Energy Conservation Standards
 

Rulemaking Framework Document for
 

Certain Small Diameter, Elliptical Reflector, 

and Bulged Reflector Incandescent Reflector Lamps
 

RIN: 1904-AC15
 

U.S. Department of Energy 

Office of Energy Efficiency and Renewable Energy 

Building Technologies Program 

April 23, 2010 
TABLE OF CONTENTS
 

1 Introduction ............................................................................................................................... 1
 

1.1 Overview of the Framework Document ............................................................................. 1
 

1.2 Authority ............................................................................................................................. 1
 

1.3 Background ......................................................................................................................... 3
 

1.3.1	 History of Standards Rulemaking for ER, BR, and Small Diameter Incandescent
 

Reflector Lamps............................................................................................................ 3
 

1.3.2 Current Rulemaking Process................................................................................... 3
 

2 Rulemaking Analyses Overview and Proposed Methodology ................................................. 4
 

2.1 Test Procedures................................................................................................................... 4
 

2.2 Off Mode and Standby Mode Energy Consumption Standards .......................................... 5
 

2.3 Market and Technology Assessment .................................................................................. 5
 

2.3.1 Scope of Coverage .................................................................................................. 6
 

2.3.2 Product Classes ....................................................................................................... 7
 

2.3.2.1 Lamp Spectrum .............................................................................................. 7
 

2.3.2.2 Lamp Diameter............................................................................................... 8
 

2.3.2.3 Input Voltage.................................................................................................. 8
 

2.3.3 Market Assessment ................................................................................................. 8
 

2.3.4 Technology Assessment.......................................................................................... 9
 

2.4 Screening Analysis............................................................................................................ 11
 

2.5 Engineering Analysis........................................................................................................ 12
 

2.5.1 Approach ............................................................................................................... 12
 

2.5.2 Representative Product Classes ............................................................................ 13
 

2.5.3 Baseline Lamps..................................................................................................... 13
 

2.5.4 Higher-Efficacy Lamp Designs ............................................................................ 14
 

2.5.5 Efficiency Levels .................................................................................................. 16
 

2.5.6 Scaling to Product Classes Not Analyzed............................................................. 17
 

2.6 Energy Use Characterization ............................................................................................ 18
 

2.7 Product Price Determination ............................................................................................. 19
 

2.8 Life-Cycle Cost and Payback Period Analyses ................................................................ 20
 

2.8.1 Installation Costs ................................................................................................... 23
 

2.8.2 Electricity Prices ................................................................................................... 23
 

2.8.3 Electricity Price Trends......................................................................................... 23
 

2.8.4 Lifetime ................................................................................................................. 23
 

2.8.5 Analysis Period ..................................................................................................... 24
 

2.8.6 Consumer Discount Rates..................................................................................... 24
 

2.9 Shipments Analysis ........................................................................................................... 24
 

2.9.1 Historical Shipments............................................................................................. 25
 

2.9.2 Installed Stock....................................................................................................... 26
 

2.9.2.1 Existing/Emerging Technologies Scenarios................................................. 26
 

2.9.2.2 Additional Shipments Growth Due to the July 2009 Final Rule.................. 27
 

2.9.3 Market-Share Matrices.......................................................................................... 27
 

2.10 National Impact Analysis............................................................................................ 28
 

2.10.1 Approach ......................................................................................................... 28
 

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2.10.2 Base-Case and Standards-Case Forecasted Efficacies .................................... 29
 

2.10.3 National Impact Analysis Inputs ..................................................................... 30
 

2.11 Life-Cycle Cost Subgroup Analysis ........................................................................... 33
 

2.12 Manufacturer Impact Analysis.................................................................................... 33
 

2.13 Utility Impact Analysis............................................................................................... 34
 

2.14 Employment Impacts Analysis ................................................................................... 34
 

2.15 Environmental Assessment ......................................................................................... 35
 

2.16 Monetization of Emissions Reductions ...................................................................... 37
 

2.17 Regulatory Impact Analysis ........................................................................................ 38
 

LIST OF TABLES 

Table 2.1 Product Classes ............................................................................................................... 7
 

Table 2.2 Incandescent Reflector Lamp Technology Options..................................................... 10
 

Table 2.3 Baseline Lamp Characteristics ...................................................................................... 14
 

Table 2.4 65 W BR30 Higher Efficacy Lamp Designs ............................................................... 15
 

Table 2.5 45 W R20 Higher Efficacy Lamp Designs .................................................................. 16
 

Table 2.6 IRL Efficiency Levels.................................................................................................. 17
 

Table 2.7 Summary of Inputs and Key Assumptions Used for the LCC Analyses ..................... 22
 

Table 2.8 Inputs to the National Impact Analysis......................................................................... 30
 

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LIST OF ACRONYMS
 

AEO Annual Energy Outlook 

ANOPR Advanced notice of proposed rulemaking 

BPAR bulged parabolic aluminized reflector (reflector lamp shape) 

BR bulged reflector (reflector lamp shape) 

BT Building Technologies Program 

CAIR Clean Air Interstate Act 

CAMR Clean Air Mercury Rule 

CBECS Commercial Buildings Energy Consumption Survey 

CCT correlated color temperature 

CFR Code of Federal Regulations 

CFL compact fluorescent lamp 

CO2 carbon dioxide 

CSL candidate standard level 

DOE U.S. Department of Energy 

EIA Energy Information Administration 

EISA 2007 Energy Independence and Security Act of 2007 

EL efficiency level 

EPA Environmental Protection Agency 

EPACT 1992 Energy Policy Act of 1992 

EPACT 2005 Energy Policy Act of 2005 

EPCA Energy Policy and Conservation Act 

ER elliptical reflector (reflector lamp shape) 

FR Federal Register 

GRIM Government Regulatory Impact Model 

Hg mercury 

HIR halogen infrared reflector 

HVAC heating, ventilating and air conditioning 

INPV industry net present value 

IRL incandescent reflector lamp 

LCC lifecycle cost 

LMC U.S. Lighting Market Characterization Volume I 

MECS Manufacturer Energy Consumption Survey (MECS) 

MIA Manufacturer Impact Analysis 

NEMS National Energy Modeling System 

NEMS-BT National Energy Modeling System – Building Technologies 

NES national energy savings 

NIA National Impact Analysis 

NOPR notice of proposed rulemaking 

NOX nitrogen oxides 

NPV net present value 

PAR parabolic aluminized reflector (reflector lamp shape) 

PBP payback period 

R reflector (reflector lamp shape) 

RCFL reflector compact fluorescent lamp 

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RECS Residential Energy Consumption Survey 

RIA regulatory impact analysis 

SBA Small Business Administration 

SEC U.S. Securities and Exchange Commission 

SO2 sulfur dioxide 

TSD technical support document 

U.S.C. United States Code 

V volts 

W watts 

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Rulemaking Framework Document for Certain Small Diameter, Elliptical Reflector, 

and Bulged Reflector Incandescent Reflector Lamps 

1 Introduction 

1.1 Overview of the Framework Document 

The purpose of this framework document is to describe the detailed analytical approaches 

the U.S. Department of Energy (DOE) anticipates using to evaluate potential amended energy 

conservation standards for certain incandescent reflector lamps (IRLs). The framework 

document informs interested parties of the analytical methods, data sources, and key assumptions 

DOE plans to use in its notice of proposed rulemaking (NOPR) stage. The framework document 

is the starting point for developing energy conservation standards and is not a definitive 

statement on any issue to be determined in the rulemaking. DOE will analyze each product class 

of incandescent reflector lamps under consideration to determine whether amended energy 

conservation standards are technologically feasible, economically justified, and would result in 

significant energy savings. DOE will maintain information about this rulemaking on its website 

at: 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/incandescent_lamps.html 

. 

While DOE invites comment on all aspects of the material presented in this document, several 

specific issues on which DOE seeks comment are set out in comment boxes like this one. DOE 

uses these comment boxes to highlight issues and ask specific questions on the approaches DOE 

is proposing to follow to conduct the analyses required for the standards rulemaking. Such 

requests for feedback are numbered sequentially throughout the document and are repeated in 

Appendix A. 

1.2 Authority 

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

(EPCA or the Act) established the Energy Conservation Program for Consumer Products Other 

Than Automobiles, covering major household appliances. Subsequent amendments expanded 

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

equipment. In particular, the Energy Policy Act of 1992 (EPACT 1992) included amendments to 

EPCA that added as covered products certain IRLs with wattages of 40 watts (W) or higher, and 

that established energy conservation standards for these IRLs. In defining the term 

“incandescent reflector lamp,” EPACT 1992 excluded lamps with elliptical reflector (ER) and 

bulged reflector (BR) bulb shapes, and with diameters of 2.75 inches or less. Therefore, such 

IRLs were neither included as covered products nor subject to EPCA’s standards for IRLs. 

However, section 322(a)(1) of the Energy Independence and Security Act of 2007 (EISA 

2007) subsequently amended EPCA to expand the Act’s definition of “incandescent reflector 

lamp” to include lamps with a diameter between 2.25 and 2.75 inches, as well as lamps with ER, 

BR, bulged parabolic aluminized reflector (BPAR), or similar bulb shapes. (42 U.S.C. 

6291(30)(C)(ii) and (F)) Consequently, these lamps became covered products subject to EPCA’s 

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standards for IRLs, except that section 322(b) of EISA 2007 also amended EPCA to exempt 

from the IRL standards the following categories of these lamps: (1) lamps 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 (lamps that have a 

diameter of 2.5 inches or less, such as R20 lamps, are commonly referred to as small diameter 

lamps). (42 U.S.C. 6295(i)(1)(C)) (Hereafter, DOE refers to these lamps collectively as the 

“exempt IRLs.”) 

In a recent rulemaking to consider amending EPCA’s standards for IRLs and certain 

other types of lamps, DOE initially concluded that it lacked authority to set standards for the 

exempt IRLs. 74 FR 16920, 16930 (April 13, 2009). DOE also concluded, therefore, that these 

lamps were not covered by the EPCA directive that DOE consider amending the Act’s standards 

for IRLs and other lamps. (42 U.S.C. 6295(i)) However, upon consideration of the comments it 

received in that rulemaking, DOE decided to reexamine these conclusions. 74 FR 16920, 16930-

31 (April 13, 2009); 74 FR 34080, 34092 (July 14, 2009). 

DOE has undertaken this reexamination and has now concluded, for the reasons that 

follow, that it has the authority under EPCA to adopt standards for the exempt IRLs, and that 

these lamps are covered by the directive in 42 U.S.C. 6295(i) to amend EPCA’s standards for 

IRLs. First, by amending the definition of “incandescent reflector lamp” (42 U.S.C. 

6291(30)(C)(ii) and (F)), EISA 2007 effectively brought ER, BR, and small diameter lamps into 

the Federal energy conservation standards program as covered product, thereby granting DOE 

regulatory authority. Additionally, although 42 U.S.C 6295(i)(1)(C) exempts certain ER, BR, 

and small diameter lamps from statutorily-prescribed standards, EISA 2007 grants DOE 

authority to amend the standards laid out in 42 U.S.C 6295(i)(1), which includes subparagraph 

(C). As a result, the statutory text did not exempt the bulbs from future regulation, only from the 

specified minimum standards in 42 U.S.C. 6295(i)(1). Consequently, DOE is conducting this 

rulemaking to address the potential for development of energy conservation standards for the 

exempt IRLs. 

DOE must design any new or amended standard for these products to achieve the 

maximum improvement in energy efficiency that is technologically feasible and economically 

justified. Such standards must also result in significant conservation of energy. (42 U.S.C. 

6295(o)(2)(A) and (3)) To determine whether a proposed standard is economically justified, 

DOE must, after receiving comments on the proposed standard, determine whether the benefits 

of the standard exceed its burdens to the greatest extent practicable, weighing the following 

seven factors: 

1.	 The economic impact of the standard on manufacturers and consumers of products 

subject to the standard; 

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

products in the type (or class) compared to any increase in the price, initial charges, 

or maintenance expenses for the covered products which are likely to result from the 

imposition of the standard; 

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3.	 The total projected amount of energy 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 conservation; and 

7.	 Other factors the Secretary [of Energy] considers relevant. 

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

1.3 Background 

1.3.1History of Standards Rulemaking for ER, BR, and Small Diameter Incandescent 

Reflector Lamps 

As indicated above, EISA 2007 amended EPCA both to add as covered products the 

exempt IRLs (42 U.S.C. 6291(30)(C)(ii) and (F)) and to exempt them from EPCA’s energy 

conservation standards for IRLs (42 U.S.C. 6295(i)(1)(C). As also indicated, DOE initially 

concluded that it lacked authority to adopt standards for the exempt IRLs. Accordingly, in the 

recent lamps standards rulemaking, DOE’s analyses did not examine whether standards for these 

exempt IRLs might be warranted. (74 FR 34080, July 14, 2009) Based upon a reexamination of 

its authority, DOE decided to conduct this separate rulemaking to assess energy conservations 

standards for the exempt IRLs. 

1.3.2Current Rulemaking Process 

By publishing a notice of public meeting (NOPM), DOE is initiating the rulemaking to 

consider energy conservation standards for the exempt IRLs. To consider and develop such 

standards, DOE intends to conduct the following technical analyses in this rulemaking: 

•	 A market and technology assessment to characterize the relevant product markets and 

existing technology options, including prototype designs. 

•	 A screening analysis to review each technology option and determine if it is 

technologically feasible; is practical to manufacture, install, and service; would adversely 

affect product utility or product availability; or would have adverse impacts on health and 

safety. 

•	 An engineering analysis to develop cost-efficiency relationships that show the 

manufacturer’s cost of achieving increased efficiency. 

•	 An energy-use characterization analysis to determine the annual energy use of the exempt 

IRLs. 

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•	 A product-price analysis that determines low, medium, and high prices for consumers of 

exempt IRLs. 

•	 Life-cycle cost (LCC) and payback period (PBP) analyses to calculate, at the consumer 

level, the discounted savings in operating costs (less maintenance and repair costs) 

throughout the estimated average life of these products, compared to any increase in the 

installed cost for the products likely to result directly from imposition of the standard. 

•	 A shipments analysis to forecast shipments of the exempt IRLs, which will then be used 

to calculate the national impacts of standards on energy, net present value (NPV), and 

future manufacturer cash flows. 

•	 A national impact analysis (NIA) to assess the aggregate impacts at the national level of 

the NPV of total consumer LCC and national energy savings. 

•	 An LCC subgroup analysis to evaluate variations in customer characteristics that might 

cause a standard to affect particular consumer sub-populations, such as low-income 

households, differently than the overall population. 

•	 A manufacturer impact analysis (MIA) to estimate the financial impact of standards on 

manufacturers and to calculate impacts on competition, employment, and manufacturing 

capacity. 

•	 A utility impact analysis to estimate the effects of proposed standards on electric utilities. 

•	 An employment impact analysis to assess the aggregate impacts on national employment. 

•	 An environmental assessment to provide estimates of the effects of amended energy 

conservation standards on three pollutants—sulfur dioxide (SO2), nitrogen oxides (NOx), 

and mercury—as well as carbon emissions. 

•	 A regulatory impact analysis to present major alternatives to proposed amended energy 

conservation standards that could achieve substantially the same regulatory goal at a 

lower cost. 

This framework document and the associated public meeting represent the first step in the 

process to consider adoption of energy conservation standards for the exempt IRLs. Because the 

previous rulemaking for IRLs was completed relatively recently, DOE possesses methodologies 

for all stages of the analysis that have already been vetted and revised according to public 

comments. Accordingly, DOE intends to present the results of its analyses in the notice of 

proposed rulemaking (NOPR) phase. DOE is issuing the framework document and NOPM with 

the intention of receiving as much feedback as possible regarding the methodologies, data, and 

key assumptions that will be used for the analyses before performing the NOPR analyses. The 

analyses and proposed methodologies that will be used for the NOPR phase of this rulemaking 

are described in detail in the framework document, available at 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/incandescent_lamps.html 

. 

2 Rulemaking Analyses Overview and Proposed Methodology 

2.1 Test Procedures 

DOE’s test procedures for fluorescent and incandescent lamps are set forth in the Code of 

Federal Regulations (CFR) at 10 CFR part 430, subpart B, appendix R. These test procedures 

provide detailed instructions for measuring the performance of general service fluorescent lamps 

4 
 

 

 

 

and IRLs, as well as performance attributes of general service incandescent lamps, largely by 

incorporating several industry standards. In July 2009, in response to comments, DOE adopted 

amendments to the IRL test procedure, updating several industry standards. 74 FR 31829 (July 6, 

2009). Although DOE previously has not regulated the products addressed in this rulemaking, 

DOE believes that the IRL test procedures provided in 10 CFR 430, subpart B, appendix R are 

appropriate for ER, BR, and small diameter IRLs. Therefore, DOE is not proposing any 

amendments to the IRL test procedure. DOE requests comments on this tentative conclusion. 

Item 1 DOE welcomes comment on its conclusion that the test procedures for IRL 

covered by this rulemaking do not need to be updated. DOE believes that the IRL test 

procedures currently provided in 10 CFR part 430, subpart B, appendix R are appropriate 

for the ER, BR, and small diameter IRLs that are the subject of this rulemaking. 

2.2 Off Mode and Standby Mode Energy Consumption Standards 

Section 310(3) of EISA 2007 amended EPCA to require new or amended energy 

conservation standards adopted for a covered product after July 1, 2010 to address standby mode 

and off mode energy use. (42 U.S.C. 6295(gg)(3)) As the final rule in this standards rulemaking 

is scheduled for publication after July 1, 2010, DOE has done a preliminary analysis of the 

potential for energy savings associated with the regulation of standby mode and off mode energy 

use in these additional IRLs. Similar to DOE’s conclusion in the July 2009 final rule, DOE has 

determined that the IRLs that are the subjects of this rulemaking do not operate in standby mode 

or off mode. 74 FR 34080, 34094 (July 14, 2009). 

To meet EISA 2007’s definitions of ‘‘active mode,’’ ‘‘off mode,’’ and ‘‘standby mode’’ 

applicable to IRL (42 U.S.C. 6295(gg)(1)), the lamp must not be providing any active mode 

function (i.e., emitting light). However, to reach such a state, the lamp must be entirely 

disconnected from the main power source (i.e., switched off), thereby not satisfying the 

requirements of operating in off mode. In addition, DOE believes that all covered products that 

meet the definition of “incandescent reflector lamp” are single-function products and do not offer 

any secondary user-oriented or protective functions. Thus, IRLs do not satisfy the definition for 

“standby mode.” Therefore, DOE maintains that it is not feasible to incorporate off mode or 

standby mode energy use into the energy conservation standards for IRLs and is not considering 

amendments to the standard to address lamp operation in such modes. DOE requests comments 

on this tentative conclusion. 

Item 2 DOE welcomes comment on its decision to not amend energy conservation 

standards to address lamp operation in “off mode” or “standby mode.” DOE does not 

believe that any commercially-available IRLs satisfy the definition for “off mode” or 

“standby mode” operation. Therefore, DOE maintains that it is not feasible to incorporate 

off mode or standby mode energy use into the energy conservation standards for IRLs. 

2.3 Market and Technology Assessment 

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2.3.1Scope of Coverage 

EPCA defines “incandescent reflector lamp” as follows: “...[A] lamp in which light is 

produced by a filament heated to incandescence by an electric current . . . (commonly referred to 

as a reflector lamp) 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, an R, PAR, ER, BR, 

BPAR, or similar bulb shapes with E26 medium screw bases, a rated voltage or voltage range 

that lies at least partially within 115 and 130 volts, a diameter which exceeds 2.25 inches, and 

has a rated wattage that is 40 watts or higher.” (42 U.S.C. 6291(30)(C), (C)(ii) and (F)) 

EPCA further clarifies this definition of IRL by defining the lamp types excluded from 

the definition: “The term ‘rough service lamp’ means a lamp that--(i) has a minimum of 5 

supports with filament configurations that are C–7A, C–11, C–17, and C– 22 as listed in Figure 

6–12 of the 9th edition of the IESNA Lighting handbook, or similar configurations where lead 

wires are not counted as supports; and (ii) is designated and marketed specifically for ‘rough 

service’ applications, with -- (I) the designation appearing on the lamp packaging; and (II) 

marketing materials that identify the lamp as being for rough service.” (42 U.S.C. 6291(30)(X)) 

The term “vibration service lamp” means “a lamp that—(i) has filament configurations 

that are C-5, C-7A, or C-9, as listed in Figure 6-12 of the 9th Edition of the IESNA Lighting 

Handbook or similar configurations;(ii) has a maximum wattage of 60 watts; (iii) is sold at retail 

in packages of 2 lamps or less; and (iv) is designated and marketed specifically for vibration 

service or vibration-resistant applications, with—(I) the designation appearing on the lamp 

packaging; and (II) marketing materials that identify the lamp as being vibration service only.” 

(42 U.S.C. 6291(30)(AA)) 

The term “colored incandescent lamp” means “an incandescent lamp designated and 

marketed as a colored lamp that has—(i) a color rendering index of less than 50, as determined 

according to the test method given in C.I.E. publication 13.3–1995; or (ii) a correlated color 

temperature of less than 2,500K, or greater than 4,600K, where correlated temperature is 

computed according to the Journal of Optical Society of America, Vol. 58, pages 1528–1595 

(19861

).” (42 U.S.C. 6291(30)(EE)) 

As discussed earlier, section 322(b) of EISA 2007 incorporates several exemptions to the 

IRL standards in the new section 325(i)(1)(C) of EPCA. (42 U.S.C. 6295(i)(1)(C)) These 

exemptions are as follows: (1) lamps 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. As the July 2009 final rule has already evaluated amending 

standards for all IRLs other than the aforementioned exemptions, in this rulemaking, DOE 

intends to evaluate establishing energy conservation standards for solely the exempted ER, BR, 

and small diameter IRLs. 

1

 This journal article was incorrectly cited in the U.S. Code. The correct citation appears at 10 CFR 430.3(n). 

6 
 

 

 

2.3.2Product Classes 

When evaluating and establishing energy conservation standards, DOE divides covered 

products into classes by the type of energy used, capacity, other performance-related features 

that affect efficiency, and factors such as the utility of the product to users. (See 42 U.S.C. 

6295(q)) In the July 2009 final rule, DOE adopted product classes for IRLs based on three lamp 

attributes: (1) modified/standard-spectrum; (2) lamp diameter; and (3) input voltage. In addition, 

DOE decided to analyze standard levels for IRLs that allowed the minimum efficacy requirement 

to vary as a function of rated wattage. 74 FR 34080, 34099 (July 14, 2009). Given the similarity 

in technology between the IRLs for which standards were adopted in the July 2009 final rule and 

those additional IRLs being analyzed in this rulemaking, DOE believes that a similar approach to 

product classes is appropriate. 74 FR 34080, 34082 (July 14, 2009). Table 2.1 summarizes the 

product classes adopted in the July 2009 final rule and being considered in this rulemaking. Id. 

DOE invites comment on whether there are any unique characteristics of these additional ER, 

BR, and small diameter R-shaped IRLs that would warrant a different approach to product 

classes. The following section describes and discusses the product classes of IRLs that DOE is 

considering for this rulemaking. 

Table 2.1 Product Classes 

Spectrum Diameter, inches Voltage, volts 

> 2.5 ≥ 125 

Standard < 125 

≤ 2.5 ≥ 125 

< 125 

> 2.5 ≥ 125 

Modified < 125 

≤ 2.5 ≥ 125 

< 125 

2.3.2.1 Lamp Spectrum 

Modified-spectrum lamps (as defined in 42 U.S.C. 6291(30)(W)) provide a unique 

performance-related feature to consumers, in that they offer a different spectrum of light from a 

typical standard-spectrum incandescent lamp, much like two fluorescent lamps with different 

correlated color temperature2

 (CCT) values. Modified-spectrum lamps may ensure better color 

discrimination and often appear more similar to natural daylight, possibly resulting in 

psychological benefits.3 In addition to providing a unique performance feature, DOE also 

understands that the technologies that modify the spectral emission from these lamps also 

decrease their efficacy because a portion of the light emission is absorbed by the coating. Given 

the reduction in efficacy, DOE believes that some modified-spectrum lamps may not be able to 

meet standards if subjected to the same levels as standard-spectrum lamps. That, in turn, could 

2 Correlated color temperature means the absolute temperature of a blackbody whose chromaticity most nearly
 

resembles that of the light source. 10 CFR 430.2.

3

 ‘‘Full Spectrum Q&A,’’ National Lighting Product Information Program, Vol. 7 Issue 5 (March 2005). Available 

at: http://www.lrc.rpi.edu/programs/nlpip/lightingAnswers/fullSpectrum. 

7 
 

 

cause the unavailability of such products, thereby eliminating this performance-related feature 

from the IRL market. DOE notes that the statute prohibits DOE from prescribing a standard if 

such standard is likely to result in the unavailability of performance characteristics or features for 

a covered product type. (42 U.S.C. 6295(o)(4)) Thus, DOE believes it is appropriate to establish 

separate product classes for modified-spectrum lamps and standard-spectrum lamps, based on 

modified-spectrum lamps’ unique performance feature and the impact of this performance 

feature on product efficacy. 

2.3.2.2 Lamp Diameter 

In the July 2009 final rule, DOE adopted separate product classes for smaller-diameter 

lamps (i.e., lamps with a diameter less than or equal to 2.5 inches). 74 FR 34080, 34082 (July 14, 

2009). Such lamps provide a distinct utility (such as the ability to be installed in smaller 

fixtures) which generally results in lower efficacy because they have an inherently lower optical 

efficacy than larger-diameter lamps of similar filament size. In addition, DOE is aware that 

additional efficacy losses are associated with the installation of double-ended burners (a 

technology option to increase efficacy) in smaller-diameter lamps. Therefore, DOE is 

considering establishing separate product classes for lamps with a diameter of 2.5 inches or less 

and lamps with a diameter greater than 2.5 inches. 

2.3.2.3 Input Voltage 

Current DOE test procedures provide for lamps rated at 130 volts (V) to be tested at 130 

V and for lamps rated at 120 V to be tested at 120 V. However, DOE is aware that a large 

number of consumers actually operate 130 V lamps at 120 V, which results in longer lifetime but 

lower efficacy. With a single efficacy level (EL) for lamps rated at each voltage, this situation 

would effectively lead to a lower efficacy requirement for these 130 V lamps that are run at 120 

V, compared to 120 V lamps run at 120 V. These 130 V lamps would not require the same level 

of technology as 120 V-rated lamps to meet the same standard, and, thus, they would be cheaper 

to produce. Therefore, setting higher standards for IRLs without accounting for voltage 

differences could result in increased migration to the 130 V lamps and possible lost energy 

savings. For these reasons, in the July 2009 final rule, DOE set separate standards for 130 V 

lamps by establishing separate product classes based on rated voltage. 74 FR 34080, 34082 (July 

14, 2009). Similar to the approach discussed in the July 2009 final rule, DOE is considering 

establishing two separate sets of product classes: (1) lamps with a rated voltage less than 125 V, 

and (2) lamps with a rated voltage greater than or equal to 125 V. 

In summary, DOE is considering product class divisions based on standard/modified 

spectrum, lamp diameter, and input voltage. DOE requests comments on these product class 

divisions. 

Item 3 DOE welcomes comments on its decision to base product class divisions on 

standard/modified spectrum, lamp diameter, and input voltage. 

2.3.3Market Assessment 

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

the structure of the exempted incandescent reflector lamp market. DOE will identify and 

characterize the manufacturers of exempted incandescent reflector lamps, estimate market shares 

and trends in the market, and address regulatory and non-regulatory initiatives intended to 

improve the energy efficiency or reduce the energy consumption of the exempted incandescent 

reflector lamps. 

The market assessment phase allows DOE to gather data that will assist in identifying 

important issues later in the rulemaking, such as potential small business impacts, competitive 

disruptions, and other factors that may arise from enacting standards. For example, DOE will use 

historical equipment shipments and prices as an indicator of future shipments and prices. Market 

structure data will be particularly useful for assessing competitive impacts as part of the MIA. 

This phase also allows DOE to start identifying technologies commonly used for improving 

efficiency by reviewing product literature, industry publications, and company websites. 

DOE understands that there are considerable data available on manufacturers, market 

shares, and other information. Such data are essential to the development of technologicallyfeasible, economically-justified energy conservation standards. Interested parties are encouraged 

to submit any available, applicable data to DOE. The National Electrical Manufacturers 

Association (NEMA) is the trade association for manufacturers of incandescent reflector lamps. 

DOE expects that NEMA will play an important role in providing market information, including 

information on manufacturers, market shares, and trends in the market. 

Item 4 DOE invites interested parties to submit data relevant to the market assessment in 

the form of a written comment. This is includes historical shipments of the exempted 

incandescent reflector lamp market by lamp type, lamp wattage, and market sector. 

2.3.4 Technology Assessment 

In the technology assessment, DOE identifies technology options that appear to improve 

product efficacy. This assessment provides the technical background and structure on which 

DOE bases its screening and engineering analyses. Table 2.2 lists the technology options DOE 

identified to improve the efficacy of IRLs in the July 2009 final rule. 74 FR 34080, 34098 (July 

14, 2009). For a complete discussion on these technology options, please see chapter 3 of the 

July 2009 final rule technical support document (TSD).4 

4

 The July 2009 final rule TSD is available at the following web address: 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/incandescent_lamps_standards_final_rule_ts 

d.html. 

9 
 

 

 

Table 2.2 Incandescent Reflector Lamp Technology Options 

Name of Technology 

Option 

Description July 2009 Final Rule TSD 

Reference 

Higher-Temperature 

Operation 

Operating the filament at higher temperatures, the 

spectral output shifts to lower wavelengths, 

increasing its overlap with the eye sensitivity 

curve. This measure may shorten the operating life 

of the lamp. 

Chapter 3, Section 3.3.2.1 

Microcavity Filaments Texturing, surface perforations, microcavity holes 

with material fillings 

Chapter 3, Section 3.3.2.2 

Novel Filament Materials More-efficacious filament alloys Chapter 3, Section 3.3.2.3 

Thinner Filaments Thinner filaments to increase operating 

temperature. This measure may shorten the 

operating life of the lamp. 

Chapter 3, Section 3.3.2.4 

Efficient Filament Coiling Coiling of the filament to increase surface area Chapter 3, Section 3.3.2.5 

Crystallite Filament 

Coatings 

Layers of micron or submicron crystallites 

deposited on the filament surface 

Chapter 3, Section 3.3.2.6 

Efficient Filament 

Orientation 

Positioning the incandescent filament to increase 

light emission out of the lamp 

Chapter 3, Section 3.3.2.7 

Higher-Efficiency Inert Fill 

Gas 

Filling lamps with alternative gases, such as 

Krypton, to improve efficacy by reducing heat 

conduction 

Chapter 3, Section 3.3.2.8 

Luminescent Gas Gaseous fills that react with certain wavelengths 

of the filament emission to generate visible light 

Chapter 3, Section 3.3.2.9 

Tungsten-Halogen Lamps Small diameter fused quartz envelope with a 

halogen molecule to re-deposit tungsten on the 

filament. Commonly referred to as a “halogen” 

lamp. 

Chapter 3, Section 3.3.2.10 

Higher-Pressure TungstenHalogen Lamps 

Increased pressure of the halogen capsule by 

increasing the density of halogen elements. 

Chapter 3, Section 3.3.2.11 

Non-Tungsten Regenerative 

Cycles 

Novel filament materials that incorporate a 

regenerative cycle 

Chapter 3, Section 3.3.2.12 

Infrared Glass Coatings Infrared coatings (both phosphor and thin-film) to 

reflect some of the radiant energy back onto the 

filament. When used in conjunction with a halogen 

capsule, this technology option is referred to as a 

halogen infrared reflector (HIR) lamp. 

Chapter 3, Section 3.3.2.13 

Integrally-Ballasted LowVoltage Lamps 

The ballast converts the operating voltage of the 

lamp from line voltage to a lower voltage. 

Chapter 3, Section 3.3.2.14 

Higher-Efficiency Reflector 

Coatings 

Alternative internal coatings with higher 

reflectivity 

Chapter 3, Section 3.3.2.15 

Trihedral Corner 

Reflectors 

Individual corner reflectors in the cover glass that 

reflect light directly back in the direction from 

which it came 

Chapter 3, Section 3.3.2.16 

Efficient Filament 

Placement 

Positioning the filament to increase light emission 

out of the lamp 

Chapter 3, Section 3.3.2.17 

10 
 

 

 

Item 5 DOE welcomes comments on all of the technology options it is considering for 

IRLs, including any omissions or revisions necessary to have a more comprehensive 

technology assessment for the exempt IRLs covered in this rulemaking. In the context of 

commenting on technology options, DOE also requests information on the feasibility, 

performance improvement, and cost of the technology options, as well as any recent 

developments in their technical maturity. 

2.4 Screening Analysis 

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

considered further in the analysis. These “screened out” technologies will not be considered as 

possible methods of improving the efficiency of IRLs. Following development of the 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 comes into effect, 

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 this 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 this technology 

further. 

DOE’s reasoning for eliminating any technologies from consideration during the 

screening analysis will be documented and published as part of the NOPR, and will be available 

for review and comment by interested parties. DOE is seeking comments from interested parties 

about the technologies that should be considered for the NOPR analysis. 

Several technologies for improving the efficiency of incandescent reflector lamps were 

considered for the July 2009 final rule that were ultimately screened out during the screening 

analysis. Specifically, the following technologies were screened out: microcavity filaments, 

novel filament materials, crystallite filament coatings, luminescent gas, non-tungsten-halogen 

regenerative cycles, infrared phosphor coatings, and trihedral corner reflectors. See chapter 4 of 

the technical support document for the July 2009 final rule for more details. 

11 
 

 

 

Item 6 DOE requests comments regarding the technologies that were screened out for 

the July 2009 final rule and whether any additional technology options should be screened 

out for this rule. Specifically, DOE is seeking any data or information that would allow 

DOE to determine whether it is still appropriate to screen out these technologies. 

2.5 Engineering Analysis 

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. Design options consist of discrete 

technologies (e.g., halogen capsules, infrared reflective coatings). As detailed in the July 2009 

final rule, to ensure that efficacy levels analyzed are technologically feasible, DOE concentrated 

its efforts on developing product efficacy levels associated with “lamp designs," based upon 

commercially-available lamps that incorporate a range of design options in the engineering 

analysis. 74 FR 34080, 34102 (July 14, 2009). However, when necessary, DOE supplemented 

commercially-available product information with an examination of the improved performance 

attributable to discrete technologies so that a substitute lamp at each efficacy level would be 

available for each baseline lamp. 

In energy conservation standard rulemakings for other products, DOE often develops 

cost-efficiency relationships in the engineering analysis. However, for this rulemaking (similar to 

the July 2009 final rule), DOE will develop efficacy levels in the engineering analysis and enduser prices in the 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 the section 2.7 of this framework document for further details on the product price 

determination. 

2.5.1 Approach 

For this rulemaking, DOE is using the same methodology for the engineering analysis 

that was detailed in the July 2009 final rule. 74 FR 34080, 34102-08 (July 14, 2009). The 

following is a summary of the steps taken in that engineering analysis: 

• Step 1: Select Representative Product Classes 

• Step 2: Select Baseline Lamps 

• Step 3: Identify Higher-Efficacy Lamp Replacements 

• Step 4: Develop Efficiency Levels. 

A more detailed discussion of the methodology DOE followed to perform the engineering 

analysis can be found in the engineering analysis chapter of the July 2009 final rule TSD 

(chapter 5). 

12 
 

2.5.2 Representative Product Classes 

As discussed in section 2.3.2 of this framework document, DOE is considering 

establishing eight product classes for exempt IRLs. Similar to the approach in the July 2009 final 

rule, DOE is not planning to directly analyze each and every product class. Instead, DOE will 

carefully 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. 74 FR 34080, 34102 

(July 14, 2009). 

As discussed in section 2.3.2, DOE intends to subdivide the exempt IRLs into eight 

product classes with three subdivisions: (1) high versus low voltage; (2) large versus small 

diameter lamps; and (3) modified spectrum versus standard spectrum. As detailed in the July 

2009 final rule, DOE chose to analyze the standard-spectrum incandescent reflector lamp 

product class because standard-spectrum lamps are more common than modified-spectrum 

lamps. After analyzing catalog data and talking to industry experts, DOE found that lamps with 

voltage ratings less than 125 V also are more common than lamps with higher voltage ratings. 74 

FR 34080, 34102 (July 14, 2009). Similar to the July 2009 final rule, for this rulemaking, DOE 

intends to analyze the product classes characterized by standard spectrum and voltage less than 

125 V. Also, DOE found that among the lamps covered in the July 2009 final rule, lamps with a 

diameter greater than 2.5 inches are significantly more common than lamps of smaller diameters. 

Although, in the July 2009 final rule, DOE chose to directly analyze only lamps with diameters 

greater than 2.5 inches, for this rulemaking, DOE is considering directly analyzing both the large 

and small diameter product classes. 74 FR 34080, 34102 (July 14, 2009). DOE is considering 

this change because a large portion of the exempted IRL being considered for energy 

conservation standards in this rulemaking have small diameters (the R20 lamps with a rated 

wattage of 45 watts or less). 

2.5.3 Baseline Lamps 

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

representative units for analysis (i.e., baseline lamps) from within the representative product 

class. These representative units are generally what DOE believes to be the most-common, leastefficacious lamps in their respective product classes. To establish the baseline lamps for this 

rulemaking, DOE analyzed manufacturer catalogs to determine which currently-sold products 

fall within the scope of the current IRL exemptions. Based on the number of models sold across 

several manufacturer catalogs, DOE found that two lamp types make up most of the exempted 

lamp market: 65 W BR30 and 45 W R20. For this rulemaking, DOE is considering analyzing 

these two baseline lamps for the standard-spectrum, low-voltage, large-diameter and smalldiameter product classes, respectively. Table 2.3 depicts the common efficacy and lifetime 

characteristics of these baseline lamps. 

13 
 

Table 2.3 Baseline Lamp Characteristics 

Baseline 

Lamp 

Wattage Initial Light 

Output Efficacy Lamp Lifetime 

W Lm lm/W hr 

BR30 65 620 9.5 2,000 

R20 45 380 8.4 2,000 

2.5.4 Higher-Efficacy Lamp Designs 

As described in the July 2009 final rule engineering analysis, DOE considers only 

“design options”—technology options used to improve lamp efficacy that are not eliminated in 

the screening analysis. 74 FR 34080, 34102 (July 14, 2009). In the July 2009 final rule, DOE’s 

selection of design options guided its selection of higher-efficacy lamp designs and efficacy 

levels. Id. DOE identified natural “technology-based” divisions in the market around the type of 

incandescent technology used (e.g., non-halogen, halogen, or halogen infrared reflector (HIR)). 

DOE also identified certain technology options and created model lamps to represent the efficacy 

those technology options could achieve. 

DOE also accounted for lumen output when DOE established lamp designs for its 

analyses. For the LCC analysis, where possible, DOE considered those lamps that: (1) emit 

lumens equal to the lumen output of the baseline lamp, or below that lamp by no more than 10 

percent; and (2) result in energy savings. DOE took this approach in order to accurately 

characterize the cost-effectiveness of a particular efficacy level if a consumer makes an informed 

decision that maintains light output. However, because all consumers may not make such 

decisions, lamp designs that under-illuminate, over-illuminate, or do not result in energy savings 

were considered in the NIA. 

In the July 2009 final rule, DOE selected lamp designs and efficiency levels by observing 

natural efficacy divisions in the marketplace that correspond to the use of more-efficacious 

technologies (e.g., halogen capsules, HIR technology, and improved reflector coatings). 74 FR 

34080, 34102 (July 14, 2009). 

For this rulemaking, DOE intends to adopt these same technology divisions to develop 

higher-efficacy lamp design and efficiency levels. Because the lamps covered under this 

rulemaking are exempt from standards, DOE will analyze the baseline lamp designs from the 

July 2009 final rule as a higher-efficacy lamp option in this rulemaking. 74 FR 34080, 34102 

(July 14, 2009). Table 2.4 and Table 2.5 present the higher-efficacy lamp designs DOE intends 

to analyze in this rulemaking for the 65 W BR30 and 45 W R20 baseline lamps, respectively. As 

seen in Table 2.4, for the 65 W BR30 lamp, DOE is considering analyzing the same lamp 

designs as those analyzed for the 50 W PAR30 baseline in the July 2009 final rule. 74 FR 34080, 

34102 (July 14, 2009). As DOE believes that there is no clear utility difference between BR-, R-

, and PAR-shaped lamps, DOE intends to analyze PAR-shaped lamps as direct replacements for 

the BR- and R-shaped lamps. DOE developed the initial higher-efficacy lamp designs that serve 

as replacements for the 45 W R20 lamp by examining catalogs for commercially-available lamps 

and by estimating efficacy increases for each design option employed. As seen in Table 2.4 and 

14 
 

 

 

 

 

 

 

 

 

 

Table 2.5, DOE’s initial lamp designs for analysis do not have wattages below 40 W for two 

reasons. First, DOE’s scope of coverage of incandescent reflector lamps, as defined by EPCA, 

has a minimum wattage of 40 W. Second, DOE understands that there are difficulties employing 

some higher-efficacy design options (such as HIR capsules) in lamps with wattages below 40 W. 

Because DOE has preliminarily decided to not analyze lamps below the 40 W limit, many of the 

higher-efficacy lamp replacements for the 65 W BR30 and 45 W R20 lamps have higher lumen 

outputs than the baselines. 

Table 2.4 65 W BR30 Higher Efficacy Lamp Designs 

Efficacy 

Level (EL) 

Design 

Option 

Lamp 

Descriptor 

Wattage Efficacy Initial Light 

Output 

Lamp 

Life 

W lm/W lm hr 

Baseline Incandescent BR30 65.0 9.5 620 2,000 

EL1 Halogen PAR30 50.0 12.6 630 3,000 

EL2 

Improved 

Halogen 

(Xenon) 

PAR30 47.8 13.2 630 3,000 

EL3 

Long-Life HIR PAR30 46.0 13.5 620 6,000 

Improved 

Halogen (Silver) PAR30 45.0 14.0 630 3,000 

EL4 HIR PAR30 41.8 15.1 630 3,000 

EL5 

Improved HIR PAR30 40.0 17.0 680 4,000 

Low-Lifetime 

Improved HIR PAR30 40.0 17.0 680 3,000 

EL6 

Improved HIR 

Plus PAR30 40.0 19.1 765 4,200 

Low-Lifetime 

Improved HIR 

Plus 

PAR30 40.0 19.1 765 2,500 

15 
 

 

 

 

 

 

 

 

 

Table 2.5 45 W R20 Higher Efficacy Lamp Designs 

Efficacy 

Level 

Design 

Option 

Lamp 

Descriptor 

Wattage Efficacy Initial Light 

Output 

Lamp 

Life 

W lm/W lm hr 

Baseline Incandescent R20 45.0 8.4 380 2,000 

EL1 Halogen PAR20 40.0 10.4 416 2,500 

EL2 

Improved 

Halogen 

(Xenon) 

PAR20 40.0 10.9 437 2,500 

EL3 

Long-Life HIR PAR20 40.0 12.1 483 6,000 

Improved 

Halogen (Silver) PAR20 40.0 11.6 463 2,500 

EL4 HIR PAR20 40.0 13.3 530 3,000 

EL5 Improved HIR PAR20 40.0 14.3 570 3,000 

EL6 Improved HIR 

Plus PAR20 40.0 15.8 633 3,000 

2.5.5 Efficiency Levels 

As wattage increases for incandescent lamps, efficacy generally increases. So that the 

efficacy levels (ELs) reflected the performance of these lamps, in the July 2009 final rule, DOE 

established that the efficacy requirement for IRLs varies according to the following equation: 

a*P0.27, where “a” is a constant specifying the technology level and “P” is the wattage of the 

lamp. 74 FR 34080, 34104 (July 14, 2009). For this rulemaking, DOE intends to maintain the 

continuous function for IRL in the same equation form used in the July 2009 final rule. In 

addition, because the majority of lamp designs discussed above are identical to those analyzed in 

the July 2009 final rule, DOE intends to adopt EL1 through EL5 from the July 2009 final rule as 

EL2 through EL6 for this rulemaking. Similarly, the baseline lamps from the July 2009 final 

rule will become EL1 for this rulemaking and the exempt lamps will become the new baseline.5 

74 FR 34080, 34102-8 (July 14, 2009). 

In summary, DOE will consider six efficacy levels in the NOPR. EL1 is based on a 

halogen lamp with a lifetime of 3,000 hours for large diameter lamps and 2,500 hours for small 

diameter lamps. EL2 is based on an improved halogen lamp that uses xenon, a higher-efficiency 

inert fill gas, and has a lifetime of 3,000 or 2,500 hours for large or small diameter lamps, 

respectively. EL3 is based on a halogen infrared lamp with a lifetime of 6,000 hours. A halogen 

lamp using a silverized reflector coating also meets this EL. EL4 is based on the 3,000-hour HIR 

lamp. EL5 is based on an improved HIR lamp with a lifetime of 4,000 hours for large diameter 

lamps and 3,000 hours for small diameter lamps. EL6 is based on a further improved HIR lamp 

5

 In the July 2009 final rule, there was not a baseline lamp identified for small diameter lamps because those product 

classes were not directly analyzed. For this rulemaking, DOE intends to select a small diameter lamp for EL1 that 

uses an equivalent technology (halogen) as the analyzed baseline lamps in the July 2009 final rule. 

16 
 

 

 

 

with a lifetime of 4,200 or 3,000 hours for large or small diameter lamps, respectively. In the 

July 2009 final rule, DOE used IRL compliance report data to adjust the efficacy levels presented 

in the April 2009 NOPR downward to better reflect the observed compliance efficacies of 

commercially-available lamps that feature the described technologies of each EL. DOE intends 

to adopt the same approach in this rulemaking. Table 2.6 lists the ELs DOE intends to analyze 

for both representative product classes in this rulemaking. 

Table 2.6 IRL Efficiency Levels 

Lamp 

Wattage, 

W 

Lamp 

Type 

Diameter, 

inches 

Voltage, 

V 

Efficiency Level* 

1 2 3 4 5 6 

40–205 Standardspectrum 

> 2.5 < 125 4.2 4.6 4.8 5.4 5.9 6.4 

≤ 2.5 < 125 3.8 4.0 4.2 4.8 5.0 5.4 

*The values in this table are the coefficients A in the equation A*P^0.27, which represents the efficacy level 

requirement for IRL. P is the rated wattage of the lamp. 

2.5.6 Scaling to Product Classes Not Analyzed 

As discussed above, DOE plans to select certain product classes as “representative” 

product classes where DOE would concentrate its analytical effort. DOE chooses these 

representative product classes primarily because of their high market volumes. In the July 2009 

final rule, DOE stated that IRLs operated at 130 V are generally 15 percent more efficacious than 

when they are operated at 120 V; thus, DOE established a separate product class such that 130 V 

IRLs would be subject to standards that are 15-percent higher than 120 V IRL standards, 

allowing DOE to take into account the efficacy reduction that 130 V IRLs will experience when 

operated at 120 V. 74 FR 34080, 34107-08 (July 14, 2009). For modified-spectrum lamps, as 

discussed in the July 2009 final rule, DOE conducted an analysis to determine how the 

concentration of neodymium affects efficacy of IRLs. Using that analysis, DOE implemented a 

15-percent reduction in efficacy levels for the modified-spectrum IRL product classes. 74 FR 

34080, 34106 (July 14, 2009). In consideration of the similarity in technologies between the 

exempt IRLs covered in this rulemaking and those covered in the July 2009 final rule, DOE 

intends to use the same scaling relationships for this rulemaking as those established in the July 

2009 final rule. 74 FR 34080, 34105-8 (July 14, 2009). 

Item 7 DOE welcomes comments on its decision to use the same methodology for the 

engineering analysis as that used in the July 2009 final rule. DOE specifically requests 

comments on the following: (1) the designated representative product classes; (2) the 

selected baseline lamps; (3) the selected higher-efficiency lamp designs; (4) the efficiency 

levels considered for analysis; and (5) the adjustments considered for scaling to product 

classes not analyzed. 

17 
 

 

 

2.6 Energy Use Characterization 

The purpose of the energy-use characterization is to estimate the energy consumption of 

the baseline and higher-efficacy lamps considered in this analysis. DOE determines the energy 

consumption of the lamps through the rated power (i.e., rated in watts) 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. The 

energy-use characterization enables DOE to determine the LCC and the PBP of more-efficacious 

lamps relative to the baseline lamp. DOE derives the annual energy consumption of lamps by 

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

In the July 2009 final rule, DOE developed operating hours for IRLs in both the 

residential and commercial sectors. 74 FR 34080, 34111 (July 14, 2009). DOE did not analyze 

IRLs in the industrial sector, because they are rarely used in industrial settings. 74 FR 16920, 

16954 (April 13, 2009). As the exempt IRLs are similar to those included in coverage by the 

July 2009 final rule, DOE does not intend to analyze exempt IRLs in the industrial sector for this 

rulemaking. In addition, DOE accounted for variability of operating hours by developing a 

distribution of operating hours for the LCC spreadsheet. DOE used the U.S. Lighting Market 

Characterization Volume I (LMC)6

 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 category for all sectors. Within the commercial sector, the distributions 

were broken down by application, and within the residential sector, the distribution was broken 

down by room type. 

In conjunction with data from the LMC, DOE used data from the Energy Information 

Administration’s (EIA) 2003 Commercial Building Energy Consumption Survey (CBECS)7, 

2005 Residential Energy Consumption Survey (RECS)8

, and the 2002 Manufacturing Energy 

Consumption Survey.9 These EIA studies provide information on the distribution of buildings 

within the U.S., by building type and Census Division. DOE used the LMC’s operating hour 

data by building type and the EIA’s data by building type and Census Division to derive 

operating hours by Census Division. This allowed DOE to correlate the electricity price 

distribution and sales tax distribution with the operating hour distribution by Census Division in 

the LCC spreadsheet. 

6

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

for Consumer Products: Final Report: U.S. Lighting Market Characterization, Volume I: National Lighting
 

Inventory and Energy Consumption Estimate (2002). Available at:
 

http://www.eere.energy.gov/buildings/info/documents/pdfs/lmc_vol1_final.pdf.

7

 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: http://www.eia.doe.gov/emeu/cbecs/public_
 

use.html.
 8

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

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

9

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

Table 1.4: Number of Establishments by First Use of Energy for All Purposes (Fuel and Nonfuel) (2002). Available 

at: http://www.eia.doe.gov/emeu/mecs/mecs2002/data02/ shelltables.html.
 

18 
 

 

For the residential sector, DOE used RECS building data and LMC residential sector 

operating hour data. The 2005 RECS data indicate the probability that a certain building type is 

within a Census Division. The LMC indicates the occurrence of certain room types within a 

given building type and the operating hour characteristics of typical lamps in these rooms. By 

using probabilities derived from RECS, the LCC model selected a building of a certain type and 

Census Division. The model then selected a room within that building type using LMC data and 

presented operating hour data for a typical lamp in that room. 

DOE used a similar approach to the one described for the residential sector to develop a 

distribution of operating hours in the commercial sector. However, in lieu of room type, the 

model selected operating hours based on application. The 2003 CBECS data indicate the 

probability a certain building type is located in a certain Census Division. Once the LCC model 

selected a building, DOE used the LMC to indicate the probability a lamp was installed in a 

certain application in that building. The LMC then estimated the operating hour characteristics of 

a typical lamp for that application. 

Item 8 DOE welcomes comments on its methodology to determine operating hours for 

covered lamps in the commercial and residential sectors. 

2.7 Product Price Determination 

This section explains how DOE is considering developing end-user prices for baseline 

products and higher-efficacy products, and how DOE is considering developing the sales tax 

figures to use in the analyses. 

In the July 2009 final rule, DOE obtained 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 from 

distributors, State contracts, and other publicly-available information sources. In addition, DOE 

obtained information on distributor pricing (i.e., what a distributor would pay) for commercial, 

industrial, and institutional consumers of lamps. 74 FR 34080, 34110-11 (July 14, 2009). 

Starting from a consistent set of prices in the blue books, DOE looked at publiclyavailable prices in State procurement contracts, at large electrical supply distributors, homeimprovement/hardware stores, and other sources of publicly-available end-user prices, such as 

Internet retailers. In its review of publicly-available market prices, DOE observed a range of enduser prices paid for a given lamp, depending on the distribution channel through which it was 

purchased and the volume at which it was purchased. DOE observed that State procurement 

contracts typically negotiated a discount of around 70 to 90 percent off the blue book. In the vast 

majority of instances, these discounts applied uniformly to all products on a price schedule 

irrespective of the volume of a particular lamp. 

Internet retailers, electrical supply distributors, and home-improvement/ hardware stores 

generally reflected prices paid by consumers in the medium-to-high range of prices. 

Furthermore, these channels usually applied different discounts to lamps depending on their sales 

19 
 

 

volume. Since many high-efficacy lamps are ‘‘niche’’ products, DOE observed that they were 

generally less discounted than commodity lamps. 

Using this information, DOE developed three sets of discounts from the blue books, 

representing the range of low, medium, and high lamp prices for IRLs. To reflect future 

commoditization of higher-efficacy lamps when they become the minimum complying products, 

the discounts DOE applied to blue books to derive the low, medium, and high prices are a 

constant markdown across all lamps. Commercially-available IRL products did not span the full 

range of efficacies considered. For those lamps where commercial pricing was not available, 

DOE extrapolated pricing from available lamps. 

Once DOE calculated end-user prices, DOE added sales tax and, if appropriate, 

installation costs to derive the total, installed end-user cost. For the reference case in the LCC, 

DOE used the medium lamp prices, but it also conducted analysis at the low and high lamp 

prices, to ascertain the impact of these other price points. In the NIA, DOE used only the 

medium prices because this price scenario best represents the average purchase price for a 

variety of consumers nationwide. 

For this rulemaking for exempt IRLs, DOE is considering using the same prices for the 

65 W BR30 baseline lamp and its higher-efficacy replacements as those developed for the July 

2009 final rule. 74 FR 34080, 34110-11 (July 14, 2009). Because DOE did not establish prices 

for small diameter lamps in the July 2009 final rule, for the 45 W R20 baseline lamp, DOE will 

use discounted blue book prices to establish a baseline lamp price. Then, because many of the 

higher-efficacy lamp replacements are not commercially-available, DOE intends to apply the 

same incremental prices between technologies (calculated from the 65 W BR30) to the 45 W 

R20 baseline lamp price. DOE requests comments on its approach to developing lamp prices for 

lamps covered by this rulemaking for exempt IRLs. 

In the July 2009 final rule, DOE presented sales tax figures that represented State and 

local sales taxes that were applied to the consumer product price. 74 FR 34080, 34111 (July 14, 

2009). It was a multiplicative factor that increased the consumer product price. DOE derived 

State and local taxes from data provided by the Sales Tax Clearinghouse.10 The data represented 

weighted averages that included county and city rates. DOE is considering using the same 

methodology to develop sales tax figures for this rulemaking for exempt IRLs. DOE requests 

comments on this approach. 

Item 9 DOE welcomes comments on its decision to use the same methodology as the July 

2009 final rule to develop lamp prices and sales tax figures for this rulemaking. 

2.8 Life-Cycle Cost and Payback Period Analyses 

10 Sales Tax Clearinghouse, Aggregate State Tax Rates (2007). Available at: http://thestc.com/STrates.stm. 

20 
 

 

This section describes the LCC and payback period analyses and the spreadsheet model 

DOE intends to use for analyzing the economic impacts of possible standards on individual 

consumers. DOE will conduct the LCC and PBP analyses using a spreadsheet model developed 

in Microsoft Excel, similar to the one developed for the July 2009 final rule. When combined 

with Crystal Ball (a commercially-available software program), the LCC and PBP model 

generates a Monte Carlo simulation11 to perform the analysis by incorporating uncertainty and 

variability considerations. 

The LCC analysis estimates the impact of a standard on consumers by calculating the net 

cost of a lamp under a base-case scenario (in which no new energy conservation standard is in 

effect) and under a standards-case scenario (in which a potential energy conservation standard is 

applied). As detailed in the July 2009 final rule, the life-cycle cost of a particular lamp design is 

composed of the total installed cost (which includes manufacturer selling price, sales taxes, 

distribution chain mark-ups, and any installation cost), operating expenses (energy, repair, and 

maintenance costs), product lifetime, and discount rate. 74 FR 34080, 34108 (July 14, 2009). 

As noted in the July 2009 final rule, DOE also incorporated a residual value calculation to 

account for any remaining lifetime of lamps at the end of the analysis period. Id. The residual 

value is an estimate of the product’s value to the consumer at the end of the life-cycle cost 

analysis period. In addition, this residual value must recognize 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.

12 

The payback period is the change in product purchase expense due to an increased energy 

conservation standard, divided by the change in annual operating cost that results from the 

standard. Stated more simply, the payback period is the time period it takes to recoup the 

increased purchase cost (including installation) of a more-efficient product through energy 

savings. DOE expresses this period in years. As in the July 2009 final rule, DOE intends to use a 

“simple” PBP for this rulemaking, because the PBP does not take into account other changes in 

operating expenses over time or the time value of money. 74 FR 34080, 34113 (July 14, 2009). 

As inputs to the PBP analysis, DOE used 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. 

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

certain inputs and variables.

12 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/fire/firedocs/build96/PDF/b96121.pdf. 

21 
 

 

 

 

 

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 

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

or rebutting the results of any preliminary determination of economic justification). 

Table 2.7 summarizes the approach and data that DOE intends to use to derive the inputs 

to the LCC and PBP calculations for the exempt IRLs rulemaking. The following sections 

discuss several of these inputs not addressed by other analyses DOE conducts. 

Table 2.7 Summary of Inputs and Key Assumptions Used for the LCC Analyses 

Inputs Description 

Consumer Product 

Price 

Applies discounts to manufacturer catalog (“blue-book”) pricing in order to represent 

low, medium, and high prices for all lamp categories. See Product Price Determination. 

Sales Tax Derives weighted-average tax values for each Census Division and large State from 

data provided by the Sales Tax Clearinghouse. See Product Price Determination. 

Installation Cost Derives costs using the RS Means Electrical Cost Data, 2007 to obtain average labor 

times for installation, as well as labor rates for electricians and helpers based on wage 

rates, benefits, and training costs. 

Annual Operating 

Hours 

Determines operating hours by associating building-type-specific operating hours data 

with regional distributions of various building types using the 2002 U.S. Lighting 

Market Characterization and the Energy Information Administration’s (EIA) 2003 

Commercial Building Energy Consumption Survey (CBECS) and 2005 Residential 

Energy Consumption Survey. See Energy Use Characterization. 

Product Energy 

Consumption Rate 

Determines lamp input power based on published manufacturer literature. See 

Engineering Analysis. 

Electricity Prices Price: Based on EIA’s 2007 Form EIA-861 data. 

Variability: Regional energy prices determined for 13 regions 

Electricity Price 

Trends 

Forecasts with EIA’s Annual Energy Outlook (AEO) 2009. 

Lifetime Lamp lifetime based on published manufacturer literature where available. Where 

manufacturer literature was not available, DOE derived lamp lifetimes as part of the 

engineering analysis. 

Discount Rate Residential: Approach based on the finance cost of raising funds to purchase lamps 

either through the financial cost of any debt incurred to purchase product or the 

opportunity cost of any equity used to purchase equipment, based on the Federal 

Reserve’s Survey of Consumer Finances data for 1989, 1992, 1995, 1998, 2001, 2004, 

and 2007. Uses data from the Cost of Savings Index dataset covering 1984 to 2008. 

Commercial: Derives discount rates using the cost of capital of publicly-traded firms in 

the sectors that purchase lamps, based on data in the 2003 CBECS, Damodaran Online, 

Ibbotson’s Associates, the 2007 Value Line Investment survey, Office of Management 

and Budget (OMB) Circular No. A-94, 2008 State and local bond interest rates, and the 

U.S. Bureau of Economic Analysis. 

Analysis Period Based on the baseline lamp life divided by the annual operating hours of that lamp. 

Lamp Purchasing 

Events 

DOE assesses two events: lamp failure and new construction/renovation. 

22 
 

 

2.8.1 Installation Costs 

As detailed in the July 2009 final rule, DOE considers the total installed cost of a lamp to be the 

consumer product price (including sales taxes) plus the installation cost. 74 FR 34080, 34108 

(July 14, 2009). For the commercial sector, DOE assumes an installation cost that was the 

product of the average labor rate and the time needed to install a lamp. In the residential sector, 

DOE assumes that consumers would install their own replacement lamps and, thus, would incur 

no installation cost. 

In the July 2009 final rule, DOE derived costs using the “RS Means Electrical Cost Data, 

200713” to obtain average labor times for installation, as well as labor rates for electricians and 

helpers based on wage rates, benefits, and training costs. DOE uses “RS Means Electrical Cost 

Data, 2007,” because labor costs in RS Means are based on labor union agreements and 

construction wages, as well as actual working conditions in 30 major U.S. cities. 74 FR 34080, 

34109 (July 14, 2009). In the July 2009 final rule, DOE estimated that the rates for electricians 

and electrician’s helpers in 2007 dollars are $55.41 per hour and $27.70 per hour, respectively. 

DOE also determined the lamp replacement labor rate to be $15.94 per hour in 2007 dollars. 74 

FR 34080, 34109 (July 14, 2009). DOE intends to use the same installation rates for this 

rulemaking for exempt IRLs. 

2.8.2 Electricity Prices 

In the July 2009 final rule, DOE determined energy prices by deriving regional average 

prices for 13 geographic areas consisting of the nine U.S. Census Divisions, with four large 

States (New York, Florida, Texas, and California) treated separately. 74 FR 34080, 34109 (July 

14, 2009). The derivation of prices was based on data in EIA’s Form EIA-861.14 DOE intends 

to use the same methodology for this rulemaking for exempt IRLs. 

2.8.3 Electricity Price Trends 

DOE will use projections of national average electricity prices to residential and 

commercial consumers to estimate future energy prices and energy bill savings in its LCC 

analysis. DOE will use the most recently available edition of EIA’s Annual Energy Outlook 

(AEO) as the default source of projections for future energy prices. 

2.8.4 Lifetime 

13 R. S. Means Company, Inc., 2007 RS Means Electrical Cost Data (2007).
 14 Energy Information Administration, Form EIA-861 Final Data File for 2006 (2006)(Last accessed June 20, 

2008). Available at: .
 

23 
 

 

 

 

When possible, DOE intends to use manufacturer literature to measure lamp lifetimes for 

exempt IRLs, as in the July 2009 final rule. 74 FR 34080, 34109 (July 14, 2009). When 

published manufacturer literature is not available, DOE will derive lamp lifetimes as part of the 

engineering analysis. 

2.8.5 Analysis Period 

The analysis period is the span of time over which the LCC is calculated. For the July 

2009 final rule, DOE used the longest baseline lamp life in a product class divided by the annual 

operating hours of that lamp as the analysis period. 74 FR 34080, 34110 (July 14, 2009). During 

Monte Carlo simulations for the LCC analysis, DOE selected the analysis period based on the 

longest baseline lamp life divided by the annual operating hours chosen by Crystal Ball. For this 

rulemaking for exempt IRLs, DOE intends to retain this methodology. 

2.8.6Consumer Discount Rates 

The calculation of consumer LCC requires the use of an appropriate discount rate. DOE 

uses the discount rate to determine the present value of lifetime operating expenses. The discount 

rate used in the LCC analysis represents the rate from an individual consumer’s perspective.15 

For consumers of exempt IRLs, DOE plans to use the same approach that it relied on to 

develop discount rates for July 2009 final rule (i.e., deriving the discount rates from estimates of 

the interest or “finance cost” to purchase residential products). 74 FR 34080, 34109 (July 14, 

2009). The finance cost of raising funds to purchase these products can be interpreted as: (1) the 

financial cost of any debt incurred to purchase products (principally interest charges on debt), or 

(2) the opportunity cost of any equity used to purchase products (principally interest earnings on 

household equity). Household equity is represented by holdings in assets such as stocks and 

bonds, as well as the return on homeowner equity. Much of the data required, which involves 

determining the cost of debt and equity, comes from the Federal Reserve Board’s triennial 

Survey of Consumer Finances.

16 

Item 10 DOE welcomes comments on its decision to use a similar approach as the July 

2009 final rule to conduct the LCC and PBP analyses. 

2.9 Shipments Analysis 

This section presents the methodology DOE is considering for the shipment analysis, 

which is an input into the national impact analysis and manufacturer impact analysis. The 

15 The consumer discount rate is in contrast to the discount rates used in the national impact analysis, which are 

intended to represent the rate of return of capital in the U.S. economy as well as the societal rate of return on private 

consumption.

16 Available at: http://www.federalreserve.gov/pubs/oss/oss2/scfindex.html. 

24 
 

 

 

following section provides a summary of the shipment methodology from the July 2009 final 

rule and highlights those areas in which the analysis for this rulemaking will remain the same or 

differ. 74 FR 34080, 34115-16 (July 14, 2009). 

In the July 2009 final rule, DOE developed a base-case shipment forecast for each 

analyzed lamp type to depict what would happen to energy use, and to consumer costs for 

purchase and operation of lamps, in the absence of new or revised energy conservation standards. 

To evaluate the impacts of such standards for those lamps, DOE compared the estimated basecase projection against forecasted estimates of what would happen if DOE were to promulgate 

standards for IRLs. 

DOE followed a four-step process to forecast shipments for IRLs. First, DOE used 2001-

to-2005 historical shipment data from NEMA and other publicly-available sources to estimate 

the total historical shipments (i.e., NEMA member and non-NEMA member shipments) of each 

lamp type analyzed. Second, based on these historical shipments and the average service lifetime 

of each lamp type, DOE calculated the installed stock of lamps in 2005. Third, by applying 

growth, emerging technologies, and shipment assumptions, DOE projected lamp stock from 

2006 to 2042. DOE then calculated the lamp shipments required to meet the lamp stock 

projections based on operating hours and lifetimes. DOE calibrated its shipments model to reflect 

confidential shipment data provided by NEMA for 2006 and 2007. Finally, DOE developed 

base-case and standards-case market-share matrices as another model input. The market-share 

matrices characterized the efficacy, power rating, light output, and lifetime of the lamp designs. 

DOE is considering adopting this methodology for the present rulemaking for exempt 

IRLs. Each of the above steps is discussed in further detail below. 

2.9.1Historical Shipments 

As discussed in the July 2009 final rule, NEMA provided shipment data on IRLs 

spanning from 2001 to 2005. 74 FR 34080, 34115-16 (July 14, 2009). Recognizing that these 

shipment figures cover only NEMA members, DOE increased these estimates slightly to account 

for the volume of IRLs that were imported and/or manufactured by non-NEMA lamp companies. 

DOE assumed NEMA shipments represented 85 percent of all halogen lamp shipments and 70 

percent of all incandescent lamp shipments. Furthermore, DOE used manufacturer product 

catalogs to estimate the market share of the products covered by the July 2009 final rule versus 

those products that were exempt. DOE estimated that for both the commercial and residential 

sectors, 60 percent of the historical non-halogen lamp shipments were exempt from standards. 

In the July 2009 final rule, to model IRLs operated in the commercial sector separately 

from those operated in the residential sector, DOE used a reflector lamp study conducted by the 

New York State Energy Research and Development Authority17 with additional shipment data 

17 New York State Energy Research and Development Authority, Incandescent Reflector Lamps Study of Proposed 

Energy Efficiency Standards for New York State (2006). 

25 
 

submitted by NEMA (NEMA, No. 17 at p. 2)18 to estimate the percentage of incandescent and 

halogen IRL shipments by sector. DOE estimated that 33 percent of incandescent and 60 percent 

of halogen lamp shipments go to the commercial sector, whereas 67 percent of incandescent and 

40 percent of halogen shipments go to the residential sector. 

For this rulemaking for exempt IRLs, DOE will continue to use this same historical 

shipment data and the assumptions presented above to develop forecasts for the exempted lamp 

types. DOE requests comments on these assumptions. 

2.9.2Installed Stock 

Based on these historical shipments and the average service lifetime of each lamp type, 

DOE calculated the installed stock of lamps (total lamp sockets) in 2005. DOE assumed a 

distribution of operating hours in the residential sector due to the variety of usage patterns 

present in a single home. DOE then used growth in floor space, lamp replacement, and 

assumptions regarding emerging technologies to model the installed stock from 2006 to 2042. 

DOE determined anticipated growth in the number of IRL sockets using historical residential 

building growth from RECS 2005 and historical commercial floor space growth from CBECS 

2003. 

In this rulemaking for exempt IRLs, DOE is considering using a similar methodology 

with a several changes. Because the final rule for these products is expected to be published in 

2011 and take effect in 2014, DOE will project the installed stock from 2006 to 2043. DOE will 

update the emerging technology percentages to reflect the wattage and lumens of the selected 

baseline lamps. Additionally, DOE will attempt to account in the base case for an additional shift 

of shipments to lamps covered by this rulemaking once the July 2009 final rule takes effect. 

DOE requests comments on this methodology. 

2.9.2.1 Existing/Emerging Technologies Scenarios 

In the July 2009 final rule, DOE accounted for the market impact of reflector compact 

fluorescent lamps (RCFLs) and emerging technologies in the NIA by deducting the anticipated 

RCFL/emerging technology market share from the installed base. 74 FR 34080, 34117-18 (July 

14, 2009). For example, if DOE projected that 10 percent of consumers would switch from IRLs 

to other emerging technologies, DOE would reduce the installed stock of IRLs by this amount. 

This methodology effectively reduced the size of the market impacted by energy conservation 

standards, without requiring DOE to prepare estimates of the price and efficacy of those 

emerging technologies for the NIA model. Thus, DOE could incorporate the impact of RCFLs 

and emerging technologies in the base-case and standards-case, without having to prepare 

uncertain forecasts for those technologies. 

18 This written comment, document number 17, was submitted in response to the Energy Conservation Program for 

Commercial and Industrial Equipment: High–Intensity Discharge Lamps and is available in Docket #EE-DET-03-

001. 

26 
 

 

 

DOE is considering using the same methodology for this rulemaking for exempt IRLs, 

but will update its projections of percentage market penetration to reflect the characteristics of 

the baselines selected in the engineering analysis. DOE requests comments on the emerging and 

existing technology scenarios. 

2.9.2.2 Additional Shipments Growth Due to the July 2009 Final Rule 

The standards adopted in the July 2009 final rule take effect in 2012. At that time, IRLs 

covered by that rulemaking will be required to comply with what is equivalent to efficiency level 

5 of this rulemaking. 74 FR 34080, 34082 (July 14, 2009). As these lamps have higher prices 

than the baseline lamps being considered in this rulemaking for exempt IRLs, consumers who 

make purchase decisions based on first cost will likely purchase a lamp exempted from those 

standards (but covered by this rulemaking). Thus, in 2012, it is likely that shipments of lamps 

covered by this rulemaking will increase as some consumers purchase the cheapest lamp 

available. In addition to growth due to new construction, DOE is considering modeling this 

effect in the base-case shipment forecast. DOE requests comments on this approach. 

2.9.3Market-Share Matrices 

As discussed in the engineering analysis and the LCC analysis, consumers have available 

to them a variety of choices in terms of types of lamps. Consumers often make their choice after 

considering lamp attributes such as lifetime, efficacy, price, lumen output, and rated wattage. 

Therefore, within each product class, DOE believes it necessary to directly account for the mix 

of technologies which consumers select in the base case and standards case. In order to account 

for the range of possible consumer choices, DOE will develop and populate technology marketshare matrices. These market-share matrices allocate percentage market shares to each of the 

lamp technologies for the base case and standards case by proportioning lamp stocks. This 

enables the IRL shipment model to capture a migration to different lamps over time in both the 

base case and standards case. To establish the base-case market-share matrices, DOE requests 

comment on the average shipment-weighted wattage or market shares by wattage of the IRLs 

covered under this rulemaking. 

In addition, for the standards-case market-share matrices in the July 2009 final rule, DOE 

implemented two shipment scenarios for IRLs: (1) ‘‘roll-up,’’ and (2) ‘‘shift.’’ 74 FR 34080, 

34115-16 (July 14, 2009). The ‘‘roll-up’’ scenario represented the standards case assuming all 

product efficacies in the base case which did not meet the standard would ‘‘roll-up’’ to meet the 

new standard level. Those consumers that were above the standard level were considered 

unaffected and continued to purchase the same base-case lamp. The ‘‘roll-up’’ scenario 

characterized consumers primarily driven by the first-cost of the lamp, and they were restricted 

to replacing their base-case lamp with an equal wattage lamp when possible. The ‘‘roll-up’’ 

scenario, therefore, represents a lower bound of energy-savings scenario. In contrast, the 

‘‘shift’’ scenario modeled the standards case assuming all product efficacies were affected by the 

standard (whether or not their base-case efficacy met the standard). This scenario, in which 

consumers were driven by both lamp cost and energy savings, resulted in an upper-bound 

energy-savings scenario. 

27 
 

 

 

For this rulemaking, DOE is considering only modeling a “roll-up” scenario. DOE 

believes that consumers purchasing lamps covered by this rulemaking are primarily driven by the 

first-cost of the lamp and, therefore, will continue to purchase the lowest-cost lamp available. 

DOE makes this assumption because the exempt IRL are less expensive than the IRL covered by 

the lamps rule and also less efficient. If consumers were motivated by energy savings, they 

would already have been purchasing a more efficient lamp. This behavior is best modeled by the 

“roll-up” rather than the “shift” scenario. DOE requests comments on the tentative selection of 

this standards-case scenario. 

Item 11 DOE requests comment on the methodology it is considering to forecast 

shipments and specifically on: (1) historical shipment data and the assumptions presented 

to develop shipment forecasts; (2) the percent market penetration of existing and emerging 

technologies; (3) modeling a shift to exempted IRL in the base case due to the July 2009 

final rule; and (4) considering only a roll-up scenario in the standards case. 

2.10 National Impact Analysis 

The NIA assesses cumulative national energy savings (NES) and the cumulative national 

economic impacts of efficacy levels. The analysis measures economic impacts using the NPV 

metric, which represents the “net present value” (i.e., future amounts discounted to the present) 

of total customer costs and savings expected to result from new standards at specific efficacy 

levels. For a given efficiency level, DOE calculates the NPV, as well as the NES, as the 

difference between a base-case and the standards-case forecasts. 

DOE determines national annual energy consumption as the product of the annual energy 

consumption per unit lamp system and the number of total units in the installed stock. The perunit annual energy consumption is a function of lamp efficacy and lamp wattage. Cumulative 

energy savings are the sum of the annual NES determined over a specified time period. DOE 

calculates net economic savings each year as the difference between total operating cost savings 

and increases in total installed costs. Cumulative economic savings are the sum of the annual 

NPVs determined over a specified time period. 

2.10.1 Approach 

In the standards case, more-efficacious products gradually replace less-efficacious 

products over time. This affects calculations of the NES and NPV, which are both a function of 

the total number of units in use and their efficacies, and, thus, depend on annual shipments and 

the lifetime of a product. Both calculations start by first estimating the installed lamp stock. As 

discussed in the shipments analysis, new lamp types shipped over time are specified by marketshare matrices. These shipments are tracked through the analysis period to establish the installed 

stock of lamps. 

In the standards case, given that most consumers are likely to install lamps with energy 

consumption less than or equal to their base-case counterparts, the energy consumption per unit 

of capacity used by the products in service gradually decreases in the standards case relative to 

the base case. In the July 2009 final rule, to estimate the resulting national energy savings at each 

28 
 

CSL, DOE followed a four-step process. 74 FR 34080, 34114 (July 14, 2009). First, DOE 

calculated the national site-energy19 consumption for IRLs in each year, beginning with the 

expected effective date of the standards for the base-case forecast and each standards-case 

forecast. Second, DOE determined the annual site-energy savings, consisting of the difference in 

site-energy consumption between the base case and the standards case. DOE also estimated and 

reported additional heating, ventilating, and air conditioning (HVAC) interaction savings 

associated with increased lamp efficacy in the commercial sector. Third, DOE converted the 

annual site-energy savings into the annual amount of energy saved at the source of electricity 

generation (i.e., primary energy), using a site-to-source conversion factor that varies by year 

(calculated from AEO2009 projections). Finally, DOE summed the annual source-energy savings 

from 2012 to 2042 to calculate the total NES for that period. DOE is considering using the same 

methodology to calculate NES in this rulemaking for exempt IRLs. DOE requests comments on 

this methodology. 

To estimate NPV in the July 2009 final rule, DOE calculated the net impact each year as 

the difference between total operating cost savings (or the electricity cost savings) and increases 

in total installed costs (which consist of manufacturer selling price, sales taxes, and installation 

cost). 74 FR 34080, 34114 (July 14, 2009). DOE calculated the national NPV at each efficiency 

level using a three-step process. First, DOE determined the total product costs under the 

standards case and the base case from the total installed cost (including product prices, 

installation, and replacement costs) and shipments of lamps. Second, DOE determined the total 

operating costs in the base case and standards case from electricity prices and the stock of lamps. 

Third, DOE determined the difference between the net operating cost savings and the net product 

cost increase to get the net savings (or expense) for each year. DOE then discounted the annual 

net savings (or expenses) to 2009 for lamps bought during the analysis period and summed the 

discounted values to provide the NPV of an efficiency level. An NPV greater than zero shows 

net savings (i.e., the efficiency level would reduce customer expenditures relative to the base 

case in present-value terms). An NPV that is less than zero indicates that the efficiency level 

would result in a net increase in customer expenditures in present-value terms. DOE is 

considering using the same methodology to calculate NPV in this rulemaking for exempt IRLs. 

DOE requests comments on this methodology. 

2.10.2 Base-Case and Standards-Case Forecasted Efficacies 

A key aspect of the estimates of NES and NPV is the proportion of future lamp shipments 

meeting different efficacies for the base case (without new standards) and each of the standards 

cases (with new standards). Because key inputs to the calculation of the NES and NPV are 

dependent on the estimate of the lamps shipped at different efficacies, it is important to know the 

projected efficacy-distribution of lamp shipments. However, with regard to the calculation of the 

NES, it is also important to note that the total energy savings per unit is not solely dependent on 

the lamp efficacy, but also on the lamp wattage. Because most consumers select lamps by 

wattage when purchasing lamps, per-unit energy consumption for a particular standards-case 

19 “Site energy” is the energy consumed by the lamp systems directly as they are operated at the end-use site. 

29 
 

 

purchase is not necessarily less than per-unit energy consumption for the corresponding basecase purchase. For example, a higher-efficacy lamp can be purchased at the same wattage under 

the standards case, thereby increasing lumen output without reducing energy consumption. As 

discussed in the shipments analysis, the base-case and standards-case forecasted efficacies are 

primarily determined by inputs into the market-share matrices, which are then used in the NIA 

model. 

2.10.3 National Impact Analysis Inputs 

Table 2.8 summarizes the major inputs to the NES and NPV spreadsheet models. DOE 

provides a brief description of key inputs below. 

Table 2.8 Inputs to the National Impact Analysis 

Inputs Description 

Shipments Annual shipments from shipments model 

Effective Date of Standard 2014 

Analysis Period 2014 to 2043 

Unit Energy Consumption 

(kWh/yr) 

Established in the energy-use characterization for each lamp 

analyzed 

Total Installed Cost Established in the product price determination for each lamp 

analyzed 

Electricity Price Forecast Based on AEO2009 forecasts to 2030 and an extrapolation beyond 

2030 

Energy Site-to-Source 

Conversion 

Conversion varies yearly and was generated by DOE/ 

EIA’s National Energy Modeling System (NEMS) program (a 

time-series conversion factor; includes electric generation, 

transmission, and distribution losses). Conversion factors beyond 

2030 were held constant. 

HVAC Interaction Savings 6.25 % of total energy savings in the commercial sector. Assumed 

negligible in the residential sector. 

Rebound Effect 1 % of total energy savings in the commercial and industrial 

sectors. 8.5 % of total energy savings in the residential sector. 

Discount Rate 3 % and 7 % real 

Present Year Future costs and savings are discounted to 2009. 

One of the critical inputs to the NES and NPV calculations is the analysis period. DOE 

recognizes that the life-cycle of IRLs is estimated to be less than 30 years; however, in the July 

2009 final rule, DOE decided to use an analysis period from 2012 to 2042 for consistency with 

the shipment and national impact analyses of other rulemakings. 74 FR 34080, 34114 (July 14, 

2009). DOE is considering the same approach in this rulemaking for exempt IRLs. DOE 

requests comments on this methodology. 

The site-to-source conversion factor is the multiplicative factor DOE uses for converting 

site-energy consumption (the energy used at the end-use site) into primary or source energy 

consumption (the energy used at the source before transmission or conversion losses). For 

electricity, the conversion factors vary over time due to projected changes in generation sources 

(i.e., the power plant types projected to provide electricity to the country). For the July 2009 final 

rule, DOE calculated annual average site-to-source conversion factors using DOE/EIA’s 

National Energy Modeling System (NEMS) program (a time-series conversion factor; includes 

30 
 

 

 

electric generation, transmission, and distribution losses). 74 FR 34080, 34114-15 (July 14, 

2009). Conversion factors for beyond 2030 were held constant. DOE is considering using the 

same methodology to calculate site-to-source conversion factors in this rulemaking for exempt 

IRLs. DOE requests comments on this methodology. 

In the July 2009 final rule, DOE decided to include HVAC interaction in its calculation 

of the NES but not in the NPV calculation. 74 FR 34080, 34115 (July 14, 2009). The HVAC 

interaction factor measures the reduced cooling loads and increased heating loads that result 

from their interaction with more-efficacious lighting systems. To account for HVAC energy 

savings, DOE used the analysis completed by the 2000 Ballast Rule20, which calculated an 

HVAC interaction energy savings of 6.25 percent of total energy savings. This analysis 

incorporated changes in both heating and cooling loads as a result of the standard. The analysis 

also involved calculating the lighting HVAC interaction energy savings on buildings built before 

1989 (5 percent of total energy savings) and ones built from 1990 to 1995 (10 percent of total 

energy savings). The ballast analysis assumed that over the analysis period, the building stock 

would move from the 5 percent interaction factor towards the 10 percent interaction factor. 

Using simple scaling methods, 6.25 percent was used as an average interaction over the entire 

analysis period. Using this same methodology for the July 2009 final rule, an analysis period 

ranging from 2012 to 2042 would have had a slightly higher HVAC energy savings. However, 

overall HVAC savings with lighting may also decrease due to more-efficient heating and cooling 

systems. Considering these competing factors, DOE used 6.25 percent of total energy savings as 

the HVAC energy savings in commercial sector for IRLs. DOE did not include HVAC 

interaction in the residential sector because it believed IRLs to have a minor impact on HVAC 

energy usage in that market. In this rulemaking for exempt IRLs, DOE is also considering 

including HVAC interaction in its calculation of NES, at the same percent of total savings used 

in the July 2009 final rule (i.e., 6.25 percent). DOE requests comments on this interaction factor. 

In the July 2009 final rule, DOE considered the rebound effect that occurs after 

installation of energy-efficient lighting equipment. 74 FR 34080, 34115 (July 14, 2009). DOE 

examined a summary of the literature regarding the rebound effect in relation to lighting 

equipment. Based on four studies, the summary estimated that, for a 100 percent increase in 

energy efficiency, values of “take-back” or rebound for residential lighting were between 5 and 

12 percent of the energy consumption savings. In addition, with regards to a commercial firm’s 

response to higher-efficiency lighting, the summary estimated 0 to 2 percent for values of 

rebound for lighting. Therefore, in the calculation of national energy savings due to energy 

conservation standards on lighting, DOE used a rebound rate of 8.5 percent in the residential 

sector and 1 percent in the commercial sector. DOE believes that this rulemaking for exempt 

IRLs should account for the rebound effect described above. DOE is considering using the same 

rebound rates as used by the July 2009 final rule. DOE requests comments on these rates for the 

residential and commercial sectors. 

20 65 FR 56739 (September 19, 2000). U.S. Department of Energy, Energy Efficiency and Renewable Energy, 

Office of Building Research and Standards, Technical Support Document: Energy Efficiency Standards for 

Consumer Products: Fluorescent Lamps Ballast Final Rule (Sept. 2000). Available at: 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/gs_fluorescent_0100_r.html. 

31 
The inputs to the NPV calculation are total installed cost per unit (see product price 

determination), annual operating cost savings per unit, total annual installed cost increases, total 

annual operating cost savings, discount rate, present value of increased installed costs, and 

present value of operating cost savings. 

The annual operating cost savings per unit incorporates changes in electricity costs due to 

a standard efficacy level and lower energy consumption per unit. In the July 2009 final rule, 

DOE forecasted electricity prices based on EIA’s AEO2009. 74 FR 34080, 34115 (July 14, 

2009). By using both of these values, DOE was able to establish the annual operating cost 

savings per unit. DOE is considering using the same methodology in this rulemaking for exempt 

IRLs. 

The total annual installed cost increase is equal to the annual change between the base 

case and standards case in the per-unit total installed cost of the product multiplied by the 

shipments forecasted for each lamp design. The total annual operating cost savings are equal to 

the change in the annual operating costs per unit of the product and the total lamp stock by lamp 

design. 

DOE multiplies monetary values in future years by the discount rate to determine the 

present value. In the July 2009 final rule, DOE estimated national impacts using both a 3-percent 

and a 7-percent real discount rate as the average real rate of return on private investment in the 

U.S. economy. 74 FR 34080, 34122-23 (July 14, 2009). DOE used these discount rates in 

accordance with the U.S. Office of Management and Budget (OMB) guidance to Federal 

agencies on the development of regulatory analysis (OMB Circular A–4 (Sept. 17, 2003)), 

particularly section E, “Identifying and Measuring Benefits and Costs.” For purposes of its 

analysis, DOE defined the present year as 2009. DOE is considering using the same discount 

rates in this rulemaking for exempt IRLs. DOE requests comments on the appropriateness of 

these discount rates. 

The present value of increased installed costs is the annual installed cost increase in each 

year (i.e., the difference between the standards case and base case), discounted to the present, 

and summed for the time period over which DOE is considering the installation of product (i.e., 

from the effective date of standards, 2014, to the year 2043). The increase in total installed cost 

refers to both product cost and installation cost associated with the higher energy efficacy of 

product purchased in the standards case compared to the base case. 

The present value of operating cost savings is the annual operating cost savings (i.e., the 

difference between the base case and standards case) discounted to the present, and summed over 

the period from the effective date, 2014, to the time when the last unit installed in 2043 is retired 

from service. Savings are decreases in operating costs associated with the higher energy efficacy 

of products purchased in the standards case compared to the base case. Total annual operating 

cost savings is the savings per unit multiplied by the number of units surviving in a particular 

year. 

32 
 

 

Item 12 DOE welcomes comments on its decision to use the same inputs and methodology 

as the July 2009 final rule to calculate NES and NPV. 

2.11 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. For 

this rulemaking, DOE intends to evaluate impacts of standards on low-income and senior-only 

households. DOE seeks input regarding which consumer subgroups it should consider in this 

rulemaking. 

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. 

Item 13 DOE currently plans on assessing the impacts on low-income households and 

senior citizens, but seeks input regarding which other consumer subgroups it should 

consider in this rulemaking. 

2.12 Manufacturer Impact Analysis 

The purpose of the MIA is to identify and quantify the likely impacts of amended energy 

conservation standards on manufacturers of exempted IRLs. During the NOPR stage of analysis, 

DOE will analyze and consider a wide range of quantitative and qualitative industry impacts that 

may occur due to amended energy conservation standards. DOE will identify and analyze these 

impacts through industry research, public comments, and interviews with manufacturers and 

other interested parties. Other sources of information will include reports published by industry 

groups, trade journals, the U.S. Census Bureau, and U.S. Securities and Exchange Commission 

(SEC) 10-K filings. 

Initially, DOE will conduct a profile of the IRL manufacturer industry by gathering 

pertinent qualitative and quantitative financial and market information, including industry cost 

structures, employment metrics, and competitive behavior. Next, DOE will conduct detailed 

interviews with manufacturers of exempt IRL to gain insight into the potential impact of 

amended standards on sales, direct employment, capital assets, and industry competitiveness. 

DOE will use the information gathered in the industry profile to shape an interview guide that 

will be distributed to manufacturers prior to these interviews. The guide will facilitate the 

discussion of production costs, shipment projections, product mix, conversion costs, markups, 

competitive impacts, manufacturing capacity, and other relevant topics. Because standards may 

have differential impacts on groups of manufacturers with different cost structures or business 

models, DOE will also identify and characterize any such subgroups during interviews. 

33 
 

 

DOE is aware that amended standards may require additional investment, raise 

production costs, and affect revenue through higher prices. To quantify these potential impacts 

on manufacturers, DOE will calculate standards-induced changes in industry and subgroup cash 

flows using the Government Regulatory Impact Model (GRIM). This will enable DOE to derive 

a base-case and standards-case industry net present value. The inputs to the GRIM will include 

financial information, manufacturing costs, shipment forecasts, and price forecasts developed in 

other analyses. Lastly, based on the information gathered during interviews and other research, 

DOE will assess impacts on competition, manufacturing capacity, employment, and regulatory 

burden. DOE requests comments on its methodology for assessing the impacts on manufacturers 

of products covered under this rulemaking. 

Item 14 DOE welcomes comments on its methodology for assessing the impacts on 

manufacturers of products covered under this rulemaking. 

2.13 Utility Impact Analysis 

To estimate the effects of energy conservation standards for exempt IRLs on the 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 (i.e., the AEO reference case) and standards cases. 

The utility impact analysis reports the changes in installed capacity and generation that result for 

each standard level by plant type. DOE will model the impacts from amended energy 

conservation standards using NEMS-BT to generate forecasts that deviate from the AEO 

reference case.21 DOE requests comments on its approach to assessing utility impacts of 

standards on the products covered under this rulemaking. 

Item 15 DOE welcomes comments on its approach to assessing utility impacts of potential 

standards on the products covered under this rulemaking. To estimate the effects of energy 

conservation standards for exempt IRLs on the utility industry, DOE plans to use a variant 

of EIA’s NEMS that refers to DOE’s Building Technologies Program (NEMS-BT). 

2.14 Employment Impacts 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 equipment, along with the affiliated distribution and service companies, 

resulting from the standards. DOE will evaluate direct employment impacts in the MIA. 

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. DOE defines indirect employment impacts from standards as net jobs 

21 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: 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/ch_14_lamps_standards_final_tsd.pdf. 

34 
 

eliminated or created in the general economy as a result of increased spending driven by the 

increased equipment prices and reduced spending on energy. 

The indirect employment impacts will be investigated in the employment impact analysis 

using the 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. In comparison with simple economic multiplier 

approaches, ImSET allows for more complete and automated analysis of the economic impacts 

of energy conservation investments. DOE requests comments on its approach to assessing 

employment impacts of standards on the products covered under this rulemaking. 

Item 16 DOE welcomes comments on its approach to assessing employment impacts of 

standards on the products covered under this rulemaking. The indirect employment impacts 

are investigated in the employment impact analysis using the Pacific Northwest National 

Laboratory’s “Impact of Sector Energy Technologies” (ImSET) model whereas the direct 

employment impacts are calculated during the manufacturer impact analysis. 

2.15 Environmental Assessment 

The intent of the environmental assessment is to quantify and consider the environmental 

effects of amended energy conservation standards for the ER, BR, and small diameter IRL 

covered by this rulemaking. The primary environmental effects of these standards would be 

reduced power plant emissions resulting from reduced consumption of electricity. DOE will 

assess these environmental effects by using NEMS-BT to provide key inputs to its analysis. The 

portion of the environmental assessment that will be produced by NEMS-BT considers carbon 

dioxide (CO2), nitrogen oxides (NOX), and mercury (Hg). The environmental assessment also 

considers impacts on SO2 emissions. After a brief discussion of general methodology, this 

section will address each of the relevant emissions. The next section then explains how DOE 

plans to monetize the benefits associated with emissions reductions. 

Carbon Dioxide 

In the absence of any Federal emissions control regulation of power plant emissions of 

CO2, a DOE standard is likely to result in reductions of these emissions. The CO2 emission 

reductions likely to result from a standard will be estimated using NEMS-BT and national energy 

savings estimates drawn from the NIA spreadsheet model. The net benefit of the standard is the 

difference between emissions estimated by NEMS-BT at each standard level considered and the 

AEO Reference Case. NEMS-BT tracks CO2 emissions using a detailed module that provides 

results with broad coverage of all sectors and inclusion of interactive effects. 

Sulfur Dioxide 

DOE has preliminarily determined that SO2 emissions from affected Electric Generating 

Units (EGUs) are subject to nationwide and regional emissions cap and trading programs that are 

likely to eliminate the standards’ impact on SO2 emissions. The costs of meeting such emission 

35 
 

 

 

cap requirements are reflected in the electricity prices and forecasts used in DOE’s analysis of 

the standards. Title IV of the Clean Air Act sets an annual emissions cap on SO2 for all affected 

EGUs. SO2 emissions from 28 eastern States and the District of Columbia (DC) are also limited 

under the Clean Air Interstate Rule (CAIR, published in the Federal Register on May 12, 2005. 

70 FR 25162 (May 12, 2005)), which creates an allowance-based trading program that will 

gradually replace the Title IV program in those States and DC. (The recent legal history 

surrounding CAIR is discussed below.) The attainment of the emissions caps is flexible among 

EGUs and is enforced through the use of emissions allowances and tradable permits. Under 

existing EPA regulations, any excess SO2 emission allowances resulting from the lower 

electricity demand caused by the imposition of an efficiency standard could be used to permit 

offsetting increases in SO2 emissions by any regulated EGU. However, if the standard resulted in 

a permanent increase in the quantity of unused emission allowances, there would be an overall 

reduction in SO2 emissions from the standards. While there remains some uncertainty about the 

ultimate effects of efficiency standards on SO2 emissions covered by the existing cap and trade 

system, the NEMS-BT modeling system that DOE plans to use to forecast emissions reductions 

currently indicates that no physical reductions in power sector emissions would occur for SO2. 

Nitrogen Oxides 

NEMS-BT also has an algorithm for estimating NOX emissions from power generation. 

The impact of these emissions, however, will be affected by the CAIR, which the Environmental 

Protection Agency (EPA) issued on May 12, 2005. CAIR will permanently cap emissions of 

NOX in 28 eastern states and the District of Columbia. 70 FR 25162 (May 12, 2005). 

Much like SO2 emissions, a cap on NOX emissions means that the amended fluorescent 

lamp ballast standards may have little or no physical effect on these emissions in the 28 eastern 

States and the DC covered by CAIR. Although CAIR has been remanded to the EPA by the DC 

Circuit, it will remain in effect until it is replaced by a rule consistent with the Court’s July 11, 

2008, opinion in North Carolina v. EPA. 531 F.3d 896 (DC Cir. 2008); see also North Carolina 

v. EPA, 550 F.3d 1176 (DC Cir. 2008). Because all States covered by CAIR opted to reduce 

NOX emissions through participation in cap-and-trade programs for electric generating units, 

emissions from these sources are capped across the CAIR region. 

DOE plans to use NEMS-BT to estimate the emissions reductions from possible 

standards in the 22 States where emissions are not capped. 

Mercury 

Similar to emissions of SO2 and NOX, future emissions of Hg would have been subject to 

emissions caps. In May 2005, EPA issued the Clean Air Mercury Rule (CAMR). 70 FR 28606 

(May 18, 2005). CAMR would have permanently capped emissions of mercury for new and 

existing coal-fired power plants in all States by 2010. However, on February 8, 2008, the DC 

Circuit issued its decision in New Jersey v. Environmental Protection Agency, in which the DC 

Circuit, among other actions, vacated the CAMR. 517 F.3d 574 (DC Cir. 2008). EPA has 

decided to develop emissions standards for power plants under the Clean Air Act (Section 112), 

consistent with the DC Circuit’s opinion on the CAMR. See 

36 
http://www.epa.gov/air/mercuryrule/pdfs/certpetition_withdrawal.pdf. Pending EPA's 

forthcoming revisions to the rule, DOE is excluding the CAMR from its Environmental 

Analysis. In the absence of CAMR, a DOE standard would likely reduce Hg emissions and DOE 

plans to use NEMS-BT for this rulemaking to estimate these emission reductions. However, 

DOE continues to review the impact on Hg emissions of rules that reduce energy consumption, 

and may revise its assessment of Hg emission reductions in future rulemakings. 

Particulate Matter 

DOE acknowledges that particulate matter (PM) impacts are of concern due to human 

exposures that can impact health. But impacts of PM emissions reduction are much more 

difficult to estimate than other emissions reductions due to the complex interactions between 

PM, other power plant emissions, meteorology, and atmospheric chemistry that impact human 

exposure to particulates. Human exposure to PM usually occurs at a significant distance from the 

power plants that are emitting particulates and particulate precursors. When power plant 

emissions travel this distance, they undergo highly complex atmospheric chemical reactions. 

Although the EPA does keep inventories of direct PM emissions of power plants, in its source 

attribution reviews, the EPA does not separate direct PM emissions from power plants from the 

sulfate particulates indirectly produced through complex atmospheric chemical reactions. The 

great majority of PM emissions from power plants are of these secondary particles (secondary 

sulfates). Thus, it is not useful to examine how the amended standard impacts direct PM 

emissions independent of indirect PM production and atmospheric dynamics. Therefore, DOE is 

not planning to assess the impact of these standards on particulate emissions. Further, even the 

cumulative impact of PM emissions from power plants and indirect emissions of pollutants from 

other sources is unlikely to be significant. 

Item 17 DOE welcomes comments on its plan to use NEMS-BT to conduct the 

environmental assessment on the equipment covered by this rulemaking. DOE is 

particularly interested in whether there are any other approaches to the environmental 

assessment that it should consider and the advantages and disadvantages for each 

approach. 

2.16 Monetization of Emissions Reductions 

For those emissions for which real national emission reductions are anticipated (CO2, Hg, 

and NOX for 22 states), only ranges of estimated economic values based on environmental 

damage studies of varying quality and applicability are available. Therefore, DOE plans on 

reporting estimates of monetary benefits derived using these values and plans to consider these 

benefits in weighing the costs and benefits of each of the standard levels considered. 

In order to estimate the monetary value of benefits resulting from reduced emissions of 

CO2 emissions, it is DOE’s intent to use in its analysis the most current Social Cost of Carbon 

(SCC) values developed and/or agreed to by interagency reviews. 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 

37 
 

 

 

 

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. 

At the time of this notice, the most recent interagency estimates of the potential global 

benefits resulting from reduced CO2 emissions in 2010 were $4.7, $21.4, $35.1, and $64.9 per 

metric ton in 2007 dollars. These values are then adjusted to 2009$ using the standard GDP 

deflator value for 2008 and 2009. For emissions (or emission 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 preference will be given to consideration of the global 

benefits of reducing CO2 emissions. 

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 intends to estimate the potential monetary benefit of reduced NOX emissions 

resulting from the standard levels it considers. For NOX emissions, available estimates suggest a 

very wide range of monetary values for NOX emissions, ranging from $370 per ton to $3,800 per 

ton of NOX from stationary sources, measured in 2001$ (equivalent to a range of $442 to $4,540 

per ton in 2008$). Refer to the OMB, 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,” for additional information. In accordance with U.S. Office of 

Management and Budget (OMB) guidance, DOE will conduct two calculations of the monetary 

benefits derived using each of the economic values used for NOX, one using a real discount rate 

of 3 percent and another using a real discount rate of 7 percent.22 

DOE does not plan to monetize estimates of Hg in this rulemaking. DOE is aware of 

multiple agency efforts to determine the appropriate range of values used in evaluating the 

potential economic benefits of reduced Hg emissions. DOE has decided to await further guidance 

regarding consistent valuation and reporting of Hg emissions before it once again monetizes Hg 

in its rulemakings. 

Item 18 DOE welcomes comments on its approach for the monetization of emissions. 

2.17 Regulatory Impact Analysis 

In the NOPR and final rule stages of this rulemaking, DOE will prepare a regulatory 

impact analysis, which addresses the potential for non-regulatory approaches to supplant or 

augment energy conservation standards to improve the efficiency of IRLs on the market. DOE 

recognizes that voluntary or other non-regulatory efforts by manufacturers, utilities, and other 

22 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003). 

38 
interested parties can result in substantial efficiency improvements. DOE intends to analyze the 

likely effects of non-regulatory initiatives on product energy use, consumer utility, and LCCs. 

DOE will attempt to base its assessment on the actual impacts of any such initiatives to date, but 

will also consider information presented regarding the impacts that any existing initiative might 

have in the future. 

If DOE determines that amended energy conservation standards for the exempt IRLs 

would constitute a significant regulatory action, DOE will prepare and submit to OMB for 

review the assessment of costs and benefits required under section 6(a)(3) of Executive Order 

12866, “Regulatory Planning and Review,” 58 FR 51735 (Oct. 4, 1993). 

Item 19 DOE welcomes comments on the methodology it is considering for the regulatory 

impact analysis.

 APPENDIX A – LIST OF ITEMS FOR COMMENT 

Item 1 DOE welcomes comment on its conclusion that the test procedures for IRL covered by 

this rulemaking do not need to be updated. DOE believes that the IRL test procedures 

currently provided in 10 CFR part 430, subpart B, appendix R are appropriate for the ER, 

BR, and small diameter IRLs that are the subject of this rulemaking. ............................... 5 

Item 2 DOE welcomes comment on its decision to not amend energy conservation standards to 

address lamp operation in “off mode” or “standby mode.” DOE does not believe that any 

commercially-available IRLs satisfy the definition for “off mode” or “standby mode” 

operation. Therefore, DOE maintains that it is not feasible to incorporate off mode or 

standby mode energy use into the energy conservation standards for IRLs....................... 5 

Item 3 DOE welcomes comments on its decision to base product class divisions on 

standard/modified spectrum, lamp diameter, and input voltage. ........................................ 8 

Item 4 DOE invites interested parties to submit data relevant to the market assessment in the 

form of a written comment. This is includes historical shipments of the exempted 

incandescent reflector lamp market by lamp type, lamp wattage, and market sector. ....... 9 

Item 5 DOE welcomes comments on all of the technology options it is considering for IRLs, 

including any omissions or revisions necessary to have a more comprehensive technology 

assessment for the exempt IRLs covered in this rulemaking. In the context of 

commenting on technology options, DOE also requests information on the feasibility, 

performance improvement, and cost of the technology options, as well as any recent 

developments in their technical maturity.......................................................................... 11 

Item 6 DOE requests comments regarding the technologies that were screened out for the July 

2009 final rule and whether any additional technology options should be screened out for 

this rule. Specifically, DOE is seeking any data or information that would allow DOE to 

determine whether it is still appropriate to screen out these technologies........................ 12 

Item 7 DOE welcomes comments on its decision to use the same methodology for the 

engineering analysis as that used in the July 2009 final rule. DOE specifically requests 

comments on the following: (1) the designated representative product classes; (2) the 

selected baseline lamps; (3) the selected higher-efficiency lamp designs; (4) the 

39 
efficiency levels considered for analysis; and (5) the adjustments considered for scaling 

to product classes not analyzed......................................................................................... 17 

Item 8 DOE welcomes comments on its methodology to determine operating hours for covered 

lamps in the commercial and residential sectors............................................................... 19 

Item 9 DOE welcomes comments on its decision to use the same methodology as the July 2009 

final rule to develop lamp prices and sales tax figures for this rulemaking. .................... 20 

Item 10 DOE welcomes comments on its decision to use a similar approach as the July 2009 

final rule to conduct the LCC and PBP analyses. ............................................................. 24 

Item 11 DOE requests comment on the methodology it is considering to forecast shipments 

and specifically on: (1) historical shipment data and the assumptions presented to develop 

shipment forecasts; (2) the percent market penetration of existing and emerging 

technologies; (3) modeling a shift to exempted IRL in the base case due to the July 2009 

final rule; and (4) considering only a roll-up scenario in the standards case.................... 28 

Item 12 DOE welcomes comments on its decision to use the same inputs and methodology as 

the July 2009 final rule to calculate NES and NPV. ......................................................... 33 

Item 13 DOE currently plans on assessing the impacts on low-income households and senior 

citizens, but seeks input regarding which other consumer subgroups it should consider in 

this rulemaking.................................................................................................................. 33 

Item 14 DOE welcomes comments on its methodology for assessing the impacts on 

manufacturers of products covered under this rulemaking............................................... 34 

Item 15 DOE welcomes comments on its approach to assessing utility impacts of potential 

standards on the products covered under this rulemaking. To estimate the effects of 

energy conservation standards for exempt IRLs on the utility industry, DOE plans to use 

a variant of EIA’s NEMS that refers to DOE’s Building Technologies Program (NEMSBT). ................................................................................................................................... 34 

Item 16 DOE welcomes comments on its approach to assessing employment impacts of 

standards on the products covered under this rulemaking. The indirect employment 

impacts are investigated in the employment impact analysis using the Pacific Northwest 

National Laboratory’s “Impact of Sector Energy Technologies” (ImSET) model whereas 

the direct employment impacts are calculated during the manufacturer impact analysis. 35 

Item 17 DOE welcomes comments on its plan to use NEMS-BT to conduct the environmental 

assessment on the equipment covered by this rulemaking. DOE is particularly interested 

in whether there are any other approaches to the environmental assessment that it should 

consider and the advantages and disadvantages for each approach.................................. 37 

Item 18 DOE welcomes comments on its approach for the monetization of emissions. ......... 38
 

Item 19 DOE welcomes comments on the methodology it is considering for the regulatory 

impact analysis. ................................................................................................................. 39 

40