Ontario Ministry of Energy…

Ontario Ministry of Energy
Conservation and Renewable Energy Division
Attn: Senka Krsikapa MSc. P. Eng. Manager
77 Grenville Street, Floor 5 & 6
Toronto ON
M7A 2C1

Dear Ms. Krsikapa

Comments on pending January 1st, 2018 Regulations on General Service Incandescent Lamps (Reg. 404/12 Energy Efficiency – Appliances and Products / Schedule 5, Lamps and Other Lighting Products / Section 6.1 Lamp, regulated incandescent)

Electro-Federation Canada (EFC) has a significant concern about the pending Ontario energy efficiency regulation for Halogen Lamps. The efficiency regulation of concern is listed as: 6.1. Lamp, regulated incandescent: i. Date of Manufacture: January 1st, 2018 or later ii. Testing standards: A. for lamp lumen output and wattage: IES LM-45-09, IESNA Approved Method for Electrical and Photometric Measurements of General Service Incandescent Filament Lamps, except that the lamp must be tested at 120 volts regardless of it nominal voltage, B. for life; IES LM-49-12, IESNA Approved Method for Life Testing of General Lighting Incandescent Filament Lamps, except that the lamp must be tested at 120 v00100olts regardless of its nominal voltage, C. for colour rendering index (CRI): CIE 13.3-1995, Method of Measuring and Specifying Colour Rendering Properties of Light Sources. iii. Scope of application: a “regulated incandescent” lamp as defined in section 2 of this Schedule. iv. Prescribed efficiency standard or requirement: A. lamp efficacy in lm/W: ≥ 45, B. life: ≥ 1000 hours, and C. CRI: ≥ 80. This proposed regulation is not harmonized with any other Canadian Provincial regulations, Federal NRCan regulations, or United States Department of Energy regulations. Of primary concern is the implementation date of January 1st, 2018 and the regulatory level. The standard of 45 LPW, and 1000 hours life cannot be met by any known Halogen Technology which means that implementing such a standard in 2018 would eliminate halogen A-line lamps from the Ontario market. Ontario would be the only market in North America to clearly implement such a standard in 2018. (It is still unclear when the California regulation will be pre-empted by Federal USA regulations. It is also unclear when the United States regulation will be finalized. Any California regulation will ultimately be pre-empted by the United States federal regulations.)

Requested Action

Industry strongly recommends that Ontario withdraw this regulation; or at the very least push the regulatory compliance date to no earlier than January 1st 2020; or to a later year in which the outcome of the final United States Department of Energy efficiency regulations for Halogen Lamps will be clearly known. In addition, NRCan has stated it intends to harmonize with the United States regulations when finalized. British Columbia has indicated a similar goal to achieve harmonization. If not withdrawn or delayed, Ontario may be left with a regulation that differs from every other Province and State in North America.

Sales of Standard A-line Halogen Lamps in Ontario Today

In 2016, there was a significant number of Halogen Lamp Sales in the Ontario Market. Based on Electro-Federation Canada statistics about 25% of all A-line light bulbs sold by industry in 2016 in Ontario were halogen lamps. The remainder were LED and CFL lamps (approximately 55%) and non-regulated Incandescent lamps. Halogen lamps still provide the best solution for many lighting applications due to their colour, sparkle, light distribution, warmth, and ability to fully operate on all installed dimmers while being 30% more efficient than standard incandescent lamps. CFL and LED light sources offer the best solution for many other lighting applications and are also quite popular. Industry does not have a lighting substitute that offers all the lighting qualities of halogen lamps. Therefore, if this regulation is not changed millions of customers using this lamp type will be forced to look outside of the Province should this regulation go into effect in 2018.

Negative Industry Impacts due to lack of North American Harmonization

As discussed during the CLIC meeting, the same lighting products are sold throughout North America in both Canada and the United States due to a common product distribution system and very similar electric power systems. As such, it is critically important to the lighting industry that efficiency regulations are harmonized as much as possible. Industry recognizes that it is not always possible to harmonize United States and Canadian regulations. However, it is equally important for Provincial efficiency regulations to harmonize with federal Canadian efficiency regulations, which is nearly always possible. Not harmonizing creates difficult and unnecessary product development, distribution, and sales problems for industry throughout North America. Keeping specific products out of individual provinces or states adds significant internal costs to industry and may require special package labelling. Lack of harmonization can also produce significant enforcement and compliance problems for a Province or State that is not harmonized.

History of Halogen A-line Lamps

When the Canadian halogen lamp standard (using a linear log-function curve) was first proposed by NRCan around 2010, the only halogen lamps that could meet that standard were Halogen-IR A-line lamps. This lamp had been introduced by industry a few years prior to 2010. At the time, standard halogen lamps were slightly more efficient than incandescent lamps; a 90-watt halogen lamp could replace a 100-watt incandescent lamp. A halogen lamp had a much longer life, typically 3000 to 4000 hours compared to approximately 1000 hours for an incandescent lamp. The more advanced Halogen-IR lamps offered both long life and energy efficiency with a 65 watt (or 70 watt) Halogen-IR lamp with a 3000-hour life being offered as a replacement for a 100 watt incandescent lamp. However, due to its very high price, up to ten (10) dollars per lamp, the Halogen-IR A-line lamp was typically only sold in commercial channels. When industry attempted to sell the Halogen-IR lamps in consumer channels, even discounted down as low as two (2) lamps for ten (10) dollars, the product did not sell due to the high price point compared to other lighting products on the shelf. The economics of a ten (10) dollar Halogen-IR lamp were only favorable when compared with traditional incandescent technology, such as a 100-watt incandescent lamp, coupled with a high electric rate.

When the U.S. incandescent efficiency regulations were implemented in 2012 through 2014, industry developed a brand-new Halogen lamp designed to last 1000 hours, using no more than 72 watts (to replace a 100 watt lamp), and sold for less than two (2) dollars per lamp. The efficiency of a standard halogen lamp was increased by reducing lamp life from 3000 hours to 1000 hours as well as employing additional design changes. With the new low cost 72 watt halogen lamp on the market, the expensive 65 watt (or 70 watt) Halogen-IR lamp was no longer economical for any customer and was removed from the market. The new, lower cost halogen lamps (popular in 29w, 43w, and 72w) are sold in Ontario as well as North America today; and are the halogen lamps that would be eliminated by the pending 2018 Ontario regulation.

The Issue with Dimmers

Elimination of all halogen A-Line lamps will eliminate the only energy efficient filament-based product that will operate on all existing dimmers and provide the ability for dimming to very low light levels. Although some CFL lamps and some LED lamps are marketed as dimmable, the ability to dim depends on the compatibility between the electrical circuit in the dimmer and the electronics in the lamp. Even if the circuits are compatible, the LED and CFL products often do not dim very low and can start to strobe, flicker, shut off, or just stop dimming at lower light levels. While this is OK for some applications, it is not OK for all applications. A halogen lamp option needs to be kept on the market place for applications requiring deep dimming. In the meantime, industry is working on dimming standards for new LED lamps and new LED Dimmers to improve the dimming experience with these products.

If this rule is adopted in 2018 as proposed, it will produce a limited product selection of lamp options; product unavailability; limited dimmable lamp options with a reduced dimming range; significant enforcement issues; and customer dissatisfaction with many lighting applications in their home. In turn, significant consumer dissatisfaction will result in complaints to manufacturers, retailers and government officials. To avoid these issues, industry urges Ontario to wait until the United States Department of Energy (DOE) rule making is finalized, and harmonize with that rule making as planned by NRCan. Only in this way can Ontario truly harmonize with this future regulation on General Service Lamps.

In summary, the Lighting Industry respectfully requests that Ontario withdraw this regulation, or, push the implementation date to 2020 or later.

Robert (Rob) McIntyre CPA CMA
Vice President, Technical Services
Electro-Federation Canada
180 Attwell Drive, Suite 300
Toronto, ON
M9W 6A9

[Original Comment ID: 210173]