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DOE's Level VI Energy Efficiency Regulation for EPSs & The House Bill H.R. 4444

I n February 10, 2016, the Department of Energy (DOE) Level VI Energy Efficiency Regulation for External Power Supplies (EPSs) became effective. As the progress of technology continues and the progression of the title suggests, this regulation is much more stringent and wider in scope than its predecessors, Level III, IV, or V, and is applicable world wide. This regulation is more stringent in the terms of efficiency requirements and no load power consumption, and wider in scope since it includes multiple output EPSs and the output power level is extended beyond 250 watts. Earlier regulations were limited to power products with output power up to 250 watts.

According to the DOE web site: "...more than 300 million external power supplies are shipped annually. This regulation will save consumers up to an additional $3.8 billion (in energy costs) and will cut emissions by nearly another 47 million metric tons of carbon dioxide over 30 years. That is equivalent to the annual electricity use of 6.5 million homes...". In the current debate of climate change and global warming, implementation of this regulation, popularly known as Level VI Energy Efficiency Regulation, seems like an excellent idea. But one has to note that not all industry participants were happy and welcomied this enhancement regulation when it was announced two years ago. Nonetheless it is now the law of the land.

The DOE's Level VI Energy Efficiency Regulation for External Power Supplies was first put forth about two years ago, in February 2014. By the time it went into effect, in February 2016, the power supply industry became familiar with this regulation and invested the necessary technical resources to introduce many new products that meet these requirements and the regulation is currently not viewed as technically obstructive. But it seems, in the hoopla of conceiving this regulation, DOE overlooked one key basic issue related to the product itself. In the DOE definition of EPS the regulation included LED drivers. This is now recognized as being a major "glitch" in the definition of the EPS as LED driver products are technically quite different.

To address this "mistake", the Energy and Commerce (E&C) Subcommittee on Energy and Power held a hearing on January 12, 2016, "HR ____ EPS Improvement Act of 2016" to address this issue of LED drivers being includded in this regulation. The Subcommittee stated: "...Given the broad and circular statutory definition of EPS, DOE has determined that additional products should be covered by the EPS definition for purposes of regulation. For instance, in a 2014 final rule establishing efficiency standards for EPS products, DOE included as a regulated EPS product certain drivers and devices that power solid state lighting products (e.g. light-emitting diodes (LEDs) and organic light-emitting diodes (OLEDDs)). DOE made this determination despite the fact that the design and use of LEDS drivers is distinct from the design and use of EPS..."

The January 12th meeting was attended by the members of the Subcommittee on Energy and Power and by witnesses, Dr. Pekka Hakkarainen, Vice President, Lutron Electronics, on behalf of the National Electrical Manufacturers Association (NEMA: www.nema.org) and Jennifer Amann, Buildings Program Director, American Council for an Energy Efficient Economy (ACEEE; www.aceee.org). The role of the US representatives was to review and modify the regulation with the input from Dr. Hakkarainen who represented the industry and Ms. Amann who represented broader social/environmental community.

For more information about this hearing and its scope please visit:
docs.house.gov/meetings/IF/IF03/20160112/104321/HHRG-114-IF03-20160112-SD002.pdf

There was broad consensus that LED drivers did not belong in the EPS category and should be removed and all parties agreed to amend the definition of EPSs from the original document.

On February 3, 2016, Rep. Renee Ellmers of R-North Carolina (for herself and on behalf of Ms. Degette (D-CO), Mr. Pompeo (R-KS), Ms. Matsui (D-CA) and Mr. Dent (R-PA)) introduced a bill: To amend the Energy Policy and Conservation Act to exclude power supply circuits, drivers, and devices designed to be connected to, and power, light-emitting diodes or organic light-emitting diodes providing illumination from energy conservation standards for external power supplies, and for other purposes.

The bill, titled "EPS Improvement Act of 2016" was introduced in the 114th Congress. It was referred to the E&C. However, it still needs to be passed by the House, Senate and then signed by the President to become law. The Bill has bipartisan support and is expected to pass – but when it will pass is another matter since it takes time to pass any legislation through the US government.

In the mean time, what happens to companies that introduce LED drivers that currently are included in the EPS's definition, but do not meet the efficiency regulation during this interim period between February 10, 2016 and the day when the bill becomes the law? Most manufacturers and users understand that there is a pending legislation and are willing to accept such products. But will they be legal?

CUI's web site: www.cui.com/energystandards was extensively used to review the entire background of the DOE's energy efficiency program.

 

Provided by Mohan Mankikar,
President, Micro-Tech Consultants

 

 

The views expressed in this article are solely of Mohan Mankikar. They do not represent the views of PSMA. Mohan Mankikar has been a part of the power supply industry for over thirty years. An active member of the PSMA since its founding, he had been a board member of the PSMA and currently serves on the Advisory Council. He can be reached at:
Micro-Tech Consultants
(707) 575-4820
MicroMohan@AOL.com
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