Energy Conservation Standards 

Rulemaking Framework Document for 

General Service Fluorescent Lamps and 

Incandescent Reflector Lamps

RIN: 1904-AC43

U.S. Department of Energy 

Office of Energy Efficiency and Renewable Energy 

Building Technologies Program

August 31, 2011 
TABLE OF CONTENTS

1. INTRODUCTION ................................................................................................................... 1

1.1 Authority and Background .................................................................................................. 1

2. OVERVIEW OF RULEMAKING PROCESS ....................................................................... 3

2.1 Test Procedures ................................................................................................................ 3

2.2 Rulemaking Process and Stakeholder Participation ......................................................... 3

2.3 Preliminary Analyses and Notice of Public Meeting ....................................................... 5

2.4 Notice of Proposed Rulemaking (NOPR) ........................................................................ 6

2.5 Final Rule ......................................................................................................................... 7

2.6 Overview of Analyses for Rulemaking ............................................................................ 8

3. SCOPE OF COVERAGE ...................................................................................................... 10

3.1 General Service Fluorescent Lamps ............................................................................... 10

3.2 Incandescent Reflector Lamps ....................................................................................... 11

4. MARKET AND TECHNOLOGY ASSESSMENT .............................................................. 12

4.1 Market Assessment Overview ........................................................................................ 12

4.2 Product Classes .............................................................................................................. 13

4.2.1 General Service Fluorescent Lamps .................................................................... 13

4.2.2 Incandescent Reflector Lamps ............................................................................ 14

4.3 Technology Assessment ................................................................................................. 15

5. SCREENING ANALYSIS .................................................................................................... 18

6. ENGINEERING ANALYSIS ............................................................................................... 19

6.1 Engineering Analysis Overview..................................................................................... 19

6.2 Representative Product Classes ...................................................................................... 20

6.3 Baseline Lamps .............................................................................................................. 20

6.4 Identify Higher-Efficacy Lamp Replacements .............................................................. 23

6.5 Efficacy Levels ............................................................................................................... 24

6.6 Scaling to Product Classes Not Analyzed ...................................................................... 25

6.7 Proprietary Designs ........................................................................................................ 26

6.8 Outside Regulatory Changes Affecting the Engineering Analysis ................................ 27

7. ENERGY USE CHARACTERIZATION ............................................................................. 27

8. PRODUCT PRICE DETERMINATION .............................................................................. 28

9. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS ........................................... 29

9.1 Installation Costs ............................................................................................................ 32

9.2 Energy Prices and Trends ............................................................................................... 32

9.3 Analysis Period .............................................................................................................. 32

9.4 Discount Rates................................................................................................................ 33

10. SHIPMENTS ANALYSIS .................................................................................................... 34

10.1 Base Case Forecast and Accounting Methodology ........................................................ 34

10.2 Impacts of Standards on Shipments ............................................................................... 35

11. NATIONAL IMPACT ANALYSIS ...................................................................................... 35

11.1 Inputs to Forecasts .......................................................................................................... 35

11.2 Calculation of National Energy Savings ........................................................................ 37

11.3 Net Present Value ........................................................................................................... 38

12. LIFE-CYCLE COST SUBGROUP ANALYSIS .................................................................. 38

13. MANUFACTURER IMPACT ANALYSIS ......................................................................... 39
14. UTILITY IMPACT ANALYSIS .......................................................................................... 39

15. EMPLOYMENT IMPACT ANALYSIS .............................................................................. 40

16. ENVIRONMENTAL ASSESSMENT .................................................................................. 40

16.1 Carbon Dioxide .............................................................................................................. 41

16.2 Sulfur Dioxide ................................................................................................................ 41

16.3 Nitrogen Oxides ............................................................................................................. 42

16.4 Mercury .......................................................................................................................... 42

16.5 Particulate Matter ........................................................................................................... 42

17. MONETIZING CARBON DIOXIDE AND OTHER EMISSIONS REDUCTIONS .......... 43

18. REGULATORY IMPACT ANALYSIS ............................................................................... 44

APPENDIX A – LIST OF ITEMS FOR COMMENT ................................................................ 44

APPENDIX B – DEFINITIONS .................................................................................................. 47

APPENDIX C – EPCA DIRECTIVES ON FLUORESCENT AND INCANDESCENT LAMPS

 51

LIST OF TABLES 

Table 2.1 Preliminary Rulemaking Schedule for GSFL and IRL Energy Conservation Standards 5

Table 4.1. 2009 Lamps Rule Product Classes for GSFL .............................................................. 14

Table 4.2 2009 Lamps Rule Product Classes for IRL .................................................................. 15

Table 4.3 GSFL Technology Options ........................................................................................... 16

Table 4.4 IRL Technology Options .............................................................................................. 16

Table 5.1 IRL Technology Options Screened Out of the Analysis .............................................. 18

Table 6.1 GSFL Standards Adopted in 2009 Lamps Rule............................................................ 21

Table 6.2 IRL Standards Adopted in 2009 Lamps Rule ............................................................... 21

Table 6.3 GSFL Baseline Lamp Characteristics Under Consideration ........................................ 22

Table 6.4 IRL Baseline Lamp Characteristics Under Consideration ............................................ 22

Table 6.5 GSFL Efficacy Levels Under Consideration ................................................................ 24

Table 6.6 IRL Efficacy Level Under Consideration ..................................................................... 25

Table 9.1 Summary of Inputs and Key Assumptions Used for the LCC Analyses ...................... 31

Table 11.1 Input to the National Impact Analysis ........................................................................ 36

LIST OF FIGURES

Figure 2.1 Flow Diagram of Analyses for the General Service Fluorescent Lamps and 

Incandescent Reflector Lamps Energy Conservation Standard Rulemaking Process 9
LIST OF ABBREVIATIONS

AEO Annual Energy Outlook (Annual energy forecast published by EIA) 

BPAR bulged parabolic aluminized reflector (reflector lamp shape) 

BR bulged reflector (reflector lamp shape) 

BT Building Technologies Program 

CAIR Clean Air Interstate Rule 

CAMR Clean Air Mercury Rule 

CBECS Commercial Buildings Energy Consumption Survey by EIA

CCT correlated color temperature 

CFR Code of Federal Regulations 

CFL compact fluorescent lamp 

CO2 carbon dioxide 

CSPAR Cross-State Air Pollution Rule (replaces CAIR)

CSL candidate standard level (energy-efficiency level) 

DOE U.S. Department of Energy 

EIA Energy Information Administration (statistical and analytical agency within DOE) 

EISA 2007 Energy Independence and Security Act of 2007 

EL efficacy level 

EPA U.S. Environmental Protection Agency 

EPAct 1992 Energy Policy Act of 1992 

EPAct 2005 Energy Policy Act of 2005 

EPCA Energy Policy and Conservation Act of 1975 

ER elliptical reflector (reflector lamp shape) 

FR Federal Register 

GRIM Government Regulatory Impact Model 

GSFL general service fluorescent lamp

GSIL general service incandescent lamp

Hg mercury 

HIR halogen infrared 

INPV industry net present value 

IRL incandescent reflector lamp 

K degrees Kelvin (an absolute temperature scale equal to –273.15 o 

LCC life-cycle cost 

C) 

LMC U.S. Lighting Market Characterization Volume I 

max-tech maximum technologically-feasible CSL

MECS Manufacturer Energy Consumption Survey (performed for EIA by the Census 

 Bureau) 

MIA Manufacturer Impact Analysis 

NEMS National Energy Modeling System (developed and used by EIA) 

NEMS-BT National Energy Modeling System – Building Technologies 

NES national energy savings 

NIA National Impact Analysis 

NOPR notice of proposed rulemaking 

NOX

NPV net present value 

 nitrogen oxides 

PAR parabolic aluminized reflector (reflector lamp shape) 
PBP payback period 

R reflector (reflector lamp shape) 

RCFL reflector compact fluorescent lamp

RECS Residential Energy Consumption Survey by EIA 

RIA regulatory impact analysis 

SBA U.S. Small Business Administration 

SEC U.S. Securities and Exchange Commission 

SO2

TSD technical support document 

 sulfur dioxide 

U.S.C. United States Code 

V volts 

W watts
Rulemaking Framework Document for General Service Fluorescent Lamps and 

Incandescent Reflector Lamps

1. Introduction

The purpose of this document is to describe the procedural and analytical approaches the 

U.S. Department of Energy (DOE) anticipates using to evaluate energy conservation standards 

for general service fluorescent lamps (GSFLs) and incandescent reflector lamps (IRLs). It is 

intended to inform interested parties and to encourage and facilitate their input during the 

rulemaking. This document is the starting point for developing standards and not a definitive 

statement with respect to any issue to be determined in the rulemaking. 

Sections 1 and 2 discuss the rulemaking process. Sections 3 through 18 outline the 

analyses DOE intends to conduct to fulfill the statutory requirements and guidance for this 

standards rulemaking. Although DOE is combining rulemaking activities for GSFLs and IRLs, it 

is conducting separate analyses for each lamp type to determine whether amended energy 

conservation standards are technologically feasible and economically justified. For each of the 

two lamp types examined in this rulemaking, DOE is performing separate analyses, including an 

engineering analysis, a lifecycle cost (LCC) payback period analysis (PBP), national impact 

analysis (NIA), and manufacturer impact analysis (MIA). 

Information regarding this rulemaking will be maintained on the DOE website at: 

www.eere.energy.gov/buildings/appliance_standards/residential/incandescent_lamps.html. 

While DOE invites stakeholder comment on all aspects of the material presented in this 

document, specific issues on which DOE seeks comment are highlighted by comment boxes. 

These comment boxes include questions on the approaches DOE is proposing for the analyses 

required for the standard rulemaking. These text in the boxes is assembled in Appendix A.

1.1 Authority and Background 

Title III of Energy Policy and Conservation Act of 1975 (EPCA) (42 U.S.C. 6291 et seq.) 

sets forth a variety of provisions designed to improve energy efficiency. Part B of Title III (42 

U.S.C. 6291-6309) established the “Energy Conservation Program for Consumer Products Other 

Than Automobiles,” which includes major household appliances.1

 Subsequent amendments 

expanded Title III of EPCA to include additional consumer products and certain commercial and 

industrial equipment, including certain fluorescent and incandescent lamps—the products that 

are the focus of this document. In particular, amendments to EPCA in the Energy Policy Act of 

1992 (EPAct 1992), P.L. 102-486, established energy conservation standards for certain classes 

of GSFLs and IRLs, and authorized DOE to conduct two rulemaking cycles to determine 

whether these standards should be amended. (42 U.S.C. 6291(1), 6295(i)(1) and (3)-(4)) EPCA 

also authorized DOE to adopt standards for additional GSFLs, if such standards were warranted. 

(42 U.S.C. 6295(i)(5)) 

 

1

Part B was re-designated Part A on codification in the U.S. Code for editorial reasons. 
DOE completed the first cycle of amendments by publishing a final rule in July 2009 

(referred to as the 2009 Lamps Rule in this document). 74 FR 34080 (July 14, 2009). The 2009 

Lamps rule addressed two statutory directives under 42 U.S.C. 6295(i) by amending existing 

energy conservation standards for GSFLs and IRLs (42 U.S.C. 6295(i)(3)) and adopting 

standards for additional GSFLs (42 U.S.C. 6295(i)(5)). This rule also amended the definition of 

“colored fluorescent lamp” and “rated wattage” and adopted test procedures applicable to the 

newly covered GSFL. Information regarding the 2009 Lamps Rule can be found on DOE’s 

website at: 

www.eere.energy.gov/buildings/appliance_standards/residential/incandescent_lamps_standards_

final_rule.html. 

The EPAct 1992 amendments to EPCA added as covered products certain IRLs with 

wattages of 40 watts (W) or higher, and established energy conservation standards for these 

IRLs. In defining the term “incandescent reflector lamp,” EPAct 1992 excluded lamps with 

elliptical reflector (ER) and bulged reflector (BR) bulb shapes, and with diameters of 2.75 inches 

or less. Therefore, such IRLs were neither included as covered products nor subject to EPCA’s 

standards for IRLs. 

Section 322(a)(1) of the Energy Independence and Security Act of 2007 (EISA 2007) 

subsequently amended EPCA to expand the Act’s definition of “incandescent reflector lamp” to 

include lamps with a diameter between 2.25 and 2.75 inches, as well as lamps with ER, BR, 

bulged parabolic aluminized reflector (BPAR), or similar bulb shapes. (42 U.S.C. 

6291(30)(C)(ii) and (F)) Section 322(b) of EISA 2007, in amending EPCA to set forth revised 

standards for IRLs in new section 325(i)(1)(C), exempted from these standards the following 

categories of IRLs: (1) lamps rated 50 watts or less that are ER30, BR30, BR40, or ER40; (2) 

lamps rated 65 watts that are BR30, BR40, or ER40 lamps; and (3) R20 incandescent reflector 

lamps rated 45 watts or less. (42 U.S.C. 6295(i)(C)) Lamps that have a diameter of 2.5 inches or 

less, such as R20 lamps, are commonly referred to as small diameter lamps. (DOE refers to these 

three categories of lamps collectively as “certain reflector (R), ER and BR IRLs.”)

DOE has concluded, for the reasons that follow, that it has the authority under EPCA to 

adopt standards for these R, ER, and BR IRLs, and that these lamps are covered by the directive 

in 42 U.S.C. 6295(i)(3) to amend EPCA’s standards for IRLs. First, by amending the definition 

of “incandescent reflector lamp” (42 U.S.C. 6291(30)(C)(ii) and (F)), EISA 2007 effectively 

brought these R, ER and BR IRLs into the Federal energy conservation standards program as 

covered products, thereby subjecting them to DOE’s regulatory authority. Second, although 42 

U.S.C 6295(i)(1)(C) exempts these R, ER and BR IRLs from the standards specified in 42 

U.S.C. 6295(i)(1)(B), EPCA directs that DOE amend the standards laid out in 42 U.S.C 

6295(i)(1), which includes subparagraph (C). As a result, the statutory text exempted these bulbs 

only from the standards specified in 42 U.S.C. 6295(i)(1), not from future regulation. 

Consequently, DOE is considering energy conservation standards for these R, ER and BR IRLs. 

DOE initiated a new rulemaking for these products by publishing a framework document and 

publishing a notice announcing its availability. 75 FR 23191 (May 3, 2010). DOE held a public 

meeting on May 26, 2010 to seek input from interested parties on its proposals, methodologies, 

assumptions, and data sources. 
This framework document and the associated public meeting represent the first step in the 

process to consider a second review of existing energy conservation standards for GSFLs and 

IRLs, other than the certain R, ER, and BR IRLs discussed in the preceding paragraphs. As part 

of amending existing conservation standards for GSFL, this rulemaking will also consider 

adopting standards for additional types of GSFL. 

2. Overview of Rulemaking Process

2.1 Test Procedures

 DOE’s test procedures for fluorescent and incandescent lamps are set forth at 10 CFR 

part 430, subpart B, appendix R.These test procedures provide instructions for measuring GSFL 

and IRL performance, as well as performance attributes of GSIL, largely by incorporating 

industry standards. These test procedures were updated in a final rule published in July 2009 

(2009 test procedure final rule). 74 FR 31829 (July 6, 2009). The rule updated citations and 

references to the industry standards currently referenced in DOE’s test procedures, and made 

several technical modifications. The amendments also provided test methods for some GSFLs 

based on new product designs. Test procedures for additional GSFLs included in 2009 Lamps 

Rule were adopted as part of the standards rulemaking. DOE is revising GSFL and IRL test 

procedures in a separate rulemaking, in which DOE is considering updates to the latest versions 

of the relevant industry standards currently referenced in DOE’s test procedures. 

DOE is also reevaluating the metric for measuring IRL efficacy. Currently, IRL standards 

are based on lamp efficacy measured as the lumen output of the lamp per watt supplied to the 

lamp. Another potential metric is application efficacy, the average luminous flux2 within a 

specific solid angle of interest per unit power. It is measured in lumens per steradian3 (lm/sr) or 

candelas per watt (cd/W). Application efficacy is based on the principle that the effectiveness of 

the lamp should be quantified in terms of the lamp delivering light to locations where it is 

needed. DOE will consider this metric as it reassesses the most appropriate metric for IRLs in 

these revised standards and the concurrent test procedure rulemaking. 

Item 1 DOE welcomes comment on establishing a new metric for IRL standards. 

2.2 Rulemaking Process and Stakeholder Participation

When DOE evaluates any new or amended energy conservation standard for “covered 

products,” EPCA, as amended, specifies that any standard DOE prescribes for consumer 

products must be designed to achieve the maximum improvement in energy efficiency that is 

technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) Moreover, the 

Secretary may not establish an amended standard if such standard would not result in a 

 

2 Luminous flux is the time rate of flow of radiant energy, evaluated in terms of a standardized visual response. 

3 Steradian is a solid angle subtended at the center of the sphere by an area on the surface of the sphere equal to the 

square of the sphere radius. The amount of light given into one steradian by a point of source with a luminous 

intensity of one candela placed at the center of the sphere is one lumen.
significant conservation of energy. (42 U.S.C. 6295(o)(3)(B)) In determining whether a 

standard is economically justified, DOE must consider, to the greatest extent practicable, the 

following seven factors: 

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

the products subject to such standard; 

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

product in the type (or class) compared to any increase in the price of, or in the initial 

charges for, or maintenance expenses of, the covered products which are likely to result 

from the imposition of the standard; 

(3) The total projected amount of energy, or as applicable, water, savings likely to result 

directly from the imposition of the standard; 

(4) Any lessening of the utility or the performance of the covered products likely to result 

from the imposition of the standard; 

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

General, that is likely to result from the imposition of the standard;

(6) The need for national energy and water conservation; and 

(7) Other factors the Secretary considers relevant. 

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

The process of developing efficiency standards involves analysis, public notice, and 

consultation with interested parties. Such interested parties generally include manufacturers, 

consumers, energy conservation and environmental advocates, State and Federal agencies, and 

any other groups or individuals with an interest in energy conservation standards and test 

procedures. DOE considers participation of interested parties to be a very important part of the 

rulemaking process. Accordingly, DOE actively encourages the participation and interaction of 

all interested parties during the comment period provided at each stage of the rulemaking. The 

broad array of interested parties who routinely provide comments promotes a balanced 

discussion of critical information required to conduct the standards rulemaking, beginning with 

public comment on the Framework Document. 

In conducting the test procedure rulemakings and the energy (and water) conservation 

standards rulemakings, DOE involves interested parties through a variety of means. As discussed 

in further detail below, the standards rulemaking process typically involves three public notices 

in addition to the notice of availability of the framework document. All of these notices are 

published in the Federal Register. Publication of the framework document, preliminary analysis, 

and notice of proposed rulemaking (NOPR) are typically accompanied by public meetings to 

solicit comment from interested parties to enhance the rulemaking process. 

• Preliminary Analysis and Notice of Public Meeting (section 2.3). The preliminary 

analysis is designed to publicly vet the models and tools that DOE will use in the 

rulemaking, and to facilitate public participation before the proposed rule stage. 

Candidate standard levels (CSLs), which are levels that span the range of efficiencies 

from baseline products to the most efficient technology, are the basis for 

demonstrating the functionality of the models and tools. 
• Notice of Proposed Rulemaking (section 2.4). The NOPR presents a discussion of 

comments received in response to the preliminary analysis; DOE’s analysis of the 

impacts of potential standards on consumers, manufacturers, and the nation; DOE’s 

weighing of these impacts; and the proposed standard levels for public comment. 

• Final Rule (section 2.5). The final rule presents a discussion of comments received in 

response to the NOPR; the revised analysis of the impacts of standards; DOE’s 

weighting of the impacts; and the standard levels DOE is adopting. The final rule also 

sets out the compliance date of the standards based on statuatory requrements. 

DOE has prepared the preliminary schedule below for the GSFL and IRL rulemaking. 

Table 2.1 Preliminary Rulemaking Schedule for GSFL and IRL Energy Conservation 

Standards

Deliverable Publication Date 

Framework Document August 2011 

Preliminary Analysis September 2012

NOPR August 2013

Final Rule April 2014

Any final energy conservation standards for GSFLs and IRLs would require compliance three 

years after the final rule is published, which is projected to be April 2017 (see 42 U.S.C. 

6295(i)(4)).

2.3 Preliminary Analyses and Notice of Public Meeting

During the preliminary analysis phase of the rulemaking, DOE presents the models and 

tools it will use to conduct the four principal analyses that comprise the preliminary analysis–the 

engineering analysis, life-cycle cost analysis, national impact analysis, and preliminary 

manufacturer impact analysis. Before conducting the engineering analysis, DOE typically 

identifies technology options to increase efficiency and then preliminarily determines whether to 

retain that option for detailed analysis or to eliminate it from further consideration. The process 

for consideration of technology options includes a market and technology assessment (section 4) 

and a screening analysis (section 5). DOE applies four screening criteria in the screening analysis 

to determine which technology options to eliminate from further consideration: (1) technological 

feasibility; (2) practicability to manufacture, install, and service; (3) adverse impacts on product 

utility or availability; and (4) adverse impacts on health or safety. Technology options that 

remain after screening analysis are referred to as design options in the engineering analysis. DOE 

consults with interested parties and independent technical experts to identify the design options, 

efficiency levels, or key issues that DOE will consider in the rulemaking. 

Next, DOE considers design options or efficiency levels for each product class. DOE 

collects manufacturer cost data, historical shipment data, shipment-weighted average efficiency 
data, and preliminary manufacturer impact data (e.g., capital conversion expenditures, marketing 

costs, and research and development costs) based on these design options or efficiency levels. 

DOE then conducts the principal analyses, including: (1) the engineering analysis (section 6); (2) 

the LCC and PBP analyses (section 6); (3) the NIA, which considers national energy savings 

(NES) and consumer net present value (NPV) (section 11); and (4) a preliminary MIA (section 

13). DOE will present the results of these analyses in the preliminary analysis technical support 

document (TSD). 

Based on the results of the preliminary analysis described above, DOE selects CSLs from 

among the energy efficiency levels considered in the preliminary analysis. Publication of DOE 

analysis of various CSLs in the preliminary analysis will enable interested parties to review the 

spreadsheet models (also posted on DOE’s website) that underpin the analyses and provide DOE 

with comments so that the models can be refined. In the next stage of rulemaking, the NOPR, 

DOE generally considers energy efficiency levels or design options that span technologically 

achievable efficiencies. The range of levels DOE typically analyzes includes: 

• The baseline efficiency level (the minimum level) set by the product with the lowest 

energy efficiency level currently sold on the market for a given category; For product 

categories where minimum federal energy conservation standards already exist, this is 

typically defined by the existing energy conservation standard; 

• The CSL with the lowest LCC or greatest LCC savings; 

• The highest energy efficiency CSL or lowest energy consumption CSL that is 

technologically feasible (maximum technologically-feasible (max-tech)); and

• CSLs that incorporate technologies of significance or fill in large gaps between other 

efficiency levels considered. 

At the preliminary analysis stage, DOE uses analytical models and tools to assess the 

different product classes at each CSL analyzed. Many of these analytical models and tools are in 

the form of spreadsheets, which are also used to conduct the LCC and PBP analyses and to 

determine the national energy savings and NPV of CSLs. 

DOE will make the spreadsheet tools used in the preliminary analysis and results of the 

preliminary analysis available on its website for review. DOE will also make a TSD available 

containing the details of all the analyses performed to date when it publishes the preliminary 

analysis. After publication of the preliminary analysis, DOE will provide a public comment 

period and hold a public meeting. In addition, as stated above, DOE encourages interested parties 

to make joint recommendations for CSLs and to submit them to DOE for consideration. 

2.4 Notice of Proposed Rulemaking (NOPR)

For the proposed Rule, DOE reviews and considers all the comments received after the 

publication of the preliminary analysis. This process may result in revisions or refinements to the 

preliminary analyses, including the engineering analysis and life-cycle cost analysis. DOE also 
will conduct additional economic and environmental impact analyses at this stage of the 

rulemaking. These analyses generally include a consumer LCC subgroup analysis (see section 

12), a complete manufacturer impact analysis (see section 13), a utility impact analysis (see 

section 14), an employment impact analysis (see section 15), an environmental assessment (see 

section 16, and a regulatory impact analysis (see section 18). 

DOE describes the methodology used and posts the results of all the analyses on its 

website for review and comments. Based on comments by stakeholders, further revisions to the 

analysis may be undertaken. This analytical process ends with the proposal of standard levels in 

the NOPR. DOE proposes standard levels based on the trial standard levels (TSLs) analyzed 

during the NOPR phase of the rulemaking. The NOPR, published in the Federal Register, 

documents the evaluation and selection of the proposed standard level(s), along with a discussion 

of other TSLs considered but not selected (and the reasons for not selecting them). 

The selection process for proposed efficiency standards generally runs as follows. For 

each product class, DOE will identify the max tech efficiency level. If DOE proposes a level 

lower than the max tech level, it will sequentially explain the reasons for eliminating higher 

levels beginning with the highest level considered. DOE will present the analytical results in the 

NOPR and the analysis details in an accompanying TSD. 

DOE considers many factors in selecting proposed standards, as described above in 

section 2.2. These factors and criteria are prescribed by EPCA and take into consideration the 

impacts of energy conservation standards. In addition, as stated previously, DOE encourages 

stakeholders to make joint recommendations for standard levels. DOE carefully considers such 

recommendations in its decision process. 

When DOE publishes the NOPR, it will provide the Department of Justice (DOJ) with a 

copy of the NOPR and TSD to solicit DOJ review of the impact of the proposed standard levels 

on competition in the lighting industry. Publication of the NOPR is followed by a 60-day public 

comment period. 

2.5 Final Rule

After the publication of the NOPR, DOE will consider public comments it receives on the 

proposal and supporting analyses. On the basis of the public comments, DOE will review the 

supporting analyses and proposed standards and consider modifications where necessary. Before 

the final rule is issued, DOE also will consider DOJ comments on the NOPR relating to the 

impacts of the proposed standard levels on competition to determine whether changes to these 

standard levels are needed.

The standards rulemaking will conclude with the publication of the final rule. DOE will 

select the final standard level based on the complete record of the standards rulemaking. The 

final rule will promulgate the final standard level and the compliance date and explain the basis 

for its selection. The final rule will be accompanied by a final TSD.
2.6 Overview of Analyses for Rulemaking 

The purpose of the analyses conducted in support of the standards rulemaking is to ensure 

that DOE selects energy conservation standards that achieve the maximum improvement in 

energy efficiency that is technologically feasible and economically justified, and will result in 

significant energy savings. Economic justification includes the consideration of economic 

impacts on domestic manufacturers and consumers, national benefits including environmental 

impacts, issues of consumer utility, and impacts from any lessening of competition. DOE 

expects the selection of such standards to achieve the maximum energy savings that are 

economically justified without imposing excessive financial burden on any particular party. 

Figure 2.1 summarizes the analytical components of the standards-setting process. The 

“analyses” are presented in the center column. Each analysis has a set of “key inputs,” which are 

data and information required for the analysis. “Approaches” are the methods that DOE will use 

to obtain key inputs, which may vary depending on the information in question. For example, 

some key inputs exist in public databases; DOE will collect other information from stakeholders 

or experts with special knowledge, and DOE will gather other information in support of this 

rulemaking. The results of each analysis are “key outputs,” which feed directly into the 

rulemaking. Arrows indicate the flow of information between the various analyses. DOE 

ensures a consistent approach to its analyses throughout the rulemaking by considering each 

analysis as a part of the overall standards-setting framework. 
Figure 2.1 Flow Diagram of Analyses for the General Service Fluorescent Lamps and 

Incandescent Reflector Lamps Energy Conservation Standard Rulemaking Process
3. Scope of Coverage 

3.1 General Service Fluorescent Lamps

As previously mentioned, DOE is conducting its second review to determine whether 

existing standards for GSFLs should be amended in this rulemaking. In implementing 42 U.S.C. 

6295(i)(5), the 2009 Lamps Rule expanded the definition of “fluorescent lamp” to include 

additional lamp wattages and two additional lamp types.4

 The definitions of “fluorescent lamp” 

and “general service fluorescent lamp” are provided below and also in Appendix B: 

Fluorescent lamp means a low pressure mercury electric-discharge source in which a 

fluorescing coating transforms some of the ultraviolet energy generated by the mercury 

discharge into light, including only the following: 

(1) Any straight-shaped lamp (commonly referred to as 4-foot medium bipin lamps) with 

medium bipin bases of nominal overall length of 48 inches and rated wattage of 25 or 

more;

(2) Any U-shaped lamp (commonly referred to as 2-foot U-shaped lamps) with medium 

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

or more;

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

recessed double contact bases of nominal overall length of 96 inches; 

(4) Any instant start lamp (commonly referred to as 8-foot slimline lamps) with single pin 

bases of nominal overall length of 96 inches and rated wattage of 52 or more;

(5) Any straight-shaped lamp (commonly referred to as 4-foot miniature bipin standard 

output lamps) with miniature bipin bases of nominal overall length between 45 and 48 

inches and rated wattage of 26 or more; and 

(6) Any straight-shaped lamp (commonly referred to 4-foot miniature bipin high output 

lamps) with miniature bipin bases of nominal overall length between 45 and 48 inches 

and rated wattage of 49 or more.

General service fluorescent lamp means any fluorescent lamp which can be used to 

satisfy the majority of fluorescent lighting applications, but does not include any lamp 

designed and marketed for the following nongeneral application: 

(1) Fluorescent lamps designed to promote plant growth; 

(2) Fluorescent lamps specifically designed for cold temperature applications;

(3) Colored fluorescent lamps; 

(4) Impact-resistant fluorescent lamps;

(5) Reflectorized or aperture lamps;

(6) Fluorescent lamps designed for use in reprographic equipment; 

(7) Lamps primarily designed to produce radiation in the ultra-violet region of the 

spectrum; and

(8) Lamps with a Color Rendering Index of 87 or greater. 

10 CFR 430.2 

 

4 As explained previously, DOE concluded that the directive of 42 U.S.C. 6295(i)(5) to consider additional GSFL 

was not restricted to the four specific lamp types in the definition of “fluorescent lamp” in the U.S. Code.
In this second review, DOE will consider adoption of standards for additional types of 

GSFL with shapes and lengths other than the ones already covered by standards. Some additional 

GSFL types DOE is considering include: 

• Pin-based compact fluorescent lamps (CFLs)

• Non-linear fluorescent lamps (e.g. circline) 

• Fluorescent lamps with alternate lengths (e.g. 2-,3-,5-foot) 

If DOE determines that standards for additional types of GSFL would require further 

amendment to the definition of “fluorescent lamp” which lists covered lamp types, DOE will 

consider such amendments in this rulemaking. In determining whether to make standards 

applicable to additional GSFL types, DOE will evaluate lamps that meet the statutory definition 

of “general service fluorescent lamp.” 

3.2 Incandescent Reflector Lamps

DOE is also conducting this second review to determine whether existing standards for 

IRLs should be amended in this rulemaking. The definition of “incandescent reflector lamp” is 

provided below and also in Appendix B. 

Incandescent reflector lamp (commonly referred to as a reflector lamp) means any lamp 

in which light is produced by a filament heated to incandescence by an electric current, 

which: is not colored or designed for rough or vibration service applications that contains 

an inner reflective coating on the outer bulb to direct the light; has an R, PAR, ER, BR, 

BPAR, or similar bulb shapes with an E26 medium screw base; has a rated voltage or 

voltage range that lies at least partially in the range of 115 and 130 volts; has a diameter 

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

10 CFR 430.2 

DOE is considering the certain R, ER and BR IRL discussed in section 1.1 in a separate 

rulemaking. Therefore, DOE is not considering amending standards for these products in this 

rulemaking. 

With respect to wattage, EISA 2007 amends EPCA to define IRL as a lamp that “has a 

rated wattage that is 40 watts or higher.” (42 U.S.C. 6291(30)(C), (C)(ii), and (F)) Current IRL 

standards are set for the 40-205W range. Similar to the 2009 Lamps Rule, DOE is not 

considering IRL with rated wattages greater than 205W because these comprise a very small 

portion of the market and therefore do not represent significant potential energy savings. 74 FR 

34080, 34092 (July 14, 2009). 

Item 2 DOE welcomes comment on additional GSFLs and IRLs that should be included for this 

rulemaking. For suggested additional lamp types, DOE requests market and shipment 

information as well as potential for efficacy improvements and energy savings.
4. Market and Technology Assessment

The market and technology assessment will provide information about the manufacturers 

of general service fluorescent lamps and incandescent reflector lamps, and specifics about the 

performance attributes of these lamps. This assessment is used to develop product classes and 

identify technology options to improve lamp efficacy for each of the lamp types. EPCA defines 

“lamp efficacy” as the lumen output of a lamp divided by its wattage, expressed in lumens per 

watt (LPW).

4.1 Market Assessment Overview

As part of the market assessment, DOE will qualitatively and quantitatively characterize 

the structure of the general service fluorescent and incandescent reflector lamp market. DOE will 

identify and characterize the manufacturers, estimate market shares and trends, address 

regulatory and non-regulatory initiatives intended to improve the energy efficiency or reduce the 

energy consumption of covered lamps, and explore the potential for technological improvements 

in the design and manufacturing of such products. 

This market assessment will serve as a resource to guide the analyses that follow. For 

example, DOE may use historical shipments and prices as an indicator of future shipments and 

prices. Similarly, DOE plans to use market structure data for the manufacturer impact analysis, 

data which will be particularly useful for assessing competitive impacts. This phase also allows 

DOE to start updating design options by reviewing product literature and industry publications. 

DOE has already gathered a large amount of information in support of the 2009 Lamps 

Rule. DOE recognizes, however, that additional data may have become available since the 

publication of that rule. In addition, DOE recognizes that there may be limited public 

information regarding recent trends in national shipments, manufacturing costs, channels of 

distribution, and manufacturers’ market shares of GSFLs and IRLs. This type of data is an 

important input for analyses that determine if energy conservation standards are economically 

justified and will result in significant energy savings. Therefore, DOE encourages stakeholders to 

submit data that pertains to these issues and would improve DOE’s understanding of recent 

trends in the GSFL and IRL market. 

 Stakeholders may submit confidential data to DOE, indicating in writing which data 

should remain confidential. To prevent public disclosure of the data due to actions taken by a 

third party, stakeholders providing confidential information to DOE must submit that data 

according to 10 CFR 1004.11. Under 10 CFR 1004.11, any person submitting information that 

he or she believes to be confidential and exempt by law from public disclosure should submit 

two copies. One copy of the document shall include all the information believed to be 

confidential, and the other copy of the document shall have the information believed to be 

confidential deleted. DOE will make its own determination about the confidential status of the 

information and treat it according to its determination. DOE prepares aggregated results from the 

data submitted for use in DOE’s analyses. These aggregated results do not divulge the sensitive 

nature of the individual raw data, but enable other stakeholders to review and comment on the 

aggregated dataset. 
DOE is updating its database of commonly-available products based on recent catalogs 

from manufacturers of GSFL and IRL, including both small and large market participants. DOE 

will use the resulting knowledge about product availability to evaluate how the market may 

respond to various standard levels (e.g., consumers substituting lamps that are not subject to 

regulation), and to gain additional insight on the performance attributes of various commerciallyavailable GSFL and IRL technologies.

Item 3 DOE welcomes information on shipments, product-feature and efficiency trends, 

distribution channels and estimates of market shares for the lamps considered in this 

rulemaking. For the data to be used to conduct energy savings calculations, please provide 

appropriate groupings (e.g., by product class and wattage). 

4.2 Product Classes

DOE divides covered products into classes by: (a) the type of energy used; (b) the 

capacity of the product; or (c) any other performance-related feature that justifies different 

standard levels, such as features affecting consumer utility. (42 U.S.C. 6295(q)) For this 

rulemaking, the DOE intends to analyze product classes for GSFL and IRL separately. 

4.2.1 General Service Fluorescent Lamps

As in the 2009 Lamps Rule, DOE plans to establish product classes for GSFLs based on 

the following three factors: (1) physical constraints of lamps (i.e., lamp shape and length); (2) 

lumen package (i.e., standard versus high output); and (3) correlated color temperature (CCT). 

The shape and geometry of a lamp affect its efficacy. At the same time, lamp shape and 

length provide unique utility and cannot always be used as replacements in a given fixture. For 

example, a 2-foot U-shaped lamp, while having the same overall tube length, is less efficacious 

than a 4-foot linear lamp due in part to the fact that the electrical arc within the tube has to bend 

to conform to the shape of the lamp. However, a linear-shaped lamp cannot substitute for a Ushaped lamp due to the size of the fixture. Additionally, while 8-foot lamps generally have 

higher efficacy values than 4-foot lamps, they usually require different fixtures. Thus, DOE is 

considering establishing a separate product class based on the physical constraints of lamps.

DOE is considering separate product classes based on lumen package. Lumen package 

refers to the quantity of light that a lamp-and-ballast system provides to a consumer. DOE notes 

that efficacy decreases as a fluorescent lamp is driven harder to increase its light output. For 

example, the efficacy of high output 8-foot lamps is approximately 7 to 10 percent lower than 

that of slimline 8-foot lamps. DOE believes that lumen package provides utility because 

consumers tend to prefer systems with different lumen packages for different applications. For 

example, high-lumen-output systems appear more likely to be installed in high-ceiling or outdoor 

applications, where large quantities of light are needed. Alternatively, standard-lumen-output 

systems are more likely to be installed in lower-ceiling applications such as offices or hospitals, 

where the distance between the light source and the illuminated surfaces is not as large. 
Thirdly, DOE is considering separate product classes for lamps with a CCT less than or 

equal to 4500K and greater than 4500K. CCT is a measure of the perceived color of the white 

light emitted from a lamp. As the spectral emission from the lamp is modified to change the 

CCT, the lamp efficacy can vary. For example, due to their greater blue light content, higher 

CCT fluorescent lamps tend to have lower efficacies. DOE recognizes that the CCT of 

fluorescent lamps provides a distinct utility (e.g., the light emitted by the fluorescent lamp has 

different qualities). Given the impact of CCT on efficacy and utility, DOE established separate 

product classes based on CCT. 

Using these three criteria, similar to the 2009 Lamps Rule, DOE is considering 

establishing 12 product classes, which are listed in Table 4.1 below. 74 FR 34080, 34099 (July 

14, 2009). DOE may consider additional product classes resulting from consideration of new 

GSFL lamp types. In the 2009 Lamps Rule, DOE had created a separate product class for T5 

lamps because physical constraints prevent them from serving as direct replacements for T8 and 

T12 lamps and the lamps are generally considered too bright for use in direct lighting. DOE 

requests comment on maintaining separate product classes for T5 lamps in this rulemaking. In 

general, DOE requests comment on the approach for establishing product classes and the product 

classes under consideration for GSFLs. 

Table 4.1. 2009 Lamps Rule Product Classes for GSFL 

Lamp Type CCT

4-foot medium bipin ≤4500 K 

>4500 K 

2-foot U-shaped ≤4500 K

>4500 K

8-foot single pin slimline ≤4500 K

>4500 K

8-foot recessed double contract high output ≤4500 K

>4500 K

4-foot T5, miniature bipin standard output ≤4500 K

>4500 K

4-foot T5, miniature bipin high output ≤4500 K

>4500 K

Item 4 DOE welcomes comment on the product classes it is considering for general service 

fluorescent lamps. In particular, DOE welcomes comment on maintaining separate product 

classes for T5 lamps. 

4.2.2 Incandescent Reflector Lamps

As in the 2009 Lamps Rule, DOE plans to establish product classes based on: (1) lamp 

spectrum; (2) lamp diameter; and (3) rated voltage. 

Modified-spectrum lamps can provide features such as ensuring better color 

discrimination and often appearing more similar to natural daylight. DOE understands that the 
technologies that modify the spectral emission from these lamps also decrease their efficacy. 

This is because a portion of the light emission is absorbed by the coating. Modified-spectrum 

lamps provide unique utility to consumers, in that they offer a different spectrum of light from 

the typical incandescent lamp, much like two fluorescent lamps with different CCT values. Thus, 

DOE is considering separate product classes for modified-spectrum and standard-spectrum 

lamps. 

 

DOE found that a smaller diameter lamp has an inherently lower optical efficiency than a 

larger diameter lamp given a similar filament size. Further, it is not technically feasible to 

incorporate some technologies proven to increase efficacy, such as double-ended burners, in 

small-diameter lamps due to space constraints. In addition, DOE believes small diameter lamps 

provide a distinct utility (such as the ability to be installed in smaller fixtures). Therefore, DOE is 

considering separate product classes for IRL with diameters less than or equal to 2.5 inches and 

greater than 2.5 inches. 

DOE is aware that a large number of consumers actually operate 130 V-rated lamps at 

120 V, which increases lifetime but decreases efficacy. If lamps with different rated voltages 

were combined in the same product class, it would effectively lead to a lower efficacy 

requirement for 130 V lamps that are run at 120 V, compared to 120 V lamps run at 120 V. 

These 130 V lamps would not require the same level of technology as 120 V-rated lamps to meet 

the same standard, and would therefore be cheaper to produce. Without a separate standard, 

consumers may purchase 130V lamps because they are less expensive. When consumers operate 

these lamps at 120V to obtain sufficient light output, they may migrate to higher wattages and 

use more energy than standards-compliant 120 V lamps. For these reasons, DOE is considering 

separate product classes based on input voltage. 

Similar to the 2009 Lamps Rule, DOE is considering adopting the product class structure 

outlined in Table 4.2 for this rule. 74 FR 34080, 34082 (July 14, 2009). 

Table 4.2 2009 Lamps Rule Product Classes for IRL 

Lamp Type Diameter (in inches) Voltage

Standard Spectrum > 2.5 ≥125 V

<125 V

≤ 2.5 ≥125 V

<125 V

Modified Spectrum > 2.5 ≥125 V

<125 V

≤ 2.5 ≥125 V

<125 V

Item 5 DOE welcomes comment on the product classes it is considering for incandescent 

reflector lamps. 

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

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

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

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

options, which are then considered against four screening criteria discussed in the following 

section. Those technology options that pass the four screening criteria are called design options 

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

analysis and will assist DOE in determining the max-tech design. 

In the 2009 Lamps Rule, DOE reviewed manufacturer catalogs, recent trade publications, 

technical journals, and patent filings; and consulted with technical experts to determine 

technology options. Table 4.3 and Table 4.4 respectively list the technology options DOE 

identified to improve the efficacy of GSFL and IRL in the 2009 Lamps Rule. DOE is considering 

using the same technology options in this rule. See chapter 3 of the technical support document 

for the 2009 Lamps Rule for a more complete discussion of the technology options. 

Table 4.3 GSFL Technology Options 

Name of Technology 

Option 

Description 2009 Lamps Rule TSD 

Reference 

Highly Emissive Electrode 

Coatings

Improved electrode coatings will allow electrons 

to be more easily removed from electrodes, 

reducing lamp power and increase overall efficacy. 

Chapter 3, Section 3.3.1.1 

Higher Efficiency Lamp 

Fill Gas Composition 

Fill gas compositions to improve cathode 

thermionic emission or increase mobility of ions 

and electrons in the lamp plasma.

Chapter 3, Section 3.3.1.2 

Higher Efficiency 

Phosphors 

Techniques to increase the conversion of 

ultraviolet light into visible light.

Chapter 3, Section 3.3.1.3 

Glass Coatings Coatings on inside of bulb enabling the phosphors 

to absorb more UV energy, so that they emit more 

visible light.

Chapter 3, Section 3.3.1.4 

Higher Efficiency Lamp 

Diameter 

Vary the lamp diameter to improve its efficacy. Chapter 3, Section 3.3.1.5 

Multi-Photon Phosphors Emitting more than one visible photon for each 

incident UV photon.

Chapter 3, Section 3.3.1.6 

Table 4.4 IRL Technology Options 

Name of Technology 

Option 

Description 2009 Lamps Rule TSD 

Reference

Higher-Temperature 

Operation 

Operating the filament at higher temperatures, the 

spectral output shifts to lower wavelengths, 

increasing its overlap with the eye sensitivity 

curve. 

Chapter 3, Section 3.3.2.1 

Microcavity Filaments Texturing, surface perforations, microcavity holes 

with material fillings. 

Chapter 3, Section 3.3.2.2 

Novel Filament Materials 

More-efficacious filament alloys that have a high 

melting point, low vapor pressure, high strength, 

high ductility, or good radiating characteristics. 

Chapter 3, Section 3.3.2.3 

Thinner Filaments Thinner filaments to increase operating 

temperature. This measure may shorten the 

operating life of the lamp. 

Chapter 3, Section 3.3.2.4 

Efficient Filament Coiling Coiling the filament to increase surface area, thus 

increasing light output. Chapter 3, Section 3.3.2.5 
Crystallite Filament 

Coatings 

Layers of micron or submicron crystallites 

deposited on the filament surface that increases 

emissivity of the filament. 

Chapter 3, Section 3.3.2.6 

Efficient Filament 

Orientation 

Positioning (horizontal or vertical) the 

incandescent filament to increase light emission 

from the lamp. Vertical orientation, used by 

majority of lamps, allows for greater light 

emission. 

Chapter 3, Section 3.3.2.7 

Higher-Efficiency Inert 

Fill Gas 

Filling lamps with alternative gases, such as 

Krypton, to reduce heat conduction.

Chapter 3, Section 3.3.2.8 

Luminescent Gas Fill gases that react with wavelengths not detected 

by the human eye, converting portions of the 

invisible incandescent spectrum into visible light.

Chapter 3, Section 3.3.2.9 

Higher-Pressure 

Tungsten-Halogen Lamps Increased halogen bulb capsule pressurization. Chapter 3, Section 3.3.2.11 

Non-Tungsten-Halogen

Regenerative Cycles Novel filament materials that regenerate. Chapter 3, Section 3.3.2.12 

Infrared Glass Coatings 

When used with a halogen 

capsule, this is referred to as 

a halogen infrared reflector 

(HIR) lamp.

Infrared coatings on the inside of the bulb to 

reflect some of the radiant energy back onto the 

filament. 

Chapter 3, Section 3.3.2.13 

Infrared Phosphor Glass 

Coating

Infrared phosphor coating on the surface of the 

bulb that harvest emitted infrared energy and 

convert it to visible light.

Chapter 3, Section 3.3.2.14

Integrally-Ballasted LowVoltage Lamps 

An integral ballast converts the operating voltage 

of the lamp from line voltage to a lower voltage. 

Chapter 3, Section 3.3.2.15 

Higher-Efficiency 

Reflector Coatings 

Alternative reflector coatings such as gold, with 

higher reflectivity increase the amount of directed 

light.

Chapter 3, Section 3.3.2.16 

Trihedral Corner 

Reflectors 

Individual corner reflectors in the cover glass that 

reflect light directly back in the direction from 

which it came.

Chapter 3, Section 3.3.2.17 

Efficient Filament 

Placement 

Placement of the filament so that a portion of the 

spectrum emitted by the filament is focused back 

into the filament, increasing operating 

temperature. 

Chapter 3, Section 3.3.2.18 

DOE is aware that some attempts to improve lamp efficacy may also modify lamp 

performance or other lamp characteristics. For example, in incandescent reflector lamps 

operating filaments at higher temperatures can increase lamp efficacy but may also shorten the 

operating life of the lamp. DOE will consider these tradeoffs in the subsequent analyses and will 

eliminate any technology options that increase efficacy by decrease lamping lifetime such that 

they have a significant adverse impact on utility, pursuant to the screening criteria discussed 

below. 

Item 6 DOE welcomes comments on all of the technology options it is considering for this rule, 

including any omissions or revisions for the GSFLs and IRLs covered in this rulemaking. DOE 

also requests information on the feasibility, performance, impacts, and cost of the technology 

options—especially those reflecting recent technological developments. 
5. Screening Analysis

The purpose of the screening analysis is to screen out technologies that will not be 

considered further in the analysis. After making an initial list of technologies (during the market 

and technology assessment), DOE will review and evaluate each technology based on the 

following four criteria, as specified by 10 CFR part 430, subpart C, Appendix A, sections 4(a)(4) 

and 5(b): 

1. Technological feasibility

2.

. DOE will consider technologies incorporated in commercial 

products or in working prototypes to be technologically feasible. 

Practicability to manufacture, install, and service

3.

. If mass production and reliable 

installation and servicing of a technology in commercial products could be achieved on 

the scale necessary to serve the relevant market at the time the standard requires 

compliance, then DOE will consider that technology practicable to manufacture, install, 

and service. 

Adverse impacts on product or equipment utility to consumers or availability

4.

. If DOE 

determines a technology would have a significant adverse impact on the utility of the 

product to significant subgroups of consumers, or would result in the unavailability of 

any covered product type with performance characteristics (including reliability), 

features, sizes, capacities, and volumes that are substantially the same as products

generally available in the United States at the time, it will not consider that technology 

further. 

Adverse impacts on health or safety. If DOE determines that a technology will have 

significant adverse impacts on health or safety, it will not consider that technology 

further. 

DOE will fully document its reasons for eliminating any technology options during the 

screening analysis, and will publish this documentation for stakeholder review and comment as 

part of the preliminary analysis. Those technology options not screened out by the above four 

criteria are called “design options” and are considered as possible methods of improving efficacy 

in the engineering analysis.

In the 2009 Lamps Rule, DOE screened out several technology options. For GSFL, DOE 

screened out the multi-photon phosphor technology because of concerns related to technological 

feasibility and practicability to manufacture, install and service. Development of this technology 

remained in the research phase and DOE was unaware of any prototypes or commercialized 

products that incorporate multi-photon phosphors. For IRLs, several technologies were screened 

out: microcavity filaments, novel filament materials, crystallite filament coatings, luminescent 

gas, non-tungsten-halogen regenerative cycles, infrared phosphor coatings, and trihedral corner 

reflectors. Table 5.1 is a list of the IRL technologies screened out and the criteria on which they 

were eliminated. Many of the technology options were screened out because DOE was unaware 

of any commercially available products with the specific technology, which affected its 

practicability to be manufactured, installed, and serviced. See chapter 4 of the TSD for the 2009 

Lamps Rule for more details on technology options. 

Table 5.1 IRL Technology Options Screened Out of the Analysis
Design Option Excluded Screening Criteria 

Microcavity Filaments Adverse Impacts on Product Utility

Practicability to manufacture, install, and service 

Novel Filament Materials Adverse Impacts on Product Utility

Practicability to manufacture, install, and service

Crystallite Filament Coatings Practicability to manufacture, install, and service 

Luminescent Gas Technological feasibility

Non-Tungsten-Halogen Regenerative 

Cycles 

Practicability to manufacture, install, and service 

Adverse Impacts on Product Utility

Infrared Phosphor Glass Coating Practicability to manufacture, install, and service 

Trihedral Corner Reflectors Practicability to manufacture, install, and service 

Item 7 DOE welcomes comments regarding the technologies that were screened out for the 2009 

Lamps Rule, including whether it is still appropriate to screen out these technologies and 

whether any additional technology options should be screened out for this rule. 

6. Engineering Analysis 

The engineering analysis identifies potential, increasing efficacy levels above the level of 

the baseline model for each product class. Those technologies not eliminated in the screening 

analysis (design options) are inputs to this process. As in the 2009 Lamps Rule, to ensure that 

efficacy levels analyzed are technologically feasible, DOE plans to concentrate its efforts on 

developing product efficacy levels associated with lamp designs that incorporate a range of 

design options based upon commercially available lamps or working prototypes. 74 FR 34080, 

34102 (July 14, 2009). 

6.1 Engineering Analysis Overview

The purpose of the engineering analysis is to determine the relationship between the 

manufacturers’ selling price and efficacy of the covered products. The engineering analysis

identifies potential, increasing efficacy levels above the level of the baseline model for each 

product class. In energy conservation standard rulemakings for other products, DOE typically

develops cost-efficiency relationships in the engineering analysis. For this rulemaking, as in the 

2009 Lamps Rule, DOE will develop efficacy levels in the engineering analysis and end-user 

prices in the product price determination. By combining the results of the engineering analysis 

and the product price determination, DOE will derive typical inputs for use in the LCC and NIA. 

See the section 8 of this framework document for further details on the product price 

determination.

 

For this rulemaking, DOE is using the same methodology for the engineering analysis 

that was detailed in the 2009 Lamps Rule. 74 FR 34080, 34102-08 (July 14, 2009). The 

following is a summary of the steps DOE plans to take in the engineering analysis: 

• Step 1: Select Representative Product Classes 

• Step 2: Select Baseline Lamps 

• Step 3: Identify Higher-Efficacy Lamp Replacements 

• Step 4: Develop Efficacy Levels. 
A more detailed discussion of the methodology DOE followed to perform the engineering 

analysis can be found in chapter 5 of the TSD for the 2009 Lamps Rule. 

Item 8 DOE welcomes comments on the overall methodology for the engineering analysis. 

6.2 Representative Product Classes

As discussed previously in this framework document, DOE is considering establishing 

twelve product classes for GSFLs and eight product classes for IRLs. Similar to the approach in 

the 2009 Lamps Rule, DOE is not planning to directly analyze every product class. Instead, DOE 

will select certain product classes to analyze, and then scale its analytical findings for those 

representative product classes to other product classes that are not analyzed. DOE typically 

chooses representative product classes based on the highest shipment volumes. 

As discussed in section 4.2.1 DOE is considering establishing product classes for GSFLs 

based on the following three factors: (1) physical constraints of lamps (i.e., lamp shape and 

length); (2) lumen package (i.e., standard versus high output); and (3) correlated color 

temperature (CCT). Similar to the 2009 Lamps Rule, DOE plans to establish the following as 

representative product classes: 4-foot medium bipin (MBP), 8-foot single pin (SP) slimline, 8-

foot recessed double contact (RDC) high output (HO), 4-foot miniature bipin (MiniBP) standard 

output (SO), and 4-foot MiniBP HO lamps with a CCT less than or equal to 4,500 Kelvin (K). 

DOE does not plan to explicitly analyze U-shaped lamps because they represent a small portion 

of the market. 74 FR 34080, 34102 (July 14, 2009). 

As discussed in section 4.2.2, DOE is considering establishing product classes for IRLs 

based on the following factors: (1) lamp spectrum (modified versus standard spectrum); (2) lamp 

diameter (greater than 2.5 inches or less than or equal to 2.5 inches); and (3) rated voltage (less 

than 125V or greater than or equal to 125V). After analyzing catalog data and talking to industry 

experts for the 2009 Lamps Rule, DOE found that standard-spectrum lamps were more common 

than modified-spectrum lamps, lamps with voltage ratings less than 125V were more common 

than lamps with higher voltage ratings, and lamps with diameters greater than 2.5 inches were 

significantly more common than lamps of smaller diameters. Therefore, in this rulemaking, DOE 

is considering analyzing IRL with standard-spectrum, voltage ratings less than 125V and 

diameters greater than 2.5 inches as representative. 74 FR 34080, 34102 (July 14, 2009). See 

chapter 5 of the TSD for the 2009 Lamps Rule for more discussion on representative product 

classes.

Item 9 DOE welcomes comments on the product classes that it has selected to analyze as 

representative for this rulemaking. 

6.3 Baseline Lamps

Once DOE identifies the representative product classes for analysis, DOE selects 

representative units (baseline lamps) from within the representative product classes. These 
baseline units are generally what DOE believes to be the most-common, least-efficacious lamps 

in their respective product classes. 

Similar to the 2009 Lamps Rule, DOE plans to establish baseline lamps by analyzing 

manufacturer catalogs and compliance data to determine the most common, least efficacious 

lamps that just meet existing standards. 74 FR 34080, 34102 (July 14, 2009). Where necessary, 

DOE plans to analyze more than one baseline lamp. For example, in the 2009 Lamps Rule, DOE 

considered both T8 and T12 lamps as baselines for 4-foot MBP, 8-foot HO, and 8-foot slimline 

lamps. Table 6.1 and Table 6.2 list the standards adopted in the 2009 Lamps Rule for 

respectively, GSFL and IRL. 

Table 6.1 GSFL Standards Adopted in 2009 Lamps Rule

Lamp/Tube type Correlated color temperature

(CCT)

Minimum average 

lamp

efficacy (lm/W)

4-foot medium bipin

 

≤4,500K 89

>4,500K and ≤7,000K 88

2-foot U-shaped

 

≤4,500K 84

>4,500K and ≤7,000K 81

8-foot slimline

 

≤4,500K 97

>4,500K and ≤7,000K 93

8-foot high output

 

≤4,500K 92

>4,500K and ≤7,000K 88

4-foot miniature bipin standard 

output 

≤4,500K 86

>4,500K and ≤7,000K 81

4-foot miniature bipin high output

 

≤4,500K 76

>4,500K and ≤7,000K 72

Table 6.2 IRL Standards Adopted in 2009 Lamps Rule

Rated 

Lamp 

Wattage 

Lamp Spectrum Lamp 

Diameter 

(inches) Rated 

Voltage 

Minimum 

average 

lamp 

efficacy 

(lm/W)

40-205 Standard 

Spectrum

>2.5 >125V 6.8*P0.27

<125V 5.9*P0.27 

<2.5 >125V 5.7*P0.27 

<125V 5.0*P0.27 

40-205 Modified 

Spectrum

>2.5 >125V 5.8*P0.27
<125V 5.0*P0.27

<2.5 >125V 4.9*P0.27

<125V 4.2*P0.27

For GSFLs and IRLs, DOE is considering as baselines lamps that just meet the standards 

adopted in the 2009 Lamps Rule. For GSFLs, these baseline lamps, listed in Table 6.3, were 

based off of the full-wattage (as opposed to reduced-wattage) representative units analyzed at 

TSL 4 in the 2009 Lamps Rule (the adopted level, see Table 6.1). DOE requests comment on 

whether these lamps represent the lowest efficacy lamps expected to be available in 2012. 

Additionally, based on the assumption that most commercially available T12 lamps will 

not be able to meet the standards adopted in the 2009 Lamps Rule, DOE is currently considering 

not analyzing T12 lamps as baselines in this rulemaking. However, DOE notes that several

manufacturers have claims on their websites that some T12 lamps would be able to meet 

standards. Therefore, DOE requests comment on its proposal to not analyze T12 lamps as 

baselines. 

Table 6.3 GSFL Baseline Lamp Characteristics Under Consideration

Baseline 

Lamp 

Lamp 

Diameter

Nominal 

Wattage 

Rated 

Wattage 

Rated 

Efficacy

Initial 

Light 

Output

Mean 

Light 

Output

Life CRI

W W Lm/W lm lm hr

4-Foot MBP T8 32 32.5 92.3 3,000 2,850 24,000 85 

8-Foot SP 

Slimline

T8 59 60.1 98.2 5,900 5,428 15,000 82 

8-Foot RDC 

HO

T8 86 86 91.9 7,900 7,100 24,000 78 

8-Foot RDC 

HO

T8 86 86 93.0 8,000 7,200 18,000 75 

4-Foot T5 

MiniBP SO

T5 28 27.8 104.3 2,900 2,660 20,000 85 

4-Foot T5 

MiniBP HO

T5 54 53.8 92.9 5,000 4,600 20,000 85 

For IRLs, DOE is considering the halogen infrared (HIR) technologies that uses both 

halogen and glass coatings that reflect infrared light. The baseline lamps DOE is considering are 

listed in Table 6.4. As noted these lamps just meet the standards adopted in the 2009 Lamps Rule 

(see Table 6.2) and were identified in that rulemaking as equivalent lumen replacements for 

50W, 75W, and 90W IRLs. DOE requests comment on whether the 40W, 55W, and 66W IRL 

baselines are representative of IRL wattages on the market in 2012. 

Table 6.4 IRL Baseline Lamp Characteristics Under Consideration

Baseline 

Lamp 

Design Option Initial Light 

Output Efficacy Lamp Lifetime

lm lm/W hr
40W PAR30 Improved HIR 680 17.0 4,000 

55W PAR38 Improved HIR 1,050 19.1 4,000 

66W PAR38 Improved HIR* 1,310 19.8 4,000 

*IRL lamp designs with an asterisk are model lamp designs developed in the 2009 Lamps Rule. 

These model lamp designs were not commercially available at the time and were developed by 

DOE based on technical literature and confidential information from manufacturers on 

incandescent design lamp options 

Item 10 DOE welcomes comments on the baseline lamps it is considering for GSFLs in this 

rulemaking and whether they are representative of products sold on the market in 2012. In 

particular, DOE requests comment on whether the baseline lamps under consideration have 

lower efficacies than their catalog-rated efficacy values. Additionally, DOE requests comment 

on whether it is appropriate to analyze only a T8 baseline for GSFL. 

Item 11 DOE welcomes comments on the baseline lamps it is considering for IRLs in this 

rulemaking and whether they are representative of the products expected to be sold on the 

market in 2012. In particular, DOE requests comment on the expected lifetime and wattage of 

IRL.

6.4 Identify Higher-Efficacy Lamp Replacements

DOE selects more efficacious lamps for each baseline lamp by considering technologies 

not eliminated in the screening analysis. DOE considers these technologies in the engineering 

analysis, either by modeling potential efficacy improvements due to the design options or by

analyzing commercially available lamps in which the design options are incorporated. In 

identifying more efficacious lamp-and-ballast designs, DOE recognizes that a lamp’s lumen 

package and performance characteristics are important design criteria for consumers. DOE 

chooses substitute lamps with performance characteristics similar to those of the baseline lamps. 

Similar to the 2009 Lamps Rule, DOE plans to account for lumen output when it 

establishes lamp designs for its analyses. In its analysis, DOE considers lamps that emit lumens 

equal to the lumen output of the baseline lamp, or below that lamp by no more than 10 percent; 

and result in energy savings. This approach will help accurately characterize the costeffectiveness of a particular efficacy level if a consumer makes an informed decision that 

maintains light output. However, DOE considers consumer behaviors resulting in underillumination, over-illumination, or no energy savings in the NIA.

In identifying more efficacious substitutes, DOE plans to use a database of commerciallyavailable lamps for GSFLs and IRLs and develop model lamps as it did in the 2009 Lamps Rule. 

These models will incorporate designs that may not be commercially available for certain lamp 

types and wattages, but use commercially-available technologies. DOE will verify with 

manufacturers whether the designs considered by DOE are technologically feasible and whether 

they meet DOE’s screening criteria. See chapter 5 of the TSD for the 2009 Lamps Rule for more 

discussion on the selection of higher-efficacy lamp replacements.
Item 12 DOE welcomes comments on the methodology it is considering to select higher-efficacy 

lamp designs. 

6.5 Efficacy Levels 

After identifying the more efficacious substitutes for each baseline lamp or lamp-andballast system, DOE develops efficacy levels (ELs) based on three factors: (1) the design options 

associated with the specific lamps being studied (e.g., grades of phosphor for fluorescent lamps, 

the use of halogen IR coatings for IRLs, etc.); (2) the ability of lamps across wattages to comply 

with the EL of a given product class;5 and (3) the maximum technologically-feasible efficacy 

level. DOE is considering adopting the same methodology to determine efficacy levels in this 

rulemaking. 

Similar to the 2009 Lamps Rule, DOE plans to use catalog data on commerciallyavailable lamps to develop continuous equations that represent the potential efficacy achieved by

a particular design option. DOE plans to establish the minimum efficacy requirements for each 

efficacy level by comparing the catalog data with data submitted to DOE by manufacturers for 

the purpose of compliance with existing energy conservation standards. When DOE does not 

have compliance report data on every lamp design analyzed, DOE plans to use compliance report 

data of lamps with similar design options to determine the appropriate minimum efficacy 

requirement. 

In the 2009 Lamps Rule, DOE identified five efficacy levels for both GSFLs and IRLs. 

For all lamp types except for 4-foot T5 MiniBP HO lamps, the adopted standard level 

represented the second highest efficacy level identified. Therefore, for this rulemaking, DOE is 

generally considering establishing the 2009 Lamps Rule’s maximum technologically feasible 

level as CSL1, as depicted in Table 6.5 and Table 6.6. For 4-Foot T5 MiniBP HO lamps, only 

one standard level was proposed and subsequently adopted in the 2009 Lamps Rule. DOE is 

currently not aware of full-wattage T5 HO lamps with efficacy levels that exceed those adopted 

for 4-Foot T5 MiniBP HO lamps in the 2009 Lamps Rule. DOE notes that there are 

commercially-available reduced-wattage T5 HO lamps with lamp efficacies that significantly 

exceed the levels adopted in the 2009 Lamps Rule. However, due to reduced wattage lamps’ 

potential application limitations (inability to operate at cold temperatures or in drafty 

environments) DOE has preliminarily decided that the baseline represents the maximum 

technologically feasible level (as indicated by commercially available products). DOE requests 

comment on whether candidate standard levels should be based on reduced wattage lamps, and 

whether these lamps represent equivalent utility as full-wattage lamps. In addition, DOE requests 

comment on whether higher efficacy levels than those depicted in the Table 6.5 and Table 6.6

can be achieved through redesign of commercially available products.

Table 6.5 GSFL Efficacy Levels Under Consideration

Baseline Lamp CCT Efficacy Level 

lm/W

 

5 Efficacy levels span multiple lamps of different wattages. In selecting ELs, DOE considered whether lamps of 

different wattages can meet the efficacy levels prescribed by those ELs. 
4-Foot MBP ≤ 4,500K 93

8-Foot SP Slimline 

Lamps 

≤ 4,500K 98

8-Foot RDC HO Lamps ≤ 4,500K 95

4-Foot T5 MiniBP SO 

Lamps 

≤ 4,500K 90

Table 6.6 IRL Efficacy Level Under Consideration

Lamp Type Diameter Voltage Efficacy Level 

Equation 

lm/W

Standardspectrum > 2.5 inches < 125 6.4P0.27 

Additionally, in the 2009 Lamps Rule, DOE established that the efficacy requirement for 

IRL varies according to the following equation: A*P0.27, where “A” is a constant specifying the 

technology level and “P” is the rated wattage of the lamp. For this rulemaking, DOE is 

considering using the same type of power law equation for IRL. 

Item 13 DOE also welcomes comments on the potential efficacy levels identified and whether 

higher efficacy levels can be achieved through redesign of commercially available product. In 

addition DOE requests comments on whether GSFL efficacy levels should be based on reducedwattage lamps. 

6.6 Scaling to Product Classes Not Analyzed 

As mentioned previously, DOE plans to select certain product classes as representative 

and concentrate its analytical effort on those classes. Standards for non-representative product 

classes are determined by scaling standards from product classes that were directly analyzed. 

Similar to the 2009 Lamps Rule, DOE will develop scaling factors for GSFLs by 

comparing the efficacy level of the representative product classes to efficacies of commerciallyavailable lamps from the non-representative product classes. For 2-foot U-shaped lamps with 

CCT less than or equal to 4,500K scaling factors will be based on efficacy levels of 4-foot MBP 

lamps. For lamps with CCTs above 4,500K scaling factors will be based on efficacy levels of 

corresponding lamp types with CCTS less than or equal to 4,500K. DOE is considering using the 

reduction factor of 6.5 percent developed in the 2009 Lamp Rule for 2-foot U-Shaped lamps in 

this rulemaking. DOE is considering using reduction factors within the range of 1.1 to 6.0 

percent developed in the 2009 Lamps Rule for lamps with CCTs above 4,500K in this 

rulemaking. 

 For IRLs, DOE plans to create scaling factors to develop efficacy levels for lamps with 

modified spectrum, diameters less than or equal to 2.5 inches (small-diameter), and operating 

voltages greater than or equal to 125V based on respectively, efficacy levels of lamps with 

standard-spectrum, diameters greater than 2.5 inches (large-diameter), and voltage ratings less 

than 125V. 
In the 2009 Lamps Rule, DOE assessed the efficacy differences between standard- and 

modified-spectrum IRL by measuring the efficacies of commercially-available standard- and 

modified-spectrum lamps. DOE is considering using the resulting determination of a 15 percent 

reduction for modified-spectrum IRL from the standard-spectrum efficacy levels in this 

rulemaking. DOE is also planning to use the reduction factor of 15.5 percent developed in the 

2009 Lamps Rule for small-diameter lamps from large-diameter efficacy levels in this 

rulemaking. 

 In the 2009 Lamps Rule, using IESNA Lighting Handbook6 equations relating life, 

voltage and lumens and confidential information on incandescent lamp design, DOE determined 

that a lamp operating at 130V would be 15-percent more efficacious than a lamp of a similar 

wattage operating at 120V. DOE is considering using the same 15 percent increase for IRLs 

operating at greater than 120V from IRLs operating at less than 120V in this rulemaking. 

See chapter 5 of the TSD for the 2009 Lamps Rule for a more complete discussion of 

how efficacy levels were scaled to non-representative product classes.

Item 14 DOE welcomes comments on the methodology to scale to products not directly analyzed 

and the specific scaling factors it is considering. 

6.7 Proprietary Designs 

DOE will consider in its engineering and economic analyses all design options that are 

commercially available or present in a working prototype, including proprietary designs, that 

meet the screening criteria discussed in section 5. However, DOE will consider a proprietary 

design in the subsequent analyses only if it does not represent a unique path to a given efficiency 

level. If the proprietary design is the only approach available to achieve a given efficiency level, 

then DOE will eliminate the efficiency level from further analysis. DOE will reject a standard 

level that can be met only with a proprietary technology because it could result in an anticompetitive market, a principle consistently applied in past DOE rulemakings as economically 

unjustifiable. However, if a given energy efficiency level can be achieved by a number of design 

approaches, including a proprietary design, DOE will continue to examine the given efficiency 

level. 

DOE is aware of manufacturer concerns about proprietary designs and will take steps to 

maintain the confidentiality of any proprietary data provided by manufacturers. This information 

will provide input to the competitive impacts assessment and other economic analyses. 

Item 15 DOE welcomes comments on proprietary designs it should be aware of for the GSFLs 

and IRLs that are the subject of this rulemaking. 

 

6 Rea, M. S., ed., The IESNA Lighting Handbook: Reference and Application, 9th Edition. New York: Illuminating 

Engineering Society of North America. IESNA (2000).
6.8 Outside Regulatory Changes Affecting the Engineering Analysis 

In conducting an engineering analysis, DOE considers the effects of regulations outside 

DOE’s statutory energy conservation standards rulemaking process that can affect manufacturers 

of the covered products. Some regulatory requirements can also affect the efficacy or energy 

consumption of the covered lamps. DOE will attempt to identify other regulatory requirements 

that could affect the engineering analysis. The consideration of these requirements is closely 

related to the cumulative regulatory burdenassessment that DOE will conduct as part of the 

manufacturer impact analysis. Based on consideration of the comments received on the 

engineering analysis, DOE will make any necessary changes to its analysis. 

Item 16 DOE welcomes comments on regulatory burdens or changes that should be considered 

in the engineering analysis. 

Item 17 DOE welcomes comments on other engineering issues that could affect the engineering 

analysis. 

7. Energy Use Characterization

The purpose of the energy-use characterization is to identify how products are used by 

consumers, and thereby determine the energy savings potential of energy efficiency 

improvements. DOE determines the energy consumption of lamps through the rated power (rated 

in watts) and the way consumers use the lamp (operating hours per year). This analysis, which is 

meant to represent typical energy consumption in the field, is an input to both the LCC and PBP 

analyses and the NIA. DOE derives the annual energy consumption of lamps by multiplying the 

power rating by the number of hours of operation per year. 

As in the 2009 Lamps Rule, DOE plans to use the U.S. Lighting Market Characterization: 

Volume I (LMC)7 to determine operating hours. The LMC is based on thousands of building 

audits and surveys and provides national-level data on operating hours by building type and lamp 

category for all sectors. Within the commercial sector, the distributions were broken down by 

application, and within the residential sector, the distribution was broken down by room type. In 

conjunction with data from the LMC, DOE plans to use data from the recent versions of Energy 

Information Administration’s (EIA) Commercial Building Energy Consumption Survey 

(CBECS)8, Residential Energy Consumption Survey (RECS)9

 

7 U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Energy Conservation Program 

for Consumer Products: Final Report: U.S. Lighting Market Characterization, Volume I: National Lighting 

Inventory and Energy Consumption Estimate (2002). Available at: 

www.eere.energy.gov/buildings/info/documents/pdfs/lmc_vol1_final.pdf.

, and the Manufacturing Energy 

8 U.S. Department of Energy, Energy Information Administration, Commercial Building Energy Consumption 

Survey: Micro-level data, file 2 Building Activities, Special Measures of Size, and Multi-building Facilities (2003). 

Available at: www.eia.doe.gov/emeu/cbecs/public_ use.html.

9 U.S. Department of Energy, Energy Information Administration, Residential Energy Consumption Survey: File 1: 

Housing Unit Characteristic (2006). Available at: www.eia.doe.gov/emeu/recs/recs2001/publicuse2001.html.
Consumption Survey (MECS).10 These EIA studies provide information on the distribution of 

buildings within the U.S., by building type and Census Division. DOE plans to use the LMC’s 

operating hour data by building type and the EIA’s data by building type and Census Division to 

derive operating hours by Census Division. This would allow DOE to correlate the electricity 

price distribution and sales tax distribution with the operating hour distribution by Census 

Division in the LCC spreadsheet. DOE also plans to determine average operating hours for the 

residential, commercial, and industrial sectors. As in the 2009 Lamps Rule, however, DOE does 

not plan to analyze IRL in the industrial sector. See chapter 6 of the TSD for the 2009 Lamps 

Rule for a more complete discussion on the energy-use characterization. 

Item 18 DOE welcomes comments on the methodology it is considering to determine energy use. 

In particular, DOE requests comments on its approach to calculate operating hours for the 

covered lamps.

8. Product Price Determination

The purpose of the engineering analysis and product price determination together is to 

provide an analysis of the relationship between the efficacy and end-user price for GSFL and 

IRL. As in the 2009 Lamps Rule, DOE intends to obtain manufacturers’ published end-user price 

schedules for lamps (hereafter called the manufacturer’s “blue book” or “lamp price schedules”) 

as well as information on discounts applied to those price schedules from distributors, State 

contracts, and other publicly-available information sources. In addition, DOE intends to obtain 

information on distributor pricing (what a distributor would pay) for commercial, industrial, and 

institutional consumers of lamps. 74 FR 34080, 34110-11 (July 14, 2009). Starting from lamp 

price schedules provided by manufacturers, DOE intends to look at publicly-available prices in 

State procurement contracts, at large electrical supply distributors, home improvement/hardware 

stores, and other sources of publicly-available end-user prices, such as Internet retailers. 

For the 2009 Lamps Rule, in its review of publicly-available market prices, DOE 

observed a range of end-user prices paid for a given lamp, depending on the distribution channel 

through which it was purchased and the volume at which it was purchased. DOE observed that 

State procurement contracts typically negotiated a discount of around 70 to 90 percent off the 

blue book price. In the majority of instances, these discounts applied uniformly to all products on 

a price schedule irrespective of the volume of a particular lamp. Internet retailers, electrical 

supply distributors, and home-improvement/hardware stores generally reflected prices paid by 

consumers in the medium-to-high range of prices. These channels usually applied different 

discounts to lamps depending on their sales volume. Since many high-efficacy lamps are lowvolume products, DOE observed that they were generally less discounted than commodity lamps. 

Using this information, DOE calculated three sets of discounts from the blue books, 

representing the range of low, medium, and high lamp prices for GSFL and IRL for the 2009 

Lamps Rule. To reflect future commoditization of higher-efficacy lamps when they become the 

minimum complying products, the discounts DOE applied to blue book prices to derive the low, 

 

10 U.S. Department of Energy, Energy Information Administration, Manufacturing Energy Consumption Survey, 

Table 1.4: Number of Establishments by First Use of Energy for All Purposes (Fuel and Nonfuel) (2002). Available 

at: www.eia.doe.gov/emeu/mecs/mecs2002/data02/ shelltables.html.
medium, and high prices were a constant markdown across all lamps. For those lamps where 

commercial (blue book) pricing was not available, DOE extrapolated pricing from available 

lamps. 

Once DOE calculated end-user prices, DOE added sales tax and, if appropriate, 

installation costs to derive the total, installed end-user cost. For the reference case in the LCC, 

DOE used the medium lamp prices, but it also conducted analysis at the low and high lamp 

prices, to ascertain the impact of these other price points. In the NIA, DOE used only the 

medium prices because this price scenario represents the average purchase price for a variety of 

consumers nationwide. In this rulemaking DOE is considering using the same methodology to 

develop prices. 74 FR 34080, 34110-11 (July 14, 2009). 

In the 2009 Lamps Rule, DOE presented figures that represented State and local sales 

taxes that were applied to the consumer product price. 74 FR 34080, 34111 (July 14, 2009). It 

was a multiplicative factor that increased the consumer product price. DOE derived State and 

local taxes from data provided by the Sales Tax Clearinghouse.11 The data represented weighted 

averages that included county and city rates. DOE is considering using the same methodology to 

estimate sales tax estimates for this rulemaking. For more information on product price 

determination, see chapter 7 of the 2009 Lamps Rule TSD. 

In addition, as part of the product price determination DOE will also conduct a price 

trends analysis. As noted in a Notice of Data Availability published by DOE, economic literature 

and historical data suggest that the real costs of many covered products have trended downward 

over time according to ‘‘experience’’ curves. 76 FR 9696, 9697 (Feb. 22, 2011). DOE will 

investigate various methods for forecasting future prices of GSFL and IRL in the base case. 

Item 19 DOE welcomes comments on the methodology it is considering for lamp prices and 

sales tax estimates for this rulemaking. DOE also welcomes comment on the price forecasting 

methodologies it is considering. 

9. Life-Cycle Cost and Payback Period Analysis 

The effects of increased energy conservation standards on consumers include a change in 

their operating expenses (usually decreased) and a change in the purchase price (usually 

increased) they pay. The LCC of a product is the cost a product incurs over its lifetime, taking 

into account both purchase price, operating costs (including energy expenditures), and 

installation costs. The payback period (PBP) represents the time it takes to recover the additional 

installed cost of the more-efficient product through annual operating cost savings. DOE analyzes 

the net effect on consumers by calculating the LCC and PBP using the engineering performance 

data (section 6), the energy-use and end-use load characterization data (section 7), and the 

product price determination (section 8). Inputs to the LCC calculation include the installed cost 

to the consumer (purchase price plus installation cost), operating expenses (energy expenses, 

and, if applicable, repair costs and maintenance costs), the lifetime of the product or other 

defined period of analysis, and a discount rate. Inputs to the payback period calculation include 

 

11 Sales Tax Clearinghouse, Aggregate State Tax Rates (2007). Available at: thestc.com/STrates.stm. 
the installed cost to the consumer and annual operating costs. DOE will conduct the LCC and 

PBP analyses using a spreadsheet model developed in Microsoft Excel, similar to the one 

developed for the 2009 Lamps Rule. When combined with the Crystal Ball model (a 

commercially-available software program), the LCC and PBP model generates a Monte Carlo12

simulationto perform the analysis by incorporating uncertainty and variability considerations. 

The life-cycle cost of a particular lamp design is composed of the total installed cost 

(which includes manufacturer selling price, sales taxes, distribution chain mark-ups, and any 

installation cost), operating expenses (energy, repair, and maintenance costs), product lifetime, 

and discount rate. 74 FR 34080, 34108 (July 14, 2009). In the 2009 Lamps Rule, DOE also 

incorporated a residual value calculation to account for any remaining lifetime of lamps at the 

end of the analysis period. Id. The residual value is an estimate of the product’s value to the 

consumer at the end of the life-cycle cost analysis period. This residual value recognizes that a 

lamp system may continue to function beyond the end of the analysis period. DOE calculates the 

residual value by linearly prorating the product’s initial cost consistent with the methodology 

described in the Life-Cycle Costing Manual for the Federal Energy Management Program.

13

As in the 2009 Lamps Rule, DOE plans to use a “simple” PBP for this rulemaking which 

is the ratio of the increase in purchase cost (i.e., from a less efficient design to a more efficient 

design) to the decrease in annual operating expenditures. The “simple” PBP does not take into 

account other changes in operating expenses over time or the time value of money, and is 

calculated at an effective discount rate of zero. 74 FR 34080, 34113 (July 14, 2009). As inputs to 

the PBP analysis, DOE used the total installed cost of the product to the consumer for each 

efficacy level, as well as the first year annual operating costs for each efficacy level. The 

calculation requires the same inputs as the LCC, except for energy price trends and discount 

rates; only energy prices for the year the standard takes effect are needed. 

Section 325(o)(2)(B)(iii) of EPCA states that there is a rebuttable presumption that an 

energy conservation standard is economically justified if the increased installed cost for a 

product that meets the standard is less than three times the value of the first-year energy savings 

resulting from the standard, as calculated under the applicable DOE test procedure. (42 U.S.C. 

6295(o)(2)(B)(iii)) DOE’s LCC and PBP analyses generate values that calculate the payback 

period for consumers of potential energy conservation standards, which includes, but is not 

limited to, the three-year payback period contemplated under the rebuttable presumption test. 

However, DOE routinely conducts a full economic analysis that considers the full range of 

impacts, including those to the consumer, manufacturer, nation, and environment, as required 

under 42 U.S.C. 6295(o)(2)(B)(i). The results of this analysis serve as the basis for DOE to 

evaluate the economic justification for a potential standard level (thereby supporting or rebutting 

the results of any preliminary determination of economic justification). 

 

12 Monte Carlo simulations model uncertainty by utilizing probability distributions instead of single values for 

certain inputs and variables.

13 Fuller, Sieglinde K. and Stephen R. Peterson, National Institute of Standards and Technology Handbook 135 

(1996 Edition); Life-Cycle Costing Manual for the Federal Energy Management Program (Prepared for U. S. 

Department of Energy, Federal Energy Management Program, Office of the Assistant Secretary for Conservation 

and Renewable Energy)(Feb. 1996). Available at: fire.nist.gov/fire/firedocs/build96/PDF/b96121.pdf. 
See chapter 8 of the TSD for the 2009 Lamps Rule for a more detailed discussion of the 

LCC and PBP analysis. Table 9.1 summarizes the approach and data that DOE intends to use to 

derive the inputs to the LCC and PBP calculations for this rulemaking. The following sections 

discuss several of these inputs not addressed by other analyses DOE conducts. 

Table 9.1 Summary of Inputs and Key Assumptions Used for the LCC Analyses

Inputs Description 

Consumer Product 

Price 

Applies discounts to manufacturer catalog (“blue-book”) pricing in order to represent 

low, medium, and high prices for all lamp categories. Discounts were also applied to 

develop a price for ballasts. See Product Price Determination. 

Sales Tax Derives weighted-average tax values for each Census Division and large State from data 

provided by the Sales Tax Clearinghouse. See Product Price Determination. 

Installation Cost Derives costs using the RS Means Electrical Cost Data to obtain average labor times for 

installation, as well as labor rates for electricians and helpers based on wage rates, 

benefits, and training costs. For GSFLs, included 2.5 minutes of installation time to the 

new construction, major retrofit, and renovation events in the commercial and industrial 

sectors to capture the time needed to install luminaire disconnects.

Disposal Cost GSFL: Includes a recycling cost of 10 cents per linear foot in the commercial and 

industrial sectors.

IRL: Not included.

Annual Operating 

Hours 

Determines operating hours by associating building-type-specific operating hours data 

with regional distributions of various building types using the U.S. Lighting Market 

Characterization and the Energy Information Administration’s (EIA) Commercial 

Building Energy Consumption Survey (2003) and Residential Energy Consumption 

Survey (2009). See Energy Use Characterization. 

Product Energy 

Consumption Rate 

Determines lamp input power (or lamp-and-ballast system input power for GSFL) based 

on published manufacturer literature. See Engineering Analysis. 

Electricity Prices Price: Based on EIA’s most recent, 2009 Form EIA-861 data. Variability: Regional 

energy prices determined for 13 regions 

Electricity Price 

Trends 

Forecasts with EIA’s Annual Energy Outlook (AEO) 2011. 

Lifetime Lamp lifetime based on the most recent published manufacturer literature where 

available. Where manufacturer literature is not available, DOE derives lamp lifetimes as 

part of the engineering analysis. 

Discount Rate Residential: Approach based on the finance cost of raising funds to purchase lamps 

either through the financial cost of any debt incurred to purchase product or the 

opportunity cost of any equity used to purchase equipment, based on the Federal 

Reserve’s Survey of Consumer Finances data for 1989, 1992, 1995, 1998, 2001, 2004, 

and 2007. Uses data from the Cost of Savings Index dataset covering 1984 to 2008. 

Commercial and Industrial: Derives discount rates using the cost of capital of publiclytraded firms in the sectors that purchase lamps, based on data in CBECS, Damodaran 

Online, Ibbotson’s Associates, the 2007 Value Line Investment survey, Office of 

Management and Budget (OMB) Circular No. A-94, 2008 State and local bond interest 

rates, and the U.S. Bureau of Economic Analysis. 

Analysis Period Commercial and industrial GSFL: Based on the longest baseline lamp life in a product 

class divided by the annual operating hours of that lamp.

Residential GSFL: Based on the useful lifetime of the baseline lamp.

Lamp Purchasing 

Events 

Commercial and industrial sectors: DOE will assess five events: lamp failure, standardsinduced retrofit, ballast failure (GSFL only), ballast retrofit (GSFL only), and new 

construction/renovation. 

Residential sector: DOE assessed three events: lamp failure, ballast failure (GSFL 

only), and new construction/renovation.
9.1 Installation Costs 

As detailed in the 2009 Lamps Rule, DOE considers the total installed cost of a lamp to 

be the consumer product price (including sales taxes) plus the installation cost. 74 FR 34080, 

34108 (July 14, 2009). For the commercial and industrial sectors, DOE assumes an installation 

cost that was the product of the average labor rate and the time needed to install a lamp. DOE 

assumes that in the residential sector, the homeowner replaces individual lamps; thus, DOE 

applies installation costs only to lamp-and-ballast systems in the residential sector.

As in the 2009 Lamps Rule, DOE plans to derive costs using the “RS Means Electrical 

Cost Data, 200714” to obtain average labor times for installation, as well as labor rates for 

electricians and helpers based on wage rates, benefits, and training costs. DOE uses “RS Means 

Electrical Cost Data, 2007,” because labor costs in RS Means are based on labor union 

agreements and construction wages, as well as actual working conditions in 30 major U.S. cities. 

74 FR 34080, 34109 (July 14, 2009). In the 2009 Lamps Rule, DOE estimated that the rates for 

electricians and electrician’s helpers in 2007 dollars are $55.41 per hour and $27.70 per hour, 

respectively. DOE also determined the lamp replacement labor rate to be $15.94 per hour in 

2007 dollars. 74 FR 34080, 34109 (July 14, 2009). DOE is considering using the same 

installation rates for this rulemaking. See chapter 8 of the TSD for the 2009 Lamps Rule for a 

more complete discussion of installation costs.

9.2 Energy Prices and Trends

As in the 2009 Lamps Rule, DOE plans to determine energy prices by deriving regional 

average prices for 13 geographic areas consisting of the nine U.S. Census Divisions, with four 

large states (New York, Florida, Texas, and California) treated separately. 74 FR 34080, 34109 

(July 14, 2009). DOE intends to base the derivation of prices on data in EIA’s Form EIA-861.15

DOE plans to use projections of national average electricity prices to estimate future 

energy prices and energy bill savings in its LCC analysis. DOE will use the most recently 

available edition of EIA’s Annual Energy Outlook (AEO) as the default source of projections for 

future energy prices.

9.3 Analysis Period 

 

The analysis period is the time span over which the LCC is calculated and is based on the 

lifetime of the product. To account for variability in lifetime of lamp designs, DOE creates a 

consistent analytical time periodcomparing more-efficacious lamps against a baseline lamp 

over the lifetime of the longest-lived baseline lamp in a particular product class. When this 

analysis period is shorter than the lifetime of the replacement lamp, DOE accounts for the 

remaining life of the replacement lamp as a residual value. When the analysis period is longer 

than the lifetime of the replacement lamp, a second replacement lamp is installed, and if any 

operating life of that second replacement lamp remains at the end of the analysis period, then its 

 

14 R. S. Means Company, Inc., 2007 RS Means Electrical Cost Data (2007). 15 Energy Information Administration, Form EIA-861 Final Data File for 2006 (2006)(Last accessed June 20, 

2008).
residual value is added back into the LCC. By using the annual operating hours paired with 

published lamp lifetimes, DOE calculates the lamp service lifetime in years.

As in the 2009 Lamps Rule, for the IRL and the commercial and industrial sector GSFL 

LCC analyses, DOE intends to base the analysis period on the longest baseline lamp life in a 

certain product class divided by the annual operating hours of that lamp. DOE plans to account 

for two types of GSFL consumer behavior in the residential sector. In the first kind of consumer 

behavior, consumers disposed of their lamps when replacing a ballast, regardless of how much 

lifetime the lamps had remaining. Because a lamp failure for these consumers would not occur 

under average operating hours of 791 hours per year (as the fixture would be removed before the 

lamp would reach the end of its rated life), DOE plans to use only high operating hours in the 

lamp failure event for these consumers. In the second kind of consumer behavior, residentialsector GSFL consumers preserve their lamps when replacing a fixture, then install the lamps on 

the new fixture. This allows the lamps to live for their entire rated lifetimes in situations of 

average operating hours, and DOE plans to model a lamp failure event for average operating 

hours. See chapter 8 of the TSD for the 2009 Lamps Rule for a more complete discussion of the 

analysis period.

9.4 Discount Rates 

The calculation of consumer LCC requires the use of an appropriate discount rate. DOE 

uses the discount rate to determine the present value of lifetime operating expenses. The discount 

rate used in the LCC analysis represents the rate from an individual consumer’s perspective.16

DOE is considering using the same approach that it relied on to develop discount rates for 

the 2009 Lamps Rule. For the residential sector, DOE would derive the discount rates from 

estimates of the interest or “finance cost” to purchase residential products. 74 FR 34080, 34109 

(July 14, 2009). The finance cost of raising funds to purchase these products can be interpreted 

as: (1) the financial cost of any debt incurred to purchase products (principally interest charges 

on debt), or (2) the opportunity cost of any equity used to purchase products (principally interest 

earnings on household equity). Household equity is represented by holdings in assets such as 

stocks and bonds, as well as the return on homeowner equity. Much of the data required, which 

involves determining the cost of debt and equity, comes from the Federal Reserve Board’s 

triennial Survey of Consumer Finances.

17 

For the commercial sector and industrial sector, DOE would derive the discount rate from 

the cost of capital of publicly-traded firms in the sectors that purchase lamps. 74 FR 34080, 

34113 (July 14, 2009). Most companies use both debt and equity capital to fund investments; for 

most companies, therefore, the cost of capital is the weighted average of the cost to the firm of 

equity and debt financing. DOE estimates the cost of equity financing using the Capital Asset 

Pricing Model (CAPM). DOE is considering using the same method for determining LCC 

 

16 The consumer discount rate is in contrast to the discount rates used in the national impact analysis, which are 

intended to represent the rate of return of capital in the U.S. economy as well as the societal rate of return on private 

consumption.

17 Available at: www.federalreserve.gov/pubs/oss/oss2/scfindex.html.
discount rates for this rulemaking. See chapter 8 of the TSD for the 2009 Lamps Rule for a more 

complete discussion of the discount rates. 

Item 20 DOE welcomes comments on the approach it is considering to conduct the LCC and 

PBP analyses.

 

10. Shipments Analysis 

DOE forecasts product shipments to calculate the national impacts of standards on energy

consumption, NPV, and future manufacturer cash flows. DOE plans to create shipment forecasts 

based on an analysis of key market drivers for GSFLs and IRLs. 

10.1 Base Case Forecast and Accounting Methodology 

To evaluate the various impacts of standards, DOE must develop a base case forecast 

against which to compare forecasts for higher efficacy levels. The base case forecast is designed 

to depict what will happen to energy consumption and energy costs over time if DOE does not 

adopt amended energy conservation standards for the products covered by this rulemaking. In 

determining the base case forecast, DOE will consider historical shipments, the mix of efficacies 

sold under current standards, and how that mix might change over time. 

In the 2009 Lamps Rule, NEMA provided shipment data on GSFL and IRL spanning 

from 2001 to 2005. 74 FR 34080, 34115-16 (July 14, 2009). DOE used this data to calculate an 

installed stock in 2005 and then projected the installed stock from 2006 to 2042. DOE based 

forecasted growth for GSFL and IRL on historical residential building growth from RECS and 

historical commercial and industrial floor space growth from CBECS and MECS (see Table 9.1). 

DOE then applied growth, replacement rate, and emerging technologies assumptions to develop 

shipments estimates over the analysis period. 

In this rulemaking, DOE plans to review NEMA data and any other data that becomes 

available to determine the most appropriate distribution of shipments among product classes and 

the most appropriate forecast for installed stock. Specifically, as it did for the 2009 Lamps Rule, 

DOE plans to follow a four-step process to forecast shipments. First, DOE would use 2001-to2005 historical shipment data from NEMA and other publicly-available sources to estimate the 

total historical shipments (i.e., NEMA member and non-NEMA member shipments) of each 

lamp type analyzed. Second, based on these historical shipments and the average service lifetime 

of each lamp type, DOE would calculate the installed stock of lamps in 2005. Third, by applying 

growth, emerging technologies, and shipment assumptions, DOE would project lamp stock from 

2017 to 2046. DOE would then calculate the lamp shipments required to meet the lamp stock 

projections based on operating hours and lifetimes. Finally, DOE would develop base-case and 

standards-case market-share matrices as another model input. The market-share matrices 

characterize the efficacy, power rating, light output, and lifetime of the lamp designs. For lamp 

and ballast retirements, DOE would use the same product lifetimes that it generates for the LCC 

and PBP analysis.
Item 21 DOE seeks information on historical shipments of GSFLs and IRLs for each product 

class covered under this rulemaking, as well as industry-trend data regarding relative growth in 

each product class.

10.2 Impacts of Standards on Shipments 

For each product class, DOE plans to forecast shipments over the 30-year analysis period 

for each of the potential standards analyzed. These standards case forecasts would be used to 

evaluate the impacts of standards on shipments. Standards case forecasts are derived using the 

same data-sets as base case forecasts; however, because the standards case forecasts take into 

account the increase in purchase price and the decrease in operating costs caused by new or 

amended standards, forecasted shipments could deviate from the base case. The magnitude of the 

difference between the standards case and base case shipment forecasts depends on the estimated 

purchase-price-increase as well as the operating-cost-savings caused by the standard. Because 

the purchase price tends to have a larger impact than operating cost on purchase decisions, 

standards case forecasts typically show a drop in shipments relative to the base case.

Programs such as consumer rebates that encourage the purchase of more-efficient 

products and manufacturer tax credits that encourage the production of more-efficient products 

also affect standards case forecasts. When such programs exist at the federal level, DOE 

considers their impact on the forecast of both standards case and base case shipments.

Item 22 DOE requests input on the potential impact of new energy conservation standards on 

shipments of GSFLs and IRLs. DOE also requests input on any other federal programs that 

currently exist to promote the adoption of more-efficient lamps. 

11. National Impact Analysis 

The NIA provides DOE’s assessment of the aggregate impacts of potential efficiency 

standards at the national level. Measures of impact that DOE will report include future NES from 

CSLs (i.e., the cumulative incremental primary energy savings from an increased energy 

conservation standard relative to a base case that assumes no change in the energy conservation 

national standard over a specific forecast period) and the NPV for consumers in the aggregate 

from CSLs (i.e., the cumulative incremental LCC from an increased energy conservation 

standard relative to the base case over a specific forecast period). 

11.1 Inputs to Forecasts 

Analyzing impacts of Federal energy conservation standards for products covered in this 

rule requires comparison of projected energy consumption in the United States with, and 

without, new energy conservation standards. The forecasts contain projections of unit energy 

consumption of new lamps, annual product shipments, the prices of purchased products, and 

base-case and standards-case forecasted efficacies. The base-case shipments forecasts are 

derived in section 10. Approaches to determine retail prices for products are described in section 

8, while approaches to determine unit energy consumption are described in section 7. Table 11.1

describes some of the major inputs DOE anticipates using for the NIA.
Table 11.1 Input to the National Impact Analysis 

Inputs Description 

Shipments Annual shipments based on DOE’s shipment forecasts.

Stock of GSFL and IRL Calculated from the GSFL and IRL service life developed in the 

Life-Cycle Cost analysis and annual shipments developed in the 

Shipments Analysis.

Standard Compliance 

Date 

2017 

Analysis Period 2017 to 2046 (30 years based on an estimate of the longest 

baseline lamp life in a certain product class divided by the annual 

operating hours of that lamp) 

Base-Case Forecasted 

Efficacy

Distribution of base-case shipments by efficacy level over time 

developed as described in the Shipment Analysis.

Standards-Case 

Forecasted Efficacy

Distribution of shipments by efficacy level for each standards 

case over time as described in the Shipment Analysis.

Unit Energy Consumption 

(kilowatt-hour (kWh)/yr) 

Established in the Energy-Use Characterization for each lamp 

analyzed.

Total Installed Cost Established in the product price determination and LCC Analysis 

for each lamp analyzed. 

Electricity Price Forecast Based on AEO2011 forecasts to 2030 and an extrapolation 

beyond 2030 

Energy Site-to-Source 

Conversion 

Varies yearly and is generated by DOE/ EIA’s National Energy 

Modeling System (NEMS) program (a time-series conversion 

factor; includes electric generation (by fuel), transmission, and 

distribution losses). Conversion factors beyond 2030 were held 

constant. 

Rebound Effect 1% of total energy savings in the commercial and industrial 

sectors. 8.5% of total energy savings in the residential sector. 

Discount Rate 3% and 7% real.

Present Year Future costs and savings will be discounted to 2012. 

The site-to-source conversion factor is the multiplicative factor DOE uses for converting 

site-energy consumption (the energy used at the end-use site) into primary or source energy 

consumption (the energy used at the source before transmission or conversion losses). For 

electricity, the conversion factors vary over time due to projected changes in generation sources 

(i.e., the power plant types projected to provide electricity to the country). As in the 2009 Lamps 

Rule, DOE intends to calculate annual average site-to-source conversion factors using 

DOE/EIA’s National Energy Modeling System (NEMS) program (a time-series conversion 

factor; includes electric generation, transmission, and distribution losses). 74 FR 34080, 34114-

15 (July 14, 2009). Conversion factors for beyond 2030 were held constant. See chapter 11 of the 

TSD for the 2009 Lamps Rule for a more complete discussion on site-to-source conversion. 

The rebound effect is another input to the NIA. Consumers that encounter lower 

operating costs associated with more energy-efficient products may use that product more often 

than the less-efficient product. DOE’s rebound effect analysis accounts for any increase in 

consumer use. As in the 2009 Lamps Rule, DOE plans to incorporate the rebound effect that 

occurs after installation of energy-efficient lighting equipment. 74 FR 34080, 34115 (July 14, 

2009) The existence of the rebound effect in certain (e.g. residential) markets is uncontroversial. 

However, debate continues as to the size and importance of the effect in real world situations. In 

the 2009 Lamps Rule, DOE examined a summary of the literature regarding the rebound effect in 
relation to lighting equipment. Based on four studies, the summary estimated that, for a 100 

percent increase in energy efficiency, values of “take-back” or rebound for residential lighting 

were between 5 and 12 percent of the energy consumption savings. In addition, with regards to a 

commercial firm’s response to higher-efficiency lighting, the summary estimated 0 to 2 percent

for values of rebound for lighting. Therefore, in the calculation of national energy savings due to 

energy conservation standards on lighting, DOE plans to use the rebound rate of 8.5 percent in 

the residential sector and 1 percent in the commercial sector estimated in the 2009 Lamps Rule. 

See chapter 11 of the TSD for the 2009 Lamps Rule for a more complete discussion on the 

rebound effect. 

Item 23 DOE welcomes comment on the data sources it anticipates using to develop inputs for 

the national impact analysis. 

Item 24 DOE welcomes comments on the quantitative and theoretical underpinnings of the 

rebound effect as well as results from newer studies of the size and sign of the rebound effect for 

residential, commercial, industrial, and municipal consumers. 

11.2 Calculation of National Energy Savings 

DOE intends to calculate national energy consumption for each year beginning with the 

expected compliance date of the standards. DOE would calculate national energy consumption 

for the base case and each standard level analyzed. DOE plans to perform this calculation 

through the use of a spreadsheet model that effectively multiplies annual stock forecasts by 

efficiency level (based on shipments and retirements in each year) by unit electricity use at the 

site of use, for each efficiency level. DOE then plans to multiply the site electricity use by yearby-year marginal site-to-source conversion factors that account for energy losses in generation, 

transmission, and distribution of electricity in order to estimate national primary energy savings. 

As in the 2009 Lamps Rule, DOE would base the site-to-source conversion factors on modeled 

savings of primary energy in the electric utility industry of EIA’s National Energy Modeling 

System (NEMS) that corresponds to EIA most recent Annual Energy Outlook. DOE plans to use 

the same methodology for this rulemaking. 

In response to comments by interested parties who asked for a simple, transparent model, 

DOE developed NES spreadsheet models for its standards rulemakings starting in 1996. These 

models project energy savings and demonstrate how to account for the growth in efficiency over 

time.18 See chapter 11 of the TSD for the 2009 Lamps Rule for a more complete discussion on 

the NES calculation. DOE expects the NES spreadsheet model to provide a credible, stand-alone 

forecast of national energy savings and aggregate consumer NPV for GSFLs and IRLs. Based on 

consideration of comments DOE may receive on the preliminary analysis, DOE will make any 

necessary changes to the analysis. It will reflect those changes in the NOPR. 

 

18 Several examples of NES spreadsheet models from previous rulemakings can be found on DOE’s website at 

www.eere.energy.gov/buildings/appliance_standards
Item 25 DOE welcomes comments on the NES spreadsheet models it plans to use for estimating 

national impacts of amended energy conservation standards for GSFLs and IRLs. DOE also 

welcomes comments on the inputs to the models and the sources used for determining the inputs. 

11.3 Net Present Value 

DOE calculates the national net present value (NPV) of the standards in conjunction with 

the NES. It calculates annual energy expenditures from annual energy consumption by 

incorporating forecasted energy prices, using the shipment forecasts described in the Shipment 

Analysis and electricity savings forecasts. DOE calculates annual product expenditures by 

multiplying the price per unit by the forecasted shipments. The difference between a base case 

and a standards case scenario gives the national energy bill savings and increased product 

expenditures in dollars. The difference each year between energy bill savings and increased 

product expenditures is the net savings (if positive) or net cost (if negative). DOE discounts these 

annual values to the present time and sums them to give an NPV. Since the national cost of 

capital may differ from the consumer cost of capital, the discount rate used in the NIA can be 

different from the rate used in the LCC. In accordance with OMB guidance, DOE will conduct 

two NPV calculations, one using a real discount rate of 3 percent and another using a real 

discount rate of 7 percent.19 Based on consideration of the comments received for the 

preliminary analysis, DOE will make any necessary changes to the analysis and the CSLs.

Item 26 DOE welcomes comments on the inputs and methodology to calculate NES and NPV. 

12. Life-Cycle Cost Subgroup Analysis 

The LCC (consumer) subgroup analysis evaluates economic impacts on selected groups 

of consumers who might be adversely affected by a change in the national energy conservation 

standards for the considered products. DOE evaluates impacts on particular subgroups of 

consumers primarily by analyzing the LCC impacts and PBP for those particular consumers. For 

this rulemaking, DOE intends to evaluate impacts of standards on low-income consumers, 

institutions of religious worship, and institutions serving low-income consumers. In the 2009 

Lamps Rule DOE defined low-income consumers as residential consumers with incomes at or 

below the poverty line as defined by the U.S. Census Bureau. DOE seeks input regarding which 

consumer subgroups it should consider in this rulemaking. 

In comparing potential impacts on the different consumer subgroups, DOE will evaluate 

variations in energy prices, energy use, and installation costs that might affect the impacts of a 

standard on the consumer subgroups. 

Item 27 DOE plans to assess the impacts on low-income households, institutions of religious 

worship, and institutions serving low-income consumers, and seeks input regarding which other 

consumer subgroups it should consider in this rulemaking. 

 

19 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003).
13. Manufacturer Impact Analysis 

The purpose of the MIA is to identify and quantify the likely impacts of amended energy 

conservation standards on manufacturers of GSFLs and IRLs. During the NOPR stage of 

analysis, DOE will analyze and consider a wide range of quantitative and qualitative industry 

impacts that may occur due to amended energy conservation standards. DOE will identify and 

analyze these impacts through industry research, public comments, and interviews with 

manufacturers and other interested parties. Other sources of information will include reports 

published by industry groups, trade journals, the U.S. Census Bureau, and U.S. Securities and 

Exchange Commission (SEC) 10-K filings. 

Initially, DOE will profile the covered GSFL and IRL industry by updating pertinent 

qualitative and quantitative financial and market information, including industry cost structures, 

employment metrics, and competitive behavior. Next, DOE will conduct detailed interviews with 

manufacturers of the covered lamps to gain insight into the potential impact of amended 

standards on sales, direct employment, capital assets, and industry competitiveness. DOE will 

use the information gathered in the industry profile to facilitate discussion with manufacturers on 

production costs, shipment projections, product mix, conversion costs, markups, competitive 

impacts, manufacturing capacity, and other relevant information. Because standards may have 

differential impacts on groups of manufacturers with different cost structures or business models, 

DOE will also identify and characterize any such subgroups during interviews. 

DOE is aware that amended standards may require additional investment, raise 

production costs, and affect manufacturers’ revenue through higher prices. To quantify these 

potential impacts on manufacturers, DOE will calculate standards-induced changes in industry 

and subgroup cash flows using the Government Regulatory Impact Model (GRIM). The model 

results will enable DOE to derive a base-case and standards-case industry net present value. To 

quantitatively assess the impacts of energy conservation standards on manufacturing 

employment, DOE will use GRIM to estimate the impact on domestic labor expenditures and 

number of employees. The inputs to the GRIM will include financial information, manufacturing 

costs, shipment forecasts, and price forecasts from other analyses. Based on the information 

gathered during interviews and other research, DOE will assess impacts on competition, 

manufacturing capacity, employment, and regulatory burden. 

Item 28 DOE welcomes comments on its methodology for assessing the impacts on 

manufacturers of products covered under this rulemaking. DOE also requests information on 

manufacturing costs. 

14. Utility Impact Analysis 

To estimate the effects of energy conservation standards for covered GSFLs and IRLs on 

the electric utility industry, DOE plans to use a variant of EIA’s NEMS that is tailored to DOE’s 

Building Technologies Program (NEMS-BT). The utility impact analysis is a comparison 

between the NEMS-BT model results for the base case (the AEO reference case from the latest 

year available) and standards cases. The utility impact analysis reports the changes in installed 

electric capacity and generation that result for each standard level by plant type. DOE will model 
the impacts from amended energy conservation standards using NEMS-BT to generate standards 

case forecasts.20 

Item 29 DOE welcomes comments on the approach it is considering to assess the impacts of 

potential standards under this rulemaking on electric utilities. 

15. Employment Impact Analysis 

The promulgation of energy conservation standards can affect employment both directly 

and indirectly. Direct employment impacts, often occurring as a result of manufacturing process 

changes, are changes in the number of employees at the plants that produce the covered products, 

along with employment at affiliated distribution and service companies, resulting from the 

standards. DOE will evaluate direct employment impacts through the use of the GRIM in the 

MIA (see section 13 for more information). 

Indirect employment impacts may result from expenditures shifting between goods (the 

substitution effect) and changes in income and overall expenditure levels (the income effect) that 

occur due to the standards. DOE defines indirect employment impacts from standards as net jobs 

eliminated or created in the general economy as a result of increased spending driven by the 

increased product prices and reduced spending on energy. 

The indirect employment impacts will be investigated in the employment impact analysis 

using an input/output model of the U.S. economy called Impact of Sector Energy Technologies 

(ImSET), version 3.1.1. ImSET is a spreadsheet model of the U.S. economy that focuses on 187 

sectors most relevant to industrial, commercial, and residential building energy use.21 ImSET is a 

special purpose version of the “U.S. Benchmark National Input-Output” (I–O) model, designed 

to estimate the national employment and income effects of energy-saving technologies. The 

ImSET software includes a computer-based I–O model with structural coefficients to 

characterize economic flows among the 187 sectors. ImSET’s national economic I–O structure is 

based on a 1997 U.S. benchmark table22 (specially aggregated to the 187 sectors. DOE will 

estimate changes in expenditures using the NIA spreadsheet and using ImSET, DOE will 

estimate the net national, indirect-employment impacts by sector. 

Item 30 DOE welcomes comments on the approach it is considering to assess indirect 

employment impacts as a result of energy conservation standards. 

16. Environmental Assessment

 

20 Several descriptions of NEMS-BT models from previous rulemakings, including general service fluorescent 

lamps and incandescent reflector lamps, can be found on DOE’s website at: 

www.eere.energy.gov/buildings/appliance_standards/residential/pdfs/ch_14_lamps_standards_final_tsd.pdf. 21 Roop, J. M., M. J. Scott, and R. W. Schultz, ImSET 3.1: Impact of Sector Energy Technologies (PNNL-18412 

Pacific Northwest National Laboratory) (2008). Available at 

www.pnl.gov/main/publications/external/technical_reports/PNNL-18412.pdf. 22 Lawson, Ann M., Kurt S. Bersani, Mahnaz Fahim-Nader, and Jiemin Guo, “Benchmark Input-Output Accounts of 

the U.S. Economy, 1997,” Survey of Current Business (Dec. 2002) pp. 19–117
Pursuant to the National Environmental Policy Act of 1969 and the requirements of 42 

U.S.C. 6295(o)(2)(B)(i)(VI) and 6316(a), DOE intends to prepare an environmental assessment 

of the impacts of amended energy conservation standards for the GSFL and IRL covered by this 

rulemaking. The primary environmental effects of these standards would be reduced power plant 

emissions resulting from reduced consumption of electricity. DOE will assess these 

environmental effects by using NEMS-BT to provide key inputs to its analysis. The portion of 

the environmental assessment that will be produced by NEMS-BT considers carbon dioxide 

(CO2), nitrogen oxides (NOx), and mercury (Hg). The environmental assessment also considers 

impacts on SO2

17

emissions and discusses particulate matter (PM) emissions. After a brief 

discussion of general methodology, this section will address each of the relevant emissions. The 

following section, section , explains how DOE plans to monetize the benefits associated with 

emissions reductions. 

16.1 Carbon Dioxide 

In the absence of any Federal emissions control regulation of power plant emissions of 

CO2, a DOE standard is likely to result in reductions of these emissions. The CO2 emission 

reductions likely to result from a standard will be estimated using NEMS-BT and national energy 

savings estimates drawn from the NIA spreadsheet model. The net benefit of the standard is the 

difference between emissions estimated by NEMS-BT at each standard level considered and the 

AEO Reference Case. NEMS-BT tracks CO2

16.2 Sulfur Dioxide

 emissions using a detailed module that provides 

results with broad coverage of all sectors and inclusion of interactive effects. 

SO2 emissions from affected electric generating units (EGUs) are subject to nationwide 

and regional emissions cap and trading programs, and DOE has preliminarily determined that 

these programs create uncertainty about the potential standards’ impact on SO2 emissions. Title 

IV of the Clean Air Act sets an annual emissions cap on SO2 for affected EGUs in the 48 

contiguous states and the District of Columbia (D.C.). SO2 emissions from 28 eastern states and 

D.C. are also limited under the Clean Air Interstate Rule (CAIR, 70 Fed. Reg. 25162 (May 12, 

2005)), which created an allowance-based trading program. 23

The attainment of emissions caps is typically flexible among EGUs and is enforced 

through the use of emissions allowances and tradable permits. Under existing EPA regulations, 

and under the proposed Transport Rule, any excess SO2 emissions allowances resulting from the 

lower electricity demand caused by the imposition of an efficiency standard could be used to 

permit offsetting increases in SO2

 

23 CAIR was remanded to EPA by the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit), see 

North Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008), and remained in effect consistent with the D.C. Circuit’s 

earlier opinion in North Carolina v. EPA, 531 F.3d 896 (D.C. Cir. 2008). On July 6, 2010, EPA issued the Transport 

Rule proposal, a replacement for CAIR, which would limit emissions from EGUs in 32 states, potentially through 

the interstate trading of allowances, among other options. 75 FR 45210 (Aug. 2, 2010) and 76 FR 48208 (August 8, 

2011). On July 6, 2011, EPA issued the final transport rule, entitled the Cross-State Air Pollution Rule 

(

 emissions by any regulated EGU. However, if the standard 

resulted in a permanent increase in the quantity of unused emissions allowances, there would be 

http://www.epa.gov/airtransport/, last visited July 15, 2011). DOE will consider the impacts of this rule in its 

analyses as appropriate. 
an overall reduction in SO2 emissions from the standards. While there remains some uncertainty 

about the ultimate effects of efficiency standards on SO2 emissions covered by the existing cap

and trade system, the NEMS-BT modeling system that DOE uses to forecast emissions 

reductions currently indicates that no physical reductions in power sector emissions would occur 

for SO2. 24

16.3 Nitrogen Oxides

A cap on NOx emissions, affecting electric generating units in the CAIR region, would 

mean that the standards for GSFL and IRL may have little or no physical effect on NOx

emissions in the 28 eastern states and the D.C. covered by CAIR or any states covered by the 

proposed Transport Rule.. The standards would, however, reduce NOx emissions in those 22 

states not affected by the CAIR. As a result, DOE plans to use NEMS-BT to estimate the 

emissions reductions from possible standards in the states where emissions are not capped.25

16.4 Mercury

Similar to emissions of SO2 and NOx, future emissions of Hg would have been subject to 

emissions caps. In May 2005, EPA issued the Clean Air Mercury Rule (CAMR). 70 FR 28606 

(May 18, 2005). CAMR would have permanently capped emissions of mercury for new and 

existing coal-fired power plants in all states by 2010. However, on February 8, 2008, the D.C. 

Circuit issued a decision in New Jersey v. Environmental Protection Agency, in which it vacated 

CAMR. 517 F.3d 574 (D.C. Cir. 2008). EPA has decided to develop emissions standards for 

power plants under the Clean Air Act (Section 112), consistent with the D.C. Circuit’s opinion 

on CAMR. See http://www.epa.gov/air/mercuryrule/pdfs/certpetition_withdrawal.pdf. Pending 

EPA's forthcoming revisions to the rule, DOE is excluding CAMR from its environmental 

assessment. In the absence of CAMR, a DOE standard would likely reduce Hg emissions and 

DOE plans to use NEMS-BT to estimate these emission reductions. However, DOE continues to 

review the impact of rules that reduce energy consumption on Hg emissions, and may revise its 

assessment of Hg emission reductions in future rulemakings. 

16.5 Particulate Matter

DOE acknowledges that particulate matter (PM) exposure can impact human health. 

Power plant emissions can have either direct or indirect impacts on PM. A portion of the 

pollutants emitted by a power plant are in the form of particulates as they leave the smoke stack. 

These are direct, or primary, PM emissions. However, the great majority of PM emissions 

associated with power plants are in the form of secondary sulfates, which are produced at a 

significant distance from power plants by complex atmospheric chemical reactions that often 

involve the gaseous (non-particulate) emissions of power plants, mainly SO2 and NOx. The 

quantity of the secondary sulfates produced is determined by a very complex set of factors 

including the atmospheric quantities of SO2 and NOx

 

24 As noted above, EPA issued the Cross-State Air Pollution Rule on July 6, 2011. DOE will determine the impacts 

of this regulation on its analyses in this rulemaking. 

, and other atmospheric constituents and 

conditions. Because these highly complex chemical reactions produce PM comprised of different 

constituents from different sources, EPA does not distinguish direct PM emissions from power 

25 DOE will also determine the impacts of the Cross-State Air Pollution rule on its NOx analysis. 
plants from the secondary sulfate particulates in its ambient air quality requirements, PM 

monitoring of ambient air quality, or PM emissions inventories. For these reasons, it is not 

currently possible to determine how the amended standard impacts either direct or indirect PM 

emissions. Therefore, DOE is not planning to assess the impact of these standards on PM 

emissions. Further, as described previously, it is uncertain whether efficiency standards will 

result in a net decrease in power plant emissions of SO2, which are now largely regulated by cap 

and trade systems. 

Item 31 DOE seeks input on its plans to use NEMS-BT to conduct the environmental assessment 

for the products covered by this rulemaking. 

17. Monetizing Carbon Dioxide and Other Emissions Reductions

DOE plans to consider the estimated monetary benefits likely to result from the reduced 

emissions of CO2 and NOX that are expected to result from each of the standard levels 

considered. 

 In order to estimate the monetary value of benefits resulting from reduced emissions of 

CO2, DOE plans to use the most current Social Cost of Carbon (SCC) values developed and/or 

agreed to by an interagency process. The SCC is intended to be a monetary measure of the 

incremental damage resulting from greenhouse gas (GHG) emissions, including, but not limited 

to, net agricultural productivity loss, human health effects, property damage from sea level rise, 

and changes in ecosystem services. Any effort to quantify and to monetize the harms associated 

with climate change will raise serious questions of science, economics, and ethics. But with full 

regard for the limits of both quantification and monetization, the SCC can be used to provide 

estimates of the social benefits of reductions in GHG emissions. 

At the time of this notice, the most recent interagency estimates of the potential global 

benefits resulting from reduced CO2 emissions in 2010, expressed in 2010$, were $4.9, $22.3, 

$36.5, and $67.6 per metric ton avoided. For emissions reductions that occur in later years, these 

values grow in real terms over time. Additionally, the interagency group determined that a range 

of values from 7 percent to 23 percent should be used to adjust the global SCC to calculate 

domestic effects, although DOE will give preference to consideration of the global benefits of 

reducing CO2

 

emissions. To calculate a present value of the stream of monetary values, DOE 

will discount the values in each of the four cases using the discount rates that had been used to 

obtain the SCC values in each case.

 DOE recognizes that scientific and economic knowledge continues to evolve rapidly as to 

the contribution of CO2

 

and other GHG to changes in the future global climate and the potential 

resulting damages to the world economy. Thus, these values are subject to change. 

DOE also intends to estimate the potential monetary benefit of reduced NOX emissions 

resulting from the standard levels it considers. For NOx emissions, available estimates suggest a 

very wide range of monetary values for NOX emissions, ranging from $450 to $4,623 per ton in 
2010$).26 In accordance with U.S. Office of Management and Budget (OMB) guidance, DOE 

will conduct two calculations of the monetary benefits derived using each of the economic values 

used for NOx, one using a real discount rate of 3 percent and another using a real discount rate of 

7 percent.27

 

 DOE does not plan to monetize estimates of Hg in this rulemaking. DOE is aware of 

multiple agency efforts to determine the appropriate range of values used in evaluating the 

potential economic benefits of reduced Hg emissions. DOE has decided to await further guidance 

regarding consistent valuation and reporting of Hg emissions before it once again monetizes Hg 

in its rulemakings.

18. Regulatory Impact Analysis 

In the NOPR and final rule stages of this rulemaking, DOE will prepare a regulatory 

impact analysis, which addresses the potential for non-regulatory approaches to supplant or 

augment energy conservation standards to improve the efficacy of GSFL and IRL on the market. 

DOE recognizes that voluntary or other non-regulatory efforts by manufacturers, utilities, and 

other interested parties can result in substantial efficiency improvements. DOE intends to 

analyze the likely effects of non-regulatory initiatives on product energy use, consumer utility, 

and LCC. DOE will attempt to base its assessment on the actual impacts of any such initiatives to 

date, but will also consider historical information presented regarding the impacts that any 

existing initiative might have in the future. DOE will use the NES spreadsheet model to calculate 

the NES and NPV for the non-regulatory alternatives.

Item 32 DOE welcomes comments on the methodology it is considering for the regulatory impact 

analysis.

APPENDIX A – LIST OF ITEMS FOR COMMENT 

Item 1 DOE welcomes comment on establishing a new metric for IRL standards. ....................... 3

Item 2 DOE welcomes comment on additional GSFLs and IRLs that should be included for this 

rulemaking. For suggested additional lamp types, DOE requests market and shipment 

information as well as potential for efficacy improvements and energy savings. ........................ 11

Item 3 DOE welcomes information on shipments, product-feature and efficiency trends, 

distribution channels and estimates of market shares for the lamps considered in this 

rulemaking. For the data to be used to conduct energy savings calculations, please provide 

appropriate groupings (e.g., by product class and wattage). ....................................................... 13

 

26 For additional information, refer to U.S. Office of Management and Budget, Office of Information and Regulatory 

Affairs, 2006 Report to Congress on the Costs and Benefits of Federal Regulations and Unfunded Mandates on 

State, Local, and Tribal Entities, Washington, DC. 27 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003).
Item 4 DOE welcomes comment on the product classes it is considering for general service 

fluorescent lamps. In particular, DOE welcomes comment on maintaining separate product 

classes for T5 lamps. ..................................................................................................................... 14

Item 5 DOE welcomes comment on the product classes it is considering for incandescent 

reflector lamps. ............................................................................................................................. 15

Item 6 DOE welcomes comments on all of the technology options it is considering for this rule, 

including any omissions or revisions for the GSFLs and IRLs covered in this rulemaking. DOE 

also requests information on the feasibility, performance, impacts, and cost of the technology 

options—especially those reflecting recent technological developments. .................................... 17

Item 7 DOE welcomes comments regarding the technologies that were screened out for the 2009 

Lamps Rule, including whether it is still appropriate to screen out these technologies and 

whether any additional technology options should be screened out for this rule. ....................... 19

Item 8 DOE welcomes comments on the overall methodology for the engineering analysis....... 20

Item 9 DOE welcomes comments on the product classes that it has selected to analyze as 

representative for this rulemaking. ............................................................................................... 20

Item 10 DOE welcomes comments on the baseline lamps it is considering for GSFLs in this 

rulemaking and whether they are representative of products sold on the market in 2012. In 

particular, DOE requests comment on whether the baseline lamps under consideration have 

lower efficacies than their catalog-rated efficacy values. Additionally, DOE requests comment 

on whether it is appropriate to analyze only a T8 baseline for GSFL. ......................................... 23

Item 11 DOE welcomes comments on the baseline lamps it is considering for IRLs in this 

rulemaking and whether they are representative of the products expected to be sold on the 

market in 2012. In particular, DOE requests comment on the expected lifetime and wattage of 

IRL................................................................................................................................................. 23

Item 13 DOE also welcomes comments on the potential efficacy levels identified and whether 

higher efficacy levels can be achieved through redesign of commercially available product. In 

addition DOE requests comments on whether GSFL efficacy levels should be based on reducedwattage lamps. .............................................................................................................................. 25

Item 15 DOE welcomes comments on proprietary designs it should be aware of for the GSFLs 

and IRLs that are the subject of this rulemaking. ......................................................................... 26

Item 16 DOE welcomes comments on regulatory burdens or changes that should be considered 

in the engineering analysis. .......................................................................................................... 27

Item 17 DOE welcomes comments on other engineering issues that could affect the engineering 

analysis. ........................................................................................................................................ 27
Item 18 DOE welcomes comments on the methodology it is considering to determine energy use. 

In particular, DOE requests comments on its approach to calculate operating hours for the 

covered lamps. .............................................................................................................................. 28

Item 19 DOE welcomes comments on the methodology it is considering for lamp prices and 

sales tax estimates for this rulemaking. DOE also welcomes comment on the price forecasting 

methodologies it is considering. ................................................................................................... 29

Item 20 DOE welcomes comments on the approach it is considering to conduct the LCC and 

PBP analyses. ............................................................................................................................... 34

Item 21 DOE seeks information on historical shipments of GSFLs and IRLs for each product 

class covered under this rulemaking, as well as industry-trend data regarding relative growth in 

each product class......................................................................................................................... 35

Item 23 DOE welcomes comment on the data sources it anticipates using to develop inputs for 

the national impact analysis. ........................................................................................................ 37

Item 24 DOE welcomes comments on the quantitative and theoretical underpinnings of the 

rebound effect as well as results from newer studies of the size and sign of the rebound effect for 

residential, commercial, industrial, and municipal consumers. ................................................... 37

Item 25 DOE welcomes comments on the NES spreadsheet models it plans to use for estimating 

national impacts of amended energy conservation standards for GSFLs and IRLs. DOE also 

welcomes comments on the inputs to the models and the sources used for determining the inputs.

....................................................................................................................................................... 38

Item 26 DOE welcomes comments on the inputs and methodology to calculate NES and NPV. 38

Item 27 DOE plans to assess the impacts on low-income households, institutions of religious 

worship, and institutions serving low-income consumers, and seeks input regarding which other 

consumer subgroups it should consider in this rulemaking.......................................................... 38

Item 28 DOE welcomes comments on its methodology for assessing the impacts on 

manufacturers of products covered under this rulemaking. DOE also requests information on 

manufacturing costs. ..................................................................................................................... 39

Item 29 DOE welcomes comments on the approach it is considering to assess the impacts of 

potential standards under this rulemaking on electric utilities. ................................................... 40

Item 30 DOE welcomes comments on the approach it is considering to assess indirect 

employment impacts as a result of energy conservation standards. ............................................. 40

Item 31 DOE seeks input on its plans to use NEMS-BT to conduct the environmental assessment 

for the products covered by this rulemaking. ................................................................................ 43

Item 32 DOE welcomes comments on the methodology it is considering for the regulatory impact 

analysis. ........................................................................................................................................ 44
APPENDIX B – DEFINITIONS

This appendix provides the CFR (10 CFR section 430.2) and U.S.C. (statutory) (42 U.S.C. 

6291(30)) definitions for the products covered under this rulemaking. 

The definitions are as follows: 

Color Terms

The term “color rendering index” or “CRI” means the measure of the degree of color 

shift objects undergo when illuminated by a light source as compared with the color of 

those same objects when illuminated by a reference source of comparable color 

temperature. 

42 U.S.C. 6291(30)(J) 

The term “correlated color temperature” or “CCT” means the absolute temperature of a 

blackbody whose chromaticity most nearly resembles that of the light source. 

42 U.S.C. 6291(30)(K) 

Efficacy

The term “lamp efficacy” means the lumen output of a lamp divided by its wattage, 

expressed in lumens per watt (LPW). 

42 U.S.C. 6291(30)(M) 

Lamp Efficacy (LE) means the measured lumen output of a lamp in lumens divided by 

the measured lamp electrical power input in watts expressed in units of lumens per watt 

(LPW).

10 CFR 430.2 

Fluorescent Lamps 

The term “fluorescent lamp” means a low pressure mercury electric-discharge source in 

which a fluorescing coating transforms some of the ultraviolet energy generated by the 

mercury discharge into light, including only the following: 

(i) Any straight-shaped lamp (commonly referred to as 4-foot medium bi-pin 

lamps) with medium bi-pin bases of nominal overall length of 48 inches and rated 

wattage of 28 or more. 

(ii) Any U-shaped lamp (commonly referred to as 2-foot U-shaped lamps) with 

medium bi-pin bases of nominal overall length between 22 and 25 inches and 

rated wattage of 28 or more. 

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

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

nominal amperes, as defined in ANSI C78.1–1978 and related supplements. 
(iv) Any instant start lamp (commonly referred to as 8-foot slimline lamps) with 

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

more, as defined in ANSI C78.3–1978 (R1984) and related supplement ANSI 

C78.3a–1985. 

42 U.S.C. 6291(30)(A) 

Fluorescent lamp means a low pressure mercury electric-discharge source in which a 

fluorescing coating transforms some of the ultraviolet energy generated by the mercury 

discharge into light, including only the following: 

(1) Any straight-shaped lamp (commonly referred to as 4-foot medium bipin 

lamps) with medium bipin bases of nominal overall length of 48 inches and rated 

wattage of 25 or more; 

(2) Any U-shaped lamp (commonly referred to as 2-foot U-shaped lamps) with 

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

wattage of 25 or more; 

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

recessed double contact bases of nominal overall length of 96 inches; 

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

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

more;

(5) Any straight-shaped lamp (commonly referred to as 4-foot miniature bipin 

standard output lamps) with miniature bipin bases of nominal overall length 

between 45 and 48 inches and rated wattage of 26 or more; and

(6) Any straight-shaped lamp (commonly referred to 4-foot miniature bipin high 

output lamps) with miniature bipin bases of nominal overall length between 45 

and 48 inches and rated wattage of 49 or more. 

10 CFR 430.2 

Rated wattage means:

(1) With respect to fluorescent lamps and general service fluorescent lamps:

(i) If the lamp is listed in ANSI C78.81 (incorporated by reference; see §430.3) or 

ANSI C78.901 (incorporated by reference; see §430.3), the rated wattage of a 

lamp determined by the lamp designation of Clause 11.1 of ANSI C78.81 or 

ANSI C78.901; 

(ii) If the lamp is a residential straight-shaped lamp, and not listed in ANSI 

C78.81 (incorporated by reference; see §430.3), the wattage of a lamp when 

operated on a reference ballast for which the lamp is designed; or 

(iii) If the lamp is neither listed in one of the ANSI standards referenced in (1)(i) 

of this definition, nor a residential straight-shaped lamp, the electrical power of a 

lamp when measured according to the test procedures outlined in appendix R to 

subpart B of this part. 

10 CFR 430.2 

General Service Fluorescent Lamp
The term “general service fluorescent lamp” means fluorescent lamps which can be used 

to satisfy the majority of fluorescent applications, but does not include any lamp designed 

and marketed for the following nongeneral lighting applications: 

(i) Fluorescent lamps designed to promote plant growth. 

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

(iii) Colored fluorescent lamps. 

(iv) Impact-resistant fluorescent lamps. 

(v) Reflectorized or aperture lamps. 

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

(vii) Lamps primarily designed to produce radiation in the ultra-violet region of 

the spectrum. 

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

42 U.S.C. 6291(30)(B) 

General service fluorescent lamp means any fluorescent lamp which can be used to 

satisfy the majority of fluorescent lighting applications, but does not include any lamp 

designed and marketed for the following nongeneral application: 

(1) Fluorescent lamps designed to promote plant growth;

(2) Fluorescent lamps specifically designed for cold temperature applications;

(3) Colored fluorescent lamps; 

(4) Impact-resistant fluorescent lamps;

(5) Reflectorized or aperture lamps;

(6) Fluorescent lamps designed for use in reprographic equipment; 

(7) Lamps primarily designed to produce radiation in the ultra-violet region of the 

spectrum; and

(8) Lamps with a Color Rendering Index of 87 or greater. 

10 CFR 430.2 

Cold temperature fluorescent lamp means a fluorescent lamp specifically designed to 

start at −20 °F when used with a ballast conforming to the requirements of ANSI C78.81 

(incorporated by reference; see §430.3) and ANSI C78.901 (incorporated by reference; 

see §430.3), and is expressly designated as a cold temperature lamp both in markings on 

the lamp and in marketing materials, including catalogs, sales literature, and promotional 

material.

10 CFR 430.2 

Colored fluorescent lamp means a fluorescent lamp designated and marketed as a colored 

lamp and not designed or marketed for general illumination applications with either of 

the following characteristics:

(1) A CRI less than 40, as determined according to the method set forth in CIE 

Publication 13.3 (incorporated by reference; see §430.3); or 

(2) A correlated color temperature less than 2,500K or greater than 7,000K as 

determined according to the method set forth in IESNA LM–9 (incorporated by 

reference; see §430.3). 

10 CFR 430.2 
Incandescent Reflector Lamp

The term “incandescent reflector lamp” means a lamp described in subparagraph (C)(ii). 

42 U.S.C. 6291(30)(F) 

... 

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

rough or vibration service applications, that contains an inner reflective coating on the 

outer bulb to direct the light, an R, PAR, ER, BR, BPAR, or similar bulb shapes with E26 

medium screw bases, a rated voltage or voltage range that lies at least partially within 115 

and 130 volts, a diameter which exceeds 2.25 inches, and has a rated wattage that is 40 

watts or higher. 

42 U.S.C. 6291(30)(C)(ii) 

Incandescent reflector lamp (commonly referred to as a reflector lamp) means any lamp 

in which light is produced by a filament heated to incandescence by an electric current, 

which: is not colored or designed for rough or vibration service applications that contains 

an inner reflective coating on the outer bulb to direct the light; has an R, PAR, ER, BR, 

BPAR, or similar bulb shapes with an E26 medium screw base; has a rated voltage or 

voltage range that lies at least partially in the range of 115 and 130 volts; has a diameter 

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

10 CFR 430.2 

BPAR incandescent reflector lamp means a reflector lamp as shown in figure C78.21–

278 on page 32 of ANSI C78.21–2003 (incorporated by reference; see §430.3). 

BR incandescent reflector lamp means a reflector lamp that has— 

(1) A bulged section below the major diameter of the bulb and above the approximate 

baseline of the bulb, as shown in figure 1 (RB) on page 7 of ANSI C79.1–1994, 

(incorporated by reference, see §430.3); and 

(2) A finished size and shape shown in ANSI C78.21–1989 (incorporated by reference; 

see §430.3), including the referenced reflective characteristics in part 7 of ANSI C78.21–

1989. 

ER incandescent reflector lamp means a reflector lamp that has— 

(1) An elliptical section below the major diameter of the bulb and above the approximate 

baseline of the bulb, as shown in figure 1 (RE) on page 7 of ANSI C79.1–1994, 

(incorporated by reference; see §430.3); and 

(2) A finished size and shape shown in ANSI C78.21–1989, (incorporated by reference; 

see §430.3). 

Colored incandescent lamp means an incandescent lamp designated and marketed as a 

colored lamp that has— 

(1) A color rendering index of less than 50, as determined according to the test method 

given in CIE 13.3 (incorporated by reference; see §430.3); or 

(2) A correlated color temperature of less than 2,500K, or greater than 4,600K, where 

correlated temperature is computed according to the “Computation of Correlated Color 
Temperature and Distribution Temperature,” Journal of the Optical Society of America, 

(incorporated by reference; see §430.3). 

Rough or vibration service incandescent reflector lamp means a reflector lamp: in which 

a C–11 (5 support), C–17 (8 support), or C–22 (16 support) filament is mounted (the 

number of support excludes lead wires); in which the filament configuration is as shown 

in Chapter 6 of the 1993 Illuminating Engineering Society of North America Lighting 

Handbook, 8th Edition (see 10 CFR 430.22); and that is designated and marketed 

specifically for rough or vibration service applications. 

10 CFR 430.2 

APPENDIX C – EPCA DIRECTIVES ON FLUORESCENT AND INCANDESCENT 

LAMPS

This appendix provides a copy of the current requirements the EPCA sets forth for the 

Department regarding fluorescent and incandescent lamps under EPCA, 42 U.S.C. 6295(i), as 

well as those prescribed in the Code of Federal Regulations (CFR) at 10 CFR 430.32(n). 

The following are the relevant requirements set forth in 42 U.S.C. 6295(i): 

General service fluorescent lamps, general service incandescent lamps, intermediate base 

incandescent lamps, candelabra base incandescent lamps, and incandescent reflector 

lamps 

(1) Standards.— 

(A) Definition of effective date.— In this paragraph (other than subparagraph 

(D)), the term “effective date” means, with respect to each type of lamp specified 

in a table contained in subparagraph (B), the last day of the period of months 

corresponding to that type of lamp (as specified in the table) that follows October 

24, 1992. 

(B) Minimum standards.— Each of the following general service fluorescent 

lamps and incandescent reflector lamps manufactured after the effective date 

specified in the tables contained in this paragraph shall meet or exceed the 

following lamp efficacy and CRI standards: 

FLUORESCENT LAMPS 

Lamp Type Nominal 

Lamp 

Wattage

Minimum 

CRI

Minimum Average 

Lamp Efficacy 

(LPW)

Effective 

Date 

(Months)

4-foot medium 

bi-pin 

35 W 69 75.0 36

35 W 45 75.0 36

2-foot U-shaped 35 W 69 68.0 36

35 W 45 64.0 36

8-foot slimline 65 W 69 80.0 18

65 W 45 80.0 18
8-foot high 

output 

100 W 69 80.0 18

100 W 45 80.0 18

INCANDESCENT REFLECTOR LAMPS 

Nominal 

Lamp 

Wattage

Minimum Average Lamp 

Efficacy (LPW) 

Effective Date (Months)

40–50 10.5 36

51–66 11.0 36

67–85 12.5 36

86–115 14.0 36

116–155 14.5 36

156–205 15.0 36

(C) Exemptions.— The standards specified in subparagraph (B) shall not apply to 

the following types of incandescent reflector lamps: 

(i) Lamps rated at 50 watts or less that are ER30, BR30, BR40, or ER40 lamps. 

(ii) Lamps rated at 65 watts that are BR30, BR40, or ER40 lamps. 

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

(D) Effective dates.— 

(i) ER, br, and bpar lamps.— The standards specified in subparagraph (B) shall 

apply with respect to ER incandescent reflector lamps, BR incandescent reflector 

lamps, BPAR incandescent reflector lamps, and similar bulb shapes on and after 

January 1, 2008. 

(ii) Lamps between 2.25–2.75 inches in diameter.—The standards specified in 

subparagraph (B) shall apply with respect to incandescent reflector lamps with a 

diameter of more than 2.25 inches, but not more than 2.75 inches, on and after the 

later of January 1, 2008, or the date that is 180 days after December 19, 2007. 

(2) Notwithstanding section 6302 (a)(5) of this title and section 6302 (b) of this title, it 

shall not be unlawful for a manufacturer to sell a lamp which is in compliance with the 

law at the time such lamp was manufactured. 

(3) Not less than 36 months after October 24, 1992, the Secretary shall initiate a 

rulemaking procedure and shall publish a final rule not later than the end of the 54-month 

period beginning on October 24, 1992, to determine if the standards established under 

paragraph (1) should be amended. Such rule shall contain such amendment, if any, and 

provide that the amendment shall apply to products manufactured on or after the 36-

month period beginning on the date such final rule is published. 
(4) Not less than eight years after October 24, 1992, the Secretary shall initiate a 

rulemaking procedure and shall publish a final rule not later than nine years and six 

months after October 24, 1992, to determine if the standards in effect for fluorescent 

lamps and incandescent lamps should be amended. Such rule shall contain such 

amendment, if any, and provide that the amendment shall apply to products manufactured 

on or after the 36-month period beginning on the date such final rule is published. 

(5) Not later than the end of the 24-month period beginning on the date labeling 

requirements under section 6294 (a)(2)(C) of this title become effective, the Secretary 

shall initiate a rulemaking procedure to determine if the standards in effect for fluorescent 

lamps and incandescent lamps should be amended so that they would be applicable to 

additional general service fluorescent [2] and shall publish, not later than 18 months after 

initiating such rulemaking, a final rule including such amended standards, if any. Such 

rule shall provide that the amendment shall apply to products manufactured after a date 

which is 36 months after the date such rule is published. 

The following are the relevant requirements set forth in 10 CFR 430.32(n): 

(n) General service fluorescent lamps and incandescent reflector lamps. (1) Except as provided 

in paragraphs (n)(2) and (n)(3) of this section, each of the following general service fluorescent 

lamps manufactured after the effective dates specified in the table shall meet or exceed the 

following lamp efficacy and CRI standards: 

Lamp type Nominal lamp wattage Minimum CRI

Minimum

average lamp 

efficacy

(lm/W) Effective date

4-foot medium bipin >35W 69 75.0 Nov. 1, 1995.

 ≤35W 45 75.0 Nov. 1, 1995.

2-foot U-shaped >35W 69 68.0 Nov. 1, 1995.

8-foot slimline ≤35W 45 64.0 Nov. 1, 1995.

>65W 69 80.0 May 1, 1994.

 >65W 45 80.0 May 1, 1994.

8-foot high output >100W 69 80.0 May 1, 1994.

 ≤100W 45 80.0 May 1, 1994.

(2) The standards described in paragraph (n)(1) of this section do not apply to: 

(i) Any 4-foot medium bipin lamp or 2-foot U-shaped lamp with a rated wattage less than 28 

watts;

(ii) Any 8-foot high output lamp not defined in ANSI C78.81 (incorporated by reference; see 

§430.3) or related supplements, or not 0.800 nominal amperes; or 
(iii) Any 8-foot slimline lamp not defined in ANSI C78.3 (incorporated by reference; see 

§430.3). 

(3) Each of the following general service fluorescent lamps manufactured after July 14, 2012, 

shall meet or exceed the following lamp efficacy standards shown in the table: 

Lamp type Correlated color temperature

Minimum average lamp

efficacy

(lm/W)

4-foot medium bipin ≤4,500K 89

 >4,500K and ≤7,000K 88

2-foot U-shaped ≤4,500K 84

 >4,500K and ≤7,000K 81

8-foot slimline ≤4,500K 97

 >4,500K and ≤7,000K 93

8-foot high output ≤4,500K 92

 >4,500K and ≤7,000K 88

4-foot miniature bipin standard output ≤4,500K 86

 >4,500K and ≤7,000K 81

4-foot miniature bipin high output ≤4,500K 76

 >4,500K and ≤7,000K 72

(4) Except as provided in paragraph (n)(5) of this section, each of the following incandescent 

reflector lamps manufactured after November 1, 1995, shall meet or exceed the lamp efficacy 

standards shown in the table: 

Nominal lamp wattage

Minimum

average lamp 

efficacy

(lm/W)

40–50 10.5

51–66 11.0

67–85 12.5

86–115 14.0

116–155 14.5

156–205 15.0
(5) Each of the following incandescent reflector lamps manufactured after July 14, 2012, shall 

meet or exceed the lamp efficacy standards shown in the table:

Rated lamp wattage Lamp spectrum

Lamp diameter

(inches) Rated voltage

Minimum

average lamp 

efficacy equation 

(lm/W)

40–205 Standard Spectrum >2.5 ≥125V 6.8*P0.27

 <125V 5.9*P0.27

 ≤2.5 ≥125V 5.7*P0.27

 <125V 5.0*P0.27

40–205 Modified Spectrum >2.5 ≤125V 5.8*P0.27

 <125V 5.0*P0.27

 ≤2.5 ≥125V 4.9*P0.27

 <125V 4.2*P0.27

Note 1: P is equal to the rated lamp wattage, in watts.

Note 2: Standard Spectrum means any incandescent reflector lamp that does not meet the 

definition of modified spectrum in 430.2. 

(6) (i)(A) Subject to the exclusions in paragraph (n)(6)(ii) of this section, the standards specified 

in this section shall apply to ER incandescent reflector lamps, BR incandescent reflector lamps, 

BPAR incandescent reflector lamps, and similar bulb shapes on and after January 1, 2008. 

(B) Subject to the exclusions in paragraph (n)(6)(ii) of this section, the standards specified in this 

section shall apply to incandescent reflector lamps with a diameter of more than 2.25 inches, but 

not more than 2.75 inches, on and after June 15, 2008. 

(ii) The standards specified in this section shall not apply to the following types of incandescent 

reflector lamps:

(A) Lamps rated at 50 watts or less that are ER30, BR30, BR40, or ER40 lamps; 

(B) Lamps rated at 65 watts that are BR30, BR40, or ER40 lamps; or 

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