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.gov2 

# 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 Remarks3 

# 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 Lunch4 

# 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 p m 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 Adjourn5 

# 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 discussion7 

# Proposed Ceiling Fan Light Kit (CFLK) Test Procedures8 

# 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 EDT10 

# 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 201912 

# 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 off

mode 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

Proposed Test Procedures to Support Standards Rulemaking 3 Existing Product Classes, Metrics, and Test Procedures 1

Proposed Amendments to Current Test Procedures 2

Clarifications to the Energy Conservation Standards 4

Determination of Represented Values 516 

# 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 LM

66

- 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 None18 

# 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 pr ocedures 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

Proposed Test Procedures to Support Standards Rulemaking 3 Existing Product Classes, Metrics, and Test Procedures 1

Proposed Amendments to Current Test Procedures 2

Clarifications to the Energy Conservation Standards 4

Determination of Represented Values 520 

# 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 metric21 

# 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

Proposed Test Procedures to Support Standards Rulemaking 3 Existing Product Classes, Metrics, and Test Procedures 1

Proposed Amendments to Current Test Procedures 2

Clarifications to the Energy Conservation Standards 4

Determination of Represented Values 523 

## 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. p roposing 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) circuitry25 

# 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

- 0829 

# 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

Proposed Test Procedures to Support Standards Rulemaking 3

Determination of Represented Values 5 Existing Product Classes, Metrics, and Test Procedures 1

Proposed Amendments to Current Test Procedures 2

Clarifications to the Energy Conservation Standards 432 

# 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

Proposed Test Procedures to Support Standards Rulemaking 3

Determination of Represented Values 5 Existing Product Classes, Metrics, and Test Procedures 1

Proposed Amendments to Current Test Procedures 2

Clarifications to Energy Conservation Standards 435 

# 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 4 29.56 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 429.3337 

# 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 EDT38 

## CFLK Energy Conservation Standards Preliminary Analysis39 

# 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 EDT40 

# 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 2016 2017 2018 2020

2015 201942 

# 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

Screening Analysis 3

Product Price Determination 5 Scope of Coverage 1

Energy Use 6 Market & Technology 2

Closing Remarks 11 Engineering Analysis 4

Life

- Cycle Cost Analysis 7
Shipments; National Impact Analysis 8
Preliminary MIA 9

NOPR Analyses 1044 

# 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

Screening Analysis 3

Product Price Determination 5 Scope of Coverage 1

Energy Use 6 Market & Technology 2

Closing Remarks 11 Engineering Analysis 4

Life

- Cycle Cost Analysis 7
Shipments; National Impact Analysis 8
Preliminary MIA 9

NOPR Analyses 1046 

# 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 efficiency47 

# 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%

84.8% GU24 4.6% 12.8% Others (e.g., G9, GU 10, integral solid

state 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 2,140,86749 

# 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 high

volume 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

.

• N ew 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 externally

ballasted or driven lamps

2 All other CFLKs51 

# 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

Screening Analysis 3

Product Price Determination 5 Scope of Coverage 1

Energy Use 6 Market & Technology 2

Closing Remarks 11 Engineering Analysis 4

Life

- Cycle Cost Analysis 7
Shipments; National Impact Analysis 8
Preliminary MIA 9

NOPR Analyses 1054 

### • 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

Screening Analysis 3

Product Price Determination 5 Scope of Coverage 1

Energy Use 6 Market & Technology 2

Closing Remarks 11 Engineering Analysis 4

Life

- Cycle Cost Analysis 7
Shipments; National Impact Analysis 8
Preliminary MIA 9

NOPR Analyses 1056 

#  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 Results57 

# 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 Lamps58 

### • 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 Results59 

### • 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 Results61 

### • 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 Substitutes63 

## 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 wattage65 

# All Other CFLKs: Candidate Standard Levels

All Other CFLKs: Lamp and Fixture Replacement Scenarios66 

# 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

Life

time 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 l m lm hr lm/W lm/W

Baseline Fluor

escent 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 Scenario70 

## 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 wattage72 

## Externally

- Ballasted/Driven Product Class: Candidate Standard Levels

CFLKs with Externally

- Ballasted or Driven Lamps73 

## 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 Results75 

# 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

Screening Analysis 3

Product Price Determination 5 Scope of Coverage 1

Energy Use 6 Market & Technology 2

Closing Remarks 11 Engineering Analysis 4

Life

- Cycle Cost Analysis 7
Shipments; National Impact Analysis 8
Preliminary MIA 9

NOPR Analyses 1078 

### • 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 Determination79 

## 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 Determination80 

## 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 Determination81 

### 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 Determination82 

# CFLK ECS Pre

- Analysis Presentation Overview

Screening Analysis 3

Product Price Determination 5 Scope of Coverage 1

Energy Use 6 Market & Technology 2

Closing Remarks 11 Engineering Analysis 4

Life

- Cycle Cost Analysis 7
Shipments; National Impact Analysis 8
Preliminary MIA 9

NOPR Analyses 1083 

# 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 1.484 

# 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) In

store 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

Screening Analysis 3

Product Price Determination 5 Scope of Coverage 1

Energy Use 6 Market & Technology 2

Closing Remarks 11 Engineering Analysis 4

Life

- Cycle Cost Analysis 7
Shipments; National Impact Analysis 8
Preliminary MIA 9

NOPR Analyses 1089 

# 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.



### • R esidential 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 ft 2, 

### and fraction of lamps using light source technologies found in CFLKs 

# LCC and PBP91 

# 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 section92 

# 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 scenario93 

# 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

• E lectricity 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:

• F or 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 Rates96 

# 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 markup98 

# 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

• D ata 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 cost100 

# 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 (2013$) Installed Cost 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 $0.7103 

# 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

Screening Analysis 3

Product Price Determination 5 Scope of Coverage 1

Energy Use 6 Market & Technology 2

Closing Remarks 11 Engineering Analysis 4

Life

- Cycle Cost Analysis 7
Shipments; National Impact Analysis 8
Preliminary MIA 9

NOPR Analyses 10107 

### • 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: Overview108 

# 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 retailers109 

# Shipments Analysis: Schematic

Replacements

New Construction

New Installations Retirement Function Historical Shipments

AEO Projection

RECS 2009 Total Shipments Shipments by Product Class and CSL Consumer

Choice
Model110 

### • 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 incursion113 

# 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 Model115 

### • 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 t he impact of a CF standard on CFLK shipments in its base case CFLK shipments scenario 

# Shipments Analysis: Impact of Standards116 

# Shipments Analysis: Results

Externally Ballasted/Driven All Other CFLKs117 

### • 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: Overview118 

# 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 Out puts119 

## National Impact Analysis Inputs

Input Description

Total Installed Cost Per

- unit a nnual 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 Analysis120 

# National Impact Analysis

Where: NES(y) = National energy savings in year y (quads),
AEC b ase (y) = base case annual national energy consumption, considering the full

- fuel cycle, for all product classes combined in year y (quads),
AEC std (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 Cycle122 

# National Impact Analysis

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

Externally

Ballasted / 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 Externally

Ballasted / 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 Externally

Ballasted / 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 rate127 

# CFLK ECS Pre

- Analysis Presentation Overview

Screening Analysis 3

Product Price Determination 5 Scope of Coverage 1

Energy Use 6 Market & Technology 2

Closing Remarks 11 Engineering Analysis 4

Life

- Cycle Cost Analysis 7
Shipments; National Impact Analysis 8
Preliminary MIA 9

NOPR Analyses 10128 

# 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

Screening Analysis 3

Product Price Determination 5 Scope of Coverage 1

Energy Use 6 Market & Technology 2

Closing Remarks 11 Engineering Analysis 4

Life

- Cycle Cost Analysis 7
Shipments; National Impact Analysis 8
Preliminary MIA 9

NOPR Analyses 10131 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 Analysis132 

# NOPR Analyses

• LCC Subgroup Analysis

– E ffects 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

– E ffects on generation capacity of utilities



### • Emissions Analysis

– Effects on airborne pollutant emissions



### • Monetization of Emission Reductions Benefits

– M onetary benefits from emissions reduction



### • Regulatory Impact Analysis

– Potential for non

- regulatory approaches133 

# CFLK ECS Pre

- Analysis Presentation Overview

Screening Analysis 3

Product Price Determination 5 Scope of Coverage 1

Energy Use 6 Market & Technology 2

Closing Remarks 11 Engineering Analysis 4

Life

- Cycle Cost Analysis 7
Shipments; National Impact Analysis 8
Preliminary MIA 9

NOPR Analyses 10134 

# Closing Remarks/Questions135 

# 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