PRELIMINARY TECHNICAL SUPPORT 

DOCUMENT: 

ENERGY EFFICIENCY PROGRAM 

FOR CONSUMER PRODUCTS AND 

COMMERCIAL AND INDUSTRIAL EQUIPMENT:

GENERAL SERVICE LAMPS

December 1, 2014

U.S. Department of Energy

Assistant Secretary

Office of Energy Efficiency and Renewable Energy

Building Technologies Program

Appliances and Commercial Equipment Standards

Washington, DC 20585
This document was prepared for the U.S. Department of Energy 

by staff members of 

Navigant Consulting, Inc. 

and 

Lawrence Berkeley National Laboratory
EXECUTIVE SUMMARY

TABLE OF CONTENTS

ES.1 OVERVIEW OF PRELIMINARY ANALYSIS ACTIVITIES......................................ES-1

ES.2 KEY RESULTS OF THE ANALYSIS ..........................................................................ES-3

ES.2.1 Determination of Scope ......................................................................................ES-3

ES.2.2 Market and Technology Assessment ..................................................................ES-4

ES.2.3 Screening Analysis..............................................................................................ES-5

ES.2.4 Engineering Analysis ..........................................................................................ES-5

ES.2.5 Product Price Determination...............................................................................ES-6

ES.2.6 Energy Use Analysis...........................................................................................ES-7

ES.2.7 Life-Cycle Cost and Payback Period Analyses ..................................................ES-8

ES.2.8 Shipments Analysis ...........................................................................................ES-13

ES.2.9 National Impact Analysis..................................................................................ES-16

ES.2.9.1 National Energy Savings..........................................................................ES-17

ES.2.9.1 Net Present Value of Consumer Benefits.................................................ES-17

ES.2.10 Preliminary Manufacturer Impact Analysis......................................................ES-18

ES.2.11 Other Analyses...................................................................................................ES-18

ES.3 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT..........................................ES-19

ES.3.1 GSL Definitions.................................................................................................ES-19

ES.3.2 Specialty Application MBCFLs and LED Lamps .............................................ES-19

ES.3.3 GSL Exemptions ................................................................................................ES-19

ES.3.4 OLED Lamps......................................................................................................ES-20

ES.3.5 Lamps Addressed in Other Rulemakings ...........................................................ES-20

ES.3.6 Other Integrated Lamps ......................................................................................ES-20

ES.3.7 Other Non-Integrated Lamps ..............................................................................ES-20

ES.3.8 MBCFL Metrics..................................................................................................ES-20

ES.3.9 GSL Technology Options ...................................................................................ES-21

ES.3.10 GSL Product Classes...........................................................................................ES-21

ES.3.11 GSL Design Options ...........................................................................................ES-21

ES.3.12 GSL Data Approach............................................................................................ES-21

ES.3.13 GSL Baseline Selection ......................................................................................ES-21

ES.3.14 More Efficacious Substitutes ..............................................................................ES-21

ES.3.15 Non-Integrated Ballast Pairing ...........................................................................ES-22

ES.3.16 Candidate Standard Levels .................................................................................ES-22

ES.3.17 CSL Equation Methodology ...............................................................................ES-22

ES.3.18 Non-Integrated GSL Replacement Assumptions................................................ES-22

ES.3.19 Product Price Determination...............................................................................ES-22

ES.3.20 GSL Hours of Use...............................................................................................ES-23

ES.3.21 EISA 2007 Backstop Criteria..............................................................................ES-23

ES.3.22 Fraction of Dimmable GSLs in the Residential Sector.......................................ES-23

ES.3.23 Energy Savings from Lighting Controls .............................................................ES-23

ES.3.24 Integrated Low Lumen GSL Market Distribution Estimates..............................ES-23

ES.3.25 Consumer Purchases in Standards Case Analyses...............................................ES-23

ES.3.26 Commercial Hours of Use Variability ................................................................ES-23

ES-i
ES.3.27 GSL Service Life Scenarios.............................................................................ES-23

ES.3.28 Lifetime Distribution Modeling.......................................................................ES-24

ES.3.29 Installation Costs..............................................................................................ES-24

ES.3.30 LCC and Consumer Impacts from Potential Standards ...................................ES-24

ES.3.31 GSL Disposal Costs .........................................................................................ES-24

ES.3.32 LCC and PBP Methodologies ..........................................................................ES-24

ES.3.33 GSL Shipments Data........................................................................................ES-24

ES.3.34 Residential Integrated High Lumen GSLs .......................................................ES-24

ES.3.35 Integrated LED Fixture Penetration.................................................................ES-24

ES.3.36 Non-Integrated CFL GSLs................................................................................ES-25

ES.3.37 Rare Earth Price Scenarios................................................................................ES-25

ES.3.38 Electricity Price Scenarios................................................................................ES-25

ES.3.39 LED Learning Rate Scenarios ..........................................................................ES-25

ES.3.40 Incremental Price of Brighter LED GSLs.........................................................ES-25

ES.3.41 Pre-Compliance Year Shift Away from Incandescent GSLs............................ES-25

ES.3.42 GSL Market Data.............................................................................................ES-25

ES.3.43 GSL Rebound Effect Scenarios .......................................................................ES-25

ES.3.44 Penetration of LED GSLs with Standby Functionality....................................ES-26

ES.3.45 Penetration of Commercial GSLs with Controls.............................................ES-26

ES.3.46 Shipments Analysis and NIA Scenarios ..........................................................ES-26

ES.3.47 Consumer Subgroup Analysis..........................................................................ES-26

ES.3.48 Emissions Analysis..........................................................................................ES-26

ES.3.49 Monetization of Emissions Reductions Benefits .............................................ES-26

ES.3.50 Utility Impact Analysis....................................................................................ES-26

ES.3.51 Employment Impact Analysis..........................................................................ES-26

ES.3.52 Regulatory Impact Analysis..............................................................................ES-27

LIST OF TABLES

Table ES.2.1 Product Classes for GSLs ............................................................................ES-5

Table ES.2.2 Candidate Standard Levels for GSL Representative Product Classes..........ES-6

Table ES.2.3 Average Annual Energy Use and Savings per Unit for Integrated Low 

Lumen (< 2,000 lm) GSLs...........................................................................ES-7

Table ES.2.4 Average Annual Energy Use and Savings per Unit for Integrated High 

Lumen (≥ 2,000 lm) GSLs ..........................................................................ES-8

Table ES.2.5 Average Annual Energy Use and Savings per Unit for Non-Integrated 

GSLs ............................................................................................................ES-8

Table ES.2.6 Market Share of each Candidate Standard Level in the Base Case ..............ES-9

Table ES.2.7 LCC and PBP Results by Efficiency Level for Integrated Low Lumen 

(< 2,000 lm) GSLs .....................................................................................ES-10

Table ES.2.8 Average LCC Savings for Integrated Low Lumen (< 2,000 lm) GSLs.....ES-11

Table ES.2.9 LCC and PBP Results by CSL for Integrated High Lumen 

(≥ 2,000 lm) GSLs .....................................................................................ES-11

Table ES.2.10 Average LCC Savings for Integrated High Lumen (≥ 2,000 lm) GSLs ..........ES-12

Table ES.2.11 LCC and PBP Results by CSL for Non-Integrated GSLs..........................ES-12

Table ES.2.12 Average LCC Savings for Non-Integrated GSLs ......................................ES-13

ES-ii
Table ES.2.13 Estimates of Cumulative Full-Fuel Cycle National Energy Savings 

(quads)........................................................................................................ES-17

Table ES.2.14 Cumulative Net Present Value of Consumer Benefits at 3% in billion 

2014$..........................................................................................................ES-17

Table ES.2.15 Cumulative Net Present Value of Consumer Benefits at 7% in billion 

2014$..........................................................................................................ES-18

LIST OF FIGURES

Figure ES.1.1 Flow Diagram of Analyses for the GSL Rulemaking Process ....................ES-2

Figure ES.2.1 Projected Total Base Case Shipments by Technology Type for 

Integrated Low Lumen GSLs (< 2,000 lm) ...............................................ES-14

Figure ES.2.2 Projected Total Shipments by Candidate Standard Case for Integrated 

Low Lumen GSLs (< 2,000 lm).................................................................ES-15

Figure ES.2.3 Projected Total Shipments by Candidate Standard Case for Integrated 

High Lumen GSLs (≥ 2,000 lm) ............................................................... .ES-15

Figure ES.2.4 Projected Total Shipments by Candidate Standard Case for NonIntegrated GSLs ..........................................................................................ES-16

ES-iii
EXECUTIVE SUMMARY

ES.1 OVERVIEW OF PRELIMINARY ANALYSIS ACTIVITIES

Section 6295(o)(3)(B) of 42 U.S.C. requires the U.S. Department of Energy (DOE) to 

establish energy conservation standards (ECS) that achieve the maximum improvement in 

energy efficiency that is technologically feasible and economically justified. Pursuant to Energy 

Policy and Conservation Act (EPCA), DOE has the discretion to issue energy conservation 

standards for general service lamps (GSLs). (42 U.S.C. 6295(i)(6)(A)-(B)) DOE is currently 

conducting an ECS rulemaking for GSLs. This technical support document presents preliminary 

analyses in support of that rulemaking. This executive summary presents key results of those 

analyses and delineates issues on which DOE seeks comment. 

Figure ES.1.1 presents a summary of the analytical components of the standards-setting 

process and illustrates how key results are generated. The focal point of the figure is the center 

column, labeled “Analyses.” The columns labeled “Key Inputs” and “Key Outputs” show how 

the analyses fit into the process and how they relate to each other. Key inputs are the types of 

data and other information that the analyses require. Some key information is obtained from 

public databases; DOE collects other inputs from interested parties or persons having special 

knowledge and expertise. Key outputs are analytical results that feed directly into the standardssetting process. The issues on which DOE seeks comment from interested parties derive from the 

key results that are generated by the preliminary analysis. Arrows connecting analyses show the 

types of information that feed from one analysis to another. 

ES-1
Figure ES.1.1 Flow Diagram of Analyses for the GSL Rulemaking Process

ES-2
ES.2 KEY RESULTS OF THE ANALYSIS

ES.2.1 Determination of Scope

The Energy Policy and Conservation Act definition of “general service lamp” includes

general service incandescent lamps (GSILs), compact fluorescent lamps (CFLs), general service 

lighting-emitting diode (LED) lamps, organic light-emitting diode (OLED) lamps, and any other 

lamps that the Secretary determines are used to satisfy lighting applications traditionally served 

by general service incandescent lamps. However, the term general service lamp does not include

any GSIL excluded from the “general service incandescent lamp” definition, or any general 

service fluorescent lamp or incandescent reflector lamp. 10 CFR 430.2 Chapter 2 of this 

technical support document (TSD) discusses each of the lamp types included in the definition of 

general service lamp in more detail.

In summary, DOE is considering establishing standards in this rulemaking for the 

following lamps:

• Integrated, non-reflector, medium screw base lamps with a lumen output between 310 

and 2,600 lumens;

• GU24 base, non-reflector lamps with a lumen output between 310 and 2,600 lumens; and

• Non-integrated, non-reflector, pin base, CFLs with a lumen output between 310 and 

2,600 lumens.

Standards would not apply to the follow lamp types:

• OLED lamps

• Mercury vapor lamps

• Incandescent reflector lamps

• General service fluorescent lamps

• Light fixtures

• Appliance lamps

• Black light lamps

• Bug lamps

• Colored lamps

• Infrared lamps

• Marine signal lamps

• Mine service lamps

• Plant light lamps

• Sign service lamps

• Silver bowl lamps

• Showcase lamps

• Traffic signal lamps

• General service incandescent lamps that are:

o A left-hand thread lamp

o A marine lamp

ES-3
o A reflector lamp

o A rough service lamp

o A shatter-resistant lamp (including a shatter-proof lamp and a shatter-protected 

lamp)

o A 3-way incandescent lamp

o A vibration service lamp

o A G shape lamp (as defined in ANSI C78.20) (incorporated by reference; see 

§430.3) and ANSI C79.1-2002 (incorporated by reference; see §430.3) with a 

diameter of 5 inches or more

o A T shape lamp (as defined in ANSI C78.20) (incorporated by reference; see 

§430.3) and ANSI C79.1-2002 (incorporated by reference; see §430.3) and that 

uses not more than 40 watts or has a length of more than 10 inches

o A B, BA, CA, F, G16-1/2, G-25, G30, S, or M-14 lamp (as defined in ANSI 

C79.1-2002) (incorporated by reference; see §430.3) and ANSI C78.20 

(incorporated by reference; see §430.3) of 40 watts or less.

ES.2.2 Market and Technology Assessment

A market and technology assessment characterizes the relevant markets and technology 

options. DOE addresses (1) manufacturer market share and characteristics, (2) existing 

regulatory and non-regulatory initiatives for improving product efficacy, and (3) trends in 

product characteristics and retail markets. This information provides data and resource material 

throughout the analysis.

In its market assessment, which is described in chapter 3 of this TSD, DOE qualitatively 

and quantitatively characterizes the structure of the GSL market. DOE reviewed existing 

literature and spoke with manufacturers to gain an understanding of the GSL industry in the 

United States. Industry publications (e.g., manufacturer catalogs, trade journals), government 

agencies, and trade organizations provided the bulk of the information. Using this information, 

DOE assessed the overall state of the industry, GSL manufacturing and market shares, shipments 

by lamp type, general technical information on GSLs, and industry trends.

The technology assessment centers on understanding how energy is used by the product, 

and what changes are possible that would reduce energy consumption. Measures that improve 

the energy efficiency of the products are called technology options, and they are based on 

existing technologies, as well as working prototypes. DOE develops a list of technology options,

which are then considered against four screening criteria discussed in the following section. 

Those technology options that pass the four screening criteria are called design options and will 

be considered as ways to improve the efficacy of the products in the engineering analysis and 

will assist DOE in determining the maximum technologically feasible design. 

DOE reviewed manufacturer catalogs, recent trade publications, technical journals, and 

patent filings to determine technology options. In chapter 3 of this TSD, DOE presents the 

technology options and applicable lamp types that DOE has preliminarily identified to improve 

the efficacy of general service lamps.

ES-4
DOE generally divides covered products into product classes by the type of energy used, 

capacity, or other performance-related features that affect efficacy. Different energy conservation 

standards may apply to different product classes. (42 U.S.C. 6295(q)) In this preliminary 

analysis, DOE is considering ballast location and lumen package as product class setting factors 

for GSLs. DOE is considering establishing the three product classes shown in Table ES.2.1. See 

chapter 3 of this TSD for further discussion.

Table ES.2.1 Product Classes for GSLs

Lamp Type Lumen Output

Integrated GSLs (e.g., self-ballasted CFL, 

integrated LED lamp)

310-1,999

2,000-2,600

Non-Integrated GSLs (e.g., externally ballasted 

CFL) 310-2,600

ES.2.3 Screening Analysis

DOE developed technology options for enhancing efficacy of lamps used in GSLs in the 

technology assessment. In consultation with interested parties, DOE reviewed the options to 

assess whether the options are technologically feasible; practicable to manufacture, install, and 

service; would adversely impact product utility or availability; or would have adverse impacts on 

health and safety. See chapter 4 of this TSD for details.

ES.2.4 Engineering Analysis

In the engineering analysis, DOE chose certain product classes as representative and 

concentrated its analytical effort on those classes. Generally, DOE selected representative 

product classes based on the highest shipment volumes, although it also considered unique 

performance characteristics as appropriate. DOE then chose appropriate baseline models and

identified more efficacious replacements. A baseline model is typically the most common, least 

efficacious product sold in a given product class. See chapter 5 of this TSD for details. Candidate 

standard levels (CSLs) were developed using catalog data and were analyzed against publicly 

available compliance and testing verification databases when available.

DOE is considering an equation-based standard for efficacy that varies based on lumen 

output. DOE is considering the following equation form to develop CSLs for the integrated 

GSLs product classes:

EEEEEEEEEEEEEEEE = AA − 29.42 ∗ 0.9983LLLLLLLLLLLL

Equation ES.2.1

Where:

Efficacy = minimum efficacy requirement,

Lumens = measured lumen output, and

A = an adjustment variable defined for each CSL.

ES-5
DOE is considering the following equation form to develop CSLs for the non-integrated 

GSLs product class:

EEEEEEEEEEEEEEEE = AA − 25.00 ∗ 0.9989LLLLLLLLLLLL

Equation ES.2.2

Where:

Efficacy = minimum efficacy requirement,

Lumens = measured lumen output, and

A = an adjustment variable defined for each CSL.

Table ES.2.2 presents the CSLs identified in the engineering analysis for the integrated 

and non-integrated product classes.

Table ES.2.2 Candidate Standard Levels for GSL Representative Product Classes

Representative Product Class Candidate Standard Level Efficacy

lm/W

Integrated Low Lumen

(310 – 1,999 lumens)

Baseline (<15 W)* 45 lm/W

CSL 1 67.6-29.42*0.9983^Lumens

CSL 2 74.2-29.42*0.9983^Lumens

CSL 3 80.2-29.42*0.9983^Lumens

CSL 4 87.5-29.42*0.9983^Lumens

CSL 5 90.8-29.42*0.9983^Lumens

Integrated High Lumen

(2,000 – 2,600 lumens)

Baseline (≥15 W)** 60 lm/W

CSL 1 67.6-29.42*0.9983^Lumens

CSL 2 74.2-29.42*0.9983^Lumens

Non-Integrated

(310 – 2,600 lumens)

Baseline† 45 lm/W

CSL 1 72.6-25.00*0.9989^Lumens

* Baseline corresponds to the highest existing standard for medium base CFLs with wattage less than 15 W.

** Baseline corresponds to the highest existing standard for medium base CFLs with wattage greater than or equal 

to 15 W.

† Baseline corresponds to the backstop requirement of 45 lumens per watt for GSLs because no existing standards 

apply for the non-integrated product class. (See 42 U.S.C. 6295(i)(6)(A)(ii) and (i)(6)(A)(v))

ES.2.5 Product Price Determination

For this rulemaking, DOE estimated the end-user price of GSLs directly, rather than 

develop manufacturer selling prices (MSPs) from a bill of materials and manufacturer markup 

analysis. DOE selected this methodology because it is difficult to reverse-engineer GSLs, which 

are not easily disassembled.

Because blue book price data were not available for all GSLs, DOE was unable to utilize 

blue book prices to develop end-user prices in the preliminary analysis. Therefore, DOE 

reviewed and used publicly available retail prices for GSLs to develop end-user prices for each 

CSL. In its review of price data, DOE observed a range of end-user prices paid for a lamp, 

depending on the distribution channel through which the lamp is purchased. DOE identified four 

main distribution channels (large consumer-based distributors [e.g., home centers], small 

consumer-based distributors [e.g., drug stores], electrical distributors, and state procurement). 

ES-6
DOE then developed an average weighted end-user price using estimated percentage of 

shipments that go through each distribution channel obtained in interviews with manufacturers. 

Additionally, DOE assessed and accounted for the general price trends in relation to efficacy for 

all GSLs. Once DOE calculates end-user prices, DOE adds sales tax and, if appropriate, 

installation costs to derive the total, installed end-user cost. See chapter 6 of this TSD for details.

ES.2.6 Energy Use Analysis

The purpose of the energy use analysis is to determine the annual energy consumption of 

GSLs and to assess the energy savings potential of increased lamp efficiency. The energy use 

analysis provides the basis for developing the energy savings used in the life-cycle cost (LCC)

analysis and subsequent analyses. DOE’s test procedures provide standardized results that can 

serve as the basis for comparing the performance of different products used under the same 

conditions, but actual usage in the field may differ from usage estimated by the test procedure.

To determine the energy use for GSLs in residential and commercial installations, DOE 

combined information on power consumption of the representative lamps from the engineering 

analysis (chapter 5 of this TSD) with information on operating hours of those lamp types. For the 

residential sector, DOE used metered data of daily hours of use for regions where the data were 

available; for all other regions, DOE used daily hours of use values based on the metered data 

from adjacent regions. For the commercial sector, DOE used average daily hours of use data 

from a survey of commercial lighting energy use. For both the residential and commercial 

sectors, DOE included the impact of lighting controls, such as dimmers, timers, or occupancy 

sensors (hereafter referred to simply as “controls”), in the energy use calculation for the fraction 

of GSLs installed in locations with controls. To illustrate the impact that controls have on energy 

use, Chapter 7 also provides energy use results assuming that no GSLs are used with controls.

Table ES.2.3, Table ES.2.4, and Table ES.2.5 show the average annual energy use of 

GSLs in each of the product classes at each CSL that DOE considered in this rulemaking and the 

annual energy savings with respect to the baseline (CSL 0). All values are in units of kilowatthours (kWh) per year. Chapter 7 provides more details on the methods, data sources, and 

assumptions used for the energy use analysis.

Table ES.2.3 Average Annual Energy Use and Savings per Unit for Integrated Low 

Lumen (< 2,000 lm) GSLs

CSL

Residential Commercial

Energy Use

(kWh/yr)

Savings

(kWh/yr)

Energy Use

(kWh/yr)

Savings

(kWh/yr)

0 11.6 0.0 46.3 0.0

1 10.8 0.8 43.0 3.3

2 8.9 2.7 39.7 6.6

3 8.2 3.4 36.4 9.9

4 7.4 4.2 33.1 13.2

5 7.1 4.6 31.4 14.9

ES-7
Table ES.2.4 Average Annual Energy Use and Savings per Unit for Integrated High 

Lumen (≥ 2,000 lm) GSLs

CSL

Residential Commercial

Energy Use

(kWh/yr)

Savings

(kWh/yr)

Energy Use

(kWh/yr)

Savings

(kWh/yr)

0 26.6 0 106.0 0.0

1 24.9 1.7 99.2 6.6

2 24.1 2.5 95.9 9.9

Table ES.2.5 Average Annual Energy Use and Savings per Unit for Non-Integrated 

GSLs

CSL

Residential Commercial

Energy Use

(kWh/yr)

Savings

(kWh/yr)

Energy Use

(kWh/yr)

Savings

(kWh/yr)

0 24.9 0 99.2 0.0

1

24.9 0 99.2 0.0

20.3 4.6 80.7 18.4

ES.2.7 Life-Cycle Cost and Payback Period Analyses

The impacts of energy conservation standards on consumers often include a change in 

operating expense (usually decreased energy expenses) and a change in purchase price (usually 

increased). The LCC of a product is the cost it incurs over its lifetime, taking into account both 

purchase price and operating expenses. The payback period (PBP) represents the time it takes to 

recover the additional installed cost of the more-efficient products through operating expense 

savings. 

DOE analyzed the net effect on consumers by calculating the LCC and PBP using inputs 

from the engineering performance data, the product price determination, and the energy use and 

shipments analyses. Inputs to the LCC calculation include the installed cost to the consumer, 

operating expenses, lifetime of the product, discount rates. In addition, it uses base case and 

standards case efficiency distributions derived in the shipments analysis using a consumer choice 

model. 

For the integrated low-lumen product class (the only product class that includes LEDs), 

the LCC and PBP analysis samples GSLs from four lumen bins according to their market 

distribution, because of the high variability in LED prices across lumen ranges. The prices and 

efficacies from the 60 W-equivalent lamps in the engineering analysis results were used to 

project prices and efficacies for the other lumen bins using online retailer data and the efficacyto-lumen relationship developed in the engineering analysis.

ES-8
DOE accounted for variability in operating hours in the residential sector by generating 

distributions for daily hours of use derived from a residential metering study. For the commercial 

sector, DOE developed triangular daily hours of use distributions corresponding to ±20 percent

of the average daily hours of use derived in the energy use analysis. Lamp lifetime was based on 

the sampled hours of use, considering the lamp's rated lifetime, renovation/retrofit rates, and the 

effects of on-cycle length on CFL lifetimes. To account for differences in the lifetime of lamps at 

different efficiency levels, DOE incorporated a residual value in the LCC calculation. Chapter 8 

of this TSD provides a detailed description of the LCC and PBP inputs, analysis, and results.

Table ES.2.6 shows the base case efficiency distribution used for each product class in 

the compliance year.

Table ES.2.6 Market Share of each Candidate Standard Level in the Base Case

Residential Commercial

CSL

Integrated

NonIntegrated

Integrated

NonIntegrated

Low 

Lumen

(< 2,000 lm)

High 

Lumen

(≥ 2,000 lm)

Low Lumen

(< 2,000 lm)

High 

Lumen

(≥ 2,000 lm)

0 1.1% 21.4% 65.4% 0.1% 21.4% 65.4%

1 48.5% 31.8%

30.5%

53.8% 31.8%

30.5%

4.1% 4.1%

2 0.5% 46.8% 0.0% 46.8%

3 1.7% 0.1%

4 21.0% 17.5%

5 27.1% 28.4%

Table ES.2.7 through Table ES.2.12 present the key findings from the analyses. These 

findings include, for the compliance year: (1) the average LCC of each CSL, (2) the average PBP 

relative to the baseline product (CSL 0), (3) average LCC savings that result from a standard set 

at a given CSL, based on the base-case and standards-case efficiency distributions, and (4) the 

share of consumers that would experience a net cost (i.e., negative LCC savings). Because the 

lighting market is in the process of undergoing significant transformation, DOE also calculated 

LCC results for 2025, five years after the compliance year. Details and results of this calculation 

can be found in Chapter 8 of this TSD.a

a Chapter 8 also provides LCC savings estimates relative to the base case efficiency distribution for a “roll-up” 

scenario, in which all consumers who purchased a lamp in the base case that is less efficient than the minimum 

allowable efficiency in the standards case purchase the least efficient lamp available in the standards case.

ES-9

 
Table ES.2.7 LCC and PBP Results by Efficiency Level for Integrated Low Lumen 

(< 2,000 lm) GSLs

CSL

Average Costs

(2014$) Simple 

Payback

(years)

Average 

Lifetime

(years) Installed Cost

First Year’s 

Operating 

Cost

Lifetime 

Operating 

Cost

LCC

Residential Sector

0 6.2 1.6 5.6 11.8 --- 8.8

1 4.0 1.5 5.2 8.8 0 9.8

2 34.9 1.3 4.6 23.1 99.6 17.9

3 22.2 1.2 4.2 16.0 40.5 17.9

4 7.5 1.1 3.8 8.5 2.6 17.9

5 7.2 1.0 3.6 8.1 1.7 17.9

Commercial Sector

0 7.0 6.9 17.7 24.8 --- 2.2

1 4.4 6.4 16.5 20.2 0 2.8

2 45.7 6.0 15.3 37.9 40.0 6.3

3 29.1 5.5 14.0 28.4 15.3 6.3

4 7.7 5.0 12.8 17.2 0.4 6.3

5 7.3 4.8 12.2 16.4 0.2 6.3

Note: The LCC results for each CSL are calculated assuming that all consumers use products with that efficiency 

level. The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include 

residual value and disposal cost. The PBP is measured relative to the baseline product.

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Table ES.2.8 Average LCC Savings for Integrated Low Lumen (< 2,000 lm) GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 0% 0.0

2 27% -0.1

3 27% 0.0

4 25% 0.3

5 22% 0.5

Commercial Sector

0 0.0% 0.0

1 0.0% 0.0

2 1.1% 1.7

3 1.1% 1.7

4 0.8% 1.7

5 0.3% 2.1

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

Table ES.2.9 LCC and PBP Results by CSL for Integrated High Lumen (≥ 2,000 lm) 

GSLs

CSL

Average Costs

(2014$) Simple 

Payback

(years)

Average 

Lifetime

(years) Installed Cost

First Year’s 

Operating 

Cost

Lifetime 

Operating 

Cost

LCC

Residential Sector

0 9.7 3.6 12.8 22.5 --- 8.8

1 10.1 3.4 12.0 22.1 1.5 8.8

2 10.8 3.3 11.6 21.3 3.1 9.8

Commercial Sector

0 9.7 12.4 31.6 41.5 --- 2.2

1 10.1 11.6 29.7 39.8 0.4 2.2

2 10.8 11.2 28.7 37.6 0.9 2.8

Note: The LCC results for each CSL are calculated assuming that all consumers use products with that efficiency 

level. The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include 

residual value and disposal cost. The PBP is measured relative to the baseline product.

ES-11
Table ES.2.10 Average LCC Savings for Integrated High Lumen (≥ 2,000 lm) GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 6% 0.2

2 13% 0.5

Commercial Sector

0 0.0% 0.0

1 0.2% 0.5

2 1.2% 1.7

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

Table ES.2.11 LCC and PBP Results by CSL for Non-Integrated GSLs

CSL

Average Costs

2014$ Simple 

Payback

(years)

Average 

Lifetime

(years) Installed Cost

First Year’s 

Operating 

Cost

Lifetime 

Operating 

Cost

LCC

Residential Sector

0 13.2 3.4 11.9 25.2 --- 8.8

1

14.2 3.4 11.9 22.8 N/A 11.6

15.7 2.8 9.7 21.1 4.0 12.5

Commercial Sector

0 13.2 11.6 29.6 42.9 --- 2.2

1

14.2 11.6 29.6 39.0 N/A 4.1

15.7 9.4 24.1 33.3 1.2 5.0

Note: The LCC results for each CSL are calculated assuming that all consumers use products with that efficiency 

level. The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include 

residual value and disposal cost. The PBP is measured relative to the baseline product.

ES-12
Table ES.2.12 Average LCC Savings for Non-Integrated GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 12% 1.6

Commercial Sector

0 0.0% 0.0

1 5.4% 2.6

Note: The results for each CSL represent the impact a standard set at that CSL, based on base 

case and standards case efficiency distributions calculated in Chapter 9 of this TSD. 

ES.2.8 Shipments Analysis

Shipments projections are used to calculate the national impacts of standards on energy 

use, net present value (NPV), and future manufacturer cash flows. The shipments model has 

three main interacting elements: (1) a lamp demand module, which estimates total shipments of 

GSLs for each year of the analysis period; (2) a price learning module, which projects future 

prices based on historic price trends; and (3) a consumer choice module, which assigns 

shipments to product classes and efficacy levels based on sector-specific consumer sensitivities 

to lamp price, energy consumption, lifetime, and mercury content. Details of the model DOE 

used to estimate shipments in this rulemaking, including the consumer-choice model, are 

described in chapter 9 of this TSD.

For the reference scenario, which reflects DOE’s best estimate of all variables, DOE 

estimated that integral LED luminaires would grow into the market for traditional GSL 

luminaires according to a Bass diffusion curve, resulting in the displacement of 15 percent of the 

market for traditional GSL luminaires at the end of the analysis period. To determine GSL price 

trends, DOE used a learning curve approach, in which the learning rate is defined as the 

percentage drop in price with each doubling in cumulative production. DOE estimated that LED 

GSLs will experience learning at the historic CFL-GSL learning rate during the analysis period, 

for reasons detailed in Appendix 9A of this TSD. The reference scenario assumes that rare earth 

oxide prices remain constant at their current price. Lamp lifetime distributions in the reference 

scenario were developed from the rated lifetimes of lamps, considering sector-specific hours of 

use distributions, renovation/retrofit rates, and the effects of on-cycle length on CFL lifetimes.

DOE also developed alternative shipments scenarios in addition to the reference scenario, 

to reflect uncertainties in certain parameters and to determine the impact of key variables on the 

rulemaking. DOE analyzed a scenario in which there was no incursion of integral LEDs by the 

end of the analysis period, and a scenario in which 50 percent of the market for traditional GSL 

luminaires was displaced at the end of the analysis period. To capture uncertainty in the rate of 

price decline for LED-GSLs, DOE analyzed two additional scenarios: a scenario where LED 

GSLs decline in price at the historic LED-GSL learning rate, and a scenario where LED and CFL 

GSL prices remain constant throughout the analysis period. Given the uncertainty in the future 

ES-13
trajectory of rare earth oxide prices, DOE also analyzed a scenario in which rare earth oxide 

prices are significantly higher. Additionally, DOE analyzed two alternative lifetime scenarios: 

one in which lamp lifetime was based only on a lamp's rated lifetime and the effects of on-cycle 

length on CFL lifetimes, without consideration of renovations or retrofits, and another in which 

LED GSLs were treated like consumer electronics devices and retired much sooner than their 

rated lifetime. Alternative scenarios are discussed in more detail in appendix 8B and Chapter 9 of 

this TSD. 

Figure ES.2.1 shows the projected total (i.e., residential and commercial) base case 

shipments by technology type for integrated low lumen GSLs over the analysis period. There is a 

spike in shipments in 2020 as a result of the backstop prescribed by amendments to EPCA in the 

Energy Independence and Security Act of 2007 (EISA 2007). Because GSILs are not included in 

the scope of this rulemaking, DOE assumed that a potential GSL final rule would not yield 

sufficient energy savings to avoid triggering the EISA 2007 backstop. Therefore, DOE assumed

that the EISA 2007 backstop will go into effect concurrently with a potential GSL standard at the 

compliance date of this rulemaking. (See 42 U.S.C. 6295(i)(6)(A)(ii) and (i)(6)(A)(v))

Figure ES.2.1 Projected Total Base Case Shipments by Technology Type for Integrated 

Low Lumen GSLs (< 2,000 lm)

Figure ES.2.2, Figure ES.2.3, and Figure ES.2.4 show projected total shipments by 

candidate standard case for integrated low lumen GSLs, integrated high lumen GSLs, and nonintegrated GSLs, respectively, over the analysis period.

ES-14
Figure ES.2.2 Projected Total Shipments by Candidate Standard Case for Integrated 

Low Lumen GSLs (< 2,000 lm)

Note: In some cases, the change in shipments between a candidate standards case and the base case or between two 

candidate standards cases is so small that it is indistinguishable on the figure. In these cases, the higher standard 

level overwrites the lower.

Figure ES.2.3 Projected Total Shipments by Candidate Standard Case for Integrated 

High Lumen GSLs (≥ 2,000 lm)

ES-15
Figure ES.2.4 Projected Total Shipments by Candidate Standard Case for NonIntegrated GSLs

ES.2.9 National Impact Analysis

The national impact analysis (NIA) estimates the following national impacts from 

possible efficiency levels for GSLs: (1) national energy savings; (2) monetary value of the 

energy savings due to standards; (3) increased total installed costs of the considered products due 

to standards; and (4) the NPV of the difference between the value of energy savings and 

increased total installed costs. DOE prepared a spreadsheet model to estimate energy savings and 

national consumer economic costs and savings resulting from potential standards. In contrast to 

the LCC and PBP analyses, which use probability distributions for the inputs, the NIA uses 

average or typical values for inputs. 

A key component of DOE’s estimates of national energy savings (NES) and NPV is the 

trend in energy efficiency projected for the base case (without new standards) and each of the 

standards cases (with new standards). DOE developed a consumer-choice model to estimate the 

base-case efficiency distribution based on consumer sensitivity to lamp price, energy 

consumption, lifetime, and mercury content. For its determination of standards-case efficiency 

distributions, DOE recalculated market shares for efficiency levels using only those efficiency 

levels that meet or exceed a standard in the year a standard comes into effect and subsequent 

years.

Several alternative scenarios were analyzed by DOE in the NIA, including alternative 

scenarios for electricity price projections, the fraction of LED shipments that operate in standby 

mode, the fraction of GSL shipments with controls in the commercial sector, and rebound effect. 

DOE assumed no rebound effect in the reference scenario. Chapter 10 of this TSD provides 

additional details on these scenarios and other aspects of the NIA analysis.

ES-16
ES.2.9.1 National Energy Savings

DOE calculated annual NES as the difference between national energy consumption in 

the base case (without new efficiency standards) and under each CSL. Cumulative energy 

savings are the sum of the annual NES over the period in which products shipped in 2020-2049 

are in operation. The NES results shown in Table ES.2.13 are expressed as full-fuel cycle energy 

savings in quads (quadrillion Btu).

Table ES.2.13 Estimates of Cumulative Full-Fuel Cycle National Energy Savings 

(quads) 

CSL

Integrated

Low Lumen Non-Integrated

(< 2,000 lm)

High Lumen

(≥ 2,000 lm)

1 0.00 0.01 0.00

2 0.34 0.02

3 0.34

4 0.35

5 0.47

ES.2.9.1 Net Present Value of Consumer Benefits

DOE calculated net monetary savings in each year as the difference between total savings 

in operating costs and increases in total equipment costs in the base case and standards cases. 

DOE calculated savings over the life of the products purchased in the forecast period. The NPV 

is the difference between the present value of operating cost savings and the present value of 

increased total installed costs. DOE used discount rates of 7 percent and 3 percent to discount 

future costs and savings to the present. The NPV results are shown in Table ES.2.14 and Table 

ES.2.15.

Table ES.2.14 Cumulative Net Present Value of Consumer Benefits at 3% in billion 

2014$

E

L

Integrated

Low Lumen Non-Integrated

(< 2,000 lm)

High Lumen

(≥ 2,000 lm)

1 0.02 0.04 1.95

2 1.21 0.09

3 1.44

4 1.90

5 2.52

ES-17
Table ES.2.15 Cumulative Net Present Value of Consumer Benefits at 7% in billion 

2014$

E

L

Integrated

Low Lumen Non-Integrated

(< 2,000 lm)

High Lumen

(≥ 2,000 lm)

1 0.02 0.02 0.96

2 0.54 0.04

3 0.67

4 0.96

5 1.28

ES.2.10 Preliminary Manufacturer Impact Analysis

The manufacturer impact analysis (MIA) assesses the potential impacts of energy 

conservation standards on manufacturers, including effects on expenditures for capital 

conversion, marketing costs, shipments, and research and development costs. Impacts to direct 

employment are also addressed in the MIA. Potential impacts might lead to changes in 

manufacturing practices for GSLs. DOE identified potential impacts through interviews with 

manufacturers and other interested parties. See chapter 12 of this TSD for details.

ES.2.11 Other Analyses

The remaining chapters of this preliminary TSD address the following analyses, which will be 

performed for any NOPR issued for GSLs:

• The consumer subgroup analysis evaluates the effects of energy conservation standards 

on various consumer subgroups (chapter 11).

• The emissions analysis examines the effects of energy conservation standards on various 

airborne emissions (chapter 13).

• The monetization of emissions analysis estimates the economic impacts of reduced 

emissions as a result of energy conservation standards (chapter 14).

• The utility impact analysis examines impacts of energy conservation standards on the 

generation capacity of electric utilities (chapter 15).

• The employment impact analysis examines the indirect effects of energy conservation 

standards on national employment (chapter 16).

• The regulatory impact analysis examines the national impacts of non-regulatory 

alternatives to mandatory energy conservation standards (chapter 17).

ES-18
ES.3 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT

DOE is interested in receiving comment on all aspects of this preliminary analysis. DOE 

especially invites comment or data to improve DOE’s analyses, including information that will 

respond to the following questions and concerns raised in the development of this preliminary 

TSD.

ES.3.1 GSL Definitions

DOE developed definitions for several terms in support of the scope of the rulemaking. 

DOE requests comment on the definitions under consideration including “integrated lamp,”

“non-integrated lamp,” “general service LED lamp,” “OLED lamp,” “colored lamp,” “reflector 

lamp,” “non-reflector lamp,” “light fixture,” “pin base lamp,” and “GU24 base.”

ES.3.2 Specialty Application MBCFLs and LED Lamps

DOE identified MBCFLs and LED lamps that are designed for specialty applications and 

are not able to provide overall illumination including: black light lamps, bug lamps, colored 

lamps, plant light lamps, and silver bowl lamps. DOE is considering providing exemptions for 

these specialty applications. DOE requests comment on the MBCFLs identified for specialty 

applications that cannot provide overall illumination and if there are other MBCFLs that should 

be considered. DOE requests comment on the LED lamps identified for specialty applications 

that cannot provide overall illumination and if there are other LED lamps that should be 

considered.

ES.3.3 GSL Exemptions

DOE assessed the full list of exemptions that apply to GSILs to determine if the lamp 

types provide overall illumination and therefore can be used in general lighting applications. Of 

the exemptions provided for GSILs, DOE has preliminarily determined that appliance lamps, 

black lights, bug lamps, colored lamps, infrared lamps, marine signal lamps, mine service lamps, 

plant lights, sign service lamps, silver bowl lamps, showcase lamps, and traffic signal lamps 

cannot provide overall illumination and therefore cannot be used in general lighting applications. 

DOE is considering not establishing standards for these lamp types under the GSL rulemaking 

because the lamps are intended for use in non-general applications. DOE requests comment on 

the exemptions that DOE is considering providing for GSLs based on its assessment that the 

lamp types are intended for non-general applications.

DOE has preliminarily determined that 3-way lamps, vibration service lamps, rough 

service lamps, and shatter-resistant lamps are able to provide overall illumination and therefore 

can be used in general lighting applications. For these reasons, DOE believes that 3-way lamps, 

vibration service lamps, rough service lamps, and shatter-resistant lamps are general service 

lamps and do not require an exemption from standards. DOE requests comment on this decision.

ES-19
ES.3.4 OLED Lamps

DOE requests comment on its consideration to continue to not establish standards for

OLED lamps in this rulemaking.

ES.3.5 Lamps Addressed in Other Rulemakings

DOE has the authority to consider additional lamp types that it determines are used to 

satisfy lighting applications traditionally served by GSILs. To limit the probability that one lamp 

type might be subject to two different standards, DOE is not considering including self-ballasted 

mercury vapor lamps in the scope of this rulemaking. DOE requests comment on its 

consideration to exclude from the scope of the GSL rulemaking lamps that are addressed in other 

rulemakings. 

ES.3.6 Other Integrated Lamps

DOE does not believe that LED technology is currently able to provide the same utility as 

halogen technology in the MR16 lamp shape. Because more efficient replacements that maintain 

the same utility are not currently available, DOE has tentatively decided to not establish energy 

conservation standards for reflector pin base integrated lamps at this time. DOE requests 

comment on whether LED MR16 lamps are suitable replacements for incandescent/halogen 

reflector integrated MR16 lamps.

DOE also requests comment on whether there are any integrated lamps with other bases 

than screw bases that have a significant market share.

ES.3.7 Other Non-Integrated Lamps 

Due to low market share and to avoid stifling innovation with LED non-reflector pin base 

non-integrated lamps, DOE is not considering establishing standards for these products. DOE 

requests comment on the market share and technological feasibility of increasing the efficacy of 

non-reflector pin base non-integrated lamps.

DOE identified screw base and pin base non-integrated lamps that meet the definition of 

GSL. DOE requests comment on whether there are any non-integrated lamps with other bases 

that meet the definition of GSL and the market share of these lamps.

ES.3.8 MBCFL Metrics

DOE has the authority to revise the existing metrics and consider additional metrics for 

MBCFLs in this rulemaking and requests comment on several topics related to this. Regarding 

metrics that DOE is not considering revising, DOE requests comment on maintaining the current 

lumen maintenance requirements. Regarding metrics that DOE is considering revising, DOE 

requests comment on the rapid cycle stress performance of commercially available MBCFLs and 

the appropriateness of requiring an increased lifetime of 10,000 hours for MBCFLs. Regarding 

metrics that DOE is considering adding, DOE requests comment on adding a requirement for 

ES-20
power factor and its consideration of a standard for power factor of 0.5 or greater; CRI and its 

consideration of a standard for CRI of 80 or greater; and the start time of MBCFLs and its 

consideration to require a start time of within one second of the application of electrical power. 

Regarding metrics that DOE is not considering adding, DOE requests comment on the 

consideration to not set a separate requirement for THD; the consideration to not set a CCT 

requirement for MBCFLs; and the consideration to not set requirements for operating frequency. 

ES.3.9 GSL Technology Options

DOE requests comment on the technology options under consideration for GSLs. 

Specifically, DOE also requests comment on the addition of reduced current density as a 

technology option. 

ES.3.10 GSL Product Classes

DOE is considering establishing three product classes for this rulemaking. DOE 

welcomes comments on the product class divisions it is considering for GSLs in this preliminary 

analysis. Further, DOE specifically requests comments on a product class division based on 

lumen package for the integrated GSLs. DOE also requests comments on its preliminary 

determination that energy consumed in standby mode will be negligible and therefore a product 

class division based on standby mode operation for integrated GSLs is not warranted.

ES.3.11 GSL Design Options

DOE requests comments on the design options it is considering for GSLs.

ES.3.12 GSL Data Approach

DOE welcomes comment on the data approach including any additional databases that

should be considered.

ES.3.13 GSL Baseline Selection

DOE is directly analyzing all product classes and has selected one baseline lamp for each 

product class. DOE requests comment on its analysis of one baseline lamp for each product 

class. DOE also requests comment on the baseline units selected for each product class. 

ES.3.14 More Efficacious Substitutes

DOE requests comment on the criteria used in selecting more efficacious substitute lamps 

in the integrated product class, as well as the characteristics of the lamps selected. In particular, 

DOE requests comment on its assumptions that more efficacious substitutes must have lumen 

output within 10 percent of the baseline lamp and must be omnidirectional light sources.

Similarly, DOE requests comment on the criteria used in selecting more efficacious 

substitute lamps in the non-integrated product class, as well as the characteristics of the lamps 

ES-21
selected. In particular, DOE requests comment on its assumptions that more efficacious 

substitutes must have lumen output within 10 percent of the baseline lamp-and-ballast system. 

DOE also requests comment on its assumption that the base type of the baseline lamp in the nonintegrated product class must be maintained for more efficacious substitutes.

ES.3.15 Non-Integrated Ballast Pairing

DOE pairs non-integrated GSLs with representative ballasts because the non-integrated 

GSLs analyzed in this preliminary analysis operate on a ballast in practice. DOE requests 

comment on the lamp-and-ballast systems selected for the non-integrated product class.

ES.3.16 Candidate Standard Levels

DOE requests comment on the CSLs under consideration for the integrated and nonintegrated product classes, including the max tech levels.

ES.3.17 CSL Equation Methodology

DOE requests comment on the methodology used to develop the CSLs equations. In 

particular, DOE requests comment on the use of a lumens-based equation and the equation form 

itself. 

ES.3.18 Non-Integrated GSL Replacement Assumptions

DOE found that the fixtures frequently used with the non-integrated GSLs analyzed were 

available in configurations for several different lamp types, and therefore assumed that fixture 

compatibility would not be an issue for the vast majority of consumers. DOE requests comment 

on its assumption that fixture compatibility would not be a common issue for non-integrated 

GSL replacements.

DOE evaluated the impacts of CSL 1 on the individual base types in the non-integrated 

product class. DOE confirmed that the vast majority of base types were still available at CSL 1, 

and therefore consumers will not be forced to switch between lamps with differing base types. 

DOE also requests comment on its assumption that consumer utility will not be lost with the base 

types that remain at CSL 1.

ES.3.19 Product Price Determination

DOE invites comment on the methodology and results for estimating end-user prices for 

GSLs in this preliminary analysis. DOE also requests comment on the appropriateness of the 

distribution channels and estimated percentage shipments through each channel used in this 

preliminary analysis.

ES-22
ES.3.20 GSL Hours of Use

DOE requests comment on the data and methodology used to estimate operating hours 

for GSLs, particularly in the residential sector. Also, DOE seeks comment on its assumption that 

GSL operating hours will not vary by light source technology during the analysis period.

ES.3.21 EISA 2007 Backstop Criteria

DOE requests any data suggesting that the EISA 2007 backstop criteria will not be met.

ES.3.22 Fraction of Dimmable GSLs in the Residential Sector

For the residential sector, DOE estimated that at the compliance year five percent of CFL 

GSLs will be dimmable based on manufacturer interviews, whereas no such limit was placed on 

LED GSLs (though they may not be installed in fixtures that employ dimmers). DOE requests 

comment on this approach.

ES.3.23 Energy Savings from Lighting Controls

For this preliminary analysis, DOE estimated 30 percent energy savings for any GSL 

operated with lighting controls, including dimmers and controls integrated into smart LED 

lamps. DOE requests data and information to help compare the energy use implications of using 

dimmers as opposed to other lighting controls.

ES.3.24 Integrated Low Lumen GSL Market Distribution Estimates

DOE seeks comment on the market distribution estimates for the four lumen ranges 

analyzed as part of the integrated low lumen product class.

ES.3.25 Consumer Purchases in Standards Case Analyses

In each of the 10,000 sampled purchases used to determine the average LCC savings, 

DOE assumes that in the standards case consumers purchase lamps that are at least as efficient as 

the ones they would purchase in the absence of standards. DOE seeks comment on this 

assumption.

ES.3.26 Commercial Hours of Use Variability

DOE invites comments and data on its approach to account for variability in hours of use 

in the commercial sector.

ES.3.27 GSL Service Life Scenarios

DOE is analyzing three GSL service life scenarios in its analyses. DOE invites comment 

on the lifetime scenarios considered in the LCC, PBP, and subsequent analyses.

ES-23
ES.3.28 Lifetime Distribution Modeling

DOE invites comments and data on the assumptions and methodology used to calculate 

GSL survival probabilities as a function of GSL age.

ES.3.29 Installation Costs

For this preliminary analysis, DOE assumed that the installation costs for GSLs are 

identical for all CSLs and product classes in the residential sector as well as the commercial 

sector (though they may differ by sector). Therefore, DOE did not include installation costs. 

DOE welcomes comment on this approach.

ES.3.30 LCC and Consumer Impacts from Potential Standards

For a potential standard at each CSL, DOE presents the resulting average LCC savings 

and the percent of consumers affected by the standard using the base-case and standards-case 

efficiency distributions calculated in the shipments analysis. DOE seeks comment on this 

approach.

ES.3.31 GSL Disposal Costs

DOE requests comment and relevant data on the disposal cost assumptions used in its 

analyses.

ES.3.32 LCC and PBP Methodologies

DOE requests comment on the overall methodology and results of the LCC and PBP 

analyses.

ES.3.33 GSL Shipments Data

DOE requests any representative data on GSL shipments as they become available in 

order to improve the accuracy of the shipments analysis.

ES.3.34 Residential Integrated High Lumen GSLs

DOE requests comment on its assumption that approximately 3 percent of all residentialsector GSLs with integrated ballasts or drivers are brighter than 2,000 lumens.

ES.3.35 Integrated LED Fixture Penetration

DOE assumed that integrated LED fixtures will capture 0 percent, 15 percent, and 50 

percent of the fixture market by 2049 in the low-penetration, reference, and high-penetration 

scenarios, respectively. DOE invites comment and data on these scenarios.

ES-24
ES.3.36 Non-Integrated CFL GSLs

DOE assumed that non-integrated CFL GSLs will remain a constant fraction of the 

installed GSL stock in the commercial sector, after accounting for the incursion from integrated 

LED fixtures into the commercial building stock. DOE seeks comment and data on this 

assumption.

ES.3.37 Rare Earth Price Scenarios

DOE invites comment on the two rare earth materials price scenarios considered in its 

analyses.

ES.3.38 Electricity Price Scenarios

DOE invites comment on the electricity price projection scenarios considered in its 

analyses.

ES.3.39 LED Learning Rate Scenarios

In its reference scenario for this preliminary analysis, DOE assumed that the LED GSL 

learning rate will slow in the near future to equal the historical learning rate for CFL GSLs. In an 

alternative scenario, DOE assumed that the LED GSL learning rate will remain at the faster 

value observed in recent years. DOE invites comment on these scenarios.

ES.3.40 Incremental Price of Brighter LED GSLs

DOE is assuming that both the price of LED GSLs and the incremental price of brighter 

LED GSLs are falling. DOE requests comment and data on this assumption.

ES.3.41 Pre-Compliance Year Shift Away from Incandescent GSLs

DOE assumed in its shipments projections that some fraction of the market for GSILs 

shifts to CFL or LED GSLs in each year prior to 2020, with the remainder shifting to CFL or 

LED GSLs in 2020. DOE assumed that the remaining market for GSILs in the commercial sector 

is already negligible, so this shift was assumed to occur entirely within the residential market. 

DOE requests comment and data on this assumption.

ES.3.42 GSL Market Data

DOE requests comment and data on current market shares and market trends for GSLs in 

the commercial sector.

ES.3.43 GSL Rebound Effect Scenarios

DOE analyzed three rebound effect scenarios in the NIA: 1) 0 percent rebound for both 

the residential and commercial sectors (the reference scenario), 2) 8.5 percent rebound and 1 

ES-25
percent rebound for the residential and commercial sectors, respectively, and 3) 15 percent 

rebound for both the residential and commercial sectors. DOE requests data that can be used to 

further refine the rebound effect assumptions used in the NIA.

ES.3.44 Penetration of LED GSLs with Standby Functionality

DOE assumed that residential LED GSLs with standby functionality will represent 0

percent, 50 percent, and 100 percent of residential LED GSLs in the market by 2049 in the lowpenetration, reference, and high-penetration scenarios, respectively. DOE invites comment and 

data on these assumptions.

ES.3.45 Penetration of Commercial GSLs with Controls

DOE analyzed two scenarios to account for the fraction of GSL shipments with controls 

in the commercial sector: 1) The current fraction of GSLs with controls remains constant over 

the analysis period, and 2) The fraction of commercial floor space utilizing various types of 

controls grows from 30 percent today to a projected value of 80 percent by the end of the 

analysis period (the reference scenario). DOE invites comment and data on these scenarios.

ES.3.46 Shipments Analysis and NIA Scenarios

DOE is considering a number of scenarios in its shipments and NIA analyses. DOE asks 

for comment on whether there are other scenarios which should be considered.

ES.3.47 Consumer Subgroup Analysis

DOE welcomes input regarding which, if any, consumer subgroups should be considered 

when developing potential energy conservation standards for GSLs.

ES.3.48 Emissions Analysis

DOE requests comment on its approach to conducting the emissions analysis for GSLs. 

ES.3.49 Monetization of Emissions Reductions Benefits

DOE invites input on the proposed approach for estimating monetary benefits associated 

with emissions reductions. 

ES.3.50 Utility Impact Analysis

DOE seeks comment on the planned approach to conduct the utility impact analysis.

ES.3.51 Employment Impact Analysis

DOE welcomes input on its proposed approach for assessing national employment 

impacts.

ES-26
ES.3.52 Regulatory Impact Analysis

DOE requests any available data or reports that would contribute to the analysis of 

alternatives to standards for GSLs. In particular, DOE seeks information on the effectiveness of 

existing or past efficiency improvement programs for these products.

ES-27
CHAPTER 1. INTRODUCTION

TABLE OF CONTENTS

1.1 PURPOSE OF THE DOCUMENT ................................................................................. 1-1

1.2 OVERVIEW OF THE APPLIANCES AND COMMERCIAL EQUIPMENT 

STANDARDS PROGRAM ......................................................................................................... 1-1

1.3 OVERVIEW OF GSL STANDARDS ............................................................................ 1-2

1.4 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS ................... 1-3

1.5 STRUCTURE OF THE DOCUMENT ............................................................................ 1-5

LIST OF TABLES

Table 1.4.1 Analyses Under the Process Rule ............................................................................. 1-4

1-i 
CHAPTER 1. INTRODUCTION

1.1 PURPOSE OF THE DOCUMENT

This preliminary technical support document (TSD) provides the analytical approaches, 

inputs, and results associated with the U.S. Department of Energy’s (DOE’s) study of energy 

conservation standards for general service lamps (GSLs). The preliminary TSD also serves to 

provide technical detail and is a compendium to the life-cycle cost (LCC) and payback period 

(PBP) and national impact analysis (NIA) spreadsheets that are available on regulations.gov, 

docket number EERE–2013–BT–STD–0051 for the preliminary analysis at 

http://www.regulations.gov/#!docketDetail;D=EERE-2013-BT-STD-0051.

a

1.2 OVERVIEW OF THE APPLIANCES AND COMMERCIAL EQUIPMENT 

STANDARDS PROGRAM

Title III of the Energy Policy and Conservation Act of 1975 (EPCA; 42 U.S.C. 6291–

6317), as amended, established the “Energy Conservation Program for Consumer Products Other 

Than Automobiles,” which includes major household appliances.b Subsequent amendments 

expanded Title III of EPCA to include additional consumer products, including general service 

lamps—the products that are the focus of this rulemaking. Before DOE determines whether to 

adopt a proposed energy conservation standard, it first solicits comments on the proposed 

standard. DOE designs any new or amended standard to achieve the maximum improvement in 

energy efficiency that is technologically feasible and economically justified. (42 U.S.C. 

6295(o)(2)(A)) To determine whether a standard is economically justified, DOE must review 

comments on the proposal and determine that the benefits of the proposed standard exceed its 

burdens to the greatest extent practicable, weighing the following seven factors:

(1) the economic impact of the standard on the manufacturers and consumers of the 

products subject to the standard;

(2) the savings in operating costs throughout the estimated average life of the products 

compared to any increases in the price, initial charges, or maintenance expenses for 

the products that are likely to result from the imposition of the standard;

(3) the total projected amount of energy savings likely to result directly from 

imposition of the standard;

(4) any lessening of the utility or the performance of the products likely to result from 

imposition of the standard;

a Information regarding the preliminary analysis can also be found here:

http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/83. b Part B was re-designated Part A on codification in the U.S. Code for editorial reasons.

1-1

 
(5) the impact of any lessening of competition, as determined in writing by the 

Attorney General, likely to result from imposition of the standard;

(6) the need for national energy conservation; and

(7) other factors the Secretary considers relevant.

(42 U.S.C. 6295(o)(2)(B)(i))

1.3 OVERVIEW OF GSL STANDARDS

As mentioned in the previous section, Part B of Title III (42 U.S.C. 6291-6309), as 

amended, established the “Energy Conservation Program for Consumer Products Other Than 

Automobiles,” which includes the GSLs that are the subject of this rulemaking. In particular, 

amendments to EPCA in the Energy Independence and Security Act of 2007 (EISA) directed

DOE to conduct two rulemaking cycles to evaluate energy conservation standards for GSLs. (42 

U.S.C. 6295(i)(6)(A)-(B))

For the first rulemaking cycle, EPCA, as amended by EISA, directs DOE to initiate a 

rulemaking no later than January 1, 2014, to evaluate standards for GSLs and determine whether 

exemptions for certain incandescent lamps should be maintained or discontinued. (42 U.S.C. 

6295(i)(6)(A)(i)) The scope of the rulemaking is not limited to incandescent lamp technologies. 

(42 U.S.C. 6295(i)(6)(A)(ii)) Further, for this first rulemaking cycle, the EISA amendments 

provide that DOE must consider a minimum standard of 45 lumens per watt (lm/W). (42 U.S.C. 

6295(i)(6)(A)(ii)) If DOE fails to meet the requirements of 42 U.S.C. 6295(i)(6)(A)(i)-(iv) or the 

final rule from the first rulemaking cycle does not produce savings greater than or equal to the 

savings from a minimum efficacy standard of 45 lm/W, sales of GSLs that do not meet the 

minimum 45 lm/W standard will be prohibited beginning on January 1, 2020. (42 U.S.C. 

6295(i)(6)(A)(v)) 

The EISA-prescribed amendments direct DOE to initiate a second rulemaking cycle by 

January 1, 2020 to determine whether standards in effect for general service incandescent lamps 

(GSILs) should be amended with more stringent requirements and if the exemptions for certain 

incandescent lamps should be maintained or discontinued. (42 U.S.C. 6295(i)(6)(B)(i)) For this 

second review of energy conservation standards, the scope is again not limited to incandescent 

lamp technologies. (42 U.S.C. 6295(i)(6)(B)(ii))

This preliminary analysis is part of DOE’s first cycle of review to evaluate standards for 

GSLs and whether the standards should apply to additional GSL types. (42 U.S.C. 6295(i)(A) 

Additionally, this rulemaking satisfies the requirements under 42 U.S.C 6295(m)(1) for DOE to 

review the existing standards for medium base compact fluorescent lamps (MBCFLs), as 

compact fluorescent lamps (CFLs) are included in the definition of GSL. It also addresses 42 

U.S.C. 6295(gg)(3) in which DOE is directed to incorporate standby mode and off mode energy 

use in any amended (or new) standard adopted after July 1, 2010, pursuant to 42 U.S.C. 6295(o).

1-2
1.4 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS

DOE considers stakeholder participation a very important part of the standards-setting 

process. DOE encourages the participation of all stakeholders during the comment period of each 

rulemaking stage. Beginning with the rulemaking framework document for GSLs (hereafter the 

“framework document”) and during subsequent comment periods, interactions among 

stakeholders provide a balanced discussion of the information that is required for the standards 

rulemaking. 

In conducting test procedure and the energy conservation standard rulemakings, DOE 

involves interested parties through formal public notifications (i.e., Federal Register notices).

For this GSL energy conservation standards rulemaking, DOE will employ the procedures set 

forth in DOE’s Process Rule (Procedures for Consideration of New or Revised Energy 

Conservation Standards for Consumer Products, 61 FR 36974, July 15, 1996, 10 CFR Part 430, 

Subpart C, Appendix A) to the extent they are appropriate for developing energy conservation 

standards for the lamps covered under this rulemaking. 

Before DOE determines whether to amend energy conservation standards for GSLs, it 

must first solicit comments on a proposed standard. (42 U.S.C. 6295(o)(2)(B)(i)) DOE must 

design new standards for these products to achieve the maximum improvement in energy 

efficiency that is technologically feasible and economically justified, and would result in 

significant energy savings. (42 U.S.C. 6295(o)(2)(A) and (3)) To determine whether a proposed 

standard complies with these requirements, DOE must, after receiving comments on the 

proposed standard, determine whether the benefits of the standard exceed its burdens to the 

greatest extent practicable, weighing the seven factors previously described. 

Subsequent to the publication of the framework document, the standards rulemaking 

process involves preliminary analyses followed by two additional formal, major public notices, 

which are published in the Federal Register. The preliminary analyses are designed to publicly 

vet the models and tools used in the rulemaking and to facilitate public participation before the 

proposed rule stage. After the preliminary analyses are vetted, DOE issues the first major notice, 

the notice of proposed rulemaking (NOPR), which presents a discussion of comments received in 

response to the preliminary analyses of the impacts of standards on consumers, manufacturers, 

and the nation; DOE’s weighing of the impacts; and the proposed standards. The second notice is 

the final rule, which presents a discussion of comments received in response to the NOPR; the 

revised analysis of the impacts of standards; DOE’s weighing of the impacts; the standards 

adopted by DOE; and the compliance dates of the standards.

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Table 1.4.1 Analyses Under the Process Rule

Preliminary Analysis NOPR Final Rule*

Market and Technology Assessment Revised Preliminary Analyses Revised Analyses

Screening Analysis Consumer Subgroup Analysis

Engineering Analysis Manufacturer Impact Analysis

Energy Use Characterization Emissions Analysis

Product Price Determination Monetizing CO2 and Other Emissions

Life-Cycle Cost and Payback Period Analysis Utility Impact Analysis

Shipments Analysis Employment Impact Analysis

National Impact Analysis Regulatory Impact Analysis

Preliminary Manufacturer Impact Analysis

* During the final rule phase, DOE considers the comments submitted by the U.S. Department of Justice concerning 

the impact of any lessening of competition that is likely to result from the imposition of the standard. (42 U.S.C. 

6295(o)(2)(B)(v))

On December 9, 2013, DOE published a notice announcing the availability of the 

framework document and a public meeting to discuss the proposed analytical framework for the 

rulemaking. 78 FR 73737. DOE also posted the framework document on its website: 

http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/83. 

DOE held the public meeting on January 14, 2014 to discuss procedural and analytical 

approaches to the rulemaking and to inform and facilitate stakeholders’ involvement in the 

rulemaking process. The analytical framework presented at the public meeting described 

rulemaking analyses, such as the engineering analysis and the LCC and PBP analysis, the 

methods proposed for conducting them, and the relationships among the various analyses. See 

Table 1.4.1 for all the analyses discussed at the public meeting and the stage at which the 

analyses are undertaken. PDF copies of the slides and other material associated with the public 

meeting are available at: 

http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/83. 

During the public meeting and the framework document comment period,c DOE received 

several comments about the GSL rulemaking from stakeholders, including manufacturers, trade 

associations, environmental advocates, and other interested parties. The major issues discussed 

were: scope of coverage, scope of metrics, product classes, efficacy level approach, shipment 

forecasts, and the backstop analysis. A detailed discussion of stakeholder comments is available 

in chapter 2 of this TSD. 

c The National Electrical Manufacturers Association (NEMA) requested that DOE extend the comment deadline by 

two weeks from the original January 23, 2014 deadline. DOE agreed and moved the comment deadline to February 

7, 2014. The notice extending the framework comment period is available at:

http://www.regulations.gov/#!documentDetail;D=EERE-2013-BT-STD-0051-0009. 

1-4 

 
As part of the information gathering and sharing process, DOE organized and held 

interviews with GSL manufacturers who operate in the U.S. market. DOE had five objectives for 

these interviews: (1) solicit feedback on the scope of coverage for the rulemaking; (2) solicit 

feedback on the engineering analysis; (3) solicit feedback on topics related to the preliminary 

manufacturer impact analysis; (4) provide an opportunity early in the rulemaking process to 

express specific concerns to DOE; and (5) foster cooperation between manufacturers and DOE. 

During the manufacturer interviews, DOE discussed these and other issues regarding market 

data, distribution channels, anticipated consumer responses to standards, production and 

equipment mix, conversion costs, and cumulative regulatory burden. Appendix 12A of this TSD 

contains a complete copy of the interview guide. 

DOE incorporated the information gathered at the meetings into its market and 

technology assessment (chapter 3 of this TSD), engineering analysis (chapter 5 of this TSD), 

product price determination (chapter 6 of this TSD), and the preliminary manufacturer impact 

analysis (chapter 12 of this TSD). Following the publication of the preliminary analysis, DOE 

intends to hold additional meetings with manufacturers as part of the consultative process for the 

manufacturer impact analysis conducted during the NOPR phase. 

For the LCC, PBP, and NIA, DOE developed spreadsheets using Microsoft Excel®. The 

LCC and PBP spreadsheets calculate the economic impacts of replacing GSLs with more 

efficacious lamps. The NIA spreadsheet calculates the national energy savings (NES) and 

national net present value (NPV) at various candidate standard levels and includes a model that 

forecasts the impacts of energy conservation standards at various levels on product shipments. 

These spreadsheets are available on regulations.gov, docket number EERE–2013–BT–STD–

0051 at http://www.regulations.gov/#!docketDetail;D=EERE-2013-BT-STD-0051. 

1.5 STRUCTURE OF THE DOCUMENT

This preliminary TSD outlines the analytical approaches used in this rulemaking. The 

TSD consists of 17 chapters and 11 appendices.

Chapter 1 Introduction: provides an overview of the appliance standards program 

and how it applies to the rulemaking for GSLs, and outlines the 

structure of the document 

Chapter 2 Analytical Framework: describes the rulemaking process, and provides 

an overview of each analysis including rationale for preliminary 

determinations

Chapter 3 Market and Technology Assessment: characterizes the GSL market 

and the technologies available for increasing efficacy, and outlines 

product classes

Chapter 4 Screening Analysis: determines which technology options are viable 

for consideration in the engineering analysis 

1-5 
Chapter 5 Engineering Analysis: describes DOE’s approach to the engineering 

analysis, and establishes candidate standard levels based on lamp 

efficacy

Chapter 6 Product Price Determination: describes DOE’s approach to 

determining the end-user prices for GSLs 

Chapter 7 Energy Use Characterization: discusses the sources and methods for 

developing energy use estimates for GSLs 

Chapter 8 Life-Cycle Cost and Payback Period Analysis: discusses the economic 

effects of standards on individual consumers and calculates the LCC 

and PBP of GSLs

Chapter 9 Shipments Analysis: discusses the methods used for forecasting 

shipments with and without higher energy conservation standards 

Chapter 10 National Impacts Analysis: discusses the methods used for 

forecasting national energy consumption and national economic 

impacts based on annual product shipments and estimates of future 

product efficiency distributions in the absence and presence of higher 

efficiency standards 

Chapter 11 Consumer Subgroup Analysis: discusses the methods to be used to 

study the impacts of standards on a subgroup of GSL consumers and 

compares the LCC and PBP of products with and without higher 

efficiency standards

Chapter 12 Preliminary Manufacturer Impact Analysis: discusses the methods to 

be used to study the impacts of standards on the finances and 

profitability of GSL manufacturers, and presents preliminary 

manufacturer impact analysis results 

Chapter 13 Emissions Analysis: discusses the methods to be used to study the 

effects of standards on sulfur dioxide (SO2), nitrogen oxides 

(NOx), mercury (Hg), and carbon dioxide (CO2) emissions 

Chapter 14 Monetization of Emission Reductions Benefits: discusses the 

methods to be used to study the effects of standards on monetary 

benefits likely to result from the reduced emissions of CO2 and NOX 

Chapter 15 Utility Impact Analysis: discusses the methods to be used to study 

the effects of standards on the installed generation capacity of 

electric utilities 

Chapter 16 Employment Impact Analysis: discusses the methods to be used to 

analyze the effects of standards on national employment 

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Chapter 17 Regulatory Impact Analysis: discusses present regulatory actions and 

the methods to be used to determine the impact of non-regulatory 

alternatives to energy conservation standards 

Appendix AA Acronyms and Abbreviations: provides a set of acronyms and 

abbreviations used throughout the TSD 

Appendix 8A User Instructions for LCC and PBP Spreadsheet: provides basic 

instructions for operating the LCC and PBP workbook, as well as 

descriptions of each worksheet included in the workbook 

Appendix 8B Uncertainty and Variability: describes how uncertainty and variability 

were incorporated into the analyses and presents LCC and PBP 

analysis results for alternative scenarios DOE considered

Appendix 8C Discount Rate Distributions: provides the probability distributions 

used with real interest rates to develop residential and commercial 

discount rates 

Appendix 8D Modeling of Rare Earth Price Impacts: reflects the findings of DOE’s 

analysis of the rare earth phosphor market 

Appendix 8E Lifetime Modeling: describes the methodology DOE used to model 

GSL survival probability as a function of GSL age 

Appendix 10A User Instructions for National Impact Analysis Spreadsheet Model: 

provides basic instructions for operating the NIA workbook, as well as 

descriptions of each worksheet included 

Appendix 10B Full-Fuel-Cycle Multipliers: summarizes the methods used to calculate 

full-fuel-cycle (FFC) energy savings expected to result from potential 

standards 

Appendix 10C Lighting Controls Market Penetration Projection: describes the 

assumptions and analysis DOE used to project changes in the 

penetration of lighting controls 

Appendix 10D Rebound Effect: describes the direct rebound effect and the analysis 

DOE used to establish its baseline rebound rate 

Appendix 12A Manufacturer Impact Analysis Interview Guide 

1-7 
CHAPTER 2. ANALYTICAL FRAMEWORK

TABLE OF CONTENTS

2.1 INTRODUCTION ........................................................................................................... 2-1

2.2 BACKGROUND ............................................................................................................. 2-3

2.2.1 Regulatory Authority and History of Standards Rulemakings for GSLs ............ 2-3

2.2.2 Rulemaking Schedule .......................................................................................... 2-4

2.2.3 Test Procedure ..................................................................................................... 2-5

2.2.4 Standby and Off Mode Energy Consumption ...................................................... 2-8

2.3 SCOPE OF LAMPS ......................................................................................................... 2-9

2.3.1 General Service Incandescent Lamps .................................................................. 2-9

2.3.1.1 Appropriations Rider ............................................................................. 2-10

2.3.1.2 Exempted Incandescent Lamps .............................................................. 2-13

2.3.2 Compact Fluorescent Lamps.............................................................................. 2-16

2.3.3 General Service LED Lamps ............................................................................. 2-18

2.3.4 OLED Lamps ..................................................................................................... 2-20

2.3.5 Other Lamps....................................................................................................... 2-21

2.3.5.1 Lamps Addressed In Other Rulemakings .............................................. 2-25

2.3.5.2 Lamps without an ANSI Base................................................................ 2-27

2.3.5.3 High Lumen Lamps (>2,600 Lumens) .................................................. 2-27

2.3.5.4 General Service Lamps that Operate in Standby Mode ......................... 2-28

2.3.5.5 Integrated Lamps ................................................................................... 2-28

2.3.5.6 Non-Integrated ....................................................................................... 2-33

2.3.5.7 Summary of Lamps ................................................................................ 2-35

2.3.5.8 Summary of Definitions ......................................................................... 2-36

2.4 SCOPE OF METRICS ................................................................................................... 2-37

2.4.1 Existing Metrics for MBCFLs ........................................................................... 2-38

2.4.2 Additional Metrics for MBCFLs ....................................................................... 2-40

2.4.3 Summary ............................................................................................................ 2-42

2.5 MARKET AND TECHNOLOGY ASSESSMENT ...................................................... 2-42

2.5.1 Market Assessment ............................................................................................ 2-43

2.5.1.1 Manufacturers of GSLs .......................................................................... 2-43

2.5.2 Technology Assessment..................................................................................... 2-44

2.5.2.1 CFL Technology Options ...................................................................... 2-45

2.5.2.2 LED Lamp Technology Options ............................................................ 2-45

2.5.3 Product Classes .................................................................................................. 2-52

2.5.3.1 Covering ................................................................................................. 2-53

2.5.3.2 Dimmability ........................................................................................... 2-54

2.5.3.3 Ballast Location ..................................................................................... 2-55

2.5.3.4 Lamp Technology .................................................................................. 2-56

2.5.3.5 Base Type............................................................................................... 2-56

2.5.3.6 Lamp Spectrum ...................................................................................... 2-57

2.5.3.7 Correlated Color Temperature ............................................................... 2-57

2.5.3.8 Lumen Package ...................................................................................... 2-58

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2.5.3.9 Standby Mode Operation ....................................................................... 2-58

2.5.3.10 Summary ........................................................................................... 2-59

2.6 SCREENING ANALYSIS ............................................................................................ 2-59

2.7 ENGINEERING ANALYSIS........................................................................................ 2-62

2.7.1 Approach............................................................................................................ 2-62

2.7.2 Representative Product Classes ......................................................................... 2-64

2.7.3 Baseline Lamps.................................................................................................. 2-66

2.7.3.1 Integrated Lamps ................................................................................... 2-67

2.7.3.2 Non-Integrated Lamps........................................................................... 2-67

2.7.4 More Efficacious Substitutes............................................................................. 2-68

2.7.4.1 Integrated Lamps ................................................................................... 2-69

2.7.4.2 Non-Integrated Lamps........................................................................... 2-69

2.7.5 Candidate Standard Levels ................................................................................ 2-70

2.7.5.1 Integrated Lamps ................................................................................... 2-72

2.7.5.2 Non-Integrated Lamps........................................................................... 2-75

2.7.6 Scaling to Other Product Classes....................................................................... 2-77

2.8 PRODUCT PRICE DETERMINATION ...................................................................... 2-77

2.9 ENERGY-USE CHARACTERIZATION..................................................................... 2-80

2.10 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS ................................... 2-84

2.11 SHIPMENTS ANALYSIS ............................................................................................ 2-86

2.12 NATIONAL IMPACT ANALYSIS.............................................................................. 2-90

2.12.1 National Energy Savings.................................................................................... 2-93

2.12.2 Net Present Value .............................................................................................. 2-93

2.13 CONSUMER SUBGROUP ANALYSIS ...................................................................... 2-94

2.14 MANUFACTURER IMPACT ANALYSIS.................................................................. 2-95

2.14.1 Sources of Information for the Manufacturer Impact Analysis......................... 2-95

2.14.2 Industry Cash Flow Analysis............................................................................. 2-96

2.14.3 Direct Employment Impact Analysis................................................................. 2-96

2.14.4 Manufacturer Subgroup Analysis...................................................................... 2-97

2.14.5 Competitive Impacts Assessment ...................................................................... 2-97

2.14.6 Cumulative Regulatory Burden ......................................................................... 2-98

2.14.7 Preliminary Results for the Manufacturer Impact Analysis .............................. 2-99

2.15 EMISSIONS ANALYSIS............................................................................................ 2-100

2.16 MONETIZING CO2 AND OTHER EMISSIONS ...................................................... 2-102

2.17 UTILITY IMPACT ANALYSIS................................................................................. 2-103

2.18 EMPLOYMENT IMPACT ANALYSIS..................................................................... 2-103

2.19 REGULATORY IMPACT ANALYSIS ..................................................................... 2-104

2.20 DEPARTMENT OF JUSTICE REVIEW ................................................................... 2-105

LIST OF TABLES

Table 2.4.1 Performance Metrics for Medium Base Compact Fluorescent Lamps................... 2-42

Table 2.5.1 GSL Technology Options....................................................................................... 2-51

Table 2.5.2 GSL Product Classes .............................................................................................. 2-59

Table 2.7.1 GSL Representative Product Classes...................................................................... 2-65

Table 2.7.2 Integrated Product Classes Baseline Lamps........................................................... 2-67

Table 2.7.3 Non-Integrated Product Class Baseline Lamp........................................................ 2-68

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Table 2.7.4 Integrated Product Class’ Representative Lamp Units........................................... 2-73

Table 2.7.5 Summary of CSLs for GSL Integrated Representative Product Classes................ 2-75

Table 2.7.6 Non-Integrated Product Class Design Representative Lamp Units........................ 2-75

Table 2.7.7 Summary of CSLs for GSL Non-Integrated Representative Product Class........... 2-77

2-iii
CHAPTER 2. ANALYTICAL FRAMEWORK

2.1 INTRODUCTION

The Energy Policy and Conservation Act of 1975 (EPCA; 42 U.S.C. 6291 et seq.), as 

amended, requires that energy conservation standards set by the U.S. Department of Energy 

(DOE) be technologically feasible and economically justified, and achieve the maximum 

possible improvement in energy efficiency. (42 U.S.C. 6295(o)(2)(A) and (3)) This chapter 

provides a description of the general analytical framework that DOE uses in developing such 

standards, and in particular, standards for general service lamps (GSLs). It includes a description 

of the methodology, the analytical tools, and relationships among the various analyses that are 

part of this rulemaking. Chapter 2 also provides an overview of the preliminary activities DOE 

has conducted and discusses the comments it received in response to the framework document. 

Finally, chapter 2 provides cross-references to the other chapters of this technical support 

document (TSD) that address DOE’s analytical approach, inputs, and findings.

The analyses presented in this TSD include:

• a market and technology assessment to characterize the relevant GSL market; to identify 

technology options that improve efficacy; and to develop product classes;

• a screening analysis to review each technology option and determine if it is 

technologically feasible; is practicable to manufacture, install, and service; would 

adversely impact lamp utility or lamp availability; or would have adverse impacts on 

health and safety;

• an engineering analysis to study representative lamp systems and, as appropriate, lampand-ballast systems used as substitutes for baseline lamps, to select candidate standard 

levels (CSLs), and to determine lamp system power ratings;

• a product price determination that develops end-user product prices for the representative 

lamps identified in the engineering analysis;

• an energy-use characterization that generates energy-use estimates for covered GSLs;

• a life-cycle cost (LCC) analysis that calculates, at the consumer level, the discounted 

savings in operating costs throughout the estimated average life of the lamp, compared to 

any increase in the installed costs likely to result directly from imposition of the standard;

• a payback period (PBP) analysis to estimate the amount of time it takes consumers to 

recover the higher purchase expense of more efficacious lamps through lower operating 

costs;

2-1
• a shipments analysis that estimates shipments of GSLs over the time period examined in

the analysis;

• a national impact analysis (NIA) that assesses the aggregate impacts at the national level

of potential energy conservation standards as measured by the net present value (NPV) of

total consumer economic impacts and national energy savings (NES); and

• a preliminary manufacturer impact analysis (MIA) that begins to evaluate the effects on

manufacturers that may result from an amended efficacy standard.

DOE may revise any of its analyses based on comments and new information received on

this preliminary analysis before publishing any subsequent notice of proposed rulemaking 

(NOPR). The analyses DOE performs in any NOPR stage include the following: 

• a consumer subgroup analysis that evaluates the economic impacts on identifiable groups

of consumers of GSLs, including various categories of lamp purchasers or owners who

may experience disproportionate impacts from a national energy conservation standard;

• an MIA that estimates the financial impact of standards on lamp manufacturers and

calculates impacts on competition, employment at the manufacturing plant, and

manufacturing capacity;

• a utility impact analysis that estimates the effects of proposed standards on the installed

capacity and the generating base of electric utilities;

• an employment impact analysis that estimates the impacts of standards on net jobs

eliminated or created in the general economy as a consequence of increased spending on

the installed price of GSLs and reduced consumer spending on energy;

• an emissions analysis to provide estimates of the effects of amended energy conservation

standards on emissions of carbon dioxide (CO2), sulfur dioxide (SO2), nitrogen oxides

(NOX), and mercury (Hg);

• a monetization of the reduced emissions from the proposed standard levels; and

• a regulatory impact analysis (RIA) that presents major alternatives to proposed standards

that may achieve comparable energy savings at a reasonable cost.

DOE developed this analytical framework and documented its findings in the Energy

Conservation Standards Rulemaking Framework Document for General Service Lamps 

(December 9, 2013).1 DOE presented the analytical approach to interested parties during a public 

meeting held on January 14, 2014 (hereafter the “framework public meeting”). 

1 The framework document is available at: www.regulations.gov/#!documentDetail;D=EERE-2013-BT-STD-0051-

0006. 

2-2 
In response to the publication of the framework document and the framework public 

meeting, DOE received comments from interested parties on its analytical approach. Based on 

the timing of the release of the framework document, the National Electrical Manufacturers 

Association (NEMA) requested that DOE extend the comment deadline by two weeks. (NEMA, 

Public Meeting Transcript, No. 19 at p. 13)2 DOE agreed and extended the comment deadline 

from January 23, 2014 until February 7, 2014.3 This chapter summarizes the key comments DOE 

received, describes DOE’s responses, and summarizes the analytical approach taken in this 

preliminary analysis. In the executive summary of this TSD, DOE identifies issues on which it 

seeks public comment, which are also discussed in the following sections. 

2.2 BACKGROUND

2.2.1 Regulatory Authority and History of Standards Rulemakings for GSLs

Title III of EPCA sets forth a variety of provisions designed to improve energy 

efficiency. Part B of Title III (42 U.S.C. 6291-6309) established the “Energy Conservation 

Program for Consumer Products Other Than Automobiles,” which includes major household 

appliances.4

 Subsequent amendments expanded Title III of EPCA to include additional consumer 

products, including GSLs—the products that are the focus of this preliminary analysis. In 

particular, amendments to EPCA in the Energy Independence and Security Act of 2007 (EISA) 

directed DOE to conduct two rulemaking cycles to evaluate energy conservation standards for 

GSLs. (42 U.S.C. 6295(i)(6)(A)-(B))

For the first rulemaking cycle, EPCA, as amended by EISA, directs DOE to initiate a 

rulemaking no later than January 1, 2014, to evaluate standards for GSLs and determine whether 

exemptions for certain incandescent lamps should be maintained or discontinued. (42 U.S.C. 

6295(i)(6)(A)(i)) The scope of the rulemaking is not limited to incandescent lamp technologies. 

(42 U.S.C. 6295(i)(6)(A)(ii)) Further, for this first cycle of rulemaking, the EISA amendments 

provide that DOE must consider a minimum standard of 45 lumens per watt (lm/W). (42 U.S.C. 

6295(i)(6)(A)(ii)) If DOE fails to meet the requirements of 42 U.S.C. 6295(i)(6)(A)(i)-(iv) or the 

final rule from the first rulemaking cycle does not produce savings greater than or equal to the 

savings from a minimum efficacy standard of 45 lm/W, sales of GSLs that do not meet the 

minimum 45 lm/W standard beginning on January 1, 2020, will be prohibited. (42 U.S.C. 

6295(i)(6)(A)(v)) 

The EISA-prescribed amendments direct DOE to initiate a second rulemaking cycle by 

January 1, 2020, to determine whether standards in effect for general service incandescent lamps 

2 A notation in this form provides a reference for information that is in the docket of DOE’s rulemaking to develop 

energy conservation standards for GSLs (Docket No. EERE–2013–BT–STD– 51), which is maintained at 

www.regulations.gov. This notation indicates that the statement preceding the reference is document number 19 in 

the docket for the GSL energy conservation standards rulemaking, and appears at page 13 of that document.

3 The notice extending the framework comment period is available at 

www.regulations.gov/#!documentDetail;D=EERE-2013-BT-STD-0051-0009. 

4Part B was re-designated Part A on codification in the U.S. Code for editorial reasons. 

2-3 
(GSILs) should be amended with more stringent requirements and if the exemptions for certain 

incandescent lamps should be maintained or discontinued. (42 U.S.C. 6295(i)(6)(B)(i)) For this 

second review of energy conservation standards, the scope is not limited to incandescent lamp 

technologies. (42 U.S.C. 6295(i)(6)(B)(ii)) 

This preliminary analysis is part of DOE’s first cycle of review to evaluate standards for 

GSLs and whether the standards should apply to additional GSL types. (42 U.S.C. 6295(i)(A) 

Additionally, this rulemaking satisfies the requirements under 42 U.S.C 6295(m)(1) for DOE to 

review the existing standards for medium base compact fluorescent lamps (MBCFLs), as 

compact fluorescent lamps (CFLs) are included in the definition of GSL. It also addresses 42 

U.S.C. 6295(gg)(3) in which DOE is directed to incorporate standby mode and off mode energy 

use in any amended (or new) standard adopted after July 1, 2010, pursuant to 42 U.S.C. 6295(o). 

2.2.2 Rulemaking Schedule

In the schedule presented in the framework document, this preliminary analysis was 

scheduled to be published in November 2014, the NOPR in December 2015, and the final rule in 

December 2016. DOE received no comments regarding the proposed rulemaking schedule; 

however, DOE received comments on the general timing and initiation of this rulemaking. 

NEMA commented that the recent implementation of EISA—which requires the phase-out of 

60 W screw-based bulbs as of January 1, 2014—will affect the market in ways that surveys will 

be unable to adequately characterize until late 2014. NEMA therefore encouraged DOE to make 

every effort to gather data after the effects of the EISA implementation have run their course. 

(NEMA, No. 15 at p. 15) Additionally, NEMA indicated that it is difficult to comment on the 

standards rulemaking when a test procedure (TP) rulemaking is happening concurrently, because 

it is largely unknown how the products will be tested. (NEMA, Public Meeting Transcript, No. 

19 at p. 77) 

DOE acknowledges that implementation of the latest phase of EISA will have market 

implications that will take time to be fully realized. Accordingly, DOE intends to collect and use 

the most recent available market data to inform its analyses. For this preliminary analysis, DOE 

has used the latest relevant market information available, including the 2010 U.S. Lighting 

Market Characterization (LMC);

5

 recent versions of the U.S. Energy Information 

Administration’s (EIA’s) Commercial Building Energy Consumption Survey (CBECS);

6

 and 

Residential Energy Consumption Survey (RECS);7 NEMA lamp indices;

8

 KEMA shelf survey 

5 U.S. Department of Energy. 2010 U.S. Lighting Market Characterization. January 2012. Available at 

http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf. 

6 U.S. Department of Energy–Energy Information Administration. Commercial Building Energy Consumption 

Survey. Micro-level data: File 1 General Building Information and Energy End Uses. 2003. Washington, D.C. 

(Last Accessed September 15, 2014) http://www.eia.gov/consumption/commercial/data/2003/index.cfm?

view=microdata. 

7 U.S. Department of Energy–Energy Information Administration. Residential Energy Consumption Survey. 2009 

RECS Survey Data. 2011. Washington, D.C. (Last Accessed September 15, 2014) 

http://www.eia.gov/consumption/residential/data/2009/. 

8 National Electrical Manufacturers Association. Lamp Indices. (Last Accessed August 4, 2014.) 

http://www.nema.org/news/Pages/NEMA-News.aspx. 

2-4 
data;

9

 and shipments and GSL lumen bin data provided by the Cadeo Group.10 DOE requests any 

recent information or data on market shipments data for GSLs that can be used to provide a 

representative baseline for the NOPR analyses.

The People’s Republic of China (P.R. China) judged the existing GSL standards and test 

procedures as adequate, given current energy efficiency goals, and stated that this rulemaking 

adds nothing new. For that reason, P.R. China considered it unnecessary to complete the 

rulemaking and suggested withdrawal. (P.R. China, No. 21 at p. 3) 

As stated in section 2.2.1, DOE is required by EPCA, as amended by EISA, to initiate a 

rulemaking no later than January 1, 2014, to evaluate standards for GSLs and to publish a final 

rule by January 1, 2017, if standards are to be established. (42 U.S.C. 6295(i)(6)(A)(i) and (iii)) 

Additionally, this rulemaking also satisfies the requirements under 42 U.S.C 6295(m)(1) for 

DOE to review the existing standards for MBCFLs. When DOE evaluates any new or amended 

energy conservation standard for “covered products,” EPCA, as amended, specifies that any 

standard DOE prescribes for consumer products must be designed to achieve the maximum 

improvement in energy efficiency that is technologically feasible and economically justified. (42 

U.S.C. 6295(o)(2)(A)) Moreover, the Secretary of Energy (Secretary) may not establish a new or

amended standard if such standard would not result in a significant conservation of energy. (42 

U.S.C. 6295(o)(3)(B)) Therefore, DOE must evaluate GSLs to determine if standards are 

technologically feasible and economically justified.

2.2.3 Test Procedure

EPCA sets forth generally applicable criteria and procedures for DOE’s adoption and 

amendment of test procedures. (42 U.S.C. 6293) Manufacturers of covered products must use 

these test procedures to certify to DOE that their product complies with EPCA energy 

conservation standards and to quantify the efficiency of their product. DOE is considering 

developing and amending test procedures for products included in the definition of GSLs. The 

term GSL includes GSILs, CFLs, general service light-emitting diode (LED) lamps, organic 

light-emitting diode (OLED) lamps, and any other lamps that the Secretary determines are used 

to satisfy lighting applications traditionally served by general service incandescent lamps. 10 

Code of Federal Regulations (CFR) 430.2 

DOE’s test procedures for GSILs are set forth at 10 CFR 430, subpart B, appendix R. 

These test procedures provide instructions for measuring GSIL performance largely by 

incorporating industry standards. These test procedures were updated in a final rule published in 

January 2012. 77 FR 4203 (January 27, 2012). The rule updated citations and references to the 

industry standards currently referenced in DOE’s test procedures for GSILs and established a 

new test procedure for determining the rated lifetime of GSILs. 

9 DNV GL Sustainable Energy Use. California Retail Lighting Shelf Survey Online Tool. (Last Accessed 

September 15, 2014.) https://websafe.kemainc.com/projects62/crlss/Home.aspx. 

10 Carmichael, R. GSL shipments and lumen bin distribution data. 2014. Washington, DC. Cadeo Group. Contract 

7094760-T2D.

2-5 
In the preliminary analysis of the general service fluorescent lamp (GSFL) and 

incandescent reflector lamp (IRL) energy conservation standards rulemaking11 (hereafter “GSFL 

and IRL Standards Rulemaking”), DOE determined that the term “compact fluorescent lamps” 

includes both pin base and medium base CFLs (see section 2.3 for further discussion). DOE’s 

current test procedures for MBCFLs are set forth at 10 CFR 430, subpart B, appendix W. These 

test procedures provide instructions for measuring MBCFL performance by referencing the 

August 9, 2001, ENERGY STAR® Program Requirements for CFLs Version 2.0. Currently there 

is no DOE test procedure for non-integrated CFLs (also referred to as pin base CFLs); however, 

DOE has initiated a CFL TP rulemaking to amend existing test procedures for MBCFLs at 

appendix W and to include test procedures for additional CFL metrics and CFL types, including 

non-integrated CFLs. 

DOE is also currently developing test procedures for LED lamps. DOE published a 

supplemental notice of proposed rulemaking (SNOPR) on August 4, 2014, to propose test 

procedures for integrated LED lamps. 79 FR at 32019. The rulemaking does not include test 

procedures for non-integrated LED lamps or OLED lamps. However, as discussed in section 

2.3.5, DOE is not considering establishing standards for non-integrated LED lamps at this time. 

Further, DOE is not considering establishing standards for OLED lamps at this time. See section

2.3.4 for more information. Therefore, DOE does not believe test procedures for non-integrated 

LED lamps and OLED lamps are necessary in advance of prescribing standards for this 

rulemaking. 

DOE has the authority to consider additional lamps that it determines are used to satisfy 

lighting applications traditionally served by GSILs. (42 U.S.C. 6291(30)(BB)) In the framework 

document, DOE stated that it would consider establishing test procedures for additional lamp 

types, including hybrid lamps and self-ballasted mercury vapor (SBMV) lamps. As discussed in 

section 2.3.5.5, DOE determined that the hybrid lamps identified fall within the definition of 

MBCFL and therefore will address test procedures for hybrid lamps in the CFL TP rulemaking. 

DOE is no longer considering establishing standards for SBMV lamps in the scope of this 

rulemaking (see section 2.3.5.1 for more detail). DOE did not identify any additional lamp types 

covered by this rulemaking that would need test procedures to be established prior to an energy 

conservation standard being prescribed for these lamps. 

DOE received comments regarding test procedures for the products included in the scope 

of this rulemaking. The California Energy Commission (CEC) stated that DOE should attempt to 

use the same testing methodology for all lamps within the scope of the rulemaking, particularly 

where lamps serve the same utility and are direct substitutes for one another. (CEC, No. 11 at p. 

7) 

While DOE is maintaining a technology neutral approach to this rulemaking, there are 

inherent mechanical and electrical differences between lamp types that require separate testing 

methods. Additionally, DOE test procedures frequently incorporate references to industry11 The preliminary analysis technical support document for the GSFL and IRL Standards Rulemaking is available at 

www.regulations.gov/#!documentDetail;D=EERE-2011-BT-STD-0006-0022. 

2-6 
approved test methods. The Illuminating Engineering Society of North America (IES) has 

developed separate standards for solid-state lighting products (i.e., LEDs and OLEDs) and CFLs. 

Although DOE is not considering establishing one test procedure for all GSLs, DOE intends to 

coordinate the test procedures in development for CFLs and integrated LED lamps and prescribe 

consistent testing methodologies when possible.

NEMA urged DOE not to develop test procedures that make the testing and qualification 

process overly complicated and burdensome. NEMA also requested that DOE take into account 

any existing test procedures in place for these products developed by other agencies or groups, so 

as not to be redundant. (NEMA, No. 15 at p. 7)

EPCA provides, in relevant part, that any test procedures prescribed or amended under 42 

U.S.C. 6293 shall not be unduly burdensome to conduct. (42 U.S.C. 6293(b)(3)) Therefore, in 

developing test procedures, DOE makes significant efforts to prevent the adoption of test 

methods that are overly burdensome for manufacturers. DOE weighs burden in the development 

of test procedures, and solicits feedback from manufacturers and other stakeholders during the 

test procedure rulemaking process to ensure its test procedures are not overly burdensome. To 

reduce testing burden and redundancy, DOE incorporates industry standard test procedures, thus 

aligning with industry practice. DOE also considers voluntary testing methods, such as 

ENERGY STAR, when developing its test procedures. See section 2.4 for more information. 

DOE also received comments on the impact of establishing new test procedures on the 

timing of this GSL rulemaking. NEMA commented that as more lamp types without existing test 

procedures are added to the scope of this GSL rulemaking, the longer it would take to 

accomplish the rulemaking. NEMA further noted that it is difficult to comment on a standards 

rulemaking when the test procedure rulemaking for the product is happening concurrently. 

(NEMA, Public Meeting Transcript, No. 19 at pp. 74, 77) NEMA specifically noted that there 

are currently no test procedures for pin base CFLs and self-ballasted mercury vapor lamps, and 

that development of these new test procedures could delay the rulemaking. (NEMA, No. 15 at p. 

7) Natural Resources Defense Council (NRDC), Appliance Standard Awareness Project (ASAP),

Alliance to Save Energy, American Council for an Energy-Efficient Economy, Consumer 

Federation of America, Northeast Energy Efficiency Partnerships, and Northwest Energy 

Efficiency Alliance (NRDC, ASAP, et al.) commented that if issues related to test methods for 

pin base CFLs or hybrid lamps are difficult to resolve, DOE should not set standards for these 

lamp types to prevent delaying the GSL rulemaking. (NRDC, ASAP, et al., No. 17 at p. 10)

DOE understands the concerns of stakeholders regarding the timing of establishing test 

procedures for products that are included in the scope of the rulemaking but do not currently 

have DOE test procedures. DOE acknowledges the importance of having a test procedure in 

place prior to the standards being finalized and thus has already initiated rulemakings for these 

products. Regarding pin base CFLs, DOE is considering developing test procedures for 

additional CFL types including non-integrated CFLs in the ongoing CFL TP rulemaking. DOE is 

also planning to develop test procedures for hybrid lamps in the CFL TP rulemaking. As 

mentioned previously, DOE is not considering establishing standards for SBMV lamps in the 

scope of this rulemaking and therefore does not believe a test procedure is necessary at this time

(see section 2.3.5.1 for more detail).

2-7
DOE received comments on suggested test methods for CFLs. NRDC requested that the 

sample size of five used in the existing DOE MBCFL test procedure for several metrics be 

updated to a sample size of ten to align with the current ENERGY STAR specification so the 

data can be used for future enforcement. (NRDC, Public Meeting Transcript, No. 19 at pp. 79-

80) NRDC, ASAP, et al. also commented that DOE would need to review test methods and 

make adjustments as necessary to accommodate hybrid lamps as their power consumption during 

warm-up periods differs greatly from steady state operation. To account for this, NRDC, ASAP,

et al. suggested that DOE establish an alternate time to take the power and light output 

measurements. (NRDC, ASAP, et al., No. 17 at p. 10) 

DOE recognizes that the sampling requirements of the existing MBCFL Test Procedure

do not align with the current ENERGY STAR specifications, ENERGY STAR Program 

Requirements Product Specification for Lamps (Light Bulbs) Eligibility Criteria Version 1.1

(hereafter “ENERGY STAR Lamps Specification V1.1”). DOE will address potential 

amendments to the sampling requirements in the upcoming CFL TP rulemaking. Regarding 

hybrid lamps, DOE will address the testing of these lamp types in the CFL TP rulemaking. 

NEMA commented that the CFL test procedure must address the differences in operation 

between externally ballasted CFLs and self-ballasted CFLs and determine how to best 

accommodate the discrepancy. NEMA further noted that reference ballast specifications do not 

exist at this time. (NEMA, Public Meeting Transcript, No. 19 at p. 75)

DOE acknowledges the differences in operation between self-ballasted and externally 

ballasted CFLs. Subsequently, DOE will consider test procedures specific to integrated (i.e., selfballasted) and non-integrated (i.e., externally ballasted) CFLs in the CFL TP rulemaking. DOE 

will also address reference ballast specifications for non-integrated CFLs in the CFL TP

rulemaking. Further, DOE is considering separate product classes for integrated and nonintegrated GSLs, with the inherent difference in their efficacies as one of the factors in the 

decision. See section 2.5.3 for more information.

NRDC, ASAP, et al. commented that DOE should work with the Federal Trade 

Commission (FTC) to require labels on all lamps indicating the date of manufacture or import. 

Such labeling would make it possible to determine if a given lamp has been manufactured or 

imported after the effective date of the rulemaking. NRDC, ASAP, et al. also suggested that 

DOE establish lumen equivalency tables that manufacturers would be required to adhere to when 

making equivalency claims, thus discouraging exaggerated claims. (NRDC, ASAP, et al., No. 17 

at pp. 13-14) DOE understands concerns regarding the manufacture date and potentially inflated 

lumen equivalency claims of covered products, and DOE will continue to work with FTC on 

labeling issues.

2.2.4 Standby and Off Mode Energy Consumption

EPCA requires energy conservation standards adopted for a covered product after July 1, 

2010, to address standby mode and off mode energy use. (42 U.S.C. 6295(gg)(3)) EPCA defines 

active mode as the condition in which an energy-using piece of equipment is connected to a main 

2-8
power source, has been activated, and provides one or more main functions. (42 U.S.C. 

6295(gg)(1)(A)) Standby mode is defined as the condition in which an energy-using piece of 

equipment is connected to a main power source and offers one or more of the following useroriented or protective functions: facilitating the activation or deactivation of other functions 

(including active mode) by remote switch (including remote control), internal sensor, or timer; or 

providing continuous functions, including information or status displays (including clocks) or 

sensor-based functions. Id. Off mode is defined as the condition in which an energy-using piece 

of equipment is connected to a main power source, and is not providing any standby or active 

mode function. Id. 

To satisfy the EPCA definitions of standby mode and off mode (42 U.S.C. 6295(gg)(1)), 

the lamp must not be providing any active mode function (i.e., emitting light). DOE determined 

that it is not possible for GSLs included in the scope of this rulemaking to meet the off-mode 

criteria because there is no condition in which a GSL is connected to main power is not already 

in a mode accounted for in either active or standby mode. DOE notes the existence of a small 

number of commercially available GSLs that operate in standby mode. DOE discusses GSLs that 

operate in standby mode in further detail in sections 2.3.5.4, 2.5.3.9, and 2.11. 

2.3 SCOPE OF LAMPS

In this section, DOE discusses specific issues and comments related to the scope of lamps 

included in this rulemaking. The term, general service lamp, includes general service 

incandescent lamps, compact fluorescent lamps, general service light-emitting diode lamps, 

organic light-emitting diode lamps, and any other lamps that the Secretary determines are used to 

satisfy lighting applications traditionally served by general service incandescent lamps; however, 

this definition does not apply to any lighting application or bulb shape excluded from the 

“general service incandescent lamp” definition, or any general service fluorescent lamp or 

incandescent reflector lamp. (See 42 U.S.C. 6291(30)(BB)) In the following sections, DOE 

discusses each part of this definition to clearly define the scope of this rulemaking. 

2.3.1 General Service Incandescent Lamps

As stated previously, GSILs are included in the definition of GSL. The definition of 

“general service incandescent lamp” is as follows: 

General service incandescent lamp means a standard incandescent or halogen type lamp 

that is intended for general service applications; has a medium screw base; has a lumen 

range of not less than 310 lumens and not more than 2,600 lumens or, in the case of a 

modified spectrum lamp, not less than 232 lumens and not more than 1,950 lumens; and 

is capable of being operated at a voltage range at least partially within 110 and 130 volts; 

however this definition does not apply to the following incandescent lamps— 

(1) An appliance lamp;

(2) A black light lamp; 

(3) A bug lamp; 

2-9 
(4) A colored lamp; 

(5) An infrared lamp; 

(6) A left-hand thread lamp; 

(7) A marine lamp;

(8) A marine signal service lamp;

(9) A mine service lamp;

(10) A plant light lamp;

(11) A reflector lamp;

(12) A rough service lamp; 

(13) A shatter-resistant lamp (including a shatter-proof lamp and a shatter-protected 

lamp);

(14) A sign service lamp; 

(15) A silver bowl lamp; 

(16) A showcase lamp; 

(17) A 3-way incandescent lamp;

(18) A traffic signal lamp;

(19) A vibration service lamp; 

(20) A G shape lamp (as defined in ANSI C78.20) (incorporated by reference; see § 

430.3) and ANSI C79.1-2002 (incorporated by reference; see § 430.3) with a diameter of 

5 inches or more; 

(21) A T shape lamp (as defined in ANSI C78.20) (incorporated by reference; see § 

430.3) and ANSI C79.1-2002 (incorporated by reference; see § 430.3) and that uses not 

more than 40 watts or has a length of more than 10 inches; and 

(22) A B, BA, CA, F, G16-1/2, G-25, G30, S, or M-14 lamp (as defined in ANSI C79.1-

2002) (incorporated by reference; see § 430.3) and ANSI C78.20 (incorporated by 

reference; see § 430.3) of 40 watts or less. 

10 CFR 430.2 

The Consolidated Appropriations Act, 2014 (Public Law 113-76, January 17, 2014; 

hereafter referred to as the “Appropriations Rider”), in relevant part, restricts the use of 

appropriated funds in connection with several aspects of DOE’s incandescent lamps energy 

conservation standards program. Specifically, section 322 states that none of the funds made 

available by the Act may be used to implement or enforce standards for GSILs, intermediate base 

incandescent lamps and candelabra base incandescent lamps. Thus, DOE is not considering 

GSILs, intermediate base incandescent lamps or candelabra base incandescent lamps in this 

rulemaking. DOE received several comments on the inclusion of GSILs in the scope of this 

rulemaking. 

2.3.1.1 Appropriations Rider

DOE received comments on its interpretation of the Appropriations Rider. NEMA and 

ASAP requested for DOE to elaborate on its conclusion to not include lamps that meet the 

definition of GSIL in the GSL rulemaking due to the Appropriations Rider. NEMA and ASAP

asked for more background information on this decision process because the current 

interpretation of the Appropriations Rider will reduce DOE’s flexibility and become a hindrance 

to the best outcomes for manufacturers, consumers, and the environment. (NEMA, Public 

2-10
Meeting Transcript, No. 19 at pp. 14-15; ASAP, Public Meeting Transcript, No. 19 at pp. 16-17, 

19-20) 

California Investor-Owned Utilities (CA IOUs), CEC, and Earthjustice and the Northwest 

Energy Efficiency Alliance (NEEA) commented that GSILs should be included within the 

rulemaking and cited sections of 42 U.S.C. 6295(i)(6) as support. Specifically, CA IOUs, CEC, 

Earthjustice, and NEEA commented that per section 42 U.S.C. 6295(i)(6)(A)(i)(I), DOE must 

determine whether the standards for GSLs should be amended to become more stringent than the 

GSIL standards specified in paragraph (1)(A). CA IOUs, CEC, Earthjustice, and NEEA cited 42 

U.S.C. 6295(i)(6)(A)(ii)(I), which states that the GSL rulemaking shall not be limited to GSILs, 

thereby including GSILs in the rulemaking. (CA IOUs, No. 18 at p. 2; CEC, No. 11 at pp. 7-12; 

Earthjustice and NEEA, No. 12 at p. 2) CA IOUs and CEC further noted that 42 U.S.C. 

6295(i)(6)(A)(ii)(II) states that the rulemaking shall include a minimum 45 lm/W standard for all 

GSLs, which includes GSILs by definition. (CA IOUs, No. 18 at p. 2; CEC, No. 11 at pp. 7-12) 

CEC and Earthjustice and NEEA commented that GSLs are defined in 42 U.S.C. 

6291(30)(BB)(i)(I) as including GSILs, thus making DOE obligated to evaluate amended 

standards for the lamps. (CEC, No. 11 at pp. 7-12; Earthjustice and NEEA, No. 12 at p. 2) CEC 

concluded that legal precedent requires that if the plain language of a statute is clear, effect must 

be given to the intent of that statute, which in this case requires DOE to consider GSILs. (CEC, 

No. 11 at p. 8) 

DOE acknowledges that 42 U.S.C. 6295(i)(6) authorizes DOE to evaluate energy 

conservation standards for GSLs, which, by definition, includes GSILs. However, DOE is 

restricted currently by the Appropriations Rider from using appropriated funds to implement or 

enforce standards for GSILs and therefore is not including GSILs in the GSL rulemaking. If the 

limitation on DOE’s use of appropriated funds regarding new standards for GSILs is removed 

during the course of this rulemaking, DOE can at that point consider revising the scope of the 

rulemaking to include GSILs. 

NEMA commented that excluding GSILs from the rulemaking is not the most obvious 

interpretation of the Appropriations Rider because NEMA does not believe it prevents the 

Secretary from making a decision for each of the lamp types included in the scope of the 

rulemaking, therefore satisfying all obligations of 42 U.S.C. 6295(i)(6)(A)(i-iv). NEMA 

commented that the Secretary can decide not to amend standards in 10 CFR 430.32(x) but 

promulgate or amend standards for other GSLs without constituting as implementing 10 CFR 

430.32(x). (NEMA, No. 15 at p. 7) Earthjustice and NEEA commented that adopting new, more 

stringent standards for GSILs would not render the Appropriations Rider meaningless, as it 

would still apply to existing GSIL standards. (Earthjustice and NEEA, No. 12 at p. 3) CA IOUs 

commented that the current rulemaking would neither implement, nor enforce the previous 

standard but rather propose and adopt new standards for a newly defined group of lamps. CA 

IOUs noted that if Congress’s intent were to prevent DOE from developing new standards for 

GSLs, it would have said that DOE could not use funds to carry out EISA requirements or amend 

existing GSIL standards in any way. (CA IOUs, No. 18 at p. 2) 

As noted previously, DOE is restricted by the Appropriations Rider from including 

GSILs in its analysis at this time.

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CA IOUs also stated that even if setting new standards for GSLs were considered to be 

implementing existing standards, this would not be an issue until a final rule adopted the 

standards and set an effective date. CA IOUs commented that DOE should include GSILs in the 

rulemaking throughout the analysis period and revisit the issue in three years when the final rule 

is expected to be published. If at the end of the rulemaking DOE determines it is not able to 

adopt new standards for GSILs, DOE could remove them from the scope at that time. (CA IOUs, 

No. 18 at p. 2) Earthjustice and NEEA also jointly commented that DOE must at a minimum 

begin to conduct analysis necessary to ensure that DOE is prepared for the expiration of the 

Appropriations Rider. They stated that there is no reason that DOE cannot conduct analyses of 

the impact of a more stringent standard and the Appropriations Rider is due to expire before 

DOE must complete this rulemaking. (Earthjustice and NEEA, No. 12 at p. 3) 

As stated, because section 322 of the Appropriations Rider prohibits the expenditure of 

appropriated funds to implement or enforce GSILs, DOE is not including GSILs in the scope of 

the GSL rulemaking at this time. 

DOE received comments on the importance of analyzing GSILs as part of the market. 

NRDC, ASAP, et al. urged DOE to carry out EPCA’s intended more expansive view of lamps 

that serve general service lighting applications, thus enabling evaluation of standards on a 

technology neutral basis. NRDC, ASAP, et al. suggested that DOE has taken an inappropriately 

restrictive view of the Appropriations Rider and that GSILs should be included. (NRDC, ASAP, 

et al., No. 17 at p. 2) CEC was also concerned that DOE was not including all lamps that are 

direct substitutes within the rulemaking, such as GSILs, noting that it is impossible to set a 

meaningful technology-neutral standard as these lamps will gain a unique market advantage by 

not having the same standards apply. (CEC, No. 11 at pp. 6-7) 

NRDC, ASAP, et al. commented that even if DOE is forbidden from working on new 

GSIL standards, it must evaluate GSIL technology in order to carry out its statutory obligations 

with respect to other GSLs. NRDC, ASAP, et al. commented that carrying out an evaluation of 

the GSIL market and technologies does not further the implementation or enforcement of GSIL 

standards and is completely outside the scope of the Appropriations Rider. NRDC, ASAP, et al.

also stated that GSILs represent the lowest efficacy product in the GSL market and therefore 

must be used as the baseline technology against which all improvements are measured. (NRDC, 

ASAP, et al., No. 17 at pp. 2-3) NRDC, ASAP, et al. commented that in order to develop a 

standard that meets the statutory criteria of section 325(o), DOE must evaluate a range of 

efficacy improvements from the baseline to the maximum technologically feasible (max-tech) 

design, which includes improved incandescent technologies. NRDC, ASAP, et al. concluded that 

even if the Appropriations Rider is interpreted to prevent application of a new standard for 

GSILs, GSIL technology might still provide the technical basis for the selected standard level. 

(NRDC, ASAP, et al., No. 17 at p. 3) 

DOE understands concerns regarding the analysis of standards on a technology neutral 

basis and therefore is not considering technology specific standards. However, as discussed 

previously, DOE is restricted by the Appropriations Rider from including GSILs in the analysis 

2-12
at this time. For more information on technology options DOE is considering, see section 2.5.2. 

For more information on the baseline lamps that DOE is considering, see section 2.7.3. 

2.3.1.2 Exempted Incandescent Lamps

DOE is also directed by 42 U.S.C. 6295(i)(6)(A)(i)(II) to determine whether the 

exemptions for certain incandescent lamps should be maintained or discontinued based, in part, 

on exempted lamp sales collected from manufacturers. In March 2013, DOE reviewed the 2012 

sales of rough service lamps, vibration service lamps, 3-way incandescent lamps, 2,601-

3,300 lumen general service incandescent lamps, and shatter-resistant lamps. DOE published a 

notice of data availability regarding the data collection and estimated future unit sales in which it 

concluded that these five types of incandescent lamps have not experienced significant growth 

since their exemption from federal efficiency standards. 78 FR 15891 (March 13, 2013). Because 

this assessment indicated no further action is necessary regarding these lamp types, DOE 

concluded in the framework document that they would not be included in the GSL rulemaking. 

CA IOUs, CEC, Earthjustice and NEEA, and NRDC, ASAP, et al. commented that DOE 

has not followed its obligations under 42 U.S.C. 6295(i)(6)(A)(i)(II), which requires the 

exemptions for certain lamps to be re-evaluated based in part on exempted lamp sales data, thus 

indicating that DOE is required to consider factors other than lamp sales. Further, CEC and

NRDC, ASAP, et al. stated that DOE is separately required to track the sales of rough service, 

vibration service, 3-way, 2,601-3,300 lumen output, and shatter resistant under 42 U.S.C. 

6295(1)(4)(b)(1) but must consider all 22 exemptions in this rulemaking. (CA IOUs, No. 18 at p. 

5; CEC, No. 11 at p. 15; Earthjustice and NEEA, No. 12 at pp. 3-5; NRDC, ASAP, et al., No. 17 

at p. 3) CEC also noted that DOE’s assessment in the framework document is legally invalid 

because DOE is not permitted to exclude exempted lamps from consideration at this stage and 

must address the exemptions as part of the rulemaking process. (CEC, No. 11 at p. 15) 

DOE agrees that 42 U.S.C. 6295(i)(6)(A)(i)(II) authorizes DOE to evaluate whether the 

22 exemptions for incandescent lamps should be maintained or discontinued based in part on 

exempted lamp sales data. DOE further acknowledges that it is authorized to consider factors 

beyond sales data in its assessment of the exemptions. As stated previously, DOE is prohibited 

by the Appropriations Rider from using appropriated funds to implement or enforce standards for 

GSILs and thus cannot modify the existing exemptions for GSILs in the rulemaking. If the 

limitations imposed by the Appropriations Rider are lifted, DOE can evaluate whether the 22 

exemptions for incandescent lamps should be maintained based on sales data and other factors. 

Soraa recommended that rough service lamps, vibration service lamps, 3-way 

incandescent lamps, 2,601-3,300 lumen general service incandescent lamps, and shatter-resistant 

lamps be included in the scope of the GSL rulemaking. (Soraa, No. 10 at p. 1) NRDC, ASAP, et 

al. noted that many of the exempted incandescent lamps are already being designed, labeled, and 

marketed as substitutes for incandescent lamps that are no longer compliant with standards. 

NRDC, ASAP, et al. provided examples of three exempted lamp types that demonstrate 

circumvention of standards. NRDC identified a multipack of vibration service lamps at a 

significantly lower price than the least costly compliant lamps and that are also lower efficacy 

than conventional incandescent lamps. Another example they noted were 3-way lamps which can 

be marketed as replacements to traditional incandescent lamps for a similarly low price. Lastly, 

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NRDC, ASAP, et al. commented that lamps just outside the lumen range (e.g., 2,601 lumens) are 

allowed to be sold without any efficacy improvements. NRDC urged DOE to consider extending 

the maximum lumen output range. (NRDC, ASAP, et al., No. 17 at pp. 4-5; NRDC, Public 

Meeting Transcript, No. 19 at pp. 71-72) ASAP also expressed concern over DOE’s decision not 

to thoroughly examine exempted lamps (i.e., three-way, rough service, high-output lamps). 

While these lamps all meet a particular market niche and need, which is the reason they are 

exempted, they do not deliver energy savings like lamps compliant with the standards 

promulgated by EISA do. ASAP further noted the potential risk for a loophole and also an 

opportunity to improve the efficacy of these lamps, and therefore ASAP requested DOE further 

evaluate these lamp types. (ASAP, Public Meeting Transcript, No. 19 at pp. 21-22) 

CA IOUs shared NRDC’s sentiments for DOE to strongly consider standards for the 

exempted incandescent lamp types, as they have seen a huge amount of shelf space become 

available to exempted lamp types. CA IOUs noted that DOE must consider other factors besides 

its assessment that there were not sufficient sales. CA IOUs commented that as the EISA Phase 1 

standards require compliance, the pressure on the niche market will increase and more of these 

lamps will be produced and sold. (CA IOUs, Public Meeting Transcript, No. 19 at pp. 45-46) 

ASAP concurred with this comment and predicted that in all likelihood, sales of some of these 

exempted lamps are significantly larger than those of the additional categories DOE is 

considering, such as hybrid lamps and mercury vapor lamps. General Electric (GE) replied that 

3-way and higher lumen lamps are included in their annual surveys, so DOE has the ability to 

evaluate those to see if they are exempted lamp types of concern or not. (ASAP, Public Meeting 

Transcript, No. 19 at pp. 72-73; GE, Public Meeting Transcript, No. 19 at p. 73) 

DOE recognizes the possibility that exempted incandescent/halogen lamps could be used 

in general service applications. DOE notes that the sales volume of rough service, vibration 

service, 3-way incandescent/halogen, 2,601 – 3,300 lumen output, and shatter-resistant lamps is 

continuing to be monitored. Therefore, if sales of these lamp types increase substantially and the 

established threshold is crossed, a separate rulemaking will be initiated as authorized by 42 

U.S.C. 6295(l)(4). DOE further notes that it cannot modify exemptions as they pertain to GSILs. 

However, DOE has preliminarily determined that several of the exemptions for GSILs describe 

lamps that do not serve in general lighting applications and therefore has not included those 

lamps, regardless of the technology used, in the scope of this rulemaking.

DOE discusses its assessment of exemptions in the following relevant subsections.

ASAP asked whether all NEMA manufacturers participate in the EISA-required survey 

of exempted lamp types and if any non-NEMA manufacturers participate. GE responded that all 

NEMA manufacturers participate in the survey and that it was unlikely that non-NEMA 

manufacturers participate in the survey. ASAP expressed concern that the non-NEMA portion of 

the market is the area likely to see exploitation of potential loopholes regarding exempted lamps. 

ASAP noted that once one manufacturer exploits a loophole and starts getting a cost advantage 

and market share, it creates pressure for others to follow suit. ASAP also noted that it may make 

sense to develop standards for these products not only for loophole prevention but because many 

of these lamps are sold now and are a significant portion of residential energy consumption. 

(ASAP, Public Meeting Transcript, No. 19 at pp. 48-51; GE, Public Meeting Transcript, No. 19 

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at p. 49) NRDC, ASAP, et al. commented that included in the statute is the implication that sales 

data should only be part of the evaluation process for whether an exemption should be continued 

in this rulemaking and that the sales data should not only utilize NEMA members. Although it is 

appreciated that NEMA provided their sales data, NRDC, ASAP, et al. stated that NEMA does 

not cover all U.S. lamp sales and most attempts to circumvent the standards would occur with 

offshore brands and thus not appear in NEMA data. NRDC, ASAP, et al. suggested that DOE 

supplement the currently gathered data with sales data from utilities or market research firms. 

(NRDC, ASAP, et al., No. 17 at pp. 3,13) 

NEMA and GE commented that they are required to monitor the five exempted lamp 

types, and they will continue to honor their responsibility to the federal government to track and 

report on the sales figures of the exempted lamp types. GE noted that when one of the lamp 

types’ sales volume crosses the EISA-prescribed threshold, then it would be an appropriate time 

for DOE to consider standards. NEMA commented that until there is statistical proof that the five 

exempted lamp types are being exploited as loopholes, there is no cause to consider them for 

efficacy standards. (NEMA, Public Meeting Transcript, No. 19 at pp. 46-47; NEMA, No. 15 at p. 

21; GE, Public Meeting Transcript, No. 19 at p. 54) NRDC asked for further clarity on if the

NEMA survey includes sales of private label lamps. For example, many lamps sold at Home 

Depot or Wal-Mart are not labeled as Philips or GE but are made by those manufacturers and 

sold under a private label. NEMA responded that if NEMA manufacturers make it, regardless of 

the name on it, it is included in the survey. NRDC also noted that many small manufacturers who 

were previously small but now have increasing sales (e.g., Cree) need to be included in the 

NEMA dataset if they are not already. (NRDC, Public Meeting Transcript, No. 19 at pp. 51-52; 

NEMA, Public Meeting Transcript, No. 19 at p. 52) 

Regarding the data included in DOE’s monitoring of exempted lamp types, DOE notes 

that the manufacturers that participate in NEMA’s collection of shipment data each year are 

listed in the spreadsheet model comparing actual lamp sales with benchmark unit sales, which is 

published along with the notice of data availability.12 Additionally, as noted in the spreadsheet 

model, NEMA aggregates and adjusts company data using market share estimates in order to 

represent the entire U.S. market. Due to the restrictions imposed by the Appropriations Rider 

preventing DOE from using appropriated funds to implement or enforce the standards for GSILs, 

DOE is unable to modify exemptions for GSILs in this rulemaking. As stated previously, DOE 

will continue to monitor sales of the five exempted lamp types on an annual basis and will 

initiate an accelerated rulemaking as required by 42 U.S.C. 6295(l)(4) if the threshold is 

exceeded. 

DOE also received several comments suggesting that DOE project sales trends of the 

exempted incandescent/halogen lamp types. CA IOUs suggested that for each exempted lamp 

type, DOE should model future sales in 2020 to determine whether to set standards for them, 

rather than only looking retrospectively at lamp sales patterns. CA IOUs noted there would be 

significantly more pressure on the exempted lamp types in 2020 due to pressure from the 

backstop or standards. To do this, CA IOUs commented that DOE should assess whether the 

12 The historical spreadsheets showing comparisons of anticipated versus actual sales is available online

at: http://www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/63. 

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lamp could be utilized in the same sockets as covered GSLs, and whether the exempted lamp 

could be cost competitive with regulated GSLs if manufactured in bulk. If an exempted lamp 

type could meet these two requirements, DOE should forecast the expected increase in market 

share for this lamp when the efficacy standard for covered lamps becomes more stringent. CA 

IOUs concluded that DOE could then assess whether there is any energy savings potential for 

these exempted lamps, and whether to set standards for them. (CA IOUs, No. 18 at pp. 5-6; CA 

IOUs, Public Meeting Transcript, No. 19 at pp. 53-54) NRDC urged caution to not make 

assumptions about the specialty or exempted lamps because inexpensive 60 W incandescent 

lamps are still available, so there is currently less motivation for manufacturers and consumers to 

shift to niche lamps that have low sales, but that market trend could escalate in the future. 

(NRDC, Public Meeting Transcript, No. 19 at pp. 25-26) CEC also commented that DOE failed

to consider the effect of the phase out of 60 W and 40 W incandescent lamps on exempted lamp 

sales. (CEC, No. 11 at p. 15) 

As discussed previously in this section, DOE is prohibited by the Appropriations Rider 

from using appropriated funds to implement or enforce the standards for GSILs and therefore is 

not including GSILs in the scope of this rulemaking at this time. As such, DOE is unable to 

model the effect of standards for GSILs prescribed by EISA or project future trends of certain 

exempted incandescent/halogen lamps. 

2.3.2 Compact Fluorescent Lamps

CFLs are also included in the definition of GSL, however the term “compact fluorescent 

lamp” is not currently defined in the CFR. CFLs can be integrated (e.g., medium base CFLs) or 

non-integrated (e.g., pin base CFLs). The Energy Policy Act of 2005 (EPAct 2005; Pub. L. 109–

58) amended EPCA by setting energy conservation standards for MBCFLs. DOE’s existing

energy conservation standards apply only to integrally ballasted (also referred to as selfballasted) MBCFLs. 10 CFR 430.32(u) The definition for “medium base compact fluorescent 

lamp” is as follows: 

Medium base compact fluorescent lamp means an integrally ballasted fluorescent lamp 

with a medium screw base, a rated input voltage range of 115 to 130 volts and which is 

designed as a direct replacement for a general service incandescent lamp; however, the 

term does not include— 

(1) Any lamp that is— 

(i) Specifically designed to be used for special purpose applications; and 

(ii) Unlikely to be used in general purpose applications, such as the applications 

described in the definition of “General Service Incandescent Lamp” in this section; or

(2) Any lamp not described in the definition of “General Service Incandescent Lamp” in 

this section that is excluded by the Secretary, by rule, because the lamp is— 

(i) Designed for special applications; and 

(ii) Unlikely to be used in general purpose applications. 

10 CFR 430.2 

2-16
As stated previously, the term “compact fluorescent lamp” is not currently defined but 

was determined to apply to both integrated and non-integrated CFLs in the preliminary analysis 

of the GSFL and IRL Standards Rulemaking.13 NRDC agreed that both screw-based and pin 

base CFLs should be included in the analysis. (NRDC, Public Meeting Transcript, No. 19 at pp. 

64-65) NEMA suggested a definition of “compact fluorescent lamp” adapted from the current 

definition of “medium base compact fluorescent lamp” in 10 CFR 430.2 to accommodate both 

integrated and non-integrated CFLs. NEMA suggested the definition to be “compact fluorescent 

lamp means an integrally or externally ballasted fluorescent lamp with a medium screw base or a 

pin base, a rated input voltage range of 115 to 130 volts and which is used in general lighting 

applications” and maintained the exemptions for lamps used in specialty applications from the 

MBCFL definition. (NEMA, No. 15 at p. 8) 

DOE is considering a definition for “compact fluorescent lamp” in the CFL TP 

rulemaking. Similar to NEMA’s proposed definition, DOE is considering defining the term 

“compact fluorescent lamp” to include both integrated and non-integrated CFLs. The definition 

that DOE is considering is as follows: 

Compact fluorescent lamp means an integrated or non-integrated single-ended, low 

pressure mercury electric-discharge source in which a fluorescing coating transforms 

some of the ultraviolet energy generated by the mercury discharge into light; however, 

the term does not include circline or U-shaped fluorescent lamps. 

DOE is also considering defining the terms “integrated” and “non-integrated” to further 

support the scope of this rulemaking. DOE developed technology neutral definitions that can be 

used to describe the various lamp technologies covered by this rulemaking. The definitions that 

DOE is considering are as follows: 

Integrated lamp means a lamp that contains all components necessary for the starting and 

stable operation of the lamp, does not include any replaceable or interchangeable parts, 

and is connected directly to a branch circuit through an ANSI base and corresponding 

ANSI standard lamp-holder (socket). 

Non-integrated lamp means a lamp that is not an integrated lamp.

DOE requests comment on the definitions under consideration for integrated lamp and 

non-integrated lamp. 

In the framework document, DOE proposed including in this rulemaking all lamps that 

met the definition of “medium base compact fluorescent lamp” stated in 10 CFR 430.2. DOE 

noted that, as stated in the definition, MBCFLs designed for special purpose applications and 

unlikely to be used in general purpose applications are exempted from standards. For 

determining such non-general applications, the definition specifically references the GSIL 

definition, which lists several lamp types, such as reflector lamps, not considered for use in 

13 The preliminary analysis technical support document for the GSFL and IRL Standards Rulemaking is available at 

www.regulations.gov/#!documentDetail;D=EERE-2011-BT-STD-0006-0022. 

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general service applications. Thus, in the framework document DOE interpreted the GSIL 

exemptions as also applying to MBCFLs.

In this preliminary analysis, DOE reassessed its interpretation of the exemptions from the 

MBCFL definition for MBCFLs used in specialty applications. Upon further consideration, DOE 

believes that because the definition of GSL in 42 USC §6291(30)(BB)(i) explicitly states that the 

term includes CFLs, and is not in any way limited to a particular base type of CFL, the intent of 

the definition was to consider all CFLs to be GSLs. Thus, DOE preliminarily concluded that the 

exemptions for the lamp types listed in the GSIL definition at 42 USC §6291(30)(D)(ii), referred 

to in the GSL definition, do not automatically apply to the MBCFLs included in the GSL 

rulemaking. Otherwise, the inclusion of CFLs in the definition of GSL would be a nullity. DOE 

conducted a separate assessment to determine if there are MBCFLs that are designed for 

specialty use and therefore cannot provide overall illumination. DOE identified MBCFLs that 

were designed for specialty applications and are not able to provide overall illumination,

including black light lamps, bug lamps, colored lamps, plant light lamps, and silver bowl lamps. 

DOE is considering providing exemptions for these specialty applications, which are discussed 

further in section 2.3.5. DOE requests comment on the MBCFLs identified for specialty 

applications that cannot provide overall illumination and if there are other MBCFLs that should 

be considered.

As described previously, DOE determined that the term “compact fluorescent lamps” is 

not limited to MBCFLs. DOE therefore concluded that both integrated and non-integrated CFLs

could be considered in the GSL rulemaking. Section 2.3.5 discusses additional CFLs for which 

DOE is considering establishing standards. 

2.3.3 General Service LED Lamps

General service LED lamps are included in the definition of GSL. LED means a p-n 

junction solid state device of which the radiated output, either in the infrared region, the visible 

region, or the ultraviolet region, is a function of the physical construction, material used, and 

exciting current of the device. 10 CFR 430.2 Similar to CFLs, LED lamps can be integrated or 

non-integrated. DOE proposed a definition for “integrated LED lamp” in a test procedure 

SNOPR for LED lamps (hereafter “LED TP SNOPR”). 79 FR 32048 (June 3, 2014). The 

proposed definition is as follows:

Integrated light-emitting diode lamp means an integrated LED lamp as defined in 

ANSI/IESNA RP–16 (incorporated by reference; see § 430.3).

As stated in the LED TP SNOPR, the ANSI/IESNA standard defines integrated LED 

lamps as comprising the LED source (the LED packages [components] or LED arrays 

[modules]), LED driver, ANSI standard base, and other optical, thermal, mechanical and 

electrical components such as phosphor layers, insulating materials, fasteners to hold 

components within the lamp together, and electrical wiring. The LED lamp is intended to 

connect directly to a branch circuit through a corresponding ANSI standard socket. 79 FR at 

32021-22 (June 3, 2014).

2-18
Although 10 CFR 430.2 defines the term “light-emitting diode or LED” and DOE has 

proposed a definition for “integrated light-emitting diode lamp,” DOE does not currently have a 

definition for “general service LED lamp.” NEMA proposed definitions for LED lamps included 

in the scope of this rulemaking based on adapting definitions from ENERGY STAR Lamps 

Specification V1.1. NEMA proposed defining integral screw base LED lamp as an “integrated 

assembly comprised of LED packages (components) or LED arrays (modules), LED driver, 

medium screw base and other optical, thermal, mechanical, and electrical components. The 

device is intended to connect directly to the branch circuit through a corresponding screw based 

lamp-holder (socket).” NEMA also proposed a definition for integral pin base LED lamp as “an 

integrated assembly comprised of LED packages (components) or LED arrays (modules), LED 

driver, pin base, and other optical, thermal, mechanical, and electrical components. The device is 

intended to connect directly to the branch circuit through a corresponding GU pin base lamp 

holder (socket).” (NEMA, No. 15 at p. 8)

DOE appreciates NEMA’s proposals for definitions to support the LED lamps covered in 

this rulemaking. As stated previously, DOE has tentatively determined that the term general 

service LED lamp includes both integrated and non-integrated LED lamps. Therefore, DOE has 

decided to propose a more general definition similar to the definition proposed for “compact 

fluorescent lamp” discussed in section 2.3.2 to clearly explain this determination. DOE is 

proposing the following definition for general service LED lamp:

General service light-emitting diode (LED) lamp means an integrated or non-integrated 

LED lamp designed for use in general lighting applications (as defined in 430.2).

As stated in the definition, general service LED lamps are used in general lighting 

applications. In the framework document, DOE considered including in this rulemaking all LEDs 

that serve general lighting applications and are not the lamp types or shapes excluded from the 

GSIL definition in 42 USC §6291(30)(D)(ii). As discussed in section 2.3.2, DOE reassessed its 

interpretation of the exemptions from the GSIL definition, referred to in the GSL definition, and 

determined that because the definition of GSL in 42 USC §6291(30)(BB)(i) explicitly states that 

the term includes general service LEDs, the intent of the definition was to consider all general 

service LEDs to be GSLs. DOE determined that the exemptions for certain bulb shapes and 

lighting applications in the GSIL definition do not generally apply to the other lamp types 

included in the definition of GSL. Otherwise all LED lamps would be considered exempt, 

rendering the inclusion of LED lamps in the GSL definition a nullity. In this preliminary 

analysis, DOE assessed whether LED lamps exist that are designed for specialty applications and 

therefore cannot provide overall illumination. DOE identified LED lamps that were designed for 

specialty applications and are not able to provide overall illumination, including black light 

lamps, bug lamps, colored lamps, plant light lamps, and silver bowl lamps. DOE is considering 

providing exemptions for these specialty applications, which are discussed further in section 

2.3.5. DOE requests comment on the LED lamps identified for specialty applications that cannot 

provide overall illumination and if there are other LED lamps that should be considered. DOE 

also requests comment on its proposed definition for general service LED lamp. 

As described previously, DOE determined that the term “general service LED lamp” is 

not limited to integrated LED lamps. DOE therefore concluded that both integrated and non2-19
integrated LED lamps could be considered in the GSL rulemaking. Section 2.3.5 discusses LED

lamps for which DOE is considering establishing standards.

2.3.4 OLED Lamps

OLED lamps are included in the definition of GSL. OLED means a thin-film lightemitting device that typically consists of a series of organic layers between two electrical 

contacts (electrodes). 10 CFR 430.2 OLEDs are diffuse light sources made of thin layers of 

carbon-based semiconductor material. The layer-based construction tends to support 

development of large, flat surfaces rather than traditional lamp shapes. Because OLEDs are an 

emerging technology, the commercial availability of OLEDs is very limited. Further, products 

that are available are not used in general lighting applications due to their size and shape. The 

OLEDs that are available are marketed for accent lighting, interior design, or are sold integrated 

into fixtures. In addition, due to the emerging nature of the technology and the limited 

commercial availability of OLEDs, it is unclear whether the efficacy of existing OLED products 

can be improved. For these reasons, in the framework document DOE considered not 

establishing standards for OLED lamps in this rulemaking.

DOE received comments on its consideration to not establish standards for OLED lamps 

at this time. NRDC, ASAP, et al. commented that they would not oppose DOE leaving out 

OLED lamps from this rulemaking and phase of review of GSL energy conservation standards. 

(NRDC, ASAP, et al., No. 17 at p. 10) NEMA agreed that it is too early to set standards for 

OLEDs. NEMA noted that the market is just beginning to see the earliest applications of this 

technology and is expected to rapidly evolve. NEMA concluded that there is insufficient 

experience, technology evolution, and commercial availability to justify including them in the 

scope of the rulemaking. (NEMA, No. 15 at p. 8; GE, Public Meeting Transcript, No. 19 at p. 67)

DOE agrees that it would be premature to establish standards for OLED lamps at this 

time. As noted in the framework document and by NEMA, OLED lamps are an emerging 

technology with limited commercial availability. Further, DOE notes that it remains unclear if 

the efficacy of existing OLED product can be improved. For these reasons, DOE is maintaining 

its decision to not consider establishing standards for OLED lamps in this preliminary analysis. 

NRDC commented that a definition for OLED lamp is necessary to distinguish between 

LED lamps and OLED lamps, especially if no standard will be set for OLED lamps. (NRDC, 

Public Meeting Transcript, No. 19 at p. 68) DOE agrees that a definition for OLED lamp is 

necessary to clearly define the scope of this rulemaking. DOE is considering defining OLED 

lamps as follows:

Organic light-emitting diode or OLED lamp means an integrated or non-integrated lamp

that uses OLEDs as the primary source as light.

DOE requests comment on its consideration to continue to not establish standards for

OLED lamps in this rulemaking. DOE also requests comment on its proposed definition for 

OLED lamp. 

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2.3.5 Other Lamps

Pursuant to the definition of GSL, DOE has the authority to consider additional lamps 

that it determines are used to satisfy lighting applications traditionally served by GSILs. In the 

framework document, DOE stated that the definition of GSIL indicates that GSLs are: (1) 

typically intended for general service applications; (2) have a medium screw base; (3) emit 

between 310 and 2,600 lumens; and (4) are capable of being operated at a voltage range at least 

partially within 110 and 130 V. DOE defines the term “general lighting application” as follows:

General lighting application means lighting that provides an interior or exterior area with 

overall illumination. 

10 CFR 430.2

Thus, in the framework document, lamps that met the four criteria outlined in the 

definition of GSIL were proposed to be included in the scope of coverage, regardless of the 

technology used to produce light. DOE received comments regarding the scope of coverage of 

this rulemaking.

CEC commented that DOE should include lamps within the rulemaking, regardless of 

socket type, because the application is to provide general, omnidirectional illumination. CEC 

cited that the definition of GSLs includes any lamp that can satisfy lighting applications 

traditionally served by GSILs and does not preclude certain lamps based on their socket type. 

CEC noted that there are already several socket types other than medium screw bases, including 

candelabra, intermediate, pin, and GU24 bases, which are currently serving the same purpose as 

GSLs, have significant sales volumes, and therefore should be included in this rulemaking. 

(CEC, No. 11 at p. 17) Soraa also recommended that DOE not limit the GSL definition by base 

type, as there are many base types that can be used in general service applications. (Soraa, No. 

10 at p. 2)

DOE agrees with CEC and Soraa that a socket or base type does not preclude the use of a 

lamp in general service applications and recognizes that lamps with base types other than 

medium screw bases can provide overall illumination. Therefore, DOE has revised its criteria for

lamps meeting the definition of GSL stated in the framework, including the requirement for a 

GSL to have a medium screw base. 

In this preliminary analysis, DOE has taken a broad interpretation for what can be 

considered a GSL. In this broad interpretation, GSLs are lamps intended to serve in general 

lighting applications. As noted previously, a general lighting application is defined in 10 CFR 

430.2 as lighting that provides an interior or exterior area with overall illumination.

DOE believes that several different base types can be used in general lighting 

applications, and that GSLs utilize an ANSI base to ensure they can be used in sockets 

commonly found in residential, commercial, and industrial fixtures. Therefore, DOE considers 

GSLs to have an ANSI base. DOE also believes that lumen output can restrict a lamp’s use in 

general lighting applications. DOE does not believe that lamps with lumen outputs below 310 

lumens are intended for use in general lighting applications because their low lumen output is not 

2-21
sufficient for overall illumination. Thus, DOE considers GSLs to have a lumen output of at least 

310 lumens. Additionally, DOE believes that lamps with operating voltage outside the range of 

110 to 130 V can be used in general lighting applications. Specifically, DOE believes that both 

lamps operating on line voltage (i.e., connects directly to a branch circuit) and lamps operating 

on low voltage (i.e., requires the use of a transformer) can provide overall illumination. 

Therefore, DOE does not consider GSLs to have a specific voltage range.

DOE also considered whether lamps designed or labeled for specific applications could 

provide overall illumination and therefore met the definition of general service lamp. DOE 

determined that the exemptions for specialty applications listed in 42 U.S.C. 6291(30)(D)(ii) are 

only applicable to GSILs. However, DOE is considering in this rulemaking whether any 

exemptions for specialty applications are needed for other GSLs. DOE received several 

comments on if exemptions for specialty applications were necessary. 

NRDC, ASAP, et al. and CA IOUs commented that if more energy efficient lamps can 

provide the same services as the exempted lamps, then those exemptions should be discontinued 

and the lamps should be included in the scope. (NRDC, ASAP, et al., No. 17 at p. 6; CA IOUs, 

No. 18 at p. 6) NRDC, ASAP, et al. commented that DOE should also consider the risk of lamps 

circumventing standards, specifically whether exempted lamps can be used for general service 

illumination and whether lamps, if exempted, could be sold at prices lower than compliant 

lamps. NRDC, ASAP, et al. noted that sales data could be useful in the assessment of 

circumvention but should not be the only consideration. In situations where an exempted product 

has a risk of circumvention, but cannot feasibly become more efficient, NRDC, ASAP, et al.

recommended that DOE consider creating a separate product class or narrowing the definitions 

of the exempted lamp categories. (NRDC, ASAP, et al., No. 17 at p. 4) 

DOE agrees that factors, including the technological feasibility of offering the exempted

lamp’s utility at a higher level of efficacy and potential circumvention of standards, are 

important considerations for this rulemaking. When determining whether an exemption for a 

specialty application is necessary, DOE assessed whether the lamp types could provide overall 

illumination and therefore could be used in general lighting applications. If DOE determined that 

the lamp could be used to provide overall illumination, but also offered a separate feature that 

was valued by consumers, DOE ensured that the utility provided by the lamp was offered at the 

highest efficacy levels. 

Although the exemptions that apply to GSILs do not automatically apply to other lamp 

technologies, DOE considered whether these exemptions should be continued. DOE assessed 

whether each specified lamp type provides overall illumination and therefore can be used in 

general lighting applications. DOE has preliminarily determined that appliance lamps, black 

lights, bug lamps, colored lamps, infrared lamps, marine signal lamps, mine service lamps, plant 

lights, sign service lamps, silver bowl lamps, showcase lamps, and traffic signal lamps cannot 

provide overall illumination and therefore cannot be used in general lighting applications. DOE 

found the lumen output of these lamps, when provided by manufacturers, was insufficient to 

provide overall illumination. DOE notes that for many of the lamp types listed, such as colored 

lamps and bug lamps, the lumen output is not stated in manufacturer catalogs as providing lumen 

output is not the primary application. Therefore, DOE is considering not establishing standards 

2-22
for these lamp types under the GSL rulemaking because the lamps are intended for use in nongeneral applications. DOE requests comment on this decision.

DOE also reviewed left-hand thread lamps, marine lamps, reflector lamps, rough service 

lamps, shatter-resistant lamps, 3-way lamps, vibration service lamps, and lamps of several 

specific shapes (such as G, T, B, BA, CA, F, G16.5, G25, G30, S, and M14, as defined in ANSI 

C79.1-2002 and ANSI C78.20). Based on its assessment, DOE has preliminarily determined that 

these lamp types provide overall illumination and therefore can serve in general lighting 

applications and do not require an exemption from standards.

DOE received specific comments on several of the lamp types that DOE is considering 

establishing standards for in this rulemaking. NRDC, ASAP, et al. noted that 3-way lamps are 

offered in more efficient halogen, CFL, and LED technologies and therefore the exemption is no 

longer warranted. NRDC, ASAP, et al. also commented that LED lamps are a filament-less 

technology and therefore can serve as vibration service and rough service lamps. NRDC, ASAP,

et al. further noted that halogen, CFL, and LED lamps can use shatter-resistant coatings similar 

to traditional incandescent/halogen lamps. NRDC, ASAP, et al. concluded that if shatter resistant 

coatings affect efficacy, a separate product class may be warranted, rather than an exemption. 

(NRDC, ASAP, et al., No. 17 at p. 6)

As stated previously, DOE has preliminarily determined that 3-way lamps, vibration 

service lamps, rough service lamps, and shatter-resistant lamps are able to provide overall 

illumination and therefore can be used in general lighting applications. DOE also assessed 

whether the utility offered by these lamp types is available at higher levels of efficacy, which 

would indicate that there is no technological reason the utility could not be maintained in the 

future. DOE found that 3-way CFLs and LED lamps are available. Further, DOE found that one 

of the most efficacious GSLs currently available on the market is a 3-way LED lamp. Vibration

service lamps and rough service lamps are defined specifically in the context of 

incandescent/halogen technology. However, DOE believes the utility of these lamp types, as well 

as shatter-resistant lamps, is their service in applications where vibrations occur (such as in a 

ceiling fan) or in applications where broken glass due to shattering would be a safety hazard

(such as a food preparation area). DOE believes that LED lamps are inherently durable and 

resistant to shattering and thus can provide the necessary utility to serve in these applications. 

DOE also confirmed that shatter-resistant CFLs exist. DOE requests comment on the lamp types 

that DOE is considering not providing exemptions for in this GSL rulemaking.

CEC commented that the current list of exemptions exists from a perceived need for 

specialty lamps that provide a distinct utility and cannot meet efficacy standards. CEC noted that 

because the scope of the rulemaking is limited to medium screw bases, the specialty purpose 

lamps could continue to be distributed and sold in other base types without having to maintain 

the exemptions. CEC concluded that if DOE continues to limit the rulemaking to medium screw 

bases, it should remove all exemptions and define GSL to cover products in direct competition 

for general purpose lighting and include primary features, such as omnidirectional light, white 

light, and medium screw bases. (CEC, No. 11 at pp. 16-17)

2-23
As stated previously, DOE has taken a broad interpretation of GSL and is considering 

lamps with base types other than medium screw bases to be general service lamps because lamps 

with other base types, such as candelabra and GU24, are frequently used in general lighting 

applications. 

Soraa commented that the scope of lamps should be broadened to include all lamp types 

that are used in general service lighting applications today, such as reflector lamps. (Soraa, No. 

10 at p. 1) Soraa commented that DOE’s Lighting Market Characterization14 indicates that 

reflector (R), parabolic aluminum reflector (PAR), bulged reflector (BR), and multifaceted

reflector (MR) shaped lamps are used for general service lighting and make up a significant 

component of the energy consumption of the general lighting market. Soraa noted that if these 

lamps types are not included, there may be as much energy consumed by the remaining halogen 

reflector and low voltage display lamps as the regulated GSLs. (Soraa, No. 10 at p. 2) 

DOE agrees with Soraa that reflector lamps provide overall illumination and therefore 

can serve in general lighting applications. In this preliminary analysis, DOE has determined that 

reflector lamps are included in the broad interpretation of the scope of coverage of the GSL 

rulemaking. DOE notes, however, that the definition of GSL explicitly states that IRLs are not 

included. DOE addresses other reflector lamps that are included in the scope of this rulemaking 

in more detail in the subsections that follow.

DOE is considering defining terms in support of the scope of coverage. To further 

explain lamp types DOE identified for use in non-general applications, DOE is considering 

defining the term “colored lamp” as follows: 

Colored lamp means a colored fluorescent lamp, a colored incandescent lamp, or a lamp 

designed and marketed as a colored lamp and not designed or marketed for general 

lighting applications with either of the following characteristics (if multiple modes of 

operation are possible [such as variable CCT], either of the below characteristics must be 

maintained throughout all modes of operation): 

(1) A CRI less than 40, as determined according to the method set forth in CIE 

Publication 13.3 (incorporated by reference; see §430.3); or 

(2) A correlated color temperature less than 2,200 K or greater than 7,000 K as 

determined according to the method set forth in IES LM-66 or IES LM-79 as 

appropriate (incorporated by reference; see §430.3). 

DOE is also considering defining terms related to the lamp types that can serve in general 

lighting applications. Specifically, DOE is considering defining “reflector lamp” and “nonreflector” lamp as follows:

14 U.S. Department of Energy. 2010 U.S. Lighting Market Characterization. January 2012. Available 

at http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf. 

2-24
Reflector lamp means a lamp that has an R, PAR, BPAR, BR, ER, MR, or similar bulb 

shape as defined in ANSI C78.20 (incorporated by reference; see §430.3) and ANSI 

C79.1 (incorporated by reference; see §430.3) and is used to direct light.

Non-reflector lamp means a lamp that is not a reflector lamp.

To ensure that complete light fixtures with ANSI bases (e.g., certain retrofit kits) are not 

included in the scope of this rulemaking, DOE is considering defining the term light fixture.

DOE is considering defining the term based on the definition in the industry standard, 

ANSI/IESNA RP-16. The definition DOE is considering for light fixture is as follows:

Light Fixture means a complete lighting unit consisting of lamp(s) and ballast(s) (when 

applicable) together with the parts designed to distribute the light, to position and protect 

the lamps, and to connect the lamp(s) to the power supply.

DOE requests comment on the definitions under consideration in support of the scope of 

coverage of the GSL rulemaking.

Thus, for the purposes of this rulemaking, DOE considered lamps which are not or could 

not be considered in another rulemaking proceeding, have a lumen output of 310 lumens or 

greater, have an ANSI base, are not a light fixture, and are not designed and labeled for use in the 

following non-general applications, as meeting the definition of GSL: appliance lamps, black 

light lamps, bug lamps, colored lamps, infrared lamps, marine signal lamps, mine service lamps, 

plant light lamps, sign service lamps, silver bowl lamps, showcase lamps, and traffic signal 

lamps.

Although many lamp types meet the definition, DOE has tentatively decided to not set 

standards for several of these lamp types at this time. When evaluating GSLs, DOE considered 

standards for lamps when it concluded that standards were technologically feasible, 

economically justified, and would result in significant energy savings. DOE conducted a twophase review of specific lamp types to define which lamps would be analyzed in this rulemaking. 

DOE began by analyzing the potential for energy savings and technological feasibility. For the 

GSLs that passed those criteria, DOE conducted a full economic analysis in the LCC analysis 

and NIA. The following sections evaluate several lamp types and summarize which lamp types 

DOE is considering setting standards for at this time.

2.3.5.1 Lamps Addressed In Other Rulemakings

As discussed previously, DOE has the authority to consider additional lamp types that it 

determines are used to satisfy lighting applications traditionally served by GSILs. To limit the 

probability that one lamp type might be subject to two different standards, DOE did not consider 

adding lamp types that are or could be addressed in a separate rulemaking proceeding. For 

example, the general service fluorescent lamp rulemaking considered establishing standards for 

additional types of fluorescent lamps (such as 2-foot linear fluorescent lamps). While that 

rulemaking ultimately concluded that additional lamps should not be subject to standards, DOE 

did not consider the additional lamps evaluated as GSFLs to be candidates for coverage in the 

GSL rulemaking.

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In the framework document, DOE stated that it identified self-ballasted mercury vapor 

(SBMV) lamps that were marketed as GSIL replacements and determined that SBMV lamps 

were intended for general service applications. DOE received comments on including SBMV 

lamps in the scope of the GSL rulemaking.

NEMA commented that SBMV lamps should not be included in the scope of this 

rulemaking, as 10 CFR 431.282 defines a mercury vapor lamp as a high-intensity discharge 

(HID) lamp, which means it is covered by a different rulemaking. NEMA also stated that selfballasted mercury vapor lamps are not used in high volume and have very little energy savings 

potential. NEMA noted that the high prices and lumen output of these lamps make them an 

unlikely substitute for covered GSLs or potential loophole. NEMA further questioned the 

plausibility of consumers purchasing SBMV lamps considering existing public concern 

regarding the 2 milligrams of mercury in a CFL. (NEMA, No. 15 at pp. 7, 9; NEMA, Public 

Meeting Transcript, No. 19 at p. 71)

As stated previously, to limit the probability that one lamp type may be subject to two 

different standards, DOE is not considering lamp types in this preliminary analysis that are or 

could be addressed in a separate rulemaking proceeding. As noted by NEMA, mercury vapor 

lamps are defined as HID lamps. Because SBMV lamps could be addressed in a separate 

rulemaking, DOE is not considering including SBMV lamps in the scope of this GSL 

rulemaking. 

CEC commented that SBMV lamps should not be included in the scope of this 

rulemaking because EISA prohibited the sale of mercury vapor ballasts after January 1, 2008, 

which are used in SBMV lamps, thereby making the sale of SBMV lamps in the United States

illegal. Furthermore, CEC commented that sockets that are compatible with mercury vapor lamps 

are also compatible with other, higher-efficacy lighting technologies, so there would not be any 

loss in utility by removing these lamps from the market. However, CEC allowed that if evidence 

suggests that SBMV lamps do not use mercury vapor ballasts, or that there would be a 

significant utility loss, then they should be included in the scope of the rulemaking. (CEC, No. 

11 at p. 18)

While mercury vapor ballasts, other than specialty application mercury vapor ballasts, 

have been banned from import or production in the United States since January 1, 2008, the sale 

of SBMV lamps is not prohibited in the United States. (See 42 U.S.C. 6295(ee)) Notably, 42 

U.S.C. 6291(47) defines the term mercury vapor lamp as including self-ballasted screw base 

lamps. Mercury vapor ballast is later defined in 42 U.S.C. 6291(48) as a device that is designed 

and marketed to start and operate mercury vapor lamps intended for general illumination. Thus, a 

SBMV lamp is a separately defined covered product and the energy conservation standards 

prescribed by EISA prohibiting the sale of mercury vapor ballasts does not apply to SBMV 

lamps. However, because SBMV lamps can be considered under the HID lamp rulemaking, as 

mentioned previously, DOE is not considering SBMV lamps in the scope of this GSL 

rulemaking.

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DOE is considering defining the term mercury vapor lamp in support of the scope of 

coverage of this rulemaking. DOE is considering using the definition in 42 U.S.C. 6291(47) for 

mercury vapor lamp which is defined as follows:

Mercury vapor lamp means a high intensity discharge lamp, including clear, phosphorcoated, and self-ballasted screw base lamps, in which the major portion of the light is 

produced by radiation from mercury typically operating at a partial vapor pressure in 

excess of 100,000 Pa (approximately 1 atm).

DOE requests comment on its consideration to exclude from the scope of the GSL 

rulemaking lamps that are addressed in other rulemakings. 

2.3.5.2 Lamps without an ANSI Base

In the framework document, DOE considered general service lamps to have a medium 

screw base. In this preliminary analysis, DOE has taken a broader interpretation of the definition 

of general service lamp. As noted previously, DOE believes that GSLs use an ANSI base to 

ensure they can be used in sockets commonly found in residential, commercial, and industrial

fixtures. Thus, DOE considers general service lamps to have an ANSI base.

The Edison Electrical Institute (EEI) suggested that DOE include gas lamps within the 

scope of the GSL rulemaking as they provide overall illumination. EEI commented that although 

gas lamps have a small market share, they are competitive products and use a significant amount 

of energy. EEI noted that many gas lamps use continuously burning pilot lights and therefore use 

energy usage at all times, even when the fixture is producing no light. (EEI, No. 16 at pp. 4-5)

DOE conducted a survey of the market and was unable to identify any gas lamps with ANSI 

bases. Based on the criteria established in this preliminary analysis, DOE does not believe gas 

lamps meet the definition of general service lamp.

2.3.5.3 High Lumen Lamps (>2,600 Lumens)

DOE is considering lamps with a lumen output of at least 310 lumens as meeting the 

definition of a GSL. In the framework document, DOE considered including lamps with lumen 

output between 310 and 2,600 lumens. DOE maintains this lower bound in the preliminary 

analysis because lamps with lumen output less than 310 lumens do not provide sufficient overall 

illumination. However, DOE does not believe there is an upper bound on lumen output that can 

provide overall illumination.

DOE received a comment on the lumen output range considered in the framework 

document. NRDC, ASAP, et al. commented that incandescent/halogen lamps and CFLs can 

provide high lumen outputs, and therefore lamps with lumen output in the range of 2,601 – 3,300 

lumens should be included in the scope of this rulemaking. (NRDC, ASAP, et al., No. 17 at p. 6)

Regarding lamps with a lumen output greater than 2,600 lumens, DOE believes that these 

lamps can be used in overall illumination and therefore meet the definition of GSL. DOE also 

agrees that higher lumen output lamps exist in more efficient technologies (e.g., integrated and 

non-integrated CFLs). DOE notes that, as discussed in section 2.3.1, due to the restrictions of the 

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Appropriations Rider, DOE is unable to consider modifying existing exemptions for GSILs and 

therefore is not currently including GSILs with lumen output greater than 2,600 lumens in the 

scope of the rulemaking. DOE believes that establishing energy conservation standards for 

higher lumen lamps, while not also addressing higher lumen incandescent lamps, may ultimately 

increase national energy consumption. More efficient products typically have lower operating 

costs but higher initial costs relative to the baseline products available on the market. Because 

the GSILs with lumen outputs greater than 2,600 lumens are exempt from standards, consumers 

may choose to purchase incandescent lamps rather than more expensive CFL and LED lamps. 

Therefore, DOE is considering not establishing standards for GSLs with lumen outputs greater 

than 2,600 lumens at this time.

2.3.5.4 General Service Lamps that Operate in Standby Mode

DOE identified lamps that meet the definition of GSL and can operate in standby mode. 

See section 2.2.4 for more information on standby mode. Feedback from manufacturers during 

interviews indicated that few GSLs provide standby mode functionality. Manufacturers noted 

that only a handful of such lamps exist, and it is a niche market at this time. DOE also found,

based on manufacturer feedback, that GSLs that operate in standby mode use a variety of 

methods to achieve the desired functionality (e.g., remotely turn the lamp on or off, changing 

lamp color, dimming the lamp), which results in differing power consumption and utility 

provided. DOE believes that while such GSLs currently represent a very small fraction of the 

GSL market, the market share for GSLs that can operate in standby mode will increase over the 

analysis period. Thus, due to the increasing market share of these products, DOE is considering

establishing standards for GSLs with standby mode power at this time.

2.3.5.5 Integrated Lamps

As described in section 2.3.2, integrated lamps (also referred to as self-ballasted lamps) 

contain all components necessary to start and operate a lamp and directly connect to a branch 

circuit via an ANSI base. DOE considered integrated lamps that are not or could not be 

considered in another rulemaking proceeding, have a lumen output of 310 lumens or greater, 

have an ANSI base, are not a light fixture, and are not designed and labeled for use in the nongeneral applications described in section 2.3.5, to meet the definition of general service lamp. 

The following sections discuss these general service integrated lamps by base type and identify 

lamps for which DOE is considering establishing standards at this time.

Medium Screw Base

Medium screw base integrated lamps are offered in a variety of technologies and are also 

offered with or without a reflector. Medium screw base lamps are the most common lamps on 

the market, given the proliferation of the medium screw base socket. While most of these lamps 

are omnidirectional, many are also offered with reflectors, which are used to direct the light. 

Reflector lamps are commonly used in track lighting and recessed can light fixtures. Medium 

screw base integrated lamps provide overall illumination and are commonly found in residential, 

commercial, and industrial locations.

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Non-reflector medium screw base integrated lamps exist primarily in three technologies: 

incandescent/halogen, compact fluorescent, and LED.15 General service incandescent/halogen

lamps that have a medium screw base are addressed in section 2.3.1; DOE is not considering 

GSILs in this rulemaking due to the Appropriations Rider. MBCFLs are addressed in section 

2.3.2. As standards already exist for these products, this rulemaking considers whether to amend 

standards for MBCFLs. In the framework document, DOE stated that it identified lamps that can 

serve in general lighting applications that use a CFL as the primary lighting source and also 

contain either a halogen capsule or an LED. The hybrid lamps that DOE identified meet the 

definition of MBCFL, though the term “hybrid CFL” is not currently defined. DOE received 

comments on hybrid lamps. 

NEMA proposed the definition of a hybrid lamp to be “a lamp utilizing two or more 

lighting technologies to provide two or more different lighting functions.” (NEMA, No. 15 at p. 

9) 

DOE is considering a similar definition as proposed by NEMA for “hybrid CFL.” The 

definition under consideration in the CFL TP rulemaking is as follows:

Hybrid compact fluorescent lamp means a compact fluorescent lamp that incorporates 

one or more supplemental light sources of different technology. 

NRDC, ASAP, et al. commented that hybrid lamps should be included in the scope of the 

rulemaking, noting that that certain halogen-CFL hybrid lamps address the consumer complaint 

of long warm-up periods for CFLs. (NRDC, ASAP, et al., No. 17 at p. 10) On the other hand, 

NEMA commented that hybrid lamps are not used in sufficient volumes to warrant including 

these lamps under this rulemaking. (NEMA, No. 15 at p. 7) As noted, DOE has determined that 

the hybrid lamps identified meet the definition of MBCFL. Because MBCFLs are included in the 

scope of this rulemaking, as discussed in section 2.3.2, hybrid lamps are also included in the 

scope. 

Medium screw base integrated LED lamps are rapidly increasing their market share 

relative to incandescent/halogen and compact fluorescent technology. In the most recent lamp 

indices data published by NEMA for the fourth quarter of 2013, the market share of LED Ashape replacement lamps increased 42.3 percent over the previous quarter.16 Given their 

nontrivial market share, DOE has tentatively concluded that standards for medium screw base 

integrated LED lamps would result in significant energy savings. Technology for these lamps is 

rapidly changing, such that new generations of LED products have improved performance 

relative to products that entered the market six months before. In its Multi-Year Program Plan for 

solid state lighting, DOE published a target LED package efficacy for the year 2020 and 

identified areas that could potentially be improved to achieve the targeted efficacy, such as 

15 In addition, DOE identified non-reflector medium screw base integrated lamps available in mercury vapor 

technology. These lamps are discussed in more detail in section 2.3.5.1. 

16 NEMA. Halogen A-line Lamp Shipments Continue to Rise During Fourth Quarter. March 27, 2014. Available 

at: http://www.nema.org/news/Pages/Halogen-A-line-Lamp-Shipments-Continue-to-Rise-During-FourthQuarter.aspx. 

2-29
package efficiency, electrical efficiency, and power and phosphor conversion efficiency.17

Because further efficacy improvements are possible, DOE has tentatively concluded that 

standards for these lamps are technologically feasible. For these reasons, DOE conducted a full 

economic analysis for medium screw base integrated LED lamps in the LCC analysis and NIA. 

See chapters 8 and 10 of this TSD for more information. 

Reflector medium screw base integrated lamps are also typically offered with 

incandescent/halogen, compact fluorescent, or LED technology. As discussed in section 2.3.5, 

IRLs are specifically excluded from the definition of GSL and therefore will not be considered in 

this rulemaking. Based on data from the 2010 LMC, DOE determined that reflector CFLs 

compose less than 2 percent of the total inventory of lamps in the United States. The LED lamp 

data is not given by lamp shape, however LED lamps compose less than 1 percent of the total 

inventory of lamps in the United States, of which reflector LED lamps would be an even smaller 

portion. Although DOE believes that LED reflector lamps may compose a growing portion of the 

reflector lamp market, DOE believes that establishing energy conservation standards for these 

lamps may ultimately increase national energy consumption. As noted previously, more efficient 

products typically have lower operating costs but higher initial costs relative to the baseline 

products available on the market. Because IRLs are not considered in this rulemaking and would 

be subject to separate, less stringent efficacy requirements, consumers may choose to purchase 

IRLs rather than more expensive CFL and LED reflector lamps. Because IRLs are less 

efficacious, they require more energy to produce the same amount of light as CFLs and LED 

lamps and thus any shift to these products could increase overall energy consumption. For these 

reasons, DOE has tentatively decided to not establish energy conservation standards for reflector 

medium screw base integrated lamps at this time.

Candelabra and Intermediate Base

Candelabra and intermediate base integrated lamps are offered with 

incandescent/halogen, compact fluorescent, and LED technology. The candelabra base is the 

more common of the two base types – about 5 percent of product offerings compared to less than 

1 percent for the intermediate base. Candelabra and intermediate base integrated lamps provide 

overall illumination and are found primarily in residential locations. 

Non-reflector candelabra and intermediate base integrated lamps exist primarily in three 

technologies: incandescent/halogen, compact fluorescent, and LED. Incandescent/halogen lamps 

that have a candelabra or intermediate screw base are addressed in section 2.3.1; DOE is not 

considering these lamps in this rulemaking due to the Appropriations Rider. A review of 

compact fluorescent and LED product offerings indicates that few products are offered in these 

technologies compared to the number offered with incandescent/halogen technology. After 

reviewing the available product information, DOE does not believe it is appropriate to establish 

energy conservation standards for these lamps at this time. DOE found that a large number of 

CFL and LED candelabra and intermediate base lamps do not have standard ANSI shape 

designations. DOE believes these non-standard form factors could prevent the CFL and LED 

17 U.S. Department of Energy. Solid State Lighting Research and Development Multi-Year Program Plan.

May 2014. Available at: http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/ssl_mypp2014_web.pdf. 

2-30
lamps from serving in the same applications as lamps with incandescent/halogen technology, and 

thus these lamp types may not be available at higher levels of efficacy. For these reasons, DOE 

has tentatively decided to not establish energy conservation standards for non-reflector 

candelabra and intermediate base integrated lamps at this time.

At the time of this analysis, the vast majority of candelabra and intermediate base 

integrated lamps were omnidirectional. DOE identified one incandescent/halogen reflector 

candelabra base integrated lamp and a limited number of incandescent/halogen reflector 

intermediate base integrated lamps. However, as stated previously, DOE is not considering these 

lamp types due to the Appropriations Rider. DOE was unable to identify reflector candelabra 

base or intermediate base integrated lamps in CFL or LED technology. For these reasons, DOE 

does not believe that standards for reflector candelabra and intermediate base integrated lamps 

would result in significant energy savings. Therefore, DOE has tentatively decided not to

establish energy conservation standards for these lamps at this time.

Pin Base

DOE considers pin base integrated lamps to be integrally ballasted (if applicable) lamps

with plug-in lamp bases that operate on line voltage (i.e., connect directly to the branch circuit 

without the use of a transformer). Pin base integrated lamps are offered in a variety of 

technologies and are also offered with or without a reflector. Common pin base integrated lamps 

are tubular quartz halogen lamps, GU24 base lamps, and GU10 base lamps with a MR shape. Pin 

base integrated lamps provide overall illumination and are found predominately in residential 

and commercial locations. DOE is considering defining terms related to pin base lamps in 

support of the scope of this rulemaking. The terms DOE is considering are as follows: 

Pin base lamp means a lamp that uses a base type designated as a single pin base or

multiple pin base system in Table 1 of ANSI C81.61, Specifications for Electrics Bases 

(incorporated by reference; see §430.3).

GU24 base means the GU24 base standardized in ANSI C81.61 (incorporated by 

reference; see §430.3).

DOE requests comment on the definitions under consideration for pin base lamp and 

GU24 base. 

Non-reflector pin base integrated lamps are available with multiple pin bases and exist

with incandescent/halogen, CFL, and LED technology. The incandescent/halogen non-reflector 

pin base integrated lamps (e.g., G8 and G9 base tubular halogen quartz lamps) have few products 

available on the market. CFL and LED non-reflector pin base integrated lamps commonly use 

GU24 bases. Of the integrated pin bases considered, lamps with GU24 bases compose the vast 

majority of the market. The GU24 base was created as a substitute to the medium screw base to 

prevent the use of incandescent/halogen lamps. While GU24 lamps may not currently be sold in 

the same volume as medium screw base lamps, DOE expects their sales to increase considerably 

as a result of regulations and voluntary program specifications. For example, California’s 

Building Code Standards Title 24 requires high efficiency lighting to be installed, thus 

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prohibiting screw base sockets.18 Similarly, the ENERGY STAR Program Requirements Product 

Specification for Luminaires (Light Fixtures) Eligibility Criteria Version 1.2 specification 

prohibits the use of screw bases (e.g., E26) in luminaires in order to achieve ENERGY STAR 

certification.19 Given their expected market share, DOE has tentatively concluded that standards 

for non-reflector GU24 base integrated lamps would result in significant energy savings. 

Furthermore, because these lamps exist in varying levels of efficacy (i.e., CFL and LED 

technology), DOE has concluded that standards for these lamps would be technologically 

feasible. For these reasons, DOE conducted a full economic analysis for non-reflector GU24 

base integrated lamps in the NIA. See chapters 8 and 10 of this TSD for more information. 

Reflector pin base integrated lamps are also offered with multiple pin bases, but in 

contrast to non-reflector lamps, the GU10 base is the most common base for reflector lamps. 

Although products are offered with incandescent/halogen, CFL, and LED technology, there are 

very few CFL products and halogen and LED lamp options dominate the market. Although DOE 

believes these lamps compose a sizeable portion of the reflector lamp market, DOE does not 

believe it is appropriate to establish energy conservation standards for these lamps at this time. 

DOE does not believe that LED technology is currently able to provide the same utility as 

halogen technology in the MR16 lamp shape. MR lamps are used in recessed downlights and 

track lighting, typically in retail, hospitality, residential, and museum applications.

20 As noted by 

DOE’s CALiPER program, halogen MR16 lamps deliver focused illumination from their small 

(2 inch) diameter, have desirable color quality, are easy to use with controls, and are available 

with a range of different options (e.g., beam angle and intensity) and accessories (e.g., spread 

lenses). Given this combination of features, the conventional halogen MR16 lamp is one of the 

most difficult lamps for LED technology to successfully replicate.21 A recent report by DOE’s 

CALiPER program found that every LED MR16 that claimed to be a replacement for a halogen 

MR16 produced fewer lumens and had lower center beam intensity than would be predicted 

using the ENERGY STAR center beam intensity tool. While new products continue to enter the 

market, LED MR16s still do not offer the same lumen packages as available halogen MR16s 

(particularly above 500 lumens). This difference is likely because LED lamps must incorporate a 

driver into an already small form factor and struggle to efficiently dissipate heat to achieve 

optimal performance. Because more efficient replacements that maintain the same utility are not 

currently available, DOE has tentatively decided to not establish energy conservation standards 

for reflector pin base integrated lamps at this time. DOE requests comment on whether LED 

MR16 lamps are suitable replacements for incandescent/halogen reflector integrated MR16 

lamps. 

18 California Energy Commission’s Building Code Standards are available at: http://www.energy.ca.gov/title24/. 

19 ENERGY STAR® Program Requirements for Luminaires (Light Fixtures) Eligibility Criteria Version 1.2. 

December 21, 2012. Washington, DC. 

20 U.S. Department of Energy. CALiPER Application Summary Report 22: LED MR16 Lamps. June 2014. Available 

at http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/caliper_22_summary.pdf. 

21 Ibid. 

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Other Bases 

Additional base types exist for integrated lamps, including other screw bases, however 

DOE identified very few integrated non-reflector and reflector lamps with these base types. DOE 

has tentatively concluded that given their low market share, standards for non-reflector and 

reflector lamps with other bases such as mogul bases and bayonet bases would not result in 

significant energy savings. DOE requests comment on whether there are any integrated lamps 

with other bases that have a significant market share. 

2.3.5.6 Non-Integrated 

As described in section 2.3.2, non-integrated lamps (also referred to as externally 

ballasted lamps) are lamps that do not contain all components necessary for the starting and 

stable operation of the lamp. Non-integrated lamps require an external component, such as a 

ballast, driver, or transformer to operate on a branch circuit. DOE considered non-integrated 

lamps that are not or could not be considered in another rulemaking proceeding, have a lumen 

output equal to or greater than 310 lumens, have an ANSI base, are not a light fixture, and are 

not designed and labeled for use in the non-general applications described in section 2.3.5, to 

meet the definition of general service lamp. The following sections discuss general service nonintegrated lamps by base type and identify lamps for which DOE is considering establishing 

standards at this time. 

Screw Base 

Non-reflector and reflector screw base non-integrated lamps are very uncommon and are 

available in a limited range of technologies. DOE identified one non-reflector medium screw 

base non-integrated lamp that may meet the definition of GSL. The non-reflector screw base 

non-integrated lamp is a CFL intended to be used in marine applications and operates using a 

battery. Similarly, DOE identified few reflector screw base non-integrated lamps. The reflector 

screw base non-integrated lamp type it did identify is used for providing illumination in pool and 

spa applications. DOE has tentatively concluded that given their extremely low market share, 

standards for non-reflector and reflector screw base non-integrated lamps would not result in 

significant energy savings and is therefore not considering establishing standards for these 

products at this time. 

Pin Base

DOE considers pin base non-integrated lamps to be lamps that use a single pin base or 

multiple pin base system (as defined by ANSI 81.61) and operate using an external ballast, 

driver, or transformer. Pin base non-integrated lamps are offered in a variety of technologies and 

are also offered with or without a reflector. Pin base non-integrated lamps provide overall 

illumination and are found in residential, commercial, and industrial locations. Common lamp 

types considered pin base non-integrated lamps are pin base CFLs and low voltage 

incandescent/halogen lamps with or without a reflector. 

Although non-reflector pin base non-integrated lamps are available in 

incandescent/halogen, CFL, and LED technologies, CFLs are by far the most common type. As 

2-33
stated in the framework document, DOE determined that the term compact fluorescent includes

both integrated and non-integrated CFLs and therefore stated that it was considering including 

non-integrated, or pin base, CFLs in the scope of this rulemaking. Pin base CFLs are available in 

a variety of pin bases including 2-pin and 4-pin configurations such as the G24d-3 and G24q-3 

bases, respectively. For more detail on common base types of pin base CFLs, see section 2.7. 

DOE received comments regarding the inclusion of pin base CFLs in the scope of this 

rulemaking. 

NEMA advised DOE to reconsider whether to include pin base CFLs in this rulemaking. 

(NEMA, No. 15 at p. 7) NEMA commented that pin base CFLs are not a direct replacement for 

millions of incandescent screw base products and would require a consumer to purchase a new 

luminaire. NEMA stated that while the pin base CFL market is noticeable, it is minor and its 

growth comes from consumers purchasing new fixtures. (NEMA, Public Meeting Transcript, No. 

19 at p. 76) NEMA further commented that pin base CFLs are already at max-tech efficiency, 

and therefore there is no justification for including them in this rulemaking. NEMA noted that if 

DOE does include them in the rulemaking, the standard should be set at the current max-tech 

levels and should take into account the increased burden on the industry of the additional 

reporting and testing requirements for pin base CFLs. (NEMA, No. 15 at p. 9) 

DOE agrees with NEMA that the market share of pin base CFLs is not insignificant given 

the vast number of product offerings and common use in commercial applications. Given their 

nontrivial market share, DOE has tentatively concluded that standards for pin base CFLs could 

result in significant energy savings. As discussed in section 2.7, DOE identified some variation 

in levels of efficacy for non-integrated lamps and therefore believes standards are 

technologically feasible. For these reasons, DOE assessed whether standards for these lamps are 

economically justified. See chapter 10 of this TSD for more information.

Incandescent/halogen non-reflector pin base non-integrated lamps include quartz halogen 

lamps that operate on low voltage and thus require the use of a transformer. Common base types 

for these lamps include G4 and GY6.35 bases. Incandescent/halogen non-reflector pin base nonintegrated lamps have few products available on the market. A very limited number of LED nonreflector pin base non-integrated lamps with the same base types, and thus intended to replace 

the incandescent/halogen versions, are available on the market currently. DOE has tentatively 

concluded that given their low market share, standards for non-reflector pin base non-integrated 

lamps would not result in significant energy savings. Further, because LED technology is 

changing rapidly, DOE believes that establishing standards for these products may slow 

innovation in a market that appears to be developing. DOE requests comment on the market 

share and technological feasibility of increasing the efficacy of non-reflector pin base nonintegrated lamps.

Reflector pin base non-integrated lamps are also offered with multiple pin bases, but in 

contrast to non-reflector lamps, the GU5.3 base is the most common base and corresponds to the 

MR16 lamp shape. Although products are offered with incandescent/halogen, CFL, and LED 

technology, incandescent/halogen and LED lamp options dominate the market and there are very 

few CFL products. DOE received a comment on reflector pin base non-integrated lamps. Soraa

recommended that lamps that are driven by transformers, such as low voltage LED MR16 lamps, 

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should be included in the scope. Soraa commented that while this lamp was initially only used 

for projectors, it is now widely used in restaurants, hotels, and residential settings. (Soraa, No. 10 

at p. 2)

DOE agrees that MR16 lamps can be used in general lighting applications. Although 

DOE believes these lamps provide overall illumination and compose a sizeable portion of the 

reflector lamp market, DOE does not believe it is appropriate to establish energy conservation 

standards for these lamps at this time. For the same reasons described for reflector pin base 

integrated lamps in section 2.3.5.5, DOE does not believe that LED technology is currently able 

to provide the same utility as halogen technology in the MR16 lamp shape. Additionally, LED 

reflector pin base non-integrated lamps have the added complexity of needing to be compatible 

with an existing transformer. Because replacements that are more efficient and yet maintain the 

same utility are not currently available, DOE has tentatively decided not to establish energy 

conservation standards for reflector pin base integrated lamps at this time. DOE requests 

comment on whether LED MR16 lamps are suitable replacements for incandescent/halogen 

reflector non-integrated MR16 lamps.

Other Bases

DOE did not identify any additional base types for non-integrated lamps that meet the 

definition of GSL. DOE requests comment on whether there are any non-integrated lamps with 

other bases that meet the definition of GSL and the market share of these lamps. 

2.3.5.7 Summary of Lamps

In summary, while many different lamp types meet the definition of GSL, DOE is only

considering establishing standards in this rulemaking for the following lamps:

• Integrated, non-reflector, medium screw base lamps with a lumen output between 310 

and 2,600 lumens;

• GU24 base, non-reflector lamps with a lumen output between 310 and 2,600 lumens; and

• Non-integrated, non-reflector, pin base, CFLs with a lumen output between 310 and 

2,600 lumens.

Standards would not apply to the follow lamp types:

• OLED lamps

• Mercury vapor lamps

• IRLs

• GSFLs

• Light fixtures

• Appliance lamps

• Black light lamps

• Bug lamps

• Colored lamps

• Infrared lamps

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• Marine signal lamps

• Mine service lamps

• Plant light lamps

• Sign service lamps

• Silver bowl lamps

• Showcase lamps

• Traffic signal lamps

• GSILs that are:

o A left-hand thread lamp

o A marine lamp

o A reflector lamp

o A rough service lamp

o A shatter-resistant lamp (including a shatter-proof lamp and a shatter-protected

lamp)

o A 3-way incandescent lamp

o A vibration service lamp

o A G shape lamp (as defined in ANSI C78.20) (incorporated by reference; see

§430.3) and ANSI C79.1-2002 (incorporated by reference; see §430.3) with a

diameter of 5 inches or more 

o A T shape lamp (as defined in ANSI C78.20) (incorporated by reference; see

§430.3) and ANSI C79.1-2002 (incorporated by reference; see §430.3) and that

uses not more than 40 watts or has a length of more than 10 inches 

o A B, BA, CA, F, G16-1/2, G-25, G30, S, or M-14 lamp (as defined in ANSI

C79.1-2002) (incorporated by reference; see §430.3) and ANSI C78.20

(incorporated by reference; see §430.3) of 40 watts or less.

2.3.5.8 Summary of Definitions

In summary, DOE is considering defining the following terms in this rulemaking to support 

the scope of coverage: 

• Integrated lamp (discussed in section 2.3.2)

• Non-integrated lamp (discussed in section 2.3.2)

• General service LED lamp (discussed in section 2.3.3)

• OLED lamp (discussed in section 2.3.4)

• Colored lamp (discussed in section 2.3.5)

• Reflector lamp (discussed in section 2.3.5)

• Non-reflector lamp (discussed in section 2.3.5)

• Light fixture (discussed in section 2.3.5)

• Mercury vapor lamp (discussed in section 2.3.5.1)

• Pin base lamp (discussed in section 2.3.5.5)

• GU24 base (discussed in section 2.3.5.5)

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2.4 SCOPE OF METRICS

In this section, DOE discusses specific issues and comments related to the scope of 

metrics included in this rulemaking. The topics of discussion include revising existing metrics 

for MBCFLs and additional metrics under consideration for MBCFLs. 

As stated in section 2.2.1, this rulemaking satisfies the requirements under 42 U.S.C 

6295(m)(1) to review existing standards for MBCFLs, as CFLs are included in the definition of a 

GSL. EPAct 2005 amended EPCA by establishing energy conservation standards for MBCFLs. 

Performance requirements were specified for five metrics: (1) minimum initial efficacy; (2) 

lumen maintenance at 1,000 hours; (3) lumen maintenance at 40 percent of lifetime; (4) rapid 

cycle stress; and (5) lamp life. (42 U.S.C. 6295(bb)(1)) DOE received several comments on the 

authority to revise the existing metrics and consider additional metrics for lamp types included in 

the scope of this rulemaking.

ASAP noted that DOE intends to treat this rulemaking as the six-year review for the 

EPAct CFL standards and that as such, DOE is authorized by EPAct 2005 to consider revising 

existing quality specifications, such as the rapid cycle test, and adding new quality elements, 

such as power factor. ASAP asked whether DOE intends to evaluate these other elements of the 

CFL standard and if not, why they are not under consideration. (ASAP, Public Meeting 

Transcript, No. 19 at p. 24) Earthjustice and NEEA also suggested that DOE consider adopting 

additional requirements for MBCFLs. Earthjustice and NEEA added that under EPCA section 

325(bb) paragraph (2), DOE is authorized to adopt requirements for color rendering index (CRI), 

power factor, frequency, and start time using the August 9, 2001, ENERGY STAR® Program 

Requirements for CFLs Version 2.0, but they have failed to do so. (Earthjustice and NEEA, No. 

12 at p. 7) 

In addition to revising the existing requirements for MBCFLs, DOE has the authority to 

establish requirements for additional metrics including CRI, power factor, operating frequency, 

and maximum allowable start time based on the requirements prescribed by the August 9, 2001, 

ENERGY STAR® Program Requirements for CFLs Version 2.0, or establish other requirements 

after considering energy savings, cost effectiveness, and consumer satisfaction. (42 U.S.C. 

6295(bb)(2)-(3)) Therefore, as part of this rulemaking, DOE is reviewing whether all five 

existing metrics for MBCFLs should be amended and if additional performance requirements, 

including CRI, power factor, frequency, and start time, among others, should be added. 

NRDC commented that current CFL standards regulate performance characteristics, in 

addition to the efficacy of the product, and asked if DOE is open to including other metrics 

besides efficacy (e.g., power factor, stress test) for the other lamp types covered by the new 

standard. (NRDC, Public Meeting Transcript, No. 19 at p. 179) 

As discussed in section 2.2.1, DOE is directed to evaluate energy conservation standards 

for GSLs. (42 U.S.C. 6295(i)(6)(A)-(B)) The term “energy conservation standard” is defined, in 

relevant part, as a performance standard that prescribes a minimum level of energy efficiency or 

a maximum quantity of energy used. (42 U.S.C. 6291(6)(A)) Further, under 42 U.S.C. 6293, 

EPCA sets forth the criteria and procedures DOE must follow when prescribing or amending test 

procedures for covered products. EPCA provides that any test procedures prescribed or amended 

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under this section shall be reasonably designed to produce test results, which measure energy 

efficiency, energy use, or estimated annual operating cost of a covered product during a 

representative average use cycle or period of use and shall not be unduly burdensome to conduct. 

(42 U.S.C. 6293(b)(3)) Therefore, when considering energy conservation standards and test 

procedures, DOE is only authorized to evaluate performance standards and prescribe test 

procedures directly related to energy efficiency or energy used. DOE may consider other 

performance metrics related to quality if given explicit authority to do so for a covered product, 

as is the case with MBCFLs. Thus, for this rulemaking, DOE will not be evaluating performance 

metrics for covered lamp types other than MBCFLs. 

2.4.1 Existing Metrics for MBCFLs

DOE received several comments suggesting revisions to the existing metrics and 

recommendations for new metric requirements. NRDC, ASAP, et al. suggested that DOE adopt 

the latest ENERGY STAR specifications and test methods for each of the existing parameters, 

and added that this approach will likely not meet a great deal of opposition as most CFLs in 

today’s market already meet ENERGY STAR requirements. NRDC, ASAP, et al. further stated 

that a standard based on the latest ENERGY STAR specifications would set a minimum floor for

CFLs, thus providing energy savings from the minimum efficacy and performance requirements 

that are designed to prevent consumers from reverting to less efficient technologies due to 

premature failure or removal by unsatisfied customers. (NRDC, ASAP, et al., No. 17 at p. 11) 

ASAP agreed, noting that it would make sense to update the existing, outdated quality 

specifications copied from August 9, 2001, ENERGY STAR® Program Requirements for CFLs 

Version 2.0 to reflect current ENERGY STAR specifications. (ASAP, Public Meeting 

Transcript, No. 19 at pp. 56-57) 

DOE is considering revising existing metrics and incorporating new metrics that improve 

the quality of MBCFLs. As stated previously, standards currently exist for initial lamp efficacy, 

lumen maintenance at 1,000 hours, lumen maintenance at 40 percent of lifetime, rapid cycle 

stress, and lamp lifetime. The current standards are based on August 9, 2001, ENERGY STAR®

Program Requirements for CFLs Version 2.0. ENERGY STAR has since released several 

updates to the specification, the latest of which was finalized in August 2014, ENERGY STAR 

Lamps Specification V1.1. DOE assessed the revisions in the ENERGY STAR specification for 

the five existing metrics required by DOE and also surveyed the specifications of commercially 

available MBCFLs to determine current product performance for the five existing metrics.

The current energy conservation standards for efficacy of MBCFLs vary based on 

wattage and whether the lamp has a cover. The ENERGY STAR Lamps Specification V1.1 

revised the wattage and covering divisions and increased the minimum lamp efficacy 

requirements. Based on an assessment of commercially available products, DOE determined that 

MBCFLs are performing above DOE’s current efficacy standard. DOE is evaluating revised 

efficacy requirements for GSLs, which includes MBCFLs, as part of this rulemaking. For more 

information on the levels of efficacy under consideration, see section 2.7.5. 

DOE also has minimum requirements for lumen maintenance. For lumen maintenance at 

1,000 hours, DOE requires that the average of at least five lamps be a minimum of 90 percent of 

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initial lumen output at 1,000 hours. The ENERGY STAR Lamps Specification V1.1 maintained 

this requirement with the added specification that all units must be surviving at 1,000 hours. For 

lumen maintenance at 40 percent of lifetime, DOE requires that 80 percent of the initial lumens 

must be achieved at 40 percent of lifetime. The ENERGY STAR Lamps Specification V1.1 also 

maintained this requirement with the added specification that no more than three units may be 

less than 75 percent of the initial lumen rating. DOE found that manufacturers do not publish 

information in catalogs on lumen maintenance at 1,000 hours and 40 percent of lifetime for 

MBCFLs. DOE assessed data submitted for the compliance certification management system 

(CCMS) reporting requirements and found that the majority of lamps certified exceeded the 

minimum lumen maintenance standards. DOE believes that the current requirements for lumen 

maintenance adequately address potential issues with lumen depreciation that could lead to 

consumer dissatisfaction and is therefore considering maintaining the existing requirements for 

lumen maintenance at 1,000 hours and lumen maintenance at 40 percent of lifetime. DOE 

requests comment on maintaining the current lumen maintenance requirements. 

Additionally, there is a minimum requirement for rapid cycle stress for MBCFLs. DOE 

requires that at least five lamps must survive cycling once per every two hours of rated life. The 

ENERGY STAR Lamps Specification V1.1 changed the cycling requirement to once per hour of 

rated lifetime or a maximum of 15,000 cycles. The ENERGY STAR Lamps Specification V1.1 

added an exception for instant start CFLs with a start time less than or equal to 100 milliseconds 

(ms), which are only required to survive cycling once per every two hours of rated life. For 

MBCFLs other than instant start CFLs, the increased requirement for rapid cycle stress provides 

consumer satisfaction by ensuring that MBCFLs are able to survive frequent switching and 

preventing premature failure. DOE found that manufacturers do not publish information on rapid 

cycle stress or starting method for MBCFLs. Further, manufacturers simply report the number of 

surviving units for DOE CCMS reporting requirements. However, DOE has received feedback

from manufacturers that the market shifts in response to ENERGY STAR specifications and so 

DOE believes that MBCFLs are likely already achieving this level of product performance for 

rapid cycle stress. Therefore, DOE is considering increasing the number of cycles required for 

non-instant start lamps (i.e., lamps with start times greater than 100 ms) to once per every hour 

of rated life with a maximum of 15,000 cycles to reduce testing burden. DOE requests comment 

on the rapid cycle stress performance of commercially available MBCFLs.

DOE currently requires a minimum lifetime of 6,000 hours for MBCFLs. The ENERGY 

STAR Lamps Specification V1.1 revised the minimum lifetime requirement to be 10,000 hours. 

Lifetime impacts consumer satisfaction as a longer life requires less frequent changes. Based on 

an assessment of commercially available lamps in manufacturer catalogs, DOE found that the 

majority of MBCFLs on the market have lifetimes of at least 10,000 hours. Further, of the 

MBCFLs for which data was submitted to DOE for CCMS reporting, 73 percent have a lifetime 

of at least 10,000 hours. The ENERGY STAR Certified Light Bulbs database also supports an 

increased lifetime with 79 percent of certified products having a lifetime of at least 10,000 

hours.22 Because DOE found that commercially available MBCFLs are already achieving this 

higher level of performance, DOE is considering revising the lifetime standard for MBCFLs to 

22 ENERGY STAR Program Requirements Product Specification for Lamps (Light Bulbs) Eligibility Criteria Version 

1.0 becomes effective September 30, 2014, at which time the updated lifetime of 10,000 hours will be required. 

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be a minimum of 10,000 hours. DOE requests comment on the appropriateness of requiring an 

increased lifetime of 10,000 hours for MBCFLs. 

2.4.2 Additional Metrics for MBCFLs

DOE received comments on additional metrics that should be considered in this 

rulemaking. EEI recommended adding requirements for power factor and total harmonic 

distortion (THD). EEI commented that lamps with low power factors increase demand for power 

and related transmission and distribution losses, which undermines the purposes of DOE’s 

energy conservation standards program. (EEI, No. 16 at p. 2) 

DOE does not currently have a standard for power factor, however, DOE has explicit 

authority to consider power factor for MBCFLs. (42 U.S.C. 6295(bb)(2)) Power factor is the 

ratio of active input power to apparent input power. A low power factor product is inefficient and 

requires an increase in electric utility’s generation and transmission capacity.23 Because a 

minimum power factor requirement could decrease energy use, DOE is considering power factor 

in this rulemaking. Total harmonic distortion is defined as the ratio of the root mean square (rms) 

values of the harmonic content to that of the fundamental current, expressed as a percentage. 

Because THD is directly related to power factor, setting a minimum power factor requirement 

will effectively set a standard for THD and therefore DOE is not considering a setting a separate 

requirement for THD.

DOE reviewed industry specifications for MBCFLs and found that the ENERGY STAR 

Lamps Specification V1.1 requires that CFLs have a power factor of 0.5 or greater. ENERGY 

STAR does not have a separate requirement for THD. The industry standard ANSI C82.77 

Harmonic Emission Limits – Related Power Quality Requirements for Lighting Equipment 

suggests a power factor of 0.5 for integrally ballasted medium screw base compact light sources 

with input power less than or equal to 35 watts. Based on an assessment of commercially 

available lamps in manufacturer catalogs, DOE determined that the majority of MBCFLs have a 

power factor in the range of 0.5 to 0.6 and a limited number of MBCFLs have a power factor 

greater than 0.6. The ENERGY STAR Certified Light Bulbs database supported this distribution 

with about 77 percent of MBCFLs with a power factor in the range of 0.5 to 0.6. 

EEI commented that power factor should be the highest possible value and harmonic 

distortion should be the lowest possible value that all lamps included in the scope of this 

rulemaking are able to achieve. EEI added that the requirements should be technology and 

market neutral, and noted that CFLs and LED lamps exist with power factors greater than 0.8. 

EEI concluded that these metrics should be considered for all technologies under this rulemaking 

and stated that 42 U.S.C 6295(bb)(2) gives DOE the authority to set minimum power factors for 

CFLs. (EEI, No. 16 at pp. 2-4) 

23 U.S. Department of Energy. Reducing Power Factor Cost. 

https://www1.eere.energy.gov/manufacturing/tech_assistance/pdfs/mc60405.pdf. 

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As stated previously, DOE has explicit authority to consider additional metrics, including 

power factor, for MBCFLs. (42 U.S.C. 6295(bb)(2)) However, DOE does not have authority to 

consider additional metrics for LED lamps and therefore is not considering setting power factor 

requirements for LED lamps in this rulemaking. DOE agrees that MBCFLs exist with a power 

factor greater than 0.8 but found these lamps to be extremely uncommon. Based on the 

ENERGY STAR Certified Light Bulbs database, approximately two percent of MBCFLs had a 

power factor greater than 0.8. As noted, the majority of the market reports power factor in the 

range of 0.5 to 0.6. Thus, DOE believes that requiring a minimum power factor of 0.5 is 

achievable for MBCFLs while supporting improved overall efficacy. It is also consistent with 

ENERGY STAR requirements and recommendations in industry standards. DOE is considering 

adding the requirement for MBCFLs to have a power factor of 0.5 or greater and no separate 

requirement for THD. DOE requests comment on adding a requirement for power factor and its 

consideration of a standard for power factor of 0.5 or greater. DOE also requests comment on its 

consideration not to set a standard for THD. 

DOE is also considering standards for other metrics as discussed previously in this 

section. DOE does not currently have a standard for CRI, however, DOE has explicit authority to 

consider CRI for MBCFLs. (42 U.S.C. 6295(bb)(2)) CRI is a measure of the color rendering 

properties of a light source, or the ability of a light source to show the “true” color of an object as 

compared to a reference source.24 A standard for CRI ensures consumer satisfaction because 

high CRI light sources render colors well. The ENERGY STAR Lamps Specification V1.1 

requires that CFLs have a CRI of at least 80. It also requires that no more than 3 units included in 

the average have a CRI less than 77 and no units have a CRI less than 75. Based on an 

assessment of commercially available lamps in manufacturer catalogs, DOE found that over 99 

percent of MBCFLs on the market have a CRI of at least 80. DOE identified only a few 

MBCFLs with a CRI of less than 80. Because a minimum CRI requirement would increase 

consumer satisfaction and DOE found that nearly all commercially available MBCFLs are 

already achieving a CRI of at least 80, DOE is considering requiring MBCFLs to have a CRI of 

80 or greater. DOE requests comment on adding a requirement for CRI and its consideration of a 

standard for CRI of 80 or greater. 

DOE does not have a standard for correlated color temperature (CCT). CCT is a measure 

of the perceived color of the white light emitted from a lamp.25 Lower CCT values correspond to 

warmer light, with more red content in the spectrum, and higher CCTs correspond to cooler light, 

with more blue content. The ENERGY STAR Lamps Specification V1.1 requires CCT to 

correspond to one of six nominal CCTs and fall within a prescribed chromaticity space. DOE 

believes that different CCTs are desirable depending on the application and therefore is not 

considering setting a requirement for CCT. DOE requests comment on its consideration not to 

set a CCT requirement for MBCFLs.

24 Illuminating Engineering Society of North America. The IESNA Lighting Handbook: Reference and Applications. 

Ninth Edition. 2000. p. G-7. 25 Illuminating Engineering Society of North America. The IESNA Lighting Handbook: Reference and Applications. 

Ninth Edition. 2000. p. G-8.

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Currently, DOE does not have a standard for operating frequency. Operating frequency is 

the frequency of the current measured in hertz supplied by the ballast to the lamp during 

operation. The ENERGY STAR Lamps Specification V1.1 requires that CFLs have a frequency 

within 20 to 33 kHz or at least 40 kHz. Requiring an operating frequency within a specified 

range ensures that lamps do not interfere with other electrical products, such as television 

remotes. Because operating frequency does not directly impact consumer satisfaction, DOE is 

not considering setting standards for operating frequency at this time. DOE requests comment on 

the consideration to not set requirements for operating frequency.

DOE does not currently have a standard for start time. The ENERGY STAR Lamps 

Specification V1.1 requires that the time needed for a lamp to become fully illuminated must be 

within one second of application of electrical power. DOE believes that start time impacts 

consumer satisfaction because a delay in starting is undesirable and can affect acceptance of a 

more efficient lamp technology. DOE reviewed manufacturer catalogs and the ENERGY STAR 

Certified Light Bulbs database and found that neither start time nor starting method is typically 

reported. DOE is considering requiring a start time of within one second of the application of 

electrical power because the market likely finds one second an acceptable start time since it has

been the ENERGY STAR specification for several years. DOE requests comment on the start 

time of MBCFLs and its consideration to require a start time of within one second of the 

application of electrical power.

2.4.3 Summary

Table 2.4.1 summarizes the metrics and corresponding requirements that DOE is 

considering for MBCFLs.

Table 2.4.1 Performance Metrics for Medium Base Compact Fluorescent Lamps

Metric Minimum Standard Considered

Efficacy See section 2.7.5 for more information on candidate standard 

levels under consideration.

Lumen maintenance at 1,000 hours 90 percent of initial lumen output at 1,000 hours

Lumen maintenance at 40 percent of 

lifetime 80 percent of initial lumen output at 40 percent of lifetime

Rapid cycle stress

MBCFL with start time > 100 ms: survive one cycle per hour of 

rated lifetime or a maximum of 15,000 cycles

MBCFLs with a start time of ≤ 100 ms: survive one cycle per

every two hours of rated lifetime

Lifetime 10,000 hours

Power factor 0.5

CRI 80

Start time The time needed for a MBCFL to become fully illuminated must 

be within one second of application of electrical power

2.5 MARKET AND TECHNOLOGY ASSESSMENT

In the initial stages of an energy conservation standards rulemaking, DOE gathers 

information that provides an overall picture of the market for the products concerned, including 

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the nature and market characteristics of the products and the industry structure. This activity 

consists of both quantitative and qualitative analysis, based primarily on publicly available 

information. The subjects addressed in the market and technology assessment for the preliminary 

analysis include the major manufacturers, product classes, retail market trends, shipments of 

covered products, regulatory and non-regulatory programs, and technologies that could be used 

to improve the efficacy of GSLs. This information serves as a resource throughout the 

rulemaking.

DOE reviewed existing literature and spoke with manufacturers to gain an understanding 

of the GSL industry in the United States. Industry publications (e.g., manufacturer catalogs, trade 

journals), government agencies, and trade organizations provided the bulk of the information. 

Using this information, DOE assessed the overall state of the industry, GSL manufacturing and 

market shares, shipments by lamp type, general technical information on GSLs, and industry 

trends.

The discussion below summarizes the analytical approach and the comments DOE 

received in response to the framework document. A more detailed discussion on DOE’s 

approach can be found in the market and technology assessment (chapter 3 of this TSD).

2.5.1 Market Assessment

2.5.1.1 Manufacturers of GSLs

The GSL industry is characterized by both domestic and international manufacturers. The 

majority of covered GSLs are manufactured by four large companies. The four manufacturers 

that hold the majority of the domestic market share of GSLs are listed below.

• GE Consumer and Industrial of General Electric, Inc. (GE)

• OSRAM SYLVANIA of Siemens AG (OSI)

• Philips Lighting Company of Philips Electronics North America Corporation (Philips)

• Cree, Inc. (Cree)

In addition to lamps listed under this rulemaking, the lighting divisions of GE, OSI, and 

Philips manufacture other products, such as lamp ballasts, high intensity discharge lamps, 

GSFLs, and IRLs.

All four companies are members of NEMA, a trade association that represents manufacturers 

of electrical equipment, including GSLs. NEMA provides an organizational framework for 

manufacturers of lighting products to work together on projects that affect their industry and 

businesses.

Although the GSL market is predominantly supplied by large manufacturers, DOE 

intends to conduct a study of small businesses that manufacture GSLs for the NOPR stage of this 

rulemaking analysis. The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires preparation 

of an initial regulatory flexibility analysis for every rule that by law must be proposed for public 

comment, unless the agency certifies that the rule, if promulgated, will not have a significant 

economic impact on a substantial number of small entities. A regulatory flexibility analysis 

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examines the impact of the rule on small entities and considers alternative ways of reducing 

negative impacts. The Small Business Administration defines small business manufacturing 

enterprises for GSLs under the North American Industry Classification System product code 

335110, “Electric Lamp Bulb and Part Manufacturing,” which has a size standard of 1,000 

employees or fewer. This includes the total number of employees in the parent company, not 

only those in the divisions that produce GSLs. DOE invites interested parties to provide 

information for any small businesses that manufacture GSLs and should be consulted before 

DOE publishes a NOPR.

2.5.2 Technology Assessment

In the technology assessment, DOE identifies technology options that appear to be 

feasible means of improving lamp efficacy. This assessment provides the technical background 

and structure on which DOE bases its screening and engineering analyses. To develop a list of 

technology options, DOE reviewed manufacturer catalogs, recent trade publications and 

technical journals, and consulted with technical experts. 

In the framework document, DOE included a list of technology options to analyze for 

GSLs. Recognizing that GSLs comprise of more than one lamp type, each with their own 

mechanisms for improving efficacy DOE identified technology options by lamp type. 

Specifically, DOE presented technology options for GSIL, CFL, and LED lamp types and also 

identified a change in technology (e.g., moving from CFLs to LED lamps) as a technology 

option. DOE received several comments on these options. 

NRDC, ASAP, et al. and CA IOUs commented on the omission of halogen infrared 

(HIR) from the list of technology options. NRDC, ASAP, et al. encouraged DOE to look further 

into this technology and contact coating companies since the technology can lead to a significant 

efficacy improvement for GSILs. CA IOUs noted that HIR is one of the best technology options 

to improve incandescent filament technology. (NRDC, ASAP, et al., No. 17 at pp. 10-11; CA 

IOUs, Public Meeting Transcript, No. 19 at p. 100) NEMA stated that their comments regarding 

incandescent reflector lamps made in response to the rulemaking that constitutes the second 

review of GSFL and IRL standards26 also apply to this rulemaking. Specifically, they stated that 

the technology options presented are already being used or are not technically feasible to produce 

a practical product. Further, NEMA recalled DOE’s first review of IRL standards which resulted 

in amended IRL standards published in a final rule in July 2009 (hereafter the “2009 Lamps 

Rule”). 74 FR 34080 (July 14, 2009). NEMA noted that in the 2009 Lamps Rule DOE had 

determined the max-tech level was possible with the use of the highest-efficiency technologically 

feasible reflector, halogen IR coating, and filament design and because this would require the use 

26 DOE initiated a rulemaking to conduct a second review of existing general service fluorescent lamps (GSFLs) and 

IRL. At the time of this analysis, DOE had published a notice of proposed rulemaking (NOPR) and held an 

associated public meeting May 1, 2014. 79 FR 24067 (April 29, 2014). Further information on the rulemaking 

including comments received at the preliminary analysis and NOPR phase can be found under Docket No. EERE–

2011–BT–STD–0006), which is maintained at www.regulations.gov.

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of proprietary technology, DOE could not consider this level further in its analyses. 74 FR 

34080, 34096 (July 14, 2009).27 (NEMA, No. 15 at pp. 11-12) 

As stated previously, DOE is restricted by the Appropriations Rider from using 

appropriated funds to implement or enforce standards for GSILs and therefore is not considering 

GSILs in this rulemaking at this time. See section 2.2.1 for further details. 

2.5.2.1 CFL Technology Options 

Regarding the technology options for CFLs, NEMA reiterated that their comments 

pertaining to GSFLs made in the second review of GSFL and IRL standards remain equally 

applicable here as nothing regarding the feasibility for these technologies has changed. NEMA 

noted that several of the technology options considered by DOE have reached their limit in 

currently available products. Specifically, NEMA noted that with regards to highly emissive 

electrode coatings, existing emitters are already designed for energy conservation and long life. 

According to NEMA, further changes could shorten lamp life and any potential improvements 

would be minimal, as electrode losses have been reduced significantly with high frequency 

operation. NEMA also stated that based on current technologies, the limits of gas fill technology 

and high efficiency phosphor technology have been reached by manufacturers and a 

breakthrough is needed to make further improvements. (NEMA, No. 15 at pp. 11-13) 

In the framework document, DOE presented highly emissive electrode coatings, higher 

efficiency lamp fill gas composition, and higher efficiency phosphors as a technology options 

that can improve CFL efficacy. Based on DOE’s research there are various combinations of 

highly emissive electrode coatings; various weights and mixes of phosphors; and various types 

and ratios of fill gases that can be used to improve lamp efficacy. Because CFLs are present on 

the market at more than one level of efficacy, each of these technology options can be used to 

improve the efficacy of less efficient products. Therefore, DOE continues to consider these 

technology options. 

Further, DOE recognizes that certain technology options may require a trade-off between 

increasing efficacy and maintaining long lifetimes. DOE screens out technology options that 

have an adverse impact on consumer utility including a shortened lifetime product. See section 

2.6 and chapter 4 of this TSD for more details on technology options screened out in this 

preliminary analysis. 

2.5.2.2 LED Lamp Technology Options 

NEMA noted several technical challenges for each of the LED lamp technology options 

presented in the framework document. Based on a review of research efforts in this field, patents, 

prototypes, and commercially available products DOE has found that the LED lamp technology 

27 In the 2009 Lamps Rule, the highest level analyzed for IRLs was based on a commercially available lamp that 

employed a silver reflector, an improved IR coating, and a filament design that resulted in a lifetime of 4,200 hours, 

and did not require proprietary technology. In its second review of IRL standards, DOE was able to identify even 

more efficacious IRLs, which also did not require proprietary technology. 74 FR 24068, 24110-11 (April 29, 2014).

2-45
options presented in the framework have met or have the potential to meet the technical issues 

outlined by NEMA. 

Regarding efficient down converters NEMA commented that these are not in use today 

due to technical challenges surrounding the narrow-band phosphors that enable high spectral 

efficiency and include robust packaging for lumen maintenance, while still achieving high 

quantum efficiency under high temperature and flux. (NEMA, No. 15 at pp. 13-14) 

In the framework document, DOE presented efficient down converters as a technology 

option that uses high-efficiency wavelength conversion materials such as nano-phosphors and 

quantum dot phosphors. DOE has identified research efforts that have made progress in 

addressing the technical issues associated with these technologies. For example, DOE-funded 

SUNY/Buffalo program developed quantum dot phosphor down converters with 80 percent 

efficiency in the green through red wavelengths with only a five percent loss in efficiency at 

150 °C, and have minimal losses at fluxes up to 38,000 W/cm2.

28 Further, although no longer 

commercially available, a R30 LED lamp utilizing quantum dot phosphors was introduced by 

Nexxus Lighting, Inc. and QD Vision in 2010.29 Therefore, DOE continues to consider efficient 

down converters as a viable means of increasing LED lamp efficacy.

NEMA noted the following challenges with the improved package architectures 

technology option: unreliable die attachment methods; development of polymer optical 

encapsulants to improve color stability and emitter lifetime; development of high index 

encapsulants to increase photon extraction; and ability to reduce down converting layer 

temperatures using high thermal conductivity. 

In the framework document, DOE presented improved package architecture as a 

technology option, noting examples of architecture enhancements such as RGB+, hybrid color, 

and bonding the chip directly on to the heat sink. Manufacturer feedback and DOE research 

indicates that these and various other ways for improving package architecture are being utilized 

in products and are the subject of further R&D. Cree, for example, produced an LED in its lab 

with an efficacy of 276 lm/W in 2013 owing the improvement in part to advances in LED 

package architecture.30 Cree has since improved its lab LED performance to over 300 lm/W as of 

March 2014.31 Therefore, DOE continues to consider improved package architecture as a viable 

means of improving LED lamp efficacy. 

28 U.S. Department of Energy. SUNY/Buffalo Developing High-Efficiency Colloidal Quantum Dot Phosphors. July 

11, 2013. (Last Accessed September 15, 2013) http://www1.eere.energy.gov/buildings/ssl/suny_quantum_dots.html.

29 Nexxus Lighting. NEXXUS LIGHTING DELIVERS FIRST COMMERCIALLY-AVAILABLE QUANTUM 

DOT.LED REPLACEMENT LIGHT BULBS. (Last Accessed September 15, 2014) 

http://www.nexxuslighting.com/news/pressReleases/news_030810.php#. 

30 Cree. Cree Sets New R&D performance Record with 276 Lumen-Per-Watt Power LED. February 13, 2013. (Last 

Accessed September 15, 2014) http://www.cree.com/News-and-Events/Cree-News/PressReleases/2014/March/~/link.aspx?_id=2F008013AEF14FAAA42C2A9686F5F865&_z=z.

31 Cree. Cree Sets New R&D performance Record with 276 Lumen-Per-Watt Power LED. February 13, 2013. (Last 

Accessed September 15, 2014) http://www.cree.com/News-and-Events/Cree-News/PressReleases/2014/March/300LPW-LED-barrier. 

2-46
Regarding improved emitter materials, NEMA commented that there is no clear path 

toward development of green and yellow emitters. NEMA added that multi-color modules 

require more advanced drivers to handle color stability since different color LED chips will 

degrade at different rates. (NEMA, No. 15 at p. 13) 

In the framework document, DOE presented improved emitter material as a technology 

option; specifically, non-blue LED emitters (i.e., red, green, or amber) that allow for 

optimization of spectral efficiency. The primary issue with developing non-blue emitters is the 

efficiency droop caused by Auger recombination, a process in which electrons collide and 

product heat rather than emit light. Researchers have identified methods to mitigate Augur 

recombination. (See chapter 3 of this TSD for further details.) Therefore, DOE believes there are 

pathways to develop improved emitters including green and yellow. Further, demonstrated 

products such as the Philips L Prize LED lamp with different color LEDs (i.e., blue and red) 

indicate that the issue of controlling color stability over lamp life for multi-color modules can be 

addressed by manufacturers. 32 Therefore, DOE continues to consider improved emitter materials 

as a technology option to improve LED lamp efficacy. 

NEMA also commented on the alternative substrate materials technology option stating 

that silicon (Si) and gallium nitride (GaN)-on-Si devices do not perform significantly better than 

sapphire devices. (NEMA, No. 15 at p. 13) 

In the framework document, DOE presented alternative substrate material as a 

technology option. While, sapphire is the most commonly used substrate in LEDs, alternative 

substrate materials such as gallium nitride (GaN), GaN-on-Si, and silicon carbide (SiC) have 

lattice mismatch that is absent or minimal, reducing likelihood of defects and thereby device 

quality and efficiency.33 Soraa manufactures lamps using GaN on GaN LEDs and recently 

announced a new LED package reaching 75 percent wall-plug-efficiency.34 Hence, DOE 

continues to consider use of substrates other than sapphire as a technology option to improve 

LED lamp efficacy.

Regarding improved thermal interface material (TIM) technology, NEMA remarked that 

there are challenges in developing such materials to enable high efficiency thermal transfer for 

long-term reliability and high performance. (NEMA, No. 15 at p. 13) 

In the framework document, DOE presented improved TIMs as a technology option that 

allows for higher efficiency thermal transfer, which can improve LED efficacy by lowering LED 

junction temperature.35 DOE’s research indicates that there are commercially available high 

32 U.S. Department of Energy. Lab Testing for Philips Entry. July 1, 2013. (Last Accessed September 15, 2014)

http://www.lightingprize.org/60watttest.stm. 

33 Solid State Technology. Beyond sapphire: LED substrates from GaN to ZnO, SiC, and Si. May 14, 2012. (Last 

Accessed September 15, 2014) http://electroiq.com/blog/2012/05/beyond-sapphire-led-substrates-gan-zno-sic-si/. 

34 Soraa. Soraa develops the world’s most efficient LED; begins integration into large lamp line. February 24, 

2014. (Last Accessed September 15, 2014) http://www.soraa.com/news/soraa-large-lamp-gen3-022414. 

35 RPI. Junction temperature in light-emitting diodes assessed by different methods. (Last Accessed September 15, 

2014) http://www.ecse.rpiscrews.us/~schubert/Reprints/2005%20Chhajed%20et%20al%20%28SPIE%

20Photonics%20West%29%20Junction%20temperature%20in%20LEDs.pdf.

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performing TIMs. There are also research efforts targeting reliable high efficiency thermal 

transfer materials such as chemical vapor deposition (CVD) diamond which provides high 

thermal conductivity while allowing for standard methods of attachment (e.g., solders and 

epoxies).36 Therefore, DOE continues to consider improved TIM as a viable means for 

improving LED lamp efficacy. 

With regard to optimized heat sinks, NEMA commented that performance is generally 

compromised by form factor constraints. (NEMA, No. 15 at p. 13) NEMA also noted that 

reliability is a concern with active thermal management systems. (NEMA, No. 15 at p. 13)

In the framework document, DOE presented optimized heat sinks and active thermal 

management systems as technology options that improve thermal conductivity and heat 

dissipation, lowering the temperature at the LED junction and increasing lamp efficacy. DOE 

determined that geometrical constraints can be addressed in optimized heat sink designs. For 

example, finned designs made out of materials with high thermal transfer coefficients have been 

utilized in commercially available A-shape lamps. Further, there are existing patents on 

optimized heat sinks for LEDs indicating this is an area of ongoing research.37 38 Additionally as 

active thermal management systems are being used in commercially available lamps, such as 

Philips MASTER LEDspot MR16s, and DOE believes any reliability concerns can be addressed 

by manufacturers.39 Therefore, DOE continues to consider optimized heat sinks and active 

thermal management systems as a technology options that can increase the efficacy of LED 

lamps. 

NEMA commented on the device level optics technology option, stating that the package 

size limits the extent of beam shaping that can be done with reasonable extraction efficiency and

that it adds system complexity. (NEMA, No. 15 at p. 14) 

In the framework document, DOE presented device level optics as a technology option 

that involves optimizing optics at the chip level or the primary optic, so that the outer secondary 

optic can be removed, thereby eliminating losses due to absorption. DOE has found that there are 

research efforts addressing issues of optimizing extraction efficiency for small package sizes as 

well as improving beamshaping. An existing patent presents primary optic configurations that 

achieve more controlled beam shapes while allowing for a more simplified and efficient 

36 Aidala, Dwain A. CVD Diamond Solves Thermal Challenges. Solid State Technology. (Last Accessed September 

15, 2014) http://electroiq.com/blog/2006/10/cvd-diamond-solves-thermal-challenges/.

37 Ashfaqul Chowdhury and Gary Allen. GE Lighting Solutions, LLC. (2014) U.S. Patent No. 8,672,516. 

Washington DC: US Patent and Trademark Office. 

38 Timothy Chen and George Uhler. Technical Consumer Products, Inc. (2013) U.S. Patent Application 

No.20130294097 A1. Washington DC: US Patent and Trademark Office. 

39 Philips. Technical application guide: Philips MASTER LEDspot LV D 7-35W or 10-50W MR16. (Last Accessed 

September 15, 2014) http://www.lighting.philips.com/pwc_li/main/shared/led/portal/pdf/Technical-ApplicationGuide-MASTER-LEDspot-LV-D-7-35W-10-50W-MR16.pdf. 

2-48
secondary optic.40 Therefore, DOE continues to consider device level optics as a viable means of 

increase LED lamp efficacy.

Regarding improved driver designs, NEMA commented that the functional requirements 

of the driver (e.g., power quality, flicker, dimmability, isolation, line regulation, and 

transient/surge protection) often limit its efficiency. (NEMA, No. 15 at p. 14) 

In the framework document, DOE presented improved driver design as a technology 

option that can increase driver efficiency through advanced circuit designs. Manufacturer 

feedback and DOE’s review of catalogs indicate a range of efficiencies associated with drivers. 

The existence of this range, coupled with historical increases in driver efficiency in 

commercially available lamps, demonstrates the potential for improvement in driver design while 

meeting the functional specifications of the product. Therefore, DOE continues to consider 

improved driver design as a technology option for improving LED lamp efficacy. 

With regard to AC LEDs, NEMA noted that these often need external components to 

mitigate inherent issues like flicker and operate with 50 percent utilization or less. NEMA added 

that high voltage AC LEDs include losses due to die segmentation and have other complexity 

issues. (NEMA, No. 15 at p. 14) 

DOE presented AC LEDs as a technology option in the framework document. By 

reducing conventional driver size or removing the driver component, complexity, and efficiency 

losses AC-powered LEDs can increase performance of the LED lamp. Seoul Semiconductor has 

a number of high voltage AC LED modules commercially available for integration into lamps. In 

July 2014, Seoul Semiconductor announced a new line of AC LED modules with improved AC 

drivers designed specifically for the omnidirectional lamps.41 The new AC driver improves 

compatibility with TRIAC dimmers and is designed to mitigate flicker issues that can arise 

during dimming of AC LEDs. 42 43 Additionally, improvements in circuit design can increase 

LED utilization. For example, Texas Instruments’ (TI’s) TPS92411 MOSFET switch allows a 

small capacitor to be placed across each LED segment on a circuit to store energy keeping all 

LEDs lit even when the AC line voltage is too low, thereby increasing LED utilization.44

Therefore, DOE continues to consider AC LEDs as a viable means of improving LED lamp 

efficacy. 

40 Eric Tars, Bernd Kellerm Peter Guschl, and Gerald Negley. (2011) U.S. Patent No. 8,564,004. Washington

DC: US Patent and Trademark Office.

41 Seoul Semiconductor. Seoul Semiconductor Introduces a New Acrich-based Module for Omnidirectional 

Lamps. July 29, 2014. (Last Accessed September 15, 2014) 

http://www.seoulsemicon.com/en/html/company/press_view.asp?Idx=265. 

42 Seoul Semiconductor. Seoul Semiconductor Launches the Next Generation of Smart Lighting LED Technology

– 

Acrich3. July 29, 2014. (Last Accessed September 15, 2014) 

http://www.seoulsemicon.com/en/html/company/press_view.asp?Idx=264. 

43 LED Magazine. Seoul Semiconductor announces Acrich3 AC-LED driver, new MJT LEDs. June 4, 2014. (Last

Accessed September 15, 2014) http://www.ledsmagazine.com/articles/2014/06/seoul-semiconductor-announcesacrich3-ac-led-driver-new-mjt-leds.html. 

44 LED Magazine, TI launches AC-driver technology for LED-based lighting. (Last Accessed September 15,2014) 

http://www.ledsmagazine.com/articles/2013/11/ti-launches-ac-driver-technology-for-led-based-lighting.html. 

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NEMA cited costs issues for the following technology options presented in the 

framework document: improved package architecture involving mixed color configurations 

requiring additional controls; use of alternative substrates such as GaN; active thermal 

management systems, and increased light utilization technology which involves a trade-off with 

optical losses and cost. (NEMA, No. 15 at pp. 13-14) 

DOE does not take cost into consideration when identifying technology options. DOE 

considers costs in determining the economic justification of any standard levels developed using 

these technologies.

In addition to the technology options detailed in the framework document, DOE is 

considering reduced current density as a technology option for improving LED lamp efficacy. 

DOE notes that increasing current results in a commensurate decrease in LED efficacy.45 DOE’s 

research and manufacturer feedback have shown that reducing current density within reason will 

increase LED lamp efficacy while maintaining practical levels of lumen output per unit area. 

Therefore, DOE is considering reduced current density, which involves increasing the number of 

LEDs, as a technology option that can increase the efficacy LED lamps. See chapter 3 of this 

TSD for further details. DOE requests comment on the addition of reduced current density as a 

technology option. 

Further, based on manufacturer feedback and research conducted in this preliminary 

analysis, DOE is considering clarifying certain technology options for LED lamps. For the 

efficient down converter technology, DOE is noting that efficient down converters also include 

optimized phosphor conversion resulting from either advanced phosphor compositions or 

placement of phosphors (i.e., remote phosphor technology). Phosphor-coated LEDs is the most 

common down converter mechanism for converting shorter wavelengths to longer wavelengths 

to produce white light in LEDs. DOE has found there are research efforts and existing patents on 

optimized phosphor coating for LEDs.46 47 Further, Cree, for example, produced an LED in its 

lab with an efficacy of 276 lm/W in 2013 owing the improvement in part to advancements in 

phosphors.48 

In the framework document, DOE defined device level optics as integrating a specific 

lens into the primary optic to allow for the removal of the secondary optic. DOE research 

indicates that in addition to a lens, there are other methods for optimizing the primary optic and 

further that even the simplification of the secondary optic due to such enhancements can 

eliminate losses due to absorption at interfaces. Therefore, DOE is considering clarifying that 

45 U.S. Department of Energy. Energy Efficiency of LEDs. March, 2013. (Last Accessed September 15, 2014)

http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/led_energy_efficiency.pdf. 

46 Anant Setlur. Phosphors for LED-based Solid-State Lighting. 2009. (Last Accessed September 15, 2014)

http://www.electrochem.org/dl/interface/wtr/wtr09/wtr09_p032-036.pdf.

47 William Winder Beers, Jon Bennett Jansma,Fangming Du, William Erwin COHEN, Alok Mani 

Srivastava, Samuel Joseph Camardello, Holly Ann Comanzo. (2013) U.S. Patent Application No. 201301140978. 

Washington DC: US Patent and Trademark Office. 

48 Cree. Cree Sets New R&D performance Record with 276 Lumen-Per-Watt Power LED. February 13, 2013.

(Last Accessed September 15, 2014) http://www.cree.com/News-and-Events/Cree-News/PressReleases/2014/March/~/link.aspx?_id=2F008013AEF14FAAA42C2A9686F5F865&_z=z

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this technology option encompasses any enhancements to the primary optic of the LED package 

that would simplify or remove entirely the secondary optic, and thereby reduce losses due to 

absorption at interfaces. 

To conduct the technology assessment, DOE reviewed manufacturer catalogs, recent 

trade publications, technical journals, and patent filings; and consulted with technical experts and 

manufacturers to ensure it identified all possible technology options that can increase the 

efficacy of GSLs. In summary, DOE is considering the technology options as shown in Table 

2.5.1 in this preliminary analysis. For further information on all technology options considered in 

this TSD see chapter 3. DOE requests comment on the technology options under consideration 

for GSLs.

Table 2.5.1 GSL Technology Options 

Lamp Type Name of Technology Option Description

CFL

Highly Emissive Electrode 

Coatings

Improved electrode coatings allow electrons to be more 

easily removed from electrodes, reducing lamp power and 

increasing overall efficacy. 

Higher Efficiency Lamp Fill 

Gas Composition 

Fill gas compositions improve cathode thermionic emission 

or increase mobility of ions and electrons in the lamp 

plasma.

Higher Efficiency Phosphors Techniques to increase the conversion of ultraviolet (UV) 

light into visible light.

Glass Coatings Coatings on inside of bulb enable the phosphors to absorb 

more UV energy, so that they emit more visible light.

Multi-Photon Phosphors Emitting more than one visible photon for each incident 

UV photon.

Cold Spot Optimization Improve cold spot design to maintain optimal temperature 

and improve light output.

Improved Ballast 

Components

Use of higher-grade components to improve efficiency of 

integrated ballasts.

Improved Ballast Circuit 

Design

Better circuit design to improve efficiency of integrated 

ballasts.

Change in Technology Replace CFL with LED technology.

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Lamp Type Name of Technology Option Description

LED

Efficient Down Converters

New high-efficiency wavelength conversion materials, 

including optimized phosphor conversion, quantum-dots 

and nano-phosphors, have the potential for creating warmwhite LEDs with improved spectral efficiency, high color 

quality, and improved thermal stability. 

Improved Package 

Architectures

Novel package architectures such as RGB+, system-inpackage, hybrid color, and chip-on-heat-sink have the 

potential to improve thermal management, color-efficiency, 

optical distribution, as well as electrical integration to 

greatly improve overall lamp and luminaire efficacy.

Improved Emitter Materials

The development of efficient red, green, or amber LED 

emitters, will allow for optimization of spectral efficiency 

with high color quality over a range of correlated color 

temperatures (CCT) and which also exhibit color and 

efficiency stability with respect to operating temperature.

Alternative Substrate 

Materials

Alternative substrates such as gallium nitride (GaN), silicon 

(Si), GaN-on-Si, and silicon carbide to enable high-quality 

epitaxy for improved device quality and efficacy. 

Improved Thermal Interface 

Materials

Develop TIMs that enable high efficiency thermal transfer 

for long-term reliability and performance optimization of 

the LED device and overall lamp product.

Optimized Heat Sink Design

Improve thermal conductivity and heat dissipation from the 

LED chip thus reducing efficacy loss from rises in junction 

temperature. 

Active Thermal 

Management Systems

Devices such as internal fans, vibrating membranes, and 

circulated liquid cooling systems to improve thermal 

dissipation from the LED chip.

Device Level Optics

Enhancements to the primary optic of the LED package that 

would simplify or remove entirely the secondary optic, and 

thereby reduce losses due to absorption at interfaces.

Increased Light Utilization

Reduce optical losses from the lamp housing, diffusion, 

beam shaping and color-mixing to increase the efficacy of 

the LED lamp.

Improved Driver Design Increase driver efficiency through novel and intelligent 

circuit design. 

AC LEDs Reduce or eliminate the requirements of a driver and 

therefore the effect of driver efficiency on lamp efficacy.

Reduced Current Density

Increase the number of LEDs in a lamp to reduce current 

density while maintaining lumen output. This reduces the 

efficiency losses associated with higher current density.

2.5.3 Product Classes

DOE divides covered products into classes by: (a) the type of energy used; (b) the 

capacity of the product; or (c) other performance-related features that justify different standard 

levels, considering the consumer utility of the feature and other relevant factors. (42 U.S.C. 

6295(q)) In the framework document, DOE considered establishing product classes for GSLs 

based on the following three factors: (1) ballast location; (2) dimmability; and (3) cover.

CEC proposed that DOE should start with a single product class and add product classes 

only if significant cost or technical challenges arise based on the stringency of the standard. 

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(CEC, No. 11 at p. 14) CA IOUs stated that while the product classes presented in the framework 

impact consumer utility, it is questionable whether they have any correlation with efficacy, and 

recommended DOE consider only one product class for GSLs in the preliminary analysis.

However, CA IOUs noted that should any of the product classes in the framework document be 

maintained, DOE should make them more self-explanatory, well-defined, and less subject to 

interpretation. (CA IOUs, No. 18 at pp. 7-8) ASAP added that the product class structure should 

be robust so that it can accommodate technologies not yet on the market. (ASAP, Public Meeting 

Transcript, No. 19 at pp. 94-95)

In evaluating product class setting factors, DOE considers their impact on both efficacy 

and consumer utility. In this preliminary analysis, DOE has reevaluated the product class setting 

factors considered in the framework document and also considered additional class setting 

factors. The following sections discuss the comments received on potential product class setting 

factors and whether DOE is establishing a separate product class division for them.

2.5.3.1 Covering

Some lamps incorporate an added glass or silicone cover over the main light source,

which can reduce the lumen output of the lamp. Covered lamps may offer utility to consumers as 

they more closely resemble traditional lighting technologies and are frequently utilized where a 

lamp is visible. For this reason, DOE considered establishing a separate product class for covered 

lamps in the framework document.

Soraa recommended eliminating this product class stating that a cover provides no real 

value or distinction over the other product class-setting factors of ballast location and 

dimmability. (Soraa, No. 10 at p. 2) CEC also supported the removal of the product class 

division based on lamp cover and commented that if a 45 lm/W standard is adopted, a product 

class based on lamp cover should not exist since a large number of lamps in this category 

currently exceed 45 lm/W. (CEC, No. 11 at pp. 13-15)

CA IOUs stated that the cover versus bare distinction for lamps is based on CFLs, which 

with an external cover look more like a traditional lamp but have decreased efficacy. However, 

CA IOUs noted that because there are LED lamps with a cover that have a higher efficacy and 

incandescent lamps with a cover that have a lower efficacy than CFLs that are covered and bare, 

there is no apparent correlation between efficacy and this product attribute across all GSLs. 

NRDC, ASAP, et al. agreed that the covered versus uncovered terms apply only to CFLs and 

that considering a frosted lamp to be covered did not make sense. (NRDC, ASAP, et al., No. 17 

at pp. 7-8)

However, NEMA and GE supported a covered and bare product class division for 

integrated CFLs and a diffuse and clear coated product class division for LED lamps. (NEMA, 

No. 15 at p. 10; GE, Public Meeting Transcript, No. 19 at pp. 111-112) NEMA also provided

definitions for “covered compact fluorescent lamp” and “covered light-emitting diode lamp” 

which specified that these lamps have a glass or plastic housing that can either be clear or 

diffuse. NEMA recommended that “diffuse cover” be defined as a cover that scatters light 

transmitted through the cover such that the source of the light is not discernable. (NEMA, No. 15 

at p. 11)

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In the framework document, DOE considered a cover to be something added to the lamp 

such that the main light source is not distinguishable. For the preliminary analysis, DOE 

conducted additional research on covered versus bare lamps and the applicability of this 

distinction across different lamp technologies. DOE found that while a cover generally decreased 

efficacy, particularly in CFLs, a cover could also result in increased efficacy, such as when it has 

a phosphor coating and transforms light emitted from LEDs into visible light. As described later 

in this section, DOE is considering technology neutral product classes in the preliminary 

analysis. DOE notes that many LED lamps that have covers also have high efficacies. Thus, 

covered products will still be available at the highest levels of efficacy analyzed. For these 

reasons, DOE is no longer considering establishing a product class for covered versus bare 

products. 

2.5.3.2 Dimmability

In the framework document, DOE noted that dimmable lamps could have a lower 

efficacy than lamps with otherwise similar characteristics because of the added circuitry 

necessary for dimming functionality and the inclusion of cathode heat. For certain technologies, 

such as CFLs and LED lamps, not all products are marketed as capable of being dimmed. Thus a 

lamp that can be dimmed may offer unique performance characteristics and provide a utility to 

consumers. For these reasons, in the framework document DOE considered establishing a 

separate product class based on dimmability.

NEMA noted that while dimmability is a consumer utility, it is not included in all lamp 

designs, and further that the ability to dim varies by lamp type and brand. NEMA recommended 

that dimmable products should be tested at full power and should not be subject to different 

requirements. (NEMA, No. 15 at p. 10) NRDC, ASAP, et al. commented that a product class 

based on dimmability is unnecessary since dimming products exist at a range of levels of 

efficacy. (NRDC, ASAP, et al., No. 17 at pp. 7-8) CEC again noted that if a 45 lm/W standard is 

adopted, a dimmable product class should not exist since a large number of lamps in that 

category currently exceed 45 lm/W. (CEC, No. 11 at pp. 13-15)

CEC and CA IOUs stated they could not find a correlation between dimmability and 

efficacy. (CEC, No. 11 at pp. 13-15; CA IOUs, No. 18 at pp. 7-8) According to CEC’s analysis 

of ENERGY STAR lamps, the average efficacy of medium screw base, non-reflector lamps was 

66 lm/W for those that were dimmable and 64 lm/W for those that were not dimmable. (CEC, 

No. 11 at pp. 13-15) CA IOUs further noted that should this product class be maintained, DOE 

should clarify what qualifies as a minimum level of dimmability as dimmable lamps have 

different capacities to dim (e.g., some lamps dim smoothly down to 1-2 percent of light output 

while others only dim to 50 percent). CA IOUs also directed DOE to a dimmability standards 

proposal and test procedure for LED replacement lamps submitted to CEC in 2013 by PG&E and 

SDG&E. (CA IOUs, No. 18 at pp. 7-8)

Several stakeholders commented on the applicability of such a product class setting factor 

across different lamp technologies. GE remarked that for externally ballasted lamps it is the 

ballast rather than the lamp that is designed to be dimmed or not dimmed. Therefore, GE stated 

that the dimmable product class distinction is not applicable to the externally ballasted lamps. 

2-54
(GE, Public Meeting Transcript, No. 19 at pp. 90-91) CEC noted that a dimmable distinction 

does not apply to incandescent lamps, as they are all dimmable. (CEC, No. 11 at pp. 13-15)

In the framework document DOE determined that a lamp that could be dimmed offers a 

consumer utility but this ability could also result in reduced efficacy due to added circuitry. Upon 

further review of catalog data and feedback from stakeholders, DOE determined that dimmable 

lamps are available across a range of efficacies and further confirmed that the ability to dim has a 

negligible impact on efficacy. Therefore, because there is no discernable impact on efficacy in 

relation to dimmability, DOE is no longer considering establishing separate product classes for 

lamps that are dimmable and those that are not. 

2.5.3.3 Ballast Location

Ballast location refers to the use of integrated ballasts (i.e., self-ballasted) or nonintegrated ballasts (i.e., externally ballasted). DOE notes that self-ballasted lamps may have 

lower inherent efficacy compared to lamps that utilize external ballasts due to the additional 

components and circuitry integrated into a self-ballasted lamp. The use of a self-ballasted lamp 

can be advantageous in that a consumer need only replace one lamp unit rather than two separate 

components. Self-ballasted lamps are also generally more compact and thus can be used in 

applications with size constraints. For these reasons, in the framework document DOE 

considered establishing separate product classes based on ballast location.

CA IOUs recommended eliminating the externally ballasted product class as they have a 

low market share, may not be easily adopted as they require special fixtures, and do not pose a 

low-efficacy loophole. (CA IOUs, No. 18 at pp. 7-8) NRDC, ASAP, et al. commented that the 

same standards should apply to self-ballasted lamps as externally ballasted lamps, as the latter 

would require a reference ballast for purposes of testing. (NRDC, ASAP, et al., No. 17 at pp. 7-

8)

DOE does not consider market share when identifying product class setting factors but 

rather focuses primarily on the impact on consumer utility and efficacy. DOE determined that the 

location of a ballast, specifically whether it is external and replaceable or permanently enclosed 

in the lamp can impact consumer utility and efficacy. The difference in size and physical 

configuration (i.e., one lamp component versus two lamp components) offer different utility to 

consumers. Further based on DOE research, lamps that incorporate a ballast include additional 

components and circuitry and therefore are likely to have a lower inherent efficacy compared to 

lamps that utilize external ballasts. Additionally, the testing of externally ballasted lamps on a 

reference ballast would still not account for the additional circuitry that would be reflected in the 

measured efficacy of a self-ballasted lamp. Therefore, DOE continues to consider ballast location 

to be a product class-setting factor. 

Regarding the terminology used to describe a product class division based on ballast 

location, GE pointed out that “driver” is a more accurate term when referring to LED lamps. 

(GE, Public Meeting Transcript, No. 19 at p. 93) CA IOUs agreed that it would be confusing to 

use the term ‘ballast’ when referring to LED drivers. ASAP suggested that the product classes be 

revised to reduce ambiguity and conform with industry terminology to avoid confusion (e.g., not 

using the term “ballast” interchangeably with “driver”). (ASAP, Public Meeting Transcript, No. 

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19 at pp. 94-95) CA IOUs also requested that if DOE was going to consider product classes 

based on ballast location, that it clarify how an incandescent lamp, which has no ballast, would 

be categorized. (CA IOUs, No. 18 at p. 8)

The impact on efficacy and utility for this product class division is based on the lamp 

having all its components enclosed within it as opposed to requiring an external, replaceable 

component. Therefore, to provide a clearer description of the product class that is applicable 

across all GSL technology types, DOE is considering using the terms ‘integrated’ and ‘nonintegrated’ rather than ‘self-ballasted’ and ‘externally ballasted.’ Integrated GSLs would 

comprise lamps that contain all components necessary for the starting and stable operation of the 

lamp, do not include any replaceable or interchangeable parts, and are connected directly to a 

branch circuit through an ANSI base and corresponding ANSI standard lamp-holder (socket).

Non-integrated GSLs would comprise any lamp that is not an integrated lamp. 

2.5.3.4 Lamp Technology

In the framework document, DOE did not consider establishing separate product classes 

based on lamp technology. Rather, multiple lamp technologies could be present in a single 

product class. CEC agreed with DOE’s decision not to establish product classes by lamp 

technology, noting that otherwise more efficient technologies would be unfairly impacted as they 

would be subject to higher standards while less efficient technologies would likely have lower 

first costs and remain competitive in the market. (CEC, No. 11 at p. 6) NRDC, ASAP, et al. also 

endorsed a technology-neutral approach. (NRDC, ASAP, et al., No. 17 at pp. 7-8; ASAP, Public 

Meeting Transcript, No. 19 at p. 22)

NEMA, however, proposed product class divisions that are specific to lamp technology. 

Specifically, NEMA recommended the following product classes: 1) medium screw base (MSB) 

filament lamps (i.e., halogen incandescent), 2) MSB and pin base self-ballasted CFL (covered 

and bare/clear cover, two categories), 3) MSB and pin base LED lamp with integral driver (clear 

coated and diffuse coatings, two categories). (NEMA, No. 15 at p. 10). 

In evaluating GSLs, DOE determined that different lamp technologies do not offer 

consumers different utility. DOE believes that for use in a general service application, a CFL and 

LED lamp offer similar functionality. Therefore, DOE is not considering product class divisions 

based on lamp technology. In the product class structure under consideration, medium base CFLs 

fall into the integrated GSL product class. DOE accounts for the existing standards for medium 

base CFLs in the analysis of this product class to ensure there is no backsliding.49

2.5.3.5 Base Type

In the framework document, DOE did not consider establishing separate product classes 

based on base type. CEC commented that if smaller base types, such as candelabra, are included 

in the scope of coverage, those may warrant a separate product class because of space constraints 

49 EPCA’s anti-backsliding provision mandates that the Secretary not prescribe any amended standard that either 

increases the maximum allowable energy use or decreases the minimum required energy efficiency of a covered 

product. (42 U.S.C. 6295(o)(1))

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of certain products. (CEC, Public Meeting Transcript, No. 19 at pp. 95-96) As discussed in 

section 2.3.5.5, DOE is not considering setting standards for GSLs with candelabra bases in this 

rulemaking. 

2.5.3.6 Lamp Spectrum

DOE received comments on establishing a product class division based on lamp 

spectrum. ASAP commented that DOE did not address how it planned to include modified 

spectrum lamps in the analysis which have a lower standard than conventional lamps. (ASAP, 

Public Meeting Transcript, No. 19 at pp. 22-23) NEMA recommended that DOE develop a 

definition based on the color point defined in the current definition for incandescent modified 

spectrum lamps per 10 CFR 430.2 and then develop derating factors for CFL and LED lamps as 

appropriate. (NEMA, No. 15 at pp. 10-11)

NRDC, ASAP, et al and CA IOUs disagreed, recommending that DOE not include an 

allowance for modified spectrum lamps allowing them to meet weaker standards. (NRDC, 

ASAP, et al., No. 17 at p. 8; CA IOUs, No. 18 at p. 9) NRDC, ASAP, et al noted that the current 

EISA standards already provide a 25 percent allowance for modified spectrum GSILs and as a 

result these lamps are no more efficient than conventional inefficient incandescent lamps. They 

cited an example of a GE 72 W Reveal incandescent lamp that claims to be a 100 W replacement 

but produces lumen output equivalent to a 75 W and a GE 13 W Reveal CFL that claims to be a 

60 W replacement but produces 30 percent less light than a standard 60 W incandescent lamp. 

(NRDC, ASAP, et al., No. 17 at pp. 8-10) Further CA IOUs commented that they have been able 

to show in the past that modified spectrum incandescent lamps can be manufactured with only a 

10 percent reduction in light output compared to standard spectrum lamps. Additionally, CA 

IOUs emphasized that in considering all types of GSLs, an efficacy allowance for modified 

spectrum lamps is inappropriate because fluorescent and LED technologies can offer a modified 

spectrum without reducing efficacy. (CA IOUs, No. 18 at p. 9)

DOE is not considering a separate product class for modified spectrum lamps in this 

preliminary analysis. Modified spectrum lamps provide a unique spectral power distribution 

(SPD) that increases the contrast between reds and greens, resulting in a type of light different 

from a standard spectrum. DOE’s research indicates that are various ways to manipulate SPDs to 

achieve a modified spectrum such as neodymium coating, phosphor mixes and LED color 

mixing or a combination thereof. DOE has found that certain methods do not require a decrease 

in efficacy. For example the Philips L Prize lamp and Cree’s existing product line of True 

White® color mixed LED modules are able to achieve a modified spectrum at high efficacies. 

Because efficacy is impacted in different ways based on the method used to achieve modified 

spectrum GSLs, DOE is not considering a product class division for modified spectrum GSLs. 

2.5.3.7 Correlated Color Temperature

NEMA also suggested that DOE consider derating factors for high CCT CFLs (> 4,500

K) and low CCT LED lamps (< 3,200 K). 

DOE understands that CCT is a measure of the perceived color of the white light emitted 

from the lamp. The perception of light affords consumers a different utility for lamps with 

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different CCT values. DOE found that while there is a reduction in efficacy for fluorescent 

technology at higher CCTs, LED technology experiences an increase. For CFLs at higher CCTs, 

more light is converted to shorter wavelengths (i.e., blue, violet) to which human eyes are less 

sensitive, thereby resulting in a decline in efficacy. In LED lamps, the LED emits blue light (i.e.,

shorter wavelengths) which is partially down converted to longer wavelengths. While this 

process results in longer wavelengths to which human eyes are more sensitive, there is a decrease 

in lumen output due to losses from phosphor conversion and a larger Stokes’ shift.50 To achieve 

lower CCTs in LED lamps more down conversion and a larger Stokes’ shift is required, resulting 

in lower efficacy. Due to these underlying differences in technology, the efficacy trends 

associated with CCT differ for CFLs and LED lamps. Therefore, a consistent correlation 

between efficacy and CCT cannot be established for all GSLs. Hence, DOE is not considering 

such a product class division based on CCT. 

2.5.3.8 Lumen Package

In this preliminary analysis, DOE is also considering lumen package as a product class 

setting factor for integrated GSLs. After further analysis, DOE determined that higher lumen 

output products cannot achieve the same levels of efficacy as lower lumen output products. DOE 

believes that higher lumen packages offer a consumer utility. After evaluating manufacturer 

catalogs and other sources,51 DOE determined that a general service high lumen application 

would have light output in the range of 2,000 – 2,600 lumens. DOE was unable to identify LED 

lamp replacements for incandescent lamps of wattages higher than 100 W. Therefore, DOE 

examined lumen ranges of CFLs marketed as being equivalent to a 125 W incandescent lamp, 

the next common incandescent wattage after the 100 W. Additionally, ENERGY STAR Lamps 

Specification V1.152 defines a 125 W incandescent equivalent lamp to have a lumen range of 

2,000 – 2,549. The upper lumen limit of the high lumen package product class under 

consideration is maintained at 2,600 in accordance with the scope of this rulemaking, which 

covers products in the lumen range of 310 – 2,600. Because of the impact on both efficacy and 

utility, DOE is considering establishing separate product classes for integrated GSLs with lumen 

outputs between 310 and 1999 and integrated GSLs with lumen outputs between 2,000 and 

2,600. DOE is not establishing a product class division based on lumen package for nonintegrated GSLs, as DOE found lumen packages across a range of efficacies for these products. 

DOE requests comments on a product class division based on lumen package for the integrated 

GSLs. 

2.5.3.9 Standby Mode Operation

In this preliminary analysis, DOE is also considering a division based on the ability for a 

lamp to operate in standby mode. As stated in section 2.3.5.4, DOE identified integrated lamps

that meet the definition of GSL and operate in standby mode. DOE believes that standby mode 

operation offers a consumer utility because these lamps have the ability to be remotely turned 

50 Stokes’ shift is the difference, in nanometres, between the peak excitation and the peak emission wavelengths.

Stokes’ law states that radiation emitted must be of the longer wavelength than that absorbed. 

51 ENERGY STAR Lamps Specification V1.1, available at 

http://www.energystar.gov/sites/default/files/ENERGY%20STAR%20Lamps%20V1%201_Specification.pdf. 

52 Ibid. 

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off, turned on, dimmed, or other functionality. DOE evaluated whether operation in standby 

mode impacts lamp efficacy. Based on commercially available products, DOE found that 

standby power consumption can vary based on the technology used to facilitate standby 

functionality. DOE assumes that the market will shift to the lowest energy consuming method 

available, such as Bluetooth or smart controls that are external to the lamp, over the course of the 

analysis period and therefore believes that the energy consumed in standby mode is negligible. 

Because DOE believes that the energy consumed while operating standby mode will be 

negligible for GSLs, DOE does not believe there is a difference in efficacy for lamps that can 

operate in standby mode compared to lamps that cannot operate in standby mode. Therefore, 

DOE is not considering a product class division based on standby mode operation. DOE requests 

comments on its preliminary determination that energy consumed in standby mode will be 

negligible and therefore a product class division based on standby mode operation for integrated 

GSLs is not warranted.

2.5.3.10 Summary

In summary, DOE is considering establishing the three product classes shown in Table 

2.5.2. See chapter 3 of this TSD for further discussion. DOE welcomes comments on the product 

class divisions it is considering for GSLs in this preliminary analysis.

Table 2.5.2 GSL Product Classes

Lamp Type Lumen Output

Integrated GSLs (e.g., self-ballasted CFL, 

integrated LED lamp)

310-1,999

2,000-2,600

Non-Integrated GSLs (e.g., externally ballasted 

CFL) 310-2,600

2.6 SCREENING ANALYSIS

After DOE identifies the technologies that improve the efficacy of GSLs, DOE conducts 

the screening analysis. The purpose of the screening analysis is to determine which options to 

consider further and which options to screen out. DOE consults with industry, technical experts, 

and other interested parties in developing a list of technology options. DOE then applies the 

following set of screening criteria to determine which options are unsuitable for further 

consideration in the rulemaking (10 CFR Part 430, subpart C, appendix A at 4(a)(4) and 5(b)):

• Technological Feasibility: DOE will consider technologies incorporated in commercially 

available products or in working prototypes to be technologically feasible.

• Practicability to Manufacture, Install, and Service: If mass production of a technology 

and reliable installation and servicing of the technology could be achieved on the scale 

necessary to serve the relevant market at the time the standard comes into effect, then 

DOE will consider that technology practicable to manufacture, install, and service.

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• Adverse Impacts on Product Utility or Product Availability: If DOE determines a 

technology to have significant adverse impact on the utility of the product to significant 

subgroups of consumers, or to result in the unavailability of any covered product type 

with performance characteristics (including reliability), features, sizes, capacities, and 

volumes that are substantially the same as products generally available in the United 

States at the time, it will not further consider this technology.

• Adverse Impacts on Health or Safety: If DOE determines that a technology will have 

significant adverse impacts on health or safety, it will not further consider this 

technology.

Those technology options not screened out by the above four criteria are called “design 

options” and are considered as possible methods of improving efficacy in the engineering 

analysis.

NEMA agreed with the four screening criteria, but stated that it is essential that 

performance enhancements meet a maximum three-year payback for consumer acceptance. 

NEMA also noted their concern regarding determining technological feasible technology options 

which have not been mass produced and met the litmus test of commercial offering. 

Additionally, NEMA stated that DOE assess whether combination of technology options are

technologically feasible together before determining them as technologically feasible for a given 

lamp type. (NEMA, No. 15 at p. 14)

As noted, DOE screens out technology options that will have an adverse impact on 

product utility to ensure that the functionality consumers are receiving will be preserved in 

higher efficacy products. Therefore, a period to determine consumer acceptance is unnecessary. 

DOE will consider technology options in prototype lamps or model lamps only when the lamp 

can be produced with commercially available technologies and information is available 

indicating that the lamp can be manufactured on a commercial scale at the time any final 

standards require compliance.

Soraa commented that the technology options for GSILs and CFLs come with 

considerable detriment of lifetime, small efficacy gains, or both. Soraa recommended that the 

only technology options for improving the efficacy of GSILs and CFLs should be switching to a 

more efficient lamp technology. (Soraa, No. 10 at p. 2) 

DOE recognizes that certain technology options result in an inverse relationship between 

efficacy and lifetime. However, DOE believes that the technology options under consideration 

can be adjusted to produce an optimal combination of efficacy and lifetime. Further, the impacts 

of lamp lifetime are considered in the cost assessment of this analysis. 

Soraa noted that all technology options for CFLs retain mercury, which is both 

poisonous, a threat to human safety, and a waste hazard. (Soraa, No. 10 at p. 2) Private citizen, 

Thomas Duchesneau commented that he hoped incandescent bulbs will still be available for 

residential use in the future, as CFLs bring on eye strain and headaches. (Duchesneau, No. 3 at p. 

1)

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DOE screens out any technology option that would have an adverse impact on health or 

safety. DOE is not aware of any reports or documentation regarding safety and health concerns 

resulting for the technology options under consideration for CFLs. Therefore, DOE is not 

considering screening out any CFL technology option due to adverse impact on health or safety.

Regarding the higher efficiency phosphor technology option for CFLs, NEMA stated that 

given rare earth phosphor availability and cost issues, all coating resources used in the 

implementation of higher efficiency phosphors are being used to reduce losses and optimize 

current technology performance rather than attain further improvements in lamp efficacy. 

(NEMA, No. 15 at p. 13) DOE has found lamps which utilize higher efficiency phosphors to be 

commercially available and of varying efficacies. DOE understands there are concerns regarding 

a limited supply of rare earth phosphors that may impact the application of this technology 

option. However, DOE considers this technology option as means of improving lamp efficacy to 

be practicable to manufacture, install, and service. Therefore, DOE finds that higher efficiency 

phosphors meet the screening criteria and is considering it as a design option. 

NEMA reiterated its comment made in the second review of the GSFL and IRL 

rulemaking that it is still appropriate to screen out the multi-photon phosphor technology because 

cost effective, improved performance phosphors have not been identified. (NEMA, No. 15 at p. 

12) In this preliminary analysis, DOE is considering screening out multi-photon phosphor 

technology based on the first criterion, technological feasibility, because the technology is still in 

the research phase and DOE is unaware of any prototypes or commercially available products 

that incorporate the technology. See chapter 4 of this TSD for further details.

In this preliminary analysis, of the GSL technology options identified for improving CFL 

efficacy, DOE is considering screening out the following:

CFL Technology Options

• Multi-photon phosphors because they could not be proven to be technologically feasible;

LED Technology Options

• Quantum dot and nanophosphor technologies because they could not be proven to be 

technologically feasible;

• Improved emitter materials because they could not be proven to be technologically 

feasible and/or practicable to manufacture, install and service; 

• AC LEDs because they could not be proven to be practicable to manufacture, install and 

service

The following are GSL technologies that DOE has not screened out and is still 

considering as design options:

CFL Design Options

• Highly Emissive Electrode Coatings

• Higher Efficiency Lamp Fill Gas Composition

• Higher Efficiency Phosphors

• Glass Coatings

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• Cold Spot Optimization

• Improved Ballast Components

• Improved Ballast Circuit Design

• Change in Technology

LED Design Options

• Efficient Down Converters (with the exception of quantum dots and nanophosphor 

technologies)

• Improved Package Architectures

• Alternative Substrate Materials

• Improved Thermal Interface Materials

• Optimized Heat Sink Design

• Active Thermal Management Systems

• Device Level Optics

• Increased Light Utilization

• Improved Driver Design

• Reduced Current Density

For further details on the screening out of GSL technology options, see chapter 4 of this 

TSD. DOE requests comments on the design options it is considering for GSLs.

2.7 ENGINEERING ANALYSIS

In the engineering analysis, DOE first selects representative product classes to analyze. It 

then selects baseline lamps within those representative product classes, and identifies more 

efficacious substitutes for the baseline lamps. DOE uses these more efficacious lamps to develop 

CSLs.

For this rulemaking, DOE derives CSLs in the engineering analysis and end-user prices 

in the product price determination. DOE estimates the end-user price of GSLs directly because 

reverse-engineering a lamp is impractical as the lamps are not easily disassembled. By 

combining the results of the engineering analysis and the product price determination, DOE 

derives typical inputs for use in the LCC and NIA. Section 2.8 discusses the product price 

determination (see chapter 6 of this TSD for further detail).

2.7.1 Approach

The following is a summary of the steps taken in the engineering analysis:

• Step 1: Select Representative Product Classes

• Step 2: Select Baseline Lamps

• Step 3: Identify More Efficacious Substitutes

• Step 4: Develop CSLs

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A more detailed discussion of the methodology DOE followed to perform the engineering 

analysis can be found in chapter 5 of this TSD. The following discussion summarizes the general 

steps of the engineering analysis:

Representative product classes: DOE first reviews covered lamps and the associated 

product classes. When a product has multiple product classes, DOE selects certain classes as 

“representative” and concentrates its analytical effort on these classes. DOE selects 

representative product classes primarily because of their high market volumes. For those product 

classes that are not directly analyzed, DOE extrapolates the CSLs from representative product 

classes.

Baseline lamps: For each representative product class, DOE selects a baseline lamp as a 

reference point against which to measure changes resulting from energy conservation standards. 

Typically, a baseline model is the most common, least efficacious lamp sold in a given product

class. For this preliminary analysis, DOE uses performance data presented in manufacturer 

catalogs to determine lamp efficacy. DOE also considers other lamp characteristics in choosing 

the most appropriate baseline for each product class such as lumen output, wattage, CCT, shape, 

and lifetime.

More efficacious substitutes: DOE selects higher efficacy lamps as replacements for each 

of the baseline models considered. When selecting higher efficacy lamps, DOE considers only 

design options that meet the criteria outlined in the screening analysis (see section 2.6 or chapter 

4 of this TSD). DOE also sought to maintain the baseline lamp’s characteristics, such as base 

type, CCT, and CRI among other specifications, for substitute lamps. For non-integrated GSLs, 

DOE pairs each representative lamp with an appropriate ballast because non-integrated GSLs are 

a component of a system, and their performance is related to the ballast on which they operate.

Candidate standard levels: After identifying the more efficacious substitutes for each 

baseline lamp, DOE develops CSLs. DOE bases its analysis on three factors: (1) the design 

options associated with the specific lamps studied; (2) the ability of lamps across the lumen 

range to comply with the standard level of a given product class;

53 and (3) the maximum 

technologically feasible CSL.

DOE received several comments on the general approach to the engineering analysis 

presented in the framework document. Regarding the data approach, CEC requested that DOE, 

when determining performance characteristics of lamps on the market, use DOE certification 

data, the LED Lighting Facts Database, CEC certification data, the Federal Trade Commission 

labeling data, and the ENERGY STAR qualified list. (CEC, No. 11 at p. 21)

On the topic of using certification data and verification testing data when establishing 

efficacy levels, NEMA commented that DOE must be careful in evaluating apparent outliers and

filter out data that may be the result of misunderstood reporting requirements or mistakes in 

reporting. NEMA cautioned DOE to give careful consideration to any data, including 

53 CSLs span multiple lamps of different lumen outputs and wattages. In selecting CSLs, DOE considered whether 

these multiple lamps can meet the standard levels.

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manufacturer catalogs, that is used in order to ensure that values reported are measured using the 

same test methods used in this rulemaking. (NEMA, No. 15 at p. 16) Westinghouse also made 

note of the possibility of data entry errors arising from confusion when entering lamps into the 

certification database. Westinghouse thus requested that DOE consider potential outliers in the 

database and to ignore those in any baseline establishment to avoid potentially creating a 

disruption in the market. (Westinghouse, Public Meeting Transcript, No. 19 at pp. 122-123) 

For the preliminary analysis, DOE used performance data of commercially available 

GSLs presented in manufacturer catalogs to identify potential baseline lamps and develop CSLs. 

DOE used catalog data as the basis of its engineering analysis because it is the largest and most 

comprehensive dataset. However, DOE also used publicly available test data from the CEC

Appliance Efficiency Certified Light Bulbs Database,

54 DOE’s LED Lighting Facts Product 

List,

55 ENERGY STAR Certified Light Bulbs database,56 and DOE’s CCMS database57 when 

possible to verify efficacies calculated from catalog values and to ensure lamps can comply with 

CSLs based on test data. Regarding outliers, DOE identified data outliers in both its collection of 

lamp performance data from manufacturer catalogs and in its review of efficacy values from the 

compliance and verification testing databases. DOE identified both on the high and low end 

outliers, and in cases where DOE was unable to verify the value using third-party data or 

manufacturer confirmation, did not consider the lamp in the engineering analysis. DOE 

welcomes comment on the data approach including any additional databases that should be 

considered.

Although certain products included in the scope of this rulemaking do not currently have 

DOE test procedures (e.g., LED lamps), industry standards for testing efficacy have been in 

place for several years for these products. Therefore, DOE believes that manufacturers and the 

organizations conducting verification testing are likely using existing industry standard test 

methods to determine performance values. As stated in section 2.2.3, EPCA directs DOE to 

establish test procedures for covered products in advance of prescribing an energy conservation 

standard. (42 U.S.C. 6295(o)(3)(A)) Thus, DOE plans to finalize test procedures for GSLs for 

which DOE is considering establishing standards prior to the completion of this rulemaking. 

2.7.2 Representative Product Classes

In the case where a covered product has multiple product classes, DOE identifies and 

selects certain product classes as “representative” and concentrates its analytical effort on those 

classes. DOE chooses product classes as representative primarily because of their high market 

volumes. In the framework document, DOE identified its methodology for selecting 

representative product classes and discussed its preliminary findings on the highest volume 

GSLs. DOE received several comments on the methodology of selecting representative product 

54 Certification data is publicly available on CEC’s Appliance Efficiency Database available here: 

http://www.appliances.energy.ca.gov/Default.aspx. 

55 DOE’s LED Lighting Facts Product List is publicly available here: http://www.lightingfacts.com/products. 

56 The ENERGY STAR Certified Light Bulbs database is publicly available here: 

http://www.energystar.gov/productfinder/product/certified-light-bulbs/results. 

57 DOE’s Compliance Certification Database is publicly available here: www.regulations.doe.gov/certification-data/.

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classes as well as the product classes from the framework document that should be directly 

analyzed. 

NEEA suggested that DOE consider more than shipment volume when selecting 

representative product classes, reasoning that there are many other factors that affect the 

economics of the analysis (e.g., lifetime of the product, predicted number of on/off cycles, etc.). 

(NEEA, Public Meeting Transcript, No. 19 at pp. 106-108) DOE typically chooses representative 

product classes based on the highest shipment volume and then scales its analytical findings for 

those representative product classes to other product classes that are not directly analyzed. 

However in this preliminary analysis, DOE is considering directly analyzing all product classes 

for GSLs. As stated in section 2.5.3.3, DOE is considering product class divisions based on 

ballast location. DOE is considering directly analyzing both the integrated and non-integrated 

product classes because of technological differences that would preclude scaling from the high 

volume integrated product class. Specifically, DOE observed different efficacy trends and 

maximum technologically feasible levels between the two classes. Further, manufacturer 

feedback indicated that scaling between the integrated and non-integrated product classes is not 

appropriate. DOE is also considering a product class division based on lumen package for the 

integrated product class as discussed in section 2.5.3.8. DOE is considering directly analyzing 

both the low lumen and high lumen integrated product classes. DOE has found that there are 

technological limitations to producing high lumen (i.e., 2,000 lumens or greater) GSLs using 

LED technology and therefore CSLs for this product class cannot be scaled from the low lumen 

output integrated product class.

Noting that standard CFLs are non-dimmable and comprise the majority of the market 

because LED lamps are an emerging product, NEMA questioned DOE’s determination that 

dimmable products are more common than non-dimmable products. (NEMA, Public Meeting 

Transcript, No. 19 at pp. 104-105) GE noted that for medium screw bases, more sockets have 

dimmable lamps because incandescent/halogen lamps are all dimmable. However, GE agreed 

that most sockets with CFLs or LED lamps are not currently dimmable. (GE, Public Meeting 

Transcript, No. 19 at pp. 105-106)

In the framework document, DOE determined the commonality of dimmable GSLs by 

evaluating product offerings in catalogs of dimmable CFLs and LED lamps, which cumulatively 

resulted in a majority of dimmable products. However, in this preliminary analysis, DOE is no 

longer considering dimmability as a product class division. See section 2.5.3 and chapter 3 of 

this TSD for further discussion of product classes.

In summary, DOE is considering analyzing all product classes as representative as shown 

(in gray) in Table 2.7.1. See chapter 5 of this TSD for further discussion.

Table 2.7.1 GSL Representative Product Classes

Lamp Type Lumen Package

Integrated GSLs 310-1,999

2,000-2,600

Non-Integrated GSLs 310-2,600

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2.7.3 Baseline Lamps

Once DOE identified the representative product classes for analysis, it selected 

baseline lamps to analyze in each class. Typically, a baseline lamp is the most common, least 

efficacious lamp that meets existing energy conservation standards. Specific lamp characteristics 

are used to characterize the most common lamps purchased by consumers today (e.g., wattage, 

CCT, CRI, and light output). Because certain products within the scope of this rulemaking have 

existing standards, GSLs that fall within the same product class as these lamps must meet the 

existing standard in order to prevent backsliding. (See 42 U.S.C. 6295(o)(1))

Thus, DOE is only considering baseline lamps in the integrated product classes that meet the 

existing standards for bare MBCFLs. The non-integrated product class does not have any 

applicable existing standards.

DOE received general comments regarding baseline lamps. NEMA and GE noted that 

although the most common lamp is not always the least efficacious, the least efficacious lamp for 

each product class is the most appropriate baseline. (NEMA, No. 15 at p. 15; GE, Public Meeting 

Transcript, No. 19 at pp. 114-115) CA IOUs agreed that efficacy should be the most important 

metric to consider when establishing the baseline. (CA IOUs, Public Meeting Transcript, No. 19 

at p. 116)

As noted, DOE considers both commonality and efficacy when selecting baseline lamps 

and thus selects the most common, least efficacious lamp that just meets existing standards 

(when applicable). DOE determines the most common product characteristics such as lumen 

output range, CCT, and CRI. Among lamps with those characteristics, DOE selects the least 

efficacious product as the baseline. 

CEC asked for clarification on whether incandescent technology would be considered as 

a baseline. (CEC, Public Meeting Transcript, No. 19 at pp. 120-121) NRDC urged caution to not 

prematurely or incorrectly lock down a baseline because the full impact of the first phase of the 

EISA standards for GSILs has not been seen yet, and the final phase of standards for 60 W and 

40 W lamps just became effective this year. NRDC noted that there is lag time in the impact of 

standards due to warehousing and stockpiling by manufacturers and retailers of lamps that were 

legal at the time of their production. (NRDC, Public Meeting Transcript, No. 19 at pp. 24-25)

As discussed in section 2.3.1, DOE is unable to analyze incandescent/halogen lamps in 

the rulemaking at this time. Therefore, DOE is considering CFLs and LED lamps when selecting 

the most common, least efficacious lamp to serve as the baseline. Further, DOE must only 

consider lamps that meet the most stringent existing standard for applicable product classes to 

ensure backsliding does not occur.

NRDC expressed concern regarding light output as a criterion for the baseline lamp 

stating that it could lead to a comparison of brighter lamps versus less bright. For example, a 

40 W lamp and its alternatives might be very different from 100 W lamps in terms of pricing and 

availability. NRDC suggested that multiple baseline lamps might be needed. (NRDC, Public 

Meeting Transcript, No. 19 at pp. 113-114)

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DOE considered light output, or lumen package, when selecting baseline lamps in each 

product class to ensure that the most common lamp was analyzed. As discussed in section 

2.5.3.8, DOE found differences in available technology between high lumen (2,000-2,600 

lumen) integrated lamps and low lumen (310-1,999 lumen) integrated lamps and thus created a 

product class division based on lumen package. DOE directly analyzes all product classes and 

has selected a baseline lamp in both the low lumen and high lumen integrated product classes. 

DOE does not believe that there would be substantial differences in consumer economics within 

each product class and therefore analyzed one baseline lamp for each product class. DOE 

requests comment on its analysis of one baseline lamp for each product class. 

2.7.3.1 Integrated Lamps

In this preliminary analysis, DOE identified baseline lamps in the integrated product 

classes as the most common, least efficacious lamps that meet existing standards for MBCFLs. 

For integrated GSLs, the most common lamps were determined based on characteristics such as 

lumen output, lifetime, CRI, and CCT. Based on a review of lamps that had the most common 

characteristics, DOE determined that the baseline lamp for the integrated low lumen product 

class is a 14 W, 750 lumen (i.e., 60 W equivalent) A-shape CFL with a lifetime of 10,000 hours, 

a CRI of 80, and a CCT of 2,700 K. Feedback collected during manufacturer interviews 

confirmed the 60 W equivalent lamps to be the highest volume GSL. For the integrated high 

lumen product class, DOE determined the baseline to be a 32 W, 2,000 lumen (i.e., greater than 

100 W equivalent) spiral CFL with a lifetime of 10,000 hours, a CRI of 80, and a CCT of 

2,700 K.

The characteristics of the baseline lamps in the integrated product classes that DOE is 

considering in this preliminary analysis are summarized in Table 2.7.2. See chapter 5 of this TSD 

for additional detail on the baseline selection process. DOE requests comment on the baseline 

units selected for the integrated product classes.

Table 2.7.2 Integrated Product Classes Baseline Lamps

Product 

Class

Lamp 

Shape

Base 

Type

Lamp 

Type

Nominal 

Wattage

Initial 

Lumens

Rated 

Efficacy Lifetime CCT CRI

W lm lm/W hr K

Integrated 

Low Lumen 

(310-1,999

Lumens)

A-Shape E26 CFL 14 750 53.6 10,000 2,700 80

Integrated 

High Lumen 

(2,000-

2,600 

Lumens)

Spiral E26 CFL 32 2,000 62.5 10,000 2,700 80

2.7.3.2 Non-Integrated Lamps

In the preliminary analysis, DOE identified the baseline lamp in the non-integrated 

product class as the most common, least efficacious lamp. The non-integrated product class does 

2-67
not have applicable existing standards and therefore the lowest efficacy lamps on the market 

were considered. For non-integrated GSLs, the most common lamps were determined based on 

characteristics such as wattage, lumen output, shape, base type, lifetime, and CCT. DOE found 

that the base types of non-integrated CFLs typically correspond to certain wattages and lumen 

outputs, and thus DOE concentrated on a common wattage and its associated base type. Based on 

a review of lamps that had the most common characteristics, DOE determined that the baseline 

lamp for the non-integrated product class is a 26 W, 1,710 lumen double tube58 G24q-3 base 

CFL with a lifetime of 10,000 hours and a CCT of 4,100 K. Feedback collected during 

manufacturer interviews confirmed the 26 W CFL to be the highest volume non-integrated GSL. 

The characteristics of the baseline lamp in the non-integrated product class that DOE is 

considering in this preliminary analysis are summarized in Table 2.7.3. See chapter 5 of this TSD 

for additional detail on the baseline selection process. DOE requests comment on the baseline

unit selected for the non-integrated product class.

Table 2.7.3 Non-Integrated Product Class Baseline Lamp

Lamp 

Shape

Base 

Type

Lamp 

Type

Nominal 

Wattage

Rated 

Wattage

Initial 

Lumens

Mean 

Lumens

Rated 

Efficacy Lifetime CCT CRI

W W lm lm lm/W hr K

Double 

Tube

G24q3 CFL 26 26 1,710 1,450 65.8 10,000 4,100 82

2.7.4 More Efficacious Substitutes

DOE selects a series of more efficacious replacements for the baseline lamps considered 

within each representative product class. DOE considered only technologies that met all four 

criteria in the screening analysis. These selections were made such that potential substitutions 

maintained light output within 10 percent of the baseline lamp’s light output with similar 

characteristics when possible. In identifying the more efficacious substitutes, DOE utilized a 

database of commercially available lamps. 

DOE received a general comment on the methodology used to identify more efficacious 

substitutes. NEMA urged caution regarding the use of modeling to identify higher-efficacy 

products. NEMA asserted that the list of design options must come from a commercially 

available, proven product and that only commercially available solutions can be fairly used to set 

efficacy levels. NEMA additionally cited its disagreements from other rulemakings that proposed 

inclusion of proprietary, laboratory-only, or prototypical technology options. (NEMA, No. 15 at 

p. 16)

When evaluating higher efficacy substitutes, DOE only considers lamps that incorporate 

technology options that meet the screening criteria described in section 2.6. DOE considers

technologies incorporated in commercially available products or in working prototypes to be 

technologically feasible. The technology must also be practicable to manufacture, install, and 

58 The double tube shape for CFLs, that is, a CFL with two U-shaped glass tubes, is also sometimes referred to as 

quad tube in industry. 

2-68

 
service, have no adverse impacts on product utility or product availability, and have no adverse 

impacts on health or safety. There is no requirement that an analyzed product be commercially 

available. However, in this preliminary analysis, DOE did not model any lamps and therefore the 

more efficacious substitute lamps under consideration are, in fact, commercially available 

products. 

Further details specific to the more efficacious substitutes of the integrated and nonintegrated product classes are discussed in the following sections. 

2.7.4.1 Integrated Lamps

For integrated GSLs, DOE identified more efficacious substitute lamps that saved energy 

and had light output within 10 percent of the baseline lamp’s light output. DOE selected more 

efficacious substitutes with same base type as the baseline lamp since replacing an integrated 

lamp with a lamp of a different base type would potentially require a fixture or socket change 

and thus is considered an unlikely replacement. In this preliminary analysis, DOE also ensured 

that the more efficacious substitutes were marketed as omnidirectional,59 thus maintaining the 

even light distribution of the baseline lamp. DOE found several lamp types marketed as semiomnidirectional. However, to ensure that the more efficacious substitutes could be used in the 

same applications as the baseline lamps, DOE only considered marketed as omnidirectional in 

this preliminary analysis. See chapter 5 of this TSD for additional details of the more efficacious 

substitutes selected. DOE requests comment on the criteria used in selecting more efficacious 

substitute lamps in the integrated product class, as well as the characteristics of the lamps 

selected. In particular, DOE requests comment on its assumptions that more efficacious 

substitutes must have lumen output within 10 percent of the baseline lamp and must be 

omnidirectional light sources.

2.7.4.2 Non-Integrated Lamps

For non-integrated GSLs, DOE considered more efficacious lamps that did not increase 

energy consumption relative to the baseline and had light output within 10 percent of the 

baseline lamp-and-ballast system when possible. Due to potential physical and electrical 

constraints associated with switching base types, DOE selected substitute lamps that had the 

same base type as the baseline lamp. DOE identified substitute lamps that were the same wattage 

as the baseline but produced more light and were therefore more efficacious or lamps that were 

lower wattage than the baseline but produced similar light and were therefore more efficacious. 

For further detail, see chapter 5 of this TSD. DOE requests comment on the criteria used in 

selecting more efficacious substitute lamps in the non-integrated product class, as well as the 

characteristics of the lamps selected. In particular, DOE requests comment on its assumptions 

that more efficacious substitutes must have lumen output within 10 percent of the baseline lampand-ballast system. DOE also requests comment on its assumption that the base type of the 

59 ENERGY STAR Lamps Specification V1.1 specifies luminous intensity distribution requirements for

omnidirectional light sources and is available here: 

http://www.energystar.gov/sites/default/files/ENERGY%20STAR%20Lamps%20V1%201_Specification.pdf. 

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baseline lamp in the non-integrated product class must be maintained for more efficacious 

substitutes.

DOE received a comment pertaining to the methodology outlined in the framework 

document for selecting more efficacious substitutes for the non-integrated product class. NRDC

asked if pin base CFLs will be analyzed with an assumed ballast because non-integrated lamps 

operate as part of a system. (NRDC, Public Meeting Transcript, No. 19 at pp. 64-65)

DOE pairs non-integrated GSLs with representative ballasts because the non-integrated 

GSLs analyzed in this preliminary analysis operate on a ballast in practice. To develop 

representative lamp-and-ballast system pairings, DOE determined the most common nonintegrated CFL ballasts based on manufacturer feedback and a survey of the market. Specifically 

in this rulemaking, DOE chose to pair the non-integrated GSLs with a one-lamp electronic 

ballast with programmed start starting method to represent the lamp-and-ballast combinations 

present in the market. See chapter 5 of this TSD for additional details. DOE requests comment 

on the lamp-and-ballast systems selected for the non-integrated product class.

2.7.5 Candidate Standard Levels

After identifying more efficacious substitutes for each of the baseline lamps, DOE 

develops CSLs based on the consideration of several factors, including: (1) the design options 

associated with the specific lamps being studied (e.g., grades of phosphor for CFLs, improved 

package architecture for LEDs); (2) the ability of lamps across the applicable lumen range to 

comply with the standard level of a given product class;60 and (3) the max-tech level. DOE 

received comments specific to the general methodology for selecting CSLs presented in the 

framework document.

The NRDC and ASAP joint comment, CEC, and CA IOUs urged DOE to establish

smooth, continuous efficacy levels as opposed to step functions because step functions 

encourage manufacturers to design products at the lowest efficacy requirements thus resulting in 

dimmer lamps. (NRDC, ASAP, et al., No. 17 at pp. 6-7; CEC, No. 11 at p. 13; CA IOUs, No. 18 

at pp. 9-10) ASAP stated that equation-based standards generally result in fewer discontinuities 

and reduced potential for gaming opportunities. (ASAP, Public Meeting Transcript, No. 19 at p. 

21) The NRDC and ASAP joint comment also noted that this approach is widely accepted and 

has been used by the European Union, its member countries, and other countries around the 

world. (NRDC, ASAP, et al., No. 17 at p. 7)

NEMA agreed with the application of an equation-based approach to efficacy standards

but noted that other approaches such as a step function and efficacy bins have been successful for 

certain technologies in the past. NEMA urged DOE to evaluate which approach would be best 

for the technology being regulated and reserved final comment until review of DOE’s 

preliminary analysis. (NEMA, No. 15 at p. 16) GE also suggested that a tiered or stepped 

60 ELs span multiple lamps of different lumen output and wattages. In selecting CSLs, DOE considered whether 

these multiple lamps can meet the ELs.

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approach could be considered in addition to an equation-based approach in this rulemaking. GE 

noted that the step approach was very successful in the previous incandescent rulemaking and 

noted that an equation-based approach is not always the best approach. (GE, Public Meeting 

Transcript, No. 19 at pp. 117-118)

CA IOUs commented on the step-based approach mentioned by DOE noting that Phase 1 

of the EISA standards caused manufacturers to introduce many products at the least efficacious 

part of the step function. Consequently, consumers ended up with products that may not have 

been as bright as what they thought they were getting. CA IOUs noted that a step-based approach 

creates a disincentive in the design process by giving an advantage to products that are less 

efficacious. (CA IOUs, Public Meeting Transcript, No. 19 at pp. 118-119) GE disagreed with CA 

IOUs regarding the success of the step function saying that the step function had the effect of 

manufacturers ending up at common wattages thus avoiding massive consumer confusion. GE 

noted that there are marketing, consumer education, and other industry benefits associated with a 

step function including consumer understanding of replacement wattages. (GE, Public Meeting 

Transcript, No. 19 at p. 119) NRDC, ASAP, et al. commented that it is inaccurate to state that 

the existing binned standards for incandescent lamps restricted wattages to four values, noting 

that 60 W incandescent lamps have been replaced with 43 W halogen lamps, CFLs between 

13 W and 15 W, and LED lamps between 9 W and 13 W. NRDC, ASAP, et al. further stated that 

more efficient incandescent lamps that use 50 percent less power for the same light are also 

expected to enter the market this year thus potentially introducing more wattage options. 

(NRDC, ASAP, et al., No. 17 at pp. 6-7)

DOE is considering an equation-based approach in this rulemaking. DOE is considering a 

continuous function based on its assessment that a step function, where efficacy rises 

significantly at certain increments in lumen output or wattage, is not representative of the 

technology used in the products covered by this rulemaking. DOE also recognizes that a step 

function increases the potential for products to be introduced at the lowest possible efficacy point 

in each step. While this could potentially encourage the development of similar-wattage products 

across the industry, DOE believes that a wide variety of replacement wattages are already 

available to consumers, and a wide variety will continue to be available in the future as new, 

more efficacious products are introduced. For these reasons, DOE believes that the limitations of 

a step function outweigh its benefits and is therefore considering a standard based on a smooth, 

continuous equation. See chapter 5 for more detail on CSLs and the equation-based approach.

Regarding whether standards should be based on lumen output or wattage, Philips 

suggested DOE group products by lumens instead of wattage because that is how the lamps will 

be bought for applications. Philips further noted that there are such large variations in the 

wattages for lamps used in the same application that it no longer makes any sense to group 

products by wattage. (Philips, Public Meeting Transcript, No. 19 at p. 117) NRDC agreed that 

future standards should be focused on lumen output and suggested setting minimum efficacy

standards as a function of light output. (NRDC, Public Meeting Transcript, No. 19 at p. 122) CA 

IOUs also agreed that standards and equations should be a function of lumen output rather than 

wattage because lumens identify the product utility. CA IOUs noted that there is a wide range of 

wattages that offer the same utility and thus wattage is no longer an indicator of the product’s 

core function, to produce light. CA IOUs noted that lamps that provide the same lumen output 

2-71
provide the same utility and therefore should have to meet the same performance standard. (CA 

IOUs, No. 18 at pp. 9-10; Public Meeting Transcript, No. 19 at p. 118) 

ACEEE commented that manufacturers, the advocacy community, and others have spent 

a lot of time and effort recently in educating the consumer about the importance of shopping 

based on lumens. ACEEE noted that as more products enter the market with very different 

wattages for delivering the same lumen package, the market will move away from purchasing 

based on wattage. ACEEE further commented that while the step function may have served the 

purpose of minimizing confusion for consumers in the past, hopefully consumers will have 

shifted to lumen-based purchasing before the standard takes effect. (ACEEE, Public Meeting 

Transcript, No. 19 at pp. 119-120) NRDC, ASAP, et al. also commented that manufacturers, 

retailers, DOE, FTC, EPA, utilities, and others have been working to educate consumers to buy 

lamps based on light output rather than wattage, and DOE should avoid setting a standard that 

encourages consumer reliance on energy use rather than light output as a measure of 

performance. (NRDC, ASAP, et al., No. 17 at p. 7)

DOE is considering a lumens-based approach in this preliminary analysis. Because the 

lamps covered by the scope of this rulemaking span different lighting technologies, GSLs 

designed to satisfy the same applications are available in a variety of wattages. DOE agrees that 

the primary utility provided by a lamp is lumen output, which can be achieved through a wide 

range of wattages depending on the lamp technology. For these reasons, DOE believes that 

lamps providing equivalent lumen output and therefore intended for the same applications should 

be subject to the same minimum efficacy requirements. Thus, DOE is considering an equationbased approach to establish CSLs for GSLs reflecting the relationship between efficacy and 

lumen output.

The following sections discuss the CSLs developed in the preliminary analysis for the 

integrated and non-integrated product classes in more detail.

2.7.5.1 Integrated Lamps

For this preliminary analysis, DOE analyzed CSLs for each of the integrated product 

classes. DOE used commercially available lamps and their associated efficacies to determine the 

design options required to meet each CSL. For the integrated product classes, DOE used the 

catalog initial lumen output and the catalog wattage of the lamp to calculate efficacy. To 

establish final minimum efficacy requirements for each CSL, DOE evaluated whether any 

adjustments were necessary to the initial CSLs to ensure lamps were available across the entire 

lumen range represented by the product class. DOE determined that adjustments to CSLs were 

necessary to ensure lamps were available across the entire lumen range. As discussed in section 

2.7.1, DOE also evaluated publicly available compliance and testing verification databases to 

ensure the CSLs were achievable. DOE determined that no adjustments to CSLs were necessary 

based on additional compliance and testing data. See chapter 5 of this TSD for more detail. The 

CSLs and characteristics of the representative lamp units for the integrated product classes are 

summarized in the table below. 

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Table 2.7.4 Integrated Product Class’ Representative Lamp Units

Product 

Class CSL Lamp 

Shape

Base 

Type

Lamp 

Type

Nominal 

Wattage

Initial 

Lumens

Rated 

Efficacy Lifetime CCT CRI

W lm lm/W hr K

Integrated 

Low 

Lumen

(310-1,999 

lumens)

Baseline AShape E26 CFL 14 750 53.6 10,000 2,700 80

CSL 1 Spiral E26 CFL 13 800 61.5 12,000 2,700 82

CSL 2 AShape E26 LED 12 800 66.7 25,000 2,700 82

CSL 3 AShape E26 LED 11 800 72.7 25,000 2,700 81

CSL 4 AShape E26 LED 10 800 80.0 25,000 2,700 82

CSL 5 AShape E26 LED 9.5 800 84.2 25,000 2,700 80

Integrated 

High 

Lumen

(2,000-

2,600 

lumens)

Baseline Spiral E26 CFL 32 2,000 62.5 10,000 2,700 80

CSL 1 Spiral E26 CFL 30 2,000 66.7 10,000 2,700 82

CSL 2 Spiral E26 CFL 29 2,200 75.9 12,000 2,700 82

For the integrated low lumen representative product class, five CSLs are being 

considered. The baseline represents a basic CFL with an efficacy near the existing MBCFL 

standard level. CSL 1 represents an improved CFL with more efficient phosphors and improved 

ballast components. CSL 2 represents a basic LED lamp with an efficacy near the lowest 

performing LED lamps currently available on the market. CSL 3 represents an improved LED 

lamp with improved package architecture, high efficiency driver, and improved optics. CSL 4 

represents an advanced LED lamp with further improved package architecture, high efficiency 

driver, and improved optics. CSL 5 is the maximum technologically feasible level and represents 

an LED lamp with the most efficacious combination of package architecture, driver, and optics 

available on the market today.

For the integrated high lumen representative product class, two CSLs are being 

considered. The baseline represents a basic CFL with an efficacy near the existing MBCFL 

standard level. CSL 1 represents an improved CFL with more efficient phosphors and improved 

ballast components. CSL 2 is the maximum technologically feasible level and represents the 

most efficacious combination of phosphors and ballast components.

2-73
DOE utilized a database of commercially available lamps to evaluate efficacy trends of 

integrated GSLs across a range of lumen outputs61 in order to fit the curve. DOE confirmed the 

curve fit matched product performance, particularly in the low and high ends of the GSL lumen 

range. As stated previously, DOE is considering establishing CSLs based on an equation for 

efficacy using lumens as the input. DOE requests comment on the methodology used to develop 

the CSLs equations. In particular, DOE requests comment on the use of a lumens-based equation 

and the equation form itself. DOE is considering the following equation form for integrated 

GSLs:

EEEEEEEEEEEEEEEE = AA − 29.42 ∗ 0. 9983LLLLLLLLLLLL

Eq. 2.1

Where:

Efficacy = minimum efficacy requirement,

Lumens = measured lumen output, and

A = an adjustment variable.

Because the equations account for changes in efficacy due to lumen output, they can also 

account for market shifts to new lumen packages. For each representative lamp unit, DOE 

calculated the “A-value” of the equation. The A-value is an adjustment variable that shifts the 

equation in a vertical direction and is calculated to represent certain levels of efficacy. DOE 

evaluated the equation against lamps with the same design options as the representative lamp 

unit for each CSL and made slight adjustments to capture the efficacy of lamps with those design 

options across the entire lumen output range. This allowed for continuous CSLs across product 

classes. DOE also reviewed test data as discussed in section 2.7.1 and found that compliance and 

verification testing data supported the CSLs under consideration. DOE did not make any 

adjustments to CSLs based on this additional data. See chapter 5 of this TSD for further detail. 

DOE received a comment pertaining to the CSLs of the integrated product classes. 

Earthjustice and NEEA commented that MBCFLs have existing standards ranging from 40 to 60 

lm/W, and therefore DOE cannot set standards for GSLs that apply to MBCFLs lower than these 

existing standards because DOE is prohibited from backsliding under 42 U.S.C. 6295(o)(1). 

Earthjustice and NEEA also noted the provision in section 325(i)(7)(B) that creates a limited 

exception for certain lamps including MBCFLs from the anti-backsliding provision, but further 

noted that Congress did not intend to lower standards for MBCFLs and therefore MBCFLs 

remain subject to existing standards that exceed 45 lm/W. (Earthjustice, NEEA, No. 12 at pp. 6-

7) DOE agrees that the anti-backsliding provision in 42 U.S.C. 6295(o)(1) applies and thus any 

standard prescribed for GSLs that is applicable to MBCFLs cannot be lower than the existing 

MBCFL standards. Therefore, DOE only considered CSLs for the integrated product classes that 

would not decrease the existing minimum efficacy requirements for MBCFLs in this preliminary 

analysis.

61 DOE included lamps that meet the definition of GSL but were outside the lumen range of 310 – 2,600 lumens 

because it believes this would result in a curve that better represents the relationship between efficacy and lumen 

output for the technologies analyzed.

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Table 2.7.5 summarizes the efficacy requirements at each CSL for the integrated product 

classes. DOE requests comment on the CSLs under consideration for the integrated product 

classes, including the max-tech levels.

Table 2.7.5 Summary of CSLs for GSL Integrated Representative Product Classes

Representative Product Class Candidate Standard Level Efficacy

lm/W

Integrated Low Lumen

(310 – 1,999 lumens)

CSL 1 67.6-29.42*0.9983^Lumens

CSL 2 74.2-29.42*0.9983^Lumens

CSL 3 80.2-29.42*0.9983^Lumens

CSL 4 87.5-29.42*0.9983^Lumens

CSL 5 90.8-29.42*0.9983^Lumens

Integrated High Lumen

(2,000 – 2,600 lumens)

CSL 1 67.6-29.42*0.9983^Lumens

CSL 2 74.2-29.42*0.9983^Lumens

2.7.5.2 Non-Integrated Lamps

For this preliminary analysis, DOE analyzed CSLs for the non-integrated product class. 

DOE used commercially available lamps and their associated rated efficacies to determine the 

design options required to meet each CSL. For the non-integrated product class, DOE used the 

catalog initial lumen output and the ANSI rated wattage of the lamp, or nominal wattage if the 

ANSI rated wattage was not available, to calculate efficacy. The CSL and characteristics of the 

representative lamp units for the non-integrated product class are summarized in Table 2.7.6.

Table 2.7.6 Non-Integrated Product Class Design Representative Lamp Units

CSL Lamp 

Shape

Base 

Type

Lam

p 

Type

Nomina

l 

Wattag

e

Rated 

Wattage

Initial 

Lumens

Mean

Lumen

s

Rated 

Efficac

y

Lifetim

e

CCT CR

I

W W lm lm lm/W hr K

Baselin

e

Doubl

e Tube

G24q

-3 CFL 26 26 1,710 1,450 65.8 10,000 4,100 82

CSL 1 Doubl

e Tube

G24q

-3 CFL 26 26 1,800 1,530 69.2 17,000 4,100 82

CSL 1 Doubl

e Tube

G24q

-3 CFL 21 21 1,525 1,310 72.6 20,000 4,100 82

For the non-integrated representative product class, one CSL is being considered. The 

baseline represents a basic CFL with an efficacy near the lowest performing non-integrated 

GSLs currently available on the market. DOE is considering two representative lamp units at 

CSL 1, consisting of a full wattage, improved CFL with more efficient phosphors and therefore 

more light output and a more efficient reduced wattage CFL that produces similar lumen output 

as the baseline unit. The full wattage representative lamp unit is used to set the minimum 

efficacy requirements of CSL 1 because it represents the maximum technologically feasible level 

that applies across all lumen packages within this product class. DOE added a second 

representative unit, the reduced wattage CFL, which gives consumers the option to replace their 

current full wattage lamp with one that saves energy. 

2-75
For this preliminary analysis, DOE evaluated whether replacing the baseline lamp with 

more efficacious substitutes at the higher CSL would require a fixture change. However, based 

on an assessment of commonly available fixtures on the market, DOE found that the fixtures 

frequently used with the non-integrated GSLs analyzed were available in configurations for 

several different lamp types. Therefore, DOE assumed that fixture compatibility would not be an 

issue for the vast majority of consumers. Similarly, DOE evaluated the impacts of CSL 1 on the 

individual base types in the non-integrated product class. DOE confirmed that the vast majority 

of base types were still available at CSL 1, and therefore consumers will not be forced to switch 

between lamps with differing base types.

62 Further, because the different bases are maintained at 

CSL 1 and base type dictates the required ballast, consumers will not be required to change 

ballasts with CSL 1. DOE also ensured that the impacts of CSL 1 are consistent across the lumen 

output range of the entire product class. See chapter 5 of this TSD for more detail. DOE requests 

comment on its assumption that fixture compatibility would not be a common issue for nonintegrated GSL replacements. DOE also requests comment on its assumption that consumer 

utility will not be lost with the base types that remain at CSL 1. 

DOE utilized a similar methodology as the integrated product classes to develop the CSL 

equation. DOE again analyzed products outside of the GSL lumen range in order to create the 

best curve fit possible for the product class, and confirmed the curve fit matched product 

performance. DOE is considering the following equation form for non-integrated GSLs:

EEEEEEEEEEEEEEEE = AA − 25.00 ∗ 0.9989LLLLLLLLLLLL

Eq. 2.2

Where:

Efficacy = minimum efficacy requirement,

Lumens = measured lumen output, and

A = an adjustment variable.

DOE calculated the “A-value” for the representative lamp unit used to set the minimum 

efficacy requirements of CSL 1. DOE then evaluated the equation against lamps with the same 

design options as the representative lamp unit and made slight adjustments to capture the 

efficacy of lamps with those design options across the entire lumen output range. In particular, 

DOE ensured that lamps of different base types were represented at the CSL. See chapter 5 of 

this TSD for further detail. Table 2.7.7 summarizes the efficacy requirement of CSL 1 for the 

non-integrated GSLs. DOE requests comment on the CSL under consideration for the nonintegrated product class.

62 DOE identified three base types that are potentially unable to meet CSL 1 out of an original 26 base types. Based 

on consultation with manufacturers and electrical distributors, DOE believes these base types are discontinued or are 

used in applications (e.g., desk lamps) that have already transitioned to higher efficiency technologies. 

2-76

 
Table 2.7.7 Summary of CSLs for GSL Non-Integrated Representative Product Class

Representative Product Class Candidate Standard Level Efficacy

lm/W

Non-Integrated

(310 – 2,600 lumens) CSL 1 72.6-25.00*0.9989^Lumens

2.7.6 Scaling to Other Product Classes

DOE identifies and selects certain product classes as representative and analyzes these 

product classes directly. DOE determines certain product classes to be representative due to high 

market volumes and/or distinct characteristics. CSLs for product classes that are not directly 

analyzed (“non-representative product classes”) are then determined by scaling from the CSLs of 

the representative product classes. However, DOE chose to directly analyze all product classes as 

representative in this preliminary analysis. Thus, no scaling was required.

2.8 PRODUCT PRICE DETERMINATION

Typically, DOE develops manufacturing selling prices (MSPs) for covered products and 

applies markups to create end-user prices to use as inputs to the LCC analysis and NIA. Because 

GSLs are difficult to reverse-engineer (i.e., not easily disassembled), DOE directly derives enduser prices for the lamps covered in this rulemaking. In the framework document, DOE proposed 

estimating end-user prices for lamps by establishing discounts from manufacturer suggested 

price lists (hereafter “blue-book prices”). DOE received several comments on pricing 

methodology presented in the framework document.

CA IOUs and ASAP questioned DOE’s approach specifically asking how DOE would 

estimate prices of any new products or technologies that are not commercially available without 

a developing a cost efficiency curve. (CA IOUs, Public Meeting Transcript, No. 19 at pp. 139-

140; ASAP, Public Meeting Transcript, No. 19 at p. 23) NRDC, ASAP, et al. suggested that to 

develop prices for products that are not commercially available or sold in low quantities, DOE 

should supplement its retail price data with the engineering analysis. (NRDC, ASAP, et al., No. 

17 at p. 11)

If DOE analyzes prototype lamps or model lamps, DOE will determine pricing for these 

lamps based on information available at the time of the analysis – such as the cost-efficiency 

relationship of other analyzed lamps, the cost of commercially available lamps that utilize similar 

technology or components, manufacturer-provided data, and any other relevant sources. 

However, in this preliminary analysis DOE is not considering any lamps that are not 

commercially available. 

CEC pointed out lamp prices are impacted by non-efficiency factors including lamp 

characteristics such as CRI and lifetime, as well as warrantees, brand value, packaging quality, 

inventory cost, and profit margin. CEC noted that DOE’s analysis would include both high-end 

products marketed to consumers not sensitive to prices as well as products that are marketed to 

consumers sensitive to price, rendering the comparison invalid. CEC suggested that DOE should 

disaggregate the cost of non-efficiency features and normalize to profit margins. CEC also 

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suggested that to account for the wide variation in product lifetimes DOE should normalize 

prices based on dollars per lumen-year. (CEC, No. 11 at p. 19; CEC, Public Meeting Transcript, 

No. 19 at pp 144-145)

In the product price determination, DOE develops end-user prices for each representative 

lamp. These representative lamps reflect the common characteristics (e.g., CCT, CRI, lifetime) 

of lamps being purchased by consumers within a product class. With regards to these nonefficiency factors and factors related to how the lamp is being sold (e.g., warranties, packaging, 

profit margins), DOE notes that the end-user price is inclusive of these costs – such as the 

manufacturer’s cost to offer a specific warranty, use certain packaging, and earn a desired profit. 

The final product available on shelves reflects a combination of features as determined by the 

manufacturer - consumers cannot pick and choose among them. Therefore, DOE has not 

disaggregated the cost of these features and instead presents only the end-user price. Further, 

product lifetimes are considered in the life-cycle cost analysis of the lamp. See section 2.10.

NRDC, ASAP, et al. noted actual retail prices can vary greatly and are frequently well

below blue book prices and encouraged DOE to supplement its analysis with a range of retail 

outlet data that accounts for different types of retailers (e.g., high volume versus low volume)

and package sizes in which bulbs are sold. They further suggested DOE weight its pricing data 

according to the percentage of sales associated with each type of retailer. (NRDC, ASAP, et al., 

No. 17 at p. 7; NRDC, Public Meeting Transcript, No. 19 at pp. 129-134) NRDC also urged 

DOE not to make the assumption that a less efficient lamp, costs less as future LED lamps might 

not only be more efficient, but also cost less. (NRDC, Public Meeting Transcript, No. 19 at pp. 

129-130)

Because blue book price data was not available for all GSLs, DOE was unable to utilize 

blue book prices to develop end-user prices in the preliminary analysis. Therefore, DOE 

reviewed and used publicly available retail prices for GSLs to develop end-user prices for each 

CSL. In its review of price data, DOE observed a range of end-user prices paid for a lamp, 

depending on the distribution channel through which the lamp is purchased. DOE identified four 

main distribution channels (large consumer-based distributors [e.g., home centers], small 

consumer-based distributors [e.g., drug stores], electrical distributors, and state procurement). 

DOE then developed an average weighted end-user price using the estimated percentage of 

shipments that go through each distribution channel based on feedback from interviews with 

manufacturers. Additionally, DOE assessed and accounted for the general price trends in relation 

to efficacy for all GSLs. For example, DOE noted that available data indicated that LED lamp 

prices decreased with increased lamp efficacy and confirmed that calculated end-user prices 

reflected this trend. Once DOE calculated end-user prices, DOE added sales tax and, if 

appropriate, installation costs to derive the total, installed end-user cost. See chapter 6 of this 

TSD for further details. DOE invites comment on the methodology and results for estimating 

end-user prices for GSLs in this preliminary analysis. 

GE noted that the distribution of GSLs is broader than for commercial products, and 

suggested DOE expand its list of distribution channels presented in framework document to 

consumer channels such as mass merchants, drug stores, and grocery stores. (GE, Public Meeting 

Transcript, No. 19 at pp. 132-133) ALA noted that new retailers such as battery stores and 

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consumer-oriented lighting showrooms are beginning to enter the CFL and LED lamp market. 

(ALA, Public Meeting Transcript, No. 19 at pp. 133-134) NEMA asserted that because screwbased products target the same end-user/socket distribution channels for these products do not 

vary by technology. NEMA noted, however, that smaller distribution channels may tend to 

feature less expensive technologies, and therefore, may not carry LED lamps. NEMA also stated 

that remotely ballasted pin base CFLs tend to be distributed through commercial channels. 

(NEMA, No. 15 at p. 18) 

In the framework document, DOE had noted the following potential distribution channels 

for the pricing analysis: State procurement contracts, large electrical supply distributors, home 

improvement/hardware stores, and other sources of publicly available end-user prices, such as 

Internet retailers. Based on further research and feedback from manufacturers, DOE identified 

other channels from which consumers commonly purchase GSLs. Therefore, in this preliminary 

analysis, in addition to the channels mentioned in the framework document, DOE also gathered 

prices from mass merchants (e.g., Walmart), grocery stores (e.g., Safeway), and drug stores (e.g.,

CVS). DOE did not include battery stores and lighting showrooms in its analysis as DOE 

research and feedback from manufacturers indicate they are not considered common channels 

through which consumers purchase GSLs. 

Further, based on feedback from manufacturer interviews and an assessment of lamp 

price data and trends, DOE determined that certain GSL distribution channels should be grouped 

together. DOE determined that home centers, hardware stores, and mass merchants could be 

appropriately grouped into one distribution channel based on their similarity in price and target 

market. DOE also determined that Internet retailers, grocery stores, and drug stores could be 

grouped into one distribution channel because they all offer consumers a more convenient 

purchasing option at a typically increased cost. In summary, DOE identified the following four 

main distribution channels for GSLs in this preliminary analysis: 

• Large consumer-based distributors: Home Centers, Hardware Stores, and Mass

Merchants

• Small consumer-based distributors: Internet Retailers, Grocery Stores, and Drug Stores

• Electrical Distributors

• State Procurement

Further, as NEMA noted and as is reflected by DOE research and feedback in 

manufacturer interviews, distribution channels do not generally vary by technology type. 

Therefore, DOE considers the four main distribution channels identified above for all GSLs. 

However, based on stakeholder comments and feedback from manufacturer interviews, DOE 

acknowledges that a larger volume of non-integrated GSLs go through commercial distribution 

channels than integrated GSLs. Therefore, DOE applied different percentage weightings to each 

distribution channel for integrated versus non-integrated GSLs. For the integrated GSLs, large 

consumer-based distributors were estimated at 75 percent, small-consumer-based distributors at 

10 percent, electrical distributors at 10 percent, and State procurement at 5 percent. For nonintegrated GSLs, large consumer-based distributors were estimated at 10 percent, smallconsumer-based distributors at 5 percent, electrical distributors at 75 percent, and State 

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procurement at 10 percent. See chapter 6 of this TSD for further details. DOE requests comment 

on the appropriateness of the distribution channels and estimated percentage shipments through 

each channel used in this preliminary analysis.

2.9 ENERGY-USE CHARACTERIZATION

The purpose of the energy use analysis is to identify how products are used by 

consumers, and thereby determine the energy savings potential of energy efficiency 

improvements. DOE determines the energy consumption of lamps using estimates of a lamp’s

power consumption (i.e., the rate of energy consumed, in watts) and estimates of the way 

consumers use the lamp (i.e., operating hours per year and the impact of controls such as 

dimmers). This analysis, which is meant to represent typical energy consumption in the field, is 

an input to both the LCC and PBP analyses and the NIA. 

 In the framework document, DOE indicated that it would derive annual energy 

consumption of lamps by multiplying the power rating by the number of hours of operation per 

year. DOE further stated that it would use the LMC and recent versions of EIA’s CBECS, RECS,

and the Manufacturing Energy Consumption Survey (MECS)63 to determine operating hours by 

building type and Census Division. DOE received several comments on the methodology 

presented in the framework document. 

NEMA agreed with the proposed methodology, but suggested that DOE consider 

establishing separate operating hours by technology. (NEMA, No. 15 at p. 17) For the 

preliminary analysis, DOE did not use separate operating hours by technology, but instead 

assumed that the operating hours for lamps considered by this rulemaking are the same as the 

current operating hours for all GSLs. 

Because GSILs are not included in the scope of this rulemaking, DOE assumed that any 

GSL final rule would not yield sufficient energy savings to avoid triggering the EISA 2007 45 

lm/W backstop. Therefore, DOE assumed that the backstop will go into effect on January 1, 

2020, per statutory requirement. Given the statutory requirement to publish a GSL final rule by 

January 1, 2017, and the requirement for the compliance date to be at least three years after the 

publication of a GSL final rule, DOE assumed that the compliance date for any final GSL rule 

would be concurrent with the compliance date for the EISA 2007 backstop. (See 42 U.S.C. 

6295(i)(6)(A)(ii), (i)(6)(A)(iii) and (i)(6)(A)(v)) Thus, during the analysis period, DOE assumes 

that CFL and LED GSLs will be filling all sockets currently filled by GSLs. Although some 

metering studies have observed higher hours of operation for CFL GSLs compared to 

incandescent/halogen GSLs—such as NMR Group, Inc.’s Northeast Residential Lighting Hours63 Administration., U.S. Department of Energy–Energy Information Manufacturing Energy Consumption Survey.

2010 MECS Survey Data. 2013. Washington, D.C. (Last Accessed September 15, 2014.) 

http://www.eia.gov/consumption/manufacturing/data/2010/. 

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of-Use Study64 —DOE assumed that the higher hours of use found for CFL GSLs is based on 

those lamps currently disproportionately filling sockets with higher hours of use. This would not 

be the case during the analysis period, when CFL and LED GSLs are expected to fill all GSL 

sockets. This assumption is equivalent to assuming no rebound in operating hours as a result of 

more efficacious technologies filling sockets currently filled by less efficacious technologies 

prior to, or as a result of, the EISA 2007 backstop. Additionally, operating hours were assumed 

to be equivalent for CFL and LED GSLs in the reference scenario. In other words, the reference 

scenario assumed no rebound as a result of a potential GSL energy conservation standard. 

Additional rebound scenarios are discussed in section 2.12 and in chapter 10. 

NRDC, ASAP, et al. encouraged DOE to collect hours of use data from a variety of 

sources and suggested that the daily hours of use results from the Residential Lighting End-Use 

Consumption Study: Estimation Framework and Initial Estimates (RLEUCS)65 are potentially 

too low. (NRDC, ASAP, et al., No. 17 at p. 12) NEEA pointed out that an online database would 

be made available containing GSL socket metering data by fixture, room, and lamp type. 

(NEEA, Public Meeting Transcript, No. 19 at pp. 91-92) 

In addition to drawing information from LMC, CBECS, and RECS, DOE collected data 

from a number of sources in order to characterize GSL energy use. For the residential sector, 

DOE used hours of use data from metering studies in California,66 Georgia,67 North Carolina,68

64 NMR Group, DNV GL. Northeast Residential Lighting Hours-of-Use Study. May 5, 2014. Prepared for

Connecticut Energy Efficiency Board, Cape Light Compact, Massachusetts Energy Efficiency Advisory Council, 

National Grid Massachusetts, National Grid Rhode Island, New York State Energy Research and Development 

Authority. (Last Accessed August 22, 2014.) 

65 DNV KEMA Energy and Sustainability, Pacific Northwest Laboratory. Residential Lighting End-Use

Consumption Study: Estimation Framework and Baseline Estimates. December 2012. (Last Accessed September 

15, 2014) http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2012_residential-lighting-study.pdf. 

66 DNV KEMA Energy and Sustainability, Pacific Northwest Laboratory. Residential Lighting End-Use

Consumption Study: Estimation Framework and Baseline Estimates. December 2012. (Last Accessed September 

15, 2014) http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2012_residential-lighting-study.pdf. 

67 Nexant, Inc., and Apex Analytics, LLC. Georgia Power Company Residential Lighting Saturation and Metering 

Study. October 4, 2013. Prepared for Georgia Power Company. (Last Accessed August 22, 2014.) 

68 Navigant Consulting, Cadmus Group, Inc, and Apex Analytics LLC. EM&V Report for the 2010-2011 Residential 

Energy Star Lighting Program. June 27, 2012. Prepared for Duke / Progress Energy Carolinas (Last Accessed 

August 22, 2014.) 

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South Carolina,69 Maryland,70 Ohio,71 Illinois,72 the Northwest,73 and the Northeast.74 Some of 

the metering studies separately reported daily hours of use for all GSLs and for the subset of 

CFL GSLs. Others studies only reported operating hours for CFL GSLs. If daily operating hours 

for all GSLs were not reported in a particular metering study, a correction factor (based on the 

average fractional difference in operating hours between all GSLs and CFL GSLs from recent 

metering studies that reported both) was used to estimate daily operating hours for all GSLs. 

NEMA stated that DOE should pay attention to specific location and time of use and 

whether an application is residential or commercial/industrial. (NEMA, No. 15 at p. 17) DOE 

characterized GSL energy use separately for the residential and commercial sectors. In 

determining energy use in the residential sector, DOE used daily hours of use metered data for 

regions where the data were available; for all other regions, DOE used daily hours of use values 

based on the metered data from adjacent regions (see chapter 7 of this TSD for more detail). For 

the commercial sector, DOE used average daily hours of use data by building type from LMC. 

DOE notes that the installed stock of GSLs in the industrial sector is less than 1 percent of the 

installed stock in the commercial sector according to LMC; furthermore, DOE assumes that the 

hours of operation for GSLs in the industrial sector (e.g., in offices) are approximately equal to 

the hours of operation for GSLs in the commercial sector. Therefore, DOE analyzed these two 

sectors together (using data specific to the commercial sector), and refers to the combined sector 

as the commercial sector.

During the framework public meeting, stakeholders commented on DOE's analysis of 

dimmable GSLs. Philips inquired as to how DOE will account for the amount of time dimmable 

GSLs are dimmed and also noted that DOE cannot use a uniform dimming factor across 

technology types, because some technologies cannot be dimmed. (Philips, Public Meeting 

Transcript, No. 19 at pp. 148-149) NRDC suggested DOE collect data on the percentage of 

dimmable GSLs in the market, noting that dimmable GSLs likely represent a small part of the 

market and therefore should be treated separately from the non-dimmable lamps in terms of 

69 TecMarket Works and Building Metrics. Duke Energy Residential Smart $aver CFL Program in North Carolina 

and South Carolina: Results of a Process and Impact Evaluation. February 15, 2011. (Last Accessed August 22, 

2014.)

70 Navigant Consulting, and Cadmus Group, Inc. EmPOWER Maryland 2010 Interim Evaluation Report. January 

15, 2011. Prepared for Baltimore Gas and Electric, Potomac Electric Power Company, Delmarva Power and Light 

(DPL), Southern Maryland Electric Cooperative (SMECO), and Allegheny Power (AP). (Last Accessed August 22, 

2014.) 

71 Vermont Energy Investment Corporation. State of Ohio Energy Efficiency Technical Reference Manual. August 

6, 2010. Prepared for the Public Utilities Commission of Ohio. 

72 Cadmus Group, Inc. Lighting and Appliance Evaluation—PY 2. December 2010. Prepared for Ameren Illinois. 

(Last Accessed August 22, 2014.) 

73 Northwest Energy Efficiency Alliance. Residential Building Stock Assessment Metering Study. April 28, 2014.

Seattle, WA. Report #E14-283. (Last Accessed June 20, 2014) 

74 NMR Group, DNV GL. Northeast Residential Lighting Hours-of-Use Study. May 5, 2014. Prepared for

Connecticut Energy Efficiency Board, Cape Light Compact, Massachusetts Energy Efficiency Advisory Council, 

National Grid Massachusetts, National Grid Rhode Island, New York State Energy Research and Development 

Authority. (Last Accessed August 22, 2014.) 

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energy use. (NRDC, Public Meeting Transcript, No. 19 at p. 150) An independent stakeholder 

also noted the importance of considering lighting controls—specifically dimming and sensors—

stating that controls are an easy way to limit wattage use and prolong lamp life. (Madden, No. 4 

at p. 1) 

DOE acknowledges that dimmability and lighting controls are important factors in 

estimating energy consumption of GSLs. Rather than estimating the amount of time dimmable 

GSLs are dimmed, DOE estimated a 30 percent decrease in energy use for all installation 

locations with controls (whether dimming or other types of controls) in both the residential and 

commercial sectors, based on a meta-analysis of field measurements of energy savings from 

commercial lighting controls by Williams et al.75 DOE estimated that five percent of CFL GSLs 

can be dimmed, whereas no such limit was placed on LED GSLs (though they may not be 

installed in fixtures which are dimmable). 

In analyzing the commercial sector, DOE used LMC data to determine that, in 2010, 30 

percent of commercial buildings employ some means of lighting control (3 percent dimming, 27 

percent switching-based controls or a combination of switching and dimming). DOE then used a 

model to estimate the commercial floor area incorporating controls, accounting for the current 

variation in standards adopted by the States, the relevant floor area in each State, the breakdown 

of floor area by application, and the code requirements for each floor area application. By the 

end of the analysis period (2049), DOE estimates that approximately 80 percent of commercial 

buildings employ some means of lighting control. 

In analyzing the residential sector, DOE assumed the same energy use reductions from 

employing dimmers or other controls as in the commercial sector. DOE used LMC data to 

determine that 14 percent of residential fixtures employed some form of lighting control (12

percent dimming, 2 percent switching-based controls) in 2010, and DOE assumed that the 

fraction of residential fixtures employing controls remained constant over the analysis period. 

The limit of five percent of CFL GSLs being dimmable resulted in the estimation of more than 

14 percent of LED GSLs being installed in fixtures with controls in the LCC savings, shipments 

and national impact analyses. 

DOE also estimated that the market share of “smart” LED GSLs, with controls integrated 

into the lamp, would grow according to a Bass diffusion curve over the course of the analysis 

period. DOE assumed that the energy saving associated with these integrated controls would be 

the same as the energy savings for GSLs used with fixtures employing controls. See chapter 10 

of this TSD for more discussion of the modeling of the market share of smart LED GSLs and the 

national impact of such lamps. 

75 Williams, A., B. Atkinson, K. Garbesi, E. Page, and F. Rubinstein. Lighting controls in commercial buildings. 

2012. Leukos 8(3) pp. 161-180. (Last Accessed August 8, 2014.) 

http://ies.tandfonline.com/doi/pdf/10.1582/LEUKOS.2012.08.03.001#.VH9IAzHF-UY. 

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2.10 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS

The impacts of amended energy conservation standards on consumers often include a 

change in operating expense (usually decreased energy costs) and a change in purchase price 

(usually increased). The life-cycle cost (LCC) of a product is the cost it incurs over its lifetime, 

taking into account both purchase price and operating expenses. The payback period (PBP)

represents the time it takes to recover the additional installed cost of the more efficient products

through annual operating-cost savings. DOE analyzes the net effect on consumers by calculating 

the LCC and PBP using the engineering performance data, the product price determined in 

chapter 6, the product price learning rate developed in the shipments analysis, and the energy use 

results. Inputs to the LCC calculation include the installed cost to the consumer (purchase price 

plus installation cost), operating expenses, the lifetime of the product or another defined period 

of analysis, and a discount rate. Inputs to the PBP calculation include the installed cost to the 

consumer and first-year operating costs.

The engineering analysis presents representative lamp data for lamps at a specific lumen 

level. Because of the high variability in LED lamp prices across lumen ranges, DOE analyzed 

the LCC and PBP across four lumen bins (310-749 lm, 750-1,049 lm, 1,050-1,489 lm, and 1,490-

1,999 lm) for the integrated low-lumen product class, which is the only product class that 

includes LED lamps. DOE used online retailer data, market share data of each lumen bin, and the 

efficacy-to-lumen relationship developed in the engineering analysis to generate representative 

lamp data for all lumen bins, across all CSLs for the integrated low-lumen product class. 

Recognizing that several inputs to the determination of consumer LCC and PBP are 

either variable or uncertain, DOE conducted the LCC and PBP analyses by modeling the 

variability in the inputs using Monte Carlo simulation and probability distributions. Each Monte 

Carlo simulation consists of 10,000 LCC and PBP calculations. The model performs each 

calculation using input values that are either sampled from probability distributions and building 

or household samples or characterized with single point values. For example, DOE accounted for 

variation in residential and commercial daily hours of use by generating distributions. For the 

residential sector, DOE derived hours of use distributions by room type from the database 

associated with the NEEA Residential Building Stock Assessment Metering (RBSAM) Study.

76

For the commercial sector, DOE mapped the daily hours of use values for each LMC building 

type to the CBECS building types. DOE then developed triangular daily hours of use 

distributions for each CBECS building type, with the mean of each distribution corresponding to 

the respective building type’s average daily hours of use. 

DOE used a “simple” PBP for this rulemaking, which is the ratio of the increase in 

purchase cost (i.e., from a less efficient design to a more efficient design) to the decrease in 

annual operating expenditures. The “simple” PBP does not take into account other changes in 

operating expenses over time or the time value of money. 

76 Northwest Energy Efficiency Alliance Residential Building Stock Assessment Metering Study. April 28, 2014. 

Seattle, WA. Report #E14-283. (Last Accessed June 20, 2014)

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In regard to the PBP, NEMA stated that consumers demand a short payback period, and 

recommended DOE use a maximum of three years. (NEMA, No. 15 at p. 18) DOE 

acknowledges consumer sensitivity to PBP. DOE conducts a PBP analysis on each of the 

selected CSLs, and those PBP results help inform the selection of a potential energy conservation 

standard.

DOE received a number of written comments as well as statements from stakeholders at 

the public meeting relating to the LCC analysis. CEC suggested DOE use the average number of 

operating hours of all GSLs today for its LCC analysis, treating every lamp as an equal 

competitor for any given GSL socket in the market. (CEC, No. 11 at p. 20) DOE agrees with 

CEC and has used the average operating hours of all GSLs in the analyses.

DOE received a number of comments of the lifetimes of GSLs. NRDC, ASAP, et al., GE, 

and ASAP recommended DOE account for different product lifetimes in its analysis, with GE 

specifically indicating that different lamp technologies offer different levels of convenience to 

the consumer by way of frequency of replacement. (NRDC, ASAP, et al., No. 17 at p. 12; GE, 

Public Meeting Transcript, No. 19 at pp. 148-149; ASAP, Public Meeting Transcript, No. 19 at 

pp. 158-159) NRDC also recommended DOE use residual value calculations to account for the 

different GSL lifetimes. (NRDC, No. 17 at pp. 12-13) 

To account for differences in the lifetime of lamps at different levels of efficacy, DOE 

incorporated a residual value in the LCC calculation. The residual value is an estimate of the 

product’s value to the consumer at the end of the LCC analysis period. For this rulemaking, the 

LCC analysis period is the lifetime of the product within a product class with the shortest 

lifetime. The residual value recognizes that some lamps have a longer lifetime and may continue 

to function beyond the end of the LCC analysis period. Thus, consumers of longer-lived lamps 

do not have to incur the purchase of another lamp at the end of the LCC analysis period. The 

residual value calculation conducted for this preliminary analysis took into account the timevalue of money and the decline in lamp prices over time. Details of the LCC calculation can be 

found in chapter 8 of this TSD.

NEEA commented that the energy savings depend on the lifetime of the product, hours of 

use and, in some cases, how many times it is switched on and off. (NEEA, Public Meeting 

Transcript, No. 19 at pp. 107-108) DOE used data from a CFL Laboratory Testing Report

submitted to the California Public Utilities Commission77 for information regarding the effect of 

on-cycle switching time on CFL life. DOE assumed that the lifetime of LED GSLs was not 

affected by on/off switching.

For the LCC, PBP, and subsequent analyses, the relevant GSL lifetime is the service

lifetime of the GSL (i.e., the age at which the GSL is retired from service), and not the technical 

lifetime of the GSL. To characterize the uncertainty in GSL lifetime, DOE conducted three 

separate GSL survival probability (lifetime) scenarios:

77 James J. Hirsch and Associates, Erik Page & Associates, Inc. CFL Laboratory Testing Report: Preliminary 

Results from a CFL Switching Cycle and Photometric Laboratory Study. Submitted to the California Public Utilities 

Commission Energy Division on May 21, 2012.

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Scenario 1: The probability of survival as a function of the analysis year is a distribution of 

lamp lifetimes considering the lamp's rated lifetime (in hours), sector-specific 

hours-of-use distributions, and effects of on-cycle length on CFL lifetimes; 

Scenario 2: This scenario (the reference scenario) uses the probability of survival used in 

Scenario 1, truncated by a Weibull distribution with a median of 20 years to 

account for lamp turnover when a renovation or retrofit occurs; and

Scenario 3: For LED GSLs, this scenario uses the probability of survival in Scenario 1, 

truncated by a Weibull distribution with a median of 5 years, to account for the 

possibility of the service lifetime of LED GSLs being similar to those of 

consumer electronic devices. The probability of survival for CFL GSLs is 

identical to Scenario 2. 

DOE also received comments regarding its intention to assume the residential GSL 

installation cost is zero. Philips, Westinghouse, and ASAP all recommended that DOE consider 

residential installation costs in the LCC and PBP calculations. (Philips, Public Meeting 

Transcript, No. 19 at p. 155; Westinghouse, Public Meeting Transcript, No. 19 at pp. 155-156; 

ASAP, Public Meeting Transcript, No. 19 at pp. 158-159) In particular, ASAP requested DOE 

account for the benefit to a consumer in a long-lived lamp from avoided installation time and 

effort, both in the residential and commercial sectors. (ASAP, Public Meeting Transcript, No. 19 

at pp. 158-159) NEMA suggested that installation costs need to be included in the analyses in 

cases where an externally ballasted GSL is replacing an integrally ballasted GSL and requires a 

new fixture. (NEMA, Public Meeting Transcript, No. 19 at pp. 82-83)

DOE acknowledges the convenience provided to consumers of not having to replace 

longer-life GSLs as often as comparatively short-lived GSLs, but DOE has assumed no product 

class switching for this preliminary analysis and notes that installation time is negligible under 

this assumption. Additionally, installation costs will be equivalent across the various levels of 

efficacy under consideration for a given product class and building sector, and lifetime is taken 

into account in the LCC calculation. Therefore, DOE did not include installation costs. 

NRDC suggested DOE consider new, longer-lifetime incandescent lamps in its LCC and 

PBP analyses. (NRDC, Public Meeting Transcript, No. 19 at p. 157) DOE assumes that the EISA 

2007 backstop will go into effect concurrently with the compliance date of this rulemaking. 

Therefore, DOE assumed that there will be no shipments of incandescent lamps (for the general 

service applications covered by this rulemaking) during the analysis period.

2.11 SHIPMENTS ANALYSIS

DOE uses projections of product shipments to calculate the national impacts of standards 

on energy use, NPV, and future manufacturer cash flows. Details of the shipments analysis are 

provided in chapter 9 of this TSD. This section highlights key changes in the shipments 

modeling approach from the approach presented in the framework document, and responds to 

comments by stakeholders regarding how DOE projects shipments.

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DOE adopted a consumer-choice-based shipments model to estimate lamp shipments for 

this rulemaking. The shipments model has three main interacting elements: (1) a demand 

module, which estimates the demand for new GSL shipments in each lamp category for each 

year of the shipments projection period; (2) a price projection module, which projects future 

lamp prices based on historic price trends and projected future shipments; and (3) a consumer 

choice module, which assigns shipments to lamps at different efficiencies based on consumer 

sensitivities to lamp price, energy consumption, lifetime, and mercury content. Because the 

product classes considered here are typically used in dissimilar applications, the model did not 

consider the possibility that standards could drive consumers to switch between product classes. 

The lamp demand module estimates the demand for GSLs, both as replacements for 

failed lamps and for new luminaire installations. The demand calculation assumes that the sectorspecific density and lumen distribution of installed GSLs remains fixed per square foot of floor 

space, and that floor space changes over the analysis period according to the EIA’s sectorspecific Annual Energy Outlook (AEO) 201478 projections. While lamp demand per square foot 

remains fixed, annual lighting energy consumption per square foot is allowed to vary according 

to the fraction of the floor space implementing lighting system controls. A lamp turnover 

calculation estimates demand for lamps in each year given the initial stock, the expected 

lifetimes of the lamps, and sector-specific assumptions about operating hours. 

The price learning module estimates lamp prices in each year of the analysis period. 

Separate experience curves were utilized for CFLs and LED GSLs, based on fits to historic price 

and sales data for GSLs utilizing each technology. For LED lamps, DOE also assumed that the 

incremental price of increased lumens will decline exponentially with time, based on fits to 

historical price data, so that the current large price premium for 1,600 lm lamps, relative to 500 

lm lamps, will decrease over time and eventually become negligible. For CFLs, DOE assumed 

that experience-curve price declines do not apply to the portion of the price that is attributable to 

the cost of rare-earth oxides for use in the lamp phosphors. Finally, DOE assumed that the prices 

of integrated, low-lumen GSLs at CSLs 0, 2, and 3 will not experience price declines due to 

experience curves. DOE assumes that these technologies are becoming obsolete as the market 

has shifted to more efficacious CFLs and LED lamps. 

The consumer-choice module assigns shipments to the available lamp options, 

determined in the engineering analysis and the LCC analysis, based on sector-specific consumer 

sensitivities to lamp price, energy consumption, lifetime, and mercury content. In the base case, 

all lamp options are available. In each possible standards case only those lamp options at or 

above the CSL are considered to be available. Where appropriate, the consumer choice module 

also accounts for observed deviations from the explicitly modeled consumer sensitivities 

mentioned previously using an acceptance factor that limits the maximum market share of 

certain product options. 

78 Energy Information Administration. Annual Energy Outlook 2014 with Projections to 2040. Report No. 

DOE/EIA-03832014. Washington, D.C. http://www.eia.gov/forecasts/aeo/pdf/0383(2014).pdf. 

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Numerous stakeholders provided comments regarding DOE's forecasting of GSL 

shipments. NEMA and NRDC pointed out that regulations are still taking effect that make it 

difficult to estimate future GSL shipments. (NEMA, No. 15 at p. 18; NRDC, Public Meeting 

Transcript, No. 19, pp. 24-25) NEMA also noted that there are programs in place encouraging 

the use of more efficient lighting technologies. (NEMA, No. 15 at p. 18) GE agreed with NEMA, 

indicating that it is difficult to start a rulemaking soon after another rulemaking has gone into 

effect due to the lack of available data on the effect of the past rulemaking. (GE, Public Meeting 

Transcript, No. 19 at p. 164). NRDC also pointed out that DOE needs to be careful not to assume 

that niche bulbs that currently have low sales will automatically continue to have low sales 

(NRDC, Public Meeting Transcript, No. 19 at pp. 25-26) Philips, NRDC, ASAP, et al., and 

NEEA all recommended DOE analyze multiple forecast scenarios due to the inherent uncertainty 

in forecasting and the rapid market adoption of LED lamps. (Philips, Public Meeting Transcript, 

No. 19 at p. 166; NRDC, ASAP, et al., No. 17 at p. 12; NEEA, Public Meeting Transcript, No. 

19 at pp. 166-167)

DOE recognizes the inherent uncertainty in projecting GSL shipments in the face of 

proposed energy conservation standards as well as in the base case scenario. Furthermore, DOE 

acknowledges that there are a number of programs and statutes currently in place that affect the 

GSL market, not least of which is the January 1, 2014 compliance date for the latest phase of 

EISA standards for GSILs.

79 DOE requests any representative data on GSL shipments as they 

become available in order to improve the accuracy of the shipments analysis. DOE will also 

continue to monitor sales of certain lamps exempted from GSIL standards to assess if they are no 

longer niche products.

In light of the uncertainty in the future GSL market, DOE conducted shipments 

projections for a number of scenarios, with alternative assumptions (described in chapter 8B) for 

each of the following: (1) Incursion of integral LED luminaires into the market for traditional 

GSL luminaires at the end of the analysis period; (2) Lamp service lifetime; (3) LED price 

learning rate; and (4) Rare earth material prices. Uncertainty was also addressed via additional 

scenarios considered in the national impact analysis, with alternative assumptions for each of the 

following: (1) Fraction of LED shipments that have standby functionality at the end of the 

analysis period (residential sector only); (2) Standby power consumption; (3) Rebound; (4) 

Fraction of GSL shipments with controls (for commercial sector); and (5) Electricity price 

projection (also described in appendix 8B).

Regarding the fraction of LED shipments that have standby functionality, as stated in 

section 2.3.5.4, DOE believes that while “smart” LED GSLs, which have standby functionality, 

currently represent a very small fraction of the GSL market, the market share for such GSLs will 

increase over the course of the analysis period. Therefore, DOE included GSLs with standby 

functionality in its analyses. In the reference scenario, DOE assumed that the proportion of GSLs 

shipped with standby functionality would increase over time according to a Bass diffusion curve, 

with 50 percent of GSLs shipped including standby functionality by the end of the analysis 

period. DOE also considered low- and high-standby scenarios, where 0 percent and 100 percent 

of GSLs shipped, respectively, include standby functionality by the end of the analysis period. 

79 See 10 CFR 430.32(x).

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As stated in section 2.9, DOE has assumed that the integrated controls associated with these 

smart LEDs result in a similar reduction in energy consumption compared to lamps used with 

fixtures employing controls.

A number of stakeholders commented on the uncertainty in future LED lamp prices. 

NRDC, ASAP, et al. expect LED GSL prices to continue dropping, but they do not anticipate 

significant price changes for CFL GSLs. (NRDC, ASAP, et al., No. 17 at p. 11) Lutron inquired 

into how DOE intends to project the prices of LEDs (Lutron, Public Meeting Transcript, No. 19 

at pp. 128-129) In response to DOE’s planned consideration of experience curves, CA IOUs 

recommend that DOE consider experience curves separately for each GSL technology type. (CA 

IOUs, Public Meeting Transcript, No. 19 at pp. 135-136) 

To account for expected changes in the price of GSLs over the analysis period, DOE used 

a learning curve (also referred to as experience curve) approach. Learning curves relate a 

product’s cumulative production (production since the product’s introduction to the market) to 

the product’s price. Product price generally decreases as a function of increasing cumulative 

production, with a learning rate equal to the percentage drop in price for each doubling in 

cumulative production. LED GSLs are currently in a very early phase of their market adoption, 

and their learning rate currently appears to be higher than the historic learning rate for the more 

mature CFL technology (see chapter 9 of this TSD). Given the very early-market nature of LED 

GSLs and associated uncertainty in the LED-GSL learning rate, DOE analyzed three scenarios 

for LED-GSL learning rates: (1) a scenario where LED GSLs experience price learning at the 

historic LED-GSL learning rate; (2) a scenario where LED GSLs experience price learning at the 

historic CFL-GSL learning rate; and (3) for reference to gauge the impact of price learning, a 

scenario where LED and CFL GSLs experience no price learning (i.e., prices stay at constant real 

prices throughout the analysis period). As discussed in chapter 9 of this TSD, DOE is using the 

historic CFL-GSL learning rate as the reference price learning scenario. In this scenario, the 

prices of LED GSLs will still decrease faster than the prices of CFL GSLs on an annual basis, 

because LED GSLs are still in a relatively early phase of their market adoption and cumulative 

production will double more rapidly than for CFL GSLs. Details of the experience curve 

methodology and calculations are discussed in chapter 9 of this TSD.

Lutron Electronics indicated that it may be useful for DOE to determine the relative 

weight of the purchase price compared to the remainder of the life-cycle cost when 

characterizing the behavior of GSL consumers. (Lutron Electronics, Public Meeting Transcript, 

No. 19 at p. 156) DOE agrees with Lutron Electronics' suggestion and accounted for consumer 

sensitivity to lamp price, energy consumption, lifetime, and mercury content in the consumer 

choice model.

NEMA suggested that a GSL socket that contains an incandescent GSL will not 

necessarily always contain an incandescent GSL, and that eventually a longer-life, higherefficacy GSL will replace it. (NEMA, Public Meeting Transcript, No. 19 at p. 85) GE added that, 

over time, CFL and LED GSLs will reduce the market for incandescent GSLs. (GE, Public 

Meeting Transcript, No. 19 at pp. 85-86) DOE agrees that there may be voluntary conversions to 

more efficient light technologies over time, and is using a consumer-choice approach to 

modeling shipments to capture this effect. DOE also notes that the EISA 2007 backstop is 

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assumed to go into effect concurrently with the compliance date of this rulemaking. Therefore, 

DOE assumed that there will be no shipments of incandescent lamps (for the general service 

applications covered by this rulemaking) during the analysis period. 

2.12 NATIONAL IMPACT ANALYSIS

The NIA provides DOE’s assessment of the aggregate impacts of potential efficacy

standards at the national level. Measures of impact that DOE will report include future NES from

a standard set at each CSL (i.e., the cumulative energy savings from a potential energy 

conservation standard relative to a base case that assumes no change in the standard over a 

specific forecast period), and the NPV for consumers in the aggregate from a standard set at each 

CSL.

DOE accounts for the direct rebound effect in its NES analyses. Direct rebound is the 

concept that as appliances become more efficient, consumers use more of their service because 

their operating cost is reduced. In the case of lighting, the rebound could be manifested in 

increased hours of use or in increased lighting density (fixtures per square foot). 

Lutron Electronics suggested DOE consider that consumers will use their lamps more as 

the lamps become more efficacious, and NEMA encouraged DOE to consider studies that 

indicate longer operating hours for more efficient CFL or LED GSLs. (NEMA, No. 15 at p. 17; 

Lutron Electronics, Public Meeting Transcript, No. 19 at p. 147) 

A publication by Greening et al. (2000)80 looked at lighting rebound estimates from earlier 

studies conducted in the 1990s. They found that the studies for residential lighting rebound are 

inconclusive due to the methods used. A more recent study of residential lighting in 369 homes 

in California showed no difference in the hours of use of CFLs with respect to other lamps,81

which suggests a low degree of rebound from efficacy improvement. A comparison of the 200182

and 201083 LMC reports show no evidence of rebound of residential or commercial lighting. 

Given the information from the above sources, DOE assumed no rebound for the residential or 

commercial lighting in its reference scenario for this preliminary analysis. 

In addition to the reference scenario, DOE conducted an analysis for two alternative 

scenarios, which account for increased GSL usage stemming from the use of more efficacious 

lamps: a scenario with an 8.5 percent rebound rate for residential lighting, based on the average of 

80 Greening, Lorna, David Green, and Carmen Difiglio. "Energy efficiency and consumption - the rebound effect - a

survey." Energy Policy. 2000. Vol. 28, pp. 389-401 (Last Accessed September 15, 2014.) 

www.elsevier.com/locate/enpol. 

81 KEMA. CFL Metering Study Final Report. Oakland, CA. (Last Accessed September 11, 2014.) 

http://www.calmac.org/publications/2005_Res_CFL_Metering_Study_Final_ReportES.pdf. 

82 Navigant Consulting. U.S. Lighting Market Characterization, Volume I: National Lighting Inventory and Energy

Consumption Estimate. September 2002. (Last Accessed September 15, 2014.) 

http://apps1.eere.energy.gov/buildings/publications/pdfs/corporate/lmc_vol1.pdf. 

83 U.S. Department of Energy. 2010 U.S. Lighting Market Characterization. January 2012. (Last Accessed

September 15, 2014.) http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf. 

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two hours-of-use studies cited by Greening et al. (2000), and a one percent rebound rate for 

commercial and industrial lighting, also derived from Greening et al. (2000); and a scenario where 

both the residential and commercial rebound rates were assumed to be 15 percent, based on an 

estimate of the average rebound rate for a suite of appliances from the National Energy Modeling 

System (NEMS). DOE requests data that can be used to further refine the rebound assumptions

used in the NIA.

DOE received a large number of comments regarding the relationship between the 

45 lm/W backstop provision in EISA and the NIA for this rulemaking. CEC provided analysis 

results indicating that it is only feasible to adopt a regulation for GSLs that achieve greater 

savings than the backstop if GSILs are included in the scope. (CEC, No. 11 at p. 10) CA IOUs 

indicated that DOE should forecast business-as-usual energy use in the GSL market and quantify 

the savings that would result from the backstop, stating that this is an important part of the 

rulemaking, and that DOE needs to consider future GSIL efficacy, cost, lifetime, performance, 

supply chains, and market share in conducting this analysis. (CA IOUs, No. 18 at p. 3) During 

the framework public meeting, ASAP commented that it is reasonable for DOE to analyze the 

backstop as an option in the GSL rulemaking. (ASAP, Public Meeting Transcript, No. 19 at p. 

37) CEC also noted that even if the final rule from this rulemaking achieves less energy savings 

than the backstop, the final rule would still be beneficial because it would achieve incremental 

energy savings for GSLs beyond the energy savings from the backstop. (CEC, No. 11 at p. 12) 

The Appropriations Rider, in relevant part, restricts the use of appropriated funds in 

connection with several aspects of DOE’s incandescent lamps program. Specifically, section 322

states that none of the funds made available by the Act may be used to implement or enforce 

standards for GSILs, intermediate base incandescent lamps and candelabra base incandescent 

lamps. Because section 322 appears to curtail any further activity to implement or enforce 

standards for GSILs, DOE will not be considering GSILs in its analyses. Furthermore, because 

GSILs are not included in the scope of this rulemaking, DOE assumed that a potential GSL final 

rule would not yield sufficient energy savings to avoid triggering the EISA 2007 backstop. 

Therefore, as discussed in section 2.9, DOE assumes that the EISA 2007 backstop will go into 

effect concurrently with a potential GSL standard at the compliance date of this rulemaking,

eliminating the need to characterize the effect of the backstop for this rulemaking’s analyses.

Thus, as noted previously, DOE has assumed that there will be no shipments of incandescent 

lamps for general service applications during the analysis period.

A discussion took place during the public meeting that indicated a difference in 

interpretation among key stakeholders regarding the 45 lm/W backstop provision in EISA. (See

42 U.S.C. 6295(i)(6)(A)(ii) and (i)(6)(A)(v)) NEMA and GE interpreted the backstop as 

enforcing a 45 lm/W limit average across the entire fleet of GSLs sold. (NEMA, Public Meeting 

Transcript, No. 19 at pp. 30-31; GE, Public Meeting Transcript, No. 19 at pp. 32-33, 35-36) In 

contrast, NRDC interpreted the backstop as enforcing the 45 lm/W limit on a per-lamp basis. 

(NRDC, Public Meeting Transcript, No. 19 at p. 34) The EISA 2007 backstop provision states 

that, if certain requirements are not met, the sale of any GSL that does not meet the 45 lm/W 

minimum efficacy standard shall be prohibited. (See 42 U.S.C. 6295(i)(6)(A)(v)) DOE interprets 

this to mean that the 45 lm/W backstop mandated by EISA 2007 (which would go into effect 

beginning on January 1, 2020 if a GSL rulemaking does not occur or does not obtain energy 

savings equal to or larger than the energy savings of the backstop), would apply to every GSL 

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being sold in the market on a per-lamp basis. DOE also clarifies that it is possible for the 45 

lm/W backstop to come into effect concurrently with the GSL energy conservation standards 

from this rulemaking in the event that the energy savings from this rulemaking do not equal or 

exceed the savings from the backstop.

CA IOUs, ASAP and CEC provided comments on the inclusion of GSILs in the analyses 

DOE undertakes. CA IOUs and ASAP stated that DOE cannot accurately analyze the impact of 

LED and CFL GSL standards without considering the interaction of LED and CFL GSLs with 

GSILs. (CA IOUs, No. 18 at p. 3; ASAP, Public Meeting Transcript, No. 19 at p. 60) CEC 

agreed, commenting that DOE must analyze the GSIL market in the rulemaking, as GSILs are 

the least expensive GSLs and they directly substitute CFL and LED GSLs. (CEC, No. 11 at p. 

18) As noted previously, the Appropriations Rider, in relevant part, appears to curtail any further 

activity to implement or enforce standards for GSILs. Additionally, DOE assumes that the EISA 

2007 backstop will go into effect concurrently with the compliance date of this rulemaking; 

therefore, DOE has assumed that there will be no shipments of incandescent lamps for general 

service applications during the analysis period, which begins with the compliance date of this 

rulemaking, eliminating any competition between incandescent GSLs and LED or CFL GSLs.

DOE received a number of other comments on the NIA from NEMA, Lutron Electronics, 

and ASAP. 

NEMA recommends DOE use an analysis period of no longer than 10 years due to the 

rapid market adoption of LED GSLs and the comparatively short lifetime of other GSL 

technologies. (NEMA, No. 15 at p. 15) DOE notes that the lifetimes of the CFL and LED GSLs 

under consideration in this rulemaking are comparable to (and in some cases, longer than) the 

lifetimes of products in other rulemakings that have used the standard 30-year analysis period. 

ASAP commented that DOE needs to account for GSL inventories (i.e., stockpiling) in 

consumers’ homes in its analyses. (ASAP, Public Meeting Transcript, No. 19 at p. 109) On the 

other hand, Lutron Electronics encouraged DOE not to become overburdened with trying to 

incorporate GSL stockpiling into the NIA models, with the reasoning that the lifetime of GSILs 

is relatively short and consumers will not stockpile other lamp types at this point due to the 

higher cost of more efficient lamps. (Lutron Electronics, Public Meeting Transcript, No. 19 at 

pp. 171-172)

DOE agrees with Lutron Electronics’ assessment of lamp stockpiling by consumers. 

Given the comparatively short lifetime of GSILs (those most likely to be stockpiled by 

consumers due to the increasing efficacy requirements being phased in by EISA) relative to more 

efficient GSL technologies, as well as the comparatively high price of more efficacious GSLs, 

DOE assumed that GSL stockpiling will not have a significant impact on the NIA results. 

CEC suggested DOE include the impacts of GSL standards adopted in California when 

modeling the years 2018 up to the compliance date of the proposed rule, because the California 

standards are equivalent to the EISA backstop and will have effects on the national GSL market. 

(CEC, No. 11 at p. 19) In its analyses, DOE has assumed that a potential GSL final rule would 

have a compliance date that would be concurrent with the compliance date for the EISA 2007 

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backstop. The years prior to the compliance date of a potential GSL rule are outside of the 

analysis period for this rulemaking. However, in calibrating the shipments model for the 

residential sector, DOE assumed a consistent shift in shipments of 15 percent per year from 

incandescent GSLs to CFL or LED GSLs during the years leading up to the compliance date, 

which would account for the impacts of GSL standards adopted in California in addition to 

general market shifts. For the commercial sector, DOE assumed that the current market share of 

incandescent GSLs is negligible. DOE requests comment on these assumptions. 

2.12.1 National Energy Savings

The inputs for determining the national energy savings for each product class are: (1) 

lamp shipments; (2) annual energy consumption per unit; (3) stocks of lamps in each year; (4) 

national energy consumption; and (5) site-to-primary energy and fuel-full-cycle conversion 

factors. The lamp stocks were calculated by the shipments model for each year of the analysis 

period from the prior year’s stock, minus retirements, plus new shipments, accounting for lamp 

lifetimes. DOE calculated the national electricity consumption in each year by multiplying the 

number of units of each product class and CSL in the stock by the corresponding power 

consumption and operating hours. The electricity savings are estimated from the difference in 

national electricity consumption between the base case (without new standards) and the 

candidate standards cases for the lifetime of lamps shipped during the 2020-2049 period. To 

avoid penalizing longer lived lamps for not being retired from service as quickly as shorter-lived 

lamps, and therefore continuing to consume energy, DOE modified this approach in the years 

after 2049. The energy savings per lamp was determined for the final year of analysis period, and 

this multiplier was applied to the remaining stock in each year after the analysis period until the 

last lamp shipped during the analysis period was retired. For more details, see chapter 10 of this 

TSD.

DOE has historically presented NES in terms of primary energy savings. In response to

the recommendations of a committee on “Point-of-Use and Full-Fuel-Cycle Measurement 

Approaches to Energy Efficiency Standards” appointed by the National Academy of Science,

DOE announced its intention to use full-fuel-cycle (FFC) measures of energy use and 

greenhouse gas and other emissions in the national impact analyses and emissions analyses 

included in future energy conservation standards rulemakings. 76 FR 51281 (August 18, 2011). 

After evaluating the approaches discussed in the August 18, 2011 notice, DOE published a 

statement of amended policy in the Federal Register in which DOE explained its determination 

that NEMS is the most appropriate tool for its FFC analysis and its intention to use NEMS for 

that purpose. 77 FR 49701 (August 17, 2012). For this preliminary analysis, DOE calculated 

both site and primary energy savings as well as FFC energy savings for the considered ELs.

2.12.2 Net Present Value

The inputs for determining NPV are: (1) total annual installed cost; (2) total annual 

savings in operating costs; and (3) a discount factor to calculate the present value of costs and 

savings. DOE calculated net savings each year as the difference between the base case and each 

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standards case in terms of total savings in operating costs versus total increases in installed costs. 

DOE calculated savings over the lifetime of products shipped in the 30-year analysis period. 

For the NPV analysis, DOE calculates increases in total installed costs as the difference 

in total installed cost between the base case and standards case (i.e., once the standards take 

effect). Because the more efficacious products bought in the standards case usually cost more 

than products bought in the base case, cost increases appear as negative values in the NPV. 

DOE expresses savings in operating costs as decreases associated with the lower energy 

consumption of products bought in the standards case compared to the base case. Total savings 

in operating costs are the product of savings per unit and the number of units of each vintage that 

survive in a given year. 

DOE calculated NPV as the difference between the present value of operating-cost 

savings and the present value of total installed costs. DOE used a discount factor based on real 

discount rates of 3 and 7 percent to discount future costs and savings to present values. 

2.13 CONSUMER SUBGROUP ANALYSIS

The consumer subgroup analysis, which DOE conducts at the NOPR stage of a 

rulemaking, evaluates economic impacts on selected groups of consumers. A consumer subgroup 

comprises a subset of the population that may be affected disproportionately by amended energy 

conservation standards (e.g., low income consumers, seniors). The purpose of a subgroup 

analysis is to determine the extent of any such disproportionate effect. DOE will work with 

industry and other interested parties to identify any subgroups for consideration. 

In comparing potential effects on the different consumer subgroups, DOE will use 

appropriate values for the inputs that affect the LCC and PBP, such as annual energy use, 

lifetime, and electricity prices. For more detail on the approach to the subgroup analysis, see 

chapter 11 of this TSD. 

NEMA agreed with the proposed subgroups, but also commented that all income groups 

and age groups should be evaluated individually for impacts specific to the group’s situation. 

(NEMA, No. 15 at p. 19) Additionally, an independent stakeholder pointed out that the elderly 

and terminally ill constitute a subgroup that is often unable to afford more efficient lighting 

technologies, that has an expected lifespan significantly shorter than the expected lifetime of the 

GSLs under consideration, and that may benefit greatly from not having to replace GSLs. (Wills, 

No. 13 at p. 1) The commenter also noted that temporary-use, use by non-profit organizations in 

rented spaces, as well as general low-use applications may make it difficult to justify increased 

costs for more efficacious GSL technologies. 

DOE does not envision a need to separately evaluate all income groups and age groups, 

because DOE believes that the impacts in these subgroups are reflected in the distribution of 

LCC results. The LCC analysis also captures impacts on low-use applications. DOE plans to 

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evaluate impacts of potential GSL standards on low-income, senior-only, and small business 

subgroups. 

2.14 MANUFACTURER IMPACT ANALYSIS

The purpose of the MIA is to identify the likely impacts of higher energy conservation 

standards on manufacturers. In conducting this analysis, DOE will seek input from 

manufacturers and other interested parties and consider financial impacts, as well as a wide range 

of quantitative and qualitative industry impacts that might occur after adoption of GSL standards. 

For example, a particular standard level could require changes to manufacturing practices of 

GSLs. DOE will identify and discuss these impacts in interviews with manufacturers and other 

interested parties during the NOPR stage of the analysis.

DOE conducts the MIA in three phases, and further tailors the analytical framework 

based on the comments it receives. In Phase I, DOE creates an industry profile to characterize the 

industry and identify important issues that require consideration. In Phase II, DOE prepares an 

industry cash-flow model and considers what information it might gather in manufacturer

interviews. In Phase III, DOE interviews manufacturers and assesses the impacts of standards 

both quantitatively and qualitatively. DOE assesses industry and subgroup cash flows and

industry net present value (INPV) using the Government Regulatory Impact Model (GRIM). 

DOE then assesses impacts on competition, manufacturing capacity, employment, and 

cumulative regulatory burden based on manufacturer interview feedback and discussions. 

DOE evaluates and reports preliminary MIA information in this preliminary analysis

phase. DOE gathered the information for this preliminary analysis during manufacturer 

interviews. See chapter 12 of this TSD for more detailed information on the MIA. 

2.14.1 Sources of Information for the Manufacturer Impact Analysis

The MIA uses outputs from other analyses, such as the engineering analysis, the 

shipment analysis, and the product price determination. It also uses inputs based on publicly 

available information, such as 10-K filings, and refines these inputs based on feedback during 

manufacturer interviews. These analyses provide important information for the MIA, including 

the number of shipments and the manufacturer production costs for each lamp type. DOE 

supplements this information with company financial data and other information gathered and/or 

refined during interviews with manufacturers to estimate the industry financial parameters, such 

as the tax rate, the R&D rate, the capital expenditure rate, the depreciation rate, the industry 

discount rate, and manufacturer markups. 

DOE aggregates information across manufacturers to create a combined industry opinion 

or estimate. The interview process plays a key role in the MIA. DOE conducts detailed 

interviews with manufacturers to gain insight into the range of potential impacts of standards. 

Typically, DOE solicits both quantitative and qualitative information during the interviews on 

the potential impacts of ELs on sales, direct employment, capital assets, and industry 

competitiveness.

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2.14.2 Industry Cash Flow Analysis 

The industry cash flow analysis relies primarily on the GRIM. DOE uses the GRIM to 

analyze the financial impacts of energy conservation standards on the industry. The GRIM 

analysis uses several inputs to determine industry annual cash flows with and without standards. 

These inputs include shipments, manufacturer production costs, product markups, conversion 

costs for higher efficacy standards, and industry financial parameters. DOE then compares the 

industry annual cash flows resulting from two scenarios – one where more efficacious standards 

are mandated and one where base case projections, which involve no standards, are applied. The 

financial impact of standards is the difference between the two sets of discounted industry annual 

cash flows. Other performance metrics, such as return on invested capital, are also available from 

the GRIM. 

NEMA noted that some of the recent lighting rulemakings have had negative INPVs for 

both high and low shipment scenarios, and urged DOE to create a rule that more closely strikes a 

compromise between desired energy savings and economic burden on industry and consumers. 

NEMA requested that DOE consider avoiding future rulemakings with negative INPVs, and to 

work with industry and other stakeholders to promote non-regulatory initiatives to encourage 

penetration of more efficacious lighting technologies. (NEMA, No. 15 at pp. 20-21) DOE 

carefully examines the potential burdens placed on manufacturers of covered products and 

weighs these burdens against other benefits of energy conservation standards before adopting an 

appropriate final rule for the analyzed products. DOE will weigh the potential burdens, including 

any potential loss of GSL manufacturers’ INPV, against the potential benefits before proposing 

standards for GSLs in the NOPR. See chapter 12 of this TSD for more information on the 

industry cash flow analysis.

2.14.3 Direct Employment Impact Analysis

The impact of energy conservation standards on employment is an important 

consideration in the rulemaking process. Manufacturer interviews play a significant role in 

assessing how domestic employment patterns might be impacted by standards. DOE explores 

current employment trends in the GSL industry and solicits feedback from manufacturers on 

changes in employment patterns that may result from increased efficacy standards. NEMA 

expressed concern regarding the potential for GSL standards to offshore LED lamp production, 

which is currently experiencing growth in the United States. In DOE’s “Keeping Manufacturing 

in the United States” white paper,84 it is noted that there is strong potential for capital investment 

to be made in domestic SSL manufacturing. NEMA suggested that DOE take this data into 

account to monetize the impacts on the cost analyses being performed. (NEMA, No. 15 at p. 20) 

DOE will examine the potential change in domestic employment as a result of GSL standards 

during the NOPR MIA. These potential benefits or burdens will be taken into account when 

84 U.S. Department of Energy. Keeping Manufacturing in the United States. July 2010. (Last Accessed 

November 10, 2014.) http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/ssl_whitepaper_july2010.pdf 

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proposing and ultimately selecting standards for GSLs in the NOPR and final rule stages of the 

analysis.

NEMA also commented that some manufacturers have invested in adding U.S.-based 

incandescent production since EISA 2007 was enacted, which could be at risk if this rulemaking 

does not adequately address the potential impacts to incandescent products. The Appropriations 

Rider restricts the use of appropriated funds in connection with several aspects of DOE’s 

incandescent lamps program. DOE is not including lamps that meet the definition of GSIL in the 

GSL rulemaking at this time. See chapter 12 of this TSD for more information on the direct 

employment impact analysis.

2.14.4 Manufacturer Subgroup Analysis

Average industry impacts may not adequately show differential impacts among 

subgroups of manufacturers that have different cost structures or operate within different 

regulatory frameworks. For example, small and niche manufacturers, or manufacturers whose 

cost structure differs significantly from the industry average, could experience a more negative 

impact. Ideally, DOE would consider the impact on every firm individually; however, because 

this usually is not possible, DOE typically uses the results of the industry characterization to 

group manufacturers exhibiting similar characteristics. One common subgroup identified is small 

business manufacturers. DOE will analyze impacts on small business manufacturers consistent 

with the Regulatory Flexibility Act. (5 U.S.C. 601 et seq.) NEMA agreed with DOE’s proposed 

subgroups of the GSL manufacturers that it should consider in a manufacturer subgroup analysis. 

(NEMA, No. 15 at p. 19) 

During the interview process, DOE discusses in more detail the potential subgroups and 

subgroup members it has identified for the analysis. DOE will continue to encourage 

manufacturers to recommend subgroups or characteristics that are appropriate for the subgroup 

analysis. In addressing the impacts of potential GSL standards, NEMA suggested that DOE 

examine manufacturers of different technologies separately because of differing market 

dynamics for each technology. (NEMA, No. 15 at p. 19) DOE will consider manufacturers of 

different technologies separately in the MIA if these manufacturers have a significantly different 

cost structure. See chapter 12 of this TSD for more detail on the manufacturer subgroup analysis. 

2.14.5 Competitive Impacts Assessment

EPCA directs DOE to consider any lessening of competition likely to result from the 

imposition of standards. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It further directs the Attorney General 

to determine, in writing, the impacts, if any, of any lessening of competition. (42 U.S.C. 

6295(o)(2)(B)(ii))

The manufacturer interviews focus on gathering information that would help in assessing 

impacts on competition, such as asymmetrical cost increases to some manufacturers, increased 

proportion of fixed costs potentially escalating business risks, and potential barriers to market 

entry (e.g., proprietary technologies, limited access to resources). DOE will provide the Attorney 

General with a copy of any NOPR for consideration in evaluating the impact of standards on the 

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lessening of competition. DOE will publish the Attorney General’s letter and address any related 

comments in any final rule.

2.14.6 Cumulative Regulatory Burden

Other regulations may apply to the GSLs covered under this rulemaking, and to other 

products produced by GSL manufacturers. DOE recognizes that multiple regulations could result 

in a significant cumulative regulatory burden on manufacturers. DOE’s initial analysis of 

regulations affecting GSLs is located in the market and technology assessment (chapter 3 of this

TSD). During the NOPR, DOE plans to investigate the regulations manufacturers mentioned in 

interviews and the public meetings, and will further analyze and consider the impact of multiple, 

product-specific regulatory actions on GSL manufacturers.

NEMA commented that lighting products are already heavily regulated as there are 

several DOE, individual State, Environment Protection Agency (EPA), and Federal Trade 

Commission (FTC) regulations that impose a substantial cumulative regulatory burden on 

lighting manufacturers. There are currently energy conservation standards for exit signs, set by 

EPAct 2005; fluorescent lamp ballasts, general service fluorescent lamps and incandescent 

reflector lamps, metal halide lamp fixtures, all set by DOE. Further DOE’s ongoing standards 

rulemaking include ceiling fans and ceiling fan light kits, high impact discharge lamps, 

incandescent elliptical reflector and bulge reflector lamps (on hold but authorized), luminaires 

(on hold but authorized). Additionally, there are several other non-energy conservation standard 

regulations that lighting manufacturers must comply with, including the lighting facts label, set 

by the FTC; ENERGY STAR lamps program, set by EPA; ENERGY STAR luminaires program, 

specification revision are being discussed by EPA; California building and appliance efficiency 

regulations rulemakings, there are significant revisions in progress for 2014; California Title 20 

enforcement rulemaking; individual State mercury and recycling requirements in Maine, 

Vermont, Massachusetts, and others that are being proposed; numerous Canadian regulations 

which U.S. manufacturers attempt to align their products with in an effort to minimize 

differences between the neighboring markets. (NEMA, No. 15 at pp. 16-17) DOE acknowledges 

that lighting manufacturers must comply with several lighting regulations. As part of the NOPR 

MIA, DOE will examine the potential additional cumulative regulatory burden placed on lighting 

manufacturers imposed by this GSL rulemaking. 

NEMA also commented that according to DOE’s own analysis, several energy 

conservation standards enacted by DOE since 2007 are projected to have a negative impact on 

the manufacturers of those covered products, as reflected by a decrease in INPV due to the 

rulemakings adopted. NEMA commented that this underscores the recent regulatory burden 

placed on lighting manufacturers. (NEMA, No. 15 at p. 17) DOE recognizes that there have been 

at least three energy conservation standard final rules enacted by DOE since 2007 that cover 

lighting products. These previous standards covered GSFLs and IRLs (74 FR 34080 [July 14, 

2009]), fluorescent lamp ballasts (76 FR 70548 [Nov. 14, 2011]), and metal halide lamp fixtures 

(79 FR 7746 [Feb. 10, 2014]). The INPV impacts to lighting manufacturers for these 

rulemakings ranged from moderate to significant, depending on the markup scenario analyzed. 

Lastly, NEMA commented that since there are numerous small businesses entering the LED 

lamp market, any regulation that is overly burdensome or imposes a high cost of compliance on 

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LED lamp manufacturers could result in fewer small businesses entering the LED lamp market 

and bringing with them potential radical and innovative energy-saving solutions. (NEMA, No. 

15 at p. 19) The cumulative regulatory burden seeks to mitigate the overlapping effects on 

manufacturers of new or revised DOE standards and other regulatory actions affecting those 

same manufacturers. DOE will consider the cumulative regulatory burden on lighting 

manufacturers as one of the burdens of complying with GSL standards as part of the NOPR 

analysis.

2.14.7 Preliminary Results for the Manufacturer Impact Analysis

One important aspect of the preliminary MIA is the opportunity it creates for DOE to 

identify key manufacturer issues early in the evaluation of energy conservation standards. During 

preliminary interviews, manufacturers identified two major areas of concern regarding GSL 

standards: (1) testing burden and (2) impacts of technology neutral standards.

Testing Burden

Several manufacturers expressed concern over the testing burden associated with GSL 

energy conservation standards. Manufacturers expressed concern regarding new testing 

requirements for LED lamps and expanded scope of CFLs to comply with GSL standards. 

Manufacturers stated that they would now need to spend capital that is already limited on testing 

and certifying already efficacious lamps to demonstrate compliance with GSL standards instead 

of on research and development that could result in increase of energy savings from these lamps. 

Additionally, manufacturers claimed that standards covering LED lamps could present a barrier 

to entry for small LED lamp manufacturers due to the increase in testing and certification 

requirements caused by GSL standards. Manufacturers claim this could result in a potential 

decrease of product innovation and energy-saving potential for LED lamps.

Impacts of Technology Neutral Standards

Manufacturers are concerned that technology neutral standards for GSLs could have a 

disproportionate effect on the range of technologies covered by standards. If GSL standards are 

set at the highest levels of efficacy, manufacturers are concerned that they may experience a loss 

of product differentiation among their lighting offerings. Manufacturers claim that as premium 

products become the baseline offering to consumers, previously offered advantages in lighting 

utility could be eliminated in an attempt to meet these higher standards.

Several manufacturers also stated they are concerned that GSL standards could be set at 

unattainable efficacy levels for CFLs. If CFLs are regulated out of the market it could force CFL 

manufacturers to either make significant investments in converting their production lines to other 

lighting technologies and cause them to incur a significant loss on the stranded assets associated 

with their existing CFL production or exit the GSL lighting market altogether. Lastly, 

manufacturers claim that setting GSL standards at efficacy levels that cannot be attained by 

CFLs would remove product utility from the market as consumers still value CFLs for certain 

applications and derive utility from these products.

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2.15 EMISSIONS ANALYSIS

In the emissions analysis, DOE will estimate the reduction in power sector emissions of 

carbon dioxide (CO2), nitrogen oxides (NOX), sulfur dioxide (SO2) and mercury (Hg) from 

potential amended energy conservation standards for GSLs. In addition, DOE will estimate 

emissions impacts in production activities (extracting, processing, and transporting fuels) that 

provide the energy inputs to power plants. These are referred to as “upstream” emissions. 

Together, these emissions account for the FFC. In accordance with DOE’s FFC Statement of 

Policy (76 FR 51281 [Aug. 18, 2011]), the FFC analysis also includes impacts of standards on 

emissions of methane and nitrous oxide, both of which are recognized as greenhouse gases 

(GHGs). 

DOE will conduct the emissions analysis using emissions factors derived from data in the 

latest version of EIA’s AEO, supplemented by data from other sources. EIA prepares the AEO

using NEMS. Each annual version of NEMS incorporates the projected impacts of existing air 

quality regulations on emissions. The text below refers to AEO 2014, which generally represents 

current legislation and environmental regulations, including recent government actions, for 

which implementing regulations were available as of October 31, 2013.

SO2 emissions from affected electric generating units (EGUs) are subject to nationwide 

and regional emissions cap-and-trade programs. Title IV of the Clean Air Act sets an annual 

emissions cap on SO2 for affected EGUs in the 48 contiguous states and the District of Columbia 

(D.C.). SO2 emissions from 28 eastern states and D.C. were also limited under the Clean Air 

Interstate Rule (CAIR), which created an allowance-based trading program that operates along 

with the Title IV program in those States and D.C. 70 FR 25162 (May 12, 2005). CAIR was 

remanded to EPA by the U.S. Court of Appeals for the District of Columbia Circuit (D.C. 

Circuit), but it remained in effect.85 On July 6, 2011 EPA issued a replacement for CAIR, the 

Cross-State Air Pollution Rule (CSAPR). 76 FR 48208 (August 8, 2011). On August 21, 2012, 

the D.C. Circuit issued a decision to vacate CSAPR.86 The court ordered EPA to continue 

administering CAIR. AEO 2014 assumes that CAIR remains a binding regulation through 

2040.87

The attainment of emissions caps is typically flexible among EGUs and is enforced 

through the use of emissions allowances and tradable permits. Under existing EPA regulations, 

any excess SO2 emissions allowances resulting from the lower electricity demand caused by the 

85 See North Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008); North Carolina v. EPA, 531 F.3d 896 (D.C. Cir. 

2008).

86 See EME Homer City Generation, LP v. EPA, 696 F.3d 7, 38 (D.C. Cir. 2012). 87 On April 29, 2014, the U.S. Supreme Court reversed the judgment of the D.C. Circuit and remanded the case for 

further proceedings consistent with the Supreme Court's opinion. The Supreme Court held in part that EPA's 

methodology for quantifying emissions that must be eliminated in certain states due to their impacts in other 

downwind states was based on a permissible, workable, and equitable interpretation of the Clean Air Act provision 

that provides statutory authority for CSAPR. See EPA v. EME Homer City Generation, No 12-1182, slip op. at 32 

(U.S. April 29, 2014). Because DOE is using emissions factors based on AEO 2014, the analysis assumes that 

CAIR, not CSAPR, is the regulation in force. The difference between CAIR and CSAPR is not relevant for the 

purpose of DOE's analysis of SO2 emissions.

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adoption of an efficiency standard could be used to permit offsetting increases in SO2 emissions 

by any regulated EGU. In past rulemakings, DOE recognized that there was uncertainty about 

the effects of efficiency standards on SO2 emissions covered by the existing cap-and-trade 

system, but it concluded that negligible reductions in power sector SO2 emissions would occur as 

a result of standards.

Beginning in 2016, however, SO2 emissions will fall as a result of the Mercury and Air 

Toxics Standards (MATS) for power plants. 77 FR 9304 (Feb. 16, 2012). In the final MATS 

rule, EPA established a standard for hydrogen chloride as a surrogate for acid gas hazardous air 

pollutants (HAP), and also established a standard for SO2 (a non-HAP acid gas) as an alternative 

equivalent surrogate standard for acid gas HAP. The same controls are used to reduce HAP and 

non-HAP acid gas; thus, SO2 emissions will be reduced as a result of the control technologies 

installed on coal-fired power plants to comply with the MATS requirements for acid gas. AEO 

2014 assumes that, in order to continue operating, coal plants must have either flue gas 

desulfurization or dry sorbent injection systems installed by 2016. Both technologies, which are 

used to reduce acid gas emissions, also reduce SO2 emissions. Under the MATS, emissions will 

be far below the cap that would be established by CAIR, so it is unlikely that excess SO2

emissions allowances resulting from the lower electricity demand would be needed or used to 

permit offsetting increases in SO2 emissions by any regulated EGU. Therefore, DOE believes 

that efficiency standards will reduce SO2 emissions in 2016 and beyond.

CAIR established a cap on NOX emissions in 28 eastern states and the District of 

Columbia. Energy conservation standards are expected to have little effect on NOx emissions in 

those states covered by CSAPR because excess NOx emissions allowances resulting from the 

lower electricity demand could be used to permit offsetting increases in NOx emissions. 

However, standards would be expected to reduce NOx emissions in the States not affected by the 

caps, so DOE estimates NOX emissions reductions from potential standards in the States where 

emissions are not capped.

The MATS limit mercury emissions from power plants, but they do not include emissions 

caps and, as such, DOE’s energy conservation standards would likely reduce Hg emissions. DOE 

will estimate mercury emissions reduction using emissions factors based on AEO 2014, which 

incorporates the MATS.

Power plants may emit particulates from the smoke stack, which are known as direct 

particulate matter (PM) emissions. NEMS does not account for direct PM emissions from power 

plants. DOE is investigating the possibility of using other methods to estimate reduction in PM 

emissions due to standards. The great majority of ambient PM associated with power plants is in 

the form of secondary sulfates and nitrates, which are produced at a significant distance from 

power plants by complex atmospheric chemical reactions that often involve the gaseous 

emissions of power plants, mainly SO2 and NOx. The monetary benefits that DOE estimates for 

reductions in SO2 and NOx emissions resulting from standards are in fact primarily related to the 

health benefits of reduced ambient PM.

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2.16 MONETIZING CO2 AND OTHER EMISSIONS

DOE plans to consider the estimated monetary benefits likely to result from the reduced 

emissions of CO2 and NOX that are expected to result from each of the energy conservation 

standard levels considered. 

To estimate the monetary value of benefits resulting from reduced emissions of CO2, 

DOE plans to use the most current Social Cost of Carbon (SCC) values developed and/or agreed 

to by an interagency process. The SCC is intended to be a monetary measure of the incremental 

damage resulting from GHG emissions, including, but not limited to, net agricultural 

productivity loss, human health effects, property damage from sea level rise, and changes in 

ecosystem services. Any effort to quantify and to monetize the harms associated with climate 

change will raise serious questions of science, economics, and ethics. But with full regard for the 

limits of both quantification and monetization, the SCC can be used to provide estimates of the 

social benefits of reductions in GHG emissions. 

The Interagency Working Group on Social Cost of Carbon released an update of its 

previous report in 2013.88 The most recent estimates of the SCC in 2015, expressed in 2013$, are 

$12.0, $40.5, $62.4, and $119 per metric ton of CO2 avoided. For emissions reductions that occur 

in later years, these values grow in real terms over time. Additionally, the interagency group 

determined that a range of values from 7 percent to 23 percent should be used to adjust the global 

SCC to calculate domestic effects, although DOE will give preference to consideration of the 

global benefits of reducing CO2 emissions. 

DOE multiplies the CO2 emissions reduction estimated for each year by the SCC value 

for that year in each of the four cases. To calculate a present value of the stream of monetary 

values, DOE discounts the values in each of the four cases using the discount rates that had been 

used to obtain the SCC values in each case.

DOE recognizes that scientific and economic knowledge continues to evolve rapidly as to 

the contribution of CO2 and other GHG to changes in the future global climate and the potential 

resulting damages to the world economy. Thus, these values are subject to change. 

DOE also estimates the potential monetary benefit of reduced NOX emissions resulting 

from the standard levels it considers. Estimates of monetary value for reducing NOX from 

stationary sources range from $476 to $4,893 per ton in 2013$.89 DOE calculates monetary 

88 Interagency Working Group on Social Cost of Carbon. Technical Update of the Social Cost of Carbon for

Regulatory Impact Analysis Under Executive Order 12866. May 2013; revised November 2013. (Last Accessed 

September 15, 2014.) http://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-costof-carbon-for-regulator-impact-analysis.pdf. 

89 U.S. Office of Management and Budget. 2006 Report to Congress on the Costs and Benefits of Federal

Regulations and Unfunded Mandates on State, Local, and Tribal Entities. 2006. Washington, D.C. (Last Accessed 

September 15, 2014.) 

http://www.whitehouse.gov/sites/default/files/omb/assets/omb/inforeg/2006_cb/2006_cb_final_report.pdf. 

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benefits using a medium value for NOX emissions of $2,684 per short ton (in 2013$), and real 

discount rates of 3 percent and 7 percent, in accordance with OMB guidance.90

DOE is evaluating an appropriate valuation of avoided SO2 and Hg emissions. Whether 

monetization of these emissions will occur in this rulemaking is yet to be determined. 

2.17 UTILITY IMPACT ANALYSIS

In the utility impact analysis, DOE analyzes the changes in electric installed capacity and 

generation that result for each trial standard level. The utility impact analysis is based on output 

of DOE/EIA’s NEMS. NEMS is a public domain, multi-sectored, partial equilibrium model of 

the U.S. energy sector. Each year, DOE/EIA uses NEMS to produce an energy forecast for the 

United States, the Annual Energy Outlook (AEO). The EIA publishes a reference case, which 

incorporates all existing energy-related policies at the time of publication, and a variety of side 

cases which analyze the impact of different policies, energy price and market trends. As of 2014, 

DOE is using a new methodology based on results published for the AEO 2014 Reference case 

and a set of side cases that implement a variety of efficiency-related policies. 

DOE received comments about the importance of power factor. In the public meeting, 

NEEA inquired as to DOE’s intent on considering the effects of GSLs with power factor less 

than 1. (NEEA, Public Meeting Transcript, No. 19 at p. 176) Philips stated that it is not the 

power factor but the impact on actual energy usage that should be considered. (Philips, Public 

Meeting Transcript, No. 19 at p. 177) NEMA indicated that any issues resulting from a decrease 

in power factor are already adequately addressed in other standards. (NEMA, No. 15 at p. 19) 

ALA requested information regarding the effect of lower power factor devices on electricity 

generating plants, indicating that it was unclear if these devices have much of an impact at the 

generation plant. (ALA, Public Meeting Transcript, No. 19 at p. 178) DOE acknowledges that 

phase shifts introduced into the grid by loads could theoretically increase power production and 

transmission system demands. However, it is the net impact of many loads that ultimately 

determines the impact, which in turn depends on a dynamically changing load mix. DOE is not 

aware of field data quantifying the impact of power factor on the electric grid. Therefore, DOE 

did not account for power factor in its analyses. 

2.18 EMPLOYMENT IMPACT ANALYSIS

Employment impacts include direct and indirect changes in the domestic workforce 

resulting from new or amended energy conservation standards. Direct employment impacts are 

any changes in the number of employees of manufacturers of the product subject to standards. 

The MIA addresses impacts in the number of employees working for the manufacturers. Indirect 

employment impacts from standards consist of the net jobs created or eliminated in the national 

90 U.S. Office of Management and Budget. Circular No. A-4, Regulatory Analysis. 2003. Washington, DC. (Last

Accessed September 15, 2014.) http://www.whitehouse.gov/sites/default/files/omb/assets/regulatory_matters_pdf/a4.pdf.

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economy, other than in the manufacturing sector being regulated, caused by: (1) reduced 

spending by end users on energy; (2) reduced spending on new energy supply by the utility 

industry; (3) increased spending on new products to which the new standards apply; and (4) the 

effects of those three factors throughout the economy. 

In any NOPR stage of a rulemaking, DOE estimates indirect national employment 

impacts using an input/output model of the U.S. economy called Impact of Sector Energy 

Technologies version 3.1.1 (ImSET).91 ImSET is a special-purpose version of the “U.S. 

Benchmark National Input-Output” (I–O) model, which was designed to estimate the national 

employment and income effects of energy saving technologies. The ImSET software includes a 

computer-based I–O model having structural coefficients that characterize economic flows 

among 187 sectors most relevant to industrial, commercial, and residential building energy use. 

DOE notes that ImSET is not a general equilibrium forecasting model and understands 

the uncertainties involved in projecting employment impacts, especially changes in the later 

years of the analysis. Because ImSET does not incorporate price changes, the employment 

effects predicted by ImSET may overestimate actual job impacts over the long run. Therefore, 

DOE focuses its quantitative analysis on short-term employment impacts.

DOE received comments from CEC on the proposed employment impact analysis. CEC 

opposed DOE’s use of short-term combined direct and indirect employment impacts, pointing 

out that DOE’s analysis would cover the fixed costs of the regulation, but would only cover a 

very limited scope of benefits. (CEC, No. 11 at pp. 20-21) CEC therefore recommends that DOE 

extend its employment assessment until job creation/loss becomes static. 

DOE acknowledges that short-term employment impacts do not present a full picture of 

indirect employment impacts of energy efficiency standards that yield reductions in energy 

expenditures over a lengthy period. However, DOE has concerns about using ImSET to project 

employment impacts over the long run, as stated above. DOE does present a qualitative 

assessment of long-run impacts as part of its analysis. 

2.19 REGULATORY IMPACT ANALYSIS

In the NOPR stage of this rulemaking, DOE will prepare an RIA that will address the 

potential for non-regulatory approaches to supplant or augment energy conservation standards to 

improve the efficacy of GSLs on the market. DOE recognizes that voluntary or other nonregulatory efforts by manufacturers, utilities, and other interested parties can result in substantial 

efficacy improvements. DOE intends to analyze the likely effects of non-regulatory initiatives 

and compare such effects with those projected to result from amended energy conservation 

standards. DOE will attempt to base its assessment on the actual impacts of any such initiatives 

91 Scott, M.J., J.M. Roop, O.V. Livingston, R.W. Schultz, and P.J. Balducci. ImSET 3.1: Impact of Sector 

Energy Technologies Model Description and User's Guide. 2009. Pacific Northwest National Laboratory, 

Richland, WA. Report No. PNNL–18412. (Last Accessed September 15, 2014.) 

http://www.pnl.gov/main/publications/external/technical_reports/PNNL-18412.pdf.

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to date, but will also consider information presented regarding the impacts that any existing 

initiative might have in the future.

2.20 DEPARTMENT OF JUSTICE REVIEW

Section 325(o)(2)(B)(i)(V) of EPCA states that, before the Secretary of Energy may 

prescribe a new or amended energy conservation standard, the Secretary shall ask the U.S. 

Attorney General to make a determination of “the impact of any lessening of competition...that 

is likely to result from the imposition of the standard.” (42 U.S.C. 6295) Pursuant to this 

requirement, DOE will solicit the views of the U.S. Department of Justice on any lessening of 

competition that is likely to result from the imposition of a proposed standard and will give any

views provided full consideration in assessing economic justification of a proposed standard.

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CHAPTER 3.MARKET AND TECHNOLOGY ASSESSMENT

TABLE OF CONTENTS

3.1 INTRODUCTION ........................................................................................................... 3-1

3.2 SCOPE OF COVERAGE ................................................................................................ 3-1

3.2.1 General Service Incandescent Lamps .................................................................. 3-2

3.2.2 Compact Fluorescent Lamps................................................................................ 3-3

3.2.3 General Service LED Lamps ............................................................................... 3-4

3.2.4 OLED Lamps ....................................................................................................... 3-5

3.2.5 Other Lamps......................................................................................................... 3-6

3.2.5.1 High Lumen Lamps (> 2,600 Lumen) ..................................................... 3-9

3.2.5.2 General Service Lamps that Operate in Standby Mode ........................... 3-9

3.2.5.3 Integrated Lamps ................................................................................... 3-10

3.2.5.4 Non-Integrated Lamps ........................................................................... 3-13

3.2.6 Summary of Lamps ............................................................................................ 3-15

3.3 SCOPE OF METRICS ................................................................................................... 3-16

3.3.1 Existing Metrics for MBCFLs ........................................................................... 3-17

3.3.2 Additional Metrics for MBCFLs ....................................................................... 3-18

3.3.3 Summary ............................................................................................................ 3-20

3.4 MARKET ASSESSMENT ............................................................................................ 3-20

3.4.1 Trade Association .............................................................................................. 3-20

3.4.2 Manufacturers and Market Share ....................................................................... 3-21

3.4.2.1 Small Businesses .................................................................................... 3-21

3.4.3 Regulatory Programs ......................................................................................... 3-22

3.4.3.1 GSL Federal Energy Conservation Standards ....................................... 3-22

3.4.3.2 California Energy Commission.............................................................. 3-24

3.4.3.3 Nevada Governor’s Office of Energy .................................................... 3-27

3.4.3.4 Canadian Energy Efficiency Standards ................................................. 3-28

3.4.3.5 European Energy Efficiency Standards ................................................. 3-28

3.4.4 Non-Regulatory Initiatives................................................................................. 3-35

3.4.4.1 Federal Energy Management Program .................................................. 3-35

3.4.4.2 Consortium for Energy Efficiency ......................................................... 3-36

3.4.4.3 Efficiency Vermont – Business Rebate Program & SMARTLIGHT .... 3-36

3.4.4.4 Southern California Edison – Multiple Rebate Programs ...................... 3-36

3.4.4.5 Commonwealth Edison – Business Instant Lighting Discounts Program3-36

3.4.4.6 Consolidated Edison – Multi-Family Energy Efficiency Program ........ 3-37

3.4.4.7 Cape Light Compact – Commercial, Industrial and Municipal Buildings 

Energy Efficiency Rebate Program ....................................................... 3-37

3.4.4.8 Central Electric Cooperative – Non-Residential Lighting Rebate ......... 3-37

3.4.4.9 Empire District Electric Company – Commercial and Industrial Energy 

Efficiency Rebate Program .................................................................... 3-37

3.4.5 GSL Market Trends ........................................................................................... 3-38

3.5 TECHNOLOGY ASSESSMENT .................................................................................. 3-39

3.5.1 Compact Fluorescent Lamps.............................................................................. 3-40

3.5.2 LED Lamps ........................................................................................................ 3-41

3-i 
3.5.3 GSL Technology Options.................................................................................. 3-45

3.5.3.1 Highly Emissive Electrode Coatings..................................................... 3-47

3.5.3.2 Higher Efficiency Lamp Fill Gas Composition..................................... 3-47

3.5.3.3 Higher Efficiency Phosphors................................................................. 3-48

3.5.3.4 Glass Coatings ....................................................................................... 3-51

3.5.3.5 Multi-Photon Phosphors........................................................................ 3-51

3.5.3.6 Cold Spot Optimization ......................................................................... 3-51

3.5.3.7 Improved Ballast Components............................................................... 3-52

3.5.3.8 Improved Ballast Circuit Design ........................................................... 3-53

3.5.3.9 Change to LEDs..................................................................................... 3-53

3.5.3.10 Efficient Down Converters................................................................. 3-53

3.5.3.11 Improved Package Architectures........................................................ 3-54

3.5.3.12 Improved Emitter Materials................................................................ 3-55

3.5.3.13 Alternative Substrate Materials........................................................... 3-57

3.5.3.14 Thermal Interface Materials................................................................ 3-58

3.5.3.15 Optimized Heat Sink Design .............................................................. 3-59

3.5.3.16 Active Thermal Management Systems............................................... 3-59

3.5.3.17 Device Level Optics............................................................................ 3-60

3.5.3.18 Increased Light Utilization ................................................................. 3-60

3.5.3.19 Improved Driver Design ..................................................................... 3-60

3.5.3.20 AC LEDs............................................................................................. 3-60

3.5.3.21 Reduced Current Density.................................................................... 3-61

3.6 PRODUCT CLASSES................................................................................................... 3-61

3.6.1.1 Lamp Technology .................................................................................. 3-62

3.6.1.2 Cover...................................................................................................... 3-62

3.6.1.3 Dimmability........................................................................................... 3-62

3.6.1.4 Ballast Location ..................................................................................... 3-63

3.6.1.5 Base Type............................................................................................... 3-63

3.6.1.6 Lamp Spectrum...................................................................................... 3-63

3.6.1.7 Correlated Color Temperature ............................................................... 3-64

3.6.1.8 Lumen Package...................................................................................... 3-64

3.6.1.9 Standby Mode Operation ....................................................................... 3-64

3.6.1.10 Product Class Summary...................................................................... 3-65

REFERENCES .......................................................................................................................... 3-66

3-ii
LIST OF TABLES

Table 3.3.1 Performance Metrics for Medium Base Compact Fluorescent Lamps................... 3-20

Table 3.4.1 EPAct 2005 Federal Regulations for Medium Base Compact Fluorescent Lamps 3-22

Table 3.4.2 EISA 2007 Federal Regulations for General Service Incandescent Lamps ........... 3-23

Table 3.4.3 EISA 2007 Federal Regulations for Modified Spectrum General Service 

Incandescent Lamps................................................................................................................... 3-23

Table 3.4.4 California Standards for State-Regulated General Service Incandescent Lamps Tier I

.................................................................................................................................................... 3-25

Table 3.4.5 California Standards for State-Regulated Modified Spectrum General Service 

Incandescent Lamps Tier I......................................................................................................... 3-25

Table 3.4.6 California Standards for State-Regulated General Service Lamps Tier II ............. 3-25

Table 3.4.7 California Standards for State-Regulated LED Lamps........................................... 3-26

Table 3.4.8 California Classification of High Efficacy and Low Efficacy Light Sources ........ 3-27

Table 3.4.9 California Minimum Requirements for Other Light Sources to Qualify as High 

Efficacy...................................................................................................................................... 3-27

Table 3.4.10 NRCan Proposed Amendment 12B...................................................................... 3-28

Table 3.4.11 EU Minimum Efficacy for Single Capped Fluorescent Lamps Working on 

Electromagnetic and Electronic Ballast..................................................................................... 3-29

Table 3.4.12 EU Minimum Efficacy for Single Capped Fluorescent Lamps Working on Only an 

Electronic Ballast....................................................................................................................... 3-30

Table 3.4.13 EU Minimum Efficacy for Single Capped Fluorescent Lamps with Square Shape or

(Very) High Output.................................................................................................................... 3-30

Table 3.4.14 EU Deduction Percentages for Efficacy Values for Fluorescent Lamps.............. 3-30

Table 3.4.15 EU Lamp Lumen Maintenance Factors for Fluorescent Lamps........................... 3-31

Table 3.4.16 EU Deduction Percentages for Fluorescent Lamp Lumen Maintenance 

Requirements ............................................................................................................................. 3-31

Table 3.4.17 EU Lamp Survival Factors for Fluorescent Lamps.............................................. 3-32

Table 3.4.18 EU Non-Directional Household Lamp Efficacy Requirements ........................... 3-33

Table 3.4.19 EU Non-Directional Household Lamp Efficacy Exceptions................................ 3-33

Table 3.4.20 EU Non-Directional Household Lamp Efficacy Correction Factors.................... 3-33

Table 3.4.21 EU Non-Directional Household Lamp Functionality Requirements for CFLs.... 3-34

Table 3.4.22 EU Non-Directional Household Lamp Functionality Requirements for Lamps 

Excluding CFLs and LEDs........................................................................................................ 3-34

Table 3.4.23 EU Functionality Requirements for Non-Directional and Directional LED Lamps 3-

35

Table 3.5.1 GSL Technology Options....................................................................................... 3-46

Table 3.5.2 Substrate Comparison............................................................................................. 3-58

Table 3.6.1 GSL Product Classes .............................................................................................. 3-65

LIST OF FIGURES

Figure 3.5.1 Photon Production through Electroluminescence ................................................. 3-42

Figure 3.5.2 LED Chip............................................................................................................... 3-43

Figure 3.5.3 LED Module.......................................................................................................... 3-43

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Figure 3.5.4 Exploded View of a LED Lamp............................................................................ 3-44

Figure 3.5.5 Light Conversion in a Phosphor-Converted LED Lamp....................................... 3-44

Figure 3.5.6 Creating White Light in LEDs .............................................................................. 3-45

Figure 3.5.7 Human Eye Photopic Spectral Luminous Efficiency Function, V(λ) ................... 3-49

Figure 3.5.8 Light Output versus Phosphor Thickness.............................................................. 3-50

Figure 3.5.9 T2 and T3 Spiral CFL Performance at 140 mA .................................................... 3-52

Figure 3.5.10 Projected LED Package Efficacy Trends............................................................ 3-55

Figure 3.5.11 The “Green Gap”................................................................................................. 3-56

Figure 3.5.12 Efficiency Droop ................................................................................................. 3-57

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CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT

3.1 INTRODUCTION

This chapter consists of four sections: scope of coverage, market assessment, the 

technology assessment, and product classes. The scope of coverage describes the products 

covered under this rulemaking and discusses certain amendments to the definitions of these 

products being considered by the U.S. Department of Energy (DOE). The market assessment 

provides an overall picture of the market for the products concerned, including the nature of the 

products, industry structure, and manufacturer market shares; regulatory and non-regulatory 

efficiency improvement programs; market trends; and quantities of products sold. The

technology assessment identifies a preliminary list of technologies to consider in the screening 

analysis. The product classes section discusses the class-setting factors DOE considered for this 

rulemaking.

The information DOE gathers from the market and technology assessment serves as 

resource material for use throughout the rulemaking. DOE considers both quantitative and 

qualitative information from publicly available sources and interested parties.

3.2 SCOPE OF COVERAGE

In this section, DOE clarifies the scope of lamps included in this rulemaking. The term 

general service lamp (GSL) includes general service incandescent lamps (GSILs), compact 

fluorescent lamps (CFLs), general service light-emitting diode (LED) lamps, organic lightemitting diode (OLED) lamps, and any other lamps that the Secretary determines are used to 

satisfy lighting applications traditionally served by general service incandescent lamps; however, 

this definition does not apply to any lighting application or bulb shape excluded from the 

“general service incandescent lamp” definition, or any general service fluorescent lamp or 

incandescent reflector lamp. 

DOE’s definition notes that as well as certain lamp types, a GSL is identified as any lamp 

that is used to satisfy lighting applications traditionally served GSILs. Based on this guidance, 

DOE has taken a broad interpretation for what can be considered a GSL. DOE has determined 

GSL to mean any lamp intended to serve in a general lighting application that has an ANSI base; 

has a lumen output of 310 lumens or greater; is not a light fixture; is not designed and labeled for 

use in non-general applications; and is not or could not be considered in another rulemaking 

proceeding.

For each lamp type included in the GSL definition, DOE assessed whether standards for 

such lamps would result in significant energy savings and, further, if such standards are 

technologically feasible and economically justified based on criteria specified for products per 42 

U.S.C. 6295(o).

DOE first examined factors such as market share and product offerings to ascertain the 

potential for energy savings. DOE surveyed market and inventory reports on lighting and found 

that the California Retail Lighting Shelf Survey provided the most detailed information on 

specific lamp types. DOE also assessed the technological feasibility of setting standards for the 

lamp types that meet the GSL definition. The following sections discuss each of the lamp types 

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included in the definition of general service lamp and the application of the scope criteria in 

more detail.

3.2.1 General Service Incandescent Lamps

Section 321 of the Energy Policy and Conservation Act (EPCA; 42 U.S.C. 6291 et seq.) 

contains a definition for GSIL. DOE codified the statutory definition for GSIL in the Code of 

Federal Regulations (CFR). 10 CFR 430.2. This definition is provided below. 10 CFR 430.2

defines a general service incandescent lamp as follows:

General service incandescent lamp means a standard incandescent or halogen type lamp 

that is intended for general service applications; has a medium screw base; has a lumen 

range of not less than 310 lumens and not more than 2,600 lumens or, in the case of a 

modified spectrum lamp, not less than 232 lumens and not more than 1,950 lumens; and 

is capable of being operated at a voltage range at least partially within 110 and 130 volts; 

however this definition does not apply to the following incandescent lamps—

(1) An appliance lamp;

(2) A black light lamp;

(3) A bug lamp;

(4) A colored lamp;

(5) An infrared lamp;

(6) A left-hand thread lamp;

(7) A marine lamp;

(8) A marine signal service lamp;

(9) A mine service lamp;

(10) A plant light lamp;

(11) A reflector lamp;

(12) A rough service lamp;

(13) A shatter-resistant lamp (including a shatter-proof lamp and a shatter-protected 

lamp);

(14) A sign service lamp;

(15) A silver bowl lamp;

(16) A showcase lamp;

(17) A 3-way incandescent lamp;

(18) A traffic signal lamp;

(19) A vibration service lamp;

(20) A G shape lamp (as defined in ANSI C78.20) (incorporated by reference; see § 

430.3) and ANSI C79.1-2002 (incorporated by reference; see § 430.3) with a diameter of 

5 inches or more;

(21) A T shape lamp (as defined in ANSI C78.20) (incorporated by reference; see § 

430.3) and ANSI C79.1-2002 (incorporated by reference; see § 430.3) and that uses not 

more than 40 watts or has a length of more than 10 inches; and

(22) A B, BA, CA, F, G16-1/2, G-25, G30, S, or M-14 lamp (as defined in ANSI C79.1-

2002) (incorporated by reference; see § 430.3) and ANSI C78.20 (incorporated by 

reference; see § 430.3) of 40 watts or less.

10 CFR 430.2

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The Consolidated Appropriations Act, 2014 (Public Law 113-76, January 17, 2014; 

hereafter referred to as the “Appropriations Rider”), in relevant part, restricts the use of 

appropriated funds in connection with several aspects of DOE’s incandescent lamps energy 

conservation standards program. Specifically, section 322 states that none of the funds made 

available by the Act may be used to implement or enforce standards for GSILs, intermediate base 

incandescent lamps, and candelabra base incandescent lamps. Thus, DOE is not considering 

GSILs, intermediate base incandescent lamps, or candelabra base incandescent lamps in this 

rulemaking.

Section 42 U.S.C. 6295(i)(6)(A)(i)(II) also directs DOE to determine whether the 

exemptions for certain incandescent lamps should be maintained or discontinued based, in part, 

on exempted lamp sales collected from manufacturers. As stated previously, DOE is prohibited

by the Appropriations Rider from using appropriated funds to implement or enforce standards for 

GSILs and thus cannot modify the existing exemptions for GSILs in the rulemaking. If the 

limitations imposed by the Appropriations Rider are lifted, DOE can evaluate whether the 22 

exemptions for incandescent lamps should be maintained based on sales data and other factors. 

3.2.2 Compact Fluorescent Lamps

CFLs are also included in the definition of GSL, however the term “compact fluorescent 

lamp” is not currently defined in the CFR. CFLs can be integrated (e.g., medium base CFLs) or 

non-integrated (e.g., pin base CFLs). EPAct 2005 amended EPCA by setting energy conservation 

standards for MBCFLs. DOE’s existing energy conservation standards apply only to integrally 

ballasted (also referred to as self-ballasted) MBCFLs. 10 CFR 430.32(u) The definition of 

“medium base compact fluorescent lamp” is as follows:

Medium base compact fluorescent lamp means an integrally ballasted fluorescent lamp 

with a medium screw base, a rated input voltage range of 115 to 130 volts and which is 

designed as a direct replacement for a general service incandescent lamp; however, the 

term does not include—

(1) Any lamp that is—

(i) Specifically designed to be used for special purpose applications; and

(ii) Unlikely to be used in general purpose applications, such as the applications 

described in the definition of “General Service Incandescent Lamp” in this section; or

(2) Any lamp not described in the definition of “General Service Incandescent Lamp” in 

this section that is excluded by the Secretary, by rule, because the lamp is—

(i) Designed for special applications; and

(ii) Unlikely to be used in general purpose applications.

10 CFR 430.2

As stated previously, the term “compact fluorescent lamp” is not currently defined but 

has been determined to apply to both integrated and non-integrated CFLs. DOE is considering a 

definition for “compact fluorescent lamp” in the CFL TP rulemaking. DOE is considering 

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defining the term “compact fluorescent lamp” to include both integrated and non-integrated 

CFLs. The definition that DOE is considering is as follows:

Compact fluorescent lamp means an integrated or non-integrated single-ended, low 

pressure mercury electric-discharge source in which a fluorescing coating transforms 

some of the ultraviolet energy generated by the mercury discharge into light; however, 

the term does not include circline or U-shaped fluorescent lamps.

DOE is also considering defining the terms “integrated” and “non-integrated” to further 

support the scope of this rulemaking. DOE developed technology neutral definitions that can be 

used to describe the various lamp technologies covered by this rulemaking. The definitions that 

DOE is considering are as follows:

Integrated lamp means a lamp that contains all components necessary for the starting and 

stable operation of the lamp, does not include any replaceable or interchangeable parts, 

and is connected directly to a branch circuit through an ANSI base and corresponding 

ANSI standard lamp-holder (socket).

Non-integrated lamp means a lamp that is not an integrated lamp.

Section 3.2.5 discusses additional CFLs for which DOE is considering establishing 

standards. Because the definition of GSL explicitly states that the term includes CFLs, and is not 

in any way limited to a particular base type of CFL, the intent of the definition was to consider 

all CFLs to be GSLs. Thus, DOE concluded that the exemptions for the lamp types listed in the 

GSIL definition, referred to in the GSL definition, do not automatically apply to the MBCFLs 

included in the GSL rulemaking. Otherwise, the inclusion of CFLs in the definition of GSL 

would be a nullity. DOE conducted a separate assessment to determine if there are MBCFLs that 

are designed for specialty use and therefore cannot provide overall illumination. DOE identified 

MBCFLs that were designed for specialty applications and are not able to provide overall 

illumination, including black light lamps, bug lamps, colored lamps, plant light lamps, and silver 

bowl lamps. DOE is considering providing exemptions for these specialty applications, which 

are discussed further in section 3.2.5.

3.2.3 General Service LED Lamps

General service LED lamps are included in the definition of GSL. LED means a p-n 

junction solid state device of which the radiated output, either in the infrared region, the visible 

region, or the ultraviolet region, is a function of the physical construction, material used, and 

exciting current of the device. 10 CFR 430.2 Similar to CFLs, LED lamps can be integrated or 

non-integrated. DOE proposed a definition for “integrated light-emitting diode lamp” in a test 

procedure SNOPR for LED lamps (hereafter “LED TP SNOPR”). 79 FR 32048 (June 3, 2014). 

The proposed definition is as follows:

Integrated light-emitting diode lamp means an integrated LED lamp as defined in 

ANSI/IESNA RP–16 (incorporated by reference; see § 430.3).

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As stated in the LED TP SNOPR, the ANSI/IESNA standard defines integrated LED 

lamps as comprising the LED source (the LED packages [components] or LED arrays 

[modules]), LED driver, ANSI standard base, and other optical, thermal, mechanical and 

electrical components such as phosphor layers, insulating materials, fasteners to hold 

components within the lamp together, and electrical wiring. The LED lamp is intended to 

connect directly to a branch circuit through a corresponding ANSI standard socket. 77 FR at 

32021-22 (June 3, 2014).

Although 10 CFR 430.2 defines the term “light-emitting diode or LED” and DOE has 

proposed a definition for “integrated light-emitting diode lamp,” DOE does not currently have a 

definition for “general service LED lamp.” As stated previously, DOE has tentatively determined 

that the term general service LED lamp includes both integrated and non-integrated LED lamps. 

Therefore, DOE has decided to propose a more general definition similar to the definition 

proposed for “compact fluorescent lamp” to clearly explain this determination. DOE is proposing 

the following definition for general service LED lamp: 

General service light-emitting diode (LED) lamp means an integrated or non-integrated 

LED lamp designed for use in general lighting applications (as defined in 430.2).

As stated in the definition, general service LED lamps are used in general lighting 

applications. DOE determined that the term “general service LED lamp” is not limited to

integrated LED lamps. DOE therefore concluded that both integrated and non-integrated LED 

lamps could be considered in the GSL rulemaking. Further, because the definition of GSL 

explicitly states that the term includes general service LEDs, the intent of the definition was to 

consider all general service LEDs to be GSLs. Therefore, DOE determined that the exemptions 

for certain bulb shapes and lighting applications in the GSIL definition, referred to in the GSL 

definition, do not apply to the other lamp types included in the definition of GSL. Otherwise all 

LED lamps would be considered exempt, rendering the inclusion of LED lamps in the GSL 

definition a nullity. DOE assessed whether LED lamps exist that are designed for specialty 

applications and therefore cannot provide overall illumination. DOE identified LED lamps that 

were designed for specialty applications and are not able to provide overall illumination, 

including black light lamps, bug lamps, colored lamps, plant light lamps, and silver bowl lamps. 

DOE is considering providing exemptions for these specialty applications, which are discussed 

further in section 3.2.5.

3.2.4 OLED Lamps

OLED lamps are included in the definition of GSL. OLED means a thin-film lightemitting device that typically consists of a series of organic layers between two electrical 

contacts (electrodes). 10 CFR 430.2 OLEDs are diffuse light sources made of thin layers of 

carbon-based semiconductor material. The layer-based construction tends to support 

development of large, flat surfaces rather than traditional lamp shapes. Because OLEDs are an 

emerging technology, the commercial availability of OLEDs is very limited. Further, products 

that are available are not used in general lighting applications due to their size and shape. The 

OLEDs that are available are marketed for accent lighting, interior design, or are sold integrated 

into fixtures. In addition, due to the emerging nature of the technology and the limited 

3-5
commercial availability of OLEDs, it is unclear whether the efficacy of existing OLED products 

can be improved. Therefore, DOE is not considering establishing standards for OLED lamps in 

this preliminary analysis. To clearly define the scope of this rulemaking, DOE is considering 

defining OLED lamps as follows:

Organic light-emitting diode or OLED lamp means an integrated or non-integrated lamp

that uses OLEDs as the primary source as light.

3.2.5 Other Lamps

Pursuant to the definition of GSL, DOE has the authority to consider additional lamps 

that it determines are used to satisfy lighting applications traditionally served by GSILs. The 

definition of GSIL specifies lamps that are: (1) typically intended for general service 

applications; (2) have a medium screw base; (3) emit between 310 and 2,600 lumens; and (4) are 

capable of being operated at a voltage range at least partially within 110 and 130 V. DOE defines 

the term “general lighting application” as follows:

General lighting application means lighting that provides an interior or exterior area with 

overall illumination. 

10 CFR 430.2

In this preliminary analysis, as noted previously, DOE has taken a broad interpretation 

for what can be considered a GSL. In this interpretation, GSLs are lamps intended to serve in 

general lighting applications and have the following basic characteristics: 1) an ANSI base with 

the exclusion of light fixtures; 2) lumen output of 310 lumens or greater; 3) line voltage or low 

voltage operation; 4) are not the subject of other rulemakings; and 5) are not designed and 

labeled for use in certain non-general applications (i.e., appliance lamps, black light lamps, bug 

lamps, colored lamps, infrared lamps, marine signal lamps, mine service lamps, plant light 

lamps, sign service lamps, silver bowl lamps, showcase lamps, and traffic signal lamps).

DOE believes that several different base types can be used in general lighting 

applications, and that GSLs utilize an ANSI base to ensure they can be used in sockets 

commonly found in residential, commercial, and industrial fixtures. Therefore, DOE considers 

GSLs to have an ANSI base. To ensure that complete light fixtures with ANSI bases (e.g., 

certain retrofit kits) are not included in the scope of this rulemaking, DOE is considering 

defining the term light fixture. DOE is considering defining the term based on the definition in 

the industry standard, ANSI/IESNA RP-16. The definition DOE is considering for light fixture is

as follows:

Light fixture means a complete lighting unit consisting of lamp(s) and ballast(s) (when 

applicable) together with the parts designed to distribute the light, to position and protect 

the lamps, and to connect the lamp(s) to the power supply.

DOE also believes that lumen output can restrict a lamp’s use in general lighting 

applications. DOE does not believe that lamps with lumen outputs below 310 lumens are 

3-6
intended for use in general lighting applications because their low lumen output is not sufficient 

for overall illumination. Thus, DOE considers GSLs to have a lumen output of at least 310 

lumens. DOE does not believe there is an upper bound on lumen output that can provide overall 

illumination. 

Additionally, DOE believes that lamps with operating voltage outside the range of 110 to 

130 V can be used in general lighting applications. Specifically, DOE believes that both lamps 

operating on line voltage (i.e., connects directly to a branch circuit) and lamps operating on low 

voltage (i.e., requires the use of a transformer) can provide overall illumination. Therefore, DOE 

does not consider GSLs to have a specific voltage range.

Further, to limit the probability that one lamp type might be subject to two different 

standards, DOE did not consider adding lamp types that are or could be addressed in a separate 

rulemaking proceeding. For example, the general service fluorescent lamp rulemaking 

considered establishing standards for additional types of fluorescent lamps (such as 2-foot linear 

fluorescent lamps). While that rulemaking ultimately concluded that additional lamps should not 

be subject to standards, DOE did not consider the additional lamps evaluated as general service 

fluorescent lamps (GSFLs) to be candidates for coverage in the GSL rulemaking.

DOE has identified self-ballasted mercury vapor (SBMV) lamps that are marketed as 

GSIL replacements and determined that some SBMV lamps are intended for general service 

applications. However, 10 CFR 431.282 defines a mercury vapor lamp as an HID lamp, which 

means SBMV lamps are covered by a different rulemaking. Because SBMV lamps could be 

addressed in a separate rulemaking, DOE is not considering including SBMV lamps in the scope 

of this GSL rulemaking. DOE is considering defining the term mercury vapor lamp in support of 

the scope of coverage of this rulemaking. DOE is considering using the definition in 42 U.S.C. 

6291(47) for mercury vapor lamp which is defined as follows:

Mercury vapor lamp means a high intensity discharge lamp, including clear, phosphorcoated, and self-ballasted screw base lamps, in which the major portion of the light is 

produced by radiation from mercury typically operating at a partial vapor pressure in 

excess of 100,000 Pa (approximately 1 atm).

DOE also considered whether lamps designed or labeled for specific applications could 

provide overall illumination and therefore meet the definition of general service lamp. DOE 

determined that the exemptions for specialty applications listed in 42 U.S.C. 6291(30)(D)(ii) are 

only applicable to GSILs. However, DOE is considering in this rulemaking whether any 

exemptions for specialty applications are needed for other GSLs. DOE assessed whether each 

specified lamp type provides overall illumination and therefore can be used in general lighting 

applications. DOE has preliminarily determined that appliance lamps, black lights, bug lamps, 

colored lamps, infrared lamps, marine signal lamps, mine service lamps, plant lights, sign service 

lamps, silver bowl lamps, showcase lamps, and traffic signal lamps cannot provide overall 

illumination and therefore cannot be used in general lighting applications. DOE found the lumen 

output of these lamps, when provided by manufacturers, was insufficient to provide overall 

illumination. DOE notes that for many of the lamp types listed, such as colored lamps and bug 

lamps, the lumen output is not stated in manufacturer catalogs as providing lumen output is not 

3-7
the primary application. Therefore, DOE is considering not establishing standards for these lamp 

types under the GSL rulemaking because the lamps are intended for use in non-general 

applications.

DOE also reviewed left-hand thread lamps, marine lamps, reflector lamps, rough service 

lamps, shatter-resistant lamps, 3-way lamps, vibration service lamps, and lamps of several 

specific shapes (such as G, T, B, BA, CA, F, G16.5, G25, G30, S, and M14, as defined in ANSI 

C79.1-2002 and ANSI C78.20). Based on its assessment, DOE has preliminarily determined that 

these lamp types provide overall illumination and therefore can serve in general lighting 

applications. 

DOE assessed further whether the utility offered by 3-way lamps, vibration service 

lamps, rough service lamps, and shatter-resistant lamps is available at higher levels of efficacy, 

which would indicate that there is no technological reason the utility could not be maintained in 

the future. DOE found that 3-way CFLs and LED lamps are available. Further, DOE found that 

one of the most efficacious GSLs currently available on the market is a 3-way LED lamp. 

Vibration service lamps and rough service lamps are defined specifically in the context of 

incandescent/halogen technology. However, DOE believes the utility of these lamp types, as well 

as shatter-resistant lamps, is their service in applications where vibrations occur (such as in a 

ceiling fan) or in applications where broken glass due to shattering would be a safety hazard 

(such as a food preparation area). DOE believes that LED lamps are inherently durable and 

resistant to shattering and thus can provide the necessary utility to serve in these applications. 

DOE also confirmed that shatter-resistant CFLs exist.

DOE is considering defining terms in support of the scope of coverage. To further 

explain lamp types DOE identified for use in non-general applications, DOE is considering 

defining the term “colored lamp” as follows:

Colored lamp means a colored fluorescent lamp, a colored incandescent lamp, or a lamp 

designed and marketed as a colored lamp and not designed or marketed for general 

lighting applications with either of the following characteristics (if multiple modes of 

operation are possible [such as variable CCT], either of the below characteristics must be 

maintained throughout all modes of operation):

(1) A CRI less than 40, as determined according to the method set forth in CIE 

Publication 13.3 (incorporated by reference; see §430.3); or

(2) A correlated color temperature less than 2,200 K or greater than 7,000 K as 

determined according to the method set forth in IES LM-66 or IES LM-79 as 

appropriate (incorporated by reference; see §430.3).

DOE is also considering defining terms related to the lamp types that can serve in general 

lighting applications. Specifically, DOE is considering defining “reflector lamp” and “nonreflector” lamp as follows:

3-8
Reflector lamp means a lamp that has an R, PAR, BPAR, BR, ER, MR, or similar bulb 

shape as defined in ANSI C78.20 (incorporated by reference; see §430.3) and ANSI 

C79.1 (incorporated by reference; see §430.3) and is used to direct light.

Non-reflector lamp means a lamp that is not a reflector lamp.

Thus, for the purposes of this rulemaking, DOE considered lamps that have an ANSI 

base, are not a light fixture, have a lumen output of 310 lumens or greater, operate at line voltage

or low voltage, are not the subject of other rulemakings, are not or could not be considered in 

another rulemaking proceeding, and are not designed and labeled for use in the following nongeneral applications, as meeting the definition of GSL: appliance lamps, black light lamps, bug 

lamps, colored lamps, infrared lamps, marine signal lamps, mine service lamps, plant light 

lamps, sign service lamps, silver bowl lamps, showcase lamps, and traffic signal lamps.

3.2.5.1 High Lumen Lamps (> 2,600 Lumen)

As stated, DOE is considering lamps with a lumen output of at least 310 lumens as 

meeting the definition of a GSL. Regarding lamps with a lumen output greater than 2,600 

lumens, DOE believes that these lamps can be used in overall illumination and therefore meet the 

definition of GSL. However, as discussed in section 3.2.1, due to the restrictions of the 

Appropriations Rider, DOE is unable to consider modifying existing exemptions for GSILs and 

therefore is not currently including GSILs with lumen output greater than 2,600 lumens in the 

scope of the rulemaking. DOE believes that establishing energy conservation standards for 

higher lumen lamps, while not also addressing higher lumen incandescent lamps, may ultimately 

increase national energy consumption. Further, DOE notes that higher lumen output lamps exist 

in more efficient technologies (e.g., integrated and non-integrated CFLs). More efficient 

products typically have lower operating costs but higher initial costs relative to the baseline 

products available on the market. Because the GSILs with lumen outputs greater than 2,600 

lumens are exempt from standards, consumers may choose to purchase incandescent lamps 

rather than more expensive CFL and LED lamps. Therefore, while DOE considers GSLs to have 

only the lower bound lumen output of 310 lumens or less, DOE is considering not establishing 

standards for GSLs with lumen outputs greater than 2,600 lumens at this time.

3.2.5.2 General Service Lamps that Operate in Standby Mode

DOE identified lamps that meet the definition of GSL and can operate in standby mode. 

Feedback from manufacturers during interviews indicated that few GSLs provide standby mode 

functionality. Manufacturers noted that only a handful of such lamps exist, and it is a niche 

market at this time. DOE also found, based on manufacturer feedback, that GSLs that operate in 

standby mode use a variety of methods to achieve the desired functionality (e.g., remotely turn 

the lamp on or off, changing lamp color, dimming the lamp), which results in differing power 

consumption and utility provided. DOE believes that while such GSLs currently represent a very 

small fraction of the GSL market, the market share for GSLs that can operate in standby mode 

will increase over the analysis period. Thus, due to the increasing market share of these products, 

DOE is considering establishing standards for GSLs with standby mode power at this time.

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3.2.5.3 Integrated Lamps

Integrated lamps (also referred to as self-ballasted lamps) contain all components 

necessary to start and operate a lamp and directly connect to a branch circuit via an ANSI base. 

DOE considered integrated lamps that are not or could not be considered in another rulemaking 

proceeding, have a lumen output equal to or greater than 310 lumens, have an ANSI base, are not 

a light fixture, and are not designed and labeled for use in the non-general applications described 

in section 3.2.5, to meet the definition of general service lamp. The following sections discuss 

these general service integrated lamps by base type and identify lamps for which DOE is 

considering establishing standards at this time.

Medium Screw Base

Medium screw base integrated lamps are offered in a variety of technologies and are also 

offered with or without a reflector. Medium screw base lamps are the most common lamps on 

the market, given the proliferation of the medium screw base socket. While most of these lamps 

are omnidirectional, many are also offered with reflectors, which are used to direct the light. 

Reflector lamps are commonly used in track lighting and recessed can light fixtures. Medium 

screw base integrated lamps provide overall illumination and are commonly found in residential, 

commercial, and industrial locations.

Non-reflector medium screw base integrated lamps exist primarily in three technologies: 

incandescent/halogen, compact fluorescent, and LED.a DOE is not considering GSILs that have 

a medium screw base in this rulemaking due to the Appropriations Rider (see section 3.2.1.).

MBCFLs are addressed in section 3.2.2. As standards already exist for these products, 

this rulemaking considers whether to amend standards for MBCFLs. DOE also identified lamps 

that can serve in general lighting applications that use a CFL as the primary lighting source and 

also contain either a halogen capsule or an LED. The hybrid lamps that DOE identified meet the 

definition of MBCFL, though the term “hybrid CFL” is not currently defined. DOE is 

considering a definition for “hybrid CFL” in the CFL TP rulemaking. The definition under 

consideration is as follows:

Hybrid compact fluorescent lamp means a compact fluorescent lamp that incorporates 

one or more supplemental light sources of different technology.

Because MBCFLs are included in the scope of this rulemaking hybrid lamps are also 

included in the scope.

Medium screw base integrated LED lamps are rapidly increasing their market share 

relative to incandescent/halogen and compact fluorescent technology. In the most recent lamp 

indices data published by the National Electrical Manufacturers Association (NEMA) for the 

a In addition, DOE identified non-reflector medium screw base integrated lamps available in mercury vapor 

technology. These lamps are discussed in more detail in section 3.2.5.

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fourth quarter of 2013, the market share of LED A-shape replacement lamps increased 42.3 

percent over the previous quarter.1 Given their nontrivial market share, DOE has tentatively 

concluded that standards for medium screw base integrated LED lamps would result in 

significant energy savings. Technology for these lamps is rapidly changing with further 

improvements in lamp efficacy possible, thus DOE has tentatively concluded that standards for 

these lamps are technologically feasible. 

Reflector medium screw base integrated lamps are also typically offered with 

incandescent/halogen, compact fluorescent, or LED technology. Incandescent reflector lamps 

(IRLs) are specifically excluded from the definition of GSL and therefore will not be considered 

in this rulemaking. Based on data from the 2010 LMC, DOE determined that reflector CFLs 

compose less than 2 percent of the total inventory of lamps in the United States. The LED lamp 

data is not given by lamp shape, however LED lamps compose less than 1 percent of the total 

inventory of lamps in the United States, of which reflector LED lamps would be an even smaller 

portion. Although DOE believes that LED reflector lamps may compose a growing portion of the 

reflector lamp market, DOE has tentatively determined that establishing energy conservation 

standards for these lamps may ultimately increase national energy consumption. More efficient 

products typically have lower operating costs but higher initial costs relative to the baseline 

products available on the market. Because IRLs are not considered in this rulemaking and would 

be subject to separate, less stringent efficacy requirements, consumers may choose to purchase 

IRLs rather than more expensive CFL and LED reflector lamps. Further, because IRLs are less 

efficacious, they require more energy to produce the same amount of light as CFLs and LED 

lamps and thus any shift to these products could increase overall energy consumption. For these 

reasons, DOE has tentatively decided to not establish energy conservation standards for reflector 

medium screw base integrated lamps at this time.

Candelabra and Intermediate Base 

Candelabra and intermediate base integrated lamps are offered with 

incandescent/halogen, compact fluorescent, and LED technology. The candelabra base is the 

more common of the two base types – about 5 percent of product offerings compared to less than 

1 percent for the intermediate base. Candelabra and intermediate base integrated lamps provide 

overall illumination and are found primarily in residential locations. 

Non-reflector candelabra and intermediate base integrated lamps exist primarily in three 

technologies: incandescent/halogen, compact fluorescent, and LED. DOE is not considering 

incandescent/halogen lamps that have a candelabra or intermediate screw base in this rulemaking 

due to the Appropriations Rider. A review of compact fluorescent and LED product offerings 

indicates that few products are offered in these technologies compared to the number offered 

with incandescent/halogen technology. After reviewing the available product information, DOE 

does not believe it is appropriate to establish energy conservation standards for these lamps at 

this time. DOE found that a large number of CFL and LED candelabra and intermediate base 

lamps do not have standard ANSI shape designations. DOE believes these non-standard form 

factors could prevent the CFL and LED lamps from serving in the same applications as lamps 

with incandescent/halogen technology, and thus these lamp types may not be available at higher 

3-11
levels of efficacy. For these reasons, DOE has tentatively decided to not establish energy 

conservation standards for non-reflector candelabra and intermediate base integrated lamps at 

this time.

At the time of this analysis, the vast majority of candelabra and intermediate base 

integrated lamps were omnidirectional. DOE identified one incandescent/halogen reflector 

candelabra base integrated lamp and a limited number of incandescent/halogen reflector 

intermediate base integrated lamps. However, as stated previously, DOE is not considering these 

lamp types due to the Appropriations Rider. DOE was unable to identify reflector candelabra 

base or intermediate base integrated lamps in CFL or LED technology. For these reasons, DOE 

does not believe that standards for reflector candelabra and intermediate base integrated lamps 

would result in significant energy savings. Therefore, DOE has tentatively decided to not 

establish energy conservation standards for these lamps at this time.

Pin Base

DOE considers pin base integrated lamps to be integrally ballasted lamps (if applicable) 

with plug-in lamp bases that operate on line voltage (i.e., connect directly to the branch circuit 

without the use of a transformer). Pin base integrated lamps are offered in a variety of 

technologies and are also offered with or without a reflector. Common pin base integrated lamps 

are tubular quartz halogen lamps, GU24 base lamps, and GU10 base lamps with a MR shape. Pin 

base integrated lamps provide overall illumination and are found predominately in residential 

and commercial locations. DOE is considering defining terms related to pin base lamps in 

support of the scope of this rulemaking. The terms DOE is considering are as follows: 

Pin base lamp means a lamp that uses a base type designated as a single pin base or 

multiple pin base system in Table 1 of ANSI C81.61, Specifications for Electrics Bases 

(incorporated by reference; see §430.3).

GU24 base means the GU24 base standardized in ANSI C81.61 (incorporated by 

reference; see §430.3).

Non-reflector pin base integrated lamps are available with multiple pin bases and exist 

with incandescent/halogen, CFL, and LED technology. The incandescent/halogen non-reflector 

pin base integrated lamps (e.g., G8 and G9 base tubular halogen quartz lamps) have few products 

available on the market. CFL and LED non-reflector pin base integrated lamps commonly use 

GU24 bases. Of the integrated pin bases considered, lamps with GU24 bases compose the vast 

majority of the market. The GU24 base was created as a substitute to the medium screw base to 

prevent the use of incandescent/halogen lamps. While GU24 lamps may not currently be sold in 

the same volume as medium screw base lamps, DOE expects their sales to increase considerably 

as a result of regulations and voluntary program specifications. For example, California’s 

Building Code Standards Title 24 requires high efficiency lighting to be installed, thus 

prohibiting screw base sockets.2 Similarly, the ENERGY STAR® Program Requirements for 

Luminaires (Light Fixtures) V1.2 specification prohibits the use of screw bases (e.g., E26) in 

luminaires in order to achieve ENERGY STAR certification.3 Given their expected market share, 

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DOE has tentatively concluded that standards for non-reflector GU24 base integrated lamps 

would result in significant energy savings. Furthermore, because these lamps exist in varying 

levels of efficacy (i.e., CFL and LED technology), DOE has tentatively concluded that standards 

for these lamps would be technologically feasible. 

Reflector pin base integrated lamps are also offered with multiple pin bases, but in 

contrast to non-reflector lamps, the GU10 base is the most common base for reflector lamps. 

Although products are offered with incandescent/halogen, CFL, and LED technology, there are 

very few CFL products and halogen and LED lamp options dominate the market. Although DOE 

believes these lamps compose a sizeable portion of the reflector lamp market, DOE does not 

believe it is appropriate to establish energy conservation standards for these lamps at this time. 

DOE does not believe that LED technology is currently able to provide the same utility as 

halogen technology in the MR16 lamp shape. MR lamps are used in recessed downlights and 

track lighting, typically in retail, hospitality, residential, and museum applications.

4 As noted by 

DOE’s CALiPER program, halogen MR16 lamps deliver focused illumination from their small 

(2 inch) diameter, have desirable color quality, are easy to use with controls, and are available 

with a range of different options (e.g., beam angle and intensity) and accessories (e.g., spread 

lenses). Given this combination of features, the conventional halogen MR16 lamp is one of the 

most difficult lamps for LED technology to successfully replicate.5 A recent report by DOE’s 

CALiPER program found that every LED MR16 that claimed to be a replacement for a halogen 

MR16 produced fewer lumens and had lower center beam intensity than would be predicted 

using the ENERGY STAR center beam intensity tool. While new products continue to enter the 

market, LED MR16s still do not offer the same lumen packages as available halogen MR16s 

(particularly above 500 lumens). This difference is likely because LED lamps must incorporate a 

driver into an already small form factor and struggle to efficiently dissipate heat to achieve 

optimal performance. Because more efficient replacements that maintain the same utility are not 

currently available, DOE has tentatively decided to not establish energy conservation standards 

for reflector pin base integrated lamps at this time. 

Other Bases

Additional base types exist for integrated lamps, including other screw bases, however 

DOE identified very few integrated non-reflector and reflector lamps with these base types. DOE 

has tentatively concluded that given their low market share, standards for non-reflector and 

reflector lamps with other bases such as mogul bases and bayonet bases would not result in 

significant energy savings.

3.2.5.4 Non-Integrated Lamps

Non-integrated lamps (also referred to as externally ballasted lamps) are lamps that do 

not contain all components necessary for the starting and stable operation of the lamp. Nonintegrated lamps require an external component, such as a ballast, driver, or transformer to 

operate on a branch circuit. DOE considered non-integrated lamps that are not or could not be 

considered in another rulemaking proceeding, have a lumen output equal to or greater than 310 

lumens, have an ANSI base, are not a light fixture, and are not designed and labeled for use in 

3-13
the non-general applications described in section 3.2.5, to meet the definition of general service 

lamp. The following sections discuss general service non-integrated lamps by base type and 

identify lamps for which DOE is considering establishing standards at this time.

Screw Base

Non-reflector and reflector screw base non-integrated lamps are very uncommon and are 

available in a limited range of technologies. DOE identified one non-reflector medium screw 

base non-integrated lamp that may meet the definition of GSL. The non-reflector screw base 

non-integrated lamp is a CFL intended to be used in marine applications and operates using a 

battery. Similarly, DOE identified few reflector screw base non-integrated lamps. The reflector 

screw base non-integrated lamp type it did identify is used for providing illumination in pool and 

spa applications. DOE has tentatively concluded that given their extremely low market share, 

standards for non-reflector and reflector screw base non-integrated lamps would not result in 

significant energy savings and is therefore not considering establishing standards for these 

products at this time. 

Pin Base

DOE considers pin base non-integrated lamps to be lamps that use a single pin base or 

multiple pin base system (as defined by ANSI 81.61) and operate using an external ballast, 

driver, or transformer. Pin base non-integrated lamps are offered in a variety of technologies and 

are also offered with or without a reflector. Pin base non-integrated lamps provide overall 

illumination and are found in residential, commercial, and industrial locations. Common lamp 

types considered pin base non-integrated lamps are pin base CFLs and low voltage 

incandescent/halogen lamps with or without a reflector. 

Although non-reflector pin base non-integrated lamps are available in 

incandescent/halogen, CFL, and LED technologies, CFLs are by far the most common type. As 

stated previously, DOE determined that the term compact fluorescent includes both integrated 

and non-integrated CFLs and therefore DOE is considering including non-integrated, or pin base, 

CFLs in the scope of this rulemaking. Pin base CFLs are available in a variety of pin bases 

including 2-pin and 4-pin configurations such as the G24d-3 and G24q-3 bases, respectively. 

DOE notes that the market share of pin base CFLs is not insignificant given the vast 

number of product offerings and common use in commercial applications. Given their nontrivial 

market share, DOE has tentatively concluded that standards for pin base CFLs could result in 

significant energy savings. As discussed in chapter 5 of this TSD, DOE identified some variation 

in levels of efficacy for non-integrated lamps and therefore believes standards are 

technologically feasible. 

Incandescent/halogen non-reflector pin base non-integrated lamps include quartz halogen 

lamps that operate on low voltage and thus require the use of a transformer. Common base types 

for these lamps include G4 and GY6.35 bases. Incandescent/halogen non-reflector pin base non3-14
integrated lamps have few products available on the market. A very limited number of LED nonreflector pin base non-integrated lamps with the same base types, and thus intended to replace 

the incandescent/halogen versions, are available on the market currently. DOE has tentatively 

concluded that given their low market share, standards for non-reflector pin base non-integrated 

lamps would not result in significant energy savings. Further, because LED technology is 

changing rapidly, DOE believes that establishing standards for these products may slow 

innovation in a market that appears to be developing. 

Reflector pin base non-integrated lamps are also offered with multiple pin bases, but in 

contrast to non-reflector lamps, the GU5.3 base is the most common base and corresponds to the 

MR16 lamp shape. Although products are offered with incandescent/halogen, CFL, and LED 

technology, incandescent/halogen and LED lamp options dominate the market and there are very 

few CFL products. DOE notes that MR16 lamps can be used in general lighting applications. 

Although DOE believes these lamps provide overall illumination and compose a sizeable portion

of the reflector lamp market, DOE does not believe it is appropriate to establish energy 

conservation standards for these lamps at this time. For the same reasons described for reflector 

pin base integrated lamps in section 3.2.5.3, DOE does not believe that LED technology is 

currently able to provide the same utility as halogen technology in the MR16 lamp shape. 

Additionally, LED reflector pin base non-integrated lamps have the added complexity of needing 

to be compatible with an existing transformer. Because replacements that are more efficient and 

yet maintain the same utility are not currently available, DOE has tentatively decided to not 

establish energy conservation standards for reflector pin base integrated lamps at this time. 

Other Bases

DOE did not identify any additional base types for non-integrated lamps that meet the 

definition of GSL. 

3.2.6 Summary of Lamps

In summary, while many different lamp types meet the definition of GSL, DOE is only 

considering establishing standards in this rulemaking for the following lamps:

• Integrated, non-reflector, medium screw base lamps with a lumen output between 310 

and 2,600 lumens;

• GU24 base, non-reflector lamps with a lumen output between 310 and 2,600 lumens; and

• Non-integrated, non-reflector, pin base, CFLs with a lumen output between 310 and 

2,600 lumens.

Standards would not apply to the follow lamp types:

• OLED lamps

• Mercury vapor lamps

• IRLs

• GSFLs

3-15
• Light fixtures

• Appliance lamps

• Black light lamps

• Bug lamps

• Colored lamps

• Infrared lamps

• Marine signal lamps

• Mine service lamps

• Plant light lamps

• Sign service lamps

• Silver bowl lamps

• Showcase lamps

• Traffic signal lamps

• GSILs that are:

o A left-hand thread lamp

o A marine lamp

o A reflector lamp

o A rough service lamp

o A shatter-resistant lamp (including a shatter-proof lamp and a shatter-protected 

lamp)

o A 3-way incandescent lamp

o A vibration service lamp

o A G shape lamp (as defined in ANSI C78.20) (incorporated by reference; see 

§430.3) and ANSI C79.1-2002 (incorporated by reference; see §430.3) with a 

diameter of 5 inches or more

o A T shape lamp (as defined in ANSI C78.20) (incorporated by reference; see 

§430.3) and ANSI C79.1-2002 (incorporated by reference; see §430.3) and that 

uses not more than 40 watts or has a length of more than 10 inches

o A B, BA, CA, F, G16-1/2, G-25, G30, S, or M-14 lamp (as defined in ANSI 

C79.1-2002) (incorporated by reference; see §430.3) and ANSI C78.20 

(incorporated by reference; see §430.3) of 40 watts or less.

3.3 SCOPE OF METRICS

In this section, DOE discusses the scope of metrics included in this rulemaking. This 

rulemaking satisfies the requirements under 42 U.S.C 6295(m)(1) to review existing standards 

for MBCFLs, as CFLs are included in the definition of a GSL. EPAct 2005 amended EPCA by 

establishing energy conservation standards for MBCFLs. Performance requirements were 

specified for five metrics: (1) minimum initial efficacy; (2) lumen maintenance at 1,000 hours; 

(3) lumen maintenance at 40 percent of lifetime; (4) rapid cycle stress; and (5) lamp life. (42 

U.S.C. 6295(bb)(1)) 

In addition to revising the existing requirements for MBCFLs, DOE has the authority to 

establish requirements for additional metrics including color rendering index (CRI), power 

3-16
factor, operating frequency, and maximum allowable start time based on the requirements 

prescribed by the August 9, 2001, ENERGY STAR Program Requirements for CFLs Version 

2.0, or establish other requirements after considering energy savings, cost effectiveness, and 

consumer satisfaction. (42 U.S.C. 6295(bb)(2)-(3)) Therefore, as part of this rulemaking, DOE is 

reviewing whether all five existing metrics for MBCFLs should be amended and if additional 

performance requirements, including CRI, power factor, frequency, and start time, among others, 

should be added. 

3.3.1 Existing Metrics for MBCFLs

DOE is considering revising existing metrics and incorporating new metrics that improve 

the quality of MBCFLs. As stated previously, standards currently exist for initial lamp efficacy, 

lumen maintenance at 1,000 hours, lumen maintenance at 40 percent of lifetime, rapid cycle 

stress, and lamp lifetime. The current standards are based on August 9, 2001, ENERGY STAR 

Program Requirements for CFLs Version 2.0. ENERGY STAR has since released several 

updates to the specification, the latest of which was finalized in August 2014, ENERGY STAR 

Lamps Specification V1.1. DOE assessed the revisions in the ENERGY STAR specification for 

the five existing metrics required by DOE and also surveyed the specifications of commercially 

available MBCFLs to determine current product performance for the five existing metrics.

The current energy conservation standards for efficacy of MBCFLs vary based on 

wattage and whether the lamp has a cover. The ENERGY STAR Lamps Specification V1.1 

revised the wattage and covering divisions and increased the minimum lamp efficacy 

requirements. Based on an assessment of commercially available products, DOE determined that 

MBCFLs are performing above DOE’s current efficacy standard. DOE is evaluating revised 

efficacy requirements for GSLs, which includes MBCFLs, as part of this rulemaking. (See 

chapter 5 of this TSD for further details.)

DOE also has minimum requirements for lumen maintenance. For lumen maintenance at 

1,000 hours, DOE requires that the average of at least five lamps be a minimum of 90 percent of 

initial lumen output at 1,000 hours. The ENERGY STAR Lamps Specification V1.1 maintained 

this requirement with the added specification that all units must be surviving at 1,000 hours. For 

lumen maintenance at 40 percent of lifetime, DOE requires that 80 percent of the initial lumens 

must be achieved at 40 percent of lifetime. The ENERGY STAR Lamps Specification V1.1 also 

maintained this requirement with the added specification that no more than three units may be 

less than 75 percent of the initial lumen rating. DOE found that manufacturers do not publish 

information in catalogs on lumen maintenance at 1,000 hours and 40 percent of lifetime for 

MBCFLs. DOE assessed data submitted for the compliance certification management system 

(CCMS) reporting requirements and found that the majority of lamps certified exceeded the 

minimum lumen maintenance standards. DOE believes that the current requirements for lumen 

maintenance adequately address potential issues with lumen depreciation that could lead to 

consumer dissatisfaction and is therefore considering maintaining the existing requirements for 

lumen maintenance at 1,000 hours and lumen maintenance at 40 percent of lifetime.

Additionally, there is a minimum requirement for rapid cycle stress for MBCFLs. DOE 

requires that at least five lamps must survive cycling once per every two hours of rated life. The 

3-17
ENERGY STAR Lamps Specification V1.1 changed the cycling requirement to once per hour of 

rated lifetime or a maximum of 15,000 cycles. The ENERGY STAR Lamps Specification V1.1 

added an exception for instant start CFLs with a start time less than or equal to 100 milliseconds 

(ms), which are only required to survive cycling once per every two hours of rated life. For 

MBCFLs other than instant start CFLs, the increased requirement for rapid cycle stress provides 

consumer satisfaction by ensuring that MBCFLs are able to survive frequent switching and 

preventing premature failure. DOE found that manufacturers do not publish information on rapid 

cycle stress or starting method for MBCFLs. Further, manufacturers simply report the number of 

surviving units for DOE CCMS reporting requirements. However, DOE has received feedback 

from manufacturers that the market shifts in response to ENERGY STAR specifications and so 

DOE believes that MBCFLs are likely already achieving this level of product performance for 

rapid cycle stress. Therefore, DOE is considering increasing the number of cycles required for 

non-instant start lamps (i.e., lamps with start times greater than 100 ms) to once per every hour 

of rated life with a maximum of 15,000 cycles to reduce testing burden.

DOE currently requires a minimum lifetime of 6,000 hours for MBCFLs. The ENERGY 

STAR Lamps Specification V1.1 revised the minimum lifetime requirement to be 10,000 hours. 

Lifetime impacts consumer satisfaction as a longer life requires less frequent changes. Based on 

an assessment of commercially available lamps in manufacturer catalogs, DOE found that the 

majority of MBCFLs on the market have lifetimes of at least 10,000 hours. Further, of the 

MBCFLs for which data was submitted to DOE for CCMS reporting, 73 percent have a lifetime 

of at least 10,000 hours. The ENERGY STAR Certified Light Bulbs Database also supports an 

increased lifetime with 79 percent of certified products having a lifetime of at least 10,000 

hours.b Because DOE found that commercially available MBCFLs are already achieving this 

higher level of performance, DOE is considering revising the lifetime standard for MBCFLs to 

be a minimum of 10,000 hours.

3.3.2 Additional Metrics for MBCFLs

With respect to requiring additional metrics for MBCFLs, DOE considered power factor, 

THD, CRI, correlated color temperature (CCT), operating frequency, and start time. DOE’s 

evaluation of these potential metrics for MBCFLs is detailed below. 

DOE has explicit authority to consider power factor for MBCFLs. (42 U.S.C. 

6295(bb)(2)) Power factor is the ratio of active input power to apparent input power. A low 

power factor product is inefficient and requires an increase in electric utility’s generation and 

transmission capacity.6 Because a minimum power factor requirement could decrease energy 

use, DOE is considering power factor in this rulemaking. Total harmonic distortion is defined as 

the ratio of the root mean square (rms) values of the harmonic content to that of the fundamental 

current, expressed as a percentage. Because THD is directly related to power factor, setting a 

minimum power factor requirement will effectively set a standard for THD and therefore DOE is 

not considering a setting a separate requirement for THD.

b ENERGY STAR Program Requirements Product Specification for Lamps (Light Bulbs) Eligibility Criteria Version 

1.0 becomes effective September 30, 2014, at which time the updated lifetime of 10,000 hours will be required. 

3-18

 
DOE reviewed industry specifications for MBCFLs and found that the ENERGY STAR 

Lamps Specification V1.1 requires that CFLs have a power factor of 0.5 or greater. ENERGY 

STAR does not have a separate requirement for THD. The industry standard ANSI C82.77 

Harmonic Emission Limits – Related Power Quality Requirements for Lighting Equipment 

suggests a power factor of 0.5 for integrally ballasted medium screw base compact light sources 

with input power less than or equal to 35 watts. Based on an assessment of commercially 

available lamps in manufacturer catalogs, DOE determined that the majority of MBCFLs have a 

power factor in the range of 0.5 to 0.6 and a limited number of MBCFLs have a power factor 

greater than 0.6. The ENERGY STAR Certified Light Bulbs Database supported this distribution 

with about 77 percent of MBCFLs with a power factor in the range of 0.5 to 0.6 and only about 

two percent of MBCFLs had a power factor greater than 0.8. Thus, DOE believes that requiring a 

minimum power factor of 0.5 is achievable for MBCFLs while supporting improved overall 

efficacy. It is also consistent with ENERGY STAR requirements and recommendations in 

industry standards. DOE is considering adding the requirement for MBCFLs to have a power 

factor of 0.5 or greater and no separate requirement for THD. 

DOE does not currently have a standard for CRI, however, DOE has explicit authority to 

consider CRI for MBCFLs. (42 U.S.C. 6295(bb)(2)) CRI is a measure of the color rendering 

properties of a light source, or the ability of a light source to show the “true” color of an object as 

compared to a reference source.7 A standard for CRI ensures consumer satisfaction because high 

CRI light sources render colors well. The ENERGY STAR Lamps Specification V1.1 requires 

that CFLs have a CRI of at least 80. It also requires that no more than 3 units included in the 

average have a CRI less than 77 and no units have a CRI less than 75. Based on an assessment of 

commercially available lamps in manufacturer catalogs, DOE found that over 99 percent of 

MBCFLs on the market have a CRI of at least 80. DOE identified only a few MBCFLs with a 

CRI of less than 80. Because a minimum CRI requirement would increase consumer satisfaction 

and DOE found that nearly all commercially available MBCFLs are already achieving a CRI of 

at least 80, DOE is considering requiring MBCFLs to have a CRI of 80 or greater. 

DOE does not have a standard for correlated color temperature (CCT). CCT is a measure 

of the perceived color of the white light emitted from a lamp.8 Lower CCT values correspond to 

warmer light, with more red content in the spectrum, and higher CCTs correspond to cooler light, 

with more blue content. The ENERGY STAR Lamps Specification V1.1 requires CCT to 

correspond to one of six nominal CCTs and fall within a prescribed chromaticity space. DOE 

believes that different CCTs are desirable depending on the application and therefore is not 

considering setting a requirement for CCT for MBCFLs. 

Currently, DOE does not have a standard for operating frequency. Operating frequency is 

the frequency of the current measured in hertz supplied by the ballast to the lamp during 

operation. The ENERGY STAR Lamps Specification V1.1 requires that CFLs have a frequency 

within 20 to 33 kHz or at least 40 kHz. Requiring an operating frequency within a specified 

range ensures that lamps do not interfere with other electrical products, such as television 

remotes. Because operating frequency does not directly impact consumer satisfaction, DOE is 

not considering setting standards for operating frequency at this time. 

3-19
DOE does not currently have a standard for start time. The ENERGY STAR Lamps 

Specification V1.1 requires that the time needed for a lamp to become fully illuminated must be 

within one second of application of electrical power. DOE believes that start time impacts 

consumer satisfaction because a delay in starting is undesirable and can affect acceptance of a 

more efficient lamp technology. DOE reviewed manufacturer catalogs and the ENERGY STAR 

Certified Light Bulbs Database and found that neither start time nor starting method is typically 

reported. DOE is considering requiring a start time of within one second of the application of 

electrical power because the market likely finds one second an acceptable start time since it has 

been the ENERGY STAR specification for several years. 

3.3.3 Summary

Table 3.3.1 summarizes the metrics and corresponding requirements that DOE is 

considering for MBCFLs.

Table 3.3.1 Performance Metrics for Medium Base Compact Fluorescent Lamps

Metric Minimum Standard Considered

Efficacy See chapter 5 of this TSD for more information on candidate 

standard levels under consideration.

Lumen Maintenance at 1,000 hours 90 percent of initial lumen output at 1,000 hours

Lumen Maintenance at 40 percent of Lifetime 80 percent of initial lumen output at 40 percent of lifetime

Rapid Cycle Stress

MBCFL with start time > 100 ms: survive one cycle per hour of 

rated lifetime or a maximum of 15,000 cycles

MBCFLs with a start time of ≤ 100 ms: survive one cycle per every 

two hours of rated lifetime

Lifetime 10,000 hours

Power Factor 0.5

CRI 80

Start Time The time needed for a MBCFL to become fully illuminated must be 

within one second of application of electrical power

3.4 MARKET ASSESSMENT

For GSLs, the following market assessment identifies the relevant manufacturer trade 

association and domestic manufacturers; discusses manufacturer market share, regulatory 

programs, and non-regulatory initiatives; provides historical shipment data and market trends; 

and defines product classes.

3.4.1 Trade Association

The National Electrical Manufacturers Association (NEMA) is the trade association for 

GSLs. NEMA’s Lighting Systems Division is one of ten product divisions, and is further divided 

into six product sections. Feedback from manufacturer interviews indicated that the Lamp 

Section’s 27 member companies comprise a significant portion of the U.S. halogen lamp market, 

but a much lesser portion of the U.S. CFL and LED lamp markets. In addition to GSLs, NEMA’s 

Lighting Systems Division also oversees products such as emergency lighting, lighting controls, 

and emerging lighting technologies. NEMA provides an organization through which 

manufacturers of lighting equipment can work together on projects that affect their industry and 

businesses. NEMA’s activities relating to energy efficiency include:

9

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• “Advising the Department of Energy (DOE) and executive agencies on lighting 

research and market transformation needs

• Participating in the climate change discussions with the Administration and 

Congress

• Monitoring energy-efficiency rulemakings and standards affecting lighting 

products by DOE and states

• Promoting the national voluntary luminaire rating and information program under 

the National Lighting Collaborative

• Supporting adoption of new ASHRAE/IESNA 90.1 lighting provisions

• Advising the DOE Federal Energy Management Program on energy efficient 

lighting recommendations

• Coordinating with DOE and the Environmental Protection Agency on ENERGY

STAR Buildings and ENERGY STAR voluntary product labeling programs.

• Advocating market-based approaches to enhance the use and penetration of 

energy-efficient technologies”

3.4.2 Manufacturers and Market Share

The following list contains the names of some manufacturers that produce GSLs:

• Bulbrite Industries, Inc.

• Cree, Inc.

• EiKO Global, LLC

• Feit Electric Company, Inc.

• General Electric Company

• GREEN CREATIVE, LLC.

• Halco Lighting Technologies

• Lighting Science Group Corp.

• Litetronics International, Inc.

• MaxLite, Inc.

• OSRAM SYLVANIA, Inc.

• Philips Lighting Company

• Premium Quality Lighting, Inc.

• Satco Products, Inc.

• Technical Consumer Products, Inc.

• Toshiba International Corp.

• Ushio America, Inc.

• Westinghouse Lighting Corp.

• Zenaro Lighting, Inc.

3.4.2.1 Small Businesses

Small businesses may be particularly affected by the promulgation of minimum energy

conservation standards for GSLs. The Small Business Administration (SBA) lists small business 

size standards that are matched to industries as they are described in the North American 

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Industry Classification System (NAICS). A size standard is the largest that a for-profit concern 

can be and still qualify as a small business for Federal Government programs. These size 

standards are generally the average annual receipts or the average employment of a firm. For 

lamps, the size standard is matched to NAICS code 335110, Electric Lamp Bulb and Part 

Manufacturing, which has a size standard of 1,000 employees or fewer.

10

DOE studies the potential impacts on these small businesses in detail as part of the 

manufacturer impact analysis.

3.4.3 Regulatory Programs

Several federal and international regulatory programs affect the markets for GSLs. The 

following section summarizes U.S., Canadian, and European regulatory initiatives relevant to the 

lamps covered by this rulemaking. While the following discussion is not exhaustive in describing 

all regulatory action related to GSLs, it provides detail on some notable initiatives that 

characterize recent developments in the lighting market.

3.4.3.1 GSL Federal Energy Conservation Standards

EPCA established an energy conservation program for major household appliances. 

Additional amendments to EPCA gave DOE the authority to regulate the energy efficiency of 

several products, including GSL types. Specifically, the Energy Policy Act of 2005 established 

standards for MBCFLs. The standards mandate that lamps manufactured on or after the specified 

effective dates must meet the minimum lumen maintenance, rapid cycle stress test, average rated 

lamp life, and average lamp efficacy requirements. 10 CFR Section 430.32(u) DOE published a 

technical amendment in October 2005 that codified the EPAct 2005 standards into the CFR with 

an effective date of January 1, 2006. Table 3.4.1 presents these Federal standards.

Table 3.4.1 EPAct 2005 Federal Regulations for Medium Base Compact Fluorescent 

Lamps

Factor Requirements

Lamp Power (Watts) & 

Configuration1

Minimum Efficacy: lumens/watt (Based upon initial lumen data).2

Bare Lamp:

Lamp Power < 15 45.0.

15 ≤ Lamp Power 60.0.

Covered Lamp (no reflector):

Lamp Power < 15 40.0.

15 ≤ Lamp Power < 19 48.0.

19 ≤ Lamp Power < 25 50

25 ≤ Lamp Power 55.0.

1,000-hour Lumen Maintenance The average of at least 5 lamps must be a minimum 90.0% of initial (100-

hour) lumen output @ 1,000 hours of rated life.

Lumen Maintenance 80.0% of initial (100-hour) rating at 40 percent of rated life (per ANSI 

C78.5 Clause 4.10).

3-22
Rapid Cycle Stress Test Per ANSI C78.5 and IESNA LM-65 (clauses 2,3,5, and 6).

Exception: Cycle times must be 5 minutes on, 5 minutes off. Lamp will be 

cycled once for every two hours of rated life. At least 5 lamps must meet 

or exceed the minimum number of cycles.

Average Rated Lamp Life ≥6,000 hours as declared by the manufacturer on packaging. At 80% of 

rated life, statistical methods may be used to confirm lifetime claims based 

on sampling performance.

1Take performance and electrical requirements at the end of the 100-hour aging period according to ANSI Standard C78.5. The 

lamp efficacy shall be the average of the lesser of the lumens per watt measured in the base up and/or other specified positions. 

Use wattages placed on packaging to select proper specification efficacy in this table, not measured wattage. Labeled wattages 

are for reference only.

2Efficacies are based on measured values for lumens and wattages from pertinent test data. Wattages and lumens placed on 

packages may not be used in calculation and are not governed by this specification. For multi-level or dimmable systems, 

measurements shall be at the highest setting. Acceptable measurement error is ±3%.

EISA also prescribed new standards for GSILs which DOE codified into the CFR on 

March 23, 2009. The standards mandate that lamps manufactured on or after the specified 

effective dates must meet minimum lifetime and lumen output requirements for a given wattage. 

(42 U.S.C. 6295(i)(1)); 10 CFR Section 430.32(x)(1)). Further, the standards require GSILs to 

have a CRI greater than or equal to 80, and the modified spectrum GSILs have a CRI greater 

than or equal to 75. 10 CFR Section 430.32(x)(1) Table 3.4.2 and Table 3.4.3 show the standards 

which had effective dates ranging from January 1, 2012 to January 1, 2014.

Table 3.4.2 EISA 2007 Federal Regulations for General Service Incandescent Lamps

Rated Lumen 

Ranges

Maximum 

Rated Wattage

Minimum Rated 

Lifetime

Effective 

Date

1,490-2,600 72 1,000 hrs 1/1/2012

1,050-1,489 53 1,000 hrs 1/1/2013

750-1,049 43 1,000 hrs 1/1/2014

310-749 29 1,000 hrs 1/1/2014

Table 3.4.3 EISA 2007 Federal Regulations for Modified Spectrum General Service 

Incandescent Lamps

Rated Lumen 

Ranges

Maximum 

Rated Wattage

Minimum Rated 

Lifetime

Effective 

Date

1,118-1,950 72 1,000 hrs 1/1/2012

788-1,117 53 1,000 hrs 1/1/2013

563-787 43 1,000 hrs 1/1/2014

232-562 29 1,000 hrs 1/1/2014

Currently no energy conservation standards exist for LED lamps, OLED lamps, or the 

additional GSLs identified under the scope of coverage.

Title III of EPCA sets forth a variety of provisions designed to improve energy 

efficiency. Part B of Title III (42 U.S.C. 6291-6309) established the “Energy Conservation 

Program for Consumer Products Other Than Automobiles,” which includes major household 

3-23
appliances.c Subsequent amendments expanded Title III of EPCA to include additional consumer 

products, including GSLs—the products that are the focus of this preliminary analysis. In 

particular, amendments to EPCA in the Energy Independence and Security Act of 2007 (EISA)

directed DOE to conduct two rulemaking cycles to evaluate energy conservation standards for 

GSLs. (42 U.S.C. 6295(i)(6)(A)-(B))

For the first rulemaking cycle, EPCA, as amended by EISA, directs DOE to initiate a 

rulemaking no later than January 1, 2014, to evaluate standards for GSLs and determine whether 

exemptions for certain incandescent lamps should be maintained or discontinued. (42 U.S.C. 

6295(i)(6)(A)(i)) The scope of the rulemaking is not limited to incandescent lamp technologies. 

(42 U.S.C. 6295(i)(6)(A)(ii)) Further, for this first cycle of rulemaking, the EISA amendments 

provide that DOE must consider a minimum standard of 45 lumens per watt (lm/W). (42 U.S.C. 

6295(i)(6)(A)(ii)) If DOE fails to meet the requirements of 42 U.S.C. 6295(i)(6)(A)(i)-(iv) or the 

final rule from the first rulemaking cycle does not produce savings greater than or equal to the 

savings from a minimum efficacy standard of 45 lm/W, sales of GSLs that do not meet the 

minimum 45 lm/W standard beginning on January 1, 2020, will be prohibited. (42 U.S.C. 

6295(i)(6)(A)(v)) 

The EISA-prescribed amendments direct DOE to initiate a second rulemaking cycle by 

January 1, 2020, to determine whether standards in effect for general service incandescent lamps 

(GSILs) should be amended with more stringent requirements and if the exemptions for certain 

incandescent lamps should be maintained or discontinued. (42 U.S.C. 6295(i)(6)(B)(i)) For this 

second review of energy conservation standards, the scope is not limited to incandescent lamp 

technologies. (42 U.S.C. 6295(i)(6)(B)(ii))

This preliminary analysis is part of DOE’s first cycle of review to evaluate standards for 

GSLs and whether the standards should apply to additional GSL types. (42 U.S.C. 6295(i)(A) 

Additionally, this rulemaking satisfies the requirements under 42 U.S.C 6295(m)(1) for DOE to 

review the existing standards for MBCFLs, as CFLs are included in the definition of GSL. It also 

addresses 42 U.S.C. 6295(gg)(3) in which DOE is directed to incorporate standby mode and off 

mode energy use in any amended (or new) standard adopted after July 1, 2010, pursuant to 42 

U.S.C. 6295(o).

3.4.3.2 California Energy Commission

California’s Office of Administrative Law (OAL) enacts statewide regulatory programs 

published in the California Code of Regulations (CCR). CCR Title 20, Division 2, Chapter 4, 

Article 4, Section 1605.3 contains state standards for GSLs in accordance with the WarrenAlquist State Energy Resources Conservation and Development Act, last revised in August 2013. 

This law requires that lighting standards be set to achieve a 50 percent reduction in energy 

consumption from 2007 levels for indoor residential lighting and a 25 percent reduction from 

2007 levels for indoor commercial and outdoor lighting by 2018. Current CCR standards for 

c

Part B was re-designated Part A on codification in the U.S. Code for editorial reasons. 

3-24

 
GSLs use a modified version of the federal GSIL standard with effective dates a year prior to the 

federal standard. The standards are provided in Table 3.4.4 and Table 3.4.5 below.11

Table 3.4.4 California Standards for State-Regulated General Service Incandescent Lamps 

Tier I

Rated Lumen 

Ranges

Maximum 

Rated Wattage

Minimum Rated 

Lifetime

Proposed California 

Effective Date

1,490-2,600 72 1,000 hrs 1/1/2011

1,050-1,489 53 1,000 hrs 1/1/2012

750-1,049 43 1,000 hrs 1/1/2013

310-749 29 1,000 hrs 1/1/2013

Table 3.4.5 California Standards for State-Regulated Modified Spectrum General Service 

Incandescent Lamps Tier I

Rated Lumen 

Ranges

Maximum 

Rated Wattage

Minimum Rated 

Lifetime

Proposed California 

Effective Date

1,118-1,950 72 1,000 hrs 1/1/2011

788-1,117 53 1,000 hrs 1/1/2012

563-787 43 1,000 hrs 1/1/2013

232-562 29 1,000 hrs 1/1/2013

Similarly, California also has proposed standards for GSLs which will precede the EISA 

2007 backstop requirement of 45 lm/W effective January 1, 2020 if a GSL final rule does not 

yield sufficient energy savings. Section 1605.3(k)(3)(A) of the CCR states that the standards 

apply to any lamp intended for a general service or general illumination application, regardless 

of whether it is an incandescent; that has a medium screw base or any screw base not defined in 

ANSI C81.61-2006; and that has an operating voltage in the range of 110 to 130 V. The 

requirements are detailed in Table 3.4.6.

12

Table 3.4.6 California Standards for State-Regulated General Service Lamps Tier II

Rated Lumen 

Ranges

Minimum 

Lamp Efficacy

Minimum Rated 

Lifetime

Proposed California 

Effective Date

1,490-2,600 45 lm/W 1,000 hrs 1/1/2018

Additionally, California has preliminarily proposed standards for white light LED 

replacement lamps and retrofit kits with E12, E17, E26, or GU24 bases. This proposal includes 

omnidirectional, directional, and decorative lamps. The standards, which take into account CRI 

and efficacy, are expected to come in a two-phase process, as detailed in Table 3.4.7. The 

proposal also requires omnidirectional lamps to produce a light distribution pattern that aligns 

with the requirements in ENERGY STAR Lamps Specification V1.1.13 Lastly, the proposal adds 

labeling standards that require manufacturers to demonstrate performance before making claims 

of dimmability, incandescent equivalence, and meeting the Voluntary California Quality LED 

Lamp Specification.14

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Table 3.4.7 California Standards for State-Regulated LED Lamps

Compliance 

Equation

Minimum 

Lamp Efficacy Minimum CRI Proposed California 

Effective Date

Tier I

3*CRI + 

Efficacy ≥ 335 55 lm/W 82 1/1/2017

Tier II

3*CRI + 

Efficacy ≥ 350 65 lm/W 84 1/1/2019

CCR Title 24, Part 6 contains the 2013 Building Energy Efficiency Standards, Section 

150.0(k) of which mandates requirements for residential lighting. These regulations were 

approved in May 2012 and go into effect on January 1, 2014, replacing the 2008 Building 

Energy Efficiency Standards. The 2013 Building Energy Efficiency Standards are 25 percent 

more efficient than the previous standards for residential construction and 30 percent more 

efficient for non-residential construction.15 Title 24 also regulates products that can be used with 

GSLs, such as automatic time-switch control devices, occupancy sensors, multilevel occupancy 

sensors, automatic day lighting control devices, interior photosensors, multilevel and outdoor 

astronomical time-switch controls, manual-on occupancy sensors, and dimmers. The regulations 

mandate that the products have specific features and capabilities in order to be installed.

Section 150.0(k) of the CCR draws divisions between high and low efficacy light 

sources. The categories are laid out in Table 3.4.8 and Table 3.4.9. In order to comply with the 

new standards, homeowners must meet certain criteria of high efficacy lighting in various rooms 

of their home. The section details standards for lighting in kitchens, cabinets, bathrooms, 

garages, laundry rooms, utility rooms, and all other rooms. There are also stipulations for 

residential outdoor lighting, illuminated address signs, residential garages for eight or more 

vehicles, and interior common areas of low-rise multi-family residential buildings. For each 

space, these standards prescribe either a minimum percentage of high efficacy luminaires, a 

minimum quantity of high efficacy luminaires, or a maximum wattage. Some standards also 

include control requirements depending on the space.16

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Table 3.4.8 California Classification of High Efficacy and Low Efficacy Light Sources

High Efficacy Light Sources

Luminaires manufactured, designed and rated 

for use with only lighting technologies in this 

column shall be classified as high efficacy.

Low Efficacy Light Sources

Luminaires manufactured, designed or rated for use with any of 

the lighting technologies in this column shall be classified as 

low efficacy. 

1. Pin-based linear or compact fluorescent lamps 

with electronic ballasts. Compact fluorescent 

lamps ≥ 13 watts shall have 4 pins for compliance 

with the electronic ballast requirements in Section 

150.0(k)1D. 

2. Pulse-start metal halide lamps. 

3. High pressure sodium lamps. 

4. GU-24 sockets rated for LED lamps. 

5. GU-24 sockets rated for compact fluorescent 

lamps. 

6. Luminaires using LED light sources which have 

been certified to the Commission as high efficacy 

in accordance with Reference Joint Appendix JA8. 

7. Luminaire housings rated by the manufacturer 

for use with only LED light engines. 

8. Induction lamps. 

Note: Adaptors which convert an incandescent 

lamp holder to a high-efficacy luminaire shall not 

be used to classify a luminaire as high efficacy. 

1. Line-voltage lamp holders (sockets) capable of operating 

incandescent lamps of any type. 

2. Low-voltage lamp holders capable of operating incandescent 

lamps of any type. 

3. High efficacy lamps installed in low-efficacy luminaires, 

including screw base compact fluorescent and screw base LED 

lamps. 

3. Mercury vapor lamps. 

4. Track lighting or other flexible lighting system which allows 

the addition or relocation of luminaires without altering the 

wiring of the system. 

6. Luminaires using LED light sources which have not been 

certified to the Commission as high efficacy. 

7. Lighting systems that have modular components that allow 

conversion between high-efficacy and low-efficacy lighting

without changing the luminaires’ housing or wiring. 

8. Electrical boxes finished with a blank cover or where no 

electrical equipment has been installed, and where the electrical 

box can be used for a luminaire or a surface mounted ceiling 

fan. 

Table 3.4.9 California Minimum Requirements for Other Light Sources to Qualify as High 

Efficacy

Use this table to determine luminaire efficacy only for lighting systems not listed in Table 3.4.7

Luminaire Power Rating Minimum Luminaire Efficacy to Qualify as High Efficacy 

5 watts or less 30 lumens per watt

over 5 watts to 15 watts 45 lumens per watt

over 15 watts to 40 watts 60 lumens per watt 

over 40 watts 90 lumens per watt

Note: Determine minimum luminaire efficacy using the system initial rated lumens divided by the luminaire total 

rated system input power.

3.4.3.3 Nevada Governor’s Office of Energy

In June of 2007, the state of Nevada adopted Assembly Bill 178 which established 

efficacy standards for general purpose lights sold in the state of Nevada.17 The bill set the 

required efficacy to a minimum of 25 lumens per watt (lm/W) of electricity. That standard will 

be in effect between January 1, 2012 and December 31, 2015. The Director of the Office of 

3-27
Energy must adopt regulations to establish a new minimum standard to take effect on January 1, 

2016, which must exceed 25 lm/W. As used in the legislation, general purpose light means

"lamps, bulbs, tubes or other devices that provide functional illumination for indoor and outdoor 

use. The term does not include ‘specialty lighting’ or ‘lighting necessary to provide illumination

for persons with special needs.’" Nevada Revised Statutes 701.26018

3.4.3.4 Canadian Energy Efficiency Standards

The Natural Resources Canada (NRCan) Office of Energy Efficiency regulates the 

energy efficiency of GSLs in Canada.d In 1992, the Canadian Parliament passed the Energy 

Efficiency Act (S.C. 1992, c. 36), which concerns minimum performance levels for energy-using 

products, effective February 1995. In December 2008, Canada’s Energy Efficiency Regulations

(SOR/2008-323) were amended to include GSLs. 

Canada’s approach to the regulation of GSLs differs from U.S. energy conservation 

standards established by EISA discussed in section 3.4.3.1. There are substantial differences in 

the products covered under Canada’s GSL rule compared to the scope of coverage of this 

rulemaking. Most notably, the Canadian rule for GSLs does not include all integrally ballasted 

CFLs nor any lamps using solid state technology,

19 thus closely aligning with the definition of a 

GSIL at 10 CFR 430.2. NRCan does not currently have minimum energy performance standards 

(MEPs) for CFLs or LEDs, however a CFL test procedure exists in support of labeling. The first 

GSL standards were published in the 10th amendment to Canada’s Energy Efficiency 

Regulations. In October 2013, NRCan pre-published a proposed amendment 12B, which is the 

most recent update of those standards. The amendment aligns Canadian standards with the EISA 

2007 energy conservation standards for GSILs. The MEPs and effective dates are detailed in

Table 3.4.10.

20

Table 3.4.10 NRCan Proposed Amendment 12B

Type of Light Bulb Standards Effective Date

Traditional 

Incandescent 

Light Bulb

Standard Spectrum 

(lumen range)

Modified 

Spectrum 

(lumen range)

MEPS 

(maximum 

wattage)

Date of 

Manufacture

(no change)

100 W 1,490 – 2,600 1,118 – 1,950 72 W January 1, 2014

75 W 1,050 – 1,489 788 – 1,117 53 W January 1, 2014

60 W 750 – 1,049 563 – 787 43 W December 31, 2014

40 W 310 – 749 232 – 562 29 W December 31, 2014

3.4.3.5 European Energy Efficiency Standards

Commission Regulation (EC) No 245/2009 (March 18, 2009) implemented Directive 

2005/32/EC (July 6, 2005) of the European Parliament and the Council of the European Union 

and amended Council Directive 92/42/EEC and Directives 96/57/EC and 2000/55/EC 

(September 18, 2000) to establish a framework for setting energy efficiency requirements for 

d News and information on NRCan energy efficiency regulations and standards can be found at 

http://www.nrcan.gc.ca/energy/regulations-codes-standards/6845. 

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energy-using equipment, including non-integrated CFLs. The energy efficiency requirements 

apply to equipment available on the market and do not differentiate requirements by lamp 

application. Lamps that are not white light sources, are directional, or intended for use in 

applications other than general lighting are exempted from standards. 

The European energy efficiency requirements stipulated in Commission Regulation (EC) 

No 245/2009 regulate the covered equipment in three stages and for three categories. The stages 

implement the regulations over time with stage one effective in 2010, stage two in 2013, and 

stage three in 2018. The categories regulate lamp efficacy, performance, and labeling. Part of the 

first stage required CFLs without integrated ballasts to comply with the efficacies listed in Table 

3.4.11 through Table 3.4.13 when tested at 25 °C. The rule also stipulates:

“In case the nominal wattages or lamp shapes are different from those listed... lamps 

must reach the luminous efficacy of the nearest equivalent in terms of wattage and shape. 

If the nominal wattage is at equal distance from two wattages in the table, it shall 

conform to the higher efficacy of the two. If the nominal wattage is higher than the 

highest wattage in the table, it shall conform to the efficacy of that highest wattage.”

The second and third stage efficacy requirements do not affect non-integrated CFLs.21

Table 3.4.11 EU Minimum Efficacy for Single Capped Fluorescent Lamps Working on 

Electromagnetic and Electronic Ballast

Small Single Parallel Tube, Lamp 

Cap G23 (2 pin) or 2G7 (4 pin)

Double Parallel Tubes, Lamp Cap 

G24d (2 pin) or G24q (4 pin)

Triple Parallel Tubes, Lamp Cap 

GX24d (2 pin) or GX24q (4 pin)

Nominal 

Wattage (W)

Rated Luminous 

Efficacy (lm/W) 

100 hr Initial 

Value

Nominal 

Wattage (W)

Rated Luminous 

Efficacy (lm/W) 

100 hr Initial 

Value

Nominal 

Wattage (W)

Rated Luminous 

Efficacy (lm/W) 

100 hr Initial 

Value

5 48 10 60 13 62

7 57 13 69 18 67

9 67 18 67 26 66

11 76 26 66

4 Legs in One Plane, Lamp Cap 

2G10 (4 pin)

Long Single Parallel Tube, Lamp 

Cap 2G11 (4 pin)

Nominal 

Wattage (W)

Rated Luminous 

Efficacy (lm/W) 

100 hr Initial 

Value

Nominal 

Wattage (W)

Rated Luminous 

Efficacy (lm/W) 

100 hr Initial 

Value

18 61 18 67

24 71 24 75

36 78 34 82

36 81

Source: 2010/347/EU

3-29
Table 3.4.12 EU Minimum Efficacy for Single Capped Fluorescent Lamps Working on 

Only an Electronic Ballast

Triple Parallel Tubes, Lamp Cap 

GX24q (4 pin)

Four Parallel Tubes, Lamp Cap 

GX24q (4 pin)

Long Single Parallel Tube, Lamp 

Cap 2G11 (4 pin)

Nominal 

Wattage (W)

Rated Luminous 

Efficacy (lm/W) 

100 hr Initial 

Value

Nominal 

Wattage (W)

Rated Luminous 

Efficacy (lm/W) 

100 hr Initial 

Value

Nominal 

Wattage (W)

Rated Luminous 

Efficacy (lm/W) 

100 hr Initial 

Value

32 75 57 75 40 83

42 74 70 74 55 82

57 75 80 75

70 74

Source: 2010/347/EU

Table 3.4.13 EU Minimum Efficacy for Single Capped Fluorescent Lamps with Square 

Shape or (Very) High Output

Single Flat Plane Tube, Lamp Cap 

GR8 (2 pin), GR10q (4 pin) or 

GRY10q3 (4 pin)

Four or Three Parallel T5 Tubes, 

Lamp Cap 2G8 (4 pin)

Nominal 

Wattage (W)

Rated Luminous 

Efficacy (lm/W) 

100 hr Initial 

Value

Nominal 

Wattage (W)

Rated Luminous 

Efficacy (lm/W) 

100 hr Initial 

Value

10 65 60 67

16 66 82 75

21 64 85 71

28 73 120 75

38 71

55 71

Source: 2009/245/EC

2010/347/EU amended the efficacy deductions given in 2009/245/EC for fluorescent 

lamps with high color temperature, high color rendering, second lamp envelope, or long life, so 

that required efficacy is cumulatively reduced as shown in Table 3.4.14.

22

Table 3.4.14 EU Deduction Percentages for Efficacy Values for Fluorescent Lamps

Lamp Parameter Deduction from Luminous Efficacy at 25 °C

Tc* ≥ 5,000 K -10%

95 ≥ Ra** > 90 -20%

Ra > 95 -30%

Second lamp envelope -10%

Lamp Survival Factor ≥ 0.50 after 40,000 burning hours -5%

*Tc is correlated color temperature.

**Ra is general color rendering index, also referred to as color rendering index.

Source: 2010/347/EU

In addition to lamp efficacy, the EU standards contain requirements for lamp 

performance, including lamp lumen maintenance factor (LLMF) and lamp survival factor (LSF). 

The LLMF describes how bright a lamp remains as a percentage of the original brightness after a 

given period of time, while the LSF describes how long a lamp lasts before ceasing to function 

3-30
and requiring replacement, and is expressed as a percentage of the number of lamps still working 

after a specified period of time. 2010/347/EU amended the LLMF and LSF requirements given 

in 2009/245/EC, and added cumulative LLMF deductions for certain lamps. Under current 

standards, for the first stage requirements, non-integrated fluorescent lamps must have a 

minimum CRI of 80. For the second stage requirements, all covered fluorescent lamps without 

an integrated ballast must have a minimum CRI of 80, an LLMF as shown in Table 3.4.15 and 

Table 3.4.16, and an LSF as shown in Table 3.4.17. Stage three performance requirements do not 

affect non-integrated fluorescent lamps.23

Table 3.4.15 EU Lamp Lumen Maintenance Factors for Fluorescent Lamps

Lamp Lumen Maintenance Factor Burning hours

Lamp Types 2,000 4,000 8,000 16,000

Double-Capped Fluorescent lamps operating on non-high 

frequency ballasts 0.95 0.92 0.90 --

T8 Double-Capped Fluorescent lamps on high frequency 

ballast with warmstart 0.96 0.92 0.91 0.90

Other Double-Capped Fluorescent lamps on high frequency 

ballast with warmstart 0.95 0.95 0.90 0.90

Circular Single-Capped Fluorescent lamps operating on 

non-high frequency ballasts, T8 U-shaped double-capped 

fluorescent lamps and spiral-shaped double-capped 

fluorescent lamps of all diameters equal to or larger than 16 

mm (T5)

0.80 0.74 -- --

0.72 at 5,000 burning hours

Circular Single-Capped Fluorescent lamps operating on 

high frequency ballasts

0.85 0.83 0.80 --

0.75 at 12,000 burning hours

Other Single-Capped Fluorescent lamps operating on nonhigh frequency ballasts 0.85 0.78 0.75 --

Other Single-Capped Fluorescent lamps operating on high 

frequency ballast with warmstart 0.90 0.84 0.81 0.78

Source: 2010/347/EU

Table 3.4.16 EU Deduction Percentages for Fluorescent Lamp Lumen Maintenance 

Requirements

Lamp Parameter Deduction from Lamp Lumen Maintenance Requirement

Lamps with 95 ≥ Ra* > 90 At burning hours ≤ 8,000 h: -5%

At burning hours > 8,000 h: -10%

Lamps with Ra* > 95 At burning hours ≤ 4,000 h: -10%

At burning hours > 4,000 h: -15%

Lamps with a color temperature ≥ 5,000 K -10%

Source: 2010/347/EU

* Ra is general color rendering index, also referred to as color rendering index.

3-31
Table 3.4.17 EU Lamp Survival Factors for Fluorescent Lamps

Lamp Survival Factor Burning Hours

Lamp Types 2,000 4,000 8,000 16,000

Double-Capped Fluorescent lamps operating on non-high 

frequency ballasts 0.99 0.97 0.90 --

Double-Capped Fluorescent lamps on high frequency ballast 

with warmstart 0.99 0.97 0.92 0.90

Circular Single-Capped Fluorescent lamps operating on nonhigh frequency ballasts, T8 U-shaped double-capped 

fluorescent lamps and spiral-shaped double-capped 

fluorescent lamps of all diameters equal to or larger than 16 

mm (T5)

0.98 0.77 -- --

0.50 at 5,000 burning hours

Circular Single-Capped Fluorescent lamps operating on high 

frequency ballasts

0.99 0.97 0.85 --

0.50 at 12,000 burning hours

Other Single-Capped Fluorescent lamps operating on nonhigh frequency ballasts 0.98 0.90 0.50 --

Other Single-Capped Fluorescent lamps on high frequency 

ballast with warmstart 0.99 0.98 0.88 --

Source: 2010/347/EU

In addition to non-integrated fluorescent lamps, EU began to regulate non-directional 

household lamps under Commission Regulation (EC) No 244/2009 (March 18, 2009) 

implementing Directive 2005/32/EC. The exemptions to this regulation include:

• lamps having the following x and y chromaticity coordinates:

o x < 0,200 or x > 0,600

o y < – 2,3172 x2 + 2,3653 x – 0,2800 or

o y > – 2,3172 x2 + 2,3653 x – 0,1000;

• directional lamps;

• lamps having a luminous flux below 60 lumens or above 12,000 lumens;

• lamps having:

o 6% or more of total radiation of the range 250-780 nm in the range of 250-400 

nm,

o the peak of the radiation between 315-400 nm (UVA) or 280-315 nm (UVB);

• fluorescent lamps without integrated ballast;

• high-intensity discharge lamps; and

• incandescent lamps with E14/E27/B22/B15 caps, with a voltage equal to or below 60 

volts and without integrated transformer in Stages 1-5.

Similar to other EU efficiency regulations, these standards are implemented in a series of 

stages with increasing strictness. The first stage became effective as of September 2009 and the 

sixth and final stage will become effective September 2016. The baseline efficacy requirements 

are detailed in Table 3.4.18. EU defines a “clear lamp” as “a lamp (excluding compact 

fluorescent lamps) with a luminance above 25,000 cd/m2 for lamps having a luminous flux 

below 2,000 lm and above 100,000 cd/m2 for lamps having more luminous flux, equipped with 

only transparent envelopes in which the light producing filament, LED or discharge tube is 

clearly visible.” Further, EU defines a “non-clear lamp” as a lamp that does not meet the 

specifications of a “clear lamp,” including compact fluorescent lamps. Low lumen output lamps 

and lamps with G9 or R7s caps will have slightly lower standards at some stages as described in 

3-32
Table 3.4.20. EU standards also include correction factors, listed in Table 3.4.21, to reduce the 

burden for unique products.24

Table 3.4.18 EU Non-Directional Household Lamp Efficacy Requirements

Application Date Maximum Rated Power (Pmax) for a Given Rated Luminous Flux (Ф) (W)

Clear Lamps Non-clear Lamps

Stages 1 to 5 0.8*(0.88√Ф+0.049Ф) 0.24√Ф+0.0103Ф

Stage 6 0.6*(0.88√Ф+0.049Ф) 0.24√Ф+0.0103Ф

Source: 2009/244/EC

Table 3.4.19 EU Non-Directional Household Lamp Efficacy Exceptions

Scope of the Exception Maximum Rated Power (W)

Clear Lamps 60 lm ≤ Ф ≤ 950 lm in Stage 1 1.1*(0.88√Ф+0.049Ф)

Clear Lamps 60 lm ≤ Ф ≤ 725 lm in Stage 2 1.1*(0.88√Ф+0.049Ф)

Clear Lamps 60 lm ≤ Ф ≤ 450 lm in Stage 3 1.1*(0.88√Ф+0.049Ф)

Clear Lamps with G9 or R7s cap in Stage 6 0.8*(0.88√Ф+0.049Ф)

Source: 2009/244/EC

Table 3.4.20 EU Non-Directional Household Lamp Efficacy Correction Factors

Scope of the Correction Maximum Rated Power (W)

Filament lamp requiring external power supply Pmax / 1.06

Discharge lamp with cap GX53 Pmax / 0.75

Non-clear lamp with color rendering index ≥ 90 and P ≤ 0.5*(0.88√Ф+0.049Ф) Pmax / 0.85

Discharge lamp with color rendering index ≥ 90 and Tc ≤ 5,000 K Pmax / 0.76

Non-clear lamp with second envelope and P ≤ 0.5*(0.88√Ф+0.049Ф) Pmax / 0.95

LED lamp requiring external power supply Pmax / 1.10

Source: 2009/244/EC

The EU also requires certain functional requirements for household lamps. The 

requirements include: LSF, LLMF, switching cycles before failure, start time, time to reach 60 

percent output, premature failure rate, maximum UV radiation, lamp power factor, and CRI. The 

requirements included under this regulation are listed in Table 3.4.21 and Table 3.4.22. 

Commission Regulation No 859/2009 amended Regulation No 244/2009 to remove ultraviolet 

radiation requirements for non-directional household lamps excluding CFLs and LEDs because it 

was technologically infeasible for tungsten halogen lamps without using a second envelope. That 

requirement would have effectively banned all halogen lamps as of September, 2009.25

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Table 3.4.21 EU Non-Directional Household Lamp Functionality Requirements for CFLs

Functionality Parameter Stage 1 Stage 5

Lamp Survival Factor at 6,000 hr ≥ 0.50 ≥ 0.70

Lumen Maintenance At 2,000 hr: ≥ 85 % ( ≥ 80 % for lamps 

with second lamp envelope)

At 2,000 hr: ≥ 88 % ( ≥ 83 % for 

lamps with second lamp envelope)

At 6,000 hr: ≥ 70 %

Number of Switching Cycles 

Before Failure

≥ half the lamp lifetime expressed in 

hours

≥ 10,000 if lamp starting time > 0.3 s

≥ the lamp lifetime expressed in 

hours

≥ 30,000 if lamp starting time > 0.3 s

Starting Time < 2.0 s < 1.5 s if P < 10 W

< 1.0 s if P ≥ 10 W

Lamp Warm-Up Time to 60 % Φ < 60 s

or < 120 s for lamps containing 

mercury in amalgam form

< 40 s

or < 100 s for lamps containing 

mercury in amalgam form

Premature Failure Rate ≤ 2.0 % at 200 hr ≤ 2.0 % at 400 hr

UVA + UVB Radiation ≤ 2.0 mW/klm ≤ 2.0 mW/klm

UVC Radiation ≤ 0.01 mW/klm ≤ 0.01 mW/klm

Lamp Power Factor ≥ 0.50 if P < 25 W

≥ 0.90 if P ≥ 25 W

≥ 0.55 if P < 25 W

≥ 0.90 if P ≥ 25 W

CRI ≥ 80 ≥ 80

Source: 2009/244/EC

Table 3.4.22 EU Non-Directional Household Lamp Functionality Requirements for Lamps 

Excluding CFLs and LEDs

Functionality Parameter Stage 1 Stage 5

Rated Lamp Lifetime ≥ 1,000 hr ≥ 2,000 hr

Lumen Maintenance ≥ 85 % at 75 % rated average 

lifetime

≥ 85 % at 75 % rated average 

lifetime

Number of Switching Cycles 

Before Failure

≥ four times the rated lamp 

life expressed in hours

≥ four times the rated lamp 

life expressed in hours

Starting Time < 0.2 s < 0.2 s

Lamp Warm-Up Time to 60 % 

Φ

≤ 1.0 s ≤ 1.0 s

Premature Failure Rate ≤ 5.0 % at 100 hr ≤ 5.0 % at 200 hr

Lamp Power Factor ≥ 0.95 ≥ 0.95

Source: 2009/895/EC

Commission Regulation No 1194/2012 (December 12, 2012) implementing Directive 

2009/125/EC prescribed regulations for directional lamps, LED lamps, and related equipment. 

The relevant portion covering general service LED lamps creates standards only for lamp 

functionality and not performance. These functionality requirements are detailed in Table 

3.4.23.

26

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Table 3.4.23 EU Functionality Requirements for Non-Directional and Directional LED 

Lamps

Functionality Parameter Requirement from Stage 1, Except Where Indicated 

Otherwise

Lamp Survival Factor at 6,000 hr From 1 March 2014: ≥ 0.90

Lumen Maintenance at 6,000 hr From 1 March 2014: ≥ 0.80

Number of Switching Cycles 

Before Failure

≥ 15,000 if rated lamp life ≥ 30,000 otherwise:

≥ half the rated lamp life expressed in hours

Starting Time < 0.5 s

Lamp Warm-Up Time to 95 % Φ < 2 s

Premature Failure Rate ≤ 5.0 % at 1,000 hr

CRI ≥ 80

≥ 65 if the lamp is intended for outdoor or industrial 

applications

Color Consistency Variation of chromaticity coordinates within a six-step 

MacAdam ellipse or less

Lamp Power Factor for Lamps 

with Integrated Control Gear

P ≤ 2 W: no requirement

2 W < P < 5 W: > 0.4

5 W< P < 25 W: > 0.5

P > 25 W: > 0.9

Source: 2012/1194/EU

3.4.4 Non-Regulatory Initiatives

DOE reviewed several national, regional, and local voluntary programs that promote the 

use of energy efficient lighting in the United States. The following section summarizes these 

programs for the lamps covered by this rulemaking. While it is not an exhaustive list, the 

discussion provides detail on some notable initiatives that characterize voluntary energy 

efficiency efforts in the lighting market.

3.4.4.1 Federal Energy Management Program

The Federal Energy Management Program (FEMP) helps Federal buyers identify and 

purchase energy efficient products including certain CFLs and LED lamps. Section 161 of EPAct 

1992 encourages energy efficient Federal procurement. Executive Order 13423 and Federal 

Acquisition Regulations section 23.203 requires agencies to purchase ENERGY STAR or 

FEMP-designated products.27 For CFLs, FEMP typically provides recommendations of power 

factor and CRI. FEMP also advises consumers to buy CFLs with rated lumen output equal to or 

greater than the bulbs they replace in order to maintain an appropriate light levels over the 

lifetime of the CFL.28 With regards to LED lamps, FEMP redirects consumers to the ENERGY 

STAR webpage of “LED Light Bulbs Key Product Criteria”. This page lists many performance 

characteristics (e.g., CRI, Dimming, CCT) of LEDs and the current associated ENERGY STAR 

criteria for each characteristic.29 Further, FEMP offers buyer support tools, such as efficiency 

guidelines, cost-effectiveness examples, and a cost calculator. FEMP also offers training, on-site 

audits, demonstrations, and design assistance.30

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3.4.4.2 Consortium for Energy Efficiency

The Consortium for Energy Efficiency (CEE) aims to maximize the impact of energy 

efficiency programs by influencing manufacturers, stakeholders, and government agencies. The 

CEE leads initiatives in the residential, commercial, and industrial sectors. Their Residential 

Lighting Initiative, revised in 2006, primarily promotes high efficiency fixtures, CFLs, and LED

lamps. With regards to CFLs, the initiative aims to ensure positive customer experience with 

ENERGY STAR CFLs and to increase consumer understanding of CFLs and their benefits over 

traditional incandescent lamps.

31 In 2011, CEE published a Summary of Residential Lighting 

Programs in the United States and Canada featuring dozens of rebate programs focused on 

CFLs, fluorescent fixtures, LED lamps, LED fixtures, and other products as well. The programs 

listed were primarily sponsored by utilities, U.S. states, and energy efficiency programs.32

3.4.4.3 Efficiency Vermont – Business Rebate Program & SMARTLIGHT

In Vermont, agricultural operations are eligible for prescriptive and customized 

incentives on equipment proven to help make farms more efficient. Efficiency Vermont gives 

prescriptive rebates for a variety of equipment and for lighting. Efficiency Vermont will rebate 

$8 to $50 for interior LED lighting products and $40 to $120 for exterior LED lighting products.

Efficiency Vermont also offers $30 to $75 rebates for lighting control systems. Businesses and 

regular consumers can also purchase replacement lamps with rebates from local lighting 

distributors through the SMARTLIGHT program. The program applies to select pin and screw 

base LED lamps, linear fluorescents, CFLs, and metal halide lamps. The rebates range from $4 

to $30 per LED lamp and $2 per CFL. This version of the rebate expires at the end of 2014.33

3.4.4.4 Southern California Edison – Multiple Rebate Programs

Southern California Edison (SCE) currently offers a variety of rebates to customers who 

are residences, multi-family building owners, or businesses. The rebates and incentives promote 

energy efficiency and integration of renewable energy systems. With regards to GSLs in the 

residential program, SCE offers both a Lamp Exchange and Light Bulb Discount program. The 

Lamp Exchange allows individuals meeting the program requirements to bring up to 10 

incandescent or halogen luminaires to an SCE event where they can exchange those luminaires 

for new luminaires with ENERGY STAR labeled CFLs. Through the Light Bulb Discount 

program, SCE is offering up to $15 off of each LED lamp and CFL bought through participating 

online retailers.34 SCE also offers rebates for business buying GSLs through its Energy 

Efficiency Express Solutions program. The program offers $5 to $15 per A-shape LED lamp, 

$30 per LED fixture, $20 to $60 per low wattage interior CFL replacement fixture, and $10 per 

low wattage exterior CFL replacement fixture. The program also offers rebates for different 

lighting control systems. This latest iteration of SCE’s program is in effect for 2013-2014.35

3.4.4.5 Commonwealth Edison – Business Instant Lighting Discounts 

Program

Commonwealth Edison (ComEd) sponsors a Business Instant Lighting Discounts 

program that offers rebates for several GSLs. This program is part of ComEd’s larger Smart 

Ideas for Your Business® program which offers incentives to businesses for everything from 

farm equipment to data center efficiency. The relevant portion of their lighting program offers $8 

per LED lamp, $13 per LED trim kit, $1 per standard screw-in CFL, $3 per specialty CFL, $3 

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per high wattage CFL, and $3 per cold cathode CFL. The lamps must meet ComEd’s program 

requirements of efficacy and performance to qualify. A-shape LED lamps must exceed 55 lm/W 

and LED trim kits must exceed 42 lm/W. All screw-in CFLs must be ENERGY STAR certified. 

This program ends May 31, 2015.36

3.4.4.6 Consolidated Edison – Multi-Family Energy Efficiency Program

In New York, Consolidated Edison (ConEd) runs a Multi-Family Energy Efficiency 

Program with rebates for energy efficiency improvements. Owners and managers of multi-family 

buildings (of 5 to 75 units in size) are eligible for the program. Offers include not only rebates, 

but also free surveys to evaluate potential energy-saving upgrades as well as free installation 

inside individual units. The rebate offered for A-shape LED lamps is $15 per lamp. The rebates 

for common area CFLs include $2 per lamp for CFLs under 32 watts, $3 per lamp for CFLs of 

32 watts or more, and $35 per pin-based CFL fixture. The program also offers up to six free 

CFLs, including installation, per unit. There are no expiration dates for these rebates at this 

time.37

3.4.4.7 Cape Light Compact – Commercial, Industrial and Municipal Buildings 

Energy Efficiency Rebate Program

Through a multi-member partnership, Cape Light Compact (CLC) and MassSave offer a 

variety of financial incentives for commercial, industrial, and municipal facilities in 

Massachusetts. Custom rebate options are available for both new construction and retrofit 

measures in commercial/industrial buildings, as well as for small businesses and municipal 

projects. There are prescriptive rebates through the partnership on sensors and GSL lighting 

equipment and controls for eligible new and existing buildings. Rebates vary depending on 

whether projects are retrofit or new construction. Through this program, CLC offers $25 to $200 

per LED fixture in retrofits, and $15 to $150 per LED fixture in new construction. There are no 

expiration dates for these rebates at this time.38

3.4.4.8 Central Electric Cooperative – Non-Residential Lighting Rebate

In Oregon, the Central Electric Cooperative offers a commercial lighting system 

improvement incentive for any customer not on a residential utility rate. For existing building 

projects, the Central Electric Cooperative will give rebates of $40 to $80 per hardwired CFL 

installed new or as a retrofit, $3 to $12 per screw-in CFL retrofit, and $30 to $50 per LED fixture 

installed new or as a retrofit. The program also offers rebates for occupancy sensors and other 

lighting controls. There are no expiration dates for these rebates at this time.39

3.4.4.9 Empire District Electric Company – Commercial and Industrial Energy 

Efficiency Rebate Program

The Empire District Electric Company (Empire) offers a Commercial/Industrial 

Prescriptive Rebate Program to its non-residential customers in Arkansas who purchase certain 

high efficiency equipment for eligible facilities. A variety of prescriptive rebates are available to 

customers served under any non-residential rate schedule in the Empire service territory. The 

rebates, which can be applied to both new construction and retrofit projects, are offered for 

certain equipment meeting the program’s energy efficiency standards. Empire offers a rebate of 

$8 to $24 per hardwired or modular CFL fixture (depending on the wattage) and $25 per multi3-37
CFL industrial fixture. The hardwired or modular fixtures must replace incandescent, halogen, 

high pressure sodium, or mercury vapor systems and cannot include screw-base CFLs. To 

qualify, the industrial multi-CFL fixtures must replace T12 or HID systems. There are no 

expiration dates for these rebates at this time.40

3.4.5 GSL Market Trends

Shipment data and market trend information are used to conduct the shipment analysis 

and develop base-case forecasts in the shipment analysis (see chapter 9 of this TSD). DOE also 

uses shipment data to identify and analyze representative product classes and lamps to ensure the 

analysis is representative of the market (see chapter 5 of this TSD). Shipment data also feeds into 

the national impact analysis (see chapter 10 of this TSD). DOE gathered insights into GSL 

market trends by reviewing updates to NEMA’s lamp indices, which detail progress in the GSL 

market from 2010-2014 as well as the 2010 U.S. Lighting Market Characterization (LMC) 

report. 

NEMA’s lamp indices are composite measures of NEMA member companies’ U.S. 

shipments of a variety of lamp types, including compact fluorescent, halogen, incandescent, and 

LED lamps. Product shipments data are drawn from NEMA statistical surveys conducted 

regularly by NEMA and are adjusted for recurring seasonal fluctuations.

41

An evaluation of NEMA’s lamp indices indicates that incandescent lamps rose in market 

share through 2011, ultimately reaching approximately 82.8 percent of the incandescent-CFL 

market at the end of 2011. This ratio suggests that CFLs accounted for approximately one out 

every six incandescent and CFLs sold at that time. The 17.2 percent market penetration of CFLs 

at year-end 2011 was down from 22.1 percent at year-end 2010. NEMA asserted that the 

decrease in demand of CFLs was due to the fact that EISA 2007 standards were not yet in effect, 

and consumers were likely stockpiling incandescent lamps in preparation for the new 

standards.

42,43

Starting in 2012, NEMA added halogen A-shape lamps to its incandescent-CFL indices. 

These lamps began to garner a small market share in 2012 as they continued to develop and be 

introduced to consumers, eventually climbing to 3.8 percent by the end of 2012. Although 

incandescent lamps maintained control of the GSL market in 2012, they declined to their lowest 

market percentage, 74 percent, since 2010. CFLs increased to 22.8 percent in 2012.44

The development of LED lamps began to show movement in the market penetration of 

GSLs in 2013, leading to NEMA’s addition of LED A-shape lamps to its lamp indices. By yearend 2013, LED A-shape lamps reached a market penetration of 1.1 percent. Incandescent lamps 

continued to decline in market share in 2013,

e dropping to 51.5 percent, and CFLs showed a 

significant increase in market share, reaching 33.8 percent. Halogen A-shape lamps also 

increased in market share, rising to 13.6 percent in 2013.

45

e Starting in 2013 NEMA included only incandescent A-shape lamps in the lamp indices.

3-38

 
Through two quarters thus far in 2014, these trends continued as incandescent A-shape 

lamps dropped to a 34.7 percent market share; halogen A-shape lamps rose to 26 percent; and 

LED A-shape lamps increased to 2.9 percent. Most notably, CFLs surpassed the incandescent Ashape lamps to assume the lead position in the market, rising to 36.4 percent.46

DOE supplemented its understanding of the NEMA lamp indices with market 

information from the 2010 LMC and also evaluated data from the 2001 LMC. The LMCs 

provide estimates of the installed stock, energy use, and lumen production of all lamps operating 

in the United States. The reports deliver results at a national level and a sector-specific level; the 

four sectors represented include the residential, commercial, and industrial building sectors as 

well as an outdoor sector. These estimates have been based primarily on public sources of 

information, building lighting audits, industry surveys, national lamp shipment data, and 

interviews with lighting professionals and subject matter experts.

The 2010 LMC estimated that A-shape GSILs represented 25.3 percent and decorative 

GSILs represented 11.9 percent of the overall lamp market in 2010.

f The 2001 LMC combined 

these two categories and estimated general service incandescent lamps to represent 56 percent of 

the lamp market in 2001. The 2001 and 2010 LMCs estimated general service screw-in CFLsg to 

represent 2 and 14.2 percent of the lamp markets in 2001 and 2010, respectively. Similarly, 

general service pin-based CFLsh represented 1 and 1.7 percent of the lamp markets in 2001 and 

2010. Lastly, general service halogen lampsi garnered a 0.3 percent market share in the 2010 

LMC, while LED lampsj reached a 0.8 percent market share in 2010. Both general service 

halogen lamps and LED lamps had 0 percent reported market share in 2001. For historical 

shipment data and trends please refer to Chapter 9 of this TSD.

3.5 TECHNOLOGY ASSESSMENT

The purpose of the technology assessment is to develop a preliminary list of technologies 

that could be used to improve the efficacy of GSLs. GSLs are most commonly used for general 

lighting applications. Three lamp technologies dominate the GSL market: incandescent, compact 

fluorescent, and LED. The following assessment provides a description of the basic construction 

and operation of compact fluorescent lamps and LED lamps, followed by options to improve 

efficacy within these lamp technologies.

f General service A-type incandescent lamps are defined in the 2010 LMC as standard incandescent lamps greater 

than 15 W and with an a-type bulb and of all base types. General service decorative incandescent lamps are defined 

as standard incandescent lamps greater than 15 W with a globe, bullet, candle, tubular, or other decorative-shaped 

bulb and of all base types. 

g General service screw-in CFLs are defined in the 2010 LMC as CFLs with an a-type, globe, spiral or other 

decorative-shaped bulb meant as a direct replacement for general service incandescent lamps having a screw-in 

base, including all wattages. 

h General service pin-based CFLs are defined in the 2010 LMC as CFLs with an a-type, globe, spiral, or other 

decorative-shaped bulb having a non-screw-in base, such as a pin base, including all wattages. i General service halogen lamps are defined in the 2010 LMC as halogen lamps with a tungsten halogen capsule 

with an a-type, globe, candle or other decorative-shaped bulb meant as a direct replacement for general service 

incandescent lamps, including all base types and wattages. 

j LED lamps are defined in the 2010 LMC as LED lamps and luminaires greater than or equal to 2 watts of all 

shapes, sizes, and bases not including LED screens or decorative walls. 

3-39

 
3.5.1 Compact Fluorescent Lamps

CFLs are fluorescent lamps of bent-tube construction. The bent-tube construction of 

CFLs (e.g., spiral or U-shaped) allows them to fit into smaller spaces. CFLs consist of a glass 

envelope or tube with a phosphor coating on its interior surface, oxide coated electrodes on each 

end of the tube, small amounts of mercury or mercury amalgam, and an inert gas (e.g., argon). 

Voltage is applied to the two electrodes at the ends of the tube, emitting large quantities of 

electrons that collide with gaseous mercury atoms and excite the electrons within those atoms. 

As the mercury electrons return to their stable state, they release ultraviolet (UV) radiation. 

Because UV radiation is not visible to the human eye, phosphors are coated along the inner walls 

of the tube to absorb the UV radiation and emit visible light. CFLs are also operated with a 

current-limiting device, either a ballast integrated into the CFL (i.e., self-ballasted) or a ballast 

separate from the lamp (i.e., externally ballasted).47

Like GSFLs, the two electrodes are hermetically sealed to both ends of the bulb, typically 

constructed from coiled tungsten wires coated with a mixture of alkaline oxides. Once a ballast 

applies the initial voltage to the electrodes, the tungsten coil and coatings emit large quantities of 

electrons after the coating has reached the appropriate temperature (800 °C). Although the 

electrodes are actually in close proximity to each other at the base of the lamp (both tubes 

connect to the single base of the lamp), the electrons released by the coiled wires travel the full 

length of the tubes. These electrons collide with gaseous mercury atoms and the inert gas filling 

the rest of the tube. The inert gas is present to moderate the collisions of mercury ions and 

minimize evaporation of the electrode coating. The electrons from the electrodes excite those in 

the mercury atoms to release UV radiation that is absorbed by the phosphors and reemitted as 

visible light.48

A key to the miniaturization of GSFLs into CFLs in the 1980s was the development of 

new phosphor compositions that are more stable in intense UV radiation. A combination of rare 

earth phosphors is best suited for the miniaturization and strong radiation, while also providing 

better color rendering and increased efficacy (lumens per watt).49 CFLs use the same phosphors 

as GSFLs, but in different compositions. The five rare earth elements in the phosphors used in 

these lamps are lanthanum, cerium, europium, terbium, and yttrium. CFLs primarily use a 

Calcium Tungstate (CAT) phosphor that is higher in cerium, and GSFLs use a Lanthanum 

Phosphate (LAP) phosphor that is higher in lanthanum.50

Fluorescent lamp performance is influenced by the cold spot on a lamp and the ambient 

temperature of the operating environment. The cold spot is the area where excess mercury 

condenses, so the temperature of the cold spot defines the level of mercury vapor pressure and 

thus the luminous flux.51 CFLs fail when the emissive coating on the electrodes is completely 

dissipated by evaporation or sputtering. The inert gas is used to prevent this from occurring by 

protecting the electrodes from the bombardment of mercury ions, but loss of the emissive coating 

during starting is inevitable, albeit in small amounts.52

CFLs must be operated with magnetic or electronic ballasts, which supply the starting 

and operating voltages required by the lamp and limit the current while the lamp is in use. CFLs 

can be self-ballasted or externally ballasted (sometimes referred to as pin-based). The majority of 

CFLs in the marketplace are self-ballasted, and virtually all of these have electronic ballasts. 

3-40
These self-ballasted CFLs integrate a screw base with a ballast for direct retrofitting of 

incandescent luminaires. Popular base types for self-ballasted CFLs include E12 (candelabra), 

E17 (intermediate), E26 (medium), E39 (mogul), or GU24 (twist and lock), with E26 being the 

most common because it is designed to fit standard luminaires and overhead light fixtures.48

External ballasts can be electronic or magnetic, though the market is shifting more toward 

electronic ballasts due to improved system efficacy and starting time; minimized flickering and

operating sounds; and lighter weight. Externally ballasted CFLs can be found with 2-pin or 4-pin 

socket configurations, with base types including (but not limited to) G23, 2G7, G24d, G24q, 

2G11, and GR10q.53 Base types that are 4-pin are generally paired with electronic ballasts that 

may be dimmable, while 2-pin bases are typically magnetic and seldom paired with electronic 

ballasts.48

CFL ballast starting modes, for both self-ballasted and externally ballasted CFLs, include 

preheat, rapid start (RS), instant start (IS), and programmed start (PS). The preheat mode 

requires an external starter or switch to strike the arc. RS ballasts produce a nearly instant start 

with almost full lumen output by having a short period of electrode heating, followed by the 

application of a higher voltage to initiate the arc between the two electrodes. IS ballasts bypass 

the initial electrode heating and apply high voltage to create an instant start of the arc between 

the two unheated electrodes. IS ballasts may sustain damage to the electrodes and reduced lamp 

life when they are started frequently, while PS ballasts are designed to prevent this damage by 

controlling the frequency of starting.48,52

CFL shapes differ depending on whether the lamp is self-ballasted or externally ballasted. 

Self-ballasted lamps can either be bare tubes (most often spiral-shaped) or tubes with an outer 

cover. These covered lamps primarily include A-shapes, globes, reflectors, posts, and candles.54

Externally ballasted CFLs typically consist of an arrangement of bare, bent tubes.53

3.5.2 LED Lamps

Generally, LED lamps utilize multiple LEDs inside of a housing that disperses or 

redirects the light from the point source LEDs to provide general illumination. LEDs work by 

using semiconductor material intentionally doped with an impurity to make a positive (p-type) 

and negative (n-type) region. The doping elements contain a similar atomic structure with either 

slightly fewer valence electrons to create a p-type region or slightly more valence electrons

creating a n-type region. This causes the p-type regions to have hole concentrations while the ntype regions have excess electrons. When a voltage is applied, excess electrons from the n-type 

region combine with holes from the p-type regions and the resulting recombination radiation 

produces photons. The semiconducting elements most commonly used in LEDs for lighting are 

group III (boron) and V (nitrogen) combinations such as Gallium Nitride (GaN). The different 

group III and group V pairings have different size bandgaps, and these different energy levels 

correspond to distinct parts of the visible spectrum. For instance, GaN LEDs usually emit violet 

light, however their wavelength can be adjusted by mixing in other elements with different 

bandgaps. An added benefit of group III-V compositions is that they often have direct rather than 

indirect bandgaps, leading to more efficient LEDs.55 An indirect bandgap is less efficient as it 

requires the electron to pass through an intermediate state and transfer momentum to the crystal 

3-41
lattice before it can recombine with a hole to produce a photon. Figure 3.5.1 displays this 

phenomenon known as electroluminescence.

Figure 3.5.1 Photon Production through Electroluminescence

Source: Digi-Key56

The photon production happens within the LED chip where the p and n-type regions, 

known as epitaxial layers, are built on top of a substrate, most commonly made out of sapphire.

57

Often a reflective layer such as silver is used below the active region to help prevent absorption 

of emitted light into the substrate as seen in Figure 3.5.2. This is just one of many different 

approaches that are utilized to minimize absorption. The epitaxial layers, substrate, and a 

covering lens make up the LED module. LED modules or arraysk can be integrated into a lamp 

to provide illumination. If required, a phosphor can be mounted directly onto the LED die, as 

seen in Figure 3.5.3, or placed remotely to achieve a white light. The LEDs are mounted to the 

lamp housing which acts as a heat sink for the LEDs. The housing also accommodates the driver 

which transforms the incoming power supply from AC to DC and controls the flow of power to 

the LEDs. LED circuitry employs capacitors (typically electrolytic capacitors) to store electric 

charges on the input AC stage to enable filtering of noise or on the output channel DC stage.

Similar to CFLs, LED lamps are offered in a variety of lamp shapes and base types to serve as 

replacements for GSILs. Figure 3.5.4 shows the breakdown of the components for a typical Ashape LED GSL.

k The IESNA Lighting Handbook defines “LED array or module” as an assembly of LED packages (components), 

or dies on a printed circuit board or substrate. This assembly could also have optical elements and additional 

thermal, mechanical, and electrical interfaces that are intended to connect to the load side of a LED driver. However, 

the power source and ANSI standard base are not incorporated into the device and it cannot be connected directly to 

the branch circuit.

3-42

 
Figure 3.5.2 LED Chip

Source: LED Magazine58

Figure 3.5.3 LED Module

Source: WILA59

3-43
Figure 3.5.4 Exploded View of a LED Lamp

Source: EE Times60

White Light. LED lamps typically consist of an InGaN/GaN LED that emits blue 

light which then meets a yttrium aluminum garnet (YAG) phosphor coating before leaving the 

luminaire. That phosphor converts a portion of the blue light to longer wavelength (green 

through red) light to produce a combined white light as shown in Figure 3.5.5. Though phosphor 

coating a blue LED is the most common mode of producing white light in LED lamps, there are 

many other LED systems that can achieve white light. 

Figure 3.5.5 Light Conversion in a Phosphor-Converted LED Lamp

Source: Japanese Journal of Applied Physics61

Combining blue, green, and red LEDs can also produce a balanced white light and is 

theoretically the most efficient way to produce light since no light is lost during phosphor 

conversion; however, since green and amber LEDs lag behind blue LEDs in their respective 

3-44
efficiency, this method is uncommon in today’s LED lamp market.62 Hybrid LED architectures 

contain a mix of LED colors and use phosphor conversion on some of the LEDs. One example of 

such a product is the Philips L-Prize lamp. The lamp down shifts some blue light to the green 

spectrum to avoid the least efficient green LEDs and adds in red LEDs to produce white light at a 

warmer color temperature and a higher CRI. Figure 3.5.6 describes the three primary methods of 

creating white light with LEDs. 

Figure 3.5.6 Creating White Light in LEDs

Source: U.S. Department of Energy63

Lifetime. Unlike GSILs and CFLs, LED lamps rarely fail entirely. Rather their light 

output drops throughout their lifetime. For this reason ENERGY STAR, the lighting industry,

and standards organizations have approached lifetime ratings based on the amount of time 

expected before a 70 percent deterioration in total luminous flux (L70) rather than the expected 

lifetime of the components, which tend to be much longer.64 At this stage, two primary causes of 

premature failure of LED GSLs are overheated capacitors and faulty solder joints. Some 

electrolytic capacitors used in the lamps are not rated to withstand the high level of heat they 

endure which will shorten their lifetime. Low quality solder joints, particularly those that are 

hand soldered, as well as mechanical fatigue from thermal stresses, can also lead to broken 

contacts and lamp failure.65

3.5.3 GSL Technology Options

This section outlines the technology options DOE is considering for improving efficacy 

of GSLs. DOE reviewed manufacturer catalogs, recent trade publications, technical journals, and 

patent filings to determine technology options. Table 3.5.1 presents the technology options DOE 

has preliminarily identified to improve the efficacy of general service lamps. DOE notes in Table 

3.5.1 the applicable lamp type for the technology options listed.

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Table 3.5.1 GSL Technology Options

Lamp Type Name of Technology Option Description

CFL

Highly Emissive Electrode 

Coatings

Improved electrode coatings allow electrons to be more 

easily removed from electrodes, reducing lamp power and 

increasing overall efficacy. 

Higher Efficiency Lamp Fill 

Gas Composition 

Fill gas compositions improve cathode thermionic emission 

or increase mobility of ions and electrons in the lamp 

plasma.

Higher Efficiency Phosphors Techniques to increase the conversion of ultraviolet (UV) 

light into visible light.

Glass Coatings Coatings on inside of bulb enable the phosphors to absorb 

more UV energy, so that they emit more visible light.

Multi-Photon Phosphors Emitting more than one visible photon for each incident 

UV photon.

Cold Spot Optimization Improve cold spot design to maintain optimal temperature 

and improve light output.

Improved Ballast 

Components

Use of higher-grade components to improve efficiency of 

integrated ballasts.

Improved Ballast Circuit 

Design

Better circuit design to improve efficiency of integrated 

ballasts.

Change in Technology Replace CFL with LED technology.

LED

Efficient Down Converters

New high-efficiency wavelength conversion materials, 

including optimized phosphor conversion, quantum-dots 

and nano-phosphors, have the potential for creating warmwhite LEDs with improved spectral efficiency, high color 

quality, and improved thermal stability. 

Improved Package 

Architectures

Novel package architectures that can improve package 

efficacy through use of color mixing with RGB+ or hybrid 

systems and higher current drivers; resulting in 

improvement of overall lamp and luminaire efficacy.

Improved Emitter Materials

The development of efficient red, green, or amber LED 

emitters, will allow for optimization of spectral efficiency 

with high color quality over a range of CCT and which also 

exhibit color and efficiency stability with respect to 

operating temperature.

Alternative Substrate 

Materials

Alternative substrates such as gallium nitride (GaN), silicon

(Si), GaN-on-Si, and silicon carbide to enable high-quality 

epitaxy for improved device quality and efficacy. 

Improved Thermal Interface 

Materials (TIM)

Develop TIMs that enable high efficiency thermal transfer 

for long-term reliability and performance optimization of 

the LED device and overall lamp product.

Optimized Heat Sink Design

Improve thermal conductivity and heat dissipation from the 

LED chip thus reducing efficacy loss from rises in junction 

temperature. 

Active Thermal 

Management Systems

Devices such as internal fans, vibrating membranes, and 

circulated liquid cooling systems to improve thermal 

dissipation from the LED chip.

Device Level Optics

Enhancements to the primary optic of the LED package that 

would simplify or remove entirely the secondary optic, and 

thereby reduce losses due to absorption at interfaces.

Increased Light Utilization

Reduce optical losses from the lamp housing, diffusion, 

beam shaping and color-mixing to increase the efficacy of 

the LED lamp using mechanisms such as highly reflective 

coatings inside the lamp. 

3-46
Lamp Type Name of Technology Option Description

Improved Driver Design Increase driver efficiency through novel and intelligent 

circuit design. 

AC LEDs Reduce or eliminate the requirements of a driver and 

therefore the effect of driver efficiency on lamp efficacy.

Reduced Current Density

Increase the number of LEDs in a lamp to reduce current 

density while maintaining lumen output. This reduces the 

efficiency losses associated with higher current density.

3.5.3.1 Highly Emissive Electrode Coatings

Fluorescent lamp electrodes are generally tungsten filaments coated with a mixture of 

alkaline earth oxides. The purpose of the electrodes is to emit a sufficient number of electrons to 

ionize the gas and maintain the lamp discharge. When electrons are more easily emitted from the 

electrodes, a lower voltage is needed to maintain the arc. Therefore, any improvement in 

electrode coating that would allow electrons to be more easily removed from the electrodes 

would reduce the lamp power and increase the overall efficacy of the lamp. Using highly 

emissive electrode coatings essentially addresses the efficiency of the conversion of electrical 

input power to visible radiation. In addition to raising efficacy, highly emissive electrode 

coatings can result in an increased lamp lifetime. Without sufficient electron emission from the 

electrode, a large voltage gradient is created in front of the electrode during the cathode cycle, 

which is emitting negatively charged ions and receiving positively charged ions. This high 

electric field accelerates these ions into the electrode at a high velocity, causing electrode 

damage. The damage shortens the lifetime of the lamp. Conventional emissive coatings include 

barium oxide (BaO), calcium oxide (CaO), and strontium oxide (SrO). Additional materials have 

been mixed with existing conventional oxides to coat fluorescent lamp electrodes. These 

materials include zirconium oxide (ZrO), which extends lamp lifetime, and silicon carbide (SiC), 

which more effectively removes electrons from the electrode.

3.5.3.2 Higher Efficiency Lamp Fill Gas Composition

Fluorescent lamps contain mercury vapor, which when ionized produces UV radiation. 

They also contain a rare gas or combination of gases to facilitate ignition. These “lamp fill 

gases” affect the mobility of the mercury ions and electrons in the lamp plasma based on their 

molecular weight. Lower molecular weight gases generally result in higher lamp efficacy. As 

lighter gases are used, the mobility of mercury ions and electrons increases, allowing them to 

reach greater velocities. This causes a rise in electron temperature of the plasma, facilitating 

recombination and ultimately raising the UV radiation to saturation level. However, if the 

mobility of the ions and electrons exceeds a certain optimal point, they are then able to reach the 

lamp glass surface, which prevents emission and effectively reduces UV output.

Standard lamps generally use argon gas or a mixture of argon and neon. These gases are 

usually at low pressures, typically ranging from three to four torr. As the pressure exceeds a 

certain point, elastic scattering increases, decreasing the mobility of the ions and electrons. This 

decreased mobility lowers the total UV radiation of the lamp, thereby decreasing lamp efficacy. 

Because fluorescent lamp ballasts are often current-controlled devices, the use of higher 

efficiency lamp fill gases results in lower power. 

3-47
Lamp fill gas composition can also affect lamp lifetime due to collisions between the 

lamp fill gas and the evaporated electrode coatings. As discussed earlier, one common emissive 

coating used on electrodes is barium oxide (BaO). During lamp operation the BaO coating 

slowly evaporates from the surface of the electrode. However, some of these escaped barium 

atoms then collide with the lamp fill gas, propelling them back toward the electrode and 

redepositing them. The relative thermionic emission for the cathode, a measure of the number of 

electrons emitted, is much greater for a larger molecular weight gas than for a lighter gas. This is 

because a larger mass atom can more effectively collide with and change the trajectory of the 

barium atoms, providing a lower diffusion rate of the barium atoms away from the electrode. 

This redeposition of the electrode coating results in a longer lamp lifetime as less of the electron 

emissive material is lost.

3.5.3.3 Higher Efficiency Phosphors

As described earlier, the main purpose of phosphor in a fluorescent lamp is to absorb the 

UV radiation and reemit it as visible radiation. Therefore, one method of improving lamp 

efficacy is to increase phosphor efficiency. As stated, a key to the miniaturization of GSFLs into 

CFLs in the 1980s was the development of new phosphor compositions that are more stable in 

intense UV radiation. Specifically, these narrow-band rare earth, or triband, phosphors 

(containing the rare earth elements terbium, europium, and yttrium), emit light in the short, 

middle, and long wavelength ranges of the visible spectrum. Compact fluorescent lamps on the 

market today exclusively use triband phosphors.

Lamp efficacy can be improved by using triband phosphors, which can increase UV 

absorption and emission of radiation in the visible spectrum relative to other phosphors. 

Typically, there are efficiency losses in the phosphor’s conversion of UV radiation to visible 

radiation, or light. Some of these losses are related to the extent to which the phosphors emit 

light in the visible spectrum (i.e., radiation with wavelengths between 400 and 750 nm) and the 

extent that they radiate at visually sensitive wavelengths. Triband phosphors allow a lamp to 

emit light at the wavelengths to which human eyes are most sensitive which increases lamp 

efficacy. To understand this effect it is important to note the relationship between the efficiency 

losses in the phosphor’s conversion of light, wavelengths sensitive to the human eye, and 

measurement of lamp efficacy.

Lumens, used to calculate lamp efficacy, measure the radiometric energy emission from a 

light source weighted by the response function of the human eye, V(λ) (also referred to as the 

photopic luminous efficiency function). Figure 3.5.7 depicts V(λ). The human eye does not have 

the same level of sensitivity to all wavelengths of light. For example, the eye is highly sensitive 

to light emission around 550 nm, but less sensitive to emission at 450 nm or 650 nm.

3-48
Figure 3.5.7 Human Eye Photopic Spectral Luminous Efficiency Function, V(λ)

Therefore, the specific wavelengths that a lamp emits will affect the lamp’s calculated 

efficacy. In other words, because the human eye is less responsive to certain wavelengths of 

light, such as those in the blue spectrum, those lamps that contain these less sensitive 

wavelengths will have lower efficacies. As such, every watt of radiometric energy emitted from a 

fluorescent lamp is not equal under a lm/W metric. Therefore, by allowing a lamp to emit greater 

light at wavelengths to which the human eye is more sensitive, triband phosphors are able to 

increase lamp efficacy.

Lamp efficacy can also be improved by increasing the thickness of the phosphor layer, 

also called phosphor weight. Generally, as phosphor thickness increases, lamp light output 

increases until it slightly decreases or stays flat. Figure 3.5.8 illustrates this point, where coating 

weight is indicative of phosphor thickness.

-

0.2

0.4

0.6

0.8

1.0

1.2

400 450 500 550 600 650 700 750

Wavelength (nanometers)

Relative Sensitivity

3-49
Figure 3.5.8 Light Output versus Phosphor Thickness

Source: Journal of the Electrochemical Society 66

Different types of phosphor emit light with different spectral power distributions (SPDs), 

and the choice of phosphor or blend of phosphors greatly affects the color of the lamp. The SPD 

of light emitted from a lamp characterizes the amount of power radiated at each wavelength in 

the visible spectrum. SPD determines the CCT and the CRI, both important properties for 

measuring the color quality of light. CRI, a single value with no units, is a measure of the color 

rendering properties of a light source, or the ability of a light source to show the “true” color of 

an object as compared to a reference source.l 67 The maximum CRI is 100. Lower CRI values 

indicate greater variation in an object’s apparent color compared to when lit by the reference 

source. DOE has observed that higher efficiency phosphors on the market typically offer higher 

CRIs. While CRI is not necessarily positively correlated to efficacy, the majority of phosphors 

offered in the market currently reflect this relationship. DOE has found that the vast majority of 

CFLs available on the market have a CRI of 80 or greater. 

CCT, a single value with units of degrees Kelvin (K), is a measure of the color 

appearance of light emitted from a lamp.m n 68 Lower CCT values correspond to warmer light, 

with more red content in the spectrum, and higher CCTs correspond to cooler light, with more 

blue content. As the spectral emission from the lamp is modified to change the CCT, the light 

emitted often contains more red or blue light. Given the shift in the wavelengths of light emitted 

from lamps with different CCTs, and the fact that lumens account for the amount of light emitted 

at particular wavelengths, the efficacy of lamps with different CCTs can vary.

l According to the IESNA Lighting Handbook, the CRI of a light source is “a measure of the degree of color shift 

objects undergo when illuminated by the light source as compared with those same objects when illuminated by a 

reference source of comparable color temperature.” m According to the IESNA Lighting Handbook, the CCT of a light source is “the absolute temperature of a 

blackbody whose chromaticity most nearly resembles that of the light source.”

n While CCT is a single value, light with the same CCT value may have slightly different properties. Therefore, the 

lighting industry has defined elliptical regions in chromaticity space (called 4 MacAdam color steps) for specific 

CCT values (e.g., 2,700 K, 3,000 K, 3,500 K, 4,000 K/4,100 K, 5,000 K, and 6,500 K) in ANSI C78.376-2001.

These regions act as a tolerance for the color properties of the lamp. 

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3.5.3.4 Glass Coatings

To increase the UV absorption by the phosphors, the bulb glass can be covered with an 

antireflective coating. This coating, also referred to as the undercoat or base coat layer, is a 

refractory oxide, such as aluminum oxide (Al2O3), silicon oxide (SiO2), and titanium oxide 

(TiO2). This layer is used to reflect any UV radiation that passes through the phosphor back onto 

the phosphor, allowing a greater portion of UV to be absorbed. As the phosphors absorb more 

UV radiation, they will emit more visible light, thereby increasing the overall efficacy of the 

lamp. When these coatings are used with rare earth phosphors, a good CRI can be achieved while 

minimizing the phosphor thickness necessary to absorb maximum UV radiation. A recent 

patent69 by Philips was issued in 2005 for an improved undercoat that reduces the amount of 

lamp contaminant resulting from the manufacture process. The improved coating covered under 

the patent contains an aluminum oxide material and a getter material which reacts with 

contaminants. This reduction or elimination of contaminants results in improved lamp arc 

stability.

3.5.3.5 Multi-Photon Phosphors

The use of multi-photon phosphors, or quantum-splitting phosphors, can significantly 

improve lamp efficacy. Because these phosphors emit more than one visible photon for each 

incident UV photon, a lamp would be able to emit more light in the visible spectrum for the same 

amount of power. However, there are technical drawbacks with the technology such as light 

color output, color stability, and phosphor lifetime.70

3.5.3.6 Cold Spot Optimization

The point on a CFL with the lowest temperature is where the vaporized mercury 

condenses. The temperature of this “cold spot” has an impact on overall lamp efficacy as it 

influences the vapor pressure of gaseous mercury. With lower cold spot temperatures there is 

insufficient gaseous mercury which reduces UV output; however, high cold spot temperatures 

cause UV radiation to become trapped in the tubing. Cold spot temperature is a function of 

current density, and light output increases with current density until it reaches a certain saturation 

level. As current density increases, the ionization rate of mercury atoms increases, causing UV 

radiation to increase, ultimately improving the transfer of UV radiation to visible light. 

Simultaneously, however, the electron temperature will drop due to a step-wise ionization at the 

higher current density and the chemical tendency to revert back to a state of equilibrium. As 

electron temperature decreases and electrons experience de-excitation, the useful UV radiation 

intensity is unable to increase as quickly as the current density, so it will gradually approach a 

constant. Therefore, by finding the right cold spot temperature, one can balance these effects and 

optimize light output. In a study of commercially available T2 and T3 CFLs, Feng and Hu found 

that light output reaches a maximum at about 48 °C with a fixed current of 140 mA (see Figure 

3.5.9). This conclusion is similar to the temperature of 50 °C for T2 tubes found by Han et al.

Future CFL designs should ensure that the cold spot reach an optimal temperature in steady state 

operation to maximize efficacy.71

3-51
Figure 3.5.9 T2 and T3 Spiral CFL Performance at 140 mA

The lamp’s orientation (i.e. base up versus base down) also affects the cold spot 

temperature. A typical spiral CFL’s cold spot occurs at the top of the bulb where the two helical 

spirals meet. Due to rising heat, the cold spot temperature is higher when the lamp is operated 

base down rather than base up. The higher temperature can result in roughly 10 percent less light 

output. The use of amalgam in CFLs help alleviates efficacy issues related to lamp orientation 

but also increases warm up time over liquid Hg CFLs. In 2010, the United States granted GE a 

patent that involves a CFL with a secondary cold spot to maintain cold spot temperature for base 

up and base down applications. The secondary cold spot is positioned between the longitudinal 

end portions of the discharge tube arrangement, contrary to the first cold chamber, which is 

located in a longitudinal end portion of the tube arrangement. The second is positioned on the 

wall of the tube and has a cold chamber wall protruding substantially away from the central axis 

of the discharge tube arrangement. This location optimizes the cooling effect of ambient air to 

provide efficient cooling of the second cold chamber in base down positions.72

3.5.3.7 Improved Ballast Components

Integrated CFLs use electronic ballasts. The use of ballasts with high efficacy factors in 

integrated CFLs will increase lamp efficacy. Further, proper lamp-ballast combinations can 

affect lamp life up to 50 percent.73 New electronic ballast components and novel circuit designs 

can continue to improve overall lamp efficacy. A common way to increase the efficiency of 

ballasts is to improve the quality of their components. Magnetics (transformers and inductors), 

diodes, capacitors, and transistors are the main components that affect efficiency. For example, 

one way to reduce magnetic component power loss at light loads is to select magnetics with 

higher quality core materials. Another way to reduce the magnetic component’s power loss is to 

select materials with lower winding losses. The efficiency of the circuit can also be improved by 

using capacitors with low effective series resistance (ESR). Further, using transistors with drainto-source resistance (low RDS_ON) can reduce losses.

3-52
3.5.3.8 Improved Ballast Circuit Design

Another method of increasing the efficiency of integrated CFLs is to improve the 

ballast’s circuit design. Examples of improved circuit design include cathode cutout technology, 

integrated circuits, improved starting method, and synchronous rectification.

Cathode cutout technology using an electronic circuit removes the power provided to the 

filament after the lamp has been started, thereby increasing the efficiency of both PS and RS

ballasts. In certain cases, a ballast’s efficiency can be improved by substituting integrated circuits 

for discrete components.

74Further, RS and PS ballasts are inherently less efficient than IS 

ballasts even though IS ballasts use extra power to provide filament power to the ballast to 

increase its lifetime. 

3.5.3.9 Change to LEDs

LED lamps can provide a higher level of efficacy than CFLs, and it is likely that LED 

lamp’s efficacy margin over CFLs will grow attributed to ongoing R&D. Therefore, DOE is 

considering a switch from CFL to LED technology as an option for improving lamp efficacy of 

GSLs. 

3.5.3.10 Efficient Down Converters

The color of light produced by an LED lamp is dependent on the type of semiconductor 

material used in the lamp, and is not inherently white. Since LEDs themselves emit a single 

fairly narrow wavelength, some sort of manipulation of light or addition of light is necessary to 

produce a quality (high CRI) mixed white light source. Currently, manipulation of light in LED 

lamps is most commonly done through phosphor conversion, converting some light from a UV 

or blue LED to longer wavelength light (green through red) for a cumulative white light. The 

conversion of light from shorter wavelength photons to longer wavelength photons is a high to 

low energy conversion. The difference in energy between the high energy UV or blue photons 

and the low energy green through red photons is lost in the conversion. The most commonly 

used phosphor today, with variations, is Y3Al5O12:Ce3+ (YAG:Ce) with a blue LED. The

quantum efficiency (a component of overall phosphor efficiency) of YAG:Ce under excitation of 

a blue LED can exceed 85 percent.75 By improving down converter efficiencies more light will 

be produced for the same input, and lamp efficacy will increase.

Novel compositions of phosphor can further improve down converter efficiencies. The 

United States recently granted GE a patent for a novel phosphor producing blue-green and green 

light. The quantum efficiency of the phosphor at 150 °C is 80 percent of quantum efficiency at

ambient temperature. Most current phosphors’ quantum efficiencies at 150 °C degrade to 60 

percent of their efficiency at ambient temperature.

76 This new composition would allow for 

greater package efficacy at higher system temperatures, which are characteristic of LED lamps. 

Although phosphors are the most common type of down converters, other quantum dots

can also improve LED efficacy. Colloidal quantum dot phosphors are nanocrystal emitters that 

can tune their emission wavelength by changing their size and contain no rare earth elements. 

These could be a potential replacement for traditional phosphors if they can overcome 

3-53
temperature performance issues as well as light flux issues. Researchers at State University of 

New York (SUNY) at Buffalo have produced quantum dot phosphors emitting green through red 

wavelengths at efficiencies over 80 percent. Further, the phosphors are able to produce green 

through red wavelengths with only a five percent loss in efficiency at 150 °C, and have minimal 

losses at fluxes up to 38,000 W/cm. Researchers have also managed to significantly reduce 

Auger recombinationo through these new phosphors.

77 Further, although no longer commercially 

available, a R30 LED lamp utilizing quantum dot phosphors was introduced by Nexxus Lighting, 

Inc. and QD Vision in 2010.78

3.5.3.11 Improved Package Architectures

LED packages are individual nodes that make up the LED and have their own efficacy 

which is driven by the method of generating white light, color quality attributes, and drive 

current. The package efficacy ultimately contributes to the LED lamp efficacy. Improved LED 

package architectures utilize color mixing with multiple monochromatic LEDs (e.g., red, blue, 

green) or hybrid systems that incorporate both phosphor-converted (PC) LEDs and multiple 

monochromatic LEDs. LED color-mixing is one method to generate white light output from 

LEDs. It entails mixing the appropriate amount of light from multiple monochromatic LEDs 

(red, green, and blue) to yield white light. Additional LEDs, such as amber, can be added to 

potentially improve the color characteristics but may also lower efficacy. Because it avoids 

phosphor conversion losses, LED color mixing is theoretically the most efficient way to produce 

light from LEDs. However, the efficacy of color mixing package architecture lags behind 

packages using PC LEDs due to the inability to produce efficient green or amber LEDs which 

has led to the prevalence of PC LED lamps. 

Hybrid package architectures combine the use of multiple monochromatic LEDs as in 

color mixing along with PC LEDs. Configurations may involve efficient blue LEDs with a 

phosphor coating to emit green wavelengths and efficient red LEDs to provide combined white 

light. Such a design could prove to be more efficient than current designs utilizing only PC LEDs

by eliminating the loss during blue to red down conversion with phosphor. In 2002, Philips filed 

a patent for such a device as well as other combinations of LEDs and phosphors to make white 

light with comparable color rendering and color temperature control to existing LED lamps but 

with potentially higher efficacies.

79 Further, LED package efficacies tend to be lower at higher 

CRI as well as at lower CCTs (warm-white). High efficacy warm-white luminaires employing 

the hybrid approach have been on the market since 2009.80 In 2013 Philips reported on the 

development of a warm-white hybrid LED package for general illumination that could 

potentially achieve 131 lm/W at 85 °C with a CRI 90, a CCT of 2955 K. Philips noted that the 

hybrid architecture can allow for more efficacious warm-white LEDs and at high CRIs.

81

Additionally, the driver current also impacts efficacy of the package. A package 

architecture that increases driver current will increase the lumen output but also results in a 

proportional decrease in efficacy (an effect called the efficiency droop which is discussed in 

section 3.5.3.12). 

o Auger recombination is a process by which electrons collide and produce heat rather than emit light. 

3-54

 
Manufacturer feedback and DOE research indicates that these and various other ways for 

improving package architecture are being utilized in products and are the subject of further 

R&D. Cree, for example, produced a traditional PC LED in its lab with an efficacy of 276 lm/W 

in 2013 owing the improvement in part to advances in LED package architecture.82 Cree has 

since improved its lab LED performance to over 300 lm/W as of March 2014.83 Figure 3.5.10

shows the expected efficacy gains for the color mixing and PC methodologies.

Figure 3.5.10 Projected LED Package Efficacy Trends

Source: DOE’s Solid-State Lighting Technology Fact Sheet

3.5.3.12 Improved Emitter Materials

Advanced emitter materials and structures can improve the efficiency of LEDs. The basis 

of any LED lamp is the LED emitter, which actually produces the light. As mentioned 

previously, the predominant configuration in the LED GSL market is a PC blue LED which 

produces white light by mixing the down converted light with some of the blue light which 

passes through the phosphor unchanged. The color mixing methodology uses individual 

monochromatic LEDs (e.g., red, green, blue) to produce a mix of colors that generates white 

light. Because color mixing does not utilize PC LEDs, it avoids down conversion losses

associated with the phosphor conversion methodology. While blue LEDs have made good 

progress towards their theoretical maximum efficiencies, green LEDs remain markedly behind 

their theoretical maximum of 683 lm/W for a monochromatic light source at 555 nm.84 Improved 

emitter materials for green and amber LEDs would allow for development of high efficacy colormixed LED lamps. 

Figure 3.5.11 plots the lumens per watt of various researchers’ prototype LEDs versus

their wavelength at a given current of 45 Acm-2 (note the y axis is logarithmic). The additional

lines show the theoretical maximum wall plug efficiency (WPE), a dimensionless efficiency 

metric of optical radiant flux (in watts) per watt of electricity supplied. Semiconducting materials 

such as Group III nitrides (such as Gallium Nitride [GaN] and Indium Gallium Nitride [InGaN]) 

and Group III phosphides (such as Gallium Phosphide [GaP]) are efficient in producing shorter 

and longer wavelength light, respectively, but have much lower WPEs in the middle of the 

3-55
visible spectrum. This region has been dubbed the “green gap” by researchers because of the 

difficulty creating highly efficient LEDs in this part of the visible spectrum.

Figure 3.5.11 The “Green Gap”

Source: Compound Semiconductor85

In order to emit green light, a high forward voltage must be applied which reduces power 

conversion efficiency. Also, green LEDs, even more so than other LEDs, fall victim to reduced 

efficiency with increased current, known as “efficiency droop”. At typical operating currents, the 

effect is large as seen in Figure 3.5.12.

3-56
Figure 3.5.12 Efficiency Droop

Source: Compound Semiconductor86

While there have been many different theories regarding the efficiency droop, in April 

2013, researchers at the University of California, Santa Barbara in collaboration with École 

Polytechnique in France identified Auger recombination as the primary source of efficiency 

droop. Auger recombination is a process by which electrons collide and produce heat rather than 

emit light. The rate at which this process occurs is proportional to third power of carrier density, 

which leads to low efficacy at high injection rates (i.e. high current).

87 The problem is inherent 

with the technology and not solvable, but can be mitigated through either thicker quantum wells 

or growth of epitaxial layers along non-polar or semi-polar directions in order to lower carrier 

density.88, 89 Accordingly, RPI and other institutions such as NREL are continuing research 

efforts to reduce the effect through different polarities and even non polar epitaxial structures. In 

another approach, Dr. Alexander Efros with the U.S. Naval Research Laboratory obtained a 

patent for a method that utilizes quantum wells with softened confinement electrostatic potential 

that reduce carrier momentum necessary for the Augur process as a means of reducing efficiency

droop.

90,91

3.5.3.13 Alternative Substrate Materials

One of the major barriers to producing efficient LEDs is the lack of proper substrate 

materials. The LED substrate is the foundation on which the emitting material is built. The key 

issues surrounding substrates for LEDs are price and efficiency. The difference between the 

spacing of the atoms in the crystal lattice of the substrate and epitaxial layer has a large influence 

on the efficiency of the LED. A mismatch between the substrate and the GaN epitaxial layer 

creates strain which causes the materials to break away and fracture leading to decreased 

performance.92 Better matched substrates will result in less strain in epitaxial layers leading to 

fewer defects and higher efficiency LEDs, thereby increasing LED lamp efficacy as well.

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The oldest and most common LED substrate material is sapphire. Because sapphire has 

been used for so long, manufacturers have been able to solve a lot of performance issues and 

bring down price substantially. A few manufacturers are utilizing GaN on silicon carbide 

substrates which are more costly but also offer higher performance over sapphire (see Table 

3.5.2). 93

Other than silicon-carbide, GaN on GaN LEDs have emerged as a potential alternative 

substrate option. The major advantage of using GaN on GaN LED material comes from a better 

crystal lattice match with fewer defects, which enables LEDs to emit more light per unit area of 

LED material. Further, GaN on GaN LEDs have greater optical transparency and high thermal 

and electrical conductivity that delivers improved light output and performance.94 The main 

issues with GaN substrates are high substrate cost, consistency, and a lack of large diameter 

wafers.

95 On February 24, 2014 Soraa, a company known for their GaN on GaN LEDs, 

announced their third generation GaN on GaN LED package achieving a 75 percent WPE at 35 

A/cm2 and 85 °C. It also renders with a CRI of 95 and R9

p

 of 95.96

Table 3.5.2 Substrate Comparison 

Material Lattice 

mismatch (%) Strength Weakness

Sapphire 16 Low price, 

chemical stability Large lattice mismatch

GaN 0 Homogeneous 

substrates

Difficulty in high-quality crystal 

growth, high price. Currently in basic 

research stage.

SiC 3.5 Small lattice 

mismatch

Price, difficulty in large substrate 

growth

Si 18 Low price, large 

substrate possible

Difficulty in high-brightness 

manufacturing

Source: Solid State Technology97

3.5.3.14 Thermal Interface Materials

Thermal interface materials (TIMs) have the ability to improve cooling of the LED chip. 

LEDs produce not only light, but also heat during their operation since they are not perfectly 

efficient light emitters. Increasing heat at the LED junction can decrease LED efficacy.98, 99

Continuously high junction temperatures are also known to hasten lumen depreciation over time 

due to LED component degradation, ultimately reducing lamp efficacy and lifetime.

100 There are 

varying levels of thermal performance offered by commercially available TIMs. For example, 

Dow Corning offers thermal adhesives, thermal greases, and thermal pads each available in a 

range of thermal conductivities for use in LED lamps.101 Additionally, DOE has identified novel 

approaches to TIMs for use in LEDs and continual R&D advancements in the field. For example 

p R9 is not used in the calculation of CRI. It is part of the special color rendering indices, referred to as R9 through

R14, which are each based on single test colors. R9, the “strong red” color sample, is especially pertinent because the 

rendition of saturated red is important for the appearance of skin tones, among other materials. For more information 

please refer to the LED Color Characteristics Fact Sheet: 

http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/led-color-characteristics-factsheet.pdf. 

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chemical vapor deposition (CVD) diamond provides higher thermal conductivity than 

conventional materials as the diamond acts as an effective heat spreader. Further, a titanium layer 

can be applied to the diamond allowing for use of platinum or gold enabling attachment via 

standard methods such as solders or epoxies.102 There is also research regarding use of carbon 

nanotubes, which have high thermal conductivity, in TIMs of high-brightness LEDs.103

3.5.3.15 Optimized Heat Sink Design

As mentioned in section 3.5.3.14 high LED junction temperatures can lead to a decrease 

in efficacy. The LED heat sink is the primary means by which LED lamps wick away heat from 

the LED chips. A well designed heat sink helps reduce LED junction temperature. DOE has 

found that optimized heat sink designs are being used in commercially available lamps that have 

traditional A-shape form factors. For example, finned designs made out of materials with high 

thermal transfer coefficients have been utilized in commercially available A-shape lamps. 

Further, there are existing patents on optimized heat sinks for LEDs indicating this is an area of 

ongoing research.104, 105

Sapa Extrusions North America recently unveiled a new method in manufacturing high 

ratio air cooled extruded aluminum heat sinks that are approximately eight percent more 

thermally efficient than the industry standard. The new technology allows them to achieve heat 

sink fin ratios, a ratio of the fin height to the spacing between the fins, in excess of 40:1 where 

they were previously restricted to ratios of 16:1 based on extrusion limitations.

106 This allows an 

increase in the number of fins on a finite footprint, leading to the boost in convection.

Another novel approach to thermal management in LED lamps is the use of a liquid filler 

inside the bulb to increase convection from the LED to the surface of the lamp through a liquid 

with much higher thermal mass than the conventional fluid, which is air. Follett Optoelectronic 

Co., Ltd. in China has announced liquid cooled LEDs at 6-8 W producing 90-100 lm/W.107 Cree 

also recently announced a new LED lamp that removed the need for a heat sink. It is designed 

with ventilation chambers at the top and bottom of the bulb, and when heat is generated by the 

LEDs, the heat causes air to circulate, which ultimately cools the components using

thermodynamic properties of convection.108 Further improvements to heat sink manufacturing 

and materials will increase LED lamp performance and broaden application.

3.5.3.16 Active Thermal Management Systems

As mentioned in section 3.5.3.14 high LED junction temperatures can lead to a decrease 

in lamp efficacy. Active thermal management systems can provide higher performance

alternatives to the conventional passively cooled convection heat sink designs. Active thermal 

management systems are specifically designed to provide cooling to LED components and 

theoretically, should provide net gains in overall efficiency even though they consume extra 

energy. Some active thermal management systems take the form of integral fans or vibrating 

membranes, increasing convection. The Philips MASTER LEDspot product line with integrated 

fans for cooling is an example of commercially available lamps that utilize active thermal 

management systems.

109

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3.5.3.17 Device Level Optics

A primary optic is integrated onto the LED package that optimizes light extraction and/or 

beam shaping. Secondary optics help further shape light of the LED lamp and are additional 

components separate and outside of the LEDs itself (e.g., lens or diffuser). Reducing secondary 

interfaces through integration of a lens onto the LED, or removing the secondary optic 

altogether, will increase package efficacy of LED lamps. Secondary surfaces lower the efficacy 

of LED lamps by introducing another layer for light absorption. By removing secondary optics

or integrating lens functionality at the package level, LED lamps will suffer fewer absorption 

losses at the same power input, and therefore have higher efficacy. DOE has found that there are 

research efforts addressing issues of optimizing extraction efficiency for small package sizes as 

well as improving beam shaping through only primary optics. An existing patent presents 

primary optic configurations that achieve more controlled beam shapes while allowing for a 

more simplified and efficient secondary optic.110

3.5.3.18 Increased Light Utilization

Once light is emitted from an LED, there are still a number of losses to the lamp and 

surrounding housing. Highly reflective coatings inside the lamp can help reduce light absorption 

losses, thereby increasing overall luminaire efficacy. WhiteOptics, in conjunction with DOE and 

University of Delaware’s composite materials department, has developed a new reflector 

composite coating demonstrated in LED luminaires that achieves a 97 percent reflectance as well 

as 15 percent optical efficiency improvement over benchmark LED luminaires. Further, the 

diffuse coating allows luminaires it is applied on to produce a uniform light distribution.

111 Other 

companies, such as SABIC, also offer plastics with reflectivities around 97 percent.

112 Dow 

Corning won an award at the 2014 LIGHTFAIR® International Innovation Awards for their MS2002 Moldable White Reflector Silicon for use in LED devices that targets reflectivity up to 98 

percent.

113 With fewer reflective interfaces and highly reflective materials, LED lamps will be

able to decrease light absorption and increase efficacy.

3.5.3.19 Improved Driver Design

Current LED drivers are typically 85 percent efficient with improvements expected.

114

New designs will allow for smaller, more compact drivers with even higher efficiency, which 

will boost overall LED lamp efficacy. Philips Light Sources and Electronics is developing 

drivers with the help of DOE funding. These drivers are expected to have efficiencies over 90 

percent and are also smaller and lower in cost. Philips’ new designs for 75 W drivers are 36 

percent smaller than existing drivers, enable more precise dimming from 1V to 8V, and have 

added protection in the case of module overheating.115 Additionally, manufacturer feedback and 

DOE’s review of catalogs show a range of efficiencies associated with drivers, indicating the 

potential for improvement in driver design.

3.5.3.20 AC LEDs

By reducing conventional driver size or removing the driver component, complexity, and 

efficiency losses, AC-powered LEDs can increase performance of the LED lamp. AC LEDs 

integrate power conversion into the package, thus requiring few additional components though 

design specifics vary by manufacturer. In original AC LED setups, half of the LEDs would light 

up for the first half of the AC power sine wave cycle and only the other half would light up for 

3-60
the second half of the cycle.q Under this setup, LEDs were linked together in a series forming 

strings and provided low efficacy solutions for niche applications such as accent lighting. The 

latest AC LED designs use a high voltage architecture with simple control circuitry to operate on 

AC current. Seoul Semiconductor has a number of high voltage AC LED modules commercially 

available for integration into lamps. In July 2014, Seoul Semiconductor announced a new line of 

AC LED modules with improved AC drivers designed specifically for the omnidirectional 

lamps.116 The new AC driver improves compatibility with TRIAC dimmers and is able to 

effectively mitigate flicker issues that can arise during dimming of AC LEDs. 117, 118

Additionally, improvements in circuit design can increase LED utilization. For example, Texas 

Instruments (TI)'s TPS92411 MOSFET switch allows for a small capacitor to be placed across 

each LED segment on a circuit to store energy keeping all LEDs lit even when the AC line 

voltage is too low, thereby increasing LED utilization.119 Some challenges for AC LEDs 

functionality include total harmonic distortion, power-factor correction, and zonal dimming. 

3.5.3.21 Reduced Current Density

As discussed previously, efficiency droop negatively impacts the performance of LEDs at 

common current densities.120 Most LEDs peak in efficiency when driven at just tens of 

milliamps whereas 350 mA is much more common. However, decreasing current also reduces 

lumen output, thus requiring more LEDs. Therefore, current density must be reduced in a way 

that increases LED efficacy while maintaining practical levels of lumen output per unit area. One 

method to achieve this benefit would be to design a lamp with several arrays of medium or low 

power LEDs in lieu of a small number of high power LEDs. Cree has introduced mid-power 

LEDs at 154 lm/W that uses the ceramic substrate that is typically utilized in high-power LEDs 

rather than plastic packaging found in most mid-power LEDs. This product could potentially 

minimize lumen depreciation and offer lifetimes comparable to the high-power LEDs.121

3.6 PRODUCT CLASSES

When evaluating and establishing energy conservation standards, DOE divides covered 

products into classes by (a) the type of energy used; (b) the capacity of the product; or (c) other 

performance-related features that justify different standard levels, such as features affecting 

consumer utility. (See 42 U.S.C. 6295(q)) DOE then conducts its analysis and considers separate 

standard levels for each product class. DOE applied the criteria of 42 U.S.C. 6295(q) to GSLs to 

develop product classes in this preliminary analysis. This section of the TSD describes the 

factors DOE examined in considering product classes for GSLs.

This rulemaking cycle is the first for GSLs and therefore there are no precedents for GSL 

product classes. The standards set by EPAct 2005 and in EISA 2007 for MBCFLs and GSILs 

respectively, established product classes for these lamp types. EPAct 2005 divided MBCFLs by 

whether or not they contained a cover and by wattage. EISA’s standards set separate standards 

for standard versus modified spectrum lamps and further by lumen bins. 

q In the US wall socket power supplies operate at 120 V and 60 Hz

3-61

 
For this preliminary analysis DOE examined several possible characteristics or features of

GSLs that could warrant separation of covered products into different product classes, including:

• Cover

• Dimmability

• Ballast Location

• Lamp Technology

• Base Type

• Lamp Spectrum

• Correlated Color Temperature

• Lumen Package

• Standby Mode Operation

The following subsections discuss these lamp attributes and how they pertain to product 

class divisions.

3.6.1.1 Lamp Technology

In evaluating GSLs, DOE determined that different lamp technologies do not offer 

consumers different utility. DOE believes that for use in a general service application, a CFL and 

LED lamp offer similar functionality. Therefore, DOE is not considering product class divisions 

based on lamp technology. In the product class structure under consideration, medium base CFLs 

fall into the integrated GSL product class. DOE accounts for the existing standards for medium 

base CFLs in the analysis of this product class to ensure there is no backsliding.

3.6.1.2 Cover

DOE considered the effect that the presence of a cover over the main light source has on 

lamp efficacy. Some lamps incorporate an added glass or silicone cover over the main light 

source which can reduce the lumen output of the lamp. In some cases, covered lamps may offer 

utility to consumers as they more closely resemble traditional lighting technologies and are 

frequently utilized where a lamp is visible. 

DOE researched the applicability of the covered versus bare feature across different lamp 

technologies. DOE found that while a cover generally decreased efficacy, particularly in CFLs, a 

cover could also result in increased efficacy, such as when it has a phosphor coating and 

transforms light emitted from LEDs into visible light. Further many LED lamps that have covers 

also have high efficacies. As noted previously, DOE is considering technology neutral product 

classes in this preliminary analysis. Thus, covered products will still be available at the highest 

levels of efficacy analyzed. For these reasons, DOE is not considering establishing a product 

class for covered versus bare products in this preliminary analysis.

3.6.1.3 Dimmability

For certain technologies, such as CFLs and LED lamps, not all products are marketed as 

capable of being dimmed. Thus a lamp that can be dimmed may offer unique performance 

characteristics and provide a utility to consumers.

3-62
DOE analyzed the impacts of dimming on lamp efficacy. Review of catalog data and 

feedback from stakeholders, indicated that dimmable lamps are available across a range of 

efficacies and further confirmed that the ability to dim has a negligible impact on efficacy. 

Therefore, because there is no discernable impact on efficacy in relation to dimmability, DOE is 

not considering establishing separate product classes for lamps that are dimmable and those that 

are not in this preliminary analysis. 

3.6.1.4 Ballast Location

Ballast location refers to the use of integrated ballasts (i.e., self-ballasted) or nonintegrated ballasts (i.e., externally ballasted). DOE notes that self-ballasted lamps may have 

lower inherent efficacy compared to lamps that utilize external ballasts due to the additional 

components and circuitry integrated into a self-ballasted lamp. The use of a self-ballasted lamp 

can be advantageous in that a consumer need only replace one lamp unit rather than two separate 

components. Self-ballasted lamps are also generally more compact and thus can be used in 

applications with size constraints. For these reasons, DOE is considering establishing separate 

product classes based on ballast location in this preliminary analysis.

The impact on efficacy and utility for this product class division is based on the lamp 

having all its components enclosed within it as opposed to requiring an external, replaceable 

component. Therefore, to provide a clearer description of the product class that is applicable 

across all GSL technology types, DOE is considering using the terms ‘integrated’ and ‘nonintegrated’ rather than ‘self-ballasted’ and ‘externally-ballasted.’ Integrated GSLs would 

comprise lamps that contain all components necessary for the starting and stable operation of the 

lamp, do not include any replaceable or interchangeable parts, and are connected directly to a 

branch circuit through an ANSI base and corresponding ANSI standard lamp-holder (socket).

Non-integrated GSLs would comprise any lamp that is not an integrated lamp.

3.6.1.5 Base Type

DOE considered that smaller base types, such as candelabra, may warrant a separate 

product class due to space constraints. However, DOE is not considering setting standards for 

GSLs with candelabra bases in this rulemaking (see section 3.2.5.3). Therefore, DOE is not 

considering establishing separate product classes based on base type in this preliminary analysis.

3.6.1.6 Lamp Spectrum

DOE considered lamp spectrum as a product class setting factor. Modified spectrum 

lamps provide a unique spectral power distribution (SPD) that increases the contrast between 

reds and greens, resulting in a type of light different from a standard spectrum. DOE’s research 

indicates that there are various ways to manipulate SPDs to achieve a modified spectrum such as 

neodymium coating, phosphor mixes and LED color mixing or a combination thereof. DOE has 

found that certain methods do not require a decrease in efficacy. For example the Philips L Prize 

lamp and Cree’s existing product line of True White ® color mixed LED modules are able to 

achieve a modified spectrum at high efficacies. Because efficacy is impacted in different ways 

based on the method used to achieve modified spectrum GSLs, DOE is not considering separate 

product classes for standard and modified spectrum GSLs in this preliminary analysis.

3-63
3.6.1.7 Correlated Color Temperature

DOE considered CCT as a product class setting factor. CCT is a measure of the perceived 

color of the white light emitted from the lamp. The perception of light affords consumers a 

different utility for lamps with different CCT values. DOE found that while there is a reduction

in efficacy for fluorescent technology at higher CCTs, LED technology experiences an increase. 

For CFLs at higher CCTs, more light is converted to shorter wavelengths (i.e., blue, violet) to 

which human eyes are less sensitive, thereby resulting in a decline in efficacy. In LED lamps, the 

LED emits blue light (i.e., shorter wavelengths) which is partially down converted to longer 

wavelengths. While this process results in longer wavelengths to which human eyes are more 

sensitive, there is a decrease in lumen output due to losses from phosphor conversion and a 

larger Stokes’ shift.

r To achieve lower CCTs in LED lamps, more down conversion and a larger 

Stokes’ shift is required, resulting in lower efficacy. Due to these underlying differences in 

technology, the efficacy trends associated with CCT differ for CFLs and LED lamps. Therefore, 

a consistent correlation between efficacy and CCT cannot be established for all GSLs. Hence 

DOE is not considering such a product class division based on CCT in this preliminary analysis. 

3.6.1.8 Lumen Package

DOE considered lumen packages as a product class setting factor for integrated GSLs. 

DOE determined that higher lumen output products cannot achieve the same levels of efficacy as 

lower lumen output products. DOE believes that higher lumen packages offer a consumer utility. 

After evaluating manufacturer catalogs and other sources,s DOE determined that a general 

service high lumen application would have light output in the range of 2,000 – 2,600 lumens. 

DOE was unable to identify LED lamp replacements for incandescent lamps of wattages higher

than 100 W. However, DOE identify lumen ranges of CFLs marketed as being equivalent to a 

125 W incandescent lamp, the next common incandescent wattage higher than the 100 W. 

Additionally, ENERGY STAR Lamps Specification V1.1t defines a 125 W incandescent 

equivalent lamp to have a lumen range of 2,000 – 2,549. The upper lumen limit of the high 

lumen package product class under consideration is maintained at 2,600 in accordance with the 

scope of this rulemaking which is considering setting standards for products in the lumen range 

of 310 – 2,600. Because of the impact on both efficacy and utility, DOE is considering 

establishing separate product classes for integrated GSLs with lumen outputs between 310 and 

1,999 and integrated GSLs with lumen outputs between 2,000 and 2,600. DOE is not establishing 

a product class division based on lumen package for non-integrated GSLs, as DOE found lumen 

packages across a range of efficacies for these products.

3.6.1.9 Standby Mode Operation

DOE considered a division based on the ability of a lamp to operate in standby mode. As 

stated in section 3.2.5.1, DOE identified integrated lamps that meet the definition of GSL and 

operate in standby mode. DOE believes that standby mode operation offers a consumer utility 

r Stokes’ shift is the difference, in nanometres, between the peak excitation and the peak emission wavelengths. 

Stokes’ law states that radiation emitted must be of the longer wavelength than that absorbed. s ENERGY STAR Lamps V1.1 Final Specification, available at 

http://www.energystar.gov/sites/default/files/ENERGY%20STAR%20Lamps%20V1%201_Specification.pdf. t Ibid.

3-64

 
because these lamps have the ability to be remotely turned off, turned on, dimmed, or other 

functionality. DOE evaluated whether operation in standby mode impacts lamp efficacy. Based 

on commercially available products, DOE found that standby power consumption can vary based 

on the technology used to facilitate standby functionality. DOE assumes that the market will shift 

to the lowest energy consuming method available, such as Bluetooth or smart controls that are 

external to the lamp, over the course of the analysis period and therefore believes that the energy 

consumed in standby mode is negligible. Because DOE believes that the energy consumed while 

operating standby mode will be negligible for GSLs, DOE does not believe there is a difference 

in efficacy for lamps that can operate in standby mode compared to lamps that cannot operate in 

standby mode. Therefore, DOE is not considering a product class division based on standby 

mode operation. 

3.6.1.10 Product Class Summary

After considering GSL characteristics above, in this preliminary analysis, DOE is 

considering establishing the three GSL product classes summarized in Table 3.6.1.

Table 3.6.1 GSL Product Classes

Lamp Type Lumen Output

Integrated GSLs (e.g., self-ballasted CFL, 

integrated LED lamp)

310-1,999

2,000-2,600

Non-Integrated GSLs (e.g., externally ballasted

CFL) 310-2,600

3-65
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67 Illuminating Engineering Society of North America. The IESNA Lighting Handbook: 

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68 Illuminating Engineering Society of North America. The IESNA Lighting Handbook: 

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72 Erzsébet Cserteg,(Erdösor u. HU); Károly Tálosi, (Herkules u. HU); Arni Siti, (Fövám tér

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73 Illuminating Engineering Society of North America. The IESNA Lighting Handbook: 

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75 Setlur, Anant. Phosphors for LED-based Solid-State Lighting. The Electrochemical Society 

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76 Setlur, Anant (Niskayuna, NY, US); Chandran, Ramachandran (Bangalore, IN); Henderson, 

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78 Nexxus Lighting. NEXXUS LIGHTING DELIVERS FIRST COMMERCIALLY-AVAILABLE 

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80 U.S. Department of Energy. Solid-State Lighting Research and Development Multi-Year 

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81 Wouter Soer, Guan Huang, Frank Jin, Han Ho Choi, Dave Kharas, Henry Choy, Frank Wall.

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82 Cree. Cree Sets New R&D performance Record with 276 Lumen-Per-Watt Power LED. 

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83 Cree. Cree First to Break 300 Lumens-Per-Watt Barrier. March 26, 2014. (Last Accessed 

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86 Ibid.

87 Applied Physics Letters. Indirect Auger recombination as a cause of efficiency droop in 

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91 Alexander Efros and George Cragg. (2013) U.S. Patent No. 8,394,651. Washington DC: US 

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92 LEDs Magazine. GaN on silicon: A breakthrough technology for LED lighting. February 13, 

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94 Soraa. GAN ON GAN. 2014. (Last accessed November 21, 2014.) 

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99 David S. Meyaard et al. Temperature dependent efficiency droop in GaInN light-emitting 

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100 U.S. Department of Energy. Lifetime of White LEDs. (Last accessed November 21, 2014.) 

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102 Aidala, Dwain A. CVD Diamond Solves Thermal Challenges. Solid State Technology. 2006. 

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3-74
105 Timothy Chen George Uhler. (2013) U.S. Patent Application No. 13/889,034. Washington 

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107 LEDs Magazine. Follett produces liquid-cooled, dimmable LED bulb. July 11, 2013. (Last 

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112 SABIC. SABIC SHOWCASES BROAD PORTFOLIO OF MATERIALS SOLUTIONS FOR 

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115 U.S. Department of Energy. Philips Light Sources & Electronics is Developing an Efficient, 

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117 Seoul Semiconductor. Seoul Semiconductor Launches the Next Generation of Smart Lighting 

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119 LED Magazine, TI launches AC-driver technology for LED-based lighting. 2013. (Last 

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121 Cree. Cree Introduces Industry’s First No-Compromise, Ceramic, Mid-Power LEDs. May, 

2013. (Last accessed November 21, 2014.) <http://www.cree.com/News-and-Events/CreeNews/Press-Releases/2013/May/XH-intro>

3-76
CHAPTER 4. SCREENING ANALYSIS

TABLE OF CONTENTS

4.1 INTRODUCTION ............................................................................................... 4-1

4.2 SCREENED OUT TECHNOLOGIES ................................................................ 4-2

4.1.1 Compact Fluorescent Lamps.................................................................... 4-2

4.1.1.1 Multi-Photon Phosphors.............................................................. 4-2

4.2.1 Light-Emitting Diode Lamps................................................................... 4-2

4.1.1.2 Colloidal Quantum Dot Phosphors.............................................. 4-2

4.1.1.3 Improved Emitter Materials......................................................... 4-3

4.1.1.4 AC LEDs...................................................................................... 4-3

4.3 SUMMARY OF TECHNOLOGY OPTIONS SCREENED OUT...................... 4-3

4.4 REMAINING TECHNOLOGIES ....................................................................... 4-4

4.4.1 General Service Lamp Design Options.................................................... 4-4

REFERENCES ................................................................................................................ 4-5

LIST OF TABLES

Table 4.3.1 GSL Technology Options Screened Out of the Analysis............................. 4-3

4-i
SCREENING ANALYSIS

4.1 INTRODUCTION

This chapter discusses the U.S. Department of Energy’s (DOE) screening analysis 

of the technology options identified for general service lamps (GSLs). As discussed in 

chapter 3 of this technical support document (TSD), DOE consults with industry, 

technical experts, and other interested parties in developing a list of technology options 

for consideration. The purpose of the screening analysis is to evaluate the list of options 

and determine which to consider further and which to screen out.

Section 325(o)(2) of the Energy Policy and Conservation Act (EPCA) provides 

that any new or revised standard must be designed to achieve the maximum improvement 

in energy efficiency that is determined to be technologically feasible and economically 

justified. (42 U.S.C. 6295(o)(2)) In view of the EPCA requirements for determining 

whether a standard is technologically feasible and economically justified, Appendix A to 

Subpart C of Title 10, Code of Federal Regulations (CFR), Part 430, “Procedures, 

Interpretations, and Policies for Consideration of New or Revised Energy Conservation 

Standards for Consumer Products” (the Process Rule) sets forth procedures to guide DOE 

in its consideration and promulgation of new or revised efficiency standards. These 

procedures elaborate on the statutory criteria provided in 42 U.S.C. 6295(o) and, in part, 

eliminate problematic technologies early in the process of prescribing or amending an 

energy efficiency standard. In particular, sections 4(b)(4) and 5(b) of the Process Rule 

provide guidance to DOE for determining which technology options are unsuitable for 

further consideration:

1. Technological feasibility. DOE will consider technologies incorporated in 

commercially available products or in working prototypes to be technologically 

feasible.

2. Practicability to manufacture, install, and service. If mass production of a 

technology and reliable installation and servicing of the technology could be 

achieved on the scale necessary to serve the relevant market at the time the 

standard requires compliance, then DOE will consider that technology practicable 

to manufacture, install, and service.

3. Adverse impacts on product utility or product availability. If DOE determines 

a technology would have significant adverse impact on the utility of the product 

to significant subgroups of consumers, or would result in the unavailability of any 

covered product type with performance characteristics (including reliability), 

features, sizes, capacities, and volumes that are substantially the same as products 

generally available in the United States at the time, it will not further consider this 

technology.

4. Adverse impacts on health or safety. If DOE determines that a technology will 

have significant adverse impacts on health or safety, it will not further consider 

this technology.

4-1
Section 4.2 of this chapter discusses the technology options DOE screened out 

from further consideration. Section 4.3 summarizes those options. Section 4.4 lists the 

remaining technology options not screened out and considered as design options in this 

preliminary analysis. The market and technology assessment (see chapter 3 of this TSD)

discusses in detail all technology options analyzed in this preliminary analysis.

4.2 SCREENED OUT TECHNOLOGIES

This section addresses the technologies that DOE screened out, having considered 

the following four factors: (1) technological feasibility; (2) practicability to manufacture, 

install, and service; (3) adverse impacts on product utility or product availability; and (4) 

adverse impacts on health or safety.

4.1.1 Compact Fluorescent Lamps

4.1.1.1 Multi-Photon Phosphors

Theoretically, the use of multi-photon phosphors, or quantum-splitting phosphors, 

could significantly improve lamp efficacy of compact fluorescent lamps (CFLs). By 

emitting more than one visible photon for each ultraviolet photon, a lamp would be able 

to emit more light for the same amount of power. Researchers at Georgia Tech were 

issued a patent for an oxide-based phosphor doped with praseodymium and atoms of at 

least one activator that produces two visible light photons from a single ultraviolet light 

photon.1 However, development of this technology for use in lighting products remains in 

the research phase and DOE is unaware of any prototypes or commercialized products 

that incorporate multi-photon phosphors.2 Further, researchers have identified technical 

drawbacks to this technology such as light color output, color stability, and phosphor 

lifetime.3 Thus, DOE screened out this technology option based on the first criterion, 

technological feasibility, and will not consider multi-photon phosphors as a design option 

for improving the efficacy of GSLs.

4.2.1 Light-Emitting Diode Lamps

4.1.1.2 Colloidal Quantum Dot Phosphors

Improving the efficiency of down converters in light-emitting diodes (LEDs) can

result in more light output with the same power input, thus improving lamp efficacy. One 

method of down conversion that can result in increased lamp efficacy is the use of 

colloidal quantum dot phosphors. These quantum dot phosphors are nanocrystal emitters 

formed from indium phosphide-based nanocrystals that have unique compositional

structures enabling higher efficiencies at higher temperatures and minimal losses 

associated with light flux. While researchers at State University of New York (SUNY) 

have produced quantum dot phosphors emitting green through red wavelengths at 

efficiencies over 80 percent, they have been unable to incorporate these nanocrystal 

emitters into white LED products.

4 Because quantum dot and nanophosphor technologies 

are still in R&D and not currently commercially available in LED lamps, DOE screened 

out this technology option based on the first criterion, technological feasibility, and will 

4-2
not consider quantum dot and nanophosphor technologies as a design option for 

improving the efficacy of GSLs. 

4.1.1.3 Improved Emitter Materials

The LED emitter is the component of the LED that generates the actual light 

output. LED lamps are now able to use color mixing of red, green, and amber emitters to 

produce white light rather than phosphor coated LEDs. Increasing the efficiency of each 

of these emitters will increase the efficacy of the lamp. In particular green LEDs are 

unable to achieve their theoretical maximum efficiency. Green LEDs experience an 

efficiency droop with increased operating currents. This effect is noticeably large at 

typical operating currents, compared to other LED colors such as blue. Research has 

shown that the efficiency problem with green LEDs is inherent with the technology but it

can be mitigated through thicker quantum wells or growth of epitaxial layers along nonpolar or semi-polar directions in order to lower carrier density and thereby increase lamp 

efficacy. However, because research in these mechanisms to reduce efficiency droop is 

ongoing, DOE screened out this technology option based on the first criterion, 

technological feasibility, and will not consider improved emitter materials as a design 

option for improving the efficacy of GSLs. 

4.1.1.4 AC LEDs

By reducing conventional driver size or removing the driver component, 

complexity, and efficiency losses, AC-powered LEDs can increase performance of the 

LED lamp. AC LEDs integrate power conversion into the package, thus requiring few 

additional components. However, commercially available AC LED products are LED 

modules, rather than LED lamps. LED modules do not directly incorporate a power 

source or ANSI standard base within the device, thus it cannot be connected directly to 

the branch circuit. Because AC LEDs are not currently integrated into lamps, DOE 

screened out this technology option based on the second criterion, practicability to 

manufacture, install and service, and will not consider AC LEDs as a design option for 

improving the efficacy of GSLs. 

4.3 SUMMARY OF TECHNOLOGY OPTIONS SCREENED OUT

The following tables summarize the technology options DOE is considering 

screening out and the associated screening criteria.

Table 4.3.1 GSL Technology Options Screened Out of the Analysis

Technology Design Option Excluded Screening Criteria

CFL Multi-Photon Phosphors Technological feasibility

LED

Colloidal Quantum Dot 

Phosphors Technological feasibility

Improved Emitter Materials Technological feasibility

AC LEDs Practicability to manufacturer, install 

and service

4-3
4.4 REMAINING TECHNOLOGIES

After screening out those technologies in accordance with the policies set forth in 

10 CFR Part 430, Subpart C, Appendix A, (4)(a)(4) and 5(b), DOE is considering the 

design options in the following list as viable means for improving efficacy. These design 

options are being utilized in commercially available lamps and have demonstrated that 

they are technologically feasible, practicable to manufacture, install, and service, and do

not result in adverse impacts on product utility/availability or health and safety. The 

market and technology assessment (see chapter 3 of this TSD) provides a detailed 

description of these design options.

4.4.1 General Service Lamp Design Options

CFL Design Options

• Highly Emissive Electrode Coatings

• Higher Efficiency Lamp Fill Gas Composition

• Higher Efficiency Phosphors

• Glass Coatings

• Cold Spot Optimization

• Improved Ballast Components

• Improved Ballast Circuit Design

• Change in Technology

LED Design Options

• Efficient Down Converters (with the exception of colloidal quantum dots 

phosphors)

• Improved Package Architectures

• Alternative Substrate Materials

• Optimized Heat Sink Design

• Active Thermal Management Systems

• Device Level Optics

• Increased Light Utilization

• Improved Driver Design

• Reduced Current Density

4-4
REFERENCES

1 Do, Young-rag (Seoul, KR); Park, Do-hyung (Suwon-city, KR); Park, Woun-jhang 

(Boulder, CO, US); Summers, Christopher J. (Dunwoody, GA, US); Yang, Hong-guen 

(Suwon-City, KR). (2003). U.S. Patent No. 6669867.Washington, DC: U.S. Patent and 

Trademark Office.

2 U.S. Department of Energy Office of Building Technologies. U.S. Lighting Market 

Characterization, Volume II: Energy Efficient Lighting Technology Options. September,

2005. (Last accessed November 21, 2014). 

< http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/ee_lighting_vol2.pdf>

3 Scholand, Michael. (2012). Max Tech and Beyond: Fluorescent Lamps. Lawrence 

Berkeley National Laboratory. LBNL Paper LBNL-5403E. (Last accessed November 21, 

2014) <http://escholarship.org/uc/item/9569025t>

4 U.S. Department of Energy. SUNY/Buffalo Developing High-Efficiency Colloidal 

Quantum Dot Phosphors. July 11, 2013. (Last accessed November 21, 2014) 

<http://energy.gov/eere/ssl/sunybuffalo-developing-high-efficiency-colloidal-quantumdot-phosphors>

4-5
CHAPTER 5. ENGINEERING ANALYSIS

TABLE OF CONTENTS

5.1 INTRODUCTION ...........................................................................................................5-1

5.2 METHODOLOGY OVERVIEW....................................................................................5-1

5.3 ANALYSIS......................................................................................................................5-2

5.3.1 Representative Product Classes...........................................................................5-2

5.3.2 Integrated Product Class......................................................................................5-3

5.3.2.1 Existing Standards ...................................................................................5-3

5.3.2.2 Baseline Lamps........................................................................................5-4

5.3.2.3 More Efficacious Substitutes...................................................................5-5

5.3.2.4 Candidate Standard Levels ......................................................................5-6

5.3.3 Non-Integrated Product Class............................................................................5-12

5.3.3.1 Existing Standards .................................................................................5-12

5.3.3.2 Baseline Lamps......................................................................................5-12

5.3.3.3 More Efficacious Substitutes.................................................................5-13

5.3.3.4 Non-Integrated GSL Systems................................................................5-13

5.3.3.5 Candidate Standard Levels ....................................................................5-16

5.4 SCALING TO PRODUCT CLASSES NOT ANALYZED.......................................... 5-22

5.5 SUMMARY OF ALL EFFICACY LEVELS FOR COVERED GSLS ........................ 5-22

LIST OF TABLES

Table 5.3.1 Representative Product Classes for General Service Lamps.................................... 5-2

Table 5.3.2 Existing Efficacy Standards for Medium Base Compact Fluorescent Lamps..........5-3

Table 5.3.3 Integrated Product Classes Current Standard Efficacy Requirements...................... 5-3

Table 5.3.4 Integrated Product Classes’ Baseline Lamps............................................................ 5-5

Table 5.3.5 Integrated Product Classes’ Representative Units....................................................5-8

Table 5.3.6 Certification and Verification Testing Databases...................................................5-10

Table 5.3.7 Summary of CSLs for GSL Integrated Representative Product Classes................5-11

Table 5.3.8 Non-Integrated Product Class’s Baseline Lamp..................................................... 5-13

Table 5.3.9 Non-Integrated Product Class Design Representative Units.................................. 5-18

Table 5.3.10 Lamp Replacement Engineering Analysis for a One-Lamp Programmed Start 26 W 

Double Tube, 4,100 K System...................................................................................................5-21

Table 5.3.11 Summary of CSLs for GSL Non-Integrated Representative Product Class.........5-21

Table 5.5.1 Summary of All Efficacy Levels for Covered GSLs..............................................5-22

LIST OF FIGURES

Figure 5.3.1 CSLs for GSL Integrated Representative Product Classes....................................5-11

Figure 5.3.2 Graph of CSLs for GSL Non-Integrated Representative Product Class ...............5-20

5-i
CHAPTER 5. ENGINEERING ANALYSIS

5.1 INTRODUCTION

The U.S. Department of Energy (DOE) performed engineering analyses for general 

service lamps (GSLs). This chapter of the technical support document (TSD) provides the 

analyses DOE used to study representative lamps, to select candidate standard levels (CSLs), and 

to develop power rating estimates for the products analyzed. After selecting representative 

product classes, DOE then selects lamps that represent the baseline efficacy, as well as more 

efficacious substitutes for those baseline lamps. DOE uses these more efficacious lamps to 

develop CSLs. While DOE establishes CSLs based on lamp designs for the engineering analysis, 

for non-integrated GSLs it also develops lamp-and-ballast systems for use in the life-cycle cost 

(LCC) analysis and national impact analysis (NIA) because non-integrated compact fluorescent 

lamps and ballastsa operate together in practice.

In energy conservation rulemakings for other products, DOE often develops costefficiency relationships in the engineering analysis. However, for this rulemaking, DOE derives 

CSLs in the engineering analysis and end-user prices in the product price determination. By 

combining the results of the engineering analysis and the product price determination, DOE 

derives typical inputs for use in the LCC and NIA. See chapter 6 of this TSD for discussion of 

DOE’s methodology for determining product prices.

5.2 METHODOLOGY OVERVIEW

To the extent possible, DOE bases the engineering analysis on commercially available 

lamps that incorporate the design options identified in the technology assessment and screening 

analysis (chapters 3 and 4 of this TSD). The engineering analysis for the lamps DOE analyzes in 

this rulemaking (i.e., GSLs) takes the following four steps:

1. Select representative product classes: DOE first reviews covered lamps and the associated 

product classes. When multiple product classes are needed, DOE selects certain classes as 

“representative” and concentrates its analytical effort on these classes. DOE selects 

representative product classes primarily because of their high market volumes.

2. Select Baseline Lamps: For each representative product class, DOE selects a baseline lamp as 

a reference point against which to measure changes resulting from energy conservation 

standards. Typically, a baseline lamp is the most common, least efficacious lamp sold in a 

given product class. For this preliminary analysis, DOE used performance data presented in 

manufacturer catalogs to determine lamp efficacy. DOE also considers other lamp 

characteristics in choosing the most appropriate baseline for each product class such as 

lumen output, correlated color temperature (CCT), color rendering index (CRI), shape, and 

lifetime. 

3. Identify More Efficacious Substitutes: DOE selects higher efficacy lamps as replacements for 

each of the baseline lamps. When selecting higher efficacy lamps, DOE considers only 

a DOE is not considering setting standards for commercially available GSLs that operate using an external driver at 

this time. 

5-1

 
design options that meet the criteria outlined in the screening analysis (chapter 4 of this

TSD). For non-integrated GSLs, DOE pairs each representative unit with an appropriate 

ballast because non-integrated GSLs are a component of a system, and their performance is 

related to the ballast on which they operate.

4. Determine Candidate Standard Levels: After identifying more efficacious substitutes for 

each baseline lamp, DOE develops CSLs. DOE bases its analysis on three factors: (1) the 

design options associated with the specific lamps studied; (2) the ability of lamps across the 

lumen range to comply with the CSL of a given product class;

b and (3) the maximum 

technologically feasible efficacy level. DOE then scales the CSLs of representative product 

classes to those product classes not directly analyzed.

The sections that follow discuss how DOE applies this methodology to each GSL product

class to create the engineering analysis.

5.3 ANALYSIS

5.3.1 Representative Product Classes

As discussed in the market and technology assessment, DOE is considering three product

classes for GSLs based on two class-setting factors: ballast/driver location (i.e., integrated or 

non-integrated) and lumen package. See chapter 3 of this TSD for more details. DOE typically 

chooses representative product classes based on the highest shipment volume. In this preliminary 

analysis, DOE is considering directly analyzing all product classes for GSLs. DOE is considering 

directly analyzing both the integrated and non-integrated product classes because of 

technological differences that would preclude scaling from the high volume integrated product 

class. Specifically, DOE observed different efficacy trends and maximum technologically 

feasible levels between the two classes. Manufacturer feedback also indicated that scaling 

between the integrated and non-integrated product classes is not appropriate. Further, for the 

integrated product class, DOE is considering directly analyzing both the low lumen and high 

lumen product classes. DOE has found that there are technological limitations to producing high 

lumen (i.e., 2,000 lumens or greater) GSLs using light-emitting diode (LED) technology and 

therefore CSLs for this product class cannot be scaled from the low lumen integrated product 

class.

Table 5.3.1 lists the representative product classes that DOE is considering in this 

preliminary analysis.

Table 5.3.1 Representative Product Classes for General Service Lamps

Lamp Type Lumen Output

Integrated GSLs 310-1,999

2,000-2,600

Non-Integrated GSLs 310-2,600

b CSLs span multiple lamps of different lumen outputs and wattages. In selecting CSLs, DOE considered whether 

these multiple lamps can meet the standard levels.

5-2

 
5.3.2 Integrated Product Class

5.3.2.1 Existing Standards

Energy conservation standards currently exist for medium base compact fluorescent 

lamps (MBCFLs). Bare and covered MBCFLs are subsets of compact florescent lamps, which 

are included in the definition of GSL. DOE has the authority to evaluate energy conservations 

standards for compact fluorescent lamps (CFLs), including MBCFLs, in this GSL rulemaking.

(42 U.S.C. 6291(30)(BB)) The Energy Policy and Conservation Act (EPCA) contains an “antibacksliding” provision which prevents DOE from prescribing any amended standard that either 

increases the maximum allowable energy use or decreases the minimum required energy 

efficiency of a covered product. (42 U.S.C. 6295(o)(1)) Therefore, any standard prescribed for 

GSLs that is applicable to MBCFLs must not backslide from existing standards. The existing 

standards for MBCFLs are summarized in Table 5.3.2. 

Table 5.3.2 Existing Efficacy Standards for Medium Base Compact Fluorescent Lamps

Configuration

Lamp Power Minimum Efficacy

W lm/W

Bare Lamp

< 15 45.0

> 15 60.0

Covered Lamp (No Reflector)

< 15 40.0

15 < Lamp Power < 19 48.0

19 < Lamp Power < 25 50.0

> 25 55.0

MBCFLs fall within the integrated low lumen and integrated high lumen product classes. 

Because DOE determined that lamp configuration (i.e., bare or covered) is not a class setting 

factor in the product class structure proposed in this analysis, the baseline efficacy requirements 

are determined by lamp wattage. Therefore, for products with wattages less than 15 watts (W), 

which fall into the integrated low lumen product class, DOE set the baseline efficacy at 45 lm/W

(the highest of the existing standards for that wattage range) to prevent backsliding. For products 

with wattages greater than or equal to 15 W, which fall into the integrated high lumen product 

class, DOE set the baseline efficacy at 60 lm/W to prevent backsliding. The baseline efficacy 

requirements for the integrated product classes are shown in Table 5.3.3. 

Table 5.3.3 Integrated Product Classes Current Standard Efficacy Requirements

Product Class Lamp Power Minimum Efficacy

W lm/W

Integrated Low Lumen (310-

1,999 Lumens) < 15 45.0

Integrated High Lumen 

(2,000-2,600 Lumens) > 15 60.0

5-3
5.3.2.2 Baseline Lamps

For each representative product class, DOE selects baseline lamps that are typically the 

most common, least efficacious lamps that meet existing standards (when applicable). To 

identify baseline lamps, DOE reviews product offerings in catalogs, shipment information, and 

manufacturer feedback obtained during interviews. DOE determines the most common product 

characteristics such as lumen output range, shape, lifetime, CCT, and CRI. Among lamps with 

those characteristics, DOE selects the least efficacious product as the baseline. 

Integrated Low Lumen Product Class. DOE first identified the common characteristics 

of the integrated low lumen product class. DOE utilized a database of commercially available 

GSLs when determining common lamp characteristics. For the integrated low lumen product 

class, DOE found that the most common lamps are 60 W equivalent lamps which produce lumen 

output in the range of 700-900 lumens. Manufacturer feedback confirmed that 60 W equivalent 

general service incandescent lamp (GSIL) replacements are the GSLs shipped in the highest 

volume. DOE also found that CFLs are the most common lamp technology, and spiral and “Ashape” are the most common shapes. DOE analyzed the commercially available CFLs in the 

integrated low lumen product class and determined that a rated lifetime of 10,000 hours was 

most common. Further, DOE found that the vast majority of CFLs in the integrated low lumen 

product class have a CCT of 2,700 Kelvin (K) and CRI of 80 to 82. 

Of lamps with the common characteristics identified, DOE then selected the least 

efficacious lamp to represent the baseline. While 13 W spiral CFLs are the most common lamps 

for the associated lumen range, DOE found that these lamps are not the least efficacious and 

typically perform well above the applicable existing standard for MBCFLs. Covered CFLs, such 

as A-shape CFLs, replicate the traditional shape of GSILs and tend to have lower efficacies

compared to spiral CFLs. Therefore, DOE has preliminarily selected an A-shape 14 W CFL with 

lumen output of 750 lumens (53.6 lm/W) as the baseline. The baseline lamp has a medium screw

(E26) base, a rated lifetime of 10,000 hours, a CCT of 2,700 kelvin (K) and a CRI of 80.

Integrated High Lumen Product Class. For the high lumen integrated product class, 

DOE found that the most common lamps are 125 W equivalent lamps which produce lumen 

output in the range of 2,000-2,600 lumens. DOE found at this time that CFLs are the only lamp 

technology commercially available in the high lumen integrated product class. Further, DOE 

found that the vast majority of products in the integrated high lumen product class were spiral 

shape CFLs. Similar to the low lumen product class, DOE analyzed the commercially available 

CFLs in the integrated high lumen product class and determined that a rated lifetime of 10,000 

hours was most common. Further, DOE found that CFLs in the integrated high lumen product 

class most commonly have a CCT of 2,700 K and CRI of 80 or above.

Of lamps with the common characteristics identified, DOE then selected the least 

efficacious lamp to represent the baseline. DOE has preliminarily selected a spiral 32 W CFL 

with lumen output of 2,000 lumens (62.5 lm/W) as the baseline. The baseline lamp has a medium 

screw (E26) base, a rated lifetime of 10,000 hours, a CCT of 2,700 K, and a CRI of 80, all of 

which are common characteristics of the integrated high lumen product class.

5-4
Table 5.3.4 lists the specifications for the baseline lamps DOE is considering for the 

integrated product classes.

Table 5.3.4 Integrated Product Classes’ Baseline Lamps

Product 

Class

Lamp 

Shape

Base 

Type

Lamp 

Type

Nominal 

Wattage

Initial 

Lumens

Rated 

Efficacy Lifetime CCT CRI

W lm lm/W hr K

Integrated 

Low Lumen 

(310-1,999 

Lumens)

A-Shape E26 CFL 14 750 53.6 10,000 2,700 80

Integrated 

High Lumen 

(2,000-2,600 

Lumens)

Spiral E26 CFL 32 2,000 62.5 10,000 2,700 80

5.3.2.3 More Efficacious Substitutes

After choosing a baseline lamp for each representative product class, DOE identifies 

more efficacious substitutes. When identifying higher efficacy replacement lamps, DOE used 

lamp efficacy values determined using catalog lumens and catalog wattage. DOE utilized a 

database of commercially available lamps and selected more efficacious replacement lamps that 

both save energyc and maintain comparable light output to the baseline lamp when possible. 

Specifically, DOE ensured that potential substitutions maintained light output within ten percent 

of the baseline lamp lumen output. Further, DOE considered only technologies that met all four 

criteria in the screening analysis.

DOE also sought to keep characteristics of substitute lamps as similar as possible to the 

baseline lamps. DOE selected more efficacious substitutes with same base type as the baseline 

lamp because replacing an integrated lamp with a lamp of a different base type would potentially 

require a fixture or socket change and is thus considered an unlikely replacement. In addition to 

maintaining a consistent base type, DOE maintained a CCT of 2,700 K for all replacements. 

Manufacturer feedback indicated that differences between the common, nominal CCTs (e.g., 

2,700 K to 3,000 K) would be noticeable by the consumer, and therefore DOE did not consider a 

change in CCT to be viable for higher efficacy replacements. DOE maintained a CRI in the 

range of 80 to 82. DOE also selected replacement lamp units with lifetimes greater than or equal 

to the lifetime of the baseline lamp. For LED lamps, DOE utilized the L70 lifetime values, which 

is consistent with DOE’s proposal in the LED test procedure (TP) supplementary notice of 

proposed rulemaking (SNOPR).d

DOE also ensured that the LED lamps considered as more efficacious substitutes were 

marketed as omnidirectional, thus maintaining the uniform light distribution of the baseline 

lamp. Based on manufacturer feedback, DOE found that the majority of manufacturers consider 

lamps to be omnidirectional if they meet the performance requirements of the ENERGY STAR® 

c DOE considers substitutions that both save energy and do not save energy in the NIA.

d DOE’s LED TP SNOPR can be found here:

http://www.regulations.gov/#!documentDetail;D=EERE-2011-BT-TP-0071-0022

5-5

 
definitione for omnidirectional lamps. Omnidirectional lamps evenly distribute light in all 

directions, whereas the light distribution of semi-omnidirectional lamps is more directed. Some 

manufacturers noted that semi-omnidirectional lamps are cheaper products that are not desired 

by the consumer. Further, some manufacturers stated that semi-omnidirectional lamps cannot be 

used in the same application as omnidirectional lamps. DOE found several lamps marketed as 

semi-omnidirectional. However, to ensure that the more efficacious substitutes could be used in 

the same applications as the baseline lamps, DOE only considered lamps that were marketed as 

omnidirectional in the analysis.

5.3.2.4 Candidate Standard Levels

After identifying more efficacious substitutes for each of the baseline lamps, DOE 

develops CSLs based on the consideration of several factors, including: (1) the design options 

associated with the specific lamps being studied (e.g., grades of phosphor for CFLs, improved 

package architecture for LEDs); (2) the ability of lamps across the applicable lumen range to 

comply with the standard level of a given product class; and (3) the maximum technologically 

feasible (“max tech”) level. DOE used commercially available lamps and their associated catalog 

efficacies to determine the design options required to meet each CSL. DOE used catalog data as 

the basis of its engineering analysis because it is the largest and most comprehensive dataset. To 

establish final minimum efficacy requirements for each CSL, DOE evaluated whether any 

adjustments were necessary to the initial CSLs to ensure lamps were available across the entire 

lumen range represented by the product class.

DOE adopted an equation-based approach to establish CSLs for GSLs, reflecting the 

relationship between efficacy and lumen output. Because the lamps covered by the scope of this 

rulemaking span different lighting technologies, GSLs designed to satisfy the same applications 

are available in a variety of wattages. Further, DOE believes that the primary utility provided by 

a lamp is lumen output which can be achieved through a wide range of wattages depending on 

the lamp technology. For these reasons, DOE believes that lamps providing equivalent lumen 

output, and thus intended for the same applications, should be subject to the same minimum 

efficacy requirements. DOE developed a smooth, continuous equation that specifies a minimum 

efficacy requirement across lumen output and represents the potential efficacy a lamp achieves 

using a particular design option. Because the equations account for changes in efficacy due to

lumen output, they can also account for market shifts to new lumen packages.

DOE utilized a database of commercially available lamps to evaluate efficacy trends of 

integrated GSLs at different lumen outputs. DOE acknowledges that lower lumen output GSLs 

tend to be less efficacious than higher lumen output GSLs and is considering CSLs with a curved 

shape rather than a horizontal line for that reason. Specifically, DOE believes that fixed losses in 

GSLs, such as power consumed by the integrated ballast/driver, become proportionally smaller at 

higher lumen outputs thereby increasing efficacy. Using the database of commercially available 

integrated GSLs, DOE conducted regression analyses on a number of different equation forms to 

find the form that best fit the efficacy trend. DOE included lamps that met the definition of GSL 

but were outside the lumen range of 310 – 2,600 lumens because DOE believes this dataset 

e The ENERGY STAR Program Requirements for Lamps (Light Bulbs) V1.1 specifies luminous intensity 

distribution requirements for omnidirectional light sources and is available here: 

http://www.energystar.gov/sites/default/files/ENERGY%20STAR%20Lamps%20V1%201_Specification.pdf.

5-6

 
results in a curve that better represents the relationship between efficacy and lumen output for 

the technologies analyzed. DOE confirmed the curve fit matched product performance 

particularly in the low and high ends of the GSL lumen range. DOE also ran regression analyses 

for the equation forms under consideration on subsets of integrated GSLs by technology (i.e. 

only CFLs or only LEDs) and by manufacturer in order to verify the efficacy trends. The 

equation form DOE selected for this preliminary analysis, a decaying exponential, was chosen 

based on its consistent ability to fit the data well (measured by R2 valuef

) across the subsets of 

data. DOE is considering establishing CSLs based on an equation for efficacy using lumens as 

the input in the following form:

EEEEEEEEEEEEEEEE = AA − 29.42 ∗ 0.9983LLLLLLLLLLLL

Eq. 5.1

Where:

Efficacy = minimum efficacy requirement,

Lumens = measured lumen output, and

A = an adjustment variable (the “A-value”).

After identifying more efficacious substitutes, DOE calculated the A-value of the 

equation using catalog lumen output and catalog efficacy for each representative lamp unit. The 

A-value is an adjustment variable that shifts the equation in a vertical direction and is calculated 

to represent certain levels of efficacy. DOE evaluated the equation against lamps with the same 

design options as the representative lamp unit for each CSL and made slight adjustments to 

capture the efficacy of lamps with those design options across the entire lumen output range thus 

allowing for continuous CSLs across the integrated product classes. 

In general terms, for the integrated low lumen product class, DOE based its CSLs on 

design options described below.

CSL 1: This level represents an improved CFL with more efficient phosphors and 

improved ballast components. 

CSL 2: This level represents a basic LED lamp with an efficacy near the lowest 

performing LED lamps currently available on the market. 

CSL 3: This level represents an improved LED lamp with improved package architecture, 

high efficiency driver, and improved optics. 

CSL 4: This level represents an advanced LED lamp with further improved package 

architecture, high efficiency driver, and improved optics. 

CSL 5: This level is the maximum technologically feasible level and represents an LED 

lamp with the most efficacious combination of package architecture, driver, and optics available 

on the market today.

f R2 is calculated based on the difference between all observed values (in this case catalog efficacy) versus the 

modelled values. As the fitted equation becomes closer to modelling the observed values, the R2 value will increase.

5-7

 
For the integrated high lumen product class, DOE based its CSLs on the design options described below.

CSL 1: This level represents an improved CFL with more efficient phosphors and improved ballast components. 

CSL 2: This level is the maximum technologically feasible level and represents the most efficacious combination of phosphors 

and ballast components.

Table 5.3.5 provides detailed information on the representative lamps in the integrated product classes used in the engineering 

analysis and subsequent analyses.

Table 5.3.5 Integrated Product Classes’ Representative Units

Product Class CSL A-value Lamp 

Shape

Base 

Type

Lamp 

Type

Nominal 

Wattage

Initial 

Lumens

Rated 

Efficacy Lifetime CCT CRI

W lm lm/W hr K

Integrated Low 

Lumen

(310-1,999 

Lumens)

Baseline 61.7 A-Shape E26 CFL 14 750 53.6 10,000 2,700 80

CSL 1 69.0 Spiral E26 CFL 13 800 61.5 12,000 2,700 82

CSL 2 74.2 A-Shape E26 LED 12 800 66.7 25,000 2,700 82

CSL 3 80.2 A-Shape E26 LED 11 800 72.7 25,000 2,700 81

CSL 4 87.5 A-Shape E26 LED 10 800 80.0 25,000 2,700 82

CSL 5 91.7 A-Shape E26 LED 9.5 800 84.2 25,000 2,700 80

Integrated High 

Lumen

(2,000-2,600 

Lumens)

Baseline 63.4 Spiral E26 CFL 32 2,000 62.5 10,000 2,700 80

CSL 1 67.6 Spiral E26 CFL 30 2,000 66.7 10,000 2,700 82

CSL 2 76.5 Spiral E26 CFL 29 2,200 75.9 12,000 2,700 82

5-8
As stated, DOE found it was necessary to make slight adjustments to the minimum 

efficacy requirements of the CSLs to develop levels that were continuous across the integrated 

product classes and representative of lamps across the entire lumen range. At CSL 1, DOE found 

that the calculated A-value of the representative unit in the integrated low lumen product class 

was slightly higher than the A-value of the representative unit in the integrated high lumen 

product class (i.e., 69.0 versus 66.7). Conversely, at CSL 2, DOE found that the calculated Avalue of the representative unit in the integrated high lumen product class was slightly higher 

than the representative unit in the integrated low lumen product class (i.e., 76.5 versus 74.2). To 

avoid discontinuities in efficacy between the two product classes, DOE made adjustments 

downward to allow for continuous CSLs across the integrated product classes. Therefore, DOE 

utilized the minimum A-value of the representative units at each CSL to set the minimum 

efficacy requirements of CSL 1 and CSL 2 (i.e., 66.7 and 74.2, respectively). 

In addition, DOE made adjustments to ensure that lamps were available across the entire 

lumen range. Specifically, DOE adjusted CSL 5, the max-tech level, in the low lumen product 

class downward from an A-value of 91.7 to 90.8. DOE made this adjustment to account for the 

performance of commercially available products at the 100 W GSIL equivalency. Thus, DOE 

ensured that lumen packages throughout the low lumen product class would be maintained, even 

at the highest CSL. DOE did not find it was necessary to make any adjustment for 40 W GSIL 

equivalents as commercially available products with the common characteristics are able to meet 

the max tech level. Though DOE did not find a commercially available 75 W equivalent GSIL

with the common characteristics meeting max tech, DOE believes the level is technologically 

feasible as both 60 W equivalent and 100 W equivalent lamps can meet the max-tech level under 

consideration.

DOE also used publicly available certification data and verification testing data from the 

California Energy Commission’s (CEC’s) Appliance Efficiency Certified Light Bulbs Database,

g

DOE’s LED Lighting Facts Product List,

h the U.S. Environmental Protection Agency’s (EPA’s)

ENERGY STAR Certified Light Bulbs database,i

and DOE’s Compliance Certification 

Management System (CCMS) databasej

when possible to verify the CSLs were achievable. The 

GSL types found in each database are outlined in Table 5.3.6. DOE matched the certification and 

verification testing data with catalog values for GSLs and found that both the mean and median 

efficacy of all matched products were higher in the compliance and verification databases than 

the mean and median catalog values for all matched products for each of the certification and 

verification databases analyzed. 

g Certification data is publicly available on CEC’s Appliance Efficiency Database available here:

http://www.appliances.energy.ca.gov/Default.aspx. h DOE’s LED Lighting Facts Product List is publicly available here: http://www.lightingfacts.com/products. i

EPA’s ENERGY STAR Certified Light Bulbs database is publicly available here: 

http://www.energystar.gov/productfinder/product/certified-light-bulbs/results. j

DOE’s Compliance Certification Database is publicly available here: www.regulations.doe.gov/certification-data/.

5-9

 
Table 5.3.6 Certification and Verification Testing Databases

Database GSL Types Included in Database*

CEC Appliance Efficiency Database Medium base CFLs, medium base LED 

lamps, GU24 base CFLs, GU24 base LED 

lamps

LED Lighting Facts Product List Medium base LED lamps, GU24 base LED 

lamps

Energy Star Certified Light Bulbs Medium base CFLs, medium base LED 

lamps, GU24 base CFLs, GU24 base LED 

lamps

DOE Compliance Certification Management 

System

Medium base CFLs

* This table does not include all lamp types reported in the databases. The GSL types listed in this table are only 

those that DOE is considering setting standards for and thus used in the engineering analysis.

DOE also used the supplementary data to assess the individual performance of the 

representative units and equivalent lamps. DOE found that the representative units’ catalog 

efficacies were supported by the certification and verification testing databases. Additionally, 

DOE found that the efficacy of certified and verified products with similar specificationsk to 

those selected as representative units were, in the vast majority of cases, equally or more 

efficacious than stated by catalog value. Therefore, DOE determined that no further downward 

adjustments to CSLs were necessary based on additional compliance and testing data.

Lastly, DOE examined the performance of different types of bulbs that are subject to 

standards including 3-way lamps and dimmable lamps. DOE found dimmable lamps performing 

at max tech, including those selected as substitutes, and found no reason to make adjustments on 

that basis. DOE also found 3-way lamps performing at max tech and therefore made no further 

adjustments to the max-tech level.

DOE notes that data outliers were identified in its review of efficacy values from the 

compliance and verification testing databases. DOE identified outliers both on the high and low 

end, and in cases where DOE was unable to verify the value using third party data or 

manufacturer confirmation, did not consider the lamp in the engineering analysis.

Figure 5.3.1 illustrates the five CSLs for the integrated low lumen product class and the 

two CSLs for the integrated high lumen product class on a plot with the representative lamp 

units. The line at 45.0 lm/W for wattages less than or equal to 15 W and 60.0 lm/W for wattages 

greater than 15 W denotes the existing energy conservation standard. The red triangles identify 

the baseline lamps. The plot also shows more efficacious substitutes that DOE considered as 

replacements, which are denoted by square boxes. These replacements were selected such that 

they have increased efficacy compared to the previous level while maintaining light output 

within ten percent of the baseline lamp.

k Products were deemed similar if they matched the representative units same technology, lamp shape, base type, 

wattage, and CCT while having a minimum CRI of 80 and a lumen output between 700-900 lumens. 

5-10

 
Figure 5.3.1 CSLs for GSL Integrated Representative Product Classes

Table 5.3.7 summarizes the resulting efficacy requirements at each CSL after accounting 

for any adjustments made and rounding A-values to the nearest tenth.

Table 5.3.7 Summary of CSLs for GSL Integrated Representative Product Classes

Representative Product Class Candidate Standard Level Efficacy

lm/W

Integrated Low Lumen

(310 – 1,999 Lumens)

CSL 1 67.6-29.42*0.9983^Lumens

CSL 2 74.2-29.42*0.9983^Lumens

CSL 3 80.2-29.42*0.9983^Lumens

CSL 4 87.5-29.42*0.9983^Lumens

CSL 5 90.8-29.42*0.9983^Lumens

Integrated High Lumen

(2,000 – 2,600 Lumens)

CSL 1 67.6-29.42*0.9983^Lumens

CSL 2 74.2-29.42*0.9983^Lumens

CSL 1

CSL 2

CSL 3

CSL 4

CSL 5

Existing Standard

40.0

50.0

60.0

70.0

80.0

90.0

100.0

0 500 1000 1500 2000 2500 3000

Efficacy (lm/W)

Lumens (lm)

Baseline

CSL 1

CSL 2

CSL 3

CSL 4

CSL 5

5-11
5.3.3 Non-Integrated Product Class

5.3.3.1 Existing Standards

The non-integrated product class does not have any existing applicable energy 

conservation standards.

5.3.3.2 Baseline Lamps

For each representative product class, DOE selects baseline lamps that are typically the 

most common, least efficacious lamps that meet existing standards (when applicable). Because 

the non-integrated product class does not have applicable existing standards, the lowest efficacy 

lamps on the market were considered. To identify baseline lamps, DOE reviews product 

offerings in catalogs, shipment information, and manufacturer feedback obtained during 

interviews. DOE determines the most common product characteristics such as lumen output 

range, shape, lifetime, CCT, and CRI. Among lamps with those characteristics, DOE selects the 

least efficacious product as the baseline. For the non-integrated product class, DOE used rated 

efficacylto evaluate representative lamps for this analysis.

Similar to the integrated product class, DOE first identified the common characteristics of 

the non-integrated product class. DOE utilized a database of commercially available GSLs when 

determining common lamp characteristics. In this preliminary analysis, DOE is only considering 

setting standards for non-integrated CFLs. (See chapter 2 of this TSD for more information on 

scope.) DOE found that the base types of non-integrated CFLs typically correspond to certain 

wattages and lumen outputs, and thus DOE concentrated on a common wattage and its associated 

base type. The most common non-integrated GSL wattages that DOE identified based on its 

database of commercially available GSLs are 13 W, 18 W, and 26 W which typically correspond 

to lumen outputs in the range of 700-900, 1,000-1,300, and 1,500-1,800 lumens, respectively. 

Using manufacturer feedback, DOE confirmed that 26 W CFLs are the highest volume nonintegrated GSLs. DOE identified three shapes that comprised the vast majority of non-integrated 

GSLs: single tube, double tubem, and triple tube. While non-integrated CFLs of the same wattage 

are sometimes offered in different lamp shapes, DOE found the double tube shape to be the most 

common shape associated with 26 W CFLs. DOE found the most common base type associated 

with 26 W double tube CFLs to be the G24q-3 base. DOE analyzed the commercially available 

lamps in the non-integrated product class and determined that a 10,000 hour lifetime was most 

common. Further, DOE identified a CCT of 4,100 K to be the most prevalent across the nonintegrated product class. DOE also found that the vast majority of products in the non-integrated 

product class have a CRI of 80 to 82. 

Of lamps with the common characteristics identified, DOE then selected the least 

efficacious lamp. As stated previously, the non-integrated product class does not have applicable 

existing standards and therefore the lowest efficacy lamps on the market were considered. DOE 

has preliminarily selected a 26 W double tube CFL with G24q-3 base and lumen output of 1,710 

l

For the non-integrated GSLs analyzed, the rated efficacy is the initial lumen output published in manufacturer 

catalogs divided by the American National Standards Institute (ANSI) rated wattage. For lamp types that do not 

have a defined ANSI rated wattage, DOE utilized the lamp’s nominal wattage to calculate rated efficacy. m The double tube shape for CFLs, that is, a CFL with two U-shaped glass tubes, is also sometimes referred to as 

quad tube in industry. 

5-12

 
lumens (65.8 lm/W) as the baseline. The baseline lamp has a lifetime of 10,000 hours, a CCT of 

4,100 K, and a CRI of 82, all of which are common characteristics of the non-integrated product 

class.

Table 5.3.8 lists the specifications for the baseline lamp DOE is considering for the nonintegrated product class. 

Table 5.3.8 Non-Integrated Product Class’s Baseline Lamp

Lamp 

Shape

Base 

Type

Lamp 

Type

Nominal 

Wattage

Rated 

Wattage

Initial 

Lumens

Mean 

Lumens

Rated 

Efficacy Lifetime CCT CRI

W W lm lm lm/W hr K

Double 

Tube G24q-3 CFL 26 26 1,710 1,450 65.8 10,000 4,100 82

5.3.3.3 More Efficacious Substitutes

After choosing a baseline lamp for the representative product class, DOE identifies more 

efficacious substitutes. Similar to the selection of baseline lamps, DOE used the rated efficacy to 

evaluate more efficacious replacement lamps in its analysis. DOE utilized a database of 

commercially available lamps and selected more efficacious replacement lamps that did not 

increase energy consumption relative to the baseline and had light output within ten percent of 

the baseline lamp-and-ballast system when possible. (See section 5.3.3.4 for more information on 

lamp-and-ballast systems.) For the non-integrated product class, DOE identified substitute lamps 

that were the same wattage as the baseline but produced more light and were therefore more 

efficacious, or lamps that were lower wattage than the baseline but produced similar light and 

were therefore more efficacious. Further, DOE considered only technologies that met all four 

criteria in the screening analysis.

DOE also sought to keep characteristics of substitute lamps as similar as possible to the 

baseline lamp. Due to potential physical and electrical constraints associated with switching base 

types, DOE selected substitute lamps that had the same base type as the baseline lamp. In 

addition to maintaining a consistent base type, DOE maintained a CCT of 4,100 K for all 

replacements. As discussed in section 5.3.2.3, manufacturer feedback indicated that differences 

between the common, nominal CCTs would be noticeable by the consumer; therefore, DOE did 

not consider a change in CCT to be viable for higher efficacy replacements. DOE maintained a 

CRI in the range of 80 to 82. DOE also selected replacement lamp units with lifetimes greater 

than or equal to the lifetime of the baseline.

5.3.3.4 Non-Integrated GSL Systems

Because non-integrated GSLs operate with an external power converter (i.e., ballast, 

driver, or other transformer) in practice, DOE analyzed lamp-and-ballast systems in the 

engineering analysis. DOE is not considering setting standards for any non-integrated 

incandescent or LED lamps at this time and therefore only considered non-integrated CFL and 

ballast systems in this preliminary analysis. (See chapter 2 of this TSD for more information on 

scope.) DOE believes that pairing these lamps with a ballast more accurately captures real-world

energy use and light output.

5-13
DOE is aware that lumen package is an important consideration for consumers. If 

consumers do not have the option to purchase substitute lamp systems with similar lumen 

packages, a modification in the lighting design of their space (e.g., change in fixture spacing) 

may be required to maintain a similar light output. In assessing light output of the representative 

systems, DOE made a distinction between mean and initial lumen output. Consistent with 

industry consensus on efficacy measurements, DOE used catalog initial lumen output to 

calculate efficacy when determining CSLs. However, the light output of a lamp decreases over 

time. To account for this real-world depreciation in lumens, DOE analyzed more efficacious

systems that maintain mean lumen output within ten percent of the baseline system, when 

possible. Mean lumen output is a measure of light output midway through the rated life of a 

lamp, and a ten percent change is a common parameter used by lighting designers to specify 

acceptable substitute products on the basis of light output.

In the LCC analysis, DOE considers lamp purchase events, or events that cause a 

consumer to purchase a new lamp. For GSLs, DOE determined that consumers may purchase a 

new lamp to operate on an existing ballast. For this lamp replacement scenario, DOE selects 

more efficacious full wattage and reduced wattage replacement lamps that can operate on the 

installed ballast. DOE only selected replacement lamps that do not have higher energy 

consumption than the baseline.

For the lamp replacement scenario, DOE determined energy consumption by calculating 

the system input power of the lamp-and-ballast system. The system input power represents the 

energy consumption rate of both the lamp and ballast, and therefore is greater than the rated 

power of the lamp alone. In addition to the rated lamp power, the system power is also affected 

by the number of lamps operated per ballast, type of ballast used (i.e., electronic or magnetic), 

starting method, and the ballast factor (BF)n of that ballast.

The following sections discuss in more detail how DOE selected a ballast for the 

representative lamp-and-ballast pairings and its methodology for calculating system input power.

Ballast Selection. Although DOE identifies more efficacious substitutes based on lamp 

characteristics alone, DOE pairs non-integrated GSLs with representative ballasts because the 

non-integrated GSLs analyzed in this preliminary analysis (i.e., non-integrated CFLs) operate on 

a ballast in practice. To develop representative lamp-and-ballast system pairings, DOE 

determined the most common non-integrated CFL ballasts based on manufacturer feedback and a 

survey of the market. DOE identified the most common number of lamps operated per ballast, 

starting method by ballast type, and mode of operation (i.e., electronic or magnetic). Based on 

this assessment, DOE chose to analyze one-lamp programmed start (PS) electronic ballasts as

representative of the lamp-and-ballast combinations present in the market. Manufacturer 

feedback confirmed that these are among the most common characteristics of non-integrated 

CFL ballasts.

n BF is defined as the output of a ballast delivered to a reference lamp in terms of power or light divided by the 

output of the relevant reference ballast delivered to the same lamp (ANSI C82.13-2002). Because BF affects the 

light output of the system, manufacturers design ballasts with a range of ballast factors to allow consumers to vary 

the light output, and thus power consumed, of a fluorescent system. See the 2011 Ballast Rule final rule TSD 

Chapter 3.

5-14

 
After determining the representative lamp-and-ballast system pairing, DOE selected a 

specific ballast model to use in the systems analyzed. DOE utilized a database of commercially 

available CFL ballast models to determine the ballast that represents the product that is most 

likely to be installed in 2020. DOE identified a ballast model with typical light output (i.e., BF) 

and efficiency (i.e., ballast luminous efficiency [BLE]). DOE found that the majority of the 

commercially available CFL ballasts had normal BFs (close to 1.0). Because CFL ballasts are not 

covered by standards, DOE believes that the ballast models of average efficiency would be most 

representative of the market. DOE determined that the BLEo of one-lamp PS normal BF CFL 

ballasts that are compatible with the non-integrated representative units ranged from 81.1 to 96.2.

CFL ballasts operate specific base types, thus DOE selected a ballast model that was compatible 

with the base type of the baseline lamp and more efficacious substitutes. Therefore for this 

preliminary analysis, DOE paired the non-integrated representative units with a one-lamp, PS

electronic ballast with a BF of 1.04 and an average BLE of 90.2.

System Input Power Calculation. After selecting a ballast to pair with the representative 

units, DOE then calculated the system input power. The system input power depends on both the 

total lamp arc power operated by the ballast and the ballast’s efficiency, or BLE. DOE first 

calculated the total lamp arc power of the system by multiplying the catalog BF, number of 

lamps operated by the ballast, and the high frequency reference lamp arc power. Because DOE 

selected an electronic ballast for this preliminary analysis, all lamp-and-ballast systems were 

high frequency. If a high frequency reference arc power was not available for a specific lamp 

type, DOE used the nominal wattage.

For ballasts paired with full wattage lamps, DOE next determined BLE using catalog 

ballast efficacy factorp (BEF) for the selected ballast model. DOE calculated the BLE by 

multiplying the catalog BEF, high frequency reference arc power, and number of lamps operated 

by the ballast. Using the calculated total lamp arc power and converted BLE value of the ballast 

model, DOE then calculated the system input power, or ballast input power, using Eq. 5.1. This 

process was repeated for each full wattage lamp-and-ballast system pairing.

BBBB = TTTTTT TT LLLL AAAA PP PPPP

BB BB IIII II PP PPPP ∗ 100 ∗ ββ

Eq. 5.1

Where:

β = 1.0 for high frequency ballasts

Because the ballast specifications when operating reduced wattage lamps were not 

published, DOE had to determine the expected reduced wattage BLE using the known powerefficiency relationship of ballasts. In the 2011 Ballast Rule, DOE developed a power law 

equation to model the trend between total lamp arc power and average BLE. The power law 

equation followed the form:

o Ballast luminous efficiency is the ratio of the total lamp arc power to ballast input power multiplied by the 

appropriate frequency adjustment factor. p Ballast efficacy factor is equal to relative light output divided by input power.

5-15

 
BBBB = AA

1 + BB ∗ −CC

Eq. 5.2

Where:

power = total lamp arc power

Similar to the full wattage system, DOE first calculated the total lamp arc power of the 

reduced wattage lamp-and-ballast system. DOE assumed that BF does not change when 

operating reduced wattage lamps and therefore used the catalog BF of the ballast when operating 

full wattage lamps to calculate the total lamp arc power for both full wattage and reduced 

wattage systems.

In general, as lamp arc power increases or decreases, BLE increases or decreases as well. 

In the 2011 Ballast Rule, DOE defined this relationship using Eq. 5.2. In this rulemaking, DOE 

assumed that this relationship holds true for individual ballasts. Therefore, DOE assumed that an 

individual ballast operating full wattage lamps would have the same coefficient B when 

operating reduced wattage lamps. Using this assumption, DOE calculated the selected ballast 

model’s coefficient B when operating full wattage lamps using the converted full wattage BLE 

value, the calculated total lamp arc power at full wattage, and the appropriate exponent C, which 

is dependent on the ballast starting method, and was found to be 0.37 for programmed start 

ballasts.

q The coefficient A was assumed to be one.r DOE was then able to calculate the new 

BLE when operating reduced wattage lamps by using the total lamp arc power when operating 

reduced wattage lamps and keeping the coefficient B, the exponent C, and the coefficient A the 

same. Given this expected BLE and total lamp arc power calculated in the previous steps, DOE 

determined the system input power of the reduced wattage lamp-and-ballast system using Eq. 

5.1.

5.3.3.5 Candidate Standard Levels

After identifying more efficacious substitutes for the baseline lamp, DOE develops CSLs 

based on the consideration of several factors, including: (1) the design options associated with 

the specific lamps being studied (e.g., grades of phosphor for CFLs); (2) the ability of lamps 

across the applicable lumen range to comply with the standard level of a given product class; and 

(3) the max-tech level. DOE used commercially available lamps and their associated rated 

efficacies to determine the design options required to meet each CSL. For the non-integrated 

product class, DOE used the catalog initial lumen output and the ANSI rated wattage of the 

lamp, or nominal wattage if the ANSI rated wattage was not available, to calculate efficacy. 

DOE used catalog data as the basis of its engineering analysis because it is the largest and most 

comprehensive dataset. Although non-integrated GSLs are a component of a system that often 

q The exponent C was found to be 0.37 for PS ballasts in the 2011 Ballast Rule. See chapter 5 of the 2011 Ballast 

Rule TSD, available on regulations.gov, docket number EERE-2007-BT-STD-0016 at 

www.regulations.gov/#!docketDetail;D=EERE-2007-BT-STD-0016. r The coefficient A was used as an adjustment factor for testing variation when developing efficiency levels in the 

2011 Ballast Rule. In this rulemaking, A was assumed to be one as no adjustments were made to the ballast test data 

used in the calculation.

5-16

 
includes ballasts and fixtures, DOE based its CSLs only on lamp performance because GSLs are 

the subject of this rulemaking. DOE acknowledges, however, that the energy consumption of 

non-integrated GSLs is related to the ballast on which they operate. Therefore, DOE paired each 

lamp with an appropriate ballast to better approximate real-world conditions as discussed in 

section 5.3.3.4.

As stated previously, DOE adopted an equation-based approach to establish CSLs for 

GSLs, reflecting the relationship between efficacy and lumen output. Similar to the integrated 

product classes, DOE developed a smooth, continuous equation that specifies a minimum 

efficacy requirement across lumen output and represents the potential efficacy a lamp achieves 

using a particular design option. DOE utilized a similar methodology as the integrated product 

classes to develop the CSL equation. Using a database of commercially available non-integrated 

GSLs, DOE conducted regression analyses on several different equation forms to find the form 

that best fit the efficacy trend. DOE again analyzed products outside of the GSL lumen range 

(310 – 2,600 lumens) in order to create the best curve fit possible for the technology included in 

the product class, and confirmed the curve fit matched product performance particularly in the 

low and high ends of the GSL lumen range. DOE also ran regression analyses for the different 

equation forms on subsets of non-integrated GSLs to verify the efficacy trends. DOE is 

considering a decaying exponential equation form based on its consistent ability to fit the data 

well (measured by R2 value) across the subsets of data. DOE is considering establishing CSLs 

based on an equation for efficacy using lumens as the input in the following form:

EEEEEEEEEEEEEEEE = AA − 25.00 ∗ 0. 9989LLLLLLLLLLLL

Eq. 5.2

Where:

Efficacy = minimum efficacy requirement,

Lumens = measured lumen output, and

A = an adjustment variable (the “A-value”).

After identifying more efficacious substitutes, DOE calculated the A-value of the 

equation using catalog lumen output and catalog efficacy for each representative lamp unit. The 

A-value is an adjustment variable that vertically shifts the equation and is calculated to represent 

certain levels of efficacy. For the preliminary analysis, DOE considered two representative units 

at CSL 1, consisting of a more efficient full wattage CFL and a reduced wattage CFL. The full 

wattage representative lamp unit is used to set the minimum efficacy requirements of CSL 1 

because it represents the maximum technologically feasible level that applies across all lumen 

packages within this product class. DOE added a second representative unit, the reduced wattage 

CFL, which gives consumers the option to replace their current full wattage lamp with one that 

saves energy. DOE then evaluated the equation against lamps with the same design options as 

the representative lamp unit to determine if any adjustments were necessary to capture the 

efficacy of lamps with those design options across the entire lumen output range. In particular, 

DOE ensured that lamps of different base types were represented at the CSL.

In general terms, for the non-integrated product class, DOE based CSL 1 on the design 

options described below.

5-17
CSL 1: This level represents an improved full wattage (26 W) CFL with more efficient 

phosphors and a reduced wattage (21 W) CFL that produces similar lumen output as the baseline 

unit.

Table 5.3.9 provides detailed information on the representative lamps in the nonintegrated product class used in the engineering analysis and subsequent analyses.

Table 5.3.9 Non-Integrated Product Class Design Representative Units CSL

A-value

Lamp Shape

Base Type

Lamp Type

Nominal 

Wattage

Rated Wattage

Initial Lumens

Mean

Lumens

Rated 

Efficacy

Lifetime

CCT

CRI

W W lm lm lm/W hr K

Baseline 69.5 Double 

Tube

G24q3 CFL 26 26 1,710 1,450 65.8 10,000 4,100 82

CSL 1 72.6 Double 

Tube

G24q3 CFL 26 26 1,800 1,530 69.2 17,000 4,100 82

CSL 1 77.2 Double 

Tube

G24q3 CFL 21 21 1,525 1,310 72.6 20,000 4,100 82

As stated, DOE evaluated the impacts of CSL 1 on the individual base types and across 

the lumen output range in the non-integrated product class to determine if any adjustments were 

necessary. DOE confirmed that the vast majority of base types were still available at CSL 1, and 

therefore concluded consumers will not be forced to switch between lamps with differing base 

types. DOE identified three base types – GX10q-4, GX32d-2, and GX32d-3 – out of an original 

26 base types that do not currently have commercially available products at CSL 1. However, 

based on consultation with manufacturers and electrical distributors, DOE believes these base 

types are discontinued or are used in applications (e.g., desk lamps) that have already 

transitioned to higher efficiency technologies. Therefore, DOE did not adjust CSL 1 to account 

for the availability of base types. 

DOE also ensured that the impacts of CSL 1 are consistent across the lumen output range 

of the entire product class. In particular, DOE considered the impacts of CSL 1 for the high 

volume non-integrated GSLs not analyzed as representative units. As stated previously, in 

addition to the 26 W CFL, 13 W and 18 W CFLs are the highest volume products in the nonintegrated product class. These wattages typically correspond to lumen output ranges of 700 –

900 and 1,000 – 1,300 lumens, respectively. DOE found that in the 700 – 900 lumen range, CSL 

1 resulted in a similar technology impact as the 26 W representative units. DOE determined that 

improved full wattage 13 W CFLs meet CSL 1. However, for the 700-900 lumen range, DOE did 

not identify any commercially available reduced wattage CFLs (i.e., higher efficacy lamp with 

lower wattage) within the lumen range. DOE found that in the 1,000 – 1,300 lumen range, CSL 1 

also resulted in similar technology impacts as the 26 W representative units. DOE identified 

improved full wattage 18 W CFLs that meet CSL 1 and reduced wattage 15 W and 14 W CFLs 

that meet CSL 1. Because DOE ensured lumen packages across the product class’s range of 

lumen output are available at CSL 1, consumer utility with regard to lumen output is maintained 

5-18
throughout the entire non-integrated product class. Therefore, DOE did not find it necessary to 

adjust CSL 1 to account for the availability of lumen packages. 

For this preliminary analysis, DOE also considered whether replacing the baseline lamp 

with more efficacious substitutes at the higher CSL would require a fixture change. DOE 

conducted a survey of the market (e.g. lamp manufacturer literature and interviews with fixture 

manufacturers and distributors) to identify the fixture types most commonly used with nonintegrated GSLs and found recessed cans (horizontal and vertical lamp orientation) to be most 

common. Based on an assessment of the commonly available fixtures, DOE found that the 

fixtures frequently used with the non-integrated GSLs analyzed were available in configurations 

for several different lamp types thus indicating flexibility to use lamps of different lengths and 

shapes within the same fixture. Further, because DOE ensured that the vast majority of base 

types were available at CSL 1, DOE does not believe that consumers would be forced to change 

fixtures and therefore considered fixture replacement to be an unlikely replacement scenario. 

Consequently, DOE assumed that fixture compatibility would not be an issue for the vast 

majority of consumers and did not evaluate a fixture replacement scenario for this preliminary 

analysis. 

Figure 5.3.2 depicts the CSL for the non-integrated product class on a plot with the 

representative units. The triangle denotes the baseline representative unit, and the square boxes 

denote the more efficacious substitutes that DOE is considering as replacement representative 

units. 

5-19
Figure 5.3.2 Graph of CSLs for GSL Non-Integrated Representative Product Class

40.0

50.0

60.0

70.0

80.0

90.0

100.0

0 500 1000 1500 2000 2500 3000

Efficacy (lm/W)

Lumens (lm)

Baseline

CSL 1 - Full Wattage

CSL 1 - Reduced Wattage

CSL 1

5-20
Table 5.3.10 shows the engineering results for the non-integrated GSL representative lamp-and-ballast systems.

Table 5.3.10 Lamp Replacement Engineering Analysis for a One-Lamp Programmed Start 26 W Double Tube, 4,100 K 

SystemCSL

Lamp Shape

Base Type

Lamp Type

Nominal Wattage

Rated Wattage

Initial Lumens

Mean Lumens

Rated Efficacy

Lifetime

CCT

CRI

Number of Lamps

Starting Method

Ballast Factor

System Input 

Power

BLE

System Initial 

Light Output

System Mean 

Light Output

W W lm lm lm/W hr K W lm lm

Baseline Double 

Tube

G24q3 CFL 26 26 1,710 1,450 65.8 10,000 4,100 82 1 Programmed 

Start 1.04 30.0 90.2 1,778 1,508

CSL 1 Double 

Tube

G24q3 CFL 26 26 1,800 1,530 69.2 17,000 4,100 82 1 Programmed 

Start 1.04 30.0 90.2 1,872 1,591

CSL 1 Double 

Tube

G24q3 CFL 21 21 1,525 1,310 72.6 20,000 4,100 82 1 Programmed 

Start 1.04 24.4 89.5 1,586 1,362

Table 5.3.11 summarizes the efficacy requirement of CSL 1 for the non-integrated GSLs after rounding A-values to the nearest 

tenth.

Table 5.3.11 Summary of CSLs for GSL Non-Integrated Representative Product Class

Representative Product Class Candidate Standard Level Efficacy

lm/W

Non-Integrated

(310 – 2,600 Lumens) CSL 1 72.6-25.00*0.9989^Lumens

5-21
5.4 SCALING TO PRODUCT CLASSES NOT ANALYZED

DOE identified and selected certain product classes as representative and analyzed these 

product classes directly. DOE determined certain product classes to be representative due to high 

market volumes and/or distinct characteristics. In general, CSLs for product classes that are not 

directly analyzed (“non-representative product classes”) are then determined by scaling from the 

CSLs of the representative product classes. However, DOE chose to directly analyze all product 

classes as representative in this preliminary analysis. Thus, no scaling was required.

5.5 SUMMARY OF ALL EFFICACY LEVELS FOR COVERED GSLS

Table 5.5.1 shows a summary of CSLs for all GSLs covered by this rulemaking. 

Table 5.5.1 Summary of All Efficacy Levels for Covered GSLs

Representative Product Class Candidate Standard Level Efficacy

lm/W

Integrated Low Lumen

(310 – 1,999 Lumens)

CSL 1 67.6-29.42*0.9983^Lumens

CSL 2 74.2-29.42*0.9983^Lumens

CSL 3 80.2-29.42*0.9983^Lumens

CSL 4 87.5-29.42*0.9983^Lumens

CSL 5 90.8-29.42*0.9983^Lumens

Integrated High Lumen

(2,000 – 2,600 Lumens)

CSL 1 67.6-29.42*0.9983^Lumens

CSL 2 74.2-29.42*0.9983^Lumens

Non-Integrated

(310 – 2,600 Lumens) CSL 1 72.6-25.00*0.9989^Lumens

5-22
CHAPTER 6. PRODUCT PRICE DETERMINATION

TABLE OF CONTENTS

6.1 INTRODUCTION ...........................................................................................................6-1

6.2 LAMP METHODOLOGY ..............................................................................................6-1

6.2.1 Distribution Channels..........................................................................................6-2

6.2.2 Price Determinations............................................................................................6-2

6.3 BALLAST METHODOLOGY .......................................................................................6-3

6.4 RESULTS ........................................................................................................................6-4

6.4.1 End-User Prices for Low Lumen Integrated Lamps............................................6-4

6.4.2 End-User Prices for High Lumen Integrated Lamps ........................................... 6-5

6.4.3 End-User Prices for Non-Integrated Lamps ........................................................6-6

LIST OF TABLES

Table 6.2.1 Shipment Weightings Used per Distribution Channel..............................................6-3

Table 6.4.1 End-User Prices for Low Lumen Integrated Lamps.................................................6-5

Table 6.4.2 End-User Prices for High Lumen Integrated Lamps................................................6-5

Table 6.4.3 End-User Prices for Non-Integrated Lamps .............................................................6-6

6-i
CHAPTER 6. PRODUCT PRICE DETERMINATION

6.1 INTRODUCTION

This chapter describes the methodology the U.S. Department of Energy (DOE) followed 

in developing end-user prices for the general service lamps (GSLs) being analyzed in this 

rulemaking (see section 6.2). It also provides the results for the lamp end-user prices in section 

6.4. 

In energy conservation standards rulemakings, DOE often develops cost-efficiency 

relationships in the engineering analysis (chapter 5 of this technical support document [TSD]). 

Then, DOE applies markups to derive end-user prices. For this rulemaking, DOE derived 

candidate standard levels (CSLs) in the engineering analysis and developed the prices in this 

chapter of this TSD. DOE develops end-user prices directly in the product price determination 

assessment because reverse-engineering a lamp is impractical, as the lamps are not easily 

disassembled. By combining the results of the engineering analysis and the product price 

determination, DOE derived typical inputs for use in the life-cycle cost (LCC; chapter 8 of this

TSD) analysis and the national impact analysis (NIA; chapter 10 of this TSD). Section 6.2 of this 

chapter describes the methodology used to develop end-user prices for lamps that are presented 

in the engineering analysis. The results for lamp end-user prices are in section 6.4. 

Because the non-integrated GSLs analyzed operate with a ballast in practice, DOE also 

developed prices for ballasts. Section 6.3 of this chapter describes the methodology used to 

derive the end-user prices for the ballasts that are presented in the engineering analysis. The 

results for the ballast end-user prices are in section 6.4.

6.2 LAMP METHODOLOGY

End-user price refers to the product price a consumer pays before tax and installation. 

Typically, DOE develops manufacturing selling prices (MSPs) for covered products and applies 

markups to create end-user prices to use as inputs to the LCC analysis and NIA. Because GSLs 

are difficult to reverse-engineer (i.e., not easily disassembled), DOE directly derives end-user 

prices for the lamps covered in this rulemaking. DOE considered using manufacturers’ published 

end-user price schedules for lamps (hereafter called the manufacturer’s “blue book” or “lamp 

price schedules”). However, DOE found that blue book prices for all GSLs within the scope of 

this rulemaking were not available. Instead, DOE reviewed and used publicly available retail 

prices in the pricing analysis. 

In its review of publicly available prices for GSLs, DOE observed a range of end-user 

prices paid for a lamp, depending on the distribution channel through which the lamp is 

purchased. DOE developed end-user prices for the representative units sold in each of the main 

distribution channels for GSLs. DOE then calculated an average weighted end-user price using 

the estimated shipment percentage of each distribution channel. DOE also assessed and 

accounted for general price trends in relation to efficacy for all GSLs. For example, DOE noted 

that available data indicated that light-emitting diode (LED) lamp prices decreased with 

increased lamp efficacy and confirmed that calculated end-user prices reflected this trend.

6-1 
6.2.1 Distribution Channels

Because of the range of end-user prices paid for a lamp, DOE decided to collect GSL 

prices from many different vendors representing a variety of distribution channels. Through 

feedback from manufacturer interviews and market research, DOE determined that the most 

common channels through which GSLs are sold are State procurement contracts, electrical 

distributors (e.g., Grainger), home centers (e.g., Home Depot), hardware stores (e.g., Ace 

Hardware), Internet retailers (e.g., Amazon), mass merchants (e.g., Walmart), grocery stores 

(e.g., Safeway), and drug stores (e.g., CVS).

Based on manufacturer feedback and an assessment of lamp price data and trends for each 

of these channels, DOE determined that certain GSL distribution channels should be grouped 

together. DOE determined that Internet retailers, grocery stores, and drug stores could be 

grouped into one distribution channel because they all similarly offer consumers a more 

convenient purchasing option at a typically increased cost. DOE also found that home centers, 

hardware stores, and mass merchants could be appropriately grouped into one distribution 

channel based on their similarity in price and target market. In summary, DOE identified the 

following four main distribution channels for GSLs in this preliminary analysis:

• Small Consumer-Based Distributors: Internet Retailers, Grocery Stores, and Drug Stores;

• Large Consumer-Based Distributors: Home Centers, Hardware Stores, and Mass 

Merchants;

• Electrical Distributors; and

• State Procurement.

6.2.2 Price Determinations

DOE collected pricing data for GSLs in the scope of this rulemaking from each of the four 

distribution channels discussed in section 6.2.1. 

For the small consumer-based distributor channel, DOE used both online prices and instore prices. DOE collected Internet prices from several Internet retailers, including 

Amazon.com, eLightBulbs.com, and GoodMart.com. DOE also collected in-store prices from 

grocery stores and drug stores, including Giant, Safeway, CVS, and Rite Aid. DOE again 

ensured that in-store prices collected from grocery and drug stores did not reflect a rebate.

For the large consumer-based distributor channel, DOE collected prices for stores 

including Target, Walmart, Home Depot, Lowes, and Ace Hardware. DOE ensured that rebated 

prices were not included in the analysis because rebates are typically available for a limited 

period of time and are specific to the region of the country. Thus, DOE does not believe that 

rebated prices are representative of the typical end-user price during the analysis period. 

For the electrical distributor distribution channel, DOE surveyed GSL prices from the 

large electrical distributors identified based on market research and manufacturer feedback to 

determine appropriate end-user prices for the electrical distributor channel. DOE gathered prices 

from electrical distributors including Grainger, Graybar, and WESCO. 

6-2
Lastly, for the State procurement distribution channel, DOE gathered State procurement 

contracts from all states that had publicly available information and offered discounted prices for 

GSLs. 

The prices gathered for each of the four distribution channels were then used to develop 

prices for the representative lamp units identified for each CSL analyzed in the engineering 

analysis (see chapter 5 of this TSD). For each distribution channel, DOE calculated an aggregate 

price for the representative unit at each CSL using the average lamp model prices for the 

representative units and their similar lamp models. Because the lamps with similar characteristics 

as the representative units (e.g., wattage, correlated color temperature [CCT], bulb shape, base 

type, color rendering index [CRI]) were equivalent in terms of performance and utility, DOE 

considered the pricing of these lamps to also be representative of the technology of the CSL. 

When sufficient data was not available at a specific distribution channel, DOE extrapolated 

pricing from similar lamps with available pricing data. This was done by using the pricing data 

of similar lamps and developing price trends based on wattage and/or efficacy, as appropriate.

Once DOE determined end-user prices at the four distribution channels for each of the 

representative units analyzed in the engineering analysis, DOE then developed an end-user price 

that was weighted by distribution channel. Based on manufacturer feedback in interviews, DOE 

determined an aggregated percentage of shipments that go through each distribution channel for 

GSLs. DOE used different shipment percentages for integrated lamps and non-integrated lamps 

because integrated lamps are more commonly residential products while non-integrated lamps 

are more commonly commercial products. Because the end-user shipment percentages for 

distribution channels will vary based on whether the product is residential or commercial, DOE 

determined that it was appropriate to use different weightings for the two lamp types. The 

weightings used to calculate the end-user price are shown in Table 6.2.1. 

Table 6.2.1 Shipment Weightings Used per Distribution Channel

Small ConsumerBased DistributorsLarge ConsumerBased DistributorsElectrical 

Distributors

State Procurement

Integrated GSLs 10% 75% 10% 5%

Non-Integrated GSLs 5% 10% 75% 10%

As stated, DOE assessed and accounted for general price trends in relation to efficacy for 

all GSLs in its determination of end-user prices. Specifically, DOE noted that available data 

indicated that LED lamp prices decreased with increased lamp efficacy and confirmed that 

calculated end-user prices reflected this trend. DOE also confirmed that for compact fluorescent 

lamps (CFLs), a mature technology, an increase in efficacy typically results in an increased 

price. However, consistent with manufacturer feedback, DOE found that covered CFLs were 

more expensive than spiral CFLs of similar efficacy. For the non-integrated product class, DOE 

also found that CFL prices increased with increased lamp efficacy, whether achieved through 

increasing lumen output or reducing wattage.

6.3 BALLAST METHODOLOGY

Because CFL ballasts are not subject to energy conservation standards, DOE did not 

analyze these ballasts in the rulemaking for fluorescent lamp ballasts finalized in 2011 (hereafter 

6-3
the “2011 Ballast Rule”). 76 FR 70548 (Nov. 14, 2011). Therefore, DOE developed prices for 

the ballasts analyzed with the non-integrated GSLs in this rulemaking. 

To determine prices for CFL ballasts, DOE compared the blue book prices of CFL 

ballasts to comparable fluorescent lamp ballasts and developed a scaling factor to apply to the 

end-user prices of the fluorescent lamp ballasts developed in the 2011 Ballast Rule. DOE 

considered ballasts with similar specifications, including starting method, maximum number of 

lamps operated, ballast factor, and input power, to be comparable. DOE calculated the percent 

difference in blue book prices for the comparable pairs of fluorescent lamp ballasts and CFL 

ballasts. The average percent decrease from prices of fluorescent ballasts to CFL ballasts was 29 

percent. Because DOE determined that 2-lamp programmed start (PS) fluorescent ballasts were 

the most similar to the CFL ballasts selected for this analysis, DOE reduced the end-user ballast 

price developed for the 2-lamp PS 4-foot medium bi-pin system by 29 percent to determine the 

CFL ballast price for this rulemaking.

6.4 RESULTS

Sections 6.4.1, 6.4.2, and 6.4.3 below summarize the prices for each distribution channel, 

and weighted end-user prices for each GSL product class: low lumen integrated lamps, high 

lumen integrated lamps, and non-integrated lamps. Section 6.4.3 also summarizes the ballast 

prices developed for the ballasts paired with non-integrated lamps. (See chapter 3 of this TSD for 

further details on GSL product classes.) 

6.4.1 End-User Prices for Low Lumen Integrated Lamps

The following tables present the end-user prices for low lumen integrated lamps. The 

prices presented do not include sales tax.

6-4
Table 6.4.1 End-User Prices for Low Lumen Integrated Lamps

CSL Lamp 

Type

Nominal 

Wattage 

W

Lamp 

Efficacy 

lm/W

Initial 

Lumen 

Output

lm

CRI CCT 

K

Rated 

Life 

hrs

Lamp End-User Price 2014$

Large 

ConsumerBased 

Distributors

Small 

ConsumerBased 

Distributors

Electrical 

Distributors

State 

Procurement

Weighted 

Price

Baseline CFL 14 53.6 750 80 2,700 10,000 $4.84 $7.65 $7.63 $9.32 $5.62

CSL1 CFL 13 61.5 800 82 2,700 12,000 $3.10 $6.24 $6.69 $7.13 $3.97

CSL2 LED 12 66.7 800 82 2,700 25,000 $27.47 $25.50 $43.92 $13.29 $28.21

CSL3 LED 11 72.7 800 81 2,700 25,000 $14.25 $25.27 $41.70 $12.61 $18.02

CSL4 LED 10 80.0 800 82 2,700 25,000 $10.00 $23.39 $39.48 $11.92 $14.38

CSL5 LED 9.5 84.2 800 80 2,700 25,000 $9.47 $21.51 $38.37 $11.58 $13.67

6.4.2 End-User Prices for High Lumen Integrated Lamps

The following table presents the end-user prices for high lumen integrated lamps. The prices presented do not include sales tax.

Table 6.4.2 End-User Prices for High Lumen Integrated Lamps

CSL Lamp 

Type

Nominal 

Wattage 

W

Lamp 

Efficacy 

lm/W

Initial 

Lumen 

Output

lm

CRI CCT 

K

Rated 

Life 

hrs

Lamp End-User Price 2014$

Large 

ConsumerBased 

Distributors

Small 

ConsumerBased 

Distributors

Electrical 

Distributors

State 

Procurement

Weighted 

Price

Baseline CFL 32 62.5 2,000 80 2,700 10,000 $8.62 $9.99 $20.46 $11.80 $10.10

CSL1 CFL 30 66.7 2,000 82 2,700 10,000 $8.75 $11.99 $20.96 $11.86 $10.45

CSL2 CFL 29 75.9 2,200 82 2,700 12,000 $8.82 $18.49 $21.46 $11.89 $11.20

6-5
6.4.3 End-User Prices for Non-Integrated Lamps

The following table presents the end-user prices for non-integrated lamps and ballasts. The prices presented do not include 

sales tax.

Table 6.4.3 End-User Prices for Non-Integrated Lamps

CSL Lamp 

Type

Nominal 

Wattage 

W

Lamp 

Efficacy 

lm/W

Initial 

Lumen 

Output

lm

CRI CCT 

K

Rated 

Life 

hrs

Lamp End-User Price 2014$

Ballast 

EndUser 

Price 

2014$

Large 

ConsumerBased 

Distributors

Small 

ConsumerBased 

Distributors

Electrical 

Distributors

State 

Procurement

Weighted 

Price

Baseline CFL 26 65.8 1,710 82 4,100 10,000 $6.73 $5.70 $16.50 $3.63 $13.70 $13.26

CSL1 CFL 26 69.2 1,800 82 4,100 17,000 $7.23 $7.21 $17.47 $5.57 $14.74 $13.26

CSL1 CFL 21 72.6 1,525 82 4,100 20,000 $8.68 $14.34 $18.42 $9.47 $16.35 $13.26

6-6
CHAPTER 7. ENERGY USE CHARACTERIZATION

TABLE OF CONTENTS

7.1 INTRODUCTION ........................................................................................................... 7-1

7.2 OPERATING HOURS .................................................................................................... 7-1

7.2.1 Residential Sector ................................................................................................ 7-1

7.2.2 Commercial Sector............................................................................................... 7-5

7.3 LIGHTING CONTROLS ................................................................................................ 7-7

7.3.1 Residential Sector ................................................................................................ 7-8

7.3.2 Commercial Sector............................................................................................... 7-8

7.4 RESULTS ........................................................................................................................ 7-9

REFERENCES .......................................................................................................................... 7-18

LIST OF TABLES

Table 7.2.1 CFL-to-All GSL HOU Correction Factor...................................................... 7-2

Table 7.2.2 CFL HOU Converted to All GSL HOU ........................................................ 7-2

Table 7.2.3 Average Hours of Use of GSLs in each Reportable Domain ........................ 7-5

Table 7.2.4 Daily GSL HOU by Building Type in the Commercial Sector ..................... 7-6

Table 7.2.5 CBECS Building Type Average HOU .......................................................... 7-7

Table 7.4.1 Average Annual Energy Use and Savings per Unit for Integrated Low 

Lumen (< 2,000 lm) GSLs for Reference and No Controls Scenarios........ 7-10

Table 7.4.2 Average Annual Energy Use and Savings per Unit for Integrated High 

Lumen (≥ 2,000 lm) GSLs for Reference and No Controls Scenarios........ 7-10

Table 7.4.3 Average Annual Energy Use and Savings per Unit for Non-Integrated 

GSLs for Reference and No Controls Scenarios.......................................... 7-11

Table 7.4.4 Annual Energy Use for Integrated Low Lumen (< 2,000 lm) GSLs in 

the Residential Sector .................................................................................. 7-12

Table 7.4.5 Annual Energy Use for Integrated Low Lumen (< 2,000 lm) GSLs in 

the Commercial Sector................................................................................. 7-13

Table 7.4.6 Annual Energy Use for Integrated High Lumen (≥ 2,000 lm) GSLs in 

the Residential Sector .................................................................................. 7-14

Table 7.4.7 Annual Energy Use for Integrated High Lumen (≥ 2,000 lm) GSLs in 

the Commercial Sector................................................................................. 7-15

Table 7.4.8 Annual Energy Use (kWh/year) for Non-Integrated GSLs in the 

Residential Sector ........................................................................................ 7-16

Table 7.4.9 Annual Energy Use (kWh/year) for Non-Integrated GSLs in the 

Commercial Sector....................................................................................... 7-17

LIST OF FIGURES

Figure 7.2.1 Mapping of Operating Hours to U.S. Regions............................................... 7-4

7-i
CHAPTER 7. ENERGY USE CHARACTERIZATION

7.1 INTRODUCTION

This chapter describes the methodology the U.S. Department of Energy (DOE) followed 

to estimate the annual energy use of general service lamps (GSLs) as used by consumers in 

homes and businesses. The results of this analysis are key inputs to the life-cycle cost and 

payback period analysis, described in chapter 8 of this technical support document (TSD), and 

the national impact analysis, described in chapter 10. DOE requires information on annual 

energy use to determine the potential energy and operating cost savings consumers would realize 

from the use of more efficient products.

DOE determined the annual energy use of GSLs using information on their input power 

consumption and the way consumers use them (their operating hours per year). DOE derives the 

annual unit energy consumption (UEC) of GSLs by multiplying the input power by the number 

of hours of operation per year:

UUUUUU = OOOOOOOOOOOOOOOOOO HHHHHH HH × II PP ww

Eq. 7.1

The energy use analysis is developed for GSLs using the representative lamps described 

in the engineering analysis (chapter 5 of this TSD). Therefore, the input power used in the energy 

use analysis is the input power presented in the engineering analysis (chapter 5 of this TSD) for

the representative lamp (or lamp and ballast) at each candidate standard level (CSL) for each of 

the three product classes considered in this rulemaking: Integrated Low-Lumen, Integrated HighLumen, and Non-Integrated GSLs. The following sections describe the inputs and calculations 

DOE used to develop annual operating hours, and annual energy use for the GSLs considered in 

this analysis.

7.2 OPERATING HOURS

This section discusses how DOE calculated operating hours for GSLs used in the 

residential and commercial sectors.

7.2.1 Residential Sector

The goal of the energy use analysis is to generate energy use values that reflect actual use 

by consumers in the U.S. Accordingly, DOE used data from various field metering studies to 

estimate operating hours for GSLs in the residential sector on a regional basis. DOE utilized 

hours of use (HOU) metered data for regions where such data were available; for regions without 

HOU metered data, DOE used data from adjacent regions, as described below. This section 

describes in detail the approach DOE followed to estimate HOU.

DOE did not differentiate HOU by light source technology, but instead assumed that

HOU would be the same across all light source technologies during the analysis period (2020-

2049). As discussed in chapter 2 of this TSD, some studies currently report higher HOU for CFL

7-1
GSLs compared to all GSLs. Specifically, DOE identified the Residential Lighting End-Use 

Consumption Study (RLEUCS)1 and the Northeast Residential Lighting Hours-of-Use Study,

2

which both report higher HOU for CFLs compared to all GSLs. DOE assumed that CFLs are 

currently disproportionately installed in sockets with higher HOU and that CFLs would have the 

same HOU as all GSLs during the analysis period, when they will fill more sockets. For LED 

GSLs, very limited HOU data exist, therefore DOE has assumed the same HOU for LED GSLs 

as CFLs.

DOE used hours of use data from metering studies in California,

1 Georgia,3 North 

Carolina,

4 South Carolina,5 Maryland,6 Ohio,7 Illinois,8 the Northwest,9 and the Northeast.2 For 

studies that only reported operating hours for CFLs, DOE used a correction factor to estimate 

operating hours for all GSLs. This correction factor was calculated based on the populationweighted-average fractional difference in operating hours between all GSLs and CFL GSLs.

Table 7.2.1 shows the daily all-GSL HOU compared to the CFL-GSL HOU for 5 U.S. states, and

the (population-weighted average) CFL-to-all GSL correction factor.

Table 7.2.1 CFL-to-All GSL HOU Correction Factor

State All GSL

HOU CFL HOU Population Weight(2013)

HOU Ratio 

All GSLs/CFLs

CT2 2.8 3.1 5% 0.90

RI2 2.6 3.0 2% 0.87

MA2 2.7 3.0 10% 0.90

NY2 3.3 4.0 28% 0.83

CA1 1.6 1.9 55% 0.83

CFL-to All GSL Correction Factor (Population-Weighted Average) 0.84

For studies that report HOU for CFL GSLs only, DOE applied the CFL-to-all GSL 

correction factor, as shown in Table 7.2.2. 

Table 7.2.2 CFL HOU Converted to All GSL HOU

State CFL GSL

HOU

All GSLs

HOU

IL8 2.7 2.3

OH7 2.8 2.4

MD6 3.0 2.5

GA3 2.8 2.4

NC4 2.9 2.5

SC5 2.7 2.3

Next, DOE estimated the representative operating hours for each Residential Energy 

Consumption Survey (RECS) reportable domain. (i.e., State, or group of States). To do this, DOE 

7-2
first grouped U.S. states by Census Division and large state. Within each of these groupings, 

DOE examined whether HOU metering data were available.

If metering data were available in a given Census Division or Large State, DOE divided 

the region to RECS reportable domains and examined whether HOU metering data were 

included within each RECS domain. For any RECS reportable domain with metering data, DOE 

used the HOU data within that reportable domain. When a reportable domain included HOU data 

from one metering study, the HOU for the reportable domain were those of that one metering 

study; when multiple metering studies were available within a reportable domain, the HOU were 

the population-weighted average HOU of all the metering studies in the reportable domain. For 

RECS reportable domains without metering data, DOE used the population-weighted average 

HOU within the larger Census Division or Large State. 

If metering data were not available in a particular Census Division or Large State, DOE 

used data from surrounding regions based on proximity, where possible, or having a similar 

latitude to the region in question (DOE assumed that regions of similar latitude would tend to

have similar HOU). 

Figure 7.2.1 shows a map of U.S. Census Divisions and Large States, and illustrates how 

HOU metering data were mapped to each region. For example, the operating hours for both the 

South Atlantic and East South Central Census Divisions were derived from the populationweighted average of metering studies within the South Atlantic Census Division, specifically 

metering studies from Georgia, South Carolina, North Carolina, and Maryland. (For clarity, 

regions where the population-weighted average of these studies was used are designated by a 

single symbol and the states are collectively referred to as the Southeast, as shown in the legend.)

As another example, the HOU in the Mountain Census Division are the population-weighted 

average HOU from metering studies conducted in California and in the Pacific Northwest 

Census Division. The HOU in Texas, a state whose immediate neighbors did not have metering

studies available, were estimated based on metering studies conducted in the Southeast, Indiana 

and Ohio.

7-3
Note: The map shows how the available HOU metering data were mapped to Census Divisions and large states. DOE used this map to determine HOU 

for each RECS reportable domain. 

Figure 7.2.1 Mapping of Operating Hours to U.S. Regions

7-4
The HOU for each RECS reportable domain, as well as the metering data used to 

estimate those HOU, are shown in Table 7.2.3. DOE estimated that the national weighted 

average operating hours for the residential sector is 2.3 hours per day, or 839.5 hours per year.

Table 7.2.3 Average Hours of Use of GSLs in each Reportable Domain

RECS

10 Reportable Domain Source of Data (States) Average HOU 

(hrs/day)

Population Weight 

(2013)

01. CT, ME, NH, RI, VT CT, RI 2.7 3%

02. MA MA 2.7 2%

03. NY NY 3.3 6%

04. NJ OH, MD, NY 2.9 3%

05. PA OH, MD, NY 2.9 4%

06. IL IL 2.3 4%

07. IN, OH OH 2.4 6%

08. MI IL, OH 2.3 3%

09. WI IL, OH 2.3 2%

10. IA, MN, ND, SD IL, OH 2.3 3%

11. KS, NE IL, OH 2.3 2%

12. MO IL, OH 2.3 2%

13. VA GA, MD, NC, SC 2.4 3%

14. DE, DC, MD, WV MD 2.5 3%

15. GA GA 2.4 3%

16. NC, SC NC, SC 2.4 5%

17. FL GA, MD, NC, SC 2.4 6%

18. AL, KY, MS GA, MD, NC, SC 2.4 4%

19. TN GA, MD, NC, SC 2.4 2%

20. AR, LA, OK GA, MD, NC, SC, IL, OH 2.4 4%

21. TX GA, MD, NC, SC, IL, OH 2.4 8%

22. CO CA, WA 1.6 2%

23. ID, MT, UT, WY CA, WA 1.6 2%

24. AZ CA, WA 1.6 2%

25. NV, NM CA, WA 1.6 2%

26. CA CA 1.6 12%

27. AK, HI, OR, WA WA 1.8 4%

National 2.3 100%

7.2.2 Commercial Sector

For the commercial sector, DOE used average daily HOU data for 15 building types from

the 2010 U.S. Lighting Market Characterization (LMC).

11 DOE notes that the installed stock of 

7-5
GSLs in the industrial sector is less than 1 percent of the installed stock in the commercial sector,

according to the LMC; furthermore, DOE assumes that the hours of operation for GSLs in the 

industrial sector (e.g., in offices) are approximately equal to the hours of operation for GSLs in 

the commercial sector. Therefore, DOE analyzed these two sectors together (using data specific 

to the commercial sector), and refers to the combined sector as the commercial sector.

DOE took the following steps to estimate the national average HOU of GSLs in the 

commercial sector: 

For each commercial building type presented in the LMC, DOE determined the fraction 

of installed lamps utilizing each of the light source technologies typically used in GSLs 

(incandescent, halogen, and CFL)a, which are reported in LMC Table 4-18. Using data on the 

commercial HOU for each of these light source technologies, (LMC/Table 4-20) and weighting 

those data by the percentage of lamps that are of each lamp type in each building type (LMC, 

Table 4-18), DOE estimated the weighted average HOU of CFLK lamps in each building type.

The results are shown in Table 7.2.4. 

Table 7.2.4 Daily GSL HOU by Building Type in the Commercial Sector

Building Type

GSLs in Each 

Building Type 

(%)

GSL Weighted 

Average HOU 

(hrs/day)

Education 12 10.6

Food Service 29 10.3

Food Store 5 10.7

Health Care–Inpatient 15 10.5

Health Care–Outpatient 11 10.4

Lodging 45 10.4

Offices (Non-medical) 16 10.5

Public Assembly 30 10.4

Public Order and Safety 8 10.7

Religious Worship 13 10.4

Retail–Mall & Non-Mall 18 11.2

Services 6 10.8

Warehouse and Storage 8 10.8

Other 15 10.9

To estimate the national average HOU for the commercial sector, DOE mapped the HOU 

of the building types in the LMC to the building types in the 2003 Commercial Building Energy 

Consumption Survey (CBECS).

12 DOE weighted each CBECS building by the final full sample 

building weightb type, the area (ft2) of each CBECS building, the number of lamps per 1000ft2

according to the LMC (Table 4.21), and the percentage of lamps that are GSLs in each building 

a Operating hours specifically for LEDs are not reported in the LMC.

b In CBECS, the final full sample building weight, denoted by the CBECS variable ADJWT8, denotes the number of 

buildings each building type in the CBECS sample represents. 

7-6

 
type, and calculated that, nationwide, GSLs are used an average of 10.7 hours per day or 3891

hours per year in the commercial sector.

Table 7.2.5 CBECS Building Type Average HOU

CBECS Building Type LMC Building HOU/day Building 

Weight*

Office Offices (Non-medical) 10.5 22%

Laboratory Other 10.9 1%

Nonrefrigerated warehouse Warehouse and Storage 10.8 4%

Food sales Food Store 10.7 1%

Public order and safety Public Order and Safety 10.7 1%

Outpatient health care Health Care – Outpatient 10.4 2%

Refrigerated warehouse Warehouse and Storage 10.8 0%

Religious worship Religious Worship 10.4 5%

Public assembly Public Assembly 10.4 10%

Education Education 10.6 7%

Food service Food Service 10.3 5%

Inpatient health care Health Care – Inpatient 10.5 3%

Nursing Lodging 10.4 3%

Lodging Lodging 10.4 11%

Strip shopping mall Retail - Mall & Non-Mall 11.2 10%

Enclosed mall Retail - Mall & Non-Mall 11.2 4%

Retail other than mall Retail - Mall & Non-Mall 11.2 9%

Service Services 10.8 2%

Other Other 10.9 1%

National Average 10.7 100% (total)

*The Building Weight is derived from the product of each CBECS building’s area (CBECS variable SQFT8), the 

final full sample building weight in CBECS (CBECS variable ADJWT8), the number of lamps per 1000 ft2 by 

building type and the percentage of lamps that are GSLs in each building type.

7.3 LIGHTING CONTROLS

DOE accounted for the impact of lighting controls on GSL energy use by reducing the 

energy use by 30 percent for GSLs that operate on lighting controls, for both the residential and 

commercial sectors. This estimate was based on a meta-analysis of field measurements of energy 

savings from commercial lighting controls by Williams, et al.

13 Field measurements of energy 

savings from controls in the residential sector are very limited; DOE assumed that controls 

would have the same impact as in the commercial sector.

The UEC of GSLs installed on any type of lighting control system, can be computed 

using the following formula:

7-7
UUUUCCcc = UUUU nn × �11 − ffcccc cccccccc × ffee ee �

Eq. 7.2

Where:

UUUUUUcc= weighted average annual energy consumption (kWh) of GSLs considering use of 

lighting controls,

UUUU nn = annual unit energy consumption (kWh) of GSLs, operating under full power, 

computed according to Eq. 7.1,

ffcccc cccccccc= the fraction of lamps estimated to be operating under lighting controls, and

ffeeeeeeee = a parameter describing the effect of lighting controls on energy consumption, i.e.,

the reduction on energy use due to lighting controls, taken to be 0.3.

7.3.1 Residential Sector

To estimate the fraction of GSLs used with lighting controls for each CSL in the 

residential sector, DOE first separately considered the fraction of CFL and LED GSLs used with 

controls in this sector. For CFLs, this fraction is limited technologically by the fraction of 

dimmable lamps. For LEDs, this fraction is limited by the fraction of dimmable sockets, and by 

the fraction of lamps with integrated wireless receivers that allow them to be controlled 

remotely, so called smart lamps, which can be installed in standard sockets.

For CFLs, DOE assumed that 5% of CFL GSLs can be used with dimmers, based on 

feedback from manufacturer interviews. DOE combined this percentage with the percentage of 

CFL GSLs used with lighting controls other than dimmers from the LMC, to estimate that the 

overall percentage of CFL GSLs used with lighting controls is about 7.3%. DOE assumes that 

this fraction remains constant throughout the analysis period for the residential sector. 

For LED GSLs, DOE looked at the overall fraction of sockets that are installed with 

lighting controls in the residential sector (mostly dimmers, with a small fraction on switching 

controls). This fraction was 14% in 2010, according to the LMC, and DOE assumed that this 

fraction was constant throughout the analysis period. DOE also assumed that in addition to 

controlled sockets, there will be an increase in the market share of smart lamps. DOE assumed 

that the incursion of smart lamps followed a Bass adoption curve, as described in chapter 10 of 

this TSD. 

Based on the incursion of smart lamps, and the fraction of controlled sockets, DOE 

estimates that at the assumed compliance year (2020), about 42% of GSL LEDs will be 

associated with some type of lighting control. Note that this relatively high fraction is due, in 

part, to the preferential use of LEDs in sockets with controls, compared to CFLs. For details on 

this estimate, see chapter 10 of this TSD.

7.3.2 Commercial Sector

For the commercial sector, DOE used the method developed for amended energy 

conservation standards for general service fluorescent lamps (GSFL) and incandescent reflector 

lamps (IRLs). DOE assumed that lighting controls are installed on an increasing fraction of 

lamps in the commercial sector as a result of updated building codes, as described in appendix 

7-8
10D of this TSD. DOE estimates that by 2020, about 49% of GSLs will be using controls in the 

commercial sector. 

To estimate the fraction of GSLs using controls in each of the commercial building types 

analyzed, DOE scaled the fraction of controls reported in the LMC for each building type by the 

ratio of the overall controls penetration in 2020 (49%) to the overall controls penetration reported 

in the LMC (30%). 

7.4 RESULTS

The following tables present results of the energy use analysis for GSLs in units of 

kilowatt-hours per year (kWh/yr). Table 7.4.1, Table 7.4.2, and Table 7.4.3 present UEC and

annual energy savings with respect to the baseline (CSL 0) at each CSL for each product class in 

the reference scenario, as well as the “no controls” scenario. The “no controls” scenario is not 

intended to be realistic, but to illustrate the impact that controls have on energy use and savings. 

7-9
Table 7.4.1 Average Annual Energy Use and Savings per Unit for Integrated Low Lumen (< 2,000 lm) GSLs for Reference 

and No Controls Scenarios

Residential Commercial

CSL

Reference No Controls Reference No Controls

Energy Use

(kWh/yr)

Savings

(kWh/yr)

Energy Use

(kWh/yr)

Savings

(kWh/yr)

Energy Use

(kWh/yr)

Savings

(kWh/yr)

Energy Use

(kWh/yr)

Savings

(kWh/yr)

0 11.6 0.0 11.9 0.0 46.3 0.0 54.5 0.0

1 10.8 0.8 11.0 0.8 43.0 3.3 50.6 3.9

2 8.9 2.7 10.2 1.7 39.7 6.6 46.7 7.8

3 8.2 3.4 9.3 2.5 36.4 9.9 42.8 11.7

4 7.4 4.2 8.5 3.4 33.1 13.2 38.9 15.6

5 7.1 4.6 8.1 3.8 31.4 14.9 36.9 17.5

Table 7.4.2 Average Annual Energy Use and Savings per Unit for Integrated High Lumen (≥ 2,000 lm) GSLs for Reference 

and No Controls Scenarios

Residential Commercial

CSL

Reference No Controls Reference No Controls

Energy Use

(kWh/yr)

Savings

(kWh/yr)

Energy Use

(kWh/yr)

Savings

(kWh/yr)

Energy Use

(kWh/yr)

Savings

(kWh/yr)

Energy Use

(kWh/yr)

Savings

(kWh/yr)

0 26.6 0.0 27.2 0.0 106.0 0.0 124.0 0.0

1 24.9 1.7 25.5 1.7 99.2 6.6 117.0 7.8

2 24.1 2.5 24.6 2.6 95.9 9.9 113.0 11.7

7-10
Table 7.4.3 Average Annual Energy Use and Savings per Unit for Non-Integrated GSLs for Reference and No Controls 

Scenarios

Residential Commercial

CSL

Reference No Controls Reference No Controls

Energy Use

(kWh/yr)

Savings

(kWh/yr)

Energy Use

(kWh/yr)

Savings

(kWh/yr)

Energy Use

(kWh/yr)

Savings

(kWh/yr)

Energy Use

(kWh/yr)

Savings

(kWh/yr)

0 24.9 0.0 25.5 0.0 99.2 0.0 117.0 0.0

1

24.9 0.0 25.5 0.0 99.2 0.0 117.0 0.0

20.3 4.6 20.7 4.7 80.7 18.4 94.9 21.7

7-11
Table 7.4.4 and Table 7.4.5 present UEC for Integrated Low-Lumen GSLs in the 

residential sector by reportable domain and in the commercial sector by building type.

Table 7.4.4 Annual Energy Use for Integrated Low Lumen (< 2,000 lm) GSLs in the 

Residential Sector

RECS Reportable Domain CSL 0 

(kWh/yr)

CSL 1 

(kWh/yr)

CSL 2

(kWh/yr)

CSL 3 

(kWh/yr)

CSL 4 

(kWh/yr)

CSL 5 

(kWh/yr)

01. CT, ME, NH, RI, VT 13.7 12.7 10.5 9.6 8.7 8.3

02. MA 13.5 12.5 10.3 9.5 8.6 8.2

03. NY 16.5 15.3 12.6 11.6 10.5 10.0

04. NJ 14.5 13.4 11.1 10.1 9.2 8.8

05. PA 14.5 13.4 11.1 10.1 9.2 8.8

06. IL 11.5 10.7 8.8 8.1 7.3 7.0

07. IN, OH 11.9 11.0 9.1 8.3 7.6 7.2

08. MI 11.7 10.9 9.0 8.2 7.5 7.1

09. WI 11.7 10.9 9.0 8.2 7.5 7.1

10. IA, MN, ND, SD 11.7 10.9 9.0 8.2 7.5 7.1

11. KS, NE 11.7 10.9 9.0 8.2 7.5 7.1

12. MO 11.7 10.9 9.0 8.2 7.5 7.1

13. VA 12.0 11.2 9.2 8.4 7.7 7.3

14. DE, DC, MD, WV 12.3 11.5 9.4 8.7 7.9 7.5

15. GA 11.8 10.9 9.0 8.3 7.5 7.1

16. NC, SC 12.0 11.1 9.2 8.4 7.6 7.3

17. FL 12.0 11.2 9.2 8.4 7.7 7.3

18. AL, KY, MS 12.0 11.2 9.2 8.4 7.7 7.3

19. TN 12.0 11.2 9.2 8.4 7.7 7.3

20. AR, LA, OK 11.9 11.0 9.1 8.3 7.6 7.2

21. TX 11.9 11.0 9.1 8.3 7.6 7.2

22. CO 8.2 7.6 6.3 5.8 5.2 5.0

23. ID, MT, UT, WY 8.2 7.6 6.3 5.8 5.2 5.0

24. AZ 8.2 7.6 6.3 5.8 5.2 5.0

25. NV, NM 8.2 7.6 6.3 5.8 5.2 5.0

26. CA 7.9 7.4 6.1 5.6 5.1 4.8

27. AK, HI, OR, WA 9.0 8.4 6.9 6.3 5.7 5.5

U.S. Average 11.6 10.8 8.9 8.2 7.4 7.1

7-12
Table 7.4.5 Annual Energy Use for Integrated Low Lumen (< 2,000 lm) GSLs in the 

Commercial Sector

Building Type CSL 0 

(kWh/yr)

CSL 1 

(kWh/yr)

CSL 2 

(kWh/yr)

CSL 3 

(kWh/yr)

CSL 4 

(kWh/yr)

CSL 5 

(kWh/yr)

Office 40.4 37.5 34.6 31.7 28.8 27.4

Laboratory 52.4 48.7 44.9 41.2 37.4 35.6

Nonrefrigerated warehouse 51.5 47.8 44.1 40.4 36.8 34.9

Food sales 43.8 40.6 37.5 34.4 31.3 29.7

Public order and safety 53.6 49.8 45.9 42.1 38.3 36.4

Outpatient health care 47.3 43.9 40.5 37.1 33.8 32.1

Refrigerated warehouse 51.5 47.8 44.1 40.4 36.8 34.9

Religious worship 51.9 48.2 44.5 40.8 37.1 35.2

Public assembly 47.1 43.7 40.4 37 33.6 32

Education 49.6 46.1 42.5 39 35.5 33.7

Food service 51.4 47.7 44 40.4 36.7 34.9

Inpatient health care 51.3 47.6 43.9 40.3 36.6 34.8

Nursing 51.8 48.1 44.4 40.7 37 35.1

Lodging 51.8 48.1 44.4 40.7 37 35.1

Strip shopping mall 42.6 39.5 36.5 33.5 30.4 28.9

Enclosed mall 42.6 39.5 36.5 33.5 30.4 28.9

Retail other than mall 42.6 39.5 36.5 33.5 30.4 28.9

Service 49.8 46.3 42.7 39.1 35.6 33.8

Other 52.4 48.7 44.9 41.2 37.4 35.6

U.S. Average 46.3 43 39.7 36.4 33.1 31.4

7-13
Table 7.4.6 and Table 7.4.7 present UEC for Integrated High-Lumen GSLs in the

residential sector by reportable domain and in the commercial sector by building type.

Table 7.4.6 Annual Energy Use for Integrated High Lumen (≥ 2,000 lm) GSLs in the 

Residential Sector

RECS Reportable Domain CSL 0 

(kWh/yr)

CSL 1 

(kWh/yr)

CSL 2 

(kWh/yr)

01. CT, ME, NH, RI, VT 31.3 29.4 28.4

02. MA 30.8 28.9 28.0

03. NY 37.7 35.3 34.2

04. NJ 33.0 31.0 29.9

05. PA 33.0 31.0 29.9

06. IL 26.3 24.7 23.9

07. IN, OH 27.2 25.5 24.6

08. MI 26.8 25.1 24.3

09. WI 26.8 25.1 24.3

10. IA, MN, ND, SD 26.8 25.1 24.3

11. KS, NE 26.8 25.1 24.3

12. MO 26.8 25.1 24.3

13. VA 27.5 25.7 24.9

14. DE, DC, MD, WV 28.2 26.4 25.6

15. GA 26.9 25.2 24.4

16. NC, SC 27.4 25.7 24.8

17. FL 27.5 25.7 24.9

18. AL, KY, MS 27.5 25.7 24.9

19. TN 27.5 25.7 24.9

20. AR, LA, OK 27.1 25.4 24.6

21. TX 27.1 25.4 24.6

22. CO 18.7 17.6 17.0

23. ID, MT, UT, WY 18.7 17.6 17.0

24. AZ 18.7 17.6 17.0

25. NV, NM 18.7 17.6 17.0

26. CA 18.1 17.0 16.4

27. AK, HI, OR, WA 20.6 19.3 18.6

U.S. Average 26.6 24.9 24.1

7-14
Table 7.4.7 Annual Energy Use for Integrated High Lumen (≥ 2,000 lm) GSLs in the 

Commercial Sector

Building Type CSL 0 

(kWh/yr)

CSL 1 

(kWh/yr)

CSL 2 

(kWh/yr)

Office 92.3 86.5 83.6

Laboratory 120 112 109

Nonrefrigerated warehouse 118 110 107

Food sales 100 93.8 90.6

Public order and safety 123 115 111

Outpatient health care 108 101 97.9

Refrigerated warehouse 118 110 107

Religious worship 119 111 108

Public assembly 108 101 97.6

Education 113 106 103

Food service 117 110 106

Inpatient health care 117 110 106

Nursing 118 111 107

Lodging 118 111 107

Strip shopping mall 97.3 91.2 88.2

Enclosed mall 97.3 91.2 88.2

Retail other than mall 97.3 91.2 88.2

Service 114 107 103

Other 120 112 109

U.S. Average 106 99.2 95.9

7-15
Table 7.4.8 and Table 7.4.9 present UEC for Non-Integrated GSLs in the residential 

sector by reportable domain and in the commercial sector by building type.

Table 7.4.8 Annual Energy Use (kWh/year) for Non-Integrated GSLs in the Residential 

Sector

RECS Reportable Domain CSL 0 

(kWh/yr)

CSL 1A 

(kWh/yr)

CSL 1B 

(kWh/yr)

01. CT, ME, NH, RI, VT 29.3 29.3 23.9

02. MA 28.9 28.9 23.5

03. NY 35.3 35.3 28.7

04. NJ 30.9 30.9 25.2

05. PA 30.9 30.9 25.2

06. IL 24.7 24.7 20.1

07. IN, OH 25.5 25.5 20.7

08. MI 25.1 25.1 20.5

09. WI 25.1 25.1 20.5

10. IA, MN, ND, SD 25.1 25.1 20.5

11. KS, NE 25.1 25.1 20.5

12. MO 25.1 25.1 20.5

13. VA 25.7 25.7 20.9

14. DE, DC, MD, WV 26.4 26.4 21.5

15. GA 25.2 25.2 20.5

16. NC, SC 25.6 25.6 20.9

17. FL 25.7 25.7 20.9

18. AL, KY, MS 25.7 25.7 20.9

19. TN 25.7 25.7 20.9

20. AR, LA, OK 25.4 25.4 20.7

21. TX 25.4 25.4 20.7

22. CO 17.6 17.6 14.3

23. ID, MT, UT, WY 17.6 17.6 14.3

24. AZ 17.6 17.6 14.3

25. NV, NM 17.6 17.6 14.3

26. CA 17.0 17.0 13.8

27. AK, HI, OR, WA 19.3 19.3 15.7

U.S. Average 24.9 24.9 20.3

7-16
Table 7.4.9 Annual Energy Use (kWh/year) for Non-Integrated GSLs in the Commercial 

Sector

Building Type CSL 0 

(kWh/yr)

CSL 1A 

(kWh/yr)

CSL 1B 

(kWh/yr)

Office 86.4 86.4 70.4

Laboratory 112 112 91.3

Nonrefrigerated warehouse 110 110 89.7

Food sales 93.7 93.7 76.3

Public order and safety 115 115 93.4

Outpatient health care 101 101 82.4

Refrigerated warehouse 110 110 89.7

Religious worship 111 111 90.5

Public assembly 101 101 82.1

Education 106 106 86.5

Food service 110 110 89.5

Inpatient health care 110 110 89.4

Nursing 111 111 90.2

Lodging 111 111 90.2

Strip shopping mall 91.2 91.2 74.2

Enclosed mall 91.2 91.2 74.2

Retail other than mall 91.2 91.2 74.2

Service 107 107 86.8

Other 112 112 91.3

U.S. Average 99.2 99.2 80.7

7-17
REFERENCES

1. DNV KEMA Energy and Sustainability and Pacific Northwest National Laboratory.

Residential Lighting End-Use Consumption Study: Estimation Framework and Baseline

Estimates. 2012.

http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2012_residential-lightingstudy.pdf.

2. NMR Group, Inc. and DNV GL. Northeast Residential Lighting Hours-of-Use Study.

2014. Connecticut Energy Efficiency Board, Cape Light Compact, Massachusetts Energy

Efficiency Advisory Council, National Grid Massachusetts, National Grid Rhode Island,

New York State Energy Research and Development Authority.

https://app.box.com/s/o1f3bhbunib2av2wiblu/1/1995940511/17399081887/1.

3. Nexant, Inc. and Apex Analytics, LLC. Georgia Power Company Residential Lighting

Saturation and Metering Study. 2013. Georgia Power Company.

4. Navigant Consulting, Inc., Cadmus Group, Inc., and Apex Analytics, LLC. EM&V

Report for the 2010-2011 Residential Energy Star Lighting Program. 2012. Prepared for

Duke / Progress Energy Carolinas.

5. TecMarket Works and Building Metrics. Duke Energy Residential Smart $aver CFL

Program in North Carolina and South Carolina: Results of a Process and Impact

Evaluation. 2011.

6. Navigant Consulting, Inc. and Cadmus Group, Inc. EmPOWER Maryland 2010 Interim

Evaluation Report. 2011. Baltimore Gas and Electric, Potomac Electric Power Company,

Delmarva Power and Light (DPL), Southern Maryland Electric Cooperative (SMECO),

and Allegheny Power (AP): Boulder, CO.

7. Vermont Energy Investment Corporation. State of Ohio Energy Efficiency Technical

Reference Manual. 2010. Public Utilities Commission of Ohio.

8. Cadmus Group, Inc. Lighting and Appliance Evaluation - PY 2. 2010. Ameren, Illinois.

http://ilsagfiles.org/SAG_files/Evaluation_Documents/Ameren/AIU%20Evaluation%

20Reports%20EPY2/AIU%20EPY2%20Draft/

AIU_Lighting_and_Appliance_PY2_Evaluation_DRAFT.pdf.

9. Ecotope Inc. Residential Building Stock Assessment: Metering Study. 2014. Northwest

Energy Efficiency Alliance: Seattle, WA. Report No. E14-283.

http://neea.org/docs/default-source/reports/residential-building-stock-assessment--

metering-study.pdf?sfvrsn=6.

10. U.S. Department of Energy–Energy Information Administration. 2009 RECS Survey

Data. (Last accessed October 10, 2014.)

http://www.eia.gov/consumption/residential/data/2009/.

7-18 
11. Navigant Consulting, Inc. Final Report: 2010 U.S. Lighting Market Characterization.

2012. http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan2012.pdf.

12. U.S. Department of Energy–Energy Information Administration. 2003 CBECS Survey

Data. (Last accessed October 6, 2014.)

http://www.eia.gov/consumption/commercial/data/2003/index.cfm?view=microdata.

13. Williams, A., B. Atkinson, K. Garbesi, E. Page, and F. Rubinstein. Lighting Controls in

Commercial Buildings. LEUKOS. 2012. 8(3): pp. 161–180.

7-19 
CHAPTER 8. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS

TABLE OF CONTENTS

8.1 INTRODUCTION ........................................................................................................... 8-1

8.1.1 General Approach for Life-Cycle Cost and Payback Period Analysis................ 8-1

8.1.2 Overview of Life-Cycle Cost and Payback Period Inputs................................... 8-2

8.2 LIFE-CYCLE COST INPUTS ........................................................................................ 8-5

8.2.1 Overview.............................................................................................................. 8-5

8.2.2 Lamp Sampling.................................................................................................... 8-6

8.2.2.1 Overview .................................................................................................... 8-6

8.2.2.2 Lamp Option Characteristics...................................................................... 8-7

8.2.2.3 Lumen Range Market Shares by Sector..................................................... 8-9

8.2.3 Consumer Samples............................................................................................. 8-13

8.2.4 Market Distribution of General Service Lamps by Candidate Standard 

Level .................................................................................................................. 8-14

8.2.5 Price Learning.................................................................................................... 8-15

8.2.6 Total Installed Cost Inputs................................................................................. 8-15

8.2.7 Operating Cost Inputs........................................................................................ 8-17

8.2.7.1 Operating Hours....................................................................................... 8-18

8.2.7.2 Energy Prices............................................................................................ 8-20

8.2.7.3 Energy Price Trends................................................................................. 8-22

8.2.7.4 Lifetime .................................................................................................... 8-23

8.2.7.5 Disposal Cost............................................................................................ 8-25

8.2.7.6 Residual Value ......................................................................................... 8-26

8.2.7.7 Discount Rates.......................................................................................... 8-27

8.3 PAYBACK PERIOD INPUTS...................................................................................... 8-34

8.4 LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS...................................... 8-35

8.4.1 “Market-Transformation” Approach Results..................................................... 8-37

8.4.1.1 Integrated Low-Lumen GSL Results ....................................................... 8-37

8.4.1.2 Integrated High-Lumen GSL Results....................................................... 8-40

8.4.1.3 Non-Integrated GSL Results.................................................................... 8-43

8.4.2 “Roll-up” Approach Results.............................................................................. 8-45

8.4.2.1 Integrated Low-Lumen GSL Results ....................................................... 8-45

8.4.2.2 Integrated High-Lumen GSL Results....................................................... 8-47

8.4.2.3 Non-Integrated GSL Results.................................................................... 8-48

8.4.3 Results in 2025................................................................................................... 8-49

8.4.3.1 Integrated Low-Lumen GSL Results ....................................................... 8-49

8.4.3.2 Integrated High-Lumen GSL Results....................................................... 8-51

8.4.3.3 Non-Integrated GSL Results.................................................................... 8-52

8.4.4 Rebuttable Presumption Payback Period........................................................... 8-53

REFERENCES .......................................................................................................................... 8-55

8-i
LIST OF TABLES

Table 8.1.1 Summary of Inputs to Life-Cycle Cost and Payback Period ......................... 8-5

Table 8.2.1 Reference Efficacy Values at Each CSL Used in Eq. 8.2. ............................. 8-8

Table 8.2.2 Representative GSL Characteristics for all Lumen Ranges ........................... 8-9

Table 8.2.3 GSL Market Distribution in the Base Case in 2020 .................................... 8-15

Table 8.2.4 Average Sales Tax Rates by RECS Reportable Domain ............................. 8-17

Table 8.2.5 Average Electricity Prices by RECS Reportable Domain ........................... 8-21

Table 8.2.6 Definitions of Income Groups ..................................................................... 8-27

Table 8.2.7 Types of Household Debt and Equity by Percentage Shares (%) ................ 8-29

Table 8.2.8 Data Used to Calculate Real Effective Mortgage Rates .............................. 8-30

Table 8.2.9 Average Real Effective Interest Rates for Household Debt ........................ 8-30

Table 8.2.10 Average Nominal and Real Interest Rates for Household Equity ............... 8-31

Table 8.2.11 Average Real Effective Discount ................................................................. 8-32

Table 8.2.12 Risk-Free Rate and Equity Risk Premium, 2010-2012 ................................ 8-33

Table 8.2.13 Weighted Average Cost of Capital for Analyzed Sectors ........................... 8-34

Table 8.4.1 Average LCC and PBP Results by Candidate Standard Level for 

Integrated Low-Lumen GSLs ...................................................................... 8-37

Table 8.4.2 Average LCC Savings for Integrated Low-Lumen GSLs ............................ 8-38

Table 8.4.3 Average LCC and PBP Results by Candidate Standard Level for 

Integrated High-Lumen GSLs...................................................................... 8-41

Table 8.4.4 Average LCC Savings for Integrated High-Lumen GSLs ........................... 8-41

Table 8.4.5 Average LCC and PBP Results by Candidate Standard Level for NonIntegrated GSLs ........................................................................................... 8-44

Table 8.4.6 Average LCC Savings for Non-Integrated GSLs ........................................ 8-44

Table 8.4.7 Average LCC and PBP Results by Candidate Standard Level for 

Integrated Low-Lumen GSLs ...................................................................... 8-46

Table 8.4.8 Average LCC Savings for Integrated Low-Lumen GSLs ............................ 8-47

Table 8.4.9 Average LCC and PBP Results by Candidate Standard Level for 

Integrated High-Lumen GSLs...................................................................... 8-48

Table 8.4.10 Average LCC Savings for Integrated High-Lumen GSLs ........................... 8-48

Table 8.4.11 Average LCC and PBP Results by Candidate Standard Level for NonIntegrated GSLs ........................................................................................... 8-49

Table 8.4.12 Average LCC Savings for Non-Integrated GSLs ........................................ 8-49

Table 8.4.13 Average LCC and PBP Results by Candidate Standard Level for 

Integrated Low-Lumen GSLs ...................................................................... 8-50

Table 8.4.14 Average LCC Savings for Integrated Low-Lumen GSLs ............................ 8-51

Table 8.4.15 Average LCC and PBP Results by Candidate Standard Level for 

Integrated High-Lumen GSLs...................................................................... 8-52

Table 8.4.16 Average LCC Savings for Integrated High-Lumen GSLs ........................... 8-52

Table 8.4.17 Average LCC and PBP Results by Candidate Standard Level for NonIntegrated GSLs ........................................................................................... 8-53

Table 8.4.18 Average LCC Savings for Non-Integrated GSLs ........................................ 8-53

8-ii
LIST OF FIGURES

Figure 8.1.1 Life-Cycle Cost Flow Diagram ...................................................................... 8-4

Figure 8.1.2 Payback Period Flow Diagram ...................................................................... 8-4

Figure 8.2.1 Residential Sector Lumen Range Distribution for the Integrated LowLumen Product Class ................................................................................... 8-12

Figure 8.2.2 Commercial Sector Lumen Distribution for the Integrated Low-Lumen 

Product Class ............................................................................................... 8-13

Figure 8.2.3 Trends in Residential Electricity Prices ....................................................... 8-22

Figure 8.2.4 Trends in Commercial Electricity Prices ..................................................... 8-23

Figure 8.2.5 Probability of Survival as a Function of GSL Age (Reference 

Scenario) ...................................................................................................... 8-25

Figure 8.4.1 Range of LCC Savings in Residential Sector for Integrated LowLumen GSLs ................................................................................................ 8-39

Figure 8.4.2 Range of LCC Savings in Commercial Sector for Integrated LowLumen GSLs ................................................................................................ 8-39

Figure 8.4.3 LCC Savings Distribution in Residential Sector for Integrated LowLumen GSLs at CSL 5 ................................................................................. 8-40

Figure 8.4.4 LCC Savings Distribution in Commercial Sector for Integrated LowLumen GSLs at CSL 5 ................................................................................. 8-40

Figure 8.4.5 Range of LCC Savings in Residential Sector for Integrated HighLumen GSLs ................................................................................................ 8-42

Figure 8.4.6 Range of LCC Savings in Residential Sector for Integrated HighLumen GSLs ................................................................................................ 8-42

Figure 8.4.7 LCC Savings Distribution in Residential Sector for Integrated LowLumen GSLs at CSL 2 ................................................................................. 8-43

Figure 8.4.8 LCC Savings Distribution in Commercial Sector for Integrated LowLumen GSLs at CSL 2 ................................................................................. 8-43

Figure 8.4.9 Range of LCC Savings in Residential Sector (left) and Commercial 

Sector (right) at CSL 1 for Non-Integrated GSLs ........................................ 8-45

8-iii
CHAPTER 8. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS

8.1 INTRODUCTION

The effect of efficiency standards on individual consumers typically includes a reduction 

in operating expense and an increase in purchase cost. This chapter describes the methodology 

and metrics the U.S. Department of Energy (DOE) used to analyze the economic impacts of 

energy conservation standards for general service lamps (GSLs) on consumers.a

 DOE used the 

following metrics for its analyses: 

• Life-cycle cost (LCC) is the total consumer expense over the life of a product, including

purchase, installation costs and operating costs (which are comprised of maintenance,

repair, and energy costs). After discounting the future operating costs to the time of

purchase, DOE sums the present value of all costs incurred over the lifetime of the

product.

• Payback period (PBP) is the amount of time it takes consumers to recover the assumed

higher purchase price of more energy-efficient products through lower operating costs.

Inputs to the LCC and PBP calculations are discussed in sections 8.2 and 8.3 of this

chapter, respectively. Calculations and results for the LCC and PBP analysis, for each different 

candidate standard level (CSL), are presented in section 8.4. The calculations discussed here are 

illustrated with a Microsoft Excel® spreadsheet, which is accessible on DOE’s rulemaking 

website for GSLs: 

(http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx?ruleid=83).

Details on the spreadsheet, and instructions for using it, are included in appendix 8A. 

8.1.1 General Approach for Life-Cycle Cost and Payback Period Analysis 

Because consumers use GSLs differently, several inputs to the determination of consumer 

LCC and PBP are either variable or uncertain. DOE analyzes the variability and uncertainty in 

the LCC and PBP inputs by performing calculations for a representative sample of individual 

consumers that purchase GSLs. DOE uses Monte Carlo simulationb

 and probability distributions 

for a sample of 10,000 consumers in the LCC and PBP analysis. 

In addition to characterizing several of the inputs to the analysis with probability 

distributions, DOE developed a sample of individual buildings in the residential and commercial 

sectors that include GSLs.c

 By developing building samples, DOE was able to account for the 

variability in energy consumption, energy price, or both, associated with GSL purchases made in 

each sampled building. 

a For the purposes of the PBP and LCC analysis, a consumer is someone who purchases and uses a GSL.

b For details on the Monte Carlo simulation, see appendix 8B

c According to the 2010 Lighting Market Characterization (LMC), the industrial sector represents less than 1% of 

the overall GSL market.1 Therefore, DOE excluded the industrial sector from this analysis.

8-1 
DOE displays the LCC results as distributions of impacts relative to the absence of an 

energy conservation standard (hereafter referred to as the “base case”). Results are presented at 

the end of this chapter and are based on 10,000 samples per Monte Carlo simulation run. 

8.1.2 Overview of Life-Cycle Cost and Payback Period Inputs

DOE categorizes inputs to the LCC and PBP analysis for each CSL as follows: (1) inputs 

for establishing the total installed cost (i.e., purchase price plus installed cost), and (2) inputs for 

calculating the operating cost.

The primary inputs for establishing the total installed cost are:

• End-User Product Price: The weighted-average end-user GSL prices from the 

engineering analysis. See chapter 6 of this technical support document (TSD) for details 

on the product price methodology. 

• Sales tax: The State and local retail sales tax.

Note that DOE did not take into account installation cost as one of the total installed cost 

inputs. As discussed in the framework document, DOE assumes that the installation cost, which 

represents all costs required to install the GSL, is not affected by changes in product efficiency 

and is therefore the same for all CSLs within a given product class and sector. DOE seeks 

comment on this approach.

The primary inputs for calculating the operating cost are:

• Power rating: The site electricity usage rate associated with operating the GSL. Chapter 5 

of this TSD details how DOE determined the power ratings for representative GSLs. For 

the integrated low-lumen product class, DOE considered representative lamps across four 

lumen ranges. See section 8.2.2 for more details. In the reference scenario, DOE did not 

account for any standby power that GSLs may have. 

• Annual Operating Hours: The estimated number of hours a GSL is used over a period of 

one year. Chapter 7 of this TSD discusses how DOE estimated the GSL operating hours 

for various geographical regions, rooms (in the residential sector), and building types (in 

the commercial sector). In the LCC and PBP analysis, DOE developed hours-of-use 

(HOU) distributions. See section 8.2.7.1 for details.

• Energy prices: The prices paid by consumers for electricity.

• Energy price trends: Forecasted electricity prices, as reported in the Energy Information 

Administration’s Annual Energy Outlook 2014 (AEO2014).

2

• Repair and maintenance costs: Repair costs are those associated with repairing or 

replacing GSLs that have failed. DOE did not take into account repair costs because 

consumers typically dispose of GSLs when they fail. Also, DOE did not take into account 

maintenance costs, if any, because those are considered to be independent of efficiency 

improvements and, therefore, do not vary across CSLs. 

8-2
• Disposal Cost: After GSLs reach the end of their life, some consumers pay to recycle or 

discard those lamps. The GSL disposal cost represents the cost of disposing these lamps.

• Lamp Residual Value: The remaining value of the surviving lamp(s) at the end of the 

LCC analysis period.

d

• Lifetime: The age at which the GSL is retired from service.

• Discount rate: The rate at which DOE discounts future expenditures to establish their 

present value.

The data inputs to the PBP for each CSL are the total installed cost to the consumer of a GSL

(relative to the installed cost of a baseline lamp) and the operating expenses in the first year of 

ownership. In this preliminary analysis, DOE used a “simple” PBP calculation, which does not 

take into account changes in operating cost over time. Thus, the input to the total installed cost is

the end-user product price (including sales tax) and the inputs to the first year’s operating 

expenses are the annual operating hours, the GSL power rating, and the electricity price in the 

compliance year of this rulemaking (2020). 

Figure 8.1.1 and Figure 8.1.2 depict the relationships among inputs for installed cost and 

operating costs that DOE used to calculate the LCC and PBP, respectively. The yellow boxes 

indicate inputs, the green boxes indicate intermediate outputs, and the blue boxes indicate final 

outputs (the LCC and PBP). 

d The LCC analysis period is based on the lifetime of the shortest-lived lamp in each product class and sector 

(residential or commercial). See section 8.2.7.6 for details on the residual value. 

8-3

 
Figure 8.1.1 Life-Cycle Cost Flow Diagram

Figure 8.1.2 Payback Period Flow Diagram

8-4
Table 8.1.1 Summary of Inputs to Life-Cycle Cost and Payback Period

Inputs Average or Typical Value Characterization

Total Installed Cost Inputs

Product Price Varies by efficiency level and 

product class Single-point value

Sales Tax 7.1% Varies by region

Operating Cost Inputs

Power Rating Varies by CSL and product class Single-point value

Operating Hours Residential sector: 2.3 hrs/day

Commercial sector: 10.7 hrs/day

Residential: Distribution - varies by 

room type and region 

Commercial: Distribution - varies

by building type

Electricity Prices Residential sector: $0.13 /kWh

Commercial sector: $0.11 /kWh Vary by region and sector

Electricity Price 

Trends AEO2014 reference case Vary by AEO growth scenario

Lamp Disposal 

Costs

Residential sector: None

Commercial sector: 1$ for 10% of

CFLs 

Vary by sector

Product Lifetime

Median*

Residential CFL: 6.8 yrs

Residential LED: 19.2 yrs

Commercial CFL: 2.7 yrs

Commercial LED: 6.8 yrs

Weibull distribution

(see appendix 8E)

Discount Rate

Residential: Mean real discount 

rates range from 0% to 11%.

Commercial: Mean real discount 

rates range from 5.1% to 6.1%.

Distribution (see appendix 8C)

Date Standards 

Become Effective

2020 (3 years after expected 

publication of a potential final rule) Single-point value

*Median lifetimes listed here correspond to CFLs for which the rated lifetime is 10,000 hours and LEDs for which 

the rated lifetime is 25,000 hours.

8.2 LIFE-CYCLE COST INPUTS

8.2.1 Overview

The LCC analysis calculates the average LCC of GSLs for consumers at each CSL 

based on the LCCs of purchases of representative products. LCC is the total consumer expense 

over the life of a product, including initial and operating costs. DOE discounts future operating 

costs to the time of purchase and sums all costs over the lifetime of the product. 

For an individual GSL purchase, DOE defines the LCC by the following equation:

8-5
LLLLLL = II + � OO yy

(1 + rr)yy + DC

1

(1 + rr)NN − RV

NN

yy=1

Eq. 8.1

Where:

LCC = life-cycle cost, in dollars,

IC = total installed cost, in dollars,

N = LCC analysis period, in years,

OC = annual operating cost, in dollars,

DC= disposal cost, in dollars,

RRRR = residual value, in dollars, for GSLs with lifetimes greater than the analysis period,

e

r = discount rate, and

y = year for which the operating cost is being determined.

DOE expresses costs in 2014$. Total installed cost, operating cost, lifetime, and discount 

rate are discussed in the following sections. DOE used 2020 as the product purchase year for the 

LCC calculation, as 2020 is the assumed compliance date of this rulemaking.

To determine the impact of standards on the average LCC for all U.S. consumers, DOE 

must address how the numerous LCC inputs vary across U.S. residential and commercial 

consumers, and how the standard itself affects the LCC through the standard’s indirect effect on 

equipment and operating costs. The following sections develop the inputs necessary to address 

those factors.

8.2.2 Lamp Sampling

8.2.2.1 Overview

Because of the high variability in LED lamp price by light output, DOE analyzed the 

LCC and PBP across four lumen ranges (310-749 lm, 750-1049 lm, 1050-1489 lm, and 1490-

1999 lm) f for the integrated low-lumen product class, which is the only product class that 

includes LED lamps. 

The engineering analysis and product price determination (chapters 5 and 6 of this TSD, 

respectively) yielded representative integrated low-lumen lamp options at each CSL for the 750-

1049 lumen range. From these representative lamp options, DOE developed representative lamp 

options for all other lumen ranges. The following sections discuss in detail how DOE developed 

these lamp options as well as the market share of each lumen range in the base case.

e The residual value is the present value benefit a consumer receives for not having to buy another GSL at the end of 

the analysis period, because the GSL is operational after the end of the LCC analysis period. Therefore, the residual 

value is subtracted from the LCC calculation, as it is applied as a credit to the consumer. For details on the residual 

value, see section 8.2.7.6. f These lumen ranges were based on the rated lumen ranges for general service incandescent lamps, which were 

established by the Energy Independence and Security Act of 2007 (EISA).3 Because the 4 lumen ranges apply only 

to the integrated low-lumen product class, the 4th lumen range covers 1490-1999 lumens, as opposed to 1490-2600 

in EISA. 

8-6

 
8.2.2.2 Lamp Option Characteristics

First, DOE identified a characteristic lumen output for each of the lumen ranges (310-749 

lm, 750-1049 lm, 1050-1489 lm, and 1490-1999 lm): 500, 800, 1200, and 1600 lumens, 

respectively.g Then, DOE multiplied the lumen output for each representative lamp option from 

the engineering analysis by the ratio of characteristic lumen output for each range to the lumen 

output for the 750-1049 lm range. For example, the lumen output of lamps at each CSL in the 

310-749 lm range was assumed to be a factor of 500/800 as large as the lumen output of the 

corresponding representative lamp option in the 750-1049 lumen range. This yielded lumen 

output values for six lamp options, one for each CSL, in each of the four lumen ranges.

Using the resulting lumen-output value for each lamp option, DOE determined an 

efficacy, and hence a wattage, for each lamp option using to the formula used to define the 

minimum efficacy for each CSL in the engineering analysis:

LLLLWWii = RRRRRR WWCCCCCC,ii − 29.42 × 0.9983 LLmmii

RRRRRR WWCCCCCC,ii − 29.42 × 0.9983 LLmmCCCCCC,RRRRRR

× LLLLWWCCCCCC,RRRRRR

Eq. 8.2

Where:

LLLLWWii = the efficacy of lamp option ii in lumens per watt,

RRRRRR WWCCCCCC,ii = the reference efficacy used to define the CSL corresponding to lamp option ii, 

summarized in Table 8.2.1,

LLLLmmii = the lumen output of lamp option ii, 

LLLLmmCCCCCC,RRRRRR = the lumen output of the representative lamp, in the 750-1049 lumen range, 

which corresponds to the same CSL as lamp option ii, and

LLLLWWCCCCCC,RRRRRR= the efficacy, in lumens per watt, of the representative lamp that corresponds to 

the same CSL as lamp option ii.

The reference efficacy values RRRRRR WWCCCCCC,ii are presented in Table 8.2.1. Since there is no 

reference value for CSL 0, DOE used the reference values for CSL 1 in Eq. 8.2 when developing 

efficacy values for lamp options at CSL 0.

g DOE used these lumen values based on typical lumen output data in CFLs and LEDs in each of the lumen ranges 

based on review of product offerings available in-store and online.

8-7

 
Table 8.2.1 Reference Efficacy Values at Each CSL Used in Eq. 8.2.

CSL Reference efficacy

0 N/A

1 67.6

2 74.2

3 80.2

4 87.5

5 90.8

To develop prices for the lamp options in the three lumen ranges for which price data 

were not available from the product price determination (chapter 6 of this TSD), DOE collected 

online retail datah for CFLs and LEDs across all four lumen ranges. To determine the 

characteristic lamp prices by lumen range and lamp technology, DOE calculated a weighted 

averagei

of the 10th percentile in price for GSL models available from four retailers, 

disaggregated by lumen range and lamp technology. The 10th percentile in price was selected 

because, according to a Lawrence Berkeley National Laboratory report,

5 for LED GSLs this 

percentile corresponds approximately to the median purchase price. To obtain a final price for 

the lamp options in each lumen range, DOE multiplied the price of each representative lamp in 

the engineering analysis by the ratio of the technology-specific weighted-average retail lamp 

price in each lumen range to the corresponding weighted-average retail price in the 750-1049 lm 

range.

Finally, DOE assumed that the lifetime for the representative lamps across all lumen 

ranges was the same as the lifetime of the representative lamp option in the 750-1049 lumen 

range from the engineering analysis at each CSL. Table 8.2.2 presents characteristics for all 

representative lamps across all CSLs and lumen ranges. 

h The online retail data consisted of 1,031 medium screw base (E26) CFLs, and 289 E26 LED lamps, between 310 

and 2600 lumens, collected in July 2014. The data were collected from the following retailers: 

www.homedepot.com, www.bulbs.com, www.elightbulbs.com, and www.1000bulbs.com. i

Detailed share data across the 4 retailers was not available in this analysis. However, DOE is aware that that home 

improvement stores have a much larger market share than online retailers.4 To account approximately for these 

relative market shares, DOE weighted the prices of each retailer as follows: 50% for Home Depot, and 16.67% for 

each online retailer.

8-8

 
Table 8.2.2 Representative GSL Characteristics for all Lumen Ranges

Lumen Range 

(lm) CSL Lamp Technology

Initial 

Lamp 

Lumens

Nominal 

Wattage

Efficacy 

(lm/W)

Price in 

2020*

(2014$)

310-749

0 CFL 469 9.5 49.1 5.20

1 CFL 500 8.9 56.4 3.30

2 LED 500 8.1 61.6 25.72

3 LED 500 7.4 67.7 16.38

4 LED 500 6.7 75.0 6.94

5 LED 500 6.3 79.1 6.59

750-1049

0 CFL 750 14.0 53.6 5.62

1 CFL 800 13.0 61.5 3.57

2 LED 800 12.0 66.7 28.12

3 LED 800 11.0 72.7 17.91

4 LED 800 10.0 80.0 6.98

5 LED 800 9.5 84.2 6.63

1050-1489

0 CFL 1125 19.8 56.9 7.08

1 CFL 1200 18.4 65.4 4.50

2 LED 1200 17.0 70.4 46.83

3 LED 1200 15.7 76.5 29.83

4 LED 1200 14.3 83.7 7.25

5 LED 1200 13.6 88.0 6.89

1490-1999

0 CFL 1500 25.6 58.6 7.96

1 CFL 1600 23.8 67.3 5.06

2 LED 1600 22.1 72.3 68.14

3 LED 1600 20.4 78.3 43.40

4 LED 1600 18.7 85.6 7.57

5 LED 1600 17.8 89.9 7.18

*Note that the price of some lamp options may be lower than their price in 2014, due to price learning.

8.2.2.3 Lumen Range Market Shares by Sector

Residential Sector

To find the lumen distribution in the residential sector for the integrated low-lumen 

product class, DOE used the Residential Lighting End-Use Consumption Study (RLEUCS),

6 and 

data from Cadeo Group.

7

8-9
RLEUCS includes characteristic GSL data for the U.S. residential sector by housing type, 

lamp type, lamp technology, room type, and U.S. geographic region. DOE assumed that 

RLEUCS includes GSLs within the 310-2,600 lumen range. DOE first used GSL wattage data 

from RLEUCS for which the lamp technology type was specified, and converted the wattage 

data to lumens using a wattage-to-efficacy relationshipjfor each lamp technology in the

RLEUCS dataset.

k After converting the RLEUCS wattages to approximate lumens, DOE 

computed the weighted national average lamp lumens from the RLEUCS dataset, which was 831 

lumens. The weighted average lumen value was used in order to calculate the market share of all 

lumen ranges, and was calculated by applying a weighting factor to the RLEUCS dataset, as 

shown in Eq. 8.3:

LLmmaaaaaa = �LL ii ×

nn

ii=0

LLii × NNii

∑ LLii × NNii nn

ii=0

Eq. 8.3

Where:

LLmmaaaaaa= weighted average lumens in the RLEUCS dataset,

ii= representative lighting characteristic in the RLEUCS dataset,

LLii= number of lamps per household in the RLEUCS dataset,

NNii= number of U.S. households in the RLEUCS dataset, and

∑ LLii × NNii nn

ii=0 = total of number of GSLs in the RLEUCS dataset.

Next, DOE used data from Cadeo Group to estimate the market share of each lumen 

range. These data, which were based on sales data from a mass market retailer focused on the 

residential market, included market shares for the 1050-1489 lm and 1490-2600 lm ranges. 

Those market shares were 8.7% and 11.4%, respectively. DOE assumed that the representative 

lumens for these lumen ranges were 1200 lumens for the 1050-1489 lm range and 1600 lumens 

for the 1490-2600 lm range.

Based on these assumptions and the weighted average lumens from the RLEUCS dataset

(831 lumens), DOE was able to estimate the market shares of the 310-749 lm and 750-1049 

lumen ranges using Eq. 8.4 and Eq. 8.5. 

j

For incandescent GSLs, DOE used the wattage-to-efficacy relationship specified in the 2009 energy conservation 

standards for General Service Incandescent Lamps.8 For CFL GSLs, DOE used the wattage-to-efficacy relationship 

from an ENERGY STAR lighting fact sheet.9 DOE did not use a wattage-efficacy relationship for LEDs because 

RLEUCS did not include wattage data on LEDs.

k For the purposes of this analysis, the RLEUCS dataset was a subset of all lighting characteristics available in 

RLEUCS. This dataset consisted of incandescent or CFL ‘space lamps’ for all RECS reportable domains. The 

dataset was derived from the (complementary to RLEUCS report) Residential Lighting Usage Estimate Tool, 

available at http://www1.eere.energy.gov/buildings/ssl/residential-lighting-study.html.

8-10

 
LL aaaaaa = 1 × 500 + 2 × 800 + 3 × 1200 + 4 × 1600

Eq. 8.4

1 + 2 + 3 + 4 = 1

Eq. 8.5

Where:

LL aaaaaa = weighted average lumens in the RLEUCS dataset (831 lumens),

3 = the market share of the 1050-1489 lm range (8.7%), and

4 = the market share of the 1490-2600 lm range (11.4%)

In order to calculate the relative market shares of the four lumen ranges in the integrated 

low-lumen product class, which has an upper lumen bound of 1999 lumens, DOE first estimated 

the market share of the 1490-1999 lumen range in comparison to the market share of the 1490-

2600 lumen range. DOE used model counts of GSLs available online and found that the 1490-

1999 portion of the lumen range represented 76% of the market share of the 1490-2600 lumen 

range.l

Based on this estimate, DOE renormalized the market shares for the four lumen ranges of 

the integrated low-lumen product class. The market shares for the 310-749 lm, 750-1049 lm, 

1050-1489 lm, and 1490-1999 lm range were calculated to be 32.5%, 49.7%, 9.0%, and 8.9%m, 

respectively, as shown in Figure 8.2.1. DOE assumed that the characteristic lumen output for the 

1490-1999 lumen range was 1600 lumens, as with the 1490-2600 lumen range. Using the 

updated lumen range market shares and Eq. 8.4, DOE also calculated the average lumen output 

for this product class to be 810 lumens. This lumen value was later used in the analysis to 

estimate the average lumens of each room type in the RLEUCS database, as discussed in section 

8.2.7.1

l

To derive this estimate, DOE used online retail data for GSLs between 1490-2600 lumens from the 4 retailers 

discussed previously (www.homedepot.com, www.bulbs.com, www.elightbulbs.com, and www.1000bulbs.com) 

and found that 367 from a total of 484 GSLs in that dataset, or 76%, were in the 1490-1999 lm range. m The sum of these market shares does not sum to 100% due to rounding

8-11

 
Figure 8.2.1 Residential Sector Lumen Range Distribution for the Integrated Low-Lumen 

Product Class 

Commercial Sector

To determine the lumen distribution for the integrated low-lumen product class in the 

commercial sector, DOE used California shelf survey datan for GSLs from DNV KEMA.

10 The 

KEMA shelf survey data include breakdowns by lamp technology, lumen range, and base type. 

Due to a lack of commercial-sector lumen distribution data for integrated low-lumen GSLs, and 

because pin-based CFLs are predominantly used in the commercial sector,

1 DOE assumed that 

the market shares across lumen ranges for the integrated low-lumen product class in the 

commercial sector would be equal to the market shares across lumen ranges for pin-based CFLs. 

These market shares for the 310-749 lm, 750-1049 lm, 1050-1489 lm, and 1490-1999 lm range 

were calculated to be 9.0%, 44.1%, 18.8%, and 28.1, and are shown in Figure 8.2.2.

n The shelf survey data were collected in summer of 2013 in 201 retail stores throughout utility service territories in 

California. 

8-12

 
Figure 8.2.2 Commercial Sector Lumen Distribution for the Integrated Low-Lumen 

Product Class 

8.2.3 Consumer Samples

As described previously, the LCC of an individual consumer depends on operating cost, 

which in turn depends on electricity use and price. Calculating the average LCC of U.S. 

consumers therefore requires data on the variation in energy use and price across the nation. 

These data were obtained from energy consumption surveys for residences and commercial 

buildings administered by the Energy Information Administration (EIA).

DOE used the EIA’s 2009 Residential Energy Consumption Survey (RECS)

11 and the 

2003 Commercial Buildings Energy Consumption Survey (CBECS)

12 to develop building 

samples for GSLs in the residential and commercial sector, respectively. RECS and CBECS 

were constructed by the EIA to be a national representation of the residential and commercial 

sector in the United States. RECS is a national sample survey of housing units that collects 

statistical information on the consumption of, and expenditures for, energy in housing units, 

along with data on energy-related characteristics of the housing units and occupants. RECS 2009 

included data from 12,083 housing units to represent almost 113.6 million households. DOE 

weighted each of the housing units in RECS according to the number of U.S. households it 

represented. CBECS collects energy-related data for commercial buildings in the United States. 

CBECS 2003 included data from 5,215 buildings to represent 4.9 million buildings. CBECS

categorizes building types by their principal building activity. DOE excluded vacant buildings

from its sample and weighted each remaining building according to the building weighto defined 

in chapter 7 of this TSD. 

o The building weight is derived from the product of each CBECS building’s area, the number of buildings each 

CBECS building represents, the number of lamps per 1000 ft2 by building type, and the percentage of lamps that are 

GSLs in each building type.

8-13

 
8.2.4 Market Distribution of General Service Lamps by Candidate Standard Level

To estimate the average LCC savings of a CSL, DOE first considers the market 

distribution by CSL, for each product class and sector, in the base case at the assumed

compliance year (2020). DOE then considers the market distribution by CSL, for each product 

class and sector, if a standard were in place, at the assumed compliance year (the candidate 

standards case efficiency distributions). 

The methodology to determine the base case and candidate standards case distributions in 

2020 is discussed in detail in chapter 9 of this TSD. Table 8.2.3 presents the base case 

distribution by CSL, for all product classes, and for both the residential and commercial sectors. 

Note that for the integrated low-lumen product class, the distribution for all lumen ranges is 

included.

8-14
Table 8.2.3 GSL Market Distribution in the Base Case in 2020

Sector CSL

Market Share (%)

Integrated Low-Lumen Integrated 

High-Lumen

NonIntegrated

310-749 lm

750-1049 lm

1050-1489 lm

1500-1999 lm

Residential

0 1.1 1.1 1.1 1.1 21.4 65.4

1 49.0 48.7 47.4 46.9 31.8 30.5 4.1

2 0.6 0.5 0.2 0.1 46.8

3 2.2 1.8 0.7 0.3

4 20.5 20.9 22.2 22.6

5 26.6 26.9 28.5 29.0

Total 100 100 100 100 100 100

Commercial

0 0.1 0.1 0.1 0.1 19.0 65.4

1 56.7 55.7 52.1 50.9 43.3 30.5 4.1

2 0.0 0.0 0.0 0.0 37.7

3 0.3 0.2 0.0 0.0

4 16.2 16.7 18.3 18.8

5 26.6 27.2 29.5 30.3

Total 100 100 100 100 100 100

Note: For the LCC and PBP analysis, DOE assumed that the market distributions of non-integrated high lumen 

GSLs are the same in the residential and commercial sector.

8.2.5 Price Learning

As described in section 8.1.2, lamp prices in the compliance year are an input to the LCC 

analysis. DOE uses a price learning analysis to account for changes in lamp prices that are 

expected to occur between the time for which DOE has data for lamp prices (2014) and the 

assumed compliance date of the rulemaking (2020). Price learning is also incorporated into the 

residual value of GSLs. Chapter 9 of this TSD discusses in detail the methodology DOE 

followed on price learning.

8.2.6 Total Installed Cost Inputs

DOE developed end-user product prices in chapter 6 of this TSD. In addition, as 

discussed previously, for the integrated low-lumen product class, DOE also developed end-user 

product prices for all lumen ranges in that product class. DOE added sales tax to these prices to 

derive final product prices, or total installed costs. 

8-15
DOE calculated the total installed cost based on the following equation:

II = FC × (1 + TTTTTT)

Eq. 8.6

Where:

FF = end-user weighted-average GSL price, in dollars, and

TTTTTT= sales tax markup.

The sales tax is a multiplicative factor that represents state and local sales taxes applied to 

the consumer price. DOE derived state and local taxes from data provided by the Sales Tax 

Clearinghouse.

13 DOE derived population-weighted average14 tax values for each RECS 

reportable domain, and at national level, as shown in Table 8.2.4p:

p The table presents sales tax for each RECS reportable domain. In the commercial sector, DOE used populationweighted average sales tax data to each Census Division and Large State.

8-16

 
Table 8.2.4 Average Sales Tax Rates by RECS Reportable Domain

RECS Reportable

Domain

Population 

(2013) Tax Rate (2014)

01. CT, ME, NH, RI, VT 7,925,982 5.1%

02. MA 6,692,824 6.3%

03. NY 19,651,127 8.5%

04. NJ 8,899,339 7.0%

05. PA 12,773,801 6.4%

06. IL 12,882,135 8.0%

07. IN, OH 18,141,710 7.1%

08. MI 9,895,622 6.0%

09. WI 5,742,713 5.5%

10. IA, MN, ND, SD 10,079,066 6.9%

11. KS, NE 4,762,473 7.2%

12. MO 6,044,171 7.4%

13. VA 8,260,405 4.0%

14. DE, DC, MD, WV 9,355,316 5.4%

15. GA 9,992,167 7.1%

16. NC, SC 14,622,899 7.0%

17. FL 19,552,860 6.7%

18. AL, KY, MS 12,220,224 7.3%

19. TN 6,495,978 9.5%

20. AR, LA, OK 11,435,411 8.7%

21. TX 26,448,193 8.0%

22. CO 5,268,367 6.1%

23. ID, MT, UT, WY 6,110,831 5.3%

24. AZ 6,626,624 7.2%

25. NV, NM 4,875,423 7.4%

26. CA 38,332,521 8.4%

27. AK, HI, OR, WA 13,040,657 5.3%

National 316,128,839 7.1%

8.2.7 Operating Cost Inputs

DOE defines the operating cost (OC) for GSLs in year t by the following equation:

8-17
OO tt = UEC × EE tt

Eq. 8.7

Where:

UU = annual unit energy consumption (defined in chapter 7 of this TSD), in kWh per year, 

and 

EE tt = electricity price in year t, in dollars.

The annual energy consumption, as discussed in chapter 7 of this TSD, is equal to the 

annual operating hours of the GSL multiplied by the GSL input power. DOE used electricity 

price trends to forecast electricity prices into the future and, along with the product lifetime and 

discount rate, to establish the present value of lifetime energy costs. The following sections 

discuss in detail the operating cost inputs.

8.2.7.1 Operating Hours

DOE determined the weighted-average GSL operating hours in chapter 7 of this TSD

using data from field metering studies for the residential sector and data from the LMC1 for the 

commercial sector. DOE estimated GSL HOU for each RECS reportable domain in the 

residential sector and for each building type in the commercial sector. In the LCC and PBP 

analysis, DOE used a more detailed approach to sample operating HOU for each consumer, as 

discussed in the following sections.

Residential Sector

For integrated low-lumen GSLs, the LCC model first sampled a representative lamp from 

the four lumen ranges (310-749 lm, 750-1049 lm, 1050-1489 lm, and 1490-1999 lm), as

discussed in section 8.2.2. Probability distributions were developed for each room type presented 

RLEUCS, which indicated the probability that a lamp in a particular lumen range would be 

found in a particular room type. For each sampled lamp, DOE sampled a room type. DOE then 

sampled from HOU distributions developed for each room type using data from the Northwest 

Energy Efficiency Alliance’s Residential Building Stock Assessment Metering Study 

(RBSAM).

15

For integrated high-lumen GSLs and non-integrated GSLs, DOE assumed that the 

distribution of lamps across room types would be same as the distribution for the highest lumen 

range of integrated low-lumen GSLs. 

The following sections describe in more detail DOE’s approach to develop HOU 

distributions. 

To develop HOU distributions for each room type and room distributions by lumen 

range, DOE first calculated the average lumens of each room type across the U.S. in the 

RLEUCS dataset, using the equivalent of Eq. 8.3 for each room type: 

8-18
LLmmaaaaaa,rr = �LL ii,rr ×

nn

ii=0

LLii,rr × NNii,rr

∑ LLii,rr × NNii,rr nn

ii=0

Eq. 8.8

Where:

LLmmaaaaaa,rr= weighted average lumens in the RLEUCS dataset for room type rr in RLEUCSq

,

ii, rr= representative lighting characteristic in the RLEUCS dataset for room type r,

LLii,rr= number of lamps per household in the RLEUCS dataset for room type r,

NNii,rr= number of U.S. households in the RLEUCS dataset for room type r, and

∑ LLii,rr × NNii,rr nn

ii=0 = total of number of GSLs in the RLEUCS dataset for room type r.

DOE multiplied the average room lumens, LLmmaaaaaa,rr, by a factor equal to 810/831 to adjust 

to the analyzed lumen ranges (310-749 lm, 750-1049 lm, 1050-1489 lm, and 1490-1999 lm). 

DOE then estimated the fraction of lamps (fi,r) in a particular lumen range (i) for each room type 

(r), under the following conditions, where each lumen range was represented by its characteristic 

lumens (500, 800, 1200, 1600r):

LL aaaaaa,rr = 1,rr × 500 + 2,rr × 800 + 3,rr × 1200 + 4,rr × 1600

Eq. 8.9

1,rr + 2,rr + 3,rr + 4,rr = 1

Eq. 8.10

3,rr = 3

2

× 2,rr

Eq. 8.11

4,rr = 4

2

× 2,rr

Eq. 8.12

DOE assumed that the relative market shares of lamps in the 750-1049, 1050-1489 and 

1490-1999 lumen ranges are fixed with the respect to one another, and with the same relative 

market share in each room type as the overall relative market share of lamps in these lumen 

ranges in all room types.

Using Eq. 8.9 through Eq. 8.12, DOE determined the lumen distribution for each room 

type. A weighting factor, based on the total lamps in each room type in the RLEUCS dataset, 

q The room types in RLEUCS are the following: bathroom, bedroom, dining room, exterior, garage, hallway, 

kitchen, living room, office, and other room.

r As discussed earlier, DOE assumed that the characteristic lumen output for the 1490-1999 lumen range was 1600 

lumens, as with the 1490-2600 lumen range. 

8-19

 
was also used to determine the probability that a lamp in a given lumen range would be installed 

in particular room type.

For each room type, DOE used RBSAM15 HOU distribution data, along with the average 

operating hours by RECS reportable domain from chapter 7 of this TSD, to sample hours of use. 

RBSAM is a metering study of 101 single-family houses across the Northwest (located in Idaho, 

Montana, Oregon, and Washington), which includes HOU data by room type for each household.

DOE mapped the RBSA room types to the RLEUCS room types, and assigned a distribution of 

HOU data to each room type in the RLEUCS dataset.

s

DOE assumed that the shape of the HOU distribution for a particular room type would be 

the same across the U.S., even if the average HOU for that room type varied by geographical 

location. To adjust the HOU distributions for each RECS reportable domain, DOE used the 

following approach: First, the model sampled an HOU from RBSAM for a specific room, r, and 

RECS reportable domain, d. Then, the sampled HOU value was multiplied by two factors: The 

first factor is the ratio of the average HOU for RECS reportable domain d as calculated in 

chapter 7 of this TSD, to the average HOU for RECS reportable domain d as reported in 

RLEUCS. The second adjustment factor is the ratio of the weighted average HOU in room r for 

RECS reportable domain d from RLEUCS, to the average HOU in room r from RBSAM. Note 

that in cases where the resulting HOU exceeded 24hr/day, DOE capped the HOU to 24hr/day.

Commercial Sector

For the commercial sector, DOE estimated that on a national level, GSLs are used 10.7 

hours per day, as discussed in chapter 7 of this TSD. Each building’s weighted-average HOU 

were estimated to range between 10.3 HOU per day for food service buildings and 11.2 HOU per 

day for retail buildings. 

To capture the variability in GSL HOU for individual consumers in the commercial 

sector, DOE applied an additional variation to each building’s weighted-average HOU when it 

conducted its LCC and PBP analysis. DOE applied a triangular distribution to each sampled GSL 

purchase with a minimum of 80% and a maximum of 120% of the HOU value for each building 

type, with the mean of each distribution corresponding to the respective building type’s average 

daily hours of use.

8.2.7.2 Energy Prices

DOE used average annual electricity prices for all RECS reportable domains, as shown in 

Table 8.2.5. Using these data, DOE assigned an appropriate electricity price to each purchase 

made in the residential and commercial sector in the sample, depending on the purchase location.

DOE derived average energy prices from data that are published on EIA Form 861.

16

Those data include, for every utility that serves final consumers, annual electricity sales in 

kilowatt-hours, revenues from electricity sales, and number of customers in the residential and 

s In cases where the RBSAM included HOU data for multiple lamps in the same room, DOE used a simple average 

of those HOU for that specific room type. DOE also applied a weighting factor based on the number of lamps 

identified in each room for each of the metered houses.

8-20

 
commercial sectors. For each utility, DOE estimated the average electricity price for each sector 

by dividing the sector’s revenues by the sector’s sales volume. DOE then calculated annual 

electricity prices by weighting each utility’s average price by the number of electricity 

consumers in each utility’s service area within each reportable domain. DOE converted the 

electricity prices to 2014$ using the gross domestic product (GDP) price deflator published by 

the Bureau of Economic Analysis.

17

Table 8.2.5 Average Electricity Prices by RECS Reportable Domain

RECS Reportable

Domain

Residential Electricity Prices 

(2014$/kWh)

Commercial Electricity Prices 

(2014$/kWh)

01. CT, ME, NH, RI, VT $0.167 $0.142

02. MA $0.155 $0.147

03. NY $0.193 $0.161

04. NJ $0.164 $0.137

05. PA $0.133 $0.110

06. IL $0.118 $0.092

07. IN, OH $0.116 $0.101

08. MI $0.146 $0.117

09. WI $0.136 $0.108

10. IA, MN, ND, SD $0.113 $0.090

11. KS, NE $0.111 $0.099

12. MO $0.105 $0.088

13. VA $0.114 $0.088

14. DE, DC, MD, WV $0.126 $0.105

15. GA $0.116 $0.103

16. NC, SC $0.116 $0.095

17. FL $0.118 $0.102

18. AL, KY, MS $0.108 $0.103

19. TN $0.104 $0.109

20. AR, LA, OK $0.093 $0.083

21. TX $0.114 $0.100

22. CO $0.118 $0.098

23. ID, MT, UT, WY $0.100 $0.084

24. AZ $0.116 $0.103

25. NV, NM $0.121 $0.097

26. CA $0.159 $0.145

27. AK, HI, OR, WA $0.124 $0.117

National $0.130 $0.112

Source: EIA Form 861, Release Date for 2012: Oct. 29, 2013.

8-21
8.2.7.3 Energy Price Trends

To calculate operating costs over the lifetime of the product, DOE requires a forecast of 

energy prices over the lifetime of the product. To arrive at prices in future years, DOE multiplied 

the average 2012 electricity prices by the forecast of annual average price changes for each 

census division from EIA’s 2014 Annual Energy Outlook (AEO2014).

2 For each purchase 

sampled, DOE applied the projection for the Census division in which the purchase was located. 

DOE used the AEO Reference Case scenarios for the 9 Census divisions. The reference 

case is a business-as-usual estimate, given known market, demographic, and technological 

trends. DOE also included AEO High Growth and AEO Low Growth scenarios in the analysis. 

The high- and low-growth cases show the projected effects of alternative growth assumptions on 

energy markets. To estimate the trends after 2040, DOE followed past guidelines provided to the 

Federal Energy Management Program (FEMP) by EIA and used the average rate of change 

during 2025–2040. 

Figure 8.2.3 and Figure 8.2.4 show residential and commercial electricity price trends

based on the three AEO2014 projections. For the LCC results presented in section 8.4, DOE used 

the energy price forecasts from the AEO reference case only. Appendix 8B of this TSD presents 

LCC results for the high- and low-economic growth scenarios. 

Figure 8.2.3 Trends in Residential Electricity Prices

8-22
Figure 8.2.4 Trends in Commercial Electricity Prices

8.2.7.4 Lifetime

DOE used Weibull survival models to calculate the probability of survival as a function 

of lamp age for the residential and commercial sectors and for CFL and LED GSLs. In the 

analysis, DOE considered the lamp’s rated lifetime (taken from the engineering analysis), sectorspecific HOU distributions, and effects of on-time cycle lengtht

, which DOE assumed only 

applied to residential CFL GSLs. DOE assumed that on-time cycle length does not affect LED 

GSLs due to lack of data to suggest otherwise. Also, DOE assumed that short on-time cycle 

lengths in the commercial sector were uncommon based on the increased HOU in this sector

(compared to the residential sector), indicating that the lifetime of CFL GSLs in the commercial 

sector is likely unaffected by on-off cycling. Finally, DOE assumed that GSL lifetimes are not 

affected by being installed on dimmers.

To generate the residential HOU distributions, DOE used data from RBSAM15 and the 

RLEUCS.

6 For the commercial sector, DOE generated HOU distributions using data in the 2010 

U.S. Lighting Market Characterization (LMC) and the 2003 CBECS12 (see chapter 7 of this TSD

and section 8.2.7.1 for details on the HOU methodology for the commercial sector). DOE also 

estimated the effect of on-time cycle length on the life of residential CFL GSLs using metering 

data from an American Council for an Energy-Efficient Economy (ACEEE) report

18 and a report 

presented to the California Public Utilities Commission (CPUC)

19 containing the measured 

lifetime of CFL GSLs as a function of on-time cycle length. DOE used all of this information to 

analyze the probability of survival as a function of GSL age for three scenarios: (1) “Rated 

Lifetime,” (2) “Renovation-Driven Lifetime” (the reference scenario), and (3) “EarlyReplacement Lifetime.” In the “rated lifetime” scenario, consumers use GSLs for their full 

lifetime. The “renovation-driven lifetime” scenario takes into account lamp turnover during 

renovations or retrofits, while the “early-replacement lifetime” scenario assumes that the lifetime 

of LED GSLs is similar to that of consumer electronics (about 5 years). 

t

On-time cycle length is the amount of time a GSL is switched on over one on-off cycle.

8-23

 
DOE modeled each of the three lifetime scenarios using Weibull survival functions, 

which take the form: 

wwss( ) = � −�

AA−dd

λλ �

kk

for > dd

1 for ≤ dd

Eq. 8.13

Where:

wwss( ) = the probability that the GSL survives to age after its initial installation,

= GSL age,

dd = delay parameter, which allows for a delay before any failures occur,

λλ = scale parameter, which would be the decay length in an exponential distribution, and

kk = shape parameter, which determines the way in which the failure rate changes through 

time.

In the reference scenario, DOE truncated the resulting survival model from the “Rated 

Lifetime” scenario using a Weibull survival function with the parameters 

(λλ, kk, dd) = (21.5, 6.0, 0.0). This Weibull function has a median of 20 years, which is intended to 

be a representative time scale for renovations or retrofits; furthermore, using scale and shape 

parameters of 21.5 and 6.0, respectively, results in a probability of survival of approximately 100 

percent for the first 10 years, decreasing probability of survival from 10 to 30 years, and 0 

percent probability of survival after 30 years for this model. Because this model is used to 

truncate the model from the “Rated Lifetime” scenario, the probability of survival in the 

reference scenario essentially equals the probability of survival from the “Rated Lifetime” 

scenario for the first 10 years, but then results in a decreased probability of survival as compared 

to the “Rated Lifetime” scenario for lamp ages greater than 10 years. The survival probability of 

CFL and LED GSLs rated at 10,000 hours and 25,000 hours, respectively, for the reference 

(“Renovation-Driven Lifetime”) scenario as a function of lamp age for the residential and 

commercial sectors is shown in Figure 8.2.5.

8-24
Note: The dashed vertical lines represent the median lifetime for each sector and lamp technology. The survival 

probability for CFLs and LEDs correspond to a rated lifetime of 10,000 and 25,000 hours, respectively. 

Figure 8.2.5 Probability of Survival as a Function of GSL Age (Reference Scenario)

Appendix 8E of this TSD presents the detailed methodology and results of DOE’s GSL 

lifetime modeling for each scenario. DOE invites comment on the assumptions and methodology 

used to develop GSL lifetime distributions for each scenario.

8.2.7.5 Disposal Cost

When GSLs fail, some consumers choose to recycle the lamps, incurring a disposal cost. 

According to the Association of Lighting and Mercury Recyclers, 23% of fluorescent lamps 

(including linear fluorescent lamps) are recycled nationwide.

u DOE performed market research 

on the recycling costs of compact fluorescents (CFLsv

) and found that, on average, disposing of 

a CFL costs about $1 per lamp. DOE did not find any data for LED bulb disposal costs, and 

assumed that their disposal costs would be zero. DOE assumed that commercial sector 

consumers pay recycling costs for 10% of CFL failures. Because few residential sector 

consumers recycle lamps, and because residential consumers generally do not pay to recycle 

u http://www.almr.org/almr_project_web.html (last accessed March 11, 2014). v Based on available vendors on the EPA website: http://www2.epa.gov/cfl/recycling-and-disposal-after-cfl-burnsout (last accessed, March 11, 2014).

8-25

 
lamps, DOE did not apply disposal costs to this sector. DOE requests comment and relevant data 

on the disposal cost assumptions for CFLs and LEDs.

8.2.7.6 Residual Value

The residual value represents the present value of surviving GSLs at the end of the LCC 

analysis period. As discussed earlier, the LCC analysis period is the lifetime of the shortest-lived 

GSL in each product class. To compute the residual value, DOE first considered the annualized 

first cost (AFC) of a GSL, which includes purchase price with sales tax. The AFC is the size of a 

single payment in a series of fixed annual payments over the LL-year life of the GSL, where the 

series of payments has a present value equal to the first cost of the GSL. For example, if a GSL 

has a first cost of $8, and a lifetime of 20 years, its AFC is $0.64, which means, that an expense 

of $8 in the present has the same present value as an annual expense of $0.64 over the next 20 

years. The AFC can be expressed as follows: 

= FF

∑ 1

(1+rr)yy yy=1

Eq. 8.14

Where:

= annualized first cost in dollars of a GSL with a lifetime of L years,

FF = first cost in dollars of the GSL, and

r = discount rate.

To compute the residual value of a GSL with a lifetime longer than the LCC analysis 

period, DOE considered the first cost of purchasing a replacement GSL at the end of the analysis 

period, FF (yy ee), which can be annualized to yield (yy ee) according to Eq. 8.14. The 

present value of postponing this purchase until the end of the GSL’s lifetime is equal to the 

present value of a series of fixed payments of (yy ee) over the remaining life of the GSL. In 

this preliminary analysis, DOE took the residual value of a surviving GSL to be equal to the 

value of this postponed cost. Note that the price of a GSL purchased at the end of the LCC 

analysis period may be lower than the price of a GSL purchased at the assumed compliance year, 

due to price learning. 

The residual value can then be expressed by the following equation: 

RRRR = (yy ee) × � 1

(1 + rr)yy

yy=yy ee +1

Eq. 8.15

Where:

(yy ee) = the annualized first cost of the longer lived GSL purchased in year yy ee, 

yy ee = the last year of the LCC analysis period, and

L = the lifetime of the longer-lived GSL.

8-26
8.2.7.7 Discount Rates

The discount rate is the rate at which future expenditures and savings are discounted to 

establish their present value. DOE estimates discount rates separately for residential and 

commercial consumers. For residential consumers, DOE calculates discount rates as the 

weighted average real interest rate across consumer debt and equity holdings. For commercial 

consumers, DOE calculates commercial discount rates as the weighted average cost of capital 

(WACC), using the Capital Asset Pricing Model (CAPM).

Discount Rates for Residential Consumers. 

The discount rate is the rate at which future savings and expenditures are discounted to 

establish their present value. DOE uses publicly available data (the Federal Reserve Board’s 

Survey of Consumer Finances (SCF)) to estimate a consumer’s opportunity cost of funds related 

to appliance energy cost savings and maintenance costs. The discount rate value is applied in the 

LCC to future year energy cost savings and non-energy operations and maintenance costs in 

order to present the estimated net LCC and LCC savings. DOE notes that the discount rate used 

in the LCC analysis is distinct from an implicit discount rate, as it is not used to model consumer 

purchase decisions. The opportunity cost of funds in this case may include interest payments on 

debt and interest returns on assets.

DOE estimates separate discount rate distributions for six income groups, divided based 

on income percentile as reported in the Federal Reserve Board’s SCF.

20 This disaggregation 

reflects the fact that low and high income consumers tend to have substantially different shares 

of debt and asset types and tend to face different rates on debts and assets. Summaries of shares 

and rates presented in this chapter are averages across the entire population.

Table 8.2.6 Definitions of Income Groups 

Income Group Percentile of Income

1 1st to 20th

2 21st to 40th

3 41st to 60th

4 61st to 80th

5 81st to 90th

6 91th to 99th

Sources: Federal Reserve Board. Survey of Consumer Finances (SCF) for 1995, 1998, 2001, 2004, 2007, and 2010.

Shares of Debt and Asset Classes 

DOE’s approach involved identifying all relevant household debt or asset classes in order 

to approximate a consumer’s opportunity cost of funds related to appliance energy cost savings 

and maintenance costs. The approach assumes that, in the long term, consumers are likely to 

draw from or add to their collection of debt and asset holdings approximately in proportion to 

their current holdings when future expenditures are required or future savings accumulate. DOE 

has included several previously excluded debt types (i.e., vehicle and education loans, 

8-27
mortgages, all forms of home equity loan) in order to better account for all of the options 

available to consumers.

The average share of total debt plus equity and the associated rate of each asset and debt 

type are used to calculate a weighted average discount rate for each SCF household (Table 

8.2.7). The household-level discount rates are then aggregated to form discount rate distributions 

for each of the six income groups. Note that previously DOE performed aggregation of asset and 

debt types over households by summing the dollar value across all households and then 

calculating shares. Weighting by dollar value gave disproportionate influence to the asset and 

debt shares and rates of higher income consumers. DOE has shifted to a household-level 

weighting to more accurately reflect the average consumer in each income group.

DOE estimated the average percentage shares of the various types of debt and equity 

using data from the Federal Reserve Board’s SCF for 1995, 1998, 2001, 2004, 2007, and 2010.w

DOE derived the household-weighted mean percentages of each source of financing throughout 

the 5 years surveyed. DOE posits that these long-term averages are most appropriate to use in its 

analysis. 

w Note that two older versions of the SCF are also available (1989 and 1992); these surveys are not used in this 

analysis, because they do not provide all of the necessary types of data (e.g., credit card interest rates, etc). DOE 

feels that the 15-year span covered by the six surveys included is sufficiently representative of recent debt and 

equity shares and interest rates.

8-28

 
Table 8.2.7 Types of Household Debt and Equity by Percentage Shares (%)

Type of Debt or Equity Income Group

1 2 3 4 5 6

Debt:

Mortgage 18.9% 24.1% 33.1% 38.1% 39.3% 25.0%

Home equity loan 3.1% 3.3% 2.6% 3.6% 4.5% 7.2%

Credit card 15.3% 13.0% 11.8% 8.7% 6.0% 2.7%

Other installment loan 25.1% 20.6% 17.3% 13.2% 9.6% 4.7%

Other residential loan 0.7% 0.6% 0.6% 0.7% 1.0% 1.2%

Other line of credit 1.6% 1.5% 1.3% 1.5% 2.1% 1.8%

Equity:

Savings account 18.5% 16.0% 12.7% 10.6% 10.4% 7.9%

Money market account 3.6% 4.5% 4.0% 4.5% 5.0% 8.6%

Certificate of deposit 7.0% 7.8% 5.5% 5.0% 4.4% 4.2%

Savings bond 1.8% 1.7% 1.9% 2.2% 1.7% 1.1%

Bonds 0.2% 0.4% 0.5% 0.7% 0.8% 3.8%

Stocks 2.3% 3.1% 4.4% 5.7% 7.6% 15.8%

Mutual funds 2.1% 3.5% 4.3% 5.7% 7.6% 15.9%

Total 100.0 100.0 100.0 100.0 100.0 100.0

Sources: Federal Reserve Board. Survey of Consumer Finances (SCF) for 1995, 1998, 2001, 2004, 2007, and 2010.

Rates for Types of Debt 

DOE estimated interest rates associated with each type of debt. The source for interest 

rates for mortgages, loans, credit cards, and lines of credit was the Federal Reserve Board’s SCF

for 1995, 1998, 2001, 2004, 2007, and 2010, which associates an interest rate with each type of 

debt for each household in the survey. 

In calculating effective interest rates for home equity loans and mortgages, DOE 

accounted for the fact that interest on both such loans is tax deductible (Table 8.2.8). This rate 

corresponds to the interest rate after deduction of mortgage interest for income tax purposes and 

after adjusting for inflation (using the Fisher formula).x For example, a 6-percent nominal 

mortgage rate has an effective nominal rate of 4.5 percent for a household at the 25-percent 

marginal tax rate. When adjusted for an inflation rate of 2 percent, the effective real rate becomes 

2.45 percent.

x Fisher formula is given by: Real Interest Rate = [(1 + Nominal Interest Rate) / (1 + Inflation Rate)] – 1.

8-29

 
Table 8.2.8 Data Used to Calculate Real Effective Mortgage Rates

Year Mortgage Interest Rates in Selected Years (%)

Average 

Nominal 

Interest Rate

Inflation Rate

21

Applicable 

Marginal Tax 

Rate

22

Average Real Effective 

Interest Rate

1995 8.2 2.83 24.2 3.3

1998 7.9 1.56 25.0 4.3

2001 7.6 2.85 24.2 2.8

2004 6.2 2.66 20.9 2.2

2007 6.3 2.85 20.6 2.1

2010 5.7 1.64 20.0 2.9

Table 8.2.9 shows the household-weighted average effective real rates for different types 

of household debt. Because the interest rates for each type of household debt reflect economic 

conditions throughout numerous years and various phases of economic growth and recession, 

they are expected to be representative of rates in effect in 2020.

Table 8.2.9 Average Real Effective Interest Rates for Household Debt

Type of Debt Income Group

1 2 3 4 5 6

Mortgage 6.6% 6.2% 6.1% 5.2% 5.0% 4.0%

Home equity loan 7.0% 6.9% 6.7% 5.9% 5.7% 4.3%

Credit card 15.2% 15.0% 14.5% 14.2% 14.0% 14.5%

Other installment loan 10.8% 10.3% 9.9% 9.4% 8.7% 8.6%

Other residential loan 9.8% 10.2% 8.9% 8.2% 7.7% 7.4%

Other line of credit 9.1% 10.9% 9.6% 8.8% 7.4% 6.1%

Sources: Federal Reserve Board. Survey of Consumer Finances (SCF) for 1995, 1998, 2001, 2004, 2007, and 2010.

Rates for Types of Assets 

No similar rate data are available from the SCF for classes of assets, so DOE derived 

asset interest rates from various sources of national historical data (1983-2013). The interest rates 

associated with certificates of deposit,

23 savings bonds,24 and bonds (AAA corporate bonds)25

were collected from Federal Reserve Board time-series data. Rates on money market accounts 

came from Cost of Savings Index data.

26 Rates on savings accounts were estimated as one half of

the rate for money market accounts, based on recent differentials between the return to each of 

these assets. The rates for stocks are the annual returns on the Standard and Poor’s.

27 Rates for 

mutual funds are a weighted average of the stock rates (two-thirds weight) and the bond rates 

(one-third weight) in each year. DOE assumed rates on checking accounts to be zero.

8-30
DOE adjusted the nominal rates to real rates using the annual inflation rate for each year. 

Average nominal and real interest rates for the classes of household assets are listed in Table 

8.2.10. Because the interest and return rates for each type of asset reflect economic conditions 

throughout numerous years, they are expected to be representative of rates that may be in effect 

in 2019. For each type, DOE developed a distribution of rates, as shown in appendix 8C.

Table 8.2.10 Average Nominal and Real Interest Rates for Household Equity 

Type of Equity Average Real 

Rate 

%

Savings accounts 1.0

Money market accounts 1.9

Certificates of deposit 1.9

Savings bonds 3.4

Bonds 4.2

Stocks 9.4

Mutual funds 7.4

Discount Rate Calculation and Summary

Using the asset and debt data discussed previously, DOE calculated discount rate 

distributions for each income group as follows. First, DOE calculated the discount rate for each 

consumer in each of the six versions of the SCF, using the following formula:

DD ii = �SShaa ii,jj

jj

× RR RRRRii,jj

Eq. 8.16

Where:

DD ii = discount rate for consumer i,

SShaa ii,jj = share of asset or debt type j for consumer i, and

RR RRRRii,jj = real interest rate or rate of return of asset or debt type j for consumer i.

The rate for each debt type is drawn from the SCF data for each household. The rate for 

each asset type is drawn from the distributions described previously. 

Once the real discount rate was estimated for each consumer, DOE compiled the 

distribution of discount rates in each survey by income group by calculating the proportion of 

consumers with discount rates in bins of 1 percent increments, ranging from 0-1 percent to 

greater than 30 percent. Giving equal weight to each survey, DOE compiled the six-survey 

distribution of discount rates. 

8-31
Table 8.2.11 presents the average real effective discount rate and its standard deviation 

for each of the six income groups. To account for variation among households, DOE sampled a 

rate for each RECS household from the distributions for the appropriate income group. (RECS 

provides household income data.) Appendix 8C presents the full probability distributions for 

each income group that DOE used in the LCC and PBP analysis. 

Table 8.2.11 Average Real Effective Discount 

Income Group Discount Rate (%)

1 4.85

2 5.12

3 4.75

4 4.04

5 3.80

6 3.57

Overall Average 4.49

Discount Rates for Commercial Sector Consumers. 

The commercial discount rate is the rate at which future operating costs are discounted to 

establish their present value in the LCC analysis. The discount rate value is applied in the LCC to 

future year energy costs and non-energy operations and maintenance costs to calculate the 

estimated net life-cycle cost of products of various efficiency levels and life-cycle cost savings as 

compared to the baseline for a representative sample of commercial end users.

DOE’s method views the purchase of a higher efficiency appliance as an investment that 

yields a stream of energy cost savings. DOE derived the discount rates for the LCC analysis by 

estimating the cost of capital for companies that purchase GSLs. The weighted average cost of 

capital (WACC) is commonly used to estimate the present value of cash flows to be derived from a 

typical company project or investment. Most companies use both debt and equity capital to fund 

investments, so their cost of capital is the weighted average of the cost to the firm of equity and 

debt financing, as estimated from financial data for publicly traded firms in the sectors that 

purchase GSLs.

28

Damodaran Online, a widely used source of information about company debt and equity 

financing, was used as the primary source of data for this analysis.

29 Companies included in the 

Damondaran Online database were assigned to the aggregate categories listed below:

• Office

• Retail

• Lodging

• Education

• Food Services

• Other

8-32
DOE estimated the cost of equity using the CAPM.

30 The CAPM assumes that the cost of 

equity (ke) for a particular company is proportional to the systematic risk faced by that company, 

where high risk is associated with a high cost of equity and low risk is associated with a low cost 

of equity. The systematic risk facing a firm is determined by several variables: the risk 

coefficient of the firm (β), the expected return on risk-free assets (Rf), and the equity risk 

premium (ERP). The risk coefficient of the firm indicates the risk associated with that firm 

relative to the price variability in the stock market. The expected return on risk-free assets is 

defined by the yield on long-term government bonds. The ERP represents the difference between 

the expected stock market return and the risk-free rate. The cost of equity financing is estimated 

using the following equation, where the variables are defined as above:

k R ( ERP) e = f + β ×

Eq. 8.17

Where:

ke = cost of equity,

Rf = expected return on risk-free assets,

β = risk coefficient of the firm, and

ERP = equity risk premium.

Several parameters of the cost of capital equations can vary substantially over time; 

therefore, the estimates can vary with the time period over which data is selected and the 

technical details of the data averaging method. For guidance on the time period for selecting and 

averaging data for key parameters and the averaging method, DOE used Federal Reserve 

methodologies for calculating these parameters. In its use of the CAPM, the Federal Reserve 

uses a forty-year period for calculating discount rate averages, utilizes the gross domestic 

product price deflator for estimating inflation, and considers the best method for determining the 

risk-free rate as one where “the time horizon of the investor is matched with the term of the riskfree security.”

31

By taking a forty-year geometric average of Federal Reserve data on annual nominal 

returns for 10-year Treasury bills, DOE found for this analysis the following risk-free rates for 

2011-2013 (Table 8.2.12).

32 DOE also estimated the ERP by calculating the difference between 

risk-free rates and stock market return for the same time period.

33

Table 8.2.12 Risk-Free Rate and Equity Risk Premium, 2010-2012

Year Risk-free rate (%) ERP (%)

2011 6.61% 2.94%

2012 6.41% 3.99%

2013 6.24% 5.30%

The cost of debt financing (kd) is the interest rate paid on money borrowed by a company. 

The cost of debt is estimated by adding a risk adjustment factor (Ra) to the risk-free rate. This 

8-33
risk adjustment factor depends on the variability of stock returns represented by standard 

deviations in stock prices. So for firm i, the cost of debt financing is:

di Rf Rai k = +

Eq. 8.18

Where:

kd = cost of debt financing for firm, i,

Rf = expected return on risk-free assets, and

Rai = risk adjustment factor to risk-free rate for firm, i. 

DOE estimates the WACC using the following equation:

e e d wd WACC = k ×w + k ×

Eq. 8.19

Where:

WACC = weighted average cost of capital,

we = proportion of equity financing, and

wd = proportion of debt financing.

By adjusting for the influence of inflation, DOE estimates the real WACC, or discount 

rate, for each company. DOE then aggregates the company real WACC to estimate the discount 

rate for each of the ownership types in the GSLs analysis. These values are presented in Table 

8.2.13. While WACC values for any category may trend higher or lower over substantial periods 

of time, these values represent a private sector cost of capital that is averaged over major 

business cycles.

Table 8.2.13 Weighted Average Cost of Capital for Analyzed Sectors

Sector Standard Deviation Market Share Mean Discount Rate

Office 1.3% 36% 5.1%

Retail 1.1% 24% 5.0%

Lodging 1.7% 14% 6.0%

Education 2.2% 7% 2.5%

Food Service 0.9% 5% 4.9%

Other 1.1% 9% 5.0%

Average Discount Rate: 5.0%

Source: Damodaran Online Data Page: Costs of Capital by Industry Sector, 2011, 2012, 2013.

8.3 PAYBACK PERIOD INPUTS

The payback period is the amount of time it takes the consumer to recover the estimated 

higher purchase expense of more energy-efficient products as a result of lower operating costs. 

As is typical in DOE rulemaking analyses, DOE has used simple payback period as the metric. 

8-34
Simple PBP does not take into account changes in operating expense over time or the time value 

of money; the calculation is done at an effective discount rate of zero percent.

The equation for PBP is:

PP = ΔΔ

ΔΔ

Eq. 8.20

Where:

ΔIC = difference in the total installed cost between the more energy-efficient design and the 

baseline design, and

ΔOC = difference in annual operating expenses between the more energy-efficient design 

and the baseline design.

Payback periods are expressed in years. Payback periods greater than the life of the 

product indicate that the increased total installed cost is not recovered with the reduced operating 

expenses.

8.4 LIFE-CYCLE COST AND PAYBACK PERIOD RESULTS

This section presents the results of the LCC and PBP analysis for GSLs. As discussed in 

section 8.1.1, DOE’s approach to the LCC analysis relied on developing samples of GSL 

consumers. DOE also used probability distributions to characterize the uncertainty in many of 

the inputs to the analysis. DOE used Monte Carlo simulation to perform the LCC calculations for 

the consumers in the sample. 

For each set of sample consumers in each product class, DOE calculated the average 

installed cost, first year operating cost, lifetime operating cost, and LCC for each CSL. The 

averages are calculated for each CSL assuming that all of the sample consumers purchase a 

product at that CSL. This allows the installation costs, operating costs, and LCCs for each CSL 

to be compared under the same conditions, across a variety of sample consumers. DOE used 

these average values for installed cost and first year operating cost to calculate the PBP for each 

CSL, relative to the baseline product.

DOE also calculated the LCC savings of a standard set at each CSL. For the reference 

scenario, DOE used a “market-transformation” approach to calculate the LCC savings: this is the 

LCC savings that result when a standard is set at a given CSL and the efficiency distribution of 

products in the base case is transformed into a different efficiency distribution in the standards 

case. In both the base case and the standards case, the efficiency distributions have been

calculated in the shipments analysis. DOE took a market transformation approach when 

calculating LCC savings in order to more accurately reflect the impact of a potential standard on 

consumers. This approach is intended to account for those consumers who, under a particular 

standard, would select more efficient (and sometimes less expensive) lamp options than the 

lamps corresponding to that standard level, as estimated by the consumer-choice model in 

chapter 9 of this TSD.

8-35
DOE first assigned products to consumers using the distribution of energy efficiencies in 

the base case. Then, for each standards case analyzed, DOE re-assigned products to consumers 

using the distribution of energy efficiencies for the standards case. When re-assigning products to 

consumers, DOE assumed that consumers would purchase a GSL at least as efficient as the GSL 

they would have purchased in the base-case. DOE assigned an LCC savings value of zero to all 

consumers who in both the base-case and standards-case would purchase a GSL of equivalent 

efficiency.

As an alternative scenario, DOE also used a “roll-up” approach to calculate the LCC 

savings relative to the LCC that each sample consumer would experience in the base case. Like 

the market-transformation approach, DOE assigned products to consumers by using the 

distribution of energy efficiencies for the base case calculated by the shipments analysis. 

However, in the “roll-up” approach, DOE assumed that all consumers who, in the base case,

would purchase a GSL that was less efficient than the standard level being analyzed, would 

purchase a GSL at the minimum efficiency level allowed in the standards case. DOE also 

assumed that all consumers who would purchase a GSL that was as efficient as, or more efficient 

than, the standard level being analyzed in the base case, would purchase the same GSL in the 

standards case (i.e., at the same CSL as in the base case). Therefore, DOE assigned an LCC 

savings value of zero to all consumers, who in the base case, would purchase a GSL that was as 

efficient as, or more efficient than, the CSL being analyzed.

Both the “market transformation” and “roll-up” approach to calculating LCC savings take 

into account the base case efficiency distribution, For this reason, in both cases, the average LCC 

savings are not equal to the difference between the LCC of a specific CSL and the LCC of the 

least efficient product available on the market.

In both approaches, DOE calculated the share of consumers receiving a net LCC cost for 

each CSL. DOE considered a consumer to receive a net LCC cost if the customer had negative 

LCC savings at the CSL being analyzed. 

LCC and PBP calculations were performed 10,000 times on the sample of consumers 

established for each product class. Each LCC and PBP calculation was performed on a single 

consumer selected from the sample in each sector. A consumer was selected based on how 

representative that particular consumer was of other consumers in the distribution (i.e., selection 

weight), as discussed in section 8.2.3. Each LCC and PBP calculation also sampled from the 

probability distributions that DOE developed to characterize many of the inputs to the analysis. 

The following sections present the key LCC and PBP findings, as well as figures that 

illustrate the range of LCC and PBP effects among sample consumers for both the markettransformation approach (section 8.4.1) and roll-up approach (section 8.4.2). Because the 

lighting market is in the process of undergoing significant transformation, DOE also presents 

LCC and PBP results for 2025, five years after the assumed compliance year, in section 8.4.3

using the market-transformation approach.

8-36
8.4.1 “Market-Transformation” Approach Results

8.4.1.1 Integrated Low-Lumen GSL Results

Table 8.4.1 and Table 8.4.2 show the LCC and PBP results for all efficiency levels 

considered for Integrated Low-Lumen GSLs.

Table 8.4.1 Average LCC and PBP Results by Candidate Standard Level for Integrated 

Low-Lumen GSLs

CSL

Average Costs

(2014$) Simple 

Payback

(years)

Average 

Lifetime

(years) Installed Cost First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 6.2 1.6 5.6 11.8 --- 8.8

1 4.0 1.5 5.2 8.8 0 9.8

2 34.9 1.3 4.6 23.1 99.6 17.9

3 22.2 1.2 4.2 16.0 40.5 17.9

4 7.5 1.1 3.8 8.5 2.6 17.9

5 7.2 1.0 3.6 8.1 1.7 17.9

Commercial Sector

0 7.0 6.9 17.7 24.8 --- 2.2

1 4.4 6.4 16.5 20.2 0 2.8

2 45.7 6.0 15.3 37.9 40.0 6.3

3 29.1 5.5 14.0 28.4 15.3 6.3

4 7.7 5.0 12.8 17.2 0.4 6.3

5 7.3 4.8 12.2 16.4 0.2 6.3

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

DOE notes that, in the residential sector, the ratio of the lifetime operating costs to the 

first year’s operating costs presented in Table 8.4.1 (and all subsequent results tables presenting 

first year and lifetime operating costs) is roughly 3.5, which is much smaller than the average 

lifetime values presented in the table. There are several reasons for this non-intuitive result. 

First, as discussed earlier, DOE computed the LCC (and thus the lifetime operating cost) 

for each product class over the shortest-lived lamp, which, for the reference scenario, is the 

baseline lamp.

y Therefore, the lifetimes of non-baseline lamps are not relevant to the lifetime 

y In the “early replacement lifetime” scenario, where LEDs are replaced every 5 years, the shortest-lived lamps in 

the residential sector are LEDs (CSL 2 through 5). See Appendix 8E for details on the “early replacement lifetime” 

scenario and appendix 8B for LCC and PBP results for this scenario. 

8-37

 
operating cost values in Table 8.4.1. Nevertheless, the ratio of lifetime to first-year operating 

costs is still significantly lower than the average lifetime presented for the baseline lamp in the 

residential sector. This is partly to be expected, because the lifetime operating costs are 

discounted, and some residential consumers have very high discount rates (see appendix 8C of 

this TSD). Discounting alone is not sufficient, however, to explain the difference of more than a 

factor of two between the average lifetime and the lifetime-to-first-year operating cost ratio. The 

most important reason for this difference is that lamps’ lifetimes are correlated with their firstyear operating costs, via the HOU, and the asymmetrical nature of the HOU distribution can lead 

to unexpected results when looking at average values. As discussed in section 8.2.7.4 (lifetime), 

a GSL with high HOU will have a short lifetime, while a GSL with low HOU, will have a long 

lifetime. Conversely, a GSL with high operating hours will have a high first-year operating cost, 

while a GSL with low HOU will have a low first-year operating cost. The HOU distribution used 

in this analysis is highly asymmetrical (see appendix 8E of this preliminary TSD); therefore, 

averages of values that depend on the HOU will not necessarily correspond to typical values. For 

example, about 24% of baseline GSLs in this analysis have a lifetime of 3 years or less, despite 

the average lifetime of 8.8 years. Because the first-year operating cost is directly proportional to 

HOU, while the lifetime is inversely proportional to HOU, the asymmetry of the HOU 

distribution will tend to skew the average values of those quantities in opposite directions. 

Table 8.4.2 Average LCC Savings for Integrated Low-Lumen GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 0% 0.0

2 27% -0.1

3 27% 0.0

4 25% 0.3

5 22% 0.5

Commercial Sector

0 0.0% 0.0

1 0.0% 0.0

2 1.1% 1.7

3 1.1% 1.7

4 0.8% 1.7

5 0.3% 2.1

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

Figure 8.4.1and Figure 8.4.2 show the range of LCC savings for all CSLs in the 

residential and commercial sector for Integrated Low-Lumen GSLs. The top and the bottom of 

the box indicate the 75th and 25th percentiles, respectively. The solid bar indicates the median; 

50 percent of the households have LCC savings above this value. The horizontal lines above and 

8-38
below each box indicate the 95th and 5th percentiles, respectively.z The red dot shows the 

average LCC savings at the CSL. A negative average LCC savings means that the average LCC 

with the standard is greater than what it is without the standard.

Figure 8.4.1 Range of LCC Savings in Residential Sector for Integrated Low-Lumen 

GSLs

Figure 8.4.2 Range of LCC Savings in Commercial Sector for Integrated Low-Lumen 

GSLs

z Note that in Figure 8.4.2 (and other subsequent box plot figures) the horizontal line indicating the 5th percentile is 

overwritten by the lowest part of the box.

8-39

 
Figure 8.4.3 and Figure 8.4.4 show the distribution of LCC impacts for CSL 5 in the 

residential sector and commercial sector, respectively, for Integrated Low-Lumen GSLs. The 

figures are presented as frequency charts that show the distribution of LCC impacts with their 

corresponding probability of occurrence. DOE generated the figures for the distributions from a 

Monte Carlo simulation run based on 10,000 samples. DOE presents the distribution of impacts 

specifically at this CSL because this is the case with the highest LCC savings.

Figure 8.4.3 LCC Savings Distribution in Residential Sector for Integrated Low-Lumen 

GSLs at CSL 5

Figure 8.4.4 LCC Savings Distribution in Commercial Sector for Integrated Low-Lumen 

GSLs at CSL 5

8.4.1.2 Integrated High-Lumen GSL Results

Table 8.4.3 and Table 8.4.4 present the key findings for Integrated High-Lumen GSLs in 

both the commercial and residential sectors. Figure 8.4.5 and Figure 8.4.6 show the range of 

8-40
LCC savings for all CSLs in the residential and commercial sector for Integrated High-Lumen 

GSLs.

Table 8.4.3 Average LCC and PBP Results by Candidate Standard Level for Integrated 

High-Lumen GSLs

CSL

Average Costs

(2014$) Simple 

Payback

(years)

Average 

Lifetime

(years) Installed Cost First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 9.7 3.6 12.8 22.5 --- 8.8

1 10.1 3.4 12.0 22.1 1.5 8.8

2 10.8 3.3 11.6 21.3 3.1 9.8

Commercial Sector

0 9.7 12.4 31.6 41.5 --- 2.2

1 10.1 11.6 29.7 39.8 0.4 2.2

2 10.8 11.2 28.7 37.6 0.9 2.8

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

Table 8.4.4 Average LCC Savings for Integrated High-Lumen GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 6% 0.2

2 13% 0.5

Commercial Sector

0 0.0% 0.0

1 0.2% 0.5

2 1.2% 1.7

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

8-41
Figure 8.4.5 Range of LCC Savings in Residential Sector for Integrated High-Lumen 

GSLs

Figure 8.4.6 Range of LCC Savings in Residential Sector for Integrated High-Lumen 

GSLs

Figure 8.4.7 and Figure 8.4.8 show the distribution of LCC impacts for CSL 2 in the 

residential sector and commercial sector, respectively, for Integrated High-Lumen GSLs. DOE 

presents the distribution of impacts specifically at this CSL because this is the case with the 

highest LCC savings.

8-42
Figure 8.4.7 LCC Savings Distribution in Residential Sector for Integrated Low-Lumen 

GSLs at CSL 2

Figure 8.4.8 LCC Savings Distribution in Commercial Sector for Integrated Low-Lumen 

GSLs at CSL 2

8.4.1.3 Non-Integrated GSL Results

Table 8.4.5 and Table 8.4.6 show the LCC and PBP results for all efficiency levels 

considered for Non-Integrated GSLs. Figure 8.4.9 shows the range of LCC savings for all CSLs

in the residential and commercial sector for Non-Integrated GSLs.

8-43
Table 8.4.5 Average LCC and PBP Results by Candidate Standard Level for NonIntegrated GSLs

CSL

Average Costs

2014$ Simple 

Payback

(years)

Average 

Lifetime

(years) Installed Cost First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 13.2 3.4 11.9 25.2 --- 8.8

1

14.2 3.4 11.9 22.8 N/A 11.6

15.7 2.8 9.7 21.1 4.0 12.5

Commercial Sector

0 13.2 11.6 29.6 42.9 --- 2.2

1

14.2 11.6 29.6 39.0 N/A 4.1

15.7 9.4 24.1 33.3 1.2 5.0

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

Table 8.4.6 Average LCC Savings for Non-Integrated GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 12% 1.6

Commercial Sector

0 0.0% 0.0

1 5.4% 2.6

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

8-44
Figure 8.4.9 Range of LCC Savings in Residential Sector (left) and Commercial Sector 

(right) at CSL 1 for Non-Integrated GSLs

8.4.2 “Roll-up” Approach Results

8.4.2.1 Integrated Low-Lumen GSL Results

Table 8.4.7 and Table 8.4.8 show the LCC and PBP results for all efficiency levels 

considered for Integrated Low-Lumen GSLs.

8-45
Table 8.4.7 Average LCC and PBP Results by Candidate Standard Level for Integrated 

Low-Lumen GSLs

CSL

Average Costs

(2014$) Simple 

Payback

(years)

Average 

Lifetime

(years) Installed Cost First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 6.2 1.6 5.6 11.8 --- 8.8

1 4.0 1.5 5.2 8.8 0 9.8

2 34.9 1.3 4.6 23.1 99.6 17.9

3 22.2 1.2 4.2 16.0 40.5 17.9

4 7.5 1.1 3.8 8.5 2.6 17.9

5 7.2 1.0 3.6 8.1 1.7 17.9

Commercial Sector

0 7.0 6.9 17.7 24.8 --- 2.2

1 4.4 6.4 16.5 20.2 0 2.8

2 45.7 6.0 15.3 37.9 40.0 6.3

3 29.1 5.5 14.0 28.4 15.3 6.3

4 7.7 5.0 12.8 17.2 0.4 6.3

5 7.3 4.8 12.2 16.4 0.2 6.3

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

8-46
Table 8.4.8 Average LCC Savings for Integrated Low-Lumen GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 0% 0.0

2 49% -7.1

3 46% -3.6

4 22% 0.3

5 19% 0.6

Commercial Sector

0 0.0% 0.0

1 0.0% 0.0

2 53.9% -9.6

3 53.9% -4.4

4 0.5% 1.6

5 0.2% 2.2

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

8.4.2.2 Integrated High-Lumen GSL Results

Table 8.4.10 and Table 8.4.11 present the key findings for Integrated High-Lumen GSLs 

in both the commercial and residential sectors.

8-47
Table 8.4.9 Average LCC and PBP Results by Candidate Standard Level for Integrated 

High-Lumen GSLs

CSL

Average Costs

(2014$) Simple 

Payback

(years)

Average 

Lifetime

(years) Installed Cost First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 9.7 3.6 12.8 22.5 --- 8.8

1 10.1 3.4 12.0 22.1 1.5 8.8

2 10.8 3.3 11.6 21.3 3.1 9.8

Commercial Sector

0 9.7 12.4 31.6 41.5 --- 2.2

1 10.1 11.6 29.7 39.8 0.4 2.2

2 10.8 11.2 28.7 37.6 0.9 2.8

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

Table 8.4.10 Average LCC Savings for Integrated High-Lumen GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 3% 0.1

2 14% 0.5

Commercial Sector

0 0.0% 0.0

1 0.0% 0.3

2 1.2% 1.7

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

8.4.2.3 Non-Integrated GSL Results

Table 8.4.11 and Table 8.4.12 show the LCC and PBP results for all efficiency levels 

considered for Non-Integrated GSLs. 

8-48
Table 8.4.11 Average LCC and PBP Results by Candidate Standard Level for NonIntegrated GSLs

CSL

Average Costs

2014$ Simple 

Payback

(years)

Average 

Lifetime

(years) Installed Cost First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 13.2 3.4 11.9 25.2 --- 8.8

1

14.2 3.4 11.9 22.8 N/A 11.6

15.7 2.8 9.7 21.1 4.0 12.5

Commercial Sector

0 13.2 11.6 29.6 42.9 --- 2.2

1

14.2 11.6 29.6 39.0 N/A 4.1

15.7 9.4 24.1 33.3 1.2 5.0

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

Table 8.4.12 Average LCC Savings for Non-Integrated GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 12% 1.6

Commercial Sector

0 0.0% 0.0

1 5.2% 2.7

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

8.4.3 Results in 2025

8.4.3.1 Integrated Low-Lumen GSL Results

Table 8.4.13 and Table 8.4.14 show the LCC and PBP results for all efficiency levels 

considered for Integrated Low-Lumen GSLs.

8-49
Table 8.4.13 Average LCC and PBP Results by Candidate Standard Level for Integrated 

Low-Lumen GSLs

CSL

Average Costs

(2014$) Simple 

Payback

(years)

Average 

Lifetime

(years) Installed Cost First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 6.2 1.6 5.7 11.9 --- 8.8

1 3.8 1.5 5.3 8.7 0 9.8

2 34.9 1.3 4.5 23.0 86.8 17.9

3 22.2 1.1 4.1 15.9 36.8 17.9

4 6.0 1.0 3.7 7.2 0 17.9

5 5.7 1.0 3.5 6.9 0 17.9

Commercial Sector

0 7.0 6.7 17.2 24.3 --- 2.2

1 4.3 6.2 16.0 19.6 0 2.8

2 45.7 5.7 14.8 37.4 41.7 6.3

3 29.1 5.3 13.6 28.0 15.9 6.3

4 6.1 4.8 12.4 15.6 0 6.3

5 5.7 4.6 11.8 14.9 0 6.3

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

8-50
Table 8.4.14 Average LCC Savings for Integrated Low-Lumen GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 0% 0.0

2 7% 0.5

3 7% 0.6

4 6% 0.7

5 4% 0.9

Commercial Sector

0 0.0% 0.0

1 0.1% 0.0

2 0.1% 1.3

3 0.1% 1.3

4 0.0% 1.3

5 0.0% 1.7

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

8.4.3.2 Integrated High-Lumen GSL Results

Table 8.4.15 and Table 8.4.16 present the key findings for Integrated High-Lumen GSLs 

in both the commercial and residential sectors.

8-51
Table 8.4.15 Average LCC and PBP Results by Candidate Standard Level for Integrated 

High-Lumen GSLs

CSL

Average Costs

(2014$) Simple 

Payback

(years)

Average 

Lifetime

(years) Installed Cost First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 9.4 3.7 12.9 22.3 --- 8.8

1 9.7 3.4 12.1 21.9 1.4 8.8

2 10.4 3.3 11.7 21.1 3.0 9.8

Commercial Sector

0 9.4 11.9 30.7 40.2 --- 2.2

1 9.7 11.1 28.8 38.6 0.4 2.2

2 10.4 10.8 27.8 36.4 0.9 2.8

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

Table 8.4.16 Average LCC Savings for Integrated High-Lumen GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 7% 0.2

2 17% 0.4

Commercial Sector

0 0.0% 0.0

1 0.3% 0.5

2 5.0% 1.5

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

8.4.3.3 Non-Integrated GSL Results

Table 8.4.17 and Table 8.4.18 show the LCC and PBP results for all efficiency levels 

considered for Non-Integrated GSLs. 

8-52
Table 8.4.17 Average LCC and PBP Results by Candidate Standard Level for NonIntegrated GSLs

CSL

Average Costs

2014$ Simple 

Payback

(years)

Average 

Lifetime

(years) Installed Cost First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 12.7 3.4 12.1 24.8 --- 8.8

1

13.6 3.4 12.1 22.5 N/A 11.6

15.1 2.8 9.9 20.7 3.9 12.5

Commercial Sector

0 12.7 11.1 28.8 41.6 --- 2.2

1

13.6 11.1 28.8 37.7 N/A 4.1

15.1 9.1 23.4 32.1 1.2 5.0

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

Table 8.4.18 Average LCC Savings for Non-Integrated GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 12% 1.5

Commercial Sector

0 0.0% 0.0

1 5.4% 2.6

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

8.4.4 Rebuttable Presumption Payback Period 

DOE also uses the results of the payback period analysis as a preliminary test of the 

economic justification of standards. By statute, there is a rebuttable presumption that a standard 

level is economically justified if the additional costs to the consumer of purchasing a product 

complying with the standard are less than three times the value of the first year’s energy cost 

savings. (42 U.S.C. §6295 (o)(2)(B)(iii)) However, the statute also specifies that: “A 

determination by the Secretary that such criterion is not met shall not be taken into consideration 

in the Secretary’s determination of whether a standard is economically justified.”

8-53
The criterion of the rebuttable presumption is equivalent to a given CSL having a simple 

payback period of less than three years. For the reference scenario, using the simple payback 

periods presented in Table 8.4.1, Table 8.4.3, and Table 8.4.5, the rebuttable presumption 

criterion is met for all product classes for certain CSLs, except for non-integrated GSLs in the 

residential sector, as shown in Table 8.4.5.

8-54
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Department of Energy.

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5. Gerke, B., A. Ngo, A. Alstone, and K. Fisseha. The Evolving Price of Household LED

Lamps: Recent Trends and Historical Comparisons for the US Market. 2014. Lawrence

Berkeley National Laboratory: Berkeley, CA. Report No. LBNL-6854E.

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6. DNV KEMA Energy and Sustainability and Pacific Northwest National Laboratory.

Residential Lighting End-Use Consumption Study: Estimation Framework and Baseline

Estimates. 2012.

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7. Carmichael, R. GSL Shipments and Lumen Bin Distribution Data. Cadeo Group. Contract

7094760-T2D: Washington, D.C.

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March 23, 2009, Page 12070. 2009. U.S. Office of the Federal Register.

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and Federal Minimum Lighting Standards: An Overview for Regulators. 2012.

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10. DNV GL Sustainable Energy Use. California Retail Lighting Shelf Survey Online Tool.

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Data. (Last accessed October 10, 2014.)

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Data. (Last accessed October 6, 2014.)

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13. Sales Tax Clearinghouse, I. State Sales Tax Rates Along with Combined Average City

and County Rates. 2014. http://thestc.com/STrates.stm.

14. U.S. Census Bureau. Annual Estimates of the Resident Population for the United States,

Regions, States, and Puerto Rico: April 1, 2013 to July 1, 2013. (Last accessed

November 3, 2014.) http://www.census.gov/popest/data/national/totals/2013/index.html.

15. Ecotope Inc. Residential Building Stock Assessment: Metering Study. 2014. Northwest

Energy Efficiency Alliance: Seattle, WA. Report No. E14-283.

http://neea.org/docs/default-source/reports/residential-building-stock-assessment--

metering-study.pdf?sfvrsn=6.

16. U.S. Energy Information Administration. Electric power sales, revenue, and energy

efficiency Form EIA-861 detailed data files. October 29, 2013. (Last accessed September

24, 2014.) http://www.eia.gov/electricity/data/eia861/index.html.

17. U.S. Department of Commerce – Bureau of Economic Analysis. Table 1.1.9. Implicit

Price Deflators for Gross Domestic Product. http://www.bea.gov/iTable/.

18. Jump, C., J. J. Hirsch, J. Peters, and D. Moran. Welcome to the Dark Side: The Effect of

Switching on CFL Measure Life. 2008. 2008 ACEEE Summer Study on Energy

Efficiency in Buildings.

http://www.eceee.org/library/conference_proceedings/ACEEE_buildings/2008/Panel_2/2

_111/paper.

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Report: Preliminary Results from a CFL Switching Cycle and Photometric Laboratory

Study. 2012. California Public Utilities Commission - Energy Division: California.

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Income Tax Rates. (Last accessed October 10, 2014.)

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certificates of deposit (secondary market), quoted on an investment basis. December 19,

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24. Board of Governors of the Federal Reserve System. Federal Reserve Statistical Release,

Selected Interest Rates, Historical Data, Instrument: State and local bonds, Maturity: 20-

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Selected Interest Rates, Historical Data, Instrument: Corporate bonds/Moody’s Seasoned

AAA, Frequency: Annual, Description: Moody’s yield on seasoned corporate bonds—all

industries, AAA. (Last accessed October 10, 2014.)

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27. Damodaran, A. Annual Returns on Stock, T.Bonds and T.Bills: 1928 - Current. January 5,

2014. (Last accessed September 24, 2014.)

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28. Modigliani, F. and M. H. Miller. The Cost of Capital, Corporations Finance and the

Theory of Investment. American Economic Review. 1958. 48(3): pp. 261–297.

29. Damodaran, A. Cost of Capital by Sector. January 2014. (Last accessed September 25,

2014.) http://people.stern.nyu.edu/adamodar/New_Home_Page/datafile/wacc.htm.

30. Ibbotson Associates. Cost of Capital 2001 Yearbook. 2001. Chicago, IL.

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Private Sector Adjustment Factor. 2005. Washington, D.C. Report No. OP-1229

(Docket).

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32. Board of Governors of the Federal Reserve System. Selected Interest Rates (Daily) -

H.15. (Last accessed October 10, 2014.)

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33. Damodaran, A. Data Page: Historical Returns on Stocks, Bonds and Bills-United States.

2013. (Last accessed February 1, 2013.) http://pages.stern.nyu.edu/~adamodar/.

8-57 
CHAPTER 9. SHIPMENTS ANALYSIS

TABLE OF CONTENTS

9.1 INTRODUCTION ........................................................................................................... 9-1

9.1.1 Analyzed Product Classes, Market Sectors, and Market Segments ..................... 9-2

9.1.2 Analyzed Time Periods ........................................................................................ 9-3

9.2 SHIPMENTS MODEL METHODOLOGY .................................................................... 9-4

9.2.1 Conceptual Framework of the Shipments Model ................................................ 9-4

9.2.1.1 Lamp options considered in the shipments analysis .................................. 9-5

9.2.1.2 Demand Module ......................................................................................... 9-7

9.2.1.3 Consumer Choice Module .......................................................................... 9-8

9.2.1.4 Price Projection Module ........................................................................... 9-10

9.2.1.5 The Coupled Model .................................................................................. 9-13

9.2.2 Detailed Modeling and Assumptions ................................................................. 9-13

9.2.2.1 Modeling GSL Demand for New Construction ....................................... 9-15

9.2.2.2 Modeling demand for replacement of retiring GSLs ............................... 9-16

9.2.2.3 Incoming and outgoing demand ............................................................... 9-17

9.2.2.4 Turnover and Shipments .......................................................................... 9-20

9.2.2.5 Stock Attrition .......................................................................................... 9-21

9.3 MODEL INPUTS AND CALIBRATION ..................................................................... 9-21

9.3.1 Historical Shipments Data ................................................................................. 9-21

9.3.1.1 Sources of Historical Shipments Data ...................................................... 9-21

9.3.1.2 Subdivision of Historical Shipments by Sector, Lamp Category, and 

CSL ........................................................................................................... 9-22

9.3.2 Consumer Choice Module Development and Calibration ................................. 9-24

9.3.2.1 Development and Calibration of the Logit Model ................................... 9-24

9.3.2.2 Bass Adoption Model ............................................................................... 9-29

9.3.2.3 Incoming and outgoing demand ............................................................... 9-30

9.3.2.4 Availability Matrix ................................................................................... 9-31

9.3.2.5 Acceptance Factors .................................................................................. 9-31

9.3.3 Price Trend Projection ....................................................................................... 9-32

9.3.3.1 Lamp Options Excluded from the Price Trend Projection ....................... 9-32

9.3.3.2 Learning Rate Parameters ........................................................................ 9-33

9.3.3.3 Incremental Price Trends for LED GSLs ................................................. 9-33

9.3.3.4 Rare Earth Costs ....................................................................................... 9-33

9.3.4 General Service Lamp Characteristics ............................................................... 9-34

9.4 ALTERNATIVE SCENARIOS..................................................................................... 9-38

9.4.1 Overview ............................................................................................................ 9-38

9.5 RESULTS ...................................................................................................................... 9-39

9.5.1 Reference Scenario Results ................................................................................ 9-39

9.5.2 Results of the Alternative Scenario Analyses .................................................... 9-46

REFERENCES .......................................................................................................................... 9-48

9-i 
LIST OF TABLES

Table 9.1.1 Standard Levels for Each Product Class at Each CSC .................................. 9-2

Table 9.1.2 Product Classes, Lamp Categories, and Sectors Analyzed in the 

Shipments Model ........................................................................................... 9-3

Table 9.1.3 Time Periods Considered in the Shipments Analysis.................................... 9-4

Table 9.2.1 GSL Options Used in the Shipments Analysis for the Integrated Lowlumen Product Class ...................................................................................... 9-6

Table 9.2.2 GSL Options Used in the Shipments Analysis for the Integrated Highlumen Product Class ...................................................................................... 9-7

Table 9.2.3 GSL Options Used in the Shipments Analysis for the Non-integrated 

Product Class ................................................................................................. 9-7

Table 9.3.1 Estimated Shipments of GSLs to the U.S. Market, by Technology 

Type12........................................................................................................... 9-22

Table 9.3.2 Sector-Specific Parameters of the Logit Formula Given in Eq. 9.28. ......... 9-29

Table 9.3.3 Nest Parameters Used in the Consumer Choice Module ............................. 9-29

Table 9.3.4 Bass Adoption Model Parameters................................................................ 9-30

Table 9.3.5 Exponential Decline Parameters for the Incremental Price of Increased 

Lumen Output for LED GSLs...................................................................... 9-33

Table 9.3.6 Lamp Characteristics Used as Inputs to the Shipments Model for the 

Integrated Low-Lumen Product Class in the Reference Scenario............... 9-35

Table 9.3.7 Lamp Characteristics Used as Inputs to the Shipments Model for the 

Integrated High-Lumen Product Class in the Reference Scenario .............. 9-36

Table 9.3.8 Lamp Characteristics Used as Inputs to the Shipments Model for the 

Non-Integrated Product Class in the Reference Scenario............................ 9-37

Table 9.4.1 Summary of Alternative Scenarios Analyzed in the Shipments 

Analysis........................................................................................................ 9-39

Table 9.5.1 Impact of Candidate Standards on the Cumulative Shipments of GSLs, 

2020-2049 .................................................................................................... 9-44

Table 9.5.2 Impact of Alternative Scenario Assumptions on the Cumulative 

Shipments of GSLs in the Base Case, 2020-2049 ....................................... 9-47

LIST OF FIGURES

Figure 9.2.1 Schematic Representation of the Shipments Model ...................................... 9-5

Figure 9.3.1 Preference Index Data from a Report7 for PG&E on Consumer Lamp 

Preferences, Fitted to Models Given by Eq. 9.27, with Variables that 

are either Linear or Logarithmic in the Quantity Plotted on Each Plot’s 

Horizontal Axis............................................................................................ 9-27

Figure 9.3.2 Bass Diffusion Curve for LED Technologies Using the Parameters 

Presented in Table 9.3.4............................................................................... 9-30

Figure 9.3.3 Inflation-Adjusted, Tri-band Phosphor REO Price Index............................ 9-34

Figure 9.5.1 Reference Scenario Base Case Shipments by Product Class, CSL, and 

Lamp Option ................................................................................................ 9-41

Figure 9.5.2 Reference Scenario Base Case Shipments by Lamp Technology in the 

Commercial Sector....................................................................................... 9-42

9-ii
Figure 9.5.3 Reference Scenario Base Case Shipments by Lamp Technology in the 

Residential Sector ........................................................................................ 9-42

Figure 9.5.4 Total Shipments of Integrated Low-Lumen Lamps in the Reference 

Scenario for All CSCs.................................................................................. 9-43

Figure 9.5.5 Total Shipments of Integrated High-Lumen Lamps in the Reference 

Scenario for All CSCs.................................................................................. 9-43

Figure 9.5.6 Total Shipments of Non-Integrated Lamps in the Reference Scenario 

for All CSCs................................................................................................. 9-44

Figure 9.5.7 Base Case Price Trends for Lamp Options in the Integrated LowLumen Product Class by Lamp Category .................................................... 9-45

Figure 9.5.8 Base Case Price Trends for Lamp Options in the Integrated HighLumen Product Class................................................................................... 9-46

Figure 9.5.9 Base Case Price Trends for Lamp Options in the Non-Integrated 

Product Class ............................................................................................... 9-46

9-iii
CHAPTER 9. SHIPMENTS ANALYSIS

9.1 INTRODUCTION

This chapter describes the methods the U.S. Department of Energy (DOE) used to project 

the future shipments of general service lamps (GSLs). Projections were developed for several 

cases: the shipments expected to occur without GSL energy conservation standards (the base 

case) and the projected shipments assuming standards are set at various efficiency levels for each 

of the GSL product classes (the candidate standards cases, or CSCs). Shipments projections are 

a necessary input to calculations of the national energy savings (NES) and net present value 

(NPV) in the national impacts analysis (NIA), as well as to the manufacturer impact analysis 

(MIA).

DOE developed a consumer-choice-based model to estimate shipments of GSLs. The 

model projects consumer purchases (and hence shipments) based on sector-specific consumer 

sensitivities to first cost, energy savings, lamp lifetime, and lamp mercury content. To account 

for non-economic consumer behaviors, a technology diffusion model and a technology 

acceptance factor are superimposed on the shipments model. 

Because of the complexity of the consumer-choice-based shipments analysis, the 

shipments model was executed as a separate computer model written in the Python language. 

The inputs and outputs of the shipments model were embedded in the NIA model, which is 

implemented in a Microsoft Excel® spreadsheet, available on regulations.gov, docket number

docket number EERE–2013–BT–STD–0051 at 

http://www.regulations.gov/#!docketDetail;D=EERE-2013-BT-STD-0051. 

For the non-integrated and integrated high-lumen product classes, and for each of four 

lumen ranges considered in the integrated low-lumen product class, DOE projected the change in 

shipments that would occur in the case of a standard set at different candidate standard levels 

(CSLs). In the engineering analysis, DOE developed five different CSLs for integrated lowlumen lamps, 2 CSLs for integrated high-lumen lamps and a single CSL for non-integrated 

lamps (see chapter 5 of this preliminary TSD). Because lamps at the higher CSLs can have 

significantly different lifetimes than lamps at the lower CSLs, a standard can have a significant 

impact on lamp shipments, since, when lamp lifetimes are longer, fewer replacements for failed 

lamps are required each year to meet a given demand for lighting capacity (i.e., maximum 

desired lumen output per square foot of floor space). DOE assumes in this analysis that the 

national average lighting capacity demand is constant over time, so increased lamp lifetimes lead 

to proportional reductions in the demand for replacement lamps. 

To evaluate the impact of a standard set at a particular CSL in each product class (which 

defines a particular CSC) on shipments of GSLs, DOE calculated the difference between the 

shipments of lamps in each CSC and those in the corresponding base case for each product class. 

The CSL for each product class at each CSC is shown in Table 9.1.1.All assumptions in a given 

CSC are identical to those in the corresponding base case, except that lamp options that do not 

meet the standard are excluded from the set of consumer purchase options in the standards case. 

The cumulative impact of each CSC on shipments is determined by summing the annual impacts 

9-1 
over a 30-year (2020 through 2049) analysis period. For each CSC, DOE calculated its best 

estimate of the impact on shipments, broken down by product class. 

Table 9.1.1 Standard Levels for Each Product Class at Each CSC

CSC Integrated 

Low-Lumen

Integrated 

High-Lumen

NonIntegrated

Base Case CSL 0 CSL 0 CSL 0

1 CSL 1 CSL 1 CSL 1

2 CSL 2 CSL 2 CSL 1

3 CSL 3 CSL 2 CSL 1

4 CSL 4 CSL 2 CSL 1

5 CSL 5 CSL 2 CSL 1

In addition to the best estimate, which is referred to as the Reference scenario in this 

document and uses the reference values for all inputs in the NIA spreadsheet, DOE ran various 

alternative scenarios, which are described in section 9.4.

This chapter reports the effects on shipments of all the CSCs in a reference scenario and 

in various alternative scenarios. (Chapter 10 of the TSD, which describes the NIA, documents

the resulting effects on NES and NPV.) Section 9.2 presents the model methodology. Section 9.3

describes model calibration and inputs. Section 9.4 describes the alternative analyses. Section 9.5

presents the results of the shipments projections for the GSL base case, CSCs, and alternative 

analyses.

9.1.1 Analyzed Product Classes, Market Sectors, and Market Segments

DOE projected GSL shipments in each of the three product classes analyzed in the 

engineering analysis (chapter 5 of this TSD). As discussed in chapter 2 of this TSD, these 

product classes include only medium screw-base, GU24, and pin-base lamps utilizing compact 

fluorescent (CFL) or light emitting diode (LED) technologies. General service incandescent 

lamps (GSILs), including halogen lamps, are not analyzed. The Energy Independence and 

Security Act of 2007 (EISA 2007)

1 includes a backstop provision specifying a minimum GSL 

efficacy of 45 lm/W if the current rulemaking is not completed by January 1, 2017, or if it does 

not yield energy savings that equal or exceed the energy savings that would result from the 

backstop. The backstop provision does not preclude the promulgation of a more stringent 

standard for GSLs in addition to the lm/W backstop, however, if energy savings from this 

rulemaking do not equal or exceed the savings from the backstop. 

DOE believes it is extremely unlikely that an energy conservation standard for GSLs 

would yield energy savings exceeding the savings from the EISA 2007 backstop if the 

rulemaking excludes GSILs. Therefore, DOE assumed in the shipments analysis that the EISA 

2007 backstop minimum efficacy requirement of 45 lm/W will take effect simultaneously with 

the candidate standards analyzed here, on January 1, 2020. 

9-2
The largest analyzed product class, integrated low-lumen GSLs, is made up of lamps with 

a broad range of lumen outputs that are typically used in different applications. Because of this, 

DOE subdivided this product class into four subcategories based on the lumen ranges established 

for GSILs by EISA 2007, with modifications to account for the product class definitions used in 

this preliminary analysis. In the following analysis, subcategories within each product class will 

be referred to as lamp categories. The integrated low-lumen product class consists of four lamp 

categories, and the other product classes consist of one lamp category each. The shipments 

analysis projects shipments of lamps and apportions them among the various CSLs within each 

lamp category separately.

DOE also projected shipments separately for the residential and commercial sectors.

DOE analyzed industrial GSL usage as part of the commercial sector, because of both the similar 

applications for GSLs in these sectors and the relatively small contribution of the industrial 

sector to overall GSL usage. Residential usage of non-integrated GSLs was considered to be a

negligible fraction of all usage for this product class, so the non-integrated product class was not 

analyzed in the residential sector. The product classes, lamp categories, and sectors analyzed in 

the shipments analysis are summarized in Table 9.1.2.

Table 9.1.2 Product Classes, Lamp Categories, and Sectors Analyzed in the Shipments 

Model

Product Class Lamp Category

Sector

Residential Commercial

Integrated low-lumen

310-749 lm X X

750-1049 lm X X

1050-1489 lm X X

1490-1999 lm X X

Integrated high-lumen 2000-2600 lm X X

Non-integrated All non-integrated

(310-2600 lm) X

9.1.2 Analyzed Time Periods

The shipments model projects shipments for thirty years following the compliance date of 

a potential GSL standard, assumed to be January 1, 2020, in this preliminary analysis. This 

thirty-year period, from 2020 through 2049, is referred to as the analysis period in this

preliminary TSD. The shipments model is initialized based on historical shipments data or 

estimates covering a sufficiently long period (the historical period), as discussed in section 9.3.1. 

In this analysis, the historical period runs from 1980 through 2013. DOE then projects shipments 

for the full shipments projection period, which runs from the year after the last year of the 

historical period, 2014, through the end of the analysis period in 2049. Finally, to enable 

accounting in the NIA of the energy consumed by products shipped at the end of the analysis 

period over their full lifetimes, DOE calculates the surviving installed stock of GSLs shipped 

9-3
during the analysis period during the years following the analysis period, until essentially all 

such lamps have been retired. This is referred to in this chapter as the stock attrition period. 

Because of the potentially very long lifetimes of certain GSLs (see appendix 8E of this 

preliminary TSD), the stock attrition period for this analysis is also long, running from 2050 

through 2099. The various time periods considered in the shipments analysis are summarized in

Table 9.1.3.

Table 9.1.3 Time Periods Considered in the Shipments Analysis

Period Years Covered

Historical period 1980-2013

Shipments projection period 2014-2049

Analysis period 2020-2049

Stock attrition period 2050-2099

9.2 SHIPMENTS MODEL METHODOLOGY 

This section describes the conceptual framework of the shipments model, the 

mathematical implementation, and the modeling assumptions. Model calibration and inputs are 

addressed in section 9.3.

9.2.1 Conceptual Framework of the Shipments Model

The shipments model estimates the changing market distributions across lamp categories

and CSLs for input to the NIA. Shipments are projected for a base case, in which no new 

standard is assumed to take effect in 2020, and for several different CSCs considered in this 

preliminary analysis.

The shipments model has three main interacting elements: (1) a demand module, which 

estimates the demand for new GSL shipments in each lamp category for each year of the 

shipments projection period; (2) a consumer choice module, which assigns shipments to lamps at 

different efficacy levels based on consumer sensitivities to lamp price, energy consumption, 

lifetime, and mercury content; and (3) a price projection module, which projects future lamp 

prices based on historic price trends and projected future shipments. To apportion shipments 

among the CSLs, the consumer choice model consults substitution matrices, which specify the 

lamp options that are available to consumers making a given purchase decision, within the CSC 

for which shipments are being projected. Based on the features and projected prices of the 

available lamps, the consumer choice model allocates the national lamp demand among the 

available CSLs for each year of the shipments projection period. A schematic representation of 

the shipments model is shown in Figure 9.2.1.

9-4
Figure 9.2.1 Schematic Representation of the Shipments Model

9.2.1.1 Lamp options considered in the shipments analysis

In the shipments modeling, DOE represented each CSL by one or more representative 

lamps in each of the lamp categories covered by that CSL. These representative lamps, referred 

to hereafter as lamp options, are identical to the lamp options analyzed in the LCC analysis

(chapter 8 of this TSD), which were themselves derived from the representative lamps analyzed 

in the engineering analysis (chapter 5 of this TSD). Table 9.2.1, Table 9.2.2, and Table 9.2.3

summarize the properties of the lamp options analyzed in the shipments analysis for each product 

class. A more complete description of the characteristics of the lamp options is presented in 

section 9.3.4.

9-5
Table 9.2.1 GSL Options Used in the Shipments Analysis for the Integrated Low-lumen 

Product Class

Lamp 

Category CSL Lamp Technology

Initial 

Lamp 

Lumens

Nominal 

Wattage

Efficacy 

(lm/W)

310-749 lm

0 CFL 469 9.5 49.1

1 CFL 500 8.9 56.4

2 LED 500 8.1 61.6

3 LED 500 7.4 67.7

4 LED 500 6.7 75.0

5 LED 500 6.3 79.1

750-1049 lm

0 CFL 750 14.0 53.6

1 CFL 800 13.0 61.5

2 LED 800 12.0 66.7

3 LED 800 11.0 72.7

4 LED 800 10.0 80.0

5 LED 800 9.5 84.2

1050-1489 lm

0 CFL 1125 19.8 56.9

1 CFL 1200 18.4 65.4

2 LED 1200 17.0 70.4

3 LED 1200 15.7 76.5

4 LED 1200 14.3 83.7

5 LED 1200 13.6 88.0

1490-1999 lm

0 CFL 1500 25.6 58.6

1 CFL 1600 23.8 67.3

2 LED 1600 22.1 72.3

3 LED 1600 20.4 78.3

4 LED 1600 18.7 85.6

5 LED 1600 17.8 89.9

9-6
Table 9.2.2 GSL Options Used in the Shipments Analysis for the Integrated High-lumen 

Product Class

CSL Lamp 

Technology

Initial 

Lamp 

Lumens

Nominal 

Wattage

Efficacy 

(lm/W)

0 CFL 2000 32.0 62.5

1 CFL 2000 30.0 66.7

2 CFL 2200 29.0 75.9

Table 9.2.3 GSL Options Used in the Shipments Analysis for the Non-integrated Product 

Class

CSL Lamp 

Technology

Initial 

Lamp 

Lumens

Nominal 

Wattage

Efficacy 

(lm/W)

0 CFL 1710 26.0 65.8

1* CFL 1800 26.0 69.2

CFL 1525 21.0 72.6 *

Two lamp options were analyzed at CSL 1 in the non-integrated product class.

9.2.1.2 Demand Module

The lamp demand module of the shipments model projects the demand for shipments of 

GSLs, both for installation in new construction and as replacements for failed or retired lamps, in 

each year of the shipments projection period. The module estimates the demand for replacement 

GSLs by computing the number of lamps retired in each year based on a lamp failure and 

retirement model described in section 9.2.2.

To project the demand for GSLs in new construction, the lamp demand module makes 

the assumption that the amount of light desired to fully light a space (measured in lumens per 

square foot), is constant over time. That is, sector-specific lumen demand per square foot stays

constant, while total national lumen demand grows proportionally with total floor area. 

Therefore, the lamp demand module increases the total lumen demand in each year of the 

shipments projection period based on the sector-specific floor-space growth rates extracted from 

Annual Energy Outlook 2014 (AEO 2014).

2 The increment in lumen demand in each year 

represents the lumen demand for new construction.

To compute the total GSL demand in each year, DOE combined the lumen demand for 

GSL replacements with the lumen demand for GSL applications in new construction. In this 

preliminary analysis, DOE assumed that an increasing fraction of this total lumen demand will 

be fulfilled by integrated LED luminaires, which are outside the scope of the present analysis. 

This attenuates the overall demand for GSL shipments in each year. DOE further assumed that, 

in the early part of the shipments projection period, demand for CFL and LED GSLs increases 

relative to other GSL technologies, as consumers switch away from the other GSLs. Details of 

the assumed substitution patterns are given in section 9.2.2.3. The retirement, floor-space 

9-7
growth, and substitution considerations yield the total lumen demand to be fulfilled by CFL and 

LED GSLs in each year of the shipments projection period.

To apportion the demand among the different lamp categories, DOE assumed that the

GSLs used to meet the demand have a fixed distribution of lumen outputs throughout the 

shipments projection period. DOE also assumed in this preliminary analysis that the fraction of 

all installed GSLs that are non-integrated GSLs remained constant throughout the shipments 

projection period. These assumptions yield a final projection of the demand for new shipments in 

each of the analyzed product classes and lamp categories.

9.2.1.3 Consumer Choice Module

The consumer choice module constitutes the analytical heart of the shipments model. The 

basic framework of the consumer choice module, also used to model consumer behavior in other 

contexts,

3,4 allocates market shares as an aggregate of many individual purchasing decisions. A

simplifying assumption of the model is that lamp efficacies exist only at the discrete levels 

defined by the lamp options listed in section 9.2.1.1. In each year of the shipments projection

period the consumer choice model assigns a share of new purchases (shipments) to each of the 

lamp options that are available to the consumer, based on consumer sensitivities to first cost and 

to other product features, as well as on diffusion rates of new technologies into the market.

Specifically, the consumer choice module couples an econometric logit model for 

consumer choice with a Bass model5 for technology diffusion, which limits the technology 

adoption rate based on historical observations. The logit model captures consumer sensitivity to 

product price and features for familiar technologies. The Bass diffusion model captures barriers 

to market entry, like lack of consumer information, that diminish over time with consumer 

exposure to new technologies. As those barriers diminish, the technology achieves a market 

share that is more perfectly described by the economic factors captured by the logit model. While 

the Bass diffusion model captures increases in product adoption over time, there are also noneconomic reasons for consumer preferences that persist over time and are not captured in this 

model. The consumer choice module uses acceptance factors, which place a cap on the potential 

market share of certain options, to capture these additional deviations from economic factors. 

The remainder of this section describes the logit and diffusion model in mathematical terms.

The Logit Model. The logit model calculates the probability PPii that a consumer will 

purchase option i from a set of n choice options, based on a logistic curve probability function. 

The category of econometric logit models contains several subtypes that are appropriate for 

different choice situations. The current analysis considers lamp options utilizing different 

lighting technologies (fluorescent and LED) in the integrated low-lumen product class. When

faced with a choice among options that can be subdivided into groups of products having 

features that provide similar consumer utility, an appropriate logit model is the nested logit 

model.6 In such a model, the choice options i ∈ {1, ... , n} are subdivided into K total subgroups, 

or “nests,” Nk ∈ {1, ... ,KK}. The choice probability then takes the form

9-8
PPii,kk(zzii) = eezzii⁄λλkk�∑ eezzjj⁄λλkk jj∈NNkk �

λλkk−11

∑ �∑ eezzjj⁄λλll

jj∈NNll � KK λλll

ll=11

Eq. 9.1

Where:

PPii,kk(zz) = the probability a consumer will purchase product i in nest NNkk among all possible 

options,

K = the total number of nests,

NNl = the lth nest out of the K total nests,

λλl = a parameter associated with nest l that controls the relative probability of choosing 

options within that nest relative to other nests, and

zj = the logit, which is a function that combines economic and other variables that describe 

option j with parameters that describe consumer sensitivity to the variables.

The logit is typically written as a linear function in the variables:

zzii = �ββjjvvjj,ii

mm

jj=11

Eq. 9.2

Where:

vvjj,ii = the jth variable describing product i, 

m = the total number of variables used in the model, and

ββjj = a parameter describing consumer sensitivity to the jth variable.

In this analysis, the variables used to construct the logit, and the values of the coefficients (beta 

values) were developed from a report investigating consumer GSL preferences for a major utility

company.

7

As mentioned previously, DOE also applies acceptance factors in some cases, to cap the 

market share for certain options whose market share may be limited by factors not captured by 

the model. The acceptance factor for a given option takes values between zero and one, 

representing the fraction of consumers who will consider that option in their choice. If only one 

option has a non-unit acceptance factor, the consumer choice model is run twice, with the option 

in question being excluded from the choice matrix in the second run. The results of these two 

runs are combined in a weighted sum, with the first run given a weight equal to the acceptance 

factor and the second run receiving complementary weight to yield the final fraction of 

consumers who choose each option. If multiple options have acceptance factors applied, the

consumer choice is run repeatedly, with the acceptance factors treated hierarchically: the option 

having lowest acceptance is excluded in the second run, and options with higher acceptance are

excluded in later runs, until the only remaining options all have unit acceptance. If no option has 

unit acceptance, then, prior to any model runs, all acceptance factors are scaled up by a constant 

factor such that the largest acceptance factor is equal to unity. The acceptance factors applied to 

the lamp options may vary depending on which lamp option is being replaced. The logit model 

9-9
with acceptance factors applied thus yields the probability PPjj that lamp ii is selected, given that 

lamp jj is being replaced.

Full details of the development and calibration of the consumer choice model are 

presented in section 9.3.2.

The Bass Technology Diffusion Curve. One of the factors that may restrict the potential 

market share of certain lamp options is limited consumer adoption of new and unfamiliar 

technologies (e.g., LED lighting products). In the shipments analysis, DOE parameterized this 

adoption rate using a Bass technology diffusion curve. 

The Bass diffusion curve sets the market penetration (i.e., the fraction of the market share

at full product maturity) for an individual lamp type at any given point in time following its 

introduction to the market, based on the historical technology diffusion rate for lighting products. 

The diffusion curve is treated as a variable cap on the market share for each option; in each year, 

this cap is implemented by multiplying the Bass market penetration for each option by the 

existing acceptance factor for each option. The resulting product is treated as the new acceptance 

factor for the year in question and is applied as discussed previously.

A Bass adoption curve is a 2-parameter diffusion curve widely used to describe how new 

products enter into markets.5 The two parameters, p and q, represent external and internal 

influences, respectively, on markets. If the fraction of the market is zero at time tt0, the Bass 

diffusion curve is expressed as follows:

MM (tt) = 11 − ee−(pp+qq)(tt−tt00)

11 + �

qq

pp� ee−(pp+qq)(tt−tt00)

Eq. 9.3

Where:

MMMM(tt) = market penetration at time t,

tt = the time variable,

tt0 = the time at which the product was introduced to the market,

pp = the coefficient of external influence, and

qq = the coefficient of internal influence.

9.2.1.4 Price Projection Module

The consumer choice module uses product prices as one of the descriptive variables in 

the logit model. Consistent with current practice in DOE rulemaking analyses, DOE has adopted 

a price learning model to project product prices over the shipments projection period.8,9 As 

originally defined, price learning reflects systematic decreases in manufacturing costs resulting 

from cumulative production experience. When price learning analyses are considered on an 

industry-wide basis, rather than at the manufacturer level, and when they include learning effects 

downstream of production (for example, increased efficiencies in product distribution), the price 

learning curve is typically referred to as an experience curve, but it takes the same mathematical 

9-10
form. A broad range of cost and price metrics have been used to quantify learning rates for 

appliances and equipment (see, for example, Weiss et al., 2010, Table A1).

10

DOE used historical data to estimate the impact of price learning by fitting the data to an

experience curve of the following form:

pp(XX) = ppiiiiii × XX−bb

Eq. 9.4

Where: 

p(X) = the price of a particular product as a function of cumulative production, 

pinit = the initial price of the product at the time of market introduction, 

X = cumulative production (total shipments) of the product from the time of its market 

introduction (number of units), and

b = a positive constant parameter that describes the rate of price decline with production.

As described in section 9.3.3, DOE used historical price and shipments data from the 

U.S. Census to determine the cumulative historical production and prices of lamps sold into the 

U.S. market and, thus, to calibrate the learning rate parameter, b.

Eq. 9.4 can be used to obtain a projection for price in each year, pp(yy), if the cumulative 

production is written explicitly as a function of time:

XX(yy) = � ss(vv)

yy−11

vv=yyiiiiii

Eq. 9.5

Where:

X(y) = the cumulative production (total shipments) of a product between the year of its 

introduction and year y (number of units),

y = the current yeara,

v = the vintage, or year in which a product was shipped to market,

yinit = the year of the product’s market introduction, and

ss(vv) = the shipments in vintage year vv (number of units).

Eq. 9.4 and Eq. 9.5 can then be combined to compute a price learning factor to correct the price 

in a particular reference year to the price in an arbitrary year:

a The time variable y in this analysis is a discrete variable representing the year being analyzed. Throughout the 

remainder of this analysis, quantities that depend on y will be written in the form D(y), which is more typically used 

for functions of a continuous variable, rather than the usual subscript form that is conventionally used for discrete 

variables Dy. This is done for the sake of avoiding confusion with other subscripts used in the notation.

9-11

 
PPPPPP(yy) = � XX(yy)

XX(yy00)

�

−bb

Eq. 9.6

Where:

PPPPPP(yy) = the price learning factor in year y, 

yy0 = the reference year, and 

all other variables are defined in Eq. 9.4 and Eq. 9.5.

For any component of total lamp price that is subject to learning, the price learning factor can

then be used to calculate the price in any year, given the price in the reference year, using the 

following equation:

pp (yy) = PPPPPP(yy) × pp (yy00)

Eq. 9.7

Where:

pp(yy) = the learning-impacted price component in year y, and

all other variables are as defined in Eq. 9.6.

In this analysis, not all components of lamp price were treated as subject to learning. For 

compact fluorescent lamps (CFLs), DOE decomposed the price into a component arising from 

rare earth oxide (REO) costs and a component arising from other manufacturing inputs. Only the 

latter component is subject to learning; the REO costs are assumed to be constant in real dollars

during the shipments projection period (although they may be assumed to be boosted relative to 

the present-day REO price in some scenarios). The details of the REO price assumptions are 

presented in appendix 8D; these assumptions yield a price evolution model for CFLs given by 

the following equation:

ppCC (yy) = ppRRRRRR(yy) + PPPPPP(yy) × (ppCC (yy00) − ppRRRRRR(yy00))

Eq. 9.8

Where:

ppCCCCCC(yy) = the price of a CFL in year y,

ppRRRRRR(yy) = the component of CFL price arising from REO costs in year y, and

all other variables are as defined previously in this section.

A more detailed version of this equation is presented in appendix 8D.

To project prices for LED GSLs, DOE made use of a study

11 from Lawrence Berkeley 

National Laboratory (hereafter the LBNL GSL price report) that tracked recent price and 

shipments data to construct a learning curve for lamps in the lowest lumen lamp category

considered for the integrated low-lumen product class in this analysis (see Table 9.2.1). That 

study also measured exponential time trends in incremental price for the brighter lumen ranges 

relative to the lowest lumen range. For this analysis, DOE combined these results to construct a 

model for LED GSL prices that consists of a base price for an LED GSL in the lowest lumen 

9-12
range, which is subject to price learning, and an incremental price of increased lumen output, 

which declines exponentially with time:

pp LL(yy) = (PPPPPP(yy) × ppbbbb (yy00)) + �ppll(yy00) × ee−ααll(yy−yy00)�

Eq. 9.9

Where:

pp LL(yy) = the price of an LED GSL in year y, 

ppbbbbbbbb(yy0) = the price, in the reference year, of an LED GSL in the lowest-lumen lamp 

category considered in this analysis,

ppl(yy0) = the incremental price above ppbbbbbbbb, in the reference year, for an LED GSL in lamp 

category l,

ααl = a constant positive parameter controlling the rate of decline in the incremental price for 

lamps in lamp category l, and

all other variables are as defined previously in this section.

As discussed in more detail in section 9.3.3.1, the price trends presented in Eq. 9.8 and Eq. 9.9

were not applied to a subset of the available CFL and LED lamp options, which DOE assumed to 

represent obsolete technologies that are exiting the present market.

9.2.1.5 The Coupled Model

The shipments model uses the price learning equations presented in the previous section 

to calculate the price of each product in each year of the analysis, according to the additions to 

the cumulative production estimate produced by the shipments model up to that point. The model

then proceeds step-wise in each year to calculate product shipments based on the projected prices 

and other variables of the logit model via the demand and consumer choice modules. It then 

calculates the following year’s product prices after adding that year’s shipments to the previous 

estimate of cumulative production.

9.2.2 Detailed Modeling and Assumptions

DOE projected the annual shipments of GSLs within the commercial and residential

sectors separately. All quantities referenced in the equations or discussion in this section (e.g., 

the total lamp demand or shipments) are intended to be specific to a particular sector. The 

modeling was performed once for the residential sector and once for the commercial sector, with 

different inputs for each sector.

To project the shipments of GSLs, DOE first computed the demand in each year and 

lamp category for GSLs or GSL substitutes to be used for

• new construction,

• replacement of retired lamps within the lamp category

9-13
• replacement of retired lamps from other lamp categories, or from lighting technologies

not explicitly analyzed in this preliminary analysis, by consumers who are substituting 

between lamp categories or technologies (if any), and

• integrated LED luminaires to be used as substitute replacements for lamps within the 

lamp category

DOE then combined these sources of demand to obtain the total demand for new shipments of 

each lamp option, using the following equation:

ii(yy) = NN ,ii(yy) + RR,ii(yy) + iiii,ii(yy) − oooo ,ii(yy)

Eq. 9.10

Where:

y = the year of the shipments projection period,

DDii(yy) = the total demand for shipments of lamp option ii in year y (number of units),

DDNN ,ii(yy) = the demand for shipments of lamp option ii in new construction (number of units), 

DR,i(y)= the demand for replacement of retired units of lamp option ii (number of units),

DDiiii,ii(yy) = the incoming demand for lamp option ii as a substitute for lamps from other lamp 

categories or technologies (if any) (number of units), and

DDoooooo,ii(yy) = the outgoing demand for units of lamp option ii being replaced by integrated LED 

luminaires (number of units).

Eq. 9.10 represents the disaggregated demand for GSLs within a given lamp option. It can be 

used to derive the total demand for GSLs within a lamp category, product class, or sector by 

summing over the relevant lamp options. 

After computing the disaggregated demand, DOE reapportioned this demand among the 

various lamp options within each lamp category via the consumer choice module to determine 

the shipments of each lamp option in each year. The lamp options DOE considered in the 

shipments analysis are discussed in section 9.2.1.1.

Given values for the retirements and new shipments in year y, as well as the total stock in 

year y-1, the stock of GSLs in year y for a particular lamp option can be calculated as:

SSii(yy) = SSii(yy − 11) − RRii(yy) + ssii(yy)

Eq. 9.11

Where:

SSii(yy) = the national stock of lamps corresponding to lamp option ii in year y (number of 

units),

Ri(y) = units of lamp option ii that are retired (because of failure or for any other reason) in 

year y (number of units), and

si(y) = the total shipments of new units of lamp option ii in year y (number of units).

The total stock of GSLs in each lamp category or sector is then given by summing over the stock 

of all relevant lamp options.

9-14
Eq. 9.11 requires the stock to be initialized at the beginning of the shipments projection

period. This is accomplished by combining the lamp survival probability as a function of lamp 

age with the historical shipments data discussed in section 9.3.1:

SSii(yy00) = � PPss ss ,ii(yy00 − yy) × sshh ,ii(yy)

yy00−11

yy=yyff

Eq. 9.12

Where:

PP ssss,ii(yy0 − yy) = the survival probability in year yy0 of a GSL of lamp option ii shipped in 

year yy, as derived in appendix 8E of this TSD for various lifetime 

scenarios,

yy0 = the first year of the shipments projection period, 2014, 

yyff = the first year of the historical period, and

sshii ,ii(yy) = the historical shipments of GSLs of lamp option ii in year yy (number of units).

The different lamp options can have different survival probability functions, since they may have 

different lifetimes (see section 9.3.4).

Eq. 9.10 and Eq. 9.11 are the fundamental equations underlying the shipments and stock 

modeling of the lamp categories in this analysis. The remainder of this section will be devoted to

deriving the various components of these equations for GSLs, as a preliminary step to computing 

the GSL shipments and stock, starting with lamp demand.

9.2.2.1 Modeling GSL Demand for New Construction

To project the lamp demand for new construction, DOE assumed that the demand for 

lumen capacity per square foot of new floor space (lm/ft2 at maximum lamp output), as well as 

the overall GSL lumen distribution in the installed stock, is constant over time, so that overall

lumen demand in each lamp category grows at the same sector-specific annual growth rate as 

floor space. Thus, the annual demand for GSLs in new construction is given by: 

NN ,ii(yy) = SSii(yy00)[(11 + γγ)yy−yy00 − (11 + γγ)yy−yy00−11]

Eq. 9.13

Where:

DNC,i(y) = the total demand from new construction for GSLs of lamp option ii in year yy

(number of lamps),

SSii(yy0) = the installed national stock of GSLs in lamp option ii in year yy0 (number of lamps), 

as defined in Eq. 9.12,

yo = the initial year of the shipments projection period, and

γγ = the sector-specific, 30-year (2010-2040) average annual floor space growth rate projected 

by AEO 2014.

9-15
The total GSL demand for new construction, DDNN (yy), is then given by the summation over all 

lamp options within each sector.

9.2.2.2 Modeling demand for replacement of retiring GSLs

DOE determined the demand for replacement shipments in a given year by computing the 

number of shipments from previous years that would be expected to retire in that year. The 

probability that a given lamp will retire AA years after installation is:

PP ,ii(AA) = PPss ss ,ii(AA − 11) − PPss ss ,ii(AA)

Eq. 9.14

Where:

AA = the lamp's age (years since installation),

PP ,ii(AA) = the probability that a GSL of lamp option ii is retired when it is AA years old, and

PP ssss,ii(AA) = the probability that the lamp survives (i.e., is not retired) for AA years after 

installation, derived in appendix 8E of this TSD for different lifetime scenarios.

The retirement probability function is used to compute the expected lamp failures in year 

y, given a time series of historical shipments spanning the maximum expected age reached by 

any lamp, Amax:

RRii(yy) = � PP ,ii(yy − vv)

yy−11

vv=yy−AAmmmmmm

ssii(vv)

Eq. 9.15

Where:

RRii(yy) = retirements of GSLs of lamp option ii in year y (number of units),

y = current year,

vv = lamp vintage (i.e., year of shipment),

Amax = maximum expected lamp lifetime (yr),

PP ,ii(yy − vv) = probability of lamp retirement in year yy − vv of a lamp’s lifetime (Eq. 9.14), 

and

ssii(vv) = total shipments of lamp option ii that occurred in a particular vintage (number of 

units).

Since LED GSLs can have very long lifetimes, DOE assumed a maximum lamp lifetime of 

AAmm mm = 50 years throughout this analysis. The demand for replacements for retired GSLs of 

lamp option ii is then simply given by the retirements in each year:

9-16
RR,ii (yy) = RRii(yy)

Eq. 9.16

Where:

DDRR,ii(yy) = the demand for replacement of retired units of lamp option ii (number of units), and

RRii(yy) is defined in Eq. 9.15.

The total annual retirements RR(yy) and demand for replacement shipments DDRR(yy) can be 

computed for each lamp category and sector by summing over the relevant lamp options.

9.2.2.3 Incoming and outgoing demand

The demand formula in Eq. 9.10 includes terms for demand entering and leaving the 

demand pool for the analyzed lamp options from and to other lighting technologies. In the case 

of outgoing demand, DOE assumed that, in each year of the shipments model, some fraction of 

the lighting demand historically fulfilled by the modeled product classes would instead be 

fulfilled by installation of integrated LED luminaires. To compute the incoming demand, in the 

years prior to 2020, DOE assumed that some consumers who historically utilized GSL 

technologies that are not analyzed here (i.e., incandescent and halogen GSLs) will switch to

CFLs or LED GSLs in either of the integrated product categories. Zero incoming demand was 

assumed for non-integrated GSLs. After 2020, DOE assumed that all remaining demand for 

those technologies would be fulfilled by CFLs or LED GSLs, in accordance with the EISA 2007 

backstop provision (see section 9.1.1).

To model the fraction of demand transferred to integrated LED luminaires in each year, 

DOE utilized the Bass adoption curve given in Eq. 9.3 with the parameterization presented in 

section 9.3.2.2. Specifically, DOE assumed that integrated LED luminaires would eventually 

displace a certain fraction of GSL luminaires at full market penetration and that this 

displacement would grow from zero percent in 2007 according to the Bass diffusion curve. The 

displacement of GSL sockets in each year corresponds to a reduction in demand for new 

shipments that is persistent in all future years. Thus, the outgoing demand in each year of the 

shipments model is given by the following formula:

9-17
oooo ,ii(yy) = � NN ,ii(yy) + RR,ii(yy)� × ffiiii ii × MM (yy)

Eq. 9.17

Where:

DDoooooo,ii(yy) = the outgoing demand leaving the demand pool for GSL lamp option ii in year yy

(number of units),

DDNN ,ii(yy) = the demand for GSLs in lamp option ii for new construction (Eq. 9.13) (number of

units),

DDRR,ii(yy) = the demand for replacement of retired units of lamp option ii (Eq. 9.16) (number of 

units),

ffiiii ii = the fraction of all GSL sockets displaced by integrated LED luminaires at maximum 

market penetration, and

MM (yy) = the market-penetration given by the Bass adoption curve (Eq. 9.3).

Note that this equation implicitly assumes that adoption of integrated LED luminaires will 

reduce demand by the same fraction across all lamp categories and lamp options. The total 

outgoing demand can be computed by summing across all relevant lamp options.

The total incoming demand from incandescent and halogen GSLs was assumed to 

constitute a fixed fraction of the previous year's demand for such lamps, in years before 2020:

iiii(yy < 22 22 ) = ffss × oo (yy − 11)

Eq. 9.18

Where:

DDiiii(yy < 2020) = the incoming demand for analyzed GSLs from technologies other than 

CFL and LED in year yy (for years before 2020) (number of units),

ff = the fraction of the previous year's demand for other technologies that is transferred to 

analyzed GSLs through substitution, and

DDooooh (yy − 1) = the previous year's demand for GSLs utilizing other technologies (number 

of units).

DOE disaggregated this demand among the lamp options by assuming it was proportional to the 

fraction of the previous year's shipments represented by each lamp option:

9-18
iiii,ii(yy) = ssii(yy − 11)

ssII (yy − 11) + ssIIII (yy − 11) iiii(yy)

Eq. 9.19

Where:

DDooooh ,ii(yy) = the incoming demand from other technologies for GSLs in integrated lamp 

option ii (number of units),

ssii(yy − 1) = the shipments of lamp option ii in year yy − 1 (number of units), and

ssII (yy − 1), ssIIII (yy − 1) = the total shipments in the integrated low-lumen and integrated 

high-lumen product classes, respectively, in year yy − 1 (number 

of units).

The previous year's demand, DDooooh (yy − 1), in Eq. 9.18 is given by reducing the 2013 

shipments of other technologies by a fixed fraction in each year:

oo (yy) = ssoo (22 22) × (11 − ffss )yy−22 22

Eq. 9.20

Where:

ssooooh (2013) = the shipments of non-CFL and non-LED GSLs in 2013, and

all other variables are as defined in Eq. 9.18. 

The selection of the input parameter values used for the equations in this section is described in 

section 9.3.2.3.

In 2020, DOE assumed that 100% of the demand that would have gone to other 

technologies is instead fulfilled by CFLs or LED GSLs, owing to the EISA 2007 backstop 

provision. For the years after 2020, DOE assumed that a shrinking number of non-CFL and nonLED GSLs will require replacement, since other GSL technologies have relatively short 

lifetimes, often a year or less. Specifically, DOE assumed that demand for such replacements in 

2021 would be 10% of the 2020 demand and zero thereafter. Hence, DOE used the following 

formulas for the incoming demand in 2020 and beyond:

iiii(yy = 22 22 ) = oo (yy = 22 22 )

iiii(yy = 22 22 ) = 00. 11 ∗ iiii(yy = 22 22 )

iiii(yy > 22 22 ) = 00

Eq. 9.21

Where:

all variables are as defined earlier in this section.

9-19
9.2.2.4 Turnover and Shipments

Because the different lamp options considered in each lamp category may have

significantly different lifetimes (e.g., LED versus CFL options), it was necessary to explicitly 

model the shipments for each lamp option separately. Additionally, because of the different 

usage patterns in each sector, DOE modeled lamps separately in the residential and commercial 

sectors. DOE computed the total yearly demand DDii for each lamp option separately within each 

sector according to the disaggregated form of Eq. 9.10. DOE then reallocated this demand 

among all lamp options in the same lamp category using the consumer choice module, yielding a 

projection for the shipments of each lamp option in each year:

ssii(yy) = � jj(yy)σσjj (yy)

jj

Eq. 9.22

Where:

ssii(yy) = projected shipments to a particular sector for GSL option i in year y (number of 

units),

DDjj(yy) = the total in-sector demand in year yy for lamp option j, defined in Eq. 9.10 (number 

of units), and

σσji (y) = the substitution matrix in year y.

The substitution matrix, σσjj , specifies the fraction of consumers who switch between the lamp 

options, according to the consumer choice model:

σσjj (yy) = PPjj (yy) × AAjj (yy)

Eq. 9.23

Where:

PPjj (yy) = probability of purchasing lamp option i in year yy from among the available lamp 

options, given that option j is being replaced, according to the consumer choice 

module described in section 9.2.1.3, 

yy = the year of the shipments model, and

AAjj (yy) = the availability matrix in year yy.

The availability matrix AAjj (yy) specifies the products that are available to a consumer who is 

retiring a unit from lamp option j and replacing it. This matrix is zero when lamp option i is not a 

direct substitute for k, or when lamp option i has been eliminated by a candidate standard in the 

standards case; it is equal to unity otherwise. 

DOE used the model above to project the shipments of each GSL option in each year of 

the analysis, for the base case and for the CSCs listed in Table 9.1.1. The input parameters, and 

their calibration, are discussed in section 9.3.2. Given the projections of failures, renovations, 

and new shipments in each year, and a calculation of the total operating stock in the initial year 

of the shipments projection period, Eq. 9.11 then yields the total operating stock of GSLs in the 

9-20
United States in each subsequent year as an input for computing the NES in the NIA (chapter 10

of this preliminary TSD). 

9.2.2.5 Stock Attrition

As mentioned in section 9.1.2, in addition to projecting shipments through the end of the 

analysis period, DOE also projects the surviving installed stock of GSLs shipped during the 

analysis period through 2099. During the time after the analysis period, this quantity shrinks 

steadily as lamps fail and are replaced by shipments that fall outside of the analysis period. The 

surviving stock during the stock attrition period is given by the following formula:

SSii(yy) = � PPss ss ,ii(yy − yy′) × ssii(yy′)

yyee ee

yy′=yy−AAmm mm

Where:

SSii(yy) = the stock of GSLs of lamp option ii in year yy following the end of the analysis 

period, which were shipped during the analysis period (number of units),

AAmm mm = the assumed maximum lifetime of a GSL (taken to be 50 years in this analysis),

yy ee = the final year of the analysis period (2049 in this analysis),

PP ssss,ii(yy − yy′) = the survival probability in year yy of a GSL of lamp option ii shipped in year 

yy′ of the analysis period, as derived in appendix 8E of this TSD for various 

lifetime scenarios, and

ssii(yy′

) = the shipments of GSLs of lamp option ii in year yy′ of the analysis period (number of 

units).

9.3 MODEL INPUTS AND CALIBRATION

9.3.1 Historical Shipments Data

Because the lamp shipments modeled in any given year depend on sums of shipments of 

GSLs in prior years, DOE needed historical data to initialize the shipments model. To accurately 

compute the initial shipments and stock projections from historical data, it is necessary to have 

data spanning a sufficiently long time period such that products shipped at the beginning of the 

historical period have a negligible surviving fraction in today’s stock. DOE estimates that, for 

GSLs, 30 years is a sufficiently long historical period to meet this criterion. The remainder of 

this section describes the sources of the historical shipments data; their disaggregation into 

different sectors, product classes, and technology options; and their use in initializing the 

shipments and stock model.

9.3.1.1 Sources of Historical Shipments Data

In support of the shipments analysis, DOE received estimates of historical GSL

shipments to the U.S. market, developed by Cadeo Group,

12 for medium screw-base integrated 

CFL and LED lamps (aggregated across both integrated product categories) and for non9-21
integrated CFLs. The estimates covered the years 2010 through 2013; they are presented in Table 

9.3.1.

Table 9.3.1 Estimated Shipments of GSLs to the U.S. Market, by Technology Type

12

Year

CFL A-line, medium 

screw base (thousands 

of lamps)

LED A-line , medium 

screw base (thousands 

of lamps)

Non-integrated CFL 

(thousands of lamps)

2010 262,241 1,540 48,314 

2011 250,178 2,002 46,864 

2012 249,428 5,544 45,458 

2013 243,441 14,630 44,095 

As mentioned previously in this section, a historical shipments time series spanning 30 

years is required for an accurate initialization of the GSL shipments model. For the period from 

2001 to 2009, DOE estimated this time series for integrated and non-integrated CFLs by utilizing 

the lamp shipments indices published periodically by NEMA,

13 as compiled in the LBNL GSL 

price report. The compiled indices provide relative shipments levels, on a quarterly basis, 

referenced to the average quarterly shipments in 2011. DOE aggregated these quarterly indices to 

produce annual indices and scaled the shipments estimates shown in Table 9.3.1 by the resulting 

indices to produce a historical time series of estimated shipments from 2001 to 2013. To estimate 

CFL shipments in years prior to 2001, DOE assumed that CFLs were introduced to the U.S. 

market in 1981 and that shipments increased linearly until 2001. Since nearly all lamps shipped 

during this period have retired by 2014, this approximation is sufficiently accurate for this 

analysis.

In the case of LED GSLs, the NEMA lamp indices do not give sufficient coverage of the 

years prior to 2010. DOE therefore assumed that LED GSLs in each of the four integrated lowlumen lamp categories (see Table 9.1.2) were introduced to the market in 2004, 2008, 2012, and 

2013, in order of increasing lumen output. For the two lowest-lumen lamp categories, DOE 

assumed linear growth in the historical shipments through 2009 and 2010, respectively, after 

which shipments for each of these lamp categories were determined by the disaggregation of 

historical shipments data described in the following section.

9.3.1.2 Subdivision of Historical Shipments by Sector, Lamp Category, and CSL

The data and historical projections described in the previous section were aggregated 

across sectors, lumen outputs and lamp efficacies for integrated LEDs, integrated CFLs, and nonintegrated CFLs. This section describes the inputs and assumptions that DOE used to 

disaggregate these historical shipments—first by sector, then by lamp category, and finally by

CSL—in order to properly initialize the shipments model. 

When subdividing the historical shipments of non-integrated GSLs by sector, DOE

assumed that all shipments of non-integrated GSLs occur in the commercial sector, with 

negligible shipments in the residential sector. Thus, no further disaggregation of the historical 

shipments by sector is required for the non-integrated product class.

9-22
For the two integrated product classes, DOE estimated the residential fraction of each 

product’s shipments using a simple stock turnover model utilizing sector-specific mean lamp 

lifetimes and estimates of medium screw-base GSL stocks in the 2010 LMC. The resulting 

estimate of the residential fraction of integrated GSL shipments is given by 

ffRR =

SSRR

RR

SSRR

RR

+ SSCC

CC

Eq. 9.24

Where:

ffRR = the fraction of lamp shipments in the residential sector,

SRes = the stock of lamps in the residential sector, as reported in Table 4.1 of the LMC 

(number of units),

SC = the stock of lamps in the commercial sector, from the same table (number of units),

LRes = the median lamp lifetime in the residential sector (yr), i.e., the average failure age 

derived from the 50% failure point in the lamp retirement distribution derived in 

appendix 8E of this TSD, using the appropriate hours-of-use distribution and lamp 

switching rates for the residential sector, and

LC = the median lamp lifetime in the commercial sector (yr), computed as above, except with 

the use of the appropriate hours-of-use distribution and switching rates for the 

commercial sector.

Based on this equation, DOE assumed that 79.2% of historical GSL shipments went to the 

residential sector.

The two integrated product classes comprise five lamp categories with different lumen 

ranges. DOE subdivided historical shipments of integrated CFLs into these five lamp categories 

in each sector according to the lamp lumen distributions developed in chapter 8 of this TSD. 

These fractions were assumed to be constant over time. For LED GSLs, DOE assumed no 

historical shipments to the integrated high-lumen product class; thus the CFLs assigned to that 

product class represent its full time series of historical shipments.

In the integrated low-lumen product class, DOE notes that LED products were only

introduced to market in 2013 for the highest lumen range. Therefore, DOE assumed that, in both 

the residential and commercial sector, only 1% of LED GSL shipments fell into that lamp 

category in 2013, and that no LED GSL shipments existed in that lamp category in earlier years. 

For the 750-1049 lumen and 1050-1489 lumen lamp categories, DOE assumed that the fraction 

of all LED GSL shipments in those categories was the same as the fraction of all integrated CFL 

shipments in those categories starting in 2011 and 2012, respectively. Prior to this, DOE 

assumed a linear historical increase in shipments starting in the introduction year for GSL LEDs 

in each category, as described in the previous section. After apportioning LED shipments among 

the other lamp categories, DOE assumed that the lowest-lumen lamp category made up the 

remainder of the historical shipments presented in Table 9.3.1.

9-23
Having subdivided the historical shipments of integrated lamps among the various lamp 

categories, DOE then apportioned these shipments to the various lamp options in each category.

This task is simplified somewhat by the fact that the lamp options available to a consumer in the 

consumer choice model are independent of the lamp option that is being replaced (see 

section9.3.2.1). Therefore, the historical shipments breakdown needs only be accurate enough to 

correctly initialize the lamp demand in the first year of the shipments model. As discussed in 

section 9.2.2, the only lamp property on which the lamp demand depends is the lamp survival 

function (see Eq. 9.14). Lamp options within each lamp category are assumed to have identical 

usage patterns, so lamp options of like technology having identical lifetimes will have identical 

survival functions. Thus, it is only necessary to apportion historical shipments among the lamp 

options that have substantially different technologies or lifetimes in each category; there is no 

need to further subdivide them between the lamp options that have identical technologies and 

similar lifetimes. In both of the integrated product classes, the different CFL lamp options have 

nearly equal lifetimes, as do the various LED lamp options. Therefore, since the particular CSL 

level at which historical shipments of CFLs or LEDs occurred would have negligible impact on 

the shipments projections, DOE assigned all historical CFL and LED shipments to the lowest 

available CSL for each technology. In contrast, for the non-integrated lamp category, the 

different CFL lamp options have significantly different lifetimes. Based on the output of the 

calibrated consumer choice module (see section 9.3.2), DOE assumed that the baseline lamp 

option made up 66%, and that the full and reduced-wattage lamp options at CSL 1 made up 30% 

and 4%, respectively, of all historical shipments of non-integrated GSLs.

9.3.2 Consumer Choice Module Development and Calibration

This section describes the methods DOE used to determine the various functional forms 

and parameters that control the behavior of the consumer choice module used in this shipments 

analysis. These include the form and parameters of the logit model, the parameters of the Bass 

adoption model, and parameters of the stock turnover model.

9.3.2.1 Development and Calibration of the Logit Model

As introduced in section 9.2.1.3, DOE used a nested logit model, described by Eq. 9.1

and Eq. 9.2, as the main driver of the consumer choice model used to predict product market 

share. The logit zzii depends on certain variables that describe lamp option ii, as well as a set of 

coefficients associated with each of the variables. This section describes the selection of the 

descriptive variables for GSLs and the determination of appropriate coefficients, first discussing

the selection of the nests, then the determination of the variables and coefficients used to 

construct the logit formula from Eq. 9.2, and finally the determination of the nest parameters λλkk

used in Eq. 9.1.

Selection of the nests. The nested logit model conceptually divides the utility that a 

consumer derives from a particular product selection into two components: an observed 

component, consisting of the variables utilized in constructing the logit equation, and an 

unobserved component, made up of elements of the utility that are not explicitly modeled 

because they are not or cannot be observed (e.g., variation in consumer tastes).

6 The standard 

logit model assumes that the unobserved component is independently and identically distributed 

for each of the products. The nested logit model used in this analysis accounts for the situation in 

9-24
which certain subsets of the available options have unobserved components of utility that are 

correlated with one another, rather than being independent. 

In the current analysis, the lamp options in the integrated low-lumen product class 

include lamps utilizing CFL and LED technologies. These two technologies can be broadly 

distinguished by certain features relating to lamp utility that are similar for lamps using each of 

the two technologies. For example, lamp appearance, start time, warm-up time, and dimming 

performance are generally different when comparing a CFL to an LED GSL, while these features 

will be more similar when comparing lamps within each of the technologies. For this reason, in 

the consumer choice module, DOE subdivided the integrated low-lumen lamp options into two 

nests: one for CFLs and one for LED GSLs. For the other two product classes, there was only a 

single nest, so the model reduces to a conditional logit model.

Development and calibration of the logit. To determine the logit variables and 

coefficients used in Eq. 9.2, DOE made use of a report issued by Pacific Gas & Electric utility

(PG&E) that used extensive consumer surveys to probe consumer preferences for GSLs as a 

function of several descriptive variables.7 The report authors used a conjoint model to produce a 

preference index for each variable, ranging from 0 to 100, and indicating relative levels of 

consumer preference. The preference index for each variable can be interpreted as representing 

the difference in the fraction of consumers who would choose a test product option over a 

reference option, where the two options differ only in the variable of interest, with all other 

features identical:

II = 11 × (PPtt tt − PP )

Eq. 9.25

subject to the constraint

PPtt tt + PP = 11

Eq. 9.26

Where:

II = the preference index,

PP = the probability of choosing the test option, and

PP = the probability of choosing the reference option.

If the test and reference options are identical, the index has a value of zero, reflecting the equal 

probabilities that consumers would choose either option. An index value of 100 indicates that 

100% of consumers would choose the test option over the reference option, an index value of 50 

indicates that 75% of consumers would choose the test option and 25% would choose the 

reference option, and so on.

Considering the logit probability function in Eq. 9.1, one notes that the two products in 

this test case can be assumed to be in the same nest, since they have identical features aside from 

the variable being considered. With that assumption, combining Eq. 9.25 with the logit 

probability function yields an equation for the probability index in terms of the relevant logit 

variable and coefficient:

9-25
IIii = 11 × �11 − eeββiivvii,tt tt − eeββiivvii,

eeββiivvii,tt tt + eeββiivvii, �

Eq. 9.27

Where:

IIii = the preference index for variable vvii,

ββii = the logit coefficient for variable vvii, and

vvii, , vvii, = the value of variable vvii for the test and reference product options, 

respectively.

To develop the logit model DOE fitted this equation to the preference indices extracted 

from the PG&E report to yield beta coefficients for four lamp features: price, fractional energy 

savings (relative to the reference lamp), lifetime, and the presence of mercury. These lamp 

features were chosen since they can be used to categorically distinguish between the lamp 

options corresponding to different CSLs. Other lamp features considered in the PG&E report, 

such as energy-efficiency labeling or dimmability, could vary within a given CSL, and so they 

are not helpful variables for a consumer-choice model that considers a choice among the CSLs 

considered in this analysis.b In the derivation of the logit model, features such as these are 

handled as unobserved random variables that drop out of the final logit formula.

The presence-of-mercury variable is a binary (dummy) variable equal to unity for CFLs 

and zero for LED GSLs. In this case, Eq. 9.27 can be solved analytically to provide a value for 

the coefficient. For the other three lamp features considered, DOE fitted Eq. 9.27 to the data via 

least-squares minimization, using two different functional forms: first, DOE assumed that the 

variable vvii was simply equal to the lamp feature being considered (price, lifetime, or energy 

savings), and second, DOE assumed that vvii was equal to the natural logarithm of the lamp 

feature. The linear model represents a consumer choice based on absolute differences between 

features, whereas the logarithmic model is more appropriate if consumers choose based on 

fractional differences between features. In developing the logit model to be used in the consumer 

choice module, DOE chose either the linear or the logarithmic scaling for each variable, 

depending on which one gave a better description of the data.

b The PG&E report also presents a preference index for the amount of money that could be saved by using a 

particular lamp option, which could be used to distinguish between the CSLs. This variable is partially redundant 

with both the fractional energy savings and the lifetime, however, and it depends strongly on consumer usage 

patterns, so DOE did not use it in the logit model for this shipments analysis.

9-26

 
Figure 9.3.1 Preference Index Data from a Report7 for PG&E on Consumer Lamp 

Preferences, Fitted to Models Given by Eq. 9.27, with Variables that are

either Linear or Logarithmic in the Quantity Plotted on Each Plot’s 

Horizontal Axis.

The fits of Eq. 9.27 to the PG&E data are shown in Figure 9.3.1, for both the linear and 

the logarithmic models. As shown, the logarithmic model gives a more accurate description of 

0

20

40

60

80

100

0 5 10 15 20 25 30 35

Preference Index

Lamp price (dollars)

data linear model log model

0

20

40

60

80

100

0 0.2 0.4 0.6 0.8 1

Preference Index

Fractional energy savings

data linear model log model

0

20

40

60

80

100

0 5 10 15 20 25

Preference Index

Lamp lifetime (years)

data linear model log model

9-27
the preference indices for price and lifetime, whereas the linear model gives a more accurate 

description of the index for fractional energy savings. (It is interesting to note that this suggests 

the preference for absolute energy savings is also logarithmic.) Therefore, DOE assumed that the 

logit model depends logarithmically on price and lifetime and linearly on fractional energy 

savings and the presence of mercury. Thus, the logit function in Eq. 9.2 becomes

zzii = ββPP llll(PPii) + ββ llll( ii) + ββWW �11 − WWii

WW00

� + ββMMMMii

Eq. 9.28

Where:

zzii = the logit for lamp option ii,

PPii = the price of lamp option ii (dollars), 

ii = the median lifetime of lamp option ii (years), 

WWii = the system wattage of lamp option ii, 

WW0 = the system wattage of the baseline lamp option,

MMii = a binary (dummy) variable indicating the presence or absence of mercury lamp option ii, 

and

ββXX = the logit coefficient for variable XX.

The median lifetime was used as a representative lifetime variable in the shipments model, since 

the lifetime in years of any individual lamp depends strongly on its usage. The median lifetime 

was computed by taking the time to 50% survival from the survival probability function PP ssss as 

derived in appendix 8E of this preliminary TSD. The values of the lamp variables used as inputs 

to this equation are presented in section 9.3.4. The residential-sector beta coefficients are given 

by the fits described in this section; they are presented in Table 9.3.2.

DOE was unable to obtain appropriate data to directly calibrate the logit coefficients for 

consumers in the commercial sector. To estimate these, DOE made use of the sector-specific

logit scaling factors developed for the shipments analysis in the TSD for the 2014 Notice of 

Proposed Rulemaking for General Service Fluorescent Lamps and Incandescent Reflector Lamps

(chapter 11 of that TSD).

14 Based on the sector-specific scaling performed for the logit 

coefficients in that analysis, DOE assumed for the present analysis that the absolute value of the 

price coefficient in the residential sector was 45% lower than in the commercial sector, while the 

absolute values of the lifetime and fractional energy savings coefficients were 50% lower in the 

residential sector than the commercial sector. The consumer sensitivity to mercury content was 

assumed to be identical in the two sectors. The resulting logit coefficients for the commercial 

sector are presented in Table 9.3.2.

9-28
Table 9.3.2 Sector-Specific Parameters of the Logit Formula Given in Eq. 9.28.

Variable Residential coefficient Commercial coefficient

Log Price -2.64 -4.8

Fractional Energy Savings 1.89 3.78

Log Lifetime 1.27 2.54

Presence of Mercury -1.18 -1.18

Calibration of the nest parameters. It was also necessary to calibrate the nest parameters,

λλkk, from Eq. 9.1. There are two such parameters for the nested logit model used in this analysis: 

one for CFLs and one for LED GSLs. To calibrate these parameters, DOE started by assuming 

that both parameters were equal to unity (and that all other parameters were as determined in this 

section). When the model was run with this parameterization, the relative market shares of CFLs 

and LED GSLs were significantly different from the market shares observed in the historical 

shipments data. Therefore, DOE varied the two parameters λλCCCCCC and λλ LLuntil the market shares 

predicted by the model were consistent with the market shares revealed in the historical data. The 

same nest parameters were applied in both the residential and commercial sectors. The calibrated 

parameters resulting from this procedure are presented in Table 9.3.3.

Table 9.3.3 Nest Parameters Used in the Consumer Choice Module

λλCC 0.2

λλ LL 0.5

9.3.2.2 Bass Adoption Model

As discussed in section 9.2.1.3 DOE used a Bass diffusion curve (Eq. 9.3) to restrict 

adoption of new technologies in the shipments model. The diffusion model was used to place an 

increasing ceiling on the market share of LED GSLs in each year of the shipments projection 

period as outlined in section 9.2.1.3. It was also used to determine the demand for integrated 

LED luminaires as substitutes for GSLs, as presented in Eq. 9.17.

The adoption parameters used for this analysis were chosen to match the adoption model 

used to forecast LED adoption in a recent report

15 from DOE's SSL program, which used a 

similar consumer-choice based approach to the one utilized in this analysis. The adoption curve

coefficients of external and internal influence used in Eq. 9.3, pp and qq, are presented in Table 

9.3.4, and the Bass adoption curve is plotted in Figure 9.3.2. For all LED technologies 

considered, DOE computed the market penetration assuming that the year of product 

introduction was 2008.

9-29
Table 9.3.4 Bass Adoption Model Parameters

p 0.012

q 0.29

Figure 9.3.2 Bass Diffusion Curve for LED Technologies Using the Parameters Presented 

in Table 9.3.4

9.3.2.3 Incoming and outgoing demand

As discussed in section 9.2.2.3, DOE assumed that some demand for the GSL lamp 

options modeled here will be displaced in each year by consumers' switching to integrated LED 

fixtures. DOE also assumed, in the early years of the projection period, that the demand for CFL 

and LED GSLs will be supplemented by consumers' switching away from incandescent and 

halogen GSLs, either independently or as a result of the EISA 2007 backstop.

The outgoing demand model (see Eq. 9.17) depends on a free parameter ffiiii ii that 

defines the maximum fraction of GSL luminaires that will be displaced by integrated LED 

luminaires when the latter reach their maximum market penetration. Based on input from 

manufacturers and lighting experts, DOE adopted a value of ffiiii ii = 0.15 in its reference 

analysis. DOE views this fraction as highly uncertain, however. To assess the impact of this 

assumption on the results of the shipments and later analyses, DOE performed alternative 

scenario analyses with different assumed values for ffiiii ii; these are discussed in section 9.4.

The incoming demand model (see Eq. 9.18) is based on an assumed fraction ff of 

consumers' substituting CFLs or LED GSLs for other GSL technologies in each year prior to 

2020. The model depends on the shipments of other GSL technologies in 2013, the year before 

the projection begins and on the assumed fraction of consumers who switch in each year. Based 

on the historical shipments estimates provided by Cadeo Group,

12 DOE assumed that 748 million 

GSLs using non-CFL and non-LED technologies were shipped to the US market in 2013. 

0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1

0 5 10 15 20 25 30

Fractional market penetration

Years since product introduction

9-30
DOE then determined a sector-specific value for ff in both the commercial and 

residential sectors by using this quantity as a calibration parameter. Starting with an assumed 

value of ff = 0, if the projected combined shipments of CFLs and LED GSLs in 2014 were

substantially below the 2013 historical shipments in a given sector, then that sector's ff value 

was increased until the shipments projection yielded a smooth transition from the historical 

shipments. This procedure yielded values of ff = 0 and ff = 0.15 for the commercial and 

residential sectors, respectively. These values amount to an assumption that the commercial 

sector has largely switched away from incandescent and halogen GSLs almost completely, while 

significant transition is still underway in the residential sector.

9.3.2.4 Availability Matrix

The availability matrix AAjj (see Eq. 9.23) specifies whether or not lamp option ii is 

available for selection if lamp option jj is being replaced. This section defines the availability 

matrix that DOE used for this shipments analysis.

Within each lamp category in the integrated product classes, all lamp options in the 

model are directly interchangeable, while lamp options in different lamp categories are not 

interchangeable. Thus, for all integrated lamp options, AAjj = 1 whenever lamp options j and i are 

in the same lamp category and option i is not eliminated by the standard under consideration. 

Otherwise, AAjj = 0.

For the non-integrated product category, there is one baseline lamp option and two lamp 

options at CSL1. One of the CSL1 lamp options has the same wattage as the baseline lamp, but 

higher lumen output, while the other lamp option has reduced wattage. Input to DOE from 

lighting manufacturers suggests that the reduced-wattage lamp option has extremely low market 

share on the order of 5% of less. Moreover, in its assessment of the market, DOE found that 

reduced-wattage options do not exist for the majority of non-integrated GSL base types. For 

these reasons, DOE assumed in the shipments analysis that the reduced-wattage lamp option is a 

niche product, so that consumers currently using it will continue to use it, but consumers 

currently using full-wattage lamps will not switch to the reduced-wattage option. 

Thus, the availability matrix for non-integrated GSLs was equal to one for consumers 

replacing a full-wattage lamp with either of the two full-wattage lamp options, and it was equal 

to one for consumers replacing a reduced-wattage with a reduced-wattage lamp, but it was zero 

for substitutions between full and reduced-wattage lamps. The historical shipments calibration 

discussed in section 9.3.1.2 assumed that the reduced wattage lamp option made up 

approximately 5% of the non-integrated GSL market; the availability matrix then ensured that 

the reduced wattage lamp retained a market share at approximately the same level throughout the 

shipments projection period.

9.3.2.5 Acceptance Factors

As discussed in section 9.2.1.3, the consumer choice module can utilize acceptance 

factors to restrict the market share of certain options and account for market factors not explicitly 

modeled. Given the market-share restrictions arising from the Bass adoption model for LED

technology (section 9.3.2.2), as well as the nest parameters which set the relative desirability of 

9-31
CFL and LED GSLs (section 9.3.2.1), the market shares for CFLs and LED GSLs at the start of 

the shipments projection period were consistent with the market share trends at the end of the 

historical period. Moreover, the availability matrix discussed in section 9.3.2.4 ensures that the 

market shares of different non-integrated lamp options are consistent with historical values. 

Therefore, no further restriction of the market shares for any of the lamp options was required for 

this analysis, so all acceptance factors were assumed equal to unity prior to the application of the 

Bass adoption curve in each year.

9.3.3 Price Trend Projection

As discussed in section 9.2.1.4, DOE uses a learning-curve model, with certain 

modifications, to project future prices in its shipments analysis. Accordingly, the initial lamp 

prices determined in the pricing analysis (chapter 6 of this TSD) are subsequently adjusted over

the shipments projection period to account for projected price trends. The price model consists of 

a learning-curve component applied to all technologies, with a separate treatment of the price 

component arising from REOs for CFLs, and a separate treatment of the incremental price of 

more luminous lamps for LED GSLs. To construct the price model, DOE made use of the LBNL 

GSL price report and the REO price analysis conducted in appendix 8D of this TSD.

9.3.3.1 Lamp Options Excluded from the Price Trend Projection

The mix of GSL products on the US market has been evolving rapidly in recent years, 

with once cutting-edge products being rapidly supplanted by new, less expensive, more 

efficacious, and more aesthetically pleasing lamps, on time scales of a year or less. This situation 

can temporarily create an unusual price structure in which the most efficacious products on the 

market are also the least expensive, since the older, less efficacious products were introduced to 

the market at a higher price point, and have since become effectively obsolete. This price 

structure is reflected in the results of the product price determination (chapter 6 of this TSD), 

where the CFL and LED GSL lamp options in the integrated low-lumen product class decline 

monotonically in price as their efficacy increases. 

In the shipments analysis and NIA, for the integrated low-lumen product class, DOE 

assumed that the two most efficacious LED lamp options, at CSLs 4 and 5, represent recent 

introductions to the market, whereas the two least efficacious LED options, CSLs 2 and 3, 

represent older products that are being supplanted by the newer entrants to the market. Similarly, 

for the integrated low-lumen product class, DOE assumed that the baseline CFL lamp option 

represents an older product that is being supplanted by the newer entrant at CSL1. Since further 

research and development is unlikely to occur on the now-obsolescent products, there is little 

driving force to bring their prices down. 

Therefore, in the integrated low-lumen product class, DOE applied the LED GSL price 

trend model only to the lamp options at CSLs 4 and 5, and DOE applied the CFL price trend 

model only to the lamp option at CSL 1. DOE assumed that all other lamp options in the product 

class will have fixed real prices over the shipments projection period. This assumption will 

effectively eliminate the older products from the market by early in the analysis period. In the 

integrated high-lumen and non-integrated product classes, by contrast DOE applied the CFL 

price trend model to all lamp options, since prices in those product classes increase 

monotonically as a function of luminous efficacy.

9-32
9.3.3.2 Learning Rate Parameters

The LBNL GSL price report measures the learning rate parameter, bb, defined in Eq. 9.6

for both CFLs and LED GSLs and compares these to the rates for other lighting technologies. It 

concludes that the learning rate parameter for CFLs is similar to the one observed for other 

lighting technologies, whereas the learning rate parameter for LEDs is substantially higher. DOE 

believes that that the higher LED learning rate may be a transitory phenomenon arising from 

strong market competition and the supportive current policy environment for LED research and 

development. In that case, the learning rate for LED GSLs may be expected to fall to a value 

nearer the rate observed for other lighting technologies. Thus, in its reference analysis, DOE 

assumed that both CFLs and LED GSLs have the same learning rate parameter of bb = 0.22

during the shipments projection period. As discussed in section 9.4, DOE also analyzed an 

alternative scenario in which LED GSLs have the higher learning rate observed in the LBNL 

GSL price report, as well as an alternative scenario in which prices are fixed in real dollars for all 

lamp options.

9.3.3.3 Incremental Price Trends for LED GSLs

For LED GSLs, in addition to applying a learning curve to the base price of the 

technology, DOE modeled an exponential price trend on the incremental price of increased 

lumen output, as detailed in section 9.2.1.4, specifically Eq. 9.9. The rates of exponential decline 

used in applying that equation were taken from the LBNL GSL price report; they are presented 

in Table 9.3.5.

Table 9.3.5 Exponential Decline Parameters for the Incremental Price of Increased 

Lumen Output for LED GSLs

Lamp 

Category

Incremental price 

decline parameter

ααl* (yr-1)

310-749 lm 0.00

750-1049 lm 0.56

1050-1489 lm 0.59

1490-1999 lm 0.59

*As defined in Eq. 9.9

9.3.3.4 Rare Earth Costs

As described in section 9.2.1.4, DOE considered the impact of possible changes in REO 

prices in its GSL shipments modeling. REOs are used in fluorescent lamp phosphors at higher 

concentrations in more efficient models. REOs saw large price increases in the third quarter of 

2010 and into 2011, which have now largely corrected themselves, as shown by the fluorescent

tri-band phosphor price index shown in Figure 9.3.3 and described in appendix 8D This volatility 

has resulted in significant uncertainty about the potential long-term impact on prices for 

fluorescent lamps, including CFLs.

9-33
Figure 9.3.3 Inflation-Adjusted, Tri-band Phosphor REO Price Index 

Given the large uncertainty caused by such price volatility, DOE modeled CFL prices 

assuming two different REO price scenarios detailed in appendix 8D a reference (best estimate) 

scenario, which reflects the REO prices with recent price data (June 2014), and a high REO price

scenario (corresponding to the identified mid-point in Figure 9.3.3), which reflects the mid-point

REO price between the 2011 peak price and the 2006 – 2009 baseline average price. Given the 

lack of any clear, consistent price trend, in both scenarios the REO price was assumed to remain 

constant in real dollars over the shipments projection period.

9.3.4 General Service Lamp Characteristics

Table 9.3.6, 

Table 9.3.7, and Table 9.3.8 show the characteristics of the GSL lamp options used as inputs to

the shipments model in DOE’s reference scenario analysis.

9-34
Table 9.3.6 Lamp Characteristics Used as Inputs to the Shipments Model for the Integrated Low-Lumen Product Class in 

the Reference Scenario

Lamp Category

CSL

Lamp 

Technology

Initial Lamp 

Lumens

Nominal 

Wattage

Efficacy 

(lm/W)

Lamp Price

(incl. Sales 

tax, 2014$)

Rare Earth 

Cost (2014$)

Life Hours

Median 

Lifetime, 

Residential

(Years)

Median 

Lifetime, 

Commercial

(Years)

System 

Wattage*

(W)

Energy 

Savings 

Relative to 

Baseline

Contains 

Mercury

310-749 lm

0 CFL 469 9.5 49.1 $5.57 $0.02 10000 6.8 2.6 9.5 0.00 Yes

1 CFL 500 8.9 56.4 $3.93 $0.02 12000 8.2 3.1 8.9 0.07 Yes

2 LED 500 8.1 61.6 $27.55 - 25000 19.2 6.5 8.1 0.15 No

3 LED 500 7.4 67.7 $17.54 - 25000 19.2 6.5 7.4 0.23 No

4 LED 500 6.7 75.0 $13.98 - 25000 19.2 6.5 6.7 0.30 No

5 LED 500 6.3 79.1 $13.27 - 25000 19.2 6.5 6.3 0.34 No

750-1049 lm

0 CFL 750 14.0 53.6 $6.02 $0.03 10000 6.8 2.6 14.0 0.00 Yes

1 CFL 800 13.0 61.5 $4.25 $0.03 12000 8.2 3.1 13.0 0.07 Yes

2 LED 800 12.0 66.7 $30.12 - 25000 19.2 6.5 12.0 0.14 No

3 LED 800 11.0 72.7 $19.18 - 25000 19.2 6.5 11.0 0.21 No

4 LED 800 10.0 80.0 $15.28 - 25000 19.2 6.5 10.0 0.29 No

5 LED 800 9.5 84.2 $14.51 - 25000 19.2 6.5 9.5 0.32 No

1050-1489 lm

0 CFL 1125 19.8 56.9 $7.58 $0.05 10000 6.8 2.6 19.8 0.00 Yes

1 CFL 1200 18.4 65.4 $5.36 $0.05 12000 8.2 3.1 18.4 0.07 Yes

2 LED 1200 17.0 70.4 $50.16 - 25000 19.2 6.5 17.0 0.14 No

3 LED 1200 15.7 76.5 $31.95 - 25000 19.2 6.5 15.7 0.21 No

4 LED 1200 14.3 83.7 $25.46 - 25000 19.2 6.5 14.3 0.28 No

5 LED 1200 13.6 88.0 $24.17 - 25000 19.2 6.5 13.6 0.31 No

9-35
Lamp 

Category

CSL

Lamp 

Technology

Initial Lamp 

Lumens

Nominal 

Wattage

Efficacy 

(lm/W)

Lamp Price

(incl. Sales 

tax, 2014$)

Rare Earth 

Cost (2014$)

Life Hours

Median 

Lifetime, 

Residential

(Years)

Median 

Lifetime, 

Commercial

(Years)

System 

Wattage*

(W)

Energy 

Savings 

Relative to 

Baseline

Contains 

Mercury

1490-1999 lm

0 CFL 1500 25.6 58.6 $8.52 $0.06 10000 6.8 2.6 25.6 0.00 Yes

1 CFL 1600 23.8 67.3 $6.02 $0.06 12000 8.2 3.1 23.8 0.07 Yes

2 LED 1600 22.1 72.3 $72.98 - 25000 19.2 6.5 22.1 0.14 No

3 LED 1600 20.4 78.3 $46.48 - 25000 19.2 6.5 20.4 0.20 No

4 LED 1600 18.7 85.6 $37.04 - 25000 19.2 6.5 18.7 0.27 No

5 LED 1600 17.8 89.9 $35.17 - 25000 19.2 6.5 17.8 0.30 No

* For integrated GSLs, the system wattage is equal to the nominal wattage. For non-integrated GSLs, the system wattage depends on the lamp-and-ballast 

combination; for details see chapter 5 of this TSD.

Table 9.3.7 Lamp Characteristics Used as Inputs to the Shipments Model for the Integrated High-Lumen Product Class in 

the Reference Scenario

CSL

Lamp 

Technology

Initial Lamp 

Lumens

Nominal 

Wattage

Efficacy 

(lm/W)

Lamp Price 

(incl. Sales 

tax, 2014$)

Rare Earth 

Cost (2014$)

Life Hours

Median 

Lifetime, 

Residential 

(Years)

Median 

Lifetime, 

Commercial 

(Years)

System 

Wattage*

(W)

Energy 

Savings 

Relative to 

Baseline

Contains 

Mercury

0 CFL 2000 32.0 62.5 $10.82 $0.07 10000 6.8 2.6 32.0 0.00 Yes

1 CFL 2000 30.0 66.7 $11.19 $0.07 10000 6.8 2.6 30.0 0.06 Yes

2 CFL 2200 29.0 75.9 $12.01 $0.07 12000 8.2 3.1 29.0 0.09 Yes

* For integrated GSLs, the system wattage is equal to the nominal wattage. For non-integrated GSLs, the system wattage depends on the lamp-and-ballast 

combination; for details see chapter 5 of this TSD.

9-36
Table 9.3.8 Lamp Characteristics Used as Inputs to the Shipments Model for the Non-Integrated Product Class in the 

Reference Scenario

CSL

Lamp 

Technology

Initial Lamp 

Lumens

Nominal 

Wattage

Efficacy 

(lm/W)

Lamp Price 

(incl. Sales 

tax, 2014$)

Rare Earth 

Cost (2014$)

Life Hours

Median 

Lifetime, 

Residential 

(Years)

Median 

Lifetime, 

Commercial 

(Years)

System 

Wattage* (W)

Energy 

Savings 

Relative to 

Baseline

Contains 

Mercury

0 CFL 1710 26.0 65.8 $14.67 $0.06 10000 N/A 2.6 30.0 0.00 Yes

1** CFL 1800 26.0 69.2 $15.79 $0.06 17000 N/A 4.4 30.0 0.00 Yes

CFL 1525 21.0 72.6 $17.51 $0.06 20000 N/A 5.2 24.4 0.19 Yes

* For integrated GSLs, the system wattage is equal to the nominal wattage. For non-integrated GSLs, the system wattage depends on the lamp-and-ballast 

combination; for details see chapter 5 of this TSD.

**

Two lamp options were analyzed at CSL 1 in the non-integrated product class.

9-37
9.4 ALTERNATIVE SCENARIOS

9.4.1 Overview

In addition to determining the best estimates of the impacts of the CSCs described in the 

introduction to this chapter (section 9.1), DOE conducted alternative analyses to gauge the 

importance of various assumptions for the results of the shipments analysis and NIA. Alternative 

analyses that affect the NIA only are described in chapter 10 of this TSD. This section describes 

the analyses that affect shipments, and, therefore, also the NIA. A complete summary of the 

alternative scenario analyses is given in appendix 8B.

As summarized in Table 9.4.1, these analyses explore the model sensitivity to 

uncertainties in the penetration of integrated LED luminaires, in the actual lamp service lifetime, 

in the price learning rate, and in REO prices. An individual scenario tests the effect of modifying 

only one scenario variable. The effect is determined by comparing the results of the alternative 

scenario model runs to the results in the reference scenario, which holds all variables at their 

reference (best estimate) values. Summary shipments analysis results for the alternative scenarios 

are presented in section 9.5.

9-38
Table 9.4.1 Summary of Alternative Scenarios Analyzed in the Shipments Analysis

Scenario Name

Scenario 

Options 

Analyzed

Scenario Description

Reference

Reference 

selection 

indicated in 

bold below

DOE’s best estimate of the national impacts of a 

GSL standard 

Integrated LED 

incursion

0% Incursion of LED luminaires into the market for 

traditional GSL luminaires at the end of the 

analysis period; see appendix 8B of this TSD

15%

50%

Lamp Service 

Lifetime

Rated

Varies assumptions about the primary driver for 

lamp replacements (lamp failure, renovation, or 

early replacement with newer technology); see 

chapter 8 of this TSD.

RenovationDriven 

EarlyReplacement

Learning Rate

None 

Learning rates used to develop lamp price trends, 

as described in section 9.3.3.2 CFL

Technology 

High Rare Earth

Constant Price scenario for rare earth oxides, applies to 

High CFLs only; see appendix 8D of this TSD

9.5 RESULTS

This section presents summary results of the GSL shipments analysis for DOE's reference 

scenario and for the alternative scenarios described in section 9.4. Complete results can be 

viewed using the Microsoft Excel® NIA spreadsheet tool described in appendix 10A of this 

TSD.

9.5.1 Reference Scenario Results

Figure 9.5.1 presents the base-case shipments for each product class by sector and lamp 

option. The large spike in shipments in the residential sector that occurs at the beginning of the 

analysis period is due to increased demand for CFLs and LED GSLs owing to the assumption 

that the EISA 2007 backstop provision takes effect concurrent to this rulemaking, as described in 

sections 9.1.1 and 9.2.2.3. 

Figure 9.5.2 and Figure 9.5.3 present the base case shipments by technology type for the 

commercial and residential sectors, respectively. Figure 9.5.4, Figure 9.5.5, and Figure 9.5.6

present the total estimated historical GSL shipments from 2010-2013 and projected shipments in

each CSC for the integrated low-lumen product class, integrated high-lumen and non-integrated 

product classes respectively. The estimated historical data are disaggregated by product class 

from the historical shipments data presented in Table 9.3.1. Table 9.5.1 presents the base case 

9-39
cumulative shipments in each product class and the percent change in cumulative shipments 

under each CSC.

The strong, periodic variation in the shipments of non-integrated GSLs in the standards 

case, visible in Figure 9.5.6, occurs because the full-wattage CSL 1 lamp option has a much 

longer lifetime than the baseline lamp option. Therefore, there is a large influx of lamps with 

longer lifetimes in the compliance year, which are all replaced at approximately the same 

cadence (set by the average lamp lifetime) in future years. This causes the observed “ringing” in 

the shipments for this product class. Similar considerations cause more muted ringing effects in 

other product classes for certain CSCs.

Finally, price trends for each lamp option are presented. Figure 9.5.7 shows the base-case 

price trends for the integrated low-lumen product class by lamp option for each lamp category. 

Figure 9.5.8 and Figure 9.5.9 show the base-case price trends by lamp option, for the integrated 

high-lumen and non-integrated product classes respectively. 

9-40
Figure 9.5.1 Reference Scenario Base Case Shipments by Product Class, CSL, and Lamp 

Option 

Integrated Low-Lumen

Integrated High-Lumen

Non-Integrated

9-41
Figure 9.5.2 Reference Scenario Base Case Shipments by Lamp Technology in the 

Commercial Sector 

Figure 9.5.3 Reference Scenario Base Case Shipments by Lamp Technology in the 

Residential Sector

9-42
Figure 9.5.4 Total Shipments of Integrated Low-Lumen Lamps in the Reference Scenario 

for All CSCs

Figure 9.5.5 Total Shipments of Integrated High-Lumen Lamps in the Reference Scenario 

for All CSCs

9-43
Figure 9.5.6 Total Shipments of Non-Integrated Lamps in the Reference Scenario for All 

CSCs

Table 9.5.1 Impact of Candidate Standards on the Cumulative Shipments of GSLs, 2020-

2049

Product 

Class

Cumulative

Shipments 

in the Base 

Case

(billions)

Fractional change in cumulative shipments under candidate 

standards cases 

CSC 1 CSC 2 CSC 3 CSC 4 CSC 5

Integrated 

low-lumen 4.24 0% -8% -8% -8% -8%

Integrated 

high-lumen 2.88 -1% -6% -6% -6% -6%

Nonintegrated 1.51 -23% -23% -23% -23% -23%

9-44
Figure 9.5.7 Base Case Price Trends for Lamp Options in the Integrated Low-Lumen 

Product Class by Lamp Category

9-45
Figure 9.5.8 Base Case Price Trends for Lamp Options in the Integrated High-Lumen 

Product Class

Figure 9.5.9 Base Case Price Trends for Lamp Options in the Non-Integrated Product 

Class

9.5.2 Results of the Alternative Scenario Analyses

Table 9.5.2 presents the cumulative shipments in the reference base case for each product 

class and the percent change in the base case cumulative shipments for each of the alternative 

scenarios that impact the shipments analysis (as summarized in Table 9.4.1).

9-46
Table 9.5.2 Impact of Alternative Scenario Assumptions on the Cumulative Shipments of 

GSLs in the Base Case, 2020-2049

Product 

Class

Cumulative 

Base-case 

Shipments 

in the

Reference 

Scenario

(billions)

Fractional change in cumulative base-case shipments in each 

alternative scenario

Integrated 

LED 

Incursion

Lamp Service 

Lifetime Learning Rate

Rare 

Earth 

Price

None High Early 

Replacement Rated None Technology High

Integrated 

lowlumen4.24 12% -22% 107% -35% 7% -2% 0%

Integrated 

highlumen2.88 13% -23% -1% -14% 0% 0% 0%

Nonintegrated 1.51 16% -28% 0% 0% 0% 0% 0%

9-47
REFERENCES

1. Energy Independence and Security Act of 2007. 42 U.S. Code 152 § 17001.

2. Energy Information Administration. Annual Energy Outlook 2014 with Projections to

2040. 2014. Washington, D.C. http://www.eia.gov/forecasts/aeo/pdf/0383(2014).pdf.

3. Cao, X. and P. L. Mokhtarian. The Future Demand for Alternative Fuel Passenger

Vehicles: A Diffusion of Innovation Approach. 2004. Prepared for The California

Department of Transportation: Sacramento, CA.

http://www.tc.umn.edu/~cao/AQP_Cao.pdf.

4. Paidipati, J., L. Frantzis, H. Sawyer, and A. Kurrasch. Rooftop Photovoltaics Market

Penetration Scenarios. 2008. National Renewable Energy Laboratory: Golden, CO.

Report No. NREL/SR-581-42306. http://www.nrel.gov/docs/fy08osti/42306.pdf.

5. Bass, F. M. A New Product Growth Model for Consumer Durables. Management

Science. 1969. 15(5): pp. 215–227.

6. Train, K. Discrete Choice Methods with Simulation. 2009. Cambridge University Press:

Cambridge; New York. http://elsa.berkeley.edu/books/choice2.html.

7. Krull, S. and D. Freeman. Next Generation Light Bulb Optimization. 2012. Pacific Gas

and Electric Company. http://www.etccca.com/sites/default/files/OLD/images/stories/Lighting_Conjoint_Study_v020712f.pdf.

8. U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Energy

Conservation Program for Consumer Products: Final Rule Technical Support Document:

Energy Efficiency Standards for Residential Refrigerators, Refrigerators-Freezers, and

Freezers. November 2011. Washington, D.C.

9. U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Using

the Experience Curve Approach for Appliance Price Forecasting. 2011.

https://www1.eere.energy.gov/buildings/appliance_standards/pdfs/

experience_curve_appliance_price_forecasting_3-16-11.pdf.

10. Weiss, M., M. Junginger, M. K. Patel, and K. Blok. A Review of Experience Curve

Analyses for Energy Demand Technologies. Technological Forecasting and Social

Change. 2010. 77(3): pp. 411–428.

11. Gerke, B., A. Ngo, A. Alstone, and K. Fisseha. The Evolving Price of Household LED

Lamps: Recent Trends and Historical Comparisons for the US Market. 2014. Lawrence

Berkeley National Laboratory: Berkeley, CA. Report No. LBNL-6854E.

12. Carmichael, R. GSL Shipments and Lumen Bin Distribution Data. Cadeo Group. Contract

7094760-T2D: Washington, D.C.

9-48 
13. National Electrical Manufacturers Association. Lamp Indices. (Last accessed September

24, 2014.) http://www.nema.org/Intelligence/Pages/Lamp-Indices.aspx.

14. U.S. Department of Energy- Office of Energy Efficiency and Renewable Energy. Notice

of Proposed Rulemaking Technical Support Document Energy Conservation Program for

Consumer Products and Certain Commercial and Industrial Equipment: General Service

Fluorescent Lamps and Incandescent Reflector Lamps. 2014. Washington, D.C.

http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/24.

15. Navigant Consulting, Inc. Energy Savings Potential of Solid-State Lighting in General

Illumination Applications. 2012.

http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/ssl_energy-savingsreport_jan-2012.pdf.

9-49 
CHAPTER 10. NATIONAL IMPACTS ANALYSIS

TABLE OF CONTENTS

10.1 INTRODUCTION ......................................................................................................... 10-1

10.2 NATIONAL ENERGY SAVINGS ............................................................................... 10-2

10.2.1 Primary Energy Savings .................................................................................... 10-3

10.2.2 Full-Fuel-Cycle Energy Savings........................................................................ 10-5

10.2.3 National Energy Savings Inputs......................................................................... 10-6

10.2.3.1 Shipments and Stock ................................................................................ 10-6

10.2.3.2 Average Unit Energy Consumption ......................................................... 10-6

10.2.3.3 Site-to-Power Plant Conversion Factor.................................................... 10-8

10.2.3.4 Primary Energy to Full-Fuel-Cycle Multipliers....................................... 10-9

10.2.3.5 Rebound Rate Factor................................................................................ 10-9

10.3 NATIONAL NET PRESENT VALUE ....................................................................... 10-10

10.3.1 Definition ......................................................................................................... 10-10

10.3.2 Net Present Value Inputs ................................................................................. 10-11

10.3.2.1 Total Annual Installed Cost Increment .................................................. 10-11

10.3.2.2 Total Annual Operating Cost Savings.................................................... 10-12

10.3.2.3 Discount Factor ...................................................................................... 10-15

10.4 RESULTS .................................................................................................................... 10-15

10.4.1 National Energy Savings Results..................................................................... 10-15

10.4.2 Net Present Value Results................................................................................ 10-17

10.4.3 Alternative Analyses Results........................................................................... 10-20

10.4.3.1 Overview ................................................................................................ 10-20

10.4.3.2 Alternative Analyses: National Energy Savings Results ....................... 10-22

10.4.3.3 Alternative Analyses: Net Present Value Results................................. 10-24

REFERENCES ........................................................................................................................ 10-31

LIST OF TABLES

Table 10.1.1 CSL for Each Product Class in Each CSC................................................... 10-1

Table 10.1.2 Summary of NES and NPV Inputs .............................................................. 10-2

Table 10.2.1 Rebound Rate Scenarios for GSLs ............................................................ 10-10

Table 10.4.1 Cumulative Site National Energy Savings for All Product Classes and 

CSCs in TWh ............................................................................................. 10-16

Table 10.4.2 Cumulative Power Plant National Energy Savings for All Product 

Classes and CSCs in Quads....................................................................... 10-16

Table 10.4.3 Cumulative Full Fuel Cycle National Energy Savings for All Product 

Classes and CSCs in Quads....................................................................... 10-17

Table 10.4.4 Cumulative Net Present Value at 3% for All Product Classes and 

CSCs in Billion 2014$ ............................................................................... 10-18

Table 10.4.5 Cumulative Net Present Value at 7% for All Product Classes and 

CSCs in Billion 2014$ ............................................................................... 10-19

10-i
Table 10.4.6 Cumulative Total Installed Cost Increment at 3% for All Product 

Classes and CSCs in Billion 2014$ ........................................................... 10-19

Table 10.4.7 Cumulative Total Installed Cost Increment at 7% for All Product 

Classes and CSCs in Billion 2014$ ........................................................... 10-19

Table 10.4.8 Cumulative Operating Cost Savings at 3% for All Product Classes and 

CSCs in Billion 2014$ ............................................................................... 10-20

Table 10.4.9 Cumulative Operating Cost Savings at 7% for All Product Classes and 

CSCs in Billion 2014$ ............................................................................... 10-20

Table 10.4.10 Alternative Scenarios Analyzed................................................................. 10-21

Table 10.4.11 Integrated Low-Lumen Alternative Analyses Full Fuel Cycle National 

Energy Savings in Quads........................................................................... 10-22

Table 10.4.12 Integrated High-Lumen Alternative Analyses Full Fuel Cycle National 

Energy Savings in Quads........................................................................... 10-23

Table 10.4.13 Non-Integrated Alternative Analyses Full Fuel Cycle National Energy 

Savings in Quads........................................................................................ 10-24

Table 10.4.14 Integrated Low-Lumen Alternative Analyses Net Present Value at 3% 

in 2014$ ..................................................................................................... 10-25

Table 10.4.15 Integrated Low-Lumen Alternative Analyses Net Present Value at 7% 

in 2014$ ..................................................................................................... 10-26

Table 10.4.16 Integrated High-Lumen Alternative Analyses Net Present Value at 3% 

in 2014$ ..................................................................................................... 10-27

Table 10.4.17 Integrated High-Lumen Alternative Analyses Net Present Value at 7% 

in 2014$ ..................................................................................................... 10-28

Table 10.4.18 Non-Integrated Alternative Analyses Net Present Value at 3% in 

2014$.......................................................................................................... 10-29

Table 10.4.19 Non-Integrated Alternative Analyses Net Present Value at 7% in 

2014$.......................................................................................................... 10-30

LIST OF FIGURES

Figure 10.2.1 Site-to-Power Plant Conversion Factor for Electricity ................................ 10-9

Figure 10.3.1 Annual Electricity Prices by Sector (2014$) ............................................. 10-14

Figure 10.4.1 Annual FFC NES for Product Classes at All CSCs................................... 10-16

Figure 10.4.2 Annual NPV at 3% for All Product Classes at All CSCs.......................... 10-17

Figure 10.4.3 Annual NPV at 7% for All Product Classes at All CSCs.......................... 10-18

10-ii
CHAPTER 10. NATIONAL IMPACTS ANALYSIS

10.1 INTRODUCTION

This chapter describes the method used to estimate the national impacts of energy 

conservation standards that the U.S. Department of Energy (DOE) is considering establishing for 

general service lamps (GSLs). In the national impacts analysis (NIA), DOE assessed the

cumulative national energy savings (NES) of products shipped during a 30-year analysis period 

(2020 – 2049) and the net present value (NPV) of the total consumer economic impacts of 

various candidate standard cases (CSCs). To fully quantify energy savings realized by lamps 

with long lifetimes, DOE continued to account for use and retirements during a period after 2049 

of those lamps shipped during the analysis period; this stock attrition period extends from 2050 

through 2099 when the last lamp shipped during the analysis period is assumed to retire if it has 

not already. Each CSC is composed of lamps in each product class that meet or exceed various 

candidate standard levels (CSLs), which are defined in terms of lamp luminous efficacy. Table 

10.1.1 lists the CSLs for all product classes at each CSC. In addition to NES and NPV, this 

chapter reports DOE’s estimate of the monetary value of cumulative national energy savings and 

the cumulative change in equipment costs nationwide resulting from each CSC relative to a base 

case in which no new standards are assumed to take effect. In both the base case and the 

standards cases the backstop provision of the Energy Independence and Security Act of 20071

(EISA) is assumed to take effect requiring all GSLs shipped after January 1, 2020 to have a 

minimum efficacy of 45 lumens per watt. 

Table 10.1.1 CSL for Each Product Class in Each CSC

Standards 

Case

Integrated 

Low-Lumen

Integrated 

High-Lumen

NonIntegrated

Base Case 0 0 0

CSC 1 1 1 1

CSC 2 2 2 1

CSC 3 3 2 1

CSC 4 4 2 1

CSC 5 5 2 1

DOE performs all NIA calculations using a Microsoft Excel® spreadsheet which is

available on regulations.gov, docket number EERE–2013–BT–STD–0051 at 

http://www.regulations.gov/#!docketDetail;D=EERE-2013-BT-STD-0051. Details regarding, 

and instructions for using, the NIA spreadsheet are provided in appendix 10A.

Table 10.1.2 summarizes the inputs to the NIA spreadsheet model. A brief description of 

the data is given for each input. 

10-1 
Table 10.1.2 Summary of NES and NPV Inputs

Input Data Description

Shipments

Annual shipments projections from the GSL shipments model (see 

chapter 9 of this preliminary TSD)

Stock of lamps Modeled from historical data and shipments projections (see chapter 9

of this preliminary TSD)

Assumed effective 

date of standard January 1, 2020

Analysis period For products shipped from 2020 through 2049

Stock attrition period 2050-2099, to account for the full energy savings of long-lived LED 

GSLs that are shipped during the analysis period

Maximum lamp 

lifetime

Assumed to be 50 years to accommodate long-lived LED GSLs in 

the residential sector. To account for lamps that live this long, the 

NES calculation must include energy consumption costs for some 

lamps out to 2099.

Lamp characteristics Wattage, first cost, and disposal cost (see chapters 5 and 8 of this 

preliminary TSD)

Lamp Prices Prices of lamps, adjusted for price trend projections in each year (see 

chapter 9 of this preliminary TSD)

Projected electricity 

prices

From the Energy Information Administration’s Annual Energy 

Outlook 20142 (AEO 2014) to 2040 and extrapolated beyond 2040

Site-to-primary 

electricity

conversion

Generated by the National Energy Modeling System (NEMS) version 

corresponding to the AEO 2014 to 2040 and extrapolated beyond 

2040

Rebound effect Percent of total energy savings in the commercial and residential 

sector (see appendix 10D)

Discount rate Real 3 and 7 percent

Present year Future costs and savings are discounted to the year 2014

The following sections describe in detail the methodology and inputs for the NIA.

Section 10.2 discusses DOE’s methods for calculating national energy consumption in the base

case and standards cases, and the resulting NES of the standards cases with respect to the base 

case. Section 10.3 discusses the NPV calculation method. Section 10.4 presents the NES and 

NPV results for the different CSCs, and under various scenarios.

10.2 NATIONAL ENERGY SAVINGS

This section describes DOE’s calculation of the NES for GSLs in the CSCs considered in this 

analysis.

10-2
10.2.1 Primary Energy Savings

The annual NES quantifies the difference in energy use between GSLs in the base case

and a standards case in a given year. During the analysis period (2020-2049) this is the annual 

energy consumption (AEC) of the standards case subtracted from the annual energy consumption 

of the base case, adjusted for any rebound:

NNNNSSaaaaaaaaaaaaaaaa( ) = �AA AA bb bb( ) − AA AA ssss( )� × RRRR

Eq. 10.1

Where:

NNNNSSaaaaaaaaaaaaaaaa(yy) = national energy savings in year ya during the analysis period (2020-2049) 

(quads),

AA AAbb bb(yy) = base case annual national energy consumption at the power plant for all lamps

in year y (quads),

AA AA ssss(yy) = standards case annual national energy consumption at the power plant for all 

lamps in year y (quads), and

RF = rebound rate factor, given by 1- rebound rate (see appendix 10D).

The shipments analysis characterizes the GSL market by analyzing shipments of various lamp

options within lamp categories. As described in chapter 9 of this preliminary TSD, lamp 

categories were developed to subdive the broad lumen range contained in the integrated lowlumen product class. The four lamp categories in the integrated low-lumen product class are 

based on the lumen ranges developed for general service incandescent lamps in EISA 2007,

1

modified for the product class definitions used in this preliminary analysis. The integrated highlumen and non-intgrated product class each contain one lamp category. The lamp options within 

each lamp category are based on the representative units described in chapters 5 and 8 of this 

preliminary TSD.In each CSC, only lamp options that meet or exceed the corresponding CSL are 

assumed to be shipped during the analysis period. DOE computed the AEC in year yy during the 

analysis period as follows:

AA AA( ) = ��SSSSSS KK ( ) × UU ( )� × SSSS( )

Eq. 10.2

Where:

SSSSSS KK (yy) = the installed stock in year yy of lamp option ll (number of units),

UU (yy) = the annual unit energy consumption of lamp option l in year y, as described in 

section 10.2.3.2 (kWh), and

SSSS(yy) = time variable site-to-power-plant conversion factor that converts site electricity use 

(kWh) to primary energy consumed at the power plant (quads/kWh).

a Note that the time variable y is a discrete variable representing any year between 2020-2099 and is not continuous. 

For quantities that depend on y, the notation ff(yy) is used, instead of ff , to avoid confusion with other subscripts.

10-3

 
During the stock attrition period (2050-2099) DOE used a different method to calculate

annual energy savings to account for the longer lifetimes of LED GSLs compared to CFLs. If 

CFLs comprise a larger fraction of the stock at the end of the analysis period in the base case 

compared to the standards case, when the shorter-lived CFLs are retired their contribution to the 

total analyzed energy consumption will be zero thereafter, but the longer-lived LEDs will 

continue contributing to the total energy consumption energy, thus reducing the apparent amount 

of energy saved in the standards case. Therefore, for each lamp category, DOE calculated the 

stock-weighted per-lamp average energy savings in 2049 (Eq. 10.3) and applied it to all lamps 

within that lamp category remaining in the stock after 2049 in the standards case to calculate the 

annual NES during the stock attrition period (Eq. 10.4). The average energy savings in each lamp 

category is given by the following formula:

����cc( ) = ∑ [SSSSSS ,cc,bb bb( ) × UU ]

∑ SSSSSS .cc,bb bb

− ∑ [SSSSSS ,cc, ssss( ) × UU ]

∑ SSSSSS ,cc, ssss

Eq. 10.3

Where:

����

cc(yy) = the stock weighted average energy savings per lamp in lamp category c, in year y, 

(kWh) and

yy = end year of the shipments analysis (2049),

SSSSSS KK ,cc,bb bb(yy) = stock of lamp option l in lamp category c, in the base case in year y

(number of units),

SSSSSS KK ,cc, ssss = stock of lamp option l in lamp category c, in the standards case in year y

number of units), and

UU = unit energy consumption of lamp option l accounting for controls, defined in Eq. 

10.11 below (kWh/year).

The NES in a given lamp category during the stock attrition period is then computed as follows:

NNNNSScc,aa aaaa aaaaaa( ) = ����cc( ) × SSSSSS KKcc, ssss( ) × SSSS( )

Eq. 10.4

Where:

NNNNSScc,aa aaaa aaaaaa(yy) = the national energy savings in year y during the stock attrition period 

(2050-2099) (quads),

����

cc(yy ) = the average energy savings per lamp in lamp category c,in the last year of the 

analysis period, 2049, defined in Eq. 10.3, (kWh/unit),

SSSSSS KKcc, ssss(yy) = is the stock of lamps in lamp category c, in year y in the stock attrition 

period (number of units), and

SSSS(yy) = time variable site-to-power plant conversion factor that converts site electricity use 

(kWh) to primary energy consumed at the power plant (quad/kWh).

The annual NES during the stock attrition period is the sum over all lamp categories:

10-4
NNNNSSaa aaaa aaaaaa( ) = �NNNNSScc,aa aaaa aaaaaa( )

cc

Eq. 10.5

Where:

all variables are as previously defined.

The cumulative national energy savings is given by the sum over the annual NES in the 

analysis and stock attrition periods:

NNNNSScccccc = � NNNNSSaaaaaaaaaaaaaaaa( ) + � NNNNSSaa aaaa aaaaaa( )

22222222

=22222222

22222222

=22222222

Eq. 10.6

Positive values of NES correspond to a net energy savings following standards implementationb.

10.2.2 Full-Fuel-Cycle Energy Savings 

DOE has historically presented the NES computed based on the primary energy savings

at the power plant, as described in the previous section. Per DOE’s 2011 Statement of Policy for 

Adopting Full Fuel Cycle Analyses, DOE now uses full-fuel-cycle (FFC) measures of energy use 

and emissions in its energy conservation standards analyses.3 In addition to the primary energy 

used at the power plant to supply electricity to the site of use and account for transmission and 

distribution losses, the FFC analysis also accounts for energy consumed up-stream of the power 

plant in extracting, processing, and transporting or distributing the primary fuels to the power 

plant, as described in appendix 10B of this preliminary TSD.

As shown in Eq. 10.7, the FFC national energy savings (NNNN FFFFFF) were obtained by 

multiplying the primary energy savings (Eq. 10.1during the 30 year analysis period and Eq. 10.5

during the stock attrition period) by the FFC multiplier computed for the same year, μ(y):

NNNN ( ) = NNNNSSpp ( ) × RRRR × μμ( )

Eq. 10.7

Where:

μμ(yy) = the FFC multiplier in year y (for details, see appendix 10B of this preliminary TSD),

NNNNSSpp pp (yy) = the energy saving in year y given by Eq. 10.1 during the analysis period 

(2020-2049) and Eq. 10.53 during the stock attrition period (2050-2099) 

and

RRRR = rebound factor.

b Following the example of the 2011 fluorescent lamp ballast final rule and for reasons given therein, DOE is 

assuming that the effects of heating, ventilating, and air conditioning (HVAC) interactions on NES are negligible.

10-5

 
The cumulative FFC energy savings are calculated by summing the annual savings from 

2020 through 2099:

NNNN ,cccccc = �NNNN ( )

Eq. 10.8

10.2.3 National Energy Savings Inputs

As described in the preceding sections, the following inputs were used for calculating the

national energy savings:

• shipments and stock projections,

• average unit energy consumption (UEC),

• site-to-power-plant conversion factor (SSSS),

• primary energy to full fuel cycle multiplier for each year of the analysis (μ), and

• rebound rate factor (RF).

These inputs are discussed further in the following sections.

10.2.3.1 Shipments and Stock

The shipments model, described in chapter 9 of this preliminary TSD, calculated the 

shipments of GSLs and market share distributions among product classes and lamp options for 

different candidate standards cases in each year of the 30-year shipments analysis period (2020

through 2049). Based on that analysis, the model developed a projection of the installed stock of 

GSLs shipped through 2049 that are affected by the rulemaking. 

10.2.3.2 Average Unit Energy Consumption

DOE calculated the average annual UEC for each lamp option by multiplying the average 

lamp power consumption by the sector-dependent average annual hours of use for that lamp, as 

shown in Eq. 10.9 below.

UU = WW × �

11

Eq. 10.9

Where:

UU = the annual UEC of lamp option l (kWh),

WW = the rated wattage of lamp option l (W), and

uu� = the average annual hours of use for the sector being considered (hours), as presented in 

chapter 7 of this TSD.

10-6
Ingrowth of controls

In the NIA DOE considered the effects of lighting controls (including manual dimmers 

and automated control systems) on GSL energy use. For the commercial sector DOE used the 

method developed for the proposed amended energy conservation standards for general service 

fluorescent lamps (GSFL) and incandescent reflector lamps (IRLs),

4 and assumed that lighting 

controls are installed on an increasing fraction of lamps in the commercial sector as a result of 

updated building codes as described in appendix 10C of this preliminary TSD. To assess the 

impact that controls have on energy savings DOE also performed an alternative analysis that 

assumed the percentage of controls in the commercial sector remains fixed at its 2014 level 

throughout the analysis period.

To account for controls in the residential sector, DOE assumed a fixed fraction of lamps 

are installed in sockets with controls. In the residential sector only, DOE also assumed that in 

addition to controlled sockets, there was an increase in the number of LED GSLs with integrated 

wireless receivers that allow them to be controlled remotely, and which can be installed in 

standard sockets: so-called smart lamps. DOE assumed that the incursion of smart lamps 

followed a Bass adoption curve, discussed below.

Bass adoption curves are commonly used to predict the growth in market share for new 

products over time:

5,6

MM ( ) = MMSS mm

11 − −(pp+qq)

11 + �

qq

pp� −(pp+qq)

Eq. 10.10

Where:

MM (tt) = market share at time t,

MMSS mm = maximum market share,

tt = time since the product was introduced to the market (yr),

pp = the coefficient of external influence, and

qq = the coefficient of internal influence.

The coefficients of internal and external influence were derived from projections of LED 

incursion into general lighting markets7 (see chapter 9 of this preliminary TSD). In its reference 

analysis DOE assumed that at the end of the analysis period smart lamps comprise 50 percent of 

the LED GSL shipments in the residential sector. DOE also performed alternative analyses in 

which the fraction of smart lamp shipments in the residential sector is zero or 100 percent of the 

shipments in the residential sector at the end of the analysis period.

Effects of controls and smart lamps on UEC

In both the commercial and residential sector DOE assumed that all lamps under controls, 

including smart lamps, reduce their UEC by a fixed fraction of 30 percent based on a metaanalysis performed by Williams et al.

8 In addition to energy savings realized from smart lamps, 

10-7
DOE considered the possibility of standby losses associated with smart lamps. In its reference 

scenario, DOE assumed zero standby power for smart lamps. DOE additionally performed an 

alternative scenario assuming 1W of standby power for all smart lamps.

The unit energy consumption of lamps installed on any type of lighting control system, 

including any standby power draw, was computed using the following formula (where 8760 is 

the number of hours in a year):

UU ( ) = UU × �11 − ffcc ( ) × ff � +

WW ss ss , × (888888 − � )

11

Eq. 10.11

Where:

UU (yy) = weighted average annual energy consumption (kWh) of lamp option l,

UU = annual unit energy consumption (kWh) of lamp option l, operating under full power 

for the average number of hours of use per year, computed using Eq. 10.9,

ffcc (yy) = the fraction of lamps estimated to be operating under lighting controls in year y, 

and

ff eeee = a parameter describing the effect of lighting controls on energy consumption, taken 

to be 0.3, 

WW ss ss , = the assumed standby power, if any, of lamp option l (W), and

all other variables as previously defined.

10.2.3.3 Site-to-Power Plant Conversion Factor

To estimate the energy used at the power plant to supply the electricity used on-site by 

GSLs, DOE multiplied the site energy consumption, UU (yy), by a lighting specific site-topower-plant conversion factor,

c which accounts for average losses associated with the 

generation, transmission, and distribution of electricity from the fleet of U.S. power plants to the 

point of use. DOE used annual site-to-power-plant conversion factors based on the version of the 

National Energy Modeling System (NEMS) that corresponds to the Energy Information 

Administration’s Annual Energy Outlook 2014 (AEO2014).

2 The factor takes into account the 

time of use distribution for lighting end uses and changes over time in response to projected 

changes in generation sources (the types of power plants projected to provide electricity to the 

country). Figure 10.2.1 shows how the site-to-power plant conversion factor is expected to 

change during the NES and NPV analysis period. 

c In previous rulemakings the site-to-power-plant conversion factor has been referred to as the site-to-source 

conversion factor. The terminology is modified here to clarify that the analysis only accounts for the energy used at 

the power plants, but not energy used upstream of the power plants to provide that service. The latter is incorporated 

in the full-fuel-cycle analysis.

10-8

 
Figure 10.2.1 Site-to-Power Plant Conversion Factor for Electricity

10.2.3.4 Primary Energy to Full-Fuel-Cycle Multipliers

For this analysis, DOE calculated FFC energy savings using a methodology described in 

appendix 10B. As discussed previously, the FFC energy savings are obtained by multiplying the 

primary energy savings at the power plant by the FFC multiplier (Eq. 10.7). The estimated FFC 

multiplier (μ) is nearly constant, ranging between 1.044 and 1.047 from 2020 to 2099.

10.2.3.5 Rebound Rate Factor

DOE generally accounts for the direct rebound effect in its estimates of the NES. For this 

preliminary analysis DOE used the same rebound assumptions developed for the 2014 GSFLIRL notice of proposed rulemaking,

4 which are described in appendix 10D of this preliminary 

TSD. In the reference scenario, the rebound rate is zero for both the commercial and residential 

sectors, and DOE additionally performed two sensitivity analyses on the rebound rate. The 

rebound rates for all scenarios are summarized in Table 10.2.1 below.

10-9
Table 10.2.1 Rebound Rate Scenarios for GSLs

Rebound Scenario

Commercial 

Rebound 

Rate

Residential 

Rebound 

Rate

None 0% 0%

Low 1% 8.5%

High 15% 15%

10.3 NATIONAL NET PRESENT VALUE

10.3.1 Definition

The NPV is the difference between the present value of savings (PVS) in operating cost 

resulting from the use of more efficient appliances under the standard and the present value of

changes in total installed costs (PVC) of those appliances. The NPV is described by the 

following equation: 

NN NN = −

Eq. 10.12

Where:

PP = present value of savings in operating costs (including costs for energy, repair, and 

maintenance) from all lamps shipped during the analysis period (2014$); and 

PP = present value of the change in total installed cost (including costs for equipment, 

installation, and disposal in 2014$) from of all lamps shipped during the analysis 

period (2014$). 

Under this definition, reductions in operating costs contribute positively to the NPV, 

while increases in total installed costs contribute negatively to the NPV. Notably, because LED 

GSLs have substantially longer lifetimes than the baseline CFL considered in this analysis, it is 

possible that some CSCs may yield a reduction in total installed costs, which would contribute 

positively to the NPV.

DOE determined the PVS and PVC according to the following equations:

10-10
= � ( ) × DD ( )

Eq. 10.13

= � EE( ) × DD ( )

Eq. 10.14

Where:

(yy) = total annual operating cost savings realized by the affected stock in year y,

(2014$),

EE(yy) = total annual equipment cost increment for shipments in year y, relative to the base 

case (2014$), and

DD (yy) = discount factor in each year (defined in section 10.3.2.3).

DOE calculated PVC and PVS for all lamps projected to be shipped from 2020 to 2049, 

the duration of the shipments analysis period. To account for all energy savings that accrue over 

the full lifetime of lamps shipped near the end of the analysis period, it was necessary to consider 

energy consumption and cash flows through 2099. The contributions to PVC and PVS for each 

year were discounted to 2014. The following sections describe how DOE derives the variables in 

Eq. 10.13 and Eq. 10.14.

10.3.2 Net Present Value Inputs

The inputs to DOE’s calculation of the NPV of costs and savings for the nation are:

• the total annual installed cost (TIC) of equipment shipped in each year of the analysis, in 

the base case and the standards cases,

• the total annual operating cost (TOC) for the affected stock in the base case and the 

standards cases, and

• the discount factor (DF).

The computation of these inputs from the outputs of upstream analyses is detailed in the 

following sections.

10.3.2.1 Total Annual Installed Cost Increment

DOE calculated the total annual change in equipment cost of using more efficient lamps

in the standards cases relative to the base case as the difference between the TIC in the standards 

case and the base case:

10-11
EE( ) = ss ( ) − bb bb( )

Eq. 10.15

Where:

EE(yy) = the total annual increment in equipment cost in the standards case, relative to the 

base case, in year y (2014$),

ssss(yy) = the total installed cost of equipment shipped in year y in the standards case

(2014$), and

bb bb(yy) = the total installed cost of equipment shipped in year y in the base case (2014$).

As discussed previously, the annual equipment cost increment can be negative in the case of 

GSLs, owing to the longer lifetimes of LED GSLs relative to the baseline CFL lamp option.

The installed cost of a GSL is the purchase price plus any installation and disposal costs. 

For this preliminary analysis DOE assumed the installation costs for all lamps is zero and that 

only CFLs incur a disposal cost. As described in chapter 8 of this preliminary TSD, DOE 

assumes that only consumers in the commercial sector pay a disposal cost for CFLs. Based on 

research also described in chapter 8, the per-lamp disposal cost for a CFL in the commercial 

sector is assumed to be one dollar, and 10-percent of CFL consumers pay the disposal cost. To 

take into account that disposal costs are paid at the end of the life of a lamp, DOE discounts the 

disposal costs by the average lifetime of a CFL before adding it to the initial costs. The total 

installed cost is given by:

( ) = � × (pp ( ) + DD × ff )

Eq. 10.16

Where:

ss (yy) = total shipments of lamp option l in year y (number of units),

pp (yy) = purchase price of lamp option l in year y, including any price trend corrections

(2014$/unit),

DD = disposal costs, for CFLs in the commercial sector only, discounted by the average 

lifetime of a CFL (2014$/unit), and

ff = fraction of lamps that pay a disposal cost.

The total installed costs are calculated for the years 2020 to 2049, with all shipments 

assumed to be zero after 2049 (the final year of the analysis period).

10.3.2.2 Total Annual Operating Cost Savings

DOE expresses savings in operating costs as cost reductions associated with the lower 

energy consumption of products shipped in the standards case compared to the base case.

Similarly to the NES, DOE calculated the annual operating cost savings (OCS) for GSLs in two 

parts, for the analysis period (2020-2049) and the stock attrition period (2050-2099). During the 

10-12
analysis period the annual OCS is the difference between the TOC in the standards case and the 

base case.

SS ss ( ) = bb bb( ) − ssss( )

Eq. 10.17

Where:

SS h (yy) = the total operating cost saving of the affected stock in year y between 2020 and 

2049 (2014$), 

bb bb(yy) = the total operating cost of the stock in year y between 2020 and 2049 in the 

base case (2014$), and 

ssss(yy) = the total operating cost of the stock in year y between 2020 and 2049 in the 

standards case (2014$).

The only component of annual operating cost for GSLs is the cost of electricity 

consumption. DOE calculated the total annual operating costs based on national average 

electricity prices. DOE used the reference-case, sector-specific electricity price projections from 

AEO2014 to establish all electricity prices. As AEO2014 only projects prices through 2040, 

electricity prices in later years were extrapolated based on the 2030 through 2040 sector-specific 

trends, up through 2060, after which prices were assumed to remain constant.

DOE calculated annual TOC during the 30 year analysis period for GSLs by summing 

over the operating costs of all lamp options in the stock, according to the following expression:

( ) = pp ( ) × �[SSSSSS ( ) × UU ( )]

Eq. 10.18

Where:

ppEE(yy)= the price of electricity, in year y, as forecasted in the AEO2014 reference 

scenario (2014$/kWh),

SSSSSS (yy) = the stock of lamp option l in year y (number of units), and

UU (yy) = the average unit energy consumption of lamp option l in year y, as 

computed using Eq. 10.11(kWh/unit).

During the stock attrition period the annual OCS is given by:

SSaa aaaa ( ) = pp ( ) ∗ �����cc

cc

( ) ∗ SSSSSSSSKKcc( )

Eq. 10.19

Where:

����

cc(yy ) = is the average energy savings per lamp in lamp category c, defined in Eq. 10.3, 

SSSSSS KKcc = the stock of all lamps in lamp category c, and

all other variables as previously defined.

10-13
The cumulative OCS for a given standard is then calculated as:

SScccccc = � SS ss ( ) + � SSaa aaaa aaaaaa( )

=22222222

=22222222

=22222222

=22222222

Eq. 10.20

Where 

all variables are as previously defined.

As stated previously, DOE used the forecast of national-average commercial and 

residential electricity prices for its analysis in the commercial and residential sectors, 

respectively. To understand the importance of uncertainty in these projections, DOE performed 

sensitivity analyses using the high- and low-economic growth scenarios from AEO2014 to 

establish electricity prices. Figure 10.3.1 shows annual electricity price projections used as inputs 

for the high-, reference-, and low-economic growth scenarios, for all sectors. Note that there is 

not a consistent relationship over time between the economic growth scenario and its impact on 

electricity prices. For example, in the early years of the analysis period, the low-economic 

growth scenario in the residential sector results in higher electricity prices than the high growth 

scenario. The opposite is true in later years. 

Figure 10.3.1 Annual Electricity Prices by Sector (2014$)

As discussed in section 10.2.3.5, DOE has included in this analysis scenarios that include 

various assumptions about rebound to adjust its estimates of NES. In principle, the rebound 

effect also affects the energy costs to consumers in the standards case. However, the take-back in 

10-14
energy consumption associated with the rebound effect provides consumers with increased value 

(e.g., improved lighting service). As described in the 2014 residential furnace fan final rule 

TSD,

9 DOE believes that, if it were able to monetize the increased value to consumers of the 

rebound effect, this value would be similar in value to the foregone energy savings. Therefore, 

the economic impacts on consumers with or without the rebound effect are the same, so DOE 

does not adjust operating cost savings in the NIA based on rebound.

10.3.2.3 Discount Factor

DOE multiplies monetary values in future years by a discount factor to determine the 

present value. The DF is described by the equation:

DD = 11

(11 + )( − pp)

Eq. 10.21

Where:

r = discount rate, 

y = year of the future monetary value (savings or expenditure), and 

yP = year for which the present value is being determined.

DOE estimates NPV using both a 3-percent and a 7-percent real discount rate, in 

accordance with the Office of Management and Budget’s guidance to Federal agencies on the 

development of regulatory analysis, particularly section E therein: Identifying and Measuring 

Benefits and Costs. DOE defines the present year for this preliminary analysis as 2014.

10.4 RESULTS

This section summarizes the NES and NPV modeling results for the different candidate

standards cases, as well as the results of the alternative scenarios.

10.4.1 National Energy Savings Results

The annual FFC NES is presented in Figure 10.4.1 for all product classes at all CSCs. 

The cumulative site, power plant and FFC NES are given in Table 10.4.1,Table 10.4.2, and Table 

10.4.3, respectively.

The lack of energy savings for the non-integrated product class is a result of the available 

lamp options in that product class. There is one lamp option at the baseline (CSL 0) and two 

lamp options at CSL 1, a lamp with the same energy consumption as the baseline lamp but 

producing more light, and a lamp with reduced energy consumption. As described in chapter 9 of 

this preliminary TSD, DOE assumed the reduced wattage option is a niche product. Accordingly, 

DOE assumed that consumers using the reduced wattage lamps will continue to do so under a 

standard, while consumers using the full wattage lamp will continue to purchase full wattage

lamps under a standard. These consumers will not realize any energy savings, but they will have 

an increase in the lighting service (in terms of lumens per square foot) from the more efficacious 

lamps. The effects on the NPV are discussed in section 10.4.2 below.

10-15
Figure 10.4.1 Annual FFC NES for Product Classes at All CSCs

Table 10.4.1 Cumulative Site National Energy Savings for All Product Classes and CSCs

in TWh

CSC

Integrated

Low Lumen Non-Integrated

(<2000lm)

High Lumen 

(> 2000lm)

1 0.27 1.35 0.00

2 34.93 2.58

3 35.33

4 36.18

5 49.52

*See text for discussion of the NES for the non-integrated product class.

Table 10.4.2 Cumulative Power Plant National Energy Savings for All Product Classes 

and CSCs in Quads

CSC

Integrated

Low Lumen Non-Integrated

(<2000lm)

High Lumen 

(> 2000lm)

1 0.00 0.01 0.00

2 0.32 0.02

3 0.32

4 0.33

5 0.45

10-16
Table 10.4.3 Cumulative Full Fuel Cycle National Energy Savings for All Product Classes 

and CSCs in Quads

CSC

Integrated

Low Lumen Non-Integrated

(<2000lm)

High Lumen 

(> 2000lm)

1 0.00 0.01 0.00

2 0.34 0.02

3 0.34

4 0.35

5 0.47

10.4.2 Net Present Value Results

Annual NPV at 3 and 7-percent discount rates for all product classes and CSCs are 

presented in Figure 10.4.2 and Figure 10.4.3 respectively. The fluctuations that occur are due to 

the CSL 1, full wattage lamp option in the non-integrated product class. This lamp has a much 

longer lifetime than the baseline lamp (17,000 hours compared to 10,000 hours), therefore when 

the standard takes effect there is a large influx of longer lived lamps that are more likely to be 

replaced at the same time, causing ‘ringing’ in the NPV as new lamp purchases are made at 

regular intervals (the average lamp lifetime). This effect decreases over time.

Figure 10.4.2 Annual NPV at 3% for All Product Classes at All CSCs

10-17
Figure 10.4.3 Annual NPV at 7% for All Product Classes at All CSCs

The net present value for all product classes at all CSCs is given in Table 10.4.4 and 

Table 10.4.5 for 3 and 7 percent, respectively. The TIC at 3 and 7 percent are given in Table 

10.4.6 and Table 10.4.7. It should be noted that for integrated low-lumen lamps and nonintegrated lamps the TIC is negative. The decrease in TIC is a result of a longer lamp lifetime for

the more efficient lamps in these two product classes. This necessitates fewer lamp replacements, 

and hence lowers the shipments in that product class. The savings from reduced purchases 

outweigh the increases in per-lamp cost for the CSCs considered in this preliminary analysis; this 

makes it possible to have a positive NPV, even, as in the case of the non-integrated product class, 

with zero NPV. The OCS at 3 and 7 percent are given in Table 10.4.8 and Table 10.4.9 below.

Table 10.4.4 Cumulative Net Present Value at 3% for All Product Classes and CSCs in 

Billion 2014$

CSC

Integrated

Low Lumen Non-Integrated

(<2000lm)

High Lumen 

(> 2000lm)

1 0.02 0.04 1.95

2 1.21 0.09

3 1.44

4 1.90

5 2.52

10-18
Table 10.4.5 Cumulative Net Present Value at 7% for All Product Classes and CSCs in 

Billion 2014$

CSC

Integrated

Low Lumen Non-Integrated

(<2000lm)

High Lumen 

(> 2000lm)

1 0.02 0.02 0.96

2 0.54 0.04

3 0.67

4 0.96

5 1.28

Table 10.4.6 Cumulative Total Installed Cost Increment at 3% for All Product Classes 

and CSCs in Billion 2014$

CSC

Integrated

Low Lumen Non-Integrated

(<2000lm)

High Lumen 

(> 2000lm)

1 -0.02 0.01 -1.95

2 -0.33 0.02

3 -0.55

4 -1.01

5 -1.28

Table 10.4.7 Cumulative Total Installed Cost Increment at 7% for All Product Classes 

and CSCs in Billion 2014$

CSC

Integrated

Low Lumen Non-Integrated

(<2000lm)

High Lumen 

(> 2000lm)

1 -0.01 0.01 -0.96

2 -0.03 0.01

3 -0.17

4 -0.45

5 -0.60

10-19
Table 10.4.8 Cumulative Operating Cost Savings at 3% for All Product Classes and CSCs 

in Billion 2014$

CSC

Integrated

Low Lumen Non-Integrated

(<2000lm)

High Lumen 

(> 2000lm)

1 0.01 0.05 0.00

2 0.88 0.11

3 0.89

4 0.89

5 1.24

Table 10.4.9 Cumulative Operating Cost Savings at 7% for All Product Classes and CSCs 

in Billion 2014$

CSC

Integrated

Low Lumen Non-Integrated

(<2000lm)

High Lumen 

(> 2000lm)

1 0.00 0.03 0.00

2 0.50 0.06

3 0.51

4 0.51

5 0.68

10.4.3 Alternative Analyses Results

10.4.3.1 Overview

Table 10.4.10 lists the alternative scenarios analyzed in the NIA; scenario options 

indicated in bold are used in the reference scenario. Complete descriptions of the alternative 

scenarios not described previously are given in appendix 8B of this TSD.

10-20
Table 10.4.10 Alternative Scenarios Analyzed

Scenario 

Name Scenario Description

Alternative

Scenario Options 

Analyzed

Analyses 

Impacted by 

Scenario

Reference DOE’s best estimate of the national 

impacts of a GSL standard 

Reference option 

indicated in bold 

below

All (Best 

Estimate)

AEO growth AEO economic growth scenario for 

electricity prices

Low

NIA only

Reference

High

Controls Commercial sector controls growth 

rate, described in appendix 10C, 

Reference

Fixed

Rebound

Rebound rate associated with energy 

savings from lighting end uses (see 

appendix 10D of this TSD for more 

details).

No

Low

High

Smart lamp 

incursion

The maximum market share of smart 

lamp shipments at the end of the 

analysis period (applies to the 

residential sector only).

0%

50%

100%

Smart lamps 

standby 

power

Standby power associated with all 

smart lamps (applies to residential 

sector only).

0W

1W

Integrated 

LED 

incursion

Incursion of LED luminaires into the 

market for traditional GSL 

luminaires at the end of the analysis 

period (see chapter 9 of this TSD)

0%

Shipments and

NIA

15%

50%

Lamp Service 

Lifetime

Parameter assumed to be the driver 

for lamp replacements, see appendix 

8E of this TSD.

Rated

RenovationDriven

EarlyReplacement

Learning Rate

Learning rates used to develop lamp

price trends, as described in chapter 

9 of this TSD.

None 

CFL

Technology 

Rare Earth

Cost

Price scenario for rare earth 

minerals, applies to CFLs only (see 

appendix 8D of this TSD).

Constant

High

10-21
10.4.3.2 Alternative Analyses: National Energy Savings Results

Table 10.4.11, Table 10.4.12 and Table 10.4.13 present the cumulative full fuel cycle NES

for the alternative analyses in the integrated low-lumen, integrated high-lumen and nonintegrated product classes respectively. For each candidate standards case, the scenario result for 

the alternative analyses should be compared to the reference scenario to determine the impact. 

Table 10.4.11 Integrated Low-Lumen Alternative Analyses Full Fuel Cycle National Energy 

Savings in Quads

Scenario 

Name Alternatives CSC 1 CSC 2 CSC 3 CSC 4 CSC 5

Reference - 0.00 0.34 0.34 0.35 0.47

AEO 

growth

Low 0.00 0.34 0.34 0.35 0.47

High 0.00 0.34 0.34 0.35 0.47

Controls Fixed 0.00 0.34 0.35 0.36 0.49

Rebound

Low 0.00 0.31 0.32 0.32 0.44

High 0.00 0.29 0.29 0.30 0.40

Smart lamp 

incursion

0% 0.00 0.27 0.28 0.29 0.43

100% 0.00 0.40 0.40 0.41 0.52

Smart lamp

standby 1W 0.00 0.14 0.14 0.15 0.28

Integrated 

LED 

incursion

0% 0.00 0.36 0.37 0.38 0.52

50% 0.00 0.27 0.27 0.28 0.37

Lamp 

Service 

Lifetime

Rated 0.00 0.37 0.37 0.38 0.54

Innovation 0.01 0.70 0.71 0.71 0.82

Learning 

Rate

None 0.01 0.61 0.64 0.71 0.83

Technology 0.00 0.25 0.25 0.26 0.38

High Rare 

Earth High 0.00 0.33 0.34 0.34 0.47

10-22
Table 10.4.12 Integrated High-Lumen Alternative Analyses Full Fuel Cycle National Energy 

Savings in Quads

Scenario 

Name Alternatives CSC 1 CSC 2

Reference - 0.01 0.02

AEO 

growth

Low 0.01 0.02

High 0.01 0.02

Controls Fixed 0.01 0.03

Rebound

Low 0.01 0.02

High 0.01 0.02

Smart lamp 

incursion

0% 0.01 0.02

100% 0.01 0.02

Smart lamp 

standby 1W 0.01 0.02

Integrated 

LED 

incursion

0% 0.01 0.03

50% 0.01 0.02

Lamp 

Service 

Lifetime

Rated 0.01 0.03

Innovation 0.01 0.02

Learning 

Rate

None 0.01 0.02

Technology 0.01 0.02

High Rare 

Earth High 0.01 0.02

10-23
Table 10.4.13 Non-Integrated Alternative Analyses Full Fuel Cycle National Energy Savings in 

Quads

Scenario 

Name Alternatives CSC 1

Reference - 0.00

AEO 

growth

Low 0.00

High 0.00

Controls Fixed 0.00

Rebound

Low 0.00

High 0.00

Smart lamp 

incursion

0% 0.00

100% 0.00

Smart lamp 

standby 1W 0.00

Integrated 

LED 

incursion

0% 0.00

50% 0.00

Lamp 

Service 

Lifetime

Rated 0.00

Innovation 0.00

Learning 

Rate

None 0.00

Technology 0.00

High Rare 

Earth High 0.00

10.4.3.3 Alternative Analyses: Net Present Value Results

This section presents the cumulative NPV for the alternative scenarios at 3 and 7-percent. Table 

10.4.14 and Table 10.4.15 present results for the Integrated Low-Lumen product class, Table 

10.4.16 and Table 10.4.17 present results for the Integrated High-Lumen product class, and

Table 10.4.18 and Table 10.4.19 present results for the Non-Integrated product class.

10-24
Table 10.4.14 Integrated Low-Lumen Alternative Analyses Net Present Value at 3% in 2014$ 

Scenario 

Name Alternatives CSC 1 CSC 2 CSC 3 CSC 4 CSC 5

Reference - 0.02 1.21 1.44 1.90 2.52

AEO 

growth

Low 0.02 1.20 1.42 1.89 2.50

High 0.02 1.23 1.46 1.92 2.55

Controls Fixed 0.02 1.21 1.44 1.90 2.52

Rebound

Low 0.02 1.21 1.44 1.90 2.52

High 0.02 1.21 1.44 1.90 2.52

Smart lamp 

incursion

0% 0.02 1.17 1.39 1.86 2.49

100% 0.02 1.26 1.48 1.94 2.56

Smart lamp 

standby 1W 0.02 1.07 1.29 1.76 2.38

Integrated 

LED 

incursion

0% 0.03 1.35 1.58 2.08 2.77

50% 0.02 0.91 1.10 1.51 1.98

Lamp 

Service 

Lifetime

Rated 0.02 1.26 1.42 1.75 2.29

Innovation 0.03 -2.03 -1.61 -0.70 0.21

Learning 

Rate

None 0.06 -2.15 -1.11 0.44 1.48

Technology 0.02 1.40 1.50 1.71 2.24

High Rare 

Earth High 0.03 1.22 1.44 1.91 2.53

10-25
Table 10.4.15 Integrated Low-Lumen Alternative Analyses Net Present Value at 7% in 2014$

Scenario 

Name Alternatives CSC 1 CSC 2 CSC 3 CSC 4 CSC 5

Reference - 0.02 0.54 0.67 0.96 1.28

AEO 

growth

Low 0.02 0.53 0.67 0.95 1.27

High 0.02 0.55 0.68 0.96 1.29

Controls Fixed 0.02 0.54 0.67 0.96 1.28

Rebound

Low 0.02 0.54 0.67 0.96 1.28

High 0.02 0.54 0.67 0.96 1.28

Smart lamp 

incursion

0% 0.02 0.52 0.65 0.94 1.26

100% 0.02 0.56 0.69 0.97 1.29

Smart lamp

standby 1W 0.02 0.48 0.61 0.89 1.22

Integrated 

LED 

incursion

0% 0.02 0.60 0.74 1.04 1.39

50% 0.01 0.39 0.51 0.76 1.02

Lamp 

Service 

Lifetime

Rated 0.01 0.56 0.67 0.88 1.17

Innovation 0.02 -1.23 -0.99 -0.48 -0.01

Learning 

Rate

None 0.04 -1.71 -1.14 -0.30 0.25

Technology 0.01 0.78 0.84 0.98 1.25

High Rare 

Earth High 0.02 0.55 0.68 0.96 1.28

10-26
Table 10.4.16 Integrated High-Lumen Alternative Analyses Net Present Value at 3% in 2014$

Scenario 

Name Alternatives CSC 1 CSC 2

Reference - 0.04 0.09

AEO 

growth

Low 0.04 0.09

High 0.04 0.09

Controls Fixed 0.04 0.09

Rebound

Low 0.04 0.09

High 0.04 0.09

Smart lamp 

incursion

0% 0.04 0.09

100% 0.04 0.09

Smart lamp 

standby 1W 0.04 0.09

Integrated 

LED 

incursion

0% 0.05 0.10

50% 0.03 0.07

Lamp 

Service 

Lifetime

Rated 0.04 0.11

Innovation 0.04 0.06

Learning 

Rate

None 0.05 0.14

Technology 0.04 0.09

High Rare 

Earth High 0.04 0.09

10-27
Table 10.4.17 Integrated High-Lumen Alternative Analyses Net Present Value at 7% in 2014$

Scenario 

Name Alternatives CSC 1 CSC 2

Reference - 0.02 0.04

AEO 

growth

Low 0.02 0.04

High 0.02 0.04

Controls Fixed 0.02 0.04

Rebound

Low 0.02 0.04

High 0.02 0.04

Smart lamp 

incursion

0% 0.02 0.04

100% 0.02 0.05

Smart lamp 

standby 1W 0.02 0.04

Integrated 

LED 

incursion

0% 0.02 0.05

50% 0.02 0.04

Lamp 

Service 

Lifetime

Rated 0.01 0.03

Innovation 0.02 0.03

Learning 

Rate

None 0.02 0.07

Technology 0.01 0.02

High Rare 

Earth High 0.02 0.04

10-28
Table 10.4.18 Non-Integrated Alternative Analyses Net Present Value at 3% in 2014$

Scenario 

Name Alternatives CSC 1

Reference - 1.95

AEO 

growth

Low 1.95

High 1.95

Controls Fixed 1.95

Rebound

Low 1.95

High 1.95

Smart lamp 

incursion

0% 1.95

100% 1.95

Smart lamp 

standby 1W 1.95

Integrated 

LED 

incursion

0% 2.18

50% 1.51

Lamp 

Service 

Lifetime

Rated 1.96

Innovation 1.91

Learning 

Rate

None 2.38

Technology 1.96

High Rare 

Earth High 1.96

10-29
Table 10.4.19 Non-Integrated Alternative Analyses Net Present Value at 7% in 2014$

Scenario 

Name Alternatives CSC 1

Reference - 0.96

AEO 

growth

Low 0.96

High 0.96

Controls Fixed 0.96

Rebound

Low 0.96

High 0.96

Smart lamp 

incursion

0% 0.96

100% 0.96

Smart lamp 

standby 1W 0.96

Integrated 

LED 

incursion

0% 1.06

50% 0.78

Lamp 

Service 

Lifetime

Rated 0.97

Innovation 0.95

Learning 

Rate

None 1.16

Technology 0.97

High Rare 

Earth High 0.97

10-30
REFERENCES

1. Energy Independence and Security Act of 2007. 42 U.S. Code 152 § 17001.

2. Energy Information Administration. Annual Energy Outlook 2014 with Projections to

2040. 2014. Washington, D.C. http://www.eia.gov/forecasts/aeo/pdf/0383(2014).pdf.

3. Federal Register, Volume 76, Number 160, August 18, 2011, Pages 51245-51868. 2011.

U.S. Office of the Federal Register.

http://digital.library.unt.edu/ark:/67531/metadc52337/m1/44/.

4. U.S. Department of Energy- Office of Energy Efficiency and Renewable Energy. Notice

of Proposed Rulemaking Technical Support Document Energy Conservation Program for

Consumer Products and Certain Commercial and Industrial Equipment: General Service

Fluorescent Lamps and Incandescent Reflector Lamps. 2014. Washington, D.C.

http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/24.

5. Bass, F. M. A New Product Growth Model for Consumer Durables. Management

Science. 1969. 15(5): pp. 215–227.

6. Elliott, D. B., D. M. Anderson, D. B. Belzer, K. A. Cort, J. A. Dirks, and D. J. Hostick.

Methodological Framework for Analysis of Buildings-Related Programs: The GPRA

Metrics Effort. 2004. U.S. Department of Energy: Richland, Washington. Report No.

PNNL-14697. http://library.cee1.org/sites/default/files/library/1977/1162.pdf.

7. Navigant Consulting, Inc. Energy Savings Forecast of Solid-State Lighting in General

Illumination Applications. 2014. U.S. Department of Energy. Report No. DOE/EE-1133.

http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/energysavingsforecast14.pdf.

8. Williams, A., B. Atkinson, K. Garbesi, E. Page, and F. Rubinstein. Lighting Controls in

Commercial Buildings. LEUKOS. 2012. 8(3): pp. 161–180.

9. U.S. Department of Energy-Office of Energy Efficiency and Renewable Energy. Energy

Conservation Program for Consumer Products: Final Rule Technical Support Document:

Energy Efficiency Standards for Consumer Products and Commercial and Industrial

Equipment: Residential Furnace Fans. June 2014.

http://www.regulations.gov/#!documentDetail;D=EERE-2010-BT-STD-0011-0111.

10-31 
CHAPTER 11. CONSUMER SUBGROUP ANALYSIS

TABLE OF CONTENTS

11.1 METHODOLOGY ........................................................................................................ 11-1

11-i 
CHAPTER 11. CONSUMER SUBGROUP ANALYSIS

11.1 METHODOLOGY

The consumer subgroup analysis evaluates impacts on any identifiable groups or 

consumers who may be disproportionately affected by a national energy conservation standard. 

DOE will conduct this analysis as one of the analyses for the notice of proposed rulemaking 

(NOPR). DOE will accomplish this, in part, by analyzing the life-cycle costs (LCCs) and 

payback periods (PBPs) for those customers that fall into any identifiable groups. DOE plans to 

evaluate variations in regional energy prices, variations in energy use, and variations in 

installation costs that might affect the net present value of a standard to customer subpopulations. 

To the extent possible, DOE will obtain estimates of each input parameter’s variability and will 

consider this variability in its calculation of consumer impacts. 

DOE will determine the impact on consumer subgroups using the LCC Spreadsheet 

Model, which allows for different data inputs. The standard LCC analysis (described in chapter 

8) focuses on the customers that use general service lamps. DOE can use the LCC Spreadsheet 

Model to analyze the LCC for any subgroup by sampling only that subgroup. (Chapter 8 explains 

in detail the inputs to the model used in determining LCC and PBPs.) In the case of general 

service lamps, one subgroup DOE plans to consider is low-income households. 

DOE will be especially sensitive to increases in the purchase price of the product due to 

amended standards, to avoid negative impacts on identifiable population groups that may not be 

able to afford significant increases in product price. 

11-1 
12-i 

CHAPTER 12. PRELIMINARY MANUFACTURER IMPACT ANALYSIS

TABLE OF CONTENTS

12.1 INTRODUCTION ......................................................................................................... 12-1

12.2 METHODOLOGY ........................................................................................................ 12-1

12.2.1 Phase I: Industry Profile..................................................................................... 12-2

12.2.2 Phase II: Industry Cash Flow Analysis and Interview Guide ............................ 12-2

12.2.2.1 Industry Cash Flow Analysis ........................................................... 12-2

12.2.2.2 Interview Guide ............................................................................... 12-2

12.2.3 Phase III: Subgroup Analysis............................................................................. 12-2

12.2.3.1 Manufacturer Interviews .................................................................. 12-3

12.2.3.2 Revised Industry Cash Flow Analysis ............................................. 12-3

12.2.3.3 Manufacturer Subgroup Analysis .................................................... 12-3

12.2.3.4 Competitive Impact Assessment ...................................................... 12-4

12.2.3.5 Manufacturing Capacity Impact ...................................................... 12-4

12.2.3.6 Employment Impact ......................................................................... 12-4

12.2.3.7 Cumulative Regulatory Burden ....................................................... 12-4

12.3 INDUSTRY OVERVIEW ............................................................................................. 12-4

12.3.1 Industry Cost Structure ...................................................................................... 12-5

12.3.2 Inventory Levels ................................................................................................ 12-6

12.4 INTERVIEW TOPICS AND PRELIMINARY FINDINGS ......................................... 12-6

12.4.1 Market Shares and Industry Consolidation ........................................................ 12-7

12.4.2 Production and Product Mix .............................................................................. 12-7

12.4.2.1 Impact on Product Mix .................................................................... 12-8

12.4.2.2 Product Utility .................................................................................. 12-8

12.4.3 Conversion Costs ............................................................................................... 12-8

12.4.4 Cumulative Regulatory Burden ......................................................................... 12-8

12.5 OVERALL KEY ISSUES ............................................................................................. 12-9

12.5.1 Testing Burden ................................................................................................... 12-9

12.5.2 Impacts of Technology Neutral Standards ......................................................... 12-9
12-ii

LIST OF TABLES

Table 12.3.1 Electric Lamp Bulb and Part Industry Employment and Earnings.......................12-5

Table 12.3.2 Electric Lamp Bulb and Part Industry Material and Payroll Costs.......................12-6

Table 12.3.3 Electric Lamp Bulb and Part Industry End-of-Year Inventory.............................12-6
12-1 

CHAPTER 12. PRELIMINARY MANUFACTURER IMPACT ANALYSIS

12.1 INTRODUCTION

The purpose of the manufacturer impact analysis (MIA) is to identify and quantify the 

likely impacts of energy conservation standards on manufacturers. The Process Rulea

 provides 

guidance for conducting this analysis with input from manufacturers and other interested parties. 

The U.S. Department of Energy (DOE) will apply this methodology to its evaluation of energy 

conservation standards for general service lamps (GSLs). DOE will consider financial impacts 

and a wide range of quantitative and qualitative industry impacts. For example, a particular 

standard level could require changes to manufacturing practices for GSLs. DOE will identify and 

analyze these impacts through interviews with manufacturers and other interested parties during 

the notice of proposed rulemaking (NOPR) stage of the analysis.

DOE announced changes to the MIA format through a report issued to Congress in

January 2006 (as required by section 141 of the Energy Policy Act of 2005 [EPAct 2005]), 

entitled “Energy Conservation Standards Activities.”b Previously, DOE did not report any MIA 

results before the NOPR phase; however, under this new format, DOE collects, evaluates, and 

reports preliminary information and data in the preliminary analysis. Such information includes 

market data, key issues, product mixes, conversion costs, foreign competition, market shares, 

industry consolidation, and cumulative regulatory burden information. DOE solicits this 

information during the preliminary manufacturer interviews and reports the results in this chapter 

of the preliminary technical support document (TSD). Appendix 12A includes a copy of the 

interview guide that DOE distributed to manufacturers. 

12.2 METHODOLOGY

DOE conducts the MIA in three phases. In Phase I, DOE creates an industry profile to 

characterize the industry and conducts preliminary manufacturer interviews to identify important 

issues that require consideration. Section 12.3 of this chapter presents initial findings of the 

Phase I analysis. In Phase II, DOE prepares an industry cash flow model and an interview 

questionnaire to guide subsequent discussions with manufacturers. In Phase III, DOE interviews 

manufacturers and assesses the impacts of energy conservation standards both quantitatively and 

qualitatively. DOE assesses industry and subgroup cash flow impacts and the industry net 

present value (INPV) using the Government Regulatory Impact Model (GRIM). DOE then 

assesses impacts on competition, manufacturing capacity, employment, and regulatory burden, 

based on manufacturer interviews and discussions. The NOPR will present the results of the 

Phase II and III analyses.

a On July 15, 1996, the Department of Energy published a Process Improvement Rule establishing procedures,

interpretations, and policies to guide the Department in the consideration of new or revised appliance 

efficiency standards (Procedures for Consideration of New or Revised Energy Conservation Standards for 

Consumer Products). 61 FR 36974. 

b This report is available on the DOE website at: 

www1.eere.energy.gov/buildings/appliance_standards/pdfs/congressional_report_013106.pdf.
12-2

12.2.1 Phase I: Industry Profile

In Phase I of the MIA, DOE collects pertinent qualitative and quantitative financial and 

market information. This includes research and development (R&D) expenses; selling, general,

and administrative (SG&A) expenses; capital expenditures; property, plant, and equipment 

expenses; tax rate; and depreciation rate for GSL manufacturers, as well as wages, employment, 

and industry costs for GSLs. Sources of information include reports published by industry 

groups, trade journals, the U.S. Census Bureau, and Securities Exchange Commission (SEC) 

10-K filings. In addition, DOE relies on information from its market and technology assessment, 

engineering analysis, life-cycle cost analysis, and consumer price analysis, as well as feedback 

from preliminary manufacturer interviews, to characterize the GSL manufacturing industries.

12.2.2 Phase II: Industry Cash Flow Analysis and Interview Guide

Phase II activities occur after publication of the preliminary analysis. In Phase II, DOE 

performs a preliminary industry cash-flow analysis and prepares a questionnaire, or interview 

guide, for interviewing manufacturers.

12.2.2.1 Industry Cash Flow Analysis

DOE uses the GRIM to analyze the financial impacts of energy conservation standards.

The implementation of these standards may require additional investment, raise production costs, 

and/or affect revenue through higher prices and lower shipments. The GRIM uses several factors 

to determine a series of annual cash flows for the years leading up to the effective date of energy 

conservation standards and for several years after implementation. These factors include annual 

expected revenues, costs of sales, SG&A costs, taxes, and capital expenditures. Inputs to the 

GRIM include financial information, manufacturing costs, shipment forecasts, and price 

forecasts developed in other analyses. Financial information is developed based on publicly 

available data and confidentially submitted manufacturer information. DOE compares the GRIM 

results for the standards case at each trial standard level (TSL) against the results for the base

case, in which no energy conservation standards are in place. The financial impact of energy 

conservation standards is the difference between the two sets of discounted annual cash flows.

12.2.2.2 Interview Guide

DOE conducts interviews with manufacturers to gather information on the effects of

energy conservation standards could have on revenues and finances, direct employment, capital 

assets, and industry competitiveness. These interviews take place during Phase III of the MIA.

Before the interviews, DOE distributes an interview guide that will help identify the impacts of 

energy conservation standards on individual manufacturers or subgroups of manufacturers within 

the GSL industry. The interview guide covers production costs; shipment projections; market 

share; product mix; conversion costs; markups and profitability; assessment of the impact on 

competition; manufacturing capacity; and other relevant topics.

12.2.3 Phase III: Subgroup Analysis

Phase III activities occur after publication of the preliminary analysis. These activities 

include manufacturer interviews; revision of the industry cash flow analysis; a manufacturer 
12-3

subgroup analysis; an assessment of the impacts on industry competition, manufacturing 

capacity, direct employment, and the cumulative regulatory burden; and other qualitative 

impacts.

12.2.3.1 Manufacturer Interviews

DOE supplements the information gathered in Phase I and the cash-flow analysis 

performed in Phase II with information gathered through interviews with manufacturers during 

Phase III. The interview process plays a key role in the MIA because it provides an opportunity 

for interested parties to express their views privately on important issues.

DOE conducts detailed interviews with manufacturers to gain insight into the potential 

impacts of energy conservation standards on sales, direct employment, capital assets, and 

industry competitiveness. Interviews are scheduled well in advance to provide every opportunity 

for key individuals to be available for comment. Although a written response to the questionnaire 

is acceptable, DOE prefers interactive interviews, which help clarify responses and provide the 

opportunity to identify additional issues.

A non-disclosure agreement allows DOE to consider confidential or sensitive information

in the decision-making process. Confidential information, however, is not made available in the 

public record. At most, sensitive or confidential information may be aggregated and presented in 

industry-wide representations.

12.2.3.2 Revised Industry Cash Flow Analysis

During the interviews, DOE requests information about profitability impacts, necessary 

plant changes, and other manufacturing impacts. Following the interviews, DOE revises the 

preliminary GRIM prepared in Phase II based on the feedback it receives during interviews.

12.2.3.3 Manufacturer Subgroup Analysis

The use of average cost assumptions to develop an industry cash flow estimate does not 

adequately assess differential impacts of energy conservation standards among manufacturer 

subgroups. Smaller manufacturers, niche players, and manufacturers exhibiting a cost structure 

that differs largely from the industry average could be more negatively affected. Ideally, DOE 

would consider the impact on every firm individually; however, it typically uses the results of the 

industry characterization to group manufacturers with similar characteristics. During the 

interviews, DOE discusses the potential subgroups that have been identified for the analysis.

DOE asks manufacturers and other interested parties to suggest what subgroups or characteristics 

are most appropriate for the analysis.

One common subgroup identified is small business manufacturers. Should DOE 

determine this rulemaking impacts any small business manufacturers, DOE will conduct a 

regulatory flexibility analysis pursuant to the Regulatory Flexibility Act. (5 U.S.C. 601 et seq.)
12-4

12.2.3.4 Competitive Impact Assessment

Section 342 (6)(B)(i)(V) of the Energy Policy Act of 1992 (EPAct 1992) directs DOE to 

consider any lessening of competition likely to result from the imposition of standards. EPAct

1992 further directs the U.S. Attorney General to determine any likely impacts resulting from a

decrease in competition. DOE gathers firm-specific financial information and attempts to 

determine the impact of standards on industry competition. The results of this effort are reported 

in the competitive impact assessment. The competitive impact assessment is based on 

manufacturer cost data and information collected from the manufacturer interviews. The 

interviews focus on assessing asymmetrical cost increases to some manufacturers, the potential 

increase in business risks from an increased proportion of fixed costs, and potential barriers to 

market entry (e.g., proprietary technologies). The competitive impact analysis also focuses on 

assessing any differential impacts to smaller manufacturers.

12.2.3.5 Manufacturing Capacity Impact

One of the significant outcomes of energy conservation standards can be the 

obsolescence of existing manufacturing assets, including tooling and other investments. The 

manufacturer interview guide has a series of questions to help identify impacts on manufacturing 

capacity, specifically capacity utilization and plant location decisions in North America with and 

without energy conservation standards; the ability of manufacturers to upgrade or remodel 

existing facilities to accommodate the new requirements; the nature and value of any stranded 

assets; and estimates for any one-time restructuring or other charges, where applicable.

12.2.3.6 Employment Impact

The impact of energy conservation standards on employment is an important 

consideration in the rulemaking process. Manufacturer interviews play a significant role in 

assessing how domestic employment patterns might be impacted by energy conservation 

standards. The interview guide contains a series of questions that are designed to explore current 

employment trends in the GSL industry and to solicit manufacturers’ views on changes in 

employment patterns that may result from increased standard levels. These questions focus on 

current employment levels at production facilities, expected future employment levels with and 

without energy conservation standards, differences in workforce skills, and employee retraining.

12.2.3.7 Cumulative Regulatory Burden

DOE seeks to mitigate the overlapping effects on manufacturers of energy conservation 

standards and other regulatory actions affecting the same products or companies. DOE analyzes

and considers the impact of multiple, product-specific regulatory actions on manufacturers.

12.3 INDUSTRY OVERVIEW

The following section summarizes publicly available industry data.
12-5

12.3.1 Industry Cost Structure

DOE developed the GSL industry cost structure from the U.S. Census Bureau Annual 

Survey of Manufacturers: Statistics for Industry Groups and Industries with data from 2003 to 

2011. GSL manufacturing is classified under the North American Industry Classification System 

(NAICS) code 335110 (Electric Lamp Bulb and Part Manufacturing).

DOE is unaware of any publicly available industry-wide cost data specific to only 

manufacturers of GSLs. DOE presents the data below as a broader industry proxy for the GSL 

industry.

Table 12.3.1 presents the electric lamp bulb and part employment levels and payroll from 

2003 to 2011. The statistics show a 34.0 percent decrease in the number of production workers 

from 2003 to 2011, with a corresponding 7.0 percent decrease in the overall industry payroll

from 2003 to 2011.

Table 12.3.1 Electric Lamp Bulb and Part Industry Employment and Earnings

Year Production Workers All Employees Payroll for All Employees

thousand current year U.S. dollars

2003 8,972.00 10,790.00 481,524.00

2004 8,022.00 9,867.00 512,514.00

2005 7,604.00 9,289.00 495,057.00

2006 6,669.00 8,192.00 449,809.00

2007 7,477.00 9,358.00 447,983.00

2008 7,884.00 10,152.00 462,196.00

2009 6,419.00 7,612.00 415,900.00

2010 6,100.00 7,698.00 464,118.00

2011 5,919.00 7,605.00 447,752.00

U.S. Census Bureau. Annual Survey of Manufacturers: 2005 and Earlier Years; Annual Survey of 

Manufacturers: 2006 and 2005; Annual Survey of Manufacturers: 2008 and 2007; Annual Survey of 

Manufacturers: 2009 and 2008; Annual Survey of Manufacturers: 2010 and 2009; and Annual Survey of 

Manufacturers: 2011 and 2010

Table 12.3.2 presents the costs of electric lamp bulb and part materials and industry 

payroll as a percentage of shipment value from 2003 to 2011. The cost of materials has 

significantly increased by 45.1 percent as a percentage of shipment value from 2003 to 2011. 

While the cost of payroll for production workers has significantly decreased by 25.3 percent, the 

cost of payroll for all employees has moderately increased by 10.8 percent as a percentage of 

shipment value from 2003 to 2011.
12-6

Table 12.3.2 Electric Lamp Bulb and Part Industry Material and Payroll Costs

Year Cost of Materials

percent of shipment value

Cost of Payroll for 

Production Workers

percent of shipment value

Cost of Payroll for All 

Employees

percent of shipment value

2003 36.0 14.8 18.5

2004 35.8 15.4 20.4

2005 42.6 15.6 20.8

2006 44.6 15.7 20.9

2007 44.7 14.7 20.3

2008 47.2 13.3 21.4

2009 49.0 16.3 21.4

2010 53.4 14.7 21.9

2011 52.2 13.2 20.5

U.S. Census Bureau. Annual Survey of Manufacturers: 2005 and Earlier Years; Annual Survey of 

Manufacturers: 2006 and 2005; Annual Survey of Manufacturers: 2008 and 2007; Annual Survey of 

Manufacturers: 2009 and 2008; Annual Survey of Manufacturers: 2010 and 2009; and Annual Survey of 

Manufacturers: 2011 and 2010

12.3.2 Inventory Levels

Table 12.3.3 shows the year-end inventory for the electric lamp bulb and part industry 

obtained from the U.S. Census Bureau Annual Survey of Manufacturer: Statistics for Industry 

Groups and Industries with data from 2003 to 2011. The industry’s end-of-year inventory from 

2003 to 2011 increased 20.7 percent when expressed in U.S. dollars, and grew significantly by 

43.8 percent when expressed as a percentage of shipment value.

Table 12.3.3 Electric Lamp Bulb and Part Industry End-of-Year Inventory

Year End-of-Year Inventory

thousand current year U.S. dollars

End-of-Year Inventory

percent of shipment value

2003 212,207 8.2%

2004 226,482 9.0%

2005 235,934 9.9%

2006 227,013 10.5%

2007 254,351 11.5%

2008 258,409 12.0%

2009 178,773 9.2%

2010 203,758 9.6%

2011 256,221 11.7%

U.S. Census Bureau. Annual Survey of Manufacturers: 2005 and Earlier Years; Annual Survey of 

Manufacturers: 2006 and 2005; Annual Survey of Manufacturers: 2008 and 2007; Annual Survey of 

Manufacturers: 2009 and 2008; and Annual Survey of Manufacturers: 2010 and 2009; and Annual Survey 

of Manufacturers: 2010 and 2011.

12.4 INTERVIEW TOPICS AND PRELIMINARY FINDINGS

The following section summarizes information gathered during interviews held in the 

second and third quarters of 2014 for the preliminary MIA.
12-7

12.4.1 Market Shares and Industry Consolidation

Energy conservation standards can alter the competitive dynamics of the marketplace, 

prompting companies to enter the market, exit the market, or merge with other companies. The 

preliminary MIA interview questions asked manufacturers to share their perspectives on industry 

consolidation both in the absence of energy conservation standards and assuming standards at 

various efficacy levels. The interview questions focused on gathering information that assessed:

• disproportionate cost increases to some manufacturers;

• increased proportion of fixed costs potentially increasing business risks; and

• potential barriers to market entry (e.g., proprietary technologies).

The need to assess anti-competitive effects of energy conservation standards comes from 

the need to protect consumer interests. During the interviews, DOE solicited information to 

determine whether energy conservation standards could result in disproportionate economic or 

performance penalties for particular consumer or user subgroups. Manufacturers were also asked 

if energy conservation standards could result in products that will be more or less desirable to 

consumers due to changes in product functionality, utility, or other features.

Market Shares: DOE inquired about the current market share of manufacturers in the 

GSL industry and how those market shares might change due to the imposition of energy 

conservation standards. Manufacturers agreed in interviews that potential market share impacts 

would vary by product. Manufacturers expect that for less efficacious technologies, market 

shares will be unchanged. While shipments of less efficacious technologies and market size may 

decrease as a result of standards, manufacturers maintain that market shares will be unaffected as 

manufacturers do not hold significant design advantages over their competitors. For more 

efficacious technologies such as light-emitting diode (LED), manufacturers suggested that the 

market shares of industry leaders will increase as they can readily meet more stringent standards

whereas other manufacturers may have difficulty doing so.

Industry Consolidation: The GSL industry is mainly composed of a few large

manufacturers, but there are a handful of smaller manufacturers. As described in chapter 3 of this

TSD, four manufacturers hold the majority of the domestic market share of GSLs. The lighting 

divisions of most of these companies also manufacture other products, such as general service 

fluorescent lamps, high intensity discharge lamps and metal halide lamp fixtures.

All of the manufacturers interviewed agreed that there would be significant consolidation 

in the GSL industry in the absence of standards. As new and innovative GSL technology brings 

new entrants into the market, manufacturers agree that eventually these more specialized

newcomers could either merge together to increase product offerings and capabilities or be 

acquired by larger manufacturers. They also agreed that standards most likely would not lead to 

additional consolidation.

12.4.2 Production and Product Mix

DOE requested manufacturers’ feedback on what they perceived to be the possible 

impact of energy conservation standards on cash flow and profitability. For instance, the capital 
12-8

and product conversion outlays needed to upgrade or redesign products before they have reached 

the end of their useful life may result in reduced cash flow and stranded investments. Higher 

energy conservation standards could also result in higher per-unit costs that could cause 

consumers to shift to less expensive products.

12.4.2.1 Impact on Product Mix

Manufacturers believe that energy conservation standards could affect the product mix of 

GSLs depending on the efficacy levels selected for the standards. Some manufacturers stated 

they may exit less efficacious sectors of the GSL industry if standards require significant 

investment to be compliant.

12.4.2.2 Product Utility

A few manufacturers expressed concern that energy conservation standards might require 

changes in product functionality, utility, and other features that would make products less 

desirable to consumers. Manufacturers stated if efficacy standards were significantly more 

stringent, manufacturers might have to shorten the life of the lamps to meet higher efficacy 

levels. Manufacturers also expressed concern that stringent standards could lead to unplanned 

fixture renovations as some fixtures and ballasts may not be compatible with LEDs.

12.4.3 Conversion Costs

In some instances, manufacturers may be able to meet proposed standard levels by 

modifying existing products. In other cases, the necessary changes may entail a complete 

product-line redesign. In either case, more stringent energy conservation standards would cause 

manufacturers to incur one-time capital and product conversion costs. Capital conversion costs

are one-time investments in property, plant, and equipment. Product conversion costs include 

one-time investments in research, product development, testing, and marketing.

All manufacturers stated that the conversion costs associated with standards would 

depend on the efficacy level established by those standards. However, several manufacturers 

stated that testing, accreditation, and laboratory expenditures due to energy conservation 

standards for GSLs would account for a large portion of product conversion costs. Manufactures 

stated that they are unlikely to make investments in lower efficacious technologies such as 

compact fluorescent lamps (CFLs), and would most likely exit that sector of the GSL market if 

standards require significant investment. Manufacturers also noted that they could be forced to 

make investments in increasing their LED production capacity to meet heightened demand if

manufacturers reduce their product offerings as a result of standards or if lower efficacy products

are regulated out of the market.

12.4.4 Cumulative Regulatory Burden

While any one regulation may not impose a significant burden on manufacturers, the 

combined effects of several impending regulations may have serious consequences for individual 

manufacturers, groups of manufacturers, or entire industries. Assessing the impact of a single 

regulation may overlook this cumulative regulatory burden.
12-9

Expenditures associated with meeting other regulations are an important aspect of DOE’s 

consideration of the cumulative regulatory burden the industry faces. The manufacturer 

interviews helped DOE identify the level and timing of investments manufacturers are expecting 

to incur because of these regulations. Manufacturers were also asked under what circumstances 

they might be able to make expenditures related to regulations and energy conservation 

standards.

Several Federal, international, and state regulatory programs may affect the markets for 

GSLs. The market and technology assessment discusses some of the notable initiatives that 

characterize recent developments in the lighting market. See chapter 3 of this TSD for a list and 

description of the regulatory requirements DOE identified.

Several of the large GSL manufacturers also manufacture other lighting products that are 

regulated by other DOE efficiency standards, such as the fluorescent lamp ballast standards (76

FR 70548 [Nov. 14, 2011]) and the metal halide lamp fixture standards (79 FR 7746 [February 

10, 2014]) and the upcoming general service fluorescent lamps and incandescent reflector lamps 

update standard. Additionally, there are existing GSL standards implemented by the general 

service incandescent lamps standards (74 FR 12058 [March 23, 2009]).

12.5 OVERALL KEY ISSUES

One important aspect of the preliminary MIA is the opportunity it creates for DOE to 

identify key manufacturer issues early in the evaluation of energy conservation standards. During 

preliminary interviews, manufacturers identified two major areas of concern regarding GSL 

standards: (1) testing burden and (2) impacts of technology neutral standards.

12.5.1 Testing Burden

Several manufacturers expressed concern over the testing burden associated with GSL 

energy conservation standards. Manufacturers expressed concern regarding new testing 

requirements for LED lamps and expanded scope of CFLs to comply with GSL standards. 

Manufacturers stated that they would now need to spend capital that is already limited on testing 

and certifying already efficacious lamps to demonstrate compliance with GSL standards instead 

of on research and development that could result in increase of energy savings from these lamps. 

Additionally, manufacturers claimed that standards covering LED lamps could present a barrier 

to entry for small LED lamp manufacturers due to the increase in testing and certification 

requirements caused by GSL standards. Manufacturers claim this could result in a potential 

decrease of product innovation and energy-saving potential for LED lamps.

12.5.2 Impacts of Technology Neutral Standards

Manufacturers are concerned that technology neutral standards for GSLs could have a 

disproportionate effect on the range of technologies covered by standards. If GSL standards are 

set at the highest levels of efficacy, manufacturers are concerned that they may experience a loss 

of product differentiation among their lighting offerings. Manufacturers claim that as premium 

products become the baseline offering to consumers, previously offered advantages in lighting 

utility could be eliminated in an attempt to meet these higher standards.
12-10

Several manufacturers also stated they are concerned that GSL standards could be set at 

unattainable efficacy levels for CFLs. If CFLs are regulated out of the market it could force CFL 

manufacturers to either make significant investments in converting their production lines to other 

lighting technologies and cause them to incur a significant loss on the stranded assets associated 

with their existing CFL production or exit the GSL lighting market altogether. Lastly, 

manufacturers claim that setting GSL standards at efficacy levels that cannot be attained by 

CFLs would remove product utility from the market as consumers still value CFLs for certain 

applications and derive utility from these products.
CHAPTER 13. EMISSIONS ANALYSIS

TABLE OF CONTENTS

13.1 INTRODUCTION ......................................................................................................... 13-1

13.2 APPROACH .................................................................................................................. 13-1

13.3 AIR QUALITY REGULATIONS AND EMISSIONS IMPACTS............................... 13-1

REFERENCES .......................................................................................................................... 13-4

13-i
CHAPTER 13. EMISSIONS ANALYSIS

13.1 INTRODUCTION

The U.S. Department of Energy (DOE) conducts an emissions analysis for the notice of 

proposed rulemaking (NOPR) stage. In the emissions analysis, DOE estimates the reduction in 

power sector and site combustion emissions of carbon dioxide (CO2), nitrogen oxides (NOX), 

sulfur dioxide (SO2), mercury (Hg), methane (CH4) and nitrous oxide (N2O) from potential 

energy conservation standards for general service lamps. In addition, DOE estimates emissions 

impacts in production activities (extracting, processing, and transporting fuels) that provide the 

energy inputs to power plants and for site combustion. These are referred to as “upstream” 

emissions. Together, these emissions account for the full-fuel-cycle (FFC). In accordance with 

DOE’s FFC Statement of Policy (76 FR 51282 (August 18, 2011)), the FFC analysis includes 

impacts on emissions of methane and nitrous oxide, both of which are recognized as greenhouse 

gases.

13.2 APPROACH

DOE conducts the emissions analysis using emissions factors that are primarily derived 

from data in the latest version of the Energy Information Administration’s (EIA’s) Annual 

Energy Outlook (AEO), supplemented by data from other sources. EIA prepares the AEO using 

the National Energy Modeling System (NEMS).a Site emissions of CO2 and NOX are estimated 

using emissions intensity factors from a publication of the Environmental Protection Agency 

(EPA).

1 Combustion emissions of CH4 and N2O are estimated using emissions intensity factors 

published by the EPA GHG Emissions Factors Hub.b The FFC upstream emissions are estimated 

based on the methodology developed by Coughlin (2013).2 The upstream emissions include both 

emissions from fuel combustion during extraction, processing and transportation of fuel, and 

“fugitive” emissions (direct leakage to the atmosphere) of CH4 and CO2.

13.3 AIR QUALITY REGULATIONS AND EMISSIONS IMPACTS

Each annual version of NEMS incorporates the projected impacts of existing air quality 

regulations on emissions. The text below refers to AEO 2014, which generally represents current 

legislation and environmental regulations, including recent government actions, for which 

implementing regulations were available as of October 31, 2013. The NOPR will use emissions 

factors derived from the most current available AEO data.

SO2 emissions from affected electric generating units (EGUs) are subject to nationwide 

and regional emissions cap and trading programs. Title IV of the Clean Air Act sets an annual 

emissions cap on SO2 for affected EGUs in the 48 contiguous states and the District of Columbia 

a For more information about NEMS, please refer to the U.S. Department of Energy, Energy Information 

Administration documentation. A useful summary is National Energy Modeling System: An Overview 2009, 

DOE/EIA-0581 (October 2009), available at: http://www.eia.gov/oiaf/aeo/overview/. b http://www.epa.gov/climateleadership/inventory/ghg-emissions.html.

13-1

 
(D.C.). SO2 emissions from 28 eastern states and D.C. were also limited under the Clean Air 

Interstate Rule (CAIR), which created an allowance-based trading program that operates along 

with the Title IV program in those States and D.C. 70 FR 25162 (May 12, 2005). CAIR was 

remanded to EPA by the U.S. Court of Appeals for the District of Columbia Circuit (D.C. 

Circuit), but it remained in effect.c On July 6, 2011 EPA issued a replacement for CAIR, the 

Cross-State Air Pollution Rule (CSAPR). 76 FR 48208 (August 8, 2011). On August 21, 2012, 

the D.C. Circuit issued a decision to vacate CSAPR.d The court ordered EPA to continue 

administering CAIR. AEO 2014 assumes that CAIR remains a binding regulation through 2040.e

The attainment of emissions caps is typically flexible among EGUs and is enforced 

through the use of emissions allowances and tradable permits. Under existing EPA regulations, 

any excess SO2 emissions allowances resulting from the lower electricity demand caused by the 

adoption of an efficiency standard could be used to permit offsetting increases in SO2 emissions 

by any regulated EGU. In past rulemakings, DOE recognized that there was uncertainty about 

the effects of efficiency standards on SO2 emissions covered by the existing cap-and-trade 

system, but it concluded that no reductions in power sector emissions would occur for SO2 as a 

result of standards.

Beginning in 2016, however, SO2 emissions will fall as a result of the Mercury and Air 

Toxics Standards (MATS) for power plants. 77 FR 9304 (Feb. 16, 2012) In the final MATS rule, 

EPA established a standard for HCl as a surrogate for acid gas hazardous air pollutants (HAP), 

and also established a standard for SO2 (a non-HAP acid gas) as an alternative equivalent 

surrogate standard for acid gas HAP. The same controls are used to reduce HAP and non-HAP 

acid gas; thus, SO2 emissions will be reduced as a result of the control technologies installed on 

coal-fired power plants to comply with the MATS requirements for acid gas. AEO 2014 assumes 

that, in order to continue operating, coal plants must have either flue gas desulfurization or dry 

sorbent injection systems installed by 2016. Both technologies, which are used to reduce acid gas 

emissions, also reduce SO2 emissions. Under the MATS, emissions will be far below the cap that 

would be established by CSAPR, so it is unlikely that excess SO2 emissions allowances resulting 

from the lower electricity demand would be needed or used to permit offsetting increases in SO2

emissions by any regulated EGU. Therefore, DOE believes that efficiency standards will reduce 

SO2 emissions in 2016 and beyond.

c See North Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008); North Carolina v. EPA, 531 F.3d 896 (D.C. Cir. 

2008).

d See EME Homer City Generation, LP v. EPA, 696 F.3d 7, 38 (D.C. Cir. 2012). e On April 29, 2014, the U.S. Supreme Court reversed the judgment of the D.C. Circuit and remanded the case for 

further proceedings consistent with the Supreme Court's opinion. The Supreme Court held in part that EPA's 

methodology for quantifying emissions that must be eliminated in certain states due to their impacts in other 

downwind states was based on a permissible, workable, and equitable interpretation of the Clean Air Act provision 

that provides statutory authority for CSAPR. See EPA v. EME Homer City Generation, No 12-1182, slip op. at 32 

(U.S. April 29, 2014). Because DOE is using emissions factors based on AEO 2014, the analysis assumes that 

CAIR, not CSAPR, is the regulation in force. The difference between CAIR and CSAPR is not relevant for the 

purpose of DOE's analysis of SO2 emissions.

13-2

 
CSAPR established a cap on NOX emissions in eastern States and the District of 

Columbia. Energy conservation standards are expected to have little or no physical effect on 

these emissions in those States covered by CSAPR because excess NOX emissions allowances 

resulting from the lower electricity demand could be used to permit offsetting increases in NOX

emissions. However, standards would be expected to reduce NOX emissions in the States not 

affected by CSAPR. Therefore, DOE estimates NOX emissions reductions from potential 

standards in the States where emissions are not capped.

The MATS limit mercury emissions from power plants, but they do not include emissions 

caps and, as such, DOE’s energy conservation standards would likely reduce Hg emissions. For 

this rulemaking, DOE plans to estimate mercury emissions reductions using emissions factors 

based on AEO 2014, which incorporates the MATS.

Power plants may emit particulates from the smoke stack, which are known as direct 

particulate matter (PM) emissions. NEMS does not account for direct PM emissions from power 

plants. DOE is investigating the possibility of using other methods to estimate reduction in PM 

emissions due to standards. The great majority of ambient PM associated with power plants is in 

the form of secondary sulfates and nitrates, which are produced at a significant distance from 

power plants by complex atmospheric chemical reactions that often involve the gaseous 

emissions of power plants, mainly SO2 and NOX. The monetary benefits that DOE estimates for 

reductions in SO2 and NOX emissions resulting from standards are in fact primarily related to the 

health benefits of reduced ambient PM.

13-3
REFERENCES

1. U.S. Environmental Protection Agency. AP-42: Compilation of Air Pollutant Emissions 

Factors. 1998. Washington, D.C. http://www.epa.gov/ttn/chief/ap42/.

2. Coughlin, K. Projections of Full-Fuel-Cycle Energy and Emissions Metrics. 2013. 

Lawrence Berkeley National Laboratory. Report No. LBNL-6025E. 

http://ees.lbl.gov/sites/all/files/lbnl6025e_ffc.pdf.

13-4
CHAPTER 14. MONETIZATION OF EMISSIONS REDUCTION BENEFITS 

TABLE OF CONTENTS

14.1 INTRODUCTION ......................................................................................................... 14-1

14.2 APPROACH .................................................................................................................. 14-1

REFERENCES .......................................................................................................................... 14-2

14-i
CHAPTER 14. MONETIZATION OF EMISSIONS REDUCTION BENEFITS 

14.1 INTRODUCTION

As part of its assessment of energy conservation standards, the U.S. Department of 

Energy (DOE) considers the estimated monetary benefits likely to result from the reduced 

emissions of carbon dioxide (CO2) and nitrogen oxides (NOX) that are expected to result from 

the energy efficiency standards levels considered for general service lamps. To make this 

calculation, similar to the calculation of the net present value (NPV) of consumer benefit, DOE 

considers the reduced emissions expected to result over the lifetime of the equipment shipped in 

the projection period for each standard level.

14.2 APPROACH

To estimate the monetary value of benefits resulting from reduced emissions of CO2, 

DOE plans to use the most current Social Cost of Carbon (SCC) values developed and/or agreed 

to by an interagency process. The SCC is intended to be a monetary measure of the incremental 

damage resulting from greenhouse gas (GHG) emissions, including, but not limited to, net 

agricultural productivity loss, human health effects, property damage from sea level rise, and 

changes in ecosystem services. Any effort to quantify and to monetize the harms associated with 

climate change will raise serious questions of science, economics, and ethics. But with full 

regard for the limits of both quantification and monetization, the SCC can be used to provide 

estimates of the social benefits of reductions in GHG emissions. 

The Interagency Working Group on Social Cost of Carbon released an update of its 

previous report in 2013.1 The most recent estimates of the SCC in 2015, expressed in 2013$, are 

$12.0, $40.5, $62.4, and $119 per metric ton of CO2 avoided. For emissions reductions that occur 

in later years, these values grow in real terms over time. Additionally, the interagency group 

determined that a range of values from 7-percent to 23-percent should be used to adjust the 

global SCC to calculate domestic effects, although DOE will give preference to consideration of 

the global benefits of reducing CO2 emissions. To calculate a present value of the stream of 

monetary values, DOE will discount the values in each of the four cases using the discount rates 

that had been used to obtain the SCC values in each case.

DOE recognizes that scientific and economic knowledge continues to evolve rapidly as to 

the contribution of CO2 and other GHG to changes in the future global climate and the potential 

resulting damages to the world economy. Thus, these values are subject to change. 

DOE also estimates the potential monetary benefit of reduced NOX emissions resulting 

from the standard levels it considers. Estimates of monetary value for reducing NOX from 

stationary sources range from $476 to $4,893 per ton in 2013$.

2 DOE calculates monetary 

benefits using a medium value for NOX emissions of $2,684 per short ton (in 2013$), and real 

discount rates of 3-percent and 7-percent.

14-1
REFERENCES

1. Interagency Working Group on Social Cost of Carbon. Technical Update of the Social

Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866. 2013.

http://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-updatesocial-cost-of-carbon-for-regulator-impact-analysis.pdf.

2. U.S. Office of Management and Budget. 2006 Report to Congress on the Costs and

Benefits of Federal Regulations and Unfunded Mandates on State, Local, and Tribal

Entities. 2006. Washington, D.C.

http://www.whitehouse.gov/sites/default/files/omb/assets/omb/

inforeg/2006_cb/2006_cb_final_report.pdf.

14-2 
CHAPTER 15. UTILITY IMPACT ANALYSIS

TABLE OF CONTENTS

15.1 INTRODUCTION ......................................................................................................... 15-1

15.2 METHODOLOGY ........................................................................................................ 15-2

REFERENCES .......................................................................................................................... 15-5

15-i
CHAPTER 15. UTILITY IMPACT ANALYSIS

15.1 INTRODUCTION

In the utility impact analysis, the U.S. Department of Energy (DOE) analyzes the changes 

in electric installed capacity and power generation that result for each trial standard level (TSL). 

The utility impact analysis is based on output of the DOE/Energy Information 

Administration (EIA)’s National Energy Modeling System (NEMS).a NEMS is a public domain, 

multi-sectored, partial equilibrium model of the U.S. energy sector. Each year, DOE/EIA uses 

NEMS to produce an energy forecast for the United States, the Annual Energy Outlook (AEO). 

The EIA publishes a reference case, which incorporates all existing energy-related policies at the 

time of publication, and a variety of side cases which analyze the impact of different policies, 

energy price and market trends. As of 2014, DOE is using a new methodology based on results 

published for the Annual Energy Outlook 2014 (AEO 2014) Reference case and a set of side 

cases that implement a variety of efficiency-related policies.

2

The new approach retains key aspects of DOE’s previous methodology, and provides 

some improvements:

• The assumptions used in the AEO reference case and side cases are fully 

documented and receive detailed public scrutiny.

• NEMS is updated each year, with each edition of the AEO, to reflect changes in 

energy prices, supply trends, regulations, etc.

• The comprehensiveness of NEMS permits the modeling of interactions among 

the various energy supply and demand sectors. 

• Using EIA published side cases to estimate the utility impacts enhances the 

transparency of DOE’s analysis.

• The variability in impacts estimates from one edition of AEO to the next will be 

reduced under the new approach.

On the average, however, over the full analysis period, the results from the new approach 

are comparable to results from the old approach.

a For more information on NEMS, refer to the U.S. Department of Energy, Energy Information Administration 

documentation. A useful summary is National Energy Modeling System: An Overview.

1

15-1

 
15.2 METHODOLOGY

DOE estimates the marginal impacts of reduction in energy demand on the energy supply 

sector. In principle, marginal values should provide a better estimate of the actual impact of 

energy conservation standards. 

NEMS uses predicted growth in demand for each end use to build up a projection of the 

total electric system load growth. The system load shapes are converted internally to load 

duration curves, which are then used to estimate the most cost-effective additions to capacity. 

When electricity demand deviates from the AEO reference case, in general there are three interrelated effects: the annual generation in terawatt hours (TWh) from the stock of electric 

generating capacity changes, the total generation capacity itself in gigawatts (GW) may change, 

and the mix of capacity by fuel type may change.b Each of these effects can vary for different 

types of end use. The change in total generating capacity is sensitive to the degree to which the 

end-use is peak coincident, while the capacity mix is sensitive to the hourly load shape 

associated with the end use. Changes in generation by fuel type lead in turn to changes in total 

power sector emissions of sulfur dioxide (SO2), nitrogen oxides (NOX), mercury (Hg), and 

carbon dioxide (CO2).

DOE’s new approach examines a series of AEO side cases to estimate the relationship 

between demand reductions and the marginal energy, emissions and capacity changes. The 

assumptions for each side case are documented in Appendix E of the AEO.c The side cases, or 

scenarios, that incorporate significant changes to equipment efficiencies relative to the Reference 

case are: 

• 2013 Technology (leaves all technologies at 2013 efficiencies);

• Best Available Technology (highest efficiency irrespective of cost);

• High Technology (higher penetration rates for efficiency and demand management);

• Extended Policies (includes efficiency standards that are not in the reference).

Scenarios that incorporate policies that directly affect the power sector without changes 

in energy demand (for example, subsidies for renewables, or high fuel price assumptions) are not 

appropriate for this analysis. The methodology proceeds in seven steps:

1. Supply-side data on generation, capacity and emissions, and demand-side data on electricity 

use by sector and end-use, are extracted from each side case. The data are converted to 

differences relative to the AEO Reference case.

b The terawatt is equal to one trillion (1012) watts. The total power used by humans worldwide (about 16 TW in 

2006) is commonly measured in this unit. The gigawatt is equal to one billion (109

) watts or 1 gigawatt = 1000 

megawatts. This unit is often used for large power plants or power grids. c Appendix E of AEO 2014 is available at http://www.eia.gov/forecasts/aeo/section_appendices.cfm and 

http://www.eia.gov/forecasts/aeo/data_side_cases.cfm

15-2

 
2. The changes in electricity use on the demand-side data are allocated to one of three 

categories: on-peak, shoulder, and off-peak. These categories are used in the utility sector to 

correlate end-use consumption with supply types. For each of the end-uses that are modeled 

explicitly in NEMS, load shape information is used to identify the fraction of annual 

electricity use assigned to each category. On-peak hours are defined as 12:00 noon to 5:00 

p.m., June through September. Off-peak hours are nights and Sundays. All other hours are 

assigned to the shoulder period. 

3. For each year and each side case, the demand-side reductions to on-peak, off-peak and 

shoulder-period electricity use are matched on the supply-side to reductions in generation by 

fuel type. The fuel types are petroleum fuels, natural gas, renewables, nuclear and coal. The 

allocation is based on the following rules:

3.1. All petroleum-based generation is allocated to peak periods;

3.2. Natural gas generation is allocated to any remaining peak reduction; this is consistent 

with the fact that oil and gas steam units are used in NEMS to meet peak demand;

3.3. Base-load generation (nuclear and coal) is allocated proportionally to all periods;

3.4. The remaining generation of all types is allocated to the remaining off-peak and shoulder 

reductions proportionally.

4. The output of Step 3 defines fuel-share weights giving the fraction of energy demand in each 

load category that is met by each fuel type as a function of time. These are combined with the 

weights that define the load category shares by end-use to produce coefficients that allocate a 

marginal reduction in end-use electricity demand to each of the five fuel types.

5. A regression model is used to relate reductions in generation by fuel type to reductions in 

emissions of power sector pollutants. The model produces coefficients that define the change 

in total annual emissions of a given pollutant resulting from a unit change in total annual 

generation for each fuel type, as a function of time. These coefficients are combined with the 

weights calculated in Step 4 to produce coefficients that relate emissions changes to changes 

in end-use demand.

6. A regression model is used to relate reductions in generation by fuel type to reductions in 

installed capacity. The categories used for installed capacity are the same as for generation 

except for peak: NEMS uses two peak capacity types (combustion turbine/diesel and oil and 

gas steam) which are combined here into a single “peak” category. The model produces 

coefficients that define the change in total installed capacity of a given type resulting from a 

unit change in total annual generation for the corresponding fuel type. These coefficients are 

combined with the weights calculated in Step 4 to produce coefficients that relate installed 

capacity changes to changes in end-use demand, as a function of time.

7. The coefficient time-series for fuel share, pollutant emissions and capacity for the 

appropriate end use are multiplied by the stream of energy savings calculated in the NIA to 

produce estimates of the utility impacts.

15-3
This analysis does not take into account pumped storage, fuel cells, and distributed 

generation, as these generation types are not affected by the policy changes modeled in the EIA 

side cases. The methodology is described in more detail in K. Coughlin, “Utility Sector Impacts 

of Reduced Electricity Demand.”

3

15-4
REFERENCES

1. U.S. Department of Energy-Energy Information Administration. The National Energy

Modeling System: An Overview 2009. 2009. Report No. DOE/EIA-0581.

http://www.eia.gov/oiaf/aeo/overview/.

2. Energy Information Administration. Annual Energy Outlook 2014 with Projections to

2040. 2014. Washington, D.C. http://www.eia.gov/forecasts/aeo/pdf/0383(2014).pdf.

3. Coughlin, K. Utility Sector Impacts of Reduced Electricty Demand. Lawrence Berkeley

National Laboratory: Berkeley, CA. Forthcoming.

15-5 
CHAPTER 16. EMPLOYMENT IMPACT ANALYSIS

TABLE OF CONTENTS

16.1 INTRODUCTION ......................................................................................................... 16-1

16.2 METHODOLOGY ........................................................................................................ 16-1

REFERENCES .......................................................................................................................... 16-3

16-i
CHAPTER 16. EMPLOYMENT IMPACT ANALYSIS

16.1 INTRODUCTION

The U.S. Department of Energy’s (DOE’s) employment impact analysis estimates

indirect national job creation or job elimination resulting from possible new energy conservation 

standards, due to reallocation of the associated expenditures for purchasing and operating certain 

equipment. DOE conducts this analysis for the notice of proposed rulemaking (NOPR) stage 

where it estimates national impacts on major sectors of the U.S. economy, using publicly 

available data.

Energy conservation standards can impact employment both directly and indirectly. 

Direct employment impacts are changes in the number of employees at the plants that produce 

the covered equipment, along with the affiliated distribution and service companies, resulting 

from standards. DOE evaluates direct employment impacts in its manufacturer impact analysis, 

as described in chapter 12 of this Technical Support Document. The employment impact analysis 

described in this chapter covers indirect employment impacts which may result from 

expenditures shifting between goods (the substitution effect) and changes in income and overall 

expenditure levels (the income effect) that occur due to the implementation of standards. 

DOE expects new or amended energy conservation standards to decrease energy 

consumption and, therefore, reduce expenditures for energy. In turn, savings in energy 

expenditures may be redirected for new investment and other items. Notwithstanding, energy 

conservation standards may potentially increase the purchase price of equipment, including the 

retail price plus sales tax, and may increase installation costs.

Using an input-output model of the U.S. economy, the employment impact analysis seeks 

to estimate the year-to-year effect of these expenditure impacts on net national employment. 

DOE intends the employment impact analysis to quantify the indirect employment impacts of 

these expenditure changes.

16.2 METHODOLOGY

To investigate the and indirect employment impacts, DOE uses the Pacific Northwest 

National Laboratory’s (PNNL’s) “Impact of Sector Energy Technologies” (ImSET 3.1.1) 

model.1 PNNL developed ImSET, a spreadsheet model of the U.S. economy that focuses on 187

sectors most relevant to industrial, commercial, and residential building energy use, for DOE’s 

Office of Energy Efficiency and Renewable Energy. ImSET is a special-purpose version of the 

U.S. Benchmark National Input-Output (I-O) model, which has been designed to estimate the 

national employment and income effects of energy saving technologies that are deployed by 

DOE’s Office of Energy Efficiency and Renewable Energy. In comparison with the previous 

versions of the model used in earlier rulemakings, this version allows for more complete and 

automated analysis of the essential features of energy efficiency investments in buildings, 

industry, transportation, and the electric power sectors.

16-1
The ImSET software includes a computer-based I-O model with structural coefficients to 

characterize economic flows among the 187 sectors. ImSET’s national economic I-O structure is 

based on the 2002 Benchmark U.S. table, specially aggregated to 187 sectors.2

DOE intends to use the ImSet model to estimate changes in employment in the overall 

U.S. economy resulting from changes in expenditures in the various sectors of the economy. 

DOE has designed the employment impact analysis to estimate the year-to-year net national 

employment effect of these different expenditure flows.

16-2
REFERENCES

1. Roop, J. M., M. J. Scott, and R. W. Schultz. ImSET: Impact of Sector Energy

Technologies. 2005. Pacific Northwest National Laboratory: Richland, WA. http://

www.pnl.gov/main/publications/external/technical_reports/PNNL-15273.pdf.

2. Lawson, A. M., K. S. Bersani, M. Fahim-Nader, and J. Guo. Benchmark Input-Output

Accounts of the U. S. Economy, 1997. Survey of Current Business. 2002. 82 pp. 19–117.

16-3 
CHAPTER 17. REGULATORY IMPACT ANALYSIS

TABLE OF CONTENTS

17.1 INTRODUCTION ......................................................................................................... 17-1

17.2 METHODOLOGY ........................................................................................................ 17-1

LIST OF TABLES

Table 17.1.1 Alternatives to Standards............................................................................. 17-1

17-i
CHAPTER 17. REGULATORY IMPACT ANALYSIS

17.1 INTRODUCTION

For “economically significant regulatory actions,” Executive Order 12866 requires 

Federal agencies to provide “an assessment, including the underlying analysis, of costs and 

benefits of potentially effective and reasonably feasible alternatives to the planned regulation, 

identified by the agencies or the public (including improving the current regulation and 

reasonably viable non-regulatory actions), and an explanation why the planned regulatory action 

is preferable to the identified potential alternatives.” 58 FR 51735, 51741 (October 4, 1993). 

Accordingly, in the notice of proposed rulemaking (NOPR) stage, the U.S. Department of 

Energy (DOE) plans to analyze feasible alternatives that possibly could provide incentives for 

the same energy efficiency levels as the proposed standards for the equipment that are subject of 

the general service lamps rulemaking. In addition, DOE proposes to analyze five feasible policy 

alternatives to energy conservation standards for the equipment considered in this rulemaking. 

The policy alternatives are listed below in Table 17.1.1. DOE will evaluate each alternative in 

terms of its ability to achieve significant energy savings at a reasonable cost, and will compare 

the effectiveness of each alternative to the effectiveness of each candidate standard.

The technical support document (TSD) is prepared in support of DOE’s notice of 

proposed rulemaking and includes a complete quantitative analysis of each alternative, the 

methodology for which is briefly addressed below.

Table 17.1.1 Alternatives to Standards

No New Regulatory Action

Consumer Rebates

Consumer Tax Credits

Manufacturer Tax Credits

Voluntary Energy Efficiency Targets

Bulk Government Purchases

17.2 METHODOLOGY

DOE uses the national impact analysis (NIA) spreadsheet model to calculate the national 

energy savings and the net present value (NPV) corresponding to each alternative to proposed 

energy conservation standards. The NIA model is discussed in chapter 10 of the TSD. To 

compare each alternative quantitatively to the proposed energy conservation standards, DOE 

quantifies the effect of each alternative on the purchase and use of energy efficient equipment, 

such as general service lamps. DOE then creates an integrated model, built on the NIA model, in 

order to make the appropriate revisions to the inputs in the NIA models. Key inputs that DOE 

may revise are the market shares of equipment meeting the target efficiency levels, which 

correspond to the efficiency levels set for the mandatory standards at each trial standard level.

17-1
The following are the key measures of the impact of each alternative:

• National Energy Savings (NES), given in quadrillion Btus (quads), will describe the 

potential cumulative national primary energy to be saved over the lifetime of equipment 

purchased during the 30-year analysis period starting in the effective date of the policy.

a

• Net Present Value (NPV), will represent the value of net monetary savings from 

equipment purchased during the 30-year analysis period starting in the compliance date

of the policy. DOE calculates NPV as the difference between the present values of 

installed equipment cost and operating expenditures in the base case and the present 

values of those costs in each policy case. DOE then calculates operating expenses 

(including energy costs) for the life of equipment.

a The British thermal unit (Btu) is the amount of energy needed to cool or heat one pound of liquid water by one 

degree Fahrenheit at a constant pressure of one atmosphere.

17-2

 
APPENDIX AA. ACRONYMS AND ABBREVIATIONS

ACEEE American Counsel for an Energy-Efficient Economy

AEC Annual Energy Consumption

AEO Annual Energy Outlook

AFC Annualized first cost

AHS American Housing Survey

Al2O3 Aluminum oxide

ALA American Lighting Association

ANSI American National Standards Institute

ASAP Appliance Standard Awareness Project

BaO Barium oxide

BEF Ballast efficacy factor

BF Ballast factor

BLE Ballast luminous efficiency

BLS Bureau of Labor Statistics

BPAR Bulged parabolic aluminum reflector

BR Bulged reflector

CAIR Clean Air Interstate Rule

CA IOUs California Investor-Owned Utilities

CaO Calcium oxide

CAPM Capital asset pricing model

CAT Calcium tungstate

CBECS Commercial Buildings Energy Consumption Survey

CCE Certification, compliance, and enforcement

CCMS Compliance certification management system

CCR California Code of Regulations

CCT Correlated color temperature

CEE Consortium for Energy Efficiency

CEC California Energy Commission

CFL Compact fluorescent lamp

CFR Code of Federal Regulations

CLC Cape Light Compact

CMS Critical Materials Strategy

CO2 Carbon dioxide

CPUC California Public Utilities Commission

ComEd Commonwealth Edison

ConEd Consolidated Edison

CPI Consumer Price Index

CRI Color rendering index

CSAPR Cross-State Air Pollution Rule

CSC Candidate standard case

CSL Candidate standard level

CVD Chemical vapor deposition

DF Discount Factor

AA-1
DOE U.S. Department of Energy

ECI Equipment Cost Increment

ECS Energy conservation standards

EEI Edison Electric Institute

EGU Electric utility generating unit

EIA U.S. Energy Information Administration

EISA Energy Independence and Security Act

EL Efficacy level

EMI Electromagnetic interference

EPA U.S. Environmental Protection Agency

EPAct Energy Policy Act

EPCA Energy Policy and Conservation Act

ER Elliptical reflector

ERP Equity risk premium

ESR Effective series resistance

EU European Union

FEMP Federal Energy Management Program

FFC Full-fuel-cycle

FTC Federal Trade Commission

GaN Gallium nitride

GaP Gallium phosphide

GDP Gross domestic product

GE General Electric

GHG Greenhouse gas

GRIM Government Regulatory Impact Model

GSFL General service fluorescent lamp

GSIL General service incandescent lamp

GSL General service lamp

HAP Hazardous air pollutant

Hg Mercury

HID High-intensity discharge

HIR Halogen infrared reflector

HOU Hours of use

IEC International Electrotechnical Commission

IESNA Illuminating Engineering Society of North America

ImSET Impact of Sector Energy Technologies model

InGaN Indium gallium nitride

INPV Industry net present value

I-O Input-Output

IR Infrared

IRL Incandescent reflector lamp

IS Instant start

K Kelvin

kWh Kilowatt-hour

LAP Lanthanum phosphate

LBNL Lawrence Berkeley National Laboratory

AA-2
LCC Life-cycle cost

LED Light-emitting diode

LLMF Lamp lumen maintenance factor

LMC U.S. Lighting Market Characterization

Lm/W Lumens per watt

LSF Lamp survival factor

MATS Mercury and Air Toxics Standards

MBCFL Medium base compact fluorescent lamp

MECS Manufacturing Energy Consumption Survey

MEPs Minimum energy performance standards

MIA Manufacturer impact analysis

MOSFETs Metal-oxide-semiconductor field-effect transistors

MR Multifaceted reflector

ms Milliseconds 

MSB Medium screw base

MSP Manufacturer selling price

NAICS North American Industry Classification System

NEEA Northwest Energy Efficiency Alliance

NEEP Northeast Energy Efficiency Partnerships

NEMA National Electrical Manufacturers Association

NEMS National Energy Modeling System

NES National energy savings

NIA National impact analysis

NODA Notice of data availability

NOPM Notice of public meeting

NOPR Notice of proposed rulemaking

NOX Nitrogen oxides

NPV Net present value

NRCan Natural Resources Canada

NRDC Natural Resources Defense Council

OAL Office of Administrative Law

OCS Operating Cost Savings

OLED Organic light-emitting diode

OMB Office of Management and Budget

OSI OSRAM SYLVANIA

PAR Parabolic aluminized reflector

PBP Payback period

PC Phosphor converted

PFC Power factor correction

PG&E Pacific Gas and Electric

PM Particulate matter

PPI Producer Price Index

P.R. China People’s Republic of China

PS Programmed start

PVC Present Value of Costs

PVS Present Value of Savings

AA-3
R Reflector

R&D Research and development

RBSAM Residential Building Stock Assessment Metering 

RECS Residential Energy Consumption Survey

REO Rare earth oxideRIA Regulatory impact analysis

RIN Regulatory information number

RLEUCS Residential Lighting End-Use Consumption Study: Estimation Framework and 

Initial Estimates

RLS Residential Lighting Strategy

rms Root mean square

ROI Returns on investment

RS Rapid start

SBA Small Business Administration

SBMV Self-ballasted mercury vapor

SCC Social cost of carbon

SCE Southern California Edison

SCF Survey of Consumer Finances

SEC Securities Exchange Commission

SG&A Selling, general, and administrative

SNOPR Supplementary notice of proposed rulemaking

Si Silicon

SiC Silicon carbide

SiO2 Silicon oxide

SO2 Sulfur dioxide

SPD Spectral power distribution

SrO Strontium oxide

SSL Solid-state lighting

SUNY State University of New York

THD Total harmonic distortion

TI Texas Instruments

TIC Total Installed Cost

TIM Thermal interface material

TiO2 Titanium oxide

TOC Total Operating Cost

TP Test procedure

TSD Technical support document

TSL Trial standard level

UEC Unit Energy Consumption

U.S.C. United States Code

UL Underwriters Laboratories

UV Ultraviolet

W Watt

WACC Weighted average cost of capital

WPE Wall plug efficiency

YAG Yttrium aluminum garnet

AA-4
APPENDIX 8A. USER INSTRUCTIONS FOR LCC AND PBP SPREADSHEET 

TABLE OF CONTENTS

8A.1 INTRODUCTION ........................................................................................................ 8A-1

8A.2 DESCRIPTION OF LIFE-CYCLE COST SPREADSHEET....................................... 8A-1

8A-i
APPENDIX 8A. USER INSTRUCTIONS FOR LIFE-CYCLE COST ANALYSIS 

SPREADSHEET

8A.1 INTRODUCTION

The detailed results of the life-cycle cost (LCC) and payback period (PBP) analysis are 

illustrated with a Microsoft Excel® spreadsheet, which is accessible on the U.S. Department of

Energy’s (DOE) rulemaking website for GSLs.a The spreadsheet posted on the DOE website has

been tested with Microsoft Excel 2010. 

8A.2 DESCRIPTION OF LIFE-CYCLE COST SPREADSHEET

For all of the product classes, DOE created a single LCC workbook file containing a 

collection of worksheets. The LCC workbook contains the following worksheets that present 

results and sample calculations:

Summary This worksheet contains summary LCC and PBP results and box plots

for all product classes, and for all alternative scenarios, at each 

candidate standard level (CSL). Users can select between the reference 

scenario or alternative scenarios to generate results.

Res Example,

Com Example

Each of these worksheets contains detailed results and sample 

calculations for a single consumer (i.e., a purchaser of a GSL) in all 

product classes for the residential sector (Res Example) and the 

commercial sector (Com Example), respectively. Users can choose 

consumer characteristics with a series of drop-down menus and fillable 

cells. Users can also choose the base case CSL (i.e., the selected GSL’s 

CSL in the base case), the candidate standards case (i.e., the standard 

level for the selected GSL in the standards case), and the candidate 

standards case CSL (i.e., the selected GSL’s CSL in the standards case).

The right side of each sheet shows LCC and LCC savings results for the 

selected parameters. 

The LCC workbook contains the following worksheets that present inputs used in the 

LCC and PBP analysis:

Res Sample, 

Com Sample

The Res Sample and Com Sample worksheets contain the samples of 10,000 

consumers for the residential and commercial sector, respectively. During a 

simulation, DOE uses these samples to derive results for the analysis.

a http://www.regulations.gov/#!docketDetail;D=EERE-2013-BT-STD-0051 (accessed November 19, 2014). 

8A-1

 
GSL Prices This worksheet contains inputs for GSL purchase prices for all lamp options 

at the base case and the candidate standards cases. Note that GSL prices are 

different across standards cases due to price learning.

E_Price&Trends This worksheet shows the prices and price trends used to estimate electricity

price for each purchaser.

Discount Rates This worksheet contains the distributions of discount rates.

Lifetime This worksheet contains the cumulative distributions of daily operating hours 

for the residential and commercial sectors, and the probability of survival as a 

function of lamp age by rated life (hours) and sector

Market 

Distribution

This worksheet contains the market distribution for all product classes for the 

selected scenario

Energy Use This worksheet contains inputs used to calculate annual GSL energy use by 

CSL: GSL power input values, operating hours, market data on controls and 

smart lamps, room distribution by lumen ranges, and the lumen range 

distribution. 

Other 

Parameters

This worksheet contains other input parameters used in the analysis, including 

tax rates and disposal costs.

8A-2
APPENDIX 8B. UNCERTAINTY AND VARIABILITY

TABLE OF CONTENTS

8B.1 INTRODUCTION .........................................................................................................8B-1

8B.2 INTRODUCTION TO UNCERTAINTY AND VARIABILITY.................................8B-1

8B.2.1 Approaches to Address Uncertainty and Variability .........................................8B-1

8B.3 PROBABILITY ANALYSIS AND THE USE OF MONTE CARLO 

SIMULATION IN THE LCC AND PBP ANALYSIS .................................................8B-2

8B.4 ALTERNATIVE SCENARIOS CONSIDERED IN THIS RULEMAKING ...............8B-3

8B.5 LCC AND PBP ALTERNATIVE SCENARIO RESULTS..........................................8B-6

8B.5.1 Lamp Service Lifetime ......................................................................................8B-6

8B.5.1.1 Rated Lifetime..........................................................................................8B-6

8B.5.1.2 Early-Replacement Lifetime ..................................................................8B-10

8B.5.2 Rare Earth Cost................................................................................................8B-12

8B.5.3 Controls............................................................................................................8B-16

8B.5.4 Smart Lamp Incursion......................................................................................8B-18

8B.5.4.1 Zero Percent Smart Lamps.....................................................................8B-18

8B.5.4.2 100 Percent Smart Lamps ......................................................................8B-19

8B.5.5 Smart Lamps Standby Power...........................................................................8B-20

8B.5.6 AEO Growth ....................................................................................................8B-21

8B.5.6.1 High........................................................................................................8B-21

8B.5.6.2 Low.........................................................................................................8B-25

REFERENCES ........................................................................................................................8B-30

LIST OF TABLES

Table 8B.4.1 Scenarios Considered in this Rulemaking that Directly Affect the LCC 

and PBP Analysis.........................................................................................8B-5

Table 8B.4.2 Scenarios Considered in this Rulemaking that Do Not Directly Affect 

the LCC and PBP Analysis..........................................................................8B-6

Table 8B.5.1 Average LCC and PBP Results by Candidate Standard Level for 

Integrated Low-Lumen GSLs......................................................................8B-7

Table 8B.5.2 Average LCC Savings for Integrated Low-Lumen GSLs............................8B-8

Table 8B.5.3 Average LCC and PBP Results by Candidate Standard Level for 

Integrated High-Lumen GSLs......................................................................8B-8

Table 8B.5.4 Average LCC Savings for Integrated High-Lumen GSLs...........................8B-9

Table 8B.5.5 Average LCC and PBP Results by Candidate Standard Level for NonIntegrated GSLs...........................................................................................8B-9

Table 8B.5.6 Average LCC Savings for Non-Integrated GSLs ......................................8B-10

Table 8B.5.7 Average LCC and PBP Results by Candidate Standard Level for 

Integrated Low-Lumen GSLs....................................................................8B-11

Table 8B.5.8 Average LCC Savings for Integrated Low-Lumen GSLs..........................8B-12

Table 8B.5.9 Average LCC and PBP Results by Candidate Standard Level for 

Integrated Low-Lumen GSLs....................................................................8B-13

8B-i
Table 8B.5.10 Average LCC Savings for Integrated Low-Lumen GSLs..........................8B-14

Table 8B.5.11 Average LCC and PBP Results by Candidate Standard Level for 

Integrated High-Lumen GSLs....................................................................8B-14

Table 8B.5.12 Average LCC Savings for Integrated High-Lumen GSLs.........................8B-15

Table 8B.5.13 Average LCC and PBP Results by Candidate Standard Level for NonIntegrated GSLs.........................................................................................8B-15

Table 8B.5.14 Average LCC Savings for Non-Integrated GSLs ......................................8B-16

Table 8B.5.15 Average LCC and PBP Results by Candidate Standard Level for 

Integrated Low-Lumen GSLs....................................................................8B-16

Table 8B.5.16 Average LCC Savings for Integrated Low-Lumen GSLs..........................8B-17

Table 8B.5.17 Average LCC and PBP Results by Candidate Standard Level for 

Integrated High-Lumen GSLs....................................................................8B-17

Table 8B.5.18 Average LCC Savings for Integrated High-Lumen GSLs.........................8B-17

Table 8B.5.19 Average LCC and PBP Results by Candidate Standard Level for NonIntegrated GSLs.........................................................................................8B-18

Table 8B.5.20 Average LCC Savings for Non-Integrated GSLs ......................................8B-18

Table 8B.5.21 Average LCC and PBP Results by Candidate Standard Level for 

Integrated Low-Lumen GSLs....................................................................8B-19

Table 8B.5.22 Average LCC Savings for Integrated Low-Lumen GSLs..........................8B-19

Table 8B.5.23 Average LCC and PBP Results by Candidate Standard Level for 

Integrated Low-Lumen GSLs....................................................................8B-20

Table 8B.5.24 Average LCC Savings for Integrated Low-Lumen GSLs..........................8B-20

Table 8B.5.25 Average LCC and PBP Results by Candidate Standard Level for 

Integrated Low-Lumen GSLs....................................................................8B-21

Table 8B.5.26 Average LCC Savings for Integrated Low-Lumen GSLs..........................8B-21

Table 8B.5.27 Average LCC and PBP Results by Candidate Standard Level for 

Integrated Low-Lumen GSLs....................................................................8B-22

Table 8B.5.28 Average LCC Savings for Integrated Low-Lumen GSLs..........................8B-23

Table 8B.5.29 Average LCC and PBP Results by Candidate Standard Level for 

Integrated High-Lumen GSLs....................................................................8B-23

Table 8B.5.30 Average LCC Savings for Integrated High-Lumen GSLs.........................8B-24

Table 8B.5.31 Average LCC and PBP Results by Candidate Standard Level for NonIntegrated GSLs.........................................................................................8B-24

Table 8B.5.32 Average LCC Savings for Non-Integrated GSLs ......................................8B-25

Table 8B.5.33 Average LCC and PBP Results by Candidate Standard Level for 

Integrated Low-Lumen GSLs....................................................................8B-26

Table 8B.5.34 Average LCC Savings for Integrated Low-Lumen GSLs..........................8B-27

Table 8B.5.35 Average LCC and PBP Results by Candidate Standard Level for 

Integrated High-Lumen GSLs....................................................................8B-27

Table 8B.5.36 Average LCC Savings for Integrated High-Lumen GSLs.........................8B-28

Table 8B.5.37 Average LCC and PBP Results by Candidate Standard Level for NonIntegrated GSLs.........................................................................................8B-28

Table 8B.5.38 Average LCC Savings for Non-Integrated GSLs ......................................8B-29

8B-ii
LIST OF FIGURES

Figure 8B.3.1 Normal, Triangular, Uniform, Weibull, and Custom Probability 

Distributions.................................................................................................8B-3

8B-iii
APPENDIX 8B. UNCERTAINTY AND VARIABILITY

8B.1 INTRODUCTION

This appendix discusses uncertainty and variability and describes how the U.S. 

Department of Energy (DOE) incorporated these into the life-cycle cost (LCC) and payback 

period (PBP) analysis and other downstream analyses reported in this preliminary analysis 

technical support document (TSD) for the general service lamp (GSL) energy conservation 

standards (ECS) rulemaking. The two key approaches are (1) to use distributions to capture 

uncertainties and variations in input variables when such distributions are reasonably well 

defined, and (2) to use scenarios that capture the bounds of uncertainty when the bounds are less 

well defined. 

8B.2 INTRODUCTION TO UNCERTAINTY AND VARIABILITY

DOE develops mathematical models to analyze the impacts of proposed energy 

conservation standards. The models generate outputs (e.g., the LCC impact of proposed 

standards) based on inputs that are often uncertain, variable, or both. 

Variability means that the quantity of interest takes on different values at different times 

or under different conditions. Variability may be caused by many factors. For example, the hours 

of use of a lamp depend on environmental factors (e.g., diurnal variations in light) and behavioral 

factors (e.g., the schedules and preferences of the inhabitants of a house). Manufacturing 

irregularities can also cause variability. For example, 10 lamps of the same model may each have 

slightly different power consumptions. DOE attempts to account for major sources of variability 

in its analyses. 

Uncertainty has many sources. Variability may lead to uncertainty in model inputs, 

because analysts frequently must estimate the values of interest based on samples of a variable 

quantity (for example, the hours of use of lighting in a home). Measurement uncertainty is 

another source of uncertainty, which may result from instrumental uncertainties (resulting, for 

example, from drift, bias, and precision of resolution) and human factors (e.g., variations in 

experimental setup, errors in instrument readings or recordings). Uncertainty can also arise when 

there is limited data available to estimate a particular parameter. DOE attempts to address the 

major sources of uncertainties in its analyses. 

8B.2.1 Approaches to Address Uncertainty and Variability

This section describes two approaches to address uncertainty and variability in numerical 

modeling that in practice are often used in tandem, as they are in this rulemaking: (1) probability 

analysis and (2) scenario analysis.

Probability analysis considers the probability that a variable has a given value over its 

range of possible values. For quantities with variability (e.g., electricity rates in different 

households), data from surveys or other forms of measurement can be used to generate a 

frequency distribution of numerical values to estimate the probability that the variable takes a 

8B-1
given value. By sampling values from the resulting distribution, it is possible to quantify the 

impact of known variability in a particular variable on the outcome of the analysis. In this 

rulemaking, DOE used probability distributions to estimate GSL service lifetime, annual lamp 

energy use, consumer electricity prices, and other variables.

Unlike probability analysis, which considers the impact of known variability, scenario 

analysis estimates the sensitivity of an analysis to sources of uncertainty and variability whose

probability distribution is not well known. Certain model inputs are modified to take a number of 

different values, and models are re-analyzed, in a set of different model scenarios. Because only 

selected inputs are changed in each scenario, the variability in the results for each scenario helps 

to quantify the impact of uncertainty in the input parameters. In this rulemaking, for example, the 

reference LCC analysis was performed assuming GSLs having a standby mode (i.e., “smart 

lamps”) had zero standby power consumption. An alternative scenario analysis assumed that 

such lamps consume 1 watt of power when in standby mode (with all other input variables 

unchanged from the reference scenario). Whereas it is relatively simple to perform scenario 

analyses for a range of scenarios, scenario analyses provide no information regarding the 

likelihood of any given scenario’s actually occurring.

Scenario and probability analysis provide some indication of the robustness of the policy 

given the uncertainties and variability. A policy is robust when the impacts are acceptable over a 

wide range of possible conditions.

8B.3 PROBABILITY ANALYSIS AND THE USE OF MONTE CARLO 

SIMULATION IN THE LCC AND PBP ANALYSIS

To quantify the uncertainty and variability that exist in inputs to the LCC and PBP 

analysis, DOE used Monte Carlo simulation and probability distributions to conduct probability 

analyses.

Simulation refers to any analytical method meant to imitate a real-life system, especially 

when other analyses are too mathematically complex or too difficult to reproduce. Without the 

aid of simulation, a model will only reveal a single outcome, generally the most likely or average 

scenario. Probabilistic risk analysis uses both a spreadsheet model and simulation to 

automatically analyze the effect of varying inputs on the outputs of a modeled system. One type 

of simulation is Monte Carlo simulation, which repeatedly generates random values for uncertain 

variables, drawn from a probability distribution, to simulate a model.

For each uncertain variable, the range of possible values is controlled by a probability 

distribution. The type of distribution selected is based on the conditions surrounding that 

variable. Probability distribution types include normal, triangular, uniform, and Weibull 

distributions, as well as custom distributions where needed. Example plots of these distributions 

are shown in Figure 8B.3.1.

8B-2
Figure 8B.3.1 Normal, Triangular, Uniform, Weibull, and Custom Probability 

Distributions

During a simulation, multiple scenarios of a model are calculated by repeatedly sampling 

values from the probability distributions for the uncertain variables and using those values for 

that input. Monte Carlo simulations can consist of as many trials as desired, with larger numbers 

of trials yielding more accurate average results. During a single trial, the simulation randomly 

selects a value from the defined possibilities (the range and shape of the probability distribution) 

for each uncertain variable and then recalculates the result for that trial.

8B.4 ALTERNATIVE SCENARIOS CONSIDERED IN THIS RULEMAKING

DOE considered a number of alternative scenarios in this rulemaking to account for 

uncertainty and variability in key analysis inputs whose probability distribution was not well 

known. Many, but not all, of the alternative scenarios DOE considered in this rulemaking 

directly impact the LCC and PBP analysis. Many scenarios also affect the Shipments and 

National Impacts analyses (chapters 9 and 10 of this preliminary TSD). The alternative scenarios 

DOE considered are:

• Lamp service lifetime: DOE believes the service lifetime of a GSL can be modeled 

using a Weibull survival function (i.e., probability of survival as a function of GSL age) 

of the GSL’s rated lifetime, truncated by another Weibull survival function to ensure 

GSLs are not in service long after the assumed renovation/retrofit cycle length (20 years). 

However, given the uncertainty in this assumption, DOE analyzed two alternative 

scenarios. See appendix 8E of this TSD for more details. 

• Rare earth cost: The reference scenario assumes that prices of rare earth elements are 

constant at their June 2014 level. DOE also considered an alternative scenario in which 

the prices of rare earth elements are midway between their 2011 peak and the 2006 –

2009 baseline average price. See appendix 8D of this TSD for details.

• Controls: DOE believes that lighting controls in the commercial sector are installed on 

an increasing fraction of lamps as a result of updated building codes, but there is 

uncertainty in this assumption. Therefore, DOE considered an alternative scenario where 

NORMAL TRIANGULAR UNIFORM

WEIBULL CUSTOM

8B-3
the fraction of commercial GSLs on controls remains constant over the analysis period at 

2014 levels. See appendix 10C of this TSD for more information.

• Smart lamp incursion: DOE believes that the residential sector will experience an 

increase in the number of LED GSLs with a standby mode and with integrated wireless 

receivers that allow them to be controlled remotely (referred to as smart lamps). DOE 

believes that these features may have a significant impact on energy consumption for 

these lamps. DOE also believes these lamps will be a growing share of the market over

the period covered by the NIA, but there is uncertainty as to the fraction of LED GSL

shipments that are smart lamps at the end of the projection period. DOE therefore tested 

the impact of varying its assumptions about the final smart-lamp market share. See 

chapter 10 of this TSD for more details.

• Smart lamps standby power: In the reference scenario, DOE assumed no standby 

power consumption for smart-lamp GSLs that have a standby mode. DOE analyzed 

another scenario in which the standby power consumption was assumed to be 1 watt.

• AEO Growth: The reference scenario uses future electricity prices based on reference 

electricity price trends projected by the Energy Information Administration in its Annual 

Energy Outlook 2014 (AEO 2014).1 Because of the uncertainty present when attempting 

to estimate future electricity prices, DOE analyzed two alternative economic growth 

scenarios: a low economic growth, and a high economic growth scenario from AEO 

2014.

• Rebound: In the reference scenario, DOE estimated no rebound effect in either the 

residential or commercial sectors. DOE explored other rebound rates for the commercial 

and residential sectors to illustrate the impact of DOE’s estimation on the analysis. See 

appendix 10D for more details.

• Integrated LED incursion: DOE believes that a growing fraction of GSL shipments 

may be displaced over the course of the shipments projection period by integrated LED 

fixtures, which do not require the use of replaceable lamps. DOE believes these fixtures 

will displace a growing fraction of shipments over time, but there is uncertainty as to the 

fraction of shipments that will be displaced by the end of the analysis period. DOE 

therefore tested the impact of varying its assumptions about the final integrated-luminaire 

market share. See chapter 9 of this TSD for more details.

• Learning rate: While price learning is known to occur for GSLs, DOE considers the

future learning rate for LED GSLs to be uncertain, because LEDs are in an early phase of 

their market adoption. DOE estimates that the current LED learning rate is substantially 

higher than the learning rate for CFLs, but DOE believes that this trend may not continue 

over the duration of the analysis period. Therefore, in the reference scenario DOE 

assumed LED GSLs have a price learning rate equal to the historic learning rate for 

CFLs. In two alternative scenarios, DOE analyzed the possibility of a sustained LED 

learning rate at the current LED learning rate over the analysis period as well as the 

possibility of no price learning for any GSLs. See chapter 9 of this TSD for more details.

Table 8B.4.1 and Table 8B.4.2 provide summary descriptions of the reference and 

alternative scenarios DOE considered in this rulemaking. Table 8B.4.1 contains the alternative 

analyses that directly affect the LCC and PBP analysis, whereas Table 8B.4.2 contains the 

alternative analyses that do not directly affect the LCC and PBP analysis, but that do have 

implications for other analyses in this rulemaking (e.g., the shipments analysis and NIA).

8B-4
Table 8B.4.1 Scenarios Considered in this Rulemaking that Directly Affect the LCC and 

PBP Analysis

Scenario Name Scenario Options 

Analyzed Description of Alternative Scenarios

Reference Reference option 

indicated in bold below

DOE’s best estimate for each variable considered 

in its analyses

Lamp Service 

Lifetime

Rated Lifetime Full rated lifetime (taking into account effects of 

on-cycle length on CFL lifetimes)

Renovation-Driven 

Lifetime

The Rated Lifetime distribution truncated by a 

Weibull distribution with a 20-year median

Early-Replacement 

Lifetime

For LEDs, the Rated Lifetime distribution

truncated by a Weibull distribution with a 5-year 

median; for CFLs, lifetime as in the reference 

scenario

Rare Earth Cost

Constant Remain constant at current level over analysis 

period

High Remain constant at increased level over analysis 

period

Controls

(commercial 

sector only)

Reference

The fraction of commercial floor space utilizing 

various types of controls grows from 30% today 

to a projected value of 80% in 2049

Fixed The current fraction of commercial GSLs with 

controls remains constant over the analysis period

Smart Lamp 

Incursion

(residential 

sector only)

0% 0% market share of smart lamp shipments at the 

end of the analysis period

50% 50% market share of smart lamp shipments at the 

end of the analysis period

100% 100% market share of smart lamp shipments at 

the end of the analysis period

Smart Lamps 

Standby Power 

(residential 

sector only)

0 W No power consumption for smart lamps in 

standby mode

1 W 1 watt power consumption for smart lamps in 

standby mode

AEO Growth

Low Low economic growth scenario from AEO 2014 

for electricity prices

Reference Reference economic growth case from AEO 2014 

for electricity prices

High High economic growth scenario from AEO 2014 

for electricity prices

8B-5
Table 8B.4.2 Scenarios Considered in this Rulemaking that Do Not Directly Affect the 

LCC and PBP Analysis

Scenario Name Scenario Options 

Analyzed Description of Alternative Scenarios

Rebound

No No rebound

Low 8.5% for residential sector; 1% for commercial 

sector

High 15% for residential and commercial sectors

Integrated LED 

Incursion 

0%

0% incursion of integrated LED luminaires into 

the market for traditional GSL luminaires at the 

end of the analysis period 

15%

15% incursion of integrated LED luminaires into 

the market for traditional GSL luminaires at the 

end of the analysis period

50%

50% incursion of integrated LED luminaires into 

the market for traditional GSL luminaires at the 

end of the analysis period

Learning Rate

None No price learning (constant real prices)

CFL Historic CFL price learning rate for both LEDs 

and CFLs

Technology Historic technology-specific price learning rates 

for LEDs and CFLs

8B.5 LCC AND PBP ALTERNATIVE SCENARIO RESULTS

DOE addressed input uncertainties in its LCC and PBP analysis for this rulemaking in 

both its reference case analyses and in its alternative scenario analyses. DOE used the Monte 

Carlo approach with 10,000 runs per alternative scenario to determine how the results of the 

LCC and PBP analysis change under the different assumptions for the inputs shown in Table 

8B.4.1.

This section presents the results of the LCC and PBP for those alternative scenario 

analyses. Note that DOE examined each scenario independently, while keeping all other 

parameters according to the reference scenario. 

8B.5.1 Lamp Service Lifetime

This section presents results for the ‘rated lifetime’ and ‘early-replacement lifetime’ 

scenarios.

8B.5.1.1 Rated Lifetime

Table 8B.5.1 through Table 8B.5.6 show results for the ‘rated lifetime’ scenario. 

8B-6
Table 8B.5.1 Average LCC and PBP Results by Candidate Standard Level for Integrated 

Low-Lumen GSLs

CSL

Average Costs (2014$) Simple 

Payback

(years)

Average 

Lifetime

Installed Cost (years)

First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 6.2 1.6 5.8 12.1 --- 12.9

1 4.0 1.5 5.4 8.9 0 14.7

2 34.9 1.3 4.7 20.5 99.6 37.1

3 22.2 1.2 4.4 14.4 40.5 37.1

4 7.5 1.1 4.0 8.1 2.5 37.1

5 7.1 1.0 3.8 7.7 1.7 37.1

Commercial Sector

0 7.0 6.9 17.7 24.8 --- 2.2

1 4.4 6.4 16.5 20.2 0 2.8

2 45.7 6.0 15.3 37.9 40.0 6.3

3 29.1 5.5 14.0 28.4 15.3 6.3

4 7.6 5.0 12.8 17.2 0.3 6.3

5 7.3 4.8 12.2 16.4 0.1 6.3

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

8B-7
Table 8B.5.2 Average LCC Savings for Integrated Low-Lumen GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience

Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 0% 0.0

2 20% 0.2

3 20% 0.3

4 18% 0.5

5 16% 0.7

Commercial Sector

0 0.0% 0.0

1 0.0% 0.0

2 1.0% 1.7

3 1.0% 1.8

4 0.8% 1.8

5 0.2% 2.1

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

Table 8B.5.3 Average LCC and PBP Results by Candidate Standard Level for Integrated 

High-Lumen GSLs

CSL

Average Costs (2014$) Simple 

Payback

(years)

Average 

Lifetime

Installed Cost (years)

First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 9.8 3.6 13.3 23.0 --- 12.9

1 10.1 3.4 12.4 22.6 1.5 12.9

2 10.8 3.3 12.0 21.7 3.1 14.7

Commercial Sector

0 9.8 12.4 31.6 41.5 --- 2.2

1 10.1 11.6 29.7 39.8 0.4 2.2

2 10.8 11.2 28.7 37.6 0.9 2.8

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

8B-8
Table 8B.5.4 Average LCC Savings for Integrated High-Lumen GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience

Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 5% 0.2

2 10% 0.6

Commercial Sector

0 0.0% 0.0

1 0.3% 0.5

2 1.2% 1.7

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

Table 8B.5.5 Average LCC and PBP Results by Candidate Standard Level for NonIntegrated GSLs

CSL

Average Costs (2014$) Simple 

Payback

(years)

Average 

Lifetime

(years) Installed Cost First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 13.2 3.4 12.4 25.7 --- 12.9

1A 14.2 3.4 12.4 22.9 N/A 18.4

1B 15.8 2.8 10.1 20.9 4.0 20.4

Commercial Sector

0 13.2 11.6 29.6 43.0 --- 2.2

1A 14.2 11.6 29.6 39.0 N/A 4.1

1B 15.8 9.4 24.1 33.3 1.2 5.0

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

8B-9
Table 8B.5.6 Average LCC Savings for Non-Integrated GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience

Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 10% 1.8

Commercial Sector

0 0.0% 0.0

1 5.4% 2.6

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

8B.5.1.2 Early-Replacement Lifetime

Because this scenario only affects LED GSLs, this section presents results only for the 

low-lumen integrated product class, which is the only product class that includes LEDs. 

8B-10
Table 8B.5.7 Average LCC and PBP Results by Candidate Standard Level for Integrated 

Low-Lumen GSLs

CSL

Average Costs (2014$) Simple 

Payback

years

Average 

Lifetime

Installed Cost years

First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 6.2 1.6 4.6 9.3 --- 8.8

1 3.9 1.5 4.2 6.9 0 9.8

2 34.9 1.3 3.7 36.2 99.6 4.5

3 22.2 1.2 3.4 24.1 40.5 4.5

4 7.7 1.1 3.1 10.4 3.0 4.5

5 7.3 1.0 2.9 9.8 2.0 4.5

Commercial Sector

0 7.0 6.9 17.7 24.8 --- 2.2

1 4.4 6.4 16.5 20.2 0 2.8

2 45.7 6.0 15.3 46.6 40.0 4.2

3 29.1 5.5 14.0 34.0 15.3 4.2

4 7.9 5.0 12.8 18.7 0.5 4.2

5 7.5 4.8 12.2 17.7 0.2 4.2

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

8B-11
Table 8B.5.8 Average LCC Savings for Integrated Low-Lumen GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience

Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 0% 0.0

2 54% -2.3

3 54% -2.0

4 53% -1.5

5 52% -1.3

Commercial Sector

0 0.0% 0.0

1 0.0% 0.0

2 12.9% 1.0

3 12.9% 1.0

4 12.6% 1.0

5 8.1% 1.4

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

8B.5.2 Rare Earth Cost

Table 8B.5.9 through Table 8B.5.14 present results for the alternative rare earth price 

scenario. Note that DOE assumes that rare earth content in LED GSLs is negligible; therefore, 

this scenario does not affect LED GSLs. 

8B-12
Table 8B.5.9 Average LCC and PBP Results by Candidate Standard Level for Integrated 

Low-Lumen GSLs

CSL

Average Costs (2014$) Simple 

Payback

(years)

Average 

Lifetime

Installed Cost (years)

First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 6.2 1.6 5.6 11.8 --- 8.8

1 4.0 1.5 5.2 8.8 0 9.8

2 34.9 1.3 4.6 23.1 99.6 17.9

3 22.2 1.2 4.2 16.0 40.5 17.9

4 7.5 1.1 3.8 8.5 2.6 17.9

5 7.2 1.0 3.6 8.1 1.7 17.9

Commercial Sector

0 7.0 6.9 17.7 24.8 --- 2.2

1 4.5 6.4 16.5 20.2 0 2.8

2 45.7 6.0 15.3 37.9 40.0 6.3

3 29.1 5.5 14.0 28.4 15.3 6.3

4 7.7 5.0 12.8 17.2 0.4 6.3

5 7.3 4.8 12.2 16.4 0.2 6.3

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

8B-13
Table 8B.5.10 Average LCC Savings for Integrated Low-Lumen GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience

Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 0% 0.0

2 27% -0.1

3 27% 0.0

4 25% 0.3

5 22% 0.5

Commercial Sector

0 0.0% 0.0

1 0.0% 0.0

2 1.1% 1.7

3 1.1% 1.7

4 0.8% 1.8

5 0.3% 2.1

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

Table 8B.5.11 Average LCC and PBP Results by Candidate Standard Level for Integrated 

High-Lumen GSLs

CSL

Average Costs (2014$) Simple 

Payback

(years)

Average 

Lifetime

Installed Cost (years)

First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 9.8 3.6 12.8 22.6 --- 8.8

1 10.1 3.4 12.0 22.1 1.5 8.8

2 10.9 3.3 11.6 21.4 3.1 9.8

Commercial Sector

0 9.8 12.4 31.6 41.5 --- 2.2

1 10.1 11.6 29.7 39.9 0.4 2.2

2 10.9 11.2 28.7 37.7 0.9 2.8

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

8B-14
Table 8B.5.12 Average LCC Savings for Integrated High-Lumen GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience

Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 6% 0.2

2 13% 0.5

Commercial Sector

0 0.0% 0.0

1 0.2% 0.5

2 1.3% 1.7

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

Table 8B.5.13 Average LCC and PBP Results by Candidate Standard Level for NonIntegrated GSLs

CSL

Average Costs (2014$) Simple 

Payback

(years)

Average 

Lifetime

Installed Cost (years)

First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 13.2 3.4 11.9 25.2 --- 8.8

1A 14.2 3.4 11.9 22.8 N/A 11.6

1B 15.8 2.8 9.7 21.1 4.0 12.5

Commercial Sector

0 13.2 11.6 29.6 43.0 --- 2.2

1A 14.2 11.6 29.6 39.0 N/A 4.1

1B 15.8 9.4 24.1 33.3 1.2 5.0

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

8B-15
Table 8B.5.14 Average LCC Savings for Non-Integrated GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience

Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 12% 1.6

Commercial Sector

0 0.0% 0.0

1 5.4% 2.6

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

8B.5.3 Controls

Results for the alternative scenario are presented in Table 8B.5.15 through Table 8B.5.20. 

Note that this scenario affects only the commercial sector; therefore, the tables below do not 

present results for the residential sector. 

Table 8B.5.15 Average LCC and PBP Results by Candidate Standard Level for Integrated 

Low-Lumen GSLs

CSL

Average Costs (2014$) Simple 

Payback

(years)

Average 

Lifetime

Installed Cost (years)

First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Commercial Sector

0 7.0 7.3 18.6 25.7 --- 2.2

1 4.4 6.8 17.3 21.0 0 2.8

2 45.7 6.3 16.0 38.6 38.1 6.3

3 29.1 5.8 14.8 29.1 14.5 6.3

4 7.7 5.3 13.5 17.9 0.4 6.3

5 7.3 5.0 12.8 17.0 0.1 6.3

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

8B-16
Table 8B.5.16 Average LCC Savings for Integrated Low-Lumen GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience

Net Cost

Average Savings

(2014$)

Commercial Sector

0 0.0% 0.0

1 0.0% 0.0

2 1.0% 1.8

3 1.0% 1.8

4 0.7% 1.9

5 0.2% 2.2

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

Table 8B.5.17 Average LCC and PBP Results by Candidate Standard Level for Integrated 

High-Lumen GSLs

CSL

Average Costs (2014$) Simple 

Payback

(years)

Average 

Lifetime

Installed Cost (years)

First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Commercial Sector

0 9.7 13.0 33.3 43.1 --- 2.2

1 10.1 12.2 31.2 41.3 0.4 2.2

2 10.8 11.8 30.1 39.1 0.9 2.8

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

Table 8B.5.18 Average LCC Savings for Integrated High-Lumen GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience

Net Cost

Average Savings

(2014$)

Commercial Sector

0 0.0% 0.0

1 0.2% 0.5

2 0.9% 1.8

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

8B-17
Table 8B.5.19 Average LCC and PBP Results by Candidate Standard Level for NonIntegrated GSLs

CSL

Average Costs (2014$) Simple 

Payback

(years)

Average 

Lifetime

Installed Cost (years)

First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Commercial Sector

0 13.2 12.2 31.1 44.4 --- 2.2

1A 14.2 12.2 31.1 40.5 N/A 4.1

1B 15.7 9.9 25.4 34.5 1.1 5.0

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

Table 8B.5.20 Average LCC Savings for Non-Integrated GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience

Net Cost

Average Savings

(2014$)

Commercial Sector

0 0.0% 0.0

1 5.4% 2.6

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

8B.5.4 Smart Lamp Incursion

The following sections (8B.5.4.1 and 8B.5.4.2) present results for the alternative 

scenarios only for the residential sector, which is the only sector where DOE assumes that smart 

lamps are used.

8B.5.4.1 Zero Percent Smart Lamps

Table 8B.5.21 through Table 8B.5.22 present results for the zero percent smart lamps 

scenario.

8B-18
Table 8B.5.21 Average LCC and PBP Results by Candidate Standard Level for Integrated 

Low-Lumen GSLs

CSL

Average Costs (2014$) Simple 

Payback

(years)

Average 

Lifetime

Installed Cost (years)

First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 6.2 1.6 5.6 11.8 --- 8.8

1 4.0 1.5 5.2 8.8 0 9.8

2 34.9 1.3 4.7 23.2 111.8 17.9

3 22.2 1.2 4.3 16.1 43.6 17.9

4 7.5 1.1 3.9 8.6 2.7 17.9

5 7.2 1.0 3.7 8.2 1.7 17.9

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

Table 8B.5.22 Average LCC Savings for Integrated Low-Lumen GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience

Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 0% 0.0

2 28% -0.2

3 27% 0.0

4 25% 0.2

5 23% 0.4

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

8B.5.4.2 100 Percent Smart Lamps

Table 8B.5.23 through Table 8B.5.24 present results for the 100 percent smart lamps scenario.

8B-19
Table 8B.5.23 Average LCC and PBP Results by Candidate Standard Level for Integrated 

Low-Lumen GSLs

CSL

Average Costs (2014$) Simple 

Payback

(years)

Average 

Lifetime

Installed Cost (years)

First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 6.2 1.6 5.6 11.8 --- 8.8

1 4.0 1.5 5.2 8.8 0 9.8

2 34.9 1.3 4.5 23.0 89.9 17.9

3 22.2 1.2 4.1 15.9 37.7 17.9

4 7.5 1.1 3.7 8.4 2.5 17.9

5 7.2 1.0 3.5 8.0 1.6 17.9

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

Table 8B.5.24 Average LCC Savings for Integrated Low-Lumen GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience

Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 0% 0.0

2 27% -0.1

3 26% 0.1

4 25% 0.3

5 22% 0.5

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

8B.5.5 Smart Lamps Standby Power

This section presents results for the alternative scenario only for the residential sector, 

which is the only sector where DOE assumes that smart lamps are used.

8B-20
Table 8B.5.25 Average LCC and PBP Results by Candidate Standard Level for Integrated 

Low-Lumen GSLs

CSL

Average Costs (2014$) Simple 

Payback

(years)

Average 

Lifetime

Installed Cost (years)

First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 6.2 1.6 5.6 11.8 -- 8.8

1 4.0 1.5 5.2 8.8 0.0 9.8

2 34.9 1.4 5.1 23.7 133 17.9

3 22.2 1.3 4.7 16.6 49.5 17.9

4 7.5 1.1 4.4 9.1 3.0 17.9

5 7.2 1.1 4.2 8.7 1.9 17.9

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

Table 8B.5.26 Average LCC Savings for Integrated Low-Lumen GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience

Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 0% 0.0

2 29% -0.4

3 28% -0.3

4 26% 0.0

5 24% 0.2

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

8B.5.6 AEO Growth

This section presents results for the alternative AEO 2014 growth electricity price scenarios.

8B.5.6.1 High

Table 8B.5.27 through Table 8B.5.32 present results for the high economic growth 

electricity price trends from AEO 2014. 

8B-21
Table 8B.5.27 Average LCC and PBP Results by Candidate Standard Level for Integrated 

Low-Lumen GSLs

CSL

Average Costs (2014$) Simple 

Payback

(years)

Average 

Lifetime

Installed Cost (years)

First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 6.2 1.6 5.6 11.8 --- 8.8

1 4.0 1.5 5.2 8.8 0 9.8

2 34.9 1.3 4.6 23.1 99.6 17.9

3 22.2 1.2 4.2 16.0 40.4 17.9

4 7.5 1.1 3.8 8.5 2.6 17.9

5 7.2 1.0 3.6 8.1 1.7 17.9

Commercial Sector

0 7.0 7.0 17.9 24.9 --- 2.2

1 4.4 6.5 16.6 20.3 0 2.8

2 45.7 6.0 15.4 38.0 39.8 6.3

3 29.1 5.5 14.2 28.5 15.2 6.3

4 7.7 5.0 12.9 17.3 0.4 6.3

5 7.3 4.8 12.3 16.5 0.2 6.3

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

8B-22
Table 8B.5.28 Average LCC Savings for Integrated Low-Lumen GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience

Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 0% 0.0

2 27% -0.1

3 27% 0.0

4 25% 0.3

5 22% 0.5

Commercial Sector

0 0.0% 0.0

1 0.0% 0.0

2 1.0% 1.7

3 1.0% 1.7

4 0.8% 1.8

5 0.3% 2.1

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

Table 8B.5.29 Average LCC and PBP Results by Candidate Standard Level for Integrated 

High-Lumen GSLs

CSL

Average Costs (2014$) Simple 

Payback

(years)

Average 

Lifetime

Installed Cost (years)

First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 9.7 3.6 12.8 22.5 --- 8.8

1 10.1 3.4 12.0 22.1 1.5 8.8

2 10.8 3.3 11.6 21.3 3.1 9.8

Commercial Sector

0 9.7 12.5 31.9 41.7 --- 2.2

1 10.1 11.7 29.9 40.1 0.4 2.2

2 10.8 11.3 28.9 37.8 0.9 2.8

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

8B-23
Table 8B.5.30 Average LCC Savings for Integrated High-Lumen GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience

Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 6% 0.2

2 13% 0.5

Commercial Sector

0 0.0% 0.0

1 0.2% 0.5

2 1.2% 1.7

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

Table 8B.5.31 Average LCC and PBP Results by Candidate Standard Level for NonIntegrated GSLs

CSL

Average Costs (2014$) Simple 

Payback

(years)

Average 

Lifetime

Installed Cost (years)

First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 13.2 3.4 12.0 25.2 --- 8.8

1A 14.2 3.4 12.0 22.8 N/A 11.6

1B 15.7 2.8 9.7 21.1 4.0 12.5

Commercial Sector

0 13.2 11.7 29.9 43.1 --- 2.2

1A 14.2 11.7 29.9 39.2 N/A 4.1

1B 15.7 9.5 24.3 33.4 1.2 5.0

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

8B-24
Table 8B.5.32 Average LCC Savings for Non-Integrated GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience

Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 12% 1.6

Commercial Sector

0 0.0% 0.0

1 5.4% 2.6

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

8B.5.6.2 Low

Table 8B.5.33 through Table 8B.5.38 present results for the low economic growth 

electricity price trends from AEO 2014. 

8B-25
Table 8B.5.33 Average LCC and PBP Results by Candidate Standard Level for Integrated 

Low-Lumen GSLs

CSL

Average Costs (2014$) Simple 

Payback

(years)

Average 

Lifetime

Installed Cost (years)

First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 6.2 1.6 5.6 11.8 --- 8.8

1 4.0 1.5 5.2 8.8 0 9.8

2 34.9 1.3 4.6 23.1 100.0 17.9

3 22.2 1.2 4.2 16.0 40.6 17.9

4 7.5 1.1 3.8 8.5 2.6 17.9

5 7.2 1.0 3.6 8.1 1.7 17.9

Commercial Sector

0 7.0 6.8 17.6 24.6 --- 2.2

1 4.4 6.4 16.3 20.0 0 2.8

2 45.7 5.9 15.1 37.7 40.6 6.3

3 29.1 5.4 13.9 28.3 15.5 6.3

4 7.7 4.9 12.7 17.1 0.4 6.3

5 7.3 4.7 12.1 16.3 0.2 6.3

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

8B-26
Table 8B.5.34 Average LCC Savings for Integrated Low-Lumen GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience

Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 0% 0.0

2 27% -0.1

3 27% 0.0

4 25% 0.3

5 22% 0.5

Commercial Sector

0 0.0% 0.0

1 0.0% 0.0

2 1.1% 1.7

3 1.1% 1.7

4 0.8% 1.7

5 0.3% 2.1

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

Table 8B.5.35 Average LCC and PBP Results by Candidate Standard Level for Integrated 

High-Lumen GSLs

CSL

Average Costs (2014$) Simple 

Payback

(years)

Average 

Lifetime

Installed Cost (years)

First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 9.7 3.6 12.8 22.5 --- 8.8

1 10.1 3.4 12.0 22.1 1.5 8.8

2 10.8 3.3 11.6 21.3 3.1 9.8

Commercial Sector

0 9.7 12.2 31.3 41.1 --- 2.2

1 10.1 11.4 29.3 39.5 0.4 2.2

2 10.8 11.1 28.4 37.3 0.9 2.8

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

8B-27
Table 8B.5.36 Average LCC Savings for Integrated High-Lumen GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience

Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 6% 0.2

2 13% 0.5

Commercial Sector

0 0.0% 0.0

1 0.3% 0.5

2 1.2% 1.7

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

Table 8B.5.37 Average LCC and PBP Results by Candidate Standard Level for NonIntegrated GSLs

CSL

Average Costs (2014$) Simple 

Payback

(years)

Average 

Lifetime

Installed Cost (years)

First Year’s 

Operating Cost

Lifetime 

Operating Cost LCC

Residential Sector

0 13.2 3.4 12.0 25.2 --- 8.8

1A 14.2 3.4 12.0 22.8 N/A 11.6

1B 15.7 2.8 9.7 21.1 4.0 12.5

Commercial Sector

0 13.2 11.4 29.3 42.6 --- 2.2

1A 14.2 11.4 29.3 38.7 N/A 4.1

1B 15.7 9.3 23.9 33.0 1.2 5.0

Note: The results for each CSL are calculated assuming that all consumers use products with that efficiency level. 

The LCC may not equal the sum of installed cost and lifetime operating cost because it may also include residual 

value and disposal cost. The PBP is measured relative to the least efficient product currently available on the market. 

8B-28
Table 8B.5.38 Average LCC Savings for Non-Integrated GSLs

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience

Net Cost

Average Savings

(2014$)

Residential Sector

0 0% 0.0

1 12% 1.6

Commercial Sector

0 0.0% 0.0

1 5.4% 2.6

Note: The results for each CSL represent the impact a standard set at that CSL, based on base case and standards 

case efficiency distributions calculated in Chapter 9 of this TSD.

8B-29
REFERENCES

1. Energy Information Administration. Annual Energy Outlook 2014 with Projections to

2040. 2014. Washington, D.C. http://www.eia.gov/forecasts/aeo/pdf/0383(2014).pdf.

8B-30
APPENDIX 8C. DISCOUNT RATE DISTRIBUTIONS

TABLE OF CONTENTS

8C.1 INTRODUCTION .........................................................................................................8C-1

8C.2 DISTRIBUTION OF RATES FOR DEBT CLASSES .................................................8C-1

8C.3 DISTRIBUTION OF RATES FOR EQUITY CLASSES.............................................8C-4

8C.4 DISTRIBUTION OF REAL EFFECTIVE DISCOUNT RATES BY INCOME

GROUP..........................................................................................................................8C-8

8C.5 DISTRIBUTIONS USED FOR COMMERCIAL DISCOUNT RATES ....................8C-11

REFERENCES ........................................................................................................................8C-12

LIST OF TABLES

Table 8C.4.1 Distribution of Real Discount Rates by Income Group.............................8C-10

Table 8C.5.1 Real Interest Rate Distribution for Commercial Buildings........................8C-11

LIST OF FIGURES

Figure 8C.2.1 Distribution of Mortgage Interest Rates ......................................................8C-1

Figure 8C.2.2 Distribution of Home Equity Loan Interest Rates.......................................8C-2

Figure 8C.2.3 Distribution of Credit Card Interest Rates...................................................8C-2

Figure 8C.2.4 Distribution of Installment Loan Interest Rates...........................................8C-3

Figure 8C.2.5 Distribution of Other Residence Loan Interest Rates..................................8C-3

Figure 8C.2.6 Distribution of Other Lines of Credit Loan Interest Rates ..........................8C-4

Figure 8C.3.1 Distribution of Annual Rate of Return on CDs ...........................................8C-5

Figure 8C.3.2 Distribution of Annual Rate of Return on Savings Bonds...........................8C-5

Figure 8C.3.3 Distribution of Annual Rate of Return on Corporate AAA Bonds..............8C-6

Figure 8C.3.4 Distribution of Annual Rate of Savings Accounts.......................................8C-6

Figure 8C.3.5 Distribution of Annual Rate of Money Market Accounts ...........................8C-7

Figure 8C.3.6 Distribution of Annual Rate of Return on S&P 500....................................8C-7

Figure 8C.3.7 Distribution of Annual Rate of Return on Mutual Funds............................8C-8

Figure 8C.4.1 Distribution of Real Discount Rates by Income Group...............................8C-9

8C-i
APPENDIX 8C. DISCOUNT RATE DISTRIBUTIONS

8C.1 INTRODUCTION

The U.S. Department of Energy (DOE) derived discount rates for the life-cycle cost (LCC) 

analysis using data on interest or return rates for various types of debt and equity to calculate a 

real effective discount rate for each household in the Federal Reserve Board’s Survey of 

Consumer Finances (SCF) in 1995, 1998, 2001, 2004, 2007, and 2010.1 To account for variation 

among households in rates for each of the types, DOE sampled a rate for each household in its 

building sample from a distribution of discount rates for each of six income groups. This 

appendix describes the distributions used.

8C.2 DISTRIBUTION OF RATES FOR DEBT CLASSES 

Figure 8C.2.1 through Figure 8C.2.6 show the distribution of real interest rates for 

different types of household debt. The data source for the interest rates for mortgages, home 

equity loans, credit cards, installment loans, other residence loans, and other lines of credit is the 

Federal Reserve Board’s SCF in 1995, 1998, 2001, 2004, 2007, and 2010.

1 DOE adjusted the 

nominal rates to real rates using the annual inflation rate in each year. 

Using the appropriate SCF data for each year, DOE adjusted the nominal mortgage 

interest rate and the nominal home equity loan interest rate for each relevant household in the 

SCF for mortgage tax deduction and inflation. In cases where the effective interest rate is equal 

to or below the inflation rate (resulting in a negative real interest rate), DOE set the real effective 

interest rate to zero.

Figure 8C.2.1 Distribution of Mortgage Interest Rates

0%

5%

10%

15%

20%

25%

30%

35%

0.5%1.6%2.5%3.5%4.4%5.4%6.3%7.4%8.5%9.4%

10.4%11.6%12.5%13.2%14.4%16.6%22.8%

Probability

Real Interest Rate

8C-1
Figure 8C.2.2 Distribution of Home Equity Loan Interest Rates

Figure 8C.2.3 Distribution of Credit Card Interest Rates

0%

5%

10%

15%

20%

25%

30%

0.4%1.5%2.5%3.5%

4.5%5.4%6.4%7.5%8.4%9.4%

10.5%11.5%12.5%13.8%14.7%

15.7%16.6%17.1%22.0%

Probability

Real Interest Rate

0%

1%

2%

3%

4%

5%

6%

7%

8%

9%

0.0%2.5%4.5%6.6%8.6%

10.5%12.5%14.7%16.4%18.4%20.4%22.7%24.7%26.8%28.5%

Probability

Real Interest Rate

8C-2
Figure 8C.2.4 Distribution of Installment Loan Interest Rates

Figure 8C.2.5 Distribution of Other Residence Loan Interest Rates

0%

5%

10%

15%

20%

25%

30%

35%

40%

0.0%2.4%4.5%6.6%8.5%

10.5%12.5%14.7%16.4%18.4%20.5%22.5%24.6%26.8%28.5%

Probability

Real Interest Rate

0%

2%

4%

6%

8%

10%

12%

14%

16%

18%

0.2%1.5%2.5%3.5%4.5%5.5%6.5%7.5%8.6%9.4%

10.4%11.5%12.5%13.1%14.7%15.7%16.6%

Probability

Real Interest Rate

8C-3
Figure 8C.2.6 Distribution of Other Lines of Credit Loan Interest Rates

8C.3 DISTRIBUTION OF RATES FOR EQUITY CLASSES

Figure 8C.3.1 through Figure 8C.3.7 show the distribution of real interest rates for 

different types of equity. Data for equity classes are not available from the Federal Reserve 

Board’s SCF, so DOE derived data for these classes from national-level historical data (1984-

2013). The interest rates associated with certificates of deposit (CDs),2 savings bonds,3 and AAA 

corporate bonds4 are from Federal Reserve Board time-series data. DOE assumed rates on 

checking accounts to be zero. Rates on savings and money market accounts are from Cost of 

Savings Index data.

5 The rates for stocks are the annual returns on the Standard and Poor’s 

(S&P) 500.

6 The mutual fund rates are a weighted average of the stock rates (two-thirds weight) 

and the bond rates (one-third weight) in each year. DOE adjusted the nominal rates to real rates 

using the annual inflation rate in each year.

0%

2%

4%

6%

8%

10%

12%

0.1%2.5%4.5%6.6%8.6%

10.5%12.5%14.7%16.4%

18.4%20.2%

22.6%25.4%

Probability

Real Interest Rate

8C-4
Figure 8C.3.1 Distribution of Annual Rate of Return on CDs

Figure 8C.3.2 Distribution of Annual Rate of Return on Savings Bonds

-0.04

-0.02

0

0.02

0.04

0.06

0.08

19841986

19881990

1992199419961998200020022004200620082010

2012

Annual Rate of Return (%)

Year

CDs (Average of 12 and 30 month)

0.0%

1.0%

2.0%

3.0%

4.0%

5.0%

6.0%

7.0%

8.0%

9.0%

198419861988199019921994199619982000200220042006200820102012

Annual Rate of Return (%)

Year

Savings Bonds

8C-5
Figure 8C.3.3 Distribution of Annual Rate of Return on Corporate AAA Bonds

Figure 8C.3.4 Distribution of Annual Rate of Savings Accounts

0.0%

1.0%

2.0%

3.0%

4.0%

5.0%

6.0%

7.0%

8.0%

9.0%

198419861988199019921994199619982000200220042006200820102012

Annual Rate of Return (%)

Year

AAA Corporate Bonds

-0.5%

0.0%

0.5%

1.0%

1.5%

2.0%

2.5%

3.0%

198419861988199019921994199619982000200220042006200820102012

Annual Rate of Return (%)

Year

Savings Accounts

8C-6
Figure 8C.3.5 Distribution of Annual Rate of Money Market Accounts

Figure 8C.3.6 Distribution of Annual Rate of Return on S&P 500

-1.0%

0.0%

1.0%

2.0%

3.0%

4.0%

5.0%

6.0%

198419861988199019921994199619982000200220042006200820102012

Annual Rate of Return (%)

Year

Money Market Accounts

-40.0%

-30.0%

-20.0%

-10.0%

0.0%

10.0%

20.0%

30.0%

40.0%

198419861988199019921994199619982000200220042006200820102012

Annual Rate of Return (%)

Year

Stocks (S&P 500)

8C-7
Figure 8C.3.7 Distribution of Annual Rate of Return on Mutual Funds

8C.4 DISTRIBUTION OF REAL EFFECTIVE DISCOUNT RATES BY INCOME 

GROUP

Figure 8C.4.1 and Table 8C.4.1 present the distributions of real discount rates for each 

income group.

-30.0%

-20.0%

-10.0%

0.0%

10.0%

20.0%

30.0%

1984198619881990199219941996

19982000

200220042006200820102012

Annual Rate of Return (%)

Year

Mutual Funds

8C-8
Figure 8C.4.1 Distribution of Real Discount Rates by Income Group

0%

5%

10%

15%

20%

25%

0.0% 5.0% 10.0% 15.0% 20.0%

Share of Individuals in Group (%)

Real Effective Discount Rate (%)

Group 1

Group 2

Group 3

Group 4

Group 5

Group 6

8C-9
Table 8C.4.1 Distribution of Real Discount Rates by Income Group 

DR Bin

Income Group 1 Income Group 2 Income Group 3 Income Group 4 Income Group 5 Income Group 6

(1-20 percentile) (21-40 percentile) (41-60 percentile) (61-80 percentile) (81-90 percentile) (90-99 percentile)

rate weight rate weight rate weight rate weight rate weight rate weight

0-1 0.5% 0.238 6% 0.152 0.6% 0.104 0.6% 0.077 0.6% 0.056 0.6% 0.057

1-2 1.6% 0.110 1.6% 0.120 1.6% 0.105 1.6% 0.146 1.6% 0.142 1.6% 0.185

2-3 2.5% 0.087 2.5% 0.112 2.6% 0.131 2.5% 0.205 2.5% 0.219 2.5% 0.207

3-4 3.5% 0.117 3.5% 0.137 3.5% 0.164 3.5% 0.173 3.5% 0.200 3.5% 0.178

4-5 4.5% 0.097 4.5% 0.113 4.5% 0.136 4.5% 0.129 4.5% 0.153 4.5% 0.144

5-6 5.5% 0.083 5.5% 0.084 5.5% 0.100 5.5% 0.093 5.5% 0.098 5.5% 0.120

6-7 6.5% 0.058 6.5% 0.062 6.5% 0.075 6.5% 0.067 6.5% 0.063 6.4% 0.079

7-8 7.5% 0.036 7.5% 0.051 7.6% 0.054 7.4% 0.041 7.4% 0.029 7.3% 0.011

8-9 8.5% 0.036 8.4% 0.039 8.4% 0.034 8.5% 0.015 8.4% 0.012 8.5% 0.005

9-10 9.5% 0.017 9.5% 0.018 9.5% 0.017 9.5% 0.010 9.5% 0.008 9.6% 0.005

10-11 10.5% 0.014 10.5% 0.019 10.5% 0.013 10.5% 0.011 10.6% 0.004 10.7% 0.004

11-12 11.5% 0.010 11.5% 0.015 11.5% 0.014 11.5% 0.007 11.4% 0.004 11.7% 0.001

12-13 12.5% 0.011 12.5% 0.012 12.5% 0.009 12.4% 0.005 12.4% 0.002 12.4% 0.002

13-14 13.6% 0.012 13.5% 0.008 13.5% 0.009 13.5% 0.004 13.5% 0.002 13.3% 0.001

14-15 14.6% 0.016 14.6% 0.014 14.6% 0.009 14.5% 0.005 14.6% 0.003 14.2% 0.001

15-16 15.5% 0.011 15.5% 0.010 15.5% 0.006 15.6% 0.004 15.6% 0.002 15.3% 0.000

16-17 16.5% 0.013 16.5% 0.009 16.5% 0.004 16.5% 0.003 16.5% 0.001 0.0% 0.000

17-18 17.5% 0.009 17.6% 0.006 17.5% 0.005 17.5% 0.003 17.6% 0.001 17.7% 0.001

18-19 18.4% 0.005 18.5% 0.005 18.6% 0.003 18.4% 0.001 18.2% 0.000 0.0% 0.000

19-20 19.4% 0.006 19.4% 0.004 19.4% 0.002 19.7% 0.000 19.7% 0.000 19.4% 0.000

20-21 20.6% 0.004 20.4% 0.002 20.5% 0.001 20.3% 0.001 20.5% 0.000 20.3% 0.000

21-22 21.4% 0.003 21.4% 0.002 21.4% 0.001 21.5% 0.001 0.0% 0.000 21.4% 0.000

22-23 22.5% 0.002 22.4% 0.001 22.6% 0.001 22.9% 0.000 22.8% 0.000 22.3% 0.000

23-24 23.6% 0.001 23.4% 0.001 23.6% 0.001 0.0% 0.000 0.0% 0.000 24.0% 0.000

24-25 24.6% 0.001 24.5% 0.000 24.6% 0.000 24.1% 0.000 24.3% 0.000 0.0% 0.000

25-26 25.4% 0.001 25.4% 0.001 25.5% 0.000 0.0% 0.000 0.0% 0.000 0.0% 0.000

26-27 26.5% 0.001 26.5% 0.000 26.4% 0.000 0.0% 0.000 0.0% 0.000 0.0% 0.000

27-28 27.8% 0.000 27.6% 0.000 27.8% 0.000 0.0% 0.000 0.0% 0.000 0.0% 0.000

28-29 28.2% 0.000 0.0% 0.000 0.0% 0.000 0.0% 0.000 0.0% 0.000 0.0% 0.000

29-23 29.9% 0.000 29.3% 0.000 0.0% 0.000 0.0% 0.000 0.0% 0.000 0.0% 0.000

>30 59.1% 0.001 142.7% 0.002 0.0% 0.000 53.3% 0.000 0.0% 0.000 0.0% 0.000

8C-10
8C.5 DISTRIBUTIONS USED FOR COMMERCIAL DISCOUNT RATES

Table 8C.4.1 shows the probability distribution used for commercial discount rates by different 

commercial sector groups:

Table 8C.5.1 Real Interest Rate Distribution for Commercial Buildings

Retail Medical Lodging Food Service Office Education Other

Rate

(%)

Weight

(%)

Rate

(%)

Weight

(%)

Rate

(%)

Weight

(%)

Rate

(%)

Weight

(%)

Rate

(%)

Weight

(%)

Rate

(%)

Weight

(%)

Rate

(%)

Weight

(%)

2.9 6.0 2.9 6.2 2.9 4.5 2.9 4.7 2.9 6.7 -1.3 17.1 2.9 6.4

3.8 11.8 3.6 4.3 3.9 7.1 3.7 14.5 3.7 12.6 0.7 7.3 3.8 5.3

4.5 32.1 4.6 41.9 4.6 15.8 4.6 37.1 4.5 31.2 1.5 14.6 4.6 41.0

5.5 31.9 5.5 38.3 5.6 30.7 5.6 35.7 5.5 27.8 2.7 7.3 5.4 31.3

6.5 15.9 6.3 7.3 6.4 20.8 6.5 7.7 6.4 15.4 3.6 31.7 6.4 11.9

7.3 1.8 7.5 1.7 7.4 9.2 7.3 0.3 7.5 3.5 4.2 9.8 7.3 2.6

8.2 0.4 8.6 0.3 8.4 5.1 8.3 0.0 8.4 1.5 5.4 9.8 8.3 1.0

9.3 0.0 9.6 0.1 9.3 3.7 9.2 1.2 6.1 2.4 9.5 0.4

10.0 0.0 10.6 0.0 10.6 3.2 10.3 0.0 10.4 0.1

11.4 0.0 11.6 0.0

12.3 0.0

13.0 0.0

8C-11
REFERENCES

1. Board of Governors of the Federal Reserve System. Survey of Consumer Finances. 1989,

1992, 1995, 1998, 2001, 2004, 2007, and 2010. (Last accessed October 10, 2014.) http://

www.federalreserve.gov/econresdata/scf/scfindex.htm.

2. Board of Governors of the Federal Reserve System. Federal Reserve Statistical Release,

Selected Interest Rates, Historical Data, Instrument: CDs (secondary market), Maturity:

6-month, Frequency: Annual, Description: Average rate on 6-month negotiable

certificates of deposit (secondary market), quoted on an investment basis. December 19,

2013. (Last accessed September 25, 2014.)

http://www.federalreserve.gov/releases/H15/data.htm.

3. Board of Governors of the Federal Reserve System. Federal Reserve Statistical Release,

Selected Interest Rates, Historical Data, Instrument: State and local bonds, Maturity: 20-

year, Frequency: Monthly, Description: Bond buyer go 20-bond municipal bond index.

(Last accessed October 10, 2014.) http://www.federalreserve.gov/releases/H15/data.htm.

4. Board of Governors of the Federal Reserve System. Federal Reserve Statistical Release,

Selected Interest Rates, Historical Data, Instrument: Corporate bonds/Moody’s Seasoned

AAA, Frequency: Annual, Description: Moody’s yield on seasoned corporate bonds—all

industries, AAA. (Last accessed October 10, 2014.)

http://www.federalreserve.gov/releases/H15/data.htm.

5. Mortgage-X. Cost of Savings Index (COSI): Historical Data. (Last accessed October 10,

2014.) http://mortgage-x.com/general/indexes/cosi_history.asp.

6. Damodaran, A. Data Page: Historical Returns on Stocks, Bonds and Bills-United States.

2013. (Last accessed February 1, 2013.) http://pages.stern.nyu.edu/~adamodar/.

8C-12
APPENDIX 8D. MODELING OF RARE EARTH PRICE IMPACTS

TABLE OF CONTENTS

8D.1 BACKGROUND .......................................................................................................... 8D-1

8D.2 ANALYSIS................................................................................................................... 8D-2

REFERENCES ......................................................................................................................... 8D-7

LIST OF TABLES

Table 8D.2.1 Estimated CFL Surface Area across Lumen Ranges.................................. 8D-2

Table 8D.2.2 Mass Density, Surface Area and REO Mass Content in CFLs................... 8D-3

Table 8D.2.3 Average Rare Earth Element Mass Percentages used in CFL Triband 

Phosphors.................................................................................................... 8D-3

Table 8D.2.4 Reference Scenario REO Costs .................................................................. 8D-5

LIST OF FIGURES

Figure 8D.1.1 Rare Earth Oxide Historic Prices................................................................ 8D-1

Figure 8D.2.1 Inflation-Adjusted, Triband Phosphor REO Price Index for CFLs ............ 8D-4

8D-i
APPENDIX 8D. MODELING OF RARE EARTH PRICE IMPACTS

8D.1 BACKGROUND

Lamp manufacturers use triband phosphors to increase the efficacy of fluorescent lamps 

and improve their color quality and lumen maintenance. According to DOE’s 2011 Critical 

Materials Strategy (CMS),

1 all CFLs use triband phosphors. Triband phosphors contain certain 

rare earth elements - lanthanum (La), cerium (Ce), europium (Eu), terbium (Tb), and yttrium (Y) 

- which, according to manufacturer interviews provided to the U.S. Department of Energy 

(DOE), are generally purchased by lamp manufacturers in their oxide form. Between the second

quarter of 2010 and the fourth quarter of 2011, the price of rare earth oxides (REOs) increased 

sharply, causing concerns about the resulting price impacts on fluorescent lamps. However, as 

shown in Figure 8D.1.1, REO prices2 have recently fallen considerably. 

Figure 8D.1.1 Rare Earth Oxide Historic Pricesa

a The reported oxide prices correspond to 99% purity minimum Free-on-Board (FOB) China for Ce, La, and Tb, 

99.9% purity minimum FOB China for Eu, and 99.999% purity minimum FOB China for Y. 

8D-1

 
DOE has examined the REO market and considers future rare earth prices significantly 

uncertain. DOE incorporates the potential impact of higher rare earth prices and price volatility 

in a scenario of the life-cycle cost (LCC) and payback period (PBP) analyses (chapter 8 of this 

TSD), as well as of the shipments and national impact assessment analyses (chapters 9 and 10 of 

this TSD). This appendix describes the approach DOE took to projecting the potential impacts of 

volatile rare earth prices on future prices of CFLs, for use in analyzing the LCC and PBP, lamp 

shipments, energy savings, and net present value of candidate standard levels (CSLs) considered 

in this preliminary analysis. Note that in this analysis, DOE assumes that the REO content in 

LED GSLs is negligible.

8D.2 ANALYSIS

DOE analyzed the impact of REO prices on CFL costs based on historical prices of REOs 

(Figure 8D.1.1) and on estimates of the average rare earth element content in phosphors of 

CFLs.

According to the 2011 CMS, CFLs are assumed to use a maximum of about to 1.5 g/bulb 

of tri-band phosphor, with 60% of that content representing rare earth mass content.

b Other 

sources of information confirm the 2011 CMS estimate of 1.5 g/bulb in phosphor.

3

As discussed in chapter 8 of this TSD, DOE analyzed GSLs in 4 different lumen ranges 

for the integrated low-lumen product class (310-749, 750-1049, 1050-1489, and 1490-1999 

lumens). In addition, the integrated high-lumen product class covers the 2000-2600 lumen range. 

Because the amount of phosphor included in fluorescent lamps is approximately 

proportional to their surface area,

1

using primarily manufacturer catalogs, DOE reviewed the

sizes and shapes of CFLs across lumen ranges to estimate their surface area. The CFL surface 

area was estimated based on typically observed number of spiral windings in each CFL, the 

spiral diameter, and the CFL spiral tube length, for each lumen range, as shown in Table 8D.2.1.

Table 8D.2.1 Estimated CFL Surface Area across Lumen Ranges

Lumen 

Range

Number of 

CFL Spiral

Windings

CFL Outside 

Diameter 

(Inches)

Spiral Tube 

Length 

(Inches)

CFL Surface 

Area 

(square inches)

310-749 2.5 1.75 11.8 9.3

750-1049 3.5 2 19.2 15.1

1050-1489 4.5 2.25 28.3 22.2

1490-1999 5.5 2.5 38.9 30.5

2000-2600 5.5 2.75 43.2 33.9

Note: CFLs spiral tubes typically have a diameter equal to 1⁄4 of an inch (T2)

According to the 2011 CMS, the rare earth mass content per unit area for linear 

fluorescent lamps ranges between 3 and 4 milligrams per square centimeter of lamp surface area 

(mg/cm2). For this analysis, DOE assumed that CFLs contain 4mg/cm2. Using this estimate, and 

b These estimates were based on manufacturer interviews.

8D-2

 
the surface area of CFLs from Table 8D.2.1, DOE calculated the REO mass content of CFLs for 

each lumen range, as shown in 

Table 8D.2.2.

c

Table 8D.2.2 Mass Density, Surface Area and REO Mass Content in CFLs

Lumen Range

Mass Content 

per surface 

area (mg/cm2)

Spiral Tube 

Surface Area 

(cm2)

REO Mass

Content 

(g/bulb)

310-749

4

59.7 0.24

750-1049 97.5 0.39

1050-1489 143.3 0.57

1490-1999 197.0 0.79

2000-2600 218.9 0.88

Table 8D.2.3 shows the average percentage contribution of the five rare earth elements 

used in CFL triband phosphors according to the 2011 CMS.

Table 8D.2.3 Average Rare Earth Element Mass Percentages used in CFL Triband

Phosphors

Element Content

Lanthanum 8.5%

Cerium 20.0%

Europium 4.5%

Terbium 5.0%

Yttrium 62.0%

TOTAL 100%

For this rulemaking, using the data shown in Figure 8D.1.1, DOE calculated a triband

phosphor price index for CFLs that reflects the rare earth element mass percentages reported in

Table 8D.2.3, and the corresponding rare earth oxide prices reported on metalpages.com.

d The 

index, shown in Figure 8D.2.1, is inflation adjusted and normalized with respect to the average 

triband phosphor cost between 2006 and 2009, the longest period prior to the peak for which data 

for all relevant REOs were available. As shown in the figure, the index rose rapidly in 2010 from 

a relatively stable period to a peak in 2011, after which it dropped almost monotonically, to a 

point near its pre-peak level. 

c Based on the assumption that the rare earth element mass content is 60% of the triband phosphor content, the 

calculated maximum REO content which is 0.88 g per bulb for the 2000-2600 lumen range, is consistent with the 

estimated maximum triband phosphor content in CFLs (1.5g). (60% of 1.5g is 0.9g).

d This analysis assumes that mass fractions of REOs needed for manufacturing are the same as the elemental mass 

fractions in Table 8D.2.3.

.

8D-3

 
Figure 8D.2.1 Inflation-Adjusted, Triband Phosphor REO Price Index for CFLs 

The future trajectory of REO prices is highly uncertain. Therefore, DOE developed an 

alternative scenario for future REO prices for the LCC, PBP, shipments, and national impact 

analyses. The reference assumption is that REO prices remain constant at their June 2014 level. 

These data were used in this preliminary analysis because they represented the most recent price 

data available at the time the analysis was performed. The high REO price scenario uses the 

REO price midway between the 2011 peak and the 2006 – 2009 baseline average price, referred 

to here as the mid-point REO price.

DOE used the REO mass content and REO mass percentages in CFLs from Table 8D.2.2

and Table 8D.2.3, respectively, to determine the inflation adjusted (2014$) reference scenario 

REO cost, based on June 2014 REO prices, for all representative CFLs considered in this 

analysis. Table 8D.2.4 shows the reference scenario REO costs for the representative lamps 

developed in the engineering analysis. These REO costs serve as reference from which to 

account for the potential impacts of potential future higher REO prices. (Table 8D.2.4 also shows 

LEDs for completeness). 

8D-4
Table 8D.2.4 Reference Scenario REO Costs

Product 

Class CSL Technology Lumen Range

REO 

content 

(gr/bulb)

Reference 

REO Cost 

($2014), 

no tax

Integrated 

Low 

Lumen 

(<2000)

Baseline CFL 750-1049 0.39 $ 0.03 

CSL 1 CFL 750-1049 0.39 $ 0.03 

CSL 2 LED* 750-1049 0 $ - 

CSL 3 LED* 750-1049 0 $ - 

CSL 4 LED* 750-1049 0 $ - 

CSL 5 LED* 750-1049 0 $ - 

Integrated 

High 

Lumen 

(>=2000)

Baseline CFL 2000-2600 0.88 $ 0.07 

CSL 1 CFL 2000-2600 0.88 $ 0.07 

CSL 2 CFL 2000-2600 0.88 $ 0.07 

NonIntegrated

Baseline CFL 1490-1999 0.79 $ 0.06 

CSL 1 CFL 1490-1999 0.79 $ 0.06 

CFL 1490-1999 0.79 $ 0.06 

*Note: DOE assumes in this analysis that the REO content in LED GSLs is negligible

Recognizing that REO costs are only one element of CFL prices, which may have an 

independent trajectory, DOE accounts for REO costs and the balance of lamps’ costs 

independently. The price of each CFL, as a function of the REO cost, is expressed as follows: 

pp(yy)CCCCCC = mmrr × �ccRRRRRR,ss ssss + cc(yy) ee �

Eq. 8D.1

Where:

pp(yy)CCCCCC = lamp price at year y,

mmrr = markup of manufacturer cost to retail price: estimated as 2.31,

e

ccRRRRRR,ssssssss = REO cost for price scenario (reference, or mid-point), and

cc(yy) ee = cost to manufacture lamp at year y, excluding CCRRRRRR,ssssssss.

DOE addresses price learning in its shipments and national impact analysis (NIA)

calculations. However, because price learning is not applicable to raw materials inputs to 

manufacturing and, therefore, is not applicable to the REO part of lamps costs, Eq. 8D.1 was 

rewritten in the following way for use in the shipments and NIA models:

e This estimate is based on the markup of manufacturer cost to retail price used in the 2014 general service 

fluorescent lamp and incandescent reflector lamp (GSFL-IRL) notice of proposed rulemaking energy conservation 

standard.4

8D-5

 
pp(yy)CCCCCC = mmrr × �SSSS × ccRRRRRR,RR RR + PP (yy) × �

PPCCCCCC,00

mmrr

− ccRRRRRR,RR RR��

Eq. 8D.2

Where:

SSSS = scenario multiplier for REO cost scenarios (described below),

ccRRRRRR,RR RR = reference scenario REO cost per CFL (itemized in Table 8D.2.4),

PPPPPP(yy) = price learning correction factor at year y (described below) and,

ppCCCCCC,0 = 2014 ‘weighted average’ CFL price.

The scenario multiplier (SSSS) is based on the triband phosphor price index, normalized to 

its reference scenario value. The reference and the mid-point scenario correspond to the price 

index of the mid-point REO price, and the index of the most recent REO price (June 2014),

respectively: 

• Reference scenario, SSSS = 1

• Mid-point scenario, SSSS = 4.5

The price learning correction factor (PPPPPP) is defined as follows (see chapter 9 of this 

TSD for more details):

PP (yy) = (

XX(yy)

XX(yy00)

)−bb

Eq. 8D.3

Where:

XX(yy) = the cumulative production (total shipments) of CFLs between the year of 

introduction to the market and year y,

XX(yy0) = the cumulative production (total shipments) of CFLs between the year of 

introduction the market and the initial year of the forecasting period, yy0, and

bb = the learning rate parameter, as defined in chapter 9 of this TSD.

The ‘weighted average’ 2014 CFL price (ppCCCCCC,0) is derived from chapter 6 of this 

preliminary analysis, Product Price Determination.

8D-6
REFERENCES

1. U.S. Department of Energy. Critical Materials Strategy. 2011. Washington, D.C. Report

No. DOE/PI-0009. http://energy.gov/sites/prod/files/DOE_CMS2011_FINAL_Full.pdf.

2. Metal-Pages. Historical Prices. 2014. (Last accessed June 19, 2014.) http://

www.metal-pages.com/.

3. Environmental Statement for GE FLUORESCENT LAMPS. April 21, 2006. (Last

accessed November 6, 2014.) http://www.rentokil.nl/files/file_367565.pdf.

4. U.S. Department of Energy- Office of Energy Efficiency and Renewable Energy. Notice

of Proposed Rulemaking Technical Support Document Energy Conservation Program for

Consumer Products and Certain Commercial and Industrial Equipment: General Service

Fluorescent Lamps and Incandescent Reflector Lamps. 2014. Washington, D.C.

http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/24.

8D-7
APPENDIX 8E. LIFETIME MODELING

TABLE OF CONTENTS

8E.1 INTRODUCTION .........................................................................................................8E-1

8E.2 LIFETIME MODELING ASSUMPTIONS ..................................................................8E-1

8E.3 RESIDENTIAL GSL HOURS OF USE........................................................................8E-2

8E.4 COMMERCIAL GSL HOURS OF USE.......................................................................8E-5

8E.5 PERCENTAGE OF EXPECTED LIFE CONSUMED AS A FUNCTION OF 

TIME..............................................................................................................................8E-6

8E.6 CALCULATING SURVIVAL PROBABILITY AS A FUNCTION OF GSL 

AGE ...............................................................................................................................8E-7

REFERENCES ........................................................................................................................8E-12

LIST OF TABLES

Table 8E.6.1 Weibull Survival Model Parameters for the “Renovation-Driven 

Lifetime” and “Early-Replacement Lifetime” Scenarios ............................8E-9

Table 8E.6.2 Resulting Median GSL Lifetimes by Scenario, Sector, and GSL Type ....8E-11

LIST OF FIGURES

Figure 8E.3.1 Weighted Daily HOU Distribution for Residential GSLs ...........................8E-3

Figure 8E.3.2 Estimated Percentage of a CFL GSL’s Rated Life Obtained as a 

Function of Average On-Time Cycle Length ..............................................8E-3

Figure 8E.4.1 Weighted Daily HOU Distribution for Commercial GSLs..........................8E-6

Figure 8E.6.1 Survival Probability as a Function of GSL Age for Residential and 

Commercial, and CFL and LED GSLs......................................................8E-10

8E-i
8E.1 INTRODUCTION

This appendix describes the methodology the U.S. Department of Energy (DOE) used to 

model the distribution of general service lamp (GSL) lifetimes. The lifetime distribution of a 

GSL is used as an input to the life-cycle cost and payback period analysis (chapter 8 of this TSD)

and the shipments analysis (chapter 9 of this TSD). DOE modeled GSL lifetime distributions

separately for the residential and commercial sectors and for compact-fluorescent lamp (CFL)

and light-emitting diode (LED) GSLs. DOE used Weibull survival probability functions in 

combination with the lamp’s rated lifetime (in hours), sector-specific hours-of-use (HOU)

distributions, and effects of on-time cycle lengtha (in the case of residential CFL GSLs) to model 

the probability of survival for a given GSL as a function of lamp age.

8E.2 LIFETIME MODELING ASSUMPTIONS

The method DOE used to model product lifetime distributions incorporates several key 

assumptions: 

• A Weibull distribution appropriately models GSL lifetime. 

• The GSL survival function does not change form through time. 

• The GSL lifetime models have a Weibull shape parameter (ββ) of at least 2. 

• A log-normal distribution appropriately models the variation of on-cycle time by 

residential room types.

• Switching effects do not negatively impact the service life of LED GSLs or commercial 

CFL GSLs.

• Dimming has no effect on CFL or LED GSL lifetime.

• A triangular distribution with a mean corresponding to the building types’ mean daily 

HOU captures the variation in commercial daily hours or use.

Many of these assumptions reflect analytical choices made by DOE. First, DOE assumed

that a Weibull distribution is the appropriate distribution to use for observed rates of lamp 

retirement, which may include other factors outside of failure rate (e.g., retirement due to reasons 

other than product failure). This distribution is the standard one used in lifetime analyses, but the 

possibility exists that the model may not reflect actual real-world experience. Next, DOE 

constrained the Weibull models’ shape parameter (kk) to values larger than two in order to avoid 

potential nonsensical behavior, such as sharp changes in purchaser behavior or appliance 

survival immediately following the delay period (dd). DOE also assumed log-normal and 

triangular distributions adequately capture the variation of on-cycle time by residential room 

types and daily HOU by commercial building types, respectively. DOE took this approach in this 

preliminary analysis as a first-order way to account for inherent variability in the face of 

insufficient data. DOE further assumed on-time cycle length does not affect the service life of 

LED GSLs (based on insufficient data to suggest otherwise) or the service life of commercial 

CFL GSLs, because DOE expects commercial GSLs to have long enough on-time cycle lengths 

so as to not negatively impact the service life of CFL GSLs. Last, DOE assumed that dimming 

does not affect CFL or LED GSL lifetime.

a On-time cycle length is the amount of time a GSL is switched on over one on-off cycle.

8E-1

 
8E.3 RESIDENTIAL GSL HOURS OF USE

For the residential sector, DOE mapped daily HOU metering data from the Northwest 

Energy Efficiency Alliance’s Residential Building Stock Assessment1 to the room types used in 

the 2012 Residential Lighting End-Use Consumption Study (RLEUCS).2 DOE then used Eq. 

8E.1 to combine these HOU distributions by room type into a single HOU distribution. Each 

room type was assigned a weight, which DOE calculated as the product of the average number of 

GSLs for that room type (reported in RLEUCS) and the number of households represented with 

that room type in each of the 2009 Residential Energy Consumption Survey’s (RECS)

3

reportable domains

b

. 

FFrrrrrr(HHHHHH) = �ffii(HHHHHH)

nn

ii=1

× wwii

Eq. 8E.1

Where:

FFrrrrrr(HHHHHH) = the weighted residential HOU frequency distribution across all RLEUCS room 

types, in hours,

ii = the room type,

nn = the total number of RLEUCS room types,

ffii(HHHHHH) = the daily HOU frequency distribution for room type ii, in hours, and

wwii = the weight for room type ii.

Figure 8E.3.1 shows the final, weighted HOU distribution for residential GSLs with the 

median (1.45 h/day) and mean (2.37 h/day) of the distribution indicated. DOE notes the slight

difference in the mean daily residential HOU for these distributions, compared to the national 

average of 2.33 h/day calculated in the energy use analysis (chapter 7 of this TSD). This 

difference is the result of using different methodologies and data sources to estimate the daily 

residential HOU for GSLs in the two cases. Because DOE needed HOU distributions for GSL 

lifetime modeling, it was able only to use the subset of the data sources that provided such 

values. In the energy use analysis, by contrast, DOE only needed an average daily HOU point 

value, so all available data sources were used, yielding a slightly different average value.

b The 2009 RECS separated the 50 states (plus the District of Columbia) into 27 reportable domains, which allowed 

the survey data to be analyzed across smaller geographic regions, when compared to using the U.S. Census Bureau’s 

census regions and divisions.

8E-2

 
Note: The mean and median daily HOU are represented by the green and blue dashed lines, respectively.

Figure 8E.3.1 Weighted Daily HOU Distribution for Residential GSLs

DOE accounted for the effect of on-time cycle length for residential CFL GSLs by using 

average on-time cycle length residential metering data from an American Council for an EnergyEfficient Economy (ACEEE) report4 (hereafter referred to as “the ACEEE report”) and a report 

presented to the California Public Utilities Commission (CPUC)5 containing the measured 

lifetime of CFL GSLs as a function of on-time cycle length (hereafter referred to as “the CPUC 

report”). Figure 8E.3.2 is a plot summarizing the measured lifetime results reported in the CPUC 

report.

Note: Adapted from the CPUC report.5

Figure 8E.3.2 Estimated Percentage of a CFL GSL’s Rated Life Obtained as a Function 

of Average On-Time Cycle Length

8E-3
To account for variation in on-time cycle length by room type, DOE developed lognormal probability distribution functions based on the average on-time cycle length by room type 

and the provided histogram of on-time cycle lengths across all room types from the ACEEE 

report. The log-normal probability density function takes the form: 

PP(xx) = 1

xx√2ππππ

ee

−(ln xx−μμ)2

2σσ2

Eq. 8E.2

Where:

PP(xx) = the log-normal probability density at xx,

μμ = the mean of the natural logarithm of xx, and

= the standard deviation of the natural logarithm of xx.

For each room type, DOE set μμ to the natural log of the mean on-time cycle length for 

that room type. Then, DOE re-binned the raw on-time cycle length histogram data from the 

ACEEE report into eight bins,c which resulted in a new histogram of the raw data that more 

closely resembles a log-normal distribution. For each room type, DOE set

PP(0 min ≤ xx < 2 min) equal to the percentage of loggers across all room types with on-time 

cycle lengths up to 2 minutes (i.e., the percentage of loggers in the first bin). Given μμ and a point 

at which PP(xx) is known, DOE was then able to back-calculate to optimally fit the log-normal 

distribution for each room type. With the log-normal distribution generated for each room type, 

DOE then discretized the distribution functions by assigning the cumulative probability across 

the eight bins of on-time cycle lengths. With the binned probabilities calculated, DOE 

determined the reduced life of residential CFL GSLs for each room type using the following 

equation:

llrrrrrr(llrrrrrrrrrr) = llrrrrrrrrrr × �PP(xx) × llff ff(xx)

8

xx=1

Eq. 8E.3

Where:

llrrrrrr(llrrrrrrrrrr) = the reduced life of a residential CFL GSL as a function of the rated lifetime, in 

hours,

llrrrrrrrrrr = the rated life of a residential CFL GSL (from the engineering analysis), in hours,

xx = the on-time cycle length bin,

PP(xx) = the log-normal distribution probability in bin xx, and

llff ff(xx) = the expected fraction of a residential CFL GSL’s rated life available with on-time 

cycle length of bin x, obtained from Figure 8E.3.2.

DOE assumed—based on insufficient data to suggest otherwise—that on-time cycle 

length does not affect the lifetime of LED GSLs (regardless of sector). 

c The minimum on-time cycle length for each of the eight bins DOE used are: 0 min, 2 min, 5 min, 15 min, 30 min, 

1.5 h, 4 h, and 23 h.

8E-4

 
8E.4 COMMERCIAL GSL HOURS OF USE

For the commercial sector, DOE used the average daily HOU provided in the energy use 

analysis (chapter 7 of this TSD) for each of the building types analyzed in the 2003 Commercial 

Building Energy Consumption Survey (CBECS).6 DOE then accounted for variability in daily 

HOU by developing triangular HOU distributions for each CBECS building type. The triangular 

distribution is a continuous probability distribution taking the form:

PP(xx) =

⎩

⎪

⎪

⎪

⎨

⎪

⎪

⎪

⎧ 0 for xx < aa

2(xx − aa)

(bb − aa)(cc − aa) for aa ≤ xx < cc

2

bb − aa

for xx = cc

2(bb − xx)

(bb − aa)(bb − cc) for cc < xx ≤ bb

0 for bb < xx

Eq. 8E.4

Where:

PP(xx) = the triangular probability density at xx,

aa = the lower limit of the triangular distribution, in hours,

bb = the upper limit of the triangular distribution, in hours, and

cc = the mode of the triangular distribution, in hours.

DOE set the mode of each distribution to the respective building type’s average daily 

HOU. The lower and upper limits of the building types’ distributions were set to the distribution 

mode less 20% and the distribution mode plus 20%, respectively (e.g., with a mode of 10 HOU 

per day, the base of the triangular distribution would start at 8 hours and end at 12 hours). DOE 

then combined the triangular HOU distributions using the building weights provided in the 

energy use analysis (chapter 7 of this TSD). The following equation was used to calculate the 

weighted commercial GSLs HOU distribution:

FF cccccc(HHHHHH) = �ffii(HHHHHH)

nn

ii=1

× wwii

Eq. 8E.5

Where:

FF cccccc(HHHHHH) = the weighted commercial HOU frequency distribution across all CBECS 

building types, in hours,

ii = the building type,

nn = the total number of CBECS building types,

ffii(HHHHHH) = the daily HOU frequency distribution for building type ii, in hours, and

wwii = the weight for building type ii.

8E-5
Figure 8E.4.1 shows the final, weighted HOU distribution for commercial GSLs with the median 

(10.1 h) and mean (10.7 h) of the distribution indicated.

Note: The mean and median daily HOU are represented by the green and blue dashed lines, respectively.

Figure 8E.4.1 Weighted Daily HOU Distribution for Commercial GSLs

DOE assumed that on-time cycle length does not affect commercial CFL GSLs, because 

DOE expects commercial GSLs to have long enough on-time cycle lengths so as to not 

negatively impact the service life of CFL GSLs. DOE also notes that—in contrast to the 

residential sector—the daily energy use analysis for the commercial sector (see chapter 7 of this 

TSD) uses the same data that DOE used in this analysis, resulting in equal mean daily HOU

estimates. The only difference is that in this case DOE assumed a distribution of daily HOU for 

commercial buildings, which was unnecessary for the energy use analysis. 

8E.5 PERCENTAGE OF EXPECTED LIFE CONSUMED AS A FUNCTION OF 

TIME

As a final step before modeling GSL lifetime distributions, DOE calculated the percent of 

a GSL’s expected life consumed as a function of the GSL age. DOE used the following set of 

equations to calculate the percent expected life in each HOU bin (the same bins used to calculate 

residential and commercial GSL HOU distributions) for a GSL that has aged one year:

8E-6
LL cc (AA, hbb) =

⎩

⎪

⎨

⎪

⎧AA ×���

hbb × 365

llrrrrrr,ii

� × wwii�

nn

ii=1

for residential CFL GSLs

AA × �

hbb × 365

llrrrrrrrrrr

� for all other GSLs

Eq. 8E.6

Where:

LL cc (AA, hbb) = the percent of a GSL’s expected life consumed as a function of GSL age and 

HOU bin,

AA = GSL age, in years,

hbb = the daily HOU bin for the residential or commercial sector, in hours,

ii = the room type,

nn = the total number of RLEUCS room types,

llrrrrrr,ii = the reduced life of a residential CFL GSL located in room type ii, in hours,

wwii = the weight for room type ii, and

llrrrrrrrrrr = the rated life of a GSL (from the engineering analysis), in hours.

8E.6 CALCULATING SURVIVAL PROBABILITY AS A FUNCTION OF GSL 

AGE

To calculate the probability of survival as a function of GSL age, DOE applied survival 

functions, which were assumed to have the form of cumulative Weibull distributions. The 

Weibull distribution is a probability distribution commonly used to measure failure rates. Its 

form is similar to an exponential distribution, which models a fixed failure rate, except that a 

Weibull distribution allows for a failure rate that changes over time in a particular fashion. The 

cumulative Weibull distribution takes the general form:

ww (AA) = �ee−�

AA−

λλ �

kk

for AA > dd

1 for AA ≤ dd

Eq. 8E.7

Where:

ww (AA) = the probability that the appliance survives to age AA after its initial installation,

AA = appliance age,

dd = delay parameter, which allows for a delay before any failures occur,

λλ = scale parameter, which would be the decay length in an exponential distribution, and

kk = shape parameter, which determines the way in which the failure rate changes through 

time.

When kk=1, the failure rate remains constant over time, giving the distribution the form of 

a cumulative exponential distribution. In the case of appliances, kk commonly exceeds 1, 

reflecting an increasing failure rate as appliances age.

8E-7
DOE first computed the survival probability distribution assuming the GSL is used for its 

full lifetime, until failure occurs.d For this model, DOE applied a survival function having 

parameters representing the GSL’s probability of survival as a function of the percentage of the 

GSL’s expected service life consumed at a given GSL age. The parameters 

(λλ, kk, dd) = (108.8, 5.5, 0.0) characterize the function, which has mean and median percentages of 

the GSL’s expected service life of 100% and 102%, respectively.e The function is modeled by 

Eq. 8E.8 (assuming dd equals 0):

PP ss ss(AA) = ��ee

−�

LLcccccccc(AA)ii×100

108.8 �

5.5

× wwii�

nn

ii=1

Eq. 8E.8

Where:

PP ss ss(AA) = the probability of survival at age AA assuming the GSL is used for its full lifetime,

until failure,

ii = the HOU bin,

nn = the total number of HOU bins (differs between residential and commercial sectors),

LL cc (AA)ii = the percent of a GSL’s expected life consumed as a function of GSL age and 

HOU bin, and

wwii = the residential or commercial HOU weighting in HOU bin ii.

DOE then considered three GSL lifetime scenarios: one scenario in which all consumers 

use GSLs for the full lifetime of the GSL, which is characterized by Eq. 8E.8, and two other 

scenarios in which lamps may be retired prior to failure. To model the possibility of GSLs being 

retired before they fail, DOE multiplied the first scenario—called the “Rated Lifetime” 

scenario—by a Weibull distribution defined as a function of GSL age. The second scenario, and 

DOE’s reference scenario—called the “Renovation-Driven Lifetime” scenario— truncates the 

“Rated Lifetime” scenario distribution to account for lamp turnover when a renovation or retrofit 

occurs. The third scenario—called the “Early-Retirement Lifetime” scenario—further truncates 

the “Rated Lifetime” scenario distribution to account for the possibility of the service lifetime of 

LED GSLs being similar to the service lifetimes of consumer electronic devices (approximately 

five years). Table 8E.6.1 provides the Weibull model parameters, along with the mean and 

median GSL lifetime of each model, for the “Renovation-Driven Lifetime” and “EarlyRetirement Lifetime” scenarios.

d In the case of LED GSLs, failure is commonly defined as the point at which the GSL’s light output has decreased 

to 70% of its initial light output. This is often referred to as “L70.” 

e DOE derived this Weibull survival function from a plot of fluorescent lamp mortality as a function of the percent 

of average life from the 9th edition of the Illuminating Engineering Society of North America’s Lighting Handbook.7

8E-8

 
Table 8E.6.1 Weibull Survival Model Parameters for the “Renovation-Driven Lifetime” 

and “Early-Replacement Lifetime” Scenarios

GSL Lifetime Scenario

Weibull Survival 

Function Parameters GSL Lifetime

Scale 

(λλ)

Shape

(kk)

Delay 

(dd)

Mean

(years)

Median

(years)

Renovation-Driven Lifetime 21.5 6.0 0 20 20

Early-Replacement Lifetime 5.55 3.5 0 5 5

Eq. 8E.9 is the general form of the equation DOE used to model the “Renovation-Driven 

Lifetime” and “Early-Replacement Lifetime” scenarios. For the each scenario, the corresponding 

shape and scale parameters provided in Table 8E.6.1 were used (the delay parameter equaled 

zero for both scenarios).

PP ss ss, (AA) = PP ss ss(AA) × �1 − ee

−� AA

λλ ss ssss �

kk ss ssss �

Eq. 8E.9

Where:

PP ss ss, (AA) = the probability of survival at age AA for the “Renovation-Driven Lifetime” 

or “Early-Replacement Lifetime” scenario,

PP ss ss(AA) = the probability of survival at age AA assuming the GSL is used for its full lifetime, 

until failure (i.e., the probability of survival in the “Rated Lifetime” scenario),

AA = the GSL age, in years,

λλ = the scale parameter for the “Renovation-Driven Lifetime” or “Early-Replacement 

Lifetime” scenario, and

kk = the shape parameter for the “Renovation-Driven Lifetime” or “EarlyReplacement Lifetime” scenario.

Figure 8E.6.1 is an example summary plot of the survival probability models for the 

scenarios considered as a function of GSL age. CFL GSLs rated at 10,000 hours, 12,000 hours, 

17,000 hours, and 20,000 hours, and LED GSLs rated at 25,000 hours were provided in the 

engineering analysis (see chapter 5 of this TSD), and DOE computed lifetime distributions for 

each of these cases in each lifetime scenario. To provide an example of the lifetime distributions, 

Figure 8E.6.1 displays the lifetime distributions for CFLs rated at 10,000 hours and LEDs rated 

at 25,000 hours. The top and bottom rows contain the models for CFL and LED GSLs, 

respectively, and the left and right columns contain the models for the residential and 

commercial sectors, respectively. Furthermore, the dashed vertical lines on the plots indicate the 

models’ median GSL lifetime (i.e., the GSL age at which the probability of survival equals 

50%).

8E-9
Note: The CFL and LED GSLs represented here have rated lifetimes of 10,000 hours and 25,000 hours, respectively. 

The solid black, green, and blue lines represent the resultant “Rated Lifetime,” “Renovation-Driven Lifetime,” and 

“Early-Replacement Lifetime” scenario models, respectively (the CFL subplots do not show a distribution for the 

“Early-Replacement Lifetime” scenario, as this scenario was only considered for LED GSLs). The vertical dashed 

lines in each plot represent the median GSL lifetime for each model.

Figure 8E.6.1 Survival Probability as a Function of GSL Age for Residential and 

Commercial, and CFL and LED GSLs

As a result of DOE applying the “Renovation-Driven Lifetime” and “Early-Replacement 

Lifetime” scenario models to the models from the “Rated Lifetime” scenario, the medians of the 

“Renovation-Driven Lifetime” and “Early-Replacement Lifetime” scenario Weibull distributions 

(see Table 8E.6.1), when taken alone, always exceed the final median GSL lifetimes for the 

“Renovation-Driven Lifetime” and “Early-Replacement Lifetime” scenarios shown in Figure 

8E.6.1. The final, median GSL ages from the lifetime distributions as a function of scenario, 

sector, and GSL type are provided in Table 8E.6.2.

8E-10
Table 8E.6.2 Resulting Median GSL Lifetimes by Scenario, Sector, and GSL Type

Scenario Sector GSL Type Median GSL Lifetime

(yrs)

Rated 

Lifetime

Residential

CFL: 10,000 hours 6.9

CFL: 12,000 hours 8.2

CFL: 20,000 hours 13.7

LED: 25,000 hours 47.5

Commercial

CFL: 10,000 hours 2.7

CFL: 12,000 hours 3.3

CFL: 17,000 hours 4.6

CFL: 20,000 hours 5.5

LED: 25,000 hours 6.8

Renovation-Driven 

Lifetime

Residential

CFL: 10,000 hours 6.8

CFL: 12,000 hours 8.2

CFL: 20,000 hours 12.8

LED: 25,000 hours 19.2

Commercial

CFL: 10,000 hours 2.7

CFL: 12,000 hours 3.3

CFL: 17,000 hours 4.6

CFL: 20,000 hours 5.5

LED: 25,000 hours 6.8

Early-Replacement 

Lifetime

Residential

LED: 25,000 hours

5.0

Commercial 4.8

8E-11
REFERENCES

1. Ecotope Inc. Residential Building Stock Assessment: Metering Study. 2014. Northwest

Energy Efficiency Alliance: Seattle, WA. Report No. E14-283.

http://neea.org/docs/default-source/reports/residential-building-stock-assessment--

metering-study.pdf?sfvrsn=6.

2. DNV KEMA Energy and Sustainability and Pacific Northwest National Laboratory.

Residential Lighting End-Use Consumption Study: Estimation Framework and Baseline

Estimates. 2012.

http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2012_residential-lightingstudy.pdf.

3. U.S. Department of Energy–Energy Information Administration. 2009 RECS Survey

Data. (Last accessed October 10, 2014.)

http://www.eia.gov/consumption/residential/data/2009/.

4. Jump, C., J. J. Hirsch, J. Peters, and D. Moran. Welcome to the Dark Side: The Effect of

Switching on CFL Measure Life. 2008. 2008 ACEEE Summer Study on Energy

Efficiency in Buildings.

http://www.eceee.org/library/conference_proceedings/ACEEE_buildings/2008/Panel_2/2

_111/paper.

5. James J. Hirsch and Associates Inc. and Erik Page & Associates. CFL Laboratory Testing

Report: Preliminary Results from a CFL Switching Cycle and Photometric Laboratory

Study. 2012. California Public Utilities Commission - Energy Division: California.

6. U.S. Department of Energy–Energy Information Administration. 2003 CBECS Survey

Data. (Last accessed October 6, 2014.)

http://www.eia.gov/consumption/commercial/data/2003/index.cfm?view=microdata.

7. Illuminating Engineering Society of North America. The IESNA Lighting Handbook:

Reference & Application. 2000. Illuminating Engineering Society of North America:

New York, NY.

8E-12
APPENDIX 10A. USER INSTRUCTIONS FOR NATIONAL IMPACT ANALYSIS 

SPREADSHEET MODEL

TABLE OF CONTENTS

10A.1 ACCESSING THE SPREADSHEET MODEL.......................................................... 10A-1

10A.2 STARTUP................................................................................................................... 10A-1

10A.3 DESCRIPTION OF NATIONAL IMPACT ANALYSIS WORKSHEETS.............. 10A-1

10A.4 BASIC INSTRUCTIONS FOR OPERATING THE NATIONAL IMPACT 

ANALYSIS SPREADSHEETS.................................................................................. 10A-2

10A-i
10A.1 ACCESSING THE SPREADSHEET MODEL

DOE performs all NIA calculations using a Microsoft Excel® spreadsheet which is

available on regulations.gov, docket number EERE–2013–BT–STD–0051 at 

http://www.regulations.gov/#!docketDetail;D=EERE-2013-BT-STD-0051.

10A.2 STARTUP

The NIA spreadsheet enables the user to perform a National Impact Analysis (NIA) for 

the candidate standard cases (CSCs) for general service lamps (GSL). To execute the 

spreadsheet, DOE assumes that the user has access to a PC with Microsoft Excel® 2007 or later 

installed under the Windows operating system.

10A.3 DESCRIPTION OF NATIONAL IMPACT ANALYSIS WORKSHEETS

The NIA spreadsheets perform calculations to forecast the change in national energy use 

and net present value of financial impacts due to an amended energy efficiency standard. The 

energy use and associated costs for a given standard are determined by first calculating the 

shipments and then calculating the energy use and costs for all lamps shipped under that 

standard. The differences between the standards and base case can then be compared and the 

overall energy savings and net present values determined. The NIA spreadsheets consist of the 

following worksheets listed in Table 10A.3.1 below.

10A-1
Table 10A.3.1 Brief Description of the Contents of All Worksheets in the NIA Workbook

Introduction Includes an introduction to the spreadsheet calculations, and information on the User 

Options & Summary worksheet

User Options & 

Summary

Includes user-selected scenarios and a summary table of the cumulative shipments,

NES, and NPV under each CSC for the user selected scenario. (More information on 

the User Options & Summary worksheet can be found in Section 10A.4)

Charts Includes charts of shipments, stock, NES and NPV, and price trends for each 

standards case for the user selected scenario and CSC

Shipments, Stock and 

Prices

Includes the shipments, stock and prices for the residential and commercial sectors 

for the user selected scenario 

Energy Savings – Res Includes the calculation of the annual energy saving for each standard case for the 

residential sector, for the user selected scenario

Energy Savings -Com Includes the calculation of the annual energy savings for each standards case for the 

commercial sector, for the user selected scenario

Electricity Cost Savings Includes the change in operating costs for the residential and commercial sectors for 

the user selected scenario

Change in Equipment 

Cost

Includes the change of equipment cost for the residential and commercial sectors for 

the user selected scenario

Parameters Includes the parameters and assumption inputs for the shipments analysis and NIA

Substitution Includes the change in equipment cost for the residential and commercial sectors for 

the user selected scenario

Retirement Includes survival and failure probabilities for lamps in the residential and commercial 

sectors

Electricity Price Trends

Includes electricity price trends and site to power plant conversion factors for the 

residential and commercial sectors, and full fuel cycle multipliers for each year in the 

analysis

Controls & Smart Lamp 

Incursion

Includes the trends in controls in the commercial sector for the user selected controls 

scenario and the fraction of LED GSL shipments that are smart lamps for the user 

selected smart lamp scenario

10A.4 BASIC INSTRUCTIONS FOR OPERATING THE NATIONAL IMPACT 

ANALYSIS SPREADSHEETS

Basic instructions for operating the NIA spreadsheets are as follows: Once the NIA

spreadsheet file has been downloaded from the Internet, open the file using Excel®. Use Excel's®

View/Zoom commands at the top menu bar to change the size of the display to make it fit your 

monitor.

Calculations are performed under a range of different sets of assumptions (scenarios), 

which can be selected by the user on the User Options & Summary worksheet. A description of 

the available options is given below. For each of the scenario options, the user should select one 

option in the associated yellow drop down menu; users must click on the yellow cell for the drop 

down menu to appear. Results throughout the spreadsheet will update automatically.

10A-2
There are two types of scenarios that can be investigated, NIA scenarios and Shipments 

scenarios. NIA Scenarios do not change shipment quantities, while Shipments Scenarios change

shipment quantities based on the selected options.

NIA Scenarios

Users can vary these scenarios independently of the shipments scenarios. Values used in the 

DOE’s best estimate reference scenario are italicized. 

AEO 2014 Economic Growth Scenarios

• Reference Case

• High economic growth

• Low economic growth

Commercial Controls

• Reference – Assumes increasing growth of controls in the commercial sector, driven by 

building codes

• Fixed – Assumes the fraction of commercial floorspace utilizing controls remains fixed at 

2014 levels

Smart Lamp Max Shipments

• 0% - Assumes no smart lamps in the residential sector

• 50% - Assumes 50% of the shipments of lamps in the residential sector, at the end of the 

analysis period are smart lamps

• 100% - Assumes 100% of the shipments of lamps in the residential sector, at the end of 

the analysis period are smart lamps

Smart Lamp Standby Power (W)

• 0 – Assumes smart lamps use no power in standby mode

• 1 – Assumes all smart lamps use 1 W of power in standby mode

Rebound Scenarios

• No - Assumes 0% rebound in the commercial sector and 0% in the residential sector. 

• Low - Assumes 1% rebound in the commercial sector and 8.5% in the residential sector 

• High - Assumes a rebound rate of 15% in both sectors.

Shipment Scenarios

There are eight Alternative Scenarios users can view in the shipments scenarios listed below.

• Reference – DOE’s best-estimate scenario 

• Early-Replacement Lifetime – Assumes turnover for LED GSLs is driven by consumer 

preference for newer products rather than product lifetime (reference scenario assumes 

renovation-driven turnover)

10A-3
• Rated Lifetime – Assumes turnover for all GSLs is driven by the full rated product 

lifetime (reference scenario assumes renovation-driven turnover)

• No Int-LED – Assumes that integrated LED fixtures do not displace GSLs

• 50% Int-LED – Assumes that integrated LED fixtures comprise 50% of the lumen 

demand at the end of the analysis period (reference scenario assumes 15%)

• Tech learning – Assumes a technology dependent price learning rate for lamps (reference 

scenario assumes a single learning rate for all technologies)

• Fixed Real Prices – All prices are held constant at their 2014 (in 2014$) level throughout 

the analysis period, i.e., no price learning.

• High REO Price – Assumes REO prices increase to 4.5 times their 2014 levels and 

remain there throughout the analysis period (reference scenario assumes real REO prices 

are constant at 2014 levels).

10A-4
APPENDIX 10B. FULL-FUEL-CYCLE MULTIPLIERS

TABLE OF CONTENTS

10B.1 INTRODUCTION .......................................................................................................10B-1

10B.2 METHODOLOGY ......................................................................................................10B-1

10B.3 FULL-FUEL-CYCLE ENERGY MULTIPLIERS......................................................10B-3

REFERENCES ........................................................................................................................10B-4

LIST OF TABLES

Table 10B.2.1 Dependence of FFC Parameters on AEO Inputs .......................................10B-3

Table 10B.3.1 Full Fuel Cycle Energy Multipliers (Based on AEO 2014).......................10B-3

10B-i
APPENDIX 10B. FULL-FUEL-CYCLE MULTIPLIERS

10B.1 INTRODUCTION

This appendix summarizes the methods used to calculate full-fuel-cycle (FFC) energy 

savings expected to result from potential standards. The FFC measure includes point-of-use (site)

energy, the energy losses associated with generation, transmission, and distribution of electricity, 

and the energy consumed in extracting, processing, and transporting or distributing primary 

fuels. DOE’s traditional approach encompassed only site energy and the energy losses associated 

with generation, transmission, and distribution of electricity. Per DOE’s 2011 Statement of 

Policy for Adopting Full Fuel Cycle Analyses, DOE now uses FFC measures of energy use and 

emissions in its energy conservation standards analyses.1 This appendix summarizes the methods 

used to incorporate the full-fuel-cycle impacts into the analysis.

This analysis uses several different terms to reference energy use. The physical sources of 

energy are the primary fuels such as coal, natural gas, liquid fuels, etc. Primary energy is equal to 

the heat content (Btu) of the primary fuels used to provide an end-use service. Site energy use is

defined as the energy consumed at the point-of-use in a building or industrial process. Where 

natural gas and petroleum fuels are consumed at the site (for example in a furnace), site energy is 

identical to primary energy, with both equal to the heat content of the primary fuel consumed. 

For electricity, site energy is measured in kWh. In this case the primary energy is equal to the 

quads of primary energy required to generate and deliver the site electricity. This primary energy 

is calculated by multiplying the site kWh times the site-to-power-plant conversion factor, given

in chapter 10 of this preliminary TSD. For the FFC analysis, the upstream energy use is defined 

as the energy consumed in extracting, processing, and transporting or distributing primary fuels. 

FFC energy use is the sum of primary plus upstream energy use.

Both primary fuels and electricity are used in upstream activities. The treatment of 

electricity in fuel cycle analysis must distinguish between electricity generated by fossil fuels 

and uranium, and electricity generated from renewable fluxes (wind, solar and hydro). For the 

former, the upstream fuel cycle impacts are derived from the amount of fuel consumed at the 

power plant. For the latter, no fuel per se is used, so there is no upstream component.

10B.2 METHODOLOGY

The mathematical approach is discussed in the paper A Mathematical Analysis of Full 

Fuel Cycle Energy Use,

2 and details on the fuel production chain analysis are presented in the 

paper Projections of Full-Fuel-Cycle Energy and Emissions Metrics.

3 The text below provides a 

brief summary of the methods used to calculate FFC energy.

When all energy quantities are normalized to the same units, the FFC energy use can be 

represented as the product of the primary energy use and an FFC multiplier. The FFC multiplier 

is defined mathematically as a function of a set of parameters representing the energy intensity 

and material losses at each production stage. These parameters depend only on physical data, so

the calculations do not require any assumptions about prices or other economic data. While in 

10B-1
general these parameter values may vary by geographic region, for this analysis national 

averages are used. 

In the notation below, the indices x and y are used to indicate fuel type, with x=c for coal, 

x=g for natural gas, x=p for petroleum fuels, x=u for uranium and x=r for renewable fluxes. The 

fuel cycle parameters are:

• ax is the quantity of fuel x burned per unit of electricity output, on average, for grid 

electricity. The calculation of ax includes a factor to account for transmission and 

distribution system losses. 

• by is the amount of grid electricity used in production of fuel y, in MWh per physical unit 

of fuel y.

• cxy is the amount of fuel x consumed in producing one unit of fuel y.

• qx is the heat content of fuel x (MBtu/physical unit)a

• zx(s) is the emissions intensity for fuel x (mass of pollutant s per physical unit of x)

The parameters are calculated as a function of time with an annual time step; hence, a 

time series of annual values is used to estimate the FFC energy and emissions savings in each 

year of the analysis period. Fossil fuel quantities are converted to energy units using the heat 

content factors qx. To convert electricity in kWh to primary energy units, on-site electricity 

consumption is multiplied by the site-to-power-plant conversion factor indicated in chapter 12 of 

this final rule TSD. The site-to-power-plant conversion factor is defined as the ratio of the total 

primary energy consumption by the electric power sector (in quadrillion Btu) divided by the total 

electricity generation in each year.

The FFC multiplier is denoted μ (mu). A separate multiplier is calculated for each fuel

used on site. A multiplier is also calculated for electricity reflecting the fuel mix used in its 

generation. The multipliers are dimensionless numbers that are applied to primary energy 

savings to obtain the FFC energy savings. The upstream component of the energy savings is 

proportional to (μ-1). The fuel type is denoted by a subscript on the multiplier μ.

For DOE’s appliance standards energy savings estimates, the fuel cycle analysis 

methodology is designed to make use of data and projections published in the Annual Energy 

Outlook (AEO). Table 10B.2.1 provides a summary of the AEO data used as inputs to the 

different parameter calculations. The AEO does not provide all the information needed to 

estimate total energy use in the fuel production chain. Reference 3 describes the additional data 

sources used to complete the analysis. However, the time dependence in the FFC multipliers 

arises exclusively from variables taken from the AEO. The FFC analysis for this preliminary 

analysis used data from AEO 2014.

4

a Where MBtu = 1000 Btu.

10B-2

 
Table 10B.2.1 Dependence of FFC Parameters on AEO Inputs

Parameter Fuel AEO Table Variables 

qx all Conversion Factors MBtu per physical unit

ax all

Electricity Supply, Disposition, 

Prices, and Emissions Generation by fuel type

Energy Consumption by Sector and 

Source

Electric power sector energy 

consumption

bc, cnc, cpc coal

Coal Production by Region and 

Type

Production by coal type and 

sulfur content

bp, cnp, cpp petroleum

Refining Industry Energy 

Consumption Refining only energy use

Liquid Fuels Supply and Disposition Crude supply by source

International Liquids Supply and 

Disposition Crude oil imports

Oil and Gas Supply Crude oil domestic production

cnn

natural 

gas

Oil and Gas Supply US dry gas production

Natural Gas Supply, Disposition and 

Prices Pipeline, lease and plant fuel

zx all

Electricity Supply, Disposition,

Prices and Emissions Power sector emissions

10B.3 FULL-FUEL-CYCLE ENERGY MULTIPLIERS

FFC energy multipliers are presented in Table 10B.3.1 for selected years. To extend the 

analysis period beyond 2040, the last year in the AEO 2014 projection, the 2040 value was held 

constant. The multiplier for electricity reflects the shares of various primary fuels in total 

electricity generation over the forecast period. 

Table 10B.3.1 Full Fuel Cycle Energy Multipliers (Based on AEO 2014)

2015 2020 2025 2030 2035 2040

Electricity 1.041 1.041 1.040 1.040 1.041 1.040

Natural Gas 1.101 1.101 1.100 1.098 1.099 1.100

Petroleum Fuels 1.139 1.140 1.148 1.158 1.166 1.168

10B-3
REFERENCES

1. Federal Register, Volume 76, Number 160, August 18, 2011, Pages 51245-51868. 2011.

U.S. Office of the Federal Register.

http://digital.library.unt.edu/ark:/67531/metadc52337/m1/44/.

2. Coughlin, K. A Mathematical Analysis of Full Fuel Cycle Energy Use. Energy. 2012.

37(1): pp. 698–708.

3. Coughlin, K. Projections of Full-Fuel-Cycle Energy and Emissions Metrics. 2013.

Lawrence Berkeley National Laboratory: Berkeley, CA. Report No. LBNL-6025E.

http://ees.lbl.gov/sites/all/files/lbnl6025e_ffc.pdf.

4. Energy Information Administration. Annual Energy Outlook 2014 with Projections to

2040. 2014. Washington, D.C. http://www.eia.gov/forecasts/aeo/pdf/0383(2014).pdf.

10B-4
APPENDIX 10C. LIGHTING CONTROLS MARKET PENETRATION PROJECTION

TABLE OF CONTENTS

10C.1 BACKGROUND .........................................................................................................10C-1

10C.2 APPROACH ................................................................................................................10C-1

10C.2.1 The Impact of State Building Codes on Controls Penetration.........................10C-1

10C.2.2 The Impact of Other Factors on Controls Penetration.....................................10C-3

10C.3 RESULTS AND CONCLUSIONS .............................................................................10C-3

REFERENCES ........................................................................................................................10C-5

LIST OF FIGURES

Figure 10C.3.1 U.S. Total Annual Commercial Lighting Capacity and the Capacity 

Projected to be Operating under Lighting Controls...................................10C-4

10C-i
APPENDIX 10C. LIGHTING CONTROLS MARKET PENETRATION PROJECTION

10C.1 BACKGROUND

Lighting controls include a range of technologies to turn lights off or down when they are

not needed or wanted. Of interest to this rulemaking are control technologies that go beyond 

manual on-off switching, which is almost universally included in lighting. These include manual 

dimmers, automatic timers, and sensor-based controls. Timers can be used to automatically 

adjust lighting based on occupancy schedules and daylight hours. More advanced sensor-based 

controls adjust light output based on signals received from the sensors. Occupancy sensors—

often referred to as motion sensors for outdoor applications and vacancy sensors for indoor 

applications—include infrared, ultrasonic, and, to a far lesser extent, microwave sensors. 

Photosensors are used to adjust light output to account for background light levels, typically 

from daylight. 

The purpose of this appendix is to describe the assumptions and analysis the U.S. 

Department of Energy (DOE) used to project changes in the penetration of lighting controls in 

the commercial sector over the analysis period of this rulemaking. DOE incorporates lighting 

controls in the analysis, because they affect lamp energy use and, therefore, the national impact 

analysis (NIA) (chapter 10). There are large, inherent uncertainties in the extent to which the 

penetration of specific controls technologies will change over time. The next section describes

the approach DOE took to estimate the penetration of lighting controls technologies in the 

building stock for the NIA analysis for this rulemaking. 

10C.2 APPROACH

DOE considered the impact of state building codes and other factors in estimating the 

adoption of lighting controls over the analysis period, as described in the following sections.

10C.2.1 The Impact of State Building Codes on Controls Penetration

Federal model energy codes drive the adoption and revision of state building codes. DOE 

adopts different model codes for commercial and residential buildings. ASHRAE Standard 90.1 

is the model energy code for commercial and multi-family high-rise residential buildings. The 

International Energy Conservation Code (IECC) is the model energy code for low-rise residential 

buildings. Both include provisions on lighting and are updated periodically. The Energy 

Conservation and Production Act (ECPA), as amended, requires that DOE, within one year of 

revision of either document, issue a determination as to whether the revised edition will improve 

energy efficiency compared to previous editions.

1 If DOE finds that the newest version of 

ASHRAE 90.1 is more energy efficient than the previous version, states are required by the 

Energy Policy Act of 1992 (EPACT 1992) to certify that their building energy codes or standards 

meet or exceed the requirements of the new standard within two years. If the analysis shows that 

the revised IECC is more energy efficient than the previous edition, EPACT 1992 requires states 

to certify that they have reviewed their residential building energy codes regarding energy 

efficiency and made a decision as to whether it is appropriate for that state to revise its 

residential building code to meet or exceed the revised code.

2

10C-1
Therefore, state compliance with the model codes is compulsory for commercial 

buildings, but not for residential buildings. DOE therefore treated the two sectors differently in 

this analysis. For the residential sector, DOE assumed that the use of lighting controls remains 

constant at today’s level.

To project the future penetration of commercial lighting controls, DOE assumed that state 

building code requirements remain as they are today, with controls being installed as required for 

new construction and renovation. The current model energy code for commercial buildings, 

ASHRAE 90.1-2007, section 9.4.1.1, mandates that almost all interior lighting be controlled 

either by a timer, an occupancy sensor, or a signal from a separate system. Exceptions are made

for buildings that are less than 5,000 square feet in floor area and for health and safety; hospital 

operating rooms and spaces that specifically require 24-hour lighting. In the current building 

stock, the square footage covered by these exceptions totals 9% of commercial floor space. Most 

of that is exempted because the floor area is less than 5,000 square feet. However, DOE has 

determined that ASHRAE 90.1-2010 will yield significant additional savings, so it will become 

the new model code. The 2010 code eliminates the exception for commercial buildings less than 

5,000 square feet, with the result that an estimated 98% of total commercial floor space would be 

required to include lighting controls—essentially all viable floor area. DOE does not model the 

adoption of the 2010 code in this rulemaking because it is uncertain if and when states will adopt 

the code. 

In addition to the mandatory general lighting provisions of section 9.4.1.1 described 

previously, ASHRAE 90.1-2007 includes additional requirements for lighting controls in some

smaller spaces, such as individual offices, which may be superimposed on controls required 

under the general provisions. DOE did not attempt to account for the effect of multiple layers of 

controls or improvements in control technologies that may take place over time. This appendix 

calculates only the lighting capacity (in teralumens) covered by controls. Given the lack of data 

on whether multiple levels of controls would be adopted and which controls will be adopted in 

which areas, the energy use calculations in chapter 12 of this final rule TSD assume that controls 

yield a fixed 30% energy savings if controls are required for the floor area.

3

Compliance rates are the largest source of uncertainty in the analysis. Given that all of the 

most populous states are currently compliant with the federal requirement to adopt the model 

code or better, future changes in the level of state compliance should do little to change the 

results of the energy analysis. The level of builders’ compliance with state codes is less clear.

This analysis assumes a 75 percent overall compliance rate. 

Using the assumptions described above, DOE estimated the national commercial lighting

capacity (in teralumens) covered by lighting controls for each year of the analysis, based on the 

floor space projected to be operating under lighting controls, using a computational model 

developed by Sturges (2012).

4 The model estimates the commercial floor area incorporating

controls, accounting for the current variation in standards adopted by the states, the relevant floor 

area in each state, the breakdown of floor area by application, and the code requirements for each

floor area application. Because the analysis period in Sturges’ study extended only until 2030, 

for this rulemaking DOE extrapolated Sturges’ projection to the end of the analysis period

(2049). The results of the analysis are described in section 10C.3.

10C-2
10C.2.2 The Impact of Other Factors on Controls Penetration

In addition to lighting controls installed as a result of state building codes, some fraction 

of building owners install controls for other reasons. For the commercial sector, DOE computed 

the current lighting capacity installed for other reasons from the difference between the current 

total lighting capacity under controls and the lighting capacity under controls as a result of 

building codes, based on Sturges’ model. DOE’s 2010 Lighting Market Characterization (LMC) 

estimates that 30% of commercial lighting was governed by lighting controls in 2010.5 The 

building codes analysis estimated that state codes would have resulted in only 12% of floorspace 

having implemented lighting controls at the beginning of the analysis period. Assuming that 

floorspace fractions equate approximately to lighting fractions, an estimated 18% of commercial 

lighting is assumed to be using lighting controls for other reasons. DOE held that fraction fixed 

throughout the analysis period.

10C.3 RESULTS AND CONCLUSIONS

Figure 10C.3.1 shows DOE’s projection of the teralumen hours of capacity expected to 

be operating under controls as a result of building codes, and for other reasons. Total lumen 

capacity is also included in the plot for comparison. As shown, by the end of the analysis period 

approximately 75% of commercial floor space is expected to be operating under lighting 

controls, assuming that today’s building codes remain frozen in place and a 75 percent 

compliance rate. If ASHRAE 90.1-2010 is adopted by the states, there will be some increase in 

lumen capacity covered by controls, because the lighting controls exception for small buildings 

will be eliminated. The magnitude of that increase will depend on which states adopt the 

standard and when. However, a larger uncertainty appears to be the rate at which builders

comply with state code requirements. Currently, DOE is assuming a 75% compliance rate.

10C-3
Figure 10C.3.1 U.S. Total Annual Commercial Lighting Capacity and the Capacity 

Projected to be Operating under Lighting Controls

10C-4
REFERENCES

1. U.S. Department of Energy. Building Energy Codes Program: Regulations &

Rulemaking. July 28, 2014. Washington, D.C. (Last accessed November 20, 2014.)

http://www.energycodes.gov/regulations.

2. U.S. Department of Energy. Building Energy Codes Program: Determinations. October

28, 2014. Washington, D.C. (Last accessed November 20, 2014.)

http://www.energycodes.gov/regulations/determinations.

3. Williams, A., B. Atkinson, K. Garbesi, E. Page, and F. Rubinstein. Lighting Controls in

Commercial Buildings. LEUKOS. 2012. 8(3): pp. 161–180.

4. Sturges, A. Modeling the Market Penetration of Advanced Lighting Controls in the U.S

Commercial Sector. Master’s thesis, Duke University. 2012.

http://dukespace.lib.duke.edu/dspace/handle/10161/5278.

5. Navigant Consulting, Inc. Final Report: 2010 U.S. Lighting Market Characterization.

2012. http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan2012.pdf.

10C-5
APPENDIX 10D. REBOUND EFFECT

TABLE OF CONTENTS

10D.1 BACKGROUND ........................................................................................................ 10D-1

10D.2 OPERATING HOURS OF EFFICIENT AND STANDARD RESIDENTIAL 

LIGHTING IN CALIFORNIA................................................................................... 10D-2

10D.3 NATIONAL LIGHTING DENSITY AS THE DETERMINANT OF LIGHTING 

REBOUND ................................................................................................................. 10D-3

10D.4 CONCLUSIONS......................................................................................................... 10D-5

REFERENCES ....................................................................................................................... 10D-6

LIST OF TABLES

Table 10D.2.1 Sample Disposition of Residential Lighting Studies................................ 10D-3

Table 10D.3.1 U.S. Residential and Commercial Lighting in 2001 and 2010 ................. 10D-4

Table 10D.3.2 Changes in Lamp Operating Hours Compared to Changes in Lighting 

Density, U.S. Residential and Commercial Sectors.................................. 10D-4

Table 10D.3.3 Estimated Rebound Rates based on LMC Data........................................ 10D-5

10D-i
APPENDIX 10D. REBOUND EFFECT

10D.1 BACKGROUND

The U.S. Department of Energy (DOE) accounts for the direct rebound effect in its 

estimates of national energy savings.a Direct rebound is the concept that an increase in the 

energy efficiency of equipment may indirectly induce greater usage by the end-user, thereby 

undercutting expected energy savings. Economic theory suggests that if efficiency improvements 

decrease the cost of obtaining a desired service—lighting, in this case—then demand for that 

service will increase, assuming demand is not saturated. 

In the case of lighting, the increased usage should be normalized to floor area. Therefore, 

if a rebound is occurring there must be a change in lighting density (lumens per square foot). 

Any combination of the following potential consumer responses to increased lighting efficiency

could increase lighting density and, therefore, indicate a positive rebound effect: 

• an increase in the average operating hours of lamps, 

• a tendency to replace less efficient lamps with more luminous efficient lamps, and

• an increase in the number of fixtures or sockets per unit floor area (ft2).

While it is the change in service demand (lighting density in lm/ft2), concomitant with an 

improvement in lighting efficiency, that is the final determinant of rebound, lacking such data, 

rebound researchers have relied on the individual factors listed previously as proxies for lighting 

rebound. (See, for example, the papers by Nadel (1993)1 and Greening et al. (2000)2

) In keeping 

with the literature on rebound, causation is not addressed in this analysis.

Lighting rebound can be quantified by the following formula:

OOOOOOOOOOOOOOOO SSSS SSSSSS = EEEEEE EEEE SSSS SSSSSS × (11 − )

Eq. 12B.1

Where:

Observed Savings = observed reduction in power consumption per square foot (W/ft2) during 

a period,

Expected Savings = expected reduction in power consumption per square foot (W/ft2

), given 

the efficiency improvements that occurred during that period, if lighting 

density (lm/ft2) had remained constant, and

rr = rebound rate.

a DOE does not include rebound effects in its NPV calculation, however, for the following reasons: The take-back in 

energy consumption associated with the rebound effect provides consumers with increased value (e.g., increased 

lighting services). DOE believes that, if it were able to monetize the increased value to consumers of the rebound

effect, this value would be similar in value to the foregone energy savings. Therefore, the economic impacts on 

consumers with or without the rebound effect are the same, so DOE does not adjust operating cost savings in the 

NIA.

10D-1

 
Therefore, a direct rebound rate of 10 percent means that 10 percent of the energy savings 

expected to materialize from efficiency improvements alone would not materialize because of 

increased lighting density.

In repose to comments received during the general service fluorescent lamps (GSFLs) 

and incandescent reflector lamps (IRLs) framework public meeting that the rebound rates 

proposed in that rulemaking were too high,

3 DOE further researched lighting rebound rates. The

rates of 8.5-percent for the residential sector and 1-percent for the commercial sector were based 

on studies cited by Greening et al.

2 The lighting rebound estimates quoted in the Greening paper 

were taken from Nadel1 (1993). Nadel, in turn, cited earlier surveys of lamp operating hours 

conducted by Pacific Gas & Electric Company (PG&E), Boston Edison (BE), and New England 

Electric System (NEES). Greening et al. used the results of quoted PG&E and BE studies only as 

the basis of their estimated 5 – 12 percent rebound for residential lighting. The results of the two 

NEES studies were not used, apparently because they had conflicting results. This may have 

been the genesis of the conclusion by Greening et al. that the data available on lighting rebound 

were ‘inconclusive’.b

DOE sought more recent studies on lighting rebounding rates. Many authors have noted 

that appliance saturation effects can reduce rebound.

4–8 Therefore, rebound rates can change 

significantly with time.

5 While Greening et al. (2000), and to a lesser extent Nadel (1993), has 

been repeatedly cited as a source for lighting rebound rates.

6,7,9,10 DOE found no studies that 

evaluated rebound rates based on more recent data. The National Energy Modeling System

(NEMS) also cites Greening et al.

2 as the source of its rebound rates, but NEMS uses a combined 

average rebound rate of 15 percent for all appliances and applies that to lighting, as well as to 

other technologies. The NEMS assumptions for commercial rebound are described in the Energy 

Information Administration’s Commercial Sector Demand Module documentation for NEMS11

the rebound rate used in the residential demand module was inferred.

Lacking more recent journal publications on U.S. lighting rebound, DOE sought lighting

data from which rebound rates could be estimated. DOE identified two large studies of lamp 

operating hours in California that are directly comparable to the original studies cited by Nadel 

(1993) and Greening et al. (2000). DOE also used lighting data from its 2001 and 2010 U.S.

Lighting Market Characterization (LMC) studies, which are a better source for national rebound 

rates, given their scope.

12,13 The results are described in sections 10D.2 and 10D.3.

10D.2 OPERATING HOURS OF EFFICIENT AND STANDARD RESIDENTIAL 

LIGHTING IN CALIFORNIA

A 2005 study by KEMA conducted for three California utilities (PG&E, Southern 

California Edison Company, and San Diego Gas and Electric Company) compared hours of use 

of compact fluorescent lamps (CFL)

14 to hours of use of all residential lamp types that were 

reported in a 1999 California Energy Commission study for the same service territory.

15 These 

b See Table 3 footnote in Greening et al.

10D-2

 
studies were based on large and more recent data sets for service areas that overlapped those

reported in Nadel (1993) and Greening et al. and used the same metric. The sample sizes used in 

the two studies and the reported hours of lamp use are reported in Table 10D.2.1. The studies 

found no discernible difference in lamps hours of use. Given that changes in lamp operating 

hours are only one possible cause of rebound, and the data are only for California, DOE sought 

national data to check the result. These are reported in the following section.

Table 10D.2.1 Sample Disposition of Residential Lighting Studies 

KEMA 200514 CEC 199915

Residences 369 683

Fixtures 752 16,275

Lamps 1,514 26,203*

CFLs only All lamps

Reported Hours of Use of 

Lamps, Average Daily 2.3 hrs/day 2.34 hrs/day * Total number of lamps calculated from reported average lamp per fixture values.

10D.3 NATIONAL LIGHTING DENSITY AS THE DETERMINANT OF LIGHTING 

REBOUND

DOE sought evidence of U.S. lighting rebound based on national lighting data reported in 

DOE’s 2001 and 2010 U.S. LMC studies.

12,13 As indicated in section 10D.1, by definition a 

positive lighting rebound occurs if there is an increase in lighting density (lm/ft2) concomitant 

with an increase in lighting efficiency. A decrease in lighting density yields a negative rebound 

rate, indicating a greater energy savings than expected from efficiency improvements alone.

DOE used data from the two LMC reports to estimate lighting density in 2001 and 2010

using the following equation:

LLLLLLLLLLLLLLLL DDDD DD DD (llll/ff 22) = NNll ll ∗ WWll ll ∗ εεll ll

FF FFFF

Eq. 10D.1

Where:

Nlamps = the number of lamps in the category under consideration in the United States,

Wlamp = the average wattage (W) of the lamp category,

εlamp = the average efficacy (lm/W) of the lamp category, and

Floorspace = the total floor space in the sector (ft2

).

As shown in Table 10D.3.1, while reported lighting efficiency increased from 2001 to 

2010, lighting density decreased, implying a negative rebound rate. The table reports the 

associated percentage decreases in power consumption per lumen: 5 percent in the residential 

sector and 21 percent in the commercial sector. In the absence of rebound, lighting power density 

10D-3
(W/ft2

) would be expected to decrease by the same amounts. Instead, it drops by considerably 

larger percentages: 29 and 31 percent in the residential and commercial sectors, respectively. 

This implies a large reduction in lighting demand: from 30 to 23 lumens per square foot in the 

residential sector, and from 90 to 75 lumens per square foot in the commercial sector.

Table 10D.3.1 U.S. Residential and Commercial Lighting in 2001 and 2010 Average Efficacy*

Elamp (lm/W)

Change in Watts per Lumen

Lamps* (Millions)

Average Lamp 

Power* (W)

Floor Space*

(Billion ft2

)

Average Lighting 

Density (lm/ft2

)

Lighting Power 

Density (W/ft2

)

Change in Lighting Power Density 

(W/ft2

)

2001201020012010200120102001201020012010200120102010-EXP**

Residential 18 19 -5% 4611 5812 63 46 174 223 30 23 1.7 1.2 1.6 -29%

Commercial 55 70 -21% 1966 2069 56 42 67 81 90 75 1.6 1.1 1.3 -31% * Data taken from LMC reports. All other values calculated. ** The expected power density in 2010 in the absence of rebound.

According to the LMC data, only in the residential sector are the reductions in lighting 

density explained (at least in part) by reductions in operating hours. As shown in Table 10D.3.2, 

in the residential sector lamp operating hours were estimated to have decreased by 10 percent, 

explaining only part of the estimated 23 percent reduction in lighting density. In the commercial 

sector the reported lamp operating hours increased. However, LMC 2010 indicates that the large 

change in estimated operating hours could be an artifact of changes in the characterization of 

commercial versus industrial lighting. Therefore, the results should not be considered conclusive. 

Table 10D.3.2 Changes in Lamp Operating Hours Compared to Changes in Lighting 

Density, U.S. Residential and Commercial Sectors

Sector

Average Daily

Operating Hours*

Percent 

Change in 

Operating 

Hours

Average Lighting 

Density (lm/ft2)

Percent 

Change in

Average 

Lighting 

2001 2010 2001 2010 Density

Residential (Total) 2 1.8 -10% 30 23 -23%

Commercial (Total) 9.9 11.2 13% 90 75 -17% * Data taken from LMC reports. All other values calculated.

Using the result from Table 10D.3.2, DOE estimated the rebound rates implied by the 

LMC data as follows: 

10D-4
= 11 − pp

pp

Eq. 10D.2

Where:

observed power savings = the difference between the 2001 and 2010 lighting power density, 

and

expected power savings = percentage change in watts per lumen multiplied by the 2001 

lighting power density.

The results are reported in Table 10D.3.3.

Table 10D.3.3 Estimated Rebound Rates based on LMC Data

Observed 

Power Savings

Expected 

Power Savings

Estimated 

Rebound Rate

Residential 0.5 0.09 -4.9 (-490%)

Commercial 0.5 0.34 -0.5 (-50%)

10D.4 CONCLUSIONS

DOE concludes that the most recent available data do not support a lighting rebound

effect for either the residential or commercial sector. The data may indicate a systematic trend in 

residential sector rebound, moving from a modest positive rebound in the early 1990s, to zero 

rebound in 2005, to a very large negative rebound in 2012. An initial reduction in rebound rates 

from positive to zero is what is expected if demand for a service saturates. Goldstein5 explains 

that negative rebounds can occur if consumers use efficiency cost savings to invest in more 

energy efficiency rather than in more energy consumption. The same may be true of commercial 

lighting, though there are fewer data to support such a conclusion. However, given the 

uncertainties inherent in comparing different data sources for different times, DOE took a 

conservative approach in estimating energy savings and assumed in this analysis no rebound 

effect for its reference scenario for both sectors. DOE also conducted alternative analyses of 

rebound rates, the low rebound alternative uses the rates originally proposed in the GSFL and 

IRL rulemaking (8.5-percent for the residential sector and 1-percent for the commercial sector),

and the high rebound alternative uses values from NEMS (15-percent for both the residential and 

commercial sectors). The results are described in chapter 10 of this preliminary analysis TSD.

10D-5
REFERENCES

1. Nadel, S. The Take-Back Effect--Fact or Fiction?. 1993. American Council for an

Energy-Efficient Economy. Report No. U933. http://www.aceee.org/researchreport/u933.

2. A. Greening, L., D. L. Greene, and C. Difiglio. Energy Efficiency and consumption —

the rebound effect — a survey. Energy Policy. 2000. 28(6-7): pp. 389–401.

3. U.S. Department of Energy. Combined Public Meeting on: Test Procedure Notice of

Proposed Rulemaking (NOPR) - General Service Fluorescent Lamps, and Incandescent

Reflector Lamps -Transcript. 2011.

http://www.regulations.gov/#!documentDetail;D=EERE-2011-BT-STD-0006-0010.

4. Gottron, F. Energy Efficiency and the Rebound Effect. 2001. Congressional Research

Service.

5. Goldstein, D. B., S. Martinez, and R. Roy. Are There Rebound Effects from Energy

Efficiency. Electricity Policy. 2011. http://www.electricitypolicy.com/Rebound-5-4-

2011-final2.pdf.

6. Sorrell, S. Jevon’s Paradox Revisited: The Evidence for Backfire from Improved Energy

Efficiency. Energy Policy. 2009. 37 pp. 1456–1469.

7. Geller, H. and A. Attali. The Experience with Energy Efficiency Policies and

Programmes in IEA Countries-Learning from the Critics. 2005. International Energy

Agency.

8. Nadel, S. The Rebound Effect: Large or Small? 2012. American Council for an 

Energy-Efficient Economy. http://www.aceee.org/files/pdf/white-paper/rebound-largeand-small.pdf.

9. Herring, H. and R. Roy. Technological Innovation, Energy Efficient Design and the

Rebound Effect. Technovations. 2007. 27 pp. 194–203.

10. Madlener, R. and B. Alcott. Energy Rebound and Economic Growth: A Review of the

Main Issues and Research Needs. Energy. 2009. 34 pp. 370–376.

11. U.S. Department of Energy–Energy Information Administration. Office of Integrated

Analysis and Forecasting, Commercial Sector Demand Module for the National Energy

Modeling System: Model Documentation. 2010.

12. Navigant Consulting, Inc. U.S. Lighting Market Characterization, Volume I: National

Lighting Inventory and Energy Consumption Estimate. 2002.

http://apps1.eere.energy.gov/buildings/publications/pdfs/corporate/lmc_vol1.pdf.

10D-6
13. Navigant Consulting, Inc. Final Report: 2010 U.S. Lighting Market Characterization.

2012. http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan2012.pdf.

14. KEMA, Inc. CFL Metering Study Final Report. 2005. Pacific Gas & Electric Company,

San Diego Gas & Electric Company, and Southern California Edison Company: Oakland,

CA. http://calmac.org/publications/2005_Res_CFL_Metering_Study_Final_Report.pdf.

15. Heshong Mahone Group. California Baseline Lighting Efficiency Technology Report.

1997. California Energy Commission.

10D-7 
APPENDIX 12A MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDE

TABLE OF CONTENTS

12A.1 PRELIMINARY MANUFACTURER INTERVIEW GUIDE FOR GENERAL 

SERVICE LAMPS...................................................................................................... 12A-1

12A-i 
12A.1 PRELIMINARY MANUFACTURER INTERVIEW GUIDE FOR GENERAL 

SERVICE LAMPS

May 2014 

Purpose: 

To gather information on the U.S. general service lamp (GSL) market to assist in the Department 

of Energy’s (DOE) energy conservation standards analysis.

Method: 

Navigant Consulting, Inc. (Navigant) is circulating this interview guide to manufacturers of 

general service fluorescent lamps who operate in the U.S. market. Navigant will combine all the 

responses from individual manufacturers to protect proprietary information of any one 

manufacturer. Individual responses to this questionnaire and any other data provided will all be 

covered under a non-disclosure agreement, which Navigant will enter into with each 

participating manufacturer. Navigant will handle all individual company data in the strictest 

confidence. 

If you have any questions, please contact: 

Aisha Husain

Navigant Consulting, Inc. 

aisha.husain@navigant.com

Tel: 202.481.8301 

Fax: 202.973.2401 

Maureen Kienle

Navigant Consulting, Inc. 

maureen.kienle@navigant.com

Tel: 202.481.8342 

Fax: 202.973.2401 

12A-1 
Amendments to Title III of Energy Policy and Conservation Act of 1975 (EPCA) (42 U.S.C. 

6291 et seq.) in the Energy Independence and Security Act of 2007 (EISA) directed DOE to 

conduct two rulemaking cycles to evaluate energy conservation standards for GSLs. (42 U.S.C. 

6295(i)(6)(A)-(B)). DOE initiated the first rulemaking cycle through publication of a framework 

document in December 2013 that describes the procedural and analytical approaches DOE 

anticipates using to evaluate potential energy conservation standards.1

1 SCOPE OF COVERAGE

DOE defines general service lamp as follows:

General service lamp includes general service incandescent lamps, compact fluorescent 

lamps, general service light-emitting diode lamps, organic light-emitting diode lamps, 

and any other lamps that the Secretary determines are used to satisfy lighting applications 

traditionally served by general service incandescent lamps; however, this definition does 

not apply to any lighting application or bulb shape excluded from the “general service 

incandescent lamp” definition, or any general service fluorescent lamp or incandescent 

reflector lamp. 

10 CFR 430.2

Applications and bulb shapes excluded from the general service lamp definition are 

provided below:

(1) An appliance lamp;

(2) A black light lamp;

(3) A bug lamp;

(4) A colored lamp;

(5) An infrared lamp;

(6) A left-hand thread lamp;

(7) A marine lamp;

(8) A marine signal service lamp;

(9) A mine service lamp;

(10) A plant light lamp;

(11) A reflector lamp;

(12) A rough service lamp;

(13) A shatter-resistant lamp (including a shatter-proof lamp and a shatter-protected 

lamp);

(14) A sign service lamp;

(15) A silver bowl lamp;

(16) A showcase lamp;

(17) A 3-way incandescent lamp;

1 The framework document is available through DOE’s website at: 

http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx?ruleid=83

12A-2

 
(18) A traffic signal lamp;

(19) A vibration service lamp;

(20) A G shape lamp (as defined in ANSI C78.20) (incorporated by reference; see § 

430.3) and ANSI C79.1-2002 (incorporated by reference; see § 430.3) with a diameter of 

5 inches or more;

(21) A T shape lamp (as defined in ANSI C78.20) (incorporated by reference; see § 

430.3) and ANSI C79.1-2002 (incorporated by reference; see § 430.3) and that uses not 

more than 40 watts or has a length of more than 10 inches; and

(22) A B, BA, CA, F, G16-1/2, G-25, G30, S, or M-14 lamp (as defined in ANSI C79.1-

2002) (incorporated by reference; see § 430.3) and ANSI C78.20 (incorporated by 

reference; see § 430.3) of 40 watts or less.

10 CFR 430.2

1.1 DOE is using the following criteria to define the scope of GSLs covered in this 

rulemaking: lamps that have an output between 279-2,860 lumens, lamps that have an ANSI 

base, and lamps that do not meet the 22 exemptions specified above. Would you agree with this 

approach? The GSL scope under consideration would include: 1) hybrid lamps (such as a 

compact fluorescent lamp (CFL) with a halogen capsule to provide instant illumination), 2) selfballasted mercury vapor lamps, and 3) low voltage lamps. Are these lamp types used in GSL 

applications?

1.2 The GSL scope under consideration would include: 1) hybrid lamps (such as a compact 

fluorescent lamp (CFL) with a halogen capsule to provide instant illumination), 2) self-ballasted 

mercury vapor lamps, and 3) low voltage lamps. Are these lamp types used in GSL applications?

1.3 Do you manufacture any additional lamp types not discussed that you would consider 

GSLs? If so, please explain. In general, what is the market share and shipment trends of these 

lamps for your company? 

1.4 What types of CFLs would fall under exemptions 20-22 listed above? Please explain. 

What types of light-emitting diode (LED) lamps would fall under exemptions 20-22 listed 

above? Please explain. 

1.5 DOE defines colored fluorescent lamp as stated below. How would you modify this 

definition to apply to a colored CFL? How would you modify this definition to apply to a 

colored LED lamp? Are these industry accepted definitions? 

Colored fluorescent lamp means a fluorescent lamp designated and marketed as a colored 

lamp and not designed or marketed for general illumination applications with either of 

the following characteristics:

(1) A CRI less than 40, as determined according to the method set forth in CIE 

Publication 13.3 (incorporated by reference; see §430.3); or

12A-3
(2) A correlated color temperature less than 2,500K or greater than 7,000K as determined 

according to the method set forth in IES LM-9 (incorporated by reference; see §430.3).

10 CFR 430.2

1.6 DOE defines rough service lamp, shatter-resistant lamp, and vibration service lamp as 

stated below. Do these terms represent distinct technologies for CFLs and LED lamps? 

How would you modify the definitions to apply to a CFL? Does the definition vary for a selfballasted versus externally ballasted CFL? How would you modify the definitions to apply to an 

LED lamp? Are these industry accepted definitions?

Rough service lamp means a lamp that—

(1) Has a minimum of 5 supports with filament configurations that are C-7A, C-11, C-17, 

and C-22 as listed in Figure 6-12 of the IESNA Lighting Handbook (incorporated by 

reference; see §430.3), or similar configurations where lead wires are not counted as 

supports; and

(2) Is designated and marketed specifically for ‘rough service’ applications, with

(i) The designation appearing on the lamp packaging; and

(ii) Marketing materials that identify the lamp as being for rough service.

Shatter-resistant lamp, shatter-proof lamp, or shatter-protected lamp means a lamp 

that—

(1) Has a coating or equivalent technology that is compliant with NSF/ANSI 51 

(incorporated by reference; see §430.3) and is designed to contain the glass if the glass 

envelope of the lamp is broken; and

(2) Is designated and marketed for the intended application, with

(i) The designation on the lamp packaging; and

(ii) Marketing materials that identify the lamp as being shatter-resistant, shatter-proof, or 

shatter-protected.

Vibration service lamp means a lamp that—

(1) Has filament configurations that are C-5, C-7A, or C-9, as listed in Figure 6-12 of the 

IESNA Lighting Handbook (incorporated by reference; see §430.3) or similar 

configurations;

(2) Has a maximum wattage of 60 watts;

(3) Is sold at retail in packages of 2 lamps or less; and

(4) Is designated and marketed specifically for vibration service or vibration-resistant 

applications, with—

(i) The designation appearing on the lamp packaging; and

(ii) Marketing materials that identify the lamp as being vibration service only.

10 CFR 430.2

12A-4
2 MARKET ANALYSIS

2.1 In order to calculate the aggregate national energy savings, DOE needs data on shipment 

trends. For each of the lamp types covered in this rulemaking (listed below), DOE is interested in 

obtaining shipment data for the lamp types specified below that have a lumen range of 279-

2,860, an ANSI base, and are not included in the 22 exemptions (e.g., reflector lamps). Please 

specify the type of data and units (i.e., unit sales, percent shipments) provided. Feel free to 

modify the table structure as appropriate to your data. 

Absent new energy conservation standards, do you expect these proportions to change over time? 

If so, how?

Table 12-1 Shipment Projections for GSL

Historical 

(Fill in years as appropriate)

Current Projections

Lamp Structure/Type 20XX 20XX 20XX 20XX 2014 2020 2025

Integrated Self-ballasted CFLs

LED lamps with 

internal driver

Self-ballasted hybrid 

lamps

Self-ballasted mercury 

vapor lamps

Other lamps

NonIntegratedExternally ballasted 

CFLs

LED lamps with 

external driver

Low voltage CFLs

Low voltage LED 

lamps

Low voltage other 

lamps

Total GSLs

2.2 How do consumers select a GSL? What characteristics are they most interested in (e.g.,

lumen output, color quality, technology type)? Do they weigh input power or light output more 

heavily?

2.3 For GSLs, what are the most common wattages? Does this vary for each of the lamp 

types covered (e.g., self-ballasted CFLs, externally ballasted CFLs, integrated LED lamps, and 

LED lamps with an external driver)? What percent of shipments are represented by each of these 

12A-5
wattages? Absent new energy conservation standards, do you expect these proportions to change 

over time? If so, how?

2.4 For GSLs, what are the most common lumen outputs? Does this vary for each of the lamp 

types covered (e.g., self-ballasted CFLs, externally ballasted CFLs, integrated LED lamps, and 

LED lamps with an external driver)? 

2.5 What are general trends you see in the market? Do you expect future market shares for 

the most common GSL types to change in the presence of new energy conservation standards for 

GSLs?

2.6 Absent new energy conservation standards, do you foresee other technologies increasing 

in market share over the next thirty years? If so, how?

2.7 DOE intends to consider GSLs operating in different sectors. For GSLs under 

consideration in this rulemaking, can you provide an estimate of the percent of GSLs by lamp

type (e.g., self-ballasted CFLs, externally ballasted CFLs, integrated LED lamps, and LED lamps 

with an external driver) sold into the commercial, industrial, and residential sectors? 

2.8 What percent of GSLs by lamp type (e.g., self-ballasted CFLs, externally ballasted CFLs, 

integrated LED lamps, and LED lamps with an external driver) are sold in the new 

construction/renovation market and the replacement market?

2.9 Do you expect a substantial drop in GSL shipments owing to the adoption of LED lamps, 

which have longer lifetimes than conventional lamps? If so, when do you expect lamp shipments 

to peak?

2.10 What do you project your sales breakdown will be between high (90 and above) and 

lower CRI lamps?

2.11 What do you anticipate will be your sales breakdown between lamps with and without 

standby power (e.g., for connection to a home network)? What will be the typical standby load?

2.12 What percentage of your CFL and LED lamps do you project will be dimmable?

12A-6
2.13 What is your estimate of the percentage of GSL sockets that will be displaced by integral 

LED fixtures? 

12A-7
3 TECHNOLOGY ASSESSMENT AND SCREENING ANALYSIS

3.1 How is self-ballasted CFL efficacy expected to change over time? For externally 

ballasted CFLs? How are research and development efforts focused on these products?

3.2 What technology options can be used to improve lamp efficacy of self-ballasted CFLs? 

Of externally ballasted CFLs? What are the expected gains from these options?

3.3 What is the range of ballast efficiencies of self-ballasted CFLs? Of externally ballasted 

CFLs? What are the typical efficiencies?

3.4 What differences in design and technology are attributable to the different efficacies 

between a self-ballasted CFL and externally ballasted CFL with the same wattage?

3.5 What factors determine the lifetime of a self-ballasted CFL? Of an externally ballasted 

CFL? Is there a relationship between lifetime and efficacy for CFLs?

3.6 How is integrated LED lamp efficacy expected to change over time? For LED lamps with 

external drivers? How are research and development efforts focused on these products?

3.7 What technology options can be used to improve lamp efficacy of integrated LED lamps? 

Of LED lamps with external drivers? What are the expected gains from those options?

3.8 What is the range of driver efficiencies of integrated LED lamps? Of LED lamps with 

external drivers? What are the typical efficiencies?

3.9 What factors determine the lifetime of an integrated LED lamp? Of LED lamps with 

external drivers? Is there a relationship between lifetime and efficacy for LEDs?

3.10 Is there any patent, technology, or other issue that you are aware of that would prevent 

your company or competitors form implementing higher efficacy designs for any GSL included 

in this rulemaking? When do these patents expire?

12A-8
4 PRODUCT CLASSES

4.1 DOE separates products into categories called product classes based on differences in 

efficacy and consumer utility (i.e., features valued by consumers). DOE then conducts its 

analyses and establishes separate standard levels for each product class. DOE is considering 

separating product classes based on whether all necessary components for operation are enclosed 

in a lamp (i.e., integrated) versus a lamp that requires external components (i.e., non-integrated), 

as shown in the table below. Do you agree with the product class divisions presented below? Are 

there other parameters that should be considered in defining product classes for GSLs?

Table 12-2 GSL Product Classes

4.2 DOE selects certain product classes (called representative product classes) to directly 

analyze in detail. The representative product classes are selected primarily based on shipment 

volume and/or distinct characteristics. For GSLs, DOE is considering directly analyzing both 

product classes. Do you agree with the representative product classes under consideration?

4.3 DOE considered a product class division separating “covered” and “uncovered” lamps. In 

the framework public meeting, stakeholders also suggested “clear” versus “diffuse” as a product 

class division. How would these divisions be defined and applied to self-ballasted CFLs, 

externally ballasted CFLs, integrated LED lamps, and LED lamps with external drivers? What 

are the differences in utility and efficacy?

4.4 Is there a difference in efficacy for low voltage lamps compared to lamps that operate on 

line voltage? Does this vary by technology type? Do low voltage CFLs and/or low voltage LED 

lamps offer a utility not offered by their line voltage counterparts? Please explain. 

4.5 DOE received comments that DOE should develop a definition for a modified spectrum 

GSL based on the color point defined in DOE’s definition for incandescent modified spectrum 

lamps (see below). What definition would you propose for modified spectrum CFLs? For 

modified spectrum LED lamps? 

Modified spectrum means, with respect to an incandescent lamp, an incandescent lamp 

that—

Lamp Type

Integrated GSLs (e.g., self-ballasted CFL, integrated LED lamp ) 

Non-integrated GSLs (e.g., externally ballasted CFL, LED lamps with 

external drivers)

12A-9
(1) Is not a colored incandescent lamp; and

(2) When operated at the rated voltage and wattage of the incandescent lamp—

(A) Has a color point with (x,y) chromaticity coordinates on the C.I.E. 1931 

chromaticity diagram, figure 2, page 3 of IESNA LM-16 (incorporated by 

reference; see §430.3) that lies below the black-body locus; and

(B) Has a color point with (x,y) chromaticity coordinates on the C.I.E. 1931 

chromaticity diagram, figure 2, page 3 of IESNA LM-16 (incorporated by 

reference; see §430.3) that lies at least 4 MacAdam steps, as referenced in IESNA 

LM-16, distant from the color point of a clear lamp with the same filament and bulb 

shape, operated at the same rated voltage and wattage.

10 CFR 430.2

4.6 What unique utility do modified spectrum CFLs provide? Modified spectrum LED

lamps?

4.7 What are the specific technologies/designs used to construct modified spectrum CFLs? 

Modified spectrum LED lamps? What is the difference in efficacy between standard spectrum 

versus modified spectrum CFLs? For standard spectrum versus modified spectrum LED lamps?

12A-10
5 ENGINEERING ANALYSIS

5.1 In the tables below, please review the information on efficacy and typical characteristics 

of the baseline model and provide information on design pathways for achieving higher 

efficacies. Please indicate which of your product lines would meet each candidate standard level 

(CSL). Feel free to add rows to the tables as needed.

Table 12-3 Integrated GSLs

Level Lamp 

Type

Efficacy

(lumens/watt)

Key Design 

Characteristics

Technology 

Options

End-User 

Price

Baseline 14 W 

CFL

52.6 A-Shape, 80 CRI, 

2700K CCT, 750 

initial lumens, 

10,000 hour rated 

lifetime 

Basic electrode and 

glass coatings; 

basic fill gas; 

triphosphors; basic 

ballast components 

and design

Candidate 

Standard Level 

(CSL)1

CSL2 

CSL3

CSL4 Maximum 

Technologically 

Feasible

Table 12-4 Non-Integrated GSLs 

Level Lamp 

Type

Efficacy

(lumens/ANSI 

rated wattage)

Key Design 

Characteristics

Technology 

Options

End-User 

Price

Baseline 18 W 

Quad 

Tube 

with 

G24q-2 

base 

CFL 

63.9 Full wattage, 82 

CRI, 4100K CCT, 

1,150 initial lumens, 

10,000 hour rated 

lifetime

Basic electrode 

and glass 

coatings; basic 

fill gas; 

triphosphors

CSL1

12A-11
CSL2

CSL3 Maximum 

Technologically 

Feasible

5.2 DOE selects baseline models within a representative product class. The baseline model 

typically represents the most common, least efficacious lamp available. Do you agree with the 

baseline models selected in the tables above? 

5.3 Should DOE ensure that the same range of CCTs is maintained when selecting more 

efficacious substitutes?

5.4 What are the most common lifetimes by lamp type (e.g., self-ballasted CFLs, externally 

ballasted CFLs, integrated LED lamps, and LED lamps with an external driver)? Do you expect 

these lifetimes to change in future products?

5.5 DOE plans to use catalog values to calculate efficacy and subsequently CSLs for GSLs. 

Do you agree with this approach?

5.6 For this rulemaking, DOE is considering an equation-based approach that reflects the 

relationship between efficacy and lumen output. Specifically, DOE is considering the equation 

forms below. Would you agree with this approach?

Integrated product class: 

EEEEEEEEEEEEEEEE = 1.28

0.019 + 1.48 ∗ LLLLLLLLLLss−1.08 + AA

Non-integrated product class:

EEEEEEEEEEEEEEEE = 0.44

0.016 ∗ LLLLLLLLLLss−0.11 + AA

5.7 Because externally ballasted CFLs covered under this rulemaking operate on a ballast in 

practice, DOE is considering analyzing these lamps with the following: 

• 1-lamp electronic rapid start ballasts; and

• 1-lamp electronic programmed start ballasts. 

Are these pairings the most common lamp-and-ballast systems used with externally ballasted 

12A-12
CFLs?

5.8 What are the typical ballast factors of ballasts paired with externally ballasted CFLs?

5.9 What is the interchangeability between externally ballasted CFLs with different base 

types? For example, if a G24d-2 base lamp is replaced with a G24q-2 or GX24q-2 base lamp, 

what needs to be replaced in the existing lamp system (e.g., the socket, lamp holder, ballast, 

fixture, etc.)? 

5.10 What is the interchangeability between externally ballasted CFLs with different shapes? 

For example, if a quad tube is replaced with a multi tube shaped lamp, what needs to be replaced 

in the existing lamp system (e.g., the socket, lamp holder, ballast, fixture, etc.)? 

5.11 DOE found that many integrated LED lamps, especially those of higher efficacy, are 

marketed as semi-omnidirectional rather than omnidirectional. How would you define semiomnidirectional lamps? What application do semi-omnidirectional integrated LED lamps serve? 

Are omnidirectional integrated LED lamps inherently less efficacious than semi-omnidirectional 

integrated LED lamps?

5.12 DOE has been unable to identify high lumen output (i.e., greater than or equal to 2,600 

lumens) LEDs. Are these products technologically feasible, and what are the current limitations 

if any? 

5.13 DOE understands that there is a relationship between efficacy and rare earth content for 

CFLs. Please provide the percentage of halophosphor CFLs only; tri-band CFLs only; and those 

that are a mix. 

5.14 How does LED lamp efficacy depend on rare earth content? 

5.15 What is the relative content of rare earth elements in comparable CFL and LED lamps 

(e.g., what are the relative quantities of rare earth elements in lamps with similar lumen outputs 

and CRI)?

12A-13
6 PRODUCT PRICE DETERMINATION

6.1 Ideally, DOE would like to estimate end-user price directly by collecting manufacturer 

suggested price lists (“blue books”) and applying a discount based on the distribution channel 

through which the lamp is purchased. DOE has had difficulty finding adequate pricing data in 

blue books for integrated LED lamps and LED lamps with external drivers. Would you know 

why pricing for these lamps is not in blue books? 

6.2 Due to the lack of blue book data, DOE is considering determining end-user prices by

gathering prices directly from distribution channels (e.g., Home Depot, Lowes, elightbulbs.com) 

and developing average prices for each channel at each CSL. DOE is considering then deriving a 

weighted price based on the shipments that go through each distribution channel. Would you 

agree with this approach? Would you suggest an alternative approach?

6.3 Can you describe how the distribution chain operates for GSLs and which end-use sector 

(e.g., commercial, residential) utilizes each distribution chain identified? 

6.4 DOE is considering evaluating the following distribution channels for GSLs: homeimprovement/hardware stores, grocery/pharmacy stores, internet retailers, and state procurement 

contracts. Would you agree with this approach for GSLs? 

6.5 Do distribution channels vary by technology (e.g., self-ballasted CFLs, externally 

ballasted CFLs, integrated LED lamps, and LED lamps with external drivers)?

6.6 What proportion of shipments move through the various channels? 

6.7 What performance characteristics usually come at a cost premium for GSLs? What about 

for each technology? How much?

6.8 In the future do you anticipate these additional costs to increase, decrease, or remain the 

same? As an individual cost? As a percentage of the product cost?

6.9 Do end-user ballast prices change with ballast factor? If so, explain how?

12A-14
7 LIFETIME AND OPERATING HOURS

7.1 What is your estimate of the fraction of lamps disposed of through recommended 

channels rather than through the general waste stream? Does this vary by lamp type (e.g., selfballasted CFLs, externally ballasted CFLs, integrated LED lamps, and LED lamps with external 

drivers)?

7.2 What is the manufacturer disposal cost per lamp by lamp type (e.g., self-ballasted CFLs, 

externally ballasted CFLs, integrated LED lamps, and LED lamps with external drivers)?

7.3 Do you anticipate that actual LED service lifetimes will differ from their functional 

lifetimes (e.g., because consumers replace lamps prior to failure as newer lamps come on the 

market)?

7.4 Do you anticipate that the frequency of on/off switching could significantly affect the 

lifetime of LED lamps (as with fluorescent lamps)? If so, how?

12A-15
8 PRELIMINARY MANUFACTURER IMPACT ANALYSIS

Key Issues

8.1 In general, what are the key issues for your company regarding energy conservation 

standards and this rulemaking?

8.2 Are there any patent, technology, or other issues that you are aware of that would prevent 

your company or competitors from implementing higher-efficacy designs?

Shipment Projections

8.3 What is your company’s approximate market share for the GSLs DOE is considering 

including in coverage? Does this vary by technology (i.e., CFL versus LED)?

8.4 Would you expect your market share to change if higher standards are adopted?

8.5 Do you expect shipments to change for the industry as a whole as a function of 

standards? If so, why?

8.6 Do you expect an increased purchase price for GSLs to result in reduced demand or 

shipments (price elasticity)? If so, how sensitive do you think shipments will be to price 

changes? Does it vary with product class?

8.7 What is the proportion of domestically consumed GSLs shipped by the National 

Electrical Manufacturers Association (NEMA) companies versus non-NEMA companies? Does 

this vary based on lamp type?

Conversion Costs

8.8 What level of capital expenditure and product conversion costs would you anticipate 

making at higher standard levels? Please describe what they are and provide your best estimate 

of their respective magnitudes.

8.9 How would the imposition of new energy conservation standards affect capacity 

utilization and manufacturing assets at your domestic production facilities? Would a new 

standard result in stranded capital assets? Would any facilities be closed or downsized? Added or 

12A-16
upgraded?

Product Mix and Profitability

8.10 Generally, how would new standards impact your customer mix, distribution channels, 

and corresponding profit margins?

8.11 Are your profitability and markups consistent across all GSL types? Does it vary by lamp 

technology?

Market Share and Industry Consolidation

8.12 In the absence of new standards, do you expect any industry consolidation?

8.13 How would new standards affect your ability to compete?

8.14 Could new standards disproportionally advance or harm the competitive positions of 

some firms?

8.15 Could new standards result in disproportionate economic or performance penalties for 

particular consumer/user subgroups?

8.16 Beyond pricing and energy efficiency, could new standards result in products that will be 

more or less desirable to consumers due to changes in product functionality, utility, or other 

features?

Cumulative Regulatory Burden

8.17 Are there recent or impending regulations on your specific products or other products that 

impose a cumulative burden on the industry?

8.18 If so, what is the total expected impact of those regulations?

12A-17