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 -532- 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 Contro ls ............................................................................................... 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 CO 2 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 ................................................................ 2-542-1 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
tec hnologically 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 de scription 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

a mong 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

re sponse to the framework document. Finally, chapter 2 provides cross-references to the other chapters of th is 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

e fficacy; 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 he alth and safety;

 an engineering analysis to study representative lamp systems and, as appropriate, lampa nd -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

a ny 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

c osts;2-2

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

e xamined 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 manuf acturers that may result from an amended efficacy standard.

DOE may revise any of its analyses based on comments and new information received on thi s 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 standa rds on emissions of carbon dioxide (CO 2 ), sulfur dioxide (SO 2 ), nitrogen oxides (NO X ), 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 Fluorescent2-3

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

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

re sponses, and summarizes the analytical approach taken in this preliminary analysis. In the executive summary of th is 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 inca ndescent 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 DO E 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 standa rds 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 amend ed

e xisting energy conservation standards for GSFLs and IRLs (42 U.S.C. 6295(i)(3)) and adopt ed standards for additional GSFLs (42 U.S.C. 6295(i)(5)). Th at 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 maintaine d 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 IR Ls. DOE is considering correcting the typographical errors in the sections of the Code of Federal Regulations (CFR) that lay out the GSFL standards
spec ified in EPCA and the IRL standards established by the 2009 Lamps Rule. Specifically, for the G SFL 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 5.8P 0.27

, 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*P 0.27

< 125 V 5.9*P 0.27

≤ 2.5 ≥ 125 V 5.7*P 0.27

< 125 V 5.0*P 0.27

40

- 205 W Modified Spectrum > 2.5 ≥ 125 V 5.8*P 0.27

< 125 V 5.0*P 0.27

≤ 2.5 ≥ 125 V 4.9*P 0.27

< 125 V 4.2*P 0.27

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)

e xpressed 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 ; EE I, 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 st andards”). 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 throug h 2012 and some production lines may be shut down if no longer profitable due to

re design costs. (NEMA, Public Meeting Transcript, No. 10 at pp. 70, 73 -74, 210; NEMA, No. 15 at p p. 2-3 ) NEMA also emphasized the unknown impact of the July 2012 standards on IRL bu ying 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 fr amework 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
p p . 2 -3)2-6

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
state d they expect catalog and product availability data to be obtainable in July 2012 and sales da ta 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

c ompliance 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

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

or iginal 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 th at date. 42 U.S.C. 6295(i)(4) DOE publish ed 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 int erval of five years would be maintained between the publications of the final rules for the first

a nd 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 obtain ed 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 framework2-7

document, DOE considered ex ploring 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,

e specially 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 ENE RGY 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 dire ctionality 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)

P G&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 DO E 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 St a ndards Awareness Project (ASAP), the Natural Resources Defense Council (NRDC), the Alli ance to Save Energy

, the American Council for an Energy-Efficient Economy, the National C onsumer Law Center, the Northwest Energy Efficiency Alliance (NEEA), and the Northeast Ene rgy Efficiency Partnerships (hereafter the “Joint Comment”) encouraged DOE to pursue the de velopment of a metric that takes the directional nature of IRLs into account and suggested that the ne w 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 be am 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 shoul d 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 incr ease in product classes required to accurately describe characteristics such as solid

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

S everal 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

e xpected 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 it2-8

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

a pproval 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 int ensity (candle power) measurements, which are not currently required. This would result in additional costs for laboratories not capable of performing light intensity measurements. Because
qua ntities such as beam angle and CBCP are not familiar to the general public, considerable

c onsumer 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 me tric 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, DO E 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. 6 293 ) Manufacturers of covered products must use these test procedures to certify to DOE that their product complies with EPCA energy

c onservation 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 ti tle 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. Th e test procedures were first updated in a final rule published in July 2009. 74 FR 31829 (July 6, 2009). The rule updated

c itations to industry standards and made several other modifications. DOE further amended the test proc edures 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 addr ess standby mode and off mode energy use. (42 U.S.C. 6295(gg)(3)) EPCA defines2-9

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 ofequipment 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,

ne ither 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 GSF Ls 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

c onsidering 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

e nergy savings. EPCA, however, directs DOE to determine if the standards in effect for fluor escent 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 EPA ct 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) ) EPC A does not limit the scope of this rulemaking to definitions specified in EPAct 1992. As mentioned in sec tion 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 I RLs 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

a s 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”

a nd 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

c an 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

sa tisfy 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,

re print, 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:2- 12

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
pro ducts 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 be en established. In considering whether to establish standards for additional GSFLs, DOE first

re views 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 li ghting applications, ar e 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, 1362 9 (March 13, 2008). For each additional GSFL identified, DOE then assesses whether standards have the potential to

re sult in significant energy savings and are technologically feasible and economically justified. S tandards 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).

I f 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
t ypes. The current definition of fluorescent lamp is as follows:

Fluorescent la mp 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) w ith 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

e valuate 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 a re 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 wit hin a range of lamp lengths. As modifying lamp length slightly could exempt a lamp fr om 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

a nd 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) S pecifically, 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 h igh 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
g aps exist for 3-foot T8 lamps. PG&E and SCE also added that there are other 2-foot and 3-foot2- 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

c ommented 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 indus tries, 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 special ty 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 im pact 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

re present 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

c onsuming 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 threeprimary 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 include s 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 T8 7 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. 8 The 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

a nd 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

a pp roximately 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
qua lifies pin base CFLs as a low volume niche product. (CA IOUs, Public Meeting Transcript, No. 10 a t 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 re asonable 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 C FLs in this rulemaking, and that a combined rulemaking would provide an opportunity to use DO E’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

c ourse 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 pr oducts 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 de termined 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

c overed or CFLs.

2.3.2.2 Additional Wattages

DO E 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

c onsidered 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 la mp s 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 Mi niBP 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

a greed 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 ex tending 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, B R30, BR40, or ER40; (2) lamps rated 65 W that are BR30, BR40, or ER40 lamps; and (3) R20 I RLs 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 f ramework document, DOE has suspended these rulemaking activities as a result of section 315 of Public Law (P ub

. L.) 112-74 (Dec. 23, 2011), which prohibits DOE from using

a ppropriated funds to implement or enforce standards for ER
, BR , a nd bulged parabolic reflector IRLs. DOE therefore does not consider these comments here and has also not included any of the
t ypes 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

EPC A defines an incandescent reflector lamp as a lamp that “has a rated wattage that is 40 wa tts 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

re viewed 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 ra ted 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
pr oducts 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 IRL s 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 i mprove 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

c ompanies. 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 S ystem product code 335110, “Electric Lamp Bulb and Part Manufacturing,” which has a size standa rd 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
pa rties 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

a nd 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 comments2- 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

I n the framework document, DOE included a list of technology options to analyze for GSF Ls. 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

a nd high efficiency phosphor technology have been reached by manufacturers and a br eakthrough is needed to make further improvements. NEMA also commented that im provements 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 publi cations, technical journals, and patent filings; and consults with technical experts and manuf acturers 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
pa ss 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.

R egarding higher efficiency lamp diameters, NEMA noted manufacturers are already
pr oducing 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 e fficient 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 Im proved electrode coatings allow electrons to be more easily removed from electrodes, reducing lamp power and increas ing 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 enabl e the phosphors to absorb more UV energy, so that they emit more visible light. Higher Efficiency Lamp Diameter Optimal la mp diameter s improve lamp efficacy.

Multi

- Photon Phosphors Phosphors e mit more than one visible photon for each incident UV photon.

2.4.2.2 IRL Technology Options

I n the framework document, DOE included a list of technology options to analyze for IRLs. DOE received several comments on these options. NEMA comment ed 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 a t p. 16) NEMA further stated that in dustry is already maximizing IRL effica cy 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 publi cations, technical journals, and patent filings; and consults with technical experts and manuf acturers 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

c ombination 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, howe ver, DOE is considering removing tungsten halogen as a technology option. DOE has de termined 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 at2- 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

a lso 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

e xtremely 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. DO E considers whether high efficiency reflector coatings pass the screening criteria in the

sc reening 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 leve ls 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 I R 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 ink 11 ). Therefore, DOE is maintaining IR phosphor glass coatings as a technology option. DOE considers whether IR phosphor glass coatings pass the

sc reening criteria in the screening analysis. DOE also considers cost and impacts on utility in de termining 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

wa velengths (under 500 nm, namely the UV and blue spectrums) into longer wavelengths (the
g reen and yellow spectrums), thereby possibly increasing the lumen output of an IRL by

a pproximately 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-Emitti ng 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
tec hnology 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

c oating, 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 de pendent 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

sc reening criteria in the screening analysis. DOE also considers cost and impacts on utility in de termining the economic justification of any standard levels developed using this technology.

NEMA commented that trihedral corner lens reflectors that reflect light back onto the filame nt would have no practical application. (NEMA, No. 15 at p. 9) DOE notes that cost is not

c onsidered when identifying technology options; cost impacts are assessed in later analyses. Regarding efficacy, while DOE is not aware of any commercially available products that incor porate 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

re flector 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 opti on meets the screening criteria in the screening analysis. DOE also considers cost and im pacts 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 ther efore cannot be used above certain wattages or with smaller lamp sizes. (OSI, Public Meeting Transcript, No. 10 at p. 193) In response, the CA IOU s 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, P ublic Meeting Transcript, No. 10 at p. 194) OSI disagreed, stating that the maximum tempe rature at which IR coatings can be used has been reached. (OSI, Public Meeting Transcript, No. 10 a t p. 195) Because there are products on the market that use IR coatings and exist at mul tiple 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 standa rds 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 ha logen 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 incor porate 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 class es for small diameter lamps ( i.e. , less than or equal to 2.5 inches) and large diameter lamps ( i.e. , gre ater than 2.5 inches) given the utility of small diameter lamps provided through their installation in smaller fixtures. DOE would dire ctly analyze and develop efficacy levels for the large diameter lamps and then apply a

sc aling 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

e fficacy 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 filame nt 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 , incre asing surface area and thereby light output.

Novel Filament Materials More effic ient 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 Efficien cy Inert Fill Gas Filling lamps with alternative gases, such as Krypton, to reduce hea t conduction. Higher Pressure Tungsten

Halogen 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 haloge n 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 Ba llasted Low Voltage Lamps An integral ballast converts the operating voltage of the lamp from line voltage to a lower voltage.
Higher Effic iency 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

o nto 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 lig ht to another filament, the reflective face of another filament support, or radially outward

.

Permanent Infrared Reflector Coating Shroud P ermanent 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

c apacity 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

c onstraints of lamps ( i.e. , lamp shape and length); and (3) lumen package.

W ith regards to separating product classes by CCT, NEMA agreed that color temperature should remain a differentiator because color temperature impacts efficacy; specifically, the hig her 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
struc ture, 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

e fficacy 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.

DO E 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 li near 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 physical2- 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 fluor escent lamps we re 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 consider ing 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 diff erences, 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

a re 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

a vailable for T8 than for T5 lamp-and-ballast systems. Lumen package refers to the quantity of li ght 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-footT5 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 fluor escent 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 Mini BP 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,

a re 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

eco nomic 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

a t 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
pa ckages, 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

c onsidering 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 IR L s 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 diame ter 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 and2- 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,

c ompared 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
ope rated 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

re sult 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 St ates that operate at 130 V and operating lamps at higher than rated voltage causes
pr emature 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, P ublic 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 spectrum 18 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; and2- 29

because they provide a different type of light than standard spectrum lamps. However, the same
tec hnologies 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 lar ge 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 fur ther 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
te chnology 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 loss es and optimize current technology performance rather than attain further improvements in lamp e fficacy. (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

c onsiders this technology option as means of improving lamp efficacy to be practicable to manuf acture, 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 Coatings2- 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 Tungst en -Halogen Lamps

 Infrared Glass Coatings

 Integrally Ballasted Low Voltage Lamps2- 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

se lects baseline lamp s within those representative product classes, and identifies more

e fficacious substitutes for the baseline lamps. DOE uses these more efficacious lamps to develop C SLs.

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

c ombining 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 de termination (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 “r epresentative” 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

c onsideration 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

c omply 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

a ssumptions and projections and that data from truly representative products should be used

w hen 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

a t 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

a vailable GSFLs and IRLs that included products on the market after the July 2012 standards

re quired compliance. DOE supplemented this evaluation with information gathered during manufacturer interviews regarding new product lines manufacturers we re planning to launch. A t the time of this analysis, many manufacturers 20 had been granted exception relief exempting their 700 se ries T8 lamps from the July 2012 standards for a period of two years. The waiver was
g ranted 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

a vailability 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 de velopment of representative lamps. However, they cautioned against using prototype lamps in m aking 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 Mini BP 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 proc edure.

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 Ame rican 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. (Compl iance 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 subm itted 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 AN SI 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 Tr anscript, 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

a nalysis 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 be cause of their high market volumes. For GSFLs, in the framework document DOE identified the r epresentative 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 K2- 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 s pectrum > 2.5 inches ≥ 125 < 125 (representative)

≤ 2.5 inches ≥ 125

< 125

Modified s pectrum > 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 diame ter) 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 r eduction factor developed to scale from ELs for large diameter lamps to those for the small diameter lamps (s e e 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

c haracterize 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 J uly 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 ba seline performance levels given in the framework document to be too high and suggested

a djusting 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 resulting2- 37

baseline ELs are reflective of commercially available products that are the most common, least

e fficacious lamps available in each representative product class.

Comments specific to the GSFL and IRL baseline selections are discussed in the sections be low.

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 un its analyzed at the standard levels adopted in 2009 Lamps Rule ( TS L 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 ba selines 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) L utron requested clarification on why the considered baseline value for the 4-foot T8 baseline doe s 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 ba sed on catalog values of the representative lamps. In the 2009 Lamps Rule, DOE utilized catalog values to develop initial EL s and then analyzed available compliance reports to establish mi nimum 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 I OUs commented that low-efficacy, high-CRI T12 lamps not covered by standards should be

a nalyzed 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 ba seline 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 ba seline for that product class. Fluorescent lamps with a CRI greater than or equal to 87, also

re ferred to as high-CRI lamps, are exempt from the definition of general service fluorescent lamp (se e 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

a nd 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 la mps 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 Mee ting 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) Althoug h 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 a t p. 167; NEMA, No. 15 at p. 13) PG&E and SCE suggested that regardless of whether standa rds-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

a way 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 (s e e 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 diff icult 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 f ramework 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 MB P 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 a t 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

ma rket, DOE is considering a baseline lamp for the 4-foot MBP product class that has an initial2- 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

a n 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

mea sured 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 diff

erent 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 e fficacy 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 DO E 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 l m/W l m lm h r 4

- Foot MBP T8 32 32.5 89.2 2,900 2,725 24,000 83 8

- Foot SP s limline 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 8 6

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 lamp s that just complied2- 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 ( TS L 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, DO E stated it was considering the 40 W, 55 W, and 66 W lamps identified as reduced wattage

e quivalent lumen replacements in the 2009 Lamps Rule. All three of the baseline lamps
pr esented in the framework document were halogen infrared (HIR) lamps that use both halogen
tec hnology 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*P 0.27 ) from the 2009 Lamps Rule 22 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 ba seline 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 doe s 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 lowe r 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 life time supported by actual life time test data. NEMA noted that 2,000 hours has been the typical I RL 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, whic h 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

a re 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 I OUs stated that a baseline lamp should not be a 4,000-hour lamp when the typical lamp has a li fetime 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 ba seline lamps of the same wattage, as each one represents the most common, least efficacious products that comply with standards.

Table 2.6. 4 . IRL Basel ine Lamps

Baseline Lamp Design Option Initial Light Output Efficacy Lamp Lifetime

l m lm/W h r 60 W PAR3 8 Improved Halogen* 1

, 070 17. 8 1,500 60 W PAR3 8 HIR 1

, 100 18.3 3 ,000 *This halogen includes a n improved reflector.

2.6.4 More Efficacious Substitutes DOE selects a series of more efficacious replacements for the baseline lamps considered withi n each representative product class. DOE considered only technologies that met all four

c riteria in the screening analysis. These selections were made such that potential substitutions maintaine d light output within 10 percent of the baseline lamp’s light output with similar
pe rformance characteristics, when possible. In identifying the more efficacious substitutes, DOE uti lized 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
g ranted 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 ex amine the impact of rare earth availability in relation to standards for GSFLs during the

c ourse of this rulemaking.2- 42

2.6.4.1 General Service Fluorescent Lamps

For GSFLs, DOE considered more efficacious lamps under two different substitution

sc enarios: (1) lamp replacement and (2) lamp-and-ballast replacement. DOE identified substitute lamps that saved energy 23 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

sc enario, 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. The refore, 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 standa rds-compliant reduced wattage version that is more efficacious than the baseline lamp. The de sign options utilized in the modeled lamp, such as higher efficiency phosphors, are the same de sign 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 de tails. 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

re present the lamp-and-ballast combinations present in the market.

For these lamp-and-ballast systems, lamps were paired with ballasts that had a BF 24 that would result in a more efficacious lamp-and-ballast system. Specifically, DOE paired highe r

e fficacy 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 identif y 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 providedenergy savings. DOE requests comments on whether replacements of lamps and/or lamp-andba llast 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

c hapter 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 li ght 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 C omment, and the CA IOUs recommended that DOE consider higher EL s 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 C omment, 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 EL s 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 C onsulting (Ecos; now Ecova, Inc.) in 2009 for PG&E, ASAP, and NRDC found that the

c ombination of a highly efficacious, double-ended halogen capsule with an advanced IR coating and a silverized reflector yield ed 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

re searched 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 6.9P 0.27 ). This performance level was shown to be possible using: n on -proprietary burners2- 44

from four different manufacturers (GE, Philips, Deposition Sciences Inc. [DSI], and Toshiba);
p atented silverized reflectors from two different manufacturers (GE and DSI), both of which are available for cross-licensing; d ouble-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 int ernal 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 model ed lamps only when the lamp c an 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
pr ototype’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 showe d 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

e stablished in the framework document. (PG&E and SCE, No. 17 at p. 4) DOE acknowledges that f or 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 a chieve 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

sc ale 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*P 0.27 , 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 hig h 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 thi s 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

e conomically 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 LC C

a nalysis 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 de velops 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 standard2- 46

level of a given product class; 27 and (3) the max tech level. In the framework document, DOE
pr esented 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 fr amework 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

a nalysis, 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. DO E 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 f ramework 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 doc ument. NEMA and OSI noted that reduced wattage lamps do not provide equivalent utility to

27 EL s 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 tha t in these applications, reduced wattage lamps may have starting or stability issues; for cing consumers to other less efficient and more expensive lighting technologies. Therefore, NEMA suggest ed 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 int erviews 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
pe rcent for 4-foot T5 MiniBP SO. (EEI, No. 13 at p. 2) NEMA remarked that the new

re quirements 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 fu ll 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 da ta 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 Classe s CSL Lamp

Diameter Nominal

Wattage Rated

Wattage Rated

Efficacy Initial

Light Output Mean

Light Output Life
CRI

W W lm/W lm l m 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

c omposition, 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 se ries 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. DO E also confirmed through compliance information that CSL 2 was attainable for full wattage hig h 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

re placement. (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

a cknowledges 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 for2- 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

c omposition, 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 ba seline 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, ba sed 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 R DC 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

c omposition, 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

re duces 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

a nd 47 W T5 lamps, or an improved 800 series full wattage T8 lamp in which the phosphor mix

a nd/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, be cause full and reduced wattage lamps are not interchangeable in all applications, DOE ensure s in this preliminary analysis that full wattage lamps can meet each CSL considered. Because there

a re no commercially available full wattage higher efficacy replacements for the 4-foot T5 Mi niBP 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

c onsider 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 T 5 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

a t 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
pe rformance characteristics were provided for lamp operation at 25 °C.

F or 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 doc ument. 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, NE MA 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
pr ograms such as ENERGY STAR ® Buildings, newer versions of ASHRAE and IEC building

e fficiency 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
g oing 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 P AR38 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
pr eliminary 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

a dopted 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 im position 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 a2-52

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*P 0.27 , 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 rule making. 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.

T able 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 dist inct 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 a nd 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 H IR technology, such as IR glass coatings with a higher efficiency reflector coating.

F or 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

e fficacies 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.2- 53

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 6.2P 0.27 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

n oted 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 class es and that therefore one scaling factor should be applied across all GSFL lamp types. To develop this scaling factor, DOE identified
pa irs 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 diff erence 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 mi nimum 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 on2- 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,

a s 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-footMBP 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 MB P 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 MB P 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
pr oduct 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

c onsideration 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

ne eded. 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)

I n this preliminary analysis, DOE directly analyzes as representative standard spectrum lamps wit h diameters greater than 2.5 inches, and input voltages less than or equal to 125 V be cause 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 inputvoltages less than or equal to 125 V to greater than 125 V. Further, the low volume of standardsc ompliant lamps in non-representative product classes would make it difficult to directly analyze2- 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
spec ified in the EISA 2007 definition of modified spectrum. The Ecos research also found that it is fe asible to make modified spectrum IRLs exceeding the max tech levels in the 2009 Lamps Rule for standard spectr

um 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 whe n 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 definition 28 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 de veloped 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 ( IES NA ) 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 app lications 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 430.22- 56

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

e xponents 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 mi nimum, the ELs should be the same for 120 V and 130 V pro ducts or, if the curves are interpreted correctly, 130 V lamps should have a slightly lower efficacy threshold. (NEMA, No. 15 a t p. 17)

As discussed in section 2.4.3.2 , DO E 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 i f it is necessary. (Lutron, Public Meeting Transcript, No. 10 at pp. 200-201) The CAIOUs 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 a ccurate assumption because Philips fit a double-ended burner in to 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 on2- 57

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

sc aling 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 incor porating various amounts of “rare earth phosphors,” which consist of rare earth materials. Ha lophosphor blends are much less costly than those containing rare earth materials. However,

ra re 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

wa velengths 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

a ddress 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

e xempting their 700 series T8 lamps from the July 2012 standards until 2014. The two-year

wa iver 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.2- 58

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 th is rulemaking needs to consider the effects of

co mponent 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 foc u s on rare earth mining in the United States and elsewhere, the specific heavy rare earth phosphors ne eded 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 b y orders of magnitude, in part caused by China closing rare earth mines for humanitarian

c oncerns 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

a nd a 130 percent increase if the max tech standard were adopted. NEMA stated the inability to

mee t 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

a ffect availability in the short term, as research is still several years away from developing a cost

e ffective 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 Tr anscript, 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 a t 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

e ndanger 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
star t 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 incr ease 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)2- 59

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 standa rds from this rulemaking would likely not require compliance until 2017 or 2018, by whic h 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
pr oduction 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

e xpected an improvement in the rare earth market, specifically noting that supplies of key rare

e arth 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

a dvancements 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

e fficiency fluorescent lamps. DOE acknowledges that supply and demand of rare earth phosphors should be c onsidered 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.) DO E requests comment on the specific impacts of an increase in rare earth phosphor prices due to decreased supply on the cost of lamps

c overed 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 pricesfor 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

re sidential 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.2- 60

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

c onsumer 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

ma y 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
st a ndards 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

a t 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 sig nificant price increases for GSFLs. Specifically, DOE conducted a sensitivity analysis that

c onsidered 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

sa vings for the 4-foot MBP product class. DOE is conducting a similar sensitivity for this preliminary analysis; s ee 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. Althoug h 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 a t 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

ne cessary. 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 1 0 of this TSD for further details. (For this preliminary analysis, when assessing data, DOE assumed the exception relief2- 61

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 bydeveloping 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 ba seline and higher efficacy lamps considered in this rulemaking. DOE determines the energy

c on sumption 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 I 31 and recent versions of Energy Information Administration’s (EIA ’s ) Comm ercial 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

c haracterization 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.2- 62

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

a nd 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 indust rial 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 the ir 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 us e. 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. DO E’s test procedure requires that GSFLs be tested at low frequency unless only high frequency ba llast 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
pr actice, DOE analyzed only electronic ballasts, and therefore calculated the system input power rating of each lamp-and-ballast system operating at high frequency.2- 63

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 o f 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 t he 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

e nergy 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.aspx2- 64

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

c omplete discussion.

Lutron noted that there are many studies in commercial buildings that document savings fr om 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, P ublic Meeting Transcript, No. 10 at p. 217-218) DOE research has indicated that the covered lamps a re 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 (E PA) 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

c hange 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

a ccount both purchase price and operating expenses. The PBP represents the time it takes torecover the additional installed cost of the more efficacious products through annual operatingc ost 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. I nputs to the LCC calculation include the installed cost to the consumer (purchase price plus inst allation cost), operating expenses, the lifetime of the product or another defined period of

a nalysis, and a discount rate. Inputs to the PBP calculation include the installed cost to the

c onsumer and annual operating costs. DOE received several comments regarding the LCC methodolog y 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. (N EEA, 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 Tr anscript, No. 10 at pp. 229-230) EEI suggested using information from banking or retail2- 65

associations to determine the percentage of purchases of lamps made by cash, credit, and debit. (E EI, 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

c ompanies 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 li fetime. 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 test 36 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 EPC A provision stating that a rebuttable presumption of economic justification results if DOE finds that the a dditional 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. DO E’s analyses of these criteria serve to either support or rebut any presumption that a standard is economically justified. DOE has conduct ed 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
pe riods,’’ computed using the same methodology utilized to compute payback periods for a

re buttable 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))2- 66

For electrical utility rates by state and market segment, NEMA and OSI suggested DOE

c ontact 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 th e 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 f ramework 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

a nalysis, no further adjustments were necessary because the dollar year of the analysis is 2011.

EE I 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 r esult 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 Tr anscript, No. 10 at p. 228)

On April 13, 2012, EPA published a proposed rule that would establish new source
pe rformance standards on emissions of carbon dioxide (CO 2 ) f or 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

se parate 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 whether2- 67

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 lum en 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

c hanges 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

mar kets. 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

a cceptance factor.

The price learning module estimates lamp and ballast prices in each year of the analysis
pe riod. 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,2- 68

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

a ssigns 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.

EE I 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 t he residential sector and to CFLs, LEDs, or metal halide lamps in the commercial sector) as a

re sult of the July 2012 standards. (EEI, No. 13 at p. 4) EEI further suggested looking at a

se nsitivity 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 2012.2- 69

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

re cent 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 obse rved 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

c omparing projections of U.S. energy consumption with new or amended energy conservation standards against projections of energy consumption without the standards. Candidate standards

c ases 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

a nalysis 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, onl y 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, docke t 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

c oncept 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 lightin g 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 eff ect

— a survey”, Energy Policy, 28: 389 – 401.2- 70

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 2001 41 and 2010 42 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

c ommercial 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 sensitivityanalysis 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 (CO 2 ) 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 shi pments; (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 fa ctors. The lamp stocks were calculated by the shipments model for each year of the analysis
pe riod 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 mul tiplying 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 c andidate standards cases for lamps shipped during the 2017-2046 period.

DO E 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.2- 71

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

e nergy 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 an al ysis 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

c onsumers. 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 IR Ls 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.2- 72

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

a nalyzes 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 manuf acturers 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 conduct s the MIA in three phases, and further tailor s the analytical framework based on the comments it receives. In Phase I, DOE creates an i ndustry 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 interview s . In Phase III, DOE interv iews 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, manufacturin g capacity, employment, and regulatory burden based on manufacturer interview feedback and discussions.

DOE evaluat es and reports preliminary MIA information in this preliminary analysis phase. DOE gathers the information for the analysis during manufacturer interviews. See chapter 1 2 of th is 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,2- 73

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 o f shipm ents, the manufacturer production costs, and the markups for each product. DOE supplements this information with company financial data and other information gathered and/or

re fined during interviews with manufacturers to estimate the industry financial parameters, such

a s 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 int erviews 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

c ompetitiveness.

2.13.2 Industry Cash Flow Analysis The industry cash flow analysis relies primarily on the GRIM. DOE uses the GRIM to

a nalyze 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

a mended energy conservation standards. These inputs include shipments, production costs,
pr oduct 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 invol ve no amended energy conservation standards, are applied. The financial impact of amended energy conservation standards is the difference between the two sets of discounted indus try annual cash flows. Other performance metrics, such as return on invested capital, are also available from the GRIM. See chapter 12 of th is 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 fe edback 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 subg roups 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 to2- 74

group manufacturers exhibiting similar characteristics. One common subgroup identified is small busi ness 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 discuss es 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 th is 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 evaluati ng 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 ot her products produced by GSFL and IRL manufacturers. DOE recognizes that multiple

re gulations could result in a significant cumulative regulatory burden on manufacturers. DOE’s ini tial analysis of regulations affecting GSFLs and IRLs is located in the market and technology

a ssessment (chapter 3 of th is 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 Tr anscript, 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)
tec hnology shift; (5) product innovation; and (6 ) impact on the residential sector.2- 75

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

a mended 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 Ru le 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

a mended 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 incr ease 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 manuf acturers’ energy use, along with their electricity bills.

Te chnology Shift Manufacturers reported that regardless of amended standards, a technological shift away fr om GSFLs and IRLs is already occurring. Several pointed out that the market is moving toward L ED technology, especially in the commercial sector because of rebates and the return on investment that characterizes this technology. Manufacturers are concerned that standards w ill accelerate this migration to alternative technologies due to potential price increases from amended energy conservation standards for GSFLs and IRLs.

Produ ct Innovation Manufacturers expressed concern that this GSFL and IRL rulemaking could divert

re sources 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. Manu facturers 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.2- 76

Impact on the Residential Sector Several manufacturers expressed concern that amended standards for GSFLs and IRLs woul d 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 (CO 2 ), nitrogen oxides (NO X ), sulfur dioxide ( SO 2 ) 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 standa rds on emissions of methane and nitrous oxide, both of which are recognized as GHG.

DO E 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.

SO 2 emissions from affected EGUs are subject to nationwide and regional emissions capa nd -trade programs. Title IV of the Clean Air Act sets an annual emissions cap on SO 2 for affected EGUs in the 48 contiguous states and the District of Columbia (D.C.). SO 2 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 Appe als for the District of Columbia Circuit (D.C. Circuit), but it remained in effect. (S ee N orth 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.2- 77

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 SO 2 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 SO 2
e missions by any regulated EGU. In past rulemakings, DOE recognized that there was uncertainty about the effects of efficacy standards on SO 2 emissions covered by the existing capand -trade system, but it concluded that negligible reductions in power sector SO 2 emissions would occur as a result of standards.

Beginning in 2015, however, SO 2 emissions will fall as a result of the Mercury and Air Tox ics 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

e stablished a standard for SO 2 (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, SO 2 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 SO 2 emissions. Under the MATS, NEMS shows a reduction in SO 2
e missions 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 SO 2 emissions allowances resulting from the lower electricity demand would be needed

or used to permit offsetting increases in SO 2 emissions by any regulated EGU. Therefore, DOE be lieves that efficiency standards will reduce SO 2 emissions in 2015 and beyond.

C SAPR established a cap on NO X emissions in 28 eastern states and the District of Columbia. Energy conservation standards are expected to have little effect on NO X emissions in those states covered by CSAPR because excess NO X emissions allowances resulting from the lower electricity demand could be used to permit offsetting increases in NO X emissions. Therefore, DOE estimates NO X 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

c aps and, as such, DOE’s energy conservation standards would likely reduce Hg emissions.

P ower plants may emit particulates from the smoke stack, which are known as direct
pa rticulate 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
powe r plants by complex atmospheric chemical reactions that often involve the gaseous emissions of power plants, mainly SO 2 and NO X . The monetary benefits that DOE estimates for reductions in SO 2 and NO X emissions resulting from standards are in fact primarily related to the health benefits of reduced ambient PM.2- 78

2.15 MONETIZING CO 2 AND OTHER EMISSIONS

DOE plans to consider the estimated monetary benefits likely to result from the reduced emissions of CO 2 and NO X 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 CO 2 , 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 incr emental 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

c hange 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 CO 2 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 CO 2 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 CO 2 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 NO X emissions resulting fro m the standard levels it considers. For NO X 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 calculat es the monetary benefits using each of the economic values for NO X and real discount rates of 3 percent and 7 percent.

DOE is evaluating appropriate monetization of Hg emissions in energy conservation standa rds rulemakings. Whether monetization of reduced Hg emissions will occur in thi s rule making 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).2- 79

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

a nd 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

re sulting 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

e mployment 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

e ffects 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 indi rectly) than expenditures in other sectors of the economy. 48 There are many reasons for thesedifferences, 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 rununder 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).2- 80

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

e mployment 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

e mployment and income effects of energy saving technologies. The ImSET software includes a

c omputer-based I–O model having structural coefficients that characterize economic flows

a mong 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
pr edicted 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

c onservation 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

a ny existing initiative might have in the future.

If DOE proposes amended energy conservation standards for GSFLs or IRLs and the NO PR 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, 1 993).

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 ).2- 81

requirement, DOE solicit ed the views of the U.S. Department of Justice on any lessening of

c ompetition that is likely to result from the imposition of a proposed standard and gave the views
pr ovided full consideration in assessing economic justification of a proposed standard.