CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT

TABLE OF CONTENTS

3.1 INTRODUCTION ........................................................................................................... 3­1

3.1.1 Definitions............................................................................................................ 3­1

3.1.1.1 Fluorescent Lamps................................................................................... 3­1

3.1.1.2 General Service Fluorescent Lamps ........................................................ 3­2

3.1.1.3 Incandescent Reflector Lamps................................................................. 3­3

3.2 MARKET ASSESSMENT.............................................................................................. 3­4

3.2.1 Trade Association ................................................................................................ 3­4

3.2.2 Manufacturers and Market Share......................................................................... 3­5

3.2.2.1 Small Businesses...................................................................................... 3­6

3.2.3 Regulatory Programs ........................................................................................... 3­7

3.2.3.1 Federal Energy Conservation Standards.................................................. 3­7

3.2.3.2 Canadian Energy Efficiency Standards ................................................. 3­10

3.2.4 Non­Regulatory Initiatives................................................................................. 3­12

3.2.4.1 Federal Energy Management Program .................................................. 3­12

3.2.4.2 Consortium for Energy Efficiency......................................................... 3­12

3.2.4.3 Energy Efficient Commercial Building Deduction................................ 3­12

3.2.4.4 Northeast Energy Efficiency Partnerships............................................. 3­13

3.2.5 Historical Shipments.......................................................................................... 3­13

3.3 TECHNOLOGY ASSESSMENT.................................................................................. 3­16

3.3.1 General Service Fluorescent Lamps .................................................................. 3­16

3.3.1.1 Highly Emissive Electrode Coatings..................................................... 3­18

3.3.1.2 Higher Efficiency Lamp Fill Gas Composition..................................... 3­18

3.3.1.3 Higher Efficiency Phosphors................................................................. 3­20

3.3.1.4 Glass Coatings ....................................................................................... 3­25

3.3.1.5 Higher Efficiency Lamp Diameter......................................................... 3­25

3.3.1.6 Multi­Photon Phosphors........................................................................ 3­26

3.3.2 Incandescent Reflector Lamps........................................................................... 3­26

3.3.2.1 Higher Temperature Operation.............................................................. 3­27

3.3.2.2 Microcavity Filaments........................................................................... 3­28

3.3.2.3 Novel Filament Materials ...................................................................... 3­29

3.3.2.4 Thinner Filaments.................................................................................. 3­29

3.3.2.5 Efficient Filament Coiling ..................................................................... 3­29

3.3.2.6 Crystallite Filament Coatings ................................................................ 3­29

3.3.2.7 Efficient Filament Orientation ............................................................... 3­29

3.3.2.8 Higher Efficiency Inert Fill Gas ............................................................ 3­30

3.3.2.9 Luminescent Gas.................................................................................... 3­30

3.3.2.10 Tungsten­Halogen Lamps................................................................. 3­30

3.3.2.11 Higher Pressure Tungsten­Halogen Lamps...................................... 3­30

3.3.2.12 Non­Tungsten­Halogen Regenerative Cycles................................... 3­31

3.3.2.13 Infrared Glass Coatings..................................................................... 3­31

3.3.2.14 Integrally Ballasted Low­Voltage Lamps......................................... 3­31

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3.3.2.15 Higher Efficiency Reflector Coatings............................................... 3­31

3.3.2.16 Trihedral Corner Reflectors.............................................................. 3­32

3.3.2.17 Efficient Filament Placement............................................................ 3­32

3.4 PRODUCT CLASSES................................................................................................... 3­32

3.4.1 General Service Fluorescent Lamps .................................................................. 3­32

3.4.1.1 Physical Constraints of Fluorescent Lamps........................................... 3­33

3.4.1.2 Lumen Package...................................................................................... 3­34

3.4.1.3 Correlated Color Temperature ............................................................... 3­34

3.4.1.4 Ballast Interoperability........................................................................... 3­34

3.4.1.5 Lamp Wattage........................................................................................ 3­35

3.4.1.6 Lamp Diameter ...................................................................................... 3­35

3.4.1.7 Color Rendering Index........................................................................... 3­36

3.4.1.8 Product Classes and Standard Form for GSFL...................................... 3­36

3.4.2 Incandescent Reflector Lamps........................................................................... 3­36

3.4.2.1 Wattage .................................................................................................. 3­37

3.4.2.2 Modified Spectrum ................................................................................ 3­37

3.4.2.3 Spot Versus Flood Incandescent Reflector Lamps................................ 3­38

3.4.2.4 Product Classes and Standard Form for IRL ......................................... 3­38

REFERENCES .......................................................................................................................... 3­40

LIST OF TABLES

Table 3.2.1 NEMA General Service Fluorescent Lamp and Incandescent Reflector Lamp

Manufacturers.............................................................................................................................. 3­5

Table 3.2.2 General Service Fluorescent Lamp Manufacturers ................................................. 3­6

Table 3.2.3 Incandescent Reflector Lamp Manufacturers.......................................................... 3­6

Table 3.2.4 Small Business Manufacturers of General Service Fluorescent Lamps or

Incandescent Reflector Lamps..................................................................................................... 3­7

Table 3.2.5 Federal Regulations for General Service Fluorescent Lamps ................................. 3­8

Table 3.2.6 EPCA Standards for Fluorescent Lamp Ballasts..................................................... 3­8

Table 3.2.7 EPACT 2005 Standards for Fluorescent Lamp Ballasts.......................................... 3­9

Table 3.2.8 Federal Regulations for Incandescent Reflector Lamps........................................... 3­9

Table 3.2.9 Canadian Energy Efficiency Regulations for Incandescent Reflector Lamps....... 3­11

Table 3.2.10 Federal Energy Management Program Efficiency Recommendation ................. 3­12

Table 3.2.11 NEMA Shipments of Four­Foot General Service Fluorescent Lamps................. 3­14

Table 3.2.12 NEMA Shipments of Eight­Foot Single Pin Slimline General Service Fluorescent

Lamps......................................................................................................................................... 3­14

Table 3.2.13 NEMA Shipments of Two­Foot U­Shaped General Service Fluorescent Lamps 3­15

Table 3.2.14 NEMA Shipments of Eight­Foot High Output General Service Fluorescent Lamps

.................................................................................................................................................... 3­15

Table 3.2.15 NEMA Shipments of Incandescent Reflector Lamps........................................... 3­16

Table 3.4.1 EPCA Product Classes for General Service Fluorescent Lamps........................... 3­33

Table 3.4.2 DOE ANOPR Product Classes for GSFL.............................................................. 3­36

Table 3.4.3 EPCA Product Classes for Incandescent Reflector Lamps ................................... 3­37

Table 3.4.4 DOE ANOPR Product Classes for IRL.................................................................. 3­39

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LIST OF FIGURES

Figure 3.3.1 Lamp Length Effects on Efficacy......................................................................... 3­17

Figure 3.3.2 Lamp Fill Gas Effect on UV Output for T12 Lamps ........................................... 3­19

Figure 3.3.3 Lamp Fill Gas Effect on Thermionic Emission for T12 Lamps........................... 3­20

Figure 3.3.4 Human Eye Photopic Spectral Luminous Efficiency Function, V(λ) .................. 3­21

Figure 3.3.5 Sample Power Spectrum Distribution .................................................................. 3­22

Figure 3.3.6 Average Efficacies of Lamps with a CCT of 6,500K versus 4,100K .................. 3­23

Figure 3.3.7 Lamp Efficacies for Halo­ and Rare­Earth Phosphors......................................... 3­24

Figure 3.3.8 Light Output versus Phosphor Thickness............................................................. 3­24

Figure 3.3.9 Bulb Diameter versus Efficacy............................................................................. 3­26

Figure 3.3.10 Radiating Characteristics of Tungsten................................................................ 3­27

Figure 3.3.11 Luminous Efficacy versus Color Temperature................................................... 3­28

Figure 3.4.1 Illustration of IRL Candidate Standard Level Forms........................................... 3­39

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CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT

3.1 INTRODUCTION

This chapter details the market and technology assessment that the U.S. Department of

Energy (DOE) has conducted in support of the ongoing energy conservation standards and test

procedures rulemakings for general service fluorescent lamps (GSFL) and incandescent reflector

lamps (IRL). These rulemakings are mandated by the Energy Policy and Conservation Act, as

amended (EPCA), and are effective for lamps manufactured in and after 2012.

This chapter consists of three sections: the market assessment, the technology

assessment, and product classes. 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 non­regulatory efficiency improvement programs;

and 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 product classes DOE considered using for this rulemaking and how they were

developed.

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 stakeholders in this assessment.

3.1.1 Definitions

This rulemaking covers certain types of fluorescent and incandescent reflector lamps.

Section 321(30) of EPCA (42 U.S.C. 6291(30)) contains definitions for “fluorescent lamp,”

“general service fluorescent lamp,” “incandescent lamps,” and “incandescent reflector lamp,”

DOE codified in the CFR the statutory definitions and definitions of supplementary terms for

fluorescent and incandescent lamps. 62 FR 29222 (May 29, 1997); 10 CFR section 430.2.

Appendix 3A lists these terms and their definitions.

As part of this energy conservation standards rulemaking, DOE is considering extending

coverage to additional general service fluorescent lamps. (42 U.S.C. 6295(i)(5)) The following

sections describe in more detail EPCA’s definitions for fluorescent and incandescent lamps, note

DOE’s interpretation of the definitions, and note the definitions DOE is considering revising or

developing. Please see section II of the ANOPR Federal Register notice associated with this

rulemaking for more discussion on DOE’s preliminary consideration of additional fluorescent

and incandescent lamps, its interpretation of EPCA’s definitions and its consideration to develop

or revise non­statutory definitions.

3.1.1.1 Fluorescent Lamps

Section 321(30)(A) of EPCA (42 U.S.C. 6291(30)(A)) defines a fluorescent lamp as:

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EERE-2007-BT-TP-0013 COMMENT 05
“a low pressure mercury electric­discharge source in which a fluorescing coating

transforms some of the ultraviolet energy generated by the mercury discharge into light,

including only the following:

(i) Any straight­shaped lamp (commonly referred to as 4­foot medium bi­pin lamps)

with medium bi­pin bases of nominal overall length of 48 inches and rated wattage of 28

or more.

(ii) Any U­shaped lamp (commonly referred to as 2­foot U­shaped lamps) with

medium bi­pin bases of nominal overall length between 22 and 25 inches and rated

wattage of 28 or more.

(iii) Any rapid start lamp (commonly referred to as 8­foot high output lamps) with

recessed double contact bases of nominal overall length of 96 inches and 0.800 nominal

amperes, as defined in ANSI C78.1­1978 and related supplements.

(iv) Any instant start lamp (commonly referred to as 8­foot slimline lamps) with

single pin bases of nominal overall length of 96 inches and rated wattage of 52 or more,

as defined in ANSI C78.3­1978 (R1984) and related supplement ANSI C78.3a­1985.”

In a final rule published May 29, 1997, DOE updated section 321(30)(A)(iv) references

of American National Standards Institute (ANSI) standards by changing “ANSI C78.3­1978”

and “ANSI C78.3a­1985” to ANSI C78.1­1991 and C78.3­1991.a 62 FR 29222.

3.1.1.2 General Service Fluorescent Lamps

Section 321(30)(B) of EPCA (42 U.S.C. 6291(30)(B)) defines general service fluorescent

lamps as:

“fluorescent lamps which can be used to satisfy the majority of fluorescent applications,

but does not include any lamp designed and marketed for the following nongeneral

lighting applications:

(i) Fluorescent lamps designed to promote plant growth.

(ii) Fluorescent lamps specifically designed for cold temperature installations.

(iii) Colored fluorescent lamps.

(iv) Impact­resistant fluorescent lamps.

a ANSI C78.3­1978 is an ANSI­published guide to standard characteristics for instant start and cold­cathode

fluorescent lamps. C78.1­1978 is the equivalent guide for rapid start fluorescent lamps. Supplements to C78.3­

1978 and C78.1­1978 update the guides over time. In 1991, ANSI combined the original standards with their

supplements into C78.3­1991 and C78.1­1991, respectively. In 1997, DOE incorporated definitions for fluorescent

lamps into the Code of Federal Regulations (CFR). 62 FR 29238. DOE used the statutory definition, but replaced

“ANSI C78.1­1978 and related supplements” with “ANSI C78.1­1991” and replaced “ANSI C78.3­1978 (R1984)

and related supplement C78.3a­1985” with “C78.3­1991.”

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EERE-2007-BT-TP-0013 COMMENT 05
(v) Reflectorized or aperture lamps.

(vi) Fluorescent lamps designed for use in reprographic equipment.

(vii) Lamps primarily designed to produce radiation in the ultra­violet region of

the spectrum.

(viii) Lamps with a color rendering index of 87 or greater.”b

As part of this rulemaking, under the authority of 42 U.S.C. 6295(i)(5), DOE is

considering extending coverage to additional general service fluorescent lamps. In the ANOPR

Federal Register notice, DOE considers extending energy conservation standards coverage to the

following list of “additional general service fluorescent lamps”:

• 4­foot, medium bipin lamps with wattages ≥ 25 and < 28;

• 8­foot recessed double contact, rapid start, HO lamps not defined in ANSI Standard

C78.1­1991;

• 8­foot recessed double contact, rapid start, HO lamps (other than 0.800 nominal amperes)

defined in ANSI Standard C78.1­1991; and

• 8­foot single pin instant start slimline lamps, with a rated wattage ≥ 52, not defined in

ANSI Standard C78.3­1991.

DOE is also considering revising the existing definitions for “rated wattage” and “colored

fluorescent lamp,” as discussed in the ANOPR Federal Register notice.

3.1.1.3 Incandescent Reflector Lamps

Section 321(30)(F) of EPCA (42 U.S.C. 6291(30)(F)) defines an incandescent reflector

lamp as “a lamp described in subparagraph (C)(ii)” of the definition for incandescent lamp.

Section 321(30)(C) of EPCA (42 U.S.C. 6291(30)(C)) defines “incandescent lamp” as:

“a lamp in which light is produced by a filament heated to incandescence by an electric

current, including only the following:

(i) Any lamp (commonly referred to as lower wattage nonreflector general service

lamps, including any tungsten­halogen lamp) that has a rated wattage between 30

and 199 watts, has an E26 medium screw base, has a rated voltage or voltage

range that lies at least partially within 115 and 130 volts, and is not a reflector

lamp.

(ii) Any lamp (commonly referred to as a reflector lamp) which is not colored or

designed for rough or vibration service applications, that contains an inner

b Section 316(b) of the Energy Independence and Security Act of 2007 amended section 321(30)(B)(viii) of EPCA

(42 U.S.C 6291(30)(B)(viii)) by replacing the exclusion for lamps with a CRI of 82 or greater, with an exclusion of

lamps with a CRI of 87 or greater.

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reflective coating on the outer bulb to direct the light, an R, PAR, ER, BR, BPAR

or similar bulb shapes with E26 medium screw bases, a rated voltage or voltage

range that lies at least partially within 115 and 130 volts, a diameter which

exceeds 2.25 inches, and has a rated wattage that is 40 watts or higher.

(iii) Any general service incandescent lamp (commonly referred to as a high­ or

higher­wattage lamp) that has a rated wattage above 199 watts (above 205 watts

for a high wattage reflector lamp).”

As seen above in subparagraph (ii) of the definition of “incandescent lamp” contains

several terms that limit scope of IRL. Appendix 3A contains statutory and CFR definitions for

many of these terms. Concerning E26 medium screw bases, DOE will use the definition of

“medium screw base” as added to EPCA in section 135(a)(3) of the Energy Policy Act of 2005

(EPACT 2005), Public Law 109­58. (42 U.S.C. 6291(51)) This defines an Edison screw base

with the prefix E26 as that appearing in the “American National Standard for Electric Lamp

Bases,” ANSI/IEC C81.61–2003, published by the American National Standards Institute. This

version of C81.61 identifies four lamp base (cap) types with a prefix of E26, which are singlecontact medium screw (E26/24), double­contact medium screw (E26d), skirted medium screw

for PAR lamps (E26/50x39), and extended skirted medium screw for R­lamps (E26/53x39).

3.2 MARKET ASSESSMENT

The following market assessment:

• identifies the manufacturer trade association and domestic manufacturers of GSFL

and IRL;

• discusses manufacturer market share, regulatory programs, and non­regulatory

initiatives;

• defines product classes;

• provides historical shipment data, shipment projections, and equipment lifetime

estimates; and

• summarizes market performance data.

3.2.1 Trade Association

The National Electrical Manufacturers Association (NEMA) is the trade association of

GSFL and IRL. In addition to lamps, NEMA’s Lighting Systems Division also oversees

products such as ballasts, emergency lighting, lighting controls, luminaires, solid state lighting,

and other emerging lighting technologies. NEMA provides an organization through which

manufacturers of lighting equipment can work together on projects that affect their industry and

business. NEMA’s activities relating to energy efficiency include:1

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• “Advising DOE and executive agencies on lighting research and market transformation

needs

• Participating in the climate change discussions with the Administration and Congress

• Monitoring energy­efficiency 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 (FEMP) on energy­efficient

lighting recommendations

• Coordinating with the DOE and Environmental Protection Agency on Energy Star®

Buildings and Energy Star voluntary product labeling programs.

• Advocating market­based approaches to enhance the use and penetration of energyefficient technologies.”

3.2.2 Manufacturers and Market Share

Table 3.2.1 lists NEMA members that manufacture GSFL, IRL, or GSIL. Parent

companies are shown in parentheses, if applicable.

Table 3.2.1 NEMA General Service Fluorescent Lamp and Incandescent Reflector Lamp

Manufacturers

EYE Lighting International of

North America, Inc. (Iwaski

Electric Co. Ltd.)

Phillips Lighting (Royal Philips

Electronics)

Venture Lighting International,

Inc. (Advanced Lighting

Technologies, Inc.)

Feit Electric Company. Ruud Lighting Inc. Welch Allyn, Inc.

GE Consumer and Industrial

(General Electric)

SLi Lighting (Sylvania Lighting

International)

Westinghouse Lighting

Corporation, Inc. (Westinghouse

Electric Corp.)

Halco Lighting Corporation Technical Consumer Products, Inc.

OSRAM Sylvania (Siemens USHIO America, Inc. (USHIO

AG). INC)

Table 3.2.2 lists the manufacturers that produce general service fluorescent lamps.

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Table 3.2.2 General Service Fluorescent Lamp Manufacturers

AAMSCO Lighting, Inc. Glass Surface Systems Inc. SLi Lighting

American Lighting Halco Lighting Corporation Standard Products Inc.

Bulbrite Industries, Inc. Hi­Light Lighting Co. Ltd. Star Lighting Products

CCL, Inc. Hybec Corporation Sunrise Lighting

DURA Lamp Interlectric Corporation Super Trend Lighting Ltd.

Duro­Test Lighting, Inc. Iwasaki Electric Co., Ltd Surya Roshni Inc.

e3light LCD Lighting, Inc. Technical Consumer Products,

Inc.

EGL Company, Inc. LITETRONICS International, Trojan Inc

Inc.

Eiko Lux Elextronic Products, Inc. Turolight Inc.

Feit Electric Company OSRAM Sylvania USHIO America, Inc.

Fulham Inc. Panasonic Corporation of North Voltarc Technologies, Inc.

America

Full Spectrum Solutions, Inc. Philips Lighting Zhejiang Yankon Group Co., Ltd

GAL Lighting Promolux Lighting International

GE Consumer and Industrial Shenzhen Shensco Pholighting

(General Electric) Tech Co., Ltd

Table 3.2.3 lists the manufacturers that produce IRL.

Table 3.2.3 Incandescent Reflector Lamp Manufacturers

Aero­Tech Light Bulb Co. GAL Lighting Philips Lighting

AAMSCO Lighting, Inc. GE Consumer and Industrial Shanghai Luxiang Lighting

(General Electric) Co.,Ltd

American Lighting Glass Surface Systems Inc. SLi Lighting

Bulbrite Industries, Inc. Globe Electric Company Inc. Standard Products Inc.

CAST Lighting LLC. Halco Lighting Corporation Sunrise Lighting

CCL, Inc. Hi­Light Lighting Co. Ltd. Super Trend Lighting Ltd.

DURA Lamp Hybec Corporation Surya Roshni Inc.

Duro­Test Lighting, Inc. Interlectric Corporation Trojan Inc

e3light Iwasaki Electric Co., Ltd Turolight Inc.

Eiko Lights of Australia Uninex International

EYE Lighting International of LITETRONICS International, USHIO America, Inc.

North America, Inc. Inc.

Feit Electric Company OSRAM Sylvania

Three manufacturers hold the majority of the domestic market share of GSFL and IRL.

These manufacturers are listed below.

• GE Consumer and Industrial of General Electric, Inc. (hereafter, “GE)

• OSRAM Sylvania of Siemens AG (hereafter “Osram”)

• Philips Lighting of Royal Philips Electronics (hereafter “Philips”)

In addition to lamps listed under this rulemaking, the lighting divisions of all three

companies manufacture other products, such as lamp ballasts, high intensity discharge lamps,

LED lighting, and compact fluorescent lamps (CFL).

3.2.2.1 Small Businesses

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Small businesses may be particularly affected by the promulgation of minimum energy

conservation standards for fluorescent and incandescent lamps. The Small Business

Administration (SBA) defines small business manufacturing enterprises for GSFL and IRL as

having 1,000 employees or fewer.2 SBA lists small business size standards that are matched to

industries as they are described in the North American Industry Classification System (NAICS).

A size standard is the largest that a for­profit 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.

DOE will study the potential impacts on these small businesses in detail during the

manufacturer impact analysis, which it will conduct as part of the Notice of Proposed

Rulemaking analysis. Table 3.2.4 lists the small business fluorescent and incandescent reflector

lamp manufacturers that DOE has identified.

Table 3.2.4 Small Business Manufacturers of General Service Fluorescent Lamps or

Incandescent Reflector Lamps

American Lighting Halco Lighting Corporation Promolux Lighting International

CCL, Inc. Hybec Corporation Star Lighting Products

Duro­Test Lighting, Inc. Interlectric Corporation Trojan Inc

EGL Company, Inc. LCD Lighting, Inc. SLi Lighting

Eiko LITETRONICS International, Inc Voltarc Technologies, Inc.

Full Spectrum Solutions, Inc. Lux Elextronic Products, Inc.

3.2.3 Regulatory Programs

DOE is aware of several Federal and international regulatory programs that affect the

markets for GSFL and IRL. Amendments to EPCA in the Energy Policy Act of 1992

(EPACT1992), P.L. 102­486, established energy conservation standards for GSFL and IRL. (42

U.S.C. 6291(1) and 6295(i)(1)) In addition, subsequent amendments to EPCA in the Energy

Independence and Security Act of 2007 (EISA 2007), P.L. 110­140, amended the existing

standard for IRL.

The following section summarizes U.S. and Canadian regulatory initiatives relevant to

the lamps covered by this rulemaking. While the following discussion is not exhaustive in

describing all regulatory action related to GSFL and IRL, it provides detail on some notable

initiatives that characterize recent developments in the lighting market.

3.2.3.1 Federal Energy Conservation Standards

Table 3.2.5 shows the Federal standards that regulate 4­foot medium bipin, 2­foot Ushaped, 8­foot single pin slimline, and 8­foot recessed double contact high output general

fluorescent lamps. The standards mandate that lamps manufactured on or after the specified

effective dates must meet the minimum CRI and minimum average lamp efficacy. 42 U.S.C.

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6295(i)(1); 10 CFR Section 430.32(n)(1)

Table 3.2.5 Federal Regulations for General Service Fluorescent Lamps

Lamp Type Nominal Lamp

Wattage

W

Minimum

CRI

Minimum Average

Lamp Efficacy

lm/W

Effective Date

Four­Foot Medium Bipin > 35 W 69 75.0 Nov. 1, 1995

≤ 35 W 45 75.0 Nov. 1, 1995

Two­Foot U­Shaped > 35 W 69 68.0 Nov. 1, 1995

≤ 35 W 45 64.0 Nov. 1, 1995

Eight­Foot Slimline > 65 W 69 80.0 May 1, 1994

≤ 65 W 45 80.0 May 1, 1994

Eight­Foot High Output > 100 W 69 80.0 May 1, 1994

≤ 100 W 45 80.0 May 1, 1994

Fluorescent lamp ballasts are also regulated at the Federal level. Though they are not

covered by this rulemaking, the ballast on which fluorescent lamps operate affects the systems’

operating characteristics (total system power, lumen output, etc.) and therefore will affect the

analyses DOE conducts. On September 19, 2000, DOE issued a Final Rule establishing energy

conservation standards for ballasts that operate one F40T12 lamp, two F40T12 lamps, two

F96T12 lamps, or two F96T12HO lamps (hereafter referred to as ‘‘the Ballast Rule’’). 65 FR

56740 (Sept. 19, 2000); 10 CFR 430.23(m)(4). This rule bans the fabrication of ballasts that do

not meet these ballast efficacy factor (BEF) requirements as of April 1, 2005. The ban on U.S.

sales by ballast manufacturers to fixture manufacturers took effect July 1, 2005. The ban on U.S.

sales of ballasts in lighting fixtures took effect on April 1, 2006. The ban on U.S. sales of

replacement ballasts begins on July 1, 2010. The regulations provide for some exemptions.

Table 3.2.6 EPCA Standards for Fluorescent Lamp Ballasts

Application for Operation of Ballast Input

Voltage

V

Total Nominal

Lamp Watts

W

Ballast Efficacy

Factor

One F40T12 Lamp 120 40 1.805

277 40 1.805

Two F40T12 Lamps 120 80 1.060

277 80 1.050

Two F96T12 Lamps 120 150 0.570

277 150 0.570

Two F96 T12 HO Lamps 120 220 0.390

277 220 0.390

Sections 135(a) of EPACT 2005 amended EPCA to set additional requirements for

fluorescent lamp ballasts operating one F34T12 lamp, two F34T12 lamps, two F96T12/ES

lamps, or two F96T12HO/ES lamps (hereafter referred to as “the EPACT 2005 Ballast

Standard”). (42 U.S.C. 6291(29) and 6295(g)(8)(a)) Table 3.2.7 outlines the EPACT 2005

Ballast Standards that DOE codified in the U.S. Code of Federal Regulations. (See 10 CFR

430.32(m)(5)) This standard effectively bans the fabrication of ballasts that do not meet these

BEF requirements as of July 1, 2009. The effective ban on U.S. sales by ballast manufacturers to

fixture manufacturers takes effect October 1, 2009. The effective ban on U.S. sales of ballasts in

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EERE-2007-BT-TP-0013 COMMENT 05
lighting fixtures takes effect on July 1, 2010. The ban on U.S. sales of replacement ballasts

begins on October 1, 2010. EPACT 2005 provided some exemptions.

Table 3.2.7 EPACT 2005 Standards for Fluorescent Lamp Ballasts

Application for Operation of Ballast Input

Voltage

V

Total Nominal

Lamp Watts

W

Ballast Efficacy

Factor

One F34T12 Lamp 120 34 2.61

277 34 2.61

Two F34T12 Lamps 120 68 1.35

277 68 1.35

Two F96T12/ES Lamps 120 120 0.77

277 120 0.77

Two F96T12HO/ES Lamps 120 190 0.42

277 190 0.42

The Ballast Rule and the EPACT 2005 Ballast Standard effectively end the sale of

magnetic ballasts that operate one F40T12 lamp, two F40T12 lamps, one F34 T12 lamp, two

F34T12 lamps, or two F96T12/ES lamps. Although there are still magnetic ballasts that operate

8­foot recessed double contact HO lamps, these ballasts are both less efficient and more

expensive than their electronic counterparts.3 Therefore, although the most common ballast

installed in 2012 for T12 lamps are magnetic ballasts, the most common ballast sold after 2012

will likely be electronic T12 or electronic T8 ballasts.

In addition to Federal energy conservation standards for fluorescent lamps, EPCA also

set Federal energy conservation standards for IRL. (42 U.S.C. 6295(i)(1)) Table 3.2.8 outlines

these standards. EPCA mandated that all lamps manufactured after November 1, 1995 meet six

efficacy requirements. Minimum lamp efficacy varies by nominal lamp wattage. One effect of

these standards is increased use of higher efficacy halogen lamps as a replacement for standard

IRL. EISA 2007 amended EPCA’s definition for incandescent reflector lamp and amended the

standard in 42 U.S.C. 6295(i)(1). Prior to EISA 2007, the statutory definition for IRL excluded

ER and BR shaped lamps and lamps with a diameter less than 2.75 inches. However, EISA

2007, amended this definition to include ER and BR shaped lamps and lamps with diameter

greater than 2.25 inches. EISA 2007 also amended 42 U.S.C. 6295(i)(1) to exempt the following

lamps from the minimum efficacy requirements: (1) lamps rated at 50 watts of less that are

ER30, BR30, BR40, and ER40; (2) lamps rated at 65 watts that are BR30, BR40, or ER40 lamps;

and (3) R20 incandescent reflector lamps rated 45 watts or less.

Table 3.2.8 Federal Regulations for Incandescent Reflector Lamps

Nominal Lamp Wattage Minimum Average Lamp Efficacy

W lm/W

40­50 10.5

51­66 11.0

67­85 12.5

86­115 14.0

116­155 14.5

156­205 15.0

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3.2.3.2 Canadian Energy Efficiency Standards

The Natural Resources Canada (NRCan) Office of Energy Efficiency regulates the

energy efficiency of GSFL and IRL in Canada. In 1992, Parliament passed the Energy

Efficiency Act (S.C. 1992, c. 36), which concerns minimum performance levels for energy­using

products, effective February 1995. In November 1995, Canada’s Energy Efficiency Regulations

(SOR/94­651) were amended to include GSFL and some GSIL. An amendment in April 2003

included regulation of selected ER and BR IRL.

Canada’s approach to the regulation of GSFL closely resembles the U.S. Federal

Efficiency Standard discussed in section 3.2.3.1. The Canadian minimum average CRI and lamp

efficacy levels are identical to those shown in Table 3.2.5. Though there are minor variations in

definition between the U.S. and Canadian standards, they effectively cover the same product.

The Canadian test procedures refer to a document published by the Canadian Standards

Association (CSA). CSA is an independent standards­setting agency that establishes test

procedures and efficiency standards that are typically adopted by the Canadian government.

Fluorescent lamp test procedure CAN/CSA­C819­95 (2001), entitled Performance of General

Service Fluorescent Lamps, references applicable ANSI, CIE, and IES standards.

Canada’s approach to regulating IRL differs from the U.S. approach. Similar to the

United States, Canada covers R, PAR, and lamps with similar bulb shapes. However, Canada

also regulates selected ER and BR lamps. The Energy Efficiency Regulations of Canada apply

to three categories of IRL: general service incandescent reflector lamps, BR lamps, and ER

lamps. A “general service incandescent reflector lamp” is defined as an:

“Incandescent reflector lamp

“a. with an R bulb shape, a PAR bulb shape or a bulb shape similar to R or PAR that

is neither ER nor BR, as described in ANSI C79.1,

b. with an R bulb shape, a PAR bulb shape or a bulb shape similar to R or PAR that

is neither ER nor BR, as described in ANSI C79.1,

c. with a nominal voltage or voltage range that lies at least partially between 100

volts and 130 volts,

d. with a diameter greater than 70 mm (2.75 inches), and

e. that has a nominal power of not less than 40 W and not more than 205 W,

but does not include:

f. a coloured incandescent reflector lamp, or

g. an incandescent reflector lamp that

i) is of the rough or vibration service type with:

(A) a C­11 filament, as described in the IES Handbook, with five supports

exclusive of lead wires,

(B) a C­17 filament, as described in the IES Handbook, with eight supports

exclusive of lead wires, or

(C) a C­22 filament, as described in the IES Handbook, with 16 supports

exclusive of lead wires,

(ii) is of the neodymium oxide type and has a lens containing not less than 5%

neodymium oxide,

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EERE-2007-BT-TP-0013 COMMENT 05
(iii) has a coating or other containment system to retain glass fragments if the

lamp is shattered and is specifically marked and marketed as an impact­resistant

lamp,

(iv) is specifically marked and marketed for plant growth use and has a spectral

power distribution that:

(A)is different from that of the lamps described in paragraphs (a) to (e), and

(B) contains a filter that suppresses yellow and green portions of the spectrum,

or

(v) is specifically marked and marketed

(A) as an infrared heat lamp,

(B) for heat­sensitive use,

(C) for mine use,

(D) for marine, aquarium, terrarium or vivarium use, or

(E) for airfield, aircraft or automotive use.”

BR lamps are defined as:

“Incandescent reflector lamp as described in ANSI C79.1, but does not include any of

those lamps that have

a. a diameter of 95.25 mm (BR30) and a nominal power of less than 66 W,

b. a diameter of 92.5 mm (BR30) and a nominal power of 85 W, or

c. a diameter of not less than 120.65 ,mm(BR38) but not more than 127 ,mm (BR40)

and a nominal power of less than 121 W.”

ER lamps are defined as incandescent reflector lamps as described in ANSI C79.1. Table

3.2.9 shows the Canadian energy conservation standards for IRL. In addition to the referenced

ANSI documents in the definitions, the Canadian test procedures reference CAN/CSA­C862­01,

Performance of Incandescent Reflector Lamps. The standards became effective on April 1, 1996

for GSFL and IRL and on January 1, 2003 for additional ER and BR lamps.

Table 3.2.9 Canadian Energy Efficiency Regulations for Incandescent Reflector Lamps

Rated Wattage

W

Minimum Average Lamp Efficacy

lm/W

ER Lamps

50 7.0

75 6.5

120 10.0

R, PAR, BR Lamps, and ER Lamps Not Covered Above

40­50 10.5

51­59 11.0

60­85 12.5

86­115 14.0

116­155 14.5

156­205 15.0

In November 2006, NRCan published a bulletin proposing to amend Canada's Energy

Efficiency Regulations. NRCan proposed testing and labeling requirements for light output,

input wattage, and rated lifetime for GSFL, medium base, integrally ballasted CFLs, and

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reflector and non­reflector GSIL.4 The bulletin also proposed a definition for non­reflector

GSIL:

3.2.4 Non­Regulatory Initiatives

DOE reviewed several national, regional, and local voluntary programs that promote the

use of energy­efficient lighting in the United States. FEMP’s program for energy­efficient

lighting, the Consortium for Energy Efficiency (CEE)’s High Performance Commercial Lighting

Initiative, the Energy Efficient Commercial Buildings Deduction, and the Northeast Energy

Efficiency Partnership (NEEP) are a few examples. The following section summarizes some of

these programs for the lamps covered by this rulemaking. While it is not an exhaustive, the

discussion provides detail on some notable initiatives that characterize recent developments in

the lighting market.

3.2.4.1 Federal Energy Management Program

FEMP helps Federal buyers identify and purchase energy­efficient products including

certain GSFL. Section 161 of EPACT 1992 encourages energy­efficient Federal procurement.

Executive Order 12902 and FAR section 23.704 direct agencies to purchase products in the

upper 25 percent of energy efficiency. As Table 3.2.4 shows, FEMP provides recommendations

of total light output (in lumens) and the best available models at the time of publishing.5 FEMP

offers buyers support tools such as efficiency guidelines, cost­effectiveness examples, and a cost

calculator. FEMP also offers training, on­site audits, demonstrations, and design assistance.

Table 3.2.10 Federal Energy Management Program Efficiency Recommendation

Lamp Type Recommended Best Available

Four­Foot T8, 32W 2,800 lumens or more 3,000 lumens

Four­Foot T12, 34W 2,800 lumens or more 2,900 lumens

Eight­Foot T8, 59W 5,700 lumens or more 5,950 lumens

Eight­Foot T12, 60W 5,600 lumens or more 6,000 lumens

T8/U, 31­32w 2,600 lumens or more 2,850 lumens

T12/U, 34w 2,700 lumens or more 2,760 lumens

3.2.4.2 Consortium for Energy Efficiency

CEE has both a Residential Lighting Initiative and a High­Performance Commercial

Lighting Initiative. The Residential Lighting Initiative primarily promotes high efficiency

fixtures and CFLs, neither of which is covered under this rulemaking. The purpose of CEE’s

High­Performance Commercial Lighting Initiative is to define what constitutes “high

performance,” and the initial efforts have focused on efficient T8 lighting products. On May 1,

2007, CEE updated its specification for high­performance T8 lamps as a T8 lamp not greater

than 32W with a minimum initial lamp lumens of 3,100 lumens or greater.6 On January 23,

2007, CEE released its specification for reduced­wattage T8 lamps as a lamp of 25W or 28W

with minimum initial lumen output greater than or equal to 2,585 lumens or 2,400 lumens,

respectively.7

3.2.4.3 Energy Efficient Commercial Building Deduction

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EPACT 2005 created the Energy Efficient Commercial Buildings Deduction (26 U.S.C

179D), which establishes a tax deduction for building owners who incur expenses for energy

efficiency upgrades. Effective for property in service from January 1, 2006 through December

31, 2008, the deduction allows partial deductions for improvement in interior lighting. Though

the statute does not specify required lamp types or efficacies, it does call for an overall reduction

in lighting power density, encouraging the use of higher performance and reduced­wattage

GSFL.

3.2.4.4 Northeast Energy Efficiency Partnerships

Northeast Energy Efficiency Partnerships (NEEP) is a regional nonprofit organization

that promotes energy efficiency in the Northeast. NEEP currently runs a High Efficiency

Commercial Lighting Initiative to “achieve cost­effective energy and demand by overcoming

market barriers to the availability and widespread market adoption of advanced T8 fluorescent

lighting systems.”8 NEEP coordinates with multiple local and state governments, utilities, and

other initiatives, such as Efficiency Vermont and the Long Island Power Authority, to promote

efficient lighting products. Efficiency Vermont offers technical assistance and financial

incentives to encourage energy efficiency in Vermont. This organization offer rebates of $15 for

the installation of “Super T8” lamp­and­ballast systems. It also provides a custom rebate for

reduced­wattage T8 lamps.9 The Long Island Power Authority is a non­profit municipal electric

utility that serves the Long Island area. It provides rebates for high­performance T8 systems and

T5 fixtures ranging from $10 to $35.10

3.2.5 Historical Shipments

Awareness of annual product shipment trends is an important aspect of the market

assessment and the development of the standards rulemaking. For this rulemaking, DOE

received from NEMA historical shipments from 2001 to 2005 of GSFL and IRL.11 DOE used

this data for three main purposes. First, the shipment data and market trend information

contributed to the shipments analysis and base­case forecast for GSFL and IRL (see Chapter 9).

By using recent shipment data and expert opinion on market trends, DOE believes that the

shipments model and base­case forecasts are based on a sound dataset. Second, DOE used the

data to select the representative product classes and representative units for analysis. Generally,

DOE selected representative product classes and units for analysis to reflect the highest volume,

most common lamp types and wattages used in the United States today (see Chapter 5). Third,

DOE used these data to develop the market share matrices for the national impact analysis (see

Chapter 10). Based on its understanding of trends in the market, DOE estimated how the market

would respond to the various candidate standard levels.

For GSFL, the historical shipment data is broken down by lamp length (2­foot, 4­foot, and

8­foot), diameter (T12 and T8), shape (linear and U­shaped), and lumen output (regular or high

output (HO)). Four­foot medium bipin lamps constitute the vast majority of GSFL sales. These

are followed in order of unit sales by 8­foot single pin slimline lamps and 8­foot recessed double

contact HO lamps, which together constitute under a quarter of GSFL sales. Four­foot medium

bipin, 8­foot single pin slimline, and 8­foot recessed double contact HO lamps are the most

common GSFL. Shipments of 2­foot U­shaped lamps account for under 5 percent of GSFL unit

sales historically.

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GSFL in the categories of 4­foot medium bipin, 8­foot single pin slimline, and 2­foot Ushaped lamps are primarily used in the commercial sectors. As Table 3.2.11 shows, 4­foot

fluorescent lamp shipments show a clear decrease in the T12 market share and an increase in the

T8 market share. These shipments, coupled with information obtained from NEMA and

manufacturers, suggest that consumers are moving away from 4­foot T12 fluorescent lamps and

toward 4­foot T8 fluorescent lamps. This trend is reflected both in the popularity of T8 lamps in

new construction and in lighting system retrofits and renovations where the ballast is replaced.

The vast majority of 4­foot T12 ballasts are magnetic, while the vast majority of 4­foot T8

ballasts are electronic. This decline of 4­foot T12 shipments will most likely be compounded in

2010 when new energy conservation standards for fluorescent ballasts, including replacement

F40T12 ballasts and new F34T12 ballasts, go into effect. (See 10 CFR 430.32(m)(4)(ii) and

430.32(m)(5)­(6)) For 4­foot F40 T12 and F34T12 lamps, discussions with manufacturers

suggest that they anticipate their customers will shift to T8 counterparts instead of T12 lamps

that operate with electronic ballasts.

Table 3.2.11 NEMA Shipments of Four­Foot General Service Fluorescent Lamps

Unit Sales by Year

thousands

2001 2002 2003 2004 2005

T12 Four­Foot Medium Bipin 212,564 205,998 181,931 175,850 162,664

T8 Four­Foot Medium Bipin 164,129 163,632 172,294 195,698 215,530

Total Four­Foot Medium Bipin 376,593 369,630 354,225 371,548 378,194

As Table 3.2.12 shows, historical shipments of 8­foot GSFL reflect a decline in

shipments of 8­foot T12 lamps and an increase in shipments of 8­foot T8 lamps. However, this

increased market share in 8­foot T8 lamps does not sufficiently compensate for the decreased

shipments of 8­foot T12 lamps. Discussions with NEMA, manufacturers, and lighting experts

suggest that a portion of the 8­foot T12 market is being transferred to the 4­foot T8 market.

However, because the lumen output from a conventional 8­foot lamp­and­ballast system is

significantly higher than that of a 4­foot lamp­and­ballast system, it is likely that one 8­foot

system containing two lamps will be replaced by two 4­foot systems, each containing two lamps.

It is therefore possible that any standard affecting shipments of T12 8­foot single pin slimline

GSFL may also notably affect the shipments of T8 4­foot medium bipin GSFL.

Table 3.2.12 NEMA Shipments of Eight­Foot Single Pin Slimline General Service

Fluorescent Lamps

Unit Sales by Year

thousands

2001 2002 2003 2004 2005

T12 Eight­Foot Single Pin Slimline 43,265 41,443 37,170 36,263 33,636

T8 Eight­Foot Single Pin Slimline 4,405 5,300 5,183 5,727 5,176

Total Eight­Foot Single Pin Slimline 47,670 46,743 42,353 41,990 38,812

Table 3.2.13 shows the historical shipments of 2­foot U­shaped GSFL. While no clear

trend can be seen in the market share progression of U­shaped T12 and T8 lamps, the market

share of U­shaped lamps is small compared to that of 4­foot medium bipin and 8­foot single pin

slimline lamps.

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Table 3.2.13 NEMA Shipments of Two­Foot U­Shaped General Service Fluorescent Lamps

Unit Sales by Year

thousands

2001 2002 2003 2004 2005

T12 Two­Foot U­Shaped 9,672 9,314 9,460 7,014 8,839

T8 Two­Foot U­Shaped 8,014 6,784 7,018 9,224 8,659

Total Two­Foot U­Shaped 17,686 16,098 16,478 16,238 17,496

While 4­foot medium bipin, 8­foot single pin slimline, and 2­foot U­shaped lamps are

primarily used in the commercial sector, 8­foot high output lamps are primarily used in the

industrial sector for applications such as high­bay lighting. Discussions with experts and

manufacturers indicate that most of the recessed double contact HO lamps currently sold are

used with electronic ballasts. The market share of 8­foot recessed double contact HO is

relatively small compared to that of 4­foot medium bipin and 8­foot single pin slimline lamps.

As seen in NEMA’s shipments data, T12 8­foot recessed double contact HO lamps have the

majority of the recessed double contact HO market. Discussions with lighting experts and lamp

manufacturers indicate that they expect any migration of the 8­foot recessed double contact HO

market to go toward T5 fluorescent lamps and metal halide lamps.

Table 3.2.14 NEMA Shipments of Eight­Foot High Output General Service Fluorescent

Lamps

Unit Sales by Year

thousands

2001 2002 2003 2004 2005

T12 Eight­Foot Recessed Double Contact HO 23,887 24,398 24,206 24,591 25,442

T8 Eight­Foot Recessed Double Contact HO 691 647 467 674 420

Total Eight­Foot Recessed Double Contact HO 24,578 25,045 24,673 25,265 25,862

IRL are primarily used in the commercial and residential sectors. Based on interviews

with lighting experts, DOE estimates that approximately 80 percent of halogen IRL are used in

the commercial sector and 20 percent are used in the residential sector. DOE also estimates that

20 percent of the incandescent (i.e., non­halogen) reflector lamps are used in the commercial

sector, and that the balance (80 percent) is used in the residential sector. As Table 3.2.15 shows,

historical shipment data indicates that the total market share of halogen IRL is growing.

However, its slow rate of growth suggests either that the market has reached near equilibrium or

that competing incandescent IRL are successfully gaining market share and new installation

opportunities. The shipment data in Table 3.2.15 reflects this trend, indicating comparatively

large growth among non­halogen IRL, in contrast to the relatively flat growth for halogen IRL.

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Table 3.2.15 NEMA Shipments of Incandescent Reflector Lamps

Unit Sales by Year

thousands

2001 2002 2003 2004 2005

PAR Incandescent 8,900 6,697 5,090 5,308 15,018

R Incandescent 89,465 96,218 103,407 111,720 124,641

PAR 38 Halogen 40,804 45,938 45,673 49,937 46,329

PAR 30 and PAR 20 Halogen 32,523 27,128 30,506 35,567 39,985

Total Incandescent Reflector Lamps 171,692 175,961 184,676 202,532 225,973

3.3 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 GSFL and IRL. The following assessment provides

brief descriptions of the basic construction and operation of each lamp type, followed by a

discussion of technology options to improve the efficacy of that lamp type.

3.3.1 General Service Fluorescent Lamps

The fluorescent lamp is a low pressure gas discharge source. The lamp consists of a glass

bulb or tube, filled with low pressure mercury vapor and inert gas, with electrodes sealed onto

both ends of the tube. An arc, in the form of primarily ultraviolet (UV) radiation, is produced by

current flowing between the two electrodes. The phosphors coating the bulb’s inner wall then

absorb this UV radiation and emit light in the visible spectrum. The fluorescent lamp has five

major components in its construction: bulb, electrodes, base, gas fill, and phosphors.

Fluorescent lamp bulbs can be manufactured in a variety of shapes and sizes. The GSFL

lamps in this rulemaking include 4­foot and 8­foot linear lamps and 2­foot U­shaped lamps.

Changing the shape of the lamp can alter the overall efficacy as the lamp may require a different

voltage to maintain the discharge and UV radiation. In addition, the length of a lamp also

influences it efficacy. As Figure 3.3.1 shows, the greater the length, the higher the efficacy,

since losses associated with the electrodes are essentially constant. Therefore, a longer arc

length will have less electrode power loss relative to the total losses. However, because different

lamp shapes and lengths may provide different utility to the consumer and also depend on the

lighting fixture, DOE is not considering these properties as technology options. Rather, as

indicated in the discussion of product classes in Section 3.4, product classes differentiate lamps

by their shape and length.

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Figure 3.3.1 Lamp Length Effects on Efficacy

Source: IESNA Lighting Handbook: Reference & Application12

Two electrodes are hermetically sealed to both ends of the bulb. The electrodes are

usually constructed from coiled tungsten wires coated with a mixture of alkaline oxides. A base

provides an electrical connection to these electrodes and also supports the lamp. Depending on

the start method and operational properties of the lamp (e.g., dimming, wattage, etc.), lamp

designs may use different bases such as single pin, medium bipin, and recessed double contact.

In its analysis, DOE determined that base type and size has little to no effect on efficacy and

therefore did not consider these as technology options. Once voltage is applied to the electrodes,

the tungsten coil and coatings emit large quantities of electrons when the coating is at the proper

temperature (1,000–1,300 K). These electrons then collide with gaseous mercury atoms, exciting

electrons within those atoms. As the electrons decay to their stable or ground state, they emit

ultraviolet radiation primarily at 254 nanometers (nm). In addition to the mercury vapor, an inert

gas or a combination of gases is added to the lamp primarily to moderate the collisions of

mercury ions and minimize evaporation of the electrode coating. As discussed above, the UV

radiation is then absorbed by the phosphors and reemitted as light.

A fluorescent lamp must be operated in series with a current­limiting device, which is

usually a magnetic or electronic ballast. Each ballast has an associated BF that affects the total

light output of the fluorescent lamp. In addition to limiting current, ballasts also supply starting

and operating voltages required by the lamp. Some ballasts also preheat the electrodes before

initiating the arc. Magnetic fluorescent lamp ballasts use a variety of starting methods, including

preheat start, instant start, or rapid start.c Electronic ballasts can also use a variety of starting

In the preheat start method, usually used with bipin bases, a current passes through both electrodes in series,

heating them. A thermal switch then opens to apply a voltage applied across the lamp and induces the arc. Instant

starting, usually used with a single pin base and with no heating of the electrodes, involves a high voltage (400V to

1,000V) applied across the lamp. This voltage causes the ejection of electrons from the electrodes, creating the arc

discharge. The arc current subsequently heats the electrodes. Rapid start lamps, operating on a bipin base, can also

be instant started and operate similarly. However, in rapid start, the electrodes are continuously actively heated

during operation by passing a small current to each of the electrodes while maintaining a voltage difference across

the lamp.

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methods, including instant start, rapid start, and programmed start.d Because different starting

methods result in changes in lamp efficacy, the test procedure for GSFL requires that the efficacy

of each lamp is measured using a common starting method and ballast. However, DOE

considers different starting methods in its analysis. For example, DOE pairs base case 4­foot

T12 medium bipin lamps with magnetic, rapid­start ballasts, and base case 4­foot T8 medium

bipin lamps with electronic, instant­start ballasts. Magnetic and electronic ballasts are also

available in a variety of lamp­per­ballast designs. For example, electronic ballasts are typically

manufactured in 1­, 2­, 3­, and 4­lamp versions.

In discussing each of the following technology options, it is important to note that the

efficacy of a lamp, in lumens per watt (lm/W), can be affected in two major ways. One method

is by affecting the total light output at a given wattage. This generally refers to changing the

spectral output of the lamp to result in a larger overlap with the spectral eye sensitivity.e The

second method of changing lamp efficacy is requiring a different electrical wattage input to

maintain a given lumen output. This method involves tweaking the processes that convert

electrical energy to visible radiation.

3.3.1.1 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. 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. This technology option essentially

addresses the efficiency of the conversion of electrical input power to visible radiation. As

electrons are more easily emitted from the electrodes, a lower voltage is needed to maintain the

arc. Conventional emissive coatings include barium oxide (BaO), calcium oxide (CaO), and

strontium oxide (SrO). In addition to raising efficacy, the 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. 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.

3.3.1.2 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

d Programmed start ballasts delay the starting voltage until the electrodes are heated to an optimum temperature.

Then, they may reduce the voltage on the electrodes. e A “lumen” is a measurement of the radiometric energy emission from a light source weighted by the response

function of a human eye, called the photopic spectral luminous efficiency function, V(λ). See Figure 3.3.4 for a

graph if this function.

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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. Energy­saver lamps may use a mixture of

krypton and argon. In addition, neon and xenon are sometimes blended with argon. As Figure

3.3.2 shows, given a linear power density of 25 watts/foot (W/ft), both neon and argon result in

similar UV radiation. However, given a high linear power density of 50 W/ft, neon clearly

allows for higher UV radiation, and therefore higher efficacy.

Figure 3.3.2 Lamp Fill Gas Effect on UV Output for T12 Lamps

Source: Electric Discharge Lamps 13

These gases are usually at low pressures, ranging from 100 to 400 Pascals. 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 current­controlled

devices, the use of higher efficiency lamp fill gases, such as krypton, results in lower power.

These lower power lamps, often called energy­saver lamps, have some restrictions of usage, such

as operation in less than 60 degree Celsius ambient temperature, with reduced current ballasts,

and with rapid­start ballasts, etc.

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. During lamp operation the barium oxide 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. As Figure 3.3.3 shows, the relative thermionic emission for the cathode, a

measure of the number of electrons emitted, is much greater for a larger molecular weight gas

such as krypton than for a lighter gas such as neon. This is because a larger mass atom can more

effectively collide with and change the trajectory of the barium atoms, providing a lower

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diffusion rate of the barium atoms away from the electrode. This redeposition of the electrode

coating results in a longer lamp lifetime.

Figure 3.3.3 Lamp Fill Gas Effect on Thermionic Emission for T12 Lamps

Source: Electric Discharge Lamps 14

3.3.1.3 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. This can be done by increasing the phosphor’s UV

absorption or by increasing its emission of radiation in the visible spectrum. Lamp efficacy can

also be improved by increasing the thickness of the phosphor layer, also called phosphor weight.

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 to 750

nanometers (nm)) and the extent that they radiate at visually sensitive wavelengths.

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 nanometers (nm), but less

sensitive to emission at 450nm or 650nm. The photopic luminous efficiency function, V(λ),

represents the response function of the human eye to light. Figure 3.3.4 depicts V(λ).

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­

0.2

0.4

0.6

0.8

1.0

1.2

Relative Sensitivity 

400 450 500 550 600 650 700 750

Wavelength (nanometers) 

Figure 3.3.4 Human Eye Photopic Spectral Luminous Efficiency Function, V(λ)

Lumens, used to calculate lamp efficacy, measures the radiometric energy emission from

a light source weighted by the response function of the human eye, 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

lumen­per­watt metric.

The spectral power distribution (SPD) of light emitted from a lamp characterizes the

amount of power radiated at each wavelength in the visible spectrum. Figure 3.3.5 illustrates a

sample SPD. It is apparent that the light source emits more radiation at certain wavelengths than

others.

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Figure 3.3.5 Sample Power Spectrum Distribution

Source: www.gelighting.com15

This SPD determines the color correlated temperature (CCT) and the color rendering

index (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.f16 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. CCT, a single value with units of degrees Kelvin

(K), is a measure of the color appearance of light emitted from a lamp.gh17 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 CCT can all vary. For lamp spectra with very high or very low

CCTs, the spectral emission of the lamp will not be tuned to the photopic luminous efficiency

function V(λ) for maximum luminous efficacy. Therefore, in principle, CCTs lower than about

3,000K and higher than about 5,000K will be less efficacious than those between 3,000K and

f 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.” g 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.” h 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., 2,700K, 3,000K, 3,500K, 4,000K/4,100K, 5,000K, and 6,500K) in ANSI C78.376­2001. These

regions act as a tolerance for the color properties of the lamp.

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5,000K. Figure 3.3.6 illustrates the difference in average efficacy between 32W T8 4­foot

medium bipin GSFL with different CCTs (and other attributes equivalent). Efficacy (lms/W)

92

90

88

86

84

82

80

78

6,500K 4,100K

CCT 

Figure 3.3.6 Average Efficacies of Lamps with a CCT of 6,500K versus 4,100K

Different types of phosphor emit light with different SPDs, and the choice of phosphor or

blend of phosphors greatly affects the color of the lamp. There are two groupings of phosphors:

halophosphors and rare­earth phosphors (often called tri­phosphors). Initially, halophosphors,

typically composed of group 17 elements from the periodic table of elements, were

predominantly used in fluorescent lamps. Then, in the late 1980s, rare­earth phosphors, which

are generally considered to have higher phosphor efficiencies, better color rendering properties,

and improved lumen maintenance, were integrated into the lamps. Many fluorescent lamps now

use three narrow­band, rare­earth phosphors that emit light in the short, middle, and long

wavelength ranges of the visible spectrum. As Figure 3.3.7 shows, the introduction of these

three­band lamps resulted in a marked increase in efficacy. However, because rare­earth

phosphors are considerably more expensive, longer length and larger diameter lamps commonly

coat the bulb walls with two phosphor layers: a less expensive halophosphor layer and a rareearth phosphor layer. This maintains the SPD of the rare­earth phosphor while keeping cost

relatively low. While some phosphors may be inherently more efficient than others, the most

efficient ones cannot always be selected. Since the choice of phosphor or blend of phosphors

greatly affects the illumination color of the lamp, a high efficiency phosphor may not have

acceptable color properties.

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Figure 3.3.7 Lamp Efficacies for Halo­ and Rare­Earth Phosphors

Source: Phosphor Handbook 18

DOE has observed that higher­efficiency 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 are. Typically lamps with a CRI in the 60s use only less efficient

halophosphors, while lamps with a CRI in the 70s (700­series phosphor) and in the 80s (800­

series phosphor) use more efficient rare­earth phosphors.

Apart from the type of phosphor used in a lamp, the thickness of the lamp’s phosphor

coating also affects lamp efficacy. Generally, as phosphor thickness increases, lamp light output

increases until it slightly decreases or stays flat. Figure 3.3.8 illustrates this point, where coating

weight is indicative of phosphor thickness.

Figure 3.3.8 Light Output versus Phosphor Thickness

Source: Journal of the Electrochemical Society 19

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3.3.1.4 Glass Coatings

To increase the UV absorption by the phosphors, the bulb glass can be covered with an

antireflective coating. This coating 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 rare­earth

phosphors, a good CRI can be achieved while minimizing the phosphor thickness necessary to

absorb maximum UV radiation.

3.3.1.5 Higher Efficiency Lamp Diameter

Similar to lamp length, lamp diameter is another design parameter of a fluorescent lamp

that can affect efficacy. Though both length and diameter often depend on the ballast and fixture

in which the lamp is being installed, some manufacturers are trying to allow for variance in the

diameter for certain fixtures. As discussed in section 3.4, product classes are not segregated by

lamp diameter. Therefore, DOE considers lamp diameter a technology option to increase

efficacy.

As Figure 3.3.9 shows, there exists an optimum design diameter for a specific fluorescent

lamp type resulting from two opposing effects. First, in small diameter lamps, an increase in

diameter decreases the number of electrons and mercury ions that recombine at the bulb wall and

produce no light. This lessening of non­radiative recombination results in an increase of optical

power output and subsequently a rise in lamp efficacy. However, when the lamp diameter is

sufficiently large as to result in minimal non­radiative recombination, a second opposing effect

begins to influence the efficacy­diameter relation. With these larger diameter lamps, a further

enlargement in diameter causes a greater imprisonment of radiation within the lamp. As the total

light output is reduced, the lamp efficacy declines as well. In addition to affecting lamp efficacy,

changing the lamp diameter alters the inner surface area of the fluorescent tube. With a larger

diameter and therefore surface area, more phosphor is needed to coat the glass, subsequently

increasing the cost of the lamp.

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Figure 3.3.9 Bulb Diameter versus Efficacy

Source: IESNA Lighting Handbook: Reference & Application12

3.3.1.6 Multi­Photon Phosphors

The use of multi­photon phosphors, or quantum­splitting phosphors, can significantly

improve lamp efficacy. Because these phosphors emit more than one visible photon for each

incident ultraviolet photon, a lamp would be able to emit more light for the same amount of

power. Development of this technology remains in the research phase.

3.3.2 Incandescent Reflector Lamps

An incandescent lamp is a light source in which an electrical current passes through a

filament, thermally exiting electrons which then radiate energy in the form of light and heat.

Incandescent lamps consist of a bulb, generally composed of glass such as regular lead, soda

lime, or borosilicate heat­resisting glass. Sealed to the bulb of the covered GSIL is an E26

medium screw base. Within the bulb, an incandescent lamp contains a filament, filament

supports, and sometimes a lamp fill gas. Though early incandescent lamps often used carbon,

osmium, and tantalum filaments, current lamps generally use tungsten filaments. Tungsten’s low

vapor pressure and high melting point allows for high operating temperatures, and consequently

high lamp efficacies. The lamp fill gas, though not included in all incandescent lamps, is used to

extend the lifetime of the lamp.

IRL are incandescent lamps with a reflective coating, most commonly composed of

aluminum or silver applied directly to part of the bulb surface. By improving directional

lighting, reflector lamps place the same illuminance on a specific area with reduced watts. The

most common bulb shapes of reflector lamps are reflector (R), parabolic reflector (PAR), bulged

reflector (BR), and elliptical reflector (ER). R­shaped lamps are primarily for indoor

applications, while PAR lamps are usually used outdoors. IRL can be spot floods or floods.

Flood IRL, which provide a greater distribution of light, typically have a beam spread of 16 to 40

degrees. Spot IRL have a beam spread from 9 to 16 degrees.

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The following assessment is a discussion of technology options to improve the efficacy

of IRL. In discussing methods to affect the efficacy of an incandescent lamp, it is important to

recognize the interrelation of a lamp’s wattage, luminous output, and lifetime. Often the most

efficacious incandescent lamps have very low lifetimes and therefore become useless to the

consumer. An indirect method to increase overall efficacy involves increasing lifetime. With a

longer lifetime, a more efficacious lamp can be manufactured and will still have utility to the

consumer.

3.3.2.1 Higher Temperature Operation

In the operation of an incandescent lamp, a current is passed through a tungsten filament,

which when heated, emits light. However, an incandescent light source’s spectrum does not fall

exclusively in the visible region of the electromagnetic spectrum, shown in Figure 3.3.10. By

operating the filament at higher temperatures, the spectral output shifts to shorter wavelengths,

increasing its overlap with the photopic spectral eye sensitivity. This, in effect, increases the

luminous output for a given power input and consequently increases the lamp efficacy. As

Figure 3.3.11 shows, increasing color temperature (a direct effect of, but not equivalent to,

raising operating temperature) causes an increase in luminous efficacy. One way to increase the

filament temperature is by increasing the wattage of the lamp. As a higher current passes

through and a high voltage drop occurs over the filament, the amount of energy released in the

form of heat increases, thereby raising the temperature. However, this significantly changes the

luminous output of the lamp and may not meet the consumer’s needs. Other technologies that

address a lamp’s ability to operate at high temperatures are filament thickness, inclusion of inert

gas fills, and the use of halogen fills, all discussed below.

Figure 3.3.10 Radiating Characteristics of Tungsten

Source: IESNA Lighting Handbook: Reference & Application 20

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Figure 3.3.11 Luminous Efficacy versus Color Temperature

Source: IESNA Lighting Handbook: Reference & Application 21

In addition to efficacy, the change in operating temperature also affects lifetime and the

color appearance of the lamp. At the melting temperature of tungsten, 6,120°F, the maximum

efficacy of an incandescent lamp with an uncoiled tungsten filament is 53 lm/W. However, to

obtain long life in an incandescent lamp, the filament should be significantly below its melting

point. As the filament burns hotter, more tungsten evaporates from the filament. When the

filament eventually breaks, the lamp fails. This is an example of the clear tradeoff between lamp

efficacy and lamp lifetime. Also, to maintain the cool bulb surface, high temperature

incandescent lamps often require larger bulbs. This affects the fixtures in which they fit.

3.3.2.2 Microcavity Filaments

Texturing of the filament surface can increase surface area and therefore emissivity.

Filament surface perforations also can act as waveguides for visible light. One technology

includes the creation of microcavity holes in the filament surface. The cavities may then be

filled with materials such as tantalum, rhenium, molubdenum, tungsten, SiC, rare­earth elements,

glass beads, or any combination thereof. Depending on their fabrication, this technology can

result in a variety of effects such as greater control of emissive direction, reduction of infrared

radiation, and increased emission efficiency over a certain bandwidth of wavelengths.

Ultimately, these effects produce a higher overall efficacy.

Sandia National Laboratories researchers examined microcavity resonance in a tungsten

photonic lattice. DOE has found multiple patents referencing this technology. However,

research indicates that materials patterned at the submicron level may experience problems with

stability.22

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3.3.2.3 Novel Filament Materials

In choosing a filament, some advantageous properties are high melting point, low vapor

pressure, high strength, high ductility, and good radiating characteristics. While tungsten is

primarily used for incandescent lamps, manufacturers also incorporate other metals such as

rhenium to improve ductility. However, these lamps are most commonly used for applications

requiring vibration­resistant lamps. Novel filament materials such as nitrides and carbides have

the potential to improve lamp efficacy by emitting more light in the visible spectrum at a given

temperature than traditional tungsten filaments. However, these novel filaments can also be

brittle, an attribute that can shorten the lamp lifetime.

3.3.2.4 Thinner Filaments

A thinner filament has an increased resistance and therefore an increased operating

temperature. As previously discussed, a higher operating temperature results in a higher lamp

efficacy. However, as an adverse effect, an incandescent lamp with a thinner filament cannot

withstand as much tungsten evaporation before failing, resulting in a shorter lifetime.

3.3.2.5 Efficient Filament Coiling

Coiling of the incandescent lamp filament can increase luminous efficacy. The light

output of an incandescent lamp is directly proportional to the light­emitting surface area of the

light source. By coiling the filament, a longer filament can be used, increasing luminous output

and therefore lamp efficacy. Coiling of the tungsten also affects the heat loss from the filament.

The more the filament is coiled, the less the effective area for convective cooling, thereby

increasing filament temperature and lamp efficacy. IRL covered in this rulemaking generally

contain filaments of the type C (coiled) or CC (coiled coil). The highly efficacious CC type

filament, which is more commonly used, consists of the coil wound into another helical coil.

3.3.2.6 Crystallite Filament Coatings

A variety of filament coatings may be used to increase the efficacy of incandescent

lamps. Layers of micron or submicron crystallites, comprised of thorium, tantalum, and/or

niobium, are deposited on the filament surface. The crystallites are coated with a protective layer

of at least one oxide of thorium, hafnium, scandium, yttrium, cerium, or zirconium. This coating

increases the emissivity of the filament in the visible part of the spectrum without increasing the

infrared radiation. However, as the operating temperature of the filament increases, the

emissivity improvement due to the crystallites decreases.

3.3.2.7 Efficient Filament Orientation

Tungsten filament in incandescent lamps can be positioned horizontally or vertically with

respect to the base of the bulb. Because the light emitted from the filament is distributed in all

directions, one way to improve efficacy is by designing the lamp in a way such that the most

amount light is able to escape the bulb. By positioning the filament in a horizontal orientation,

the base of the lamp absorbs much of the emitted light along the length of the coil. However, by

positioning the filament in vertical alignment, a small portion of the light is emitted towards the

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base. Consequently, more light escapes the bulb and is used for illumination. This can increase

the efficacy of an incandescent lamp by approximately 8 percent.

3.3.2.8 Higher Efficiency Inert Fill Gas

IRL covered in this rulemaking typically are filled an inert fill gas whose primary

purpose is to reduce the evaporation of tungsten, preventing bulb blackening and increasing

lifetime. In addition, this fill gas increases the pressure inside the bulb or halogen capsule.

However, the fill gas also provides a means of convective heat transfer between the heated

filament and cool bulb surface. This cooling of the filament represents a power loss and an

efficacy reduction due to low temperature operation. Krypton’s low thermal conductivity

decreases the convective cooling of the filament, allowing for higher temperature operation and

therefore higher efficacy. In addition, since the krypton molecule is larger than other elements

such as argon, krypton more effectively slows the evaporation of the filament and therefore

extends the life of the lamp. Xenon, having even lower heat conductivity and larger mass than

krypton, can more drastically change efficacy and life but also at a greater cost.

3.3.2.9 Luminescent Gas

A large portion of the incandescent spectrum is composed of wavelengths that cannot be

detected by the human eye. By reacting with these wavelengths, luminescent gases can convert

some portion of the “invisible” part of the incandescent spectrum into visible light. This

conversion increases the amount of lumens emitted by the lamp and thus improves its efficacy.

3.3.2.10 Tungsten­Halogen Lamps

Tungsten­halogen lamps are a subgroup of incandescent lamps which use a halogen

element such as bromine, chlorine, fluorine, or iodine to help increase lifetime of the lamp. As

discussed earlier, technologies that increase lifetime also indirectly improve efficacy, because

higher temperature operation becomes more feasible while maintaining product utility. In a

tungsten­halogen lamp, a small diameter fused quartz envelope filled with a halogen molecule

surrounds the filament. Above 500 degrees Fahrenheit, when tungsten evaporates from the

filament, the tungsten molecules combine with the halogen into a gaseous compound. This

compound circulates within the envelope until it contacts the filament again. The heat of the

filament breaks the compound, freeing the halogen and re­depositing the tungsten on the

filament. This regenerative process greatly extends the life of incandescent lamps by reducing

the loss of tungsten material. Also, because tungsten is not being deposited on the bulb surface,

bulb darkening over time is greatly reduced. However, to prevent this bulb darkening, the

halogen lamp must be operated with a sufficiently high bulb wall temperature. For this reason,

dimming circuits that employ low­voltage operation may not reap the same benefits from using

tungsten­halogen lamps. One drawback to the halogen technology is that the halogen capsule is

often under high pressure and therefore susceptible to exploding. For this reason, halogen IRL

often employs a thicker protective glass.

3.3.2.11 Higher Pressure Tungsten­Halogen Lamps

Increasing the pressure of the halogen capsule by increasing the density of halogen

elements can indirectly raise the efficacy of the tungsten­halogen lamp. The increased density of

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halogen elements raises the probability that an evaporated tungsten element combines with a

halogen element in a gaseous compound. Adding more of this gaseous compound in the capsule

effectively increases the amount of tungsten re­deposited on the tungsten filament, which can

lengthen the lifetime of the tungsten­halogen lamp or raise its efficacy by allowing for higher

temperature operation of the filament.

3.3.2.12 Non­Tungsten­Halogen Regenerative Cycles

The regenerative cycle of filament evaporation and re­deposition can be used to greatly

increase the life of an incandescent lamp. The filament can burn at a higher temperature than

conventional incandescent lamps while maintaining a useful service life. The tungsten­halogen

regenerative cycle is the most common. However, other regenerative cycles are possible.

Implementation of a non­tungsten­halogen regenerative cycle depends on incorporating a nontungsten filament.

3.3.2.13 Infrared Glass Coatings

Infrared coatings on incandescent lamps are used to reflect some of the radiant energy

emitted back onto the filament. This infrared radiation then supplies heat to the filament and the

operating temperature increases. As discussed earlier, an increase in operating temperature

results in a higher light output and therefore an increase in efficacy. In addition, the spectrum of

the incandescent lamp shifts toward shorter wavelengths. These infrared coatings can be in

many forms, such as multilayer dichroic filters and crystal lattice structures whose spacing

defines a photonic bandgap. They can be applied to the glass halogen capsule for tungstenhalogen lamps. However, they are most commonly used in the coating of the halogen capsule

since one can achieve the greatest directed reflection back onto the filament for the lowest

infrared coating usage. Because the halogen capsule is most traditionally in a cylindrical shape,

when infrared coatings are applied to a halogen lamp, manufacturers use a cylindrical capsule to

help direct the light.

3.3.2.14 Integrally Ballasted Low­Voltage Lamps

The filaments of incandescent lamps designed to operate at a low voltages are both

shorter in length and thicker in diameter than the filaments of incandescent lamps designed to

operate at a higher line voltage. Increasing the thickness of the filament can improve lamp

efficacy by increasing the filament temperatures. Using an integral ballast allows an increase in

the efficacy of a lamp because it operates at low voltages, though it is used in a socket with main

line voltage (i.e., it converts the operating voltage of the lamp to a lower wattage from line

voltage). The conversion of line voltage to lower lamp operating voltages has associated energy

losses. However, modern integral ballast technologies allow efficacy gains from low­voltage

operation to outweigh any such conversion losses.

3.3.2.15 Higher Efficiency Reflector Coatings

Though aluminum is most prevalent as a reflector coating in incandescent reflector

lamps, silver coatings can also be applied. While aluminum coatings are applied internally by

condensation of vaporized aluminum on the inner surface of the bulb, silver can be applied both

on the interior and exterior surfaces of the bulb. When applied externally, the silver coating is

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EERE-2007-BT-TP-0013 COMMENT 05
protected by a cooper coating and aluminum finish. Silver coatings are generally preferred over

aluminum due to their lower light loss. Gold is also extremely reflective and can be used to

increase the amount of directed light and therefore efficacy of the lamp. An infrared coating that

reflects the infrared radiation back toward the lamp’s filament can also be applied. This infrared

reflector coating, in the form of multilayer dichroic filters or crystal lattice structures, ultimately

increase lamp efficacy by limiting the amount of energy lost through infrared radiation and by

increasing lamp operating temperature.

3.3.2.16 Trihedral Corner Reflectors

Due to the shape of many reflector lamps, infrared lens technologies can be incorporated

in the cover glass to direct infrared radiation back onto the filament. Conventional infrared

coatings on reflector lamps direct the infrared light back into the bulb, but not directly onto the

filament. Other parts of the lamp absorb some of this heat, which is therefore a source of energy

loss. Trihedral corner reflector is a technology that incorporates individual corner reflectors into

the cover glass. These reflectors’ shapes provide the unique ability to reflect light directly back

in the direction it came. Therefore any light coming from the filament and impinging on the

cover glass will be directed straight back to the filament. These reflectors are covered with a

dichroic coating, allowing visible light to pass through and escape while causing infrared

radiation to reflect back on the filament. As this radiation heats the filament, the lamp requires

less input power to operate at a higher operating temperature, and therefore operates more

efficaciously.

3.3.2.17 Efficient Filament Placement

Placement of the filament is an important aspect of incandescent reflector design. The

placement of the filament is optimal when a portion of the spectrum emitted by the filament is

focused back onto the filament. This additional radiation supplies heat to the filament and the

operating temperature increases. As discussed earlier, an increase in operating temperature

results in a higher light output and therefore an increase in efficacy.

3.4 PRODUCT CLASSES

When evaluating and establishing energy conservation standards, DOE divides covered

products into classes by the type of energy used, capacity, or other performance­related features

that affect efficiency, and factors such as the utility of the product to users. (See 42 U.S.C.

6295(q)) DOE usually establishes different energy conservation standards for different product

classes. DOE applied the criteria of 42U.S.C. 6295(q) to GSFL and IRL to develop product

classes for the ANOPR. This section of the TSD describes the product classes DOE considers

for this rulemaking.

3.4.1 General Service Fluorescent Lamps

In setting energy conservation standards for fluorescent lamps, EPCA established product

classes based on its definition for fluorescent lamps and on nominal lamp wattages. Table 3.4.1

shows the product classes set by EPCA⎯two for each lamp type⎯for a total of eight product

classes. (42 U.S.C. 6295(i)(1)(B))

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Table 3.4.1 EPCA Product Classes for General Service Fluorescent Lamps

Product Class Lamp Type Nominal Lamp Wattage

#1 Four­Foot Medium Bipin > 35 W

#2 Four­Foot Medium Bipin ≤ 35 W

#3 Two­Foot U­Shaped > 35 W

#4 Two­Foot U­Shaped ≤ 35 W

#5 Eight­Foot Single Pin Slimline > 65 W

#6 Eight­Foot Single Pin Slimline ≤ 65 W

#7 Eight­Foot Recessed Double Contact High Output > 100 W

#8 Eight­Foot Recessed Double Contact High Output ≤ 100 W

The fluorescent lamp market has changed in the 15 years since amendments to EPCA

established these eight product classes. For example, new phosphors are used more frequently in

general illumination applications, changing average CRI values, and new lamps have entered the

market, shifting the market share to different lamp wattages. DOE has revised the product

classes to reflect some of these market changes, and to enable the analysis to better represent the

current market. DOE also reviewed the existing product classes to ensure that any additional

GSFL it regulates fit within the same regulatory framework as existing standards. In its

assessment of GSFL product classes, DOE looked to statutory criteria (42 U.S.C. 6295(q)) and

identified utility and physical attributes of fluorescent lamps around which to set product classes.

In the ANOPR Federal Register notice, DOE considers setting product classes on the

following utility and physical attributes of fluorescent lamps: physical constraints of lamps (i.e.,

lamp shape and lamp length), lumen package (i.e., regular versus HO), and correlated color

i temperature. DOE chose not to set product classes based on lamp wattage, lamp diameter (i.e.,

T8 vs. T12), or color rendering index. In addition, DOE did not consider interoperability of

lamps on the same ballast system as a differentiating factor for product classes. The following

subsections discuss these lamp attributes and how they pertain to product class divisions.

3.4.1.1 Physical Constraints of Fluorescent Lamps

The physical constraints of the lamp relate to its shape and length. Because consumers

must change a lamp fixture to substitute lamps of different geometries for one another, lamp

shape affects utility. For example, a U­shaped lamp could not substitute for a linear­shaped lamp

in the same fixture. Also, a 4­foot lamp may have a different utility than an 8­foot lamp, as these

lamps generally may require different fixtures. In addition, a lamp’s geometry also affects its

efficacy. For example, efficacy tends to increase with length. All else being equal, 8­foot lamps

generally have higher efficacy values than 4­foot lamps. Also, a 2­foot U­shaped lamp, while

In the Framework Document, DOE presented its preliminary thoughts on revising the table of standards established

by EPCA. ((42 U.S.C. 6295(i)(1)(A); see 10 CFR 430.32(n)(1)). DOE considered subdividing the product

categories by introducing lamp tube diameter as a differentiating variable (i.e., “>T8” and “≤T8”). In presenting this

concept, DOE used the same wattage divisions and minimum CRI requirements that EPCA uses for these lamps,

with T8 and T12 lamps in the same product class. Having conducted additional research on the GSFL market and

GSFL technologies, DOE does not believe separating product classes by lamp diameter is necessary.

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having the same overall tube length, is less efficacious than a 4­foot linear lamp, partly because

the electrical arc within the tube has to bend to conform to the lamp shape. Given the impact that

geometry has on both utility and efficacy, DOE maintains the division of product classes by lamp

geometry.

3.4.1.2 Lumen Package

Lumen package refers to the quantity of light that a lamp­and­ballast system provides to a

consumer. To obtain a high lumen package, certain lamps are designed to operate with ballasts

that run the lamps at high currents. For example, 8­foot recessed double contact high output

lamps tend to operate at higher currents than 8­foot single pin slimline lamps. This difference in

operating design increases the quantity of light per unit lamp length.

DOE observed that consumers tend to use systems with different lumen packages for

different applications. For example, high­lumen­output systems may be installed in certain highceiling or outdoor applications, where large quantities of light are needed. Alternatively,

standard­lumen­output systems might be installed in lower­ceiling applications such as offices or

hospitals, where, for example, distance between the light source and the illuminated surfaces is

not as large. Notable differences in the application of standard output versus high output lamps

indicate a difference in utility.

In addition to producing higher light output, operating lamps at a higher current also

decreases efficacy. For example, the efficacy of an 8­foot recessed double contact high output

lamp is as much as 10 percent lower than that of a comparable 8­foot single pin slimline lamp.

Given the observed utility distinctions and notable efficacy differences between standard and

high output lamps, DOE maintains the product class division for 8­foot linear lamps between

slimline and high output lamps.

3.4.1.3 Correlated Color Temperature

As discussed in section 3.3.1.3, in general terms, the CCT is a measure of the perceived

color of the white light emitted from the lamp. As the spectral emission from the lamp is

modified to change the CCT, the lamp efficacy can vary. Due to their greater blue light content,

higher CCT fluorescent lamps tend to have lower efficacies.

For fluorescent lamps, the differences in CCT of the light emission can be so large that

they affect the efficacy of the lamp. Given the impact on efficacy of CCT and utility, DOE is

establishing product classes by CCT range and setting separate efficacy requirements for GSFL

based on CCT. DOE is considering establishing two groups that divide the span of CCT that are

considered general purpose (between 2,500K to 6,600K). This division of product classes occurs

at 4,500K.

3.4.1.4 Ballast Interoperability

Not all lamps operate on the same ballast. Even if lamps have similar geometries,

different ballasts may be required for their operation. However, DOE treats ballast

interoperability as an economic issue (in the LCC and NIA analyses) rather than a product class

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EERE-2007-BT-TP-0013 COMMENT 05
issue. In other words, if a consumer needs to change the ballast to replace a lamp, then the

installed cost of both the lamp and ballast are factored into the net present value equation. For

example, DOE considered a T8 lamp a more efficacious replacement for a T12 baseline lamp.

Considering T8 lamps as substitutes for T12 lamps is consistent with DOE’s understanding of

the market, and with manufacturer marketing literature. It is common practice, for example, to

replace a T12 lamp­and­ballast system with a T8 lamp­and­ballast system. In its economic

analysis, DOE accounts for the need to install a new ballast to operate the T8 lamp by including

the installed cost of a new lamp and ballast for the T8 replacement. Had DOE elected to

differentiate these lamps on ballast interoperability, or indeed, lamp diameter, this direct

comparison may not have been made. DOE believes this approach is appropriate for this

rulemaking because there is no unique functionality or service rendered by, for example, one T8

lamp and an equivalent T12 lamp.

3.4.1.5 Lamp Wattage

The current regulations group standards by wattage. However, DOE believes that

product classes would more appropriately structure standards if they did not divide products by

wattage. The main function of a lamp is to provide lumen output, while other attributes such as

CCT, for example, contribute to utility. Wattage measures the power consumed by a lamp in

providing its service. Therefore, DOE does not construe wattage as a direct measurement of

utility. Following guidance from 6295(q), where utility is a factor for structuring product

classes, DOE does not establish product classes on the basis of wattage.

Furthermore, DOE believes combining wattages within one product class would allow

standards to stay relevant with the market. Dividing product classes by wattage locks the

standards to a static wattage structure. While this structure may reflect current product

availability, the market may evolve over time, shifting to different wattages. This scenario is

illustrated by comparing the current GSFL market to the existing GSFL standard structure.

Before the EPCA standard, the 40W GSFL was the most prevalent GSFL offered. Currently, the

common wattage for 4­foot medium bipin GSFL are 40W and 34W for T12 lamps and 32W for

8­foot T8 lamps, where the T8 lamps are energy­saving versions of the T12 lamps.j The existing

product class divides wattage at 35W.

3.4.1.6 Lamp Diameter

As discussed in section 3.3.1.5, lamp diameter is a feature of a lamp which impacts lamp

efficacy. DOE uses lamp diameter as a design option, and does not consider using it as a basis

for developing product classes.k Manufacturer marketing literature and general guidance on

lighting design and installation often promote T8 lamp­and­ballast systems as higher efficacy,

energy­saving substitutes for T12 lamp­and­ballast systems. Such substitute systems have the

same lengths and bases, offer comparable lumen output, and can fit within the same fixtures.

Therefore, DOE recognizes that the diameter of the lamp will affect the efficacy, but the utility

j

Additional, reduced­wattage T8 4­foot medium bipin lamps are available, but the 32W version is the most

common.

k In the Framework Document, DOE considered separating GSFL with diameters smaller than or equal to T8 from

lamps with diameters greater than T8. On further consideration, DOE has determined that the lamp diameter does

not provide significant unique utility to end­users.

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EERE-2007-BT-TP-0013 COMMENT 05
provided to the end­user is comparable and/or equivalent. The substitution of a T8 lamp for a

T12 lamp requires the substitution of a new ballast as well. DOE accounts for new ballast

purchases in its economic analyses of these substitutions (i.e., the LCC and NPV analyses) by

incorporating ballast costs in the equipment costs of the substitutes.

3.4.1.7 Color Rendering Index

In its standard for fluorescent lamps, EPCA established both an upper and a lower bound

on the CRI of GSL.l EPCA defines GSFL as having a CRI less than 82, effectively exempting

from coverage GSFL with a CRI equal to or greater than 82. (42 U.S.C. 6291(30)(B)(vii); see 10

CFR 430.2) EPCA also established two minimum CRI requirements for each of the four groups

of fluorescent lamps, one at 69 CRI and one at 45 CRI. Within 4­foot medium bipin lamps, for

example, EPCA requires that lamps nominally rated at greater than 35W have a minimum CRI of

69 and lamps nominally rated at 35W or lower have a minimum CRI of 45. (42 U.S.C.

6295(i)(1)(A); see 10 CFR 430.32(n)(1)) In removing the wattage dividers, DOE is also

effectively removing the primary differentiating factor that was used to establish minimum CRI

requirements. DOE considers several approaches to resolve this issue in section III.2.a of the

ANOPR Federal Register notice.

3.4.1.8 Product Classes and Standard Form for GSFL

For all the reasons discussed above, DOE is considering the GSFL product classes listed

in Table 3.4.2. DOE is setting constant efficacy level standards by product class, consistent with

existing standards. This standard would apply to and be constant over the full spectrum of

wattages and diameters for lamps covered by that lamp type and CCT. Chapter 5 provides detail

on the selection of candidate standard levels.

Table 3.4.2 DOE ANOPR Product Classes for GSFL

Lamp Type

For CCT ≤ 4,500K,

Minimum Lamp Efficacy

lm/W

For CCT > 4,500K,

Minimum Lamp Efficacy

lm/W

Four­Foot Medium Bipin Product Class #1 Product Class #5

Two­Foot U­Shaped Product Class #2 Product Class #6

Eight­Foot Single Pin Slimline Product Class #3 Product Class #7

Eight­Foot Recessed Double Contact HO Product Class #4 Product Class #8

3.4.2 Incandescent Reflector Lamps

In setting energy conservation standards for IRL, EPCA differentiated IRL by wattage

and established six nominal wattage ranges or “bins,” shown in Table 3.4.3. (42 U.S.C.

6295(i)(1)(B))

EPCA also defines GSFL as having a CRI less than 82, effectively exempting from coverage GSFL with a CRI

equal to or greater than 82. (42 U.S.C. 6291(30)(B)(vii); see 10 CFR 430.2)

3­36

l

EERE-2007-BT-TP-0013 COMMENT 05
Table 3.4.3 EPCA Product Classes for Incandescent Reflector Lamps

Product Class Nominal Lamp Wattage

#1 40­50

#2 51­66

#3 67­85

#4 86­115

#5 116­155

#6 156­205

3.4.2.1 Wattage

For the same reasons discussed for GSFL (see section 3.4.1.5), DOE is revising the

product classes so that they are not structured according to wattage. Instead of a structure that

uses wattage divisions, DOE is considering one that encompasses a single range of wattages.

DOE believes that wattage is not a direct measure of utility. DOE also believes that a structure

that encompasses all wattage could better keep pace with the market should it shift to reduced

wattages over time.

As wattage increases for incandescent lamps, efficacy also generally increases. To use a

single range of wattages while taking into account variation in efficacy by wattage, DOE is

developing a single standard per product class as an equation. This equation sets a minimum

efficacy requirement that varies by wattage. Figure 3.4.1 illustrates this standard form. Chapter

5 provides more detail on selection of CSLs.

3.4.2.2 Modified Spectrum

EISA 2007 adopted a new definition for “colored incandescent lamp”m which supersedes

DOE’s definition previously incorporated at 10 CFR 430.2.n This new statutory definition

effectively increases the scope of energy conservation standards coverage of IRL to include any

IRL that has a lens containing five percent or more neodymium oxide or is a plant light lamp. As

both of these types of IRL filter out portions of the emitted spectrum of the lamp, many of these

lamps fall under the definition of “modified spectrum” which was also adopted by the new

energy legislation. The EISA 2007 definition of “modified spectrum” reads as follows:

“The term ‘modified spectrum’ means, with respect to an incandescent lamp, an

incandescent lamp that—

m EISA 2007’s definition of “colored incandescent lamp” reads as follows: “ The term ‘colored incandescent lamp’

means an incandescent lamp designated and marketed as a colored lamp that has—(i) a color rendering index of less

that 50, as determined according to the test method given in CIE publication 13.3­1995; or (ii) a correlated color

temperature of less than 2,500K or greater that 4,600K, where correlated temperature is computed according to the

Journal of Optical Society of America, Vol. 58, pages 1528­1595 (1986).” n The definition of “colored incandescent lamp” adopted by the 1997 Lamps Test Procedure Final Rule 62 FR

29221,29228 (May 29, 1997) reads as follows: “Colored incandescent lamp means an incandescent lamp designated

and marketed as a colored lamp that has a CRI less than 50, as determined according to the method given in CIE

Publication 13.2 (see 10 CFR 430.22); has a correlated color temperature less than 2,500K or greater than 4,600K;

has a lens containing 5 percent or more neodymium oxide; or contains a filter to suppress yellow and green portions

of the spectrum and is specifically designed, designated and marketed as a plant light.”

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EERE-2007-BT-TP-0013 COMMENT 05
(i) is not a colored incandescent lamp; and

(ii) when operated at the rated voltage and wattage of the incandescent lamp—

I. has a color point with (x,y) chromaticity coordinates on the Commission

Internationale de l’Eclairage (C.I.E.) 1931 chromaticity diagram that lies

below the black­body locus; and

II. has a color point (x,y) chromaticity coordinates on the C.I.E. 1931

chromaticity diagram that lies at least 4 MacAdam steps (as reference in

IESNA LM16) distant from the color point of a clear lamp with the same

filament and bulb shape, operated at the same rated voltage and wattage.”

(42 U.S.C. 6291(30)(W))

Modified­spectrum lamps provide unique utility to consumers because they offer a

different light output from incandescent lamps, much like fluorescent lamps with different CCT

values. The same technologies that modify the spectral emission of a lamp also decrease the

lamp’s efficacy. To modify the spectrum, the coating absorbs a portion of the light emission

from the filament. Neodymium coatings or other coatings on modified­spectrum lamps absorb

some of the visible emission from the incandescent filament (usually red), creating a modified,

reduced spectral emission. Since the neodymium or other coatings absorb some of the lumen

output from the filament, these coatings decrease the efficacy of the lamp.

DOE is concerned that, given the newly adopted definition of “colored incandescent

lamp,” if DOE were to subject modified­spectrum IRL to the same standard as standardspectrum IRL, then these IRL with modified­spectrum glass or coatings may not be able to

achieve the mandatory standard. Therefore, DOE is planning to establish separate product

classes for regular IRL (those without modification to the spectral emission) and modifiedspectrum IRL (some portion of the spectral emission is absorbed). However, to ensure that a

suitable standard level is set for these lamps (such that they are neither disadvantaged nor

advantaged compared to standard­spectrum lamps, DOE is then establishing an appropriately

scaled efficacy requirement based on DOE’s analysis of standard­spectrum IRL. This

requirement would be adjusted to account for the portions of the spectrum that are absorbed by

the neodymium or spectrally enhancing coating. DOE discusses how this scaling would be

accomplished in Chapter 5, the Engineering Analysis.

3.4.2.3 Spot Versus Flood Incandescent Reflector Lamps

In the Framework Document, DOE considered setting product classes for IRL based on

beam spread. In particular, DOE considered separate standards for spot and flood IRL. DOE

reviewed technical reports on the performance of spot and flood reflector lamps. DOE

concluded that while there might be different utility for consumers through the light distribution

patterns of a spot reflector lamp versus a flood reflector lamp, the difference in utility does not

affect the efficacy of the lamp. Thus, DOE will not create separate product classes for spot and

flood reflector lamps.

3.4.2.4 Product Classes and Standard Form for IRL

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EERE-2007-BT-TP-0013 COMMENT 05
In sum, DOE is considering all wattages of IRL to be part of the same product class,

allowing for the standard to be a function of the lamp wattage. As DOE considers more

efficacious replacement lamps, the rated wattages must decrease to maintain consistent levels of

light output and save energy. In addition, DOE is considering energy conservation standards for

full­spectrum IRL separately from modified­spectrum IRL. Table 3.4.4 summarizes the two

product classes DOE considers for the ANOPR. To facilitate stakeholder comment on the IRL

product classes, DOE has continued the product class numbering from the GSFL.

Table 3.4.4 DOE ANOPR Product Classes for IRL

Lamp Category

Standard­Spectrum

Minimum Lamp Efficacy

lm/W

Modified­Spectrum

Minimum Lamp Efficacy

lm/W

IRL Product Class #9 Product Class #10

Figure 3.4.1 illustrates the standard form for IRL, the continuous curve, as well as the

existing standard, the step function.

.

/ , 

α 

Lamp wattage (watts)

Efficacy (lumens / watt)

EPCA 

CSL1 

CSL2 

CSL3 

Lm W ≥ α*( W^ β)

where and β are constants. 

Figure 3.4.1 Illustration of IRL Candidate Standard Level Forms

3­39

EERE-2007-BT-TP-0013 COMMENT 05
REFERENCES

1 National Electrical Manufacturers Association. Lighting Systems Division. 2002. (Last

accessed September 10, 2007)

<http://www.nema.org/prod/lighting/upload/LightingSystemsDivision.pdf>. The September 10,

2007 material from this website is available in Docket # EE–2006–STD–0131. For more

information, contact Brenda Edwards­Jones at (202) 586­2945.

2 U.S. Small Business Administration. Table of Small Business Size Standards

Matched to North American Industry Classification System Codes. 2006. (Last accessed

September 13, 2007)

<http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf>. The

September 13, 2007 material from this website is available in Docket # EE–2006–STD–0131.

For more information, contact Brenda Edwards­Jones at (202) 586­2945.

3 U.S. Department of Energy. Office of Energy Efficiency and Renewable Energy. Energy

Conservation Program for Consumer Products: Technical Support Document: Energy

Efficiency Standards for Consumer Products: Fluorescent Lamp Ballast Proposed Rule. January

2000. Washington D.C.

4 Natural Resources Canada. Proposed Requirements for Lighting Products: General Labelling,

Verification, Test Data, Reporting and Importing. 2007. (Last accessed September 12, 2007)

<http://oee.nrcan.gc.ca/regulations/lighting­products­nov06.cfm?text=N&printview=N.> The

September 12, 2007 material from this website is available in Docket # EE–2006–STD–0131.

For more information, contact Brenda Edwards­Jones at (202) 586­2945.

5 U.S. Department of Energy. Office of Energy Efficiency and Renewable EnergyCFederal

Energy Management Program. How to Buy Energy­Efficient Fluorescent Tube Lamps. 1998.

(Last accessed February 22, 2007) <http://www1.eere.energy.gov/femp/pdfs/fluor_lamps.pdf>

The February 22, 2007 material from this website is available in Docket # EE–2006–STD–0131.

For more information, contact Brenda Edwards­Jones at (202) 586­2945.

6 Consortium for Energy Efficiency. CEE High­Performance T8 Specification. 2007. (Last

accessed May 1, 2007) <http://www.cee1.org/com/com­lt/com­lt­specs.pdf> The May 1, 2007

material from this website is available in Docket # EE–2006–STD–0131. For more information,

contact Brenda Edwards­Jones at (202) 586­2945.

7 Consortium for Energy Efficiency. CEE Reduced­Wattage T8 Specification. 2007. (Last

accessed January 23, 2007) <http://www.cee1.org/com/com­lt/lw­spec.pdf> The January 23,

2007 material from this website is available in Docket # EE–2006–STD–0131. For more

information, contact Brenda Edwards­Jones at (202) 586­2945.

8 Northeast Energy Efficiency Partnership. High Efficiency Commercial Lighting. 2007 (Last

accessed September 12, 2007) <http://www.neep.org/initiatives/Comm_Lighting.html> The

3­40

EERE-2007-BT-TP-0013 COMMENT 05
September 12, 2007 material from this website is available in Docket # EE–2006–STD–0131.

For more information, contact Brenda Edwards­Jones at (202) 586­2945.

9 Efficiency Vermont. High Performance “Super T8” Fact Sheet. 2007. (Last accessed

February 23, 2007)

<http://www.efficiencyvermont.com/stella/filelib/SuperT8%20Fact%20Sheet%20Revised%2011

­20­06%20Final.pdf> The February 23, 2007 material from this website is available in Docket #

EE–2006–STD–0131. For more information, contact Brenda Edwards­Jones at (202) 586­2945.

10 Long Island Power Authority. LIPA Prescriptive. 2007. (Last accessed February 23, 2007)

<http://www.lipower.org/pdfs/cei/commercial/commconst_prog.pdf> The February 23, 2007

material from this website is available in Docket # EE–2006–STD–0131. For more information,

contact Brenda Edwards­Jones at (202) 586­2945.

11 National Electrical Manufacturers Association. 2006. No. 12 at p. 7. This written comment,

document number 12, is available in Docket # EE–2006–STD–0131. For more information,

contact Brenda Edwards­Jones at (202) 586­2945.

12 Rea, Mark S., ed. The IESNA Lighting Handbook: Reference & Application, 9th Edition.

2000. The Illuminating Engineering Society of America: New York, New York.

13 Ibid.

14 Waymouth, John F. Electric Discharge Lamps. 1971. M.I.T. Press: Cambridge,

Massachusetts.

15 GE Lighting and Industrial. “Spectral Power Distribution Curves: Tri­Phosphor Fluorescent

Colors.” SP65. Last viewed September 13, 2007.

<http://www.gelighting.com/na/business_lighting/education_resources/learn_about_light/distrib

ution_curves.htm>.

16 Illuminating Engineering Society of North America. “The IESNA Lighting Handbook:

Reference and Applications.” Ninth Edition. 2000. p. G­7.

17 Illuminating Engineering Society of North America. “The IESNA Lighting Handbook:

Reference and Applications.” Ninth Edition. 2000. p. G­8.

18 Shionoya, Shiegeo, ed. and William M. Yen, ed. Phosphor Handbook. 1998 CRC Press:

Boca Raton, FL.

19 Young, R. Gaines and E. G. F. Arnott. The Effect of Phosphor Coating Weight on the Lumen

Output of Fluorescent Lamps. Journal of the Electrochemical Society. October 1965. 112(10):

pp. 982­984.

20 Rea, Mark S., ed. The IESNA Lighting Handbook: Reference & Application, 9th Edition.

2000. The Illuminating Engineering Society of America: New York, New York.

3­41

EERE-2007-BT-TP-0013 COMMENT 05
21 Ibid.

22 Ibid.

3­42

EERE-2007-BT-TP-0013 COMMENT 05