The Department of Energy this week sent notice of a proposed change to the definitions of “general service lamp” (GSL) and “general service incandescent lamp” (GSIL) included in a January 2017 ruling. The revision will withdraw definitions established in that ruling that recategorized some niche incandescent lamps as general service lamps, which would make them subject to the same energy conservation standards under the Energy Independence and Security Act of 2007 (EISA), which set efficiency standards for general service lighting (typically used in residential applications).
The National Electrical Manufacturers Association (NEMA) objected to the January 2017 definitions in a March 2017 filing seeking judicial review of the definitions. NEMA voiced support for the change this week, noting that “DOE stated that it misconstrued existing law and could not legally justify its January 2017 definitions of general service incandescent lamp and general service lamp and that the department was proposing to align DOE definitions with those established by Congress in 2007 because that reflected what Congress intended.”
Environmental groups focused on energy efficiency have objected to the change as a “rollback” of energy efficiency advances. A joint statement by executives for the American Council for an Energy-Efficient Economy (ACEEE) and the Appliance Standards Awareness Project (ASAP) said the plan would cost consumers billions of dollars and increase pollution that harms public health and the environment. The ACEEE/ASAP statement estimated that consumers would lose at least $12 billion each year in electricity bill savings by 2025, and that U.S. electricity use would increase by 80 billion kWh per year.
In a blog post NEMA General Counsel Clark Silcox said the environmental groups’ estimates were based on data that failed to capture the consumer-led replacement of incandescent with LED technologies for GSLs and the resulting energy savings already underway.
NEMA points out that general service lamps are characterized by a number of common attributes: they emit omnidirectional light; they emit light across a broad range of lumen outputs from 310 lumens to 2600 lumens; they have a medium screw base; they are household lamps and serve domestic residential voltages from 110-130 volts; and while the “bare” spiral CFL is the exception, these lamps also possess a common bulb shape of certain dimensions known as A-17 or A-19, which the consumer recognizes as a “pear” shape bulb. “In defining general service lamps, Congress specifically identified three types of light bulb technologies that share all of these elements: general service incandescent, compact fluorescent and LED lamps,” NEMA said in the release.
“In a Final Rule issued January 19, 2017, DOE concluded that the definitions should also include light bulbs that only provided very low light output up to 380 lumens, light bulbs that only provided directional lighting (reflector lamps), light bulbs with small candelabra bases and other decorative bulb shapes; and light bulbs in higher voltage ranges more commonly used in Europe, and included some brighter light bulbs above 2600 lumens that were rarely used in household applications. NEMA argued that the inclusion of these specialty light bulbs in the definition of general service lamp was inconsistent with the text of the law and they were not ‘general service’ light bulbs. Congress expressly stated these lamps were ‘not included’ in its definition of general service lamp,” said the NEMA release.
DOE will hold a GSL public meeting on Feb. 28 in Washington, DC.