2 | Building Technologies Program eere.energy.gov



### Combined Meeting on Energy Conservation Standards & Test Procedures for Fluorescent and Incandescent Lamps Tina Kaarsberg, PhD 

## BUILDING TECHNOLOGIES PROGRAM

Department of Energy Energy Efficiency & Renewable Energy GSFL

- IRL_2011

- STD

- 0006@ee.doe.gov, Lamps

- 2011

- TP

- 0012@ee.doe.gov

October 4, 20113 | Building Technologies Program eere.energy.gov 

## • Introductions (around the room)

• Role of the Facilitator

• Ground Rules (norms)

- Listen as an ally

- Use short, succinct statements/keep to the point

- Hold sidebar conversations outside the room

- One person speaks at a time (raise hand to be recognized; state your name for the record)

- Set cell phones to silent/vibrate



## • Housekeeping Items

• Agenda Review

• Opening Remarks 

## Welcome4 | Building Technologies Program eere.energy.gov 

## Agenda

- Morning

Introduction

9:00

– 9:30 am Welcome, Introductions, Opening Statements



## Test Procedure

9:30

– 9:40 am Overview

9:40

– 10:15 am Updates to Industry Standards: GSFL, GSIL, IRL

10:15

– 10:30 am Break

10:30

– 10:50 am New GSIL Lifetime Test Procedure

10:50

– 11:00 am Questions/Discussion5 | Building Technologies Program eere.energy.gov 

## Agenda

- Afternoon

Energy Conservation Standard

11:00 am

– 12:00 pm Overview; Scope of Coverage; Market & Technology; Screening Analyses
12 :00

– 1:00 pm Lunch Break

1:00

– 1:45 pm Engineering Analysis

1:45

– 2:15 pm Product Price Determination; Energy Use

2:15

– 2:30 pm Break

2:30

– 3:30 pm Life

- Cycle Cost and Payback Period Analysis

3 :30

– 4 :00 pm Shipment Analysis; National Impact Analysis

4 :00

– 4 :35 pm NOPR Analyses; Next Steps

4 :35

– 5:00 pm Questions/Discussion

5 :00

– 5 : 1 0 pm Closing Remarks6 | Building Technologies Program eere.energy.gov 

## Purpose of the Public Meeting

• Present DOE’s proposed test procedures for general service fluorescent lamps (GSFLs), general service incandescent lamps (GSILs), and incandescent reflector lamps (IRLs) and DOE’s proposed framework for GSFL and IRL energy conservation standards.

• Invite comment on the test procedure notice of proposed rulemaking (NOPR) and energy conservation standards framework document.

• Discuss next steps in the rulemakings.

• Invite participants to provide summary comments or statements and raise additional issues for discussion.7 | Building Technologies Program eere.energy.gov 

## Issues for Discussion

Issue Box: DOE welcomes comments, data, and information concerning its proposed test procedures for GSFLs, GSILs, and IRLs and framework for GSFLs and IRLs. Issues that correspond to those raised in DOE’s published material will be numbered in accordance with that material. Whether invited by an issue box or not, comments are welcome on any part of DOE’s analysis.

Issue box numbering corresponds to the list of issues published at the end of the each document, available at:

1. Test Procedure NOPR, published September 14, 2011: http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/gsfl_gsil_irl_nopr_tp.pdf Comment Period Ends: November 28, 2011

2. Framework, published September 14, 2011: http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/gsfl_irl_ecs_framework.pdf Comment Period Ends: October 31, 20118 | Building Technologies Program eere.energy.gov



### Test Procedures for General Service Fluorescent, General Service Incandescent, and Incandescent Reflector Lamps Notice of Proposed Rulemaking Tina Kaarsberg, PhD 

## BUILDING TECHNOLOGIES PROGRAM

Department of Energy Energy Efficiency & Renewable Energy Docket Number: EERE

- 2011

- BT

- TP

- 0012 Lamps

- 2011

- TP

- 0012@ee.doe.gov

October 4, 20119 | Building Technologies Program eere.energy.gov 

## Test Procedure Agenda

2

4 Background and Legal Authority

Updates to Industry Standards: GSFL, GSIL, IRL 2 1 Overview

3 New GSIL Lifetime Test Procedure10 | Building Technologies Program eere.energy.gov 

## Regulatory History

– Test Procedure

Energy Policy and Conservation Act, 1975 (EPCA) Established energy conservation standards and methods of test procedure development for consumer products

.

1994 Interim Rule, 59 FR 49468; 1997 Final Rule, 62 FR 29221 1994 Interim Rule established test procedures for GSFLs, GSILs, and IRLs. 1997 Final Rule revised these test procedures.

2009 Lamps Test Procedure, 74 FR 31829

2009 Lamps Standards, 74 FR 34080 Revised test procedures for GSFLs, IRLs, and GSILs.

Adopted standards and test procedures for additional types of GSFLs.

Revise existing test procedures for GSFLs, IRLs, and GSILs. Adopt test procedure for GSIL lamp lifetime. Current Test Procedure Rulemaking Energy Independence and

Security Act (EISA 2007) Required DOE to review test procedures for all covered products at least once every seven years. Established lamp lifetime requirement for GSILs.11 | Building Technologies Program eere.energy.gov 

## Test Procedure Rulemaking Process

Milestone Date

Notice of Proposed Rulemaking (NOPR) September 14, 2011
Final Rule (projected) January 2012
Compliance Date (projected) June 2012 NOPR Final Rule

Today12 | Building Technologies Program eere.energy.gov 

### • Statutory obligation to review test procedures at least once every seven years requires DOE to:

(1) Amend the test procedure to improve measurement representativeness or accuracy or reduce burden; or (2) Determine that such amendments are unnecessary. (42 U.S.C. 6293(b)(1)(A))



### • NOPR examines industry best practices and technical developments relevant to GSFL, GSIL, IRL test procedures.

• NOPR proposes to update references to industry standards in the existing DOE test procedures for GSFLs and GSILs.

• Proposes a new test procedure for measuring lamp lifetime of GSILs. 

## Test Procedure Overview

Issue 1: DOE requests comments on all aspects of DOE’s test procedures for GSFLs, GSILs, and IRLs.13 | Building Technologies Program eere.energy.gov 

## Test Procedure Agenda

2

4 Background and Legal Authority

Updates to Industry Standards: GSFL, GSIL, IRL 2 1 Overview

3 New GSIL Lifetime Test Procedure14 | Building Technologies Program eere.energy.gov 

### The following updates to industry standards for the GSFL and GSIL test procedures are proposed. 

## Updates to Industry Standards Incorporated by Reference

Currently Referenced

Standard Updated Standard to be Referenced Title

ANSI C78.81

2005, ANSI C78.81

- 2003 ANSI C78.81

- 2010 American National Standard for Electric Lamps

- Double

- Capped Fluorescent Lamps

Dimensional and Electrical Characteristics

IESNA LM

- 9

- 1999 IES LM

- 9

- 2009 IES Approved Method for the Electrical and Photometric Measurement of Fluorescent Lamps

IESNA LM

- 45

2000 IES LM

- 45

- 2009 IES Approved Method for the Electrical and Photometric Measurement of General Service Incandescent Filament Lamps15 | Building Technologies Program eere.energy.gov 

### DOE proposes to update all references to ANSI C78.81 (both 2003 and 2005) to ANSI C78.81

- 2010.

• ANSI C78.81 addresses dimensional and electrical characteristics for double

- capped fluorescent lamps.

• ANSI C78.81

- 2010 adds high

- frequency and low

- frequency lamp specifications for 25

- watt (W), 28W, and 30W, reduced

- wattage 4

foot T8 medium bipin (MBP) lamps.

• The low

- frequency reference ballast specifications in ANSI C78.81

2010 for these lamps have no impact because they are identical to the specifications DOE currently directs manufacturers to use for those fluorescent lamps in section 4.1.2.1 of Appendix R. 

## ANSI C78.81

- 2010 for GSFLs16 | Building Technologies Program eere.energy.gov 

### DOE proposes to update IESNA LM

- 9

- 1999 to the more recent version IES LM

- 9

- 2009 for fluorescent lamps.

1. Addition of guidance for high

- frequency testing: root mean square (RMS) voltage regulation, instrument frequency response, reference ballast impedance, circuit setup.

2. Modifies lamp stabilization method to require more consecutive measurements be taken until stabilization criterion is met.

3. Addition of lamp stabilization guidance unique to T5 linear fluorescent lamps.

4. Adds impedance thresholds for voltage and current inputs to multimeter and power sources. 

## IES LM

- 9

- 2009 for GSFLs17 | Building Technologies Program eere.energy.gov 

### DOE proposes to update IESNA LM

- 45

- 2000 to the more recent version IES LM

- 45

- 2009 for incandescent lamps.

1. Modifies lamp stabilization method requiring measurements to continue until stability criteria is met.

2. Modifies voltage and current regulation tolerances for AC power

source.

3. Modifies instrument tolerances for AC voltage, current and wattage.

4. Adds impedance thresholds for voltage and current inputs to multimeter.

5. Adds a requirement for the degree of spectral match of the photo

detector measurements to the V(λ) function. 

## IES LM

- 45

- 2009 for GSILs18 | Building Technologies Program eere.energy.gov 

## Issues for Discussion

Issue 3: DOE requests comments on its proposed incorporation of IES LM

- 45

- 2009, and its tentative conclusion that the update would neither significantly affect lamp efficacy values nor impose an undue testing burden. Issue 2: DOE requests comments on its proposed incorporation of IES LM

- 9

- 2009, and its tentative conclusion that the update would neither significantly affect measured lamp efficacy nor increase the testing burden. In particular, DOE requests comments on the impact on lamp efficacy of high

- frequency testing amendments and modifications to the lamp stabilization procedure in IES LM

- 9

- 2009.19 | Building Technologies Program eere.energy.gov 

### Existing IRL test procedure incorporates IESNA LM

- 20

- 1994. 10 CFR part 430, subpart B, Appendix R

• Revised edition of the standard has not been published.

• Not aware of any current best practices or technical developments that necessitate modifications to the IRL test procedure. 

## Test Procedures for IRLs

Issue 4: DOE requests comment on whether any amendments to the IRL test procedure are necessary and welcome any suggestions for amendments.20 | Building Technologies Program eere.energy.gov 

## Test Procedure Agenda

2

4 Background and Legal Authority

Updates to Industry Standards: GSFL, GSIL, IRL 2 1 Overview

3 New GSIL Lifetime Test Procedure21 | Building Technologies Program eere.energy.gov 

### • EISA 2007 amended EPCA by prescribing GSIL minimum rated lifetime requirements to be phased in between January 2012 and January 2014.

• Proposed GSIL Lifetime Test Procedure

**−** Industry standard: IESNA LM

- 49

- 2001, “IESNA Approved Method for Life Testing of Incandescent Filament Lamps.”

o Coincides with rated voltage testing prescribed in the IESNA Lighting Handbook.

o Referenced by Federal Trade Commission in regulations for product labeling.

**−** Definition of “rated lifetime for general service incandescent lamps”: rated lifetime is the length of operating time between first use and failure of 50 percent of the prescribed sample size.

**−** Sample size of 20 lamps. 

## GSIL Lifetime Test Procedure Overview22 | Building Technologies Program eere.energy.gov 

## IESNA LM

- 49

- 2001: Summary

• Prescribes lifetime testing at a rated voltage.

• Requires lamp to be checked for failure at regular intervals and cooled on a daily basis.

• Provides instrument specifications for voltage, current and frequency.

• Specifies test conditions for vibration, temperature and airflow.

• Addresses lamp orientation, spacing, handling, marking of lamps, and lamp holder specifications.23 | Building Technologies Program eere.energy.gov 

### • DOE proposes to disallow use of accelerated lifetime testing

**−** LM

- 49 permits accelerated lifetime testing for non

- halogen GSILS; few

non

- halogen GSILs will meet 2012 energy conservation standards.

**−** Difficult to conduct for halogen lamps due to the tungsten

- halogen regenerative cycle which is designed around certain operating temperatures



### .

**−** Accurate scaling factors will require numerous comparison tests and need to be developed for each lamp design. 

## IESNA LM

- 49

- 2001: Accelerated Lifetime Testing

Accelerated Lifetime Testing

• Operate lamps at overvoltage, increasing operating temperature and shortening lamp lifetime

• Use empirically derived scaling factors to determine full lifetime of lamp24 | Building Technologies Program eere.energy.gov 

### DOE proposes a minimum sample size of 20 lamps.

• Minimum of two lamps per month for seven months of production out of a 12

- month period

• Consistent with statutory definition of lifetime which requires “statistically large group of lamps.” (42 U.S.C. 6291(30)(P))

• Consistent with required sample size of 21 lamps for measuring lamp efficacy. 

## GSIL Lifetime Testing: Sample Size25 | Building Technologies Program eere.energy.gov 

## Issues for Discussion

Issue 5: DOE requests comment on its proposal to adopt IESNA LM

- 49

- 2001 as the standard for GSIL lifetime testing.

Issue 6: DOE requests comments on its proposal to disallow accelerated lifetime testing as part of the GSIL test procedure.

Issue 7: DOE requests comments on its proposal to require a minimum sample size of 20 lamps for GSIL lifetime measurements.26 | Building Technologies Program eere.energy.gov 

## GSIL Certification Requirements

Issue 8: DOE requests comment on its proposal regarding GSIL certification filing requirements. GSIL new model filing requirements are similar to those for GSFLs and IRLs.

• Initial certification report describing the methodology by which it was determined the model meets or exceeds standards submitted prior to or concurrent with distribution of new model.

• Final certification report based on full sampling provisions to be submitted one year following the start of manufacturing of new model.27 | Building Technologies Program eere.energy.gov 

## Issues for Discussion

Issue 9: DOE seeks comment regarding whether the proposed amendments in today’s NOPR would have a significant economic impact on any small entities. In particular, DOE requests comments on its preliminary analysis of initial setup and labor costs for conducting lifetime testing of GSILs.28 | Building Technologies Program eere.energy.gov In all correspondence, include all of the following:

– Test Procedures for General Service Fluorescent Lamps, General Service Incandescent Lamps, and Incandescent Reflector Lamps

– Docket Number: EERE

- 2011

- BT

- TP

- 0012

– Regulatory Identification Number (RIN ): 1904

- AC45

Contact Information: Email : Lamps

- 2011

- TP

- 0012@ee.doe.gov URL : http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/gsfl_gsil_irl _nopr_tp.pdf

Comment period closes: November 28, 2011 midnight EDT Postal Mail : Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program Mailstop EE

- 2J 1000 Independence Avenue, S.W. Washington, DC 20585

- 0121 Courier : Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program 950 L’Enfant Plaza, S.W., 6 th Floor Washington, DC 20024 Telephone: (202) 586

- 2945 

## DOE Seeks Comments on its Proposed Test Procedure29 | Building Technologies Program eere.energy.gov 

## Questions?30 | Building Technologies Program eere.energy.gov 

## BUILDING TECHNOLOGIES PROGRAM

Energy Conservation Standards Framework for General Service Fluorescent Lamps and Incandescent Reflector Lamps Tina Kaarsberg, PhD
Department of Energy Energy Efficiency & Renewable Energy Docket Number: EERE

- 2011

- BT

- STD

- 0006 GSFL

- IRL_2011

- STD

- 0006@ee.doe.gov
October 4, 201131 | Building Technologies Program eere.energy.gov 

## Public Meeting Agenda

2

3

4 Background and Legal Authority

5 Market & Technology; Screening Analyses 2

Product Price Determination; Energy Use 4

5 1 Overview; Scope of Coverage

6 Life

- Cycle Cost and Payback Period Analyses

Shipment Analysis; National Impact Analysis

7 NOPR Analyses 3 Engineering Analysis32 | Building Technologies Program eere.energy.gov 

## Regulatory History

- Standards

Energy Policy and Conservation Act, 1992 Established standards for certain classes of GSFLs and IRLs; authorized DOE to conduct two rulemaking cycles to revise and amend and adopt standards for additional GSFLs, if warranted.

First revision of standards for GSFLs and IRLs

. 2009 Lamps Standards Rule, 74 FR 34080 Set standards for and expanded definition of IRLs to include lamps with a diameter between 2.25 and 2.75 inches, as well as elliptical reflector (ER), bulged reflector (BR), parabolic aluminized reflector (PAR), bulged parabolic aluminized reflector (BPAR), or similar bulb shapes. Exempted certain IRLs. Energy Independence and Security Act of 2007 (EISA 2007)

Second review of GSFL and IRL standards. Determines if coverage should be expanded to other GSFL types. Current Standards Rulemaking33 | Building Technologies Program eere.energy.gov 

## Standards Rulemaking Process

Framework Document NOPR Final Rule

Today Preliminary Analysis

Milestone Date
Framework Document September 14, 2011
Notice of Public Meeting and Availability of the Preliminary Technical Support Document (projected) September 2012

Notice of Proposed Rulemaking (NOPR) (projected) August 2013 Final Rule (projected) April 2014 Compliance Date (projected) April 201734 | Building Technologies Program eere.energy.gov 

## The Energy Policy and Conservation Act (EPCA)

Factor Analysis
1. Economic impact on consumers and manufacturers Life

- cycle cost analysis; Manufacturer impact analysis 2. Lifetime operating cost savings Life

- cycle cost analysis 3. Total projected energy savings National impact analysis

4. Impact on utility and performance Screening analysis; Engineering analysis 5. Impact of any lessening of competition Manufacturer impact analysis

6. Need for national energy conservation National impact analysis

7. Other factors the Secretary considers relevant Environmental assessment; Utility impact analysis; Employment impact analysis 

### EPCA directs DOE to consider seven factors when setting energy conservation standards.35 | Building Technologies Program eere.energy.gov 

## 2012 GSFL Standards

Lamp Type CCT Energy conservation standard (lm/W)

4

- foot Medium B ipin (MBP) ≤4500 K 89 >4500 K and ≤7,000K 88

2

- foot U

- shaped ≤4500 K 84 >4500 K and ≤7,000K 81

8

- foot Single Pin (SP) S limline ≤4500 K 97 >4500 K and ≤7,000K 93 8

- foot Recessed D ouble Contact (RDC) H igh Output (HO) ≤4500 K 92 >4500 K and ≤7,000K 88 4

- foot T5 M iniature BiPin (MiniBP) S tandard O utput (SO) ≤4500 K 86 >4500 K and ≤7,000K 81

4

- foot T5 MiniBP HO ≤4500 K 76 >4500 K and ≤7,000K 72 

### Energy conservation standards set for GSFLs by the 2009 Lamps Rule will become effective July 14, 2012.36 | Building Technologies Program eere.energy.gov 

## 2012 IRL Standards

Lamp Type Diameter (inches) Voltage Energy conservation standard (lm/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

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 

### Energy conservation standards set for IRLs by the 2009 Lamps Rule will become effective July 14, 2012.

Note: P is equal to the rated lamp wattage, in watts.37 | Building Technologies Program eere.energy.gov 

## Scope of Coverage: GSFLs

• Covered GSFL Types

**−** 4

- foot medium bipin (MBP) ( ≥ 25W);

**−** 2

- foot U

- shaped lamps, MBP ( ≥ 25W);

**−** 8

- foot high output (HO) lamps, rapid start (RS) lamp, recessed double contact (RDC) bases;

**−** 8

- foot slimline lamps, instant start (IS) lamp, single pin bases, ( ≥ 52W);

**−** 4

- foot miniature bipin (MiniBP) standard output (SO), ( ≥ 26W);

**−** 4

- foot MiniBP high output (HO), ( ≥ 49W).



### • Additional GSFL Types

**−** 2009 Lamps Rule expanded GSFL coverage to 4

- foot MiniBP lamps.

**−** In this rulemaking DOE is considering the following additional GSFLs:

o Pin

- based compact fluorescent lamps (CFLs)

o Non

- linear fluorescent lamps (e.g., circline)

o Fluorescent lamps with non

- standard lengths (e.g., 2

- ,3

- ,5

- foot)38 | Building Technologies Program eere.energy.gov 

## Scope of Coverage: IRLs

• Covered IRL Types

**−** Reflector type: reflector (R), ER, BR, PAR, BPAR, or similar bulb shapes with an E26 medium screw base;

**−** Rated voltage between 115 and 130 volts;

**−** Diameter that exceeds 2.25 inches;

**−** Rated wattage that is 40 watts or higher;

**−** Not colored or designed for rough or vibration service applications that contains an inner reflective coating on the outer bulb to direct the light.



### • Lamps not subject to EPACT 1992 and July 2012 standards

**−** Lamps rated at 50 watts or less that are ER30, BR30, BR40, or ER40;

**−** Lamps rated at 65 watts that are BR30, BR40, or ER40 lamps; and

**−** Lamps rated at 45 watts or less that are R20.



### • Standards for these lamps are being set in a separate rulemaking.39 | Building Technologies Program eere.energy.gov 

## Issues for Discussion

Item 2: DOE welcomes comment on additional GSFLs and IRLs that should be included for this rulemaking. For suggested additional lamp types, DOE requests market and shipment information as well as potential for efficacy improvements and energy savings.40 | Building Technologies Program eere.energy.gov 

### • In this rulemaking, DOE plans to reevaluate the lumens/watt (lm/w) metric for measuring IRL efficacy.

• DOE is considering application efficacy (AE) as a metric.

**−** AE is a type of directional lumens per watt.

**−** Quantifies lamp effectiveness in terms of lamp delivering light to targeted locations.

**−** Average luminous flux within a desired solid angle per unit power. 

## Application Efficacy IRL Metric

Item 1: DOE welcomes comment on establishing a new directional metric for IRL efficacy standards. AE = Luminous flux/power (lm/w) Solid angle (steradians ) = candelas/watt41 | Building Technologies Program eere.energy.gov 

## Public Meeting Agenda

2

3

4 Background and Legal Authority

5 Market & Technology; Screening Analyses 2

Product Price Determination; Energy Use 4

5 1 Overview; Scope of Coverage

6 Life

- Cycle Cost and Payback Period Analysis

Shipment Analysis; National Impact Analysis

7 NOPR Analyses 3 Engineering Analysis42 | Building Technologies Program eere.energy.gov 

## Purpose of Market and Technology; Screening Analysis

• Market and Technology Assessment

– Determine product classes

– Identify the technology options to improve lamp efficacy



### • Screening Analysis

– Screen out technology options that DOE will not consider in the engineering analysis based on (1) technological feasibility; (2) practicability to manufacture, install, and service; (3) adverse impacts on utility to consumers or availability; and (4) adverse impacts on health or safety.43 | Building Technologies Program eere.energy.gov 

## Issues for Discussion

Item 3: DOE welcomes information on shipments, product

feature and efficiency trends, distribution channels and estimates of market shares for the lamps considered in this rulemaking. For the data to be used to conduct energy savings calculations, please provide appropriate groupings (e.g., by product class and wattage).44 | Building Technologies Program eere.energy.gov 

## Product Classes

• DOE divides covered products into classes by :

– The type of energy used;

– Capacity of the product; or

– Any other performance

- related features that require different standard levels, such as features affecting consumer utility. (42 U.S.C. 6295(q))



### • DOE establishes separate energy conservation standards for each product class.45 | Building Technologies Program eere.energy.gov 

## Product Classes: GSFLs

• GSFL product class factors under consideration

**−** physical constraints of lamps (i.e., lamp shape and length);

**−** lumen package or quantity of light provided by lamp

- ballast system (i.e., standard versus high output); and

**−** correlated color temperature (CCT).



### • GSFL product classes being considered:

Product Class # Lamp Type CCT ≤4500 K CCT >4500 K

4

- foot Medium B ipin (MBP) #1 #2

2

- foot U

- shaped #3 #4

8

- foot Single Pin (SP) S limline #5 #6
8

- foot Recessed D ouble C ontract (RDC) H igh Output (HO) #7 #8

4

- foot T5 M iniature BiPin (MiniBP) S tandard O utput (SO) #9 #10

4

- foot T5 MiniBP HO #11 #1246 | Building Technologies Program eere.energy.gov 

## Issues for Discussion

Item 4: DOE welcomes comment on the 12 product classes it is considering for general service fluorescent lamps. In particular, DOE welcomes comment on maintaining two separate product classes for T5 lamps.47 | Building Technologies Program eere.energy.gov 

## Product Classes: IRLs

• IRL product class factors under consideration

**−** lamp spectrum;

**−** lamp diameter; and

**−** rated voltage.



### • IRL product classes under consideration

Product Class # Diameter (inches) Voltage Standard Spectrum Modified Spectrum

> 2.5 ≥125 V #1 #2 <125 V #3 #4

≤ 2.5 ≥125 V #5 #6 <125 V #7 #848 | Building Technologies Program eere.energy.gov 

## Issues for Discussion

Item 5: DOE welcomes comment on the product classes it is considering for incandescent reflector lamps.49 | Building Technologies Program eere.energy.gov 

## Technology Options: GSFLs

GSFL Technology Options
Highly Emissive Electrode Coatings Glass Coatings

Higher Efficiency Lamp Fill Gas Composition Higher Efficiency Lamp Diameter

Higher Efficiency Phosphors Multi

- Photon Phosphors50 | Building Technologies Program eere.energy.gov 

## Rare

- earth Phosphors Availability and Pricing

• Lamp efficacy can be improved by increasing phosphor UV absorption; increasing its emission of radiation in the visible spectrum; or increasing the thickness of the phosphor layer.

• 2009 Lamps Rule analyzed the rare earth phosphor market in response to manufacturer concerns that GSFL standards would drive up prices of key rare earths phosphors/ cost of lamps; and whether there were sufficient recoverable phosphor sources.

• DOE welcomes comments, new information relating to this issue.

**−** Composition of rare

- earth phosphors being used in lamps;

**−** Estimate of additional rare

- earth phosphors necessary to go to higher standards;

**−** Current/historical prices and availability of rare

- earth phosphors;

**−** Assessment and future predictions on the relationship between lamp costs and prices of rare

- earth phosphors.51 | Building Technologies Program eere.energy.gov 

## Technology Options: IRLs

IRL Technology Options

Higher

- Temperature Operation Higher

- Pressure Tungsten

- Halogen Lamps Microcavity Filaments Non

- Tungsten Regenerative Cycles Novel Filament Materials Infrared Glass Coatings Thinner Filaments Infrared Phosphor Glass Coating
Efficient Filament Coiling Integrally Ballasted Low

- Voltage Lamps Crystallite Filament Coatings Higher

- Efficiency Reflector Coatings Efficient Filament Orientation Trihedral Corner Reflectors Higher

- Efficiency Inert Fill Gas Efficient Filament Placement
Luminescent Gas52 | Building Technologies Program eere.energy.gov 

## Issues for Discussion

Item 7: DOE welcomes comments regarding the technologies that were screened out for the 2009 Lamps Rule, including whether it is still appropriate to screen out these technologies and whether any additional technology options should be screened out for this rule. Item 6: DOE welcomes comments on all of the technology options it is considering for this rule, including any omissions or revisions for the GSFLs and IRLs covered in this rulemaking. DOE also requests information on the feasibility, performance, impacts, and cost of the technology options

— especially those reflecting recent technological developments.53 | Building Technologies Program eere.energy.gov 

## Public Meeting Agenda

2

3

4 Background and Legal Authority

5 Market & Technology; Screening Analyses 2

Product Price Determination; Energy Use 4

5 1 Overview; Scope of Coverage

6 Life

- Cycle Cost and Payback Period Analysis

Shipment Analysis; National Impact Analysis

7 NOPR Analyses 3 Engineering Analysis54 | Building Technologies Program eere.energy.gov 

##  Choose representative product classes and lamp types to be analyzed in the engineering and life

- cycle cost analysis. Choose Representative Product Classes

Define Baseline Models 

## Engineering Analysis: Methodology

Scale to Product Classes Not

Analyzed Develop Efficacy Levels Identify Replacements 

##  Define characteristics of baseline models in each representative product class.



##  Select more efficacious lamps for each baseline lamp or lamp

- and

- ballast system based on design options.



##  Develop efficacy levels (ELs) that range from the baseline to the maximum technology feasible.



##  Scale results to product classes not analyzed.55 | Building Technologies Program eere.energy.gov 

## Representative Product Classes and Baselines: GSFLs

DOE plans to consider the following lamp types with a correlated color temperature less than or equal to 4,500 Kelvin (K) as representative. Choose Representative Product Classes

Define Baseline Models

Scale to Product Classes Not

Analyzed Develop Efficacy Levels Identify Replacements Baseline Lamp Lamp Diameter Nominal Watts Rated Efficacy Initial Light Output W lm/W lm

4

- Foot MBP T8 32 92.3 3,000
8

- Foot SP Slimline T8 59 98.2 5,900
8

- Foot RDC HO T8 86 91.9 7,900
8

- Foot RDC HO T8 86 93.0 8,000
4

- Foot T5 MiniBP SO T5 28 104.3 2,900

4

- Foot T5 MiniBP HO T5 54 92.9 5,00056 | Building Technologies Program eere.energy.gov 

## Issue for Discussion

Item 10: DOE welcomes comments on the baseline lamps it is considering for GSFLs in this rulemaking and whether they are representative of products sold on the market in 2012. In particular, DOE requests comment on whether the baseline lamps under consideration have lower efficacies than their catalog

- rated efficacy values. Additionally, DOE requests comment on whether it is appropriate to analyze only a T8 baseline for GSFL. Item 9: DOE welcomes comments on the product classes that it has selected to analyze as representative for this rulemaking

.57 | Building Technologies Program eere.energy.gov 

## Representative Product Classes and Baselines: IRLs

DOE is considering IRLs with standard

- spectrum, voltage ratings less than 125 volts (V) and diameters greater than 2.5 inches as representative. Choose Representative Product Classes

Define Baseline Models

Scale to Product Classes Not

Analyzed Develop Efficacy Levels Identify Replacements Baseline Lamp Technology Option Efficacy Initial Light Output Lamp Lifetime
**lm/W lm**  **hr**
40W PAR30 Improved HIR 17.0 680 4,000

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

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



### Item 11: DOE welcomes comments on the baseline lamps it is considering for IRLs in this rulemaking and whether they are representative of the products expected to be sold on the market in 2012. In particular, DOE requests comment on the expected lifetime and wattage of IRLs. Note: Halogen Infrared (HIR)58 | Building Technologies Program eere.energy.gov 

### • Select more efficacious lamps for each baseline lamp by considering technology options not eliminated in the screening analysis.

• Consider lamps that (1) emit lumens equal to the lumen output of the baseline lamp, or below by less than 10 percent; and (2) result in energy savings.

• Use database of commercially available GSFLs and IRLs to identify higher

- efficacy replacements. 

## Identify Higher

- Efficacy Replacements

Choose Representative Product Classes

Define Baseline Models

Scale to Product Classes Not

Analyzed Develop Efficacy Levels Identify Replacements59 | Building Technologies Program eere.energy.gov 

### • Develop efficacy levels (ELs) based on three factors: 1) the design options associated with the specific lamps being studied; 2) the ability of lamps across wattages to comply with the EL of a given product class; and 3) the maximum technologically feasible (max tech) efficacy level.



### • DOE is not basing standards on reduced

- wattage due to potentially limited utility of the lamps.

• DOE is using certification reports to determine reported efficacies of the lamps to develop continuous equations. 

## Develop Efficacy Levels

Choose Representative Product Classes

Define Baseline Models

Scale to Product Classes Not

Analyzed Develop Efficacy Levels Identify Replacements60 | Building Technologies Program eere.energy.gov 

## Develop Efficacy Levels: GSFLs

Based on review of commercially available lamps, considering EL1 as the max tech level set by the 2009 Lamps Rule. Choose Representative Product Classes

Define Baseline Models

Scale to Product Classes Not

Analyzed Develop Efficacy Levels Identify Replacements Lamp Type CCT EL1 **lm/W**
4

- Foot MBP ≤ 4,500K 93
8

- Foot SP Slimline ≤ 4,500K 98 8

- Foot RDC HO ≤ 4,500K 95 4

- Foot T5 MiniBP SO ≤ 4,500K 9061 | Building Technologies Program eere.energy.gov 

## Develop Efficacy Levels: IRLs

Choose Representative Product Classes

Scale to Product Classes Not

Analyzed Define Baseline Models

Develop Efficacy Levels Identify Replacements Lamp Type Efficacy Level Equation* Lamp Type EL1

**lm/W** lm/W Standard Spectrum, > 2.5

inches

, < 125V 6.4P 0.27 40W PAR30 19.1

51.7W PAR38 20.3

60W PAR38 21.0 

### Based on review of commercially available lamps, considering establishing EL1 as the max tech level set by the 2009 Lamps Rule.

Note: P = wattage; Parabolic aluminized reflector (PAR); 30, 38 are diameters in 1/8 th inches62 | Building Technologies Program eere.energy.gov 

## Issues for Discussion

Item 13: DOE also welcomes comments on the potential efficacy levels identified and whether higher efficacy levels can be achieved through redesign of commercially available products. In addition, DOE requests comments on whether GSFL efficacy levels should be based on reduced

- wattage lamps. Item 12: DOE welcomes comments on the methodology it is considering to select higher

- efficacy lamp designs. Item 8: DOE welcomes comments on the overall methodology for the engineering analysis.63 | Building Technologies Program eere.energy.gov 

### • Develop scaling factors by comparing the efficacy level of the representative product class to compliance reports for the non

- representative product class.

• Considering using the scaling factors developed in the 2009 Lamps Rule 

## Scaling Products Not Analyzed

Choose Representative Product Classes

Scale to Product Classes Not

Analyzed Define Baseline Models

Develop Efficacy Levels Identify Replacements64 | Building Technologies Program eere.energy.gov 

### • Proposed Scaling Factors for GSFLs

– Reduction factor of 6.5 percent for 2

- foot U

- Shaped lamps from 4

- foot MBP.

– Reduction factors within the range of 1.1 to 6.0 percent for lamps with CCTs above 4,500K from lamps with CCTs below or equal to 4,500K.



### • Proposed Scaling Factors for IRLs

– Reduction factor of 15 percent for modified

- spectrum IRL lamps from standard spectrum.

– Reduction factor of 15.5 percent for small

- diameter lamps from large diameter.

– Increase by 15 percent for lamps operating at greater than or equal to 120V from those operating at less than 120V. 

## Scaling Products Not Analyzed

Choose Representative Product Classes

Scale to Product Classes Not

Analyzed Define Baseline Models

Develop Efficacy Levels Identify Replacements65 | Building Technologies Program eere.energy.gov 

## Issues for Discussion

Item 14: DOE welcomes comments on the methodology to scale to products not directly analyzed and the specific scaling factors it is considering.66 | Building Technologies Program eere.energy.gov 

## Issues for Discussion

Item 15: DOE welcomes comments on proprietary designs it should be aware of for the GSFLs and IRLs that are the subject of this rulemaking.

Item 16: DOE welcomes comments on regulatory burdens or changes that should be considered in the engineering analysis.

Item 17: DOE welcomes comments on other engineering issues that could affect the engineering analysis.67 | Building Technologies Program eere.energy.gov 

## Public Meeting Agenda

2

3

4 Background and Legal Authority

5 Market & Technology; Screening Analyses 2

Product Price Determination; Energy Use 4

5 1 Overview; Scope of Coverage

6 Life

- Cycle Cost and Payback Period Analysis

Shipment Analysis; National Impact Analysis

7 NOPR Analyses 3 Engineering Analysis68 | Building Technologies Program eere.energy.gov 

## Product Price Determination

• Purpose

**−** To determine a relationship between efficacy levels and end

user prices.

• Methodology

**−** Based on discounts applied to blue book prices (published end

- user prices), from distributors, state contracts, and other public sources, calculate low, medium, high range of prices for each lamp.

**−** Use medium price ranges in the life

- cycle cost (LCC) and national impact analysis (NIA); conduct low and high price analyses in LCC.

**−** For lamps where blue book prices are not available, extrapolate from available lamp prices.

**−** Apply sales tax determined from State and local taxes from data provided by the Sales Tax Clearinghouse (data represented weighted averages that included county and city rates).

**−** Conduct a price trends analysis and investigate several methods for forecasting future prices per DOE guidance.69 | Building Technologies Program eere.energy.gov 

## Issues for Discussion

Item 19: DOE welcomes comments on the methodology it is considering for lamp prices and sales tax estimates for this rulemaking. DOE also welcomes comment on the price forecasting methodologies it is considering.70 | Building Technologies Program eere.energy.gov 

### • Purpose

**−** To identify how products are used by consumers, and thereby determine the energy savings potential of energy efficiency improvements.



### • Methodology

**−** Annual energy consumption (kWh) = system input power x annual operating hours

**−** Use various sources to determine annual operating hours for the commercial, residential, and industrial sectors including:

o Lighting Market Characterization (LMC), 2011

o Energy Information Administration (EIA) Commercial Building Energy Consumption Survey (CBECS), 2003

o EIA Residential Energy Consumption Survey (RECS), 2009

o EIA Manufacturing Energy Consumption Survey (MECS), 2006 

## Energy Use Calculation71 | Building Technologies Program eere.energy.gov 

## Issues for Discussion

Item 18: DOE welcomes comments on the methodology it is considering to determine energy use. In particular, DOE requests comments on its approach to calculate operating hours for the covered lamps.72 | Building Technologies Program eere.energy.gov 

## Public Meeting Agenda

2

3

4 Background and Legal Authority

5 Market & Technology; Screening Analyses 2

Product Price Determination; Energy Use 4

5 1 Overview; Scope of Coverage

6 Life

- Cycle Cost and Payback Period Analysis

Shipment Analysis; National Impact Analysis

7 NOPR Analyses 3 Engineering Analysis73 | Building Technologies Program eere.energy.gov 

## Life

- Cycle Cost and Payback Period Analysis

• Purpose

**−** Assess the net LCC and PBP for a consumer due to energy conservation standards under several scenarios/events (e.g. new construction, replacement, renovation).



### • Methodology

**−** LCC equals consumer price plus the cumulative of annual operating costs over the analysis period (baseline lamp lifetime divided by average operating hours) discounted to a particular base year.

**−** Results expressed as LCC difference (baseline minus standard level).

**−** Simple payback (years) is also calculated and reported.

Consumer Life Cycle Cost (Baseline and Standard) LCC impacts (difference between baseline and standard) First Cost (Consumer Price & Installation)
Operating Cost (Sum & discount to present value)74 | Building Technologies Program eere.energy.gov 

### • Total Installed Price (First Cost )

**−** Purchase price: product price, sales tax.

**−** Installation cost: labor rate, time needed to install lamp (minutes).

o Derive average labor times, rates, and costs using the latest “RS Means Electrical Cost Data” and data from the U.S. Bureau of Labor Statistics.



### • Total Operating Cost

**−** Electricity consumption: lamp wattage, operating hours.

**−** Electricity cost: electricity price, projected electricity price trend

.

o Derive average regional prices for 13 geographic areas consisting of nine Census Divisions with four large States, treated separately. (EIA

- 861, 2009)

o Use the EIA’s Annual Energy Outlook (AEO) for projections of future average electricity prices (reference, high, and low scenarios). 

## Life

- Cycle Cost and Payback Period Analysis75 | Building Technologies Program eere.energy.gov 

## Life

- Cycle Cost and Payback Period Analysis

• Use the discount rate to determine the present value operating expenses over the analysis period.

• Derive discount rates from estimates of the interest or “finance cost” to purchase products.

• Finance cost of raising funds to purchase products can be:

**−** Financial cost of any debt incurred to purchase products.

**−** Opportunity cost of any equity used to purchase products.76 | Building Technologies Program eere.energy.gov 

## Issues for Discussion

Item 20: DOE welcomes comments on the approach it is considering to conduct the LCC and PBP analyses.77 | Building Technologies Program eere.energy.gov 

## Public Meeting Agenda

2

3

4 Background and Legal Authority

5 Market & Technology; Screening Analyses 2

Product Price Determination; Energy Use 4

5 1 Overview; Scope of Coverage

6 Life

- Cycle Cost and Payback Period Analysis

Shipment Analysis; National Impact Analysis

7 NOPR Analyses 3 Engineering Analysis78 | Building Technologies Program eere.energy.gov 

### • Shipments Analysis

**−** To estimate lamp shipments and the product mix of the stock over the analysis period in the base cases and standards cases.



### • National Impact Analysis

**−** To estimate the National Energy Savings (NES) from energy conservation standards at different levels over the analysis period (30 years, 2017

2046)

**−** To estimate the national economic impact on the nation, or the Net Present Value (NPV), from energy conservation standards at different levels over the analysis period (30 years, 2017

- 2046). 

## Purpose: Shipments Analysis/National Impact Analysis (NIA)79 | Building Technologies Program eere.energy.gov 

### • Historical Shipments

**−** Use shipments from NEMA and other publicly available sources to estimate historical shipments of each lamp.



### • Installed Stock

**−** Calculate installed stock lamps using historical shipments and average lamp lifetime.



### • Develop shipment forecasts (2017

- 2046)

**−** Apply growth, emerging technologies, and shipment assumptions.

**−** Develop market

- share matrices with the percentage market share of each lamp type taking into account efficacy, power rating, light output, and lifetime of the lamp and lamp

- and

- ballast designs. 

## Shipments Analysis Methodology80 | Building Technologies Program eere.energy.gov 

## NES and NPV Inputs

• National Energy Savings (2017

- 2046) = Annual energy consumption (Base Case

- Standards Case)

**−** Installed Stock

**−** Unit Annual Energy Consumption

**−** Electricity Site

- to

- Source Conversion Factors

o Conversion factors forecast using latest Annual Energy Outlook

**−** Rebound Rate

o Commercial and Industrial sectors: 1 percent , Residential sector: 8.5 percent



### • Net Present Value (2017

- 2046) = Operating cost savings

- Increased total installed costs (present value)

**−** Shipments

**−** Per Unit Installed Cost

**−** Electricity Prices

**−** Discount Rate

– 7 percent and 3 percent real per OMB.81 | Building Technologies Program eere.energy.gov 

## Issues for Discussion

Item 22: DOE requests input on the potential impact of new energy conservation standards on shipments of GSFLs and IRLs. DOE also requests input on any other federal, state, and local programs that currently exist to promote the adoption of

more

- efficient lamps. Item 21: DOE seeks information on historical shipments of GSFLs and IRLs for each product class covered under this rulemaking, as well as industry

- trend data regarding relative growth in each product class.82 | Building Technologies Program eere.energy.gov 

## Issues for Discussion

Item 23: DOE welcomes comment on the data sources it anticipates using to develop inputs for the national impact analysis.

Item 24: DOE welcomes comments on the quantitative and theoretical underpinnings of the rebound effect as well as results from newer studies of the size and sign of the rebound effect for residential, commercial, industrial, and municipal

consumers.83 | Building Technologies Program eere.energy.gov 

## Issues for Discussion

Item 26: DOE welcomes comments on the inputs and methodology to calculate NES and NPV. Item 25: DOE welcomes comments on the NES spreadsheet models it plans to use for estimating national impacts of amended energy conservation standards for GSFLs and IRLs. DOE also welcomes comments on the inputs to the models and the sources used for determining the inputs.84 | Building Technologies Program eere.energy.gov 

## Public Meeting Agenda

2

3

4 Background and Legal Authority

5 Market & Technology; Screening Analyses 2

Product Price Determination; Energy Use 4

5 1 Overview; Scope of Coverage

6 Life

- Cycle Cost and Payback Period Analysis

Shipment Analysis; National Impact Analysis

7 NOPR Analyses 3 Engineering Analysis85 | Building Technologies Program eere.energy.gov 

### • Purpose

– To assess the economic impacts of standards on manufacturers;

– To identify and estimate impacts on manufacturer sub

- groups that may be more severely affected than the industry as a whole; and

– To examine the direct employment impacts, manufacturing capacity, and the cumulative regulatory impact on the manufacturing industry

.



### • Methodology

– Analyze industry cash flow and industry net present value (INPV) through use of the Government Regulatory Impact Model (GRIM); and

– Interview manufacturers to refine inputs to the GRIM, develop sub

group analyses, and address qualitative issues. 

## Manufacturer Impact Analysis (MIA)86 | Building Technologies Program eere.energy.gov Industry profile Develop straw

man GRIM* Develop interview guide Interviews & industry

wide/ subgroup analyses Assess direct employment, manufacturing capacity, and cumulative burden Finalize MIA results for NOPR Phase 2

*** Government Regulatory Impact Model (GRIM)** Phase 3 Phase 1 

## Manufacturer Impact Analysis: Overview87 | Building Technologies Program eere.energy.gov 

## Issues for Discussion

Item 28: DOE welcomes comments on its methodology for assessing the impacts on product manufacturers covered under this rulemaking. DOE also requests information on manufacturing costs.88 | Building Technologies Program eere.energy.gov 

### • Life

- Cycle Cost Subgroup Analysis

**−** Effects on various national consumer subgroups



### • Utility Impact Analysis

**−** Impacts on the generation capacity of utilities



### • Employment Impact Analysis

**−** Indirect impacts on overall national employment



### • Environmental Assessment

**−** Effects of airborne pollutant emission reductions



### • Regulatory Impact Analysis

**−** Impacts of non

- regulatory alternatives 

## Other NOPR Analyses89 | Building Technologies Program eere.energy.gov 

## Issues for Discussion

Item 27: DOE plans to assess the impacts on low

- income households, institutions of religious worship, and institutions serving low

- income consumers, and seeks input regarding which other consumer subgroups it should consider in this rulemaking.

Item 29: DOE welcomes comments on the approach it is considering to assess the impacts of potential standards under this rulemaking on electric utilities.

Item 30: DOE welcomes comments on the approach it is considering to assess national indirect employment impacts as a result of energy conservation standards.90 | Building Technologies Program eere.energy.gov 

## Issues for Discussion

Item 31: DOE seeks input on its plans to use latest version of EIA’s National Energy Modeling System (NEMS

- BT) to conduct the environmental assessment for the products covered by this rulemaking.

Item 32: DOE welcomes comments on the methodology it is considering for the regulatory impact analysis.91 | Building Technologies Program eere.energy.gov 91 Framework Document Preliminary Analysis NOPR Final Rule

National Impact Analysis Energy Use Characterization Market and Technology Assessment

Screening Analysis Engineering Analysis Markups to Determine Equipment Price Life

- Cycle Cost and Payback Period Analysis

Shipments Analysis Preliminary Manufacturer Impact Analysis 

## Next Steps: Preliminary Analysis Rulemaking Stage92 | Building Technologies Program eere.energy.gov 

### • In all correspondence, include all of the following:

– Test Procedures for General Service Fluorescent Lamps, General Service Incandescent Lamps, and Incandescent Reflector Lamps

– Docket Number: EERE

- 2011

- BT

- TP

- 0012

– Regulatory Identification Number (RIN ):1904

- AC45



### • Contact Information
Email : Lamps

- 2011

- TP

- 0012@ee.doe.gov URL : http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/gsfl _gsil_irl_nopr_tp.pdf

Comment period closes: November 28, 2011 midnight EDT Postal Mail : Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program Mailstop EE

- 2J 1000 Independence Avenue, S.W. Washington, DC 20585

- 0121 Courier : Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program 950 L’Enfant Plaza, S.W., 6 th Floor Washington, DC 20024 Telephone: (202) 586

- 2945 

## DOE Seeks Comments on its Test Procedure Proposal93 | Building Technologies Program eere.energy.gov 

### In all correspondence, include all of the following:

– Energy Conservation Standards for General Service Fluorescent Lamps and Incandescent Reflector Lamps

– Docket Number: EERE

- 2011

- BT

- STD

- 0006

– Regulatory Identification Number (RIN ):1904

- AC43



### Contact Information:
Email : GSFL

- IRL_2011

- STD

- 0006@ee.doe.gov URL : h ttp://www1.eere.energy.gov/buildings/appliance_standards/pdfs/gsf l_irl_ecs_framework.pdf

Comment period closes: October 31, 2011, midnight EDT Postal Mail : Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program Mailstop EE

- 2J 1000 Independence Avenue, S.W. Washington, DC 20585

- 0121 Courier : Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program 950 L’Enfant Plaza, S.W., 6 th Floor Washington, DC 20024 Telephone: (202) 586

- 2945 

## DOE Seeks Comments on its Framework Proposal94 | Building Technologies Program eere.energy.gov 

## Questions?