Ceiling Fan Light Kit (CFLK) Energy Conservation Standard (ECS) Preliminary Analysis - April 11, 2022
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Ceiling Fan Light Kit (CFLK) Energy Conservation Standard (ECS) Preliminary Analysis April 11, 2022 ApplianceStandardsQuestions@ee.doe.gov 1 | Energy Efficiency and Renewable Energy eere.energy.gov
Welcome • Introductions • Role of the Facilitator • Ground Rules – Participants should “raise your hand” to be recognized to speak. – Say your name for the record – there will be a complete transcript of this meeting. – Be concise – share the ‘air-time’. • Housekeeping Items • Agenda Review • Opening Remarks 2
Issues for Discussion Issue Box: The U.S. Department of Energy (DOE) welcomes comments, data, and information concerning its proposal for CFLKs. Issues that correspond to those raised in DOE’s published material will be numbered in accordance with that material. Whether invited by an issue box or not, comments are welcome on any part of DOE’s analysis. Issue box numbering is in the order that issues on which DOE seeks comment are listed in the executive summary of the preliminary analysis technical support document (TSD), available at regulations.gov, under docket number EERE-2019-BT-STD-0040, at www.regulations.gov/document/EERE-2019-BT-STD-0040-0006. The deadline for submitting comments is May 6, 2022. 3
How to Submit Written Comments for CFLKs • In all correspondence, please refer to the rulemaking by: – Energy Conservation Standards for Ceiling Fan Light Kits; – Docket Number EERE-2019-BT-STD-0040; and – Regulatory Identification Number 1904-AE52. • Email: CFLK2019STD0040@ee.doe.gov • In light of the ongoing Covid-19 pandemic, DOE is currently suspending receipt of public comments via postal mail and hand delivery/courier. If a commenter finds that this change poses an undue hardship, please contact Appliance Standards Program staff at (202) 586-1445 to discuss the need for alternative arrangements. Once the Covid-19 pandemic health emergency is resolved, DOE anticipates resuming all of its regular options for public comment submission, including postal mail and hand delivery/courier. Comment Period closes: May 6, 2022 11:59 PM EDT 4
Opening Remarks Meeting participants are invited to provide opening remarks or statements at this time. 5
CFLK Preliminary Analysis Presentation Overview 1 Overview, Schedule, Scope of Coverage 2 Market & Technology; Screening 3 Engineering Analysis 4 Energy Use Analysis Life-Cycle Cost and Payback Period 5 Analysis 6 Shipments; National Impact Analysis 7 Preliminary MIA 8 NOPR Analyses 9 Closing Remarks 6
Overview: Regulatory History • The Energy Policy Act of 2005 amended the Energy Policy and Conservation Act of 1975 (EPCA) by adding CFLKs as covered products. (42 U.S.C. 6295(ff)) – EPCA established standards for CFLKs that were codified in two separate final rule technical amendments published October 18, 2005 and January 11, 2007. 70 FR 60407, 60413; 72 FR 1270. • On January 6, 2016, DOE published a final rule amending CFLK standards and establishing a minimum efficacy requirement for all CFLKs. 81 FR 580. • On May 16, 2018, DOE published a final rule, changing the compliance date from January 7, 2019 to January 21, 2020, to align with the changes to the compliance date in the Ceiling Fan Energy Conservation Harmonization Act. 83 FR 22587. • DOE must review CFLK standards at least once every six years and publish either a Notice of Proposed Rulemaking (NOPR) to propose new standards or a notice of determination that the existing standards do not need to be amended. • DOE initiated the review of CFLK standards on June 4, 2021, by publishing a Request for Information (RFI). 86 FR 29954. 7
CFLKs ECS Rulemaking Schedule 2021 2022 2023 Milestone Date CFLK ECS RFI Publication June 4, 2021 CFLK Preliminary Analysis March 7, 2022 8
Scope of Coverage • The scope of coverage includes all CFLKs that meet the definition of a CFLK. Ceiling Fan Light Kit means equipment designed to provide light from a ceiling fan that can be − Integral, such that the equipment is attached to the ceiling fan prior to the time of retail sale; or − Attachable, such that at the time of retail sale the equipment is not physically attached to the ceiling fan, but may be included inside the ceiling fan at the time of sale or sold separately for subsequent attachment to the fan. 10 CFR 430.2; 42 U.S.C. 6291(50) 9
Scope of Coverage • DOE energy conservation standards for CFLKs require a minimum efficacy for each basic model of lamp and basic model of integrated solid-state lighting (SSL) packaged with the basic model of CFLK. – CFLKs with medium screw base sockets packaged with compact fluorescent lamps must also comply with a minimum lumen maintenance, rapid cycle stress test, and lifetime requirement. 10 CFR 430.32 (s)(6)(i) – CFLKs with pin-based sockets for fluorescent lamps must use an electronic ballast. 10 CFR 430.32 (s)(6)(ii) • The minimum efficacy requirement is measured in initial lamp light output (lumens) divided by the power in watts (W). • As of January 21, 2020, all CFLKs less than 120 lumens must have a minimum efficacy of 50 lumens per watt (lm/W). All CFLKs equal to or greater than 120 lumens must meet the requirements based on the equation below: Efficacy = 74.0 - 29.42 × 0.9983 lumens 10
CFLK Preliminary Analysis Presentation Overview 1 Overview, Schedule, Scope of Coverage 2 Market & Technology; Screening 3 Engineering Analysis 4 Energy Use Analysis Life-Cycle Cost and Payback Period 5 Analysis 6 Shipments; National Impact Analysis 7 Preliminary MIA 8 NOPR Analyses 9 Closing Remarks 11
Purpose of MTA and Screening Analysis • Market and Technology Assessment (MTA) − Determine product classes − Identify technology options • Screening Analysis − Screen out technology options that DOE will not consider in the engineering analysis based on: • Technological feasibility; • Practicability to manufacture, install, and service; • Adverse impacts on product utility or product availability; • Adverse impacts on health or safety; and • Unique-pathway proprietary technologies. 12
Technology Options • DOE identified the following technology options that can improve the efficacy of CFLKs. CFL Technology Options SSL Technology Options • Higher Emissive Electrode Coatings • Efficient Down Converters • Higher Efficiency Lamp Fill Gas • Improved Package Architectures • Improved Emitter Materials Composition • Alternative Substrate Materials • Higher Efficiency Phosphors • Improved Thermal Interface Materials • Glass Coatings (TIMs) • Multi-Photon Phosphors • Improved LED Device Architectures • Cold Spot Optimization • Optimized Heat Sink Design • Improved Ballast Components • Active Thermal Management Systems • Improved Ballast Circuit Design • Improved Primary Optics • Change to SSL • Improved Secondary Optics • Improved Driver Design • AC LEDs • Reduced Current Density 13
Screening Analysis • DOE is considering screening out the following technology options based on the associated screening criteria. Technology Technology Option Screening Criteria CFL Multi-Photon Phosphors Technological feasibility Quantum Dot Phosphors Technological feasibility LED Improved Emitter Materials Technological feasibility Issue 5: DOE requests comment on the technology options considered in this preliminary analysis and on other technology options DOE should consider for this rulemaking. Issue 6: DOE requests comment on design options considered in this preliminary analysis. 14
Product Classes • DOE divides covered products into classes by the type of energy used; capacity of the product; or other performance-related features that justify different standard levels, such as features affecting consumer utility. • DOE analyzed several product class setting factors for CFLKs. DOE did not identify any factor that uses a different type of energy, offers a different capacity of the product, or provides unique performance-related features to consumers, and thereby warrants a separate product class. • DOE is considering maintaining the existing single product class for all CFLKs for this analysis. Issue 1: DOE requests comment on the product classes considered in this preliminary analysis. 15
CFLK Preliminary Analysis Presentation Overview 1 Overview, Schedule, Scope of Coverage 2 Market & Technology; Screening 3 Engineering Analysis 4 Energy Use Analysis Life-Cycle Cost and Payback Period 5 Analysis 6 Shipments; National Impact Analysis 7 Preliminary MIA 8 NOPR Analyses 9 Closing Remarks 16
Engineering Analysis Methodology Select Representative Select certain product classes to be analyzed as Product Classes representative in the engineering analysis.. Select baseline light sources in each representative Select Baseline product class to serve as reference points from which to Light Sources assess changes due to energy conservation standards. Identify More Identify more efficacious substitutes for each baseline Efficacious model based on design options. Substitutes Develop candidate standard levels (CSLs) that span the Determine CSLs range of efficacy from the baseline to the maximum technologically feasible level. Scale Results Scale results to product classes not analyzed. 17
Representative Product Classes Select Representative • DOE is considering maintaining the existing single product class Product Classes for CFLKs: All CFLKs. • DOE analyzed the All CFLKs product class as representative in Select Baseline this analysis. Light Sources Identify More Efficacious Substitutes Determine CSLs Scale Results 18
Baseline Light Source Select • The baseline light source typically represents the most Representative common, least efficacious light source in a CFLK that meets Product Classes existing energy conservation standards. • In this analysis, DOE reviewed manufacturer catalogs and Select Baseline retailer sites and tentatively determined that ANSI base lamps Light Sources are the most common light source used in CFLKs. • DOE selected a baseline lamp representative of the most Identify More common, least efficacious lamp packaged with CFLKs that Efficacious meets existing CFLK standards and has common attributes Substitutes such as lumen output range, wattage, shape, lifetime, CCT, and CRI. Determine CSLs Nominal Initial Rated Representative Lifetime Lamp Base Lamp CCT Wattage Lumens Efficacy CRI Product Class (hr) Shape Type Type (K) (W) (lm) (lm/W) All CFLKs 10,000 Spiral E26 CFL 13 900 69.2 2700 83 Scale Results 19
Baseline Light Source Select Issue 7: DOE requests comment on the selection of a lamp as the most Representative Product Classes common light source packaged with CFLKs. DOE requests comment on the baseline lamp selected in this preliminary analysis. Select Baseline Light Sources Identify More Efficacious Substitutes Determine CSLs Scale Results 20
More Efficacious Substitutes Select • DOE selected more-efficacious replacement lamps that Representative — both save energy and maintain light output within ten percent of the Product Classes baseline lamp lumens, when possible, and — have similar attributes as the baseline lamp when possible (e.g., base type, CCT, CRI, and lifetime). Select Baseline Product CSL Lifetime Lamp Base Lamp Nominal Wattage Initial Lumens Rated Efficacy A-Value CCT CRI Light Sources Class (hr) Shape Type Type (W) (lm) (lm/W) (K) Baseline 10,000 Spiral E26 CFL 13 900 69.2 -30.8 2700 83 15,000 A19 E26 LED 10 800 80.0 -18.5 2700 80 Identify More CSL 1 25,000 A19 E26 LED 10 800 80.0 -18.5 2700 80 Efficacious 15,000 A19 E26 LED 9 800 88.9 -9.6 2700 80 All Substitutes CFLKs CSL 2 25,000 A19 E26 LED 9 800 88.9 -9.6 2700 80 CSL3 15,000 A19 E26 LED 8 800 100.0 1.5 2700 80 CSL 4 15,000 A19 E26 LED 7 800 114.3 15.8 2700 80 Determine CSLs CSL 5 15,000 A19 E26 LED 6.5 810 124.6 25.9 2700 80 Issue 8: DOE requests comment on the more efficacious substitutes Scale Results analyzed for All CFLKs. 21
Candidate Standard Levels (CSLs) Select • DOE conducted regression analyses to identify the equation Representative form that best fit lamp data of commercially available lamps Product Classes commonly used in CFLKs. • Based on these analyses, DOE developed the following new Select Baseline equation to determine efficacy based on lumen output. Light Sources = + . + − . ( − ) Identify More Lumens: measured lumen output Efficacious Substitutes A: an adjustment variable (the “A-value”) Determine CSLs Issue 9: DOE requests comment on the new equation form. Scale Results 22
Candidate Standard Levels (CSLs) Select • Based on the more-efficacious lamps selected for analysis, DOE developed CSLs for the representative product class. Representative Product Classes — To prevent backsliding (decreasing the existing minimum required energy efficiency), the current standard equation is maintained for certain CSLs in certain lumen ranges. — These CSLs are based on ANSI base lamps (replaceable). DOE’s research indicates that CFLKs with non-consumer-replaceable light sources (i.e., Select Baseline integrated SSL circuitry, which are tested as luminaires)can also meet these Light Sources CSLs. Representative Level Efficacy Lumen Range Product Class 50 < 120 Identify More CSL 1 74 ─ 29.42×0.9983Lumens 120 ≤ Lumens < 388 Efficacious 123/(1.2+e (-0.005×(Lumens-200))) ─ 18.5 ≥ 388 Substitutes 50 < 120 CSL 2 74 ─ 29.42×0.9983Lumens 120 ≤ Lumens < 276 123/(1.2+e (-0.005×(Lumens-200))) ─ 9.6 ≥ 276 All CFLKs 50 < 120 Determine CSLs CSL 3 74 ─ 29.42×0.9983Lumens 120 ≤ Lumens < 153 123/(1.2+e (-0.005×(Lumens-200))) + 1.5 ≥ 153 50 < 26 CSL 4 123/(1.2+e (-0.005×(Lumens-200))) + 15.8 ≥26 CSL 5 123/(1.2+e (-0.005×(Lumens-200))) + 25.9 All Lumens Scale Results Issue 10: DOE requests comment on its assessment on the differences in efficacy between CFLKs with non-consumer-replaceable light sources 23 and CFLKs with replaceable light sources.
Scaling Select • In general, DOE scales CSLs to product classes not directly Representative analyzed. Product Classes • Because DOE chose to analyze all product classes as representative, no scaling was required. Select Baseline Light Sources Identify More Efficacious Substitutes Determine CSLs Scale Results 24
Cost Analysis • Because the metric for CFLKs is the efficiency of the light source with which it is packaged, DOE developed consumer prices for the representative lamp unit sold in a CFLK. ‒ DOE first determined the consumer price of a ceiling fan sold with a CFLK. ‒ DOE then determined the portion of the ceiling fan price attributable to just the CFLK. ‒ DOE lastly determined the portion of the CFLK price attributable to just the lamp. • Based on manufacturer feedback, DOE determined that a basic light kit fixture comprises an estimated 20% of the consumer price of a ceiling fan sold with a CFLK and an LED light source component in a CFLK comprises an estimated 15% of the CFLK consumer price. 25
Cost Analysis • DOE developed a weighted average consumer price for a lamp by using estimated shipments through each distribution channel. • The large consumer-based distribution channel includes home centers and mass merchant ecommerce. • The small consumer-based distribution channel includes electrical wholesalers and showrooms. 81% Large Consumer- Based Distributors Weighted Average Lamp Consumer Price Small Consumer- 19% Based Distributors • To develop a consumer price for all other representative lamp units when sold in CFLKs, DOE applied a ratio based on the retail cost of the lamps, when sold individually at other levels relative to the retail cost of the 10 W A19 LED lamp. 26
Cost Analysis • The table below presents the consumer prices for all CFLKs. The prices presented do not include sales tax. Lamp Consumer Price 2020$ Nominal Rated Total Base Bulb Initial Efficacy Single CSL Technology Wattage Lifetime Lamp Remaining Type Shape Lumens (lm/W) Lamp Total CFLK (W) (hours) Price in Price of Price in Price CFLK CFLK CFLK (2 Lamps) Baseline CFL 13.0 E26 Spiral 900 10,000 69.2 $2.10 $4.19 $31.74 $35.93 LED 10.0 E26 A19 800 15,000 80.0 $2.06 $4.12 $31.74 $35.86 CSL 1 LED 10.0 E26 A19 800 25,000 80.0 $2.80 $5.60 $31.74 $37.34 LED 9.0 E26 A19 800 15,000 88.9 $2.52 $5.04 $31.74 $36.78 CSL 2 LED 9.0 E26 A19 800 25,000 88.9 $3.43 $6.86 $31.74 $38.59 CSL 3 LED 8.0 E26 A19 800 15,000 100.0 $2.98 $5.96 $31.74 $37.70 CSL 4 LED 7.0 E26 A19 800 15,000 114.3 $3.44 $6.89 $31.74 $38.63 CSL 5 LED 6.5 E26 A19 810 15,000 124.6 $3.67 $7.35 $31.74 $39.09 27
Cost Analysis Issue 11: DOE requests comment on the percentage of the consumer price of a ceiling fan with a light kit that is attributable to just the light kit and the percentage of the CFLK that is attributable to just the light source component. Issue 12: DOE requests comment on the shipment weightings used for the Large Consumer-Based Distributors channel and Small Consumer-Based Distributors channel. Issue 13: DOE requests comment on the overall methodology and results of the CFLK cost analysis. 28
CFLK Preliminary Analysis Presentation Overview 1 Overview, Schedule, Scope of Coverage 2 Market & Technology; Screening 3 Engineering Analysis 4 Energy Use Analysis Life-Cycle Cost and Payback Period 5 Analysis 6 Shipments; National Impact Analysis 7 Preliminary MIA 8 NOPR Analyses 9 Closing Remarks 29
Energy Use Analysis: Overview • Purpose: • Develop annual energy use estimates for each available CFLK CSL. • Annual energy use is the site energy use associated with operating the product. • These distributions are used in the life-cycle cost (LCC) and payback period (PBP) analysis to calculate annual operating costs. • Method: • Developed using representative lamps described in engineering analysis. • DOE considered residential and commercial consumer samples. • Annual energy use (kWh) = annual operating hours × system input power 30
Energy Use Analysis: Details • Operating Hours: Sector National Average Daily Operating Hours Commercial 11.5 hours Residential 2.0 hours • Controls: • DOE considered the impact of dimmer lighting controls. • 30% energy use reduction for 11% of CFLKs • Efficacy Trend: • DOE applied an efficacy trend to reduce the wattages of LED replacement lamps over time. • The efficacy trend is based on the market-average efficacy projections provided in the 2019 Energy Savings Forecast of Solid-State Lighting in General Illumination Applicationsreport. 31
Energy Use Analysis: Average Results Residential Sector Commercial Sector CSL Annual Energy Use Savings relative to CSL 0 Annual Energy Use Savings relative to CSL 0 (kWh/yr) (kWh/yr) (kWh/yr) (kWh/yr) 0 18.3 -- 104.5 -- 1 14.1 4.2 80.4 24.1 2 12.7 5.6 72.3 32.1 3 11.3 7.0 64.3 40.2 4 9.9 8.4 56.3 48.2 5 9.1 9.1 52.2 52.2 32
Energy Use Analysis: Issues for Discussion Issue 14: DOE requests comment and data on recent sources and methods for calculating operating hours for CFLKs. Issue 15: DOE requests comment and data on the fraction of CFLKs used with dimmers in the residential and commercial sectors, as well as the associated energy reduction estimate of 30 percent. 33
CFLK Preliminary Analysis Presentation Overview 1 Overview, Schedule, Scope of Coverage 2 Market & Technology; Screening 3 Engineering Analysis 4 Energy Use Analysis Life-Cycle Cost and Payback Period 5 Analysis 6 Shipments; National Impact Analysis 7 Preliminary MIA 8 NOPR Analyses 9 Closing Remarks 34
Life-Cycle Cost and Payback Period Analysis: Overview • Purpose • Provide an economic evaluation from the end-user’s perspective in the first year of compliance (assumed to be 2027). • LCC is the total consumer cost over the product lifetime. • PBP is the time required to recover the increased purchase price of a more efficient product through reduced operating costs. • Method • Use consumer samples developed in the energy use analysis. • Calculate LCC for each CSL by adding installed cost and lifetime operating cost. • Calculate PBP by dividing average increase in installed cost by average decrease in first-year operating cost relative to baseline unit. • LCC savings are calculated with respect to the efficiency of the product a consumer would purchase in the absence of a new standard. 35
Life-Cycle Cost and Payback Period Analysis: Key Inputs Input Description The pre-tax cost attributable to just the lamps of the CFLK. Assume 2 Pre-tax Consumer Cost lamps per CFLK. The sales tax associated with converting the pre-tax consumer cost Total Installed Cost Sales Tax to a consumer product cost. Installation Cost Not included: assumed to be constant across CSLs. Product Energy The product energy consumption is the site energy use associated Consumption with operating the product. Energy Prices and Price The prices consumers pay for energy (i.e., electricity) and annual Trends rates of change projected for electricity prices from AEO 2021. Maintenance costs include replacement lamp purchases over the Maintenance Costs lifetime of the ceiling fan. The cost of disposing the lamps in their year of retirement. Assumed Operating Cost Disposal Cost $0.70 per CFL lamp for 35% of commercial CFLK purchases. Represents the remaining dollar value of surviving lamps at the end Residual Value of the CFLK lifetime. Applied as a “credit” to the LCC. Lifetime Age at which the ceiling fan is retired from service. Mean: 13.8 years. DOE implemented a price trend for LED CFLK lamps, which is based Lamp Price Learning on an analysis of A-line LED GSLs. 36
Life-Cycle Cost and Payback Period Analysis: Inputs Market Efficacy Distribution • DOE modeled two scenarios in order to capture a range of lighting market dynamics: • Reference: Due to LED efficacy improvements, DOE assumes the 10 W LED at CSL 1 will be as efficient as the CSL 2 LED lamp by 2027. Therefore, the least- efficacious LED option available in 2027 is CSL 2. • Alternative: LED efficacy does not begin improving until 2027; therefore, the CSL 1 LED option is available in 2027. No-New-Standards Case Efficacy Distribution for All CFLKs in 2027 Market Share CSL Lamp Description Reference Alternative 0 13 W CFL 2.4% 2.4% 1 10 W LED 0.0% 97.6% 2 9 W LED 97.6% 0.0% 3 8 W LED 0.0% 0.0% 4 7 W LED 0.0% 0.0% 5 6.5 W LED 0.0% 0.0% 37
Life-Cycle Cost and Payback Period Analysis: Results Average LCC and PBP Results for Residential CFLKs Average Costs (2020$) Lamp Simple Payback Average Lifetime CSL Installed First Year’s Lifetime Life-Cycle Option Period (years) (years) Cost Operating Cost Operating Cost Cost 0 0 4.50 2.61 22.18 26.68 -- 13.8 1 3.73 2.01 20.40 24.13 0.0 13.8 1 2 5.07 2.01 20.33 25.40 0.9 13.8 3 4.56 1.81 18.96 23.53 0.1 13.8 2 4 6.21 1.81 18.57 24.78 2.1 13.8 5 3 5.40 1.61 17.52 22.92 0.9 13.8 6 4 6.23 1.41 16.07 22.30 1.4 13.8 7 5 6.65 1.31 15.34 21.99 1.6 13.8 38
Life-Cycle Cost and Payback Period Analysis: Results Average LCC and PBP Results for Commercial CFLKs Average Costs (2020$) Lamp Simple Payback Average Lifetime CSL Installed First Year’s Lifetime Life-Cycle Option Period (years) (years) Cost Operating Cost Operating Cost Cost 0 0 4.50 9.90 71.62 76.53 -- 13.8 1 3.73 7.62 66.97 70.69 0.0 13.8 1 2 5.07 7.62 67.51 72.58 0.2 13.8 3 4.56 6.86 64.56 69.12 0.0 13.8 2 4 6.21 6.86 63.79 70.00 0.6 13.8 5 3 5.40 6.09 62.10 67.49 0.2 13.8 6 4 6.23 5.33 59.71 65.94 0.4 13.8 7 5 6.65 4.95 58.51 65.16 0.4 13.8 39
Life-Cycle Cost and Payback Period Analysis: Results Average LCC Savings Results for All CFLKs Residential Commercial CSL Average LCC % of Purchasers that Average LCC % of Purchasers that Savings (2020$) Experience a Net Cost Savings (2020$) Experience a Net Cost 1 3.58 0.1 7.99 0.0 2 3.58 0.1 7.99 0.0 3 0.69 42.4 1.78 16.7 4 1.32 41.2 3.39 9.5 5 1.62 41.0 4.19 8.3 40
LCC and PBP Analysis: Issues for Discussion Issue 16: DOE requests comment and data on the efficacy distribution of CFLKs in the assumed compliance year, as well as the two scenarios DOE analyzed to capture the effect of the efficacy trend for LED lamps. Issue 17: DOE requests comment and data on the disposal cost assumptions for CFLKs. Issue 18: DOE requests comment on the ceiling fan and CFLK lamp lifetime distributions used in this preliminary analysis. Issue 19: DOE requests comment on the overall methodology and results of the life- cycle cost and payback period analysis. 41
CFLK Preliminary Analysis Presentation Overview 1 Overview, Schedule, Scope of Coverage 2 Market & Technology; Screening 3 Engineering Analysis 4 Energy Use Analysis Life-Cycle Cost and Payback Period 5 Analysis 6 Shipments; National Impact Analysis 7 Preliminary MIA 8 NOPR Analyses 9 Closing Remarks 42
Shipments Analysis: Overview • Purpose • To compute the shipments and efficiency composition projections of CFLKs over the analysis period (2027-2056). • Method • Shipments are estimated using no-new-standards-case ceiling fan shipments derived for the ECS preliminary analysis, assuming a fixed penetration of CFLKs per unit of ceiling fan shipped. • DOE applies an elasticity effect to reduce demand at higher CSLs in the presence of higher priced CFLKs. • DOE assumes that only a small fraction of CFLKs in the no-new-standards-case are shipped with CFLs, and the remainder are the least costly LEDs available. • At higher CSLs, DOE assumes shipments are all at the least costly available lamp option. 43
Shipments Analysis: Standards Case Projections • DOE applied an elasticity effect in the standards cases, which reduces shipments volume in the presence of fans with higher priced CFLKs. • Because the incremental cost of more efficient CFLKs is small compared to the overall cost of a ceiling fan, shipments are only slightly reduced at higher standards. Click to add text 44
National Impact Analysis: Overview • Purpose • Determine the projected national energy savings (NES) and consumer national net present value (NPV) of a potential standard. • Method • Develop annual series of national energy and economic impacts. • Use the shipments model to estimate the total stock of CFLKs in service each year. Click to add text • Aggregate the costs and energy use per unit in any given year. • Report estimates for economic impact as change in discounted consumer NPV (in constant year dollars). • Account for the time-value of money through defined discount rates. 45
National Impact Analysis: Inputs Input Description Annual shipments from shipments model, broken out by efficiency level at each Shipments CSL in each scenario, from 2027-2056. Annual weighted-average per-unit values as a function of efficiency distribution Total Installed Cost per Unit taken from LCC analysis. Annual weighted-average per-unit values as a function of CFLK CSL, taken from Annual Unit Energy Consumption LCC analysis. Replacement Lamp Purchase Average cost of replacement lamps, as a function of year. Price Replacement Purchase Rate Average number of replacement lamp purchases per CFLK socket at a given age. Based on the DOE Energy Information Agency’s Annual Energy Outlook 2021 Trend in Energy Prices Reference case. A time-series conversion factor that accounts for energy used to generate Energy Site-to-Primary Factor electricity. Multiplier developed to include the energy consumed in extracting, processing, Full Fuel Cycle Factor and transporting or distributing primary fuels used by CFLKs. 7 percent and 3 percent discount rate from Office of Management and Budget’s Discount Rate Regulatory Analysis Guideline A-4. Present Year Future expenses are discounted to the year 2021. Analysis Period 30 years from compliance year (2027) and through 2086 (after shipments period concludes) 46
National Impact Analysis: Results NES and NPV at 3% and 7% discount rate for the 30-year analysis period, for all CSLs CSL 1 CSL 2 CSL 3 CSL 4 CSL 5 NES Primary (quads) 0.01 0.01 0.09 0.18 0.22 NES Full Fuel Cycle (FFC) (quads) 0.01 0.01 0.10 0.19 0.23 NPV 3% Discount Rate (billions 2020$) 0.07 0.07 0.44 0.90 1.09 NPV 7% Discount Rate (billions 2020$) 0.03 0.03 0.17 0.35 0.42 47
Shipments & NIA: Issues for Discussion Issue 20: DOE requests comment and data on the prevalence of integrated LED CFLKs in the market, and information on their lifetime and replaceability that could improve shipments modeling. DOE requests comment and data that could inform the size or application of the price elasticity effect for ceiling fans as applied for CFLKs. Additionally, DOE requests comment on the overall methodology and results of the shipments and national impacts analysis. 48
CFLK Preliminary Analysis Presentation Overview 1 Overview, Schedule, Scope of Coverage 2 Market & Technology; Screening 3 Engineering Analysis 4 Energy Use Analysis Life-Cycle Cost and Payback Period 5 Analysis 6 Shipments; National Impact Analysis 7 Preliminary MIA 8 NOPR Analyses 9 Closing Remarks 49
Preliminary MIA • Purpose – The manufacturer impact analysis (MIA) identifies the impacts of energy conservation standards on manufacturers. • Phase 1 – DOE creates an industry profile to characterize the industry and identify important issues that require consideration. • Phase 2 – DOE prepares an industry cash-flow model and an interview questionnaire to guide subsequent discussions. • Phase 3 – DOE interviews manufacturers and assesses the impacts of standards both quantitatively (using the Government Regulatory Impact Model) and qualitatively (impacts on competition, manufacturing capacity, employment, and regulatory burden). 50
CFLK Preliminary Analysis Presentation Overview 1 Overview, Schedule, Scope of Coverage 2 Market & Technology; Screening 3 Engineering Analysis 4 Energy Use Analysis Life-Cycle Cost and Payback Period 5 Analysis 6 Shipments; National Impact Analysis 7 Preliminary MIA 8 NOPR Analyses 9 Closing Remarks 51
Analyses for Notice of Proposed Rulemaking (NOPR) Framework Prelim Final NOPR Document Analysis Rule Life-Cycle Monetization Revise Manufacturer Employment Utility Regulatory Preliminary Cost Emissions of Emission Impact Impact Impact Impact Subgroup Analysis Reductions Analysis Analysis Analysis Analysis Analysis Analysis Benefits 52
CFLK Preliminary Analysis Presentation Overview 1 Overview, Schedule, Scope of Coverage 2 Market & Technology; Screening 3 Engineering Analysis 4 Energy Use Analysis Life-Cycle Cost and Payback Period 5 Analysis 6 Shipments; National Impact Analysis 7 Preliminary MIA 8 NOPR Analyses 9 Closing Remarks 53
Closing Remarks/Questions 54
How to Submit Written Comments for CFLKs • In all correspondence, please refer to the rulemaking by: – Energy Conservation Standards for Ceiling Fan Light Kits; – Docket Number EERE-2019-BT-STD-0040; and – Regulatory Identification Number 1904-AE52. • Email: CFLK2019STD0040@ee.doe.gov • In light of the ongoing Covid-19 pandemic, DOE is currently suspending receipt of public comments via postal mail and hand delivery/courier. If a commenter finds that this change poses an undue hardship, please contact Appliance Standards Program staff at (202) 586-1445 to discuss the need for alternative arrangements. Once the Covid-19 pandemic health emergency is resolved, DOE anticipates resuming all of its regular options for public comment submission, including postal mail and hand delivery/courier. Comment Period closes: May 6, 2022 11:59 PM EDT 55
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