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

Energy Conservation Standards

Framework Document for

General Service Lamps

January 14, 2014

Lucy deButts

Department of Energy

Building Technologies Program

EERE–2013–BT–STD–0051

GSL2013STD0051@ee.doe.gov
2

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 Remarks
3

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 Remarks
4

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-BTSTD-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 Analyses
9

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:

– Be 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

– Consider 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

2014 2015 2016 2017 2018 2019 2020
11

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 Analysis
12

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 lightemitting 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 430.2
13

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., selfballasted) 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 replacement
21

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 Analyses
24

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

Covered
28

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 LEDs
30

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 Analyses
32

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 externallyballasted 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 

Replacements
34

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 

Replacements
36

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 

Replacements
37

Efficacy Levels

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

three factors: 

– Design options associated with the specific lamps being studied; 

– Ability of lamps across wattages to comply with the EL of a given 

product class; and 

– Maximum 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 

Replacements
38

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 

Replacements
40

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 Analyses
42

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.

– Extrapolate 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 Analyses
45

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), 2009
46

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 higherefficiency 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 Analyses
52

• 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 Analysis
53

• 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 Analysis
54

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 Analysis
56

• 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 Analysis
57

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 Analyses
59

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 subgroup analyses, and address qualitative issues.
60

MIA Methodology

The MIA consists of three main phases: 

Industry 

profile

Develop 

strawman 

GRIM

Develop 

interview 

guide

Interviews

& 

industrywide / 

subgroup

analyses

Assess direct 

employment, 

competition, 

cumulative 

burden

Phase 2 Phase 3

Initial MIA 

Interviews

Phase 1

Preliminary 

Analysis

NOPR
61

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 Other Emissions Reductions

– Monetary benefits from emissions reductions

• Regulatory Impact Analysis

– Potential for non-regulatory alternatives
63

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 EDT
66

Closing Remarks/Questions