1 | Energy Efficiency and Renewable Energy eere.energy.gov 

## Energy Conservation Standards Framework Documen t for General Service Lamps January 14, 2014 Lucy deButts Department of Energy Building Technologies Program EERE
– 2013
– BT
– STD
– 0051 GSL2013STD0051@ee.doe.gov2 

## Welcome

• Introductions (around the room )
• Role of the Facilitator
• Ground Rules

– Speak one at a time.

– Say your name for the record

– there will be a complete transcript of this meeting.

– Be concise
– share the ‘air

- time’.

– Keep the focus here

– cell phones on silent; limit sidebar conversations.

– Webinar participants turn phone on mute; “raise your hand” to be recognized to speak. 

### • Housekeeping Items
• Agenda Review
• Opening Remarks3 

## Agenda 9:00
– 9:30 AM Welcome, Introductions, Opening Statements, Overview 9:30
– 10:00 AM Scope of Coverage, Test Procedures 10:00
– 10:30 AM Market and Technology Assessment, Screening Analysis 10:30
– 10:45 AM Break 10:45
– 11:15 AM Engineering 11:15
– 11:30 AM Product Price Determination 11:30
– 12:00 PM Energy Use, Life

- Cycle Cost Analysis 12:00
– 12:45 PM Lunch 12:45
– 1:15 PM Shipments, National Impact Analysis 1:15
– 1 :30 PM NOPR Analyses 1:30
– 1:45 PM Questions, Closing Remarks4 

## Listening Via the Webcast

• The Department is broadcasting this meeting live over the Internet.

• DOE is providing the webcast to accommodate stakeholders that are unable to attend the public meeting in person.

• The web broadcast allows stakeholders to listen in and view the slides.

• All stakeholders are encouraged to submit written comments after the public meeting.5 

## Purpose of the Public Meeting

• Present the procedural and analytical approaches to evaluate energy conservation standards for general service lamps.

• Invite comment on the energy conservation standards framework document.

• Discuss next steps in the rulemaking.

• Invite participants to provide summary comments or statements and raise additional issues for discussion.6 

## Issues for Discussion

Issue box numbering corresponds to the list of issues published at the end of the framework document, available at: http://www.regulations.gov/#!docketDetail;D=EERE

- 2013

- BT

STD

- 0051 The deadline for submitting comments is January 23, 2014. Issue Box: DOE welcomes comments, data, and information on all aspects of the material presented in the framework document for general service lamps. 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.7 

## Opening Remarks

Meeting participants are invited to provide opening remarks or statements at this time.8 

## Presentation Overview

1 Overview; Scope of Coverage; Test Procedures
2 Market and Technology; Screening Analysis
3 Engineering Analysis 4 Product Price Determination 5 Energy Use; Life - Cycle Cost Analysis
6 Shipments; National Impact Analysis
7 NOPR Analyses9 

## Overview – Regulatory History

• Amendments to the Energy Policy and Conservation Act of 1975 (EPCA) in the Energy Independence and Security Act of 2007 (EISA) directed DOE to conduct two rulemaking cycles to evaluate standards for general service lamps (GSLs).

• This standards rulemaking constitutes the first cycle. The rulemaking must:

– B e initiated no later than January 1, 2014 and final rule published by January 1, 2017;

– Evaluate existing exemptions for certain incandescent lamps;

– Not limit scope to incandescent technologies;

– Consider phased

- in compliance dates; and

– C onsider a minimum standard of 45 lumens per watt ( lm/W).

• This rulemaking also satisfies requirements for DOE to review existing standards for medium base compact fluorescent lamps (MBCFLs) which are included in the definition of GSL.10 

## Overview – GSL Rulemaking Schedule

Milestone Date Notice of Public Meeting and Availability of Framework Document 9 December 2013 Notice of Public Meeting and Availability of Preliminary Technical Support Document (projected) November 2014 Notice of Proposed Rulemaking (projected) December 2015 Final Rule (projected) December 2016 Compliance Date (projected) December 2019 2015 2018 2014 2016 2017 2019 202011 

## Overview – EPCA Factors 42 U.S.C. 6295(o)(2)(B)(i) directs DOE to consider seven factors when setting energy conservation standards. EPCA Factors DOE Analysis 1. Economic impact on consumers and manufacturers Life

- Cycle Cost Analysis Manufacturer Impact Analysis 2. Lifetime operating cost savings compared to increased cost for the product Life

- Cycle Cost Analysis 3. Total projected energy savings National Impact Analysis 4. Impact on utility or performance Engineering Analysis Screening 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 Emissions Analysis Utility Impact Analysis Employment Impact Analysis12 

## Scope of Coverage

• GSL includes several lamp types by definition: General service lamp includes general service incandescent lamps (GSILs), compact fluorescent lamps (CFLs), general service light

emitting diode (LED) lamps, organic light

- emitting diode (OLED) lamps, and any other lamps that the Secretary determines are used to satisfy lighting applications traditionally served by general service incandescent lamps; however, this definition does not apply to any lighting application or bulb shape excluded from the “general service incandescent lamp” definition or any general service fluorescent lamp or incandescent reflector lamp. 10 CFR 430.213 

## Scope of Coverage – GSILs

General service incandescent lamp means a standard incandescent or halogen type lamp that is intended for general service applications; has a medium screw base; has a lumen range of not less than 310 lumens and not more than 2,600 lumens; and is capable of being operated at a voltage range at least partially within 110 and 130 volts. 10 CFR 430.2 

### • GSILs are included in the definition of GSL and are defined as follows:

• Several incandescent lamp types are exempted from the definition of GSIL such as reflector, rough service, colored, 3

- way incandescent lamps, and lamps of certain shapes.14 

## Scope of Coverage – GSILs

• DOE is directed to evaluate existing exemptions for certain incandescent lamps based, in part, on exempted lamp sales collected from manufacturers.

– In March 2013, DOE reviewed the 2012 sales of rough service, vibration service, 3

- way incandescent, 2,601

- 3,300 lumen, and shatter

- resistant lamps.

– Because DOE concluded these five lamp types have not experienced significant growth, DOE is proposing not to include the lamps in this rulemaking.


### • The Consolidated Appropriations Act, 2012 (Public Law 112

- 74 in part), restricts the use of appropriated funds in connection with several aspects of DOE’s incandescent lamps program. Specifically , Section 315 of the Act curtails any further activity to implement or enforce standards for GSILs. Therefore , DOE will not be including lamps that meet the definition of GSIL in the GSL rulemaking at this time.15 

## Scope of Coverage – CFLs

• Compact fluorescent lamps are included in the definition of GSL.

• Because this term is not currently defined, DOE will propose a definition for CFL.

• CFLs can be self

- ballasted (e.g., medium base CFLs) or externally

- ballasted (e.g., pin base CFLs).

• Current standards apply only to integrally ballasted (i.e., self

ballasted) medium base compact fluorescent lamps, while pin base CFLs are currently not subject to standards.16 

## Scope of Coverage – CFLs

• MBCFLs proposed to be included in the scope of this rulemaking will include all lamps that meet the definition of “medium base compact fluorescent lamp .”

• DOE defines the term “pin

- based” but does not currently have a definition for “pin base CFL” and thus a definition will be proposed

. • DOE is considering including all pin base CFLs that serve general lighting applications, do not meet the definition of GSFL, and are not the lamp types or shapes excluded from the GSIL definition. Issue 2: CFL Definitions DOE welcomes comment on definitions for compact fluorescent lamp and pin base compact fluorescent lamp.17 

## Scope of Coverage – LEDs

• General service LED lamps are included in the definition of GSL.

• Because this term is currently not defined , DOE will propose a definition in this rulemaking.

• DOE is considering including all LEDs that serve general lighting applications and are not the lamp types or shapes excluded from the GSIL definition

. Issue 3 : LED Definitions DOE welcomes comment on a definition for general service LED lamp.18 

## Scope of Coverage – OLEDs

• OLED lamps are included in the definition of GSL.

• DOE is considering excluding OLED lamps from this rulemaking due to the following:

– OLEDs are diffuse light sources made of thin layers of carbon

- based semiconductor material. They are not used currently in general lighting applications due to shape and size

.

– Due to limited commercial availability and the emerging nature of the technology, it is unclear whether efficacy of existing OLEDs can be improved.

Issue 4 : OLED Lamps DOE welcomes comment on the commercial availability of OLED lamps that can serve in general lighting applications, and DOE’s consideration to exclude OLED lamps in this rulemaking.19 

## Scope of Coverage – Additional Lamps

• Pursuant to the GSL definition, DOE has the authority to consider additional lamps that satisfy lighting applications traditionally served by GSILs.

• Definition of GSILs indicates that these lamps are:

– Typically intended for general service applications;

– Have a medium screw base;

– Emit between 310 and 2,600 lumens; and

– Are capable of being operated at a voltage range at least partially within 110 and 130 V.


### • Lamps that meet these four criteria are proposed to be included in the scope of coverage regardless of the technology used to produce light.20 

## Scope of Coverage – Additional Lamps

• DOE is considering including the following additional lamp types not explicitly stated in the definition of GSL:

– Hybrid lamps

– use one lighting technology for primary application and another technology to provide supplemental lighting

• Example: CFL with a halogen capsule that provides illumination during CFL warm - up period

• Example: CFL with an LED that provides nightlight functionality

– Self

- ballasted mercury vapor lamps

– intended for general service applications

• Example: Medium screw base, lumen output between 1,100 and 2,550 lumens, 120 V, and marketed as GSIL replacement21 

## Issues for Comment
Issue 5: Hybrid Lamps DOE welcomes comment on a definition for hybrid lamp.

Issue 7: Lamps Not Included in Scope DOE welcomes comment on any lamps that should not be considered within the scope of this rulemaking. If such a lamp is identified, DOE requests specific information on why the lamp should not be considered and performance characteristics of the lamp. Issue 6 : Additional Lamp Types Included in Scope DOE welcomes comment on additional lamp types that should be considered in the scope of this rulemaking.22 

## Test Procedures

• EPCA sets forth generally applicable criteria and procedures for DOE’s adoption and amendment of test procedures (42 U.S.C. 6293 ).

• DOE is considering developing and amending test procedures as necessary for products included in the definition of GSL. Product Test Procedure Additional Detail GSIL Existing 10 CFR part 430, subpart B, appendix R MBCFL Existing 10 CFR part 430, subpart B, appendix W Pin base CFL To be developed Will be established prior to standards LED lamps In development NOPR; 77 FR 21038 (April 9, 2012) OLED lamps No action No OLED lamps identified Additional lamp types (e.g., hybrid lamps) To be developed Will be established prior to standards

Issue 1 : Test Procedures DOE welcomes comment regarding the adoption of test procedures for additional lamp types, including pin base CFLs, hybrid lamps, and self

- ballasted mercury vapor lamps, covered under this rulemaking.23 

## Presentation Overview

1 Overview; Scope of Coverage; Test Procedures 2 Market and Technology; Screening Analysis 3 Engineering Analysis 4 Product Price Determination 5 Energy Use; Life - Cycle Cost Analysis 6 Shipments; National Impact Analysis
7 NOPR Analyses24 

## Purpose of MTA and Screening Analysis

• Market and Technology Assessment (MTA)

– Determine product classes

– Identify technology options to improve efficacy


### • Screening Analysis

– Screen out technology options that DOE will not consider in the engineering analysis based on:
• Technological feasibility;

• Practicability to manufacture, install, and service;

• Adverse impacts on utility to consumers or availability; and

• Adverse impacts on health or safety.25 

## Issues for Comment

Issue 8: Market Assessment 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 technology, wattage, and/or other relevant performance characteristics).26 

## Product Classes

• DOE divides covered products into classes by:

– The type of energy used;

– Capacity of the product; or

– Other performance

- related features that justify different standard levels, such as features affecting consumer utility

. 

### • DOE establishes separate energy conservation standards for each product class.27 

## Product Classes

• GSL product class factors under consideration:

– Ballast location ( i.e. , self

- ballasted or externally

- ballasted);

– Cover ( i.e., covered or bare); and

– Dimmability

. 

### • GSL product classes being considered:
Ballast Location Dimmability Cover

Self

- ballasted Dimmable Bare Covered Non

- dimmable Bare Covered Externally

- ballasted Dimmable Bare Covered Non

- dimmable Bare Covered28 

## Issues for Comment

Issue 9 : Product Class Divisions DOE welcomes comment on the product class divisions it is considering for general service lamps. In particular, DOE welcomes comment on the impact that ballast location and dimmability have on the efficacy of compact fluorescent lamps and LED lamps. DOE also welcomes comment on the utility offered by self

- ballasted, covered, and dimmable lamps.

Issue 10: Other Class - Setting Factors DOE welcomes comment on any other class

- setting factors that should be considered in the analysis.
Issue 11: Definition of Covered DOE welcomes comment on a definition for the term “covered” that is applicable across technologies.29 

## Technology Options

• The following technology options can improve GSL efficacy:

GSIL

• Higher Temperature Operation
• Microcavity Filaments
• Novel Filament Materials
• Thinner Filaments
• Efficient Filament Coiling
• Crystallite Filament Coatings
• Efficient Filament Orientation
• Higher Efficiency Inert Fill Gas
• Electron Stimulated Luminescence
• Higher Pressure Tungsten

- Halogen

Lamps
• Non

- Tungsten

- Halogen

Regenerative Cycles
• Change in Technology CFL

• Highly Emissive Electrode Coatings
• Higher Efficiency Lamp Fill Gas

Composition
• Higher Efficiency Phosphors
• Glass Coatings
• Multi

- Photon Phosphors
• Cold Spot Optimization
• Improved Ballast Components
• Improved Ballast Circuit Design
• Change In Technology LED

• Improved Package Efficacy

• Efficient Down Converters
• Improved Package Architectures
• Improved Emitter Materials
• Alternative Substrate Materials
• Increased Thermal Management

• Improved Thermal Interface

Material
• Optimized Heat Sink Design
• Active Thermal Management

Systems
• Improved Optics

• Device Level Optics
• Increased Light Utilization
• Improved Driver Design
• Other

• Reduced Current Density
• AC LEDs30 

## Issues for Comment
Issue 12: Technology Options DOE welcomes comments on the preliminary technology options it is considering for this rule and whether there are additional technology options that should be considered. DOE also requests information on the feasibility, performance, impacts, and cost of the technology options. Issue 13: Screening of Identified Technology Options DOE welcomes comments on the applicability of the four screening criteria to the technology options listed. Issue 14: Screening of Additional Technology Options DOE welcomes comments on how the four screening criteria might apply to any additional technology option(s) that an interested party recommends to DOE.31 

## Presentation Overview

1 Overview; Scope of Coverage; Test Procedures 2 Market and Technology; Screening Analysis 3 Engineering Analysis 4 Product Price Determination 5 Energy Use; Life - Cycle Cost Analysis 6 Shipments; National Impact Analysis
7 NOPR Analyses32 

##  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 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.33 

## Representative Product Classes

• DOE chooses representative product classes to concentrate its analytical effort.

• DOE selects representative product classes primarily because of their high market volumes

. • Based on preliminary research of catalogs and market reports DOE has found that:

– Self

- ballasted products are more common than externally

ballasted products

– Dimmable products are more common than non

- dimmable for most products

– Bare lamps are more common than covered lamps Choose Representative Product Classes

Define Baseline Models

Scale to Product Classes Not

Analyzed Develop Efficacy Levels Identify Replacements34 

## Issues for Comment
Issue 16: Representative Product Classes DOE welcomes comments on the identification and selection of product classes with the highest shipment volume to be analyzed as representative for this rulemaking. In particular, DOE requests shipment information for lamps included in the scope of this rulemaking broken down by ballast location, cover, dimmability , and any other features deemed relevant by interested parties. Issue 17: Shipment Information DOE welcomes comment on whether the characteristics of products with the highest shipment volume change depending on lamp technology.35 

## Baseline Lamps

• DOE selects baseline lamps in each representative product class.

• For products that do not have existing standards, DOE selects the most common, least efficacious lamp sold.

• For products that have existing standards, DOE typically selects the most common, least efficacious lamps that just meet existing energy conservation standards.

– Products with existing standards include GSILs and MBCFLs. Issue 18: Baselines DOE welcomes comments on its proposed approach for selecting baseline lamps in this rulemaking. Choose Representative Product Classes

Define Baseline Models

Scale to Product Classes Not

Analyzed Develop Efficacy Levels Identify Replacements36 

## Higher - Efficacy Replacements

• DOE selects more efficacious lamps for each baseline lamp by considering technologies not eliminated in the screening analysis.

• DOE plans to account for lumen output because consumers take lumen package into consideration when purchasing lamps.

– Lamps that emit lumens equal to the lumen output of the baseline or within 10 percent


### • DOE plans to utilize a database of commercially available lamps. Issue 19: Higher - Efficacy Replacements DOE welcomes comments on the methodology it is considering to select higher

- efficacy lamp designs. Choose Representative Product Classes

Define Baseline Models

Scale to Product Classes Not

Analyzed Develop Efficacy Levels Identify Replacements37 

## Efficacy Levels

• DOE plans to develop efficacy levels (ELs) based on three factors:

– D esign options associated with the specific lamps being studied;

– A bility of lamps across wattages to comply with the EL of a given product class; and

– M aximum technologically feasible (max tech) efficacy level.


### • DOE plans to use catalog data on commercially available lamps to develop continuous equations that represent the potential efficacy achieved by a design option across all wattages.

• DOE will consider data submitted to DOE by manufacturers for compliance with existing standards as well as verification testing. Choose Representative Product Classes

Define Baseline Models

Scale to Product Classes Not

Analyzed Develop Efficacy Levels Identify Replacements38 

## Issues for Comment
Issue 20: Efficacy Levels DOE welcomes comments on its proposed methodology of establishing efficacy levels. In particular, DOE requests comments on the appropriateness of using an equation

- based approach to reflect the relationship between efficacy and wattage for all covered lamp technologies.
Issue 21: Compliance and Verification Data DOE welcomes comment on the use of compliance data and verification testing data when establishing efficacy levels.39 

## Scaling to Products Not Analyzed

• Standards for non

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

• DOE plans to develop scaling factors by comparing the efficacy level of representative product classes to efficacies of commercially available lamps from non

- representative product classes. Issue 22: Scaling DOE welcomes comments on the methodology to scale to products not directly analyzed. Choose Representative Product Classes

Define Baseline Models

Scale to Product Classes Not

Analyzed Develop Efficacy Levels Identify Replacements40 

## Issues for Comment

Issue 23: Proprietary Designs DOE welcomes comments on proprietary designs it should be aware of for the GSLs that are the subject of this rulemaking. Issue 24: Regulatory Burdens DOE welcomes comments on regulatory burdens or changes that should be considered in the engineering analysis. Issue 25: Other Engineering Issues DOE welcomes comments on other issues that could affect the engineering analysis. Issue 15: Engineering Methodology DOE welcomes comments on the overall methodology for the engineering analysis.41 

## Presentation Overview

1 Overview; Scope of Coverage; Test Procedures 2 Market and Technology; Screening Analysis 3 Engineering Analysis 4 Product Price Determination 5 Energy Use; Life - Cycle Cost Analysis 6 Shipments; National Impact Analysis
7 NOPR Analyses42 

## Product Price Determination

• The purpose of the engineering analysis and product price determination together is to provide an analysis of the relationship between efficacy and end

- user price.

• Proposed methodology:

– Obtain manufacturers’ blue books (end

- user price schedules).

– Determine range of discounts applied to blue book prices for distribution channels such as State procurement contracts, large electrical supply distributors, home improvement/hardware stores, and other sources of publicly available end

- user prices such as internet retailers.

– Derive low, medium, and high lamp prices for GSLs.

– E xtrapolate from available lamp prices for lamps where blue book prices are not available.43 

## Issues for Comment Issue 27: Pricing Methodology DOE welcomes comments on the methodology it is considering for lamp prices for this rulemaking.

Issue 28: Distribution Channels DOE welcomes comment on the distribution channels utilized for the lamp technologies covered in this rulemaking and if the channels vary by technology. In particular, DOE requests comment on the appropriateness of the potential distribution channels identified, specifically State procurement contracts, large electrical supply distributors, home

- improvement/hardware stores, and internet retailers.

Issue 29: Blue Books DOE welcomes comment on the availability of blue books or price schedules for the lamp technologies covered in this rulemaking, particularly LED lamps.44 

## Presentation Overview

1 Overview; Scope of Coverage; Test Procedures 2 Market and Technology; Screening Analysis 3 Engineering Analysis 4 Product Price Determination 5 Energy Use; Life - Cycle Cost Analysis 6 Shipments; National Impact Analysis
7 NOPR Analyses45 

## Energy Use

• Purpose:

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


### • Proposed Methodology:

– Annual energy consumption ( kilowatt hour) = system input power x annual operating hours

– DOE is planning to develop a distribution of operating hours.

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

• DOE Residential Energy End

- Use Studies

– Residential Lighting End

- Use Consumption Study, 2012

– 2010 Lighting Market Characterization (LMC), 2012

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

• EIA Residential Energy Consumption Survey (RECS), 200946 

## Issues for Comment
Issue 26: Energy Use 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.47 

## Life - Cycle Cost and Payback Period Analysis

• Purpose:

– Assess life

- cycle cost (LCC) impacts of different efficiency levels on the consumer. The LCC reflects the total cost of a product over its lifetime.

– Assess the Payback Period (PBP), which is the amount of time required for energy cost savings to pay back any increased cost of a higher

efficiency product

. 

### • Proposed Methodology:

– Economic evaluation from the consumer perspective.

– LCC equals consumer price plus the sum of annual operating costs (including repair and maintenance costs) discounted to a particular base year.

– Results expressed as LCC difference ( baseline minus higher efficiency level ).

– DOE is considering using an annualized LCC to account for large differences in lamp lifetimes.48 

## Life - Cycle Cost and Payback Period Analysis

• Approach:

– Model uncertainty and variability in the inputs using a Monte Carlo simulation method that samples probability distributions

. 

### • Inputs:

– Installation Costs

• DOE assumes residential installation costs are zero.

• DOE assumes commercial installation costs = labor rate x time to install lamp.

– Energy Prices

• DOE will consider using the latest version of EIA’s Annual Energy Outlook ( AEO ) to estimate future electricity prices.

– Maintenance & Repair Costs

• DOE assumes that maintenance and repair costs are not applicable for GSLs.

• DOE may consider different lighting system maintenance costs associated with specific lamps types (e.g., maintenance of external ballast).49 

## Life - Cycle Cost and Payback Period Analysis

– Product Lifetime

• Age in hours of operation when a lamp is retired from service.

• DOE plans to determine lifetime using published manufacturer literature

.

– Disposal Cost

• When a GSL fails, some consumers may recycle the lamp. The cost of recycling is the disposal cost. DOE will estimate disposal cost based on public sources.

– Analysis Period

• DOE is considering determining life

- cycle cost over the lifetime of the product and then annualizing because of the very different lifetimes of lamps included in this rulemaking.

– Discount Rates

• DOE will derive the discount rates for users of GSLs by estimating the interest or financial cost to purchase products.50 

## Issues for Comment
Issue 31: LCC and PBP DOE welcomes comments on the approach it is considering to conduct the LCC and PBP analyses.51 

## Presentation Overview

1 Overview; Scope of Coverage; Test Procedures 2 Market and Technology; Screening Analysis 3 Engineering Analysis 4 Product Price Determination 5 Energy Use; Life - Cycle Cost Analysis 6 Shipments; National Impact Analysis
7 NOPR Analyses52 

### • Purpose:

– Project future shipments by product class to calculate national impacts of adopting an energy efficiency standard.


### • Proposed Methodology:

– DOE typically projects shipments over a 30

- year period beginning on the expected compliance date of the standard.

– DOE will also conduct a price trends analysis and investigate several methods for forecasting future prices per DOE guidance.


### • Approach:

– DOE plans to use an economic model to project shipments in the standards case, as compared to the base case.
• Based on observed and projected technology price trends and adoption rates.
• Will account for the shift to LED technology that is expected to occur even in the absence of new standards. 

## Shipments Analysis53 

### • Inputs:

– Energy price forecasts from EIA’s AEO.

– Forecast of building stock growth from AEO
.

– Lamp lifetimes from upstream analyses.

– Lamp prices and operating and maintenance (O&M) costs from the LCC.

– Hours

- of

- use distribution from the LCC.

– Historical shipments data and price trends from the Census Bureau, published literature, and stakeholder input

.

– Current rate of lighting controls adoption (e.g., dimmers) from DOE’s 2010 Lighting Market Characterization, and forecasts from published literature. 

## Shipments Analysis54 

## Issues for Comment
Issue 30: Price Forecasting DOE also welcomes comment on price forecasting methodologies for GSLs.
Issue 32: Historical Shipments DOE seeks information on historical shipments of GSLs for each product class covered under this rulemaking, as well as industry

- trend data regarding relative growth in each product class.
Issue 33: Shipments DOE requests input on the potential impact of new energy conservation standards on shipments of GSLs. DOE also requests input on any other federal programs that currently exist to promote the adoption of more

- efficient lamps.55 

### • Purpose:

– Determine the projected national energy savings (NES) and consumer national net present value (NPV ) associated with potential energy conservation standards.


### • Proposed Methodology:

– Develop annual series of national energy and economic impacts.

– Utilize the shipments model to estimate stock each year.

– Utilize the LCC to develop inputs for total installed cost and energy use per unit in any year.

– Aggregate the costs and energy use for all years in the analysis period.

– Report NES in terms of site, primary, and full

- fuel

- cycle (FFC) savings.

– Report change in national consumer NPV (in constant
- year dollars ).

– Account for the time

- value of money though defined discount rates of 3% and 7%. 

## National Impacts Analysis56 

### • Inputs:

– Projected lamp shipments from the Shipments Analysis.

– Energy price forecasts from EIA’s AEO.

– Lamp prices and O&M costs from the LCC.

– Annual lamp energy use from the Energy Use Analysis.

– Current rate of lighting controls adoption (e.g., dimmers) from DOE’s 2010 Lighting Market Characterization, and forecasts from published literature.

– Site

- to
- source and FFC conversion factors from the National Energy Modeling System (NEMS). 

## National Impacts Analysis57 

## Issues for Comment
Issue 34: NIA Model DOE welcomes comments on the NES spreadsheet models it plans to use for estimating national impacts of amended energy conservation standards for GSLs. DOE also welcomes comments on the inputs to the models and the sources used for determining the inputs.

Issue 35: NES and NPV Calculations DOE welcomes comments on the inputs and methodology to calculate NES and NPV.58 

## Presentation Overview

1 Overview; Scope of Coverage; Test Procedures 2 Market and Technology; Screening Analysis 3 Engineering Analysis 4 Product Price Determination 5 Energy Use; Life - Cycle Cost Analysis 6 Shipments; National Impact Analysis
7 NOPR Analyses59 

## Manufacturer Impact Analysis

• Purpose of the manufacturer impact analysis (MIA) is to:

– Assess the impacts of standards on manufacturers;

– Identify and estimate impacts on manufacturer sub

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

– Examine the direct employment impacts, manufacturing capacity, and cumulative regulatory impact on the manufacturing industry.


### • Proposed 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.60 

## MIA Methodology The MIA consists of three main phases:

Industry profile Develop strawman GRIM Develop interview guide Interviews & industry wide / subgroup analyses Assess direct employment, competition, cumulative burden Phase 2 Phase 3

Initial MIA Interviews Phase 1 Preliminary Analysis NOPR61 

## Issues for Comment
Issue 37: Manufacturer Subgroups DOE seeks comments on the subgroups of the GSL manufacturers that it should consider in a manufacturer subgroup analysis.

Issue 38: Small Businesses DOE seeks comment on small businesses that could be impacted by energy conservation standards for GSLs, and what those impacts might entail.62 

## Other NOPR Analyses

• Life

- Cycle Cost Subgroup Analysis

– Effects on various national consumer subgroups


### • Utility Impact Analysis

– Effects on generation capacity of utilities


### • Employment Impact Analysis

– Indirect impacts on overall national employment


### • Emissions Analysis

– Effects on airborne pollutant emissions


### • Monetizing Carbon Dioxide and O ther Emissions Reductions

– Monetary benefits from emissions reductions


### • Regulatory Impact Analysis

– Potential for non

- regulatory alternatives63 

## Issues for Comment
Issue 36: LCC Subgroups DOE seeks input regarding which consumer subgroups it should consider in this rulemaking. Issue 39: Utility Impact Analysis DOE welcomes comments on the approach it is considering to assess the impacts of potential standards under this rulemaking on electric utilities. Issue 40: Employment Impact Analysis DOE welcomes comments on the approach it is considering to assess employment impacts as a result of energy conservation standards. Issue 41: Emissions Analysis DOE seeks input on the approach it plans to use to conduct the emissions analysis for the products covered by this rulemaking.64 

## Issues for Comment
Issue 42: Monetizing Emissions Reductions DOE requests comments on the approach it plans to use for estimating monetary benefits associated with emissions reductions. Issue 43: Regulatory Impact Analysis DOE welcomes comments on the methodology it is considering for the regulatory impact analysis.65 

## How to Submit Written Comments

• In all correspondence, please refer to the GSL rulemaking by:

– Energy Conservation Standards for General Service Lamps;

– Docket Number EERE

- 2013

- BT

- STD

- 0051 ; and

– Regulatory Identification Number (RIN) 1904

- AD09.

• Email : GSL2013STD0051@ee.doe.gov
Postal : Courier : Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program, Mailstop EE

- 2J 1000 Independence Avenue, SW Washington, DC 20585

- 0121 Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program, Suite 600 950 L’Enfant Plaza, SW Washington, DC 20024 Tel: 202

- 586

- 2945 Comment Period closes : January 23, 2014, 11:59 PM EDT66 

## Closing Remarks/Questions