General Service Fluorescent Lamp, Incandescent Reflector Lamp and General March 10-11, 2008 

Service Incandescent Lamp Test Procedure NOPR Public Meeting 

Test Procedures for 

General Service Fluorescent Lamps, 

Incandescent Reflector Lamps, and 

General Service Incandescent Lamps 

NOPR Public Meeting 

Building Technologies Program 

Office of Energy Efficiency and Renewable Energy 

U.S. Department of Energy 

March 10-11, 2008 

http://www.eere.energy.gov/buildings/appliance_standards/residential/incandescent_lamps_nopr.html 

Introduction 

Purpose of the Test Procedure NOPR Public Meeting 

Present the Department’s proposed test procedures for fluorescent 

and incandescent lamps 

Seek comment from participants on the proposed test procedures 

Discuss specific issues or questions related to the proposal 

Discuss the next steps for the rulemaking 

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EERE-2007-BT-TP-0013 COMMENT 07
General Service Fluorescent Lamp, Incandescent Reflector Lamp and General 

Service Incandescent Lamp Test Procedure NOPR Public Meeting 

March 10-11, 2008 

3

Introduction 

NOPR issued by DOE on February 21, 2008 

NOPR Public Meeting today, March 10, 2008 

Comments on NOPR from interested parties 

• Transcript records oral comments from today’s public meeting 

• Written comments (comment period closes 75 days after publication in 

the Federal Register)

DOE reviews and considers all comments 

Final Rule Publication 

• Final Rule will be published before, or on the same day as, the NOPR 

for the energy conservations standards rulemaking (October 2008) 

Steps in the Lamps Test Procedure Rulemaking 

4

Test Procedure Overview and Issues 

Introduction 

1. Updates to Test Procedure References 

2. High-Frequency Fluorescent Ballast Testing 

3. Rounding of Fluorescent Lamp Efficacy 

4. Measurement and Calculation of Correlated Color Temperature 

5. General Service Fluorescent Lamp Basic Model Definition 

6. Reference Ballast Settings for Added Fluorescent Lamp Coverage 

7. Test Procedures for General Service Incandescent Lamps 

8. Off-Mode and Standby Mode Energy Consumption 

NOPR Final 

Rule 

EERE-2007-BT-TP-0013 COMMENT 07
General Service Fluorescent Lamp, Incandescent Reflector Lamp and General March 10-11, 2008 

Service Incandescent Lamp Test Procedure NOPR Public Meeting 

Introduction 

Comments and Issues from Participants 

Workshop participants are invited to provide summary comments or 

statements 

Participants are also invited to raise their issues on the Test 

Procedure NOPR for discussion today 

5

Introduction 

Regulatory History 

Energy Policy Act of 1992, Test Procedure Final Rule. 62 FR 29221, 

May 29, 1997. 

• Established test procedures for incandescent and fluorescent lamps 

(including compact fluorescent lamps (CFLs)) 

• Incorporated by reference several ANSI and IESNA industry standards 

Energy Policy Act of 2005 (EPACT 2005), Test Procedure Final Rule. 

71 FR 71340, December 8, 2006. 

• Established test procedures for medium base CFLs based on

Version 2.0 of the ENERGY STAR program requirements

Energy Independence and Security Act of 2007 (EISA 2007) 

• Establishes energy conservation standards for general service 

incandescent lamps

• Directs DOE to incorporate a measure of standby mode and off-mode 

energy consumption into its test procedures 

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EERE-2007-BT-TP-0013 COMMENT 07
General Service Fluorescent Lamp, Incandescent Reflector Lamp and General March 10-11, 2008 

Service Incandescent Lamp Test Procedure NOPR Public Meeting 

Test Procedure Overview 

1. Updates to Test Procedure References 

2. High-Frequency Fluorescent Ballast Testing 

3. Rounding of Fluorescent Lamp Efficacy 

4. Measurement and Calculation of Correlated Color Temperature 

5. General Service Fluorescent Lamp Basic Model Definition 

6. Reference Ballast Settings for Added Fluorescent Lamp Coverage 

7. Test Procedures for General Service Incandescent Lamps 

8. Off-Mode and Standby Mode Energy Consumption 

7

Updates to Test Procedure References 

Updates to ANSI Standards 

Outdated Referenced Updated Subject

Standard(s) Standard(s) 

ANSI C78.1-1991 ANSI C78.81-2005 Dimensional and electrical 

ANSI C78.2-1991 ANSI C78.901-2005 characteristics for fluorescent lamps 

ANSI C78.3-1991 

ANSI C78.375-1991 ANSI C78.375-1997 Guide for electrical measurements 

for fluorescent lamps 

ANSI C82.3-1983 ANSI C82.3-2002 Reference ballasts for fluorescent 

lamps

Impacts of ANSI updates on CFR: 

• Amends citations in definitions of “cold temperature fluorescent lamp,” 

and “fluorescent lamp.” 

• The term “rated wattage” is also impacted, however because this 

change has the potential to modify the scope of coverage, it is 

discussed in Section II of the ANOPR. 

• Amends 10 CFR 430.22 and 10 CFR Part 430, Subpart B, Appendix R. 

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EERE-2007-BT-TP-0013 COMMENT 07
General Service Fluorescent Lamp, Incandescent Reflector Lamp and General March 10-11, 2008 

Service Incandescent Lamp Test Procedure NOPR Public Meeting 

Updates to Test Procedure References 

Updates to IESNA and CIE Standards 

Outdated Referenced 

Standard(s) 

Updated

Standard(s) 

Subject

LM-9-1988 LM-9-1999 Electrical and photometric 

characteristics for fluorescent lamps 

LM-45-1991 LM-45-2000 Electrical and photometric 

characteristics for incandescent 

lamps

LM-16-1993 Withdrawn Colorimetry of light sources 

CIE 13.2-1974 

(c.r. 1993) 

CIE 13.3-1995 Color rendering properties of light 

sources

Impacts of IESNA and CIE updates on the CFR: 

• Amends citations in the definition for “colored fluorescent lamp.” 

• Amends 10 CFR 430.22 and 10 CFR Part 430, Subpart B, Appendix R. 

9

Updates to Test Procedure References 

Medium Base Compact Fluorescent Lamps 

DOE’s May 29, 1997 Final Rule established test procedures for CFLs 

in 10 CFR 430.22 and 10 CFR Part 430, Subpart B, Appendix R. 

• References the now outdated IESNA standard LM-66-1991. 

EPACT 2005 directed DOE to establish test procedures for CFLs 

based on Version 2.0 of the ENERGY STAR program requirements 

for CFLs. 

• DOE’s December 8, 2006 Final Rule incorporated this test procedure 

for CFLs in 10 CFR Part 430, Subpart B, Appendix W. 

• The ENERGY STAR requirements incorporate the current IESNA 

standard, LM-66-2000. 

To prevent conflicting requirements, DOE is proposing to delete the 

CFL test procedures established by the May 29, 1997 Final Rule. 

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EERE-2007-BT-TP-0013 COMMENT 07
General Service Fluorescent Lamp, Incandescent Reflector Lamp and General March 10-11, 2008 

Service Incandescent Lamp Test Procedure NOPR Public Meeting 

Updates to Test Procedure References 

Request for Comment on Test Procedure 

Reference Updates 

DOE seeks comment on the proposed test procedure 

reference updates, specifically, whether these updates to 

ANSI, IESNA, and CIE standards would introduce an additional 

testing burden or change the measurement of lamp efficacy. 

(Issue #1) 

11

Test Procedure Overview 

1. Updates to Test Procedure References 

2. High-Frequency Fluorescent Ballast Testing 

3. Rounding of Fluorescent Lamp Efficacy 

4. Measurement and Calculation of Correlated Color Temperature 

5. General Service Fluorescent Lamp Basic Model Definition 

6. Reference Ballast Settings for Added Fluorescent Lamp Coverage 

7. Test Procedures for General Service Incandescent Lamps 

8. Off-Mode and Standby Mode Energy Consumption 

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EERE-2007-BT-TP-0013 COMMENT 07
General Service Fluorescent Lamp, Incandescent Reflector Lamp and General March 10-11, 2008 

Service Incandescent Lamp Test Procedure NOPR Public Meeting 

High-Frequency Fluorescent Ballast Testing 

High-Frequency Fluorescent Ballast Testing (Slide 1 of 2) 

DOE’s test procedure requires that fluorescent lamps be tested at 

low frequency (i.e., 60Hz) using a low-frequency reference ballast. 

• High-frequency reference ballasts are incorporated into the test 

procedure as part of the updated ANSI C82.3

By continuing to test fluorescent lamps on low-frequency ballasts 

when possible, DOE ensures consistent and repeatable efficacy 

measurements. 

ANSI provides only high-frequency reference ballast settings for 

several lamps (e.g., 59W/96T8/HF/IS and 86W/96T8/HO) 

DOE proposes that high-frequency testing only be used for covered 

lamps that cannot be rated on low-frequency ballasts. 

13

High-Frequency Fluorescent Ballast Testing 

High-Frequency Fluorescent Ballast Testing (Slide 2 of 2) 

Fluorescent ballast market is shifting toward high-frequency (i.e., 

electronic) ballasts. 

If future industry standards are amended so as to provide highfrequency testing specifications for a more complete set of covered 

lamps, DOE will consider reevaluating its test procedures. 

In such case, DOE may propose allowing manufacturers the option 

of choosing to rate their lamps using either a low-frequency or highfrequency reference ballast. 

• To accommodate this flexibility in the test procedure, DOE would 

likely scale its efficacy requirements for any given product class to 

reflect the efficacy requirements of a lamp on a low-frequency ballast 

to that same lamp’s performance on a high-frequency ballast. 

DOE seeks comment on whether it should limit fluorescent 

lamp testing to low-frequency ballasts. (Issue #2) 14

EERE-2007-BT-TP-0013 COMMENT 07
General Service Fluorescent Lamp, Incandescent Reflector Lamp and General March 10-11, 2008 

Service Incandescent Lamp Test Procedure NOPR Public Meeting 

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Test Procedure Overview 

Updates to Test Procedure References 

High-Frequency Fluorescent Ballast Testing 

Rounding of Fluorescent Lamp Efficacy 

Measurement and Calculation of Correlated Color Temperature 

General Service Fluorescent Lamp Basic Model Definition 

6. Reference Ballast Settings for Added Fluorescent Lamp Coverage 

Test Procedures for General Service Incandescent Lamps 

Off-Mode and Standby Mode Energy Consumption 

Rounding of Fluorescent Lamp Efficacy 

Rounding of Fluorescent Lamp Efficacy 

Lamp efficacy (for all lamps) is defined as: “the ratio of measured 

lamp lumen output in lumens to the measured lamp electrical power 

input in watts, rounded to the nearest whole number, in units of 

lumens per watt.” (10 CFR Part 430, Subpart B, Appendix R) 

• For fluorescent lamps, lamp efficacy measurements shall be rounded 

to the nearest lumen per watt. (10 CFR 430.23(r)(2)) 

• For incandescent reflector lamps, lamp efficacy measurements shall 

be rounded to the nearest tenth of a lumen per watt (10 CFR 

430.23(r)(3)). 

DOE is proposing to revise the fluorescent lamp test procedure 

such that all efficacy measurements for fluorescent lamps be 

rounded to the nearest tenth of a lumen per watt. 

DOE does not believe this requirement would not be unduly 

burdensome. 

DOE seeks comment on whether fluorescent lamp efficacy 

should be calculated to the nearest tenth of a lumen per watt. 

(Issue #3) 16

EERE-2007-BT-TP-0013 COMMENT 07
General Service Fluorescent Lamp, Incandescent Reflector Lamp and General March 10-11, 2008 

Service Incandescent Lamp Test Procedure NOPR Public Meeting 

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Test Procedure Overview 

Updates to Test Procedure References 

High-Frequency Fluorescent Ballast Testing 

Rounding of Fluorescent Lamp Efficacy 

Measurement and Calculation of Correlated Color Temperature 

General Service Fluorescent Lamp Basic Model Definition 

6. Reference Ballast Settings for Added Fluorescent Lamp Coverage 

Test Procedures for General Service Incandescent Lamps 

Off-Mode and Standby Mode Energy Consumption 

Correlated Color Temperature 

Correlated Color Temperature 

Correlated Color Temperature (CCT) is used in DOE regulations for 

two purposes: 

1. DOE uses CCT as a metric to define “colored fluorescent lamp” and 

“colored incandescent lamp,” lamps excluded from regulation. 

2. DOE is considering establishing product classes for fluorescent 

lamps in part around CCT in the energy conservation standards 

ANOPR.

– In the ANOPR, DOE invites comment on the development of 

separate product classes and efficacy standards for fluorescent 

lamps based on CCT. 

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EERE-2007-BT-TP-0013 COMMENT 07
General Service Fluorescent Lamp, Incandescent Reflector Lamp and General March 10-11, 2008 

Service Incandescent Lamp Test Procedure NOPR Public Meeting 

Correlated Color Temperature 

CCT for Colored Fluorescent Lamps 

DOE proposes to incorporate by reference IESNA LM-9-1999 to 

determine CCT for fluorescent lamps 

• Involves measuring the spectral power distribution and calculating 

the chromaticity coordinates which correspond to a particular CCT. 

DOE does not believe the adoption of this IESNA standard imposes 

excessive burden on manufacturers because they already calculate 

chromaticity coordinates to report on CCT for their product catalogs 

and marketing literature. 

DOE proposes to amend the definition of “colored fluorescent 

lamp” under 10 CFR 430.2 and in 10 CFR Part 430, Subpart B, 

Appendix R to include references to IESNA LM-9-1999. 

DOE seeks comment on the proposed incorporation by 

reference of the industry standard LM-9-1999 for measuring 

and determining CCT for fluorescent lamps. (Issue #4) 19

Correlated Color Temperature 

CCT for Colored Incandescent Lamps 

EISA 2007 introduces a new definition for “colored incandescent 

lamp”

• A colored incandescent lamp is, in part, an incandescent lamp with “a 

correlated color temperature less than 2,500K, or greater than 4,600K, where 

correlated temperature is computed according to the Journal of Optical 

Society of America, Vol. 58, pages 1528-1595 (1986).” (EISA 2007, Section 

321(a)(1)(B)) 

[Note: the EISA 2007 citation is 1986, but it should be 1968]

EISA 2007 gives a precise reference, which DOE proposes to 

incorporate into its incandescent lamp test procedure. 

DOE does not consider this action to be unduly burdensome, as no 

manufacturer is required to determine the CCT of their incandescent 

lamps.

• However, if a manufacturer wishes to be excluded from regulatory standards 

because an incandescent lamp has a CCT <2500K or >4600K, then they must 

use the method presented in the Journal of Optical Society of America paper. 

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EERE-2007-BT-TP-0013 COMMENT 07
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Service Incandescent Lamp Test Procedure NOPR Public Meeting 

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Test Procedure Overview 

Updates to Test Procedure References 

High-Frequency Fluorescent Ballast Testing 

Rounding of Fluorescent Lamp Efficacy 

Measurement and Calculation of Correlated Color Temperature 

General Service Fluorescent Lamp Basic Model Definition 

6. Reference Ballast Settings for Added Fluorescent Lamp Coverage 

Test Procedures for General Service Incandescent Lamps 

Off-Mode and Standby Mode Energy Consumption 

GSFL Basic Model 

General Service Fluorescent Lamp Basic Model Definition 

In the energy conservation standards ANOPR, DOE is considering 

separate product classes for fluorescent lamps based on CCT.

In order to demonstrate compliance with any future efficacy 

standard that was based around CCT, manufacturers would test and 

report on their ‘basic model’ for each product class. 

• A ‘basic model’ involves identifying a lamp or class of lamps which do 

not have any differentiating electrical, physical, or functional features 

that affect efficacy. 

In DOE’s May 1997 Final Rule, ‘basic model’ was defined for GSFL 

as including all lamps with essentially identical light output, power 

input, and luminous efficacy, regardless of their CCT.

DOE proposes to amend its definition of “basic model” for GSFL in 

10 CFR 430.2 so as to require that the lamps have similar CCTs.

DOE seeks comment on its proposal that all GSFL that are 

considered to be in the same basic model must have similar 

CCTs. (Issue #5) 22

EERE-2007-BT-TP-0013 COMMENT 07
General Service Fluorescent Lamp, Incandescent Reflector Lamp and General March 10-11, 2008 

Service Incandescent Lamp Test Procedure NOPR Public Meeting 

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Test Procedure Overview 

Updates to Test Procedure References 

High-Frequency Fluorescent Ballast Testing 

Rounding of Fluorescent Lamp Efficacy 

Measurement and Calculation of Correlated Color Temperature 

General Service Fluorescent Lamp Basic Model Definition 

6. Reference Ballast Settings for Added Fluorescent Lamp Coverage 

Test Procedures for General Service Incandescent Lamps 

Off-Mode and Standby Mode Energy Consumption 

Reference Ballast Settings 

Reference Ballast Settings for 

Additional Fluorescent Lamp Coverage 

DOE proposes adopting additional reference ballast settings for 

regulated lamps that do not yet have ANSI approved reference 

ballast settings in ANSI C78.81-2005 and C78.901-2005 

These additional lamps are often lower-wattage replacements for 

lamps that already exist in the ANSI standards 

DOE derived these additional reference ballast settings based on 

the settings for lamps included in the ANSI standards 

• (e.g., for 4-foot T8 lamps, reference ballast settings are derived from 

32W/48T8/RS) 

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EERE-2007-BT-TP-0013 COMMENT 07
General Service Fluorescent Lamp, Incandescent Reflector Lamp and General March 10-11, 2008 

Service Incandescent Lamp Test Procedure NOPR Public Meeting 

Reference Ballast Settings 

Reference Ballast Settings for 

Additional Fluorescent Lamp Coverage 

These additional lamps that require reference ballast settings 

include: 

• Several 4-foot medium bipin and 2-foot U-shaped lamps that have 

been introduced into the market (e.g., 28W 4-foot T8 MBP) 

• Lamps to which DOE is considering expanding its fluorescent lamp 

coverage in the ANOPR preliminary determination 

• Several lamps to which DOE does not currently plan on extending 

coverage in the energy conservation standards rulemaking (i.e., VHO 

fluorescent lamps and T5). DOE proposes settings for these lamps to 

avoid needing to re-open the test procedure should DOE decide to 

extend coverage to these lamp types in the future. 

25

Reference Ballast Settings 

Proposed Reference Ballast Settings (Slide 1 of 2) 

4-Foot Medium Bipin Lamps not listed in ANSI C78.81-2005: 

• T10 and T12 lamps: 236 volts, 0.430 amps, 439 ohms 

• T8 lamps: 300 volts, 0.265 amps, 910 ohms 

2-Foot U-shaped Lamps not listed in ANSI C78.901-2005: 

• T12 lamps: 236 volts, 0.430 amps, 439 ohms 

• T8 lamps: 300 volts, 0.265 amps, 910 ohms 

8-Foot Single Pin Slimline Lamps not listed in ANSI C78.81-2005: 

• T12 lamps: 625 volts, 0.425 amps, 1280 ohms 

• T8 lamps: 625 volts, 0.260 amps, 1960 ohms 

8-Foot RDC HO Lamps not listed in ANSI C78.81-2005: 

• T12 lamps: 400 volts, 0.800 amps, 415 ohms 

• T8 lamps: 450 volts, 0.395 amps, 595 ohms 

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EERE-2007-BT-TP-0013 COMMENT 07
General Service Fluorescent Lamp, Incandescent Reflector Lamp and General March 10-11, 2008 

Service Incandescent Lamp Test Procedure NOPR Public Meeting 

Reference Ballast Settings 

Proposed Reference Ballast Settings (Slide 2 of 2) 

8-Foot Very High Output Lamps not listed in ANSI C78.81-2005: 

• T12 lamps: 400 volts, 1.500 amps, 215 ohms 

Normal or High Output T5 lamp with a nominal length of four feet 

not listed in ANSI C78.81-2005: 

• Normal Output T5: 329 volts, 0.170 amps, 950 ohms 

• High Output T5: 235 volts, 0.460 amps, 255 ohms 

27

Reference Ballast Settings 

Reference Ballast Settings for T5 Fluorescent Lamps 

Should DOE extend coverage to other T5 lamps (with other lengths 

than 4 foot nominal), DOE would establish reference ballast settings 

by deriving the reference ballast settings from International 

Electrotechnical Commission (IEC) 60081. 

DOE would determine the appropriate lamp replacement that exists 

in the industry standard and use the corresponding reference 

ballast settings for all lamps that fall into that category. 

DOE seeks comment on the proposed reference ballast

settings. (Issue #6)

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EERE-2007-BT-TP-0013 COMMENT 07
General Service Fluorescent Lamp, Incandescent Reflector Lamp and General March 10-11, 2008 

Service Incandescent Lamp Test Procedure NOPR Public Meeting 

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Test Procedure Overview 

Updates to Test Procedure References 

High-Frequency Fluorescent Ballast Testing 

Rounding of Fluorescent Lamp Efficacy 

Measurement and Calculation of Correlated Color Temperature 

General Service Fluorescent Lamp Basic Model Definition 

6. Reference Ballast Settings for Added Fluorescent Lamp Coverage 

Test Procedures for General Service Incandescent Lamps 

Off-Mode and Standby Mode Energy Consumption 

General Service Incandescent Lamps 

Test Procedures for General Service Incandescent Lamps 

EISA 2007 establishes energy conservation standards for GSIL. 

Currently, for the purpose of Federal Trade Commission labeling, a 

limited test procedure for GSIL is provided in the CFR. 

In this NOPR, DOE proposes to amend this test procedure to: 

1. Specify the units to be tested in 10 CFR 430.24(r)(1); 

2. Define the “basic model” for GSIL in 10 CFR 430.2; and 

3. Provide a method for calculating GSIL annual energy consumption 

and efficacy in 10 CFR 430.23(r). 

Because of the similarity in technology of GSIL and IRL, DOE is 

proposing that the above additions to the GSIL test procedure be 

implemented in the same manner as the existing IRL test procedure. 

DOE seeks comment on the proposed additions to the GSIL 

test procedure. (Issue #7) 30

EERE-2007-BT-TP-0013 COMMENT 07
General Service Fluorescent Lamp, Incandescent Reflector Lamp and General March 10-11, 2008 

Service Incandescent Lamp Test Procedure NOPR Public Meeting 

31

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Test Procedure Overview 

Updates to Test Procedure References 

High-Frequency Fluorescent Ballast Testing 

Rounding of Fluorescent Lamp Efficacy 

Measurement and Calculation of Correlated Color Temperature 

General Service Fluorescent Lamp Basic Model Definition 

6. Reference Ballast Settings for Added Fluorescent Lamp Coverage 

Test Procedures for General Service Incandescent Lamps 

Off-Mode and Standby Mode Energy Consumption 

Off-Mode and Standby Mode 

Off Mode and Standby Mode Energy Consumption 

Section 310(3) of EISA 2007 directs DOE to amend its test 

procedures to incorporate a measure of “off mode” and “standby 

mode” energy consumption, if feasible. 

DOE believes that GSFL, IRL, and GSIL do not employ a standby 

mode or off mode. 

• The lamp must be disconnected from the main power source in order 

for it to provide no active mode function (i.e., emit light). If the lamp 

is disconnected from the main power source, the lamp does not 

satisfy the requirements of operating in standby mode or off mode. 

• DOE also believes that all covered products that meet the definitions 

of GSFL, IRL and GSIL are single-function products and do not offer 

any secondary user-oriented or protective functions. 

DOE seeks comment on its proposal to not incorporate a 

measure of off mode and standby mode energy consumption 

in its test procedures for GSFL, IRL, and GSIL. (Issue #8)

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EERE-2007-BT-TP-0013 COMMENT 07
General Service Fluorescent Lamp, Incandescent Reflector Lamp and General March 10-11, 2008 

Service Incandescent Lamp Test Procedure NOPR Public Meeting 

Closing 

How to Submit Comments... 

 Public Meeting – oral comments will be captured in the transcript and become 

part of the public record. 

 Written comments – NOPR comment period open until 75 days after 

publication in the Federal Register 

Reference docket #: EERE-2007-BT-TP-0013 and/or RIN #: 1904-AB72 

Email: Lamps_Test_Procedure@ee.doe.gov 

Mail: Mrs. Brenda Edwards 

U.S. Department of Energy 

Building Technologies Program 

1000 Independence Avenue, SW, Mailstop EE-2J 

Washington, DC 20585-0121 

Courier: Mrs. Brenda Edwards 

U.S. Department of Energy 

Building Technologies Program 

950 L'Enfant Plaza, 6th Floor 

Washington, DC 20024 

Telephone: (202) 586-2945 33

EERE-2007-BT-TP-0013 COMMENT 07