7A-i

APPENDIX 12A. PRELIMINARY MANUFACTURER INTERVIEW GUIDE 

TABLE OF CONTENTS 

12A.1 INTRODUCTION ................................................................................................ 12A-1

12A.2 GENERAL SERVICE FLUORESCENT LAMPS ............................................... 12A-2

12A.3 INCANDESCENT REFLECTOR LAMPS ........................................................ 12A-15

LIST OF TABLES 

Table 12A.1 Ballast Pairings by Product Class ...................................................................... 12A-4

Table 12A.2 GSFL Product Classes ....................................................................................... 12A-5

Table 12A.3 4-foot Medium Bipin (CCT ≤ 4500K) Engineering Analysis ........................... 12A-7

Table 12A.4 8-foot Single Pin Slimline (CCT ≤ 4500K) Engineering Analysis .................... 12A-7

Table 12A.5 8-foot Recessed Double Contact High Output (CCT ≤ 4500K) Engineering 

Analysis..................................................................................................... 12A-8

Table 12A.6 4-foot Miniature Bipin Standard Output (CCT ≤ 4500K) Engineering 

Analysis at 35°C ........................................................................................ 12A-8

Table 12A.7 4-foot Miniature Bipin High Output (CCT ≤ 4500K) Engineering Analysis 

at 35°C ....................................................................................................... 12A-8

Table 12A.8 Product Classes Under Consideration .............................................................. 12A-17

Table 12A.9 PAR 38 Engineering Analysis ......................................................................... 12A-18
12A-1

APPENDIX 12A. PRELIMINARY MANUFACTURER INTERVIEW GUIDE 

12A.1 INTRODUCTION 

This appendix contains a copy of the interview guides used for the preliminary 

manufacturer impact analysis (MIA), described in chapter 12 of this preliminary technical 

support document (TSD). The U.S. Department of Energy (DOE) developed two separate 

interview guides, one for general service fluorescent lamps and one for incandescent reflector 

lamps. The contractor to DOE who conducted the preliminary manufacturer interviews circulated 

the interview guides to a limited number of manufacturers of fluorescent and incandescent lamps 

who operate in the U.S. market. 
12A-2

12A.2 GENERAL SERVICE FLUORESCENT LAMPS 

In July 2009, the U.S. Department of Energy (DOE) published a final rule for general service 

fluorescent lamp (GSFL) standards (hereafter the 2009 Lamps Rule). DOE is now conducting 

another rulemaking to evaluate amending energy conservation standards for GSFLs. As the first 

step in this process, DOE published a framework document in September 2011 that describes the 

procedural and analytical approaches DOE anticipates using to evaluate potential energy 

conservation standards.a

1 SCOPE OF COVERAGE 

1.1 Currently DOE covers fluorescent lamps defined as follows: 

DOE defines a fluorescent lamp as a low pressure mercury electric-discharge source in which a 

fluorescing coating transforms some of the ultraviolet energy generated by the mercury discharge 

into light, including only the following: 

(1) Any straight-shaped lamp (commonly referred to as 4-foot medium bipin lamps) with 

medium bipin bases of nominal overall length of 48 inches and rated wattage of 25 or 

more; 

(2) Any U-shaped lamp (commonly referred to as 2-foot U-shaped lamps) with medium 

bipin bases of nominal overall length between 22 and 25 inches and rated wattage of 25 

or more; 

(3) Any rapid start lamp (commonly referred to as 8-foot high output lamps) with 

recessed double contact bases of nominal overall length of 96 inches; 

(4) Any instant start lamp (commonly referred to as 8-foot slimline lamps) with single pin 

bases of nominal overall length of 96 inches and rated wattage of 52 or more; 

(5) Any straight-shaped lamp (commonly referred to as 4-foot miniature bipin standard 

output lamps) with miniature bipin bases of nominal overall length between 45 and 48 

inches and rated wattage of 26 or more; and 

(6) Any straight-shaped lamp (commonly referred to 4-foot miniature bipin high output 

lamps) with miniature bipin bases of nominal overall length between 45 and 48 inches 

and rated wattage of 49 or more. 

DOE defines a general service fluorescent lamp as any fluorescent lamp which can be used to 

satisfy the majority of fluorescent lighting applications, but does not include any lamp designed 

and marketed for the following nongeneral application: 

(1) Fluorescent lamps designed to promote plant growth; 

(2) Fluorescent lamps specifically designed for cold temperature applications; 

(3) Colored fluorescent lamps; 

(4) Impact-resistant fluorescent lamps; 

 

a

 The framework document is available on DOE’s website at: 

http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/gsfl_irl_ecs_framework.pdf. 
12A-3

(5) Reflectorized or aperture lamps; 

(6) Fluorescent lamps designed for use in reprographic equipment; 

(7) Lamps primarily designed to produce radiation in the ultra-violet region of the 

spectrum; and 

(8) Lamps with a Color Rendering Index of 87 or greater. 

In the framework document, DOE considered evaluating standards for additional types of GSFL 

with shapes and lengths other than the ones already covered by standards. These included: 1) 

pin-based compact fluorescent lamps (CFLs), 2) non-linear fluorescent lamps (e.g. circline), and 

3) fluorescent lamps with alternate lengths (e.g. 2-,3-,5-foot). Should DOE cover the GSFLs 

listed above or any additional GSFLs not mentioned? 

1.2 DOE has identified additional reduced wattage lamps (e.g. 49 watts (W) 8-foot slimline 

lamps, 25W 4-foot miniature bipin standard output lamps, 44W 4-foot miniature bipin high 

output lamps). Should these be included in the scope of coverage? 

1.3 How do you define impact-resistant fluorescent lamps? Which of your product lines meet 

the definition of impact-resistant? 

1.4 In the 2009 Lamps Rule, DOE decided not to expand coverage to include very high output 

(VHO) fluorescent lamps. What characteristics of VHO lamps are different from high 

output and standard output lamps? What is the percent of VHO lamps sold and how has it 

changed in recent years? 

1.5 Based on catalog information, it appears that efficacy decreases substantially at a color 

rendering index (CRI) of 87. Why is efficacy significantly lower for a lamp with a CRI of 

87 compared to a lamp with a CRI of 86? 

2 MARKET ANALYSIS 

2.1 How do consumers select a fluorescent lamp? What parameters are they most interested 

in? Do they weigh input power or light output more heavily? 

2.2 In order to calculate the aggregate national energy savings, DOE needs data on shipment 

trends. For each of the lamp types covered in this rulemaking (listed below) DOE is 

interested in obtaining shipment data: 

 4-foot medium bipin 

 8-foot single pin slimline 

 8-foot recessed double contact high output 

 2-foot U-shaped 

 4-foot T5 miniature bipin standard output 

 4-foot T5 miniature bipin high output 

What are the percent of shipments for each of the covered lamp types? Please indicate the year of 
12A-4

data provided. Absent new energy conservation standards, do you expect these proportions to 

change overtime? If so, how? 

What are the percent of shipments for each of the covered lamp types with CCT <=4500K and 

CCT > 4500K? Please indicate the year of data provided. Absent new energy conservation 

standards, do you expect these proportions to change overtime? If so, how? 

What are the percent of shipments for each of the covered lamp types that are high efficiency 

versus standard efficiency? Please indicate the year of data provided. Absent new energy 

conservation standards, do you expect these proportions to change overtime? If so, how? 

For each of the lamp types covered, what GSFL lamp wattages are most common? What percent 

of shipments are represented by each of these wattages? Absent new energy conservation 

standards, do you expect these proportions to change overtime? If so, how? 

2.3 Do you expect T12 lamps to be available in 2017? Please explain why or why not. 

2.4 Based on shipment information from the 2011 Fluorescent Ballast Rule, DOE is 

considering analyzing the lamp-and-ballast pairings listed in Table 12A.1. Please verify 

that the following pairings represent the most common lamp-and-ballast systems used. 

Table 12A.1 Ballast Pairings by Product Class

Lamp Type Ballast Type

4-foot medium bipin 2-lamp instant start/rapid start (IS/RS)

2-lamp programmed start (PS)

4-lamp IS/RS

4-lamp PS

2-lamp IS/RS for residential use

8-foot single pin slimline 2-lamp IS/RS

8-foot recessed double contact high 

output

2-lamp IS/RS

4-foot T5 standard output miniature 

bipin 

2-lamp PS

4-foot T5 high output miniature bipin 2-lamp PS

2.5 What percent of ballasts that operate 4-foot medium bipin lamps are programmed start 

ballasts and what percent are instant start/rapid start ballasts? 

2.6 DOE intends to consider GSFLs operating in different sectors. For the GSFLs under 

consideration in this rulemaking, can you provide an estimate of the percent of GSFLs sold 

into the commercial, industrial, and residential sectors? 

2.7 What percent of lamps are sold in the new renovation/construction market and the 
12A-5

replacement market? 

2.8 What are general trends you see in the market? Absent new energy conservation standards, 

do you foresee other technologies (e.g., high intensity discharge lamps or light emitting 

diodes) increasing in market share over the next thirty years? If so, how? 

2.9 Do you expect future market shares for the most common GSFL types to change in the 

presence of new energy conservation standards for GSFLs? 

3 TECHNOLOGY ASSESSMENT AND SCREENING ANALYSIS 

3.1 How is GSFL efficacy expected to change over time? Are research and development 

efforts focused on these products? 

3.2 DOE seeks comment on why lamps that utilize high efficiency phosphors such as 700 

series rare earth phosphors can be equal in efficiency to 800 series lamps. 

4 PRODUCT CLASSES 

4.1 DOE separates products into categories called product classes based on differences in 

efficacy and consumer utility (i.e., features valued by consumers). DOE then conducts its 

analyses and establishes separate standard levels for each product class. DOE is 

considering separating product classes based on lamp shape and length; lumen package 

(i.e., standard versus high output); and correlated color temperature (CCT) as shown in the 

table below. Do you agree with the product class divisions presented below? Are there 

other parameters that should be considered in defining product classes for GSFLs? 

Table 12A.2 GSFL Product Classes 

Lamp Type CCT Division

4-foot medium bipin CCT ≤ 4500K

CCT >4500K and ≤ 7000K

2-foot U-shaped CCT ≤ 4500K

CCT >4500K and ≤ 7000K

8-foot single pin slimline CCT ≤ 4500K

CCT >4500K and ≤ 7000K

8-foot recessed double contact high output CCT ≤ 4500K

CCT >4500K and ≤ 7000K

4-foot miniature bipin standard output CCT ≤ 4500K

CCT >4500K and ≤ 7000K

4-foot miniature bipin high output CCT ≤ 4500K

CCT >4500K and ≤ 7000K

* Gray shading indicates representative product classes. 

4.2 DOE selects certain product classes (called representative product classes) to directly 
12A-6

analyze in detail. The representative product classes are selected primarily based on 

shipment volume. For GSFLs DOE is directly analyzing all covered lamp types with CCTs 

less than or equal to 4,500K with the exception of 2-foot U-shaped lamps (see shaded areas 

of tables above). Do you agree with the representative product classes under consideration? 

4.3 Based on catalog and certification reports, DOE found that the expected trend of efficacy 

decreasing for a CCT higher than 4,500K did not always hold true. DOE found that some 

catalogs and certification reports stated the same efficacy for lamps across all CCT values. 

DOE seeks information on the division of product classes by CCT; specifically the 

following: 

 How does CCT impact efficacy? At what CCT does efficacy decrease and why? 

 Is the impact of CCT on lamp efficacy greater for certain lamp types? 

4.4 Do 4-foot T5 miniature bipin lamps serve as replacements for 4-foot medium bipin lamps 

in practice? Are there conditions under which they cannot serve as replacements? 

If length is an issue, are there conversion kits available? 

If application is an issue (i.e. T5 miniature bipin used in indirect lighting rather than direct 

lighting), can the use of a reflector convert one type to another? How does direct lighting differ 

from indirect lighting? 

5 ENGINEERING ANALYSIS 

5.1 In the table below please review the information on efficacy and typical characteristics of 

the baseline model and provide information on design pathways for achieving higher 

efficacies. Please indicate which of your product lines would meet each candidate standard 

level (CSL). 
12A-7

Table 12A.3 4-foot Medium Bipin (CCT ≤ 4500K) Engineering Analysis 

Level Lamp Type Efficacy

(lumens/watt)

Key Design/Technology 

Characteristics

End-User 

Price

Baseline 32W T8 90.8 Full wattage T8, 800 series 

rare earth phosphor, initial 

lumens 2,950, average rated 

lifetime hours 24,000

Candidate 

Standard Level 

(CSL)1

CSL2 

CSL3

CSL4 

Maximum 

Technologically 

Feasible

* Average rated lifetime based on 3 hour instant starts. 

Table 12A.4 8-foot Single Pin Slimline (CCT ≤ 4500K) Engineering Analysis 

Level Lamp Type Efficacy

(lumens/watt)

Key Design/Technology 

Characteristics

Price

Baseline 59W T8 98.2 Full wattage T8, 800 series 

rare earth phosphor, initial 

lumens 5,900, average rated 

lifetime hours 24,000

CSL1 

Maximum 

Technologically 

Feasible

* Average rated lifetime based on 3 hour instant starts. 
12A-8

Table 12A.5 8-foot Recessed Double Contact High Output (CCT ≤ 4500K) Engineering 

Analysis 

Level Lamp Type Efficacy

(lumens/watt)

Key Design/Technology 

Characteristics

Price

Baseline 86W T8 93.0 Full wattage T8, 700 series 

rare earth phosphor, initial 

lumens 8,000, average rated 

lifetime hours 18,000

CSL1 

Maximum 

Technologically 

Feasible

* Average rated lifetime based on 3 hour instant starts. 

Table 12A.6 4-foot Miniature Bipin Standard Output (CCT ≤ 4500K) Engineering Analysis 

at 35°C 

Level Lamp Type Efficacy

(lumens/watt)

Key Design/Technology 

Characteristics

Price

Baseline 28W T5 800 

series

104.3 Full wattage T5, 800 series 

rare earth phosphor, initial 

lumens 2,900, average rated 

lifetime hours 25,000

CSL1 

Maximum 

Technologically 

Feasible

* Average rated lifetime based on 3 hour programmed starts. 

Table 12A.7 4-foot Miniature Bipin High Output (CCT ≤ 4500K) Engineering Analysis at 

35°C 

Level Lamp Type Efficacy

(lumens/watt)

Key Design/Technology 

Characteristics

Price

Baseline 54W T5 92.9 Full wattage T5, 800 series 

rare earth phosphor, initial 

lumens 5,000, average rated 

lifetime hours 24,000

CSL2

CSL3 

Maximum 

Technologically 

Feasible

* Average rated lifetime based on 3 hour programmed starts. 

5.2 DOE selects baseline models within a representative product class. The baseline model 
12A-9

typically represents the most common, least efficacious lamp available. Do you agree with 

the baseline models selected in the tables above? 

5.3 DOE plans to use catalog values to determine efficacy and subsequently CSLs for GSFLs 

due to a lack of compliance data. Do you agree with this approach? Do you expect that 

compliance data will be available after standards go into effect on July 14, 2012 for lamps 

without compliance data currently? 

5.4 DOE has found a substantial number of covered GSFLs for which certification data is not 

available and discrepancies between catalog and certification efficacies as high as 15 

percent. Why do these differences exist? How should DOE account for compliance 

requirements? 

5.5 Are reduced wattage lamps adequate replacements for full wattage lamps in all 

applications? If not, please explain. 

5.6 Why are 8-foot high output lamps with improved efficacies not available (e.g. improved 

800 series or further reduced wattage)? What technology/design options could be used to 

achieve higher efficacy for 8-foot high output lamps? 

5.7 In the 2009 Lamps Rule, NEMA had suggested an 8 percent reduction from the 4-foot 

linear medium bipin to the 2-foot U-shaped product class, which was applied to EL4 and 

EL5. (DOE had adopted NEMA suggested EL1 through EL3 for the 2-foot U-shaped 

class.) DOE seeks comment on how to scale to the 2-foot U-shaped product class in this 

rule. 

5.8 DOE intends to analyze lamp and ballast pairings as a lamp and ballast operate together as 

a system in practice. 

Does ballast factor change depending on the lamp wattage operated? For example, if a ballast has 

a 0.88 ballast factor when operating a 32W lamp, does this change when the same ballast 

operates a 28W or 25W lamp? Does this relationship change depending on lamp type (i.e. 4-foot 

medium bipin versus T5 miniature bipin standard output)? By starting method (i.e. instant start 

versus programmed start)? 

5.9 Does striation control remain an issue for energy saving lamps? Does this issue exist only 

for energy saving T8 lamps? Are all ballasts equipped with anti-striation control circuitry? 

6 PRODUCT PRICE DETERMINATION 

6.1 DOE is considering estimating end-user price directly by collecting manufacturer 

suggested price lists (“blue books”) and applying a discount based on the distribution 

channel through which the lamp is purchased. DOE plans to gather price information from 

State procurement contracts, large electrical supply distributors, homeimprovement/hardware stores, and other sources of publicly available end-user prices such 

as Internet retailers, to estimate the appropriate discounts. 
12A-10

Do you agree with this methodology for determining lamp price? If not, why? 

For GSFLs, DOE is considering applying a range of discounts, specifically a low discount of 54 

percent, medium discount of 68 percent, and high discount of 82 percent. 

6.2 How has the limited availability of certain rare earth elements impacted the cost of GSFLs? 

6.3 Can you describe how the distribution chain operates for GSFLs and which end-use sector 

(e.g. commercial, residential) utilizes each distribution chain identified? What proportion 

of shipments move through the various channels? 

6.4 DOE is considering using end-user ballast prices derived in the 2011 Ballast Rule. These 

prices were developed by determining the manufacturer selling prices (MSPs) based on 

teardown analyses and a manufacturer markup analysis and then applying distribution 

channel markups and sales tax to derive end-user prices for ballasts. Is this methodology 

appropriate for determining ballast prices? If not, why? 

6.5 Do end-user ballast prices change with ballast factor? If so, explain how? 

7 LIFETIME AND OPERATING HOURS 

7.1 DOE intends to use catalog data to determine the lifetime of representative lamps selected 

in the engineering analysis. Do you agree with this approach? 

7.2 According to our analysis using Energy Information Administration (EIA) and American 

Housing Survey (AHS) data and data from the 2010 U.S. Lighting Market Characterization 

(DOE, 2012), the average annual operating hours for GSFLs is 4,058 hours for the 

commercial sector, 4,585 hours for the industrial sector, and 648 hours for the residential 

sector. 

Are these reasonable estimates? If not, what are the average annual operating hours by sector? 

Do the average annual operating hours vary significantly by lamp type (e.g. 4-foot medium bipin 

versus 8-foot slimline)? 

7.3 Because a higher efficacy replacement may require a new ballast, DOE must also estimate 

the service lifetime of a ballast. DOE is considering determining the average ballast service 

lifetimes using the average ballast lifetime of 49,054 hours used in the 2011 Ballast Rule 

and the estimated annual operating hours for fluorescent lamps in the commercial and 

industrial sectors yielding: 12.1 years for commercial, 10.7 years for industrial. DOE is 

considering using 15 years for residential average ballast service lifetime. Are these 

estimates representative of the market? 

7.4 What is the expected difference in lifetime for a lamp operating with a programmed start 

ballast compared to an instant start ballast? 

7.5 DOE understands GSFLs are sometimes replaced before they fail due to lighting retrofits 
12A-11

or renovations. On average, how often are GSFLs replaced before failure in each sector 

(i.e. what is their average useful lifetime)? Does this lifetime vary by efficacy or lamp 

type? In general, why are GSFLs replaced (e.g., lamp “failure”, renovation)? 

7.6 DOE is considering evaluating the impacts of lighting controls on the energy use of 

GSFLs. Most lighting controls have one of two impacts: reducing operating wattage or 

reducing operating hours. DOE refers to these two groups of controls as dimmers/light 

sensors or occupancy sensors. In order to evaluate the impact of these lighting controls, 

DOE requests data for the residential and commercial/industrial sectors. Please fill in the 

table below: 

Table 7.1 GSFL Lighting Controls 

Dimming Ballasts and Light 

Sensors

Occupancy Sensors

Residential Commercial/

Industrial Residential Commercial/Industrial

Percentage of 

GSFL using the 

lighting control

Average number 

of lamps 

controlled per 

lighting control

Average 

percentage 

reduction of lamp 

operating hours

Average 

percentage 

reduction of lamp 

lumen output

Average 

percentage 

reduction of lamp 

wattage

Average 

percentage 

increase of lamp 

lifetime

Average lifetime 

of lighting control 

unit (years)

Average, min, and 

max cost of 

lighting control 

unit

Average time 

(minutes) for

lighting control 

installation
12A-12

7.7 What specific controls are being used in conjunction with GSFLs? 

7.8 In what circumstances are lighting controls typically installed? Are there any scenarios in 

which a consumer is unable to install a dimmer, occupancy sensor, or other lighting 

control? 

7.9 Does the presence of a programmed start ballast indicate lighting controls are in use? 

8 TEST PROCEDURE INPUTS USED FOR ENERGY CONSERVATION 

STANDARDS 

8.1 The ANSI rated wattages are currently not available for the lamps listed below. What rated 

power do you suggest using for these lamp types to determine efficacy? 

a. 2-ft U-shaped: 25W, 26W, 27W, 28W, 29W 

b. 8-ft slimline: 49W, 50W, 54W 

c. T5 miniature bipin high output: 44W, 47W, 50W 

d. T5 miniature bipin standard output: 25W 

8.2 The efficacy of T5 miniature bipin lamps is tested at 25°C but the lamps are often operated 

at 35°C. DOE is considering applying a 10 percent reduction to the catalog lumen output at 

35°C in order to determine lumen output at 25°C. Is this an appropriate reduction due to the 

expected change in efficacy at different operating temperatures? 

9 PRELIMINARY MANUFACTURER IMPACT ANALYSIS 

Key Issues 

9.1 In general, what are the key issues for your company regarding energy conservation 

standards and this rulemaking? 

9.2 Are there any patent, technology, or other issues that you are aware of that would prevent 

your company or competitors from implementing higher-efficacy designs? 

Shipment Projections 

9.3 What is your company’s approximate market share for the GSFLs DOE is considering 

including in coverage? 

9.4 Would you expect your market share to change once standards become effective? Does 

your outlook change with higher efficacy levels? 

9.5 Do you expect shipments to change for the industry as a whole as a function of standards? 

If so, why? 
12A-13

9.6 Do you expect an increased purchase price for GSFLs to result in reduced demand or 

shipments (price elasticity)? If so, how sensitive do you think shipments will be to price 

changes? Does it vary with product class? 

9.7 What is the proportion of domestically consumed GSFLs shipped by the National 

Electrical Manufacturers Association (NEMA) companies versus non-NEMA companies? 

Does this vary based on lamp type? 

Conversion Costs 

9.8 What level of capital expenditure and product conversion costs would you anticipate 

making at higher standard levels? Please describe what they are and provide your best 

estimate of their respective magnitudes. 

9.9 How would the imposition of new energy conservation standards affect capacity utilization 

and manufacturing assets at your domestic production facilities? Would a new standard 

result in stranded capital assets? Would any facilities be closed or downsized? Added or 

upgraded? 

9.10 How might a new standard impact product innovation? 

Product Mix and Profitability 

9.11 How would your company’s product mix and marketing strategy change with changes in 

the efficiency standard? 

9.12 Generally, how would new standards impact your customer mix, distribution channels, and 

corresponding profit margins? 

9.13 Is your profitability consistent across all GSFL types? 

Market Share and Industry Consolidation 

9.14 In the absence of new standards, do you expect any industry consolidation? 

9.15 How would new standards affect your ability to compete? 

9.16 Could new standards disproportionally advance or harm the competitive positions of some 

firms? 

9.17 Could new standards result in disproportionate economic or performance penalties for 

particular consumer/user subgroups? 

9.18 Beyond pricing and energy efficiency, could new standards result in products that will be 

more or less desirable to consumers due to changes in product functionality, utility, or 

other features? 
12A-14

Cumulative Regulatory Burden 

9.19 Are there recent or impending regulations on your specific products or other products that 

impose a cumulative burden on the industry? 

9.20 If so, what is the total expected impact of those regulations? 
12A-15

12A.3 INCANDESCENT REFLECTOR LAMPS 

In July 2009, the U.S. Department of Energy (DOE) published a final rule for incandescent 

reflector lamp standards (hereafter the 2009 Lamps Rule). DOE is now conducting another 

rulemaking to evaluate amending energy conservation standards for IRL lamps. As the first step 

in this process, DOE published a framework document in September 2011 that describes the 

procedural and analytical approaches DOE anticipates using to evaluate potential energy 

conservation standards.b

1 SCOPE OF COVERAGE 

Currently, DOE covers incandescent reflector lamps defined as follows: 

DOE defines an incandescent reflector lamp as any lamp in which light is produced by a filament 

heated to incandescence by an electric current, which: is not colored or designed for rough or 

vibration service applications that contains an inner reflective coating on the outer bulb to direct 

the light; has an R, PAR, ER, BR, BPARc

, or similar bulb shapes with an E26 medium screw 

base; has a rated voltage or voltage range that lies at least partially in the range of 115 and 130 

volts; has a diameter that exceeds 2.25 inches; and has a rated wattage that is 40 watts or higher. 

This rulemaking will cover IRLs as specified in the above definition with the following 

exceptions: 

 Lamps with rated wattages greater than 205W. Similar to the 2009 Lamps Rule, DOE is 

not considering IRLs with these higher rated wattages because these comprise a very 

small portion of the market and therefore do not represent significant potential energy 

savings. 

 Lamps that are 1) rated 50 watts or less that are ER30, BR30, BR40, or ER40; 2) lamps 

rated 65 watts that are BR30, BR40, or ER40 lamps; and 3) R20 incandescent reflector 

lamps rated 45 watts or less. DOE is considering these R, ER and BR IRLs in a separate 

rulemaking and therefore will not cover them in this rulemaking. 

2 MARKET ANALYSIS 

2.1 How do consumers select an IRL lamp? What parameters are they most interested in? Do 

they weigh input power or light output more heavily? 

2.2 Are you aware of any progress on an application efficacy metric? 

 

b

 The framework document is available on DOE’s website at: 

http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/gsfl_irl_ecs_framework.pdf. 

c

 R (reflector), PAR, (parabolic aluminized reflector), ER (elliptical reflector), BR (bulged reflector), BPAR (bulged 

parabolic aluminized reflector) 
12A-16

2.3 In order to calculate the aggregate national energy savings, DOE would need data on 

shipment trends. 

2.4 Can you share any data on recent shipments of the covered lamps? How have shipments 

changed in recent years? 

What are the percent of shipments for each of the lamp types covered that are high efficiency 

versus standard efficiency? Please indicate the year of data provided? Absent new energy 

conservation standards, do you expect these proportions to change over time? If so, how? 

What are the percent of shipments for each of the lamp types covered that are standard spectrum 

versus modified spectrum; large diameter (i.e. > 2.5 inches) versus small diameter (≤ 2.5 inches); 

less than 125 volts versus greater than or equal to 125 volts? Please indicate the year of data 

provided. Absent new energy conservation standards, do you expect these proportions to change 

over time? If so, how? 

For the covered lamps, what IRL wattages are the most common? What percent of shipments are 

represented by each of these wattages for the most current year? Absent new energy conservation 

standards, do you expect these proportions to change over time? If so, how? 

2.5 DOE intends to consider IRLs operating in different sectors. For the IRLs under 

consideration in this rulemaking, can you provide an estimate of the percent of IRLs sold into the 

commercial, industrial, and residential sectors? 

2.6 What are general trends you see in the market? Do you foresee other technologies (e.g., 

light-emitting diodes (LEDs) and compact fluorescent lamps (CFLs) impacting the future 

shipments of IRL lamps? If so, how? 

2.7 Do you expect future market shares for the most common IRL lamp types to change in 

the presence of amended energy conservation standards for IRL lamps? If so, how? 

3 TECHNOLOGY ASSESSMENT AND SCREENING ANALYSIS 

3.1 How is IRL efficacy expected to change over time? Are research and development efforts 

focused on these products? 

3.2 Can further improvements be made in the efficiency of reflector coatings and infrared 

glass coatings? 

3.3 Newly identified technologies since the 2009 Final Rule include high reflectance filament 

supports and permanent infrared reflector coating shroudd

. Are there plans to incorporate these 

technologies in commercially available products? If so, what is the expected production date? 

 

d

http://www.google.com/patents/US20100328955?printsec=description&dq=US20100328955&ei=zad9T6yRD5CC

8QSg6NSKDQ#v=onepage&q&f=false
12A-17

3.4 What design/technology is used to change (increase/decrease) the color rendering index 

(CRI) and correlated color temperature (CCT) in an IRL lamp? 

3.5 What design/technology is used to change (increase/decrease) lamp rated life? 

3.6 Are there any patent, technology, or other issues that you are aware of that would prevent 

your company or competitors from implementing higher-efficacy designs? When do these 

patents expire? 

4 PRODUCT CLASSES 

4.1 DOE separates products into categories called product classes based on differences in 

efficacy and consumer utility (i.e., features valued by consumers). DOE then conducts its 

analyses and establishes separate standard levels for each product class. DOE is considering 

separating product classes based on spectrum, diameter, and voltage as shown in the table below. 

Do you agree with these product class divisions under consideration? Are there other parameters 

that should be considered in defining product classes for IRLs? 

Table 12A.8 Product Classes Under Consideration 

Lamp Type Diameter Voltage

Standard 

Spectrum

> 2.5 inches > 125V

< 125V

< 2.5 inches > 125V

< 125V

Modified 

Spectrum

> 2.5 inches > 125V

< 125V

< 2.5 inches > 125V

< 125V

* Gray shading indicates a representative product class. 

4.2 DOE selects certain product classes (called representative product classes) to directly 

analyze in detail. The representative product classes are selected primarily based on shipment 

volume, so that categories of lamps with higher market share are analyzed in detail. For IRLs 

DOE is directly analyzing lamps that are standard spectrum, greater than 2.5 inches in diameter, 

and less than 125 volts (see shaded area in the table above). Do you agree with this 

representative product class under consideration? 

4.3 Are there lamp types other than PAR shapes that can meet July 2012 standards? If so, 

please specify. 

4.4 Are there modified spectrum IRLs that can meet July 2012 standards? If so, please 

specify. 

5 ENGINEERING ANALYSIS 

5.1 In the table below please review the information on efficacy and typical characteristics of 

the baseline model and provide further information on design pathways for achieving higher 
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efficacies. Please indicate which of your product lines would meet each candidate standard level 

(CSL). 

Table 12A.9 PAR 38 Engineering Analysis 

Level Lamp Type Efficacy Key Design/Technology 

Characteristics*

End-User Price

Baseline 60 W PAR 

38

18.1 lm/w Halogen infrared (HIR) 

technology using higher 

efficiency reflector coating, 

lumens 1,086, average 

lifetime hours 4,000.

Candidate 

Standard Level 

(CSL)1

Maximum 

Technologically 

Feasible

*Including technology type, lumens, and lifetime 

5.2 DOE selects baseline models within a representative product class. The baseline model 

typically represents the most common, least efficacious lamp available. Do you agree with the 

wattage and lamp technology selected? 

5.3 What are the most common lifetimes for lamps that meet standards? Do you expect these 

lifetimes to change in future products? 

5.4 DOE used efficacy values from certification reports instead of catalog efficacy values to 

determine CSLs for IRLs. Do you agree with this approach? 

5.5 In reviewing available certification data, DOE noticed that all lamps listed in catalogs are 

not entered in the DOE’s certification database. Are these lamps expected to be available after 

July 2012 standards become effective? 

Are there other models that meet July 2012 standards that have not yet been included in the 

certification reports? If so, please specify which models. 

Are there any new products expected to be introduced that meet the July 2012 standards? 

DOE noticed that values on certification reports differed from values reported in catalogs. Can 

you explain the reason for this discrepancy? 

*For your reference, please see attached spreadsheet containing covered IRLs that meet the July 

2012 standards based on certification and/or catalog values. 

5.6 In the 2009 Lamps Rule, DOE scaled from the standard spectrum, > 2.5 inch diameter, < 

125 volts lamps to other IRL product classes using the following factors: 
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 Reduction in efficacy caused by using a modified spectrum lamp instead of a standard 

spectrum lamp as 15percent. 

 Reduction in efficacy caused by a reduction in lamp diameter from > 2.5 inches to < 2.5 

inches as 12 percent. 

 Increase in efficacy caused by operating a 130V lamp instead of a lamp of a similar 

wattage at 120V as 15 percent. 

Do you agree with these scaling factors? In not, please explain. 

5.7 In the 2009 Lamps Rule, DOE modeled lamps with single-ended burners by using a 

reduction of 3.5 percent in efficacy going from a double-ended to single-ended burner. Is this 

reduction appropriate? If not, please explain. 

6 PRODUCT PRICE DETERMINATION 

6.1 DOE is considering estimating end-user price directly by collecting manufacturer 

suggested price lists (“blue books”) and applying a discount based on the distribution channel 

through which the lamp is purchased. DOE plans to gather price information from State 

procurement contracts, large electrical supply distributors, home-improvement/hardware stores, 

and other sources of publicly available end-user prices such as Internet retailers, to estimate the 

appropriate discounts. 

Do you agree with this methodology for determining lamp price? If not, why? 

For IRLs, DOE is considering applying a range of discounts, specifically a low discount of 36 

percent, medium discount of 54 percent, and high discount of 73 percent. 

6.2 Can you describe how the distribution chain operates for IRLs and which end-use sector 

(i.e. commercial, residential) utilizes each distribution chain identified? What proportion of 

shipments move through the various channels? 

7 LIFETIME AND OPERATING HOURS 

7.1 DOE intends to use catalog data to determine the lifetime of representative lamps 

selected in the engineering analysis. Do you agree with this approach? 

7.2 According to our analysis using Energy Information Administration (EIA) and American 

Housing Survey (AHS) data from the 2010 U.S. Lighting Market Characterization (DOE, 2012), 

the average annual operating hours for IRL is 4,496 hours in the commercial sector, 4,246 hours 

in the industrial sector and 761 hours in the residential sector. Are these reasonable estimates? If 

not, what is the average annual operating hours by sector? 

7.3 DOE is considering evaluating the impacts of lighting controls on the energy use of IRLs. 

Most lighting controls have one of two impacts: reducing operating wattage or reducing 

operating hours. DOE refers to these two groups of controls as dimmers/light sensors or 
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occupancy sensors. In order to evaluate the impact of these lighting controls, DOE requests data 

for the residential and commercial/industrial sectors. Please fill in the table below: 

Table 6.1 IRL Lighting Controls 

Dimmers and Light Sensors Occupancy Sensors

Residential Commercial/

Industrial Residential Commercial/Industrial

Percentage of IRL 

using the lighting 

control

Average number of 

lamps controlled per 

lighting control

Average percentage 

reduction of lamp 

operating hours

Average percentage 

reduction of lamp 

lumen output

Average percentage 

reduction of lamp 

wattage

Average percentage 

increase of lamp 

lifetime

Average lifetime of 

lighting control unit 

(years)

Average, min, and 

max cost of lighting 

control unit

Average time 

(minutes) for 

lighting control 

installation

7.4 In what circumstances are lighting controls typically installed? Are there any scenarios in 

which a consumer is unable to install a dimmer, occupancy sensor, or other lighting control? 

8 PRELIMINARY MANUFACTURER IMPACT ANALYSIS 

Key Issues 

8.1 In general, what are the key issues for your company regarding energy conservation 

standards and this rulemaking? 

Shipment Projections 

8.2 What is your company’s approximate market share for the IRLs DOE is considering 

including in coverage? 
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8.3 Would you expect your market share to change once new energy conservation standards 

become effective? Does your outlook change with higher efficacy levels? 

8.4 Do you expect shipments to change for the industry as a whole as a function of 

standards? If so, why? 

8.5 Do you expect an increased purchase price for IRL to result in reduced demand or 

shipments (price elasticity)? If so, how sensitive do you think shipments will be to price 

changes? Does it vary by product class? 

8.6 What is the proportion of domestically consumed IRLs shipped by the National Electrical 

Manufacturers Association (NEMA) companies versus non-NEMA companies? Does this vary 

based on diameter or reflector shape? Does this vary for competing technologies (e.g. compact 

fluorescent lamps)? 

Conversion Costs 

8.7 What level of capital expenditure and product conversion costs would you anticipate 

making at higher standard levels? Please describe what they are and provide your best estimate 

of their respective magnitudes. 

8.8 How would the imposition of new energy conservation standards affect capacity 

utilization and manufacturing assets at your domestic production facilities? Would a new 

standard result in stranded capital assets? Would any facilities be closed or downsized? Added or 

upgraded? 

8.9 How might a new standard impact product innovation? 

Product Mix and Profitability 

8.10 How would your company’s product mix and marketing strategy change with changes in 

the efficiency standard? 

8.11 Generally, how would new standards impact your customer mix, distribution channels, 

and corresponding profit margins? 

8.12 Is your profitability consistent across all IRL types? 

Market Share and Industry Consolidation 

8.13 In the absence of new standards, do you expect any industry consolidation? 

8.14 How would new standards affect your ability to compete? 

8.15 Could new standards disproportionally advance or harm the competitive positions of 

some firms? 
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8.16 Could new standards result in disproportionate economic or performance penalties for 

particular consumer/user subgroups?

8.17 Beyond pricing and energy efficiency, could new standards result in products that will be 

more or less desirable to consumers due to changes in product functionality, utility, or other 

features? 

Cumulative Regulatory Burden 

8.18 Are there recent or impending regulations on your specific products or other products that 

impose a cumulative burden on the industry? 

8.19 If so, what is the total expected impact of those regulations?