider
laboratory accreditation, and not a
certification program. Accreditation is
the process by which an authoritative
third party gives formal recognition that
a body or person is competent to carry
out specific testing. Certification is a
procedure by which a third party gives
written assurance (certificate of
conformity) that a product, process, or
service conforms to specified
requirements. (OSI, Public Meeting
Transcript, No. 7 at pp. 60–61) NIST
commented that laboratories are
accredited for industry standards. If
testing in accredited laboratories is
required for the DOE’s LED test
procedure, this could confuse clients
expecting industry standards to be
followed without modification. (NIST,
Public Meeting Transcript, No. 7 at p.
104) South Korea requested that in the
final rule DOE detail its certification
procedures, its requirements for testing
laboratories, its designation process for
testing laboratories, and future
prospects concerning these matters.
(South Korea, No. 17 at p. 4) Finally,
Samsung suggested that DOE accept
testing by existing laboratories that have
received accreditation from the
International Laboratory Accreditation
Cooperation (ILAC). They argued that
the ILAC promotes international
acceptance of test results and inspection
reports. (Samsung, No. 14 at p. 2)
Regarding the National Voluntary
Laboratory Accreditation Program
(NVLAP) accreditation, DOE proposes
in the SNOPR to require lumen output,
input power, lamp efficacy, CCT, CRI,
lifetime, and standby mode power (if
applicable) testing be conducted by test
laboratories accredited by NVLAP or an
accrediting organization recognized by
ILAC. NVLAP is a member of the ILAC
organization, so test data collected by
any laboratory accredited by an
accrediting body recognized by ILAC
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would be acceptable. DOE requests
comment on its proposal to require
accreditation by NVLAP or an entity
recognized by ILAC, and on the costs
and benefits associated with such a
requirement.
The FTC has developed a Lighting
Facts Label to help inform consumers
about the efficiency and performance
attributes of general service lamp
products. The label became effective
January 1, 2012, and requires that a
lamp’s lumen output, energy cost,
lifetime, CCT and wattage appear on the
product packaging. Concerns regarding
the FTC Lighting Facts Label
requirements were raised at the May
2012 NOPR public meeting and in
several comment submissions. These
comments pertained to the physical
appearance and content displayed on
the FTC Lighting Facts Label, the time
it would take for FTC to certify LED
lamp testing results, and whether using
lumen maintenance as a proxy for
lifetime could confuse or mislead
consumers. The comments received are
highlighted below:
• OSI commented that FTC needs to
take into account that product
information on small packages is often
printed too small, making the
information illegible and/or difficult to
identify. (OSI, Public Meeting
Transcript, No. 7 at p. 81)
• An Anonymous commenter asked
for DOE to indicate how long it would
take FTC to certify the results and grant
permission to advertise the lifetime
values required for the FTC Lighting
Facts label. (Anonymous, No. 8 at p. 1)
• NEMA, Radcliffe Advisors, OSI,
Cooper Lighting, NEEA, the Joint
Comment, and the CA IOUs commented
that the proposed definition of lifetime
would not be directly comparable to
other general service lamp products,
which could mislead or confuse
consumers. (NEMA, Public Meeting
Transcript, No. 7 at pp. 76–77; NEMA,
No. 16 at p. 2; Radcliffe Advisors, No.
13 at p. 1; OSI, Public Meeting
Transcript, No. 7 at pp. 74–75; Cooper
Lighting, Public Meeting Transcript, No.
7 at p. 77; NEEA, No. 20 at p. 2; Joint
Comment, No. 18 at pp. 1–2; CA IOUs,
No. 19 at p. 4) Cree, Radcliffe Advisors,
and the CA IOUs recommend that for
LED lamps, FTC consider changing its
label to ‘‘lumen maintenance’’ rather
than ‘‘lifetime,’’ or not provide a
lifetime value at all. (Cree, Public
Meeting Transcript, No. 7 at p. 66, 67;
Radcliffe Advisors, No. 13 at p. 1; CA
IOUs, No. 19 at p. 4, 5) OSI pointed out
that the FTC Lighting Facts label
provides the opportunity to educate
consumers on the meaning of lumen
maintenance and how this differs from
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metrics used to define lifetime for other
lighting products. (OSI, Public Meeting
Transcript, No. 7 at pp. 74–75)
DOE recognizes these concerns about
the FTC Lighting Facts label. However,
DOE does not have authority over how
to display metrics on the FTC Lighting
Facts label or the format of the label.
Interested parties may contact FTC
about these issues.
J. State Preemption for Efficiency
Metrics
In the NOPR, DOE proposed test
procedures for measuring lumen output
and input power, and also specified
testing dimmable lamps at full light
output. 77 FR 21028 (April 9, 2012)
Only those metrics required for the FTC
Lighting Facts label were included in
the NOPR test procedure. The FTC
Lighting Facts label does not require
reporting of metrics such as power
factor, total harmonic distortion (THD),
and dimming; therefore none were
included in the NOPR test procedure for
LED lamps. However, commenters
noted that these metrics may appear in
state mandates in the future, and
therefore recommended they be
included in DOE’s test procedure for
LED lamps in order to avoid state
preemption.
The CA IOUs commented that DOE
not preempt California from developing
test procedures for other performance
metrics such as efficacy, power factor,
THD, and dimming. The CA IOUs
commented that including in DOE’s
proposal test methods for power factor,
THD, and dimming would likely require
significant additional time and industry
coordination. They asked that DOE
specifically identify these metrics and
procedures as exempt from preemption.
(CA IOUs, No. 19 at p. 2, 3)
Representations about the energy
consumption of an LED lamp must
fairly disclose the results of testing in
accordance with the DOE test
procedure. See 42 U.S.C. 6293(c). The
DOE test procedure for LED lamps will
preempt any state regulation regarding
the testing of the energy efficiency of
LED lamps. See 42 U.S.C. 6297(a)(1).
States that have regulations mandating
efficiency standards for LED lamps must
therefore use the DOE test procedure
when providing for the disclosure of
information with respect to any measure
of LED lamp energy consumption. To
support the general service lamp
rulemaking, DOE proposes to define a
calculation for the efficacy of an LED
lamp as measured initial lamp lumen
output in lumens divided by measured
lamp input power in watts. See section
III.C.4.d for details regarding the
calculation for efficacy of an LED lamp.
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K. Effective and Compliance Date
If adopted, the effective date for this
test procedure would be 30 days after
publication of the test procedure final
rule in the Federal Register. Pursuant to
EPCA, manufacturers of covered
products must use the applicable test
procedure as the basis for determining
that their products comply with the
applicable energy conservation
standards adopted pursuant to EPCA
and for making representations about
the efficiency of those products. (42
U.S.C. 6293(c); 42 U.S.C. 6295(s)) For
those energy efficiency or consumption
metrics covered by the DOE test
procedures, manufacturers must make
representations in accordance with the
DOE test procedure methodology and
sampling plan beginning 180 days after
publication of the final rule in the
Federal Register.
IV. Procedural Issues and Regulatory
Review
2003. As discussed in more detail
below, DOE found that because the
proposed test procedures have not
previously been required of
manufacturers, all manufacturers,
including small manufacturers, may
potentially experience a financial
burden associated with this new testing
requirement. While examining this
issue, DOE determined that it could not
certify that the proposed rule, if
promulgated, would not have a
significant impact on a substantial
number of small entities. Therefore,
DOE has prepared an IRFA for this
rulemaking. The IRFA describes the
potential impacts on small businesses
associated with LED lamp testing and
labeling requirements. DOE has
transmitted a copy of this IRFA to the
Chief Counsel for Advocacy of the Small
Business Administration (SBA) for
review.
1. Estimated Small Business Burden
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A. Review Under Executive Order 12866
The Office of Management and Budget
(OMB) has determined that test
procedure rulemakings do not constitute
‘‘significant regulatory actions’’ under
section 3(f) of Executive Order 12866,
Regulatory Planning and Review, 58 FR
51735 (Oct. 4, 1993). Accordingly, this
action was not subject to review under
the Executive Order by the Office of
Information and Regulatory Affairs
(OIRA) in the Office of Management and
Budget.
B. Review under the Regulatory
Flexibility Act
The Regulatory Flexibility Act (5
U.S.C. 601 et seq.) requires preparation
of an initial regulatory flexibility
analysis (IRFA) for any rule that by law
must be proposed for public comment,
unless the agency certifies that the rule,
if promulgated, will not have a
significant economic impact on a
substantial number of small entities. As
required by Executive Order 13272,
‘‘Proper Consideration of Small Entities
in Agency Rulemaking,’’ 67 FR 53461
(August 16, 2002), DOE published
procedures and policies on February 19,
2003, to ensure that the potential
impacts of its rules on small entities are
properly considered during the DOE
rulemaking process. 68 FR 7990. DOE
has made its procedures and policies
available on the Office of the General
Counsel’s Web site: https://energy.gov/
gc/office-general-counsel.
DOE reviewed the test procedures
considered in this SNOPR under the
provisions of the Regulatory Flexibility
Act (RFA) and the policies and
procedures published on February 19,
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SBA has set a size threshold for
electric lamp manufacturers to describe
those entities that are classified as
‘‘small businesses’’ for the purposes of
the RFA. DOE used the SBA’s small
business size standards to determine
whether any small manufacturers of
LED lamps would be subject to the
requirements of the rule. 65 FR 30836,
30849 (May 15, 2000), as amended at 65
FR 53533, 53545 (Sept. 5, 2000) and
codified at 13 CFR part 121. The size
standards are listed by North American
Industry Classification System (NAICS)
code and industry description and are
available at www.sba.gov/sites/default/
files/Size_Standards_Table.pdf. LED
lamp manufacturing is classified under
NAICS 335110, ‘‘Electric Lamp Bulb
and Part Manufacturing.’’ The SBA sets
a threshold of 1,000 employees or less
for an entity to be considered as a small
business for this category.
In the NOPR, DOE identified 17
potential small businesses that
manufacture LED lamps. In total, DOE
estimated that the use of the NOPR test
method for determining light output,
input power, and CCT would result in
testing-related labor costs of $57,000 for
each of the identified small businesses.
In addition, DOE estimated that the test
method described in the NOPR for
determining lifetime would result in
related labor costs of $11,000 for each
manufacturer. Finally, in the NOPR,
DOE estimated initial setup costs of
$12,000. DOE also indicated that the
setup cost would be a one-time cost to
manufacturers and that the labor costs
to perform testing would be smaller
than $68,000 after the first year of
testing. 77 FR at 21050–1 (April 9, 2012)
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OSI indicated that they believe the
number of impacted small businesses is
greater than DOE’s estimate of 17 and
speculated that the actual number could
be between two and ten times greater.
(OSI, Public Meeting Transcript, No. 7
at pp. 117–118) NEMA suggested that
DOE contact Jim Brodrick, Program
Manager of the U.S. DOE SSL program,
to help determine a better estimate for
the total number of small businesses
that will likely be affected by
implementing this test procedure.
(NEMA, Public Meeting Transcript, No.
7 at p. 119)
For this SNOPR, DOE reexamined the
number of small businesses that will
potentially be affected by the LED lamps
test procedure. This reevaluation
indicated that the test procedure
requirements proposed in this SNOPR
will apply to about 41 small business
manufacturers of LED lamps. DOE
compiled this revised list of
manufacturers by reviewing the DOE
LED Lighting Facts label list of partner
manufacturers,46 the SBA database,
ENERGY STAR’s list of qualified
products,47 and performing a general
search for LED manufacturers. DOE
determined which companies
manufacture LED lamps by reviewing
company Web sites, the SBA Web site
when applicable, calling companies
directly, and/or reviewing the Hoovers
Inc. company profile database. Through
this revised process, DOE identified 41
small businesses that manufacture LED
lamps. DOE was also able to collect
annual revenue estimates for several of
the small business LED lamp
manufacturers using the Hoovers.com
company profile database. DOE
determined that the median revenue of
the identified small business
manufacturers is $890,000.48 DOE
requests comment on the estimated
number of small businesses that would
be impacted by the proposed
rulemaking.
DOE also received several comments
about the estimate of testing burden. GE,
Feit, and OSI expressed concern that
DOE was underestimating the cost
burden to small manufacturers because
the costs associated with NOPR
Approach 4 for lifetime testing would be
significant if IES LM–80–2008 data were
unavailable. (GE, Public Meeting
Transcript, No. 7 at p. 117; Feit, Public
Meeting Transcript, No. 7 at p. 120; OSI,
46 DOE LED Lighting Facts Partner List, https://
www.lightingfacts.com/Partners/Manufacturer.
47 ENERGY STAR Qualified Lamps Product List,
https://downloads.energystar.gov/bi/qplist/Lamps_
Qualified_Product_List.xls?dee3-e997.
48 According to Hoovers.com, there are some
small business LED lamp manufacturers with
revenue as little as $120,000 per year.
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Public Meeting Transcript, No. 7 at p.
117) ICF International commented that
DOE’s estimate for the cost of initial
setup was low. ICF International
estimated that if a manufacturer were to
purchase all required testing equipment,
train personnel to operate it, and then
go through the accreditation process, it
could cost more than $100,000. (ICF
International, Public Meeting
Transcript, No. 7 at p. 119, 120) Cree
and Intertek also commented that
instrumentation costs could be
significant, pointing out that a Type C
goniophotometer could cost as much as
$200,000 and that a two meter
integrating sphere with accessories
could cost about $60,000. (Cree, Public
Meeting Transcript, No. 7 at p. 120;
Intertek, Public Meeting Transcript, No.
7 at pp. 121–122) In addition to
instrumentation costs, an anonymous
commenter also indicated that the cost
of storing inventory during lifetime
testing would be significant and should
be included in the cost burden estimate.
(Anonymous, No. 8 at p. 1) When
estimating the burden to small
manufacturers, NEMA suggested that
DOE also include FICA taxes,
unemployment taxes, workman’s
compensation, health care insurance,
holiday and vacation time, and
retirement benefits in addition to the
office, laboratory, equipment, and other
overhead costs for the engineers and
their support staff. (NEMA, No. 16 at p.
8) Finally, GE commented that it would
be unlikely that small business
manufacturers would want to set up an
accredited laboratory for testing. They
speculated that small manufacturers
would likely send their LED lamps out
for third party testing. (GE, Public
Meeting Transcript, No. 7 at p. 115)
In the NOPR, DOE determined that
the labor rate to create the initial setup
and conduct the testing for input power,
lumen output, CCT, and lifetime of LED
lamps would be $39.79 per hour.49 77
FR at 21050 However, in its analysis for
the SNOPR, DOE determined that an
electrical engineer is likely over
qualified, and would not be hired by
manufacturers to conduct these required
tasks. DOE’s view is that an electrical
engineering technician is a better
representation of the personnel likely to
perform the initial setup and required
tests for LED lamps. DOE estimated that
the wages for an electrical engineering
technician are $24.18 per hour.49 This
49 Obtained from the Bureau of Labor Statistics
(National Compensation Survey: Occupational
Earnings in the United States 2008, U.S.
Department of Labor (August 2009), Bulletin 2720,
Table 3 (‘‘Full-time civilian workers,’’ mean and
median hourly wages) https://bls.gov/ncs/ocs/sp/
nctb0717.pdf.
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cost is only representative of the hourly
billing rate for an electrical engineering
technician and does not include any
other compensation costs. DOE
estimated that providing additional
benefits 50 would add 31 percent 51 to
the overall cost to the manufacturer,
increasing the cost of employing an
electrical engineering technician to
$31.68 per hour. For the SNOPR, DOE
also applied this labor rate to
measurement of standby mode power.
DOE estimates that the labor costs
associated with conducting the input
power, lumen output, CCT, CRI, and
standby mode power testing contribute
to overall burden. However, DOE
believes that calculating the efficacy of
an LED lamp does not result in any
incremental testing burden beyond the
cost of carrying out lumen output and
input power testing. DOE estimates that
testing for input power, lumen output,
CCT, CRI, and standby mode would
require approximately four hours per
lamp by an electrical engineering
technician. DOE expects standby mode
power testing to require a negligible
incremental amount of time in addition
to the time required for the other
metrics. Therefore, DOE maintained its
estimate of four hours per lamp used in
the NOPR (77 FR at 21050) for testing
for input power, lumen output, CCT,
and CRI. DOE estimates about 41 small
business manufacturers of LEDs would
be impacted, each offering about 23
different basic models. In total, using
the DOE test method to determine light
output, input power, CCT, CRI, and
standby mode power would result in an
estimated incremental labor burden of
$29,140 for each manufacturer. DOE
expects that the majority of
manufacturers are already testing for
lumen output, input power, CCT, and
CRI as these metrics are well established
and required within the industry
standard IES LM–79–2008. However,
DOE’s sample size, input power, and
orientation settings may differ from
those selected for a manufacturer’s
existing data. Therefore, DOE included
the cost of carrying out these tests in its
assessment of testing burden.
In addition, DOE estimates that
lifetime testing would also contribute to
overall cost burden. The initial setup
would require a custom-built rack to
mount up to 120 lamps for testing,
50 Additional benefits include; paid leave,
supplemental pay, insurance, retirement and
savings, Social Security, Medicare, unemployment
insurance and workers compensation.
51 Obtained from the Bureau of Labor Statistics
(News Release: Employer Cost For Employee
Compensation—December 2012, U.S. Department of
Labor (December 2012), www.bls.gov/news.release/
ecec.nr0.htm.
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which may require up to 120 hours of
labor to build. The cost for an electrical
engineering technician to build such a
rack would be approximately $3,800.
Similar to the NOPR analysis, DOE
estimated that the material cost to build
a custom-built rack holding 120 sockets
would be $3,600, and the power supply
and regulator costs would be $4,000 and
$1,500 respectively. Therefore, the
revised SNOPR estimate for the total
cost to build one rack is approximately
$12,900. DOE estimated that a total of
two racks would be needed to hold
about 23 different LED lamp models,
each tested in sample sets of 10 lamps
(a total of 230 LED lamps). Therefore,
DOE estimates the total cost to build
two test racks to be $25,800. However,
DOE notes that LED lamp manufacturers
may already have sufficient testing racks
for their own internal uses and for FTC
labeling requirement testing. DOE
expects that manufacturers of LED
lamps would already have other
instrumentation necessary for testing
because IES LM–79–2008 is the
recommended standard for testing LED
lamps for the FTC Lighting Facts label.
The labor cost for lifetime testing also
contributes to overall burden. DOE
estimates that the combination of
monitoring the lamps during the test
duration, measuring lumen
maintenance, and calculating lifetime at
the end of the test duration would
require approximately four hours per
lamp by an electrical engineering
technician. This estimate does not
include the initial lumen output
measurement required for the lifetime
test procedure, because the testing
burden for that measurement is already
included in the estimate for input
power, lumen output, CCT, and CRI
testing. DOE estimates about 41 small
business manufacturers of LEDs, each
offering about 23 different basic models,
would be affected. In total, DOE expects
that using this test method to determine
lifetime would result in testing-related
labor costs of $29,140 for each
manufacturer.
As discussed in section III.I, DOE is
also proposing to require test facilities
conducting LED lamp light output,
input power, CCT, CRI, lifetime, and
standby mode power (if applicable)
testing to be NVLAP-accredited or
accredited by an organization
recognized by NVLAP. However,
NVLAP imposes a variety of fees during
the accreditation process including
fixed administrative fees, variable
assessment fees, and proficiency testing
fees. If a laboratory already has NVLAP
accreditation for other industry
standards, there would be no
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incremental administrative fees
associated with the SNOPR proposal.
However, if a laboratory does not
already have NVLAP accreditation for
other industry standards, there would
be an administrative fee of $5,050
assessed annually. NVLAP also collects
an assessment fee corresponding to the
amount of time the assessor requires to
complete evaluation of the laboratory. A
laboratory seeking to expand its scope of
accreditation to include IES LM–79–
2008 as well as DOE’s lifetime test
procedure for LED lamps would most
likely not experience an increase in
cost. However, a laboratory with no
existing NVLAP accreditations would
likely require two full days of an
assessor’s time at the cost of $7,470 per
assessment. Assessments are required
during the initial accreditation, on the
first anniversary (year 1), and then every
other year following the first
anniversary (year 3, 5, 7, etc.). Finally,
every laboratory seeking accreditation to
IES LM–79–2008 is required to
participate in SSL proficiency testing. A
$2,800 fee is involved with this
proficiency testing.
For each manufacturer producing 23
basic models, assuming testing
instrumentation is already available,
DOE’s estimate of the first year NVLAP
accreditation cost would be $15,320,
initial setup cost would be $25,800, and
the labor costs to carry out testing
would be approximately $58,280.
Therefore, in the first year, for
manufacturers without testing racks or
NVLAP accreditation who choose to test
in-house, DOE estimates a total cost
burden of $99,400 or about $432 per
LED lamp tested. DOE expects the setup
cost to be a onetime cost to
manufacturers. Further, DOE expects
that the labor costs to perform testing
would be smaller than $58,280 after the
first year because only new products or
redesigned products would need to be
tested. Alternatively, if a manufacturer
opts to send lamps to a third-party test
facility, DOE estimates testing of lumen
output, input power, CCT, CRI, lifetime,
and standby mode power to cost $500
per lamp. In total, the LED lamp test
procedure would result in expected
third party testing costs of $115,000 for
each manufacturer of 23 basic models.
DOE was able to collect annual
revenue estimates for several of the
small business LED lamp manufacturers
using the Hoovers.com company profile
database. DOE determined that the
median revenue of the identified small
business manufacturers is $890,000,
therefore, initial testing costs would
represent about 11.2 percent of revenue
when completed in a manufacturer’s
own laboratory, and 12.9 percent when
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completed through a third-party test
facility. As mentioned earlier, the setup
cost would be a one-time cost to
manufacturers, and the labor costs to
perform testing would be smaller after
the first year of testing. Furthermore,
when amortized over subsequent years,
testing costs would be significantly less.
DOE requests comments on its analysis
of initial setup and labor costs as well
as the average annual burden for
conducting testing of LED lamps.
2. Duplication, Overlap, and Conflict
With Other Rules and Regulations
DOE is not aware of any rules or
regulations that duplicate, overlap, or
conflict with the proposed rule being
considered today.
3. Significant Alternatives to the
Proposed Rule
DOE tentatively determined that there
are no alternatives to the proposed test
procedure, including test procedures
that incorporate industry test standards
other than the proposed standards. IES
LM–79–2008, the test procedure
referenced in this SNOPR, is the most
commonly used industry standard that
provides instructions for the electrical
and photometric measurement of LED
lamps. DOE also reviewed the efforts of
other working groups, as suggested by
interested parties, but was unable to
find any U.S. or international standard
that provides a test procedure for
measuring and/or projecting LED lamp
lifetime. The only publicly available
approach for measuring LED lamp
lifetime is the ENERGY STAR Program
Requirements for Lamps (Light Bulbs):
Eligibility Criteria—Version 1.0 (see
supra note 10).
C. Review Under the Paperwork
Reduction Act of 1995
DOE established regulations for the
certification and recordkeeping
requirements for certain covered
consumer products and commercial
equipment. 76 FR 12422 (March 7,
2011). The collection-of-information
requirement for the certification and
recordkeeping was subject to review and
approval by OMB under the Paperwork
Reduction Act (PRA). This requirement
was approved by OMB under OMB
Control Number 1910–1400. Public
reporting burden for the certification
was estimated to average 20 hours per
response, including the time for
reviewing instructions, searching
existing data sources, gathering and
maintaining the data needed, and
completing and reviewing the collection
of information.
There is currently no information
collection requirement related to
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certifying compliance for LED lamps.
Notwithstanding any other provision of
the law, no person is required to
respond to, nor must any person be
subject to a penalty for failure to comply
with, a collection of information subject
to the requirements of the PRA, unless
that collection of information displays a
currently valid OMB Control Number.
D. Review Under the National
Environmental Policy Act of 1969
In this proposed rule, DOE is
proposing a test procedure for LED
lamps that will be used to support the
upcoming general service lamps energy
conservation standard rulemaking as
well as FTC’s Lighting Facts labeling
program. DOE has determined that this
rule falls into a class of actions that are
categorically excluded from review
under the National Environmental
Policy Act of 1969 (42 U.S.C. 4321 et
seq.) and DOE’s implementing
regulations at 10 CFR part 1021.
Specifically, this proposed rule would
adopt existing industry test procedures
for LED lamps, so it would not affect the
amount, quality or distribution of
energy usage, and, therefore, would not
result in any environmental impacts.
Thus, this rulemaking is covered by
Categorical Exclusion A5 under 10 CFR
part 1021, subpart D. Accordingly,
neither an environmental assessment
nor an environmental impact statement
is required.
E. Review Under Executive Order 13132
Executive Order 13132, ‘‘Federalism,’’
64 FR 43255 (August 4, 1999) imposes
certain requirements on agencies
formulating and implementing policies
or regulations that preempt State law or
that have Federalism implications. The
Executive Order requires agencies to
examine the constitutional and statutory
authority supporting any action that
would limit the policymaking discretion
of the States and to carefully assess the
necessity for such actions. The
Executive Order also requires agencies
to have an accountable process to
ensure meaningful and timely input by
State and local officials in the
development of regulatory policies that
have Federalism implications. On
March 14, 2000, DOE published a
statement of policy describing the
intergovernmental consultation process
it will follow in the development of
such regulations. 65 FR 13735. DOE has
examined this proposed rule and has
determined that it would not have a
substantial direct effect on the States, on
the relationship between the national
government and the States, or on the
distribution of power and
responsibilities among the various
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levels of government. EPCA governs and
prescribes Federal preemption of State
regulations as to energy conservation for
the products that are the subject of this
proposed rule. States can petition DOE
for exemption from such preemption to
the extent, and based on criteria, set
forth in EPCA. (42 U.S.C. 6297(d)) No
further action is required by Executive
Order 13132.
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F. Review Under Executive Order 12988
Regarding the review of existing
regulations and the promulgation of
new regulations, section 3(a) of
Executive Order 12988, ‘‘Civil Justice
Reform,’’ 61 FR 4729 (Feb. 7, 1996),
imposes on Federal agencies the general
duty to adhere to the following
requirements: (1) eliminate drafting
errors and ambiguity; (2) write
regulations to minimize litigation; (3)
provide a clear legal standard for
affected conduct rather than a general
standard; and (4) promote simplification
and burden reduction. Section 3(b) of
Executive Order 12988 specifically
requires that Executive agencies make
every reasonable effort to ensure that the
regulation: (1) clearly specifies the
preemptive effect, if any; (2) clearly
specifies any effect on existing Federal
law or regulation; (3) provides a clear
legal standard for affected conduct
while promoting simplification and
burden reduction; (4) specifies the
retroactive effect, if any; (5) adequately
defines key terms; and (6) addresses
other important issues affecting clarity
and general draftsmanship under any
guidelines issued by the Attorney
General. Section 3(c) of Executive Order
12988 requires Executive agencies to
review regulations in light of applicable
standards in sections 3(a) and 3(b) to
determine whether they are met or it is
unreasonable to meet one or more of
them. DOE has completed the required
review and determined that, to the
extent permitted by law, the proposed
rule meets the relevant standards of
Executive Order 12988.
G. Review Under the Unfunded
Mandates Reform Act of 1995
Title II of the Unfunded Mandates
Reform Act of 1995 (UMRA) requires
each Federal agency to assess the effects
of Federal regulatory actions on State,
local, and Tribal governments and the
private sector. Public Law 104–4, sec.
201 (codified at 2 U.S.C. 1531). For a
proposed regulatory action likely to
result in a rule that may cause the
expenditure by State, local, and Tribal
governments, in the aggregate, or by the
private sector of $100 million or more
in any one year (adjusted annually for
inflation), section 202 of UMRA requires
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a Federal agency to publish a written
statement that estimates the resulting
costs, benefits, and other effects on the
national economy. (2 U.S.C. 1532(a), (b))
The UMRA also requires a Federal
agency to develop an effective process
to permit timely input by elected
officers of State, local, and Tribal
governments on a proposed ‘‘significant
intergovernmental mandate,’’ and
requires an agency plan for giving notice
and opportunity for timely input to
potentially affected small governments
before establishing any requirements
that might significantly or uniquely
affect small governments. On March 18,
1997, DOE published a statement of
policy on its process for
intergovernmental consultation under
UMRA. 62 FR 12820; also available at
https://energy.gov/gc/office-generalcounsel. DOE examined this proposed
rule according to UMRA and its
statement of policy and determined that
the rule contains neither an
intergovernmental mandate, nor a
mandate that may result in the
expenditure of $100 million or more in
any year, so these requirements do not
apply.
H. Review Under the Treasury and
General Government Appropriations
Act, 1999
Section 654 of the Treasury and
General Government Appropriations
Act, 1999 (Pub. L. 105–277) requires
Federal agencies to issue a Family
Policymaking Assessment for any rule
that may affect family well-being. This
rule would not have any impact on the
autonomy or integrity of the family as
an institution. Accordingly, DOE has
concluded that it is not necessary to
prepare a Family Policymaking
Assessment.
I. Review Under Executive Order 12630
DOE has determined, under Executive
Order 12630, ‘‘Governmental Actions
and Interference with Constitutionally
Protected Property Rights’’ 53 FR 8859
(March 18, 1988), that this regulation
would not result in any takings that
might require compensation under the
Fifth Amendment to the U.S.
Constitution.
J. Review Under Treasury and General
Government Appropriations Act, 2001
Section 515 of the Treasury and
General Government Appropriations
Act, 2001 (44 U.S.C. 3516 note) provides
for agencies to review most
disseminations of information to the
public under guidelines established by
each agency pursuant to general
guidelines issued by OMB. OMB’s
guidelines were published at 67 FR
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8452 (Feb. 22, 2002), and DOE’s
guidelines were published at 67 FR
62446 (Oct. 7, 2002). DOE has reviewed
this proposed rule under the OMB and
DOE guidelines and has concluded that
it is consistent with applicable policies
in those guidelines.
K. Review Under Executive Order 13211
Executive Order 13211, ‘‘Actions
Concerning Regulations That
Significantly Affect Energy Supply,
Distribution, or Use,’’ 66 FR 28355 (May
22, 2001), requires Federal agencies to
prepare and submit to OMB, a
Statement of Energy Effects for any
proposed significant energy action. A
‘‘significant energy action’’ is defined as
any action by an agency that
promulgated or is expected to lead to
promulgation of a final rule, and that:
(1) is a significant regulatory action
under Executive Order 12866, or any
successor order; and (2) is likely to have
a significant adverse effect on the
supply, distribution, or use of energy; or
(3) is designated by the Administrator of
OIRA as a significant energy action. For
any proposed significant energy action,
the agency must give a detailed
statement of any adverse effects on
energy supply, distribution, or use
should the proposal be implemented,
and of reasonable alternatives to the
action and their expected benefits on
energy supply, distribution, and use.
This proposed regulatory action to
establish a test procedure for measuring
the lumen output, input power, efficacy,
CCT, CRI, lifetime, and standby mode
power of LED lamps is not a significant
regulatory action under Executive Order
12866. Moreover, it would not have a
significant adverse effect on the supply,
distribution, or use of energy, nor has it
been designated as a significant energy
action by the Administrator of OIRA.
Therefore, it is not a significant energy
action, and, accordingly, DOE has not
prepared a Statement of Energy Effects.
L. Review Under Section 32 of the
Federal Energy Administration Act of
1974
Under section 301 of the Department
of Energy Organization Act (Pub. L. 95–
91; 42 U.S.C. 7101), DOE must comply
with section 32 of the Federal Energy
Administration Act of 1974, as amended
by the Federal Energy Administration
Authorization Act of 1977. (15 U.S.C.
788; FEAA) Section 32 essentially
provides in relevant part that, where a
proposed rule authorizes or requires use
of commercial standards, the notice of
proposed rulemaking must inform the
public of the use and background of
such standards. In addition, section
32(c) requires DOE to consult with the
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Attorney General and the Chairman of
the FTC concerning the impact of the
commercial or industry standards on
competition.
The proposed rule incorporates test
methods contained in the following
commercial standards: ANSI/IESNA
RP–16–2010 ‘‘Nomenclature and
Definitions for Illuminating
Engineering’’ and IES LM–79–2008
‘‘Approved Method: Electrical and
Photometric Measurements of SolidState Lighting Products.’’ The
Department has evaluated these
standards and is unable to conclude
whether they fully comply with the
requirements of section 32(b) of the
FEAA, (i.e., that they were developed in
a manner that fully provides for public
participation, comment, and review).
DOE will consult with the Attorney
General and the Chairman of the FTC
concerning the impact of these test
procedures on competition prior to
prescribing a final rule.
V. Public Participation
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A. Submission of Comments
DOE will accept comments, data, and
information regarding this proposed
rule no later than the date provided in
the DATES section at the beginning of
this proposed rule. Interested parties
may submit comments using any of the
methods described in the ADDRESSES
section at the beginning of this notice.
Submitting comments via
regulations.gov. The regulations.gov
Web page will require you to provide
your name and contact information.
Your contact information will be
viewable to DOE Building Technologies
staff only. Your contact information will
not be publicly viewable except for your
first and last names, organization name
(if any), and submitter representative
name (if any). If your comment is not
processed properly because of technical
difficulties, DOE will use this
information to contact you. If DOE
cannot read your comment due to
technical difficulties and cannot contact
you for clarification, DOE may not be
able to consider your comment.
However, your contact information
will be publicly viewable if you include
it in the comment or in any documents
attached to your comment. Any
information that you do not want to be
publicly viewable should not be
included in your comment, nor in any
document attached to your comment.
Persons viewing comments will see only
first and last names, organization
names, correspondence containing
comments, and any documents
submitted with the comments.
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Do not submit to regulations.gov
information for which disclosure is
restricted by statute, such as trade
secrets and commercial or financial
information (hereinafter referred to as
Confidential Business Information
(CBI)). Comments submitted through
regulations.gov cannot be claimed as
CBI. Comments received through the
Web site will waive any CBI claims for
the information submitted. For
information on submitting CBI, see the
Confidential Business Information
section.
DOE processes submissions made
through regulations.gov before posting.
Normally, comments will be posted
within a few days of being submitted.
However, if large volumes of comments
are being processed simultaneously,
your comment may not be viewable for
up to several weeks. Please keep the
comment tracking number that
regulations.gov provides after you have
successfully uploaded your comment.
Submitting comments via email, hand
delivery, or mail. Comments and
documents submitted via email, hand
delivery, or mail also will be posted to
regulations.gov. If you do not want your
personal contact information to be
publicly viewable, do not include it in
your comment or any accompanying
documents. Instead, provide your
contact information on a cover letter.
Include your first and last names, email
address, telephone number, and
optional mailing address. The cover
letter will not be publicly viewable as
long as it does not include any
comments.
Include contact information each time
you submit comments, data, documents,
and other information to DOE. If you
submit via mail or hand delivery, please
provide all items on a CD, if feasible. It
is not necessary to submit printed
copies. No facsimiles (faxes) will be
accepted.
Comments, data, and other
information submitted to DOE
electronically should be provided in
PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file
format. Provide documents that are
written in English, free of any defects or
viruses, and not secured. Documents
should not contain special characters or
any form of encryption and, if possible,
they should carry the electronic
signature of the author.
Campaign form letters. Please submit
campaign form letters by the originating
organization in batches of between 50 to
500 form letters per PDF or as one form
letter with a list of supporters’ names
compiled into one or more PDFs. This
reduces comment processing and
posting time.
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Confidential Business Information.
According to 10 CFR 1004.11, any
person submitting information that he
or she believes to be confidential and
exempt by law from public disclosure
should submit via email, postal mail, or
hand delivery two well-marked copies:
one copy of the document marked
confidential including all the
information believed to be confidential,
and one copy of the document marked
non-confidential with the information
believed to be confidential deleted.
Submit these documents via email or on
a CD, if feasible. DOE will make its own
determination about the confidential
status of the information and treat it
according to its determination.
Factors of interest to DOE when
evaluating requests to treat submitted
information as confidential include: (1)
A description of the items; (2) whether
and why such items are customarily
treated as confidential within the
industry; (3) whether the information is
generally known by or available from
other sources; (4) whether the
information has previously been made
available to others without obligation
concerning its confidentiality; (5) an
explanation of the competitive injury to
the submitting person which would
result from public disclosure; (6) when
such information might lose its
confidential character due to the
passage of time; and (7) why disclosure
of the information would be contrary to
the public interest.
It is DOE’s policy that all comments
may be included in the public docket,
without change and as received,
including any personal information
provided in the comments (except
information deemed to be exempt from
public disclosure).
B. Issues on Which DOE Seeks Comment
Although DOE welcomes comments
on any aspect of this proposal, DOE is
particularly interested in receiving
comments and views of interested
parties concerning the following issues:
1. DOE requests comment on its
characterization of the modes of
operation (active, standby, and off
modes) that apply to LED lamps.
2. DOE requests comment on the
proposal for an equal number of lamps
to be operated in the base-up and basedown orientations during lumen output,
input power, CCT, CRI, lifetime, and
standby mode testing.
3. DOE invites interested parties to
comment on the proposal to require all
photometric values, including lumen
output, CCT, and CRI, be measured by
an integrating sphere (via photometer or
spectroradiometer) and that goniometer
systems must not be used.
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VI. Approval of the Office of the
Secretary
The Secretary of Energy has approved
publication of this proposed rule.
List of Subjects
10 CFR Part 429
Confidential business information,
Energy conservation, Household
appliances, Imports, Reporting and
recordkeeping requirements.
10 CFR Part 430
Administrative practice and
procedure, Confidential business
information, Energy conservation,
Household appliances, Imports,
Incorporation by reference,
Intergovernmental relations, Small
businesses.
Issued in Washington, DC, on May 16,
2014.
Kathleen B. Hogan,
Deputy Assistant Secretary for Energy
Efficiency, Energy Efficiency and Renewable
Energy.
For the reasons stated in the
preamble, DOE is proposing to amend
parts 429 and 430 of Chapter II of Title
10, Subchapter D of the Code of Federal
Regulations to read as set forth below:
PART 429—CERTIFICATION,
COMPLIANCE, AND ENFORCEMENT
FOR CONSUMER PRODUCTS AND
COMMERCIAL AND INDUSTRIAL
EQUIPMENT
1. The authority citation for part 429
continues to read as follows:
■
Authority: 42 U.S.C. 6291–6317.
§ 429.12
[Amended]
2. Section 429.12(b)(13) is amended
by removing ‘‘429.54’’ and adding
‘‘429.69’’ in its place.
■ 3. Section 429.56 is added to read as
follows:
■
§ 429.56
lamps.
Integrated light-emitting diode
(a) Determination of Represented
Value. (1) Manufacturers must
determine the represented value, which
includes the certified rating, for each
basic model of integrated light-emitting
diode lamps by testing, in conjunction
with the following sampling provisions:
(i) Units to be tested. (A) The general
requirements of § 429.11(a) are
applicable except that the sample must
be comprised of production units; and
(B) For each basic model of integrated
light-emitting diode lamp, the minimum
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number of units tested shall be no less
than 10 and the same units must be
used for testing all metrics. If more than
10 units are tested as part of the sample,
the total number of units must be a
multiple of two. For each basic model,
a sample of sufficient size shall be
randomly selected and tested to ensure
that:
(1) Represented values of initial
lumen output, lifetime, lamp efficacy,
and color rendering index (CRI) of a
basic model for which consumers would
favor higher values must be less than or
equal to the lower of:
(i) The mean of the sample, where:
¯
and, x is the sample mean; n is the
number of units; and xi is the ith unit;
Or,
(ii) The lower 99 percent confidence
limit (LCL) of the true mean divided by
0.97 for initial lumen output, life, and
lifetime; the lower 99 percent
confidence limit (LCL) of the true mean
divided by 0.98 for lamp efficacy; and
the lower 99 percent confidence limit
(LCL) of the true mean divided by 0.99
for CRI, where:
¯
and, x is the sample mean; s is the
sample standard deviation; n is the
number of samples; and t0.99 is the t
statistic for a 99 percent one-tailed
confidence interval with n ¥1 degrees
of freedom (from Appendix A of this
part).
(2) Represented values of input power
and standby mode power of a basic
model for which consumers would favor
lower values must be greater than or
equal to the higher of:
(i) The mean of the sample, where:
¯
and, x is the sample mean; n is the
number of units; and xi is the ith unit;
Or,
(ii) The upper 99 percent confidence
limit (UCL) of the true mean divided by
1.01, where:
¯
and, x is the sample mean; s is the
sample standard deviation; n is the
number of samples; and t0.99 is the t
statistic for a 99 percent one-tailed
confidence interval with n ¥ 1 degrees
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EP03JN14.018</GPH>
16. DOE requests comments on its
analysis of initial setup and labor costs
as well as the average annual burden for
conducting testing of LED lamps.
EP03JN14.016</GPH> EP03JN14.017</GPH>
4. DOE invites interested parties to
comment on the proposal to remain
consistent with section 4.0 of IES LM–
79–2008, which indicates no seasoning
is required for LED lamps before
beginning photometric measurements.
5. DOE requests comments on the test
conditions when lamps are operating
but no measurements are being taken.
Specifically, DOE requests comment on
requiring ambient temperature to be
controlled between 15 °C and 40 °C; the
minimization of vibration, shock, and
air movement, as well as the
requirement for adequate lamp spacing;
the proposal to adopt the section 3.1 of
IES LM–79–2008 requirements for both
AC and DC power supplies; and the
requirement that input voltage be
monitored and regulated to within ±2.0
percent of the rated RMS voltage as
specified in section 5.3 of IES LM–65–
2010.
6. DOE requests comment on the
proposed test method for CRI.
7. DOE requests comment on the
proposed calculation for lamp efficacy.
8. For lifetime testing, DOE proposes
to continuously operate the LED lamp
and requests feedback on the
appropriateness of not requiring an
operating cycle during lumen
maintenance testing.
9. DOE requests comment on the
proposed equation to project the L70
lifetime of LED lamps.
10. DOE requests comment on the
revision to the definition of ‘‘basic
model’’ to address LED lamps.
11. DOE requests comment on the
appropriateness of adopting a minimum
sample size of 10 LED lamps for input
power, lumen output, CCT, CRI,
lifetime, and standby mode.
12. DOE requests comment on the
proposal to allow measurements
collected for the ENERGY STAR
Program Requirements for Lamps (Light
Bulbs): Eligibility Criteria—Version 1.0
to be used for calculating reported
values of lumen output, input power,
lamp efficacy, CCT, CRI, and lifetime.
13. DOE requests comment on the
proposal to round CCT values for
individual units to the tens place; and
the proposal to round the certified CCT
values for the sample to the hundreds
place.
14. DOE requests comment on its
proposal to require accreditation by
NVLAP or an entity recognized by ILAC,
and on the costs and benefits associated
with laboratory accreditation.
15. DOE requests comment on the
estimated number of entities that would
be affected by the proposed rulemaking
and the number of these companies that
are ‘‘small businesses.’’
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¯
and, x is the sample mean; n is the
number of units; and xi is the ith unit.
(ii) [Reserved]
(2) [Reserved]
(b) [Reserved]
(c) Rounding requirements for
representative values, including
certified and rated values, of lumen
output, input power, efficacy, CCT, CRI,
lifetime, standby mode power, and
estimated annual energy cost. (1) The
represented value of input power must
be rounded to the nearest tenth of a
watt.
(2) The represented value of lumen
output must be rounded to three
significant digits.
(3) The represented value of lamp
efficacy must be rounded to the nearest
tenths place.
(4) The represented value of
correlated color temperature must be
rounded to the nearest 100 Kelvin.
(5) The represented value of color
rendering index must be rounded to the
nearest whole number.
(6) The represented value of lifetime
must be rounded to the nearest whole
hour.
(7) The represented value of standby
mode power must be rounded to the
nearest tenth of a watt.
PART 430—ENERGY CONSERVATION
PROGRAM FOR CONSUMER
PRODUCTS
4. The authority citation for part 430
continues to read as follows:
■
Authority: 42 U.S.C. 6291–6309; 28 U.S.C.
2461 note.
5. Section 430.2 is amended by
revising the definition of ‘‘Basic model’’
and adding in alphabetical order the
definition of ‘‘Integrated light-emitting
diode lamp’’ to read as follows:
■
§ 430.2
Definitions.
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*
*
*
*
*
Basic model means all units of a given
type of covered product (or class
thereof) manufactured by one
manufacturer, having the same primary
energy source, and which have
essentially identical electrical, physical,
and functional (or hydraulic)
characteristics that affect energy
consumption, energy efficiency, water
consumption, or water efficiency; and
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(1) With respect to general service
fluorescent lamps, general service
incandescent lamps, and incandescent
reflector lamps: Lamps that have
essentially identical light output and
electrical characteristics—including
lumens per watt (lm/W) and color
rendering index (CRI).
(2) With respect to integrated lightemitting diode lamps: Lamps that have
essentially identical light output and
electrical characteristics—including
lumens per watt (lm/W), color rendering
index (CRI), correlated color
temperature (CCT), and lifetime.
(3) With respect to faucets and
showerheads: Have the identical flow
control mechanism attached to or
installed within the fixture fittings, or
the identical water-passage design
features that use the same path of water
in the highest flow mode.
(4) With respect to furnace fans: Are
marketed and/or designed to be
installed in the same type of
installation.
*
*
*
*
*
Integrated light-emitting diode lamp
means an integrated LED lamp as
defined in ANSI/IESNA RP–16
(incorporated by reference; see § 430.3).
*
*
*
*
*
■ 6. Section 430.3 is amended by:
■ a. Adding paragraphs (n)(8) and (n)(9);
and
■ b. Removing ‘‘and X’’ in paragraph
(o)(4) and adding in its place, ‘‘X and
BB’’ .
The additions read as follows:
§ 430.3 Materials incorporated by
reference.
*
*
*
*
*
(n) IESNA. * * *
(8) ANSI/IESNA RP–16–2010,
Nomenclature and Definitions for
Illuminating Engineering, approved
October 15, 2005; IBR approved for
§ 430.2.
(9) IES LM–79–2008 (‘‘IES LM–79’’),
Approved Method: Electrical and
Photometric Measurements of SolidState Lighting Products, approved
December 31, 2007; IBR approved for
Appendix BB to subpart B of this part.
*
*
*
*
*
■ 7. Section 430.23 is amended by
adding paragraph (dd) to read as
follows:
§ 430.23 Test procedures for the
measurement of energy and water
consumption.
*
*
*
*
*
(dd) Integrated light-emitting diode
lamp. (1) The input power of an
integrated light-emitting diode lamp
must be measured in accordance with
section 3 of Appendix BB of this
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subpart. Individual unit input power
must be rounded to the nearest tenth of
a watt.
(2) The lumen output of an integrated
light-emitting diode lamp must be
measured in accordance with section 3
of Appendix BB of this subpart.
Individual unit lumen output must be
rounded to three significant digits.
(3) The lamp efficacy of an integrated
light-emitting diode lamp must be
calculated in accordance with section 3
of Appendix BB of this subpart.
Individual unit lamp efficacy must be
rounded to the nearest tenths place.
(4) The correlated color temperature
of an integrated light-emitting diode
lamp must be measured in accordance
with section 3 of Appendix BB of this
subpart. Individual unit correlated color
temperature must be rounded to the
nearest 10 Kelvin.
(5) The color rendering index of an
integrated light-emitting diode lamp
must be measured in accordance with
section 3 of Appendix BB of this
subpart. Individual unit color rendering
index must be rounded to the nearest
whole number.
(6) The lifetime of an integrated lightemitting diode lamp must be measured
in accordance with section 5 of
Appendix BB of this subpart. Individual
unit lifetime must be rounded to the
nearest hour.
(7) The life of an integrated lightemitting diode lamp must be calculated
by dividing the represented rated
lifetime (see 10 CFR 429.56) by the
estimated annual operating hours as
specified in 16 CFR 305.15(b)(3)(iii).
The life must be rounded to the nearest
tenth of a year.
(8) The estimated annual energy cost
for an integrated light-emitting diode
lamp, expressed in dollars per year,
must be the product of the average input
power in kilowatts as determined in
accordance with Appendix BB to this
subpart, an electricity cost rate as
specified in 16 CFR 305.15(b)(1)(ii), and
an estimated average annual use as
specified in 16 CFR 305.15(b)(1)(ii). The
resulting estimated annual energy cost
for an individual unit must be rounded
to the nearest cent per year.
(9) The standby mode power must be
measured in accordance with section 5
of Appendix BB of this subpart.
Individual unit standby mode power
must be rounded to the nearest tenth of
a watt.
■ 8. Section 430.25 is revised to read as
follows:
§ 430.25 Laboratory Accreditation
Program.
(a) Testing for general service
fluorescent lamps, general service
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of freedom (from Appendix A of this
part);
(3) Represented values of correlated
color temperature (CCT) of a basic
model must be equal to the mean of the
sample, where:
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incandescent lamps, and incandescent
reflector lamps must be performed in
accordance with Appendix R to this
subpart. Testing for medium base
compact fluorescent lamps must be
performed in accordance with
Appendix W to this subpart. Testing for
fluorescent lamp ballasts must be
performed in accordance with
Appendix Q1 to this subpart. This
testing, with the exception of lifetime
testing of general service incandescent
lamps, must be conducted by test
laboratories accredited by the National
Voluntary Laboratory Accreditation
Program (NVLAP) or an accrediting
organization recognized by International
Laboratory Accreditation Cooperation
(ILAC). NVLAP is a program of the
National Institute of Standards and
Technology, U.S. Department of
Commerce. NVLAP standards for
accreditation of laboratories that test are
set forth in 15 CFR part 285. The
following metrics should be measured
by test laboratories accredited by
NVLAP or an accrediting organization
recognized by International Laboratory
Accreditation Cooperation (ILAC):
(1) Fluorescent lamp ballasts: ballast
luminous efficiency (BLE);
(2) General service fluorescent lamps:
lamp efficacy, color rendering index;
(3) General service incandescent
reflector lamps: lamp efficacy;
(4) General service incandescent
lamps: lamp efficacy; and
(5) Medium base compact fluorescent
lamps: initial efficacy, lamp life. Testing
for BLE may also be conducted by
laboratories accredited by Underwriters
Laboratories or Council of Canada.
Testing for fluorescent lamp ballasts
performed in accordance with
Appendix Q to this subpart is not
required to be conducted by test
laboratories accredited by NVLAP or an
accrediting organization recognized by
NVLAP.
(b) Testing of integrated light-emitting
diode lamps must be performed in
accordance with Appendix BB of this
subpart. Testing must be conducted in
test laboratories accredited by NVLAP
or an accrediting organization
recognized by International Laboratory
Accreditation Cooperation (ILAC) for
the following metrics: input power,
lumen output, lamp efficacy, correlated
color temperature, color rendering
index, lifetime, and standby mode
power. A manufacturer’s own
laboratory, if accredited, may conduct
the testing.
■ 9. Appendix BB to subpart B of part
430 is added to read as follows:
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Appendix BB to Subpart B of Part 430—
Uniform Test Method for Measuring the
Input Power, Lumen Output, Lamp
Efficacy, Correlated Color Temperature
(CCT), Color Rendering Index (CRI),
Lifetime, and Standby Mode Power of
Integrated Light-Emitting Diode (LED)
Lamps
Note: After [DATE 180 DAYS AFTER
PUBLICATION OF FINAL RULE IN THE
Federal Register], any representations made
with respect to the energy use or efficiency
of light-emitting diode lamps must be made
in accordance with the results of testing
pursuant to this appendix. Given that after
[DATE 180 DAYS AFTER PUBLICATION OF
FINAL RULE IN THE Federal Register]
representations with respect to the energy
use or efficiency of light-emitting diode
lamps must be made in accordance with tests
conducted pursuant to this appendix,
manufacturers may wish to begin using this
test procedure as soon as possible.
1. Scope: This appendix specifies how to
measure input power, lumen output, lamp
efficacy, CCT, CRI, lifetime, and standby
mode power for integrated LED lamps.
2. Definitions
2.1. The definitions specified in section 1.3
of IES LM–79 except section 1.3(f)
(incorporated by reference; see § 430.3)
apply.
2.2. Initial lumen output means the
measured lumen output after the lamp is
initially energized and stabilized using the
stabilization procedures in section 3 of
Appendix BB of this subpart.
2.3. Rated input voltage means the
voltage(s) marked on the lamp as the
intended operating voltage. If not marked on
the lamp, assume 120 V.
2.4. Lamp efficacy means the ratio of
measured initial lumen output in lumens to
the measured lamp input power in watts, in
units of lumens per watt.
2.5. CRI means color rendering index as
defined in § 430.2.
2.6. Test duration means the operating
time of the LED lamp after the initial lumen
output measurement and before, during, and
including the final lumen output
measurement.
2.7. Lifetime means the time at which the
lumen output is equal to 70 percent of the
initial lumen output measured using section
4 of Appendix BB of this subpart.
3. Active Mode Test Method for Determining
Lumen Output, Input Power, CCT, CRI, and
Lamp Efficacy
In cases where there is a conflict, the
language of the test procedure in this
appendix takes precedence over IES LM–79
(incorporated by reference; see § 430.3).
3.1. Test Conditions and Setup
3.1.1. The ambient conditions, power
supply, electrical settings, and
instrumentation must be established in
accordance with the specifications in
sections 2.0, 3.0, 7.0, and 8.0 of IES LM–79
(incorporated by reference; see § 430.3),
respectively.
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3.1.2. An equal number of integrated LED
lamps must be positioned in the base up and
base down orientations throughout testing.
3.1.3. The integrated LED lamp must be
operated at the rated voltage throughout
testing. For an integrated LED lamp with
multiple rated voltages including 120 volts,
the integrated LED lamp must be operated at
120 volts. If an integrated LED lamp with
multiple rated voltages is not rated for 120
volts, the integrated LED lamp must be
operated at the highest rated input voltage.
Additional tests may be conducted at other
rated voltages.
3.1.4. The integrated LED lamp must be
operated at maximum input power. If
multiple modes occur at the same maximum
input power (such as variable CCT or CRI),
the manufacturer can select any of these
modes for testing; however, all measurements
described in section 3 and section 4 must be
taken at the same selected mode.
3.2. Test Method, Measurements, and
Calculations
3.2.1. The integrated LED lamp must be
stabilized prior to measurement as specified
in section 5.0 of IES LM–79 (incorporated by
reference; see § 430.3). The stabilization
variation is calculated as
[maximum¥minimum)/minimum] of at least
three readings of the input power and lumen
output over a period of 30 minutes, taken 15
minutes apart.
3.2.2. The input power in watts must be
measured as specified in section 8.0 of IES
LM–79 (incorporated by reference; see
§ 430.3).
3.2.3. Lumen output must be measured as
specified in section 9.1 and 9.2 of IES LM–
79 (incorporated by reference; see § 430.3).
Goniometers must not be used.
3.2.4. CCT must be determined according
to the method specified in section 12.0 of IES
LM–79 (incorporated by reference; see
§ 430.3) with the exclusion of section 12.2 of
IES LM–79. Goniometers must not be used.
3.2.5. CRI must be determined according to
the method specified in section 12.0 of IES
LM–79 (incorporated by reference; see
§ 430.3) with the exclusion of section 12.2 of
IES LM–79. Goniometers must not be used.
3.2.6. Lamp efficacy must be determined
by dividing measured initial lumen output by
the measured input power.
4. Active Mode Test Method for Lifetime
In cases where there is a conflict, the
language of the test procedure in this
appendix takes precedence over IES LM–79
(incorporated by reference; see § 430.3).
4.1. Measure Initial Lumen Output. Measure
the Initial Lumen Output According to
Section 3 of This Appendix
4.2. Test Duration. Operate the integrated
LED lamp for a period of time (the test
duration) after the initial lumen output
measurement and before, during, and
including the final lumen output
measurement.
4.2.1. There is no minimum test duration
requirement for the integrated LED lamp. The
test duration is selected by the manufacturer.
See section 4.5.3 for instruction on the
maximum lifetime.
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4.2.2. The test duration only includes time
when the integrated LED lamp is energized
and operating.
4.2.3. Operating conditions and setup
during the test duration other than time
during which lumen output measurements
are being conducted are specified in section
4.3 of this appendix.
4.3. Operating Conditions and Setup Between
Lumen Output Measurements
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4.3.1. Ambient temperature must be
controlled between 15 °C and 40 °C.
4.3.2. The integrated LED lamps must be
spaced to allow airflow around each lamp.
4.3.3. The integrated LED lamps must not
be subjected to excessive vibration or shock
during lamp operation.
4.3.4. Line voltage waveshape must be as
described in section 3.1 of IES LM–79
(incorporated by reference; see § 430.3).
4.3.5. Input voltage must be monitored and
regulated to within ±2 percent of the voltage
required in section 3.1.3 for the duration of
the test.
4.3.6. Electrical settings must be as
described in section 7.0 IES LM–79
(incorporated by reference; see § 430.3).
4.3.7. An equal number of integrated LED
lamps must be positioned in the base up and
base down orientations throughout testing.
4.3.8. The integrated LED lamp must be
operated at maximum input power. If
multiple modes occur at the same maximum
input power (such as variable CCT and CRI),
the manufacturer can select any of these
modes for testing. Measurements of all
quantities described in sections 3 and 4 of
this appendix must be taken at the same
selected mode.
4.4. Measure Final Lumen Output. Measure
the lumen output at the end of the test
duration according to section 3.
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4.5.Calculate Lumen Maintenance and
Lifetime
4.5.1. Calculate the lumen maintenance of
the lamp after the test duration ‘‘t’’ by
dividing the final lumen output ‘‘xt’’ by the
initial lumen output ‘‘x0’’. Initial and final
lumen output must be measured in
accordance with sections 4.1 and 4.4 of this
appendix, respectively.
4.5.2. For lumen maintenance values
greater than 1, the lifetime (in hours) is
limited to a value less than or equal to four
times the test duration.
4.5.3. For lumen maintenance values less
than 1 but greater than or equal to 0.7, the
lifetime (in hours) is calculated using the
following equation:
Where: t is the test duration in hours; x0 is
the initial lumen output; xt is the final
lumen output at time t, and ln is the
natural logarithm function.
The maximum lifetime is limited to four
times the test duration t.
4.5.4. For lumen maintenance values less
than 0.7, including lamp failures that result
in complete loss of light output, lifetime is
equal to the previously recorded lumen
output measurement at a shorter test duration
where the lumen maintenance is greater than
or equal to 70 percent, and lifetime shall not
be calculated in accordance with section
4.5.3 of this appendix.
5. Standby Mode Test Method for
Determining Standby Mode Power
In cases where there is a conflict, the
language of the test procedure in this
appendix takes precedence over IES LM–79
(incorporated by reference; see § 430.3) and
IEC 62301 (incorporated by reference; see
§ 430.3).
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5.1. Test Conditions and Setup
5.1.1. The ambient conditions, power
supply, electrical settings, and
instrumentation must be established in
accordance with the specifications in
sections 2.0, 3.0, 7.0, and 8.0 of IES LM–79
(incorporated by reference; see § 430.3),
respectively.
5.1.2. An equal number of integrated LED
lamps must be positioned in the base up and
base down orientations throughout testing.
5.1.3. The integrated LED lamp must be
operated at the rated voltage throughout
testing. For an integrated LED lamp with
multiple rated voltages, the integrated LED
lamp must be operated at 120 volts. If an
integrated LED lamp with multiple rated
voltages is not rated for 120 volts, the
integrated LED lamp must be operated at the
highest rated input voltage.
5.2. Test Method, Measurements, and
Calculations
5.2.1. Standby mode power consumption
must be measured for integrated LED lamps
if applicable.
5.2.2. The integrated LED lamp must be
stabilized prior to measurement as specified
in section 5.0 of IES LM–79 (incorporated by
reference; see § 430.3). The stabilization
variation is calculated as [maximum—
minimum)/minimum] of at least three
readings of the input power and lumen
output over a period of 30 minutes, taken 15
minutes apart.
5.2.3. The integrated LED must be
configured in standby mode by sending a
signal to the integrated LED lamp instructing
it to have zero light output.
5.2.4. The standby mode power in watts
must be measured as specified in section 5
of IEC 62301 (incorporated by reference; see
§ 430.3).
[FR Doc. 2014–12127 Filed 6–2–14; 8:45 am]
BILLING CODE 6450–01–P
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]]>Agencies
[Federal Register Volume 79, Number 106 (Tuesday, June 3, 2014)]
[Proposed Rules]
[Pages 32019-32048]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-12127]
[[Page 32019]]
Vol. 79
Tuesday,
No. 106
June 3, 2014
Part II
Department of Energy
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10 CFR Parts 429 and 430
Energy Conservation Program: Test Procedures for Integrated Light-
Emitting Diode Lamps; Proposed Rule
Federal Register / Vol. 79 , No. 106 / Tuesday, June 3, 2014 /
Proposed Rules
[[Page 32020]]
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DEPARTMENT OF ENERGY
10 CFR Parts 429 and 430
[Docket No. EERE-2011-BT-TP-0071]
RIN 1904-AC67
Energy Conservation Program: Test Procedures for Integrated
Light-Emitting Diode Lamps
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Supplemental notice of proposed rulemaking.
-----------------------------------------------------------------------
SUMMARY: On April 9, 2012, the U.S. Department of Energy (DOE)
published a notice of proposed rulemaking (NOPR) in which DOE proposed
a test procedure for light-emitting diode (LED) lamps (hereafter
referred to as LED lamps). This supplemental notice of proposed
rulemaking (SNOPR), revises DOE's proposal for a new test procedure for
LED lamps. This SNOPR supports implementation of labeling provisions by
the Federal Trade Commission (FTC) and implementation of DOE's energy
conservation standards for general service lamps that includes general
service LED lamps. The SNOPR continues to define methods for measuring
the lumen output, input power, and relative spectral distribution (to
determine correlated color temperature, or CCT). Further, the SNOPR
revises the method for calculating the lifetime of LED lamps, and
defines the lifetime as the time required for the LED lamp to reach a
lumen maintenance of 70 percent (that is, 70 percent of initial light
output). Additionally, the SNOPR adds calculations for lamp efficacy as
well as the color rendering index (CRI) of LED lamps, which were not
proposed in the test procedure NOPR.
DATES: DOE will accept comments, data, and information regarding this
SNOPR, but no later than August 4, 2014. See section V, ``Public
Participation,'' for details.
ADDRESSES: Any comments submitted must identify the SNOPR for Test
Procedures for LED lamps, and provide docket number EE-2011-BT-TP-0071
and/or regulatory information number (RIN) number 1904-AC67. Comments
may be submitted using any of the following methods:
1. Federal eRulemaking Portal: www.regulations.gov. Follow the
instructions for submitting comments.
2. Email: LEDLamps-2011-TP-0071@ee.doe.gov. Include the docket
number and/or RIN in the subject line of the message.
3. Mail: Ms. Brenda Edwards, U.S. Department of Energy, Building
Technologies Office, Mailstop EE-5B, 1000 Independence Avenue SW.,
Washington, DC, 20585-0121. If possible, please submit all items on a
CD. It is not necessary to include printed copies.
4. Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of
Energy, Building Technologies Program, 950 L'Enfant Plaza SW., Suite
600, Washington, DC, 20024. Telephone: (202) 586-2945. If possible,
please submit all items on a CD. It is not necessary to include printed
copies.
For detailed instructions on submitting comments and additional
information on the rulemaking process, see section V of this document
(Public Participation).
Docket: The docket is available for review at regulations.gov,
including Federal Register notices, public meeting attendee lists and
transcripts, comments, and other supporting documents/materials. All
documents in the docket are listed in the regulations.gov index.
However, not all documents listed in the index may be publicly
available, such as information that is exempt from public disclosure.
A link to the docket Web page can be found at:
www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/18. This Web page will contain a link to the docket for this
notice on the regulations.gov site. The regulations.gov Web page
contains simple instructions on how to access all documents, including
public comments, in the docket. See section V for information on how to
submit comments through regulations.gov.
For further information on how to submit a comment, review other
public comments and the docket, or participate in the public meeting,
contact Ms. Brenda Edwards at (202) 586-2945 or by email:
Brenda.Edwards@ee.doe.gov.
FOR FURTHER INFORMATION CONTACT: Ms. Lucy deButts, U.S. Department of
Energy, Office of Energy Efficiency and Renewable Energy, Building
Technologies Office, EE-5B, 1000 Independence Avenue SW., Washington,
DC, 20585-0121. Telephone: (202) 287-1604. Email: light_emitting_diodes@ee.doe.gov.
Ms. Celia Sher, U.S. Department of Energy, Office of the General
Counsel, GC-71, 1000 Independence Avenue SW., Washington, DC, 20585-
0121. Telephone: (202) 287-6122. Email: Celia.Sher@hq.doe.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Authority and Background
II. Summary of the Supplemental Notice of Proposed Rulemaking
III. Discussion
A. Scope of Applicability
B. Standby and Off-Mode
C. Proposed Approach for Determining Lumen Output, Input Power,
Lamp Efficacy, Correlated Color Temperature, and Color Rendering
Index
1. NOPR Proposals
2. Test Conditions
3. Test Setup
4. Test Method
D. Proposed Approach for Lifetime Measurements
1. LED Lamp Lifetime Definition
2. NOPR Proposals
3. SNOPR Proposed Lifetime Method
E. Proposed Approach for Standby Mode Power
F. Basic Model, Sampling Plan, and Reported Value
1. Basic Model
2. Sampling Plan
3. Reported Value
G. Rounding Requirements
1. Lumen Output
2. Input Power
3. Lamp Efficacy
4. Correlated Color Temperature
5. Color Rendering Index
6. Annual Energy Cost
7. Lifetime
8. Life
9. Standby Mode Power
H. Acceptable Methods for Initial Certification or Labeling
I. Laboratory Accreditation
J. State Preemption for Efficiency Metrics
K. Effective and Compliance Date
IV. Procedural Issues and Regulatory Review
A. Review Under Executive Order 12866
B. Review under the Regulatory Flexibility Act
1. Estimated Small Business Burden
2. Duplication, Overlap, and Conflict With Other Rules and
Regulations
3. Significant Alternatives to the Proposed Rule
C. Review Under the Paperwork Reduction Act of 1995
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government
Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under Treasury and General Government Appropriations
Act, 2001
K. Review Under Executive Order 13211
L. Review Under Section 32 of the Federal Energy Administration
Act of 1974
V. Public Participation
A. Submission of Comments
B. Issues on Which DOE Seeks Comment
VI. Approval of the Office of the Secretary
I. Authority and Background
Title III of the Energy Policy and Conservation Act of 1975 (42
U.S.C. 6291, et seq.; ``EPCA'') sets forth a variety of provisions
designed to improve energy efficiency. (All
[[Page 32021]]
references to EPCA refer to the statute as amended through the American
Energy Manufacturing Technical Corrections Act (AEMTCA), Public Law
112-210 (Dec. 18, 2012)). Part B of title III, which for editorial
reasons was redesignated as Part A upon incorporation into the U.S.
Code (42 U.S.C. 6291-6309, as codified), establishes the ``Energy
Conservation Program for Consumer Products Other Than Automobiles.''
Under EPCA, this program consists of four parts: (1) testing, (2)
labeling, (3) Federal energy conservation standards, and (4)
certification and enforcement procedures. This SNOPR proposes test
procedures that manufacturers of integrated LED lamps (hereafter
referred to as ``LED lamps'') would use to meet two requirements,
namely, to: (1) satisfy any future energy conservation standards for
general service LED lamps, and (2) meet obligations under labeling
requirements for LED lamps promulgated by the Federal Trade Commission
(FTC).
First, this SNOPR would be used to assess the performance of LED
lamps relative to any potential energy conservation standards in a
future rulemaking that includes general service LED lamps. DOE is
currently developing energy conservation standards for general service
lamps (GSLs), a category of lamps that includes general service LED
lamps. See 78 FR 73737 (Dec. 9, 2013).
Second, the LED lamp SNOPR supports obligations under labeling
requirements promulgated by FTC under section 324(a)(6) of EPCA (42
U.S.C. 6294(a)(6)). The Energy Independence and Security Act of 2007
(EISA 2007) section 321(b) amended EPCA (42 U.S.C. 6294(a)(2)(D)) to
direct FTC to consider the effectiveness of lamp labeling for power
levels or watts, light output or lumens, and lamp lifetime. This SNOPR
supports FTC's determination that LED lamps, which had previously not
been labeled, require labels under EISA section 321(b) and 42 U.S.C.
6294(a)(6) in order to assist consumers in making purchasing decisions.
75 FR 41696, 41698 (July 19, 2010).
FTC published a final rule for light bulb \1\ labeling (Lighting
Facts) that required compliance on January 1, 2012. 75 FR 41696 (July
19, 2010). The FTC Lighting Facts label covers three types of medium
screw base lamps: general service incandescent lamps (GSIL), compact
fluorescent lamps (CFL), and general service LED lamps.\2\ The label
requires manufacturers to disclose information about the lamp's
brightness \3\ (lumen output), estimated annual energy cost, life \4\
(lifetime), light appearance (CCT), and energy use (input power). FTC
requires manufacturers to calculate the estimated annual energy cost by
multiplying together the energy used, annual operating hours, and an
estimate for energy cost per kilowatt-hour. FTC references DOE test
procedures, when available, for testing lamps for the FTC Lighting
Facts label. See 42 U.S.C. 6294(c). This SNOPR would enable FTC to
reference a DOE test procedure for LED lamps. DOE invites comments on
all aspects of the SNOPR for LED lamps.
---------------------------------------------------------------------------
\1\ FTC uses the term `bulb,' while DOE uses the term `lamp.'
Bulb and lamp refer to the same product.
\2\ FTC defines general service LED lamps as a lamp that is a
consumer product; has a medium screw base; has a lumen range not
less than 310 lumens and not more than 2,600 lumens; and is capable
of being operated at a voltage range at least partially within 110
and 130 volts. This proposed test procedure rulemaking could be
applied to general service LED lamps as defined by FTC as well as
all other integrated LED lamps as discussed in section 0 of this
SNOPR.
\3\ Although `light output' is the technically correct term, FTC
uses the term `brightness' on the Lighting Facts label because FTC's
research indicated that consumers prefer the term `brightness' to
`light output.'
\4\ FTC uses the term `life' while DOE uses the term `lifetime.'
Life and lifetime have the same meaning.
---------------------------------------------------------------------------
II. Summary of the Supplemental Notice of Proposed Rulemaking
In this SNOPR, DOE proposes test procedures for determining the
lumen output, input power, lamp efficacy, CCT, CRI, lifetime, and
standby mode power of an LED lamp. DOE proposes to define an LED lamp
using the ANSI \5\/IESNA \6\ RP-16-2010 \7\ definition of an integrated
LED lamp. DOE pursued an SNOPR for two main reasons: (1) to revise the
method of measuring lifetime based on public comment and (2) to add
directions for calculating the metrics lamp efficacy and CRI and
standby mode power to support the ongoing general service lamp
rulemaking. To determine lumen output, input power, CCT, and CRI, DOE
proposes to incorporate by reference IES LM-79-2008.\8\ DOE reviewed
several potential approaches to testing lamp lumen output, input power,
CCT, and CRI, and determined that this IES standard is the most
appropriate based on discussions with industry experts. IES LM-79-2008
appears to yield reliable results, and industry generally uses it to
measure photometric characteristics of LED lamps. To determine the
standby mode power, DOE proposes to incorporate by reference
International Electrotechnical Commission (IEC) 62301.\9\ In addition,
DOE proposes to calculate the efficacy of an LED lamp in units of
lumens per watt by dividing the measured initial lamp lumen output in
lumens by the measured lamp input power in watts. Lastly, no industry
standards are available for determining the lifetime of LED lamps.
Therefore, the SNOPR proposes a method for measuring and projecting LED
lamp lifetime that uses a continuous equation based on the underlying
exponential decay function in the ENERGY STAR Program Requirements for
Lamps (Light Bulbs): Eligibility Criteria--Version 1.0.\10\
---------------------------------------------------------------------------
\5\ American National Standards Institute.
\6\ Illuminating Engineering Society of North America (also
abbreviated as IES).
\7\ ``Nomenclature and Definitions for Illuminating
Engineering.'' Approved by ANSI on October 16, 2009. Approved by IES
on November 15, 2009.
\8\ ``Approved Method: Electrical and Photometric Measurements
of Solid-State Lighting Products.'' Approved by IES on December 31,
2007.
\9\ ``Household electrical appliances--Measurement of standby
power.'' Edition 2.0 2011-01.
\10\ ``ENERGY STAR Program Requirements for Lamps (Light Bulbs):
Eligibility Criteria--Version 1.0.'' U.S. Environmental Protection
Agency, August 28, 2013.
---------------------------------------------------------------------------
III. Discussion
A. Scope of Applicability
EISA 2007 section 321(a)(1)(B) added the definition for LED as a p-
n junction \11\ solid state device, the radiated output of which,
either in the infrared region, the visible region, or the ultraviolet
region, is a function of the physical construction, material used, and
exciting current \12\ of the device. (42 U.S.C. 6291(30)(CC)) In the
NOPR, published on April 9, 2012, DOE stated that this rulemaking
applies to LED lamps that meet DOE's proposed definition of an LED
lamp, which is based on the term as defined by ANSI/IESNA RP-16-2010,
``Nomenclature and Definitions for Illuminating Engineering.'' This
standard defines integrated LED lamps as an integrated assembly that
comprises LED packages (components) or LED arrays (modules)
(collectively referred to as an LED source), LED driver, ANSI standard
base, and other optical, thermal, mechanical and electrical components
(such as phosphor layers, insulating materials, fasteners to hold
components within the lamp together, and electrical wiring). The LED
lamp is intended to connect directly to a branch circuit through a
corresponding ANSI standard
[[Page 32022]]
socket. 77 FR 21038, 21041 (April 9, 2012)
---------------------------------------------------------------------------
\11\ P-n junction is the boundary between p-type and n-type
material in a semiconductor device, such as LEDs. P-n junctions are
active sites where current can flow readily in one direction but not
in the other direction--in other words, a diode.
\12\ Exciting current is the current passing through an LED chip
during steady state operation.
---------------------------------------------------------------------------
The National Electrical Manufacturers Association (hereafter
referred to as NEMA) agreed with the proposed scope and incorporation
of ANSI/IESNA RP-16-2010 for the definition of LED lamps. (NEMA, Public
Meeting Transcript, No. 7 at p. 2 \13\) DOE received no adverse comment
on this proposal. Thus, in this SNOPR, DOE proposes to maintain the
scope and definition of LED lamps.
---------------------------------------------------------------------------
\13\ A notation in the form ``NEMA, Public Meeting Transcript,
No. 7 at p. 2'' identifies a statement made in a public meeting that
DOE has received and has included in the docket of this rulemaking.
This particular notation refers to a comment: (1) submitted during
the public meeting on May 3, 2012; (2) in document number 7 in the
docket of this rulemaking; and (3) appearing on page 2 of the
transcript.
---------------------------------------------------------------------------
B. Standby and Off-Mode
EPCA directs DOE to amend test procedures ``to include standby mode
and off mode energy consumption . . . with such energy consumption
integrated into the overall energy efficiency, energy consumption, or
other energy descriptor for each covered product, unless the Secretary
determines that--(i) the current test procedures for a covered product
already fully account for and incorporate the standby and off mode
energy consumption of the covered product . . .'' 42 U.S.C.
6295(gg)(2)(A(i) Because LED lamps are placed in Part A of EPCA, they
are covered consumer products, and thus the standby and off mode
applicability of these products must be reviewed.
First, to provide context for standby and off-modes, active mode is
defined as the condition in which an energy-using product--is connected
to a main power source; has been activated; and provides one or more
main functions.10 CFR 430.2 DOE's proposals for active mode test
metrics include lumen output, input power, lamp efficacy, CCT, CRI, and
lifetime.
Standby mode is defined as the condition in which energy-using
product--is connected to a main power source; and offers one or more of
the following user-oriented or protective functions: to facilitate the
activation or deactivation of other functions (including active mode)
by remote switch (including remote control), internal sensor, or timer;
or continuous functions, including information or status displays
(including clocks) or sensor-based functions.10 CFR 430.2 Some LED
lamps can be operated by a remote control to activate active mode or to
change the appearance of the light (color or dimming). Therefore,
standby mode applies to LED lamps.
Off mode is defined as the condition in which an energy using
product--is connected to a main power source; and is not providing any
standby or active mode function.10 CFR 430.2 LED lamps do not operate
in off mode because when connected to a main power source, the LED lamp
is either in active mode or standby mode. No other modes of operation
exist for LED lamps beyond active and standby mode.
EPCA directs DOE to amend its test procedures for all covered
products to integrate measures of standby mode and off mode energy
consumption, if technically feasible. (42 U.S.C. 6295(gg)(2)(A))
Standby mode and off mode energy must be incorporated into the overall
energy efficiency, energy consumption, or other energy descriptor for
each covered product unless the current test procedures already account
for and incorporate standby and off mode energy consumption or such
integration is technically infeasible. If an integrated test procedure
is technically infeasible, DOE must prescribe a separate standby mode
and off mode energy use test procedure for the covered product, if
technically feasible. Id. Any such amendment must consider the most
current versions of IEC Standard 62301, ``Household electrical
appliances--measurement of standby power,'' and IEC Standard 62087,
``Methods of measurements for the power consumption of audio, video,
and related equipment,'' \14\ as applicable.
---------------------------------------------------------------------------
\14\ IEC standards are available online at www.iec.ch.
---------------------------------------------------------------------------
DOE proposes separate test methods for standby and active mode
metrics. This proposal is consistent with other lighting products
(fluorescent lamp ballasts and metal halide ballasts) which use
separate test methods for active and standby modes. Any future energy
conservation standards that cover LED lamps will consider the most
effective method of addressing both active and standby mode energy use.
DOE proposes a method of measuring standby mode power in section III.E.
DOE requests comment on its characterization of the modes of
operation that apply to LED lamps.
C. Proposed Approach for Determining Lumen Output, Input Power, Lamp
Efficacy, Correlated Color Temperature, and Color Rendering Index
1. NOPR Proposals
The NOPR proposed to incorporate IES LM-79-2008 for determining
lumen output, input power, and CCT, with some modifications. 77 FR at
21041 (April 9, 2012) IES LM-79-2008 specifies the test setup and
conditions at which the measurements and calculations must be
performed. These include ambient conditions, power supply
characteristics, lamp orientation, and stabilization methods for LED
lamps, and instrumentation and electrical settings. These requirements,
and any related comments, are further discussed in the sections III.C.1
through III.C.4.
Kristopher Kritzer (hereafter referred to as Kritzer) expressed
support for adopting the complete NOPR test method and backed DOE's
efforts to adopt industry practices for testing LED lamps. (Kritzer,
No. 3 at p. 1) Lutron Electronics Company, Inc. (hereafter referred to
as Lutron) and NEMA did not support all test methods proposed in the
NOPR, but did agree that IES LM-79-2008 should be used to determine
lumen output, input power, and CCT. (Lutron, Public Meeting Transcript,
No. 7 at p. 25; NEMA, Public Meeting Transcript, No. 7 at p. 2)
However, several interested parties expressed concern with the overall
proposal. Delft University of Technology (which refers to itself as
TUD) and an anonymous commenter had reservations about adopting the
test methods proposed in the NOPR. TUD indicated that the NOPR proposal
will not guarantee tested LED products are well-qualified. (Anonymous,
No. 8 at p. 1; TUD, No. 15 at p. 1) NEMA, the California Investor Owned
Utilities (hereafter referred to as CA IOUs), and Philips Lighting
Electronics N.A. (hereafter referred to as Philips) urged that DOE not
modify or supplement any industry standard. (NEMA, No. 16 at p. 2, 7;
CA IOUs, No. 19 at p. 5, 6; Philips, Public Meeting Transcript, No. 7
at p. 114) Finally, the Appliance Standards Awareness Project, the
American Council for an Energy Efficient Economy, and the Natural
Resources Defense Council (hereafter referred to as the Joint Comment)
stated that test procedures need to mimic real world installations
whenever possible and, when knowledge of real world installations is
not available, the test method needs to approximate a worst-case
installation scenario. (Joint Comment, No. 18 at p. 1)
IES is the recognized technical authority on illumination, and the
IES LM-79-2008 standard was prepared by the IES subcommittee on Solid-
State Lighting Sources of the IESNA Testing Procedure Committee. IES
LM-79-2008 was also developed in collaboration with the ANSI Solid
State Lighting Joint Working Group C78-09 and C82-09 comprising
individuals from several
[[Page 32023]]
organizations. DOE believes that the committee members who worked on
developing the IES LM-79-2008 standard represent relevant industry
groups and interested parties. Based on an independent review by DOE
and general acceptance by industry, DOE proposes that IES LM-79-2008
specifies much of the information that is required for providing a
complete test procedure for determining lumen output, input power, CCT,
and CRI of LED lamps. DOE agrees that the LED lamp test procedure needs
to mimic real world installations and believes that the procedures
described in the IES LM-79-2008 standard are representative of such
conditions. IES LM-79-2008 specifies the test conditions and setup at
which the measurements and calculations must be performed. However, DOE
proposes some clarifications to establish a repeatable procedure for
all LED lamp testing. These clarifications to IES LM-79-2008 include
mounting orientation and electrical setting requirements. These
requirements, and any clarifications proposed by DOE, are further
discussed in the sections III.C.2 through III.C.4.
2. Test Conditions
In the NOPR, DOE proposed that the ambient conditions for testing
LED lamps be as specified in section 2.0 \15\ of IES LM-79-2008. 77 FR
at 21041. These conditions include setup and ambient temperature
control, as well as air movement requirements. Both are discussed in
further detail below.
---------------------------------------------------------------------------
\15\ IES standards use the reference 2.0, 3.0, etc. for each
primary section heading. Sub-sections under each of these sections
are referenced as 2.1, 2.2, 3.1, 3.2, etc. This SNOPR refers to each
IES section exactly as it is referenced in the standard.
---------------------------------------------------------------------------
Section 2.2 of IES LM-79-2008 specifies that photometric
measurements shall be taken at an ambient temperature of 25 degrees
Celsius ([deg]C) 1 [deg]C. In the NOPR, DOE indicated that
a tolerance of 1[deg]C for the ambient temperature is practical, limits
the impact of ambient temperature on measurements, and would not be
burdensome because the instruments used to measure the temperature
provide greater accuracy than required, allowing the test laboratories
to maintain the temperature within the required tolerance for testing.
Id. Section 2.2 of IES LM-79-2008 further specifies that the
temperature shall be measured at a point not more than one meter from
the LED lamp and at the same height as the lamp. The standard requires
that the temperature sensor that is used for measurements be shielded
from direct optical radiation from the lamp or any other source to
reduce the impact of radiated heat on the ambient temperature
measurement. The NOPR stated that this setup for measuring and
controlling ambient temperature is appropriate for testing because it
requires that the lamp be tested at room temperature and in an
environment that is commonly used for testing other lighting
technologies. Id. DOE did not receive adverse comments, and therefore
maintains this proposal for ambient temperature conditions in the
SNOPR.
In the NOPR, DOE proposed that the requirement for air movement
around the LED lamp be as specified in section 2.4 of IES LM-79-2008,
which requires that the air flow around the LED lamp be such that it
does not affect the lumen output measurements of the tested lamp. Id.
DOE also considered specifying a method for determination of a draft-
free environment, such as that in section 4.3 of IES LM-9-2009,\16\
which requires that a single ply tissue paper be held in place of the
lamp to allow for visual observation of any drafts.
---------------------------------------------------------------------------
\16\ ``IES Approved Method for the Electrical and Photometric
Measurement of Fluorescent Lamps.'' Approved January 31, 2009.
---------------------------------------------------------------------------
Philips, Osram Sylvania, Inc. (hereafter referred to as OSI), and
NEMA all indicated that the surrounding air temperature and airflow for
LED lamps does not have a noticeable impact on long-term lumen
degradation. Based on this, DOE believes that the IES LM-79-2008 air
movement requirements proposed in the NOPR are more than adequate to
ensure the accuracy of test data. (Philips, Public Meeting Transcript,
No. 7 at p. 27; OSI, Public Meeting Transcript, No. 7 at pp. 27-28;
NEMA, Public Meeting Transcript, No. 7 at pp. 2-3; NEMA, No. 16 at p.
2-3) However, other stakeholders suggested adding quantitative
requirements for air movement. The People's Republic of China
(hereafter referred to as P.R. China) suggested that air movement in
the vicinity of the luminaire not exceed 0.2 m/s. For lamps designed
with a larger tolerance for ambient temperature changes, faster air
movement may be acceptable. (P.R. China, No. 12 at p. 3) The Joint
Comment noted that the air movement procedures in IES LM-79-2008 are
informative, but not very specific. Therefore, they recommended that
DOE investigate a quantitative approach so that air flow around the
device is better understood. However, the Joint Comment expressed
concern that direct measurement of the airflow (anemometry) would
increase the testing burden to manufacturers substantially; instead,
they recommended DOE investigate a suitable proxy measure to judge the
stability of the airflow around the lamp. As an example, they suggested
DOE may want to consider stability criteria on a measurement of the
case temperature. The Joint Comment noted that it is likely that other
parameters may also provide valuable information about the airflow
while minimizing testing burden. (Joint Comment, No. 18 at p. 3)
Although DOE agrees that the air movement requirement in IES LM-79-
2008 could be more precise, DOE is maintaining its proposal from the
NOPR not to modify the surrounding air temperature and airflow
specifications provided in IES LM-79-2008. DOE does not believe that
additional requirements to establish a draft-free environment would
improve measurement accuracy relative to current industry practice.
Furthermore, specifying a quantitative procedure for measuring air
movement would result in an unnecessary increase to testing burden.
Therefore, in this SNOPR, DOE maintains its proposal to retain the
requirements in IES LM-79-2008 to ensure that air movement is minimized
to acceptable levels. These requirements would apply to lamps measured
in both active mode and standby mode.
3. Test Setup
a. Power Supply
In the NOPR, DOE proposed that section 3.1 and 3.2 of IES LM-79-
2008 be incorporated by reference to specify requirements for both
alternating current (AC) and direct current (DC) power supplies. 77 FR
at 21042. Section 3.1 specifies that an AC power supply shall have a
sinusoidal voltage waveshape at the input frequency required by an LED
lamp such that the root mean square (RMS) \17\ summation of the
harmonic components does not exceed three percent of the fundamental
frequency \18\ while operating the LED lamp. Section 3.2 of IES LM-79-
2008 also requires that the voltage of an AC power supply (RMS voltage)
or DC power supply (instantaneous voltage) applied to the LED lamp be
within 0.2 percent of the specified lamp input voltage (see
section III.C.3.d for discussion of the proposed electrical settings,
including input voltage). These requirements are achievable with
[[Page 32024]]
minimal testing burden and provide reasonable stringency in terms of
power quality based on their similarity to voltage tolerance
requirements for testing of other lighting technologies. DOE did not
receive adverse comment on this proposal and, therefore, this proposal
remains unchanged for the SNOPR. These power supply requirements would
apply to lamps measured in both active mode and standby mode.
---------------------------------------------------------------------------
\17\ Root mean square (RMS) voltage/current is a statistical
measure of the magnitude of a voltage/current signal. RMS voltage/
current is equal to the square root of the mean of all squared
instantaneous voltages/currents over one complete cycle of the
voltage/current signal.
\18\ Fundamental frequency, often referred to as fundamental, is
defined as the lowest frequency of a periodic waveform.
---------------------------------------------------------------------------
b. Instrumentation
In the NOPR, DOE proposed that instrumentation requirements for the
AC power meter and the AC and DC voltmeter and ammeter, as well as the
acceptable tolerance for these instruments, be as specified in section
8.0 of IES LM-79-2008. Id. Section 8.1 of IES LM-79-2008 specifies that
for DC-input LED lamps, a DC voltmeter and DC ammeter shall be
connected between the DC power supply and the LED lamp under test. The
DC voltmeter shall be connected across the electrical power input of
the LED lamp, and the input electrical power shall be calculated as the
product of the measured input voltage and current. Section 8.2 of IES
LM-79-2008 specifies that the tolerance for the DC voltage and current
measurement instruments shall be 0.1 percent. For AC-input
LED lamps, section 8.1 of IES LM-79-2008 further specifies that an AC
power meter shall be connected between the AC power supply and the LED
lamp under test. The AC power, input voltage, and current shall be
measured. Section 8.2 of IES LM-79-2008 specifies that the tolerance of
the AC voltage and current measurement instruments shall be 0.2 percent and the tolerance of the AC power meter shall be
0.5 percent. In the NOPR, DOE concluded that the electrical
instrumentation requirements set forth in section 8.0 of IES LM-79-2008
are achievable and provide reasonable stringency in terms of
measurement tolerance based on their similarity to instrument tolerance
requirements for testing of other lighting technologies. Id. DOE did
not receive adverse comment on these electrical instrumentation
requirements and, therefore, this proposal remains unchanged for the
SNOPR.
Regarding photometric instrumentation used for measuring lumen
output, CCT, and CRI, DOE proposed in the NOPR that either a sphere-
spectroradiometer, sphere-photometer, or goniophotometer system be used
for lumen output measurement of the LED lamp as specified in IES LM-79-
2008. DOE requested comment on the differences in values measured by an
integrating sphere (via photometer or spectroradiometer) versus a
goniophotometer. 77 FR at 21042 NEMA commented that both systems are
appropriate for lumen determination, but acknowledged that a perfect
correlation between the two techniques is not possible. (NEMA, No. 16
at p. 3)
While DOE recognizes that the integrating sphere and
goniophotometer (a goniometer fitted with a photometer as the light
detector) are both valid means of photometric measurement, DOE is
concerned about the potential for a difference in the measured values.
A test procedure that yields more than one possible value depending on
instrumentation presents problems for certification and enforcement. If
DOE and the manufacturer use different test methods, DOE could find
that a lamp certified as compliant could be tested as non-compliant
during a verification or enforcement proceeding. IES LM-79-2008 does
not explicitly specify the scanning resolution (i.e., quantity and
location of measurements around the lamp), and instead provides
guidance that must be implemented differently for each lamp. DOE also
determined that further specification of the goniophotometer method is
unreasonable, because the scanning resolution specification would need
to be adequate for the lamp that requires the finest resolution. This
would likely present an overly burdensome test method for many other
lamps that could be measured at a lower resolution. In contrast, use of
an integrating sphere enables photometric characteristics of the LED
lamp to be determined with a single measurement. Therefore, integrating
spheres are the preferred method for photometric measurement due to the
reduction in time required for testing.
In consideration of the lack of measurement correlation between
integrating spheres and goniophotometers and the reduced burden and
much higher incidence of use of integrating spheres, DOE proposes in
the SNOPR to require all photometric measurements, including lumen
output, CCT, and CRI to be carried out in an integrating sphere and
that goniometer systems must not be used. Therefore, DOE proposes that
the instrumentation used for lumen output measurements be as described
in sections 9.1 and 9.2 of IES LM-79-2008, and CCT and CRI measurements
be as described in section 12.0 of IES LM-79-2008 with the exclusion of
section 12.2 of IES LM-79-2008, as goniometers must not be used. DOE
invites interested parties to comment on the proposal to require all
photometric values be measured by an integrating sphere (via photometer
or spectroradiometer). These instrumentation requirements would apply
to lamps measured in both active mode and standby mode.
c. Lamp Mounting and Orientation
In the NOPR, DOE considered testing LED lamps as specified in
section 6.0 of IES LM-79-2008, which states that LED lamps shall be
tested in the operating orientation recommended by the lamp
manufacturer for the intended use of the LED lamp. Id. As discussed in
the NOPR, DOE determined that manufacturers do not typically specify
the operating orientation for an LED lamp in their product literature.
Further, DOE indicated that it is possible manufacturers would
recommend an orientation for testing that provides the highest lumen
output rather than the orientation in which the lamp is most frequently
operated in practice. Therefore, the NOPR proposed that an LED lamp be
mounted as specified in section 2.3 of IES LM-79-2008 and be positioned
in the base-up, base-down, and horizontal orientations for testing.
Numerous commenters raised concerns about DOE's proposal. General
Electric Lighting (hereafter referred to as GE), Philips, NEMA, Samsung
Electronics (hereafter referred to as Samsung), and P.R. China
commented that the base-up and base-down orientations constitute the
best and worst-case scenarios. (GE, Public Meeting Transcript, No. 7 at
p. 29; Philips, Public Meeting Transcript, No. 7 at pp. 29-30; NEMA,
No. 16 at p. 3; Samsung, No. 14 at p. 1; China, No. 12 at p. 3) Samsung
stated that testing in the base up and base down positions is also
consistent with ENERGY STAR test procedures. (Samsung, No. 14 at p. 1)
In addition, GE and NEMA commented that testing in the horizontal
position with either type of sphere will add uncertainty to the lumen
output measurement, and that testing in the horizontal position with a
goniophotometer is very difficult or even impossible. (GE, Public
Meeting Transcript, No. 7 at pp. 42-43; NEMA, No. 16 at p. 3)
Underwriter Laboratories (hereafter referred to as UL) indicated that
shadowing is an issue with testing in the horizontal position. Lamps
are usually supported from above or below, and if tested horizontally
the support structure could interfere with the light measurement. (UL,
Public Meeting Transcript, No. 7 at p. 54) NEMA commented that current
FTC instruction for CFLs does not require testing in multiple
orientations, only that the manufacturer specify if an orientation
[[Page 32025]]
change will result in a greater than five percent difference in
measured performance. (NEMA, No. 16 at p. 6) The Republic of Korea
(hereafter referred to as South Korea) suggested that DOE be consistent
with both International Electrotechnical Commission (IEC) 62612 \19\
and IES LM-79-2008, which require that the orientation of lamps during
testing follow the manufacturer's recommendations. (South Korea, No. 17
at p. 2) Finally, P.R. China noted that testing in the horizontal
position will increase the cost of the testing as well as the total
time required for testing. (P.R. China, No. 12 at p. 3)
---------------------------------------------------------------------------
\19\ IEC/PAS 62612: Self-ballasted LED-lamps for general
lighting services--Performance requirements.
---------------------------------------------------------------------------
Other commenters supported DOE's proposals and suggested further
research. The Joint Comment and the CA IOUs agreed with DOE's proposal
to include the horizontal position for lumen output testing because it
is likely a worst-case condition. This is because heat sink fins are
most effective at dissipating heat when air flow is parallel to the
direction of the fins, rather than when air flow is perpendicular to
the fins. Because most heat sink fins are parallel to the body of the
lamp, they are likely to dissipate heat differently when the lamp is
oriented vertically than when oriented horizontally. When heat is not
dissipated effectively in a lamp, lumen output generally decreases.
(Joint Comment, No. 18 at p. 4; CA IOUs, No. 19 at p. 6) In addition,
the CA IOUs indicated that they expect to have LED lamp performance
data collected in all three orientations by the end of 2012
(subsequently published in February 2013).\20\ The CA IOUs further
commented that manufacturer concerns about testing in the horizontal
position are not an issue for testing in a sphere-spectroradiometer or
sphere-photometer. The CA IOUs stated that accurate horizontal
measurements are regularly taken for other lamp technologies, and they
do not believe any unique challenge exists for measuring LED lamps that
do not exist for other lamps of similar shapes and base types. (CA
IOUs, No. 19 at p. 6) The Joint Comment suggested that DOE investigate
whether shadowing is a significant concern in a goniophotometer when
the lamp is configured horizontally. (Joint Comment, No. 18 at p. 4)
The Joint Comment also suggested that DOE consider the appropriateness
of testing at intermediate angles for certain types of lamps that
contain heat pipes, noting that heat pipes often have the best heat
transfer performance at inclinations of 60-70 degrees. (Joint Comment,
No. 18 at p. 4)
---------------------------------------------------------------------------
\20\ CLTC, ``Omni-Directional Lamp Testing'' Prepared for PG&E
and CLASP, February 25th, 2013. https://www.energy.ca.gov/appliances/2013rulemaking/documents/responses/Lighting_12-AAER-2B/California_IOUs_Response_to_the_Invitation_to_Participate_for_LED_Lamps_REFERENCE/PGandE_2013a_Omni-Directional_Lamp_Testing-Report_Draft.pdf.
---------------------------------------------------------------------------
In light of commenters' varying opinions about the impact of lamp
orientation on lamp performance, DOE collected test data for several
LED lamps tested in each of the three orientations. DOE investigated
two sets of photometric test data, the first provided by ENERGY STAR
and the second (mentioned by the CA IOUs in the previous paragraph)
from a collaborative testing effort between the Pacific Gas and
Electric Company (hereafter referred to as PG&E), California Lighting
Technology Center (hereafter referred to as CLTC), and the
Collaborative Labeling and Appliance Standards Program (hereafter
referred to as CLASP). Id. These test data represent 10 samples each of
47 different LED lamp products. Of the 47 lamp products tested, 36 were
mounted in base-up, base-down, and horizontal configurations, and 11
were mounted in base-up and base-down configurations. DOE analyzed the
data to determine the variation of input power, lumen output, CCT, and
CRI in each of the three orientations. The analysis of the test data
revealed that some lamp models exhibited variation between the three
orientations. Of the three orientations, analysis indicated that the
base-up and base-down orientations represent the best (highest lumen
output) and worst (lowest lumen output) case scenarios. Therefore, DOE
believes that there is no need to test horizontally.
The Joint Comment stated that other lamp orientations may represent
the best-case scenario and suggested that DOE investigate testing at
intermediate angles, such as 60 to 70 degrees. DOE notes that
intermediate angles could represent a best-case scenario for some
lamps; however, testing LED lamps at these angles is not common
industry practice. Although there is no data available for testing LED
lamps at intermediate angles, DOE consulted an LED lamp manufacturer as
to whether intermediate angle testing could be a best-case scenario for
some LED lamps. The manufacturer indicated that this could improve
efficiency theoretically; however, this possible improvement would be
negligible and likely within the measurement error of the lumen output
measuring equipment. From this, DOE has determined that these
performance gains would not be measureable. Therefore, DOE is not
proposing testing of LED lamps at intermediate angles.
As mentioned above, DOE also received comments about whether it was
possible to test LED lamps in all potential orientations. GE, NEMA, and
UL indicated that testing in the horizontal position could interfere
with the lumen output measurement. (GE, Public Meeting Transcript, No.
7 at pp. 42-43; NEMA, No. 16 at p. 3; UL, Public Meeting Transcript,
No. 7 at p. 54) DOE researched this concern by consulting with the
Lighting Research Center (LRC), which has extensive lamp testing
experience, and believes that testing lumen output in the horizontal
position does not lead to significant measurement error when using the
majority of sphere-spectroradiometer, sphere-photometer, and
goniophotometer systems. For either a sphere-spectroradiometer or
sphere-photometer system, the bracket, which secures the lamp in place,
can be designed and configured to eliminate any significant measurement
error due to shadowing. For large goniophotometer systems, there would
be sufficient space to make a bracket to hold the lamp in any
orientation without risk of significant shadowing. It is possible that
smaller goniophotometer systems could have mounting and bracket
limitations that result in error when testing in the horizontal
orientation due to shadowing. However, as discussed in section
III.C.3.b, DOE proposes in the SNOPR to require all photometric
measurements to be carried out in an integrating sphere and that
goniometer systems must not be used.
In the SNOPR, DOE proposes that LED lamps be positioned such that
an equal number of units are oriented in the base-up and base-down
orientations. This proposal specifies two commonly used orientations
for LED lamps that span the highest and lowest light-output scenarios,
creating a dataset that represents average performance in practice.
These lamp mounting and orientation requirements would apply to lamps
measured in both active mode and standby mode. DOE requests comment on
the proposal for an equal number of lamps to be operated in the base-up
and base-down orientations during lumen output, input power, CCT, and
CRI testing.
d. Electrical Settings
In the NOPR, DOE proposed requiring testing of LED lamps at the
rated voltage as specified in IES LM-79-2008. For lamps with multiple
operating voltages, DOE proposed that lamps be tested at
[[Page 32026]]
120 volts because 120 volts is the most common operating voltage of
available lamps. However, if the lamp is not rated at 120 volts, DOE
proposed that it be tested at the highest rated voltage. Id. NEMA
disagreed with DOE's proposal to test at rated voltage only, arguing
the proposal was in conflict with FTC regulations that require testing
lamps at 120 volts and the rated voltage. (NEMA, No. 16 at p. 3)
In this SNOPR, DOE maintains the NOPR proposal but, in addition,
indicates that manufacturers may also test at other operating voltages
as long as the final DOE test procedure is used for making energy
representations. These electrical settings would apply to lamps
measured in both active mode and standby mode. To ensure the SNOPR
proposal is not in conflict with the FTC Lighting Facts label
requirements, as was suggested by NEMA, DOE reviewed the FTC
regulations detailed in 16 CFR 305.15. The FTC regulation states that a
general service lamp shall be measured at 120 volts, regardless of the
lamp's design or rated voltage. If a lamp's design voltage is 125 volts
or 130 volts, the disclosures of the wattage, light output, energy
cost, and lifetime must disclose the voltage at which these metrics
were measured. DOE's proposal is not in conflict with FTC's Lighting
Facts requirements because manufacturers must test at 120 volts as
required by FTC and, if the LED lamp is rated for additional voltages,
the lamp may also be tested at the highest rated voltage. This supports
FTC's program and does not provide conflicting instructions.
In the NOPR, DOE proposed incorporating section 7.0 of IES LM-79-
2008, which specifies electrical settings for LED lamps with multiple
modes of operation, such as variable CCT and dimmable lamps. 77 FR at
21043. Section 7.0 of IES LM-79-2008 indicates LED lamps with variable
CCT shall be tested in each mode of operation, and for dimmable lamps,
directs that they be tested at the maximum input power.
Philips commented that when specifying electrical settings for
variable CCT lamps it is important that DOE consider the scenario that
the testing is intended to reflect (i.e., worst-case versus most common
operating conditions) because lumen output can change based on the CCT
mode. (Philips, Public Meeting Transcript, No. 7 at p. 32) OSI agreed
with this point and indicated that in the future it is foreseeable that
LED lamps with variable CCT, CRI, and lumen output will be available.
(OSI, Public Meeting Transcript, No. 7 at pp. 32-33) Both P.R. China
and Samsung stated that LED lamps with multiple modes of operation are
currently available. (P.R. China, No. 12 at p. 4; Samsung, No. 14 at p.
1) GE and Samsung indicated that multiple mode lamps in the future
could operate at continuously variable CCT making testing at a distinct
CCT impossible. (GE, Public Meeting Transcript, No. 7 at p. 32;
Samsung, No. 14 at p. 1) OSI commented that testing at the worst-case
scenario could be a possible option for LED lamps with variable CCT,
while Samsung suggested requiring both a best- and worst-case scenario.
(OSI, Public Meeting Transcript, No. 7 at pp. 33; Samsung, No. 14 at p.
1) P.R. China suggested DOE follow international standard IEC/PAS
62717-2011,\21\ which states that LED modules with adjustable color
point must be adjusted/set to one fixed value as indicated by the
manufacturer or responsible vendor. (P.R. China, No. 12 at p. 3) At the
May 3, 2012 NOPR public meeting (hereafter the May 2012 public
meeting), NEMA argued against testing at a CCT, CRI, or lumen output
setting that would rarely be used in the field. For lamps that can vary
CCT over the power range, NEMA suggested testing the lamps only at the
CCT that occurs at full power. (NEMA, Public Meeting Transcript, No. 7
at p. 33; NEMA, No. 16 at p. 3) Finally, regarding dimming, NEMA agreed
with DOE's proposal to measure dimmable lamps at full power as this
will reflect the rating on the packaging. (NEMA, No. 16 at p. 3)
---------------------------------------------------------------------------
\21\ IEC/PAS 62717: LED modules for general lighting--
Performance requirements.
---------------------------------------------------------------------------
DOE believes that LED lamps with multiple modes of operation,
including variable CCT and CRI as well as dimmable lamps, should be
tested at maximum input power because this is the highest energy
consuming state. Therefore, DOE proposes to require testing for such
lamps at the mode that occurs at maximum input power, since this is the
highest energy consuming state. When multiple modes (such as multiple
CCTs and CRIs) occur at the same maximum input power, the manufacturer
can select any of these modes for testing. Manufacturers may also test
at other modes as long as the final DOE test procedure is used for
making representations about the energy consumption of an LED lamp. All
measurements (lumen output, input power, efficacy, CCT, CRI, lifetime,
and standby mode power) must be conducted at the same mode of
operation. DOE invites comment on its proposals for testing lamps for
which multiple modes (such as multiple CCTs and CRIs) can occur at the
same maximum input power.
4. Test Method
a. Lamp Seasoning
In the NOPR, DOE proposed requiring energizing and operating LED
lamps for 1,000 hours to season them before beginning photometric
measurements. 77 FR at 21043. DOE proposed a 1,000 hour seasoning time
because it has been indicated by industry \22\ \23\ that light output
of an LED source (and therefore, potentially the lamp) can change
during the first 1,000 hours of operation. DOE also noted that IES TM-
21-2011 \24\ specifies that the data obtained from the first 1,000
hours of operating an LED source shall not be used to project the
lifetime of an LED source.
---------------------------------------------------------------------------
\22\ Cheong, Kuan Yew. ``LED Lighting Standards Update.'' CREE,
August 5, 2011. Page 31. www.nmc.a-star.edu.sg/LED_050811/Kuan_
CREE.pdf
\23\ Richman, Eric. ``Understanding LED Tests: IES LM-79, LM-80,
and TM-21.'' DOE SSL Workshop, July 2011. Page 13. https://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/richman_tests_sslmiw2011.pdf
\24\ ``Projecting Long Term Lumen Maintenance of LED Light
Sources.'' Approved by IES on July 25, 2011.
---------------------------------------------------------------------------
Cree, Philips, Feit Electric Company, NEMA, P.R. China, the Joint
Comment, CA IOUs, Northwest Energy Efficiency Alliance (hereafter
referred to as NEEA), and South Korea all commented that LED lamps not
be seasoned for 1,000 hours prior to collecting lumen output data. They
argued that due to the evolving nature of these products, there is no
common seasoning time. (Cree, Public Meeting Transcript, No. 7 at pp.
34-35; Philips, Public Meeting Transcript, No. 7 at p. 35, 36; Feit,
Public Meeting Transcript, No. 7 at p. 45; NEMA, Public Meeting
Transcript, No. 7 at p. 36; P.R. China, No. 12 at p. 4; NEMA, No. 16 at
p. 3; Joint Comment, No. 18 at pp. 5-6; CA IOUs, No. 19 at p. 5; NEEA,
No. 20 at p. 2; South Korea, No. 17 at p. 2) Cree indicated that sudden
increases or decreases in light output in the first 1,000 hours of
operation depend on several factors in the construction of the LED
lamp. (Cree, Public Meeting Transcript, No. 7 at pp. 36-37) P.R. China,
NEEA, and the CA IOUs stated that DOE should remain consistent with the
specifications of IES LM-79-2008, and require no seasoning prior to
photometric measurements. (P.R. China, No. 12 at p. 4; NEEA, No. 20 at
p. 2; CA IOUs, No. 19 at p. 5)
The Joint Comment indicated that when taking photometric
measurements, it is not obvious if seasoning is necessary. They
suggested that DOE investigate and report on the
[[Page 32027]]
necessity of seasoning lamps prior to photometric measurements, as this
seasoning is in direct conflict with procedures established in IES LM-
79-2008. Should DOE decide that there is sufficient variability in
devices that can be mitigated by seasoning; they recommend that DOE
collaborate with industry to minimize testing burden and potential re-
testing of current LED sources/lamps. (Joint Comment, No. 18 at pp. 5-
6) The National Institute of Standards and Technology (hereafter
referred to as NIST) and Samsung, however, commented that seasoning LED
lamps for 1,000 hours prior to collecting lumen output data is
reasonable. (NIST, Public Meeting Transcript, No. 7 at p. 47; Samsung,
No. 14 at p. 1) NIST argued that including a seasoning time of 1,000
hours would help identify faulty products. (NIST, Public Meeting
Transcript, No. 7 at p. 47)
In the SNOPR, DOE proposes to eliminate the requirement to season
lamps for 1,000 hours prior to taking photometric measurements.
Although some LED lamps do experience changes in light output during
the first 1,000 hours of operation, independent research and
manufacturer comments indicate that this is not true for all LED lamps.
Each LED lamp is unique, and as a result, initial trends in light
output are not consistent from lamp to lamp. Therefore, seasoning all
lamps for a predetermined duration does not provide a more accurate
initial test measurement, though it does increase testing burden. The
current industry-accepted test procedure, IES-79-2008, reflects this
understanding by not allowing lamp seasoning. Therefore, the SNOPR
proposes to remain consistent with section 4.0 of IES LM-79-2008, which
indicates LED lamps shall not be seasoned before beginning photometric
measurements. These seasoning requirements would apply to lamps
measured in both active mode and standby mode. DOE requests comment on
this proposal.
b. Lamp Stabilization
In the NOPR, DOE proposed stabilizing lamps for the time specified
in section 5.0 of IES LM-79-2008. DOE further proposed that stability
of the LED lamp is reached when the variation [(maximum--minimum)/
minimum] of at least three readings of light output and electrical
power over a period of 30 minutes, taken 15 minutes apart, is less than
0.5 percent. 77 FR at 21043. This calculation was included to add
clarification to the method specified in section 5.0 of IES LM-79-2008.
For stabilization of a number of products of the same model, section
5.0 of IES LM-79-2008 suggests that preburning \25\ of the product may
be used if it has been established that the method produces the same
stabilized condition as when using the standard method described above.
---------------------------------------------------------------------------
\25\ IES LM-79-2008 defines preburning as the operation of a
light source prior to mounting on a measurement instrument, to
shorten the required stabilization time on the instrument.
---------------------------------------------------------------------------
NEMA agreed that the lamp stabilization method in IES LM-79-2008 be
used for the LED lamp test procedure but argued that the standard did
not need further clarification. (NEMA, Public Meeting Transcript, No. 7
at pp. 38-39; NEMA, No. 16 at p. 3) However, GE advocated for
presenting the lamp stabilization equation as a percent. (GE, Public
Meeting Transcript, No. 7 at p. 39)
DOE reconsidered its NOPR proposal, but came to the same conclusion
for the SNOPR. IES LM-79-2008 does not clearly specify the calculation
for determining the stabilization value, leaving this requirement open
to interpretation. Therefore, DOE continues to propose in the SNOPR
that variation of at least three readings of light output and
electrical power over a period of 30 minutes, taken 15 minutes apart is
calculated as [maximum--minimum]/minimum. DOE expects this proposal is
the same or very similar to the stabilization calculation methods
already used in practice. As in the NOPR, DOE continues to propose in
this SNOPR that stabilization of multiple products of the same model
can be carried out as specified in section 5.0 of IES LM-79-2008. These
stabilization requirements would apply to lamps measured in both active
mode and standby mode.
c. Lumen Output Metric
In the NOPR, DOE proposed that the test method for measuring the
lumen output of an LED lamp be as specified in section 9.0 of IES LM-
79-2008 and proposed the same lumen output measurement method for all
LED lamps, including directional \26\ LED lamps. Id. For directional
LED lamps, DOE suggested measuring total lumen output from the lamp
rather than beam lumens \27\ because other directional lamp
technologies currently measure and report total lumen output on the FTC
Lighting Facts label.
---------------------------------------------------------------------------
\26\ Directional lamps are designed to provide more intense
light to a particular region or solid angle. Light provided outside
that region is less useful to the consumer, as directional lamps are
typically used to provide contrasting illumination relative to the
background or ambient light.
\27\ Please refer to the NOPR Test Procedures for Light-Emitting
Diode Lamps (Docket No. EERE-2011-BT-TP-0071) for a detailed
explanation of why DOE is not proposing to measure beam lumens for
directional LED lamps (77 FR at 21043; April 9, 2012).
---------------------------------------------------------------------------
As discussed in section III.C.3.b, DOE proposes in the SNOPR that
goniometers may not be used for photometric measurements. As a result,
DOE proposes that the method for measuring lumen output in the SNOPR be
as specified in sections 9.1 and 9.2 of IES LM-79-2008. Section 9.3 of
IES LM-79-2008 discusses usage of goniometers, and DOE is not including
that method in the SNOPR proposal.
Regarding directional lamps, NEMA commented that industry has not
yet reached consensus regarding a light output metric for directional
lamps. (NEMA, Public Meeting Transcript, No. 7 at p. 43; NEMA, No. 16
at p. 4) Furthermore, NEMA highlighted that DOE has other rulemakings
specifically for reflector lamps that specify the use of total lumens.
Therefore, a deviation from measuring total lumens in the LED lamp test
procedure would have a significant impact on all types of directional
lamps. (NEMA, Public Meeting Transcript, No. 7 at p. 44) The CA IOUs
commented that if measuring beam lumens is only required for the LED
lamp test procedure and not all general service reflector lamps, this
could hinder the industry's ability to compare lamps across
technologies. (CA IOUs, No. 19 at p. 7) However, the CA IOUs supported
DOE's efforts to develop a beam efficacy metric and recommended that
this metric be applied to all directional lamp technologies. (CA IOUs,
No. 19 at p. 7) In contrast, P.R. China argued that testing total lumen
output instead of the beam lumen output and center-beam candle power
might bring inconsistency and confusion to the industry. Therefore,
they recommended that DOE reference the Energy Star Program
Requirements for Integral LED Lamps: Eligibility Criteria--Version 1.4
\28\ which specifies that the center-beam candle power and beam angle
be tested for directional lamps. (P.R. China, No. 12 at p. 4)
---------------------------------------------------------------------------
\28\ ``Energy Star Program Requirements for Integral LED Lamps:
Eligibility Criteria--Version 1.4.'' U.S. Environmental Protection
Agency, August 28, 2013.
---------------------------------------------------------------------------
Because total lumen output is the measurement reported on the FTC
Lighting Facts label for other directional lamp technologies, DOE
agrees with NEMA and the CA IOUs comments not to include measurements
for beam lumens in this test procedure. Therefore, DOE maintains its
proposal from the NOPR to measure the total lumen output for LED lamps.
Measuring the total lumen output for LED lamps
[[Page 32028]]
will enable industry and consumers to compare general service lamp
products across different technologies.
d. Input Power
Following seasoning and stabilization, input power to the LED lamp
is measured using the instrumentation specified in section III.C.3.b.
All test conditions and test setup requirements from sections III.C.2
and III.C.3 should also be followed.
e. Lamp Efficacy Metric
In the NOPR, DOE proposed test procedures for measuring lumen
output and input power, and also specified testing dimmable lamps at
full light output. 77 FR at 21041. However, commenters noted that
efficacy may appear in future mandates, and therefore recommended it be
included in DOE's test procedure for LED lamps. The CA IOUs commented
that a test procedure with an efficacy metric would be needed in the
future to comply with federal legislative mandates, and for this reason
they urged DOE to include an efficacy metric in the test procedure.
Both the CA IOUs and NEEA recommended that DOE adopt IES LM-79-2008,
which defines luminous efficacy as the quotient of the measured total
luminous flux (in lumens) and the measured electrical input power (in
watts), or lumens per watt. (CA IOUs, No. 19 at p. 3; NEEA, No. 20 at
p. 1)
As discussed in section I, this proposed test procedure will
support any potential future energy conservation standards for general
service LED lamps, which may include efficacy as a metric for setting
standards. Accordingly, for the SNOPR, DOE proposes that the efficacy
of an LED lamp be calculated by dividing measured initial lamp lumen
output in lumens by the measured lamp input power in watts, in units of
lumens per watt. DOE believes that providing a calculation for efficacy
of an LED lamp does not increase testing burden because the test
procedure already includes metrics for input power and lumen output.
DOE requests comment on the proposal to add a calculation for efficacy
of an LED lamp.
f. Measuring Correlated Color Temperature
In the NOPR, DOE proposed that the CCT of an LED lamp be calculated
as specified in section 12.4 of IES LM-79-2008. 77 FR at 21044. The CCT
is determined by measuring the relative spectral distribution,
calculating the chromaticity coordinates, and then matching the
chromaticity coordinates to a particular CCT of the Planckian radiator.
The setup for measuring the relative spectral distribution, which is
required to calculate the CCT of the LED lamp, shall be as specified in
section 12.0 of IES LM-79-2008. That section describes the test method
to calculate CCT using a sphere-spectroradiometer system and a
spectroradiometer or colorimeter system. Section 12.0 of IES LM-79-2008
also specifies the spectroradiometer parameters that affect CCT and the
method to evaluate spatial non-uniformity of chromaticity.
South Korea disagreed with the proposal in the NOPR and recommended
that DOE follow industry standard IEC/PAS 62612 which states that
nominal CCT values shall be reported (South Korea, No. 17 at pp. 3-4).
Nominal CCT values are defined by a region of the chromaticity diagram
and any lamp that falls in a certain region is assigned a single CCT
value. However, nominal CCT values do not address all regions of the
chromaticity diagram. Although manufacturers in the marketplace may
choose to design lamps that fall within regions defined by nominal CCT,
DOE's goal is to establish one test method that applies to all LED
lamps. Therefore, DOE is not proposing to follow a nominal CCT
methodology and maintains its proposal in the NOPR regarding the method
to calculate the CCT of an LED lamp. Furthermore, as discussed in
section III.C.3.b, DOE also proposes in the SNOPR to require all
photometric measurements (including CCT) be carried out in an
integrating sphere, and that goniometer systems must not be used.
Therefore, DOE proposes that the instrumentation used for CCT
measurements be as described in section 12.0 of IES LM-79-2008 with the
exclusion of section 12.2 of IES LM-79-2008.
g. Measuring Color Rendering Index
In the SNOPR, DOE proposes to add a requirement that the CRI of an
LED lamp be determined as specified in section 12.4 of IES LM-79-2008.
As discussed in section III.C.3.b, DOE also proposes in the SNOPR to
require all photometric measurements (including CRI) be carried out in
an integrating sphere. Therefore, the setup for measuring the relative
spectral distribution, which is required to calculate the CRI of the
LED lamp, must be as specified in section 12.0 of IES LM-79-2008 with
the exclusion of section 12.2 of IES LM-79-2008, as goniometer systems
must not be used. Section 12.4 of IES LM-79-2008 also specifies that
CRI be calculated according to the method defined in the International
Commission on Illumination (CIE) 13.3-1995.\29\ DOE proposes that the
test procedure for LED lamps include measurement methods for CRI in
order to support the upcoming general service lamps energy conservation
standard rulemaking. DOE requests comment on the proposal to add CRI to
the test procedure for LED lamps.
---------------------------------------------------------------------------
\29\ ``Method of Measuring and Specifying Colour Rendering
Properties of Light Sources.'' Approved by CIE in 1995.
---------------------------------------------------------------------------
D. Proposed Approach for Lifetime Measurements
1. LED Lamp Lifetime Definition
There are currently no industry standards that define or provide
instructions for measuring the lifetime \30\ of LED lamps. Thus, for
the NOPR, DOE conducted literature research and interviewed several
subject matter experts to understand how industry characterized
lifetime for these products. Based on the information gathered, DOE
proposed to measure lumen maintenance to determine the lifetime of LED
lamps. Although other lighting technologies define lamp lifetime as the
time at which 50 percent of tested samples stop producing light,
industry believes that an LED lamp has reached the end of its useful
life when it achieves a lumen maintenance of 70 percent (i.e. 70
percent of initial lumen output, or L70). 77 FR at 21046.
---------------------------------------------------------------------------
\30\ In the NOPR, DOE used the term ``rated lifetime.'' For the
SNOPR, DOE replaces the term ``rated lifetime'' with ``lifetime'' to
refer to the same parameter.
---------------------------------------------------------------------------
Philips, OSI, and Cree agreed that currently no industry accepted
procedure exists for measuring the lifetime of LED-based lighting
products. (Philips, Public Meeting Transcript, No. 7 at p. 64; OSI,
Public Meeting Transcript, No. 7 at pp. 74-75; Cree, Public Meeting
Transcript, No. 7 at p. 65) However, Litecontrol and NEMA disagreed
with DOE's proposal, stating that the report LED Luminaire Lifetime:
Recommendation for Testing and Reporting \31\ explicitly argues that
lumen maintenance alone cannot be used as a proxy for the lifetime of
LED-based lighting products. (Litecontrol, No. 11 at p. 1; NEMA, No. 16
at p. 5) Radcliffe Advisors and the CA IOUs emphasized that color shift
be considered when determining the lifetime because this could also
render a lamp un-usable or undesirable to a consumer before the lamp
reaches L70. (Radcliffe Advisors,
[[Page 32029]]
No. 13 at p. 1; CA IOUs, No. 19 at p. 4)
---------------------------------------------------------------------------
\31\ U.S. Department of Energy, ``LED Luminaire Lifetime:
Recommendation for Testing and Reporting,'' June 2011. https://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/led_luminaire-lifetime-guide_june2011.pdf.
---------------------------------------------------------------------------
In the absence of industry consensus regarding a definition or test
procedure for lifetime, NEMA, Lutron, the CA IOUs, and Radcliffe
Advisors emphasized that DOE should wait for industry to develop new
and revised standards that address lifetime and then reference them for
the purposes of the FTC Lighting Facts label. (NEMA, No. 16 at p. 2;
Lutron, Public Meeting Transcript, No. 7 at p. 80; CA IOUs, No. 19 at
p. 5; Radcliffe Advisors, No. 13 at p. 1) NEMA indicated that this
includes revisions of IES LM-79-2008, IES LM-80-2008,\32\ and emerging
standards IES LM-84 \33\ and IES TM-26.\34\ (NEMA, No. 16 at p. 2, 5,
7) The Joint Comment, NEMA, NEEA, and the CA IOUs encouraged DOE to
work with industry to develop a test procedure that would quantify the
lifetime of an LED lamp system. (Joint Comment, No. 18 at p. 1; NEMA,
No. 16 at p. 4; NEEA, No. 20 at pp. 2-3; CA IOUs, No. 19 at p. 5) NEMA,
Philips, and Radcliffe Advisors pointed out that there are several
industry groups working on this issue, such as the LED Systems
Reliability Consortium. (NEMA, No. 16 at p. 4; Philips, Public Meeting
Transcript, No. 7 at p. 64; Radcliffe Advisors, No. 13 at p. 1) Other
interested parties cited additional efforts; the CA IOUs commented that
DOE should coordinate efforts with ENERGY STAR while the Joint Comment
recommended that DOE coordinate test procedure development with work in
the European Union. (CA IOUs, No. 19 at p. 5; Joint Comment, No. 18 at
p. 5)
---------------------------------------------------------------------------
\32\ ``Measuring Lumen Maintenance of LED Light Sources.''
Approved by IES on September 22, 2008.
\33\ LM-84 ``IES Approved Method for Measuring Lumen and Color
Maintenance LED Lamps, Lighting engines, and Luminaires,'' will
provide the method for measurement of lumen and color maintenance of
LED lamps, light engines, and LED luminaires.
\34\ TM-26 ``Projecting Long-Term Lumen Maintenance for LED
Lamps and Luminaires,'' will provide an LED lamp and luminaire level
counterpart to IES TM-21-2011 using the IES LM-80-2008 (revision)
and LM-84 testing data for projecting long-term lumen maintenance.
---------------------------------------------------------------------------
DOE recognizes that there are degradation mechanisms other than
lumen maintenance, such as color shift, that can affect the useful
lifetime of LED lamps. However, color shift is not very well-
understood, well-studied, or commonly used even for traditional
incandescent lamps and CFLs.\31\ After conducting thorough research of
existing test procedures for all lighting products and industry
literature regarding LED lamp lifetime, DOE has tentatively concluded
that there is no industry consensus for how to characterize lifetime of
LED lamps in terms of performance metrics other than lumen maintenance.
Therefore, DOE is not proposing to use metrics such as color shift to
determine the lifetime of LED lamps.
Although industry may be working to develop new and revised
standards to define lifetime and establish test procedures for
measuring this quantity, the timeframe for their development is
unknown. DOE reviewed the efforts of other working groups, as suggested
by interested parties, but was unable to find any U.S. or international
standard that provides a test procedure for measuring and/or projecting
LED lamp lifetime. The only publicly available approach for measuring
LED lamp lifetime is ENERGY STAR Program Requirements for Lamps (Light
Bulbs): Eligibility Criteria--Version 1.0,\10\ which uses a lumen
maintenance of 70 percent (i.e. 70 percent of initial lumen output, or
L70) as an estimate for lifetime. Therefore, in this SNOPR,
DOE proposes to continue to define lifetime as the time at which the
lumen output of the LED lamp falls below 70 percent of the initial
lumen output.
2. NOPR Proposals
As mentioned above, there are currently no industry standards that
address how to measure lifetime for LED lamps. Therefore, DOE reviewed
methods to measure lifetime that were contained in industry standards
for related components and also investigated recent efforts in DOE and
ENERGY STAR working groups. In the NOPR, DOE presented four potential
lifetime measurement approaches, all of which characterized the
lifetime of LED lamps as the time required to reach a lumen maintenance
of 70 percent. 77 FR at 21044-5. Three of these approaches tested an
LED lamp to determine the lifetime and the fourth approach tested the
LED source as a proxy for the lifetime of the lamp. Ultimately, DOE
determines in this SNOPR that the test procedure for lifetime must
directly measure the performance of an LED lamp and not the LED source,
and proposes the revised lifetime measurement detailed in section
III.D.3.
Approach 1, based largely on the procedures in IES LM-79-2008,
directed manufacturers to measure the lumen output of the LED lamp
until it reaches 70 percent of its initial lumen output. In the NOPR,
DOE stated that Approach 1 is advantageous because it does not project
the time at which the lamp reaches L70 and therefore
measures the actual performance of the lamp over its useful life.
However, DOE determined that Approach 1 was not practical because it
may require up to six years of testing, by which time the LED lamp may
be obsolete. Id.
Approach 2 called for measuring lumen output of the LED lamp for a
specified period of time, 6,000 hours, and then projecting the time at
which the lamp reached L70 based on the minimum lumen
maintenance at 6,000 hours. This method was largely based on the ENERGY
STAR Specification for Integral LED Lamps Version 1.4 (see supra note
28). In addition, DOE proposed in the NOPR that a rapid-cycle stress
test be performed to assess catastrophic lamp failure (e.g. when a lamp
immediately ceases to emit light, rather than gradually decreasing in
light output). Approach 2 also enabled lifetime claims to be based on
the performance of an LED lamp, but was less time consuming than
Approach 1 because it only required 6,000 hours of testing and then
projected the lifetime based on the lumen maintenance at 6,000 hours.
However, DOE noted in the NOPR that the method used to develop the
ENERGY STAR lifetime projection is unverified and purely theoretical.
Furthermore, Approach 2 did not account for catastrophic lamp failure
beyond the 6,000 hour testing time. Id.
Similar to Approach 2, Approach 3, based on IES LM-79-2008,
directed measuring the lumen output of the LED lamp for a minimum of
6,000 hours. In the NOPR, DOE stated that the collected lumen output
data would then be used to project the L70 lifetime of the
LED lamp using an alternative procedure that would be developed by DOE.
This method would project lifetime based on the performance of an LED
lamp, but would not necessarily be based on a standardized method for
projecting lifetime. 77 FR at 21045.
Finally, Approach 4 required measuring the lumen output of LED
sources (the component of the LED lamp that produces light) at regular
intervals for a minimum of 6,000 hours, based largely on the procedures
in IES LM-80-2008. DOE would then project the time at which the lumen
output of the source reached 70 percent of its initial lumen output
using the projection method in IES TM-21-2011. In the NOPR, DOE
indicated that, although the preferred methodology is to project the
lifetime of an LED lamp rather than an LED source, an industry
standardized method only exists for projecting the lifetime of an LED
source and not an LED lamp. For this reason, DOE tentatively concluded
in the NOPR that Approach 4 was the most appropriate and proposed that
this method be used for estimating the lifetime of an LED lamp. Id.
[[Page 32030]]
DOE received many comments regarding its proposal for measuring
lifetime. Both Kritzer and Samsung agreed with NOPR Approach 4, as
written, for measuring the lifetime of LED lamps. (Kritzer, No. 3 at p.
1, Samsung, No. 14 at p. 1) Kritzer commented that it would be expected
that the proposed method would reduce the amount of time needed for
testing LED lamps and hence also reduce costs. (Kritzer, No. 3 at p. 1)
However, NEMA, Radcliffe Advisors, and the Joint Comment disagreed with
all suggested approaches within the NOPR document, including Approaches
1, 2, and 3 which DOE did not adopt as its proposal. (NEMA, No. 16 at
p. 4; Radcliffe Advisors, No. 13 at p. 1; Joint Comment, No. 18 at p.
1)
Despite their disagreement, NEMA did offer an interim solution to
use until new and revised industry standards are released. Their
proposal combined NOPR Approach 2 and 4. They indicated that NOPR
Approach 2 could be used by those manufacturers who do not have IES LM-
80-2008 data for the LED source within the lamp and that NOPR Approach
4 could be used for those products for which IES LM-80-2008 data does
exist. (NEMA, No. 16 at p. 4, 8) In addition, they suggested that DOE
not include the rapid cycle stress testing suggested in Approach 2.
They indicated that rapid cycle stress testing is practiced for some
lighting technologies; however, this technique is not widely practiced
by the LED industry and has not been verified as relevant to LED
lifetime and performance. (NEMA, No. 16 at p. 9)
DOE appreciates NEMA's interim proposal, but notes that combining
Approaches 2 and 4 would result in some manufacturers reporting
lifetime based on testing of an LED lamp and others reporting lifetime
based on testing of an LED source. The differences between Approaches 2
and 4 would lead to different results for lifetime. DOE cannot adopt
alternative test methods that yield different results as there would be
no basis for establishing any future energy conservation standards.
Furthermore, this combined approach still contains many of the
drawbacks related to the individual approaches.
Regarding Approach 4, DOE received several comments that outlined
the disadvantages of the NOPR proposal for determining the lifetime of
LED lamps. NEMA, Philips, OSI, TUD, the Joint Comment, the CA IOUs,
NEEA, Radcliffe Advisors, the Appliance Standards Awareness Project
(hereafter referred to as ASAP), and Litecontrol advocated basing the
lifetime on measurements of the whole LED lamp and not the LED source
component. They commented that it is undesirable for the lifetime of
LED lamps to be approximated by the lumen maintenance of the LED source
and stated that other components may cause lamp failure before the LED
source falls below 70 percent of its initial light output. (NEMA,
Public Meeting Transcript, No. 7 at p. 83, 84-85, 85; NEMA, No. 16 at
p. 2, 4, 5, 8, 9; Philips, Public Meeting Transcript, No. 7 at pp. 63-
64, 83; OSI, Public Meeting Transcript, No. 7 at p. 69, 100-101; TUD,
No. 15 at p. 1; Joint Comment, No. 18 at p. 1, 2, 4; CA IOUs, No. 19 at
p. 4; NEEA, No. 20 at p. 2, 3; Radcliffe Advisors, No. 13 at p. 1;
ASAP, Public Meeting Transcript, No. 7 at pp. 83-84; Litecontrol, No.
11 at p. 1)
Some interested parties suggested additional considerations for a
procedure that measured the performance of an LED lamp rather than an
LED source. The Joint Comment stated that the test procedure for LED
lamp lifetime include measurements and projections of driver lifetime.
They explained that industry has developed reliability models to
predict theoretical failure rates of LED drivers, and DOE should
investigate these models to determine if using them would help better
capture system effects of an LED lamp. (Joint Comment, No. 18 at p. 1,
4-5) The CA IOUs also suggested that DOE use accelerated testing based
on elevated temperatures, such as the method being explored by the LRC.
(CA IOUs, No. 19 at p. 5)
DOE has considered all comments received about the four approaches
discussed in the NOPR and has decided to significantly change its
approach for determining the lifetime of LED lamps in this SNOPR. DOE
agrees that there are several potential issues with requiring lumen
maintenance testing of the LED source component, as proposed in
Approach 4. DOE has preliminarily concluded in this SNOPR that the test
procedure for lifetime must directly measure the performance of an LED
lamp. DOE acknowledges that LED driver degradation and interactions
between the LED sources and other components are known to affect the
lifetime of integrated LED lamps. Regarding the proposal by the Joint
Comment, DOE conducted research of existing driver reliability modeling
and test procedures, including those specified in the military handbook
MIL-HDBK-217F,\35\ to determine whether driver failure could be
included in the projection of LED lamp lifetime. However, DOE
determined that no test procedures are available that use the expected
failure of the LED driver to predict the failure of the complete LED
lamp system. The CA IOUs suggested that DOE consider accelerated
testing based on elevated temperatures for the lifetime test procedure.
However, DOE research of existing literature and industry test
procedures indicates that accelerated test methods for LED lamp
lifetime are not available, and therefore, are not ready for inclusion
in the SNOPR.
---------------------------------------------------------------------------
\35\ Society of Reliability Engineers, Reliability Prediction of
Electronic Equipment, December 1991. https://www.sre.org/pubs/Mil-Hdbk-217F.pdf.
---------------------------------------------------------------------------
As mentioned above, DOE has decided to measure directly the
performance of an LED lamp and does not propose requiring testing of
LED sources or any individual lamp component. The complete SNOPR method
is described in section III.D.3. Although DOE has decided to make this
change, DOE did receive comments on specific aspects of the NOPR
proposal. These comments are discussed in further detail below.
a. Industry Standards
In the NOPR, DOE proposed measuring the lumen output of LED sources
based on IES LM-80-2008 and then projecting the time at which the lumen
output of the source reached 70 percent of the initial lumen output
based on IES TM-21-2011. 77 FR at 21045 NEMA, Cree, Radcliffe Advisors,
the CA IOUs, and Philips commented that the NOPR proposal modifies and
misapplies industry standards, and argued that both IES LM-80-2008 and
IES TM-21-2011 provide procedures to measure lumen maintenance of the
LED source and should not be used to estimate the lifetime of LED
lamps. (NEMA, No. 16 at p. 2, 5, 7; Cree, Public Meeting Transcript,
No. 7 at pp. 95-96, 109; Radcliffe Advisors, No. 13 at p. 1; CA IOUs,
No. 19 at p. 5, 6; Philips, Public Meeting Transcript, No. 7 at p. 114)
NEMA specified that DOE only reference IES LM-79-2008 because this
standard applies to LED lamps, which are the subject of this
rulemaking. (NEMA, No. 16 at p. 6)
DOE understands that both IES LM-80-2008 and IES TM-21-2011 are
industry standards for measuring and predicting the lumen maintenance
of an LED source. In the NOPR, DOE proposed referencing these standards
to measure the lumen maintenance of an LED source because DOE believed
it would be an adequate approximation for determining the lifetime of
LED lamps. However, based on the comments received in response to the
NOPR, DOE has changed its proposed procedure to
[[Page 32031]]
measure the lifetime of LED lamps. In this SNOPR, DOE proposes
assessing the lumen maintenance of an LED lamp and does not require
testing of LED sources. DOE's lifetime proposal, described in section
III.D.3, uses the procedures of IES LM-79-2008 to measure the lumen
output of an LED lamp.
b. LED Source In-Situ Temperature
In the NOPR, DOE proposed performing an in-situ temperature
measurement test (ISTMT) to determine the case temperature at which the
lumen maintenance data shall be obtained to project the lifetime of the
LED source. 77 FR at 21047 DOE proposed that the test setup,
conditions, test equipment, instrumentation, and test box material and
construction for the ISTMT be as specified in UL 1993-2009.\36\ UL, GE,
Cree, NEMA, and Feit argued that the test setup specified in UL 1993-
2009 is designed to represent a worst-case installation scenario. (UL,
Public Meeting Transcript, No. 7 at p. 110; GE, Public Meeting
Transcript, No. 7 at p. 91; Cree, Public Meeting Transcript, No. 7 at
p. 93; NEMA, No. 16 at p. 5; Feit, Public Meeting Transcript, No. 7 at
p. 93) Specifically, NEMA expressed concern that the test setup
described in UL 1993-2009 would elevate the ambient air to a
temperature greater than 25 [deg]C, which conflicts with the
requirement to measure photometric characteristics at 25 [deg]C. This
increase in temperature could also lead to changes in the photometric
performance of the LED sources. Furthermore, NEMA commented that using
UL 1993-2009 would force LED lamp manufacturers to increase design
margins for lumens and other lamp characteristics to account for the
temperature increase of the UL test conditions. This would lead to the
over-design of LED lamps. (NEMA, No. 16 at p. 7) GE and NEMA concluded
that UL 1993-2009 should not be used as part of the instruction for the
ISTMT. (GE, Public Meeting Transcript, No. 7 at p. 91; NEMA, No. 16 at
p. 5, 7) The Joint Comment indicated that DOE should carefully consider
whether UL 1993-2009 represents an average installation or a worst-case
scenario. (Joint Comment, No. 18 at p. 3) However, Intertek argued that
UL 1993-2009 is designed to represent typical installation conditions.
(Intertek, Public Meeting Transcript, No. 7 at p. 92, 93).
---------------------------------------------------------------------------
\36\ ``Self-Ballasted Lamps and Lamp Adapters.'' Published by UL
on August 28, 2009.
---------------------------------------------------------------------------
The Joint Comment explained that temperature plays a critical role
in the failure of LED lamps. They commented that an appropriate
lifetime test method would take careful account of all the real-world
installation parameters that could impact the natural operating
temperature of the device. The Joint Comment indicated that this would
include orientation, natural air circulation around the device, and all
the effects from other physical connections/thermal pathways. In
contrast with the manufacturers' recommendation, the Joint Comment
supported a test procedure that approximates a worst-case installation
scenario if knowledge about field installations is missing or
insufficient. (Joint Comment, No. 18 at p. 2-3) The Joint Comment
recommended that DOE carefully consider whether UL 1993-2009 represents
an average U.S. installation or a worst-case scenario and provide
justification as to why its use is appropriate. (Joint Comment, No. 18
at p. 3)
In this SNOPR, DOE has proposed a new test procedure for measuring
the lifetime of LED lamps that does not require determining the in-situ
temperature of the LED source. The test conditions for the new proposal
are discussed in section III.D.3.b.
c. LED Source Lumen Maintenance
IES LM-80-2008 requires manufacturers to test LED sources at three
temperatures: 55 [deg]C, 85 [deg]C, and a third temperature suggested
by the source manufacturer. A lamp manufacturer can then interpolate
the performance of the source at any temperature bounded by those three
temperatures, avoiding the need to conduct additional LED source
testing for their specific LED lamp. However, IES LM-80-2008 does not
provide a method for extrapolating LED source performance at an in-situ
temperature that is not bounded by those three temperatures. In this
case (an uncommon situation), DOE proposed in the NOPR that LED lamp
manufacturers would need to test the LED sources at the in-situ
temperature of their lamp to obtain the lumen maintenance data to
project the lifetime. 77 FR at 21046 DOE's NOPR proposal did not modify
IES LM-80-2008, instead it provided additional test methods for
situations outside the applicability of IES LM-80-2008.
DOE received several comments requesting that DOE not modify IES
LM-80-2008 and stating that proposed testing of LED sources would be
costly. NEMA, the CA IOUs, and NEEA commented that DOE should not
modify the test procedures specified in IES LM-80-2008. (NEMA, No. 16
at p. 5; CA IOUs, No. 19 at pp. 5-6; NEEA, No. 20 at p. 2).
Furthermore, NEEA commented that aligning DOE's test procedure and IES
LM-80-2008 will reduce the testing burden on manufacturers. (NEEA, No.
20 at p. 2) The CA IOUs elaborated that LED source testing at the case
temperature identified during the ISTMT would be impractical and/or
costly for industry because LED sources are often brought to market
with their IES LM-80-2008 testing already complete. (CA IOUs, No. 19 at
pp. 5-6)
Two commenters requested further clarification of IES LM-80-2008.
Regarding the temperature requirements, South Korea commented that
international standards do not prescribe any specific temperatures at
which to measure the lumen maintenance of the LED source. If DOE
determines it is important to test the sources at 55 [deg]C and 85
[deg]C, DOE should seek scientific justification for these
requirements. (South Korea, No. 17 at p. 3) Samsung also requested that
DOE specify the location on the LED source where temperature is
measured. (Samsung, No. 14 at p. 1)
DOE also received several comments indicating that DOE's proposal
for procurement of LED source lumen maintenance data could require
disassembly of a lamp in some cases. GE, OSI, and NEMA commented that
manufacturers would need to extract the LED source from the finished
lamp product if IES LM-80-2008 data is unavailable. (GE, Public Meeting
Transcript, No. 7 at p. 94, 95, 100; OSI, Public Meeting Transcript,
No. 7 at pp. 100-101; NEMA, No. 16 at p. 6) To avoid extracting the LED
source, GE recommended that DOE consider multiple lifetime measurement
approaches depending on the availability of IES LM-80-2008 data. (GE,
Public Meeting Transcript, No. 7 at pp. 78-79)
In the NOPR, DOE also proposed using the relevant guidelines from
an ENERGY STAR specification document to measure the lumen maintenance
for LED sources.\37\ 77 FR at 21048 Cree commented that for lamps that
use both white and red LED sources there is uncertainty as to whether
the IES LM-80-2008 data from the individual sources can be added
together to accurately represent their combined performance. Cree also
noted ENERGY STAR is currently accepting this practice. (Cree, Public
Meeting
[[Page 32032]]
Transcript, No. 7 at p. 106) Both NEMA and Radcliffe Advisors stated
that this is not an issue because DOE's test procedure should not
require testing of any individual component of an LED lamp. All testing
procedures should measure performance of the complete lamp product.
(NEMA, No. 16 at p. 4-5; Radcliffe Advisors, No. 13 at p. 1)
---------------------------------------------------------------------------
\37\ ENERGY STAR Program Guidance Regarding LED Package, LED
Array and LED Module Lumen Maintenance Performance Data Supporting
Qualification of Lighting Products, September 9, 2011.
www.energystar.gov/ia/partners/prod_development/new_specs/downloads/luminaires/ENERGY_STAR_Final_Lumen_Maintenance_Guidance.pdf.
---------------------------------------------------------------------------
DOE agrees there are drawbacks (including disassembly of the lamp
to extract an LED source) to testing the LED source component as a
proxy for estimating the lifetime of an LED lamp as outlined in IES LM-
80-2008. Therefore, DOE has developed a new proposal that only requires
testing of an LED lamp and is no longer using the test procedures in
IES LM-80-2008 or IES TM-21-2011. The new test procedure for LED lamps
indicates that after the test duration, lumen output must be measured
as specified in IES LM-79-2008. The lifetime of the LED lamp can then
be projected using an equation. The proposed method for lifetime
testing is discussed in more detail in section III.D.3.
d. Test Conditions
In the NOPR, DOE proposed that the temperature of the surrounding
air during testing be maintained between the case temperature and 5
[deg]C below the case temperature as specified in section 4.4.2 of IES
LM-80-2008. DOE also proposed that airflow around the LED sources be as
specified in section 4.4.3 of IES LM-80-2008, which states that the
airflow shall be maintained to minimize air drafts but allow some
movement of the air to avoid thermal stratification. 77 FR at 21046
NEMA and Cree commented that the upcoming IES LM-80-2008 revisions will
include recommendations on best practices for measuring and monitoring
air flow through the test system. (NEMA, Public Meeting Transcript, No.
7 at p. 97; Cree, Public Meeting Transcript, No. 7 at p. 97) However,
NEMA indicated that current test methods have led industry to believe
that the surrounding air temperature and airflow do not have noticeable
impact on long-term LED lumen degradation. They suggested that current
IES LM-79-2008 air movement requirements are more than adequate to
ensure the accuracy of test data. (NEMA, No. 16 at p. 5) TUD disagreed
with the specified test conditions, indicating that they cannot
sufficiently simulate all real world conditions. (TUD, No. 15 at p. 1)
As previously mentioned, for this SNOPR, DOE has developed a test
procedure that only requires testing of an LED lamp. Therefore, DOE no
longer references IES LM-80-2008, which applies to LED sources. The
SNOPR has proposed less stringent ambient temperature and airflow
conditions for periods when a lamp is operating but measurements are
not being taken. These requirements are discussed in more detail in
section III.D.3.b.
e. LED Source Orientation
In the NOPR, DOE proposed that the LED sources be operated in
accordance with section 4.4.4 of IES LM-80-2008, which requires
operating LED sources in the orientation specified by the source
manufacturer. Id. DOE noted that it is not specifying the orientation
for testing LED sources and invited interested parties to comment on
whether the operating orientation of the LED sources during testing
affects the lumen depreciation over time. Cree, Samsung, and NEMA
commented that DOE should not require additional marking or testing
based on orientation. (Cree, Public Meeting Transcript, No. 7 at p. 98;
Samsung, No. 14 at p. 1; NEMA, No. 16 at p. 6) NEMA stated that the
orientation specified in IES LM-80-2008 is only provided to establish a
common testing protocol, not because there is any evidence that
orientation affects performance. In this SNOPR, DOE is not referencing
the test procedures provided in IES LM-80-2008, which apply to LED
sources. Instead, DOE is proposing a new test procedure for lifetime
which measures the performance of LED lamps. Because DOE believes that
orientation impacts the performance of LED lamps, DOE is proposing that
lamps be tested in both the base-up and base-down positions. The
orientation requirements for lifetime are discussed in section
III.C.3.b.
f. External Driver Requirements
As specified in IES LM-80-2008, in the NOPR, DOE proposed using an
external driver that is compliant with manufacturer's guidance to drive
the LED source. 77 FR at 21047 Both Cree and NEMA opposed using
external drivers to test LED sources, while Samsung thought the use of
an external driver was appropriate. (Cree, Public Meeting Transcript,
No. 7 at p. 99; NEMA, No. 16 at p. 6; Samsung, No. 14 at p. 1) NEMA
indicated that the FTC label only regulates medium screw-base products
(as defined in CFR 430.2). Therefore, if the lamp is to connect to the
power supply via an ANSI base, there must be an integrated driver
rather than an external driver. (NEMA, No. 16 at p. 6) In this SNOPR,
DOE is proposing a new test procedure that measures the performance of
an LED lamp and is no longer utilizing the test procedures provided in
IES LM-80-2008. The new proposal does not require the use of an
external driver because an internal driver is included in an integrated
LED lamp. The SNOPR proposal for determining the lifetime of LED lamps
is detailed in section III.D.3.
g. Lumen Maintenance Measuring Equipment
IES LM-80-2008 specifies using a spectroradiometer to measure the
lumen output of an LED source. In the NOPR, DOE proposed using a
sphere-spectroradiometer, sphere-photometer, or a goniophotometer to
measure the lumen output of the LED source. 77 FR at 21043 Cree agreed
that all three instruments are appropriate to measure the lumen output
of LED sources. Cree indicated that IES LM-80-2008 does not specify the
use of a goniophotometer because this equipment cannot be used to
measure many of the other photometric and electrical characteristics
that the standard requires. (Cree, Public Meeting Transcript, No. 7 at
p. 103) NEMA disagreed with DOE's proposal and recommended that DOE not
modify the IES LM-80-2008 procedures. (NEMA, Public Meeting Transcript,
No. 7 at p. 104; NEMA, No. 16 at p. 6) Samsung commented that requiring
only a sphere-spectroradiometer would be suitable. (Samsung, No. 14 at
p. 1)
For this SNOPR, DOE is no longer proposing to use the test
procedures provided in IES LM-80-2008. Because DOE proposes to measure
the lifetime of LED lamps rather than LED sources, the SNOPR proposes
the use of the lumen output measuring equipment described in IES LM-79-
2008. As discussed in section III.C.3.b, DOE proposes that the
instrumentation used for lumen output measurement of LED lamps be as
described in sections 9.1 and 9.2 of IES LM-79-2008 and that goniometer
systems not be used.
h. LED Source Seasoning
Regarding seasoning of the LED source for lifetime measurements,
the Joint Comment argued that if DOE proposes a lifetime test method
that involves projection of the LED source using the Arrhenius equation
as the functional form of lumen degradation, the proposal should
include seasoning. (Joint Comment, No. 18 at pp. 5-6) DOE's proposal in
the SNOPR (discussed in section III.D.3) involves measurements of the
LED lamp, not the LED source. Therefore, DOE is not proposing a
seasoning requirement for LED sources in the SNOPR.
i. Maximum Lifetime
In the NOPR, DOE proposed projecting the lifetime as specified in
[[Page 32033]]
section 5.0 of IES TM-21-2011. DOE also proposed that if the projected
rate lifetime is greater than 25,000 hours, the maximum lifetime is
25,000 hours. If the projected lifetime is less than 25,000 hours, the
lifetime is the projected value. 77 FR at 21048
Litecontrol, Radcliffe Advisors, South Korea, Kritzer, an Anonymous
commenter, the CA IOUs, NEMA, and Philips disagreed with the proposal
to cap lifetime at 25,000 hours, stating that applying an arbitrary cap
discourages manufacturer improvements to lifetime. (Litecontrol, No. 11
at p. 1; Radcliffe Advisors, No. 13 at p. 2; South Korea, No. 17 at p.
3; Kritzer, No. 8 at p. 1; Anonymous, No. 8 at p. 1; CA IOUs, No. 19 at
p. 4; NEMA, Public Meeting Transcript, No. 7 at p. 65, 72-74; NEMA, No.
16 at p. 5; Philips, Public Meeting Transcript, No. 7 at p. 111) NEMA
commented that applying a cap of 25,000 hours is contrary to FTC
instruction, contradicts the recent L-Prize winning lamp's lifetime
rating,\38\ and limits payback analysis for rebate programs. (NEMA, No.
16 at p. 5) The Joint Comment indicated that the lifetime cap leaves
little incentive for manufacturers to test for longer periods of time
with larger samples to reduce measurement uncertainty. (Joint Comment,
No. 18 at p. 5) Kritzer pointed out that LED lamps are rapidly
improving in performance and limiting these products to a lifetime of
25,000 hours would affect their ability to compete with fluorescent
technologies, which advertise lifetimes as long as 40,000 hours.
(Kritzer, No. 8 at p. 1)
---------------------------------------------------------------------------
\38\ The Philips L-Prize Winning LED Bulb is rated at 30,000
hours and has undergone over 7,000 hours of lumen maintenance
testing. www.lightingprize.org/60watttest.stm.
---------------------------------------------------------------------------
Some interested parties suggested alternate proposals for limiting
maximum lifetime claims. South Korea proposed that the lifetime cap be
raised to 36,000 hours to be consistent with IES TM-21-2011, which
specifies that if the LED sources are tested beyond 6,000 hours they
can report up to 36,000 hours. (South Korea, No. 17 at p. 3) NIST
commented that the lifetime cap should only be raised if manufacturers
can provide statistics to prove their reported values. (NIST, Public
Meeting Transcript, No. 7 at p. 78) Alternatively, NEMA suggested that
methods for projecting lifetime beyond 25,000 hours could be drawn from
the ENERGY STAR solid-state lighting (hereafter referred to as SSL)
program and other products such as electronic fluorescent ballasts.
(NEMA, No. 16 at p. 7) The ENERGY STAR test procedure for lifetime
includes a projection method based on lumen maintenance testing of an
integrated lamp and does not require testing of the embedded LED
source. In addition, their projection method specifies that an LED lamp
has the potential to be rated at a lifetime greater than 25,000 hours
if additional testing beyond the minimum required 6,000 hours of lumen
maintenance testing is conducted (see supra note 28). The Joint Comment
agreed with the need to limit unreasonable lifetime claims and asked
DOE to work with industry to investigate a set of confidence criteria
to define a lifetime metric. (Joint Comment, No. 18 at p. 5) The Joint
Comment argued that the goal of the FTC Lighting Facts label should be
to give customers the most accurate information possible regarding the
quality and lifetime of this product, and that establishing proper test
procedures will help ensure this happens. (Joint Comment, No. 18 at p.
5)
After considering the comments about the NOPR lifetime cap
proposal, DOE has removed the 25,000 hour lifetime cap and developed a
proposal where the maximum lifetime of LED lamps depends on the test
duration. To prevent unreasonable lifetime claims based on a limited
amount of test data, DOE proposes that lifetime claims be limited to no
more than four times the duration of the test period. This limit
reflects ENERGY STAR's requirements to support lifetime claims beyond
25,000 hours, which require a test duration that is 25 percent of the
maximum projection. For example, to report a projected L70
lifetime of 30,000 hours, at least 7,500 hours of testing (and a lumen
maintenance of at least 70 percent at that time) would be required.
Requiring four times the duration of the test period is more
conservative than industry standard IES TM-21-2011 for LED sources,
which limits the L70 projection to no more than 5.5 or 6
times the testing time (depending on sample size). A more conservative
approach is reasonable because this test procedure applies to
integrated LED lamps rather than LED sources. DOE invites comment on
the proposed requirement to limit lifetime claims to four times the
duration of the test period.
j. Market Introduction
TUD commented that requiring a minimum test duration of 6,000 hours
could delay the market introduction of LED lamp products. (TUD, No. 15
at p. 1) In this SNOPR, DOE is proposing a new test method which does
not require a minimum duration of testing. Rather, DOE allows the
manufacturer to determine the test duration and then limits lifetime
claims to four times the test duration.
3. SNOPR Proposed Lifetime Method
In this SNOPR, DOE proposes a new test procedure for lifetime that
addresses many of the stakeholder concerns regarding the NOPR proposal
for measuring the lifetime of LED lamps. This proposal is simple,
straightforward, and allows significant flexibility if lifetimes of LED
products change in the future. As stated in section III.D.1, DOE
defines the lifetime of an LED lamp as the time at which a lamp reaches
a lumen maintenance of 70 percent (i.e., 70 percent of initial lumen
output, or L70). In this SNOPR, DOE proposes to measure the
lumen output of an LED lamp rather than the LED source contained in the
lamp. Thus, the test procedure directly measures the performance of the
actual product rather than an internal component. This considerably
simplifies compliance testing and provides a consistent procedure to be
used for all products. The methodology proposed in the SNOPR consists
of four main steps: (1) measuring the initial lumen output; (2)
operating the lamp for a period of time (test duration); (3) measuring
the lumen output at the end of the test duration; and (4) projecting
L70 using an equation adapted from the underlying
exponential decay function in ENERGY STAR's most recent specification
for integrated LED lamps, Program Requirements for Lamps (Light Bulbs):
Eligibility Criteria--Version 1.0. (see supra note 10) The equation
projects lifetime using the test duration and the lumen maintenance at
the end of the test duration as inputs. The following sections discuss
the methodology in greater detail.
a. Initial Lumen Output
Initial lumen output is the measured amount of light that a lamp
provides at the beginning of its life, after it is initially energized
and stabilized using the stabilization procedures in section III.C.4.b.
An initial lumen output measurement is required to calculate lumen
maintenance, which is an input for the lifetime projection. The test
procedure for lumen output is described in section III.B. The
methodology, test conditions, and setup requirements are unchanged when
measuring initial lumen output for the lifetime test procedure.
b. Test Duration
The period of time starting immediately after the initial lumen
output measurement and ending when the final lumen output measurement
is
[[Page 32034]]
recorded, is referred to as the ``test duration'' or time ``t.'' The
test duration does not include any time when the lamp is not energized.
If lamps are turned off (possibly for transport to another testing area
or during a power outage), DOE proposes that the time spent in the off-
state not be included in the test duration. DOE does not specify a
minimum test duration or measurement interval, so manufacturers can
customize the test duration based on the expected lifetime of the LED
lamp. During this time, the LED lamps are turned on (energized) and
operated for a period of time determined by the manufacturer. To reduce
test burden, the operating conditions required during the test duration
while measurements are not being taken are less stringent than those
required when taking photometric measurements (e.g., ambient
temperature). The following sections discuss the required operating
conditions for lamp operation between lumen output measurements in more
detail.
Ambient Temperature and Air Flow
DOE recognizes that while operating an LED lamp, lumen output can
vary with changes in ambient temperature, air flow, vibration, and
shock. For this reason, DOE proposes specific requirements for
quantities such as ambient temperature and air flow for photometric
measurements in section III.C.2. However, because lamps may need to be
operated for an extended period of time for the purpose of lifetime
testing, DOE proposes less stringent requirements when measurements are
not being taken. DOE proposes that ambient temperature be maintained
between 15 [deg]C and 40 [deg]C. DOE also proposes minimizing air
movement surrounding the test racks, and that the LED lamps not be
subject to excessive vibration or shock. These test conditions will
enable reliable, repeatable, and consistent test results without
significant test burden and are discussed in further detail below:
To determine ambient temperature requirements, DOE reviewed
industry standard IES LM-65-10 ``Approved Method Life Testing of
Compact Fluorescent Lamps.'' \39\ Section 4.3 of IES LM-65-10 requires
that ambient temperature be controlled between 15 [deg]C and 40 [deg]C.
Although industry standard IES LM-65-10 is intended for compact
fluorescent lamps, DOE proposes that this ambient temperature range is
appropriate for the operation of LED lamps because NEMA commented that
current test methods have led industry to believe that the surrounding
air temperature and airflow does not have a noticeable impact on long-
term LED lumen degradation. (NEMA, Public Meeting Transcript, No. 7 at
pp. 2-3; NEMA, No. 16 at p. 2-3) DOE believes that an ambient
temperature range between 15 [deg]C and 40 [deg]C encompasses the
majority of possible room temperature conditions while limiting test
burden. Therefore, in this SNOPR, DOE proposes that ambient temperature
be controlled between 15 [deg]C and 40 [deg]C. DOE requests comments on
this proposal.
---------------------------------------------------------------------------
\39\ ``Approved Method Life Testing of Compact Fluorescent
Lamps.'' Approved by IES on December 13, 2010.
---------------------------------------------------------------------------
DOE proposes that LED lamp testing racks be open and designed with
adequate lamp spacing and minimal structural components to maintain
ambient temperature conditions. Furthermore, similar to the
requirements in section 4.2 of IES LM-65-10, DOE proposes minimizing
airflow surrounding the LED lamp testing racks and that the lamps not
be subjected to excessive vibration or shock. DOE believes that these
requirements would minimize the impact of airflow and the physical
environment while minimizing test burden. DOE invites comments on the
minimization of vibration, shock, and air movement, as well as the
requirement for adequate lamp spacing during lamp operation in order to
maintain ambient temperature conditions.
Power Supply
DOE proposes that section 3.1 of IES LM-79-2008 be incorporated by
reference to specify requirements for both AC and DC power supplies.
This section specifies that an AC power supply shall have a sinusoidal
voltage waveshape at the input frequency required by the LED lamp such
that the RMS summation of the harmonic components does not exceed three
percent of the fundamental frequency while operating the LED lamp.
Section 3.2 of IES LM-79-2008 also requires that the voltage of an AC
power supply (RMS voltage) or DC power supply (instantaneous voltage)
applied to the LED lamp shall be within 0.2 percent of the
specified lamp input voltage. However, DOE determined that the IES LM-
79-2008 voltage tolerances are too burdensome to maintain for the
extended time period for which a lamp may need to be operated to
determine lifetime. When not taking measurements, DOE proposes to adopt
provisions similar to section 5.3 of IES LM-65-10 which requires that
the input voltage be monitored and regulated to within 2.0
percent of the rated RMS voltage. DOE believes that this requirement is
achievable with minimal test burden and provides reasonable stringency
in terms of power quality based on its similarity to voltage tolerance
requirements for other lamp types. DOE invites comments on the proposal
to adopt section 3.1 of IES LM-79-2008 requirements for both AC and DC
power supplies. DOE also requests comment on the requirement that input
voltage be monitored and regulated to within 2.0 percent of
the rated RMS voltage as specified in section 5.3 of IES LM-65-2010.
Lamp Mounting and Orientation
DOE proposes that the LED lamps be tested in the base-up and base-
down orientations for lumen maintenance testing. Section III.C.3.b
notes that LED lamp test data provided by ENERGY STAR, as well as PG&E,
CLASP, and CLTC, has revealed that there was variation between the
base-up, base-down and horizontal orientations (see supra note 20). Of
the three orientations, analysis revealed that the base-up and base-
down orientations represent the best (highest lumen output) and worst
(lowest lumen output) case scenarios.
Electrical Settings
DOE proposes adopting the electrical settings in section 7.0 of IES
LM-79-2008. Section III.C.3.d details the required electrical settings
for input voltage and how to operate lamps with multiple modes of
operation, such as variable CCT and dimmable lamps.
Operating Cycle
Lifetime test procedures for other lamp types sometimes require
``cycling,'' which means turning the lamp on and off at specific
intervals over the test period. However, industry has stated that
unlike other lighting technologies, the lifetime of LED lamps is
minimally affected by power cycling.\40\ Therefore, in this SNOPR, DOE
proposes to operate the LED lamp continuously and requests feedback on
the appropriateness of not requiring cycling in the test procedure for
lifetime.
---------------------------------------------------------------------------
\40\ NEMA Comments on ENERGY STAR Program Requirements Product
Specification for Lamps (Light Bulbs) Version 1.0, Draft 2https://energystar.gov/products/specs/sites/products/files/NEMA.pdf.
---------------------------------------------------------------------------
c. Lumen Output at the End of the Test Duration
Any lumen output measurement after the measurement of initial lumen
output, including that at the end of the test duration, is measured
under the
[[Page 32035]]
conditions and setup described in section III.B. DOE proposes
stabilizing the LED lamp before measuring lumen output at the end of
the test duration. Section III.C.4.b details the LED lamp stabilization
procedure.
d. Lumen Maintenance Calculation and Lifetime Projection
As discussed in section III.D.1, DOE proposes to define LED lamp
lifetime as the time required to reach a lumen maintenance of 70
percent (L70). Lumen maintenance is the measure of lumen
output after an elapsed operating time, expressed as a percentage of
the initial lumen output (the definition of initial lumen output is
provided in section III.D.3.a). DOE proposes that the lumen maintenance
at the end of the test duration equal the lumen output at the end of
the test duration (see section III.D.3.c) divided by the initial lumen
output.
DOE developed an equation to project the time at which an LED lamp
reaches L70 based on the underlying exponential decay
function used in the ENERGY STAR Program Requirements for Lamps (Light
Bulbs): Eligibility Criteria--Version 1.0 (see supra note 10). ENERGY
STAR utilizes an exponential decay function to calculate maximum
L70 life claims between 15,000 and 50,000 hours at
increments of 5,000 hours. The ENERGY STAR procedure requires a 6,000
hour test duration and provides lumen maintenance thresholds for each
incremental L70 lifetime claim. Unlike ENERGY STAR, DOE does
not have minimum lifetime requirements for LED lamps. Therefore, to
enable reporting of lifetimes less than 15,000 hours and greater than
50,000 hours, DOE has reorganized the underlying ENERGY STAR equation
to calculate L70 given the initial lumen output ``x0'', the
test duration ``t'', and the final lumen output at the end of the test
duration ``xt'' as inputs. DOE's equation is detailed below.
[GRAPHIC] [TIFF OMITTED] TP03JN14.011
L70 = Time to Reach 70% Lumen Maintenance
t = Test Duration
x0 = Initial Lumen Output
xt = Final Lumen Output at time ``t''
DOE requests comment on the proposed equation for projecting the
L70 lifetime of LED lamps.
DOE proposes that lifetime claims be limited to no more than four
times the test duration ``t.'' For example, if an LED lamp is tested
for 6,000 hours and has a lumen maintenance value of 93.1 percent at
that time, the L70 projection equation indicates that the
L70 lifetime is about 30,000 hours. However, the maximum
that could be reported based on the DOE proposal is only 24,000 hours
(four times the testing time of 6,000 hours). For lumen maintenance
values less than 70 percent, including lamp failures that result in
complete loss of light output, the SNOPR proposes that lifetime must
not be projected; instead, the lumen maintenance is equal to the
previously recorded lumen output measurement at the test duration where
the lumen maintenance is greater than or equal to 70 percent. DOE also
recognizes that it is possible that the calculated lumen maintenance at
time ``t'' could be greater than or equal to 100 percent. When this
occurs, DOE proposes that lifetime claims be determined by the maximum
projection limit. Due to the similarity of the DOE and ENERGY STAR
lifetime test procedures, manufacturers may choose to utilize lumen
maintenance measurements collected for the ENERGY STAR specification.
However, measurements must adhere to DOE's electrical setting
requirements proposed in section III.C.3.d and manufacturers must
include all LED lamps within the 10 lamp sample in the reported results
including lamp failures. DOE requests comments on its proposal to limit
the maximum lifetime to four times the test duration with no minimum
test duration.
Finally, DOE also notes that a manufacturer can report the test
duration as measured without applying the projection equation. This
approach applies to two scenarios. In the first scenario, a
manufacturer can test the lamp until it reaches 70 percent lumen
maintenance and use that test duration as the lifetime of the lamp.
This is equivalent to using the projection equation, because the output
of the projection equation would be the same as the test duration when
lumen maintenance of 70 percent is reached. In the second scenario, a
manufacturer can use the test duration associated with a lumen
maintenance greater than 70 percent. This scenario is equivalent to a
manufacturer using the projection equation, but electing to report a
more conservative value for business reasons. Reporting of conservative
values is permitted and is also discussed in section III.F.3.
E. Proposed Approach for Standby Mode Power
EPCA section 325(gg)(2)(A) in part directs DOE to establish test
procedures to include standby mode, ``taking into consideration the
most current versions of Standards 62301 and 62087 of the International
Electrotechnical Commission . . .'' (42 U.S.C. 6295(gg)(2)(A)) IEC
Standard 62087 applies only to audio, video, and related equipment, but
not to lighting equipment. Thus, IEC Standard 62087 does not apply to
this rulemaking, so DOE developed this SNOPR consistent with procedures
outlined in IEC Standard 62301, which applies generally to household
electrical appliances. However, to (1) develop a test method that would
be familiar to LED lamp manufacturers and (2) maintain consistent
requirements to the active mode test procedure, DOE referenced language
and methodologies presented in IES LM-79-2008 for test conditions and
test setup requirements.
A standby mode power measurement is an input power measurement made
while the LED lamp is connected to the main power source, but not
generating light (active mode). All test condition and test setup
requirements used for active mode measurements (e.g., input power) (see
sections III.C.2 and III.C.3) also apply to standby mode power
measurements. Once the test conditions and setup have been implemented,
the LED lamp should be seasoned and stabilized in accordance with the
requirements in sections III.C.4.a and III.C.4.b of this SNOPR. After
the lamp has stabilized, the technician should send a signal to the LED
lamp instructing it to enter standby mode (which is defined as
providing zero light output). Standby power is then measured in
accordance with section 5 of IEC 62301.
F. Basic Model, Sampling Plan, and Reported Value
1. Basic Model
In this SNOPR, DOE proposes amendments to the term ``basic model''
to include LED lamps. ``Basic model'' is currently defined (with some
exceptions) to mean all units of a given type of covered product (or
class thereof) manufactured by one manufacturer, having the same
primary energy source, and which have essentially identical electrical,
physical, and functional (or hydraulic) characteristics that affect
energy consumption, energy efficiency, water consumption, or water
efficiency; and with respect to general service fluorescent lamps,
general service incandescent lamps, and reflector lamps: Lamps that
have essentially identical light output and electrical
characteristics--including lumens per
[[Page 32036]]
watt (lm/W) and color rendering index (CRI). 10 CFR 430.2
DOE proposes to add a specification for LED lamps in the definition
of basic model in order to provide further guidance on the electrical,
physical, and functional characteristics that constitute a basic model.
Specifically, DOE proposes that a basic model for an integrated LED
lamp should represent lamps that have essentially identical light
output and electrical characteristics including lumens per watt, CRI,
CCT, and lifetime. Because these are the general characteristics by
which manufacturers identify their lamps in catalogs and marketing
material, DOE believes these parameters should be used to group lamps
of the same type.
DOE proposes to qualify the term ``basic model'' in 10 CFR 430.2
for LED lamps as lamps that have essentially identical light output and
electrical characteristics--including lumens per watt (lm/W), color
rendering index (CRI), correlated color temperature (CCT), and
lifetime.
DOE requests comments on the revision to the definition of ``basic
model'' to address LED lamps.
2. Sampling Plan
In the NOPR, DOE proposed a sampling plan for LED lamps to
determine input power, lumen output, and CCT, and a separate sampling
plan for LED sources to determine lifetime. DOE proposed testing a
minimum of 21 LED lamps to determine the input power, lumen output, and
CCT. DOE proposed that manufacturers select a minimum of three lamps
per month for seven months of production out of a 12 month period. If
lamp production occurs in fewer than seven months of the year, three or
more lamps must be selected for each month that production occurs,
distributed as evenly as possible to meet the minimum 21 unit
requirement. The seven months need not be consecutive and could be a
combination of seven months out of the 12 months. Sample sizes greater
than 21 must be multiples of three so that an equal number of lamps
were tested in each orientation (based on the lamp orientation
requirements in the NOPR). 77 FR at 21049 (April 9, 2012)
To determine the lifetime of LED lamps, DOE proposed in the NOPR
that the sample size for testing LED sources be as specified in section
4.2 of IES TM-21-2011. The IES TM-21-2011 industry standard requires a
minimum of ten units to be tested, but recommends a sample set of 20
units for projecting the lifetime of the LED sources. The method of
projection specified in IES TM-21-2011 cannot be used for less than ten
units. 77 FR at 21049
Regarding the sampling plan proposal for lumen output, CCT, and
wattage testing, NEMA and P.R. China commented that the sampling plan
should be based on the ENERGY STAR specification for integral LED
lamps, which requires a sample size of 10: five base-up and five base-
down. (NEMA, Public Meeting Transcript, No. 7 at p. 49; NEMA, No. 16 at
p. 8; P.R. China, No. 12 at pp. 4-5) In addition, ENERGY STAR has no
requirements for how lamps are selected for testing. NEMA opposed
gathering product samples over the course of a year because the
associated time to gather and test samples is much greater than a year.
(NEMA, No. 16 at p. 8) NEMA recommended that DOE not copy the sampling
requirements from other lighting technology rules. (NEMA, No. 16 at p.
9) In addition, NEMA, Cree, OSI, and South Korea commented that solid-
state lighting is still an emerging technology and requiring large test
samples and long testing time will significantly delay market
introduction. (NEMA, Public Meeting Transcript, No. 7 at p. 51; Cree,
Public Meeting Transcript, No. 7 at p. 52; OSI, Public Meeting
Transcript, No. 7 at p. 53; South Korea, No. 17 at pp. 2-3) Philips
added that LED lamp designs are evolving rapidly and often product
models are produced for less than a year before they are replaced by
more efficient designs. (Philips, Public Meeting Transcript, No. 7 at
p. 53) Lutron and Cree also commented that it is very important that
the LED lamp test procedure comply with FTC labeling requirements,
which allow for provisional labeling prior to completing all testing.
(Lutron, Public Meeting Transcript, No. 7 at pp. 51-52; Cree, Public
Meeting Transcript, No. 7 at p. 52) Alternatively, GE suggested that
DOE could retain the 21 lamp sample size, remove the requirement to
collect products for testing over the course of a year, and only test
product samples from initial production. (GE, Public Meeting
Transcript, No. 7 at pp. 52-53) Radcliffe Advisors commented that a 21
lamp sample size is small and does not have a rational basis. They
recommended that DOE give consideration to the relationship between
accuracy and the choice of sample size. (Radcliffe Advisors, No. 13 at
p. 1)
In reference to the sampling plan for determining the lifetime of
LED lamps, NEMA agreed with DOE's summary of IES TM-21-2011 stating
that it recommends a minimum of 20 LED sources be used during IES LM-
80-2008 testing to allow for lifetime projections of up to 36,000
hours. IES TM-21-2011 allows fewer LED sources to be used, but reduces
the maximum projection value to 25,000 hours. (NEMA, Public Meeting
Transcript, No. 7 at pp. 113-114) An Anonymous commenter suggested
allowing manufacturers to exclude from the overall average one unit
that fails during lifetime testing. (Anonymous, No. 8 at p. 1)
In this SNOPR, DOE proposes a new test procedure for lifetime that
measures the performance of an LED lamp and not its subcomponents
(i.e., the LED source). Therefore, DOE determined it did not need
different sampling requirements for lifetime relative to the non-
lifetime metrics. These sampling requirements proposed in the SNOPR for
all metrics are described below.
In order to address concerns regarding the sample size requirements
in the NOPR proposal, DOE collected photometric test data from two
sources, the first data set was provided by ENERGY STAR, and the second
from a collaborative effort between PG&E, CLASP, and CLTC (see supra
note 20). These test data, combined, represent 10 samples of 47
different LED lamp products each. Statistical analysis of the LED lamp
test data indicates that a minimum sample size of 10 lamps is
appropriate to estimate the average input power, initial lumen output,
efficacy, CCT, and CRI given the variation present in the data set.
Standby mode power is assumed to vary to the same degree as input power
(active mode). In addition, 37 LED lamps from the data set were tested
for lumen output after 3,000 hours of operation. DOE used this data to
help determine the sample size required for estimating the lifetime of
the LED lamp. Analysis of the test data revealed that a minimum sample
size of 10 should also be sufficient to estimate lumen output for the
LED lamp after an elapsed operating time. In addition, requiring a
minimum sample size of 10 LED lamps aligns with ENERGY STAR's sampling
procedure. Therefore, the SNOPR proposes testing a minimum of 10 LED
lamps to determine the input power, lumen output, efficacy, CCT, CRI,
lifetime, and standby mode power. DOE also proposes that all LED lamps
within the sample, including those that fail prematurely, be included
in the reported results for input power, lumen output, efficacy, CCT,
CRI, lifetime, and standby mode power. DOE's view is that LED lamp
failure should not be exempt from reporting, because this would
potentially mislead consumers, particularly with respect to lamp
lifetime. Furthermore, DOE proposes
[[Page 32037]]
that no selection process be required for the LED lamp test procedure.
Lamps for testing can be selected at any time from production units.
DOE invites interested parties to comment on the appropriateness of
adopting a minimum sample size of 10 LED lamps for input power, lumen
output, efficacy, CCT, CRI, lifetime, and standby mode power.
3. Reported Value
As in the NOPR (77 FR at 21049), DOE proposes that the CCT of the
units be averaged and that average be rounded as specified in section
III.G. The average CCT is calculated using the following equation:
[GRAPHIC] [TIFF OMITTED] TP03JN14.012
and, x is the sample mean; n is the number of units; and xi
is the i\th\ unit.
The LED lamp test data provided by ENERGY STAR as well as PG&E,
CLASP, and CLTC (see supra note 20) indicates variability within a
sample for measured lumen output, both at the initial lumen output
reading and after an elapsed operating time. Therefore, DOE proposes
that the reported value of lumen output as well as the reported value
of lifetime be equal to the lower of the average lumen output of the
sample set and the lower 99 percent confidence limit (LCL) of the
sample mean divided by 0.97.\41\ Additionally, the LED lamp test data
indicates that variability in the CRI and efficacy should be expected
within a sample. Therefore, DOE proposes that the reported value of CRI
be equal to the lower of the average CRI of the sample set and the
lower 99 percent confidence limit of the sample mean divided by 0.99,
and that the reported value of efficacy be equal to the lower of the
average efficacy of the sample set and the lower 99 percent confidence
limit of the sample mean divided by 0.98.\42\ DOE proposes the
following equation to calculate LCL for lumen output, lifetime, CRI,
and efficacy:
---------------------------------------------------------------------------
\41\ Based on the collected LED lamp test data, provided by
ENERGY STAR as well as PG&E, CLASP, and CLTC, DOE expects that the
variability for measured lumen output is within a margin of 3
percent. Thus, DOE proposes to divide the LCL value by 0.97 to
adjust for this expected variation. For example, if the mean lumen
output of 10 LED lamp units is 100 lumens with a standard deviation
of three, the LCL value will be three percent lower than the mean,
and dividing by 0.97 would result in a value that is equal to the
lumen output mean of 100 lumens. In this case, the LCL divided by
0.97 is equal to the sample mean, and 100 lumens would be reported.
If the variation within a sample set exceeds DOE's expectation, the
sample set would have a smaller LCL, such that a value less than 100
lumens would be reported.
\42\ Based on the collected LED lamp test data, provided by
ENERGY STAR as well as PG&E, CLASP, and CLTC, DOE expects that
variability for CRI is within a margin of 1 percent and for efficacy
is within a margin of 2 percent. Thus, DOE proposes to divide the
LCL value for CRI by 0.99 and the LCL value for efficacy by 0.98 to
adjust for this expected variation.
[GRAPHIC] [TIFF OMITTED] TP03JN14.013
where, x is the sample mean; s is the sample standard deviation; n is
the number of samples; and t0.99 is the t statistic for a 99
percent one-tailed confidence interval with n - 1 degrees of freedom.
Similarly, the LED lamp test data provided by ENERGY STAR as well
as PG&E, CLASP, and CLTC (see supra note 20) indicates variability
within a sample for measured input power. Therefore, DOE proposes that
the reported value of input power and standby mode power be equal to
the greater of the average lumen output of the sample set and the upper
99 percent confidence limit (UCL) of the sample mean divided by
1.01.\43\ DOE proposes the following equation to calculate UCL:
---------------------------------------------------------------------------
\43\ Based on the collected LED lamp test data, provided by
ENERGY STAR as well as PG&E, CLASP, and CLTC, DOE expects that the
variability for measured input power is within a margin of 1
percent. Thus, DOE proposes to divide the UCL value by 1.01 to
adjust for this expected variation.
[GRAPHIC] [TIFF OMITTED] TP03JN14.014
where, x is the sample mean; s is the sample standard deviation; n is
the number of samples; and t0.99 is the t statistic for a 99
percent one-tailed confidence interval with n - 1 degrees of freedom.
The proposed reported value requirements for lumen output, input
power, CRI, lamp efficacy, lifetime, and standby mode power represent
the ``best'' value that manufacturers may report. For lumen output,
CRI, lamp efficacy, and lifetime, the reported value may be rounded to
a lower value. For input power and standby mode power, the reported
value may be rounded to higher values. CCT must be reported as
calculated, as the concept of a conservative value does not apply to
these metrics. If conservative rounding is used, manufacturers must
report the conservatively rounded value to DOE so that values reported
to DOE match those used in all representations.
DOE invites interested parties to comment on the proposed reported
value requirements.
G. Rounding Requirements
In the SNOPR, DOE proposes rounding requirements for determining
lumen output, input power, efficacy, CCT, CRI, estimated annual energy
cost, lifetime, and standby mode power. Each of these is discussed in
the following sections.
1. Lumen Output
In the NOPR, DOE proposed that the lumen output of all units be
averaged and the value be rounded to the nearest tens digit. 77 FR at
21044 NEMA, OSI, and Cooper Lighting indicated that tight tolerances on
rounding requirements are undesirable. (NEMA, No. 16 at p. 4; OSI,
Public Meeting Transcript, No. 7 at pp. 55-56; Cooper, Public Meeting
Transcript, No. 7 at p. 56) NEMA commented that this will only set up
unrealistic expectations of accuracy and repeatability. (NEMA, No. 16
at p. 4) In their written comment, NEMA suggested that for lumen output
DOE round values of 0-499 to the nearest five lumens, 500-999 to the
nearest ten lumens, and 1000-9999 lumens to three significant digits.
If the lumen output is greater than or equal to 10,000, NEMA
recommended that DOE round to two significant digits. (NEMA, No. 16 at
p. 4) ASAP offered another solution, suggesting that DOE determine
appropriate rounding requirements based on the resolution of the test
measurement. (ASAP, Public Meeting Transcript, No. 7 at p. 56)
DOE agrees that rounding requirements should reflect realistic
expectations of accuracy and repeatability. Based on a review of
commercially available LED lamp products as well as testing equipment
measurement capabilities, DOE determined that three significant figures
is an achievable level of accuracy for LED lamps. Therefore, for this
SNOPR, DOE proposes rounding of three significant figures \44\ so that
lumen outputs of all sizes are provided a similar level of specificity.
---------------------------------------------------------------------------
\44\ If the number 3,563 is rounded to three significant digits
it becomes 3,560--with the 3, 5, and 6 being the significant digits.
---------------------------------------------------------------------------
2. Input Power
In the NOPR, DOE proposed that the input power of all test units be
averaged and the average value be rounded to the nearest tenths digit.
77 FR at 21044 NEMA agreed that this is acceptable. (NEMA, No. 16 at p.
4) In the SNOPR, DOE maintains its proposal for the rounding
requirements for input power.
[[Page 32038]]
3. Lamp Efficacy
In the SNOPR, DOE proposes that the efficacy of LED lamps be
rounded to the nearest tenth as this is consistent with rounding for
other lighting technologies and is achievable with today's equipment.
4. Correlated Color Temperature
In the NOPR, DOE proposed that the CCT of all units be averaged and
the value be rounded to the tens digit. 77 FR at 21044 However, NEMA
argued that most consumers can only distinguish lamp color temperature
variations on the order of 100 K. Therefore, NEMA suggested that any
CCT rating be rounded to the nearest hundreds digit. They stated that
DOE's proposal of rounding CCT values to the nearest tens digit would
cause undue consumer confusion when comparing products. (NEMA, No. 16
at p. 4)
In rulemakings for other lamp types, DOE established CCT rounding
requirements to the nearest tens place based on the precision of the
test procedure. In a rulemaking for general service fluorescent lamps,
DOE consulted with NIST and concluded that, because all laboratories
are able to measure CCT to three significant figures (a typical value
is four digits), DOE should require manufacturers to round CCT to the
nearest ten kelvin. 74 FR 31829, 31835 (July 6, 2009). In this SNOPR,
DOE continues this requirement and proposes rounding to the nearest
tens digit for measurements of individual lamp units.
However, DOE also recognizes NEMA's comment that consumers may not
be able to distinguish changes in CCT as small as 10 K. By using CCT
values rounded to the nearest 10 K, consumers could be confused, since
products with different CCT values may not have a perceptible
difference in appearance. DOE does not have data or market studies
quantifying the smallest difference in CCT that can be perceived by
consumers, but welcomes comment on this topic. DOE has observed that
the vast majority of CCT values provided in LED product literature are
rounded to the nearest hundreds place. DOE proposes to round the
reported value (i.e., certified or rated value) of the entire sample
(all lamp units collectively) to the nearest hundreds place to avoid
consumer confusion around any representations of CCT. DOE seeks comment
on this proposal.
5. Color Rendering Index
In the SNOPR, DOE proposes that the CRI of LED lamps be rounded to
the nearest whole number as this is consistent with rounding for other
lighting technologies.
6. Annual Energy Cost
Consistent with FTC's final rule that established the Lighting
Facts label (75 FR 41702 (July 19, 2010)), in the NOPR DOE proposed
calculating the estimated annual energy cost for LED lamps, expressed
in dollars per year, as the product of the average input power, in
kilowatts, the electricity cost rate of 11 cents per kilowatt-hour, and
the estimated average annual use at three hours per day, which is 1,095
hours per year. 77 FR at 21044 DOE proposed that the estimated annual
energy cost be rounded to the nearest cent because the cost of
electricity is specified to the nearest cent.
Although NEMA pointed out that the usage patterns and associated
hours used in the NOPR do not agree with DOE's 2010 U.S. Lighting
Market Characterization,\45\ NEMA agreed with DOE's proposed formula to
calculate annual energy cost and the associated rounding to the nearest
cent. (NEMA, No. 16 at p. 4) For consistency with FTC's calculations
for other lamp types, DOE proposes to maintain the rounding
requirements for estimated annual energy cost.
---------------------------------------------------------------------------
\45\ Navigant Consulting, Inc., ``2010 U.S. Lighting Market
Characterization'' Prepared for the DOE Solid-State Lighting
Program, January, 2012. https://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf.
---------------------------------------------------------------------------
7. Lifetime
In the SNOPR, DOE proposes that lifetime be rounded to the nearest
whole hour. This is consistent with the unit of time used for lifetime
metrics for other lamp technologies and is a level of accuracy a
laboratory is capable of measuring with a standard time-keeping device.
8. Life
In the NOPR, DOE proposed that the life of LED lamps be calculated
in terms of years based on three hours per day of operation. 77 FR at
21048 This is consistent with the FTC Lighting Facts label requirements
for other lamp technologies. DOE also proposed that the resulting value
be rounded to the nearest tenth of a year. Cooper Lighting recommended
that DOE consider rounding to two significant digits rather than to
tenths of a year to better capture the range in product lifetimes
across the different lighting technologies. (Cooper, Public Meeting
Transcript, No. 7 at p. 109) NEMA stated that tight rounding tolerances
only set up unrealistic expectations for the performance of LED lamps
and indicated that rounding the lifetime to the nearest tenth of a year
can be confusing to customers if they do not realize that the lifetime
values are based on three hours of use per day. (NEMA, No. 16 at p. 4,
8) Furthermore, both NEMA and the CA IOUs argued that lifetime be
reported in hours, because year-ratings are confusing to consumers, who
might assume a calendar lifetime rather than a lifetime based on hourly
use. (NEMA, No. 16 at p. 8; CA IOUs, No. 19 at p. 4) DOE proposes to
retain the rounding requirements provided in the NOPR which states that
the life of LED lamps be calculated in terms of years based on three
hours per day of operation and that the resulting value be rounded to
the nearest tenth of a year. As stated previously, this is consistent
with the FTC Lighting Facts label requirements for other lamp
technologies. FTC determines how the prescribed metrics appear on its
Lighting Facts label, as well as the overall format of the label.
Interested parties may contact FTC for concerns regarding the Lighting
Facts label.
9. Standby Mode Power
In the SNOPR, DOE proposes rounding standby mode power to the
nearest tenths place, consistent with its proposal for rounding input
power for active mode in section III.G.2.
H. Acceptable Methods for Initial Certification or Labeling
Because testing for lifetime could require six months or more from
start to finish, DOE anticipates the potential need for initial
certification requirements (such as those currently provided in 10 CFR
429.12(e)(2)) or early or interim labeling requirements. Any initial
certification requirements, if adopted, would be established by the
ongoing general service lamp energy conservation standard rulemaking.
See 78 FR 73737 (Dec. 9, 2013) Early labeling requirements, if adopted,
would be established by FTC. However, to support these potential needs,
DOE considered acceptable methods for use with initial certification or
labeling.
Test methods with shorter overall start to finish time requirements
are not available for measuring or projecting lifetime. Therefore,
initial certification and labeling is best substantiated by comparisons
to similarly designed lamps produced by the same manufacturer. A future
rulemaking addressing standards for LED lamps could require
manufacturers to provide a description of why the comparison to another
lamp is valid, including a description of the expected impact of design
differences on lifetime (if any).
[[Page 32039]]
DOE requests comment on the notion of early certification and labeling,
and the acceptable methods for substantiating those claims.
I. Laboratory Accreditation
In the NOPR, DOE did not require testing LED lamps by an accredited
laboratory. DOE received several comments during the May 2012 public
meeting as well as written comment submissions inquiring whether DOE
plans to require using accredited laboratory facilities.
Cree commented that DOE should consider requiring certification of
laboratories that are performing these tests as this is a requirement
for the ENERGY STAR program. (Cree, Public Meeting Transcript, No. 7 at
p. 57) OSI clarified that DOE should consider laboratory accreditation,
and not a certification program. Accreditation is the process by which
an authoritative third party gives formal recognition that a body or
person is competent to carry out specific testing. Certification is a
procedure by which a third party gives written assurance (certificate
of conformity) that a product, process, or service conforms to
specified requirements. (OSI, Public Meeting Transcript, No. 7 at pp.
60-61) NIST commented that laboratories are accredited for industry
standards. If testing in accredited laboratories is required for the
DOE's LED test procedure, this could confuse clients expecting industry
standards to be followed without modification. (NIST, Public Meeting
Transcript, No. 7 at p. 104) South Korea requested that in the final
rule DOE detail its certification procedures, its requirements for
testing laboratories, its designation process for testing laboratories,
and future prospects concerning these matters. (South Korea, No. 17 at
p. 4) Finally, Samsung suggested that DOE accept testing by existing
laboratories that have received accreditation from the International
Laboratory Accreditation Cooperation (ILAC). They argued that the ILAC
promotes international acceptance of test results and inspection
reports. (Samsung, No. 14 at p. 2)
Regarding the National Voluntary Laboratory Accreditation Program
(NVLAP) accreditation, DOE proposes in the SNOPR to require lumen
output, input power, lamp efficacy, CCT, CRI, lifetime, and standby
mode power (if applicable) testing be conducted by test laboratories
accredited by NVLAP or an accrediting organization recognized by ILAC.
NVLAP is a member of the ILAC organization, so test data collected by
any laboratory accredited by an accrediting body recognized by ILAC
would be acceptable. DOE requests comment on its proposal to require
accreditation by NVLAP or an entity recognized by ILAC, and on the
costs and benefits associated with such a requirement.
The FTC has developed a Lighting Facts Label to help inform
consumers about the efficiency and performance attributes of general
service lamp products. The label became effective January 1, 2012, and
requires that a lamp's lumen output, energy cost, lifetime, CCT and
wattage appear on the product packaging. Concerns regarding the FTC
Lighting Facts Label requirements were raised at the May 2012 NOPR
public meeting and in several comment submissions. These comments
pertained to the physical appearance and content displayed on the FTC
Lighting Facts Label, the time it would take for FTC to certify LED
lamp testing results, and whether using lumen maintenance as a proxy
for lifetime could confuse or mislead consumers. The comments received
are highlighted below:
OSI commented that FTC needs to take into account that
product information on small packages is often printed too small,
making the information illegible and/or difficult to identify. (OSI,
Public Meeting Transcript, No. 7 at p. 81)
An Anonymous commenter asked for DOE to indicate how long
it would take FTC to certify the results and grant permission to
advertise the lifetime values required for the FTC Lighting Facts
label. (Anonymous, No. 8 at p. 1)
NEMA, Radcliffe Advisors, OSI, Cooper Lighting, NEEA, the
Joint Comment, and the CA IOUs commented that the proposed definition
of lifetime would not be directly comparable to other general service
lamp products, which could mislead or confuse consumers. (NEMA, Public
Meeting Transcript, No. 7 at pp. 76-77; NEMA, No. 16 at p. 2; Radcliffe
Advisors, No. 13 at p. 1; OSI, Public Meeting Transcript, No. 7 at pp.
74-75; Cooper Lighting, Public Meeting Transcript, No. 7 at p. 77;
NEEA, No. 20 at p. 2; Joint Comment, No. 18 at pp. 1-2; CA IOUs, No. 19
at p. 4) Cree, Radcliffe Advisors, and the CA IOUs recommend that for
LED lamps, FTC consider changing its label to ``lumen maintenance''
rather than ``lifetime,'' or not provide a lifetime value at all.
(Cree, Public Meeting Transcript, No. 7 at p. 66, 67; Radcliffe
Advisors, No. 13 at p. 1; CA IOUs, No. 19 at p. 4, 5) OSI pointed out
that the FTC Lighting Facts label provides the opportunity to educate
consumers on the meaning of lumen maintenance and how this differs from
metrics used to define lifetime for other lighting products. (OSI,
Public Meeting Transcript, No. 7 at pp. 74-75)
DOE recognizes these concerns about the FTC Lighting Facts label.
However, DOE does not have authority over how to display metrics on the
FTC Lighting Facts label or the format of the label. Interested parties
may contact FTC about these issues.
J. State Preemption for Efficiency Metrics
In the NOPR, DOE proposed test procedures for measuring lumen
output and input power, and also specified testing dimmable lamps at
full light output. 77 FR 21028 (April 9, 2012) Only those metrics
required for the FTC Lighting Facts label were included in the NOPR
test procedure. The FTC Lighting Facts label does not require reporting
of metrics such as power factor, total harmonic distortion (THD), and
dimming; therefore none were included in the NOPR test procedure for
LED lamps. However, commenters noted that these metrics may appear in
state mandates in the future, and therefore recommended they be
included in DOE's test procedure for LED lamps in order to avoid state
preemption.
The CA IOUs commented that DOE not preempt California from
developing test procedures for other performance metrics such as
efficacy, power factor, THD, and dimming. The CA IOUs commented that
including in DOE's proposal test methods for power factor, THD, and
dimming would likely require significant additional time and industry
coordination. They asked that DOE specifically identify these metrics
and procedures as exempt from preemption. (CA IOUs, No. 19 at p. 2, 3)
Representations about the energy consumption of an LED lamp must
fairly disclose the results of testing in accordance with the DOE test
procedure. See 42 U.S.C. 6293(c). The DOE test procedure for LED lamps
will preempt any state regulation regarding the testing of the energy
efficiency of LED lamps. See 42 U.S.C. 6297(a)(1). States that have
regulations mandating efficiency standards for LED lamps must therefore
use the DOE test procedure when providing for the disclosure of
information with respect to any measure of LED lamp energy consumption.
To support the general service lamp rulemaking, DOE proposes to define
a calculation for the efficacy of an LED lamp as measured initial lamp
lumen output in lumens divided by measured lamp input power in watts.
See section III.C.4.d for details regarding the calculation for
efficacy of an LED lamp.
[[Page 32040]]
K. Effective and Compliance Date
If adopted, the effective date for this test procedure would be 30
days after publication of the test procedure final rule in the Federal
Register. Pursuant to EPCA, manufacturers of covered products must use
the applicable test procedure as the basis for determining that their
products comply with the applicable energy conservation standards
adopted pursuant to EPCA and for making representations about the
efficiency of those products. (42 U.S.C. 6293(c); 42 U.S.C. 6295(s))
For those energy efficiency or consumption metrics covered by the DOE
test procedures, manufacturers must make representations in accordance
with the DOE test procedure methodology and sampling plan beginning 180
days after publication of the final rule in the Federal Register.
IV. Procedural Issues and Regulatory Review
A. Review Under Executive Order 12866
The Office of Management and Budget (OMB) has determined that test
procedure rulemakings do not constitute ``significant regulatory
actions'' under section 3(f) of Executive Order 12866, Regulatory
Planning and Review, 58 FR 51735 (Oct. 4, 1993). Accordingly, this
action was not subject to review under the Executive Order by the
Office of Information and Regulatory Affairs (OIRA) in the Office of
Management and Budget.
B. Review under the Regulatory Flexibility Act
The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires
preparation of an initial regulatory flexibility analysis (IRFA) for
any rule that by law must be proposed for public comment, unless the
agency certifies that the rule, if promulgated, will not have a
significant economic impact on a substantial number of small entities.
As required by Executive Order 13272, ``Proper Consideration of Small
Entities in Agency Rulemaking,'' 67 FR 53461 (August 16, 2002), DOE
published procedures and policies on February 19, 2003, to ensure that
the potential impacts of its rules on small entities are properly
considered during the DOE rulemaking process. 68 FR 7990. DOE has made
its procedures and policies available on the Office of the General
Counsel's Web site: https://energy.gov/gc/office-general-counsel.
DOE reviewed the test procedures considered in this SNOPR under the
provisions of the Regulatory Flexibility Act (RFA) and the policies and
procedures published on February 19, 2003. As discussed in more detail
below, DOE found that because the proposed test procedures have not
previously been required of manufacturers, all manufacturers, including
small manufacturers, may potentially experience a financial burden
associated with this new testing requirement. While examining this
issue, DOE determined that it could not certify that the proposed rule,
if promulgated, would not have a significant impact on a substantial
number of small entities. Therefore, DOE has prepared an IRFA for this
rulemaking. The IRFA describes the potential impacts on small
businesses associated with LED lamp testing and labeling requirements.
DOE has transmitted a copy of this IRFA to the Chief Counsel for
Advocacy of the Small Business Administration (SBA) for review.
1. Estimated Small Business Burden
SBA has set a size threshold for electric lamp manufacturers to
describe those entities that are classified as ``small businesses'' for
the purposes of the RFA. DOE used the SBA's small business size
standards to determine whether any small manufacturers of LED lamps
would be subject to the requirements of the rule. 65 FR 30836, 30849
(May 15, 2000), as amended at 65 FR 53533, 53545 (Sept. 5, 2000) and
codified at 13 CFR part 121. The size standards are listed by North
American Industry Classification System (NAICS) code and industry
description and are available at www.sba.gov/sites/default/files/Size_Standards_Table.pdf. LED lamp manufacturing is classified under NAICS
335110, ``Electric Lamp Bulb and Part Manufacturing.'' The SBA sets a
threshold of 1,000 employees or less for an entity to be considered as
a small business for this category.
In the NOPR, DOE identified 17 potential small businesses that
manufacture LED lamps. In total, DOE estimated that the use of the NOPR
test method for determining light output, input power, and CCT would
result in testing-related labor costs of $57,000 for each of the
identified small businesses. In addition, DOE estimated that the test
method described in the NOPR for determining lifetime would result in
related labor costs of $11,000 for each manufacturer. Finally, in the
NOPR, DOE estimated initial setup costs of $12,000. DOE also indicated
that the setup cost would be a one-time cost to manufacturers and that
the labor costs to perform testing would be smaller than $68,000 after
the first year of testing. 77 FR at 21050-1 (April 9, 2012)
OSI indicated that they believe the number of impacted small
businesses is greater than DOE's estimate of 17 and speculated that the
actual number could be between two and ten times greater. (OSI, Public
Meeting Transcript, No. 7 at pp. 117-118) NEMA suggested that DOE
contact Jim Brodrick, Program Manager of the U.S. DOE SSL program, to
help determine a better estimate for the total number of small
businesses that will likely be affected by implementing this test
procedure. (NEMA, Public Meeting Transcript, No. 7 at p. 119)
For this SNOPR, DOE reexamined the number of small businesses that
will potentially be affected by the LED lamps test procedure. This
reevaluation indicated that the test procedure requirements proposed in
this SNOPR will apply to about 41 small business manufacturers of LED
lamps. DOE compiled this revised list of manufacturers by reviewing the
DOE LED Lighting Facts label list of partner manufacturers,\46\ the SBA
database, ENERGY STAR's list of qualified products,\47\ and performing
a general search for LED manufacturers. DOE determined which companies
manufacture LED lamps by reviewing company Web sites, the SBA Web site
when applicable, calling companies directly, and/or reviewing the
Hoovers Inc. company profile database. Through this revised process,
DOE identified 41 small businesses that manufacture LED lamps. DOE was
also able to collect annual revenue estimates for several of the small
business LED lamp manufacturers using the Hoovers.com company profile
database. DOE determined that the median revenue of the identified
small business manufacturers is $890,000.\48\ DOE requests comment on
the estimated number of small businesses that would be impacted by the
proposed rulemaking.
---------------------------------------------------------------------------
\46\ DOE LED Lighting Facts Partner List, https://www.lightingfacts.com/Partners/Manufacturer.
\47\ ENERGY STAR Qualified Lamps Product List, https://downloads.energystar.gov/bi/qplist/Lamps_Qualified_Product_List.xls?dee3-e997.
\48\ According to Hoovers.com, there are some small business LED
lamp manufacturers with revenue as little as $120,000 per year.
---------------------------------------------------------------------------
DOE also received several comments about the estimate of testing
burden. GE, Feit, and OSI expressed concern that DOE was
underestimating the cost burden to small manufacturers because the
costs associated with NOPR Approach 4 for lifetime testing would be
significant if IES LM-80-2008 data were unavailable. (GE, Public
Meeting Transcript, No. 7 at p. 117; Feit, Public Meeting Transcript,
No. 7 at p. 120; OSI,
[[Page 32041]]
Public Meeting Transcript, No. 7 at p. 117) ICF International commented
that DOE's estimate for the cost of initial setup was low. ICF
International estimated that if a manufacturer were to purchase all
required testing equipment, train personnel to operate it, and then go
through the accreditation process, it could cost more than $100,000.
(ICF International, Public Meeting Transcript, No. 7 at p. 119, 120)
Cree and Intertek also commented that instrumentation costs could be
significant, pointing out that a Type C goniophotometer could cost as
much as $200,000 and that a two meter integrating sphere with
accessories could cost about $60,000. (Cree, Public Meeting Transcript,
No. 7 at p. 120; Intertek, Public Meeting Transcript, No. 7 at pp. 121-
122) In addition to instrumentation costs, an anonymous commenter also
indicated that the cost of storing inventory during lifetime testing
would be significant and should be included in the cost burden
estimate. (Anonymous, No. 8 at p. 1) When estimating the burden to
small manufacturers, NEMA suggested that DOE also include FICA taxes,
unemployment taxes, workman's compensation, health care insurance,
holiday and vacation time, and retirement benefits in addition to the
office, laboratory, equipment, and other overhead costs for the
engineers and their support staff. (NEMA, No. 16 at p. 8) Finally, GE
commented that it would be unlikely that small business manufacturers
would want to set up an accredited laboratory for testing. They
speculated that small manufacturers would likely send their LED lamps
out for third party testing. (GE, Public Meeting Transcript, No. 7 at
p. 115)
In the NOPR, DOE determined that the labor rate to create the
initial setup and conduct the testing for input power, lumen output,
CCT, and lifetime of LED lamps would be $39.79 per hour.\49\ 77 FR at
21050 However, in its analysis for the SNOPR, DOE determined that an
electrical engineer is likely over qualified, and would not be hired by
manufacturers to conduct these required tasks. DOE's view is that an
electrical engineering technician is a better representation of the
personnel likely to perform the initial setup and required tests for
LED lamps. DOE estimated that the wages for an electrical engineering
technician are $24.18 per hour.\49\ This cost is only representative of
the hourly billing rate for an electrical engineering technician and
does not include any other compensation costs. DOE estimated that
providing additional benefits \50\ would add 31 percent \51\ to the
overall cost to the manufacturer, increasing the cost of employing an
electrical engineering technician to $31.68 per hour. For the SNOPR,
DOE also applied this labor rate to measurement of standby mode power.
---------------------------------------------------------------------------
\49\ Obtained from the Bureau of Labor Statistics (National
Compensation Survey: Occupational Earnings in the United States
2008, U.S. Department of Labor (August 2009), Bulletin 2720, Table 3
(``Full-time civilian workers,'' mean and median hourly wages)
https://bls.gov/ncs/ocs/sp/nctb0717.pdf.
\50\ Additional benefits include; paid leave, supplemental pay,
insurance, retirement and savings, Social Security, Medicare,
unemployment insurance and workers compensation.
\51\ Obtained from the Bureau of Labor Statistics (News Release:
Employer Cost For Employee Compensation--December 2012, U.S.
Department of Labor (December 2012), www.bls.gov/news.release/ecec.nr0.htm.
---------------------------------------------------------------------------
DOE estimates that the labor costs associated with conducting the
input power, lumen output, CCT, CRI, and standby mode power testing
contribute to overall burden. However, DOE believes that calculating
the efficacy of an LED lamp does not result in any incremental testing
burden beyond the cost of carrying out lumen output and input power
testing. DOE estimates that testing for input power, lumen output, CCT,
CRI, and standby mode would require approximately four hours per lamp
by an electrical engineering technician. DOE expects standby mode power
testing to require a negligible incremental amount of time in addition
to the time required for the other metrics. Therefore, DOE maintained
its estimate of four hours per lamp used in the NOPR (77 FR at 21050)
for testing for input power, lumen output, CCT, and CRI. DOE estimates
about 41 small business manufacturers of LEDs would be impacted, each
offering about 23 different basic models. In total, using the DOE test
method to determine light output, input power, CCT, CRI, and standby
mode power would result in an estimated incremental labor burden of
$29,140 for each manufacturer. DOE expects that the majority of
manufacturers are already testing for lumen output, input power, CCT,
and CRI as these metrics are well established and required within the
industry standard IES LM-79-2008. However, DOE's sample size, input
power, and orientation settings may differ from those selected for a
manufacturer's existing data. Therefore, DOE included the cost of
carrying out these tests in its assessment of testing burden.
In addition, DOE estimates that lifetime testing would also
contribute to overall cost burden. The initial setup would require a
custom-built rack to mount up to 120 lamps for testing, which may
require up to 120 hours of labor to build. The cost for an electrical
engineering technician to build such a rack would be approximately
$3,800. Similar to the NOPR analysis, DOE estimated that the material
cost to build a custom-built rack holding 120 sockets would be $3,600,
and the power supply and regulator costs would be $4,000 and $1,500
respectively. Therefore, the revised SNOPR estimate for the total cost
to build one rack is approximately $12,900. DOE estimated that a total
of two racks would be needed to hold about 23 different LED lamp
models, each tested in sample sets of 10 lamps (a total of 230 LED
lamps). Therefore, DOE estimates the total cost to build two test racks
to be $25,800. However, DOE notes that LED lamp manufacturers may
already have sufficient testing racks for their own internal uses and
for FTC labeling requirement testing. DOE expects that manufacturers of
LED lamps would already have other instrumentation necessary for
testing because IES LM-79-2008 is the recommended standard for testing
LED lamps for the FTC Lighting Facts label. The labor cost for lifetime
testing also contributes to overall burden. DOE estimates that the
combination of monitoring the lamps during the test duration, measuring
lumen maintenance, and calculating lifetime at the end of the test
duration would require approximately four hours per lamp by an
electrical engineering technician. This estimate does not include the
initial lumen output measurement required for the lifetime test
procedure, because the testing burden for that measurement is already
included in the estimate for input power, lumen output, CCT, and CRI
testing. DOE estimates about 41 small business manufacturers of LEDs,
each offering about 23 different basic models, would be affected. In
total, DOE expects that using this test method to determine lifetime
would result in testing-related labor costs of $29,140 for each
manufacturer.
As discussed in section III.I, DOE is also proposing to require
test facilities conducting LED lamp light output, input power, CCT,
CRI, lifetime, and standby mode power (if applicable) testing to be
NVLAP-accredited or accredited by an organization recognized by NVLAP.
However, NVLAP imposes a variety of fees during the accreditation
process including fixed administrative fees, variable assessment fees,
and proficiency testing fees. If a laboratory already has NVLAP
accreditation for other industry standards, there would be no
[[Page 32042]]
incremental administrative fees associated with the SNOPR proposal.
However, if a laboratory does not already have NVLAP accreditation for
other industry standards, there would be an administrative fee of
$5,050 assessed annually. NVLAP also collects an assessment fee
corresponding to the amount of time the assessor requires to complete
evaluation of the laboratory. A laboratory seeking to expand its scope
of accreditation to include IES LM-79-2008 as well as DOE's lifetime
test procedure for LED lamps would most likely not experience an
increase in cost. However, a laboratory with no existing NVLAP
accreditations would likely require two full days of an assessor's time
at the cost of $7,470 per assessment. Assessments are required during
the initial accreditation, on the first anniversary (year 1), and then
every other year following the first anniversary (year 3, 5, 7, etc.).
Finally, every laboratory seeking accreditation to IES LM-79-2008 is
required to participate in SSL proficiency testing. A $2,800 fee is
involved with this proficiency testing.
For each manufacturer producing 23 basic models, assuming testing
instrumentation is already available, DOE's estimate of the first year
NVLAP accreditation cost would be $15,320, initial setup cost would be
$25,800, and the labor costs to carry out testing would be
approximately $58,280. Therefore, in the first year, for manufacturers
without testing racks or NVLAP accreditation who choose to test in-
house, DOE estimates a total cost burden of $99,400 or about $432 per
LED lamp tested. DOE expects the setup cost to be a onetime cost to
manufacturers. Further, DOE expects that the labor costs to perform
testing would be smaller than $58,280 after the first year because only
new products or redesigned products would need to be tested.
Alternatively, if a manufacturer opts to send lamps to a third-party
test facility, DOE estimates testing of lumen output, input power, CCT,
CRI, lifetime, and standby mode power to cost $500 per lamp. In total,
the LED lamp test procedure would result in expected third party
testing costs of $115,000 for each manufacturer of 23 basic models.
DOE was able to collect annual revenue estimates for several of the
small business LED lamp manufacturers using the Hoovers.com company
profile database. DOE determined that the median revenue of the
identified small business manufacturers is $890,000, therefore, initial
testing costs would represent about 11.2 percent of revenue when
completed in a manufacturer's own laboratory, and 12.9 percent when
completed through a third-party test facility. As mentioned earlier,
the setup cost would be a one-time cost to manufacturers, and the labor
costs to perform testing would be smaller after the first year of
testing. Furthermore, when amortized over subsequent years, testing
costs would be significantly less. DOE requests comments on its
analysis of initial setup and labor costs as well as the average annual
burden for conducting testing of LED lamps.
2. Duplication, Overlap, and Conflict With Other Rules and Regulations
DOE is not aware of any rules or regulations that duplicate,
overlap, or conflict with the proposed rule being considered today.
3. Significant Alternatives to the Proposed Rule
DOE tentatively determined that there are no alternatives to the
proposed test procedure, including test procedures that incorporate
industry test standards other than the proposed standards. IES LM-79-
2008, the test procedure referenced in this SNOPR, is the most commonly
used industry standard that provides instructions for the electrical
and photometric measurement of LED lamps. DOE also reviewed the efforts
of other working groups, as suggested by interested parties, but was
unable to find any U.S. or international standard that provides a test
procedure for measuring and/or projecting LED lamp lifetime. The only
publicly available approach for measuring LED lamp lifetime is the
ENERGY STAR Program Requirements for Lamps (Light Bulbs): Eligibility
Criteria--Version 1.0 (see supra note 10).
C. Review Under the Paperwork Reduction Act of 1995
DOE established regulations for the certification and recordkeeping
requirements for certain covered consumer products and commercial
equipment. 76 FR 12422 (March 7, 2011). The collection-of-information
requirement for the certification and recordkeeping was subject to
review and approval by OMB under the Paperwork Reduction Act (PRA).
This requirement was approved by OMB under OMB Control Number 1910-
1400. Public reporting burden for the certification was estimated to
average 20 hours per response, including the time for reviewing
instructions, searching existing data sources, gathering and
maintaining the data needed, and completing and reviewing the
collection of information.
There is currently no information collection requirement related to
certifying compliance for LED lamps. Notwithstanding any other
provision of the law, no person is required to respond to, nor must any
person be subject to a penalty for failure to comply with, a collection
of information subject to the requirements of the PRA, unless that
collection of information displays a currently valid OMB Control
Number.
D. Review Under the National Environmental Policy Act of 1969
In this proposed rule, DOE is proposing a test procedure for LED
lamps that will be used to support the upcoming general service lamps
energy conservation standard rulemaking as well as FTC's Lighting Facts
labeling program. DOE has determined that this rule falls into a class
of actions that are categorically excluded from review under the
National Environmental Policy Act of 1969 (42 U.S.C. 4321 et seq.) and
DOE's implementing regulations at 10 CFR part 1021. Specifically, this
proposed rule would adopt existing industry test procedures for LED
lamps, so it would not affect the amount, quality or distribution of
energy usage, and, therefore, would not result in any environmental
impacts. Thus, this rulemaking is covered by Categorical Exclusion A5
under 10 CFR part 1021, subpart D. Accordingly, neither an
environmental assessment nor an environmental impact statement is
required.
E. Review Under Executive Order 13132
Executive Order 13132, ``Federalism,'' 64 FR 43255 (August 4, 1999)
imposes certain requirements on agencies formulating and implementing
policies or regulations that preempt State law or that have Federalism
implications. The Executive Order requires agencies to examine the
constitutional and statutory authority supporting any action that would
limit the policymaking discretion of the States and to carefully assess
the necessity for such actions. The Executive Order also requires
agencies to have an accountable process to ensure meaningful and timely
input by State and local officials in the development of regulatory
policies that have Federalism implications. On March 14, 2000, DOE
published a statement of policy describing the intergovernmental
consultation process it will follow in the development of such
regulations. 65 FR 13735. DOE has examined this proposed rule and has
determined that it would not have a substantial direct effect on the
States, on the relationship between the national government and the
States, or on the distribution of power and responsibilities among the
various
[[Page 32043]]
levels of government. EPCA governs and prescribes Federal preemption of
State regulations as to energy conservation for the products that are
the subject of this proposed rule. States can petition DOE for
exemption from such preemption to the extent, and based on criteria,
set forth in EPCA. (42 U.S.C. 6297(d)) No further action is required by
Executive Order 13132.
F. Review Under Executive Order 12988
Regarding the review of existing regulations and the promulgation
of new regulations, section 3(a) of Executive Order 12988, ``Civil
Justice Reform,'' 61 FR 4729 (Feb. 7, 1996), imposes on Federal
agencies the general duty to adhere to the following requirements: (1)
eliminate drafting errors and ambiguity; (2) write regulations to
minimize litigation; (3) provide a clear legal standard for affected
conduct rather than a general standard; and (4) promote simplification
and burden reduction. Section 3(b) of Executive Order 12988
specifically requires that Executive agencies make every reasonable
effort to ensure that the regulation: (1) clearly specifies the
preemptive effect, if any; (2) clearly specifies any effect on existing
Federal law or regulation; (3) provides a clear legal standard for
affected conduct while promoting simplification and burden reduction;
(4) specifies the retroactive effect, if any; (5) adequately defines
key terms; and (6) addresses other important issues affecting clarity
and general draftsmanship under any guidelines issued by the Attorney
General. Section 3(c) of Executive Order 12988 requires Executive
agencies to review regulations in light of applicable standards in
sections 3(a) and 3(b) to determine whether they are met or it is
unreasonable to meet one or more of them. DOE has completed the
required review and determined that, to the extent permitted by law,
the proposed rule meets the relevant standards of Executive Order
12988.
G. Review Under the Unfunded Mandates Reform Act of 1995
Title II of the Unfunded Mandates Reform Act of 1995 (UMRA)
requires each Federal agency to assess the effects of Federal
regulatory actions on State, local, and Tribal governments and the
private sector. Public Law 104-4, sec. 201 (codified at 2 U.S.C. 1531).
For a proposed regulatory action likely to result in a rule that may
cause the expenditure by State, local, and Tribal governments, in the
aggregate, or by the private sector of $100 million or more in any one
year (adjusted annually for inflation), section 202 of UMRA requires a
Federal agency to publish a written statement that estimates the
resulting costs, benefits, and other effects on the national economy.
(2 U.S.C. 1532(a), (b)) The UMRA also requires a Federal agency to
develop an effective process to permit timely input by elected officers
of State, local, and Tribal governments on a proposed ``significant
intergovernmental mandate,'' and requires an agency plan for giving
notice and opportunity for timely input to potentially affected small
governments before establishing any requirements that might
significantly or uniquely affect small governments. On March 18, 1997,
DOE published a statement of policy on its process for
intergovernmental consultation under UMRA. 62 FR 12820; also available
at https://energy.gov/gc/office-general-counsel. DOE examined this
proposed rule according to UMRA and its statement of policy and
determined that the rule contains neither an intergovernmental mandate,
nor a mandate that may result in the expenditure of $100 million or
more in any year, so these requirements do not apply.
H. Review Under the Treasury and General Government Appropriations Act,
1999
Section 654 of the Treasury and General Government Appropriations
Act, 1999 (Pub. L. 105-277) requires Federal agencies to issue a Family
Policymaking Assessment for any rule that may affect family well-being.
This rule would not have any impact on the autonomy or integrity of the
family as an institution. Accordingly, DOE has concluded that it is not
necessary to prepare a Family Policymaking Assessment.
I. Review Under Executive Order 12630
DOE has determined, under Executive Order 12630, ``Governmental
Actions and Interference with Constitutionally Protected Property
Rights'' 53 FR 8859 (March 18, 1988), that this regulation would not
result in any takings that might require compensation under the Fifth
Amendment to the U.S. Constitution.
J. Review Under Treasury and General Government Appropriations Act,
2001
Section 515 of the Treasury and General Government Appropriations
Act, 2001 (44 U.S.C. 3516 note) provides for agencies to review most
disseminations of information to the public under guidelines
established by each agency pursuant to general guidelines issued by
OMB. OMB's guidelines were published at 67 FR 8452 (Feb. 22, 2002), and
DOE's guidelines were published at 67 FR 62446 (Oct. 7, 2002). DOE has
reviewed this proposed rule under the OMB and DOE guidelines and has
concluded that it is consistent with applicable policies in those
guidelines.
K. Review Under Executive Order 13211
Executive Order 13211, ``Actions Concerning Regulations That
Significantly Affect Energy Supply, Distribution, or Use,'' 66 FR 28355
(May 22, 2001), requires Federal agencies to prepare and submit to OMB,
a Statement of Energy Effects for any proposed significant energy
action. A ``significant energy action'' is defined as any action by an
agency that promulgated or is expected to lead to promulgation of a
final rule, and that: (1) is a significant regulatory action under
Executive Order 12866, or any successor order; and (2) is likely to
have a significant adverse effect on the supply, distribution, or use
of energy; or (3) is designated by the Administrator of OIRA as a
significant energy action. For any proposed significant energy action,
the agency must give a detailed statement of any adverse effects on
energy supply, distribution, or use should the proposal be implemented,
and of reasonable alternatives to the action and their expected
benefits on energy supply, distribution, and use.
This proposed regulatory action to establish a test procedure for
measuring the lumen output, input power, efficacy, CCT, CRI, lifetime,
and standby mode power of LED lamps is not a significant regulatory
action under Executive Order 12866. Moreover, it would not have a
significant adverse effect on the supply, distribution, or use of
energy, nor has it been designated as a significant energy action by
the Administrator of OIRA. Therefore, it is not a significant energy
action, and, accordingly, DOE has not prepared a Statement of Energy
Effects.
L. Review Under Section 32 of the Federal Energy Administration Act of
1974
Under section 301 of the Department of Energy Organization Act
(Pub. L. 95-91; 42 U.S.C. 7101), DOE must comply with section 32 of the
Federal Energy Administration Act of 1974, as amended by the Federal
Energy Administration Authorization Act of 1977. (15 U.S.C. 788; FEAA)
Section 32 essentially provides in relevant part that, where a proposed
rule authorizes or requires use of commercial standards, the notice of
proposed rulemaking must inform the public of the use and background of
such standards. In addition, section 32(c) requires DOE to consult with
the
[[Page 32044]]
Attorney General and the Chairman of the FTC concerning the impact of
the commercial or industry standards on competition.
The proposed rule incorporates test methods contained in the
following commercial standards: ANSI/IESNA RP-16-2010 ``Nomenclature
and Definitions for Illuminating Engineering'' and IES LM-79-2008
``Approved Method: Electrical and Photometric Measurements of Solid-
State Lighting Products.'' The Department has evaluated these standards
and is unable to conclude whether they fully comply with the
requirements of section 32(b) of the FEAA, (i.e., that they were
developed in a manner that fully provides for public participation,
comment, and review). DOE will consult with the Attorney General and
the Chairman of the FTC concerning the impact of these test procedures
on competition prior to prescribing a final rule.
V. Public Participation
A. Submission of Comments
DOE will accept comments, data, and information regarding this
proposed rule no later than the date provided in the DATES section at
the beginning of this proposed rule. Interested parties may submit
comments using any of the methods described in the ADDRESSES section at
the beginning of this notice.
Submitting comments via regulations.gov. The regulations.gov Web
page will require you to provide your name and contact information.
Your contact information will be viewable to DOE Building Technologies
staff only. Your contact information will not be publicly viewable
except for your first and last names, organization name (if any), and
submitter representative name (if any). If your comment is not
processed properly because of technical difficulties, DOE will use this
information to contact you. If DOE cannot read your comment due to
technical difficulties and cannot contact you for clarification, DOE
may not be able to consider your comment.
However, your contact information will be publicly viewable if you
include it in the comment or in any documents attached to your comment.
Any information that you do not want to be publicly viewable should not
be included in your comment, nor in any document attached to your
comment. Persons viewing comments will see only first and last names,
organization names, correspondence containing comments, and any
documents submitted with the comments.
Do not submit to regulations.gov information for which disclosure
is restricted by statute, such as trade secrets and commercial or
financial information (hereinafter referred to as Confidential Business
Information (CBI)). Comments submitted through regulations.gov cannot
be claimed as CBI. Comments received through the Web site will waive
any CBI claims for the information submitted. For information on
submitting CBI, see the Confidential Business Information section.
DOE processes submissions made through regulations.gov before
posting. Normally, comments will be posted within a few days of being
submitted. However, if large volumes of comments are being processed
simultaneously, your comment may not be viewable for up to several
weeks. Please keep the comment tracking number that regulations.gov
provides after you have successfully uploaded your comment.
Submitting comments via email, hand delivery, or mail. Comments and
documents submitted via email, hand delivery, or mail also will be
posted to regulations.gov. If you do not want your personal contact
information to be publicly viewable, do not include it in your comment
or any accompanying documents. Instead, provide your contact
information on a cover letter. Include your first and last names, email
address, telephone number, and optional mailing address. The cover
letter will not be publicly viewable as long as it does not include any
comments.
Include contact information each time you submit comments, data,
documents, and other information to DOE. If you submit via mail or hand
delivery, please provide all items on a CD, if feasible. It is not
necessary to submit printed copies. No facsimiles (faxes) will be
accepted.
Comments, data, and other information submitted to DOE
electronically should be provided in PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file format. Provide documents that
are written in English, free of any defects or viruses, and not
secured. Documents should not contain special characters or any form of
encryption and, if possible, they should carry the electronic signature
of the author.
Campaign form letters. Please submit campaign form letters by the
originating organization in batches of between 50 to 500 form letters
per PDF or as one form letter with a list of supporters' names compiled
into one or more PDFs. This reduces comment processing and posting
time.
Confidential Business Information. According to 10 CFR 1004.11, any
person submitting information that he or she believes to be
confidential and exempt by law from public disclosure should submit via
email, postal mail, or hand delivery two well-marked copies: one copy
of the document marked confidential including all the information
believed to be confidential, and one copy of the document marked non-
confidential with the information believed to be confidential deleted.
Submit these documents via email or on a CD, if feasible. DOE will make
its own determination about the confidential status of the information
and treat it according to its determination.
Factors of interest to DOE when evaluating requests to treat
submitted information as confidential include: (1) A description of the
items; (2) whether and why such items are customarily treated as
confidential within the industry; (3) whether the information is
generally known by or available from other sources; (4) whether the
information has previously been made available to others without
obligation concerning its confidentiality; (5) an explanation of the
competitive injury to the submitting person which would result from
public disclosure; (6) when such information might lose its
confidential character due to the passage of time; and (7) why
disclosure of the information would be contrary to the public interest.
It is DOE's policy that all comments may be included in the public
docket, without change and as received, including any personal
information provided in the comments (except information deemed to be
exempt from public disclosure).
B. Issues on Which DOE Seeks Comment
Although DOE welcomes comments on any aspect of this proposal, DOE
is particularly interested in receiving comments and views of
interested parties concerning the following issues:
1. DOE requests comment on its characterization of the modes of
operation (active, standby, and off modes) that apply to LED lamps.
2. DOE requests comment on the proposal for an equal number of
lamps to be operated in the base-up and base-down orientations during
lumen output, input power, CCT, CRI, lifetime, and standby mode
testing.
3. DOE invites interested parties to comment on the proposal to
require all photometric values, including lumen output, CCT, and CRI,
be measured by an integrating sphere (via photometer or
spectroradiometer) and that goniometer systems must not be used.
[[Page 32045]]
4. DOE invites interested parties to comment on the proposal to
remain consistent with section 4.0 of IES LM-79-2008, which indicates
no seasoning is required for LED lamps before beginning photometric
measurements.
5. DOE requests comments on the test conditions when lamps are
operating but no measurements are being taken. Specifically, DOE
requests comment on requiring ambient temperature to be controlled
between 15 [deg]C and 40 [deg]C; the minimization of vibration, shock,
and air movement, as well as the requirement for adequate lamp spacing;
the proposal to adopt the section 3.1 of IES LM-79-2008 requirements
for both AC and DC power supplies; and the requirement that input
voltage be monitored and regulated to within 2.0 percent of
the rated RMS voltage as specified in section 5.3 of IES LM-65-2010.
6. DOE requests comment on the proposed test method for CRI.
7. DOE requests comment on the proposed calculation for lamp
efficacy.
8. For lifetime testing, DOE proposes to continuously operate the
LED lamp and requests feedback on the appropriateness of not requiring
an operating cycle during lumen maintenance testing.
9. DOE requests comment on the proposed equation to project the
L70 lifetime of LED lamps.
10. DOE requests comment on the revision to the definition of
``basic model'' to address LED lamps.
11. DOE requests comment on the appropriateness of adopting a
minimum sample size of 10 LED lamps for input power, lumen output, CCT,
CRI, lifetime, and standby mode.
12. DOE requests comment on the proposal to allow measurements
collected for the ENERGY STAR Program Requirements for Lamps (Light
Bulbs): Eligibility Criteria--Version 1.0 to be used for calculating
reported values of lumen output, input power, lamp efficacy, CCT, CRI,
and lifetime.
13. DOE requests comment on the proposal to round CCT values for
individual units to the tens place; and the proposal to round the
certified CCT values for the sample to the hundreds place.
14. DOE requests comment on its proposal to require accreditation
by NVLAP or an entity recognized by ILAC, and on the costs and benefits
associated with laboratory accreditation.
15. DOE requests comment on the estimated number of entities that
would be affected by the proposed rulemaking and the number of these
companies that are ``small businesses.''
16. DOE requests comments on its analysis of initial setup and
labor costs as well as the average annual burden for conducting testing
of LED lamps.
VI. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of this proposed
rule.
List of Subjects
10 CFR Part 429
Confidential business information, Energy conservation, Household
appliances, Imports, Reporting and recordkeeping requirements.
10 CFR Part 430
Administrative practice and procedure, Confidential business
information, Energy conservation, Household appliances, Imports,
Incorporation by reference, Intergovernmental relations, Small
businesses.
Issued in Washington, DC, on May 16, 2014.
Kathleen B. Hogan,
Deputy Assistant Secretary for Energy Efficiency, Energy Efficiency and
Renewable Energy.
For the reasons stated in the preamble, DOE is proposing to amend
parts 429 and 430 of Chapter II of Title 10, Subchapter D of the Code
of Federal Regulations to read as set forth below:
PART 429--CERTIFICATION, COMPLIANCE, AND ENFORCEMENT FOR CONSUMER
PRODUCTS AND COMMERCIAL AND INDUSTRIAL EQUIPMENT
0
1. The authority citation for part 429 continues to read as follows:
Authority: 42 U.S.C. 6291-6317.
Sec. 429.12 [Amended]
0
2. Section 429.12(b)(13) is amended by removing ``429.54'' and adding
``429.69'' in its place.
0
3. Section 429.56 is added to read as follows:
Sec. 429.56 Integrated light-emitting diode lamps.
(a) Determination of Represented Value. (1) Manufacturers must
determine the represented value, which includes the certified rating,
for each basic model of integrated light-emitting diode lamps by
testing, in conjunction with the following sampling provisions:
(i) Units to be tested. (A) The general requirements of Sec.
429.11(a) are applicable except that the sample must be comprised of
production units; and
(B) For each basic model of integrated light-emitting diode lamp,
the minimum number of units tested shall be no less than 10 and the
same units must be used for testing all metrics. If more than 10 units
are tested as part of the sample, the total number of units must be a
multiple of two. For each basic model, a sample of sufficient size
shall be randomly selected and tested to ensure that:
(1) Represented values of initial lumen output, lifetime, lamp
efficacy, and color rendering index (CRI) of a basic model for which
consumers would favor higher values must be less than or equal to the
lower of:
(i) The mean of the sample, where:
[GRAPHIC] [TIFF OMITTED] TP03JN14.015
and, x is the sample mean; n is the number of units; and xi
is the i\th\ unit;
Or,
(ii) The lower 99 percent confidence limit (LCL) of the true mean
divided by 0.97 for initial lumen output, life, and lifetime; the lower
99 percent confidence limit (LCL) of the true mean divided by 0.98 for
lamp efficacy; and the lower 99 percent confidence limit (LCL) of the
true mean divided by 0.99 for CRI, where:
[GRAPHIC] [TIFF OMITTED] TP03JN14.016
and, x is the sample mean; s is the sample standard deviation; n is the
number of samples; and t0.99 is the t statistic for a 99
percent one-tailed confidence interval with n -1 degrees of freedom
(from Appendix A of this part).
(2) Represented values of input power and standby mode power of a
basic model for which consumers would favor lower values must be
greater than or equal to the higher of:
(i) The mean of the sample, where:
[GRAPHIC] [TIFF OMITTED] TP03JN14.017
and, x is the sample mean; n is the number of units; and xi
is the i\th\ unit;
Or,
(ii) The upper 99 percent confidence limit (UCL) of the true mean
divided by 1.01, where:
[GRAPHIC] [TIFF OMITTED] TP03JN14.018
and, x is the sample mean; s is the sample standard deviation; n is the
number of samples; and t0.99 is the t statistic for a 99
percent one-tailed confidence interval with n - 1 degrees
[[Page 32046]]
of freedom (from Appendix A of this part);
(3) Represented values of correlated color temperature (CCT) of a
basic model must be equal to the mean of the sample, where:
[GRAPHIC] [TIFF OMITTED] TP03JN14.019
and, x is the sample mean; n is the number of units; and xi
is the i\th\ unit.
(ii) [Reserved]
(2) [Reserved]
(b) [Reserved]
(c) Rounding requirements for representative values, including
certified and rated values, of lumen output, input power, efficacy,
CCT, CRI, lifetime, standby mode power, and estimated annual energy
cost. (1) The represented value of input power must be rounded to the
nearest tenth of a watt.
(2) The represented value of lumen output must be rounded to three
significant digits.
(3) The represented value of lamp efficacy must be rounded to the
nearest tenths place.
(4) The represented value of correlated color temperature must be
rounded to the nearest 100 Kelvin.
(5) The represented value of color rendering index must be rounded
to the nearest whole number.
(6) The represented value of lifetime must be rounded to the
nearest whole hour.
(7) The represented value of standby mode power must be rounded to
the nearest tenth of a watt.
PART 430--ENERGY CONSERVATION PROGRAM FOR CONSUMER PRODUCTS
0
4. The authority citation for part 430 continues to read as follows:
Authority: 42 U.S.C. 6291-6309; 28 U.S.C. 2461 note.
0
5. Section 430.2 is amended by revising the definition of ``Basic
model'' and adding in alphabetical order the definition of ``Integrated
light-emitting diode lamp'' to read as follows:
Sec. 430.2 Definitions.
* * * * *
Basic model means all units of a given type of covered product (or
class thereof) manufactured by one manufacturer, having the same
primary energy source, and which have essentially identical electrical,
physical, and functional (or hydraulic) characteristics that affect
energy consumption, energy efficiency, water consumption, or water
efficiency; and
(1) With respect to general service fluorescent lamps, general
service incandescent lamps, and incandescent reflector lamps: Lamps
that have essentially identical light output and electrical
characteristics--including lumens per watt (lm/W) and color rendering
index (CRI).
(2) With respect to integrated light-emitting diode lamps: Lamps
that have essentially identical light output and electrical
characteristics--including lumens per watt (lm/W), color rendering
index (CRI), correlated color temperature (CCT), and lifetime.
(3) With respect to faucets and showerheads: Have the identical
flow control mechanism attached to or installed within the fixture
fittings, or the identical water-passage design features that use the
same path of water in the highest flow mode.
(4) With respect to furnace fans: Are marketed and/or designed to
be installed in the same type of installation.
* * * * *
Integrated light-emitting diode lamp means an integrated LED lamp
as defined in ANSI/IESNA RP-16 (incorporated by reference; see Sec.
430.3).
* * * * *
0
6. Section 430.3 is amended by:
0
a. Adding paragraphs (n)(8) and (n)(9); and
0
b. Removing ``and X'' in paragraph (o)(4) and adding in its place, ``X
and BB'' .
The additions read as follows:
Sec. 430.3 Materials incorporated by reference.
* * * * *
(n) IESNA. * * *
(8) ANSI/IESNA RP-16-2010, Nomenclature and Definitions for
Illuminating Engineering, approved October 15, 2005; IBR approved for
Sec. 430.2.
(9) IES LM-79-2008 (``IES LM-79''), Approved Method: Electrical and
Photometric Measurements of Solid-State Lighting Products, approved
December 31, 2007; IBR approved for Appendix BB to subpart B of this
part.
* * * * *
0
7. Section 430.23 is amended by adding paragraph (dd) to read as
follows:
Sec. 430.23 Test procedures for the measurement of energy and water
consumption.
* * * * *
(dd) Integrated light-emitting diode lamp. (1) The input power of
an integrated light-emitting diode lamp must be measured in accordance
with section 3 of Appendix BB of this subpart. Individual unit input
power must be rounded to the nearest tenth of a watt.
(2) The lumen output of an integrated light-emitting diode lamp
must be measured in accordance with section 3 of Appendix BB of this
subpart. Individual unit lumen output must be rounded to three
significant digits.
(3) The lamp efficacy of an integrated light-emitting diode lamp
must be calculated in accordance with section 3 of Appendix BB of this
subpart. Individual unit lamp efficacy must be rounded to the nearest
tenths place.
(4) The correlated color temperature of an integrated light-
emitting diode lamp must be measured in accordance with section 3 of
Appendix BB of this subpart. Individual unit correlated color
temperature must be rounded to the nearest 10 Kelvin.
(5) The color rendering index of an integrated light-emitting diode
lamp must be measured in accordance with section 3 of Appendix BB of
this subpart. Individual unit color rendering index must be rounded to
the nearest whole number.
(6) The lifetime of an integrated light-emitting diode lamp must be
measured in accordance with section 5 of Appendix BB of this subpart.
Individual unit lifetime must be rounded to the nearest hour.
(7) The life of an integrated light-emitting diode lamp must be
calculated by dividing the represented rated lifetime (see 10 CFR
429.56) by the estimated annual operating hours as specified in 16 CFR
305.15(b)(3)(iii). The life must be rounded to the nearest tenth of a
year.
(8) The estimated annual energy cost for an integrated light-
emitting diode lamp, expressed in dollars per year, must be the product
of the average input power in kilowatts as determined in accordance
with Appendix BB to this subpart, an electricity cost rate as specified
in 16 CFR 305.15(b)(1)(ii), and an estimated average annual use as
specified in 16 CFR 305.15(b)(1)(ii). The resulting estimated annual
energy cost for an individual unit must be rounded to the nearest cent
per year.
(9) The standby mode power must be measured in accordance with
section 5 of Appendix BB of this subpart. Individual unit standby mode
power must be rounded to the nearest tenth of a watt.
0
8. Section 430.25 is revised to read as follows:
Sec. 430.25 Laboratory Accreditation Program.
(a) Testing for general service fluorescent lamps, general service
[[Page 32047]]
incandescent lamps, and incandescent reflector lamps must be performed
in accordance with Appendix R to this subpart. Testing for medium base
compact fluorescent lamps must be performed in accordance with Appendix
W to this subpart. Testing for fluorescent lamp ballasts must be
performed in accordance with Appendix Q1 to this subpart. This testing,
with the exception of lifetime testing of general service incandescent
lamps, must be conducted by test laboratories accredited by the
National Voluntary Laboratory Accreditation Program (NVLAP) or an
accrediting organization recognized by International Laboratory
Accreditation Cooperation (ILAC). NVLAP is a program of the National
Institute of Standards and Technology, U.S. Department of Commerce.
NVLAP standards for accreditation of laboratories that test are set
forth in 15 CFR part 285. The following metrics should be measured by
test laboratories accredited by NVLAP or an accrediting organization
recognized by International Laboratory Accreditation Cooperation
(ILAC):
(1) Fluorescent lamp ballasts: ballast luminous efficiency (BLE);
(2) General service fluorescent lamps: lamp efficacy, color
rendering index;
(3) General service incandescent reflector lamps: lamp efficacy;
(4) General service incandescent lamps: lamp efficacy; and
(5) Medium base compact fluorescent lamps: initial efficacy, lamp
life. Testing for BLE may also be conducted by laboratories accredited
by Underwriters Laboratories or Council of Canada. Testing for
fluorescent lamp ballasts performed in accordance with Appendix Q to
this subpart is not required to be conducted by test laboratories
accredited by NVLAP or an accrediting organization recognized by NVLAP.
(b) Testing of integrated light-emitting diode lamps must be
performed in accordance with Appendix BB of this subpart. Testing must
be conducted in test laboratories accredited by NVLAP or an accrediting
organization recognized by International Laboratory Accreditation
Cooperation (ILAC) for the following metrics: input power, lumen
output, lamp efficacy, correlated color temperature, color rendering
index, lifetime, and standby mode power. A manufacturer's own
laboratory, if accredited, may conduct the testing.
0
9. Appendix BB to subpart B of part 430 is added to read as follows:
Appendix BB to Subpart B of Part 430--Uniform Test Method for Measuring
the Input Power, Lumen Output, Lamp Efficacy, Correlated Color
Temperature (CCT), Color Rendering Index (CRI), Lifetime, and Standby
Mode Power of Integrated Light-Emitting Diode (LED) Lamps
Note: After [DATE 180 DAYS AFTER PUBLICATION OF FINAL RULE IN
THE Federal Register], any representations made with respect to the
energy use or efficiency of light-emitting diode lamps must be made
in accordance with the results of testing pursuant to this appendix.
Given that after [DATE 180 DAYS AFTER PUBLICATION OF FINAL RULE IN
THE Federal Register] representations with respect to the energy use
or efficiency of light-emitting diode lamps must be made in
accordance with tests conducted pursuant to this appendix,
manufacturers may wish to begin using this test procedure as soon as
possible.
1. Scope: This appendix specifies how to measure input power,
lumen output, lamp efficacy, CCT, CRI, lifetime, and standby mode
power for integrated LED lamps.
2. Definitions
2.1. The definitions specified in section 1.3 of IES LM-79
except section 1.3(f) (incorporated by reference; see Sec. 430.3)
apply.
2.2. Initial lumen output means the measured lumen output after
the lamp is initially energized and stabilized using the
stabilization procedures in section 3 of Appendix BB of this
subpart.
2.3. Rated input voltage means the voltage(s) marked on the lamp
as the intended operating voltage. If not marked on the lamp, assume
120 V.
2.4. Lamp efficacy means the ratio of measured initial lumen
output in lumens to the measured lamp input power in watts, in units
of lumens per watt.
2.5. CRI means color rendering index as defined in Sec. 430.2.
2.6. Test duration means the operating time of the LED lamp
after the initial lumen output measurement and before, during, and
including the final lumen output measurement.
2.7. Lifetime means the time at which the lumen output is equal
to 70 percent of the initial lumen output measured using section 4
of Appendix BB of this subpart.
3. Active Mode Test Method for Determining Lumen Output, Input
Power, CCT, CRI, and Lamp Efficacy
In cases where there is a conflict, the language of the test
procedure in this appendix takes precedence over IES LM-79
(incorporated by reference; see Sec. 430.3).
3.1. Test Conditions and Setup
3.1.1. The ambient conditions, power supply, electrical
settings, and instrumentation must be established in accordance with
the specifications in sections 2.0, 3.0, 7.0, and 8.0 of IES LM-79
(incorporated by reference; see Sec. 430.3), respectively.
3.1.2. An equal number of integrated LED lamps must be
positioned in the base up and base down orientations throughout
testing.
3.1.3. The integrated LED lamp must be operated at the rated
voltage throughout testing. For an integrated LED lamp with multiple
rated voltages including 120 volts, the integrated LED lamp must be
operated at 120 volts. If an integrated LED lamp with multiple rated
voltages is not rated for 120 volts, the integrated LED lamp must be
operated at the highest rated input voltage. Additional tests may be
conducted at other rated voltages.
3.1.4. The integrated LED lamp must be operated at maximum input
power. If multiple modes occur at the same maximum input power (such
as variable CCT or CRI), the manufacturer can select any of these
modes for testing; however, all measurements described in section 3
and section 4 must be taken at the same selected mode.
3.2. Test Method, Measurements, and Calculations
3.2.1. The integrated LED lamp must be stabilized prior to
measurement as specified in section 5.0 of IES LM-79 (incorporated
by reference; see Sec. 430.3). The stabilization variation is
calculated as [maximum-minimum)/minimum] of at least three readings
of the input power and lumen output over a period of 30 minutes,
taken 15 minutes apart.
3.2.2. The input power in watts must be measured as specified in
section 8.0 of IES LM-79 (incorporated by reference; see Sec.
430.3).
3.2.3. Lumen output must be measured as specified in section 9.1
and 9.2 of IES LM-79 (incorporated by reference; see Sec. 430.3).
Goniometers must not be used.
3.2.4. CCT must be determined according to the method specified
in section 12.0 of IES LM-79 (incorporated by reference; see Sec.
430.3) with the exclusion of section 12.2 of IES LM-79. Goniometers
must not be used.
3.2.5. CRI must be determined according to the method specified
in section 12.0 of IES LM-79 (incorporated by reference; see Sec.
430.3) with the exclusion of section 12.2 of IES LM-79. Goniometers
must not be used.
3.2.6. Lamp efficacy must be determined by dividing measured
initial lumen output by the measured input power.
4. Active Mode Test Method for Lifetime
In cases where there is a conflict, the language of the test
procedure in this appendix takes precedence over IES LM-79
(incorporated by reference; see Sec. 430.3).
4.1. Measure Initial Lumen Output. Measure the Initial Lumen Output
According to Section 3 of This Appendix
4.2. Test Duration. Operate the integrated LED lamp for a period
of time (the test duration) after the initial lumen output
measurement and before, during, and including the final lumen output
measurement.
4.2.1. There is no minimum test duration requirement for the
integrated LED lamp. The test duration is selected by the
manufacturer. See section 4.5.3 for instruction on the maximum
lifetime.
[[Page 32048]]
4.2.2. The test duration only includes time when the integrated
LED lamp is energized and operating.
4.2.3. Operating conditions and setup during the test duration
other than time during which lumen output measurements are being
conducted are specified in section 4.3 of this appendix.
4.3. Operating Conditions and Setup Between Lumen Output
Measurements
4.3.1. Ambient temperature must be controlled between 15 [deg]C
and 40 [deg]C.
4.3.2. The integrated LED lamps must be spaced to allow airflow
around each lamp.
4.3.3. The integrated LED lamps must not be subjected to
excessive vibration or shock during lamp operation.
4.3.4. Line voltage waveshape must be as described in section
3.1 of IES LM-79 (incorporated by reference; see Sec. 430.3).
4.3.5. Input voltage must be monitored and regulated to within
2 percent of the voltage required in section 3.1.3 for
the duration of the test.
4.3.6. Electrical settings must be as described in section 7.0
IES LM-79 (incorporated by reference; see Sec. 430.3).
4.3.7. An equal number of integrated LED lamps must be
positioned in the base up and base down orientations throughout
testing.
4.3.8. The integrated LED lamp must be operated at maximum input
power. If multiple modes occur at the same maximum input power (such
as variable CCT and CRI), the manufacturer can select any of these
modes for testing. Measurements of all quantities described in
sections 3 and 4 of this appendix must be taken at the same selected
mode.
4.4. Measure Final Lumen Output. Measure the lumen output at the
end of the test duration according to section 3.
4.5.Calculate Lumen Maintenance and Lifetime
4.5.1. Calculate the lumen maintenance of the lamp after the
test duration ``t'' by dividing the final lumen output
``xt'' by the initial lumen output ``x0''.
Initial and final lumen output must be measured in accordance with
sections 4.1 and 4.4 of this appendix, respectively.
4.5.2. For lumen maintenance values greater than 1, the lifetime
(in hours) is limited to a value less than or equal to four times
the test duration.
4.5.3. For lumen maintenance values less than 1 but greater than
or equal to 0.7, the lifetime (in hours) is calculated using the
following equation:
[GRAPHIC] [TIFF OMITTED] TP03JN14.020
Where: t is the test duration in hours; x0 is the initial
lumen output; xt is the final lumen output at time t, and
ln is the natural logarithm function.
The maximum lifetime is limited to four times the test duration
t.
4.5.4. For lumen maintenance values less than 0.7, including
lamp failures that result in complete loss of light output, lifetime
is equal to the previously recorded lumen output measurement at a
shorter test duration where the lumen maintenance is greater than or
equal to 70 percent, and lifetime shall not be calculated in
accordance with section 4.5.3 of this appendix.
5. Standby Mode Test Method for Determining Standby Mode Power
In cases where there is a conflict, the language of the test
procedure in this appendix takes precedence over IES LM-79
(incorporated by reference; see Sec. 430.3) and IEC 62301
(incorporated by reference; see Sec. 430.3).
5.1. Test Conditions and Setup
5.1.1. The ambient conditions, power supply, electrical
settings, and instrumentation must be established in accordance with
the specifications in sections 2.0, 3.0, 7.0, and 8.0 of IES LM-79
(incorporated by reference; see Sec. 430.3), respectively.
5.1.2. An equal number of integrated LED lamps must be
positioned in the base up and base down orientations throughout
testing.
5.1.3. The integrated LED lamp must be operated at the rated
voltage throughout testing. For an integrated LED lamp with multiple
rated voltages, the integrated LED lamp must be operated at 120
volts. If an integrated LED lamp with multiple rated voltages is not
rated for 120 volts, the integrated LED lamp must be operated at the
highest rated input voltage.
5.2. Test Method, Measurements, and Calculations
5.2.1. Standby mode power consumption must be measured for
integrated LED lamps if applicable.
5.2.2. The integrated LED lamp must be stabilized prior to
measurement as specified in section 5.0 of IES LM-79 (incorporated
by reference; see Sec. 430.3). The stabilization variation is
calculated as [maximum--minimum)/minimum] of at least three readings
of the input power and lumen output over a period of 30 minutes,
taken 15 minutes apart.
5.2.3. The integrated LED must be configured in standby mode by
sending a signal to the integrated LED lamp instructing it to have
zero light output.
5.2.4. The standby mode power in watts must be measured as
specified in section 5 of IEC 62301 (incorporated by reference; see
Sec. 430.3).
[FR Doc. 2014-12127 Filed 6-2-14; 8:45 am]
BILLING CODE 6450-01-P
