Craig’s Lighting Articles, Legislation + Regulation

T8 Rules to Take Effect

Below is my contribution to the January 2018 issue of ELECTRICAL CONTRACTOR.

In 2015, the U.S. Department of Energy (DOE) issued new energy standards for general-service fluorescent lamps. These standards identify categories of lamps and impose minimum efficacies, expressed in lumens/W. Primarily impacting 4-ft. 32W T8 lamps and some reduced-wattage T8 lamps, the new standards are now set to take effect January 26, 2018.

The Energy Policy Act of 1992 regulated general-service fluorescent lamps and granted DOE rule-making authority. In 2009, DOE expanded coverage to include 8-ft. T8 and 4-ft. T5 lamps as well as a broader range of wattages of 4-ft. T8 and T12 lamps. Effective July 2012, these rules eliminated a majority of T12 lamps. Lower-color rendering (700 series) 4-ft. T8 lamps also did not comply, but DOE granted a two-year exemption to manufacturers that requested it.

The 2015 rules tightened existing energy standards for 4-ft. linear T8, 2-ft. U-bend T8, 4-ft. linear T5, and 4-ft. linear T5HO lamps. Minimum required efficacy for T8 lamps increased one to four percent, a modest increase but up to the maximum technology level. Minimum required efficacy for T5 lamps increased seven to 10+ percent. Eight-foot lamps saw no increase. DOE extended the range of covered wattages for 8-ft. single-pin lamps and 4-ft. T5 and T5HO lamps.

Existing exemptions will continue to apply, including 1) lamps designed to promote plant growth, 2) lamps designed specifically for cold-temperature applications, 3) colored lamps, 4) impact-resistant lamps, 5), reflectorized or aperture lamps, 6) lamps designed for reprographic applications, 7) UV lamps, and 8) lamps with a CRI of 87 or higher.

The regulations provided a three-year window for manufacturers to evaluate their products and either discontinue or reengineer them to comply. Eliminations were expected, which may affect lamp availability and cost, though popular models may continue to be available. After January 26, distributors may continue to sell lamps manufactured or imported before that date until inventories are exhausted.

Four-foot linear T8 lamps: At the time of regulation, a majority of these lamps passed the new standards. These were primarily 25W, 28W, and 30W lamps, however; basic-grade 32W T8 lamps did not comply and would need to be redesigned or discontinued. Similarly, 32W lamps designed to offer extended life. Lamps with lower color temperatures were disproportionately affected.

If the installation uses continuous-dimming ballasts, the end-user will have to determine whether the ballasts are rated for reduced-wattage lamps. Operating reduced-wattage lamps on incompatible dimming ballasts will produce unsatisfactory performance. If the ballasts are not rated for reduced-wattage lamps, the end-user must replace the lamps with compliant full-wattage lamps or replace the dimming ballast with ballast rated for reduced-wattage lamps.

Two-foot U-bend T8 lamps: As with 4-ft. linear T8 lamps, a majority initially complied with the new standards, though again these are low-wattage models. Many 32W models did not comply and would be discontinued or reengineered. It is expected that popular 32W models will continue to be available.

An issue with substitution centers on whether the lamp has 1-5/8-in. or 6-in. leg spacing. A majority of users of 6-in. leg spacing use full-wattage lamps on control systems so they can be dimmed, while users of lamps with 1-5/8-in. spacing use reduced-wattage lamps.

Four-foot T5 and T5HO lamps: A majority of 4-ft. T5 and T5HO lamps comply. At the time the regulations were announced, major manufacturers expected that their existing product lines would satisfy the energy standards with limited reengineering, resulting in a minimal impact on availability.

In 2010, DOE estimated that 20 percent of all commercial building sector lamps and 44 percent of industrial sector lamps were 4-ft. T8, representing some 532 million 4-ft. linear T8 lamps and 14 million T8 U-bend lamps. In its justification for the new standards, DOE estimated that over the next 30 years, end-users would receive an average payback of 3-4 years and cost savings with a cumulative new present value (factoring energy cost savings and higher purchase cost) of $2-5 billion based on a respective discount rate of seven and 3.3 percent.

Energy savings are only gained, however, if the end-user switches from a full-wattage T8 to a reduced-wattage T8 lamp or operates a compliant full-wattage T8 lamp on dimming controls. Alternately, they may make the switch to LED to achieve higher energy savings and potentially increased capabilities. Options include LED replacement lamps, retrofit kits, and new luminaires.

Overall, the 2015 rules represent another regulatory step in removing the least-efficient and lowest-cost lamps from the market. Electrical contractors may benefit from consulting with lamp manufacturers about availability and advising their customers about the regulations and impact on their lighting systems.

End-users, meanwhile, should consider the benefits of a comprehensive upgrade rather than replacing non-compliant lamps individually as part of maintenance. A comprehensive upgrade can ensure lighting quality is maintained or improved, reduce the risk of matching incompatible components, and consider all options, such as LED and advanced controls.

For more information, contact the lamp manufacturers.

author avatar
Craig DiLouie

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