2-i 

CHAPTER 2. ANALYTICAL FRAMEWORK 

TABLE OF CONTENTS 

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

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

2.2.1 Regulatory Authority and History of Standards Rulemakings for GSFLs and IRLs

 2-3

2.2.2 Corrections of Codified Standards ....................................................................... 2-4

2.2.3 Rulemaking Schedule .......................................................................................... 2-5

2.2.4 IRL Application Efficacy Metric ......................................................................... 2-6

2.2.5 Test Procedure ..................................................................................................... 2-8

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

2.3 SCOPE ............................................................................................................................. 2-9

2.3.1 Clarification of GSFL Definitions ..................................................................... 2-10

2.3.2 GSFL Scope of Coverage .................................................................................. 2-12

2.3.2.1 Additional GSFL Types ......................................................................... 2-13

2.3.2.2 Additional Wattages............................................................................... 2-16

2.3.3 IRL Scope of Coverage ...................................................................................... 2-17

2.3.3.1 Certain R, ER, and BR IRLs .................................................................. 2-17

2.3.3.2 Additional Wattages............................................................................... 2-17

2.4 MARKET AND TECHNOLOGY ASSESSMENT ...................................................... 2-17

2.4.1 Market Assessment ............................................................................................ 2-18

2.4.1.1 Manufacturers of GSFLs and IRLs ........................................................ 2-18

2.4.2 Technology Assessment..................................................................................... 2-18

2.4.2.1 GSFL Technology Options .................................................................... 2-19

2.4.2.2 IRL Technology Options ....................................................................... 2-20

2.4.3 Product Classes .................................................................................................. 2-25

2.4.3.1 GSFL Product Class Divisions .............................................................. 2-25

2.4.3.2 IRL Product Class Divisions .................................................................. 2-27

2.5 SCREENING ANALYSIS ............................................................................................ 2-29

2.5.1 GSFL Design Options ........................................................................................ 2-30

2.5.2 IRL Design Options ........................................................................................... 2-31

2.6 ENGINEERING ANALYSIS ........................................................................................ 2-32

2.6.1 Approach ............................................................................................................ 2-32

2.6.2 Representative Product Classes ......................................................................... 2-35

2.6.3 Baseline Lamps .................................................................................................. 2-36

2.6.3.1 General Service Fluorescent Lamps ...................................................... 2-37

2.6.3.2 Incandescent Reflector Lamps ............................................................... 2-39

2.6.4 More Efficacious Substitutes ............................................................................. 2-41

2.6.4.1 General Service Fluorescent Lamps ...................................................... 2-42

2.6.4.2 Incandescent Reflector Lamps ............................................................... 2-43

2.6.5 Candidate Standard Levels ................................................................................ 2-45

2.6.5.1 General Service Fluorescent Lamps ...................................................... 2-46

2.6.5.2 Incandescent Reflector Lamps ............................................................... 2-51

2.6.6 Scaling to Other Product Classes ....................................................................... 2-53
2-ii

2.6.6.1 General Service Fluorescent Lamps ...................................................... 2-53

2.6.6.2 Incandescent Reflector Lamps ............................................................... 2-54

2.6.7 Rare Earth Phosphors ......................................................................................... 2-57

2.7 PRODUCT PRICE DETERMINATION ...................................................................... 2-59

2.8 ENERGY-USE CHARACTERIZATION ..................................................................... 2-61

2.8.1 Lighting Controls ............................................................................................... 2-63

2.9 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS ................................... 2-64

2.10 SHIPMENTS ANALYSIS ............................................................................................ 2-66

2.11 NATIONAL IMPACT ANALYSIS .............................................................................. 2-69

2.11.1 National Energy Savings Analysis..................................................................... 2-70

2.11.2 Net Present Value Analysis ............................................................................... 2-71

2.12 LIFE-CYCLE COST SUBGROUP ANALYSIS .......................................................... 2-71

2.13 MANUFACTURER IMPACT ANALYSIS.................................................................. 2-72

2.13.1 Sources of Information for the Manufacturer Impact Analysis ......................... 2-72

2.13.2 Industry Cash Flow Analysis ............................................................................. 2-73

2.13.3 Direct Employment Impact Analysis ................................................................. 2-73

2.13.4 Manufacturer Subgroup Analysis ...................................................................... 2-73

2.13.5 Competitive Impacts Assessment ...................................................................... 2-74

2.13.6 Cumulative Regulatory Burden ......................................................................... 2-74

2.13.7 Preliminary Results for the Manufacturer Impact Analysis .............................. 2-74

2.14 EMISSIONS ANALYSIS .............................................................................................. 2-76

2.15 MONETIZING CO2 AND OTHER EMISSIONS ........................................................ 2-78

2.16 UTILITY IMPACT ANALYSIS ................................................................................... 2-79

2.17 EMPLOYMENT IMPACT ANALYSIS ....................................................................... 2-79

2.18 REGULATORY IMPACT ANALYSIS ....................................................................... 2-80

2.19 DEPARTMENT OF JUSTICE REVIEW ..................................................................... 2-80

LIST OF TABLES 

Table 2.2.1 GSFL Standards Prescribed by EPAct ...................................................................... 2-4

Table 2.2.2 IRL Standards Adopted by the 2009 Lamps Rule .................................................... 2-5

Table 2.4.1. GSFL Technology Options .................................................................................... 2-20

Table 2.4.2. IRL Technology Options ....................................................................................... 2-24

Table 2.4.3 GSFL Product Classes ............................................................................................ 2-27

Table 2.4.4. IRL Product Classes............................................................................................... 2-29

Table 2.6.1. GSFL Representative Product Classes .................................................................. 2-35

Table 2.6.2. IRL Representative Product Classes ...................................................................... 2-36

Table 2.6.3 GSFL Baseline Lamps ............................................................................................ 2-39

Table 2.6.4. IRL Baseline Lamps .............................................................................................. 2-41

Table 2.6.5. GSFL Lamp Design Options ................................................................................. 2-48

Table 2.6.6 Summary of CSLs for GSFL Representative Product Classes ............................... 2-51

Table 2.6.7. IRL Lamp Design Options ..................................................................................... 2-52

Table 2.6.8 Summary of CSLs for IRL Representative Product Classes .................................. 2-53

Table 2.6.9. Scaling to Other GSFL Product Classes ................................................................ 2-54
2-1 

CHAPTER 2. ANALYTICAL FRAMEWORK 

2.1 INTRODUCTION 

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

requires that energy conservation standards set by the U.S. Department of Energy (DOE) be 

technologically feasible and economically justified, and achieve the maximum possible 

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

description of the general analytical framework that DOE uses in developing such standards, and 

in particular, standards for general service fluorescent lamps (GSFLs) and incandescent reflector 

lamps (IRLs). It includes a description of the methodology, the analytical tools, and relationships 

among the various analyses that are part of this rulemaking. Chapter 2 also provides an overview 

of the preliminary activities DOE has conducted and discusses the comments it received in 

response to the framework document. Finally, chapter 2 provides cross-references to the other 

chapters of this preliminary technical support document (TSD) that address DOE’s analytical 

approach, inputs, and findings. 

The analyses presented in this preliminary TSD include: 

 a market and technology assessment to characterize the relevant fluorescent and 

incandescent reflector lamp markets; to identify technology options that improve 

efficacy; and to develop product classes; 

 a screening analysis to review each technology option and determine if it is 

technologically feasible; is practicable to manufacture, install, and service; would 

adversely impact lamp utility or lamp availability; or would have adverse impacts on 

health and safety; 

 an engineering analysis to study representative lamp systems and, as appropriate, lampand-ballast systems used as substitutes for baseline lamps, to select candidate standard 

levels (CSLs), and to determine lamp system power ratings; 

 a product price determination that develops end-user product prices for the representative 

lamps identified in the engineering analysis; 

 an energy-use characterization that generates energy-use estimates for covered GSFLs 

and IRLs; 

 a life-cycle cost (LCC) analysis that calculates, at the consumer level, the discounted 

savings in operating costs throughout the estimated average life of the lamp, compared to 

any increase in the installed costs likely to result directly from imposition of the standard; 

 a payback period (PBP) analysis to estimate the amount of time it takes consumers to 

recover the higher purchase expense of more efficacious lamps through lower operating 

costs; 
2-2 

 a shipments analysis that estimates shipments of GSFLs and IRLs over the time period 

examined in the analysis; 

 a national impact analysis (NIA) that assesses the aggregate impacts at the national level 

of potential energy conservation standards as measured by the net present value (NPV) of 

total consumer economic impacts and national energy savings (NES); and 

 a preliminary manufacturer impact analysis (MIA) that begins to evaluate the effects on 

manufacturers that may result from an amended efficacy standard. 

DOE may revise any of its analyses based on comments and new information received on 

this preliminary analysis before publishing any subsequent notice of proposed rulemaking 

(NOPR). The analyses DOE performs in any NOPR stage include those listed below: 

 an LCC subgroup analysis that evaluates the economic impacts on identifiable groups of 

consumers of GSFLs and IRLs, including various categories of lamp purchasers or 

owners who may experience disproportionate impacts from a national energy 

conservation standard; 

 an MIA that estimates the financial impact of standards on lamp manufacturers and 

calculates impacts on competition, employment at the manufacturing plant, and 

manufacturing capacity; 

 a utility impact analysis that estimates the effects of proposed standards on the installed 

capacity and the generating base of electric utilities; 

 an employment impact analysis that estimates the impacts of standards on net jobs 

eliminated or created in the general economy as a consequence of increased spending on 

the installed price of GSFLs and IRLs and reduced consumer spending on energy; 

 an emissions analysis to provide estimates of the effects of amended energy conservation 

standards on emissions of carbon dioxide (CO2), sulfur dioxide (SO2), nitrogen oxides 

(NOX), and mercury (Hg); 

 a monetization of the reduced emissions from the proposed standard levels; and

 a regulatory impact analysis (RIA) that presents major alternatives to proposed standards 

that may achieve comparable energy savings at a reasonable cost. 

DOE developed this analytical framework and documented its findings in the Energy 

Conservation Standards Rulemaking Framework Document for General Service Fluorescent 
2-3 

Lamps and Incandescent Reflector Lamps (August 31, 2011).1 DOE presented the analytical 

approach to interested parties during a public meeting held on October 4, 2011 (hereafter the 

“framework public meeting”). 

In response to the publication of the framework document and the framework public 

meeting, DOE received comments from interested parties on its analytical approach. Based on 

the discussions and issues raised at the framework public meeting, the National Electrical 

Manufacturers Association (NEMA) requested that DOE extend the comment deadline until 

November 28, 2011. (NEMA, No. 9 at p. 1)2 DOE agreed and extended the comment deadline 

accordingly.3This chapter summarizes the key comments DOE received, describes DOE’s 

responses, and summarizes the analytical approach taken in this preliminary analysis. In the 

executive summary of this TSD, DOE identifies issues on which it seeks public comment, which 

are also discussed in the sections below. 

2.2 BACKGROUND 

2.2.1 Regulatory Authority and History of Standards Rulemakings for GSFLs and IRLs 

Title III of EPCA sets forth a variety of provisions designed to improve energy 

efficiency. Part B of Title III (42 U.S.C. 6291-6309) established the “Energy Conservation 

Program for Consumer Products Other Than Automobiles,” which includes the fluorescent and 

incandescent reflector lamps that are the focus of this preliminary analysis.4

In particular, EPCA 

establishes energy conservation standards for certain classes of GSFLs and IRLs, and authorizes 

DOE to conduct two rulemaking cycles to determine whether these standards should be 

amended. (42 U.S.C. 6291(1), and 6295(i)(1) and (3)-(4)) EPCA also authorizes DOE to adopt 

standards for additional GSFLs, if such standards were warranted. (42 U.S.C. 6295(i)(5)) DOE 

completed the first cycle of amendments by publishing a final rule in July 2009 (hereafter the 

“2009 Lamps Rule”). 74 FR 34080 (July 14, 2009). In the 2009 Lamps Rule, DOE amended

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

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

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

newly covered GSFLs. Information regarding the 2009 Lamps Rule can be found on 

regulations.gov, docket number EERE-2006-STD-0131 at 

www.regulations.gov/#!docketDetail;D=EERE-2006-STD-0131. 

 

1

 The framework document is available at 

www1.eere.energy.gov/buildings/appliance_standards/pdfs/gsfl_irl_ecs_framework.pdf. 

2

 A notation in this form provides a reference for information that is in the docket of DOE’s rulemaking to develop 

energy conservation standards for GSFLs and IRLs (Docket No. EERE–2011–BT–STD–0006), which is maintained 

at www.regulations.gov. This notation indicates that the statement preceding the reference is document number 9 in 

the docket for the GSFL and IRL energy conservation standards rulemaking, and appears at page 1 of that 

document. 

3

 The notice extending the framework comment period is available at 

www1.eere.energy.gov/buildings/appliance_standards/pdfs/gsfl-irl_framework_extension.pdf. 

4

 Part B was re-designated Part A on codification in the U.S.C. for editorial reasons. 
2-4 

 This preliminary analysis is part of DOE’s second cycle of review to determine whether 

the standards in effect for GSFLs and IRLs should be amended and whether the standards should 

apply to additional GSFL types. (42 U.S.C. 6295(i)(3)-(4) and (5)) It also addresses 42 U.S.C. 

6295(gg)(3) in which DOE is directed to incorporate standby mode and off mode energy use in 

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

2.2.2 Corrections of Codified Standards 

Upon initiating the preliminary analysis for this rulemaking, DOE noticed a few errors in 

the codified standards for GSFLs and IRLs. DOE is considering correcting the typographical 

errors in the sections of the Code of Federal Regulations (CFR) that lay out the GSFL standards 

specified in EPCA and the IRL standards established by the 2009 Lamps Rule. Specifically, for 

the GSFL standards codified at 10 CFR 430.32(n)(1), the “less than or equal to 35 W” associated 

with the 8-foot slimline lamp type should instead be associated with the 2-foot U-shaped lamp 

type. For 8-foot slimline product class with a minimum color rendering index (CRI) of 45 and a 

minimum average lamp efficacy of 80.0 lm/W, the rated wattage should be less than or equal to 

65 W, not greater than 65 W. The revised table should read as follows: 

Table 2.2.1 GSFL Standards Prescribed by EPAct 

Lamp type Nominal lamp 

wattage Minimum CRI

Minimum average 

lamp efficacy

lm/W

Effective date

4-foot medium bipin

> 35 W 69 75.0 Nov. 1, 1995.

≤ 35 W 45 75.0 Nov. 1, 1995.

2-foot U-shaped

> 35 W 69 68.0 Nov. 1, 1995.

≤ 35 W 45 64.0 Nov. 1, 1995.

8-foot slimline

> 65 W 69 80.0 May 1, 1994.

≤ 65 W 45 80.0 May 1, 1994.

8-foot high output

> 100 W 69 80.0 May 1, 1994.

≤ 100 W 45 80.0 May 1, 1994.

For the IRL standards adopted by the 2009 Lamps Rule that are codified in 10 CFR 

430.32(n)(5), for lamps with a rated wattage of 40-205 W, a modified spectrum, a diameter 

greater than 2.5 inches, and a minimum average lamp efficacy of 5.8P0.27, the rated voltage 

should be “greater than or equal to 125 V” and not “less than or equal to 125 V.” The revised 

table should read as follows: 
2-5 

Table 2.2.2 IRL Standards Adopted by the 2009 Lamps Rule 

Rated lamp wattage Lamp spectrum Lamp diameter

(inches) Rated voltage

Minimum average 

lamp efficacy

lm/W

40-205 W Standard Spectrum

> 2.5

≥ 125 V 6.8*P0.27

< 125 V 5.9*P0.27

≤ 2.5

≥ 125 V 5.7*P0.27

< 125 V 5.0*P0.27

40-205 W Modified Spectrum

> 2.5

≥ 125 V 5.8*P0.27

< 125 V 5.0*P0.27

≤ 2.5

≥ 125 V 4.9*P0.27

< 125 V 4.2*P0.27

2.2.3 Rulemaking Schedule 

DOE received several comments on the framework document regarding the timing of this 

rulemaking. In the schedule presented in the framework document, this preliminary analysis was 

scheduled to be published in September 2012, the NOPR in August 2013, and the final rule in 

2014. NEMA, Lutron Electronics Co., Inc. (Lutron), and the Edison Electric Institute (EEI) 

expressed concern that by undertaking the second review of standards prior to standards from the 

first review requiring compliance, DOE would not be making an accurate market assessment. 

(NEMA, No. 15 at p. 30; NEMA, Public Meeting Transcript, No. 10 at pp. 78-79; EEI, No. 13 at 

p. 2; Lutron, Public Meeting Transcript, No. 10 at pp. 99-100) 

NEMA objected to basing analysis on speculative assumptions and projections for 

product demand, availability, and pricing. Specifically, NEMA raised the concern that product 

availability, product pricing, and investment decisions were still being made in response to the 

standards adopted in the 2009 Lamps Rule requiring compliance in July 2012 (hereafter the “July 

2012 standards”). Energy projections would be more accurate if based on final product offerings. 

Additionally, NEMA stated it would be difficult to make accurate price predictions due to the 

rare earth phosphor situation (see section 2.6.7 for further information). NEMA noted that 

manufacturers, distributors, and retailers would be selling off existing noncompliant inventory 

through 2012 and some production lines may be shut down if no longer profitable due to 

redesign costs. (NEMA, Public Meeting Transcript, No. 10 at pp. 70, 73-74, 210; NEMA, No. 15 

at pp. 2-3) NEMA also emphasized the unknown impact of the July 2012 standards on IRL 

buying decisions, particularly because standards-compliant halogen lamps may not be on the 

market. (NEMA, No. 15 at p. 21, 24) NEMA expressed its view that typically, the proposals in a 

framework document are unlikely to change greatly over the course of a rulemaking. Therefore, 

NEMA recommended DOE wait before assessing the market to develop a more meaningful base 

case scenario. (NEMA, Public Meeting Transcript, No. 10 at pp. 70, 73-74; NEMA, No. 15 at 

pp. 2-3) 
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At the framework public meeting, NEMA had suggested delaying the second rulemaking 

cycle as long as legally permissible, which it interpreted to be six months after July 14, 2012, the 

compliance date of the first rulemaking, based on 42 U.S.C. 6295(i)(3) and (4). NEMA had 

stated they expect catalog and product availability data to be obtainable in July 2012 and sales 

data to be available at the end of 2012 at the earliest. (NEMA, Public Meeting Transcript, No. 10 

at pp. 70-71, 79) In written comments, NEMA then stated DOE should base its analysis on data 

from a full year of sales under the July 2012 standards, which would not be available until early 

2014. (NEMA, No. 15 at p. 3) In a joint comment, the Pacific Gas and Electric Company 

(PG&E) and Southern California Edison (SCE) also recommended that DOE wait until after the 

compliance date of the 2009 Lamps Rule to update the assumptions used for this rulemaking, 

because it is not yet clear precisely what products will be available after that time, or how their 

performance and costs will change. (PG&E and SCE, No. 17 at pp. 1-2) 

However, PG&E and SCE supported the timing of DOE’s initiation of this rulemaking 

and noted that according to 42 U.S.C. 695(i)(4), DOE is required to issue two final rules for 

these products – the first by March 1997 and the second five years later, by March 2002. PG&E 

and SCE further stated that the 2009 Lamps Rule was approximately 12 years behind schedule 

and at this point, DOE had set a target date of 2014 for the second final rule in keeping with the 

original legislative directive to finalize a second rulemaking within five years of the first. (PG&E 

and SCE, No. 17 at p. 1) Given the long process required to develop a new standard, ASAP and 

PG&E and SCE supported DOE’s decision to begin this process now. (ASAP, Public Meeting 

Transcript, No. 10 at p.86; PG&E and SCE, No. 17 at p. 1) 

EPCA required DOE to initiate the first review of standards no earlier than three years 

after October 24, 1992, and publish a final rule no later than four years and six months after that 

date. 42 U.S.C. 6295(i)(3) The second review of standards was to be initiated no earlier than 

eight years after October 24, 1992, and the final rule published no later than nine years and six 

months after that date. 42 U.S.C. 6295(i)(4) DOE published the final rule for the first review of 

standards in July 2009. To apply the schedule set forth for the second review of standards, an 

interval of five years would be maintained between the publications of the final rules for the first 

and second review of standards, and any final rule for this rulemaking would be published by 

July 14, 2014. 

In the framework document, DOE had projected publishing the preliminary analysis in 

September 2012. However, as suggested by NEMA and PG&E and SCE, DOE delayed the 

publication of the analysis to update its product catalogs and assessments based on changes that 

took place after the compliance date of the 2009 Lamps Rule standards on July 14, 2012. DOE 

obtained information during interviews with manufacturers regarding new product lines they 

were preparing to launch to ensure that DOE’s analysis captures the initial market impacts of the 

July 2012 standards. 

2.2.4 IRL Application Efficacy Metric 

 Currently, IRL standards are based on lamp efficacy measured as the lumen output of the 

lamp per watt (lm/W) supplied to the lamp. However, the lm/W measurement does not quantify 

the effectiveness of the lamp in delivering light to locations where it is needed. In the framework 
2-7 

document, DOE considered exploring an application-based method of measuring IRL efficacy. 

DOE received several comments on this consideration. 

 Several commenters recognized the limitations of lm/W as an evaluation metric for IRLs, 

especially for directional sources. NEMA noted that of particular concern are efficacy 

comparisons, evaluations, and economic analyses across directional light sources using varying 

technologies. NEMA asserted that a technology neutral metric is necessary and noted that 

ENERGY STAR is also interested in developing a new way to evaluate directional lamp sources 

so different technologies can be fairly evaluated and compared. (NEMA, No. 15 at p. 4; NEMA, 

Public Meeting Transcript, No. 10 at pp. 113-115) NEMA also remarked that because of the 

directionality and the sensitivity of users to center beam candlepower (CBCP) intensity and 

beam spread characteristics, development of a new metric that takes into account energy efficacy 

and application efficacy should be handled with care. (NEMA, No. 15 at p. 3) 

PG&E and SCE also noted that the current lm/W efficacy metric is not ideal for IRLs 

because it does not take into account the lamps’ effectiveness in delivering light to a specific 

target. PG&E and SCE stated that the possible application efficacy metric that DOE put forward 

in the framework document and described as the “average luminous flux within a specified solid 

angle of interest per unit of power,” may be a more appropriate measure of IRL performance and 

is worth future consideration. (PG&E and SCE, No. 17 at p. 5) In a joint comment, the Appliance 

Standards Awareness Project (ASAP), the Natural Resources Defense Council (NRDC), the 

Alliance to Save Energy, the American Council for an Energy-Efficient Economy, the National 

Consumer Law Center, the Northwest Energy Efficiency Alliance (NEEA), and the Northeast 

Energy Efficiency Partnerships (hereafter the “Joint Comment”) encouraged DOE to pursue the 

development of a metric that takes the directional nature of IRLs into account and suggested that 

the new metric base efficacy on the amount of light provided in a beam, rather than total output 

from the lamp. The Joint Comment explained that looking at lamp efficacy within a specific 

beam would better represent an IRL’s performance and give consumers a more accurate 

representation of a lamp’s useful light. (Joint Comment, No. 16 at pp.1-2) 

Although interested parties generally expressed support for developing a new metric, they 

also identified several concerns with such an approach. PG&E and SCE emphasized that DOE 

should take care not to develop a metric that would require a large increase in the number of 

product classes. PG&E and SCE gave the example of a metric measuring candelas per watt based 

on CBCP that would make it impossible to compare a lamp with a 10° beam angle to a lamp with 

a 20° beam angle. (PG&E and SCE, No. 17 at p. 5) EEI also expressed concern regarding a 

potential increase in product classes required to accurately describe characteristics such as solid 

angle and beam angle. (EEI, Public Meeting Transcript, No. 10 at p. 110) 

Several organizations also expressed concern regarding the timing for introducing a new 

metric. NEMA stated that while work has already begun to identify a better metric, it was not 

expected to be finished and understood in time to benefit this rulemaking. (NEMA, No. 15 at pp. 

3-4) PG&E and SCE pointed out that introducing a new metric in the later stages (e.g., at the 

NOPR stage) of a rulemaking could not only add significant confusion, but could also negatively 

impact the standards setting process, as there may not be sufficient data available for a wide 

variety of products. (PG&E and SCE, No. 17 at p. 5) The Joint Comment noted that even if it 
2-8 

were not feasible to develop a new metric in time for the final analysis of this rulemaking, it 

should still be pursued in the near term as it could be utilized in ENERGY STAR and other 

voluntary programs that define high performance IRLs. (Joint Comment, No. 16 at p. 2) 

Furthermore, the Joint Comment stated that an amended test procedure based on a new metric 

would allow the use of the new metric even if it is adopted after the compliance date of this rule. 

(Joint Comment, No. 16 at p. 2) EEI emphasized that any new metric would also need industry 

approval and an extensive education campaign for the consumer, especially in the residential 

sector. (EEI, Public Meeting Transcript, No. 10 at pp. 110-111) 

DOE conducted thorough research of available literature and data to identify alternate 

metrics to measure IRL efficacy. DOE acknowledges that although a new metric could better 

characterize the “useful” light output of an incandescent reflector lamp, there are several 

drawbacks to pursuing such a metric at this time. A new metric would likely involve light 

intensity (candle power) measurements, which are not currently required. This would result in 

additional costs for laboratories not capable of performing light intensity measurements. Because 

quantities such as beam angle and CBCP are not familiar to the general public, considerable 

consumer education would also be required. In addition, because some consumers do not use 

IRLs for directional purposes, a new metric may not provide relevant information. 

To be effective, a directional metric should be used for all directional lamps, including 

those that utilize compact fluorescent or light-emitting diode (LED) technology. Agreement on 

the metric and method of measurement would require the input of manufacturers of these 

products and other key stakeholders in the industry. DOE is not aware of any activity regarding 

development of a directional metric for IRLs or other relevant lamps at this time. Therefore, 

DOE is maintaining the current lm/W metric for IRLs in this preliminary analysis. 

2.2.5 Test Procedure 

 EPCA sets forth generally applicable criteria and procedures for DOE’s adoption and 

amendment of test procedures. (42 U.S.C. 6293) Manufacturers of covered products must use 

these test procedures to certify to DOE that their product complies with EPCA energy 

conservation standards and to quantify the efficiency of their product. Also, these test procedures 

must be used whenever testing is required in an enforcement action to determine whether 

covered products comply with EPCA standards.

DOE’s test procedures for fluorescent and incandescent reflector lamps are set forth in

title 10 of the CFR, part 430, subpart B, appendix R. These test procedures provide instructions 

for measuring GSFL and IRL performance, largely by incorporating industry standards. DOE has 

conducted two recent reviews of the GSFL and IRL test procedures. The test procedures were 

first updated in a final rule published in July 2009. 74 FR 31829 (July 6, 2009). The rule updated 

citations to industry standards and made several other modifications. DOE further amended the 

test procedures to update references to industry standards for GSFLs in a final rule published in 

January 2012. 77 FR 4203 (January 27, 2012).

2.2.6 Standby and Off Mode Energy Consumption 

 EPCA requires energy conservation standards adopted for a covered product after July 1, 

2010 to address standby mode and off mode energy use. (42 U.S.C. 6295(gg)(3)) EPCA defines 
2-9 

active mode as the condition in which an energy-using piece of equipment is connected to a main 

power source, has been activated, and provides one or more main functions. (42 U.S.C. 

6295(gg)(1)(A)) Standby mode is defined as the condition in which an energy-using piece of 

equipment is connected to a main power source and offers one or more of the following useroriented or protective functions: facilitating the activation or deactivation of other functions 

(including active mode) by remote switch (including remote control), internal sensor, or timer; or 

providing continuous functions, including information or status displays (including clocks) or 

sensor-based functions. Id. Off mode is defined as the condition in which an energy-using piece 

of equipment is connected to a main power source, and is not providing any standby or active 

mode function. Id. 

 To satisfy the EPCA definitions of standby mode and off mode (42 U.S.C. 6295(gg)(1)), 

the lamp must not be providing any active mode function (i.e., emitting light). However, to reach 

such a state, the lamp must be entirely disconnected from the main power source (i.e., switched 

off), thereby not satisfying the requirements of operating in off mode or standby mode. Further, 

neither fluorescent nor incandescent reflector lamps covered under this rulemaking provide any 

secondary user-oriented or protection functions or continuous standby mode functions. Thus, 

these lamps do not satisfy the EPCA definition of standby mode. While EPCA allows DOE to 

amend the mode definitions (42 U.S.C. 6295(gg)(1)(B)), DOE believes that the energy use of 

GSFLs and IRLs is accounted for entirely in the active mode. Therefore, DOE is not addressing 

lamp operation in the standby and off modes in this rulemaking. 

2.3 SCOPE 

In this section, DOE discusses specific issues and comments related to the scope of this 

rulemaking. The topics of discussion include clarifying certain exemptions in the definition of 

“general service fluorescent lamp”; establishing standards for additional GSFL types; and 

considering standards for additional IRLs. 

DOE received general comments on the practicality of achieving energy savings through 

increased standards for individual products rather than considering other available options. 

NEMA stated that the energy savings for these products have been realized and the responsible 

thing to do is move to other areas such as system-based savings solutions and lighting controls. 

(NEMA, No. 7 at p. 3; NEMA, Public Meeting Transcript, No. 10 at pp. 78-79) Lutron also 

noted that GSFL and IRL standards might not be as useful as other energy saving regulations, 

stating that component regulations have diminishing returns and there are greater opportunities 

for energy savings on a building level. (Lutron, Public Meeting Transcript, No. 10 at pp. 262-

263) DOE recognizes that system- or building-based standards may result in significant national 

energy savings. EPCA, however, directs DOE to determine if the standards in effect for 

fluorescent lamps and incandescent reflector lamps should be amended. (42 U.S.C. 6295(i)(4)) 

DOE must analyze standards as they apply to GSFLs and IRLs as defined in EPCA and DOE 

regulations. These definitions are discussed in greater detail in the following sections. 

NEMA expressed concern regarding potential expansion of products covered under this 

rulemaking and stated that the scope of products affected should be restricted to those specified 

in EPAct 1992. (NEMA, No. 7 at pp. 2-3; NEMA, Public Meeting Transcript, No. 10 at pp. 76, 
2-10

79) As previously mentioned, EPCA requires DOE to determine if the standards in effect for 

fluorescent lamps and incandescent reflector lamps should be amended. (42 U.S.C. 6295(i)(4)) 

EPCA does not limit the scope of this rulemaking to definitions specified in EPAct 1992. As 

mentioned in section 2.2.1, DOE’s definitions of “fluorescent lamp” and “incandescent reflector 

lamp” have been amended since the enactment of EPAct 1992. For example, the Energy 

Independence and Security Act of 2007 (EISA 2007) amended EPCA to expand the definition of 

IRLs by including smaller diameter lamps and additional lamp shapes. In implementing 42 

U.S.C. 6295(i)(5),5 DOE expanded the definition of “fluorescent lamp” to include additional 

lamp wattages and two additional lamp types in the 2009 Lamps Rule. Therefore, the products 

that are the subject of this rulemaking include GSFLs and IRLs based on the relevant definitions 

as amended and codified in DOE’s regulations. 

2.3.1 Clarification of GSFL Definitions 

The scope of this rulemaking for GSFLs is defined by the definitions of “fluorescent 

lamp” and “general service fluorescent lamp.” EPCA defines “general service fluorescent lamp” 

and includes in that definition several exemptions. Based on several queries received from the 

general public on the application of these exemptions, DOE is considering whether further clarity 

can be provided regarding these exemptions. The statutory definition of “general service 

fluorescent lamp” is as follows: 

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 

DOE evaluated each exemption and found that “impact-resistant fluorescent lamps,” 

“reflectorized or aperture lamps,” “fluorescent lamps designed for use in reprographic 

equipment,” and “lamps primarily designed to produce radiation in the ultra-violet region of the 

spectrum,” were exemptions that consisted of terminology not defined elsewhere or for which 

the application of the exemption could be further clarified. In comparison, “colored fluorescent 

 

5

 As noted previously, 42 U.S.C. 6295(i)(5) requires DOE to consider expanding coverage of standards to other 

GSFL types. 
2-11

lamp” is already defined separately within the CFR and “fluorescent lamps designed to promote 

plant growth” clearly specifies the function of the lamps. 

To provide further clarification on the terms “impact-resistant,” “reflectorized or 

aperture,” “reprographic equipment,” and “ultra-violet region of the spectrum,” DOE examined 

industry bulletins, product literature, and other online publications. Based on the examination of 

this information, DOE developed the following definitions. 

Through this research and feedback from manufacturers, DOE found “impact-resistant” 

to be synonymous with “shatter-resistant” and is considering a definition for “impact-resistant 

fluorescent lamp” based on the existing definition of “shatter-resistant lamp” in 10 CFR 430.2 as 

follows: 

Impact-resistant fluorescent lamp means a lamp that: 

a. Has a coating or equivalent technology that is compliant with NSF/ANSI 51 

(incorporated by reference; see §430.3) and is designed to contain the glass if the 

glass envelope of the lamp is broken; and 

b. Is designated and marketed for the intended application, with 

i. The designation on the lamp packaging; and 

ii. Marketing materials that identify the lamp as being impact-resistant, 

shatter-resistant, shatter-proof, or shatter-protected.

An examination of product literature, industry bulletins, and online publications indicated 

that “reflectorized or aperture lamp” refers to lamps that contain an inner reflective coating on 

the bulb to direct emitted light. Therefore, DOE is considering defining “reflectorized or aperture 

lamp” as follows: 

Reflectorized or aperture lamp means a fluorescent lamp that contains an inner reflective 

coating on the bulb to direct light. 

 Based on a review of product literature, DOE found that “fluorescent lamp[s] designed 

for use in reprographic equipment” are intended for use in equipment that is used to reproduce, 

reprint, or copy graphic material. Therefore, DOE is considering defining “fluorescent lamp 

designed for use in reprographic equipment” as follows: 

Fluorescent lamp designed for use in reprographic equipment means a fluorescent lamp 

intended for use in equipment used to reproduce, reprint, or copy graphic material. 

 Through an examination of product literature, industry bulletins, online publications, and 

the IESNA Lighting Handbook, DOE determined that the term “ultra-violet region of the 

spectrum” refers to the portion of the electromagnetic spectrum where light has a wavelength 

between 10-400 nanometers. DOE is considering defining “lamps primarily designed to produce 

radiation in the ultra-violet region of the spectrum” as follows: 
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Lamps primarily designed to produce radiation in the ultra-violet region of the spectrum

mean fluorescent lamps that primarily emit light in the portion of the electromagnetic 

spectrum where light has a wavelength between 10-400 nanometers. 

 DOE is also considering clarifying references to “designed” and “marketed” as applied to 

definitions of lighting products covered under DOE standards. These terms are generally used to 

ensure that exemptions from applicable standards apply only to lamps used in certain intended 

applications and/or functions. Therefore, DOE is considering the terms “designed,” “designated,” 

“designation,” “designated and marketed,” and “designed and marketed” for covered lighting 

products to mean that manufacturers explicitly state the intended application of the lamp in a 

publicly available document (e.g., product literature, catalogs, packaging labels, and labels on the 

product itself).

 DOE requests comment on these definitions. 

2.3.2 GSFL Scope of Coverage 

As previously noted, pursuant to 42 U.S.C. 6295 (i)(5), DOE is directed to evaluate 

energy efficiency standards for additional GSFLs beyond those for which standards have already 

been established. In considering whether to establish standards for additional GSFLs, DOE first 

reviews the fluorescent lighting market and identifies lamps that meet the definition of a 

‘‘fluorescent lamp’’ in 42 U.S.C. 6291(30)(A), can be used to satisfy the majority of fluorescent 

lighting applications, are not within the exclusions specified in 42 U.S.C. 6291(30)(B), and are 

not already subject to energy conservation standards. 73 FR 13620, 13629 (March 13, 2008). For 

each additional GSFL identified, DOE then assesses whether standards have the potential to 

result in significant energy savings and are technologically feasible and economically justified. 

Standards for any applicable additional GSFL are adopted based on the same criteria used to set 

new or amended standards for products per 42 U.S.C. 6295(o). 

If DOE extends coverage to additional types of GSFLs, the definition of “fluorescent 

lamp,” which lists covered lamp types, would be amended to include those additional lamp 

types. The current definition of fluorescent lamp is as follows: 

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; 
2-13

(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 

DOE received several comments regarding extending coverage to additional GSFL types. 

The Joint Comment encouraged DOE to consider additional types of fluorescent lamps and 

evaluate whether the associated potential energy savings justify national standards. (Joint 

Comment, No. 16 at p. 3) EEI agreed, stating that additional GSFL and IRL products not subject 

to energy conservation standards are used in general applications and compete with the lamps 

that are the subject of this rulemaking. EEI suggested that DOE consider standards for these 

products at the same time as this rulemaking, with the goal of having the same compliance dates 

for new efficacy standards to minimize any market distortions and product switching due to 

efficacy standards. (EEI, No. 13 at p. 2; EEI, Public Meeting Transcript, No. 10 at pp. 93-94) As 

mentioned above, EPCA authorizes DOE to consider whether standards should apply to 

additional types of GSFLs under 42 U.S.C. 6295(i)(5). The following sections discuss whether 

coverage should be extended to additional GSFL types, as well as whether the definition of 

fluorescent lamp should be amended to include additional wattages for GSFL types already 

covered. 

2.3.2.1 Additional GSFL Types 

In the framework document, DOE stated it would consider standards for additional types 

of GSFL. Some additional GSFL types DOE considered included: 1) non-linear fluorescent 

lamps (e.g., circline); 2) fluorescent lamps with alternate lengths (e.g., 2-, 3-, and 5-foot lamps); 

and 3) pin base compact fluorescent lamps (CFLs). DOE received several comments regarding 

these additional GSFLs considered for coverage. 

Fluorescent Lamps with Alternate Lengths and Shapes 

The Joint Comment encouraged DOE to consider establishing standards that apply to 

lamps within a range of lamp lengths. As modifying lamp length slightly could exempt a lamp 

from current standards, the Joint Comment asserted that DOE should consider a standard that 

applies to fluorescent lamps of any length within a range. (Joint Comment, No. 16 at p. 3) PG&E 

and SCE remarked that although they do not have shipment data for circline, 2-foot, 3-foot, and 

5-foot linear fluorescent lamps, they believed that there may be sufficient savings potential to 

justify the consideration of standards for these lamps. (PG&E and SCE, No. 17 at p. 2) 

Specifically, PG&E and SCE stated that 2-foot lamps are common, frequently installed in 2-footby-2-foot troffers that have been retrofitted from 2-foot U-bend fixtures. Based on experience in 

California, PG&E and SCE estimated 2-foot lamps now exist in most commercial buildings and 

stated that there is significant potential to improve performance for these lamps. They noted that 

high efficacy 2-foot T8 lamps tend to have 1500 initial lumens at 17 W, which is about a 15 

percent improvement over basic 2-foot T8 lamps with 1300 initial lumens, and similar efficacy 

gaps exist for 3-foot T8 lamps. PG&E and SCE also added that there are other 2-foot and 3-foot 
2-14

lamps that have far lower efficacies, including 2-foot T12 lamps rated at 20 W that often provide 

fewer than 1200 or 1100 lumens. (PG&E and SCE, No. 17 at p. 2) However, PG&E and SCE 

commented that circline lamps and 5-foot lamps, and to some extent 3-foot lamps, may not be as 

common as 2-foot lamps in commercial lighting and instead are prevalent in niche applications, 

such as sign lighting, which can require long operating hours. Therefore, PG&E and SCE 

suggested DOE consider whether standards for these lamps might adversely affect these 

industries, specifically in terms of technical feasibility. (PG&E and SCE, No. 17 at p. 2) 

NEMA did not agree with the additional GSFL types presented for consideration in the 

framework and stated that a rulemaking on the enumerated lamp types would be expected to 

achieve very little, if any, national energy savings due to their minimal replacement options, 

typically shorter hours of operation (as circline and 2-foot and 3-foot T12 lamps are primarily 

used in residential applications), limited ability to increase efficacy, and low shipment volumes. 

NEMA identified these lamps as niche and specialty application products that in many cases are 

not designed specifically for efficacy, but rather to satisfy consumer demand or application 

specification. NEMA noted that circline, 2-foot, 3-foot, and 5-foot lamps would have a greater 

impact on the residential than the professional market. NEMA estimated circline lamps represent 

less than 1 percent of the fluorescent market, while 2-foot and 3-foot T12 fluorescent lamps 

represent less than 3 percent of the fluorescent market. (NEMA, No. 15 at p. 4) 

NEMA further stated that developing standards for these lamps would be costly and time 

consuming for DOE and if regulated, testing, reporting, and overall regulatory costs for 

manufacturers would increase dramatically for these low volume product lines. (NEMA, No. 15 

at p. 4) NEMA also argued that if standards for these additional lamp types were pursued, it 

would not be practical to use the currently identified representative products for the linear lamp 

types to analyze these other niche product types. (NEMA, Public Meeting Transcript, No. 10 at 

pp. 77-79; NEMA, No. 15 at p. 11) Philips recommended not expanding coverage to more 

GSFLs due to the rare earth phosphor situation. (Philips, Public Meeting Transcript, No. 10 at p. 

96) 

 When considering extending coverage to additional GSFLs, DOE considers whether 

potential energy conservation standards for these GSFLs would result in significant energy 

savings. DOE’s assessment shows that standards for fluorescent lamp shapes not currently 

covered would not likely result in significant energy savings. Fluorescent lamps come in three 

primary shapes: linear, U-shaped, and circline. Current standards cover certain linear and Ushaped lamps. There is little publicly available information on the installed stock and energy 

consumption of circline lamps. The 2010 Lighting Market Characterization (LMC) report 

includes these lamps under the miscellaneous category of fluorescent lamps, which made up 2.1 

percent of lighting and consumed 4 terawatt-hours (TWh) of electricity in 2010.6 Circline lamps 

would only be a small portion of the installed stock and energy consumption of this category, 

which includes all fluorescents other than T5 linear and T8 and T12 linear and U-shaped lamps, 

as well as fluorescent lamps with unknown characteristics. The low levels of installed stock and 

 

6

 U.S. Department of Energy. 2010 U.S. Lighting Market Characterization. January 2012. Available at 

http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf. 
2-15

energy consumption for these alternate-shaped fluorescent lamps indicate limited potential for 

energy savings. Additionally, feedback from manufacturer interviews confirmed that fluorescent 

lamps of shapes not covered do not comprise a significant portion of the market. Based on this 

analysis, DOE is not considering extending coverage to fluorescent lamps with shapes not 

currently covered. 

 DOE’s assessment of linear fluorescent lamps with lengths not covered shows that 

standards for these lamp types would not likely result in significant energy savings. Linear 

medium bipin (MBP) lamps come in lengths ranging from 1 to 6 feet and are mainly T8 and T12 

diameters. Currently only 4-foot MBP linear lamps are covered by standards. DOE’s analysis 

shows that 5- and 6-foot linear fluorescent lamps comprise a very low percentage of the linear 

MBP product offerings. For the T87 MBP lamps with lengths less than 4 feet, according to the 

2010 LMC, these lamps comprised about 0.2 percent of all installed lighting and consumed 1 

TWh of electricity in 2010.8The low levels of installed stock and energy consumption of these 

lamps indicate limited potential for energy savings. Further, in interviews manufacturers 

confirmed that linear fluorescent lamps with alternate lengths do not represent a significant 

portion of the market. Based on this analysis, DOE is not considering extending coverage to 

linear fluorescent lamps with lengths not currently covered. 

Compact Fluorescent Lamps 

Stakeholders provided specific comments regarding the consideration of pin base CFLs 

and medium base CFLs. In the public meeting, DOE stated that based on preliminary research, 

the percentage of shipments of pin base CFLs compared to currently covered GSFLs is 

approximately 11 percent. (DOE, Public Meeting Transcript, No. 10 at p. 92) The California 

investor-owned utilities, including PG&E, SCE, the San Diego Gas and Electric Company, and 

the Southern California Gas Company, (hereafter the “CA IOUs”) did not agree that this share 

qualifies pin base CFLs as a low volume niche product. (CA IOUs, Public Meeting Transcript, 

No. 10 at pp. 106-107) In written comments, NEMA reported that pin base CFLs represent only 

about 5 percent of the fluorescent market. (NEMA, No. 15 at p. 4) NEMA further asserted that 

pin base CFLs already use 800 series rare earth technology, so there is no meaningful 

opportunity for increased energy savings in this area. Additionally, NEMA stated that there are 

no reasonable substitutes currently available for pin base CFL technologies. (NEMA, No. 15 at 

p. 4) 

In addition to pin base CFLs, DOE also received comments regarding medium base CFLs. 

Earthjustice asserted that DOE is obligated to consider amended standards for medium base 

CFLs in this rulemaking, and that a combined rulemaking would provide an opportunity to use 

DOE’s resources most efficiently. (Earthjustice, No. 14 at p. 3) Earthjustice noted that EISA 

2007 amended EPCA to require that DOE review standards no later than six years after issuance 

of any final rule establishing or amending standards and pointed out that standards for medium 

 

7

 The majority of T12 MBP lamps with lengths less than 4 feet do not comply with the July 2012 standards. 

8

 U.S. Department of Energy. 2010 U.S. Lighting Market Characterization. January 2012. Available at 

http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf. 
2-16

base CFLs (which had a compliance date of January 1, 2006) are due for review. (42 U.S.C. 

6295(m)(1)) (Earthjustice, Public Meeting Transcript, No. 10 at p. 95; Earthjustice, No. 14 at p. 

3) Earthjustice further remarked that even under DOE’s recently announced interpretation that 

EISA 2007’s review obligations run from the date of enactment of EISA 2007, the prudent 

course would be to include medium base CFLs in this rulemaking. Earthjustice further noted that 

the framework document mentioned that pin base CFLs may be included in the analysis, and the 

two products are sufficiently similar that excluding medium base CFLs and relegating them to a 

stand‐alone rulemaking would waste resources. (Earthjustice, No. 14 at p. 4) 

DOE has determined that pin base and medium base CFLs fall within the definition of 

“general service lamps.” (42 U.S.C. 6291(30)(BB)) CFLs are included in the “general service 

lamps” definition, which also mentions general service incandescent lamps, general service LED 

lamps, and organic LED lamps, but excludes any general service fluorescent lamp. DOE has 

determined that the term “compact fluorescent lamps” in this definition includes both pin base 

and medium base CFLs. Under 42 U.S.C. 6295(i)(6), DOE is required to initiate a rulemaking 

for general service lamps no later than January 2014. DOE will consider whether to amend or 

establish standards for general service lamps, including CFLs, in a separate rulemaking 

consistent with this EPCA requirement. 

In conclusion, for all the reasons discussed in this section, DOE is not considering 

extending coverage to any additional GSFL types, including lamps of lengths and shapes not 

covered or CFLs. 

2.3.2.2 Additional Wattages 

DOE specifies a certain minimum wattage for each lamp type included in the definition 

of “fluorescent lamp.” As part of its assessment to identify additional GSFLs that should be 

considered for inclusion under energy conservation standards, DOE reviewed product offerings 

for covered lamps to determine if any new, lower wattage products had been introduced since 

publication of the 2009 Lamps Rule. DOE found lower wattage lamps for the 8-foot single pin 

(SP) slimline, 4-foot T5 miniature bipin (MiniBP) standard output (SO), and 4-foot T5 MiniBP 

high output (HO) lamp types. DOE currently covers 8-foot SP slimline lamps with wattages of 

52 W or more. The 8-foot SP slimline lamps are now being offered in lower wattages of 49 W, 

50 W, and 51 W. DOE currently covers 4-foot T5 MiniBP SO lamps with wattages of 26 W or 

more. The 4-foot T5 MiniBP SO lamps are now being offered at a lower wattage of 25 W. DOE 

currently covers 4-foot T5 MiniBP HO lamps with wattages of 49 W or more. The 4-foot T5 

MiniBP HO lamps are now being offered at lower wattages of 44 W and 47 W. These reduced 

wattage lamps are generally more efficacious than their full wattage counterparts and, because of 

their lower wattage, offer the potential for increased energy savings. Manufacturers generally 

agreed that coverage should be extended to these lower wattage lamps, noting that the lower 

wattage lamp market will only grow in size. Therefore, DOE is considering extending coverage 

to the following GSFLs: 

 8-foot SP slimline lamps with wattages ≥ 49 W and < 52 W; 

 4-foot MiniBP SO lamps with wattages ≥ 25 W and < 26 W; and

 4-foot MiniBP HO lamps with wattages ≥ 44 W and < 49 W. 
2-17

2.3.3 IRL Scope of Coverage 

2.3.3.1 Certain R, ER, and BR IRLs 

 DOE has taken steps to consider standards for certain reflector (R), elliptical reflector 

(ER), and bulged reflector (BR) IRLs, specifically (1) lamps rated 50 W or less that are ER30, 

BR30, BR40, or ER40; (2) lamps rated 65 W that are BR30, BR40, or ER40 lamps; and (3) R20 

IRLs rated 45 W or less. (42 U.S.C. 6295(i)(C)) Additional background can be found at 75 FR 

23191 (May 3, 2010). While DOE received comments related to these lamp types in response to 

the framework document, DOE has suspended these rulemaking activities as a result of section 

315 of Public Law (Pub. L.) 112-74 (Dec. 23, 2011), which prohibits DOE from using 

appropriated funds to implement or enforce standards for ER, BR, and bulged parabolic reflector 

IRLs. DOE therefore does not consider these comments here and has also not included any of the 

types of IRLs specified in Pub. L. 112-74 in this preliminary analysis. The prohibition in Pub. L. 

112-74 has currently been extended through March 27, 2013.

2.3.3.2 Additional Wattages 

EPCA defines an incandescent reflector lamp 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)) In this preliminary analysis, DOE 

assessed the upper limit of the wattage range for covered IRLs, which is currently 205 W. DOE 

reviewed commercially available products in manufacturer catalogs to determine the prevalence 

of products with wattages greater than 205 W. Based on this research, DOE believes that IRLs 

with rated wattages greater than 205 W comprise a very small portion of the market and, 

therefore, do not represent substantial potential energy savings. Furthermore, many of these 

products are designed for specialty uses such as heating and drying in industrial and commercial 

applications or for use in swimming pools. For these reasons, DOE is not considering coverage 

for IRLs with rated wattages greater than 205 W.

2.4 MARKET AND TECHNOLOGY ASSESSMENT 

In the initial stages of an energy conservation standards rulemaking, DOE gathers 

information that provides an overall picture of the market for the products concerned, including 

the nature and market characteristics of the products and the industry structure. This activity 

consists of both quantitative and qualitative analysis, based primarily on publicly available 

information. The subjects addressed in the market and technology assessment for the preliminary 

analysis include the major manufacturers, product classes, retail market trends, shipments of 

covered products, regulatory and non-regulatory programs, and technologies that could be used 

to improve the efficacy of GSFLs and IRLs. This information serves as a resource throughout the 

rulemaking. 

 DOE reviewed existing literature and spoke with manufacturers to gain an understanding 

of the GSFL and IRL industries in the United States. Industry publications (e.g., manufacturer 

catalogs, trade journals), government agencies, and trade organizations provided the bulk of the 

information. Using this information, DOE assessed the overall state of the industry, GSFL and 

IRL manufacturing and market shares, shipments by lamp type, general technical information on 

GSFLs and IRLs, and industry trends. 
2-18

 The discussion below summarizes the analytical approach and the comments DOE 

received in response to the framework document. A more detailed discussion on DOE’s 

approach can be found in the market and technology assessment (chapter 3 of this TSD). 

2.4.1 Market Assessment 

2.4.1.1 Manufacturers of GSFLs and IRLs 

 The GSFL and IRL industries are characterized by both domestic and international 

manufacturers. The majority of covered GSFLs and IRLs are manufactured by three large 

companies. The three manufacturers that hold the majority of the domestic market share of 

GSFLs and IRLs are listed below. 

 GE Consumer and Industrial of General Electric, Inc. (GE) 

 OSRAM SYLVANIA of Siemens AG (OSI) 

 Philips Lighting Company of Philips Electronics North America Corporation (Philips)

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

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

LEDs, and CFLs. 

All three companies are members of NEMA, a trade association that represents 

manufacturers of electrical equipment, including GSFLs and IRLs. NEMA provides an 

organizational framework for manufacturers of lighting products to work together on projects 

that affect their industry and businesses. 

 Although the GSFL and IRL markets are predominantly supplied by large manufacturers, 

DOE intends to conduct a study of small businesses that manufacture GSFLs and IRLs for the 

NOPR stage of this rulemaking analysis. The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) 

requires preparation of an initial regulatory flexibility analysis for every rule that by law must be 

proposed for public comment, unless the agency certifies that the rule, if promulgated, will not 

have a significant economic impact on a substantial number of small entities. A regulatory 

flexibility analysis examines the impact of the rule on small entities and considers alternative 

ways of reducing negative impacts. The Small Business Administration defines small business 

manufacturing enterprises for GSFLs and IRLs under the North American Industry Classification 

System product code 335110, “Electric Lamp Bulb and Part Manufacturing,” which has a size 

standard of 1,000 employees or fewer. This includes the total number of employees in the parent 

company, not only those in the divisions that produce GSFLs and IRLs. DOE invites interested 

parties to provide information for any small businesses that manufacture GSFLs and IRLs and 

should be consulted before DOE publishes a NOPR. 

2.4.2 Technology Assessment 

In the technology assessment, DOE identifies technology options that appear to be 

feasible means of improving lamp efficacy. This assessment provides the technical background 

and structure on which DOE bases its screening and engineering analyses. To develop a list of 

technology options, DOE reviewed manufacturer catalogs, recent trade publications and 

technical journals, and consulted with technical experts. DOE received general comments 
2-19

regarding the methodology presented for the technology assessment as well as specific 

comments on the GSFL and IRL technology options identified; these are discussed in the 

following sections. 

2.4.2.1 GSFL Technology Options 

In the framework document, DOE included a list of technology options to analyze for 

GSFLs. Philips and NEMA stated that for new technologies, most research and development 

(R&D) focuses on LED and organic LED (OLED) opportunities. Given that the fluorescent 

product line is considered a conventional and aging technology, it is unlikely that R&D resources 

would be allotted to fluorescent technology options. (Philips, Public Meeting Transcript, No. 10 

at p. 131; NEMA, No. 15 at p. 8) 

NEMA noted that several of the technology options considered by DOE have reached 

their limit in currently available products. With regards to highly emissive electrode coatings, 

NEMA stated that existing emitters are already designed for energy conservation and long life. 

According to NEMA, further changes could shorten lamp life and any potential improvements 

would be minimal, as electrode losses have been reduced significantly with high frequency 

operation. NEMA also stated that based on current technologies, the limits of gas fill technology 

and high efficiency phosphor technology have been reached by manufacturers and a 

breakthrough is needed to make further improvements. NEMA also commented that 

improvements have been made in the area of glass coatings over the years, but there are no 

actions underway that would result in major improvements. (NEMA, No. 15 at pp. 8-9) 

To conduct the technology assessment, DOE reviews manufacturer catalogs, recent trade 

publications, technical journals, and patent filings; and consults with technical experts and 

manufacturers to ensure it identifies all possible technology options that can increase the efficacy 

of GSFLs. Based on its research DOE has determined that highly emissive electrode coatings, 

higher efficiency fill gas composition, higher efficiency phosphors, and glass coatings can be 

used to improve lamp efficacy. Because lamps are present on the market at more than one level 

of efficiency, these options can be utilized to improve the efficacy of less efficient products. 

Therefore, DOE continues to consider these technology options as means to improve the efficacy 

of fluorescent lamps covered under this rulemaking. DOE determines whether these technologies 

pass the screening criteria in the screening analysis. DOE also considers cost and impacts on 

utility in determining the economic justification of any standard levels developed using these 

technologies. The impacts of lamp lifetime are considered in the cost assessment of this analysis. 

Regarding higher efficiency lamp diameters, NEMA noted manufacturers are already 

producing lamps within the ideal T8 and T5 diameters for maximum efficiency. (NEMA, No. 15 

at p. 9) DOE acknowledges that most products on the market are T8 or T5 diameter lamps. 

However, as with the other technology options noted by NEMA, based on DOE’s assessment 

there are less efficient lamps on the market that can be improved by using a higher efficiency 

diameter. For example, standards-compliant T12 diameter product offerings remain in the 4-foot 

MBP and 8-foot SP slimline product classes. Therefore, DOE is considering maintaining lamp 

diameter as a technology option. DOE acknowledges that the market may be shifting away from 

less efficient diameters and therefore requests comment on whether the high efficiency diameter 

technology option should be retained.
2-20

In summary, DOE is considering the technology options as shown in Table 2.4.1 in this 

preliminary analysis. 

Table 2.4.1. GSFL Technology Options 

Name of Technology Option Description

Highly Emissive Electrode 

Coatings

Improved electrode coatings allow electrons to be 

more easily removed from electrodes, reducing lamp 

power and increasing overall efficacy. 

Higher Efficiency Lamp Fill 

Gas Composition 

Fill gas compositions improve cathode thermionic 

emission or increase mobility of ions and electrons in 

the lamp plasma.

Higher Efficiency Phosphors Phosphors increase the conversion of ultraviolet light 

into visible light.

Glass Coatings 

Coatings on inside of bulb enable the phosphors to 

absorb more UV energy, so that they emit more 

visible light.

Higher Efficiency Lamp 

Diameter Optimal lamp diameters improve lamp efficacy.

Multi-Photon Phosphors Phosphors emit more than one visible photon for 

each incident UV photon.

2.4.2.2 IRL Technology Options 

In the framework document, DOE included a list of technology options to analyze for 

IRLs. DOE received several comments on these options. NEMA commented that the technology 

for these lamps has changed little since the 2009 Lamps Rule, and that there have been no 

technological breakthroughs or innovations that would make the maximum technologically 

feasible (max tech) efficacy for this rulemaking exceed that of the 2009 Lamps Rule. (NEMA, 

No. 15 at p. 16) NEMA further stated that industry is already maximizing IRL efficacy by using 

high pressure tungsten-halogen lamps with filament coiling, efficient filament placement and 

orientation, high efficiency inert fill gas, infrared (IR) glass coatings, and integrally ballasted low 

voltage lamps, where practical. (NEMA, No. 15 at p. 9) 

As mentioned in the previous section, DOE reviews manufacturer catalogs, recent trade 

publications, technical journals, and patent filings; and consults with technical experts and 

manufacturers to ensure it identifies all possible technology options that can increase the efficacy 

of IRLs. DOE understands that the most efficient IRLs on the market may be using one or a 

combination of the technology options noted by NEMA. However, manufacturers offer IRLs 

with multiple levels of efficiency. Because there are less efficient lamps on the market that can 

be improved through the use of these technologies, DOE is considering maintaining filament 

coiling, efficient filament placement and orientation, high efficiency inert fill gas, IR glass 

coatings, and integrally ballasted low voltage lamps as technology options. Based on its review, 

however, DOE is considering removing tungsten halogen as a technology option. DOE has 

determined that this technology is used in all standards-compliant IRLs on the market and 

therefore, is not considering it as a means to improve lamp efficacy. 

NEMA also pointed out certain drawbacks to the technology options identified for 

increasing IRL efficacy. For example, NEMA stated that increased filament temperatures, 

thinner filaments, and microcavity technology will greatly reduce lamp life. (NEMA, No. 15 at 
2-21

p. 9) NEMA also noted that crystallite filament coatings last for a very short period of time. 

(NEMA, No. 15 at p. 9) DOE evaluates the impact of shortened lamp lifetime in the LCC 

analysis. While DOE understands that certain technologies that improve lamp efficacies may 

also lower lamp life, DOE does not consider efficacy levels that necessitate a reduction in lamp 

lifetime (relative to the baseline lamp) to comply with standards. 

NEMA also stated that high efficiency gold reflector coatings are not practical, would be 

extremely costly, and would change light color. (NEMA, No. 15 at p. 9) In the technology 

assessment, DOE evaluates technology options based on their ability to improve lamp efficacy. 

DOE considers whether high efficiency reflector coatings pass the screening criteria in the 

screening analysis, which includes assessing impacts on product utility, such as changes in lamp 

light color. DOE also considers cost in determining the economic justification of any standard 

levels developed using this technology. 

Additionally, NEMA noted that known IR phosphor glass coatings cannot convert IR 

wavelengths into visible light. (NEMA, No. 15 at p. 9) IR phosphor glass coating technology is 

based on the principle that in the presence of infrared light, phosphor ions jump to higher energy 

levels and when the ions fall to lower energy levels, light in the visible spectrum is emitted.9

 In 

researching this issue, DOE found that a prototype solid-state lamp has been developed in which 

IR radiation generated inside the bulb is converted to visible light with a phosphor coating.10

This technology is also being used in commercially available products for non-lighting 

applications (e.g., anti-counterfeiting ink11). Therefore, DOE is maintaining IR phosphor glass 

coatings as a technology option. DOE considers whether IR phosphor glass coatings pass the 

screening criteria in the screening analysis. DOE also considers cost and impacts on utility in 

determining the economic justification of any standard levels developed using this technology. 

Additionally, DOE has identified ultraviolet (UV) phosphor glass coating as a new 

technology option, which is another type of phosphor coating that can potentially increase 

efficacy of incandescent lamps. UV phosphor glass coatings can convert radiation of shorter 

wavelengths (under 500 nm, namely the UV and blue spectrums) into longer wavelengths (the 

green and yellow spectrums), thereby possibly increasing the lumen output of an IRL by 

approximately three percent.12,13 Therefore, DOE is considering UV phosphor glass coatings as a 

technology option that can increase the efficacy of IRLs. See chapter 3 of this TSD for further 

details. 

NEMA also stated that luminescent gas cannot convert IR wavelengths into visible light, 

and that there is insufficient UV energy emitted from a filament to convert into visible light. 

 

9

 Bloembergen, N., "Solid State Infrared Quantum Counters", Physical Review Letters, 2, 84-85 (1959). 

10 Vincent, Jr.; Charles S. “Solid State Lamp Having Visible-Emitting Phosphor at Edge of Infrated-Emitting 

Element.” U.S. Patent 3,774,086, filed September 25, 1972, and issued November 20, 1973. 

11 Boston Applied Technologies Incorporated. Phosphor Powders. 2011. 

http://www.bostonati.com/products_phosper%20power.html 

12 Thorington, L. “Electric Lamp.” United States Patent Office. January 1960. 

http://www.google.com/patents/US2920222 

13 Patton, R.J., et al. “Fluorescent Incandescent Lamp.” United States Patent Office. June 1992. 
2-22

(NEMA, No. 15 at p. 9) In the 2009 Lamps Rule, luminescent gas was described as reacting with 

wavelengths that cannot be detected by the human eye and thereby being able to convert some 

portion of the ‘invisible’ part of the incandescent spectrum into visible light. See chapter 3 of the 

2009 Lamps Rule final rule TSD for the description. DOE further notes that luminescent gas 

technology involves the reaction between a hydrogen fill gas in an incandescent lamp and a 

phosphor coating on its bulb wall that causes thermal energy to be transferred to the phosphor 

coating, thus causing visible light to be emitted. Existing patents also indicate that this 

technology can increase efficacy in IRLs.14,15 However, because DOE does not believe that the 

hydrogen gas fill required for this technology would allow for increased efficacy relative to a 

halogen IRL, DOE is considering removing luminescent gas as a technology option. 

NEMA also added that there are no known novel filament materials with a higher melting 

point than tungsten to produce a non-tungsten-halogen regenerative cycle. (NEMA, No. 15 at p. 

9) DOE recognizes that the non-tungsten-halogen regenerative cycle technology option is 

dependent on the availability of a non-tungsten filament. However, DOE continues to consider 

the non-tungsten-halogen regenerative cycle as a technology option, as patents indicate that nontungsten filament is a viable option in incandescent lamps.16 See chapter 3 of this TSD for 

further discussion. As noted above, DOE considers whether this technology option passes the 

screening criteria in the screening analysis. DOE also considers cost and impacts on utility in 

determining the economic justification of any standard levels developed using this technology. 

NEMA commented that trihedral corner lens reflectors that reflect light back onto the 

filament would have no practical application. (NEMA, No. 15 at p. 9) DOE notes that cost is not 

considered when identifying technology options; cost impacts are assessed in later analyses. 

Regarding efficacy, while DOE is not aware of any commercially available products that 

incorporate trihedral corner lens reflectors, there are patents for this technology that show it can 

be used to increase lamp efficacy. Therefore, DOE continues to consider trihedral corner lens 

reflectors as a technology option. In addition, after further review DOE found that corner cube 

reflector technology has the same effect as trihedral corner reflectors, though uses a different 

reflector shape configuration. Therefore, DOE is replacing the “trihedral corner reflector” 

technology option with “corner reflector” and including both the trihedral corner and corner cube 

reflector technologies under this option. As noted above, DOE considers whether this technology 

option meets the screening criteria in the screening analysis. DOE also considers cost and 

impacts on utility in determining the economic justification of any standard levels developed 

using this technology. 

OSI stated that more advanced infrared glass coatings are limited by temperature, and 

therefore cannot be used above certain wattages or with smaller lamp sizes. (OSI, Public Meeting 

Transcript, No. 10 at p. 193) In response, the CA IOUs claimed that high power products are the 

 

14 Reid; Jack M. et al. “Luminescent Gas Lamp.” U.S. Patent 3,582,252, filed October 20, 1969, and issued June 1, 

1971.

15 Thorington, L. “Electric Lamp.” U.S. Patent 2,920,222, filed August 13, 1957, and issued January 5, 1960. 

16 Van Thyne, Ray J. “Incandescent Lamp Filament Incorporating Hafnium.” U.S. Patent 5,148,080, filed January 

16, 1990, and issued September 15, 1992. 
2-23

best halogen IR lamps and that an upper temperature limit has not yet been reached. (CA IOUs, 

Public Meeting Transcript, No. 10 at p. 194) OSI disagreed, stating that the maximum 

temperature at which IR coatings can be used has been reached. (OSI, Public Meeting Transcript, 

No. 10 at p. 195) Because there are products on the market that use IR coatings and exist at 

multiple levels of efficiency, DOE continues to consider these coatings as a viable technology 

option. 

Regarding improving the efficacy of small diameter IRLs, NEMA noted that safety 

standards have limited technological improvements. (NEMA, Public Meeting Transcript, No. 10 

at p. 192) NEMA commented that it is infeasible for some IRL products to be made with a 

halogen capsule due to size. Further, NEMA stated that there is a minimum distance between the 

halogen capsule and the glass envelope required by Underwriters Laboratories safety standards. 

NEMA also stated that the position of the capsule and design of the reflector must be able to 

provide the same light characteristics as a comparable incandescent filament lamp. (NEMA, 

Public Meeting Transcript, No. 10 at p. 97) DOE received feedback from manufacturers that 

indicated that while thermal and physical constraints make it difficult, but not impossible, to 

incorporate a halogen capsule in a small diameter IRL. Recognizing that the same technology 

options may not be available for small diameter lamps as for large diameter lamps, DOE may 

address this issue by maintaining separate product classes for small diameter lamps (i.e., less 

than or equal to 2.5 inches) and large diameter lamps (i.e., greater than 2.5 inches) given the 

utility of small diameter lamps provided through their installation in smaller fixtures. DOE 

would directly analyze and develop efficacy levels for the large diameter lamps and then apply a 

scaling factor to determine efficacy levels for small diameter lamps. DOE acknowledges that it 

may be difficult to fit a double-ended halogen capsule into a small diameter lamp. Therefore, 

DOE would apply an additional scaling factor for small diameter lamps that accounts for the 

efficacy reduction between a double-ended and single-ended capsule. See section 2.6.6 and 

chapter 5 of this TSD for further details. 

In addition to the technologies presented in the framework document, DOE has identified 

four new technology options for improving the efficacy of IRLs: UV phosphor glass coatings, 

high reflectance filament supports, permanent infrared reflector coating shroud, and electron 

stimulated luminescence. UV phosphor glass coatings are discussed above. High reflectance 

filament supports have a reflective face that can reflect light back to a filament, another reflective 

face, or radially outward. A permanent infrared reflector coating shroud contains a substrate and 

infrared reflective coating that reflects light back to the filament and can be used over the 

lifetimes of multiple lamps. Electron stimulated luminescence is a process involving a low 

voltage cathodoluminescent phosphor that emits visible light when struck by the electrons 

thermally ejected by an incandescent filament. See chapter 3 of this TSD for further information 

on all the identified technology options. 

In summary, the technology options for IRLs considered in this preliminary analysis are 

listed in Table 2.4.2.
2-24

Table 2.4.2. IRL Technology Options 

Name of Technology Option Description

Higher Temperature Operation 

Operating the filament at higher temperatures, the 

spectral output shifts to lower wavelengths, 

increasing its overlap with the eye sensitivity curve. 

Microcavity Filaments 

Texturing, surface perforations, microcavity holes 

with material fillings, increasing surface area and 

thereby light output. 

Novel Filament Materials 

More efficient filament alloys that have a high 

melting point, low vapor pressure, high strength, 

high ductility, or good radiating characteristics. 

Thinner Filaments 

Thinner filaments to increase operating temperature. 

This measure may shorten the operating life of the 

lamp. 

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

increasing light output. 

Crystallite Filament Coatings 

Layers of micron or submicron crystallites deposited 

on the filament surface that increases emissivity of 

the filament. 

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. 

Higher Efficiency Inert Fill Gas Filling lamps with alternative gases, such as 

Krypton, to reduce heat conduction.

Higher Pressure TungstenHalogen Lamps 

Increased halogen bulb capsule pressurization, 

allowing higher temperature operation.

Non-Tungsten-Halogen 

Regenerative Cycles Novel filament materials that regenerate.

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. 

IR Phosphor Glass Coatings

Phosphor coatings that can absorb IR radiation and 

re-emit it at shorter wavelengths (visible region of 

light), increasing the lumen output. 

UV Phosphor Glass Coatings

Phosphor coatings that convert UV radiation into 

longer wavelengths (visible region of light), 

increasing the lumen output.

Electron Stimulated 

Luminescence

A low voltage cathodoluminescent phosphor that 

emits green light (visible region of light) upon 

impingement by thermally ejected electrons, 

increasing the lumen output. 

Integrally Ballasted Low

Voltage Lamps 

An integral ballast converts the operating voltage of 

the lamp from line voltage to a lower voltage. 

Higher Efficiency Reflector 

Coatings 

Alternative reflector coatings such as silver, with 

higher reflectivity increase the amount of directed 

light. 

Corner Reflectors 

Individual corner reflectors in the cover glass that 

reflect light directly back in the direction from which 

it came. 

Efficient Filament Placement 

Placement of the filament so that a portion of the 

spectrum emitted by the filament is focused back 

onto the filament, increasing operating temperature. 
2-25

Name of Technology Option Description

High Reflectance Filament 

Supports

Filament supports that include a reflective face that 

reflects light to another filament, the reflective face 

of another filament support, or radially outward.

Permanent Infrared Reflector 

Coating Shroud

Permanent shroud with an infrared reflector coating 

and a removable and replaceable lamp can increase 

efficiency while reducing manufacturing costs by 

allowing infrared reflector coatings to be reused. 

2.4.3 Product Classes 

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

capacity of the product; or (c) other performance-related features that justify different standard 

levels, considering the consumer utility of the feature and other relevant factors. (42 U.S.C. 

6295(q)) In the framework document, DOE considered maintaining the same product class 

divisions as those established by the 2009 Lamps Rule for GSFLs and IRLs. DOE received 

several comments regarding these product class divisions. The comments and responses are 

summarized in the sections below. 

2.4.3.1 GSFL Product Class Divisions 

In the framework document, DOE considered establishing product classes for GSFLs 

based on the following three factors: (1) correlated color temperature (CCT); (2) physical 

constraints of lamps (i.e., lamp shape and length); and (3) lumen package. 

With regards to separating product classes by CCT, NEMA agreed that color temperature 

should remain a differentiator because color temperature impacts efficacy; specifically, the 

higher the color temperature, the lower the efficacy. Furthermore, NEMA stated that setting the 

same standard for various color temperatures would change the product design and cost 

structure, making high CCT lamps much more expensive. (NEMA, No. 15 at p. 5) 

Because CCT is a measure of the perceived color of the white light emitted from the 

lamp, different CCTs provide consumers with different perceptions of light and thus different 

utility. Additionally, DOE determined through analysis and confirmed with manufacturers that 

lamps with CCTs greater than 4500 K show a decline in efficacy. Because of the impact on 

efficacy and utility, DOE is considering establishing a separate product class for lamps with 

CCTs less than or equal to 4500 K and greater than 4500 K. See Table 2.4.3 for a GSFL product 

class summary and chapter 3 of this TSD for further discussion. 

DOE is also considering separating lamps into product classes based on physical 

constraints because lamp geometry can prohibit a lamp from acting as a direct replacement, 

which impacts consumer utility. The geometry of a lamp often impacts efficacy. For example, 8-

foot linear lamps generally have higher efficacies than 4-foot linear lamps. However, 8-foot 

linear lamps cannot serve as substitutes for 4-foot linear lamps because the footprint of the 

original fixture is too small to accommodate the replacement fixture. Similarly, 4-foot MBP 

linear lamps are more efficacious than 2-foot MBP U-shaped lamps because the electrical arc 

within the tube does not have to bend to conform to the lamp shape. However, 4-foot MBP linear 

lamps are not adequate replacements for 2-foot MBP U-shaped lamps due to physical 
2-26

constraints. Because of the impact on both utility and efficacy, DOE is considering establishing 

separate product classes based on lamp shape and length. 

OSI remarked that if additional product types such as shorter length or pin base 

fluorescent lamps were included, they would have to reanalyze product classes to confirm 

appropriateness. (OSI, Public Meeting Transcript, No. 10 at p. 123) As noted previously, DOE is 

not considering extending coverage to additional GSFL types. 

NEMA and the CA IOUs stated that DOE should continue to maintain separate product 

classes for T5 lamps. (NEMA, No. 15 at p. 5; CA IOUs, Public Meeting Transcript, No. 10 at p. 

121). NEMA stated that T5 lengths, bases, lamp holders, and performance characteristics are 

different from the T8 and T12 products currently included in the standard. Specifically, NEMA 

noted that a nominal 4-foot T5 lamp is actually two inches shorter than a nominal 4-foot T8 or 

T12 lamp, and T5 lamps require different fixtures than T8 or T12 lamps. Based on these 

differences, NEMA asserted that a T5 lamp would rarely be a direct replacement for a T8 or T12 

lamp. Further, NEMA stated that T5s are measured at high frequency, while T8 and T12 lamps 

are measured at 60 hertz (Hz). Efficacies of fluorescent lamps are generally higher when 

measured at high frequency than when measured at low frequency and therefore T5 lamps may 

appear more efficient because of test conditions. Due to differences in physical characteristics 

and performance, NEMA supported the continued separation of T5 from T8 and T12 lamps. 

(NEMA, No. 15 at pp. 5-6) 

DOE is considering maintaining separate product classes for T5 lamps due to differences 

in efficacy and utility (i.e., lumen package). DOE’s test procedure for GSFLs requires lamps to 

be tested using low frequency reference ballast settings unless only high frequency settings are 

available. Because only high frequency settings are available for T5 lamps, these lamps are 

tested under different conditions than T8 lamps. High frequency operation increases lamp lumen 

output; thus, T5 lamps appear to be more efficacious than similar T8 lamps. If T5 and T8 lamps 

were included in the same product class, T8 lamps could be eliminated due to this difference in 

efficacy. T8 lamps, however, provide consumer utility because more lumen packages are 

available for T8 than for T5 lamp-and-ballast systems. Lumen package refers to the quantity of 

light that a lamp-and-ballast system provides to a consumer. Consumers tend to use systems with 

different lumen packages for different applications. Most of the commercially available 4-foot 

T5 MiniBP SO lamps offer the same initial lumen output. Specifically, 80 percent of standardscompliant 4-foot T5 MiniBP SO lamps have an initial lumen output of 2900 lumens.17 On the 

other hand, 4-foot T8 MBP lamps offer a much wider range of initial lumen outputs. 

Additionally, as discussed in section 2.6, fluorescent lamps are a component of a system and 

their performance characteristics are related to the ballast on which they operate. Each 

fluorescent lamp ballast has a specified ballast factor, which is typically used to adjust the lumen 

package of a lamp-and-ballast system. The vast majority of ballasts designed to operate 4-foot 

T5 MiniBP SO lamps have normal ballast factors (BFs), which further limits lumen package 

options for these lamp-and-ballast systems. Ballasts that operate 4-foot T8 MBP lamps, however, 

are available with a larger range of BF options (i.e., low, normal, and high). Thus, a standard that 

 

17 Data in catalogs is often reported at 35°C. 
2-27

eliminates 4-foot T8 MBP lamps would result in a substantial decrease in available lumen 

package options and negatively impact consumer utility. DOE acknowledges that consumers 

must often replace both the fixture and ballast when installing a T5 system in place of a T8 or 

T12 system. However, because fixture and ballast purchases would be accounted for in later 

economic analyses (i.e., the LCC and NIA), DOE does not consider this to be a reason to 

establish a separate product class division. 

DOE also received comments supporting separate product classes for SO versus HO

lamps. NEMA recommended separate product classes for T5 MiniBP HO and T5 MiniBP SO

lamps due to the differences in current, and thus efficacy, between the two lamp types. (NEMA, 

Public Meeting Transcript, No. 10 at pp. 119-120) Specifically, NEMA noted that HO lamps are 

less efficacious than SO lamps. (NEMA, No. 15 at p. 5) DOE agrees that HO lamps are operated 

at a higher current than SO lamps, which decreases efficacy. Furthermore, because of this 

difference in operating current, HO lamps produce more light per unit of lamp length than SO

lamps. DOE has determined that consumers use systems with different light outputs, or lumen 

packages, for different applications. For example, HO systems are typically used in industrial 

applications, such as high bays, whereas SO systems are normally installed in general 

commercial applications. Because of the difference in efficacy and consumer utility, DOE is 

considering separate product classes for SO and HO lamps. 

In summary, DOE is considering establishing the product classes shown in Table 2.4.3. 

See chapter 3 of this TSD for further discussion. 

Table 2.4.3 GSFL Product Classes 

Lamp Type CCT

4-foot medium bipin ≤ 4,500 K

> 4,500 K

2-foot U-shaped ≤ 4,500 K

> 4,500 K

8-foot single pin slimline ≤ 4,500 K

> 4,500 K

8-foot recessed double contact high output ≤ 4,500 K

> 4,500 K

4-foot T5, miniature bipin standard output ≤ 4,500 K

> 4,500 K

4-foot T5, miniature bipin high output ≤ 4,500 K

> 4,500 K

2.4.3.2 IRL Product Class Divisions 

In the framework document, DOE considered establishing product classes for IRLs based 

on the following three factors: (1) rated voltage; (2) lamp spectrum; and (3) lamp diameter. 

NEMA remarked that, as determined during the 2009 Lamps Rule, voltage, spectrum, and lamp 

diameter all impact lamp performance, and therefore should result in separate classes. (NEMA, 

No. 15 at p. 6) 

DOE also received several comments regarding the product class division based on rated 

voltage. Existing DOE test procedures provide for lamps rated at 130 V to be tested at 130 V and 
2-28

for lamps rated at 120 V to be tested at 120 V. However, DOE is aware that a large number of 

consumers actually operate 130 V lamps at 120 V, which results in longer lifetime but lower 

efficacy. With a single efficacy level (EL) for lamps rated at each voltage, this situation would 

effectively lead to a lower efficacy requirement for these 130 V lamps that are run at 120 V, 

compared to 120 V lamps run at 120 V. The 130 V lamps would not require the same level of 

technology as 120 V lamps to meet the same standard, and, thus, they would be cheaper to 

produce. Therefore, setting higher standards for IRLs without accounting for voltage differences 

could result in increased migration to 130 V lamps instead of the 120 V lamps, which could 

increase energy consumption. 

NEMA noted that lamps designed for 130 V operate at about the same efficacy when 

operated at 130 V as lamps designed for 120 V operated at 120 V. Further, NEMA predicted that 

the standards adopted by the 2009 Lamps Rule would eliminate all 130 V products, which would 

result in a loss of utility for users requiring the higher voltage lamps and eliminate the need to 

maintain the 130 V product class. (NEMA, No. 15 at p. 6) Philips noted that there are parts of the 

United States that operate at 130 V and operating lamps at higher than rated voltage causes 

premature failure and excessive light output. (Philips, Public Meeting Transcript, No. 10 at p. 

133) OSI added that a unique utility has been removed by eliminating 130 V lamps from the 

market because when a 130 V lamp is run at 120 V, it operates at a reduced wattage, which 

results in energy savings. (OSI, Public Meeting Transcript, No. 10 at pp. 133-134) 

The CA IOUs also provided comments on voltage as a class distinction. (CA IOUs, 

Public Meeting Transcript, No. 10 at p. 126) The CA IOUs suggested requiring all lamps to be 

tested at 120 V, as the majority of line voltage is 120 V, and pointed out that this change would 

make it unnecessary to have a separate product class for 130 V lamps. However, they noted that 

if testing at 130 V is allowed, a separate product class needs to be maintained to prevent 

backsliding. (CA IOUs, Public Meeting Transcript, No. 10 at pp. 132-133) 

DOE remains concerned that the operation of 130 V lamps at 120 V has the potential to 

significantly affect energy savings. DOE agrees with OSI that there is both a wattage and light 

output reduction when 130 V lamps are operated under 120 V conditions. The reduction in 

wattage, however, could be outweighed by consumers eventually migrating to higher wattage 

products or installing additional lamps. A 130 V lamp operating on a 120 V circuit is in a 

partially dimmed mode. When consumers purchase 130 V lamps and operate them at 120 V, they 

may choose to install more lamps or lamps of higher wattages to obtain sufficient light output. 

These lamps would consume more energy than standards-compliant 120 V lamps. Therefore, 

DOE is considering establishing separate product classes for lamps with rated voltages greater 

than or equal to 125 V and less than 125 V. 

In addition to voltage, DOE is considering establishing separate product classes based on 

lamp spectrum and diameter. Modified spectrum18 lamps provide unique utility to consumers 

 

18 As found in 10 CFR 430.2: 

Modified spectrum means, with respect to an incandescent lamp, an incandescent lamp that— 

(1) Is not a colored incandescent lamp; and 
2-29

because they provide a different type of light than standard spectrum lamps. However, the same 

technologies that modify the spectral emission of a lamp also decrease lamp efficacy. Similarly, 

IRL diameter provides a distinct utility to the consumer, such as the ability to be installed in 

smaller fixtures. However, small diameter lamps have an inherently lower optical efficiency than 

large diameter lamps with similar filaments, and technology options available to larger lamps are 

not necessarily applicable to small diameter lamps given the spatial constraints. Because of the 

impacts on both efficacy and consumer utility, DOE is considering establishing separate product 

classes based on lamp spectrum and diameter. 

In conclusion, DOE is considering establishing the product classes shown in Table 2.4.4. 

See chapter 3 of this TSD for further discussion. 

Table 2.4.4. IRL Product Classes 

Spectrum Diameter Voltage

Standard Spectrum

> 2.5 inches ≥ 125 V

< 125 V

≤ 2.5 inches ≥ 125 V

< 125 V

Modified Spectrum

> 2.5 inches ≥ 125 V

< 125 V

≤ 2.5 inches ≥ 125 V

< 125 V

2.5 SCREENING ANALYSIS 

After DOE identifies the technologies that improve the efficacy of GSFLs and IRLs, 

DOE conducts the screening analysis. The purpose of the screening analysis is to determine 

which options to consider further and which options to screen out. DOE consults with industry, 

technical experts, and other interested parties in developing a list of technology options. DOE 

then applies the following set of screening criteria to determine which options are unsuitable for 

further consideration in the rulemaking (10 CFR Part 430, subpart C, appendix A at 4(a)(4) and 

5(b)): 

 Technological Feasibility: DOE will consider technologies incorporated in commercially 

available products or in working prototypes to be technologically feasible. 

 

(2) When operated at the rated voltage and wattage of the incandescent lamp— 

(A) Has a color point with (x,y) chromaticity coordinates on the C.I.E. 1931 chromaticity diagram, figure 2, page 3 

of IESNA LM-16 (incorporated by reference; see § 430.3) that lies below the black-body locus; and 

(B) Has a color point with (x,y) chromaticity coordinates on the C.I.E. 1931 chromaticity diagram, figure 2, page 3 

of IESNA LM-16 (incorporated by reference; see § 430.3) that lies at least 4 MacAdam steps, as referenced in 

IESNA LM-16, distant from the color point of a clear lamp with the same filament and bulb shape, operated at the 

same rated voltage and wattage. 
2-30

 Practicability to Manufacture, Install, and Service: If mass production of a technology 

and reliable installation and servicing of the technology could be achieved on the scale 

necessary to serve the relevant market at the time the standard comes into effect, then 

DOE will consider that technology practicable to manufacture, install, and service. 

 Adverse Impacts on Product Utility or Product Availability: If DOE determines a 

technology to have significant adverse impact on the utility of the product to significant 

subgroups of consumers, or to result in the unavailability of any covered product type 

with performance characteristics (including reliability), features, sizes, capacities, and 

volumes that are substantially the same as products generally available in the United 

States at the time, it will not further consider this technology. 

 Adverse Impacts on Health or Safety: If DOE determines that a technology will have 

significant adverse impacts on health or safety, it will not further consider this 

technology. 

Those technology options not screened out by the above four criteria are called “design 

options” and are considered as possible methods of improving efficacy in the engineering 

analysis. 

2.5.1 GSFL Design Options 

In the framework document, of the GSFL technology options identified, DOE considered 

screening out multi-photon phosphors. NEMA agreed that it is still appropriate to screen out the 

multi-photon phosphor technology because cost effective, improved performance phosphors 

have not been identified. (NEMA, No. 15 at pp. 9-10) In this preliminary analysis, DOE is 

considering screening out multi-photon phosphor technology based on the first criterion, 

technological feasibility, because the technology is still in the research phase and DOE is 

unaware of any prototypes or commercially available products that incorporate the technology. 

See chapter 4 of this TSD for further details. 

Given rare earth phosphor availability and cost issues, NEMA stated that all coating 

resources used in the implementation of higher efficiency phosphors are being used to reduce 

losses and optimize current technology performance rather than attain further improvements in 

lamp efficacy. (NEMA, No. 15 at p. 8) DOE has found lamps which utilize higher efficiency 

phosphors to be widely commercially available and of varying efficacies. Therefore, DOE 

considers this technology option as means of improving lamp efficacy to be practicable to 

manufacture, install, and service. DOE understands there are concerns regarding a limited supply 

of rare earth phosphors that may impact the application of this technology option. See section 

2.6.7 for further discussion on this issue. DOE also notes that it considers the economic impacts 

of rare earth phosphor availability and costs on individual consumers, manufacturers, and the 

nation in later analyses. 

GSFL technologies that DOE has not screened out and is still considering as design 

options include: 

 Highly Emissive Electrode Coatings 
2-31

 Higher Efficiency Lamp Fill Gas Composition 

 Higher Efficiency Phosphors 

 Glass Coatings 

 Higher Efficiency Lamp Diameter 

For further details, see chapter 4 of this TSD. 

2.5.2 IRL Design Options 

In the framework document, DOE identified several technology options for IRLs. NEMA 

stated that high efficiency gold reflector coatings should not be considered because this 

technology would change the color of the light emitted from a lamp. (NEMA, No. 15 at p. 9) 

DOE reviewed literature on this technology option and found that gold reflectivity diminishes at 

and below blue-green wavelengths, which may diminish the color quality of light, thereby 

impacting product utility. Further, gold reflector coatings have thus far been used mainly in 

lamps that produce infrared and near-infrared light – for example, heat lamps or lamps intended 

to specifically change the color of light, such as those used for photography purposes. Therefore, 

use of these reflector coatings may not be suitable for general lighting applications. Hence, DOE 

is screening out high efficiency gold reflector coatings due to adverse impact on product utility. 

 In this preliminary analysis, of the IRL technology options identified, DOE is considering 

screening out the following: 

 high reflectance filament supports and permanent infrared reflector coating shroud 

because they could not be proven to be technologically feasible; 

 crystallite filament coatings, infrared phosphor glass coating, UV phosphor glass coating, 

electron stimulated luminescence, and corner reflectors because they could not be proven 

to be practicable to manufacture, install, and service; 

 high efficiency gold reflector coatings, because they could potentially have adverse 

impacts on product utility or product availability; and

 microcavity filaments, novel filament materials, and non-tungsten-halogen regenerative 

cycles because they could not be proven practicable to manufacture, install, and service 

or could potentially have adverse impacts on product utility or product availability.

IRL technologies that DOE has not screened out and is still considering as design options 

include: 

 Higher Temperature Operation 

 Thinner Filaments 

 Efficient Filament Coiling 

 Efficient Filament Orientation 

 Higher Efficiency Inert Fill Gas 

 Higher Pressure Tungsten-Halogen Lamps 

 Infrared Glass Coatings 

 Integrally Ballasted Low Voltage Lamps 
2-32

 Higher Efficiency Reflector Coatings (with the exception of gold reflector coatings) 

 Efficient Filament Placement 

For further details, see chapter 4 of this TSD. 

2.6 ENGINEERING ANALYSIS 

 In the engineering analysis, DOE selects representative product classes to analyze. It then 

selects baseline lamps within those representative product classes, and identifies more 

efficacious substitutes for the baseline lamps. DOE uses these more efficacious lamps to develop 

CSLs. 

 For this rulemaking, DOE derives ELs in the engineering analysis and end-user prices in 

the product price determination. DOE estimates the end-user price of GSFLs and IRLs directly 

because reverse-engineering a lamp is impractical as the lamps are not easily disassembled. By 

combining the results of the engineering analysis and the product price determination, DOE 

derives typical inputs for use in the LCC and NIA. Section 2.7 discusses the product price 

determination (see chapter 7 of this TSD for further detail). 

2.6.1 Approach 

The following is a summary of the steps taken in the engineering analysis: 

 Step 1: Select Representative Product Classes 

 Step 2: Select Baseline Lamps 

 Step 3: Identify More Efficacious Substitutes 

 Step 4: Develop CSLs 

 A more detailed discussion of the methodology DOE followed to perform the engineering 

analysis can be found in chapter 5 of this TSD. The following discussion summarizes the general 

steps of the engineering analysis: 

 Representative product classes: DOE first reviews covered lamps and the associated 

product classes. When a product has multiple product classes, DOE selects certain classes as 

“representative” and concentrates its analytical effort on these classes. DOE selects 

representative product classes primarily because of their high market volumes. For those product 

classes that are not analyzed, DOE extrapolates the CSLs from representative product classes. 

 Baseline lamps: For each representative product class, DOE selects a baseline lamp as a 

reference point against which to measure changes resulting from energy conservation standards. 

Typically, a baseline model is the most common, least efficacious lamp sold in a given product 

class. For this preliminary analysis, DOE uses performance data presented in manufacturer 

catalogs to determine lamp efficacy. DOE also considers other lamp characteristics in choosing 

the most appropriate baseline for each product class such as wattage, lumen output, and lifetime. 
2-33

For some of the representative product classes, DOE selects multiple baseline models to ensure 

consideration of different consumer economics. 

More efficacious substitutes: DOE selects higher efficacy lamps as replacements for each 

of the baseline models considered. When selecting higher efficacy lamps, DOE considers only 

design options that meet the criteria outlined in the screening analysis (see section 2.5 or chapter 

4 of this TSD). For GSFLs, DOE pairs each lamp with an appropriate ballast because fluorescent 

lamps are a component of a system, and their performance is related to the ballast on which they 

operate. For this preliminary analysis, DOE developed a model lamp to consider as a more 

efficacious substitute for the 4-foot T5 MiniBP HO baseline lamp (see chapter 5 and appendix 

5A of this TSD for further detail). 

 Candidate standard levels: After identifying the more efficacious substitutes for each 

baseline lamp, DOE develops CSLs. DOE bases its analysis on three factors: (1) the design 

options associated with the specific lamps studied; (2) the ability of lamps across wattages to 

comply with the standard level of a given product class;19 and (3) the maximum technologically 

feasible EL. DOE then scales the CSLs of representative product classes to those classes not 

directly analyzed. 

 DOE received several comments on the general approach to the engineering analysis 

presented in the framework document. NEMA stated that the analysis should not be based on 

assumptions and projections and that data from truly representative products should be used 

when developing baseline and max tech estimates. (NEMA, Public Meeting Transcript, No. 10 at 

pp. 79-80) Therefore, as standards adopted by the 2009 Lamps Rule did not require compliance 

at the time of publication of the framework document for this rulemaking, NEMA recommended 

that DOE wait for information about what products will be commercially available. 

 As mentioned in section 2.2.2, DOE delayed the publication of the preliminary analysis 

to update its product catalogs and assessments based on changes that took place after the 

compliance date of the standards adopted by the 2009 Lamps Rule on July 14, 2012. In 

developing the engineering analysis for this rulemaking, DOE used a database of commercially

available GSFLs and IRLs that included products on the market after the July 2012 standards 

required compliance. DOE supplemented this evaluation with information gathered during 

manufacturer interviews regarding new product lines manufacturers were planning to launch. At 

the time of this analysis, many manufacturers20 had been granted exception relief exempting their 

700 series T8 lamps from the July 2012 standards for a period of two years. The waiver was 

granted due to the global supply restrictions on rare earth phosphors, the rising world demand of 

 

19 CSLs span multiple lamps of different wattages. In selecting CSLs, DOE considered whether these multiple lamps 

can meet the standard levels. 

20 At the time of this analysis, the following manufacturers had been granted exception relief exempting their 700 

series T8 lamps from current standards: Philips, GE, OSI, Ushio America, Halco Lighting Technologies, Premium 

Quality Lighting, Inc., Tailored Lighting, Inc., Litetronics International, Inc., Satco Products, Inc., DLU Lighting 

USA, Westinghouse Lighting Corporation, Ascent Battery Supply, LLC, Eiko, Ltd, and Topaz Lighting 

Corporation. 
2-34

these phosphors, and the resulting impacts on producing higher efficacy GSFLs.21 Because this 

waiver will expire in 2014, and any standards adopted by this rulemaking are expected to require 

compliance in 2017, DOE conducted this preliminary analysis for GSFLs assuming that the 

waiver would not be in place. DOE will continue to examine the impacts of rare earth phosphor 

availability in relation to standards for GSFLs during the course of this rulemaking. 

 NEMA agreed with DOE’s approach to use commercially available GSFL products for 

the development of representative lamps. However, they cautioned against using prototype lamps 

in making determinations for rulemakings if they represent unproven or proprietary designs, 

including proprietary equipment or component technology. (NEMA, No. 15 at pp. 14, 18) OSI 

agreed, stating that standards should not be based on samples produced in labs, but rather on 

lamps that can be produced in high volume. (OSI, Public Meeting Transcript, No. 10 at p. 181) 

 As noted above, for this preliminary analysis, DOE developed a model lamp for the 4-

foot T5 MiniBP HO GSFL product class. See section 2.6.4.1, as well as chapter 5 and appendix 

5A of this TSD, for more detail. In determining whether it is appropriate to consider a CSL based 

on this model lamp, DOE will gather additional information on the manufacturability and 

functionality of this lamp, as well as its projected efficacy when measured according to the DOE 

test procedure. 

 Regarding the GSFL analysis, NEMA cautioned that the true efficacy of a lamp should 

not be assumed to equal the catalog lumens divided by the rated wattage. As an example, NEMA 

noted that F32T8 lamps’ actual wattage could be above both the nominal wattage (32 W) and the 

American National Standards Institute (ANSI) datasheet operating characteristic wattage (32.5 

W). Instead, NEMA suggested using lamp efficacy values submitted to DOE for certification 

purposes. (NEMA, No. 15 at p. 16) The CA IOUs requested that both the rated and reported 

efficacy values be included in the rulemaking. (CA IOUs, Public Meeting Transcript, No. 10 at 

pp. 157-158) NEEA asked for definitions of rated efficacy and catalog efficacy to distinguish the 

difference between the two values. (NEEA, Public Meeting Transcript, No. 10 at p. 158) 

 Recognizing that compliance data is used to verify that products comply with the 

applicable standards, DOE analyzed available compliance data for GSFLs and IRLs. 

(Compliance data is publicly available on DOE’s Compliance Certification Database available 

here: www.regulations.doe.gov/certification-data/.) Because only 38 percent of the covered 

GSFLs compliant with DOE standards (based on catalog values) had corresponding compliance 

data, however, DOE based lamp efficacies for GSFLs used in the engineering analysis on catalog 

lumens divided by ANSI rated wattages, and then made adjustments based on available 

compliance data. Catalog and compliance efficacy values differ because compliance data 

submitted by manufacturers is based on DOE’s test procedure for GSFLs, which requires certain 

statistical evaluation and sampling requirements to address production variability. See section 

2.6.5.1 for further details on compliance data used in this analysis. For wattage values, DOE used 

ANSI rated wattage instead of the nominal wattage provided by manufacturers in catalogs 

 

21 Philips Lighting Company, et al. OHA Case Nos. EXC-12-0001, EXC-12-0002, EXC-12-0003 (2012). Accessible 

here: energy.gov/sites/prod/files/oha/EE/EXC-12-0001thru03.pdf. 
2-35

because it is the result of standardized ANSI testing and represents an industry agreed upon 

wattage. If a lamp type analyzed was not included in the ANSI standard, efficacy was calculated 

using the nominal wattage. 

 EEI expressed approval that DOE is considering proprietary designs and new 

technologies in its analysis. However, EEI added that there could be an issue in the marketplace 

unless there are multiple vendors, especially if the standard is set high enough to remove 

competitors without the proprietary technology from the marketplace. (EEI, Public Meeting 

Transcript, No. 10 at p. 204) NEMA urged DOE to address proprietary designs individually with 

each company. (NEMA, No. 15 at p. 18) DOE considers proprietary designs in its engineering 

analysis only if there are other technology pathways to meet that CSL. DOE does not analyze 

CSLs that can be met by only one proprietary design. 

2.6.2 Representative Product Classes 

 In the case where a covered product had multiple product classes, DOE identified and 

selected certain product classes as “representative” product classes where DOE would 

concentrate its analytical effort. DOE chose these representative product classes primarily 

because of their high market volumes. For GSFLs, in the framework document DOE identified 

the representative product classes as shown (in gray) in Table 2.6.1. DOE did not receive any 

comments regarding the GSFL product classes and is therefore considering maintaining the 

GSFL representative product classes identified in the framework document, based on their high 

market volumes. See chapter 5 of this TSD for additional details. 

Table 2.6.1. GSFL Representative Product Classes 

Lamp Type CCT

4-foot medium bipin ≤ 4,500 K

> 4,500 K

2-foot U-shaped ≤ 4,500 K

> 4,500 K

8-foot single pin slimline ≤ 4,500 K

> 4,500 K

8-foot recessed double contact high output ≤ 4,500 K

> 4,500 K

4-foot T5, miniature bipin standard output ≤ 4,500 K

> 4,500 K

4-foot T5, miniature bipin high output ≤ 4,500 K

> 4,500 K
2-36

 For IRLs, in the framework document DOE identified the representative product class as 

shown (in gray) in Table 2.6.2.

Table 2.6.2. IRL Representative Product Classes 

Lamp Type Diameter Voltage

Standard spectrum

> 2.5 inches

≥ 125 

< 125 (representative)

≤ 2.5 inches

≥ 125

< 125

Modified spectrum

> 2.5 inches

≥ 125

< 125

≤ 2.5 inches

≥ 125

< 125

NEMA generally agreed with the representative product classes DOE was considering for 

IRLs. However, NEMA noted that although large diameter lamps represent the greatest volume 

of IRLs, DOE should also consider small diameter lamps (equal to or less than 2.5 inches in 

diameter) because their small size presents some unique challenges when trying to increase 

efficacy. (NEMA, No. 15 at p. 12) As noted by NEMA, DOE chose large diameter lamps as 

representative due to their high volume. Based on its market analysis and manufacturer feedback, 

DOE continues to find that small diameter lamps comprise a very small portion of the market. 

DOE acknowledges that efficacy is impacted by diameter and has accounted for this relationship 

in a reduction factor developed to scale from ELs for large diameter lamps to those for the small 

diameter lamps (see section 2.6.6.1 for further details). Therefore, DOE is maintaining the IRL 

representative product class identified in the framework document. 

2.6.3 Baseline Lamps 

 Once DOE identified the representative product classes for analysis, it selected baseline 

lamps to analyze in each class. Typically, a baseline lamp is the most common, least efficacious 

lamp that meets existing energy conservation standards. Specific lamp characteristics are used to 

characterize the most common lamps purchased by consumers today (e.g., wattage and light 

output). Where necessary, DOE selected multiple baseline lamps to ensure consideration of 

different high volume lamps and their associated consumer economics. As the lamps must meet 

the July 2012 standards, in the framework document DOE presented baseline lamps analyzed as 

representative units at the standard levels adopted in the 2009 Lamps Rule. 

 

 DOE received general comments regarding these baselines. PG&E and SCE found the 

baseline performance levels given in the framework document to be too high and suggested 

adjusting them to reflect baseline products currently available in the market. They also 

recommended waiting to finalize the baseline performance level assumptions until after the 

compliance date of the standards adopted in the 2009 Lamps Rule. (PG&E and SCE, No. 17 at p. 

2) In this preliminary analysis, DOE identified baseline lamps by reviewing products available 

on the market after the July 2012 standards required compliance. Therefore, the resulting 
2-37

baseline ELs are reflective of commercially available products that are the most common, least 

efficacious lamps available in each representative product class. 

 Comments specific to the GSFL and IRL baseline selections are discussed in the sections 

below. 

2.6.3.1 General Service Fluorescent Lamps 

 For fluorescent lamps, the most common lamps were determined based on characteristics 

such as wattage, lumen output, lifetime, and CCT. For each representative product class, DOE 

identified a baseline lamp to be the most common, least efficacious lamp that just complied with 

standards adopted by the 2009 Lamps Rule (i.e., July 2012 standards). In the framework 

document, DOE presented as baseline lamps the full wattage representative units analyzed at the 

standard levels adopted in 2009 Lamps Rule (TSL 4). Additionally, based on the assumption that 

very few commercially available T12 lamps would be able to meet the July 2012 standards, DOE 

did not analyze T12 lamps as baselines. DOE received several comments specific to the GSFL 

baselines considered in the framework document. 

 

 NEMA stated that the baseline lamps being considered should not have a higher efficacy 

than the minimum efficacy required by the 2009 Lamps Rule. (NEMA, No. 15 at pp. 12-13) 

Lutron requested clarification on why the considered baseline value for the 4-foot T8 baseline 

does not match the max tech level established in the 2009 Lamps Rule. (Lutron, Public Meeting 

Transcript, No. 10 at p. 147) 

 Baseline lamps are typically products that just meet existing standards. Therefore, in the 

framework document, DOE considered baseline lamps to be the representative units identified at 

the standard levels adopted in the 2009 Lamps Rule (TSL 4), not the products identified at the 

max tech levels in that rule (TSL 5). In the framework document, the efficacies presented were 

based on catalog values of the representative lamps. In the 2009 Lamps Rule, DOE utilized 

catalog values to develop initial ELs and then analyzed available compliance reports to establish 

minimum efficacy requirements. Therefore, the catalog efficacies presented in the framework 

document were different than the standards adopted in the 2009 Lamps Rule. 

 DOE also received several comments on considering T12 diameter lamps as baseline 

lamps for the 4-foot MBP, 8-foot SP slimline, and 8-foot RDC HO product classes. The CA 

IOUs commented that low-efficacy, high-CRI T12 lamps not covered by standards should be 

analyzed as baseline lamps for the 4-foot MBP product class, as these will compete with the 

more efficient T8 lamps. (CA IOUs, Public Meeting Transcript, No. 10 at pp. 163-164) 

However, Earthjustice noted that the impact of standards cannot be measured against exempt 

products that would remain on the market. (Earthjustice, Public Meeting Transcript, No. 10 at 

pp. 165-166) 

 Exempt products are not considered as baseline lamps in this rulemaking because 

baseline lamps are determined for each product class for which DOE is considering standards, 

and it would be inappropriate to select a baseline lamp not in a particular product class as a 

baseline for that product class. Fluorescent lamps with a CRI greater than or equal to 87, also 

referred to as high-CRI lamps, are exempt from the definition of general service fluorescent lamp 

(see 10 CFR 430.2), and are therefore not included in the scope of this rulemaking. 
2-38

 DOE also received comments regarding T12 products that are included in the scope of 

this rulemaking. ASAP stated that any covered T12 lamp able to meet the July 2012 standards 

and expected to make up a significant portion of the market should be considered as the baseline. 

(ASAP, Public Meeting Transcript, No. 10 at p. 166) However, NEEA stated, and Philips agreed, 

that T12 lamps that comply with the July 2012 standards should be analyzed as baselines even if 

there are only a few on the market and price information is not yet available. (NEEA, Public 

Meeting Transcript, No. 10 at pp. 168-169; Philips, Public Meeting Transcript, No. 10 at p. 169) 

NEMA agreed that T12 lamps should be analyzed as a baseline, noting that there will still be T12 

lamps that meet the July 2012 standards in both 8-foot categories. (NEMA, No. 15 at p. 13) 

Although OSI noted that there are covered T12 products in the marketplace that meet the July 

2012 standards, NEMA stated that T12 baseline lamps need not be considered for the 4-foot 

MBP and 2-foot U-shaped product classes because there will be only a few, if any, T12 lamps 

that meet the July 2012 standards in these product categories. (OSI, Public Meeting Transcript, 

No. 10 at p. 167; NEMA, No. 15 at p. 13) PG&E and SCE suggested that regardless of whether 

standards-compliant T12 lamps are available after July 2012, DOE should establish GSFL 

baselines from the least efficacious products available on the market at that time. (PG&E and 

SCE, No. 17 at p. 3) 

 DOE’s review of the market has shown that some manufacturers offer T12 lamps in the 

4-foot MBP and 8-foot SP slimline product classes that comply with the July 2012 standards. 

Feedback from manufacturer interviews indicated, however, that new shipments were shifting 

away from these lamp diameters. This shift is also evident from shipment information provided 

by NEMA, which shows a steady decrease in 4-foot MBP T12 shipments from 2006 to 2011 and, 

with the exception of a slight rise in 2010, a consistent decrease in 8-foot SP slimline T12 

shipments between 2006 and 2011 (see chapter 3 of this TSD). Further, DOE has set standards 

for fluorescent lamp ballasts with a compliance date of November 14, 2014 that will make it 

difficult for any remaining T12 electronic ballasts to comply. 76 FR 70548 (November 14, 

2011). Because the recent lamp and ballast standards, as well as projected market trends, indicate 

decreasing use of T12 lamps in all product classes, DOE has not included T12 lamps as 

baselines. 

 Stakeholders also provided specific comments on the baselines for the 4-foot MBP 

product class. NEMA disagreed with the baseline for the 4-foot MBP product class identified in 

the framework document. NEMA stated that a 3,000-lumen lamp does not represent the lowest 

efficacy lamp that will meet the new minimum standard and recommended a lamp with initial 

light output of 2,850 lumens. (NEMA, No. 15 at pp. 12-13) EEI also noted that for the 4-foot 

MBP lamp, using the 92.3 lm/W baseline considered in the framework document instead of the 

89 lm/W standard set in the 2009 Lamps Rule would result in a maximum efficacy improvement 

of only 0.76 percent when compared to the EL1 of 93 lm/W considered in the framework. (EEI, 

No. 13 at p. 3) 

 DOE surveyed available product catalogs and also received feedback on available 

products during manufacturer interviews for this preliminary analysis. Based on its review of the 

market, DOE is considering a baseline lamp for the 4-foot MBP product class that has an initial 
2-39

lumen output of 2900 lumens and a calculated efficacy of 89.2 lm/W, which is representative of 

the most common, least efficacious lamps in this product class that meet the July 2012 standards. 

NEMA also disagreed with the baseline for the 8-foot RDC HO product class, stating that 

an 86 W T8 lamp is not the least efficacious lamp that will meet July 2012 standards. 

Furthermore, NEMA noted that DOE’s test procedure for GSFLs requires these lamps to be 

measured without cathode heat, resulting in an increase of their measured efficacy. NEMA 

suggested an energy saving (95 W) T12 HO lamp as the baseline. Additionally, NEMA stated 

that two different baseline levels of 8-foot RDC HO T8 lamps do not need to be included as it is 

a very low volume lamp type. (NEMA, No. 15 at p. 13) 

 The GSFL test procedure requires lamps be tested at low frequency unless only high 

frequency ballast specifications are available for the lamp. The test procedure also specifies that 

for high frequency testing, cathode heat should not be used when the lamp is in operation. The 

lamps covered by this rulemaking that have only high frequency ballast specifications and are 

therefore tested without cathode heat include 8-foot T8 RDC HO, 4-foot T5 MiniBP SO, and 4-

foot T5 MiniBP HO lamps. For these lamps, DOE did not include the cathode wattage when 

calculating lamp efficacy. 

 Regarding NEMA’s suggestion of a 95 W T12 HO lamp as a baseline for the 8-foot RDC 

HO product class, in its review of the market, DOE was unable to find an 8-foot RDC HO T12 

lamp that complied with the July 2012 standards. DOE determined that an 86 W RDC HO T8 

lamp with an efficacy of 91.9 lm/W was the most common, least efficacious lamp that meets 

standards. Therefore, DOE is considering the 86 W lamp as the baseline lamp for the 8-foot RDC 

HO product class. DOE is considering only one baseline for the 8-foot RDC HO product class. 

 

 Although DOE did not receive comments on the other lamp types, DOE conducted a 

thorough market analysis for each representative product class to determine the appropriate 

baseline lamps. The characteristics of the baseline lamps and their corresponding efficacies that 

DOE is considering in this preliminary analysis are summarized in Table 2.6.3.

Table 2.6.3 GSFL Baseline Lamps 

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 89.2 2,900 2,725 24,000 83

8-Foot SP slimline T8 59 60.1 98.2 5,900 5,430 24,000 82

8-Foot RDC HO T8 86 84.0 95.2 8,000 7,600 18,000 78

4-Foot T5 MiniBP SO T5 28 27.8 104.3 2,900 2,697 30,000 85

4-Foot T5 MiniBP HO T5 54 53.8 92.9 5,000 4,850 24,000 86

2.6.3.2 Incandescent Reflector Lamps 

 For IRLs, the most common lamps were determined based on characteristics such as 

wattage, diameter, lifetime, lumen package, and efficacy. For the representative product class, 

DOE identified baseline lamps as the most common, least efficacious lamps that just complied 
2-40

with standards adopted by the 2009 Lamps Rule (i.e., the July 2012 standards). In the framework 

document, DOE presented the lamps analyzed as representative at the standard level adopted in 

the 2009 Lamps Rule (TSL 4). In that rule, DOE identified baseline lamps at three common 

wattages, specifically 50 W, 75 W, and 90 W, and then identified more efficacious reduced 

wattage substitutes for each baseline. In the framework document, DOE presented the more 

efficacious substitutes analyzed at the adopted standard level as baseline lamps. Specifically, 

DOE stated it was considering the 40 W, 55 W, and 66 W lamps identified as reduced wattage 

equivalent lumen replacements in the 2009 Lamps Rule. All three of the baseline lamps 

presented in the framework document were halogen infrared (HIR) lamps that use both halogen 

technology and glass coatings that reflect infrared light. 

DOE received several comments specific to the IRL baselines considered in the 

framework document. PG&E and SCE calculated the coefficients for the baseline lamps using 

the equation (A*P0.27) from the 2009 Lamps Rule22 and found that compared to the July 2012 

standards, the coefficients for the baseline lamps in the framework document were 6 to 10 

percent higher. Based on these calculations, PG&E and SCE stated that DOE is assuming 

baseline lamps will significantly exceed the July 2012 standards although there are a number of 

products currently on the market that barely meet the standards. (PG&E and SCE, No. 17 at pp. 

2-3) NEMA stated that they disagreed with using model lamps that were not commercially 

available as the baseline. NEMA added that commercially viable product lines of IRLs that 

comply with the July 2012 standards had not yet been produced, and therefore characteristics 

such as lumen output were still unknown. (NEMA, Public Meeting Transcript, No. 10 at pp. 160-

161) Philips agreed and stated that the baseline should be based on actual IRL products. (Philips, 

Public Meeting Transcript, No. 10 at p. 185) EEI specifically commented that the 66 W PAR38 

presented in the framework document should not be chosen as a representative lamp because it 

does not exist. (EEI, Public Meeting Transcript, No. 10 at pp. 159-160) 

The potential baseline lamps DOE identified in the framework document were analyzed 

as representative of the standard levels adopted in the 2009 Lamps Rule because lamps with 

lower efficacies would no longer be on the market once these standards required compliance on 

July 14, 2012. Based on a subsequent review of the market conducted after the July 2012 

standards required compliance, DOE selected baselines in this preliminary analysis that are the 

most common, least efficacious lamps available that just meet standards. DOE supplemented a 

review of product catalogs with information received from manufacturers regarding products 

they were planning to introduce but were not currently on the market. 

 

NEMA expressed concern regarding the lifetime of 4,000 hours under consideration in 

the framework document. NEMA recommended that the analysis be revised to reflect lamp 

lifetime supported by actual lifetime test data. NEMA noted that 2,000 hours has been the typical 

IRL lifetime in the past, but until product designs are finalized in response to the July 2012 

standards, it is unknown what lamp lifetimes are possible. (NEMA, No. 15 at p. 14) PG&E and 

SCE suggested a 3,000-hour lifetime, providing the example of OSI’s Capsylite IR products, 

which have 3,000-hour lifetimes with coefficients (5.9 to 6) and efficacies (17 to 20.7 lm/W) 

 

22 In this equation, “A” is a constant specifying the technology level and “P” is the rated wattage of the lamp. 
2-41

similar to those required by the July 2012 standards. PG&E and SCE noted that these products 

are more representative of baseline lamp performance and there is a possibility that other 

products may enter the market at similar levels. (PG&E and SCE, No. 17 at pp. 2-3) The CA 

IOUs stated that a baseline lamp should not be a 4,000-hour lamp when the typical lamp has a 

lifetime of 1,500 to 2,000 hours. They further commented that DOE should take into 

consideration that higher lifetime is a tradeoff of improved efficacy. (CA IOUs, Public Meeting 

Transcript, No. 10 at pp. 162-163) 

 DOE’s review of the market for this preliminary analysis, which was conducted after the 

July 2012 standards required compliance, has indicated lifetimes of IRLs ranging from 1,100 to 

8,400 hours. DOE found that the most common, least efficacious products on the market were 

1,500-hour halogen lamps with an improved reflector and 3,000-hour HIR lamps. Because these 

lamps comprise two distinct technologies and would have different life-cycle costs, DOE is 

considering analyzing both lamps as baselines. 

 The characteristics of the baseline lamps that DOE is considering in this preliminary 

analysis are summarized in Table 2.6.4. DOE’s review of the market has shown that, of products 

that meet standards, most wattages fall within the same range. Therefore, in this preliminary 

analysis, DOE is not analyzing baseline lamps with different wattages. DOE is considering two 

baseline lamps of the same wattage, as each one represents the most common, least efficacious 

products that comply with standards. 

Table 2.6.4. IRL Baseline Lamps 

Baseline Lamp Design Option Initial Light Output Efficacy Lamp Lifetime

lm lm/W hr

60 W PAR38 Improved Halogen* 1,070 17.8 1,500

60 W PAR38 HIR 1,100 18.3 3,000

*This halogen includes an improved reflector.

2.6.4 More Efficacious Substitutes 

 DOE selects a series of more efficacious replacements for the baseline lamps considered 

within each representative product class. DOE considered only technologies that met all four 

criteria in the screening analysis. These selections were made such that potential substitutions 

maintained light output within 10 percent of the baseline lamp’s light output with similar 

performance characteristics, when possible. In identifying the more efficacious substitutes, DOE 

utilized a database of commercially available lamps. DOE also developed a model lamp for the 

T5 MiniBP HO product class. When assessing GSFL data, DOE assumed the exception relief 

granted for the 700 series T8 lamps would not be in place when the standards resulting from this 

rulemaking are expected to require compliance in 2017. As stated previously, DOE will continue 

to examine the impact of rare earth availability in relation to standards for GSFLs during the 

course of this rulemaking. 
2-42

2.6.4.1 General Service Fluorescent Lamps 

 For GSFLs, DOE considered more efficacious lamps under two different substitution 

scenarios: (1) lamp replacement and (2) lamp-and-ballast replacement. DOE identified substitute 

lamps that saved energy23 and, where possible, provided mean lumen output within 10 percent of 

the mean lumen output of the baseline lamp-and-ballast system. For the lamp replacement 

scenario, saving energy required utilizing reduced wattage lamp options. 

 For the 4-foot T5 MiniBP HO product class, DOE was unable to identify commercially 

available full wattage, higher efficacy replacements for the 4-foot T5 MiniBP HO baseline 

lamps. DOE has determined that reduced wattage lamps cannot act as replacements for full 

wattage lamps in all applications (e.g., cold temperature uses) and further, striations remain an 

issue for reduced wattage lamps due to lack of or inadequate striation control circuitry in ballasts. 

Therefore, DOE is considering the use of modeled replacements for these lamps. DOE modeled a 

more efficacious 4-foot T5 MiniBP HO full wattage lamp using a commercially available 

standards-compliant reduced wattage version that is more efficacious than the baseline lamp. The 

design options utilized in the modeled lamp, such as higher efficiency phosphors, are the same 

design options utilized in commercially available reduced wattage T5 MiniBP HO lamps that are 

more efficient than the baseline lamp. See chapter 5 and appendix 5A of this TSD for further 

details. DOE requests comment on its assessment of the T5 model lamp. 

 To develop representative lamp-and-ballast system pairings, DOE used manufacturer 

feedback and information provided in the 2011 Ballast Rule on the most common fluorescent 

lamp ballasts. Specifically in the 2011 Ballast Rule, DOE directly analyzed ballasts with starting 

methods and number of lamps operated that represented the most commonly sold ballasts and the 

majority of shipment volumes. In this rulemaking, DOE chose to pair the representative ballasts 

utilized in the 2011 Ballast Rule with the representative lamps selected in this rulemaking to 

represent the lamp-and-ballast combinations present in the market. 

 For these lamp-and-ballast systems, lamps were paired with ballasts that had a BF24 that 

would result in a more efficacious lamp-and-ballast system. Specifically, DOE paired higher 

efficacy lamps with low BF ballasts, when possible, to achieve energy savings. For each 

replacement option above the baseline, DOE identified a commercially available ballast with the 

lowest BF possible that still maintained a system mean lumen output within 10 percent of the 

baseline system. When multiple ballast options with the same BF existed, DOE selected the most 

efficient ballast based on the ballast luminous efficiency (BLE)25 metric, as this was considered 

to be the most likely ballast substitute in a lamp-and-ballast replacement scenario designed to 

 

23 DOE considers substitutions that both save energy and do not save energy in the NIA. 

24 BF is defined as the output of a ballast delivered to a reference lamp in terms of power or light divided by the 

output of the relevant reference ballast delivered to the same lamp (ANSI C82.13-2002). Because BF affects the 

light output of the system, manufacturers design ballasts with a range of ballast factors to allow consumers to vary 

the light output, and thus power consumed, of a fluorescent system. See the 2011 Ballast Rule final rule TSD 

Chapter 3. 

25 Ballast luminous efficiency is the ratio of the total lamp arc power to ballast input power multiplied by the 

appropriate frequency adjustment factor. 
2-43

achieve energy savings. For certain lamp-and-ballast system replacements, it was not possible to 

identify a replacement that maintained the 10 percent mean lumen output criterion. In such cases, 

DOE selected a commercially available ballast with the highest BF possible that still provided 

energy savings. DOE requests comments on whether replacements of lamps and/or lamp-andballast systems that result in less than 10 percent of the mean lumens of the system being 

replaced occur in practice. See chapter 5 of this TSD for further detail. 

 DOE is also evaluating a lighting controls scenario in the LCC analysis and NIA. DOE 

selected dimming ballasts to analyze with certain representative lamp types for this lighting 

controls scenario by creating a database of commercially available dimming ballasts and 

determining the most common characteristics. DOE found that dimming ballasts were most 

commonly designed to operate 4-foot MBP, 4-foot T5 MiniBP SO, and 4-foot T5 MiniBP HO 

lamps. For these product classes, DOE selected ballasts with the most common characteristics 

identified to model the lamp-and-ballast systems present on the market. See appendix 6A and 

chapter 10 of this TSD for further information. 

2.6.4.2 Incandescent Reflector Lamps 

 For IRLs, DOE identified substitute lamps that saved energy and, where possible, had a 

light output within 10 percent of the baseline lamp’s light output. Substitutes that saved energy 

required reduced wattage options. In the framework document, DOE presented the general 

methodology for identifying the most efficacious substitutes for IRLs. DOE received several 

comments regarding this methodology. 

 

 Lutron expressed concern that the considered coefficient of 6.4 for EL 1 was too high. 

(Lutron, Public Meeting Transcript, No. 10 at p. 187) However, PG&E and SCE, the Joint 

Comment, and the CA IOUs recommended that DOE consider higher ELs for IRLs. All three 

noted that, in the framework document, DOE presents only one CSL for IRLs, which is identical 

to the highest EL evaluated for the 2009 Lamps Rule. (PG&E and SCE, No. 17 at p. 3; Joint 

Comment, No. 16 at p. 3; CA IOUs, Public Meeting Transcript, No. 10 at pp. 179-180) The Joint 

Comment suggested DOE consider both the most efficacious commercially available IRLs, as 

well as working prototypes. (Joint Comment, No. 16 at p. 3) Further, the Joint Comment noted 

that, given the high annual shipment volumes of IRLs and the significant potential efficacy 

improvements, higher ELs for IRLs represent a large national energy savings opportunity. (Joint 

Comment, No. 16 at p. 3) PG&E and the Joint Comment stated that research conducted by Ecos 

Consulting (Ecos; now Ecova, Inc.) in 2009 for PG&E, ASAP, and NRDC found that the 

combination of a highly efficacious, double-ended halogen capsule with an advanced IR coating 

and a silverized reflector yielded ELs 59 percent higher than the efficacy level in TSL 5 in the 

2009 Lamps Rule. (PG&E and SCE, No. 17 at p. 4; Joint Comment, No. 16 at p. 3)

Additionally, PG&E and SCE stated that a number of technologically feasible strategies 

that may not yet be commercially available have the potential to significantly improve efficacy 

beyond the 6.4 coefficient level DOE is considering. In 2009, California investor-owned utilities 

researched these technology pathways and summarized their findings in a comment. The 

comment included examples of both prototype and commercially available products using a 

number of different design approaches to exceed a 6.9 performance level (i.e., minimum efficacy 

of 6.9P0.27). This performance level was shown to be possible using: non-proprietary burners 
2-44

from four different manufacturers (GE, Philips, Deposition Sciences Inc. [DSI], and Toshiba); 

patented silverized reflectors from two different manufacturers (GE and DSI), both of which are 

available for cross-licensing; double-ended and single-ended burners; and capsules designed to 

run on U.S. line voltage (120 V) and capsules designed to operate on low voltage (12 V) with an 

internal power supply. (PG&E and SCE, No. 17 at p. 4) 

 NEMA commented that it was aware that prototype IRLs had been developed by other 

entities that claim higher performance. However, these prototypes were never life tested, run for 

long durations, or subjected to high speed production lines and manufacturing challenges. 

Therefore, NEMA stated that standards should not be established based on prototype lamps, and 

that any lamp design must be confirmed by producing several thousand lamps on high speed 

production lines, followed by life and maintenance testing. In addition, a lamp design must be 

shown to be commercially viable in the market place. (NEMA, No. 15 at p. 10) 

 As mentioned previously, in identifying the most efficacious substitutes, DOE conducted 

a thorough review of catalogs and obtained feedback from manufacturers including information 

for relevant IRL products planned for release. Therefore, in its analysis DOE reviewed all 

relevant commercially available IRLs. Regarding the use of prototypes, DOE considers whether 

it is appropriate to use modeled lamps only when the lamp can be produced with commercially 

available technologies and information is available indicating that the lamp can be manufactured 

on a commercial scale at the time any final standards require compliance. Further, as noted by 

NEMA, DOE cannot analyze a CSL that only a prototype can meet without knowing that 

prototype’s efficacy and other performance characteristics, such as lifetime, when it is 

manufactured on a large scale. Because this information was not available for the prototypes that 

California investor-owned utilities put forth in their comments in the 2009 Lamps Rule, DOE is 

unable to consider CSLs based on these lamps in this analysis. 

 PG&E and SCE pointed out that in the NOPR TSD for the 2009 Lamps Rule, DOE 

showed it would be possible to achieve an efficacy of 27 lm/W in a 48 W lamp with a lifetime of 

3,000 hours. In DOE’s IRL efficacy equation,26 a lamp with this efficacy and wattage would 

have a coefficient of 9.5, which is 33 percent more efficacious than the max tech level 

established in the framework document. (PG&E and SCE, No. 17 at p. 4) DOE acknowledges 

that for the 2009 Lamps Rule, DOE demonstrated an optimal reflector-burner efficiency 

combination using an advanced IR coating could result in an efficacy of 27.1 lm/W for a 48.1 W 

lamp. However, DOE determined that while these results indicated that a lamp with an advanced 

IR coating could meet and exceed TSL 5, the data was not representative of the efficacy these 

lamps would achieve when manufactured on a large scale. DOE noted that large scale production 

would likely result in decreased efficacy, though the magnitude of this reduction was uncertain. 

(See appendix 5D of the 2009 Lamps Rule final rule TSD) At the time of this analysis, the large 

scale production and impact on efficacy of such a lamp remains unclear. 

 

26 In the 2009 Lamps Rule, DOE established that the efficacy requirement for IRLs 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. 

DOE is using this same equation to develop efficacy levels for IRLs in this rulemaking. 
2-45

 PG&E and SCE also gave examples of commercially available PAR38 lamps, such as GE 

HIR Plus and Philips Energy Advantage IR 4,200-hour lamps, which they noted exceeded 

DOE’s max tech level by 10-15 percent. (PG&E and SCE, No. 17 at p. 3) In its assessment of the 

most efficacious substitutes for this preliminary analysis, DOE considered all high efficacy IRLs 

on the market, including the GE and Philips lamps mentioned above. 

 Emphasizing the continued improvement of high efficacy coatings, PG&E and SCE 

noted a 1,500-hour, 50 W A-line shape lamp manufactured by TCP International Holdings LTD 

(TCP) set to be released in 2012 that would achieve an efficacy of 30-33 lm/W using advanced 

high efficiency HIR technology. They noted that if the halogen burner used in this product were 

utilized in an IRL with reflector losses of 10 percent, the lamp would exceed an efficacy of 27 

lm/W. PG&E and SCE encouraged DOE to explore the technical potential of these various 

technology pathways to improve IRLs. (PG&E and SCE, No. 17 at p. 4) DOE was unable to find 

the TCP 50 W A-line shape lamp on the market, and therefore could not evaluate it as a part of 

this analysis. Additionally, DOE research conducted in the 2009 Lamps Rule indicated that IRL 

efficacy losses attributed to the reflector are greater than 10 percent. See appendix 5D of the 

2009 Lamps Final Rule. 

 The CA IOUs asserted that at this stage in the rulemaking, DOE should be working only 

to identify the highest technologically feasible options and not yet weighing economic effects. 

(CA IOUs, Public Meeting Transcript, No. 10 at pp. 189-191) However, NEMA questioned 

whether DOE should deem the max tech standards from the 2009 Lamps Rule, which were not 

economically justified at the time, as now economically justifiable. DOE did not consider cost as

a factor in identifying more efficacious lamp options. As required by EPCA, DOE will consider 

cost in determining the economic justification of the standard levels analyzed in this second 

rulemaking cycle for GSFLs and IRLs. 

For this preliminary analysis, DOE conducted a thorough market analysis to determine all 

potential more efficacious substitutes. DOE has identified a 4,400-hr 55 W PAR38 with an 

efficacy of 20 lm/W as a more efficacious substitute for the baseline lamps identified in section 

2.6.3. (See chapter 5 of this TSD for further details.) 

 Similar to GSFLs, DOE is evaluating a lighting controls scenario for IRLs in the LCC 

analysis and NIA. DOE calculated performance characteristics of the analyzed lamps when 

operated with a dimmer. See appendix 6A and chapter 10 of this TSD for additional details. 

2.6.5 Candidate Standard Levels 

 After identifying more efficacious substitutes for each of the baseline lamps, DOE 

develops CSLs based on the consideration of several factors, including: (1) the design options 

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

infrared coatings for IRLs); (2) the ability of lamps across wattages to comply with the standard 
2-46

level of a given product class;27 and (3) the max tech level. In the framework document, DOE 

presented potential ELs that were representative of the max tech levels established in the 2009 

Lamps Rule. 

 DOE received general comments on the methodology and ELs presented in the 

framework document. NEMA stated that for both GSFLs and IRLs, DOE provided no 

explanation for the absence of ELs between the baseline level set at the standard adopted in the 

2009 Lamps Rule and the next higher efficacy level presented in the framework document. 

NEMA noted that while they are not convinced that higher standards are economically justifiable 

at the present, DOE’s rationale for an “all or nothing” choice lacks sufficient clarification. 

(NEMA, No. 15 at p. 16) 

 In the framework document, DOE presented baseline lamps that reflected the catalog 

efficacies of representative units analyzed at the standard levels adopted in 2009 Lamps Rule. 

For each GSFL and IRL product class, DOE also presented, as a potential EL, the max tech level 

identified in the 2009 Lamps Rule. The exception was the 4-foot T5 MiniBP HO product class, 

as only one level was proposed and adopted in the 2009 Lamps Rule. In this preliminary 

analysis, based on an extensive review of the market and feedback from manufacturers, DOE 

developed multiple CSLs for representative product classes as appropriate. The CSLs were based 

on catalog efficacies, and adjusted according to compliance data when available. Note that for 

GSFLs, when assessing data, DOE assumed the exception relief granted for the noncompliant 

700 series T8 lamps until 2014 would not be in place when the standards resulting from this 

rulemaking are expected to require compliance in 2017. DOE will continue to examine the 

impact of rare earth phosphor availability in relation to standards for GSFLs during the course of 

this rulemaking. 

 EEI stated that there is only a small difference in efficacy between the baselines and the 

ELs identified in the framework document, resulting in only modest energy savings. EEI 

commented that proposing only these max tech ELs might not be beneficial to either residential 

or commercial consumers and might not justify further standards. (EEI, Public Meeting 

Transcript, No. 10 at pp. 80-84, 176) As mentioned previously, to develop CSLs, DOE identified 

more efficacious substitute lamps that saved energy and, where possible, had light output within 

10 percent of the baseline lamp’s light output. DOE presents the energy use at each CSL in 

chapter 6 of this TSD. 

 The following sections discuss comments specific to the GSFL and IRL ELs presented in 

the framework document, as well as the CSLs developed in the preliminary analysis. 

2.6.5.1 General Service Fluorescent Lamps 

 DOE received several comments on the GSFL ELs presented in the framework 

document. NEMA and OSI noted that reduced wattage lamps do not provide equivalent utility to 

 

27 ELs span multiple lamps of different wattages. In selecting CSLs, DOE considered whether these multiple lamps 

can meet the ELs. 
2-47

full wattage lamps, for example, operating in cold temperature and drafty applications. NEMA 

noted that in these applications, reduced wattage lamps may have starting or stability issues; 

forcing consumers to other less efficient and more expensive lighting technologies. Therefore, 

NEMA suggested that reduced wattage lamp types not be used to set CSLs. (NEMA, No. 15 at p. 

16; OSI, Public Meeting Transcript, No. 10 at pp. 182-183) DOE confirmed during manufacturer 

interviews that reduced wattage lamps cannot act as replacements for full wattage lamps in all 

applications, particularly in cold temperature applications below 60-65 °F. In manufacturer 

interviews it was also noted that striations remain an issue for reduced wattage lamps because 

not all ballasts contain striation control circuitry, and those that are equipped with striation 

control circuitry do not completely eliminate striation. Therefore, DOE has ensured that full 

wattage lamps can meet all CSLs under consideration in this preliminary analysis. 

 DOE also received comments that setting standards for GSFLs would not result in energy 

savings. EEI stated that due to the July 2012 standards, the potential efficacy gains are extremely 

limited. EEI calculated that going from the July 2012 standards to EL 1 considered in the 

framework document would result in the following maximum efficacy gains: 4.49 percent for 4-

foot MBP; 1.03 percent for 8-foot SP slimline; 3.26 percent for 8-foot RDC HO; and 4.65 

percent for 4-foot T5 MiniBP SO. (EEI, No. 13 at p. 2) NEMA remarked that the new 

requirements under consideration for some lamp products, specifically T5 and T8 GSFL 

products, would do little if anything to reduce energy consumption as the new requirements 

would have to be met by full wattage lamps. (NEMA, No. 15 at p. 3) 

 When amending standards, DOE is directed to ensure that an adopted standard achieves 

the maximum improvement in energy efficiency that is technologically feasible and 

economically justified. (42 U.S.C. 6295(o)(2)(A)) In this engineering analysis, DOE has 

determined that further efficacy improvements are possible in covered GSFL products. 

Subsequent analyses consider economic impacts on individual consumers, manufacturers, and 

the nation. 

 The CSLs and characteristics of representative lamp units for each representative GSFL 

product class are summarized in the table below. DOE used commercially available lamps, when 

possible, and their associated rated efficacies to determine each CSL. To establish the final 

minimum efficacy requirements for each CSL, DOE analyzed the publicly available compliance 

data and evaluated whether any adjustments were necessary to the initial CSLs to account for the 

compliance efficacies of representative units and/or equivalent lamps. The paragraphs following 

Table 2.6.5 discuss the CSLs in more detail. 
2-48

Table 2.6.5. GSFL Lamp Design Options 

Product 

Classes

CSL 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

CSL 1 T8 32 32.5 90.0 2,925 2,770 21,000 85

CSL 2 T8 25 26.6 93.0 2,475 2,350 24,000 85

CSL 2 T8 32 32.5 95.4 3,100 2,941 24,000 85

CSL 2 T8 28 28.4 96.0 2,725 2,560 24,000 85

8-foot SP 

slimline

CSL 1 T8 59 60.1 99.0 5,950 5,650 24,000 85

CSL 1 T8 54 54.0 105.6 5,700 5,360 24,000 85

CSL 1 T8 50 50.0 108.0 5,400 5,075 24,000 85

8-foot 

RDC HO CSL 1 T8 86 84.0 97.6 8,200 7,800 18,000 86

T5 

MiniBP 

SO

CSL 1 T5 28 27.8 109.7 3,050 2,898 30,000 85

CSL 1 T5 26 26.0 111.5 2,900 2,660 25,000 85

CSL 1 T5 25 25.0 116.0 2,900 2,750 35,000 85

T5 

MiniBP 

HO

CSL 1 T5 54 53.8 97.3 5,237 4,871 30,000 82

CSL 1 T5 50 50.0 100.0 5,000 4,650 30,000 85

CSL 1 T5 47 47.0 102.1 4,800 4,410 30,000 84

 For the 4-foot MBP representative product class, two CSLs are being considered. The 

baseline represents a standard 800 series full wattage (32 W) T8 lamp with basic coating, gas 

composition, and phosphor mix. CSL 1 represents an improved 800 series full wattage T8 lamp 

in which the phosphor mix and/or coating is enhanced to increase efficacy. CSL 2 consists of 

800 series full wattage T8 high lumen lamps with even more advanced phosphors. Reduced 

wattage lamps, including 25 W T8 and 28 W T8 lamps that produce similar lumen outputs as the 

baseline unit, also meet this CSL. 

For the 4-foot MBP product class, DOE determined through publicly available 

compliance reports that the representative unit and/or equivalent lamps complied with CSL 1. 

DOE also confirmed through compliance information that CSL 2 was attainable for full wattage 

high lumen lamps, 25 W reduced wattage lamps, and 28 W reduced wattage lamps. Therefore, 

DOE concluded, based on compliance information, that no adjustments were necessary to the 

initial CSLs being considered for this product class. 

 In reference to the 4-foot MBP product class, NEMA stated that the only surviving lamp 

type at higher standard levels would be the high lumen lamp that requires the maximum dosing 

of rare earths, leaving full wattage T8 consumers with only one, very expensive option for 

replacement. (NEMA, No. 15 at p. 16) DOE identified full wattage lamps at multiple levels of 

efficiency and confirmed full wattage lamps comply with both CSL 1 and CSL 2. DOE 

acknowledges that the full wattage lamps, at CSL 2 in particular, require a greater amount of rare 

earth phosphors than those at the baseline level. DOE discusses its methodology to account for 
2-49

increased rare earth phosphor demand in section 2.6.7 and considers economic impacts on 

individual consumers, manufacturers, and the nation in later analyses. 

 For the 8-foot SP slimline representative product class, DOE is considering one CSL. The 

baseline represents a standard 800 series full wattage (59 W) T8 lamp with basic coating, gas 

composition, and phosphor mix. CSL 1 represents an improved 800 series full wattage T8 lamp 

in which the phosphor mix and/or coating is enhanced to increase efficacy. Reduced wattage 

lamps, including 54 W T8 and 50 W T8 lamps, that produce similar lumen outputs as the 

baseline unit, also meet this CSL. 

For the 8-foot SP slimline product class, DOE determined through publicly available 

compliance reports that the 54 W representative unit and/or equivalent lamps complied with CSL 

1. Thus, based on publicly available compliance information, DOE concluded that no adjustment 

was necessary to the initial CSL being considered for this product class. 

 For the 8-foot RDC HO representative product class, DOE is considering one CSL. The 

baseline represents a 700 series full wattage (86 W) T8 lamp with basic coating, gas 

composition, and phosphor mix. CSL 1 represents a shift to an 800 series full wattage T8 lamp. 

Based on the compliance information for the 86 W T8 representative unit and/or 

equivalent lamps at CSL 1, DOE found that an adjustment to CSL 1 was necessary for the 8-foot 

RDC HO product class. DOE adjusted CSL 1 to the lowest reported compliance efficacy of 97.0 

lm/W for 800 series full wattage T8 lamps. 

 For the 4-foot T5 MiniBP SO representative product class, DOE is considering one CSL. 

The baseline represents an 800 series full wattage (28 W) T5 lamp with basic coating, gas 

composition, and phosphor mix. CSL 1 represents an improved 800 series full wattage T8 lamp 

in which the phosphor mix and/or coating is enhanced to increase efficacy. Reduced wattage 

lamps, including 26 W T5 and 25 W T5 lamps, also meet this level. 

NEMA noted that, when analyzing T5 lamps, DOE should take into account that catalog 

values typically reflect peak performance. Actual lamp testing completed per International 

Electrotechnical Commission (IEC)/ANSI standards is performed at 25 °C, which considerably 

reduces overall efficacy. Therefore, NEMA stated that for the purposes of all testing and 

reporting, ELs should be set at 25 °C, as was done in the 2009 Lamps Rule. (NEMA, No. 15 at p. 

13) 

DOE is aware that the performance of T5 lamps is optimized at 35 °C and many T5 

lamps are operated at this temperature. However, the DOE test procedure for T5 lamps requires 

the lamps to be tested at 25 °C. Because the DOE test procedure is used to determine compliance 

with DOE energy conservation standards, DOE adjusted CSLs for 4-foot T5 MiniBP SO lamps 

(developed using catalog data for T5 lamps at 35 °C) to take into account the efficacy at 25 °C. 

Specifically, when operated at 25 °C, the lumen output of T5 lamps is approximately 10 percent 

lower than the lumen output of such lamps when operated at 35 °C. DOE also utilized certain 

manufacturers’ catalog information if performance characteristics were provided for lamp 

operation at 25 °C. 
2-50

DOE then analyzed the compliance information for this product class. For the 4-foot T5 

MiniBP SO product class, DOE determined through publicly available compliance reports that 

the representative units and/or equivalent lamps complied with CSL 1. Therefore, DOE 

concluded that no adjustments were necessary to the initial CSL being considered for this 

product class. 

 For the 4-foot T5 MiniBP HO representative product class, DOE is considering one CSL. 

The baseline represents an 800 series full wattage (54 W) T5 lamp with basic coating, gas 

composition, and phosphor mix. CSL 1 represents reduced wattage lamps, including 50 W T5 

and 47 W T5 lamps, or an improved 800 series full wattage T8 lamp in which the phosphor mix 

and/or coating is enhanced to increase efficacy. For this product class, lamps with higher 

efficacies than the baseline exist only in reduced wattage versions. As mentioned previously, 

because full and reduced wattage lamps are not interchangeable in all applications, DOE ensures 

in this preliminary analysis that full wattage lamps can meet each CSL considered. Because there 

are no commercially available full wattage higher efficacy replacements for the 4-foot T5 

MiniBP HO baseline lamps, DOE modeled a more efficacious full wattage lamp. DOE used a 

commercially available, standards-compliant reduced wattage version of the 4-foot T5 MiniBP 

HO that is more efficacious than the baseline lamp to scale to a full wattage version. See chapter 

5 and appendix 5A of this TSD for further details. In determining whether it is appropriate to 

consider a CSL based on this model lamp, DOE will gather additional information on the 

manufacturability and functionality of this lamp, as well as its projected efficacy, when measured 

according to the DOE test procedure. DOE requests comment on modeling a full wattage 4-foot 

T5 MiniBP HO lamp and the methodology used to develop the model lamp characteristics. 

DOE then adjusted CSLs for 4-foot T5 MiniBP HO lamps (developed using catalog data 

for T5 lamps at 35 °C) to take into account the efficacy at 25 °C. As stated above, when operated 

at 25 °C, the lumen output of T5 lamps is approximately 10 percent lower than the lumen output 

of such lamps when operated at 35 °C. DOE utilized manufacturers’ catalog information if 

performance characteristics were provided for lamp operation at 25 °C. 

For the 4-foot T5 MiniBP HO product class, DOE determined through publicly available 

compliance reports that the reduced wattage representative units and/or equivalent lamps 

complied with CSL 1. Therefore, DOE concluded that no adjustments were necessary to the 

initial CSL being considered for this product class. 

Table 2.6.6 summarizes the efficacy requirements at each CSL for all GSFL 

representative product classes after accounting for compliance report data and lamp operation at 

25 °C for T5 lamps. 
2-51

Table 2.6.6 Summary of CSLs for GSFL Representative Product Classes 

CCT Lamp Type

Candidate Standard Level

lm/W

1 2

4-foot MBP 90.0 93.0

8-foot SP slimline 99.0 N/A

≤ 4,500K 8-foot RDC HO 97.0 N/A

4-foot T5 MiniBP SO 98.2 N/A

4-foot T5 MiniBP HO 86.2 N/A

2.6.5.2 Incandescent Reflector Lamps 

 DOE received several comments regarding the IRL ELs presented in the framework 

document. NEMA remarked that regardless of whether DOE adopted a more comprehensive IRL 

metric to provide a more detailed comparison analysis (beyond lm/W efficacy) for IRLs, NEMA

cannot support a rulemaking that would set standards for IRLs above the levels already requiring 

compliance in July 2012. (NEMA, No. 15 at pp. 3-4) Additionally, NEMA noted that Federal 

programs such as ENERGY STAR® Buildings, newer versions of ASHRAE and IEC building 

efficiency standards, as well as Federal, state, and utility incentive programs, are already driving 

end users to use more efficacious products. (NEMA, No. 15 at p. 25) EEI stated that, due to the 

July 2012 standards, the potential efficacy gains for IRLs are extremely limited. EEI noted that 

going from the July 2012 standards to EL1 in the framework document would result in the 

following maximum efficacy gains: 12.35 percent for 40 W PAR30 lamps; 6 percent for 55 W 

PAR38 lamps; and 9.09 percent for 66 W PAR38 lamps. (EEI, No. 13 at pp. 2-3) 

As mentioned previously, DOE is required to undertake a second review of standards for 

IRLs (see section 2.2.1) and analyze the maximum technologically feasible improvements in 

efficacy to determine whether further efficiency improvements are economically justified. In this 

preliminary analysis, DOE identified covered IRLs with higher efficacies than the identified 

baseline and considers a CSL that reflects this efficacy gain. 

 

 Lutron noted that certain IRL products that had to be redesigned to comply with the July 

2012 standards will now have to be redesigned again to be in compliance with the standards 

adopted by this rulemaking. Lutron added that this redesign could lead to a significant reduction 

in available products and, therefore, sacrificed consumer utility. (Lutron, Public Meeting 

Transcript, No. 10 at pp. 188-189) When evaluating CSLs, DOE is required to consider the 

lessening of the utility or the performance of the covered products likely to result from the 

imposition of the standard. (42 U.S.C. 6295(o)(2)(A)) Therefore, DOE sets standards that ensure 

different consumer utilities can remain available in compliant products offered on the market. 

 

 EEI requested clarification on DOE’s methodology for developing EL 1 for IRLs, in 

particular the change in wattage from the baseline. (EEI, Public Meeting Transcript, No. 10 at 

pp. 183-184) As previously mentioned, in the framework document DOE presented a potential 

EL based on the max tech level developed in the 2009 Lamps Rule. For that EL, DOE presented 

only the coefficient for the IRL efficacy equation developed in the 2009 Lamps Rule and not a 
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specific wattage. DOE did present baseline lamps at different wattages, as those reflected 

representative lamps analyzed at the standard levels adopted in the 2009 Lamps Rule (i.e., July 

2012 standards). (See section 2.6.3 for further details.) 

 For this preliminary analysis, the CSLs and characteristics of representative lamp units 

for IRLs are summarized in the table below. The current IRL standards are based on a 

continuous equation that sets a minimum efficacy requirement across wattage: A*P0.27, where 

“A” is a constant specifying the technology level and “P” is the rated wattage of the lamp. 

Because the equation accounts for variation in efficacy due to wattage, it can account for market 

shifts to new lamp wattages. DOE used this same equation to develop CSLs for the IRLs in this 

rulemaking. DOE used commercially available lamps and their associated rated efficacies to 

determine the design options required to meet each CSL. To establish the minimum efficacy 

requirements for each CSL, DOE analyzed the publicly available compliance data and 

determined whether any adjustments were necessary to the initial CSLs to account for the 

compliance efficacies of representative units and/or equivalent lamps. The paragraphs following 

Table 2.6.7 discuss the CSLs in more detail. 

Table 2.6.7. IRL Lamp Design Options 

Candidate 

Standard 

Level

Design 

Option

Lamp 

Descriptor

Wattage Efficacy Initial Light 

Output

Lamp 

Life

W lm/W lm hr

Baseline 1

Improved 

Halogen* PAR38 60 17.8 1,070 1,500

Baseline 2 HIR PAR38 60 18.3 1,100 3,000

CSL 1 Improved HIR* PAR38 55 20.0 1,100 4,400

*This lamp includes a higher efficiency reflector coating. 

 Two baselines are being considered for the IRL representative product class because two 

distinct lamp designs have been identified as the most common, least efficacious products that 

comply with standards. One baseline represents a 60 W PAR38 halogen lamp that has a lifetime 

of 1,500 hours and utilizes a higher efficacy inert fill gas and a higher efficiency reflector 

coating. The other baseline represents a 60 W PAR38 halogen lamp that has a lifetime of 3,000 

hours and utilizes IR glass coatings. DOE is considering one CSL for this product class. CSL 1 

represents a 55 W PAR38 halogen lamp that has a lifetime of 4,400 hours and utilizes improved 

HIR technology, such as IR glass coatings with a higher efficiency reflector coating. 

For the IRL representative product class, DOE analyzed publicly available compliance 

data and found that an adjustment to CSL 1 was necessary to account for the compliance 

efficacies of the representative lamp resulting in a coefficient of 6.2. Table 2.6.8 summarizes the 

resulting efficacy requirements at the CSL for the IRL representative product class. 
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Table 2.6.8 Summary of CSLs for IRL Representative Product Classes 

Lamp Type Diameter Voltage CSL 1

lm/W

Standard Spectrum > 2.5 inches < 125 6.2P0.27

P = rated wattage

2.6.6 Scaling to Other Product Classes 

 DOE identified and selected certain product classes as representative and analyzed these 

product classes directly. DOE chose these representative product classes primarily due to their 

high market volumes. CSLs for product classes that were not analyzed (“non-representative 

product classes”) were then determined by scaling from the CSLs of the representative product 

classes. Below is a summary of how this methodology was applied to GSFLs and IRLs, as well 

as a discussion of comments received regarding scaling factors presented in the framework 

document. See chapter 5 for more details. 

2.6.6.1 General Service Fluorescent Lamps 

For GSFLs, the representative product classes analyzed were all lamp types with CCTs ≤ 

4,500 K, with the exception of 2-foot U-shaped lamps. CSLs developed for the representative 

product classes were scaled to obtain levels for higher CCT product classes not analyzed. In the 

framework document, DOE stated that it was considering using the same scaling factors 

developed in the 2009 Lamps Rule. DOE received several comments regarding this proposal. 

NEMA stated that using a range of factors to scale between the CCT ranges does not 

make sense because the scaling is based on the spectral content and the photopic lumen curve. 

Instead, NEMA suggested using one factor, applied to all classes of lamps. Additionally, NEMA 

noted that in the 2009 Lamps Rule, the required efficacy for 4-foot MBP lamps with CCTs > 

4,500 K was too close to the limit for the lamps with CCTs ≤ 4,500 K and made certain high 

CCT products not technologically feasible. NEMA stated that there should be a larger efficacy 

gap between low color temperature and high color temperature lamps. (NEMA, No. 15 at p. 17) 

 DOE confirmed during manufacturer interviews that the impact on efficacy as a result of 

changes in CCT remains constant across all product classes and that therefore one scaling factor 

should be applied across all GSFL lamp types. To develop this scaling factor, DOE identified 

pairs of lamps within two product classes that were manufactured by the same manufacturer, 

within the same product family, and differed only by CCT. DOE determined the average 

difference in efficacy between these lamp pairs to be 2 percent. Two percent is also the largest 

scaling factor that can be applied across all product classes without backsliding from the current 

minimum efficacy standards for GSFLs. Regarding the concern that high CCT GSFLs are unable 

to meet the July 2012 standards, DOE has found compliant lamps in all high CCT product 

classes that meet the scaled CSLs DOE is considering in this preliminary analysis. DOE requests 

comment on applying a 2 percent reduction factor to scale to high CCT product classes. 

 Philips commented that the efficacy of linear fluorescent lamps is inherently better than 

shaped lamps. Therefore, Philips expressed concern over scaling to U-shaped lamps based on 
2-54

linear lamps. (Philips, Public Meeting Transcript, No. 10 at p. 146) In this preliminary analysis, 

DOE uses the 4-foot MBP linear fluorescent products to scale to the 2-foot U-shaped products, 

as both products use the same fluorescent technology, span the same range of wattages, and, 

without its bent curve, the 2-foot U-shaped would be approximately the same length as the 4-foot 

MBP linear. DOE assessed manufacturer catalogs containing commercially available 2-foot Ushaped lamps with CCTs less than or equal to 4,500 K and determined the equivalent 4-foot 

MBP version (i.e., found lamp pairs where the only difference between lamps was shape). By 

comparing catalog efficacy values for 2-foot U-shaped lamps with the equivalent 4-foot MBP 

lamps, DOE determined a scaling factor of 2 percent was appropriate. The scaling factor being 

considered accounts for the lower efficacy that results from the curved geometry of the U-shaped 

lamps. DOE requests comment on applying a 2 percent reduction from CSLs of the 4-foot MBP 

product class to CSLs of the 2-foot U-shaped product class. 

In this preliminary analysis, DOE has developed scaling factors for GSFLs by identifying 

pairs of lamps in which the only difference between the lamps was the characteristic under 

consideration for scaling and by determining the average difference in efficacies. (See chapter 5 

of this TSD for further details.) The following table shows how the representative product 

classes were mapped to all other product classes. 

Table 2.6.9. Scaling to Other GSFL Product Classes 

Lamp Type

For CCT ≤ 4,500K Minimum 

Lamp Efficacy

lm/W

For CCT > 4,500K Minimum Lamp 

Efficacy

lm/W

4-foot MBP Representative product class Scaled from ≤ 4,500K

2-foot U-shaped Scaled from 4-foot MBP ≤ 4,500K Scaled from 2-foot U-shaped ≤ 4,500K

8-foot SP slimline Representative product class Scaled from ≤ 4,500K

8-foot RDC HO Representative product class Scaled from ≤ 4,500K

4-foot T5 MiniBP SO Representative product class Scaled from ≤ 4,500K

4-foot T5 MiniBP HO Representative product class Scaled from ≤ 4,500K

2.6.6.2 Incandescent Reflector Lamps 

 In the framework document, DOE stated that it was considering using the same scaling 

factors developed in the 2009 Lamps Rule. DOE received several comments regarding this 

proposal. EEI commented that it might not be appropriate to scale from one IRL product class to 

seven others and further suggested that additional sample lamps in the product class might be 

needed. EEI stated that extrapolating to several different lamps is not always feasible because of 

certain technical or safety reasons. (EEI, Public Meeting Transcript, No. 10 at pp. 195-197) 

In this preliminary analysis, DOE directly analyzes as representative standard spectrum 

lamps with diameters greater than 2.5 inches, and input voltages less than or equal to 125 V 

because of their high volume of shipments. DOE is unaware of any technical reasons that a 

scaling factor cannot be used to extrapolate CSLs from standard spectrum to modified spectrum; 

from diameters greater than 2.5 inches to less than or equal to 2.5 inches; and from input 

voltages less than or equal to 125 V to greater than 125 V. Further, the low volume of standardscompliant lamps in non-representative product classes would make it difficult to directly analyze 
2-55

any of these lamp types. The different scaling factors, and comments received on those scaling 

factors, are discussed in the paragraphs that follow.

 In the framework document, DOE considered using a 15 percent reduction factor to scale 

from a standard spectrum to a modified spectrum lamp. PG&E and SCE and the Joint Comment 

stated that the current efficacy allowance for modified spectrum of 15 percent is too large and 

could potentially result in modified spectrum lamps becoming a low cost option in the market. 

They referred DOE to research conducted by Ecos that found an average light loss of 9 to 11 

percent is sufficient to modify a lamp’s spectrum to meet the four MacAdam step minimum 

specified in the EISA 2007 definition of modified spectrum. The Ecos research also found that it 

is feasible to make modified spectrum IRLs exceeding the max tech levels in the 2009 Lamps 

Rule for standard spectrum lamps by 35 to 49 percent. PG&E and SCE and the Joint Comment 

recommended that the efficacy allowance for modified spectrum IRLs be removed or lowered to 

less than 10 percent. (PG&E and SCE, No. 17 at p. 4; Joint Comment, No. 16 at p. 3) 

Furthermore, the CA IOUs commented that there is a specific definition for modified spectrum 

lamps, and yet some lamps are being incorrectly marketed as such. The CA IOUs added that 

when developing a scaling factor for modified spectrum lamps, DOE should consider the 

efficacy loss associated with a product that has a spectrum shift no greater than as specified by 

DOE’s definition28 of modified spectrum. (CA IOUs, Public Meeting Transcript, No. 10 at pp. 

202-203) 

 

 DOE has found a very limited number of standards-compliant modified spectrum IRLs 

available on the market. To calculate a scaling factor for modified spectrum lamps, DOE 

developed a methodology to isolate the effects of spectrum modification to determine the relative 

reduction in lumen output and the relative change in color that would be observed if a spectrally 

modified IRL were compared to a standard spectrum lamp. See chapter 5 of this TSD for further 

details. Based on this data, DOE determined that there was a 15 percent reduction of efficacy 

between a standard spectrum lamp and a modified spectrum lamp. DOE notes that only lamps 

that meet DOE’s definition of modified spectrum are required to certify compliance with 

standards for modified spectrum lamps. 

 In the framework document, DOE also proposed to maintain the 15 percent increase in 

efficacy applied from lamps in the 120 V product class to lamps in the 130 V product class. 

NEMA noted that DOE misinterpreted Illuminating Engineering Society of North America 

(IESNA) information during the 2009 Lamps Rule and set an EL that is unattainable for 130 V 

lamps. NEMA disagreed that lamps designed to work in 130 V applications have a 15 percent 

 

28 Modified spectrum means, with respect to an incandescent lamp, an incandescent lamp that— 

(1) Is not a colored incandescent lamp; and 

(2) When operated at the rated voltage and wattage of the incandescent lamp— 

(A) Has a color point with (x,y) chromaticity coordinates on the C.I.E. 1931 chromaticity diagram, figure 2, page 3 

of IESNA LM-16 (incorporated by reference; see § 430.3) that lies below the black-body locus; and 

(B) Has a color point with (x,y) chromaticity coordinates on the C.I.E. 1931 chromaticity diagram, figure 2, page 3 

of IESNA LM-16 (incorporated by reference; see § 430.3) that lies at least 4 MacAdam steps, as referenced in 

IESNA LM-16, distant from the color point of a clear lamp with the same filament and bulb shape, operated at the 

same rated voltage and wattage. 10 CFR 430.2 
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increase in efficacy over the lamps designed for standard 120 V applications. Specifically, 

NEMA noted that the scaling equations DOE used are sensitivity equations that describe the 

resulting changes in life, lumens, and wattage for a single design incandescent filament as 

applied voltage is varied. NEMA stated that mathematically, these equations are derivatives 

describing slopes, useful for accelerated lifetime testing of prototype designs, but not pertaining 

to comparisons of lamps with different filament designs. NEMA gave the example that, using the 

exponents DOE assumed in the 2009 Lamps Rule, a single IRL designed for a 120 V application 

and operated at 130 V would operate at the increased efficacy (15 percent) for half (50 percent) 

of the lifetime. NEMA stated that in practice, a filament designed for 130 V applications tends to 

have a slightly reduced efficacy compared to one designed for 120 V applications. At a 

minimum, the ELs should be the same for 120 V and 130 V products or, if the curves are 

interpreted correctly, 130 V lamps should have a slightly lower efficacy threshold. (NEMA, No. 

15 at p. 17) 

 As discussed in section 2.4.3.2, DOE is considering separate product classes for lamps 

rated at 120 V and those rated at 130 V. DOE notes that most consumers operate 130 V lamps at 

120 V, which slightly decreases their efficacy and increases their lifetime. Therefore, DOE 

developed a scaling factor for the 130 V product class that would require 130 V lamps to use the 

same technology and possess the same general performance characteristics as 120 V lamps 

operated at 120 V. DOE found that while there may be a slight decrease in efficacy, the lifetime 

of a 130 V lamp is doubled when it is operated at 120 V, giving it an advantage over 120 V rated 

lamps. Therefore, using the IESNA Lighting Handbook equations that relate lifetime, lumens, 

and wattage to voltage of incandescent lamps, DOE determined the increase in efficacy of 130 V 

rated lamps operated at 120 V if their additional lifetime over that of 120 V lamps were instead 

used to increase their efficacy. DOE determined that a 15 percent increase in efficacy was 

necessary to capture the differences in performance characteristics between a 120 V lamp tested 

at 120 V and a 130 V lamp tested at 130 V. Therefore, DOE is considering a 15 percent increase 

to scale from the 120 V product class to the 130 V product class. (See chapter 5 of this TSD for 

further details.) 

 

 DOE also received comments on the scaling factors for small diameter lamps considered 

in the framework document. Lutron commented that the scaling factor for small diameter IRLs 

may no longer be appropriate and urged DOE to conduct a new analysis on smaller diameter 

lamps if it is necessary. (Lutron, Public Meeting Transcript, No. 10 at pp. 200-201) The CA 

IOUs noted that the small diameter scaling factor was based on the assumption that a doubleended burner cannot fit into a small diameter lamp. The CA IOUs stated they were unsure if this 

is an accurate assumption because Philips fit a double-ended burner into an MR-16 reflector 

lamp by bulging the lens. (CA IOUs, Public Meeting Transcript, No. 10 at p. 201) 

 For this preliminary analysis, DOE is considering the 15.5 percent reduction in efficacy 

from a small diameter lamp (≤ 2.5 inches) to a large diameter lamp (> 2.5 inches). This scaling 

factor incorporates the impact on efficacy of the diameter as well as the assumption that a 

double-ended burner cannot fit in a small diameter lamp. DOE examined the catalog efficacy 

differences between lamps with similar characteristics but different diameters, specifically the 

PAR20 lamp and its PAR30 or PAR38 counterparts from several lamp manufacturers. Based on 
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this analysis, DOE found that the reduction in efficacy caused by the reduction in lamp diameter 

was approximately 12 percent. 

 To determine the change in efficacy going from a double-ended burner to a single-ended 

burner, DOE assessed the loss of energy from the lead wire in a single-ended burner. Unlike a 

double-ended burner, the lead wire of a single-ended burner is located inside the capsule and 

interferes with the reflectance of energy from the capsule wall to the filament. Using 

commercially available single-ended HIR capsules, DOE developed a model to compute the 

energy lost due to the lead wire inside the capsule and determined an efficacy reduction of 3.5 

percent. Thus, for this preliminary analysis, DOE found that a 3.5 percent scaling factor accounts 

for the energy losses in a single-ended burner. 

Additionally, because DOE has not found small diameter IRLs covered under this 

rulemaking that incorporate double-ended burners, DOE has decided to continue to incorporate 

the scaling factor for single-ended burners in its analysis. Therefore, DOE is considering a 

scaling factor of 15.5 percent with 12 percent based on the impact of the diameter and an 

additional 3.5 percent based on the use of less efficient single-ended burners in small diameter 

lamps. (See chapter 5 of this TSD for further details.) 

2.6.7 Rare Earth Phosphors 

 DOE also received several comments regarding the impact of rare earth phosphor 

availability on higher standards for fluorescent lamps. The phosphor powders that manufacturers 

use in GSFLs can be divided into two groups: blends of only “halophosphor” and blends 

incorporating various amounts of “rare earth phosphors,” which consist of rare earth materials. 

Halophosphor blends are much less costly than those containing rare earth materials. However, 

rare earth phosphors are a key technology in increasing the efficacy of fluorescent lamps. 

Specifically, the use of terbium, europium, and yttrium allows a lamp to emit light at the 

wavelengths to which human eyes are most sensitive. Manufacturers expressed concern during 

the 2009 Lamps Rule that more stringent energy conservation standards for GSFLs would 

necessitate very large increases in the demand for the more costly rare earth phosphor blends. To 

address these concerns, DOE analyzed the rare earth phosphor market and concluded that the 

rare earth phosphor supply would meet the increased demand of rare earth phosphors that would 

result from energy conservation standards. (See appendix 3C of the 2009 Lamps Rule final rule 

TSD.) 

As mentioned previously, exception relief was granted to several manufacturers 

exempting their 700 series T8 lamps from the July 2012 standards until 2014. The two-year 

waiver was sought and granted on the basis that due to global supply restriction on rare earth 

phosphors and rising world demand of these phosphors, manufacturers would be unable to attain 

the necessary amount of rare earth phosphors to produce standards-compliant T8 lamps.29

 

29 Philips Lighting Company, et al. OHA Case Nos. EXC-12-0001, EXC-12-0002, EXC-12-0003 (2012). Accessible 

here: energy.gov/sites/prod/files/oha/EE/EXC-12-0001thru03.pdf. 
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In response to the framework document, DOE received several comments regarding the 

supply of rare earth phosphors and subsequent impact of setting higher energy conservation 

standards for GSFLs. OSI commented that this rulemaking needs to consider the effects of 

component availability, especially rare earth phosphors. (OSI, Public Meeting Transcript, No. 10 

at pp. 192-193) OSI asserted that mid-range and long-term projections based on current exports 

for rare earth phosphors show prices continuing to rise and the supply continuing to decline. 

(OSI, Public Meeting Transcript, No. 10 at p. 172) NEMA stated that although there is a renewed 

focus on rare earth mining in the United States and elsewhere, the specific heavy rare earth 

phosphors needed for GSFL production are in very limited supply. NEMA further noted that 

prospects for additional supplies are unclear, and even if new supplies become available in five 

years, quantities will be limited. NEMA added that prices of rare earth phosphors have increased 

by orders of magnitude, in part caused by China closing rare earth mines for humanitarian 

concerns and safety improvements, thus increasing the strain on the limited supply. (NEMA, 

Public Meeting Transcript, No. 10 at pp. 97-98) 

Additionally, NEMA stated that in the 2009 Lamps Rule, DOE projected an 83 percent 

increase in the use of rare earth phosphors as a result of the standards adopted in the final rule 

and a 130 percent increase if the max tech standard were adopted. NEMA stated the inability to 

meet consumer demand in the United States could grow exponentially with higher standards. 

(NEMA, No. 15 at p. 11) NEMA noted that the option of recycling rare earth phosphors will not 

affect availability in the short term, as research is still several years away from developing a cost 

effective means for that process. Even when recycling is made technically and financially 

feasible, adequate sources of recyclable material to reclaim will be necessary. (NEMA, No. 15 at 

p. 3) 

NEMA also stated that they are preparing a detailed analysis of the industry situation 

with rare earth phosphors, and noted that the rare earth issue is already affecting manufacturers’ 

ability to make products compliant with the July 2012 standards. (NEMA, Public Meeting 

Transcript, No. 10 at pp. 103-104) OSI stated that in response to market demands, they 

optimized their phosphor coating and introduced a new line of T8 lamps that meet current 

regulations. The new product line, however, will not be able to meet higher standards, despite 

having been designed as a result of the rare earth situation. (OSI, Public Meeting Transcript, No. 

10 at pp. 130-131) 

 NEMA further stated that any DOE analysis would have to consider various scenarios, 

including greatly increasing rare earth phosphor pricing and consumption. (NEMA, No. 15 at p. 

2) Philips added that DOE has strict rules on changing rulemakings after they are in place and, 

therefore, the rare earth phosphor situation needs to be carefully considered now so as not to 

endanger future energy savings. (Philips, Public Meeting Transcript, No. 10 at pp. 102-103) 

NEMA remarked that in view of the rare earth situation, it seems premature and inappropriate to 

start considering further efficacy requirements for GSFLs, a product that is already one of the 

most efficient lighting sources available. (NEMA, No. 15 at p. 2) NEMA and OSI noted that the 

increase in lamp costs as a result of rare earth phosphor prices has already put some energy 

efficient retrofit projects in jeopardy, due to unacceptable paybacks and returns on investments 

(ROIs). (NEMA, No. 15 at p. 2; OSI, Public Meeting Transcript, No. 10 at pp. 130-131) 
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The CA IOUs agreed that the rare earth situation is dire, and that the new proposed 

rulemaking is close in timing to the previous lamp rule. However, the CA IOUs emphasized that 

standards from this rulemaking would likely not require compliance until 2017 or 2018, by 

which time there could be a lot of change in the market. The CA IOUs stated that DOE has clear 

instructions to first identify maximum technologically feasible performance levels, and it is too 

soon in the rulemaking to discuss cost-effectiveness and screen out technologies because a 

production material is extremely expensive. The CA IOUs encouraged DOE to proceed with the 

rulemaking as directed in order to set appropriate standard levels for 2017 or 2018. (CA IOUs, 

No. 10 at pp. 100-102) 

 DOE notes that manufacturers, in their applications for exception relief, stated that they 

expected an improvement in the rare earth market, specifically noting that supplies of key rare 

earth phosphors used in fluorescent lamps will become more equal to estimated demand 

beginning in 2014. Further, manufacturers stated that the two-year relief would provide time for 

potential development of additional supplies outside of China, for progress in technology 

advancements and development of alternative technologies that use lesser amounts of rare earth 

material, and for expansion of recycling and reclamation initiatives.30 DOE recognizes that 

several manufacturers were granted the waiver from the July 2012 standards for 700 series T8 

lamps due to the issue of rare earth phosphor availability and prices. DOE understands a 

constrained supply of rare earth phosphors may have impacts on the production of higher 

efficiency fluorescent lamps. DOE acknowledges that supply and demand of rare earth 

phosphors should be considered when evaluating amended standards for GSFLs. In later 

analyses, DOE considers a scenario of increased rare earth phosphor prices in the LCC and NIA. 

(See sections 2.7 and 2.10 for further discussion.) DOE requests comment on the specific 

impacts of an increase in rare earth phosphor prices due to decreased supply on the cost of lamps 

covered under this rulemaking as well the extent of the limited worldwide resources of rare earth 

phosphors and the impact of this shortage on the feasibility of meeting higher standard levels. 

2.7 PRODUCT PRICE DETERMINATION 

 Typically, DOE develops manufacturer selling prices (MSPs) for covered products and 

applies markups to create end-user prices to use as inputs to the LCC analysis and NIA. Because 

GSFLs and IRLs are difficult to reverse-engineer (i.e., not easily disassembled), DOE directly 

derives end-user prices for the lamps covered in this rulemaking. DOE estimates end-user prices 

for lamps by establishing discounts from manufacturer suggested price lists (hereafter “bluebook prices”). In the framework document, DOE summarized this methodology for developing 

end-user prices. DOE received several comments on price methodology presented in the 

framework document. 

 EEI stated that the 2009 Lamps Rule was a significant rulemaking, particularly for the 

residential sector because this sector is strongly focused on initial prices. (EEI, Public Meeting 

 

30 Philips Lighting Company, et al. OHA Case Nos. EXC-12-0001, EXC-12-0002, EXC-12-0003 (2012). Accessible 

here:energy.gov/sites/prod/files/oha/EE/EXC-12-0001thru03.pdf. 
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Transcript, No. 10 at p. 83) Specifically, EEI noted that end-user prices for T8 fluorescent lamps 

have increased between 25 and 70 percent, which is significantly higher than projected in the 

2009 Lamps Rule. (EEI, Public Meeting Transcript, No. 10 at p. 129) EEI further stated that the 

rule had projected the purchase price of high efficacy GSFLs to be up to 13 times higher, 

including the purchase of a new ballast. As of July 2012, this will impact the residential 

consumer with a T12 lamp 10 to 20 years old who cannot replace it without replacing the whole 

fixture. EEI added that while the fixture will pay for itself over its lifetime, the replacement still 

may displease consumers. (EEI, Public Meeting Transcript, No. 10 at pp. 81-82) For IRLs, EEI 

added that there could be long periods of payback for residential consumers that purchase high 

efficacy IRLs. (EEI, Public Meeting Transcript, No. 10 at p. 82) 

 In the product price determination, DOE develops end-user prices for each representative 

lamp. These end-user prices were developed with price data gathered after the July 2012 

standards required compliance so that they reflect price increases due to these standards. These 

prices are inputs for the LCC, which determines the cost impact for consumers purchasing lamps 

at each CSL and in specific lamp purchasing scenarios, including the purchase of a new ballast. 

Further, while DOE used the medium end-user price for the reference case in the LCC, it also 

analyzed the low and high end-user prices to assess the full range of price impacts. Consumer 

behavior in response to initial price, or price elasticity, is considered in the NIA. Additionally, in 

the 2009 Lamps Rule, DOE conducted sensitivities that examined scenarios in which there were 

significant price increases for GSFLs. Specifically, DOE conducted a sensitivity analysis that 

considered the impact of an increase in GSFL prices due to rising rare earth phosphor prices in 

the presence of higher efficacy standards. This sensitivity concluded that phosphor prices could 

increase by a factor of seven before commercial consumers would experience negative LCC 

savings for the 4-foot MBP product class. DOE is conducting a similar sensitivity for this 

preliminary analysis; see appendix 7B of this TSD for more information. 

NEMA and Philips commented that determining accurate future predictions for GSFLs 

would be a major challenge given the uncertainty in the availability and pricing of rare earth 

phosphors. (NEMA, No. 15 at p. 21; Philips, Public Meeting Transcript, No. 10 at pp. 205-206) 

NEMA specifically stated that until the first quarter of 2014, when 2013 data is available, it 

would be impossible to determine what the market price levels should be for the analysis. 

Although historical data may show pricing trending downward, NEMA did not expect this to be 

the case going forward. (NEMA, No. 15 at p. 21) NEEA noted that any price projections can be 

chaotic and recommended that DOE focus on the rulemaking methodology until missing 

information regarding future product offerings is available. (NEEA, Public Meeting Transcript, 

No. 10 at pp. 211-212) 

 

 DOE understands that the market impacts of rare earth phosphor supply and demand 

make it difficult to predict future GSFL pricing trends. In this preliminary analysis, DOE is using 

the latest price data available, which is reflective of the initial market reactions to the July 2012 

standards. DOE will adjust pricing information in any later stages of the rulemaking, as 

necessary. As mentioned, DOE is also assessing the impacts of rare earth phosphor prices in the 

LCC and NIA as sensitivity analyses. See appendix 8B and chapter 10 of this TSD for further 

details. (For this preliminary analysis, when assessing data, DOE assumed the exception relief 
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granted for the 700 series T8 lamps until 2014 would not be in place when the standards 

resulting from this rulemaking are expected to require compliance in 2017.) 

 For this preliminary analysis, DOE has implemented the product pricing methodology 

described at the beginning of this section. In its review of publicly available prices, DOE 

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

which it is purchased. In line with its observation of public pricing, DOE developed three sets of 

discounts from the blue-book prices, representing low (State procurement), medium (large 

distributors, including do-it-yourself stores), and high (Internet retailers) lamp prices for both 

GSFLs and IRLs. Starting with a consistent set of aggregated blue-book prices, DOE calculated 

an average discount ratio for each end-user. DOE found the discount did not vary with wattage 

or lamp type, and therefore applied a single discount for all lamps to estimate end-user prices. 

 For the representative lamps for which blue-book prices were unavailable, DOE 

extrapolated pricing from lamps for which blue-book prices were available. This was done by 

using the blue-book prices of equivalent lamps from an alternative manufacturer or by 

developing ratios based on wattage and/or technology, as appropriate. Once DOE calculated enduser prices, DOE added sales tax and, if appropriate, installation costs to derive the total, 

installed end-user cost. See chapter 7 of this TSD for further details. DOE invites comment on its 

methodology and results for estimating end-user prices for fluorescent and incandescent reflector 

lamps. 

2.8 ENERGY-USE CHARACTERIZATION 

The purpose of the energy-use characterization is to estimate the energy usage of the 

baseline and higher efficacy lamps considered in this rulemaking. 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. In the 

framework document, DOE presented this methodology for determining energy consumption of 

lamps covered under this rulemaking. Specifically, DOE stated that it would use the U.S. LMC 

Volume I31 and recent versions of Energy Information Administration’s (EIA’s) Commercial 

Building Energy Consumption Survey (CBECS),32 Residential Energy Consumption Survey 

(RECS),33 and the Manufacturing Energy Consumption Survey (MECS)34 to determine operating 

hours by building type and Census Division. DOE received several comments on the energy-use 

characterization methodology presented in the framework document. 

 

31 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. 

32 The most recent CBECS data is available at http://www.eia.gov/consumption/commercial/. 

33 The most recent RECS data is available at http://www.eia.gov/consumption/residential/. 

34 The most recent MECS data is available at http://www.eia.gov/emeu/mecs/contents.html. 
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In regards to using current data for operating hours, NEMA stated that the LMC Volume 

I was published in 2002 and noted the analysis was becoming increasingly dated. Data was 

collected during audits conducted throughout the 1990s with a statistical correction applied to the 

audits to establish 2001 as the inventory estimate year. NEMA asked to review the upcoming 

LMC study before commenting further on which will serve the needs of this effort better. 

(NEMA, No. 15 at p. 19) In determining operating hours for this preliminary analysis, DOE used 

the latest version of the LMC, which is the 2010 LMC published in January 2012. DOE found 

that this was the most relevant source of data as it provided the most up to date national-level 

data on operating hours by building type and lamp category for all sectors. 

 EEI commented that RECS effectively characterizes residential annual operating hours 

and emphasized that proper assumptions for varying operating hours are critical so as not to 

overestimate energy savings. (EEI, Public Meeting Transcript, No. 10 at pp. 213-214) Both OSI 

and NEMA stated that residential, commercial, and industrial operating hours should be 

evaluated separately and not be averaged together as the hours vary too widely. OSI remarked 

that not doing so would be unfair to residential users. (OSI, Public Meeting Transcript, No. 10 at 

pp. 215-216; NEMA, No. 15 at p. 19) NEMA also stated that IRLs should not be analyzed for 

the industrial sector as they make up a very small percentage of this sector. (NEMA, No. 15 at p. 

19) In this preliminary analysis, DOE determined average operating hours separately for the 

residential, commercial, and industrial sectors. DOE did not analyze IRLs in the industrial sector 

due to their low volume. See chapter 8 of this TSD for further details. Additionally, because 

operating hours vary considerably by room type for IRLs in the residential sector, DOE 

performed a sensitivity analysis using high and low operating hours. See appendix 8B of this 

TSD for further details. 

 NEMA noted that the rated power of GSFLs is not necessarily the same as their energy 

consumption, especially as many lamps are measured using a 60 Hz reference ballast and 

operated at high frequency. NEMA stated that a 32 W lamp operates at approximately 25 W or 

less in use. In addition to the frequency issue, T8 and T5 lamps are operated on a variety of 

ballasts with different BFs, as well as bi-level and dimming ballasts. (NEMA, No. 15 at pp. 19-

20) 

 For GSFLs, DOE determined the system input power rating of a lamp-and-ballast system. 

DOE’s test procedure requires that GSFLs be tested at low frequency unless only high frequency 

ballast specifications are available for the lamp (i.e., 8-foot T8 RDC HO, 4-foot T5 MiniBP SO, 

and 4-foot T5 MiniBP HO lamps). Because DOE’s test procedure must be used for purposes of 

compliance, when calculating lamp efficacy and establishing CSLs, DOE used the rated wattage 

associated with the appropriate frequency as required by the test procedure. However, as stated 

by NEMA, while certain lamp types are required to be tested at low frequency, these lamps are 

frequently operated at high frequency in practice. Furthermore, DOE determined that electronic 

ballasts, which operate at high frequency, comprise the vast majority of the fluorescent ballast 

market. To accurately quantify the energy consumption of lamp-and-ballast systems operated in 

practice, DOE analyzed only electronic ballasts, and therefore calculated the system input power 

rating of each lamp-and-ballast system operating at high frequency. 
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 DOE developed lamp-and-ballast replacement options by pairing lamps with ballasts that 

represented the most commonly sold ballasts based on the 2011 Ballast Rule and manufacturer 

feedback. To achieve energy savings, DOE paired higher efficacy lamps with low BF ballasts, 

selecting the most efficient ballast based on BLE when there were multiple ballast options with 

the same BF. The system input power rating was determined by first calculating the total lamp 

arc power using the catalog BF, number of lamps operated on the system, and the high frequency 

reference arc power of the lamp being analyzed (see chapter 5 of this TSD for a table of these arc 

powers). DOE then determined the BLE of the ballast when operating the analyzed lamp type 

using test data from the 2011 Ballast Rule. Lastly, DOE calculated the system input power by 

dividing the total lamp arc power by the BLE. 

2.8.1 Lighting Controls 

 In regards to lighting controls, EEI noted that in the energy-use calculations, DOE does 

not account for the use of dimmers, especially in residential markets. EEI stated that a significant 

portion of IRLs used in the residential and commercial sectors are controlled by dimmer switches 

and are rarely operated at full system input power. These dimmers will have an impact on the 

actual energy savings and NIA. EEI referred DOE to Lutron for information on the impact of 

dimmers, and specifically to the One Year Incandescent/Halogen Energy Savings Chart.35 (EEI, 

No. 13 at p. 3) Based on this information, EEI suggested that the methodology used to determine 

energy usage incorporate the use of dimmers. (EEI, Public Meeting Transcript, No. 10 at p. 214) 

In this preliminary analysis, DOE evaluated the impact of lighting controls on the energy 

use of GSFLs and IRLs. Most lighting controls have one of two impacts: reducing operating 

wattage or reducing operating hours. DOE refers to these two groups of controls as 

dimmers/light sensors and occupancy sensors, respectively. The calculated operating hours used 

in the reference case already account for the use of occupancy sensors. In addition, DOE 

modeled dimming scenarios and developed associated energy-use results for both types of 

covered lamps as a sensitivity analysis. See appendix 6A of this TSD for further information. 

NEMA inquired about a claim that residential lighting controls deliver a 27 percent 

energy-use reduction, stating that the information may have come from DOE. NEMA noted that 

if it were correct, DOE should focus on the use of home lighting controls as a means to achieve 

energy savings rather than a lamp regulation. NEMA suggested that the ANSI/ASHRAE/IES 

90.1 lighting subcommittee could provide a summary of the effectiveness in reducing lighting 

energy use for commercial and industrial applications, which could take the form of incentives 

for the installation of lighting controls. (NEMA, Public Meeting Transcript, No. 10 at pp. 218-

219; NEMA, No. 15 at p. 19) NEEA responded that energy savings cannot automatically be 

assumed because lighting control systems consume energy as well. (NEEA, Public Meeting 

Transcript, No. 10 at p. 222) 

DOE is not familiar with 27 percent energy-use reduction noted by NEMA. DOE 

reviewed relevant research and spoke with industry experts to estimate the average reduction in 

 

35 Available at www.lutron.com/Education-Training/LCE/Pages/GreenBenefits.aspx 
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lumen output and wattage as a result of lighting controls for both GSFLs and IRLs. The energyuse results for the lighting control scenarios are presented as sensitivities to supplement the 

energy-use characterization in this preliminary analysis. See appendix 6A of this TSD for a more 

complete discussion. 

Lutron noted that there are many studies in commercial buildings that document savings 

from a variety of lighting controls, but there is a lack of data regarding residential applications. 

(Lutron, Public Meeting Transcript, No. 10 at pp. 220-221) DOE evaluated dimmers in the 

residential sector for IRLs and found sufficient data to conduct this analysis. Specifically, DOE 

determined dimmer usage from data provided in the 2010 LMC and calculated dimmer impact 

on energy usage and lamp lifetime using the Lutron Energy Savings calculator. See appendix 6A 

of this TSD for further details. 

Philips remarked that if IRLs are eliminated from the market, consumers may switch to 

CFLs and no longer use dimmers, potentially resulting in increased energy usage. (Philips, 

Public Meeting Transcript, No. 10 at p. 217-218) DOE research has indicated that the covered 

lamps are not widely used with dimmers in the residential market, which comprises a majority of 

the market for IRLs. The NIA characterizes energy savings in various scenarios, including 

substitution of more efficient technologies. See chapter 10 of this TSD. 

Lutron noted that they would like to see a lighting category within ENERGY STAR for 

lighting controls. (OSI, Public Meeting Transcript, No. 10 at pp. 221-222) DOE notes that such a 

category for ENERGY STAR would be developed by the U.S. Environmental Protection Agency 

(EPA) and is therefore outside the scope of this rulemaking. 

2.9 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS 

The impacts of amended energy conservation standards on consumers often include a 

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

price (usually increased). The LCC of a product is the cost it incurs over its lifetime, taking into 

account both purchase price and operating expenses. The PBP represents the time it takes to 

recover the additional installed cost of the more efficacious products through annual operatingcost savings. In the framework document, DOE presented its approach for the LCC analysis. 

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

engineering performance data, the product price determination, and the energy-use analysis. 

Inputs to the LCC calculation include the installed cost to the consumer (purchase price plus 

installation cost), operating expenses, the lifetime of the product or another defined period of 

analysis, and a discount rate. Inputs to the PBP calculation include the installed cost to the 

consumer and annual operating costs. DOE received several comments regarding the LCC 

methodology presented in the framework document. 

NEEA questioned using discount rates and finance costs in the LCC analysis for this 

rulemaking, noting that it is unlikely consumers face finance costs when purchasing lamps. 

(NEEA, Public Meeting Transcript, No. 10 at p. 229) OSI responded that finance costs could 

apply to consumers that have to replace entire T12 lighting systems. (OSI, Public Meeting 

Transcript, No. 10 at pp. 229-230) EEI suggested using information from banking or retail 
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associations to determine the percentage of purchases of lamps made by cash, credit, and debit. 

(EEI, Public Meeting Transcript, No. 10 at p. 231) NEEA stated that the analysis needs to be 

adjusted for the product type so that all purchases are not using the same discount rates as that of 

capital equipment. (NEEA, Public Meeting Transcript, No. 10 at pp. 233-234) 

The discount rate is the rate at which future expenditures are discounted to estimate their 

present value. DOE acknowledges that consumers may not be financing purchases of GSFLs and 

IRLs, but the discount rate accounts for consumers placing a certain value on spending money 

now versus in the future. For residential consumers, DOE estimated the discount rate by looking 

across all possible debt or asset classes that might be used to purchase lamps. For the commercial 

and industrial consumers, DOE estimated the cost of capital for commercial and industrial 

companies by examining both debt and equity capital, and developed an appropriate weighted 

average of the cost to the company of equity and debt financing. 

OSI stated that disposal costs should be included in the commercial and industrial 

analyses. (OSI, Public Meeting Transcript, No. 10 at p. 230) DOE includes disposal costs for 

GSFLs in calculations of their LCC, which is an estimate of the product’s total cost over its 

lifetime. Specifically, DOE assumes that commercial and industrial GSFL consumers pay 

disposal costs for approximately 30 percent of lamp failures. See chapter 8 of this TSD for 

further information. 

NEMA commented that while the three-year rebuttable presumption test36 may work for 

GSFLs, they did not agree that it would work for IRLs, which must pay for themselves during 

their actual, shorter lifetimes. (NEMA, No. 15 at p. 23) The three-year timeframe is based on the 

EPCA provision stating that a rebuttable presumption of economic justification results if DOE 

finds that the additional cost of purchasing a standards-compliant product is less than three times 

the value of the energy savings during the first year that would result from the standard. EPCA 

also requires DOE to consider the specific criteria in 42 U.S.C. 6295(o)(2)(B)(i) when 

prescribing new or amended standards, such as impacts on utility, competition, and the nation. 

DOE’s analyses of these criteria serve to either support or rebut any presumption that a standard 

is economically justified. DOE has conducted the full set of economic analyses required by 42 

U.S.C. 6295(o)(2)(B)(i) for this preliminary analysis. These analyses include an assessment of 

LCC savings and payback periods associated with each proposed CSL, including payback 

periods that are shorter than three years. 

Additionally, the payback periods reported in chapter 8 of the TSD are ‘‘simple payback 

periods,’’ computed using the same methodology utilized to compute payback periods for a 

rebuttable presumption payback period test. The LCC analysis also includes financing effects 

and utilizes energy costs that vary over time and expresses the total costs experienced by 

consumers in these scenarios. 

 

36 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)) 
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For electrical utility rates by state and market segment, NEMA and OSI suggested DOE 

contact EEI as an additional source of information. (NEMA, No. 15 at p. 24; OSI, Public 

Meeting Transcript, No. 10 at p. 227) EEI remarked that the most recent prices and projections 

should be used and that 2010 EIA data and Annual Energy Outlook 2012 (AEO 2012) should be 

available by early 2012. (EEI, Public Meeting Transcript, No. 10 at pp. 227-228) DOE used the

most recent data sources for electricity prices and trends, the 2011 Form EIA-861 data and AEO 

2012, in this preliminary analysis. 

Additionally, noting that DOE proposed to use 2007 data sources to derive labor rates in 

the framework document, NEMA stated that an adjustment for inflation would be required. 

(NEMA, No. 15 at p. 23) Because DOE used 2011 data sources for labor rates in this preliminary 

analysis, no further adjustments were necessary because the dollar year of the analysis is 2011. 

EEI commented that in addition to the high/low economic growth scenarios it may be 

necessary to account for stricter EPA regulations in an additional scenario. These regulations 

would result in changes to utility generation portfolios, especially in terms of coal generation and 

renewable energy, which may affect electricity prices in the United States. (EEI, Public Meeting 

Transcript, No. 10 at p. 228) 

 On April 13, 2012, EPA published a proposed rule that would establish new source 

performance standards on emissions of carbon dioxide (CO2) for new affected fossil fuel-fired 

electric utility generating units (EGUs). 77 FR 22392 (April 13, 2012). Because these potential 

regulations have not yet been finalized, DOE finds that any assessment of their impacts on 

electricity price projections would be speculative. In its LCC analysis, however, DOE uses three 

separate projections from AEO to capture the uncertainty of electricity price trends in the forecast 

period: reference, low economic growth, and high economic growth. The high and low growth 

cases show the projected effects of alternative economic growth assumptions on energy markets. 

2.10 SHIPMENTS ANALYSIS 

DOE uses projections of product shipments to calculate the national impacts of standards on 

energy use, NPV, and future manufacturer cash flows. Details on the shipments analysis are 

provided in chapter 9 of this TSD. This section highlights key changes in the shipments 

modeling approach used in this rulemaking and responds to comments by stakeholders regarding 

how DOE estimates shipments. 

DOE adopted a shipments model to estimate lamp shipments for this rulemaking. The 

details of the modeling are described in chapter 9 of this TSD. The shipments model has three 

main interacting elements: (1) a lamp demand module, which estimates the demand for GSFL 

and IRL lighting for each year of the analysis period; (2) a module that assigns shipments to 

product classes and ELs based on consumer sensitivities to first costs and operation and 

maintenance costs; and (3) a price learning module, which projects future prices based on 

historic price trends. The model allows product switching across appropriate product categories, 

constrained by substitution matrices, which specify the product choices available to consumers 

(lamps as well as lamp-and-ballast combinations for fluorescent lamps) depending on whether 
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they are renovating lighting systems, installing lighting systems in new construction, or are 

simply replacing lamps. Scenarios were constructed to assess the potential impacts of 

uncertainties in the future penetration of LEDs and lighting system controls into the GSFL and 

IRL markets and the potential impact of rare earth prices on GSFL prices. 

The lamp demand module estimates the lumen demand for GSFL and IRL lighting. The 

lumen demand calculation assumes that sector-specific lighting capacity (maximum lumen 

output of installed lamps) remains fixed per square foot of floor space, and that floor space 

changes over the analysis period according to AEO 2012 projections. While lumen capacity 

demand per square foot remains fixed, annual lighting energy consumption per square foot is 

allowed to vary according to the fraction of the floor space implementing lighting system 

controls. The module also accounts for LED lighting penetration into the GSFL and IRL 

markets. To estimate the impact of the market incursion of LEDs on the rulemaking, an 

alternative scenario was run that assumed no growth in LED use over the analysis period. A 

lamp turnover calculation estimates demand for lamps in each year given the initial stock, the 

expected lifetimes of the lamps (and ballasts for GSFLs), and sector-specific assumptions on 

operating hours. 

The module that assigns shipments to product classes and ELs based on consumer 

sensitivities to first costs and operation and maintenance costs selects which lamps are purchased 

in any given year, based on these sector-specific consumer sensitivities and the available lamp 

options, which were determined in the engineering analysis and the LCC analysis. The available 

options also depend on the case under consideration. In the base case, all lamp and ballast 

options are available. In each possible standards case only those lamp options at or above the 

CSL are considered to be available. In this way, the module assigns market shares to the different 

product classes and ELs based on historical observations of consumer behavior. The consumer 

choice module incorporates a limit on the technology diffusion using a Bass diffusion curve 

based on historic rates of penetration of new lighting technologies into the market. It also 

accounts for other observed deviations from purely price and cost-driven behavior using an 

acceptance factor. 

The price learning module estimates lamp and ballast prices in each year of the analysis 

period. Historic data on GSFL and IRL sales were fit to an experience curve that describes the 

relationship between price and cumulative shipments for U.S. consumption. Cumulative 

shipments are initialized based on historical shipments data. They are then augmented in each 

subsequent year of the analysis based on the shipments determined for the prior year by the 

module that assigns shipments to product classes and ELs based on consumer sensitivities to first 

costs and operation and maintenance costs. The current year’s shipments, in turn, affect the 

subsequent year’s prices. 

NEMA commented that the market is adopting new energy saving technologies without 

DOE rulemakings. One example is the voluntary conversion from T12 to T8 over the last 20 

years. Based on current NEMA sales data, T8 lamp market share has increased to represent 

approximately 70 percent of the 4-foot linear market, stimulated by a collaboration of industry 

and its partners rather than government regulation. The driving forces are utility and Federal 

incentive programs, increasing electricity rates, and manufacturers’ sales programs. Therefore, 
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NEMA suggested that the DOE projection models for energy savings include a derating factor 

that accounts for voluntary adoption of other efficient products and the resulting reduction of 

energy savings due to standards for regulated products. (NEMA, No. 15 at pp. 19-20). 

By using an economic model in its shipments analysis and national impacts modeling that 

assigns shipments to product classes and ELs based on consumer sensitivities to first costs and 

operation and maintenance costs, DOE accounts for voluntary conversions to more efficient 

technologies based on economic incentives. DOE accounted for past utility incentive programs 

in the calibration of its consumer choice model. The modeling includes sensitivity analysis for 

electricity rates. Observed factors that result in deviations from price-predicted market shares are 

incorporated in the model by calibration to current market shares. DOE requests feedback on 

current and planned incentive programs that could affect future sales. 

EEI stated that DOE, in addition to incorporating the use of dimmers into the analysis, 

should also consider the market shift from IRLs to other technologies (such as CFLs and LEDs 

in the residential sector and to CFLs, LEDs, or metal halide lamps in the commercial sector) as a 

result of the July 2012 standards. (EEI, No. 13 at p. 4) EEI further suggested looking at a 

sensitivity analysis for substitution based on initial price impacts because consumers, particularly 

in the residential sector, may switch to flood CFLs exclusively due to price. (EEI, Public 

Meeting Transcript, No. 10 at pp. 235-236)

DOE has incorporated the use of lighting controls, including dimmers, into the shipments 

and energy-use analyses. The modeling assumes two scenarios for commercial and industrial 

lighting and a single scenario for residential lighting. For residential lighting, DOE assumes that 

the use of dimmers remains at the current level. For commercial and industrial lighting, in one 

scenario DOE assumes that the use of controls continues to grow, driven by the requirements of 

current building codes. In an alternative scenario, lighting controls are held constant at the 

current level. 

With respect to consumer behaviors that could result in a market shifts away from IRLs, 

DOE is using a model that addresses product substitution based on consumer response to first 

costs and operating costs. DOE expects that LEDs will have a significantly larger impact on the 

IRL market than other lighting products over the analysis period. Reflector lamps have been the 

first significant target of the LED market because the directional light output of LEDs is 

consistent with the directed-light design objective of reflector lamps. While the market share of 

CFLs is expected to be fixed or declining among residential use of IRLs, LED shipments are 

expected to grow rapidly.37 The shipments model currently accounts for the projected incursion 

of LEDs into the GSFL and IRL markets based on projections developed for DOE’s Solid-State 

Lighting Program.38

 

37 Based on products offered for sale online in October 2012, offerings of LED PAR lamps already exceed those of 

CFLs by a factor of 2.5, and the LED share has been rapidly growing. 

38 Navigant Consulting, Energy Savings Potential of Solid-State Lighting in General Illumination Applications, 

DOE, Solid State Lighting Program, January 2012. 
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NEMA stated that rising lamp costs due to increases in rare earth prices could negatively 

affect shipments. (NEMA, Public Meeting Transcript, No. 10 at p. 244) DOE examined the 

recent history of volatility in rare earth prices and the potential impact on lamp prices. In its 

analysis, DOE has separated the impact of rare earth costs from the remainder of the fluorescent 

lamps’ prices. It applies price learning only to the non-rare-earth component of the price. To 

incorporate the potential impact of volatility in rare earth prices, DOE developed scenarios that 

bound the observed highest, current, and historic baseline prices. The potential impacts on 

shipments are discussed in chapter 9 of this TSD. 

2.11 NATIONAL IMPACT ANALYSIS 

The NIA assesses the NES and the NPV from a national perspective of total consumer 

costs and savings expected to result from new or amended energy conservation standards. 

Analyzing impacts of potential energy conservation standards for GSFLs and IRLs requires 

comparing projections of U.S. energy consumption with new or amended energy conservation 

standards against projections of energy consumption without the standards. Candidate standards 

cases are specified by setting the hypothetical CSL for each product class. 

Because the model allows for substitutions across product classes, to understand the impact 

of setting a standard at any given CSL for any given product, the impact on all other products 

must be considered. To explore a range of impacts from potential standards, this preliminary 

analysis explored two candidate standards cases. In one, the standard for all product classes is set 

at CSL 1. In the other, the standard is set at the maximum CSL for each product class. For IRLs, 

only the first option applies since all product classes include only one CSL. In addition to 

conducting the analysis for the rulemaking as a whole, DOE evaluated the NPV and NES by 

product class. DOE coded the NIA in a Microsoft Excel file available on regulations.gov, docket 

number EERE-2011-BT-STD-0006 at www.regulations.gov/#!documentDetail;=EERE-2011-

BT-STD-0006-0021, allowing access to a broad range of scenario assumptions for conducting 

sensitivity analyses on specific input values. 

DOE accounts for the direct rebound effect in its NES analyses. Direct rebound is the 

concept that as appliances become more efficient, consumers use more of their service because 

their operating cost is reduced. In the case of lighting, the rebound could be manifested in 

increased hours of use or in increased lighting density (fixtures per square foot). In the 

framework document, DOE proposed to use an 8.5 percent rebound rate for residential lighting 

and a 1 percent rebound rate for commercial and industrial lighting, as was used in the 2009 

Lamps Rule. Those values came from a publication by Greening et al. (2000),39 which cited 

lighting rebound estimates from earlier studies conducted in the 1990s. 

EEI and NEEA both stated that they thought the rebound rates assumed by DOE for 

residential and commercial lighting are too high, citing, among other factors, the increasing and 

 

39 Greening, L., D. Green, and C. Difigio (2000), “Energy Efficiency and consumption—the rebound effect—a 

survey”, Energy Policy, 28: 389 – 401.
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related effects of building codes and lighting controls that constrain over-lighting. (EEI, Public 

Meeting Transcript, No. 10 at p. 241; NEEA, Public Meeting Transcript, No. 10 at p. 240) 

DOE investigated U.S. light rebound rates (see appendix 10C of this TSD) based on more 

current information. Greening et al. report that the studies for residential lighting are 

inconclusive due to the methods used. A more recent study of residential lighting in 369 homes 

in California showed no difference in the hours of use of CFLs with respect to other lamps,40

which suggests a low degree of rebound from efficacy improvement. A comparison of the 200141

and 201042 LMC reports show no evidence of rebound of residential or commercial lighting. 

Given the information from the above sources, DOE assumed no rebound for the residential or 

commercial lighting in its reference scenario for this preliminary analysis. DOE also conducted 

sensitivity analyses on the rebound rate, presented in chapter 10 of this TSD. 

EEI noted that on the site-to-source conversion factors, there should be a sensitivity 

analysis based on the progress of EPA rulemakings given press announcements about older coalfired plants being retired, being refueled with natural gas, or being replaced with biomass or 

some renewals. (EEI, Public Meeting Transcript, No. 10 at p. 241) 

On April 13, 2012, EPA published a proposed rule, putting forth new source performance 

standards on emissions of carbon dioxide (CO2) for new affected fossil fuel-fired EGUs. 77 FR 

22392 (April 13, 2012). Because these potential regulations have not yet been finalized, DOE 

finds that any assessment of their impacts on site-to-source conversion factors speculative. 

2.11.1 National Energy Savings Analysis 

The inputs for determining the national energy savings for each product class are: (1) 

lamp shipments; (2) annual energy consumption per unit; (3) stocks of lamps in each year; (4) 

national energy consumption; and (5) site-to-primary energy and fuel full cycle conversion 

factors. The lamp stocks were calculated by the shipments model for each year of the analysis 

period from the prior year’s stock, minus retirements, plus new shipments, accounting for lamp 

and ballast lifetimes. DOE calculated the national electricity consumption in each year by 

multiplying the number of units of each product class and EL in the stock by the corresponding 

power consumption and operating hours. The electricity savings are estimated from the 

difference in national electricity consumption between the base case (without new standards) and 

the candidate standards cases for lamps shipped during the 2017-2046 period. 

DOE has historically presented the NES in terms of primary energy savings. In response 

to the recommendations of a committee on “Point-of-Use and Full-Fuel-Cycle Measurement 

Approaches to Energy Efficiency Standards” appointed by the National Academy of Science, 

 

40 KEMA, CFL Metering Study Final Report, Oakland, CA, 2005. 

41 Navigant Consulting Inc., 2001 U.S. Lighting Market Characterization, DOE, Solid State Lighting Program, 

September, 2002. 

42 Navigant Consulting Inc., 2010 U.S. Lighting Market Characterization, DOE, Solid State Lighting Program, 

January, 2012. Available online: http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan2012.pdf. 
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DOE announced its intention to use full-fuel-cycle (FFC) measures of energy use and 

greenhouse gas (GHG) and other emissions in the national impact analyses and emissions 

analyses included in future energy conservation standards rulemakings. 76 FR 51281 (August 18, 

2011). While DOE stated in that notice that it intended to use the Greenhouse Gases, Regulated 

Emissions, and Energy Use in Transportation (GREET) model to conduct the analysis, it also 

stated it would review alternative methods, including the use of NEMS. After evaluating both 

models and the approaches discussed in the August 18, 2011 notice, DOE has determined NEMS 

is a more appropriate tool for this application. 77 FR 49701 (Aug. 17, 2012). Therefore, DOE is 

using the NEMS model to conduct FFC analyses. For this analysis, DOE calculated FFC energy 

savings using the methodology described in appendix 10B of this TSD presents both the primary 

energy savings and the FFC energy savings for the considered candidate standard cases. 

2.11.2 Net Present Value Analysis 

The inputs for determining NPV are: (1) total annual installed cost; (2) total annual 

savings in operating costs; (3) a discount factor to calculate the present value of costs and 

savings; (4) present value of costs; and (5) present value of savings. DOE calculated net savings 

each year as the difference between the base case and each standards case in terms of total 

savings in operating costs versus total increases in installed costs. DOE calculated savings over 

the lifetime of products shipped in the 30-year analysis period. DOE calculated NPV as the 

difference between the present value of operating-cost savings and the present value of total 

installed costs. DOE used a discount factor based on real discount rates of 3 and 7 percent to 

discount future costs and savings to present values. 

 For the NPV analysis, DOE calculates increases in total installed costs as the difference 

in total installed cost between the base case and standards case (i.e., once the standards take 

effect). Because the more efficacious products bought in the standards case usually cost more 

than products bought in the base case, cost increases appear as negative values in the NPV. 

 DOE expresses savings in operating costs as decreases associated with the lower energy 

consumption of products bought in the standards case compared to the base case. Total savings 

in operating costs are the product of savings per unit and the number of units of each vintage that 

survive in a given year. 

2.12 LIFE-CYCLE COST SUBGROUP ANALYSIS 

The LCC subgroup analysis evaluates economic impacts on selected groups of 

consumers. At the NOPR stage of this rulemaking, DOE will conduct the LCC subgroup analysis 

and divide consumers into subgroups accounting for variations in key inputs to the LCC analysis. 

A consumer subgroup comprises a subset of the population more likely to be affected 

disproportionately by energy conservation standards (e.g., small businesses or firms that use 

GSFLs or IRLs in particular applications where energy savings are likely to be small). The 

purpose of a subgroup analysis is to determine the extent of any such disproportionate effect. 

DOE will work with industry and other interested parties early in the rulemaking process to 

identify any subgroups for consideration. 
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In comparing potential effects on the different consumer subgroups, DOE will evaluate 

variations in regional electricity prices, usage profiles, and installation costs that might affect 

LCC and PBP for certain consumer subgroups under potential energy conservation standards. To 

the extent possible, DOE will obtain estimates of the variability in each input and consider this 

variability when calculating effects on consumers. DOE will discuss this variability with 

interested parties and likely sources of information. For more detail on the approach to the LCC 

subgroup analysis, see chapter 11 of this TSD. 

NEMA recommended that DOE put greater weight on low-income households as that 

market segment is growing. NEMA stated that it is also important to remember that household 

use occurs primarily at night, not during peak daytime hours. With low hours of operation, 

payback lengths for households increase as product pricing increases. It is therefore essential that 

DOE develop a separate analysis for residential users. NEMA had no additional subgroups to 

recommend, but emphasized that each subgroup should be analyzed separately as their factors 

and considerations are very different. (NEMA, No. 15 at p. 27) Regarding market sectors, DOE 

analyzes the residential sector separately from the commercial and industrial sectors. DOE notes 

that all LCC subgroups will be analyzed separately from the primary LCC results, as DOE varies 

inputs such as operating hours to capture different usage profiles. 

2.13 MANUFACTURER IMPACT ANALYSIS 

The purpose of the MIA is to identify the likely impacts of higher energy conservation 

standards on manufacturers. In conducting this analysis, DOE will seek input from 

manufacturers and other interested parties and consider financial impacts, as well as a wide range 

of quantitative and qualitative industry impacts that might occur after adoption of a standard. For 

example, a particular standard level could require changes to manufacturing practices of GSFLs 

and IRLs. DOE will identify and discuss these impacts in interviews with manufacturers and 

other interested parties during the NOPR stage of the analysis. 

DOE conducts the MIA in three phases, and further tailors the analytical framework 

based on the comments it receives. In Phase I, DOE creates an industry profile to characterize the 

industry and identify important issues that require consideration. In Phase II, DOE prepares an 

industry cash flow model and considers what information it might gather in manufacturer

interviews. In Phase III, DOE interviews manufacturers and assesses the impacts of standards 

both quantitatively and qualitatively. DOE assesses industry and subgroup cash flow and NPV

using the Government Regulatory Impact Model (GRIM). DOE then assesses impacts on 

competition, manufacturing capacity, employment, and regulatory burden based on manufacturer 

interview feedback and discussions.

 DOE evaluates and reports preliminary MIA information in this preliminary analysis 

phase. DOE gathers the information for the analysis during manufacturer interviews. See chapter 

12 of this TSD for more detailed information on the MIA. 

2.13.1 Sources of Information for the Manufacturer Impact Analysis 

 The MIA uses outputs from other upstream analyses, such as the engineering analysis, 

the NIA, and the markup analysis. It also utilizes inputs based on publicly available information, 
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such as 10-K filings, and refines these inputs based on feedback during the manufacturer 

interviews. These analyses provide important information for the MIA, including the number of 

shipments, the manufacturer production costs, and the markups for each product. DOE 

supplements this information with company financial data and other information gathered and/or 

refined during interviews with manufacturers to estimate the industry financial parameters, such 

as the tax rate, the R&D rate, the capital expenditure rate, the depreciation rate, and industry 

discount rate. 

 DOE aggregates information across manufacturers to create a combined industry opinion 

or estimate. The interview process plays a key role in the MIA. DOE conducts detailed 

interviews with manufacturers to gain insight into the range of potential impacts of standards. 

Typically, DOE solicits both quantitative and qualitative information during the interviews on 

the potential impacts of ELs on sales, direct employment, capital assets, and industry 

competitiveness. 

2.13.2 Industry Cash Flow Analysis 

 The industry cash flow analysis relies primarily on the GRIM. DOE uses the GRIM to 

analyze the financial impacts of more stringent energy conservation standards on the industry. 

The GRIM analysis uses several inputs to determine industry annual cash flows with and without 

amended energy conservation standards. These inputs include shipments, production costs, 

product markups, conversion costs for higher efficacy standards, and industry financial 

parameters. DOE then compares the industry annual cash flows resulting from two scenarios – 

one where more efficacious standards are mandated and one where base case projections, which 

involve no amended energy conservation standards, are applied. The financial impact of 

amended energy conservation standards is the difference between the two sets of discounted 

industry annual cash flows. Other performance metrics, such as return on invested capital, are 

also available from the GRIM. See chapter 12 of this TSD for more information on the industry 

cash flow analysis. 

2.13.3 Direct Employment Impact Analysis 

The impact of amended energy conservation standards on employment is an important 

consideration in the rulemaking process. Manufacturer interviews play a significant role in 

assessing how domestic employment patterns might be impacted by amended conservation 

standards. DOE explores current employment trends in the GSFL and IRL industries and solicits 

feedback from manufacturers on changes in employment patterns that may result from increased 

standard levels. See chapter 12 of this TSD for more information on the direct employment 

impact analysis. 

2.13.4 Manufacturer Subgroup Analysis 

 Average industry impacts may not adequately show differential impacts among 

subgroups of manufacturers that have different cost structures or operate within different 

regulatory frameworks. For example, small and niche manufacturers, or manufacturers whose 

cost structure differs significantly from the industry average, could experience a more negative 

impact. Ideally, DOE would consider the impact on every firm individually; however, because 

this usually is not possible, DOE typically uses the results of the industry characterization to 
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group manufacturers exhibiting similar characteristics. One common subgroup identified is small 

business manufacturers. DOE will analyze impacts on small business manufacturers consistent 

with the Regulatory Flexibility Act. (5 U.S.C. 601 et seq.) 

 During the interview process, DOE discusses the potential subgroups and subgroup 

members it has identified for the analysis. DOE will encourage manufacturers to recommend 

subgroups or characteristics that are appropriate for the subgroup analysis. See chapter 13 of this

TSD for more detail on the manufacturer subgroup analysis. 

2.13.5 Competitive Impacts Assessment 

 EPCA directs DOE to consider any lessening of competition likely to result from the 

imposition of standards. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It further directs the Attorney General 

to determine, in writing, the impacts, if any, of any lessening of competition. (42 U.S.C. 

6295(o)(2)(B)(ii)) 

 The manufacturer interviews focus on gathering information that would help in assessing 

impacts on competition, such as asymmetrical cost increases to some manufacturers, increased 

proportion of fixed costs potentially escalating business risks, and potential barriers to market 

entry (e.g., proprietary technologies, limited access to resources, etc.). DOE will provide the 

Attorney General with a copy of any NOPR for consideration in evaluating the impact of 

standards on the lessening of competition. DOE will publish the Attorney General’s letter and 

address any related comments in any final rule. 

2.13.6 Cumulative Regulatory Burden 

Other regulations may apply to the GSFLs and IRLs covered under this rulemaking, and 

to other products produced by GSFL and IRL manufacturers. DOE recognizes that multiple 

regulations could result in a significant cumulative regulatory burden on manufacturers. DOE’s 

initial analysis of regulations affecting GSFLs and IRLs is located in the market and technology 

assessment (chapter 3 of this TSD). During the NOPR, DOE plans to investigate the regulations 

manufacturers mentioned in interviews and the public meeting, and will further analyze and 

consider the impact of multiple, product-specific regulatory actions on GSFL and IRL 

manufacturers. 

At the framework public meeting, DOE received comments on the energy conservation 

standards for GSFLs and IRLs established by the 2009 Lamps Rule. NEMA stated that these 

standards caused manufacturers to incur significant capital investments. (NEMA, Public Meeting 

Transcript, No. 10 at pp. 75-76) DOE acknowledges that the July 2012 standards could 

contribute to the overall regulatory burden for the current GSFL and IRL rulemaking and will 

consider the impacts in any NOPR analysis. 

2.13.7 Preliminary Results for the Manufacturer Impact Analysis 

 One important aspect of the preliminary MIA is the opportunity it creates for DOE to 

identify key manufacturer issues early in the evaluation of amended energy conservation 

standards. During preliminary interviews, manufacturers identified six major areas of concern: 

(1) rare earth materials; (2) unknown impacts of the 2009 Lamps Rule; (3) testing burden; (4) 

technology shift; (5) product innovation; and (6) impact on the residential sector. 
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Rare Earth Materials 

 Several manufacturers noted that amended standards for GSFLs could have adverse 

impacts on the domestic production of these products due to the fact that more rare earths would 

be necessary to make GSFLs more efficacious. China is currently the dominant miner and 

producer of rare earths worldwide and also imposes quotas on their raw rare earth exports, which 

drives up costs for manufacturers outside of China. As a result, manufacturers pointed out that 

amended standards could make it more attractive to manufacture GSFLs in China, rather than 

domestically. Several manufacturers stated that China’s restriction on the volume of rare earths 

exported should be cause for DOE to declare extenuating circumstances and delay a final rule. 

Unknown Impacts of the 2009 Lamps Rule

 Several manufacturers expressed concern that amended energy conservation standards 

would be premature given that the last round of standards required compliance in July 2012. 

Manufacturers are unsure how the standards from the 2009 Lamps Rule will ultimately affect 

their sales and shipments as consumer preferences shift due to the relatively elastic lighting 

market. Manufacturers noted that they have developed new products to meet the July 2012 

standards and are waiting to see which consumers order which products. 

Testing Burden 

 Several manufacturers expressed concern regarding the testing burden associated with 

amended efficacy standards for GSFLs and IRLs. Manufacturers stated that there are already 

numerous testing requirements for compliance and certification and amended GSFL and IRL 

standards would be overly burdensome. Amended standards could force manufacturers to 

increase the size of their current test laboratories and the number of man-hours associated with 

compliance testing. Additionally, the increase in the number of hours of testing would increase 

manufacturers’ energy use, along with their electricity bills. 

Technology Shift 

 Manufacturers reported that regardless of amended standards, a technological shift away 

from GSFLs and IRLs is already occurring. Several pointed out that the market is moving toward 

LED technology, especially in the commercial sector because of rebates and the return on 

investment that characterizes this technology. Manufacturers are concerned that standards will 

accelerate this migration to alternative technologies due to potential price increases from 

amended energy conservation standards for GSFLs and IRLs. 

Product Innovation 

 Manufacturers expressed concern that this GSFL and IRL rulemaking could divert 

resources from the R&D of more efficient lighting products, such as LEDs, by forcing 

manufacturers to spend time and money on products with diminishing market shares. 

Manufacturers would be forced to reallocate resources away from LEDs to make improvements 

to GSFLs and IRLs that could potentially increase end-user cost and ultimately drive consumers 

to purchase other lighting technologies. 
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Impact on the Residential Sector 

 Several manufacturers expressed concern that amended standards for GSFLs and IRLs 

would not achieve substantial energy savings in the residential sector. Residential consumers do 

not have long operating hours and manufacturers are concerned that consumers of IRLs will give 

up longer life to get a cheaper and less efficacious lamp, especially given the high first costs and 

long payback periods of more efficient technologies, such as LEDs. Furthermore, manufacturers 

expressed concern that amended standards may be overly burdensome by forcing some 

residential consumers of GSFLs to switch out their entire systems for minimal energy savings. 

2.14 EMISSIONS ANALYSIS 

 In the emissions analysis, DOE will estimate the reduction in power sector emissions of 

carbon dioxide (CO2), nitrogen oxides (NOX), sulfur dioxide (SO2) and mercury (Hg) from 

potential amended energy conservation standards for GSFL and IRL lighting. In addition, DOE 

will estimate emissions impacts in production activities (extracting, processing, and transporting 

fuels) that provide the energy inputs to power plants. These are referred to as “upstream” 

emissions. Together, these emissions account for the FFC. In accordance with DOE’s FFC 

Statement of Policy (76 FR 51281 [Aug. 18, 2011]), the FFC analysis also includes impacts of 

standards on emissions of methane and nitrous oxide, both of which are recognized as GHG. 

DOE will conduct the emissions analysis using emissions factors derived from data in the 

latest available AEO, supplemented by data from other sources. EIA prepares the AEO using 

NEMS. Each annual version of NEMS incorporates the projected impacts of existing air quality 

regulations on emissions. The text below refers to AEO 2012.

SO2 emissions from affected EGUs are subject to nationwide and regional emissions capand-trade programs. Title IV of the Clean Air Act sets an annual emissions cap on SO2 for 

affected EGUs in the 48 contiguous states and the District of Columbia (D.C.). SO2 emissions 

from 28 eastern states and D.C. were also limited under the Clean Air Interstate Rule (CAIR; 70 

FR 25162 [May 12, 2005]), which created an allowance-based trading program that operates 

along with the Title IV program. CAIR was remanded to the U.S. EPA by the U.S. Court of 

Appeals for the District of Columbia Circuit (D.C. Circuit), but it remained in effect. (See North 

Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008)). On July 6, 2011, EPA issued a replacement 

for CAIR, the Cross-State Air Pollution Rule (CSAPR). 76 FR 48208 (August 8, 2011). The 

AEO 2012 NEMS assumes the implementation of the CSAPR.43

 

43

 On December 30, 2011, the D.C. Circuit stayed the new rules while a panel of judges reviews them, and told EPA 

to continue administering CAIR. See EME Homer City Generation, LP v. EPA, Order, No. 11-1302, Slip Op. at *2 

(D.C. Cir. Dec. 30, 2011). On August 21, 2012, the D.C. Circuit issued a decision to vacate CSAPR. See EME 

Homer City Generation, LP v. EPA, No. 11-1302, 2012 WL 3570721 at *24 (D.C. Cir. Aug. 21, 2012). The court 

again ordered EPA to continue administering CAIR. AEO 2012 had been finalized prior to both these decisions, 

however. DOE understands that CAIR and CSAPR are similar with respect to their effect on emissions impacts of 

energy efficiency standards. 
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The attainment of emissions caps is typically flexible among EGUs and is enforced 

through the use of emissions allowances and tradable permits. Under existing EPA regulations, 

any excess SO2 emissions allowances resulting from the lower electricity demand caused by the 

adoption of an energy conservation standard could be used to permit offsetting increases in SO2

emissions by any regulated EGU. In past rulemakings, DOE recognized that there was 

uncertainty about the effects of efficacy standards on SO2 emissions covered by the existing capand-trade system, but it concluded that negligible reductions in power sector SO2 emissions 

would occur as a result of standards. 

Beginning in 2015, however, SO2 emissions will fall as a result of the Mercury and Air 

Toxics Standards (MATS) for power plants, which were announced by EPA on December 21, 

2011. 77 FR 9304 (Feb. 16, 2012). In the final MATS rule, EPA established a standard for 

hydrogen chloride as a surrogate for acid gas hazardous air pollutants (HAP), and also 

established a standard for SO2 (a non-HAP acid gas) as an alternative equivalent surrogate 

standard for acid gas HAP. The same controls are used to reduce HAP and non-HAP acid gas; 

thus, SO2 emissions will be reduced as a result of the control technologies installed on coal-fired 

power plants to comply with the MATS requirements for acid gas. AEO 2012 assumes that, in 

order to continue operating, coal plants must have either flue gas desulfurization or dry sorbent 

injection systems installed by 2015. Both technologies, which are used to reduce acid gas 

emissions, also reduce SO2 emissions. Under the MATS, NEMS shows a reduction in SO2

emissions when electricity demand decreases (e.g., as a result of energy efficiency standards). 

Emissions will be far below the cap that would be established by CSAPR, so it is unlikely that 

excess SO2 emissions allowances resulting from the lower electricity demand would be needed 

or used to permit offsetting increases in SO2 emissions by any regulated EGU. Therefore, DOE 

believes that efficiency standards will reduce SO2 emissions in 2015 and beyond. 

CSAPR established a cap on NOX emissions in 28 eastern states and the District of 

Columbia. Energy conservation standards are expected to have little effect on NOX emissions in 

those states covered by CSAPR because excess NOX emissions allowances resulting from the 

lower electricity demand could be used to permit offsetting increases in NOX emissions. 

Therefore, DOE estimates NOX emissions reductions from potential standards in the states where 

emissions are not capped. 

 The MATS limit mercury emissions from power plants, but they do not include emissions 

caps and, as such, DOE’s energy conservation standards would likely reduce Hg emissions. 

Power plants may emit particulates from the smoke stack, which are known as direct 

particulate matter (PM) emissions. NEMS does not account for direct PM emissions from power 

plants. DOE is investigating the possibility of using other methods to estimate reduction in PM 

emissions due to standards. The great majority of ambient PM associated with power plants is in 

the form of secondary sulfates and nitrates, which are produced at a significant distance from 

power plants by complex atmospheric chemical reactions that often involve the gaseous 

emissions of power plants, mainly SO2 and NOX. The monetary benefits that DOE estimates for 

reductions in SO2 and NOX emissions resulting from standards are in fact primarily related to the 

health benefits of reduced ambient PM. 
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2.15 MONETIZING CO2 AND OTHER EMISSIONS 

 DOE plans to consider the estimated monetary benefits likely to result from the reduced 

emissions of CO2 and NOX that are expected to result from each of the amended energy 

conservation 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 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 2015, expressed in 2011$, were $6.1, $25.4, 

$41.0, and $77.7 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 estimates 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, ranging from $460 to $4,722 per ton in 2011$.44 In accordance with 

the Office of Management and Budget (OMB) guidance,45 DOE calculates the monetary benefits 

using each of the economic values for NOX and real discount rates of 3 percent and 7 percent. 

 DOE is evaluating appropriate monetization of Hg emissions in energy conservation 

standards rulemakings. Whether monetization of reduced Hg emissions will occur in this 

rulemaking is not yet certain. 

 

44 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. 

45 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003). 
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2.16 UTILITY IMPACT ANALYSIS 

In the utility impact analysis, DOE analyzes the changes in electric installed capacity and 

generation that result for each trial standard level. The utility impact analysis uses a variant of EIA’s 

NEMS,46 which is a public domain, multi-sectored, partial equilibrium model of the U.S. energy 

sector. Each year, DOE/EIA uses NEMS to produce an energy forecast for the United States, the 

AEO. DOE uses a variant of this model, referred to as NEMS-BT,47 to account for selected utility 

impacts of new or amended energy conservation standards. DOE’s analysis consists of a comparison 

between model results for the most recent AEO Reference Case and for cases in which energy use is 

decremented to reflect the impact of potential standards. For the analysis of standards on GSFLs 

and IRLs, DOE will use the most recent version of NEMS that is available.

2.17 EMPLOYMENT IMPACT ANALYSIS 

Employment impacts include direct and indirect changes in the domestic workforce 

resulting from new or amended energy conservation standards. Direct employment impacts are 

any changes in the number of employees of manufacturers of the product subject to standards. 

The MIA addresses impacts in the number of employees working for the manufacturers. Indirect 

employment impacts from standards consist of the net jobs created or eliminated in the national 

economy, other than in the manufacturing sector being regulated, caused by: (1) reduced 

spending by end users on energy; (2) reduced spending on new energy supply by the utility 

industry; (3) increased spending on new products to which the new standards apply; and (4) the 

effects of those three factors throughout the economy. 

One method for assessing the possible effects on the demand for labor of such shifts in 

economic activity is to compare sector employment statistics developed by the Labor 

Department’s Bureau of Labor Statistics (BLS). The BLS regularly publishes its estimates of the 

number of jobs per million dollars of economic activity in different sectors of the economy, as 

well as the jobs created elsewhere in the economy by this same economic activity. Data from 

BLS indicate that expenditures in the utility sector generally create fewer jobs (both directly and 

indirectly) than expenditures in other sectors of the economy.48 There are many reasons for these 

differences, including wage differences and the fact that the utility sector is more capitalintensive and less labor-intensive than other sectors. Energy conservation standards have the 

effect of reducing consumer utility bills. Because reduced consumer expenditures for energy 

likely lead to increased expenditures in other sectors of the economy, the general effect of 

 

46 For more information on NEMS, refer to the U.S. Department of Energy, Energy Information Administration 

documentation. A useful summary is National Energy Modeling System: An Overview 2003, DOE/EIA-0581(2003), 

March, 2003. 

47 DOE/EIA approves use of the name NEMS to describe only an official version of the model without any 

modification to code or data. Because this analysis entails some minor code modifications and the model is run 

under various policy scenarios that are variations on DOE/EIA assumptions, DOE refers to it by the name NEMSBT. (BT is DOE’s Building Technologies Program, under whose aegis this work has been performed.) 

48 Bureau of Economic Analysis, Regional Multipliers: A User Handbook for the Regional Input-Output Modeling 

System (RIMS II), U.S. Department of Commerce (1992). 
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efficiency standards is to shift economic activity from a less labor-intensive sector (i.e., the 

utility sector) to more labor-intensive sectors (e.g., the retail and service sectors). 

In any NOPR stage of this rulemaking, DOE would estimate indirect national 

employment impacts using an input/output model of the U.S. economy called Impact of Sector 

Energy Technologies version 3.1.1 (ImSET).49 ImSET is a special-purpose version of the “U.S. 

Benchmark National Input-Output” (I–O) model, which was designed to estimate the national 

employment and income effects of energy saving technologies. The ImSET software includes a 

computer-based I–O model having structural coefficients that characterize economic flows 

among 187 sectors most relevant to industrial, commercial, and residential building energy use. 

DOE notes that ImSET is not a general equilibrium forecasting model and understands the 

uncertainties involved in projecting employment impacts, especially changes in the later years of 

the analysis. Because ImSET does not incorporate price changes, the employment effects 

predicted by ImSET may overestimate actual job impacts over the long run. DOE may consider 

the use of other modeling approaches for examining long-run employment impacts. 

2.18 REGULATORY IMPACT ANALYSIS 

In the NOPR stage of this rulemaking, DOE will prepare an RIA that will address the 

potential for non-regulatory approaches to supplant or augment energy conservation standards to 

improve the efficacy of GSFLs and IRLs 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 and compare such effects with those projected to result from amended energy 

conservation standards. DOE will attempt to base its assessment on the actual impacts of any 

such initiatives to date, but will also consider information presented regarding the impacts that 

any existing initiative might have in the future. 

If DOE proposes amended energy conservation standards for GSFLs or IRLs and the 

NOPR constitutes a significant regulatory action, DOE would prepare and submit to OMB for 

review the assessment of costs and benefits required under section 6(a)(3) of Executive Order 

12866, “Regulatory Planning and Review,” 58 FR 51735 (Oct. 4, 1993). 

2.19 DEPARTMENT OF JUSTICE REVIEW 

Section 325(o)(2)(B)(i)(V) of EPCA states that, before the Secretary of Energy may 

prescribe a new or amended energy conservation standard, the Secretary shall ask the U.S. 

Attorney General to make a determination of “the impact of any lessening of competition...that 

is likely to result from the imposition of the standard.” (42 U.S.C. 6295) Pursuant to this 

 

49 J. M. Roop, M. J. Scott, and R. W. Schultz, ImSET 3.1: Impact of Sector Energy Technologies (PNNL-18412), 

Pacific Northwest National Laboratory (2009) (Available at: 

www.pnl.gov/main/publications/external/technical_reports/PNNL-18412.pdf ).
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requirement, DOE solicited the views of the U.S. Department of Justice on any lessening of 

competition that is likely to result from the imposition of a proposed standard and gave the views 

provided full consideration in assessing economic justification of a proposed standard.