1 | Energy Efficiency and Renewable Energy eere.energy.gov

Test Procedures

Notice of Proposed Rulemaking for 

Ceiling Fan Light Kits

Energy Conservation Standards

Preliminary Analysis for Ceiling Fan 

Light Kits

November 18, 2014

Lucy deButts

Department of Energy

Building Technologies Program

TP: EE-2014–BT–TP–0007

CFLK2014TP0007@ee.doe.gov

ECS: EERE-2012-BT-STD-0045

CeilingFanLightKits2012STD004@

ee.doe.gov
2

Welcome

• Introductions (around the room)

• Role of the Facilitator

• Ground Rules

- Speak one at a time.

- Say your name for the record – there will be a complete transcript of this 

meeting.

- Be concise – share the ‘air-time.’

- Keep the focus here – cell phones on silent; limit sidebar conversations.

- Webinar participants turn phone on mute; “raise your hand” to be 

recognized to speak.

• Housekeeping Items

• Agenda Review

• Opening Remarks
3

Public Meeting Agenda: Morning

9:00 – 9:10 am Welcome and Introductions

Ceiling Fan Light Kit Proposed Test Procedures

9:10 – 9:30 am Opening Statements; TP Regulatory History; Rulemaking Overview

9:30 – 10:50 am Existing Product Classes, Metrics, and Test Procedures; Proposed 

Amendments to Current Test Procedures; Proposed Test Procedures 

to Support Standards Rulemaking

10:50 – 11:00 am Break

11:00 – 11:50 am Clarifications to the Energy Conservation Standards; Determination 

of Represented Values

11:50 am – 12:00 pm Closing Remarks

12:00 – 1:00 pm Lunch
4

Public Meeting Agenda: Afternoon

Ceiling Fan Light Kit Energy Conservation Standards 

Preliminary Analysis 

1:00 – 1:20 pm Opening Statements; ECS Regulatory History; Rulemaking Overview

1:20 – 1:40 pm Scope; Market & Technology Assessment

1:40 – 2:10 pm Screening and Engineering Analyses

2:10 – 2:20 pm Product Price Determination

2:20 – 2:30 pm Break

2:30 – 2:55 pm Energy Use; Life Cycle Cost Analyses

2:55 – 3:30 pm Shipments; National Impact Analyses

3:30 – 3:40 pm Preliminary Manufacturer Impact Analysis 

3:40 – 3:50 pm NOPR Analyses

3:50 – 4:00 pm Closing Remarks and Adjourn
5

Listening via the Webcast

• DOE is broadcasting this meeting live over the Internet. 

• DOE is providing the webcast to accommodate stakeholders 

that are unable to attend the public meeting in person. 

• The web broadcast allows stakeholders to listen in and view 

the slides.

• All stakeholders are encouraged to submit written comments 

after the public meeting. 
6

Purpose of this Public Meeting

1. Review statute and DOE actions for ceiling fan light kits (CFLKs)

2. Present DOE’s proposed test procedures for CFLKs

3. Present energy conservation standards DOE is considering for 

CFLKs in the Preliminary Analysis

4. Invite comment from participants on the test procedures and 

Preliminary Analysis

5. Discuss the next steps for the rulemakings

6. Encourage participants to submit data, information, summary 

statements, and written comments, including additional issues 

for discussion
7

Proposed Ceiling Fan Light Kit (CFLK) Test Procedures
8

Issue for Discussion

Issue box numbering corresponds to the list of issues published at the end of 

the Test Procedure NOPR, available at regulations.gov, under docket number:

EE-2014–BT–TP–0007, at 

http://www.regulations.gov/#!documentDetail;D=EERE-2014-BT-TP-0007-0001

The deadline for submitting comments on the Test Procedure NOPR is:

January 14, 2015

Issue Box: DOE welcomes comments, data, and information 

concerning the proposed CFLKs test procedures. Issues that 

correspond to those raised in DOE’s published material will be 

numbered in accordance with that material. Whether invited by an 

issue box or not, comments are welcome on any part of DOE’s 

analysis.
9

How to Submit Written Comments

• In all correspondence, please refer to the CFLK test procedure rulemaking 

by:

– Test Procedure for Ceiling Fan Light Kits;

– Docket Number EE-2014–BT–TP–0007; and

– Regulatory Identification Number (RIN) 1904-AD17.

• Email: CFLK2014TP0007@ee.doe.gov

Postal: Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, 

Mailstop EE-5B

1000 Independence Avenue, SW

Washington, DC 20585-0121

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Suite 600

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: 202 586-2945

Test Procedure NOPR Comment Period closes: January 14, 2015, 11:59 PM EDT
10

Opening Remarks

Meeting participants are invited to provide opening 

remarks or statements at this time.
11

CFLKs TP Rulemaking Schedule

Milestone Date

Test Procedure NOPR published

Beginning of 75-day comment period October 31, 2014

End of 75-day comment period January 14, 2015

Final rule to establish any final test procedures for CFLKs Q3 2015

Test Procedure effective date (projected) for amendments 

to current CFLK TP (proposed Appendix V)

Q3 2015 

(30 days after final rule)

Test Procedure compliance date (projected) for proposed 

CFLK test procedure (proposed Appendix V1) to support 

CFLK ECS rulemaking

Q2* 2019

* Calendar year quarter

2015 2016 2019
12

Regulatory History – Test Procedure

• Title III of the Energy Policy and Conservation Act (EPCA) establishes 

the “Energy Conservation Program for Consumer Products Other Than 

Automobiles,” which includes CFLKs.

• The Energy Policy Act of 2005 (EPAct) amended EPCA and established 

energy conservation standards for CFLKs, as well as requirements for 

the CFLK test procedures.

• EPAct 2005 required the CFLKs test procedure be based on the test 

procedures referenced in the ENERGY STAR specifications for residential 

light fixtures and compact fluorescent light bulbs.

• On December 8, 2006, DOE published a final rule in the Federal 

Register for test procedures for CFLKs. 71 FR 71340. 

• DOE is conducting this test procedure rulemaking for CFLKs pursuant to 

42 U.S.C. 6295(r).
13

Regulatory History – Test Procedure

• The Energy Independence and Security Act of 2007 (EISA) set forth 

requirements for test procedures:

• At least once every 7 years DOE must conduct an evaluation of all 

covered products and either amend the test procedures or publish a 

determination in the Federal Register not to amend them.

• For test procedures of covered products that do not fully account for 

standby-mode and off-mode energy consumption, EISA 2007 directs 

DOE to amend its test procedures to account for standby-mode and offmode energy consumption, unless it is technically infeasible to do so.

• The existing test procedures for CFLKs are specified in Appendix V to 

Subpart B of part 430 of Title 10 of the CFR.
14

Scope of Coverage

• EPCA defines a CFLK as “equipment designed to provide light from a 

ceiling fan that can be 

• (A) integral, such that the equipment is attached to the ceiling fan prior 

to the time of retail sale; or 

• (B) attachable, such that at the time of retail sale the equipment is not 

physically attached to the ceiling fan, but may be included inside the 

ceiling fan at the time of sale or sold separately for subsequent 

attachment to the fan.”

(42 U.S.C. 6291(50)(A)and(B))

• Therefore, any equipment designed to provide light from products 

that are defined as CFs under the CFs rulemaking will be included in 

the scope of the CFLK rulemaking.
15

CFLK Test Procedures NOPR Presentation Overview

3 Proposed Test Procedures to Support Standards Rulemaking

1 Existing Product Classes, Metrics, and Test Procedures

2 Proposed Amendments to Current Test Procedures

4 Clarifications to the Energy Conservation Standards

5 Determination of Represented Values
16

Current Test Procedure Applicability and Efficiency Metrics

• Currently there are three product classes for 

CFLKs and the metrics and test procedure 

requirements vary by product class

Current Product Classes

Product 

Class Description Efficiency Metric*

Test Procedure or 

Design Standard

1

CFLKs with medium screw 

base (MSB) sockets Lamp efficacy (lm/W) Test procedure

2

CFLKs with pin-based 

fluorescent sockets System efficacy (lm/W) Test procedure

3 All other CFLKs Wattage Limiter Design standard

* CFLKs with medium screw-base sockets must be packaged with lamps to fill all sockets and those 

lamps must meet additional specifications in ENERGY STAR Program Requirements for Compact 

Fluorescent Lamps, version 3.0. CFLKs with pin-based sockets must also use an electronic ballast and be 

packaged with lamps to fill all sockets.
17

DOE’s Current Test Procedures

• DOE's test procedures for determining the efficiency for CFLKs in 

product class 1 and 2 are codified in Appendix V to subpart B of part 

430 of Title 10 of the CFR; DOE has not established a test procedure for 

product class 3 CFLKs.

Product 

Class 1

Product 

Class 2 

Product 

Class 3

“CFL Requirements for Testing” of the 

“ENERGY STAR Program Requirements 

for Compact Fluorescent Lamps,” 

Version 3.0, which references IES LM66-00 for lamp efficacy measurements

“ENERGY STAR Program Requirements 

for Residential Light Fixtures,” Version 

4.0, which references IES LM-66-00 

and IES LM-9-99 for system efficacy 

measurements

None
18

Proposed Test Procedures: Two phase process 

• DOE proposes to make minor clarifications and amendments to the 

current test procedures (i.e., updates to test procedure references).

• Because the amendments will not change the measured CFLK 

efficiency, DOE proposes that the test procedure will be effective 30 

days after publication and manufacturers must make any 

representations with respect to energy use or efficiency of ceiling fan 

light kits beginning 180 days after publication of the final rule in the 

Federal Register.

• As part of this NOPR, DOE proposes to add new test procedures that 

would revise the methods for measuring the energy efficiency of 

CFLKs to support the concurrent energy conservation standards 

rulemaking.

• DOE proposes new test procedures that support the standards 

rulemaking for CFLKs and would be required at the compliance date of 

a potential amended CFLK standard.
19

CFLK Test Procedures NOPR Presentation Overview

3 Proposed Test Procedures to Support Standards Rulemaking

1 Existing Product Classes, Metrics, and Test Procedures

2 Proposed Amendments to Current Test Procedures

4 Clarifications to the Energy Conservation Standards

5 Determination of Represented Values
20

Proposed Amendments to Current Test Procedures

• DOE’s intention with the proposed changes to the current CFLK test procedure is to 

harmonize the represented values of lamp efficacy, wherever possible, with the 

covered lamp regulations. 

• DOE believes this will reduce burden on CFLK manufacturers if they purchase 

covered lamps rated pursuant to DOE’s regulations to be packaged with their CFLKs.

• DOE proposes to make the following amendments to the current test procedures for 

product classes 1 and 2:

Product 

Class

Current Test Procedure Proposed Change to Current Test 

Procedure(s)

1

(MSB)

“CFL Requirements for Testing” of the 

“ENERGY STAR Program Requirements for 

Compact Fluorescent Lamps,” Version 3.0

DOE test procedure for MSB CFL lamps:

10 CFR 430, subpart B, appendix W

2

(Pin-Base)

“ENERGY STAR Program Requirements for 

Residential Light Fixtures,” Version 4.0

Current industry test procedures:

IES LM-66-11 or IES LM-9-09

System Efficacy would remain the metric
21

Proposed Amendments to Current Test Procedures

Issue 1: CFLKs with MSB Lamps

DOE requests comments on the proposed changes for existing test 

procedures for CFLKs packaged with medium screw base lamps.

Issue 2: CFLKs with Pin-Based Fluorescent Lamps

DOE requests comments on the proposed changes for existing test 

procedures for CFLKs packaged with pin-based fluorescent lamps. 
22

CFLK Test Procedures NOPR Presentation Overview

3 Proposed Test Procedures to Support Standards Rulemaking

1 Existing Product Classes, Metrics, and Test Procedures

2 Proposed Amendments to Current Test Procedures

4 Clarifications to the Energy Conservation Standards

5 Determination of Represented Values
23

Proposed Test Procedures to Support Standards Rulemaking

• DOE is proposing to add new test procedures that would support the 

concurrent energy conservation standards rulemaking for CFLKs. 

Specifically, DOE is:

1. proposing to use an efficiency metric—efficacy (lm/W)—to quantify 

the energy efficiency of all CFLKs

2. proposing to update the active mode test procedures to reference 

current DOE or industry lamp test procedures

3. NOT proposing to incorporate any energy consumption in standby or 

off mode into the CFLK efficiency metric. 
24

1. Proposed Metric

• DOE proposes to use efficacy, measured in lumens per watt, to 

quantify the energy efficiency of all CFLKs.

• Lamp Efficacy: For CFLKs with consumer-replaceable lamps

• Luminaire Efficacy: For CFLKs with integral solid-state lighting (SSL) 

circuitry
25

1. Proposed Metric

• Luminaire Efficacy

• The luminaire efficacy of each basic model of 

CFLK with integral SSL circuitry would be 

determined.

• “CFLKs with integral SSL circuitry” means:

1. CFLKs that have SSL drivers and/or light sources 

(e.g., an LED array or module) that are not 

consumer replaceable, or

2. CFLKs that have SSL drivers and light sources that 

are consumer replaceable, but the SSL driver and 

light source are separated by additional 

intermediate circuitry within the CFLK (e.g., wiring 

between a replaceable driver and a replaceable 

light source).
26

1. Proposed Metric

Lamp Efficacy Measurement Luminaire Efficacy Measurement

Consumer-Replaceable Lamp

Non-Replaceable SSL 

Source and Driver

Non-Replaceable 

SSL Driver

Replaceable SSL 

Source and Driver

(but separated by 

socket and/or wiring)
27

1. Proposed Metric

Issue 5: Efficacy Measurements of Lamps and Luminaires

DOE requests comments on its proposal to use lamp efficacy when 

technically feasible and otherwise luminaire efficacy to determine 

the efficiency of CFLKs. 

Issue 7: CFLKs with Integral SSL Circuitry

DOE requests comment on its assessment that it is technically 

infeasible to measure the lamp efficacy of CFLKs with integrated SSL 

circuitry either because it would require destructive disassembly of 

the CFLK or measurement of consumer replaceable light source and 

driver [without integrated circuitry], which would not result in valid 

representations of the light source efficacy.
28

2. Proposed Active Mode Test Procedures

• DOE proposes to determine CFLK efficiency according to DOE test 

procedures for the given lamp, when possible, and with industry 

test procedures otherwise. DOE is currently engaged in test 

procedure rulemakings for CFLs and integrated LED lamps. 

Lighting 

Technology

Lamp or Luminaire

Efficacy Measured

Referenced Test 

Procedure

Compact fluorescent lamps (CFLs) Lamp efficacy Appendix W to Subpart 

B of 10 CFR 430

General service fluorescent lamps 

(GSFLs) and general service 

incandescent lamps (GSILs)

Lamp efficacy Appendix R to Subpart

B of 10 CFR 430

Other (non-CFL and non-GSFL)

fluorescent lamps Lamp efficacy IES LM-9-09

Integrated LED lamps Lamp efficacy Appendix BB to Subpart

B of 10 CFR 430

All other SSL lamps Lamp efficacy IES LM-79-08

CFLKs with integrated SSL circuitry Luminaire efficacy IES LM-79-08
29

2. Proposed Active Mode Test Procedures

• For CFLKs that utilize multiple lamp models, DOE proposes that each 

lamp model be tested according to the appropriate lamp test 

procedure for each lamp type.

• Referencing existing DOE lamp test procedures will minimize the overall 

testing burden (i.e., lamps already tested per DOE test procedures would 

not require additional testing).

• For CFLKs that have both consumer replaceable lamps and integrated 

SSL circuitry, DOE proposes that lamp efficacy be reported for the 

consumer replaceable lamps and that luminaire efficacy be reported 

for the CFLK integrated SSL circuitry, with the consumer replaceable 

lamps removed. 
30

3. Standby/Off-Mode Energy Consumption

• DOE is not proposing to incorporate energy consumption in standby 

mode in the CFLK efficiency metric and has determined there is no 

energy consumption in the off mode; therefore, DOE is not proposing 

standby or off mode test procedures. 

• Standby mode energy consumption for light kits packaged with CFs is 

measured as part of the proposed CF test procedure.

Issue 9: Standby/Off-Mode Energy Consumption

DOE requests comment on its approach to addressing standby 

power consumption in CFLKs. 
31

CFLK Test Procedures NOPR Presentation Overview

3 Proposed Test Procedures to Support Standards Rulemaking

5 Determination of Represented Values

1 Existing Product Classes, Metrics, and Test Procedures

2 Proposed Amendments to Current Test Procedures

4 Clarifications to the Energy Conservation Standards
32

Clarifications to 10 CFR 430.32(s)

• CFLK energy conservation standards are codified in 10 CFR 430.32(s).

• DOE proposes to replace references to ENERGY STAR program 

requirements in 10 CFR 430.32(s) with tables that contain the specific 

performance requirements. Performance requirements include:

CFLKs packaged with MSB CFLs: lamp efficacy, lumen maintenance at 

1,000 hours, lumen maintenance at 40% of lifetime, rapid cycle stress, and 

lifetime 

CFLKs packaged with MSB light sources other than CFLs: lamp efficacy

CFLKs packaged with pin-based fluorescents: system efficacy, electronic 

ballast required

• The current energy conservation requirements remain unchanged. 
33

Updated Guidance on Accent Lighting

• DOE previously issued guidance on accent lighting used in CFLKs, 

stating, “DOE does not consider ceiling fan accent lighting that is not 

a significant light source to be part of the 190-watt limitation [for 

class 3 CFLKs].”

• Because it is difficult to quantitatively define “a significant light 

source” in a CFLK, and may result in inconsistency in the application 

of CFLK standards, DOE proposes to:

1. withdraw the current guidance on accent lighting 30 days after the 

publication of the final rule, and

2. consider all lighting packaged with any CFLK to be subject to energy 

conservation requirements.

Issue 4: Accent Lighting

DOE requests comment on its withdrawal of current guidance on 

accent lighting in CFLKs and proposal to consider all lighting packaged 

with all CFLKs to be subject to energy conservation requirements.
34

CFLK Test Procedures NOPR Presentation Overview

3 Proposed Test Procedures to Support Standards Rulemaking

5 Determination of Represented Values

1 Existing Product Classes, Metrics, and Test Procedures

2 Proposed Amendments to Current Test Procedures

4 Clarifications to Energy Conservation Standards
35

Determination of Represented Values

• The requirements of 10 CFR 429.11 (“General sampling 

requirements for selecting units to be tested”) are applicable to 

CFLKs, except that, for CFLKs subject to a design standard, each unit 

must meet the design standard.

• For each basic model of CFLK, the following requirements are 

applicable for compliance with the current energy conservation 

standards:

CFLK Socket 

Type

Bulb Type Included 

in CFLK Package

Represented Values Shall be 

Determined in Accordance With:

MSB

CFL 10 CFR Part 429.35

Integrated LED 10 CFR Part 429.56

General Service 

Incandescent 10 CFR Part 429.27

Pin-based Fluorescent 10 CFR 429.35

All Others Socket Types 10 CFR 430.32(s)(4)
36

Determination of Represented Values

• For each basic model of CFLK, the following requirements are 

applicable for compliance with amended energy conservation 

standards, if established:

Lamp Type Included in CFLK Package Represented Values Shall be 

Determined in Accordance With:

CFL 10 CFR Part 429.35

General Service Fluorescent and Incandescent 

Lamps 10 CFR Part 429.27

Integrated LED 10 CFR Part 429.56

Other Fluorescent Lamps (Not CFLs or GSFLs) 10 CFR Part 429.35

Other SSL (not integrated LED) 10 CFR Part 429.56

CFLKs with Integrated SSL Circuitry 10 CFR 429.33
37

How to Submit Written Comments

• In all correspondence, please refer to the CFLK test procedure rulemaking 

by:

– Test Procedure for Ceiling Fan Light Kits;

– Docket Number EE-2014–BT–TP–0007; and

– Regulatory Identification Number (RIN) 1904-AD17.

• Email: CFLK2014TP0007@ee.doe.gov

Postal: Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, 

Mailstop EE-5B

1000 Independence Avenue, SW

Washington, DC 20585-0121

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Suite 600

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: 202 586-2945

Test Procedure NOPR Comment Period closes: January 14, 2015, 11:59 PM EDT
38

CFLK Energy Conservation Standards Preliminary Analysis
39

How to Submit Written Comments for CFLKs

• In all correspondence, please refer to the CFLK rulemaking by:

– Energy Conservation Standards for Ceiling Fan Light Kits;

– Docket Number EERE-2012-BT-STD-0045; and

– Regulatory Identification Number (RIN) 1904-AC87.

• Email: CeilingFanLightKits2012STD0045@ee.doe.gov

Postal: Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, 

Mailstop EE-2J

1000 Independence Avenue, SW

Washington, DC 20585-0121

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Suite 600

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: 202 586-2945

Energy Conservation Standards TSD Comment Period closes: 

December 30, 2014, 11:59 PM EDT
40

Opening Remarks

Meeting participants are invited to provide opening 

remarks or statements at this time.
41

CFLKs ECS Rulemaking Schedule

Milestone Date

Notice of Public Meeting and Availability of CFs and CFLKs 

Framework Document March 11, 2013

Notice of Public Meeting and Availability of CFLKs Preliminary 

Technical Support Document October 31, 2014

Notice of Proposed Rulemaking for CFLKs (projected) Q3* 2015

Final Rule for CFLKs (projected) Q2* 2016

Compliance Date for CFLKs (projected) Q2* 2019

* Calendar quarters

2013 2014 2015 2016 2017 2018 2019 2020
42

Regulatory History: Energy Conservation Standards

• The Energy Policy Act of 2005 amended the Energy Policy and 

Conservation Act of 1975 (EPCA) by adding CFLKs as covered products. 

(42 U.S.C. 6295(ff))

− Provided DOE the ability to establish energy conservation standards for 

“ceiling fan light kits,” as defined by 42 U.S.C. 6291(50), and set forth 

requirements for determining whether standards should be amended.

• On October 18, 2005, DOE published a final rule technical amendment 

(70 FR 60407, 60413) codifying energy efficiency standards for two 

product classes of CFLKs.

• On January 11, 2007, DOE published a final rule technical amendment 

codifying energy efficiency standards for a third product class of CFLKs. 

72 FR 1270. 

• DOE is conducting this energy conservation standards rulemaking 

pursuant to 42 U.S.C. 6295(ff)(5).
43

CFLK ECS Pre-Analysis Presentation Overview

3 Screening Analysis

5 Product Price Determination

1 Scope of Coverage

6 Energy Use

2 Market & Technology

11 Closing Remarks

4 Engineering Analysis

7 Life-Cycle Cost Analysis

8 Shipments; National Impact Analysis

9 Preliminary MIA

10 NOPR Analyses
44

Scope of Coverage

• EPCA defines a CFLK as “equipment designed to provide light from a 

ceiling fan that can be 

• (A) integral, such that the equipment is attached to the ceiling fan prior 

to the time of retail sale; or 

• (B) attachable, such that at the time of retail sale the equipment is not 

physically attached to the ceiling fan, but may be included inside the 

ceiling fan at the time of sale or sold separately for subsequent 

attachment to the fan.”

(42 U.S.C. 6291(50)(A)and(B))

• Therefore, any equipment designed to provide light from products 

that are defined as CFs under the CFs rulemaking will be included in 

the scope of the CFLK rulemaking.
45

CFLK ECS Pre-Analysis Presentation Overview

3 Screening Analysis

5 Product Price Determination

1 Scope of Coverage

6 Energy Use

2 Market & Technology

11 Closing Remarks

4 Engineering Analysis

7 Life-Cycle Cost Analysis

8 Shipments; National Impact Analysis

9 Preliminary MIA

10 NOPR Analyses
46

Market & Technology Assessment

• Purpose:

• Characterize the CFLK market 

• Define product classes

• Identify technology options

• Method:

• Identify and characterize manufacturers of CFLKs

• Identify existing regulatory and voluntary efficiency programs

• Gather historical shipment and other relevant market data

• Estimate market trends

• Identify measures that could improve efficiency
47

Market Assessment

• CFLKs used with low-volume CFs

• Currently three product classes:

1. Medium screw base sockets

2. Pin-based sockets (for externally-ballasted fluorescent lamps)

3. All other CFLKs

Product 

class

Shelf Surveys Online Weighted 

Total 

Market Share 

by Product Class Base Type Market Share by Base Type

Market Share by 

Product Class

Market Share 

by Base Type

Product 

Class

1 15.1% Medium screw base 15.1% 16.9% 16.9% 15.1%

2 0.0% Pin-based 

fluorescent 0.0% 0.5% 0.5% <1%

3 84.9%

Candelabra 

(including mini 

candelabra)

79.2%

82.4%

68.8%

GU24 4.6% 12.8% 84.8%

Others (e.g., G9, GU 

10, integral solidstate lighting)

1.2% 0.8%

100% 100% 100% 100% 100%

Estimates of CFLK Market Shares in 2012 by Current Product Class and Socket Type:
48

Market Assessment

NPD Estimates of Historical Shipments of CFs: 

(source: NPD Group, 2007-2011)

DOE Estimates of Historical Shipments of CFs:

(based on NPD data above, assuming ratio of CFs sold with and without CFLKs is equivalent for 

customers who did and did not specify)

Number of Units 2007 2008 2009 2010 2011

With CFLK 18,360,000 18,180,000 19,160,000 16,870.000 16,480,000

Without CFLK 2,680,000 2,610,000 2,520,000 2,560,000 2,290,000

Total 21,050,000 20,790,000 21,680,000 19,430,000 18,770,000

% with CFLK 87% 87% 88% 87% 88%

Number of Units 2007 2008 2009 2010 2011

With CFLK 14,899,594 15,485,300 16,015,248 14,414,909 14,597,241

Without CFLK 2,176,229 2,226,826 2,106,832 2,184,390 2,035,746

Not Specified 3,970,371 3,080,311 3,561,611 2,830,707 2,140,867
49

Market Assessment

Issue 1: CFLKs Sold with CFs

DOE assumes that the majority of CFLKs are sold with CFs and did not analyze 

CFLKs sold separately in its analysis. DOE requests comment on this 

assumption and available shipments data on CFLKs sold separately.

Issue 8: CFLKs for High-Volume CFs

DOE seeks answers to the following questions related to CFLKs designed for highvolume fans: 

• Do manufacturers anticipate that CFLKs designed for high-volume fans will 

constitute a significant fraction of the CFLK market in the next 5 to 10 years?

• What range of lumen outputs are/would these products be designed to achieve?

• Would these CFLKs be likely to have any other unique characteristics that are not 

common to the current market of CFLKs?
50

Considered Product Classes

• Pursuant to EPCA, DOE establishes different product classes by: (1) 

type of energy used; (2) capacity of the product; or (3) any other 

performance-related features that require different standard levels, 

such as features affecting consumer utility. (42 U.S.C. 6295(q))

• DOE is considering redefining CFLKs from the current three product 

classes into two products classes.

• New product class structure essentially combines the current product 

classes 1 and 3 into the new product class 2.

Current 

Product Class Description

1 Medium screw base (E26)

2

Pin-based fluorescent

(applies only to non-integrally 

ballasted lamps)

3 All other CFLKs

Proposed 

Product Class Description

1

CFLKs with externallyballasted or driven lamps

2 All other CFLKs
51

Product Classes

Issue 7: CFLK Product Classes

DOE is considering a new product class structure that divides CFLKs into two 

product classes: Externally-Ballasted/Driven CFLKs and All Other CFLKs. DOE 

invites comment on this structure.

Issue 19: Production of Externally-Driven LED CFLKs

DOE requests comment on whether manufacturers are currently producing or 

expecting to produce CFLKs that use externally-driven LED lamps.

Issue 4: Dimming

DOE seeks data on the dimming functionality of current generation CFL and 

LED lamps, and specifically on the performance of those lamps with dimmers 

designed for their control. DOE seeks data on consumer satisfaction with the 

dimming functionality of these systems. DOE also seeks input from 

manufacturers as to whether they anticipate accommodating dimming 

functionality into the LED CFLK models they will offer for sale in the next five 

years, and if so, what fraction of LED CFLKs would include such functionality.
52

Technology Options

• DOE is considering more efficacious light sources as the only 

technology option to increase CFLK efficacy.

• DOE is not considering external ballasts or lighting controls, as the 

impact of these technologies cannot be measured by the proposed 

CFLK test procedures.

Issue 5: Lighting Controls

DOE requests comment on its proposal not to include lighting controls as a 

technology option in this rulemaking.

Issue 6: CFLK Technology Options

DOE requests comment on lamps being considered as the technology options 

for CFLKs and any additional options that should be included.
53

CFLK ECS Pre-Analysis Presentation Overview

3 Screening Analysis

5 Product Price Determination

1 Scope of Coverage

6 Energy Use

2 Market & Technology

11 Closing Remarks

4 Engineering Analysis

7 Life-Cycle Cost Analysis

8 Shipments; National Impact Analysis

9 Preliminary MIA

10 NOPR Analyses
54

• DOE reviewed different technology options and assessed them 

using the following criteria:

– Technological feasibility

– Practicability to manufacture, install, and service

– Adverse impacts on product utility or availability to customers

– Adverse impacts on health or safety

• DOE did not screen out any technology options and therefore 

considered more efficacious light sources as design options in the 

engineering analysis.

Screening Analysis

Issue 10: Screening Analysis

DOE invites comment on the screening analysis.
55

CFLK ECS Pre-Analysis Presentation Overview

3 Screening Analysis

5 Product Price Determination

1 Scope of Coverage

6 Energy Use

2 Market & Technology

11 Closing Remarks

4 Engineering Analysis

7 Life-Cycle Cost Analysis

8 Shipments; National Impact Analysis

9 Preliminary MIA

10 NOPR Analyses
56

Select certain product classes to be analyzed in the 

engineering analysis. 

Engineering Analysis Methodology

Define characteristics of models in each product class 

that serve as reference points to assess changes due 

to energy conservation standards. 

Identify more efficacious substitutes for each 

baseline model based on design options. 

Develop candidate standard levels (CSLs) that span 

the range of efficacy from the baseline to the 

maximum technologically feasible.

Scale results to product classes not analyzed.

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results
57

Representative Product Classes

Issue 11: Representative Product Classes

DOE requests comment on the representative product classes 

for CFLKs.

• DOE chooses representative product classes to 

concentrate its analytical effort.

– Representative product classes were selected based on high 

market volume or unique performance characteristics.

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results

Product Class

All Other CFLKs

CFLKs with Externally-Ballasted/Driven Lamps
58

• The baseline model typically represents the most 

common, least efficacious lamp in a CFLK that meets 

existing energy conservation standards.

 DOE identifies a baseline model in each representative 

product class.

Baseline Lamps

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results
59

• For each baseline lamp, DOE selected more efficacious 

replacement lamps, on the basis of initial efficacy, to measure 

potential energy-saving improvements. DOE selected more 

efficacious substitutes under a lamp replacement scenario and 

a fixture replacement scenario.

– In the lamp replacement scenario, the more efficacious substitute 

with the same base type as the baseline lamp was selected.

– In the fixture replacement scenario, the more efficacious lamp 

substitute with a different base type than the baseline lamp could 

be selected and a change in number of fixture sockets was 

allowed. 

– Both the lamp and fixture replacement scenario use the same 

baseline lamp. 

More Efficacious Substitutes: Substitution Scenarios

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results

Issue 13: Substitution Scenarios

DOE requests comment on the likelihood of CFLK manufacturers 

selecting each substitution scenario and information on any 

alternative scenarios that manufacturers may choose.
60

Candidate Standard Levels

• DOE considered an equation-based approach to 

characterize a continuous relationship between lamp 

input power and initial lamp efficacy.

• DOE used commercially available lamps and their 

associated catalog rated efficacies to determine CSLs.

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results
61

• For the All Other CFLK product class DOE identified a 

baseline lamp that represents the most common, least 

efficacious lamp in a CFLK that meets existing energy 

conservation standards.

All Other CFLKs: Baseline Lamp

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results

Bulb 

Shape

Base 

Type

Lamp 

Type

Lamp 

Wattage

Initial 

Light 

Output

Efficacy

Lamp 

Lifetime

Number of 

Sockets*

W lm lm/W hr

Spiral E26 CFL 14 730 52.1 10,000 2

* Used in fixture replacement scenario

Issue 12: Baseline Lamp

DOE requests comment on the baseline unit selected for All Other 

CFLKs.
62

Efficacy 

Level

Lamp 

Type

Base Type

Bulb 

Shape

Wattage

Initial 

Light 

Output

Efficacy

CRI

CCT

Lamp 

Lifetime

W lm lm/W K hr

Baseline CFL E26 Spiral 14 730 52.1 82 2,700 10,000

CSL 1 CFL E26 Spiral 13 800 61.5 82 2,700 12,000

CSL 2 CFL E26 Spiral 11 730 66.4 82 2,700 10,000

CSL 3 LED E26 A19 10 700 70.0 75 3,000 50,000

CSL 4 LED E26/E27 A19 9 680 75.6 80 3,000 50,000

CSL 5 LED E26 G25 8 680 85.0 75 2,700 50,000

All Other CFLKs – Lamp Replacement Scenario:

More Efficacious Substitutes
63

All Other CFLKs – Fixture Replacement Scenario:

More Efficacious Substitutes

Efficacy 

Level

Lamp 

Type

Base 

Type

Bulb 

Shape

Fixture 

Sockets

Lamp 

Wattage

Fixture 

Wattage

Lamp 

Initial 

Light 

Output

Fixture 

Initial 

Light 

Output

Efficacy

CRI

CCT

Lamp 

Life

W W lm lm lm/W K hr

Baseline CFL E26 Spiral 2 14 28 730 1,460 52.1 82 2,700 10,000

CSL 1 CFL E26 Spiral 1 23 23 1,500 1,500 65.2 82 2,700 10,000

CSL 2 CFL E26 Spiral 3 7 21 450 1,350 64.3 82 2,700 12,000

CSL 3 LED E26 A19 4 5 20 340 1,360 68.0 75 2,700 50,000

CSL 4 LED E26 A21 1 19 19 1,600 1,600 84.2 94 2,700 50,000

CSL 5 LED E26 A19 3 6 18 500 1,500 83.3 80 2,700 50,000

Issue 14: More Efficacious Substitutes

DOE requests comment on the criteria used in selecting more efficacious 

substitute lamps, as well as the characteristics of the units selected for All Other 

CFLKs. DOE particularly requests comment on the lifetimes of the baseline and 

substitute lamps.
64

All Other CFLKs: Candidate Standard Levels

• DOE considered an equation-based approach to 

characterize a continuous relationship between lamp 

input power and initial lamp efficacy.

• The following are CSLs under consideration:

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results

Candidate Standard Level

Efficacy Requirement

lm/W

CSL 1 73/(1+5*((W+10)-1))

CSL 2 81/(1+5*((W+10)-1))

CSL 3 87/(1+5*((W+10)-1))

CSL 4 94/(1+5*((W+10)-1))

CSL 5 108/(1+5*((W+10)-1))

W = rated lamp wattage
65

All Other CFLKs: Candidate Standard Levels 

All Other CFLKs: Lamp and Fixture Replacement Scenarios
66

All Other CFLKs: Candidate Standard Levels

Issue 16: Candidate Standard Levels

DOE requests comment on the CSLs under consideration, including the max tech 

level, for All Other CFLKs. In particular, DOE requests comment on the equations 

used to define the efficacy requirements at each CSL.
67

Externally-Ballasted/Driven Product Class:

Lamp-and-Ballast Systems

• To assess the performance of CFLKs with Externally-Ballasted or Driven 

Lamps, DOE used a systems approach and paired lamps with ballasts, 

capturing real-world energy use and light output.

• DOE paired externally-ballasted lamps with electronic ballasts, as they 

are required by existing CFLK standards and represent the most 

common ballasts on the market.
68

Externally-Ballasted/Driven Product Class:

Baseline Lamp

Bulb 

Shape

Base 

Type

Lamp 

Type

Nominal 

Wattage

ANSI

Rated 

Wattage

System 

Input 

Power

Lamp 

Initial 

Light 

Output

System 

Initial 

Light 

Output

Lamp 

Rated 

Efficacy

System 

Efficacy

Lamp 

Lifetime

Number 

of 

Sockets*

W W W lm lm lm/W lm/W hr

T9 

Circular

G10q

Fluores

cent

22 22.5 17.0 950 855 42.2 50.3 12,000 1

Issue 12: Baseline Lamp

DOE requests comment on the baseline unit selected for CFLKs 

with Externally-Ballasted or Driven Lamps.

* Used in fixture replacement scenario

• For the Externally-Ballasted/Driven product class, DOE identified a baseline 

lamp that represents the most common, least efficacious lamp in a CFLK.

• Baseline products in this class are subject to system efficacy standards.

• DOE paired the baseline lamp with a ballast resulting in a system efficacy that 

just meets standards. 
69

Externally-Ballasted/Driven Product Class:

More Efficacious Substitutes

Efficacy 

Level

Lamp Type

Lamp 

Diameter

Nominal 

Wattage

Rated 

Wattage

System 

Input 

Power

Lamp 

Initial 

Light 

Output

System 

Initial 

Light 

Output

Lamp 

Lifetime Ballast 

Factor

Lamp Rated 

Efficacy

System 

Efficacy

W W W lm lm hr lm/W lm/W

Baseline Fluorescent T9 22 22.5 17.0 950 855 12,000 0.9 42.2 50.3

CSL 1 Fluorescent T9 20 19 14.3 920 828 12,000 0.9 48.4 57.9

Efficacy 

Level

Lamp 

Type

Lamp 

Diameter

Fixture 

Sockets

Lamp 

Wattage

Fixture 

Wattage

System 

Input 

Power

Lamp 

Initial 

Light 

Output

System 

Initial 

Light 

Output

Lamp 

Lifetime Starting 

Method

Ballast 

Factor

Lamp 

Rated 

Efficacy

System 

Efficacy

W W W lm lm hr lm/W lm/W

Baseline

Fluorescent

T9 1 22 22.5 17.0 950 855 12,000 RS 0.9 42.2 50.3

CSL 1 CFL - 1 13 13 16.0 900 900 17,000 PS 1.0 69.2 56.3

Lamp Replacement Scenario

Fixture Replacement Scenario
70

Externally-Ballasted/Driven Product Class:

More Efficacious Substitutes

Issue 13: More Efficacious Substitutes

DOE requests comment on the criteria used in selecting more efficacious 

substitute lamps, as well as the units selected for Externally-Ballasted/Driven 

CFLKs. DOE particularly requests comment on the lifetimes of the baseline 

and substitute lamps.

Issue 15: Lamp-and-Ballast Systems

DOE requests comment on the lamp-and-ballast systems selected for the 

Externally-Ballasted/Driven CFLKs product class. In particular, DOE requests 

comment on the selection of electronic ballasts for the lamp-and-ballast 

systems.
71

Externally-Ballasted/Driven Product Class:

Candidate Standard Levels

• DOE considered an equation-based approach to 

characterize a continuous relationship between lamp 

input power and initial lamp efficacy.

• The following CSL is under consideration:

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results

Candidate Standard Level

Efficacy Requirement

lm/W

CSL 1 62/(1+9*((W+12)-1))

W = rated lamp wattage
72

Externally-Ballasted/Driven Product Class:

Candidate Standard Levels

CFLKs with Externally-Ballasted or Driven Lamps
73

Externally-Ballasted/Driven Product Class:

Candidate Standard Levels

Issue 16: Candidate Standard Levels

DOE requests comment on the CSLs under consideration, including the max tech 

level, for Externally-Ballasted/Driven CFLKs. In particular, DOE requests comment 

on the equations used to define the efficacy requirements at each CSL.
74

Scaling Between Product Classes

• In general, DOE scales CSLs to product classes not 

directly analyzed.

• Because DOE chose to analyze all product classes as 

representative no scaling was required.

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results
75

Engineering Analysis

Issue 17: Ballast Replacements

DOE requests comment on whether, and what fraction of, ballasts for pin-based 

fluorescent lamps are designed to be replaceable by the consumer. DOE also 

requests comment on whether consumers generally replace the ballast in a CFLK 

with a consumer-replaceable ballast if it fails, or if consumers replace the entire 

CFLK, assuming it is no longer operable.

Issue 20: Externally-Driven LED Replacements

DOE requests comment on the practicality of externally-driven LEDs (e.g., LED 

module-and-driver systems) as replacements for externally-ballasted 

fluorescent or CFL lamps in CFLKs. Specifically, DOE requests information on the 

fixture changes necessary for such a replacement.

Issue 21: Externally-Driven LED Efficacies

DOE requests information on the typical efficacy ranges for externally-driven 

LEDs used in CFLKs. DOE requests information on what these efficacy ranges 

represent (i.e., luminaire efficacy of the fixture, LED module alone, or LED 

module-and-driver system).
76

Engineering Analysis

Issue 22: Engineering Analysis

DOE requests comments on the overall methodology and results of the CFLK 

engineering analysis.
77

CFLK ECS Pre-Analysis Presentation Overview

3 Screening Analysis

5 Product Price Determination

1 Scope of Coverage

6 Energy Use

2 Market & Technology

11 Closing Remarks

4 Engineering Analysis

7 Life-Cycle Cost Analysis

8 Shipments; National Impact Analysis

9 Preliminary MIA

10 NOPR Analyses
78

• The efficiency of the CFLK is based on the efficacy of the lamps with 

which it is packaged. 

• Therefore, DOE first developed the consumer price of the CFLK and 

then determined the part of that price attributable to the lamp 

component. 

Product Price Determination
79

Consumer price of CFLK

• DOE identified electrical/specialty (low prices); home centers 

(medium prices); and lighting showrooms (high prices) as the three 

main CFLK distribution channels.

• DOE collected manufacturer suggested distributor net price (DNP) 

data to calculate an average premium corresponding to the 

consumer price of CFLKs for each distribution channel.

• Based on shipment estimates through each channel, DOE applied 

12% to the electrical/specialty price, 80% to the home center 

channel price, and 8% to the lighting showroom channel price to 

develop a weighted average CFLK consumer price. 

Product Price Determination
80

Consumer price of CFLK attributable to lamp

• Based on manufacturer feedback, DOE determined that for a CFLK 

with a CFL or LED, the lamp component comprises an estimated 

15% of the CFLK consumer price. 

• DOE applied this percentage to the weighted average CFLK 

consumer price to obtain the weighted average consumer price of 

the lamp packaged with the CFLK.

• In cases where DOE was unable to develop a consumer price for a 

CFLK with a representative lamp, DOE applied a ratio based on the 

expected incremental cost of the representative lamp relative to the 

baseline lamp. 

Product Price Determination
81

Issue 24: CFLK and Lamp Price Percentages

DOE requests comment on its determination that a basic CFLK packaged with a 

ceiling fan comprises 20 percent of the consumer price of a ceiling fan and light 

kit. DOE also requests comment on its determination that a CFL or LED packaged 

with a CFLK comprise 15 percent of the consumer price of the CFLK.

Issue 25: Consumer Price Distribution Channel Weighting

DOE requests comment on the values of the percentages of shipments that go 

through each of these distribution channels (electrical specialty, home center, 

and lighting showroom).

Issue 27: Ballast Prices

DOE requests comment on its assumption that the prices of the different 

electronic ballasts presented in the fixture replacement scenario are equal to 

each other for the Externally-Ballasted/Driven CFLKs product class.

Issue 26: Product Price Determination

DOE invites comment on its methodology and results for estimating consumer 

prices for lamps packaged with CFLKs.

Product Price Determination
82

CFLK ECS Pre-Analysis Presentation Overview

3 Screening Analysis

5 Product Price Determination

1 Scope of Coverage

6 Energy Use

2 Market & Technology

11 Closing Remarks

4 Engineering Analysis

7 Life-Cycle Cost Analysis

8 Shipments; National Impact Analysis

9 Preliminary MIA

10 NOPR Analyses
83

Energy Use Characterization

• Purpose: 

• Develop annual energy use estimates for each efficiency level. 

• Methodology:

• Annual energy use (kWh) = annual operating hours x system input power

• Annual Operating Hours:

• Residential Sector: DOE combined data on the rooms where CFLKs are 

located (from LBNL study) with data on operating hours for residential 

ceiling light fixtures by room type (from DOE’s 2012 Residential Lighting 

End-Use Consumption Survey (RLEUCS)). 

• Commercial Sector: DOE used data on operating hours for light source 

technologies typically used in CFLKs for 14 commercial building types 

from the 2010 U.S. Lighting Market Characterization (LMC). 

Sector National Weighted Average Daily 

Operating Hours (hrs/day)

Commercial 10.6

Residential 1.4
84

Energy Use Characterization

• System Input Power: DOE utilized the power consumption data 

presented in the engineering analysis for representative lamps and 

lamp-and-ballast systems to develop system input power.

• All Other CFLKs: 

• DOE developed its estimate of the input power of CFLKs to account for the 

typical lumen output of CFLKs in the market. 

• To estimate the average lumen output of All Other CFLKs, DOE used: (1) Instore shelf survey data of CFs with light kits and CFLKs sold alone (socket 

types, socket numbers, light source technologies, lamp wattages, retail 

prices); and (2) lamp efficacy data from online retailers on the efficacy of 

lamps found in All Other CFLKs.

• CFLKs with Externally Ballasted or Driven Lamps: 

• DOE did not scale their light output.
85

Energy Use Characterization

Lamp Efficacies Base Type Market Share 

(2012)

Weighted Average 

CFLK Total Lumens

Below restructured 

baseline Candelabra 79% 1,663

Above restructured 

baseline

E26 (MSB) 15%

1,960

GU24 5%

Vary All Other 1% (excluded)

Total 100%
86

Energy Use Characterization

Results

• CFLKs with Externally Ballasted or Driven Lamps: 

• All Other CFLKs: 

CSL

Residential Commercial

Energy Use

(kWh/yr)

Savings

(kWh/yr)

Energy Use

(kWh/yr)

Savings

(kWh/yr)

0 8.6 - 66 -

1 7.7 0.9 59 7.2

CSL

Residential Commercial

Energy Use

(kWh/yr)

Savings

(kWh/yr)

Energy Use

(kWh/yr)

Savings

(kWh/yr)

0 19.0 - 145 -

1 16.7 2.4 127 18

2 14.6 4.4 112 34

3 13.6 5.4 104 42

4 12.6 6.5 96 49

5 11.6 7.5 88 57

Energy use and 

savings for each 

CSL are average 

values of the two 

engineering 

scenarios for each 

CSL 

(DOE assumed 

equal market 

shares for the two 

scenarios).
87

Energy Use Characterization

Issue 23: Lumen Output of Pin-Based Fluorescent CFLKs

To improve its energy use estimates, DOE seeks comment on the typical total 

lumen outputs of pin-based fluorescent CFLKs. 
88

CFLK ECS Pre-Analysis Presentation Overview

3 Screening Analysis

5 Product Price Determination

1 Scope of Coverage

6 Energy Use

2 Market & Technology

11 Closing Remarks

4 Engineering Analysis

7 Life-Cycle Cost Analysis

8 Shipments; National Impact Analysis

9 Preliminary MIA

10 NOPR Analyses
89

Life-Cycle Cost (LCC) and Payback Period (PBP)

• Purpose

• Provide an economic evaluation from the end-user’s perspective.

• Life-Cycle Cost (LCC) is the total purchaser cost over the life of a product. 

• Payback Period (PBP) is the time required to recover the increased purchase 

price of more energy-efficient products through reduced operating costs.

• Method

• Develop Monte Carlo sample of 10,000 purchasers

• Determine total installed costs for each CSL.

• Determine operating costs for first year and lifetime of product, including: 

lamp disposal costs, lamp replacements throughout the lifetime of a CFLK, and 

the residual value of lamps at the end of the CFLK lifetime

• Calculate PBP by dividing average increase in installed cost by average 

decrease in first-year operating cost.

• Calculate LCC by adding installed cost and lifetime operating costs.

• Calculate LCC savings by subtracting LCC of each CSL from LCC of the CSL in the 

absence of standards. 
90

Purchaser Samples

• To account for variability in energy consumption, energy price, or 

both, DOE developed a sample of 10,000 CFLK purchasers. 

• Residential sector: 

• Randomly selected households from the subset of houses with CFs in 

RECS 2009.

• DOE applied a selection weight to each household based on number 

of CFs in each household

• Commercial sector: 

• Randomly selected buildings from the 2003 Commercial Buildings 

Energy Consumption Survey (CBECS) — excluding vacant buildings.

• DOE applied a selection weight to each building based on square 

footage, number of lamps per 1000 ft2, and fraction of lamps using 

light source technologies found in CFLKs

LCC and PBP
91

LCC and PBP

Market Efficiency Distribution by CSL

• Expected market share by CSL of CFLKs that consumers would 

purchase in the compliance year in the absence of amended 

standards.

• All Other CFLKs: DOE used LED incursion in combination with a 

consumer-choice model to project the market distribution of 

shipments from 2012 to 2019.* 

• Externally Ballasted/Driven CFLKs: Due to insufficient market data, 

DOE assumed an even split in market share between CSL 0 and CSL 1. 

* LED incursion, and the consumer choice model will be discussed in detail in the 

Shipments Analysis section
92

LCC and PBP

Market Efficiency Distribution in Compliance Year (2019)

• Percentage of sales at each CSL in the absence of amended standards

CSL Scenario*

Market 

Share 

(%)

CSL 0 50

CSL 1 Lamp Replacement

50

CSL 1 Fixture Replacement

Total 100

CSL Scenario*

Market 

Share 

(%)

Below CSL 0 58.2

CSL 0 0.0

CSL 1

Lamp Replacement

11.3

Fixture Replacement

CSL 2

Lamp Replacement

3.8

Fixture Replacement

CSL 3

Lamp Replacement

0.0

Fixture Replacement

CSL 4

Lamp Replacement

0.2

Fixture Replacement

CSL 5

Lamp Replacement

26.5

Fixture Replacement

Total 100

Externally Ballasted/Driven All Other CFLKs

*DOE assumed equal market 

shares for each engineering scenario
93

LCC and PBP

Total Installed Cost

• Total Installed Cost = Product Price + Sales Tax

• Product Price based on output of product price determination

• Includes the end-user lamp and socket prices for each CFLK (number 

of lamps/sockets scaled by the same factor as total lumen output). 

• Also includes price learning for LEDs expected to occur by compliance 

date (more detail provided in the shipments section).

• Sales Tax (including state and local sales tax) is determined by 

geographic location

• Installation cost not included because it was assumed not to vary 

with CSL.
94

LCC and PBP

Operating Hours

• To capture variability in CFLK HOU for individual purchases, DOE 

applied a triangular distribution to the average HOU.

• HOU distribution for each sample had a minimum of 80% and a 

maximum of 120% of the corresponding weighted average HOU value.

Electricity Prices

• Electricity prices and trends are estimated using data from EIA. 

• DOE used EIA’s Annual Energy Outlook (AEO) for projections of future 

average energy prices (reference, high-, and low-growth scenarios). 
95

LCC and PBP

• Used to discount operating costs to year of purchase (i.e. 2019).

• Represents the opportunity cost of funds used to purchase CFLKs. 

• In the residential sector:

• For replacement CFLKs in existing homes:

• Used a distribution of debt and asset classes for purchasing appliances.

• e.g., stocks, mutual funds, savings accounts, bonds, loans

• For CFLKs installed in new construction:

• Used a distribution of mortgage rates.

• In the commercial sector:

• Used a distribution of weighted average cost of capital.

Discount Rates
96

LCC and PBP

Lifetime

• Lifetime is the age at which the CFLK is retired from service.

• DOE used CF lifetime as a proxy for CFLK lifetime.

Maintenance and Repair Costs

• DOE considers lamp replacement costs for failed lamps to be the 

only repair and maintenance cost that varies with product 

efficiency.
97

LCC and PBP

Lamp Replacements

• DOE included in the LCC the cost to replace lamps that fail during 

the lifetime of the CFLK.

• Lamp replacement costs are the purchase costs of replacement lamps 

in the year the failed lamps are replaced, discounted to the analysis 

start year.

• DOE assumes that CFLK lamps fail at the end of their average service 

life (lamp lifetime divided by the lamp’s operating hours per year).

• Replacement lamps:

• Have the same base type as failed lamps

• Provide an equivalent lumen output as failed lamps

• Prices do not include the CFLK manufacturer markup
98

LCC and PBP

Lamp Replacements: Externally Ballasted/Driven CFLKs 

• DOE assumed that failed CFLK lamps are replaced with the same 

lamp that was originally packaged with the light kit.
99

LCC and PBP

Lamp Replacements: All Other CFLKs

• Lamp replacement options for low, medium, and high efficacy lamps. 

• DOE used the engineering data for medium and high efficacy lamp 

replacements and market research data for low efficacy lamp replacements

• Data used were efficacies, watts, prices (price learning applied to LEDs), and 

lifetimes for each lamp replacement.

• LED incursion into the market for replacements lamps was based on DOE SSL 

report. Fraction of low versus medium efficacy lamps was determined by a 

consumer-choice model sensitive to price and operating cost
100

LCC and PBP

Disposal Cost

• Disposal cost represents the cost of disposing (e.g., recycling) lamps 

at the end of the lamp lifetime.

• DOE found that, on average, disposing of a CFL costs about $1 per 

lamp. 

• LED disposal costs assumed to be the same as for CFLs. 

• Residential sector:

– DOE assumed that consumers do not pay recycling costs. 

• Commercial sector:

– DOE assumed that consumers pay recycling costs for 10% of CFL and 

LED lamp failures (average cost of $0.1 applied to all)
101

LCC and PBP

Residual Value

• Lamp residual value is the remaining value of the surviving lamp(s) 

at the end of the CFLK lifetime.

– Residual value is applied as a “credit” to the LCC.

• DOE calculates the residual value for lamps based on the lamp price 

in the year the CFLK is retired, discounted to the analysis start year.
102

LCC and PBP

Externally Ballasted/Driven CFLKs Results

CSL

Average Costs 

(2013$) Simple 

Payback

(years)

Average 

Lifetime

(years)

Average 

Savings

Installed Cost (2013$)

First Year’s 

Operating 

Cost

Lifetime 

Operating 

Cost

LCC

Residential Sector

0 $8.6 $1.1 $10 $19 -- 13.8 $0.0

1 $13 $1.0 $7.7 $20 33.7 13.8 -$0.8

Commercial Sector

0 $8.6 $7.7 $81 $90 -- 13.8 $0.0

1 $13 $6.8 $76 $88 4.9 13.8 $0.7
103

LCC and PBP

Results: All Other CFLKs

CSL

Average Costs (2013$) Simple 

Payback

(years)

Average 

Lifetime

(years)

Average 

Savings 

(2013$)

Installed 

Cost

First Year’s 

Operating 

Cost

Lifetime 

Operating 

Cost

LCC

Residential Sector

0 $10.8 $2.4 $23.8 $34.6 0.5 13.8 $30.7

1 $10.9 $2.1 $20.5 $31.4 0.5 13.8 $32.5

2 $11.7 $1.9 $17.8 $29.5 0.6 13.8 $33.9

3 $24.2 $1.7 $14.2 $38.4 1.8 13.8 $27.3

4 $26.1 $1.6 $11.9 $38.0 2.0 13.8 $27.6

5 $27.5 $1.5 $9.90 $37.4 2.1 13.8 $28.1

Commercial Sector

0 $10.8 $16.9 $122 $133 0.1 13.8 $143

1 $10.9 $14.8 $116 $127 0.1 13.8 $147

2 $11.7 $13.0 $109 $120 0.1 13.8 $151

3 $24.2 $12.1 $113 $138 0.3 13.8 $139

4 $26.1 $11.2 $104 $130 0.3 13.8 $144

5 $27.4 $10.3 $96.0 $123 0.3 13.8 $149

Note: CSL 0 represents the baseline that DOE is considering for the redefined product classes.
104

LCC and PBP

Issue 3: CFLK Lifetime

For this preliminary analysis, DOE assumes that the lifetime of CFLKs is equal 

to the lifetime of the CF. DOE invites comment, input, and data on the lifetime 

of CFLKs.

Issue 18: Inseparable SSLs

DOE requests comment on whether and which components in CFLKs with 

solid-state lighting components that are inseparable from the CFLK are 

designed to be replaceable by the consumer. Specifically, DOE requests 

information on which SSL components may be easily removable and 

replaceable by consumers, and how such replacements would be performed.
105

LCC and PBP

Issue 28: CFLK Installation Costs

DOE welcomes comment on its approach of not including installation costs in 

the LCC analysis. 

Issue 29: CFLK Disposal Costs

DOE requests comment and relevant data on the disposal cost assumptions for 

the different light source technologies used in CFLKs.

Issue 32: Market Distribution of CFLKs by CSL and Product Class

DOE requests comment on the overall methodology and assumptions, as well 

as relevant data, on the market distribution of CFLKs by CSL for each product 

class.
106

CFLK ECS Pre-Analysis Presentation Overview

3 Screening Analysis

5 Product Price Determination

1 Scope of Coverage

6 Energy Use

2 Market & Technology

11 Closing Remarks

4 Engineering Analysis

7 Life-Cycle Cost Analysis

8 Shipments; National Impact Analysis

9 Preliminary MIA

10 NOPR Analyses
107

• Purpose

– Quantify changes over time in product shipments due to potential 

amended energy efficiency standards over analysis period (2019-2048)

– Estimate the disaggregation of shipments into product classes and 

CSLs over time 

• Method

– Total CFLK shipments estimated using a stock-accounting methodology 

calibrated to historical shipments data

– Model accounts for product replacements, new construction, and new 

installations into existing buildings

– Shipments disaggregated by CSL using a modified consumer-choice 

model

Shipments Analysis: Overview
108

Shipments Analysis

Input Data Description/Source

Replacements Historical shipments from Appliance Magazine, NPD, and 

Energy Star. Retirement function from lifetime.

New Construction Annual Energy Outlook 2014, penetration from RECS2009

Existing Buildings Estimate of increasing penetration from RECS

Market Share Model counts from in-store visits and online retailers
109

Shipments Analysis: Schematic

Replacements

New 

Construction

New 

Installations

Retirement Function

Historical Shipments

AEO Projection

RECS 2009

Total Shipments

Shipments

by Product 

Class and 

CSL

ConsumerChoice

Model
110

• DOE assumed 88% of low-volume CF shipments were packaged and 

sold with CFLKs based on analysis of market data

• DOE assumed CFLKs were not purchased with high-volume CFs

• Market share by product class for 2012 based on in-store shelf 

surveys

– Externally-Ballasted/Driven: 0.5%

– All Other CFLKs: 99.5% 

• LED penetration estimated with an incursion curve

Shipments Analysis: Inputs & Assumptions

Issue 36: Sector Breakdown of CFLK Usage

DOE requests comments on its assumed breakdown of CFLK usage as 95% in 

the residential sector and 5% commercial sector. 
111

• Price learning applied to CFLKs that use solid-state lighting.

Shipments Analysis: Price Learning

Issue 30: CFLK Price Learning

DOE requests comment on the assumption that only LEDs will continue to 

undergo significant cost reduction due to price learning.
112

• Market shares for LED CFLKs modelled as a Bass diffusion curve.

Shipments Analysis: LED incursion
113

Shipments Analysis

Issue 33: CFLK Distributions by Technology and Sector

DOE assumed that the distribution of CFLKs by light source technology in the 

commercial sector is the same as the light source technology distribution in the 

residential sector. DOE requests comment and input regarding this assumption.

Issue 34: LED Penetration into CFLK Market

DOE estimated the market penetration of LEDs into the CFLK market as a Bass 

diffusion curve. DOE requests comment on this approach.
114

• CFLK consumer-choice model:

1. Market share first appropriated to LED by incursion curve

2. Remaining market share split between other CSLs assuming 

manufacturers will choose the lowest first cost lamp option for a 

given socket type and lamp technology.

3. Market share for a given CSL is assumed to be divided evenly 

between lamp-replacement and fixture-replacement scenarios.

• In standards case, options that do not meet standard are 

eliminated and probabilities recalculated 

Shipments Analysis: Consumer-Choice Model
115

• DOE uses a relative price elasticity to estimate decrease in 

shipments due to a price increase due to implementation of a 

standard

• Since low-volume CFs and CFLKs are usually packaged together, 

DOE also considered the impact of a CF standard on CFLK shipments 

in its base case CFLK shipments scenario

Shipments Analysis: Impact of Standards
116

Shipments Analysis: Results

Externally Ballasted/Driven

All Other CFLKs
117

• Purpose

‒ Determine the projected national energy savings and consumer 

national net present value of a potential standard.

• Method

‒ Develop annual series of national energy and economic impacts.

‒ Use the shipments model to estimate the total stock of CFLKs in 

service each year. 

‒ Aggregate the costs and energy use per unit in any given year.

‒ Report estimates for economic impact as change in consumer National 

Net Present Value (NPV) (in constant year dollars).

‒ Account for the time-value of money through defined discount rates.

National Impact Analysis: Overview
118

National Impact Analysis: NIA Process

Shipments 

Analysis

Life-Cycle Cost 

Analysis

National Energy 

Savings (Quads)

National Net 

Present Value 

(Billions 2013$)

National 

Energy 

Savings

National 

Economic 

Impacts

• NES and NPV are calculated for products shipped from 2019-2048 

(including energy savings realized in later years by those products).

Inputs

NIA process

Outputs
119

National Impact Analysis Inputs

Input Description

Total Installed Cost Per-unit annual weighted-average values as a function of CSL taken from the LCC 

analysis.

Repair and 

Maintenance Costs

Relamping accounted for over course of CFLK lifetime depending on lifetime of lamp 

packaged with CFLK.

Annual Energy Use Per-unit annual weighted-average values as a function of CSL taken from energy use 

analysis.

Base-Case Efficiencies Shipments-weighted efficiencies determined for the compliance year from the 

consumer-choice model in the base case. 

Standards-Case 

Forecasted Efficiencies

Shipments-weighted efficiencies determined for the compliance year from the 

consumer-choice model for each potential standards case. 

Energy Prices Average national forecasted energy prices from EIA AEO 2014 forecasts (to 2040) and 

extrapolation to 2048.

Full-Fuel Cycle Multiplier for the primary fuel (electricity) used by CFLKs.

Discount Rate 7 percent and 3 percent real from OMB’s Regulatory Analysis Guideline A-4.

Present Year Future expenses are discounted to the year 2014.

National Impact Analysis
120

National Impact Analysis

NES(y) (AEC (y) AEC (y)) RF μ(y)  base  std  

Where:

NES(y) = National energy savings in year y (quads),

AECbase(y) = base case annual national energy consumption, considering the 

full-fuel cycle, for all product classes combined in year y (quads), 

AECstd(y) = standards case annual national energy consumption, considering 

the full-fuel cycle, for all product classes combined in year y

(quads),

RF = rebound rate factor = 1-rebound rate, and

μ(y) = full-fuel cycle multiplier

• National energy primary energy savings is calculated using the 

following equation:
121

• Full-fuel cycle (FFC) measure of energy and greenhouse gas and 

other emissions is accounted for in this standards rulemaking.

‒ DOE has published a Notice of Policy (NOP) stating its intention to 

incorporate FFC metrics into the cost-benefit analysis. 76 FR 51282 

(Aug. 18, 2011). 

• Methodology is based on the calculation of an FFC multiplier, or 

conversion factor, for the electricity used by the product.

National Impact Analysis: Full-Fuel Cycle
122

National Impact Analysis

NPV  PVS PVC

Where:

NPV = National net present value (2013$)

PVS = present value savings in operating cost (including costs for 

energy, repair, and maintenance in 2013$), and

PVC = present value of increase in total installed cost (including costs 

for equipment and installation in 2013$)

• National Net Present Value is calculated using the following equation. 

NPV was calculated using 3% and 7% discount rates:
123

National Impact Analysis: Lamp Replacement

Lamp Replacements

• DOE included in the NIA the cost to replace lamps that fail during 

the lifetime of the CFLK.

– Lamp replacement costs are the purchase costs of replacement lamps 

in the year the failed lamps are replaced.

– DOE assumes that CFLK lamps fail at the end of their average service 

life (lamp lifetime divided by the lamp’s operating hours per year).

– Replacement lamps:

• Have the same base type as failed lamps

• Provide an equivalent lumen output as failed lamps

• Prices do not include the CFLK manufacturer markup

– Consumer-choice model to determine replacement lamp.
124

National Impact Analysis: Residual Value

Residual Value

• Lamp residual value is the remaining value of the surviving lamp(s) 

at the end of the CFLK lifetime.

– Residual value is applied as a “credit” to the NIA.

• DOE calculates the residual value for lamps based on the lamp price 

in the year the CFLK is retired.
125

National Impact Analysis: FFC Net Energy Savings

Product 

Class CSL 1 CSL2 CSL3 CSL4 CSL5

ExternallyBallasted/ 

Driven

0.0005

All Other 0.286 0.330 0.394 0.394 0.394

Energy Savings (quads)
126

Product Class CSL 1 CSL2 CSL3 CSL4 CSL5

ExternallyBallasted/ 

Driven

(millions 2013$)

-0.34

All Other

(billions 2013$) 3.39 3.66 3.89 3.89 3.89

National Impact Analysis: Net Present Value

Product Class CSL 1 CSL2 CSL3 CSL4 CSL5

ExternallyBallasted/ 

Driven 

(millions 2013$)

-0.37

All Other

(billions 2013$) 2.22 2.35 2.25 2.25 2.25

NPV at 7% discount rate

NPV at 3% discount rate
127

CFLK ECS Pre-Analysis Presentation Overview

3 Screening Analysis

5 Product Price Determination

1 Scope of Coverage

6 Energy Use

2 Market & Technology

11 Closing Remarks

4 Engineering Analysis

7 Life-Cycle Cost Analysis

8 Shipments; National Impact Analysis

9 Preliminary MIA

10 NOPR Analyses
128

Preliminary MIA

• Purpose

– The manufacturer impact analysis (MIA) identifies the impacts of 

energy conservation standards on manufacturers.

• Phase 1

– DOE creates an industry profile to characterize the industry and 

identify important issues that require consideration.

• Phase 2

– DOE prepares an industry cash-flow model and an interview 

questionnaire to guide subsequent discussions.

• Phase 3

– DOE interviews manufacturers and assesses the impacts of standards 

both quantitatively (using the Government Regulatory Impact Model) 

and qualitatively (impacts on competition, manufacturing capacity, 

direct employment, and regulatory burden).
129

MIA: Ceiling Fan Light Kit Issues for Comment

Issue 40: Manufacturer Impact Analysis

DOE requests comment on its identification of key issues and requests data and 

information from interested parties that can assist in evaluating the potential 

impact on CFLK manufacturers.

Issue 38: Regulatory Flexibility Act Analysis

DOE invites interested parties to provide information regarding any small 

businesses that manufacture CFLKs and should be consulted before DOE 

publishes a NOPR.

Issue 39: Manufacturer Subgroup Analysis

DOE requests feedback on subgroups to analyze and/or characteristics 

appropriate for a separate subgroup analysis.

Issue 41: Manufacturer Markup

DOE requests comment on the manufacturer markup value of 1.37 used in the 

preliminary analysis.
130

CFLK ECS Pre-Analysis Presentation Overview

3 Screening Analysis

5 Product Price Determination

1 Scope of Coverage

6 Energy Use

2 Market & Technology

11 Closing Remarks

4 Engineering Analysis

7 Life-Cycle Cost Analysis

8 Shipments; National Impact Analysis

9 Preliminary MIA

10 NOPR Analyses
131

Monetization 

of Emission 

Reductions 

Benefits

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Utility 

Impact 

Analysis

Employment 

Impact 

Analysis

Regulatory

Impact 

Analysis

Revise

Preliminary

Analysis

Framework

Document 

Prelim 

Analysis NOPR 

Final

Rule

Analyses for Notice of Proposed Rulemaking (NOPR)

Emissions 

Analysis
132

NOPR Analyses

• LCC Subgroup Analysis

– Effects on various national consumer subgroups

• Manufacturer Impact Analysis

– Continue work begun in the preliminary MIA

• Employment Impact Analysis

– Indirect effects on national employment

• Utility Impact Analysis

– Effects on generation capacity of utilities

• Emissions Analysis

– Effects on airborne pollutant emissions

• Monetization of Emission Reductions Benefits

– Monetary benefits from emissions reduction

• Regulatory Impact Analysis

– Potential for non-regulatory approaches
133

CFLK ECS Pre-Analysis Presentation Overview

3 Screening Analysis

5 Product Price Determination

1 Scope of Coverage

6 Energy Use

2 Market & Technology

11 Closing Remarks

4 Engineering Analysis

7 Life-Cycle Cost Analysis

8 Shipments; National Impact Analysis

9 Preliminary MIA

10 NOPR Analyses
134

Closing Remarks/Questions
135

How to Submit Written Comments for CFLKs

• In all correspondence, please refer to the CFLK rulemaking by:

– Energy Conservation Standards for Ceiling Fan Light Kits;

– Docket Number EERE-2012-BT-STD-0045; and

– Regulatory Identification Number (RIN) 1904-AC87.

• Email: CeilingFanLightKits2012STD0045@ee.doe.gov

Postal: Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, 

Mailstop EE-2J

1000 Independence Avenue, SW

Washington, DC 20585-0121

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Suite 600

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: 202 586-2945

Energy Conservation Standards TSD Comment Period closes: 

December 30, 2014, 11:59 PM EDT