General Service Fluorescent Lamp and Incandescent Reflector March 10-11, 2008 

Lamp Energy Conservation Standard ANOPR Public Meeting 

Energy Conservation Standards for 

General Service Fluorescent Lamps and 

Incandescent Reflector Lamps

ANOPR Public Meeting

NOPR Analyses and Next Steps 

Building Technologies Program

Office of Energy Efficiency and Renewable Energy

U.S. Department of Energy

March 10-11, 2008

NOPR Analyses and Next Steps 

NOPR Analyses Flow Diagram 

Manufacturer 

Impact 

Analysis 

Utility 

Impact 

Analysis 

Trial 

Standard 

Levels 

Revise 

ANOPR 

Analyses 

Environmental 

Assessment 

Regulatory 

Impact 

Analysis 

Employment 

Impact 

Analysis 

LCC 

Subgroup 

Analysis 

2 
General Service Fluorescent Lamp and Incandescent Reflector March 10-11, 2008 

Lamp Energy Conservation Standard ANOPR Public Meeting 

ANOPR Revisions 

Revise ANOPR Analyses 

ANOPR Analysis Action 

Engineering Analysis • Consider ANOPR comments 

• Revise using latest data 

Life-Cycle Cost and 

Payback Period Analyses 

• Consider ANOPR comments 

• Revise using latest data 

• Conduct LCC Sub-Group Analysis 

National Impact Analysis • Consider ANOPR comments 

• Revise using latest data 

3 

NOPR Analyses and Next Steps 

NOPR Analyses Flow Diagram 

Manufacturer 

Impact 

Analysis 

Utility 

Impact 

Analysis 

Trial 

Standard 

Levels 

Revise 

ANOPR 

Analyses 

Environmental 

Assessment 

Regulatory 

Impact 

Analysis 

Employment 

Impact 

Analysis 

LCC 

Subgroup 

Analysis 

4 
General Service Fluorescent Lamp and Incandescent Reflector March 10-11, 2008 

Lamp Energy Conservation Standard ANOPR Public Meeting 

Trial Standard Levels 

Selection of Trial Standard Levels 

 Purpose 

• To develop a list of standard levels from which impacts are weighed and 

a proposed standard level is selected 

– Each trial standard level consists of a set of candidate standard levels 

covering all product classes, and may vary between product classes 

– NOPR analyses assess impacts for trial standard levels (not product classes) 

 Method 

• Trial standard levels are assembled from the product classes and 

candidate standards identified in the ANOPR 

– Candidate standard levels cover a range of efficiencies and can include: 

 Most energy efficient level (max tech) 

 Efficiency level with the lowest life-cycle cost 

 Efficiency levels with noteworthy technologies 

 Efficiency levels that fill in large gaps between candidate standard levels 

– Each trial standard level consists of the candidate standard level from each 

product class that meets one of the above criteria 

5 

Trial Standard Levels 

Trial Standard Levels 

 A critical part of the NOPR analysis on which DOE is seeking early 

guidance and input. 

 Trial standard levels are created from combinations of candidate 

standard levels at a product class level. 

 Based around a consistent theme, such as lowest life-cycle cost. 

DOE requests feedback on the criteria it should use for basing 

the selection of Trial Standard Levels. (Issue #13) 

6 
General Service Fluorescent Lamp and Incandescent Reflector March 10-11, 2008 

Lamp Energy Conservation Standard ANOPR Public Meeting 

NOPR Analyses and Next Steps 

NOPR Analyses Flow Diagram 

Manufacturer 

Impact 

Analysis 

Utility 

Impact 

Analysis 

Trial 

Standard 

Levels 

Revise 

ANOPR 

Analyses 

Environmental 

Assessment 

Regulatory 

Impact 

Analysis 

Employment 

Impact 

Analysis 

LCC 

Subgroup 

Analysis 

7 

Life-Cycle Cost Subgroup Analysis 

LCC Subgroup Analysis 

 Purpose 

• To evaluate the economic impacts of standards on consumer subgroups who may 

be disproportionately impacted compared with the general user population 

 Potential subgroups 

• The LCC Analysis includes the ability to examine impacts of consumers: 

– Operating lamps in a variety of sectors (e.g., residential, commercial, 

industrial) 

– Operating lamps in a variety of building types (e.g., mobile home, vs. 

educational facility) 

– Replacing different baseline lamps or lamp-and-ballast systems (e.g., T8 vs. 

T12 baseline system) 

– Subject to a variety of purchasing events (e.g., lamp failure, ballast failure) 

• DOE may also consider analyzing the impacts of low-income consumers. 

DOE welcomes comment on how LCC inputs may change for 

each consumer subgroup.

8 
General Service Fluorescent Lamp and Incandescent Reflector March 10-11, 2008 

Lamp Energy Conservation Standard ANOPR Public Meeting 

NOPR Analyses and Next Steps 

NOPR Analyses Flow Diagram 

Manufacturer 

Impact 

Analysis 

Utility 

Impact 

Analysis 

Trial 

Standard 

Levels 

Revise 

ANOPR 

Analyses 

Environmental 

Assessment 

Regulatory 

Impact 

Analysis 

Employment 

Impact 

Analysis 

LCC 

Subgroup 

Analysis 

9 

Manufacturer Impact Analysis 

Manufacturer Impact Analysis 

 Purpose 

• To assess the financial impacts and other quantitative and qualitative industry 

impacts of standards on manufacturers of general service florescent lamps (GSFL) 

and incandescent reflector lamps (IRL) 

• To identify and estimate impacts on manufacturer sub-groups that may be more 

severely impacted than the industry as a whole 

• To examine the impact of cumulative regulatory burdens on the industry 

 Method 

• Analyze industry cash flow and net present value through use of the Government 

Regulatory Impact Model (GRIM) 

• Interview manufacturers to refine inputs to the GRIM, develop sub-group analyses, 

and address qualitative issues 

 Output 

• Industry Net Present Value impacts 

• Sub-group Net Present Value impacts 

• Other impacts 

10 
l

Engineering Analysis

LCC Analysis

National Energy

Savi l sis

Consumer Subgroup

Utility Impacts

Environmental Impacts

Indirect Employment

ts

General Service Fluorescent Lamp and Incandescent Reflector March 10-11, 2008 

Lamp Energy Conservation Standard ANOPR Public Meeting 

Manufacturer Impact Analysis 

Manufacturer Impact Analysis Process 

 The MIA consists of three phases 

Phase 1 Phase 2 Phase 3 

Industry

profile 

Develop

preliminar

GRIM* 

Develo

interview 

guide 

Interviews 

& industrywide

subgroup

analyses 

Assess direct 

employment,

competition, 

cumulative 

burden 

Finalize 

MIA results 

for NOPR 

* Government Regulatory Impact Model (GRIM) 

11 

Manufacturer Impact Analysis 

The MIA is both concurrent and coordinated with activities throughout 

the rulemaking process. 

12 

Phase I 

Industry Profile 

Phase III 

Manufacturer Interviews 

Revised Industry Cash Flow 

Manufacturer Subgroup Analysis 

Qualitative Assessment 

Phase II 

Preliminary GRIM 

Manufacturer Impact Analysis 

Screening Ana ysi Screening Analysis

Engineering Analysis 

LCC Analysis 

ngs Ana y 

National Energy 

Savings Analysis 

Consumer Subgroup 

Utility Impacts 

Environmental Impacts 

Other Rulemaking Analyses 

Impac 

Indirect Employment 

Impacts 
General Service Fluorescent Lamp and Incandescent Reflector March 10-11, 2008 

Lamp Energy Conservation Standard ANOPR Public Meeting 

Manufacturer Impact Analysis 

Phase I: Industry Profile 

 Collect financial and market information 

• Industry reports 

• Company annual reports and websites 

• Trade journals 

• U.S. Census Bureau 

• SEC 10-K form filings 

• ANOPR information from the market and technology assessment, 

engineering analysis, life-cycle cost analysis, and analysis of consumer 

prices 

13 

Manufacturer Impact Analysis 

Phase II: Develop Preliminary GRIM 

 The Government Regulatory Impact Model (GRIM) is an industry

cash flow analysis that estimates the change in industry value 

due to the introduction of new energy conservation standards.

Manufacturer Prices 

Shipments 

Manufacturing Costs 

Financial Information 

Cash Flow Impacts, 

Changes in Industry NPV 

GRIM 

14 
General Service Fluorescent Lamp and Incandescent Reflector March 10-11, 2008 

Lamp Energy Conservation Standard ANOPR Public Meeting 

Manufacturer Impact Analysis 

Phase II: Develop Interview Guide 

 A critical aspect of the MIA involves interviews with manufacturers. An 

interview guide is sent to manufacturers in preparation for Phase III. 

 Interview topics will include . . . 

• Engineering analysis 

• Shipments model 

• Cost structure and financial parameters 

• Conversion costs (capital expenditures, tooling, R&D, testing) 

• Impact of other regulations / cumulative burden 

• Direct employment impacts 

• Import / export issues 

• Consolidation / competitive impacts 

• Replacement parts or refurbishments 

• Impact of the standard’s effective date 

• Other topics important to manufacturers 

15 

Manufacturer Impact Analysis 

Phase III: Manufacturer Interviews 

 Expected timeframe 

 Time and personnel commitment for manufacturers (industry-wide 

GRIM, GRIM assumptions, subgroup analysis discussion) 

 Confidentiality agreements 

16 
General Service Fluorescent Lamp and Incandescent Reflector March 10-11, 2008 

Lamp Energy Conservation Standard ANOPR Public Meeting 

Manufacturer Impact Analysis 

Phase III: Manufacturer Subgroup Analysis 

 The subgroup analysis is a more focused version of the industrywide analysis. 

• Gather information about what sub-groups or characteristics are most 

appropriate. 

• Work with subgroup representatives to tailor a GRIM incorporating unique 

financial characteristics 

• Consider and focus on issues of importance to the subgroup, including 

employment, capacity utilization and cumulative burden 

• Review draft findings with subgroup members during development 

17 

Manufacturer Impact Analysis 

Phase III: Results 

 During interviews, DOE seeks comments and suggestions on the 

parameters used in the preliminary GRIM. The results for the 

financial impacts on the industry following these comments are 

presented in the NOPR phase. 

 In addition, the results for the following qualitative impacts on the 

industry are also presented: 

• Competitive Impact Assessment 

• Manufacturing Capacity Impact 

• Employment Impact 

• Cumulative Regulatory Burden 

18 
General Service Fluorescent Lamp and Incandescent Reflector March 10-11, 2008 

Lamp Energy Conservation Standard ANOPR Public Meeting 

NOPR Analyses and Next Steps 

NOPR Analyses Flow Diagram 

Manufacturer 

Impact 

Analysis 

Utility 

Impact 

Analysis 

Trial 

Standard 

Levels 

Revise 

ANOPR 

Analyses 

Environmental 

Assessment 

Regulatory 

Impact 

Analysis 

Employment 

Impact 

Analysis 

LCC 

Subgroup 

Analysis 

19 

Utility Impact Analysis 

Utility Impact Analysis 

 Purpose 

• To investigate the effects on utilities from reduced energy sales and 

peak load demand due to potential standards 

 Method 

• Uses national energy savings results 

• Uses the Energy Information Administration’s National Energy 

Modeling System (NEMS) tailored for DOE’s Building Technologies 

Program (NEMS-BT) 

 Output 

• Change in energy sales by region 

• Change in the mix of electricity generation 

• Change in new capacity construction 

20 
General Service Fluorescent Lamp and Incandescent Reflector March 10-11, 2008 

Lamp Energy Conservation Standard ANOPR Public Meeting 

NOPR Analyses and Next Steps 

NOPR Analyses Flow Diagram 

Manufacturer 

Impact 

Analysis 

Utility 

Impact 

Analysis 

Trial 

Standard 

Levels 

Revise 

ANOPR 

Analyses 

Environmental 

Assessment 

Regulatory 

Impact 

Analysis 

Employment 

Impact 

Analysis 

LCC 

Subgroup 

Analysis 

21 

Employment Impact Analysis 

Employment Impact Analysis 

 Purpose 

• To report net jobs created or eliminated nationally as a consequence 

of new energy efficiency standards 

 Method 

• Uses the ImSET tool, a spreadsheet model of the U.S. economy that 

focuses on 188 sectors most relevant to industrial, commercial, and 

residential building energy use 

• Changes in product and energy expenditures taken from the National 

Impact Analysis 

• Estimates the national employment and income effects of energy 

saving appliances 

• Direct employment impacts taken from the Manufacturer Impact 

Analysis 

 Output 

• Change in employment by sector as a consequence of new 

standards 22 
General Service Fluorescent Lamp and Incandescent Reflector March 10-11, 2008 

Lamp Energy Conservation Standard ANOPR Public Meeting 

NOPR Analyses Flow Diagram 

Manufacturer 

Impact 

Analysis 

Utility 

Impact 

Analysis 

Trial 

Standard 

Levels 

Revise 

ANOPR 

Analyses 

Environmental 

Assessment 

Regulatory 

Impact 

Analysis 

Employment 

Impact 

Analysis 

LCC 

Subgroup 

Analysis 

23 

Environmental Assessment 

Environmental Assessment 

 Purpose 

• To report environmental impacts as a consequence of new energy 

efficiency standards, including changes in power plant emissions 

 Method 

• Energy savings results taken from the National Impact Analysis 

• National Energy Modeling System (NEMS-BT) provides power-plant 

emissions 

 Output 

• Estimate of national emission reductions 

– Impact on CO2 emissions reported 

– Power plant SO2 and NOx emissions are effectively capped through 

Congressional legislation resulting in little to no emission reductions 

due to standards 

– The mercury cap-and-trade rule was recently overturned by the 

courts; replacement regulations are not yet determined 

24 
General Service Fluorescent Lamp and Incandescent Reflector March 10-11, 2008 

Lamp Energy Conservation Standard ANOPR Public Meeting 

NOPR Analyses and Next Steps 

NOPR Analyses Flow Diagram 

Manufacturer 

Impact 

Analysis 

Utility 

Impact 

Analysis 

Trial 

Standard 

Levels 

Revise 

ANOPR 

Analyses 

Environmental 

Assessment 

Regulatory 

Impact 

Analysis 

Employment 

Impact 

Analysis 

LCC 

Subgroup 

Analysis 

25 

Regulatory Impact Analysis 

Regulatory Impact Analysis 

 Purpose 

• To investigate the national impacts due to non-regulatory alternatives 

compared with mandatory energy efficiency standards 

• The non-regulatory alternatives that may be considered: 

– Early replacement; customer tax credits; manufacturer tax credits; 

customer rebates; voluntary efficiency targets; enhanced consumer 

education and labeling program; and bulk government procurement 

 Method 

• Modify NES spreadsheet model to consider non-regulatory scenarios 

– Non-regulatory scenarios increase overall lamp efficacy and are modeled 

by modifying the base-case efficacy trend 

– A percent market adoption estimate is applied to each non-regulatory 

scenario. In each case, the percent adoption will be less than the 100% 

adoption implicit in the regulatory standard option. 

– NPV calculated for non-regulatory alternatives in the same way as for the 

adopted standard 

 Output 

• National Energy Savings and Net Present Value of the non-regulatory 

alternatives 

26