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CHAPTER 17. REGULATORY IMPACT ANALYSIS

TABLE OF CONTENTS

17.1 INTRODUCTION ......................................................................................................... 17-1

17.2 METHODOLOGY ........................................................................................................ 17-1

LIST OF TABLES

Table 17.1.1 Non-regulatory Alternatives to Standards ......................................................... 17-1
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CHAPTER 17. REGULATORY IMPACT ANALYSIS FOR ENERGY CONSERVATION 

STANDARDS FOR GSFL-IRL

17.1 INTRODUCTION

Under appendix A to subpart C of Title 10 of the Code of Federal Regulations, Part 430, 

Procedures for Consideration of New or Revised Energy Conservation Standards for Consumer 

Products (Process Rule) the U.S. Department of Energy (DOE) is committed to explore nonregulatory alternatives to energy conservation standards. Accordingly, DOE will prepare a draft 

regulatory impact analysis pursuant to Executive Order 12866, “Regulatory Planning and 

Review,” which will be subject to review by the Office of Management and Budget’s Office of 

Information and Regulatory Affairs. Pursuant to the Process Rule, DOE has identified six major 

alternatives to standards that represent feasible policy options to reduce the energy consumption 

of general service fluorescent lamps and incandescent reflector lamps (GSFL-IRL). It will 

evaluate each alternative in terms of its ability to achieve significant energy savings at a 

reasonable cost, and will compare the effectiveness of each alternative to the effectiveness of 

each trial standard. 

Table 17.1.1 lists the non-regulatory means of achieving energy savings that DOE 

proposes to analyze. The technical support document (TSD) prepared in support of DOE’s notice 

of proposed rulemaking will include a complete quantitative analysis of each alternative, the 

methodology for which is briefly addressed below. 

Table 17.1.1 Non-regulatory Alternatives to Standards 

No New Regulatory Action

Consumer Rebates

Consumer Tax Credits

Manufacturer Tax Credits

Voluntary Energy Efficiency Targets

Early Replacement

Bulk Government Purchases

17.2 METHODOLOGY

DOE will use the national impact analysis (NIA) spreadsheet model for GSFL-IRL to 

calculate the national energy savings and the net present value (NPV) corresponding to each 

alternative to proposed standards. The NIA model for GSFL-IRL is discussed in chapter 10 of 

the TSD. To compare each alternative quantitatively to the proposed energy conservation 

standards, DOE will need to quantify the effect of each alternative on the purchase and use of 

energy efficient GSFL-IRL. DOE will create an integrated NIA-RIA model, built on the NIA 

model, in which to make the appropriate revisions to the inputs in the NIA models. Key inputs 

that DOE may revise in the NIA-RIA model are:
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• GSFL-IRL market shares of products meeting target efficiency levels (identical to the 

trial standard levels for the mandatory standards) 

• Replacement rates of equipment in the stock

 The following are the key measures of the impact of each alternative.

• Energy use: Cumulative energy use of GSFL-IRL from the compliance date of the new 

standard to 2046. DOE will report electricity consumption as primary energy.

• National energy savings: Cumulative national energy use from the base-case projection 

minus the alternative-policy-case projection.

• Net present value: The value of future operating cost savings from the equipment bought 

during the period from the required compliance date of the new standard (2017) to 2046. 

DOE will calculate the NPV as the difference between the present value of equipment 

and operating expenditures (including energy) in the base case, and the present value of 

expenditures under each alternative-policy case. DOE will discount future operating and 

equipment expenditures to 2013 using a 7-percent and 3-percent real discount rate. It will 

calculate operating expenses (including energy costs) for the life of the equipment.