WRR methodology vs Lumen range For A-Lamps Alina Zohrabian IOU WRR Working Group: Richard Greenburg(SCE), Yun Han(SCE), Jeff Cox (SDG&E), Adam ScHEER(PG&E), Shareghe Mehraeen (PG&E), Alina Zohrabian (PG&E) October 27, 2016

Issues with WRR WRRs Out-of-Date as LED Efficacy Increases: Current WRR out-of-date, even if updated, as LED efficiency increases, WRR will again be out-of-date (Navigant Study) WRR Yields Inaccurate Results – for bulbs with the same lumen output, higher wattages yield higher savings – this is clearly not correct (see next slide). Creates Need for Excessive Measure Codes to Get Accurate Savings, Complicating Administration and Increasing Costs: Guidance to apply WRR to lowest end of wattage range results in creation of many individual measure codes to finely bin wattage ranges Creates Incorrect Incentives for PAs– Higher Wattage in Same Lumen Bin Yields Greater Savings, so PA incentive is to incent higher wattage bulbs to claim greater savings, even if lower wattage bulb would produce same lumens. New Slide WRR Ratio vs. Lumen Equivalency Methods September 2016

Advantages of Lumen Equivalency Method Accurate Savings: Lumen Equivalency method does not underestimate savings for more efficient or overestimate savings for less efficient lamps. Yields Accurate Results: For bulbs with same lumen output, higher wattage bulbs yields lower savings, as expected. Does Not Become Dated As LED Efficacy Improves: Lumen Equivalency Method does not become out-of-date as LEDs become more efficient Some LED measures might need to be added for the lower end of each EISA bin Most Common Approach Used Nationwide (by far): Lumen Equivalency Method is by far the most common approach to calculating savings from LEDs We should include graphic from Navigant study that demonstrates this point. Confirm where lumens come from – not manufacturers. Find cite for Navigant study. WRR Ratio vs. Lumen Equivalency Methods September 2016

Issues/Challenges for the Savings Calculation Balancing the savings accuracy and simplified implementation Making assumptions on what the appropriate percent and mix of base case should be for each bin (TRC Report looks at four data sources) After finalizing A-Lamp method, do we apply the same method to all other lamp types? But EISA Lumen bins are not defined for other lamp types, or should a different method be used for each lamp type? (R/BR, PAR, MR16, candelabra, globe) WRR Ratio vs. Lumen Equivalency Methods September 2016

Comments from ED Staff is supportive of applying lumen equivalency to determine energy savings but has some concerns with how the method is applied Proposed Lumen Range too wide. EISA ranges don’t apply since they are designed for lumen equivalency of halogens Percent of CFL in the Baseline: DMV-GL shelf survey not representative of sales, and more importantly what the LEDs will be replacing next year. Best source of data to answer question is NEMA.  NEMA data for past several quarters indicate halogens/ incandescent largely stable, whereas CFLs decreasing/LEDs increasing.  Thus, likely that LEDs are replacing CFLs. ED believes that based on initial assessment of NEMA data CFL as percentage of baseline is clearly more than 50%, but less than 90% Determining CFL Wattage Equivalent Navigant study findings not applicable for two reasons: commercial, not residential and small sample size. WP developer should go back to most recent site survey and either analyze original source data (from ’10 – ’12 CLASS survey) OR look at final report and see if KEMA determined wattage equivalents and use this. Incentive Design: Higher Efficacy Bulbs Should Receive Greater Incentives WRR Ratio vs. Lumen Equivalency Methods October 2016

Addressing ED Comments 1. Staff is supportive of applying lumen equivalency to determine energy savings but has some concerns with how the method is applied We have carefully considered all of staff’s feedback and have gathered additional data and performed additional analysis to respond and to provide recommendations. What follows are staff’s comments and our recommendations to address the issues related to baseline, lumen range, efficacy and CFL wattage equivalency. WRR Ratio vs. Lumen Equivalency Methods October 2016

Addressing ED Comments 2. Proposed Lumen Range too wide Breaking the lumen ranges creates 42 measure codes instead of 31 and greatly complicates the delivery of the program with no effect on savings. When the 40W incandescent equivalents are split into 40A and 40B half-ranges, the LED wattages have products in both halves. Recommendation: Keep the original EISA lumen ranges since more granular lumen ranges don’t change savings and increase complexity/confuse the market # of Products in each half-EISA bin LED wattage 40A 40B 60A 60B 5 29 4 6 240 19 7 224 43 25 8 66 12 9 1 447 10 464 22 11 125 81 13 14 WRR Ratio vs. Lumen Equivalency Methods October 2016

Addressing ED Comments 2a. The EISA ranges don’t apply – they were designed to determine lumen equivalencies for halogens.  The EISA lumen ranges are designed to align halogens with traditional incandescent lamps. Therefore the defined lumen ranges are the common lumen values for traditional incandescent lamps that people have become familiar with the last 100 years. When buying LED’s, the LED lamps are compared to traditional incandescent wattages and lumen values. (see inset packaging example) Using other metrics or ranges would confuse customers and implementers and it is not consisted with how these products are being marketed to our customers by manufacturers or retailers As a major online retailer explains to their customers under the heading LED Light Bulbs - 60 Watt Equal “With an efficiency up to 80% higher than similar output incandescent, it is certainly safe to say that LED light bulbs like the 60-watt equivalent use less energy than similar incandescent bulbs. You can be sure this is the case thanks to the "60 Watt Equal" in the bulb's name. This description is included because although these bulbs typically consume between just 8 and 13 watts of energy, they produce as much light as a 60-watt incandescent bulb. This information helps buyers gauge how bright a given bulb will be.” Recommendation: Keep the original EISA lumen ranges based on the manufacturer and retailer marketing approach From www.1000bulbs.com/category/60-watt-equal-led-light-bulbs/ Also, light output data was not provided with NEMA sales data WRR Ratio vs. Lumen Equivalency Methods October 2016

Addressing ED Comments 3. Baseline:  CFLs as Percent of Baseline a. DMV-GL shelf survey not representative of sales, and more importantly what the LEDs will be replacing next year. b. Best source of data to answer question is NEMA.  NEMA data for past several quarters indicate halogens/ incandescent largely stable, whereas CFLs decreasing/LEDs increasing.  Thus, likely that LEDs are replacing CFLs. c. ED believes that based on initial assessment of NEMA data CFL as percentage of baseline is clearly more than 50%, but less than 90% TRC has updated the lighting baseline data memo to include the 2nd quarter data from NEMA info as requested. Note that NEMA data is national and since several states have discontinued their CFL programs and shifted to LED programs, it is questionable to draw conclusions without more granular information on National sales data We understand that CLASS 2012 data is 4 years old, but assumptions in changes in market saturation over these 4 years should match market sales information such as NEMA shipment data. A-lamp market saturation and baseline technology should be reflected by summation of annual sales (accounting for differing product lifetimes) rather than by quarter-to-quarter trends in sales, shown on the next slide. Wisconsin, Illinois, Vermont, Mass WRR Ratio vs. Lumen Equivalency Methods October 2016

Addressing ED Comments 3. CFLs as Percent of Baseline The Residential CLASS 2012 saturation results is “updated” with sales trends from the NEMA lamp index, highlighting difference between saturation & sales, assuming: Typical product lifetimes, 541 Residential HOU When a given product type fails, that type is the baseline for the next sale The product mix sold is based on the average NEMA market share for the time period; future sales are based on latest market share; like-for-like replacement where possible is the default. Current CFL A-lamp saturation is 57%, but 28% of A-lamp failures are CFLs (2 bold columns) Recommendation: Data suggests LED sales replace: 40% Incandescent, 58% CFL, 2% LED. We recommend to combine the LEDs with CFLs since it is a very small percentage and use 40% Inc/Hal and 60% CFL and these percentages are closely inline with the most recent DNV-GL CA shelf survey data. Lamp Type 2012 CSS & CLASS saturation Lamp Lifetime (hours) % of sockets replaced ‘12-’16 Replacement Time Period (residential) Q3 2016 socket saturation Current Failures as % of total sockets (541 HOU) Current failures % of purchases Latest NEMA Sales Market Share 2016 Q2 % current Sales Replacing same technology type % of current Sales Replacing Incand. CFL failure, LED replacement Incand. 49.3% 1000 100.0% Q3 2015 - Q2 2016 8.2% 4.4% 40% 13% 0% Halogen 0.7% 4000 57.3% Q4 2012 - Q2 2016 26.4% 3.6% 32% 50% 18% CFL 49.7% 10000 57.4% 3.1% 28% 16% LED 0.3% 20000 13.2% 7.9% 0.04% 0.4% 21% 8% 12% Emphasize this is traditional incandescent; our savings are conservative b/c we are using EISA-compliant Wattages for all Halogens + incandescent WRR Ratio vs. Lumen Equivalency Methods October 2016

PG&E’s C&S Home Energy Use Study July 2016 July 2016 = HEUS. Conclusion: July 2016 data show that LED’s mostly replace incandescent in the household not CFLs, so CFLs should not be the significantly increasing part of the baseline WRR Ratio vs. Lumen Equivalency Methods September 2016

Addressing ED Comments 4. Determining CFL Wattage Equivalent a. Navigant study findings not applicable for two reasons: commercial, not residential and small sample size. b. WP developer should go back to most recent site survey and either analyze original source data (from ’10 – ’12 CLASS survey) OR look at final report and see if KEMA determined wattage equivalents and use this. c. Use DEER CFL WRR Neither the CLASS final report nor web data tool provide specific data on CFL wattage equivalents. Unfortunately the data didn’t include lumen info. CLASS data on average wattage per home and lamps per home by technology indicates average incandescent is 60W and average CFL is 17W. Wattage analysis in CLASS conducted by TRC, delivered by Marian Goebes to Doreen Caruth and Alina Zohrabian on 10/14/16 WRR Ratio vs. Lumen Equivalency Methods October 2016

Addressing ED Comments 4. Determining CFL Wattage Equivalent Equivalent Incandescent max wattage halogen max wattage CFL (based on Lumen Equivalency) max CFL wattage (based on old DEER WRR=3.47) max CFL wattage (based on DEER 2016 WRR=2.48) 40 29 10 12 16 60 43 13 17 24 75 53 18 22 30 100 72 23   Savings for 9W LED (based on lumen equivalency) Savings for 9W LED (based on WRR=3.47) Savings for 9W LED (based on WRR=2.48) 10.5 11.3 13.6 19.0 21.1 24.6 MWH from EISA; CFL LE from R Greenburg. Addressing ED Comments For illustration purposes: assumed 50% CFL and 50% Halogen for base case Conclusion: DEER WRR would increase the savings since it increases the CFL wattage. We continue to believe our original recommendation of lumen equivalency is the most appropriate but acknowledge feedback that DEER WRR values should be used. WRR Ratio vs. Lumen Equivalency Methods October 2016

Addressing ED Comments 5. Incentive Design: Higher Efficacy Bulbs Should Receive Greater Incentives It is also important to note that for Residential programs there are quality requirements in the CEC spec that must be complied with. CEC spec includes specific requirements for CCT, CRI, flicker, PF, etc and lamps with better color quality which tend to have lower efficacy. We looked into choosing a minimum efficacy requirement for the commercial market but determined that would eliminate the majority of the CEC spec lamps from being offered. Although the CEC spec lamps are not mandatory for commercial programs, we don’t want to eliminate the choice for our commercial customers to have better color and higher quality lamps since customer experience and acceptance is as important as saving energy. There are many commercial markets like: hotels, motels, restaurants, nursing homes, grocery and retail which would benefit from having better color lamps. Conclusion: As outlined in the Navigant report moving to proposed lumen equivalence calculation would be a significant improvement over the current WRR method and eliminate the perverse incentive to incent the higher wattage LEDs. WRR Ratio vs. Lumen Equivalency Methods October 2016