NEMA Supports DOE Revision of General Service Lamp Definition

The National Electrical Manufacturers Association (NEMA) has welcomed the U.S. Department of Energy (DOE) Final Rule defining the scope of general service lamps to be consistent with the intent of Congress when it enacted the Energy Independence and Security Act of 2007. The Final Rule acknowledges that a previous effort by DOE to define the scope of these lamps — to include in the definition light bulbs designed for special purposes that Congress unequivocally stated multiple times are not general service bulbs — misconstrued the statute and DOE could not legally justify that prior effort. The Final Rule will supersede the prior DOE rule. DOE further clarified in this Final Rule that States are preempted from regulating general service lamps meeting the statutory definition of general service lamp.

General service lamps share a number of common attributes: they emit between 310 and 2600 lumens of omnidirectional light; they have a medium screw base; they are generally household lamps and serve domestic residential voltages; and, while the bare spiral compact fluorescent lamp (CFL) is the exception, these lamps also possess a standard bulb shape, which consumers recognize as a pear shape bulb. In defining general service lamps, Congress specifically identified three types of light bulb technologies that share all these elements: general service incandescent, compact fluorescent, and LED lamps.

The general service LED bulb now accounts for approximately 70 percent of the shipments in the general service lamp category. Because of their longer life, it is estimated that by the end of 2019, 80-84 percent of the general service lamp sockets will be occupied by LED and CFL, while the halogen incandescent bulb is estimated to be in 16-20 percent of these sockets. This trend is not limited to general service lamps. The majority of reflector lamp shipments are now LED, and nearly half of decorative lamp shipments are LED. Data published by the U.S. Energy Information Administration documents that energy-saving lighting has contributed more to the reduction of electricity use in the U.S. over the last 18 years than any other product category. The DOE Final Rule will not impact the market’s continuing, rapid adoption of energy-saving lighting in the next few years.

NEMA also acknowledges the DOE preliminary determination that it cannot justify the further amendment of existing standards for general service incandescent lamps established by Congress in 2007. “Serious efforts by some lighting manufacturers to design and manufacture more efficient general service incandescent lamps in comparison to the halogen incandescent lamps that are in the market today, have failed,” according to Dr. David Woodward of Signify North America and current chair of the NEMA Light Source Section. The principal impediment to developing a 45 lumen-per-watt general service incandescent lamp was the inability to deliver anywhere near the minimum 1000-hour service life of that lamp that the consumer expects and demands for this type of bulb. Early lamp failure was a problem for some designs, other more efficient incandescent halogen lamp designs had high lamp cost, and potential energy savings did not translate into overall cost savings for the consumer making more efficient incandescent halogen products economically unjustified.

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