Energy Conservation Standards 

Rulemaking Framework Document for 

General Service Lamps

RIN: 1904-AD09

U.S. Department of Energy

Office of Energy Efficiency and Renewable Energy 

Building Technologies Program

December 2, 2013
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TABLE OF CONTENTS

1. INTRODUCTION................................................................................................................... 1

1.1 Authority and Background............................................................................................... 1

2. OVERVIEW OF RULEMAKING PROCESS........................................................................ 3

2.1 Rulemaking Process and Stakeholder Participation......................................................... 3

2.2 Test Procedures................................................................................................................ 4

2.3 Preliminary Analyses and Notice of Public Meeting....................................................... 6

2.4 Notice of Proposed Rulemaking ...................................................................................... 7

2.5 Final Rule ......................................................................................................................... 8

2.6 Overview of Analyses for Rulemaking............................................................................ 8

3. SCOPE OF COVERAGE........................................................................................................ 9

3.1 General Service Incandescent Lamps ............................................................................ 10

3.2 Compact Fluorescent Lamps.......................................................................................... 11

3.3 General Service LED and OLED Lamps....................................................................... 13

3.4 Additional Lamps........................................................................................................... 14

4. MARKET AND TECHNOLOGY ASSESSMENT.............................................................. 15

4.1 Market Assessment Overview........................................................................................ 15

4.2 Product Classes .............................................................................................................. 16

4.3 Technology Assessment................................................................................................. 17

5. SCREENING ANALYSIS.................................................................................................... 20

6. ENGINEERING ANALYSIS ............................................................................................... 21

6.1 Overview ........................................................................................................................ 21

6.2 Representative Product Classes...................................................................................... 21

6.3 Baseline Lamps.............................................................................................................. 22

6.4 Identify Higher-Efficacy Lamp Replacements .............................................................. 23

6.5 Efficacy Levels............................................................................................................... 24

6.6 Scaling to Product Classes Not Analyzed...................................................................... 24

6.7 Proprietary Designs........................................................................................................ 25

6.8 Outside Regulatory Changes Affecting the Engineering Analysis................................ 25

7. ENERGY USE CHARACTERIZATION............................................................................. 26

8. PRODUCT PRICE DETERMINATION .............................................................................. 26

9. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS ........................................... 27

10. SHIPMENTS ANALYSIS .................................................................................................... 29

10.1 Base Case Forecast and Accounting Methodology........................................................ 29

10.2 Impacts of Standards on Shipments............................................................................... 29

11. NATIONAL IMPACT ANALYSIS...................................................................................... 29

11.1 Calculation of National Energy Savings........................................................................ 30

11.2 Net Present Value........................................................................................................... 30

12. LIFE-CYCLE COST SUBGROUP ANALYSIS.................................................................. 31

13. MANUFACTURER IMPACT ANALYSIS ......................................................................... 31

13.1 Sources of Information................................................................................................... 31

13.2 Industry Cash Flow Analysis ......................................................................................... 32

13.3 Manufacturer Subgroup Analysis................................................................................... 32

14. UTILITY IMPACT ANALYSIS........................................................................................... 33

15. EMPLOYMENT IMPACT ANALYSIS............................................................................... 33
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16. EMISSIONS ANALYSIS ..................................................................................................... 34

17. MONETIZING CARBON DIOXIDE AND OTHER EMISSIONS REDUCTIONS .......... 36

18. REGULATORY IMPACT ANALYSIS ............................................................................... 37

APPENDIX A – LIST OF ITEMS FOR COMMENT................................................................. 38

LIST OF TABLES

Table 2.1.1 Preliminary Rulemaking Schedule for GSL Energy Conservation Standards ............ 4

Table 4.2.1. Product Classes under Consideration for GSLs........................................................ 17

Table 4.3.1 GSL Technology Options.......................................................................................... 18

Table 6.3.1 Standards for Standard Spectrum General Service Incandescent Lamps.................. 22

Table 6.3.2 Standards for Modified Spectrum General Service Incandescent Lamps ................. 22

Table 6.3.3 Standards for Medium Base Compact Fluorescent Lamps........................................ 23

LIST OF FIGURES

Figure 2.6.1 Flow Diagram of Analyses for the GSL Standards Rulemaking Process .................. 9
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LIST OF ABBREVIATIONS

AEO Annual Energy Outlook (Annual energy forecast published by EIA)

CAIR Clean Air Interstate Rule 

CBECS Commercial Buildings Energy Consumption Survey by EIA

CCT correlated color temperature 

CFR Code of Federal Regulations 

CFL compact fluorescent lamp 

CO2 carbon dioxide

CRI color rendering index

CSAPR Cross-State Air Pollution Rule (replaces CAIR)

CSL candidate standard level (energy-efficiency level)

D.C. District of Columbia

D.C. Circuit District of Columbia Circuit

DOE U.S. Department of Energy 

DOJ U.S. Department of Justice

EGU electricity generating unit

EIA Energy Information Administration (statistical and analytical agency within DOE)

EISA Energy Independence and Security Act of 2007 

EL efficacy level

EPAct 2005 Energy Policy Act of 2005 

EPCA Energy Policy and Conservation Act of 1975

FFC full-fuel-cycle

FR Federal Register 

GHG greenhouse gas

GREET Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation

GRIM Government Regulatory Impact Model

GSFL general service fluorescent lamp

GSL general service lamp

GSIL general service incandescent lamp

HAP hazardous air pollutants

Hg mercury 

ImSET Impact of Sector Energy Technologies

IRL incandescent reflector lamp

K degrees Kelvin (an absolute temperature scale equal to –273.15 oC)

LCC life-cycle cost 

LED light emitting diode

lm lumen

LMC U.S. Lighting Market Characterization

Max tech maximum technologically feasible CSL

MBCFL medium base compact fluorescent lamp

MECS Manufacturer Energy Consumption Survey (performed for EIA by the Census 

Bureau)

MIA Manufacturer Impact Analysis 

NEMS National Energy Modeling System (developed and used by EIA)

NEMS-BT National Energy Modeling System – Building Technologies 
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NES national energy savings 

NIA National Impact Analysis 

NOPR notice of proposed rulemaking 

NOX nitrogen oxides 

NPV net present value 

OIRA Office of Information and Regulatory Affairs

OLED organic light emitting diode

OMB U.S. Office of Management and Budget

PBP payback period 

PM particulate matter

RECS Residential Energy Consumption Survey by EIA 

RIA regulatory impact analysis 

SCC Social Cost of Carbon

SO2 sulfur dioxide 

TIM thermal interface material

TSD technical support document 

TSL trial standard level

U.S.C. United States Code 

V volts 

W watts
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RULEMAKING FRAMEWORK DOCUMENT FOR GENERAL SERVICE LAMPS

1. INTRODUCTION

The U.S. Department of Energy (DOE) develops and promulgates test procedures and 

energy conservation standards for certain consumer appliances and commercial equipment. The 

process for developing standards involves analysis, public notice and comment, and consultation 

with interested parties. Interested parties, also referred to as stakeholders, include manufacturers, 

consumers, energy conservation and environmental advocates, State and Federal agencies, and 

any other groups or individuals with an interest in these standards and test procedures.

The purpose of this document is to describe the procedural and analytical approaches the 

DOE anticipates using to evaluate energy conservation standards for general service lamps 

(GSLs). It is intended to inform interested parties and to encourage and facilitate their input 

during the rulemaking. This document is the starting point for developing standards and not a 

definitive statement with respect to any issue to be determined in the rulemaking.

Sections 1 and 2 discuss the rulemaking process. Sections 3 through 18 outline the 

analyses DOE intends to conduct to fulfill the statutory requirements and guidance for this 

standards rulemaking. Information regarding this rulemaking will be maintained on the DOE 

website at: 

http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx?ruleid=83.

While DOE invites stakeholder comment on all aspects of the material presented in this 

document, specific issues on which DOE seeks comment are highlighted by comment boxes. 

These comment boxes include questions on the approaches DOE is proposing for the analyses 

required for the rulemaking. The text in the boxes is assembled in Appendix A.

1.1 Authority and Background

Title III of Energy Policy and Conservation Act of 1975 (EPCA) (42 U.S.C. 6291 et seq.) 

sets forth a variety of provisions designed to improve energy efficiency. Part B of Title III (42 

U.S.C. 6291-6309) established the “Energy Conservation Program for Consumer Products Other 

Than Automobiles,” which includes major household appliances.1Subsequent amendments 

expanded Title III of EPCA to include additional consumer products and certain commercial and 

industrial equipment, including GSLs—the products that are the focus of this document. In 

particular, amendments to EPCA in the Energy Independence and Security Act of 2007 (EISA)

directed DOE to conduct two rulemaking cycles to evaluate energy conservation standards for

GSLs. (42 U.S.C. 6295(i)(6)(A)-(B))

For the first rulemaking cycle, EPCA, as amended by EISA, directs DOE to initiate a 

rulemaking no later than January 1, 2014 to evaluate standards for GSLs and determine whether 

exemptions for certain incandescent lamps should be maintained or discontinued. (42 U.S.C. 

6295(i)(6)(A)(i)) The scope of the rulemaking is not limited to incandescent lamp technologies. 

 

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Part B was re-designated Part A on codification in the U.S. Code for editorial reasons. 
2

(42 U.S.C. 6295(i)(6)(A)(ii)) The EISA amendments to EPCA further require that if standards 

are to be established for GSLs, a final rule must be published by January 1, 2017 with a

compliance date at least 3 years after the date on which the final rule is published. (42 U.S.C. 

6295(i)(6)(A)(iii)) Additionally, the requirements direct DOE to consider phased-in compliance

dates based on the impact of amending standards on manufacturers, retiring and repurposing 

existing equipment, stranded investments, labor contracts, workers, raw materials, and time 

needed to revise sales and marketing strategies. (42 U.S.C. 6295(i)(6)(A)(iv)) 

Further, for this first cycle of rulemaking, the EISA amendments provide that DOE must 

consider a minimum standard of 45 lumens per watt (lm/W). (42 U.S.C. 6295(i)(6)(A)(ii)) If 

DOE fails to meet the requirements of 42 U.S.C. 6295(i)(6)(A)(i)-(iv) or the final rule from the 

first rulemaking cycle does not produce savings greater than or equal to the savings from a 

minimum efficacy standard of 45 lm/W, sales of GSLs that do not meet the minimum 45 lm/W

standard beginning on January 1, 2020 will be prohibited. (42 U.S.C. 6295(i)(6)(A)(v))

Additionally, state preemption requirements are specified for California and Nevada. Namely, 

beginning January 1, 2018, no provision of law could preclude these states from adopting: (1) a 

final rule adopted in accordance with 42 U.S.C. 6295(i)(6)(A)(i)-(iv); (2) the minimum efficacy 

standard of the backstop requirement (45 lm/W) if no final rule was adopted; or (3) for the state 

of California, any California regulations related to the covered products adopted pursuant to 

State statue in effect as of the date of enactment of EISA. 42 U.S.C. 6295(i)(6)(A)(vi)

The EISA-prescribed amendments direct DOE to initiate a second rulemaking cycle by 

January 1, 2020 to determine whether standards in effect for general service incandescent lamps 

(GSILs) should be amended with more stringent requirements and if the exemptions for certain 

incandescent lamps should be maintained or discontinued. (42 U.S.C. 6295(i)(6)(B)(i)) For this 

second review of energy conservation standards, the scope is not limited to incandescent lamp 

technologies. (42 U.S.C. 6295(i)(6)(B)(ii)) The EISA amendments require that if standards are to 

be amended for GSILs, a final rule must be published by January 1, 2022 with a compliance date 

at least 3 years after the date on which the final rule is published. (42 U.S.C. 6295(i)(6)(B)(iii))

These amendments also direct DOE to consider phased-in effective dates for the second round of 

review based on the impact of amending standards on manufacturers, retiring and repurposing 

existing equipment, stranded investments, labor contracts, workers, raw materials, and time 

needed to revise sales and marketing strategies. (42 U.S.C. 6295(i)(6)(B)(iv))

Additionally, this rulemaking satisfies the requirements under 42 U.S.C 6295(m)(1) for 

DOE to review the existing standards for medium base compact fluorescent lamps (MBCFLs), as 

compact fluorescent lamps are included in the definition of GSL. The Energy Policy Act of 2005 

(EPAct 2005) amended EPCA by establishing energy conservation standards for MBCFLs.

Under 42 U.S.C 6295(m)(1), within 6 years after issuance of any final rule establishing or 

amending a standard, DOE is required to publish a notice determining whether to amend such 

standards. If DOE determines that amendment is warranted, DOE must also issue a notice of 

proposed rulemaking including new proposed energy conservation standards by that same date. 

(42 U.S.C. 6295(m)(l)).
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This framework document and the associated public meeting represent the first step in the 

process to consider whether to amend energy conservation standards for GSLs as well as to 

fulfill the EPCA requirement to review standards for MBCFLs.

2. OVERVIEW OF RULEMAKING PROCESS

2.1 Rulemaking Process and Stakeholder Participation

When DOE evaluates any new or amended energy conservation standard for “covered 

products,” EPCA, as amended, specifies that any standard DOE prescribes for consumer 

products must be designed to achieve the maximum improvement in energy efficiency that is 

technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) Moreover, the 

Secretary of Energy (Secretary) may not establish a new or amended standard if such standard 

would not result in a significant conservation of energy. (42 U.S.C. 6295(o)(3)(B)) In 

determining whether a standard is economically justified, DOE must consider, to the greatest 

extent practicable, the following seven factors: 

(1) The economic impact of the standard on the manufacturers and on the consumers of 

the products subject to such standard;

(2) The savings in operating costs throughout the estimated average life of the covered 

product in the type (or class) compared to any increase in the price of, or in the initial 

charges for, or maintenance expenses of, the covered products which are likely to result 

from the imposition of the standard;

(3) The total projected amount of energy, or as applicable, water, savings likely to result 

directly from the imposition of the standard; 

(4) Any lessening of the utility or the performance of the covered products likely to result 

from the imposition of the standard;

(5) The impact of any lessening of competition, as determined in writing by the Attorney 

General, that is likely to result from the imposition of the standard;

(6) The need for national energy and water conservation; and

(7) Other factors the Secretary considers relevant.

(42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))

The process of developing efficiency standards involves analysis, public notice, and 

consultation with interested parties. Such interested parties generally include manufacturers, 

consumers, energy conservation and environmental advocates, State and Federal agencies, and 

any other groups or individuals with an interest in energy conservation standards and test 

procedures. DOE considers participation of interested parties to be a very important part of the

rulemaking process. Accordingly, DOE actively encourages the participation and interaction of 

all interested parties during the comment period provided at each stage of the rulemaking. The 

broad array of interested parties who routinely provide comments promotes a balanced 

discussion of critical information required to conduct the standards rulemaking, beginning with 

public comment on the framework document. 
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In conducting the test procedure rulemakings and the energy (and water) conservation 

standards rulemakings, DOE involves interested parties through a variety of means. As discussed 

in further detail below, the standards rulemaking process typically involves three public notices

in addition to the notice of availability of the framework document. All of these notices are 

published in the Federal Register. Publication of the framework document, preliminary analysis,

and NOPR are typically accompanied by public meetings and comment periods to solicit 

comment from interested parties to enhance the rulemaking process. 

• Preliminary Analysis and Notice of Public Meeting (section 2.3). The preliminary 

analysis is designed to publicly vet the models and tools that DOE will use in the 

rulemaking, and to facilitate public participation before the proposed rule stage. 

Candidate standard levels (CSLs), which are levels that span the range of efficiencies 

from baseline products to the most efficient technology, are the basis for 

demonstrating the functionality of the models and tools.

• Notice of Proposed Rulemaking (section 2.4). The NOPR presents a discussion of 

comments received in response to the preliminary analysis; DOE’s analysis of the 

impacts of potential standards on consumers, manufacturers, and the nation; DOE’s 

weighing of these impacts; and the proposed standard levels for public comment. 

• Final Rule (section 2.5). The final rule presents a discussion of comments received in 

response to the NOPR; the revised analysis of the impacts of standards; DOE’s 

weighing of the impacts; and the standard levels DOE is adopting. The final rule also 

establishes the date for compliance with any standards. 

DOE has prepared the preliminary schedule below for the GSL rulemaking. 

Table 2.1.1 Preliminary Rulemaking Schedule for GSL Energy Conservation Standards

Deliverable Publication Date 

Framework Document December 2013

Preliminary Analysis November 2014

NOPR December 2015

Final Rule December 2016

Any final energy conservation standards for GSLs would require compliance at least three years 

after the final rule is published, which is projected to be December 2019 (see 42 U.S.C. 

6295(6)(A)(iii)).

2.2 Test Procedures

EPCA sets forth generally applicable criteria and procedures for DOE’s adoption and 

amendment of test procedures. (42 U.S.C. 6293) Manufacturers of covered products must use 

these test procedures to certify to DOE that their product complies with EPCA energy 

conservation standards and to quantify the efficiency of their product. DOE is considering 

developing and amending test procedures for products included in the definition of GSL. The 

term GSL includes GSILs, compact fluorescent lamps (CFLs), general service light-emitting 
5

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. 10 CFR 430.2 For a more detailed discussion of scope, see section 3. 

DOE’s test procedures for GSILs are set forth at 10 CFR part 430, subpart B, appendix R.

These test procedures provide instructions for measuring GSIL performance largely by 

incorporating industry standards. These test procedures were updated in a final rule published in 

January 2012. 77 FR 4203 (January 27, 2012). The rule updated citations and references to the 

industry standards currently referenced in DOE’s test procedures for GSILs and established a 

new test procedure for determining the rated lifetime of GSILs.

In the preliminary analysis of the general service fluorescent lamp (GSFL) and 

incandescent reflector lamp (IRL) energy conservation standards rulemaking2(hereafter “GSFL 

and IRL Standards Rulemaking”), DOE concluded that the term “compact fluorescent lamps” 

includes both pin base and medium base CFLs (see section 3 for further discussion). DOE’s test 

procedures for MBCFLs are set forth at 10 CFR part 430, subpart B, appendix W. These test 

procedures provide instructions for measuring MBCFL performance by referencing version 2.0 

of ENERGY STAR’s program requirements. Currently there is no DOE test procedure for pin 

base CFLs. However, EPCA directs DOE to establish test procedures for covered products in 

advance of prescribing an energy conservation standard. (42 U.S.C. 6295(o)(3)(A)) Therefore, 

DOE plans to initiate a test procedure rulemaking to propose test procedures for pin base CFLs.

DOE is currently developing test procedures for LED lamps. DOE published a notice of 

proposed rulemaking (NOPR) on April 9, 2012 to propose test procedures for LED lamps. 77 FR 

at 21038. The rulemaking does not include test procedures for OLED lamps; however, as 

discussed in section 3, DOE did not identify any OLED lamps that potentially fall within the 

scope of this rulemaking and therefore does not believe a test procedure is necessary in advance 

of prescribing standards for this rulemaking. 

DOE has the authority to consider additional lamps that it determines are used to satisfy 

lighting applications traditionally served by GSILs (see section 3 for further discussion). (42 

U.S.C. 6291(30)(BB)) Because DOE identified additional lamp types that it is considering 

including in the scope of this rulemaking, including hybrid lamps and self-ballasted mercury 

vapor lamps, test procedures would need to be established for these lamps, as well as any other 

lamps not currently covered by a DOE test procedure, prior to an energy conservation standard 

being prescribed for these lamps.

Item 1 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. 

 

2 The preliminary analysis technical support document for the GSFL and IRL Standards Rulemaking is available at 

www.regulations.gov/#!documentDetail;D=EERE-2011-BT-STD-0006-0022.
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2.3 Preliminary Analyses and Notice of Public Meeting

During the preliminary analysis phase of the rulemaking, DOE presents the models and 

tools it will use to conduct the four principal analyses that comprise the preliminary analysis–the 

engineering analysis, life-cycle cost analysis (LCC), national impact analysis (NIA), and 

preliminary manufacturer impact analysis (MIA). Before conducting the engineering analysis, 

DOE typically identifies technology options to increase efficiency and then preliminarily 

determines whether to retain that option for detailed analysis or to eliminate it from further 

consideration. The process for consideration of technology options includes a market and 

technology assessment (section 4) and a screening analysis (section 5). DOE applies four 

screening criteria in the screening analysis to determine which technology options to eliminate 

from further consideration: (1) technological feasibility; (2) practicability to manufacture, install, 

and service; (3) adverse impacts on product utility or availability; and (4) adverse impacts on 

health or safety. Technology options that remain after screening analysis are referred to as design 

options in the engineering analysis. DOE consults with interested parties and independent 

technical experts to identify the design options, efficiency levels, or key issues that DOE will 

consider in the rulemaking. 

Next, DOE considers design options or efficiency levels for each product class. DOE 

collects manufacturer cost data, historical shipment data, shipment-weighted average efficiency 

data, and preliminary manufacturer impact data (e.g., capital conversion expenditures, marketing 

costs, and research and development costs) based on these design options or efficiency levels. 

DOE then conducts the principal analyses, including: (1) the engineering analysis (section 6); (2) 

the LCC and payback period (PBP) analyses (section 9); (3) the NIA, which considers national 

energy savings (NES) and consumer net present value (NPV) (section 11); and (4) a preliminary 

MIA (section 13). DOE will present the results of these analyses in the preliminary analysis 

technical support document (TSD). 

Based on the results of the preliminary analysis described previously, DOE selects CSLs 

from among the energy efficiency levels considered in the preliminary analysis. DOE uses 

analytical models and tools to assess the different product classes at each CSL analyzed. Many of 

these analytical models and tools are in the form of spreadsheets, which are also used to conduct 

the LCC and PBP analyses and to determine the national energy savings and NPV of CSLs. DOE 

will make the spreadsheet tools used in the preliminary analysis and results of the preliminary 

analysis available on its website for review. Publication of DOE analysis of various CSLs in the 

preliminary analysis will enable interested parties to review the spreadsheet models (also posted 

on DOE’s website) that underpin the analyses and provide DOE with comments so that the 

models can be refined. 

DOE will also make a TSD available containing the details of all the analyses performed 

to date when it publishes the preliminary analysis. After publication of the preliminary analysis, 

DOE will provide a public comment period and hold a public meeting. In addition, DOE 

encourages interested parties to make joint recommendations for CSLs and to submit them to 

DOE for consideration. 
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2.4 Notice of Proposed Rulemaking

In the next stage of rulemaking, the NOPR, DOE generally considers energy efficiency 

levels or design options that span technologically achievable efficiencies. The range of levels 

DOE typically analyzes includes:

 The baseline efficiency level (the minimum level) set by the product with the lowest 

energy efficiency level currently sold on the market for a given category; For product 

categories where minimum federal energy conservation standards already exist, this is 

typically defined by the existing energy conservation standard; 

 The efficacy levels (ELs) with the lowest LCC or greatest LCC savings; 

 The highest energy efficiency EL or lowest energy consumption EL that is 

technologically feasible (maximum technologically feasible [max tech]); and

 ELs that incorporate technologies of significance or fill in large gaps between other 

efficiency levels considered. 

For the NOPR, DOE reviews and considers all the comments received after the 

publication of the preliminary analysis. This process may result in revisions or refinements to the 

preliminary analyses, including the engineering analysis and LCC analysis. DOE also will 

conduct additional economic and environmental impact analyses at this stage of the rulemaking. 

These analyses generally include a consumer LCC subgroup analysis (see section 12), a 

complete manufacturer impact analysis (see section 13), a utility impact analysis (see section 

14), an employment impact analysis (see section 15), an emissions analysis (see section 16), a 

monetized emissions analysis (see section 17), and a regulatory impact analysis (see section 18). 

DOE describes the methodology used and posts the results of all the analyses on its 

website for review and comments. Based on comments by stakeholders, further revisions to the 

analysis may be undertaken. This analytical process ends with the proposal of standard levels in 

the NOPR. DOE proposes standard levels based on the trial standard levels (TSLs) analyzed 

during the NOPR phase of the rulemaking. The NOPR, published in the Federal Register, 

documents the evaluation and selection of the proposed standard level(s), along with a discussion 

of other TSLs considered but not selected (and the reasons for not selecting them). 

The selection process for proposed efficiency standards generally runs as follows. For 

each product class, DOE will identify the max tech efficiency level. If DOE proposes a level 

lower than the max tech level, it will sequentially explain the reasons for eliminating higher 

levels beginning with the highest level considered. DOE will present the analytical results in the 

NOPR and the analysis details in an accompanying TSD. 

DOE considers many factors in selecting proposed standards, as described in section 2.1. 

These factors and criteria are prescribed by EPCA and take into consideration the impacts of 

energy conservation standards. In addition, as stated previously, DOE encourages stakeholders to 
8

make joint recommendations for standard levels. DOE carefully considers such 

recommendations in its decision process. 

When DOE publishes the NOPR, it will provide the Department of Justice (DOJ) with a 

copy of the NOPR and TSD to solicit DOJ review of the impact of the proposed standard levels 

on competition in the lighting industry. Publication of the NOPR is followed by a 60-day public 

comment period.

2.5 Final Rule

After the publication of the NOPR, DOE will consider public comments it receives on the 

proposal and supporting analyses. On the basis of the public comments, DOE will review the 

supporting analyses and proposed standards and consider modifications where necessary. Before 

the final rule is issued, DOE also will consider DOJ comments on the NOPR relating to the 

impacts of the proposed standard levels on competition to determine whether changes to these 

standard levels are needed.

The standards rulemaking will conclude with the publication of the final rule. DOE will 

select the final standard level based on the complete record of the standards rulemaking. The 

final rule will promulgate the final standard level and the compliance date and explain the basis 

for its selection. The final rule will be accompanied by a final TSD.

2.6 Overview of Analyses for Rulemaking

The purpose of the analyses conducted in support of the standards rulemaking is to ensure 

that DOE selects energy conservation standards that achieve the maximum improvement in 

energy efficiency that is technologically feasible and economically justified, and will result in 

significant energy savings. Economic justification includes the consideration of economic 

impacts on domestic manufacturers and consumers, national benefits including environmental 

impacts, issues of consumer utility, and impacts from any lessening of competition. DOE expects 

the selection of such standards to achieve the maximum energy savings that are economically 

justified without imposing excessive financial burden on any particular party. 

Figure 2.6.1 summarizes the analytical components of the standards-setting process. The 

“analyses” are presented in the center column. Each analysis has a set of “key inputs,” which are 

data and information required for the analysis. “Approaches” are the methods that DOE will use 

to obtain key inputs, which may vary depending on the information in question. For example, 

some key inputs exist in public databases; DOE will collect other information from stakeholders 

or experts with special knowledge, and DOE will gather other information in support of this 

rulemaking. The results of each analysis are “key outputs,” which feed directly into the 

rulemaking. Arrows indicate the flow of information between the various analyses. DOE ensures 

a consistent approach to its analyses throughout the rulemaking by considering each analysis as a 

part of the overall standards-setting framework. 
9

Figure 2.6.1 Flow Diagram of Analyses for the GSL Standards Rulemaking Process

3. SCOPE OF COVERAGE

General service lamps include GSILs, CFLs, general service LED lamps, OLED lamps, 

and any other lamps that the Secretary determines are used to satisfy lighting applications 

traditionally served by general service incandescent lamps. However, the term general service 
10

lamp does not include 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 The following sections discuss each of the lamp types included in the 

definition of general service lamp in more detail.

3.1 General Service Incandescent Lamps

As stated previously, GSILs are included in the definition of GSL. The definition of 

“general service incandescent lamp” is provided below:

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; however this 

definition does not apply to the following incandescent lamps—

(1) An appliance lamp;

(2) A black light lamp;

(3) A bug lamp;

(4) A colored lamp;

(5) An infrared lamp;

(6) A left-hand thread lamp;

(7) A marine lamp;

(8) A marine signal service lamp;

(9) A mine service lamp;

(10) A plant light lamp;

(11) A reflector lamp;

(12) A rough service lamp;

(13) A shatter-resistant lamp (including a shatter-proof lamp and a shatter-protected 

lamp);

(14) A sign service lamp;

(15) A silver bowl lamp;

(16) A showcase lamp;

(17) A 3-way incandescent lamp;

(18) A traffic signal lamp;

(19) A vibration service lamp;

(20) A G shape lamp (as defined in ANSI C78.20) (incorporated by reference; see § 

430.3) and ANSI C79.1-2002 (incorporated by reference; see § 430.3) with a diameter of 

5 inches or more;

(21) A T shape lamp (as defined in ANSI C78.20) (incorporated by reference; see § 

430.3) and ANSI C79.1-2002 (incorporated by reference; see § 430.3) and that uses not 

more than 40 watts or has a length of more than 10 inches; and

(22) A B, BA, CA, F, G16-1/2, G-25, G30, S, or M-14 lamp (as defined in ANSI C79.1-

2002) (incorporated by reference; see § 430.3) and ANSI C78.20 (incorporated by 

reference; see § 430.3) of 40 watts or less.

10 CFR 430.2
11

The Consolidated Appropriations Act, 2012 (Public Law 112-74), in relevant part, 

restricts the use of appropriated funds in connection with several aspects of DOE’s incandescent 

lamps program. Specifically, section 315 states that none of the funds made available by the Act 

may be used to implement or enforce section 430.32(x) of title 10, Code of Federal Regulations 

(CFR). The current standards for GSILs are set forth in 10 CFR 430.32(x). Because section 315 

appears to curtail any further activity to implement or enforce standards for GSILs, DOE will not 

be including lamps that meet the definition of GSIL in the GSL rulemaking at this time.

As stated in section 1, section 42 U.S.C. 6295(i)(6)(A)(i)(II) directs DOE to determine 

whether the exemptions for certain incandescent lamps should be maintained or discontinued 

based, in part, on exempted lamp sales collected from manufacturers. In March 2013, DOE 

reviewed the 2012 sales of rough service lamps, vibration service lamps, 3-way incandescent 

lamps, 2,601-3,300 lumen general service incandescent lamps, and shatter-resistant lamps. DOE 

published a notice of data availability regarding data collection and estimated future unit sales in 

which it concluded that these five types of incandescent lamps have not experienced significant 

growth since their exemption from federal efficiency standards. 78 FR 15891 (March 13, 2013) 

Because this assessment indicates no further action is necessary regarding these lamp types, they 

will not be included in the GSL rulemaking.

3.2 Compact Fluorescent Lamps

CFLs are also included in the definition of GSL, however the term “compact fluorescent 

lamp” is not currently defined in the CFR. Thus, DOE will propose a definition of “compact 

fluorescent lamp.” CFLs can be self-ballasted (e.g., medium base CFLs) or externally ballasted

(e.g., pin base CFLs). As stated in section 1, EPAct 2005 amended EPCA by setting energy 

conservation standards for MBCFLs. DOE’s existing energy conservation standards apply only 

to integrally ballasted (also referred to as self-ballasted) MBCFLs. 10 CFR 430.32(u) The 

definitions of “medium base compact fluorescent lamp” and “self-ballasted compact fluorescent 

lamp” are provided below:

Medium base compact fluorescent lamp means an integrally ballasted fluorescent lamp 

with a medium screw base, a rated input voltage range of 115 to 130 volts and which is 

designed as a direct replacement for a general service incandescent lamp; however, the 

term does not include—

(1) Any lamp that is—

(i) Specifically designed to be used for special purpose applications; and

(ii) Unlikely to be used in general purpose applications, such as the applications 

described in the definition of “General Service Incandescent Lamp” in this section; or

(2) Any lamp not described in the definition of “General Service Incandescent Lamp” in 

this section that is excluded by the Secretary, by rule, because the lamp is—

(i) Designed for special applications; and

(ii) Unlikely to be used in general purpose applications.

10 CFR 430.2
12

Self-ballasted compact fluorescent lamp means a compact fluorescent lamp unit that 

incorporates, permanently enclosed, all elements that are necessary for the starting and 

stable operation of the lamp, and does not include any replaceable or interchangeable 

parts.

10 CFR part 430 subpart B Appendix W

The MBCFLs proposed to be included in this rulemaking will include all lamps that meet 

the definition of “medium base compact fluorescent lamp” stated in 10 CFR 430.2. DOE notes 

that, as stated in the definition, MBCFLs designed for special purpose applications and unlikely 

to be used in general purpose applications are exempt from standards. For determining such nongeneral applications, the definition specifically references the GSIL definition which lists several 

lamp types, such as reflector lamps, not considered for use in general service applications. Thus, 

DOE interprets the GSIL exemptions to also apply to MBCFLs.

Pin base CFLs are not currently covered by DOE energy conservation standards. DOE 

considered adopting standards for pin base CFLs in the framework document3of the GSFL and 

IRL Standards Rulemaking. However, in the preliminary analysis of the GSFL and IRL 

Standards Rulemaking, DOE concluded that compact fluorescent lamps fall within the definition 

of “general service lamp.”

4 DOE further determined that the term “compact fluorescent lamps” is 

not limited to MBCFLs. DOE concluded that it was intended for DOE to establish standards for 

lamps categorized as CFLs in a rulemaking separate from GSFLs. DOE therefore determined

CFLs would be considered in the GSL rulemaking, and would include both pin base and medium 

base CFLs. For more information on the inclusion of pin base CFLs in this rulemaking, see 

chapter 2 of the preliminary analysis TSD for the GSFL and IRL Standards Rulemaking.5

DOE currently does not have a definition for pin base CFL, however, the term “pinbased” is defined in the CFR as follows:

Pin-based means (1) the base of a fluorescent lamp, that is not integrally ballasted and 

that has a plug-in lamp base, including multi-tube, multibend, spiral, and circline types, 

or (2) a socket that holds such a lamp.

10 CFR 430.2

The definition of GSL explicitly states that the term does not include any lighting 

application or bulb shape excluded from the GSIL definition or GSFLs. Thus, 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.

 

3 The framework document for the GSFL and IRL Standards Rulemaking is available at 

www.regulations.gov/#!documentDetail;D=EERE-2011-BT-STD-0006-0002.

4 Chapter 2 of the preliminary analysis technical support document for the GSFL and IRL Standards Rulemaking is 

available at www.regulations.gov/#!documentDetail;D=EERE-2011-BT-STD-0006-0022.

5

Ibid.
13

Item 2 DOE welcomes comment on definitions for compact fluorescent lamp and pin base 

compact fluorescent lamp.

3.3 General Service LED and OLED Lamps

General service LED lamps and OLED lamps are included in the definition of GSL. The 

definitions for “light-emitting diode or LED” and “organic light-emitting diode or OLED” are as 

follows:

Light-emitting diode or LED means a p-n junction solid state device of which the radiated 

output, either in the infrared region, the visible region, or the ultraviolet region, is a 

function of the physical construction, material used, and exciting current of the device.

Organic light-emitting diode or O LED means a thin-film light-emitting device that 

typically consists of a series of organic layers between 2 electrical contacts (electrodes).

10 CFR 430.2

DOE proposed a definition for “LED lamp” in a test procedure NOPR for LED lamps 

(hereafter “LED TP NOPR”). 77 FR 21038 (April 9, 2012). The proposed definition is as 

follows:

Light-emitting diode lamp means an integrated LED lamp as defined in ANSI/IESNA 

RP-16 (incorporated by reference; see §430.3).

As stated in the LED TP NOPR, the ANSI/IESNA standard defines integrated LED 

lamps as comprising the LED source (the LED packages [components] or LED arrays 

[modules]), LED driver, ANSI standard base, and other optical, thermal, mechanical and 

electrical components such as phosphor layers, insulating materials, fasteners to hold 

components within the lamp together, and electrical wiring. The LED lamp is intended to 

connect directly to a branch circuit through a corresponding ANSI standard socket. 77 FR at 

21041 (April 9, 2012).

Although 10 CFR 430.2 defines the term “light-emitting diode or LED” and DOE has 

proposed a definition for “light-emitting diode lamp,” DOE does not currently have a definition 

for “general service LED lamp.” As stated previously, the definition of GSL explicitly states that 

the definition does not include any lighting application or bulb shape excluded from the GSIL

definition. Thus, DOE is considering including in the scope of this rulemaking all LEDs that 

serve general lighting applications and are not the lamp types or shapes excluded from the GSIL 

definition.

As previously mentioned, the term general service lamp includes OLED lamps. OLEDs 

are diffuse light sources made of thin layers of carbon-based semiconductor material. The layerbased construction tends to support development of large, flat surfaces rather than traditional 

lamp shapes. Because OLEDs are an emerging technology, the commercial availability of 

OLEDs is very limited. Further, products that are available are not used in general lighting 
14

applications due to their size and shape. The OLEDs that are available are marketed for accent 

lighting, interior design, or are sold integrated into fixtures. In addition, due to the emerging 

nature of the technology and the limited commercial availability of OLEDs, it is unclear whether 

the efficacy of existing OLED products can be improved. For these reasons, DOE is considering

excluding OLED lamps in this rulemaking.

Item 3 DOE welcomes comment on a definition for general service LED lamp.

Item 4 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.

3.4 Additional Lamps

Pursuant to the definition of GSL, DOE has the authority to consider additional lamps 

that it determines are used to satisfy lighting applications traditionally served by GSILs. The 

definition of GSIL stated previously, indicates that these lamps are: (1) typically intended for 

general service applications; (2) have a medium screw base; (3) emit between 310 and 2,600 

lumens; and (4) are capable of being operated at a voltage range at least partially within 110 and 

130 V. See 10 CFR 430.2 DOE defines the term “general lighting application” as follows:

General lighting application means lighting that provides an interior or exterior area with 

overall illumination. 

10 CFR 430.2

Thus, lamps that meet the four criteria outlined in the definition of GSIL are proposed to

be included in the scope of coverage regardless of the technology used to produce light. 

DOE surveyed the market and found additional lamp technologies it believes are intended 

to serve in general lighting applications. DOE found lamps that utilize more than one technology 

to produce light (sometimes known as hybrid lamps). These hybrid lamps typically use one 

lighting technology for the primary application and another lighting technology to provide 

supplemental lighting. Specifically, DOE identified lamps that use a CFL as the primary lighting 

source and also contain a halogen capsule. The halogen capsule resides inside the CFL spiral and 

allows for instant illumination when first turned on. After the CFL reaches its full lumen output, 

the halogen capsule is turned off. Additionally, DOE identified lamps that use a CFL as the 

primary lighting source and also contain an LED. The CFL is used for general lighting 

applications and the LED is mounted inside the CFL spiral to provide a nightlight functionality. 

In addition, DOE identified a lamp type intended for general service applications that 

utilizes a technology not explicitly stated in the definition of general service lamp (i.e., 

incandescent, compact fluorescent, LED, OLED). Specifically, DOE found self-ballasted 

mercury vapor lamps that have medium screw bases, lumen outputs between 1,100 and 2,550 

lumens, operate at 120 volts, and are marketed as replacements for GSILs. 
15

Item 5 DOE welcomes comment on a definition for hybrid lamp.

Item 6 DOE welcomes comment on additional lamp types that should be considered in the 

scope of this rulemaking.

Item 7 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.

4. MARKET AND TECHNOLOGY ASSESSMENT

The market and technology assessment will provide information about the manufacturers 

of GSLs, and specifics about the performance attributes of these lamps. This assessment is used 

to develop product classes and identify technology options to improve lamp efficacy for each of 

the lamp types. EPCA defines “lamp efficacy” as the lumen output of a lamp divided by its 

wattage, expressed in lumens per watt.

4.1 Market Assessment Overview

As part of the market assessment, DOE will qualitatively and quantitatively characterize 

the structure of the GSL market. DOE will identify and characterize the manufacturers, estimate 

market shares and trends, address regulatory and non-regulatory initiatives intended to improve 

the energy efficiency or reduce the energy consumption of covered lamps, and explore the 

potential for technological improvements in the design and manufacturing of such products. 

This market assessment will serve as a resource to guide the analyses that follow. For 

example, DOE may use historical shipments and prices as an indicator of future shipments and 

prices. Similarly, DOE plans to use market structure data for the manufacturer impact analysis, 

data which will be particularly useful for assessing competitive impacts. This phase also allows 

DOE to start updating design options by reviewing product literature and industry publications. 

DOE recognizes that there may be limited public information regarding recent trends in 

national shipments, manufacturing costs, channels of distribution, and manufacturers’ market 

shares of GSLs. This type of data is an important input for analyses that determine if energy 

conservation standards are economically justified and will result in significant energy savings. 

Therefore, DOE encourages stakeholders to submit data that pertains to these issues and would 

aid DOE’s understanding of trends in the GSL market. 

Stakeholders may submit confidential data to DOE, indicating in writing which data 

should remain confidential. To prevent public disclosure of the data due to actions taken by a 

third party, stakeholders providing confidential information to DOE must submit that data 

according to 10 CFR 1004.11. Under 10 CFR 1004.11, any person submitting information that 

he or she believes to be confidential and exempt by law from public disclosure should submit 

two copies. One copy of the document shall include all the information believed to be 

confidential, and the other copy of the document shall have the information believed to be 

confidential deleted. DOE will make its own determination about the confidential status of the 
16

information and treat it according to its determination. DOE prepares aggregated results from the 

data submitted for use in DOE’s analyses. These aggregated results do not divulge the sensitive 

nature of the individual raw data, but enable other stakeholders to review and comment on the 

aggregated dataset. 

Item 8 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).

4.2 Product Classes

DOE divides covered products into classes by: (a) the type of energy used; (b) the 

capacity of the product; or (c) any other performance-related feature that justifies different 

standard levels, such as features affecting consumer utility. (42 U.S.C. 6295(q)) DOE is 

considering establishing separate product classes for GSLs based on the following three factors: 

(1) ballast location6(i.e., self-ballasted versus externally ballasted lamps); (2) cover (i.e., covered 

versus bare lamps); and (3) dimmability.

Ballast location refers to the use of integrated ballasts (i.e., self-ballasted) or nonintegrated ballasts (i.e., externally ballasted). DOE notes that self-ballasted lamps may have 

lower inherent efficiency compared to lamps that utilize external ballasts due to the additional

components and circuitry integrated into a self-ballasted lamp. The use of a self-ballasted lamp

can be advantageous in that a consumer need only replace one lamp unit rather than two separate 

components. Self-ballasted lamps are also generally more compact and thus can be used in 

applications with size constraints.

The presence of a cover over the main light source can also affect lamp efficacy. Some 

lamps incorporate an added glass or silicone cover over the light source. However, this cover can 

reduce the lumen output of the lamp. Covered lamps may offer utility to consumers as they more 

closely resemble traditional lighting technologies and are frequently utilized where a lamp is 

visible. 

Lastly, the ability of a lamp to be dimmed can impact lamp efficacy. Dimmable lamps 

could have a lower efficacy because of the added circuitry necessary for dimming functionality

and the inclusion of cathode heat. For certain technologies, such as CFLs and LED lamps, not all 

products are marketed as capable of being dimmed. Thus a lamp that can be dimmed may offer 

unique performance characteristics and provide a utility to consumers.

Because DOE believes the features listed could affect lamp efficacy and may also offer a 

distinct utility to consumers, DOE is considering establishing eight separate product classes 

based on these three features.

 

6 The term “ballast location” is used interchangeably to refer to both ballasts and drivers. Thus, in the context of this 

rulemaking the term is not limited to CFL technology.
17

Table 4.2.1. Product Classes under Consideration for GSLs

Ballast Location Dimmability Cover

Self-ballasted

Dimmable Bare 

Covered 

Non-dimmable Bare

Covered

Externally ballasted

Dimmable Bare 

Covered

Non-dimmable Bare

Covered 

Item 9 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.

Item 10 DOE welcomes comment on any other class-setting factors that should be considered 

in the analysis.

Item 11 DOE welcomes comment on a definition for the term “covered” that is applicable 

across technologies.

4.3 Technology Assessment

The technology assessment centers on understanding how energy is used by the product, 

and what changes are possible that would reduce energy consumption. Measures that improve 

the energy efficiency of the products are called technology options, and they are based on 

existing technologies, as well as working prototypes. DOE develops a list of technology options,

which are then considered against four screening criteria discussed in the following section. 

Those technology options that pass the four screening criteria are called design options and will 

be considered as ways to improve the efficacy of the products in the engineering analysis and 

will assist DOE in determining the max tech design. 

DOE reviewed manufacturer catalogs, recent trade publications, technical journals, and 

patent filings to determine technology options. Table 4.3.1 presents the technology options DOE 

has preliminarily identified to improve the efficacy of general service lamps. DOE notes in Table 

4.3.1 the applicable lamp type for the technology options listed.
18

Table 4.3.1 GSL Technology Options

Lamp Type Name of Technology Option Description

GSIL

Higher Temperature 

Operation

Operating the filament at higher temperatures, the 

spectral output shifts to lower wavelengths, increasing 

its overlap with the eye sensitivity curve.

Microcavity Filaments Texturing, surface perforations, microcavity holes 

with material fillings.

Novel Filament Materials

More-efficacious filament alloys that have a high 

melting point, low vapor pressure, high strength, high 

ductility, or good radiating characteristics.

Thinner Filaments

Thinner filaments to increase operating temperature. 

This measure may shorten the operating life of the 

lamp.

Efficient Filament Coiling Coiling the filament to increase surface area, thus 

increasing light output.

Crystallite Filament 

Coatings

Layers of micron or submicron crystallites deposited 

on the filament surface that increases emissivity of the 

filament.

Efficient Filament 

Orientation

Positioning (horizontal or vertical) the incandescent 

filament to increase light emission from the lamp. 

Vertical orientation, used by majority of lamps, allows 

for greater light emission.

Higher Efficiency Inert Fill 

Gas

Filling lamps with alternative gases, such as Krypton, 

to reduce heat conduction.

Electron Stimulated 

Luminescence

A low voltage cathodoluminescent phosphor that 

emits green light (visible region of light) upon 

impingement by thermally ejected electrons, 

increasing the lumen output.

Higher Pressure TungstenHalogen Lamps Increased halogen bulb capsule pressurization.

Non-Tungsten-Halogen 

Regenerative Cycles Novel filament materials that regenerate.

Change in Technology Replace GSIL with CFL or LED technology.

CFL

Highly Emissive Electrode 

Coatings

Improved electrode coatings will allow electrons to be 

more easily removed from electrodes, reducing lamp 

power and increase overall efficacy.

Higher Efficiency Lamp Fill 

Gas Composition

Fill gas compositions to improve cathode thermionic 

emission or increase mobility of ions and electrons in 

the lamp plasma.

Higher Efficiency Phosphors Techniques to increase the conversion of ultraviolet 

(UV) light into visible light.

Glass Coatings

Coatings on inside of bulb enabling the phosphors to 

absorb more UV energy, so that they emit more 

visible light.

Multi-Photon Phosphors Emitting more than one visible photon for each 

incident UV photon.

Cold Spot Optimization Improve cold spot design to maintain optimal 

temperature and improve light output.

Improved Ballast 

Components

Use of higher-grade components to improve efficiency 

of integrated ballasts.

Improved Ballast Circuit 

Design

Better circuit design to improve efficiency of 

integrated ballasts.

Change in Technology Replace CFL with LED technology.
19

Lamp Type Name of Technology Option Description

LED

Efficient Down Converters

New high-efficiency wavelength conversion materials, 

including quantum-dots and nano-phosphors, have the 

potential for creating warm-white LEDs with 

improved spectral efficiency, high color quality, and 

improved thermal stability.

Improved Package 

Architectures

Novel package architectures such as RGB+, systemin-package, hybrid color, and chip-on-heat-sink have 

the potential to improve thermal management, colorefficiency, optical distribution, as well as electrical 

integration to greatly improve overall lamp and 

luminaire efficiency.

Improved Emitter Materials

The development of efficient red, green, or amber

LED emitters, will allow for optimization of spectral 

efficiency with high color quality over a range of 

correlated color temperature (CCT) and which also 

exhibit color and efficiency stability with respect to 

operating temperature.

Alternative Substrate 

Materials

Alternative substrates such as gallium nitride (GaN), 

silicon (Si), GaN-on-Si, and silicon carbide to enable 

high-quality epitaxy for improved device quality and 

efficiency.

Improved Thermal Interface 

Material (TIM)

Develop TIMs that enable high efficiency thermal 

transfer for long-term reliability and performance 

optimization of the LED device and overall lamp 

product.

Optimized Heat Sink Design

Improve thermal conductivity and heat dissipation 

from the LED chip thus reducing efficacy loss from 

rises in junction temperature.

Active Thermal 

Management Systems

Devices such as internal fans, vibrating membranes, 

and circulated liquid cooling systems to improve 

thermal dissipation from the LED chip.

Device Level Optics

Integration of specific lens into the primary optic of 

the LED package allowing for the removal of 

secondary optics and eliminating losses due to 

absorption at additional interfaces.

Increased Light Utilization

Reduce optical losses from the lamp housing, 

diffusion, beam shaping and color-mixing to increase 

the efficiency of the LED lamp.

Improved Driver Design Increase driver efficiency through novel and 

intelligent circuit design.

AC LEDs

Reduce or eliminate the requirements of a driver and 

therefore the effect of driver efficiency on lamp 

efficacy.

DOE is aware that some attempts to improve lamp efficacy may also modify lamp 

performance or other lamp characteristics. For example, incandescent lamps operating filaments 

at higher temperatures can increase lamp efficacy but may also shorten the operating life of the 
20

lamp. DOE will consider these tradeoffs in the subsequent analyses and will eliminate any 

technology options that increase efficacy by decrease lamping lifetime such that they have a 

significant adverse impact on utility, pursuant to the screening criteria discussed below.

Item 12 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.

5. SCREENING ANALYSIS

The purpose of the screening analysis is to screen out technologies that will not be 

considered further in the analysis. After making an initial list of technologies (during the market 

and technology assessment), DOE will review and evaluate each technology based on the 

following four criteria, as specified by 10 CFR part 430, subpart C, Appendix A, sections 4(a)(4) 

and 5(b): 

1. Technological feasibility. DOE will consider technologies incorporated in commercial 

products or in working prototypes to be technologically feasible. 

2. Practicability to manufacture, install, and service. If mass production and reliable 

installation and servicing of a technology in commercial products could be achieved on 

the scale necessary to serve the relevant market at the time the standard requires 

compliance, then DOE will consider that technology practicable to manufacture, install, 

and service. 

3. Adverse impacts on product or equipment utility to consumers or availability. If DOE 

determines a technology would have a significant adverse impact on the utility of the 

product to significant subgroups of consumers, or would result in the unavailability of 

any covered product type with performance characteristics (including reliability), 

features, sizes, capacities, and volumes that are substantially the same as products 

generally available in the United States at the time, it will not consider that technology 

further.

4. Adverse impacts on health or safety. If DOE determines that a technology will have 

significant adverse impacts on health or safety, it will not consider that technology 

further. 

DOE will fully document its reasons for eliminating any technology options during the 

screening analysis, and will publish this documentation for stakeholder review and comment as 

part of the preliminary analysis. Those technology options not screened out by these four criteria 

are called “design options” and are considered as possible methods of improving efficacy in the 

engineering analysis.

Item 13 DOE welcomes comments on the applicability of the four screening criteria to the 

technology options listed in section 4.3.

Item 14 DOE welcomes comments on how the four screening criteria might apply to any 

additional technology option(s) than an interested party recommends to DOE.
21

6. ENGINEERING ANALYSIS

6.1 Overview

The engineering analysis identifies potential, increasing efficacy levels above the level of 

the baseline model for each product class. Those technologies not eliminated in the screening 

analysis (design options) are inputs to this process. In energy conservation standard rulemakings 

for other products, DOE typically develops cost-efficiency relationships in the engineering 

analysis. For this rulemaking, DOE is considering developing efficacy levels in the engineering 

analysis and end-user prices in a product price determination. By combining the results of the 

engineering analysis and the product price determination, DOE will derive typical inputs for use 

in the LCC and NIA. See section 8 of this framework document for further details on the product 

price determination.

The following is a summary of the steps DOE plans to take in the engineering analysis: 

• Step 1: Select Representative Product Classes 

• Step 2: Select Baseline Lamps 

• Step 3: Identify Higher-Efficacy Lamp Replacements 

• Step 4: Develop Efficacy Levels. 

The following sections discuss each of these steps in more detail. 

Item 15 DOE welcomes comments on the overall methodology for the engineering analysis.

6.2 Representative Product Classes

As discussed previously in this framework document, DOE is considering establishing 

eight product classes for GSLs. DOE is not planning to directly analyze every product class. 

Instead, DOE will select certain product classes to analyze, and then scale its analytical findings 

for those representative product classes to other product classes that are not analyzed. DOE 

typically chooses representative product classes based on the highest shipment volumes. 

As discussed in section 4.2, DOE is considering establishing separate product classes for 

general service lamps based on the following three factors: (1) ballast location (i.e., self-ballasted 

versus externally ballasted); (2) cover (i.e., covered versus bare lamps); and (3) dimmability. 

Based on preliminary research of manufacturer catalogs and market reports, DOE found that 

self-ballasted products are more common than externally ballasted products for all technologies. 

With the exception of self-ballasted CFLs, DOE found that dimmable products are more 

common than non-dimmable products. Lastly, based on a survey of the market and a review of 

market reports,

7 DOE believes that when applicable, bare lamps are more common than covered 

 

7 U.S. Department of Energy. Energy Star CFL Market Profile – Data Trends and Market Insights. September 2010. 

Prepared for the United States Department of Energy by D&R International, Ltd. U.S. Department of Energy: 

Washington, D.C. www.energystar.gov/ia/products/downloads/CFL_Market_Profile_2010.pdf.
22

lamps. As mentioned previously, DOE will also utilize information on shipment volumes when 

determining representative product classes.

Item 16 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.

Item 17 DOE welcomes comment on whether the characteristics of products with the highest

shipment volume change depending on lamp technology.

6.3 Baseline Lamps

Once DOE identifies the representative product classes for analysis, DOE selects 

representative units (baseline lamps) from within the representative product classes. These 

baseline lamps are generally what DOE believes to be the most-common, least-efficacious lamps 

in their respective product classes. 

DOE plans to establish baseline lamps by analyzing manufacturer catalogs and 

compliance and certification data to determine the most common, least efficacious lamps that 

just meet existing standards. For products that do not have existing energy conservation 

standards, DOE will select the most common, least efficacious lamp sold in a given product 

class. Certain products proposed to be covered under the scope of this rulemaking have existing 

energy conservation standards. Standard spectrum GSILs must have a color rendering index 

(CRI) greater than or equal to 80 and meet the requirements in Table 6.1. Modified spectrum 

GSILs must have a CRI greater than or equal to 75 and meet the requirements in Table 6.2. Table 

6.3.3 lists the existing standards for medium base compact fluorescent lamps.

Table 6.3.1 Standards for Standard Spectrum General Service Incandescent Lamps

Rated Lumen Ranges Maximum Rated Wattage Minimum Rated Lifetime Effective Date

1490-2600 72 1,000 hrs 1/1/2012

1050-1489 53 1,000 hrs 1/1/2013

750-1049 43 1,000 hrs 1/1/2014

310-749 29 1,000 hrs 1/1/2014

Table 6.3.2 Standards for Modified Spectrum General Service Incandescent Lamps

Rated Lumen Ranges Maximum Rated Wattage Minimum Rated Lifetime Effective Date

1118-1950 72 1,000 hrs 1/1/2012

788-1117 53 1,000 hrs 1/1/2013

563-787 43 1,000 hrs 1/1/2014

232-562 29 1,000 hrs 1/1/2014
23

Table 6.3.3 Standards for Medium Base Compact Fluorescent Lamps

Factor Requirements

Lamp Power (Watts) & 

Configuration1 Minimum Efficacy: lumens/watt (Based upon initial lumen data).2

Bare Lamp:

Lamp Power <15 45.0.

Lamp Power ≥15 60.0.

Covered Lamp (no reflector):

Lamp Power <15 40.0.

15≥Lamp Power 

<19 48.0.

19≥Lamp Power 

<25 50.0

Lamp Power ≥25 55.0.

1,000-hour Lumen 

Maintenance

The average of at least 5 lamps must be a minimum 90.0% of initial (100-hour) 

lumen output @ 1,000 hours of rated life.

Lumen Maintenance 80.0% of initial (100-hour) rating at 40 percent of rated life (per ANSI C78.5 Clause 

4.10).

Rapid Cycle Stress Test

Per ANSI C78.5 and IESNA LM-65 (clauses 2,3,5, and 6).

Exception: Cycle times must be 5 minutes on, 5 minutes off. Lamp will be cycled 

once for every two hours of rated life. At least 5 lamps must meet or exceed the 

minimum number of cycles.

Average Rated Lamp Life

≥ 6,000 hours as declared by the manufacturer on packaging. At 80% of rated life, 

statistical methods may be used to confirm lifetime claims based on sampling 

performance.

1 Take performance and electrical requirements at the end of the 100-hour aging period according to ANSI Standard 

C78.5. The lamp efficacy shall be the average of the lesser of the lumens per watt measured in the base up and/or 

other specified positions. Use wattages place on packaging to select proper specification efficacy in this table, not 

measured wattage. Labeled wattages are for reference only.

2 Efficacies are based on measured values for lumens and wattages from pertinent test data. Wattages and lumens 

placed on packages may not be used in calculation and are not governed by this specification. For multi-level or 

dimmable systems, measurements shall be at the highest setting. Acceptable measurement error is ±3%.

Item 18 DOE welcomes comments on its proposed approach for selecting baseline lamps in this 

rulemaking.

6.4 Identify Higher-Efficacy Lamp Replacements

DOE selects more efficacious lamps for each baseline lamp by considering technologies 

not eliminated in the screening analysis. DOE considers these technologies in the engineering 

analysis, either by modeling potential efficacy improvements due to the design options or by

analyzing commercially available lamps in which the design options are incorporated. In 
24

identifying more efficacious lamp or lamp-and-ballast designs, DOE recognizes that a lamp’s 

lumen package and performance characteristics are important design criteria for consumers. 

DOE chooses substitute lamps with performance characteristics similar to those of the baseline 

lamps. 

DOE plans to account for lumen output when it establishes lamp designs for its analyses

because consumers take lumen package into consideration when purchasing lamps. In its

analysis, DOE considers lamps that emit lumens equal to the lumen output of the baseline lamp, 

or within 10 percent of that lumen output. In identifying more efficacious substitutes, DOE plans 

to use a database of commercially available lamps.

Item 19 DOE welcomes comments on the methodology it is considering to select higher-efficacy 

lamp designs.

6.5 Efficacy Levels 

After identifying the more efficacious substitutes for each baseline lamp or lamp-andballast system, DOE is considering developing ELs based on three factors: (1) the design options 

associated with the specific lamps being studied (e.g., grades of phosphor for CFLs, efficient 

phosphor converters for LED lamps, etc.); (2) the ability of lamps across wattages to comply 

with the EL of a given product class;8and (3) the maximum technologically feasible efficacy 

level. DOE plans to use catalog data on commercially available lamps to develop continuous 

equations that represent the potential efficacy achieved by a particular design option across all 

wattages.

When possible, DOE will consider data submitted to DOE by manufacturers for the 

purpose of compliance with existing energy conservation standards as well as verification 

testing, such as the LED Lighting Facts Verification Program,9 when establishing minimum 

efficacy requirements for each EL.

Item 20 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.

Item 21 DOE welcomes comment on the use of compliance data and verification testing data 

when establishing efficacy levels.

6.6 Scaling to Product Classes Not Analyzed 

As mentioned previously, DOE plans to select certain product classes as representative 

and concentrate its analytical effort on those classes. Standards for non-representative product 

 

8 Efficacy levels span multiple lamps of different wattages. In selecting ELs, DOE considered whether lamps of 

different wattages can meet the levels of efficiency prescribed by those ELs. 

9

Information on the DOE’s LED Lighting Facts Verification Program including a database of tested products can be 

found at www.lightingfacts.com/.
25

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

DOE will develop scaling factors for GSLs by comparing the efficacy level of the representative 

product classes to efficacies of commercially available lamps from the non-representative 

product classes.

Item 22 DOE welcomes comments on the methodology to scale to products not directly 

analyzed.

6.7 Proprietary Designs 

DOE will consider in its engineering and economic analyses all design options that are 

commercially available or present in a working prototype, including proprietary designs, that 

meet the screening criteria discussed in section 5. However, DOE will consider a proprietary 

design in the subsequent analyses only if it does not represent a unique path to a given efficiency 

level. If the proprietary design is the only approach available to achieve a given efficiency level, 

then DOE will eliminate the efficiency level from further analysis. DOE will reject a standard 

level that can be met only with a proprietary technology because it could result in an anticompetitive market, a principle consistently applied in past DOE rulemakings as economically 

unjustifiable. However, if a given energy efficiency level can be achieved by a number of design 

approaches, including a proprietary design, DOE will continue to examine the given efficiency 

level. 

DOE is aware of manufacturer concerns about proprietary designs and will take steps to 

maintain the confidentiality of any proprietary data provided by manufacturers. This information 

will provide input to the competitive impacts assessment and other economic analyses. 

Item 23 DOE welcomes comments on proprietary designs it should be aware of for the GSLs

that are the subject of this rulemaking.

6.8 Outside Regulatory Changes Affecting the Engineering Analysis 

In conducting an engineering analysis, DOE considers the effects of regulations outside 

DOE’s statutory energy conservation standards rulemaking process that can affect manufacturers 

of the covered products. Some regulatory requirements can also affect the efficacy or energy 

consumption of the covered lamps. DOE will attempt to identify other regulatory requirements 

that could affect the engineering analysis. The consideration of these requirements is closely 

related to the cumulative regulatory burden assessment that DOE will conduct as part of the 

manufacturer impact analysis. Based on consideration of the comments received on the 

engineering analysis, DOE will make any necessary changes to its analysis. 

Item 24 DOE welcomes comments on regulatory burdens or changes that should be considered 

in the engineering analysis.

Item 25 DOE welcomes comments on other issues that could affect the engineering analysis.
26

7. ENERGY USE CHARACTERIZATION

The purpose of the energy-use characterization is to identify how products are used by 

consumers, and thereby determine the energy savings potential of energy efficiency 

improvements. DOE determines the energy consumption of lamps and lamp-and-ballast systems

through the rated power (i.e., the rate of energy they consume) and the way consumers use the 

lamp (i.e., operating hours per year). This analysis, which is meant to represent typical energy 

consumption in the field, is an input to both the LCC and PBP analyses and the NIA. DOE 

derives the annual energy consumption of lamps and lamp-and-ballast systems by multiplying 

the power rating by the number of hours of operation per year. 

DOE plans to use the 2010 U.S. Lighting Market Characterization (LMC)10 to determine 

operating hours. The LMC is based on thousands of building audits and surveys and provides 

national-level data on operating hours by building type and lamp type for all sectors. Within the 

residential sector, the distribution is broken down by room type. In conjunction with data from 

the LMC, DOE plans to use data from the recent versions of Energy Information 

Administration’s (EIA) 2003 Commercial Building Energy Consumption Survey (CBECS)11, 

2009 Residential Energy Consumption Survey (RECS)12, and 2006 Manufacturing Energy 

Consumption Survey (MECS).13 These EIA studies provide information on the distribution of 

buildings within the U.S., by building type and census division. DOE plans to use the LMC’s 

operating hour data by building type and the EIA’s data by building type and census division to 

derive annual operating hours by census division. This would allow DOE to correlate the 

electricity price distribution and sales tax distribution with the operating hour distribution by 

census division in the LCC spreadsheet.

Item 26 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.

8. PRODUCT PRICE DETERMINATION

The purpose of the engineering analysis and product price determination together is to 

provide an analysis of the relationship between the efficacy and end-user price for GSLs. DOE 

intends to obtain manufacturers’ published end-user price schedules for lamps (hereafter called 

the manufacturer’s “blue book” or “lamp price schedules”) as well as information on discounts 

applied to those price schedules for potential distribution channels such as State procurement 

 

10 U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, Energy Conservation Program 

for Consumer Products: 2010 U.S. Lighting Market Characterization (2012). Available at: 

http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf.

11 U.S. Department of Energy, Energy Information Administration, Commercial Building Energy Consumption 

Survey: Micro-level data, file 2 Building Activities, Special Measures of Size, and Multi-building Facilities (2003). 

Available at: www.eia.doe.gov/emeu/cbecs/public_ use.html.

12 U.S. Department of Energy, Energy Information Administration, Residential Energy Consumption Survey: File 1: 

Housing Unit Characteristic (2006). Available at: www.eia.doe.gov/emeu/recs/recs2001/publicuse2001.html.

13 U.S. Department of Energy, Energy Information Administration. Manufacturing Energy Consumption Survey, 

Table 9.1: Enclosed Floorspace and Number of Establishment Buildings (2006) Available at: 

www.eia.gov/emeu/mecs/mecs2006/2006tables.html.
27

contracts, large electrical supply distributors, home improvement/hardware stores, and other 

sources of publicly available end-user prices, such as Internet retailers. 

For similar lamp technologies, DOE has observed a range of end-user prices paid for a 

given lamp, depending on the distribution channel through which it was purchased and the 

volume at which it was purchased. Thus, DOE intends to calculate three sets of discounts from 

the blue books, representing the range of low, medium, and high lamp prices for GSLs. The 

discounts DOE applies to blue book prices to derive the low, medium, and high prices are a 

constant markdown across all lamps. For those lamps where commercial (blue book) pricing are

not available, DOE extrapolates pricing from available lamps. Once DOE calculates end-user 

prices, DOE adds sales tax and, if appropriate, installation costs to derive the total, installed enduser cost.

In addition, as part of the product price determination DOE is considering conducting a 

price trends analysis. As noted in a Notice of Data Availability published by DOE, economic 

literature and historical data suggest that the real costs of many covered products have trended 

downward over time according to ‘‘experience’’ curves. 76 FR 9696, 9697 (Feb. 22, 2011). DOE 

will investigate various methods for forecasting future prices of GSLs. 

Item 27 DOE welcomes comments on the methodology it is considering for lamp prices for this 

rulemaking.

Item 28 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.

Item 29 DOE welcomes comment on the availability of blue books or price schedules for the 

lamp technologies covered in this rulemaking, particularly LED lamps.

Item 30 DOE also welcomes comment on price forecasting methodologies for GSLs.

9. LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS

The effects of increased energy conservation standards on consumers include a change in 

their operating expenses (usually decreased) and a change in the purchase price (usually 

increased). The LCC of a product is the cost a product incurs over its lifetime, taking into 

account both purchase price, operating costs (including energy expenditures), and installation 

costs. The PBP represents the time it takes to recover the additional installed cost of the moreefficient product through annual operating cost savings. DOE analyzes the net effect on 

consumers by calculating the LCC and PBP using the engineering performance data (section 6), 

the energy-use data (section 7), and the product price determination (section 8). Inputs to the 

LCC calculation include the installed cost to the consumer (purchase price plus installation cost), 

operating expenses (energy expenses, and, if applicable, repair costs and maintenance costs), the 

lifetime of the product or other defined period of analysis, and a discount rate. Inputs to the PBP
28

calculation include the installed cost to the consumer and annual operating costs. DOE will 

conduct the LCC and PBP analyses using a spreadsheet model developed in Microsoft Excel. 

When combined with the Crystal Ball model (a commercially available software program), the 

LCC and PBP model generates a Monte Carlo14 simulation to perform the analysis by 

incorporating uncertainty and variability considerations. 

DOE is considering incorporating a residual value calculation to account for any 

remaining lifetime of lamps at the end of the analysis period. The residual value is an estimate of 

the product’s value to the consumer at the end of the life-cycle cost analysis period. This residual 

value recognizes that a lamp system may continue to function beyond the end of the analysis 

period. DOE calculates the residual value by linearly prorating the product’s initial cost 

consistent with the methodology described in the Life-Cycle Costing Manual for the Federal 

Energy Management Program.

15

DOE plans to use a “simple” PBP for this rulemaking which is the ratio of the increase in 

purchase cost (i.e., from a less efficient design to a more efficient design) to the decrease in 

annual operating expenditures. The “simple” PBP does not take into account other changes in 

operating expenses over time or the time value of money, and is calculated at an effective 

discount rate of zero. As inputs to the PBP analysis, DOE uses the total installed cost of the 

product to the consumer for each efficacy level, as well as the first year annual operating costs 

for each efficacy level. The calculation requires the same inputs as the LCC, except for energy 

price trends and discount rates; only energy prices for the year the standard takes effect are 

needed. 

Section 325(o)(2)(B)(iii) of EPCA states that there is a rebuttable presumption that an 

energy conservation standard is economically justified if the increased installed cost for a 

product that meets the standard is less than three times the value of the first-year energy savings 

resulting from the standard, as calculated under the applicable DOE test procedure. (42 U.S.C. 

6295(o)(2)(B)(iii)) DOE’s LCC and PBP analyses generate values that calculate the payback 

period for consumers of potential energy conservation standards, which includes, but is not 

limited to, the three-year payback period contemplated under the rebuttable presumption test. 

However, DOE routinely conducts a full economic analysis that considers the full range of 

impacts, including those to the consumer, manufacturer, nation, and environment, as required 

under 42 U.S.C. 6295(o)(2)(B)(i). The results of this analysis serve as the basis for DOE to 

evaluate the economic justification for a potential standard level (thereby supporting or rebutting 

the results of any preliminary determination of economic justification). 

Item 31 DOE welcomes comments on the approach it is considering to conduct the LCC and 

PBP analyses.

 

14 Monte Carlo simulations model uncertainty by utilizing probability distributions instead of single values for 

certain inputs and variables.

15 Fuller, Sieglinde K. and Stephen R. Peterson, National Institute of Standards and Technology Handbook 135 

(1996 Edition); Life-Cycle Costing Manual for the Federal Energy Management Program (Prepared for U. S. 

Department of Energy, Federal Energy Management Program, Office of the Assistant Secretary for Conservation 

and Renewable Energy)(Feb. 1996). Available at: http://fire.nist.gov/bfrlpubs/build96/PDF/b96121.pdf.
29

10. SHIPMENTS ANALYSIS 

DOE forecasts product shipments to calculate the national impacts of standards on energy

consumption, NPV, and future manufacturer cash flows. DOE plans to develop shipments 

projections based on analysis of the key market drivers for GSLs.

10.1 Base Case Forecast and Accounting Methodology

To evaluate the various impacts of standards, DOE must develop a base case forecast 

against which to compare forecasts for higher efficacy levels. The base case forecast is designed 

to depict what will happen to energy consumption and energy costs over time if DOE does not 

adopt amended energy conservation standards for the products covered by this rulemaking. In 

determining the base case forecast, DOE will consider historical shipments, the mix of efficacies 

sold under current standards, and how that mix might change over time.

Item 32 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.

10.2 Impacts of Standards on Shipments 

For each product class, DOE plans to forecast shipments over the 30-year analysis period 

for each of the potential standards analyzed. These standards case forecasts would be used to 

evaluate the impacts of standards on shipments. Standards case forecasts are derived using the 

same data-sets as base case forecasts; however, because the standards case forecasts take into 

account the increase in purchase price and the decrease in operating costs caused by new or 

amended standards, forecasted shipments could deviate from the base case.

Programs such as consumer rebates that encourage the purchase of more-efficient 

products and manufacturer tax credits that encourage the production of more-efficient products 

also affect standards case forecasts. When such programs exist at the federal level, DOE 

considers their impact on the forecast of both standards case and base case shipments.

Item 33 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.

11. NATIONAL IMPACT ANALYSIS 

The NIA provides DOE’s assessment of the aggregate impacts of potential efficiency 

standards at the national level. Measures of impact that DOE will report include future NES from 

CSLs (i.e., the cumulative incremental primary energy savings from an increased energy 

conservation standard relative to a base case that assumes no change in the energy conservation 

national standard over a specific forecast period) and the NPV for consumers in the aggregate 

from CSLs (i.e., the cumulative incremental LCC from an increased energy conservation 

standard relative to the base case over a specific forecast period). 
30

11.1 Calculation of National Energy Savings

DOE intends to calculate national energy consumption for each year beginning with the 

expected compliance date of the standards. DOE would calculate national energy consumption 

for the base case and each standard level analyzed. DOE plans to perform this calculation 

through the use of a spreadsheet model that effectively accounts for the stock of products 

affected by standards.16 The energy savings are measured over the lifetime of products purchased 

in the 30-year projection period.17

DOE has historically presented NES in terms of primary energy savings. On August 18, 

2011, DOE announced its intention to use full-fuel-cycle (FFC) measures of energy use and 

greenhouse gas and other emissions in the national impact analyses and emissions analyses 

included in future energy conservation standards rulemakings. (76 FR 51282) While DOE stated 

in that notice that it intended to use the Greenhouse Gases, Regulated Emissions, and Energy 

Use in Transportation (GREET) model to conduct the analysis, it also said it would review 

alternative methods, including the use of the National Energy Modeling System (NEMS). After 

evaluating both models and the approaches discussed in the August 18, 2011 notice, DOE has 

determined NEMS is a more appropriate tool for this analysis. 77 FR 49701 (August 17, 2012). 

Therefore, DOE intends to use NEMS to conduct FFC analyses.

Item 34 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. 

11.2 Net Present Value 

DOE calculates the national NPV of the standards in conjunction with the NES. It 

calculates annual energy expenditures from annual energy consumption by incorporating 

forecasted energy prices, using the shipment forecasts described in the shipments analysis and 

electricity savings forecasts. DOE calculates annual product expenditures by multiplying the 

price per unit by the forecasted shipments. The difference between a base case and a standards 

case scenario gives the national energy bill savings and increased product expenditures in 

dollars. The difference each year between energy bill savings and increased product expenditures 

is the net savings (if positive) or net cost (if negative). DOE discounts these annual values to the 

present time and sums them to give an NPV. Since the national cost of capital may differ from 

the consumer cost of capital, the discount rate used in the NIA can be different from the rate used 

in the LCC. In accordance with U.S. Office of Management and Budget (OMB) guidance, DOE 

will conduct two NPV calculations, one using a real discount rate of 3 percent and another using 

 

16 Several examples of NES spreadsheet models from previous rulemakings can be found on DOE’s website at: 

www.eere.energy.gov/buildings/appliance_standards/. 

17 In the past, DOE presented energy savings results for only the 30-year period that begins in the year of 

compliance. In the calculation of economic impacts, however, DOE considered operating cost savings measured 

over the entire lifetime of products purchased in the 30-year period. DOE has chosen to modify its presentation of 

national energy savings to be consistent with the approach used for its national economic analysis 
31

a real discount rate of 7 percent.18 Based on consideration of the comments received for the 

preliminary analysis, DOE will make any necessary changes to the analysis and the CSLs.

Item 35 DOE welcomes comments on the inputs and methodology to calculate NES and NPV. 

12. LIFE-CYCLE COST SUBGROUP ANALYSIS 

The LCC (consumer) subgroup analysis evaluates economic impacts on selected groups 

of consumers who might be adversely affected by a change in the national energy conservation 

standards for the considered products. DOE evaluates impacts on particular subgroups of 

consumers primarily by analyzing the LCC impacts and PBP for those particular consumers. In 

comparing potential impacts on the different consumer subgroups, DOE will evaluate variations 

in energy prices, energy use, and installation costs that might affect the impacts of a standard on 

the consumer subgroups. DOE seeks input regarding which consumer subgroups it should 

consider in this rulemaking. Examples of potential consumer subgroups include low-income 

consumers and institutions serving low-income consumers.

Item 36 DOE seeks input regarding which consumer subgroups it should consider in this

rulemaking.

13. MANUFACTURER IMPACT ANALYSIS 

The manufacturer impact analysis will assess the potential impacts of energy 

conservation standards on manufacturers of GSLs. A wide range of quantitative and qualitative 

effects may occur following the adoption of standards that may require changes to manufacturing 

practices. DOE will identify these potential effects through interviews with manufacturers and 

other experts.

For the NOPR, DOE will conduct an industry-wide cash-flow analysis using the 

Government Regulatory Impact Model (GRIM), identify and analyze subgroups of 

manufacturers whose businesses vary significantly from the industry as a whole, perform a 

competitive impacts assessment, and review the cumulative regulatory burden for the industry.

13.1 Sources of Information

Many of the analyses described earlier provide important information that DOE uses as 

inputs for the MIA. Such information includes financial parameters developed in the market 

assessment (section 4.1), cost data developed in the product price determination (section 8), and 

shipments projections (section 10). DOE supplements this data with information gathered during 

manufacturer interviews. The interview process will play a key role in the MIA, as it provides an 

opportunity for interested parties to express their views on important issues.

DOE will conduct detailed interviews with manufacturers to gain insight into the range of 

potential impacts of standards. During the interviews, DOE will solicit information on the 

 

18 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003).
32

possible impacts of standards on manufacturing costs, product prices, sales, direct employment, 

capital assets, and industry competitiveness. Both qualitative and quantitative information are 

valuable. DOE will schedule interviews well in advance to provide every opportunity for key 

individuals to be available. Although a written response to the questionnaire is acceptable, DOE 

prefers an interactive interview process because it helps clarify responses and provides the 

opportunity for additional issues to be identified.

DOE will ask that interview participants identify all confidential information provided, 

both in writing and orally. While it will consider information gathered, as appropriate, in its 

decision-making process, DOE will protect confidential information from disclosure consistent 

with applicable law. 

DOE will collate the information from interviews and prepare a summary of the major 

issues and outcomes. This summary will become part of the TSD produced for this rulemaking.

13.2 Industry Cash Flow Analysis

The industry cash flow analysis relies primarily on the GRIM. DOE uses the GRIM to 

analyze the financial impacts of more-stringent energy conservation standards on the industry 

that manufactures the products covered by the standard. 

The GRIM analysis uses a number of factors—annual expected revenues; costs of goods 

sold; selling, general, and administrative costs; taxes; and capital expenditures—to arrive at a 

series of annual cash flows beginning from the announcement of the standard and continuing 

through the analysis period. DOE compares the results against base-case projections that involve 

no amended standards. The financial impact of amended standards is then the difference between 

the two sets of discounted annual cash flows. Other performance metrics, such as return on 

invested capital, also are available from the GRIM.

DOE will gather inputs needed for the GRIM from two primary sources: (1) the analyses 

conducted to this point; and (2) interviews with manufacturers and other stakeholders. 

Information gathered from previous analyses will include financial parameters, manufacturing 

costs, price projections, and shipments projections. Interviews with manufacturers and other 

stakeholders will supplement this information.

13.3 Manufacturer Subgroup Analysis

Average industry cost values may not reveal differential impacts among GSL

manufacturer subgroups. Smaller manufacturers, niche players, and manufacturers exhibiting a 

cost structure that differs significantly from the industry average may be affected differently by 

amended standards. Ideally, DOE would consider the impact on every firm individually. In 

highly concentrated industries, this may be possible. However, for industries that have numerous 

participants, DOE will use the results of the market and technology assessment to group 

manufacturers into subgroups, as appropriate. For GSLs, DOE is interested in feedback about 

potential subgroups, including small businesses. DOE will conduct a Regulatory Flexibility Act 

analysis to determine the impacts of any amended standards on small businesses consistent with 

the Regulatory Flexibility Act.
33

Item 37 DOE seeks comments on the subgroups of the GSL manufacturers that it should 

consider in a manufacturer subgroup analysis.

Item 38 DOE seeks comment on small businesses that could be impacted by energy 

conservation standards for GSLs, and what those impacts might entail.

14. UTILITY IMPACT ANALYSIS 

To estimate the effects of energy conservation standards for covered GSLs on the electric 

utility industry, DOE plans to use a variant of EIA’s NEMS that is tailored to DOE’s Building 

Technologies Program (NEMS-BT). The utility impact analysis is a comparison between the 

NEMS-BT model results for the base case (the Annual Energy Outlook [AEO] reference case 

from the latest year available) and standards cases. The utility impact analysis reports the 

changes in installed electric capacity and generation that result for each standard level by plant 

type. DOE will model the impacts from energy conservation standards using NEMS-BT to 

generate standards case forecasts.19

Item 39 DOE welcomes comments on the approach it is considering to assess the impacts of 

potential standards under this rulemaking on electric utilities.

15. EMPLOYMENT IMPACT ANALYSIS

The promulgation of energy conservation standards can affect employment both directly 

and indirectly. Direct employment impacts are changes in the number of employees at the plants 

that produce the covered products. DOE will evaluate direct employment impacts through the 

use of the GRIM in the MIA (see section 13 for more information). 

Indirect employment impacts may result from expenditures shifting between goods (the 

substitution effect) and changes in income and overall expenditure levels (the income effect) that 

occur due to the standards. The short-term (5-year) combined direct and indirect employment 

impacts will be investigated in the employment-impact analysis using Pacific Northwest 

National Laboratory’s Impact of Sector Energy Technologies (ImSET) model. The ImSET 

model was developed for DOE’s Office of Planning, Budget, and Analysis, and estimates the 

employment and income effects of energy-saving technologies in buildings, industry, and 

transportation.20 In comparison with simple economic multiplier approaches, ImSET allows for 

more complete and automated analysis of the economic impacts of energy conservation 

investments. DOE believes that the complexity of potential adjustments in the U.S. economy 

largely negates the value of long-term projections of indirect employment impacts. 

 

19 Several descriptions of NEMS-BT models from previous rulemakings, including general service fluorescent 

lamps and incandescent reflector lamps, can be found on DOE’s website at: 

www.eere.energy.gov/buildings/appliance_standards/residential/pdfs/ch_14_lamps_standards_final_tsd.pdf.

20 Roop, J. M., M. J. Scott, and R. W. Schultz, ImSET 3.1: Impact of Sector Energy Technologies (PNNL-18412 

Pacific Northwest National Laboratory) (2008). Available at 

www.pnl.gov/main/publications/external/technical_reports/PNNL-18412.pdf.
34

Item 40 DOE welcomes comments on the approach it is considering to assess employment 

impacts as a result of energy conservation standards.

16. EMISSIONS ANALYSIS

In the emissions analysis, DOE will estimate the reduction in power sector emissions of 

carbon dioxide (CO2), nitrogen oxides (NOX), sulfur dioxide (SO2) and mercury (Hg) from 

potential energy conservation standards for the considered products. In addition, DOE will 

estimate emissions impacts in production activities (extracting, processing, and transporting 

fuels) that provide the energy inputs to power plants. These are referred to as “upstream” 

emissions. Together, these emissions account for the FFC. In accordance with DOE’s FFC 

Statement of Policy (76 FR 51282 (Aug. 18, 2011)), the FFC analysis includes impacts on 

emissions of methane and nitrous oxide, both of which are recognized as greenhouse gases. 

DOE conducts the emissions analysis using emissions factors derived from data in the 

latest version of EIA’s AEO, supplemented by data from other sources. EIA prepares the AEO

using NEMS. Each annual version of NEMS incorporates the projected impacts of existing air 

quality regulations on emissions. The text below refers to AEO 2013, which generally represents 

current legislation and environmental regulations, including recent government actions, for 

which implementing regulations were available as of December 31, 2012. DOE will consider 

using the most recent version of AEO at the time of the analysis.

SO2 emissions from affected electric generating units (EGUs) are subject to nationwide 

and regional emissions cap and trading programs. Title IV of the Clean Air Act sets an annual 

emissions cap on SO2 for affected EGUs in the 48 contiguous states and the District of Columbia 

(D.C.). SO2 emissions from 28 eastern states and D.C. were also limited under the Clean Air 

Interstate Rule (CAIR), which created an allowance-based trading program that operates along 

with the Title IV program in those States and D.C. 70 FR 25162 (May 12, 2005). CAIR was 

remanded to EPA by the U.S. Court of Appeals for the District of Columbia Circuit (D.C. 

Circuit), but it remained in effect. See North Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008); 

North Carolina v. EPA, 531 F.3d 896 (D.C. Cir. 2008). On July 6, 2011 EPA issued a 

replacement for CAIR, the Cross-State Air Pollution Rule (CSAPR). 76 FR 48208 (August 8, 

2011). On August 21, 2012, the D.C. Circuit issued a decision to vacate CSAPR. See EME 

Homer City Generation, LP v. EPA, 696 F.3d 7, 38 (D.C. Cir. 2012). The court ordered EPA to 

continue administering CAIR. AEO 2013 assumes that CAIR remains a binding regulation 

through 2040.

The attainment of emissions caps is typically flexible among EGUs and is enforced 

through the use of emissions allowances and tradable permits. Under existing EPA regulations, 

any excess SO2 emissions allowances resulting from the lower electricity demand caused by the 

adoption of an efficiency standard could be used to permit offsetting increases in SO2 emissions 

by any regulated EGU. In past rulemakings, DOE recognized that there was uncertainty about 

the effects of efficiency standards on SO2 emissions covered by the existing cap-and-trade 

system, but it concluded that no reductions in power sector emissions would occur for SO2 as a 

result of standards.
35

Beginning in 2015, however, SO2 emissions will fall as a result of the Mercury and Air 

Toxics Standards (MATS) for power plants, which were announced by EPA on December 21, 

2011. 77 FR 9304 (Feb. 16, 2012). In the final MATS rule, EPA established a standard for HCl 

as a surrogate for acid gas hazardous air pollutants (HAP), and also established a standard for 

SO2 (a non-HAP acid gas) as an alternative equivalent surrogate standard for acid gas HAP. The 

same controls are used to reduce HAP and non-HAP acid gas; thus, SO2 emissions will be 

reduced as a result of the control technologies installed on coal-fired power plants to comply 

with the MATS requirements for acid gas. AEO 2013 assumes that, in order to continue 

operating, coal plants must have either flue gas desulfurization or dry sorbent injection systems 

installed by 2015. Both technologies, which are used to reduce acid gas emissions, also reduce 

SO2 emissions. Under the MATS, NEMS shows a reduction in SO2 emissions when electricity 

demand decreases (e.g., as a result of energy efficiency standards). Emissions will be far below 

the cap that would be established by CAIR, so it is unlikely that excess SO2 emissions 

allowances resulting from the lower electricity demand would be needed or used to permit 

offsetting increases in SO2 emissions by any regulated EGU. Therefore, DOE believes that 

efficiency standards will reduce SO2 emissions in 2015 and beyond.

CAIR established a cap on NOX emissions in eastern States and the District of Columbia. 

Energy conservation standards are expected to have little or no physical effect on these emissions 

in those States covered by CAIR because excess NOx emissions allowances resulting from the 

lower electricity demand could be used to permit offsetting increases in NOx emissions. 

However, standards would be expected to reduce NOx emissions in the States not affected by the 

caps, so DOE estimates NOX emissions reductions from potential standards in the States where 

emissions are not capped.

The MATS limit mercury emissions from power plants, but they do not include emissions 

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

will estimate mercury emissions reduction using emissions factors based on AEO 2013, which 

incorporates the MATS.

Power plants may emit particulates from the smoke stack, which are known as direct 

particulate matter (PM) emissions. NEMS does not account for direct PM emissions from power 

plants. DOE is investigating the possibility of using other methods to estimate reduction in PM 

emissions due to standards. The great majority of ambient PM associated with power plants is in 

the form of secondary sulfates and nitrates, which are produced at a significant distance from 

power plants by complex atmospheric chemical reactions that often involve the gaseous 

emissions of power plants, mainly SO2 and NOx. The monetary benefits that DOE estimates for 

reductions in SO2 and NOx emissions resulting from standards are in fact primarily related to the 

health benefits of reduced ambient PM.

Item 41 DOE seeks input on the approach it plans to use to conduct the emissions analysis for 

the products covered by this rulemaking.
36

17. MONETIZING CARBON DIOXIDE AND OTHER EMISSIONS REDUCTIONS

DOE plans to consider the estimated monetary benefits likely to result from the reduced 

emissions of CO2 and NOX that are expected to result from each of the standard levels 

considered.

To estimate the monetary value of benefits resulting from reduced emissions of CO2, 

DOE plans to use the most current Social Cost of Carbon (SCC) values developed and/or agreed 

to by an interagency process. The SCC is intended to be a monetary measure of the incremental 

damage resulting from greenhouse gas (GHG) emissions, including, but not limited to, net 

agricultural productivity loss, human health effects, property damage from sea level rise, and 

changes in ecosystem services. Any effort to quantify and to monetize the harms associated with 

climate change will raise serious questions of science, economics, and ethics. But with full 

regard for the limits of both quantification and monetization, the SCC can be used to provide 

estimates of the social benefits of reductions in GHG emissions.

The Interagency Working Group on Social Cost of Carbon released an update of its 

previous report in 2013.21 The most recent estimates of the SCC in 2015, expressed in 2012$, are 

$12.9, $40.8, $62.2, and $117 per metric ton of CO2 avoided. For emissions reductions that occur 

in later years, these values grow in real terms over time. Additionally, the interagency group 

determined that a range of values from 7 percent to 23 percent should be used to adjust the global 

SCC to calculate domestic effects, although DOE will give preference to consideration of the 

global benefits of reducing CO2 emissions. 

DOE multiplies the CO2 emissions reduction estimated for each year by the SCC value 

for that year in each of the four cases. To calculate a present value of the stream of monetary 

values, DOE discounts the values in each of the four cases using the discount rates that had been 

used to obtain the SCC values in each case.

DOE recognizes that scientific and economic knowledge continues to evolve rapidly as to 

the contribution of CO2 and other GHG to changes in the future global climate and the potential 

resulting damages to the world economy. Thus, these values are subject to change. 

DOE also estimates the potential monetary benefit of reduced NOX emissions resulting 

from the standard levels it considers. Estimates of monetary value for reducing NOx from 

stationary sources range from $468 to $4,809 per ton in 2012$.22 In accordance with OMB 

guidance,23 DOE calculates monetary benefits using a medium value for NOX emissions of 

$2,639 per short ton (in 2012$), and real discount rates of 3 percent and 7 percent.

 

21 Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866. 

Interagency Working Group on Social Cost of Carbon, United States Government, May 2013. 

http://www.whitehouse.gov/sites/default/files/omb/inforeg/social_cost_of_carbon_for_ria_2013_update.pdf

22 U.S. Office of Management and Budget, Office of Information and Regulatory Affairs, 2006 Report to Congress 

on the Costs and Benefits of Federal Regulations and Unfunded Mandates on State, Local, and Tribal Entities, 

Washington, DC.

23 OMB, Circular A-4: Regulatory Analysis, 2003 (Posted Sept. 17, 2003).
37

DOE is evaluating appropriate valuation of avoided SO2 and Hg emissions. Whether 

monetization of reduced Hg emissions will occur in this rulemaking is yet to be determined.

Item 42 DOE requests comments on the approach it plans to use for estimating monetary 

benefits associated with emissions reductions.

18. REGULATORY IMPACT ANALYSIS

Pursuant to section 6(a)(3) of Executive Order 12866, “Regulatory Planning and 

Review,” 58 FR 51735 (Oct. 4, 1993), if DOE determines that amended energy conservation 

standards for GSLs constitute a significant regulatory action, during the NOPR stage of this 

rulemaking DOE will prepare and submit to OMB: (1) an assessment of the costs and benefits of 

the proposed regulation, and (2) if the proposed rule is also significant under section 3(f)(1) of 

the E.O. 12866, a Regulatory Impact Analysis (RIA) which is subject to review under the 

Executive Order by the Office of Information and Regulatory Affairs (OIRA) at the OMB. The 

RIA will address the potential for non-regulatory approaches to supplant or augment energy 

conservation standards to improve the energy efficiency or reduce the energy consumption of 

GSLs covered under this rulemaking.

DOE recognizes that voluntary or other non-regulatory efforts by manufacturers, utilities, 

and other interested parties can result in substantial improvements to energy efficiency or 

reductions in energy consumption. DOE will base its assessment on the actual impacts of any 

such initiatives to date, but also will consider information presented regarding the impacts that 

any existing initiative might have in the future.

Item 43 DOE welcomes comments on the methodology it is considering for the regulatory 

impact analysis.
38

APPENDIX A – LIST OF ITEMS FOR COMMENT 

This appendix lists all the items for comment contained in this Framework Document and the 

page numbers on which those items can be found.

Item 1 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. .................................................................................................................... 5

Item 2 DOE welcomes comment on definitions for compact fluorescent lamp and pin base 

compact fluorescent lamp. ............................................................................................................ 13

Item 3 DOE welcomes comment on a definition for general service LED lamp. ........................ 14

Item 4 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. ................................................................................................................................... 14

Item 5 DOE welcomes comment on a definition for hybrid lamp................................................ 15

Item 6 DOE welcomes comment on additional lamp types that should be considered in the scope 

of this rulemaking. ........................................................................................................................ 15

Item 7 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........................................ 15

Item 8 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). .... 16

Item 9 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. ...... 17

Item 10 DOE welcomes comment on any other class-setting factors that should be considered in 

the analysis.................................................................................................................................... 17

Item 11 DOE welcomes comment on a definition for the term “covered” that is applicable across 

technologies. ................................................................................................................................. 17

Item 12 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........................................................................................................................................... 20

Item 13 DOE welcomes comments on the applicability of the four screening criteria to the 

technology options listed in section 4.3........................................................................................ 20

Item 14 DOE welcomes comments on how the four screening criteria might apply to any 

additional technology option(s) than an interested party recommends to DOE. .......................... 20

Item 15 DOE welcomes comments on the overall methodology for the engineering analysis. ... 21

Item 16 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............................................................................................................................................ 22
39

Item 17 DOE welcomes comment on whether the characteristics of products with the highest 

shipment volume change depending on lamp technology. ........................................................... 22

Item 18 DOE welcomes comments on its proposed approach for selecting baseline lamps in this 

rulemaking. ................................................................................................................................... 23

Item 19 DOE welcomes comments on the methodology it is considering to select higher-efficacy 

lamp designs.................................................................................................................................. 24

Item 20 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. ................................................................................................................................. 24

Item 21 DOE welcomes comment on the use of compliance data and verification testing data 

when establishing efficacy levels.................................................................................................. 24

Item 22 DOE welcomes comments on the methodology to scale to products not directly 

analyzed. ....................................................................................................................................... 25

Item 23 DOE welcomes comments on proprietary designs it should be aware of for the GSLs that 

are the subject of this rulemaking. ................................................................................................ 25

Item 24 DOE welcomes comments on regulatory burdens or changes that should be considered 

in the engineering analysis............................................................................................................ 25

Item 25 DOE welcomes comments on other issues that could affect the engineering analysis. .. 25

Item 26 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. .............................................................................................................................. 26

Item 27 DOE welcomes comments on the methodology it is considering for lamp prices for this 

rulemaking. ................................................................................................................................... 27

Item 28 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. ......................................................................................................... 27

Item 29 DOE welcomes comment on the availability of blue books or price schedules for the 

lamp technologies covered in this rulemaking, particularly LED lamps...................................... 27

Item 30 DOE also welcomes comment on price forecasting methodologies for GSLs................ 27

Item 31 DOE welcomes comments on the approach it is considering to conduct the LCC and 

PBP analyses................................................................................................................................. 28

Item 32 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............................................................................................................................................... 29

Item 33 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.............................................................................. 29

Item 34 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. ............ 30

Item 35 DOE welcomes comments on the inputs and methodology to calculate NES and NPV. 31

Item 36 DOE seeks input regarding which consumer subgroups it should consider in this 

rulemaking. ................................................................................................................................... 31
40

Item 37 DOE seeks comments on the subgroups of the GSL manufacturers that it should 

consider in a manufacturer subgroup analysis. ............................................................................. 33

Item 38 DOE seeks comment on small businesses that could be impacted by energy conservation 

standards for GSLs, and what those impacts might entail............................................................ 33

Item 39 DOE welcomes comments on the approach it is considering to assess the impacts of 

potential standards under this rulemaking on electric utilities...................................................... 33

Item 40 DOE welcomes comments on the approach it is considering to assess employment 

impacts as a result of energy conservation standards. .................................................................. 34

Item 41 DOE seeks input on the approach it plans to use to conduct the emissions analysis for the 

products covered by this rulemaking. ........................................................................................... 35

Item 42 DOE requests comments on the approach it plans to use for estimating monetary benefits 

associated with emissions reductions............................................................................................ 37

Item 43 DOE welcomes comments on the methodology it is considering for the regulatory 

impact analysis.............................................................................................................................. 37