CHAPTER 1. INTRODUCTION

TABLE OF CONTENTS

1.1 PURPOSE OF THE DOCUMENT ................................................................................. 1­1

1.2 OVERVIEW OF THE APPLIANCES AND COMMERCIAL EQUIPMENT

STANDARDS PROGRAM......................................................................................................... 1­1

1.3 OVERVIEW OF THE SUBCATEGORIES OF LAMPS COVERED ........................... 1­2

1.4 PROCESS FOR SETTING ENERGY CONERVATION STANDARDS...................... 1­4

1.5 STRUCTURE OF THE DOCUMENT............................................................................ 1­7

LIST OF TABLES

Table 1.4.1 Analyses Under the Process Rule ............................................................................ 1­5

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CHAPTER 1. INTRODUCTION

1.1 PURPOSE OF THE DOCUMENT

This technical support document (TSD) is a stand­alone report that provides the technical

analyses supporting the information in the Advance Notice of Proposed Rulemaking (ANOPR)

for general service fluorescent lamps (GSFL) and incandescent reflector lamps (IRL).

1.2 OVERVIEW OF THE APPLIANCES AND COMMERCIAL EQUIPMENT

STANDARDS PROGRAM

Part B of Title III of the Energy Policy and Conservation Act (EPCA or the Act) of 1975

(42 U.S.C. 6291–6309) established the energy conservation program for consumer products

other than automobiles, covering major household appliances. The National Energy

Conservation Policy Act of 1978 (NECPA) amended EPCA to add Part C of Title III (42 U.S.C.

6311–6317), which established an energy conservation program for certain industrial equipment.

Additional amendments to EPCA have given the U.S. Department of Energy (DOE) the

authority to regulate the energy efficiency of several products, including certain fluorescent and

incandescent lamps, the products that are the focus of this document.

Amendments to EPCA in the Energy Policy Act of 1992 (EPACT 1992), P.L. 102­486,

and subsequent amendments in the Energy Independence and Security Act (EISA 2007), P.L.

110­140, established energy conservation standards for GSFL and IRL, as well as requirements

to conduct two cycles of rulemakings to determine whether these standards should be amended.

(42 U.S.C. 6295(i)(1) and (3)–(4)) EPCA also provides that within 24 months after U.S. Federal

Trade Commission (FTC) labeling requirements have become effective for GSFL, DOE must

initiate a rulemaking to determine if the standards in effect for these lamps should be amended to

be applicable to additional GSFL. (42 U.S.C. 6295(i)(5)) According to EPCA, DOE must

publish a rule within 18 months of initiating the rulemaking. (42 U.S.C. 6295(i)(5)) The FTC

published labeling requirements for covered lamps on May 13, 1994, with an effective date of

May 15, 1995. 59 FR 25176. Previously, DOE did not take action on the requirements of 42

U.S.C. 6295(i) because lamps were assigned a low priority based on public comment and energy

savings estimates in the priority­setting process.

EPCA establishes standards for GSFL, requiring that they meet prescribed minimum

efficacy levels for given color rendering index (CRI) levels. EPCA also requires that DOE

conduct two cycles of rulemakings to determine if the standards should be amended. (42 U.S.C.

6295(i)(1), (3)–(4)) In addition, the Act requires DOE to conduct a rulemaking to determine if

the standards in effect for fluorescent lamps should be amended so that they would be applicable

to additional GSFL. (42 U.S.C. 6295(i)(5)) In this rulemaking, DOE is conducting its first

review to determine if the standards should be amended, while fulfilling the additional statutory

requirement of determining if the standards should be applicable to other GSFL.

EPCA also establishes energy conservation standards for IRL, requiring that certain

lamps meet prescribed efficacy levels. The Act directs DOE to conduct two cycles of

rulemakings to determine if the standards should be amended. (42 U.S.C. 6295(i)(1), (3)­(4)) ]

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In this rulemaking, DOE is conducting its first review to determine if the standards for IRL

should be amended. DOE is also fulfilling the requirement of determining whether the standards

should cover additional GSFL, including additional IRL.

Additionally, EPCA specifies that the Secretary of Energy shall prescribe test procedures

for fluorescent lamps and incandescent reflector lamps, taking into consideration the applicable

Illumination Engineering Society of North America (IESNA) or American National Standards

Institute (ANSI) standards. (42 U.S.C. 6293(b)(6) Accordingly, on May 29, 1997, DOE

published a final rule establishing test procedures for fluorescent and incandescent lamps

incorporating by reference ANSI, IESNA, and International Commission on Illumination (CIE)

industry standards to measure lamp efficacy and CRI. 62 FR 29222. DOE intends to update the

test procedures of the lamps covered in this rulemaking through a separate rulemaking process.

1.3 OVERVIEW OF THE SUBCATEGORIES OF LAMPS COVERED

This rulemaking covers certain types of fluorescent lamps and incandescent lamps.

Section 321(30) of EPCA (42 U.S.C. 6291(30)) contains definitions for “fluorescent lamps,”

“general service fluorescent lamps” and “incandescent lamps.”

In addition to the statutory definitions, DOE published definitions for terms that

supplement the statutory definitions for fluorescent and incandescent lamps. 62 FR 29222 (May

29, 1997); 10 CFR section 430.2. Appendix 3A defines these terms. The market and technology

assessment (Chapter 3) describes in more detail the definitions for fluorescent and incandescent

lamps, as well as the two categories of lamps covered in this rulemaking. As part of this

rulemaking, DOE is considering whether to extend coverage to “additional general service

fluorescent lamps.” (42 U.S.C. 6295(5)) Please see the Advanced Notice of Proposed

Rulemaking (ANOPR) Federal Register notice for this rulemaking for a detailed discussion on

DOE’s consideration to expand coverage. Below are statutory definitions for fluorescent and

incandescent lamps.

Sections 321(30)(A)–(F) of EPCA (42 U.S.C. 6291(30)(A)–(F)) contains definitions for

“fluorescent lamp,” “general service fluorescent lamp,” “incandescent lamp,”and “incandescent

reflector lamp” relevant to this rulemaking:

(A) Except as provided in subparagraph (E), the term “fluorescent lamp” means a lowpressure mercury electric­discharge source in which a fluorescing coating transforms

some of the ultraviolet energy generated by the mercury discharge into light,

including only the following:

(i) Any straight­shaped lamp (commonly referred to as 4­foot medium bi­pin

lamps) with medium bi­pin bases of nominal overall length of 48 inches

and rated wattage of 28 or more.

(ii) Any U­shaped lamp (commonly referred to as 2­foot U­shaped lamps)

with medium bi­pin bases of nominal overall length between 22 and 25

inches and rated wattage of 28 or more.

(iii) Any rapid start lamp (commonly referred to as 8­foot high output lamps)

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

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and 0.800 nominal amperes, as defined in ANSI C78.1­1978 and related

supplements.

(iv) Any instant start lamp (commonly referred to as 8­foot slimline lamps)

with single pin bases of nominal overall length of 96 inches and rated

wattage of 52 or more, as defined in ANSI C78.3­1978 (R1984) and

related supplement ANSI C78.3a­1985.

(B) The term “general service fluorescent lamp” means fluorescent lamps which can be

used to satisfy the majority of fluorescent applications, but does not include any lamp

designed and marketed for the following nongeneral lighting applications:

(i) Fluorescent lamps designed to promote plant growth.

(ii) Fluorescent lamps specifically designed for cold temperature installations.

(iii) Colored fluorescent lamps.

(iv) Impact­resistant fluorescent lamps.

(v) Reflectorized or aperture lamps.

(vi) Fluorescent lamps designed for use in reprographic equipment.

(vii) Lamps primarily designed to produce radiation in the ultra­violet region

of the spectrum.

(viii) Lamps with a color rendering index of 87 or greater.

(C) Except as provided in subparagraph (E), the term “incandescent lamp” means a

lamp in which light is produced by a filament heated to incandescence by an electric

current, including only the following:

(i) Any lamp (commonly referred to as lower wattage nonreflector general

service lamps, including any tungsten­halogen lamp) that has a rated

wattage between 30 and 199 watts, has an E26 medium screw base, has a

rated voltage or voltage range that lies at least partially within 115 and

130 volts, and is not a reflector lamp.

(ii) Any lamp (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.

(iii) Any general service incandescent lamp (commonly referred to as a highor higher­wattage lamp) that has a rated wattage above 199 watts (above

205 watts for a high wattage reflector lamp).

* * * * *

(E) The terms “fluorescent lamp” and “incandescent lamp” do not include any lamp

excluded by the Secretary, by rule, as a result of a determination that standards for

such lamp would not result in significant energy savings because such lamp is

designed for special applications or has special characteristics not available in

reasonably substitutable lamp types.

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(F) The term “incandescent reflector lamp” means a lamp described in subparagraph

(C)(ii).

1.4 PROCESS FOR SETTING ENERGY CONERVATION STANDARDS

Under EPCA, when DOE evaluates new or amended standards, it must consider the

following seven factors to the greatest extent practicable:

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

products subject to the standard;

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

compared to any increases in the price, initial charges, or maintenance expenses for

the products that are likely to result from the imposition of the standard;

(3) the total projected amount of energy savings likely to result directly from

imposition of the standard;

(4) any lessening of the utility or the performance of the products likely to result from

imposition of the standard;

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

Attorney General, likely to result from imposition of the standard;

(6) the need for national energy conservation; and

(7) other factors the Secretary considers relevant.

(42 U.S.C. 6295(o)(2)(B)(i)) Additional statutory requirements for prescribing new or

amended standards are set forth in 42 U.S.C. 6295(o)(1)–(2)(A), (2)(B)(ii)–(iii), and (3)–(4).

DOE considers stakeholder participation a very important part of the standards­setting

process. DOE encourages the participation of all stakeholders during the comment period of

each rulemaking stage. Beginning with the Rulemaking Framework Document for General

Service Fluorescent Lamps, Incandescent Reflector Lamps, and General Service Incandescent

Lamps (Framework Document) and during subsequent comment periods, interactions among

stakeholders provide a balanced discussion of the information that is required for the standards

rulemaking.

In conducting the test procedures rulemaking and the energy conservation standards

rulemakings, DOE involves stakeholders through formal public notifications (i.e., Federal

Register notices). For this fluorescent and incandescent lamps energy conservation standards

rulemaking, DOE will employ the procedures set forth in DOE’s Process Rule (Procedures for

Consideration of New or Revised Energy Conservation Standards for Consumer Products, 61 FR

36974, July 15, 1996, 10 CFR Part 430, Subpart C, Appendix A) to the extent they are

appropriate for developing energy conservation standards for the lamps covered under this

rulemaking.

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Before DOE determines whether to establish or amend energy conservation standard for

GSFL and IRL, it must first solicit comments on a proposed standard. (42 U.S.C.

6295(o)(2)(B)(i)). DOE must design each new or amended standard for these products to

achieve the maximum improvement in energy efficiency that is technologically feasible and

economically justified, and would result in significant energy savings. (42 U.S.C. 6295(o)(2)(A)

and (3)) To determine whether a proposed standard complies with these requirements, 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 seven factors listed

above.

Subsequent to the publication of the Framework Document, the standards rulemaking

process involves three additional formal, major public notices, which are published in the

Federal Register. The first of the rulemaking notices is an ANOPR. The ANOPR is designed to

publicly vet the models and tools used in the rulemaking and to facilitate public participation

before the proposed rule stage. The second notice is a NOPR, which presents a discussion of

comments received in response to the ANOPR; analysis of the impacts of standards on

consumers, manufacturers, and the nation; DOE’s weighing of the impacts; and the proposed

standards. The third notice is the Final Rule, which presents a discussion of comments received

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

the impacts; the standards adopted by DOE; and the effective dates of the standards. Until

recently, DOE performed the manufacturer impact analysis in its entirety between the ANOPR

and NOPR. However, as noted in Table 1.4.1, DOE now conducts a preliminary manufacturer

impact analysis in the ANOPR stage. DOE believes this change will improve the rulemaking

process.

Table 1.4.1 Analyses Under the Process Rule

ANOPR NOPR Final Rule*

Market and technology assessment Revised ANOPR analyses Revised analyses

Screening analysis Life­cycle cost sub­group analysis

Engineering analysis Manufacturer impact analysis

Energy use characterization Utility impact analysis

Product price determination Employment impact analysis

Life­cycle cost and payback period

analyses

Environmental assessment

Shipments analysis Regulatory impact analysis

National impact analysis

Preliminary manufacturer impact

analysis

* During the Final Rule phase, DOE considers the comments submitted by the U.S. Department of Justice in the

NOPR phase concerning the impact of any lessening of competition that is likely to result from the imposition of the

standard. (42 U.S.C. 6295(o)(2)(B)(v))

In May 2006, DOE published a Rulemaking Framework Document for General Service

Fluorescent Lamps, Incandescent Reflector Lamps, and General Service Incandescent Lamps,

which describes the procedural and analytical approaches DOE anticipated using to evaluate the

establishment of energy conservation standards for fluorescent and incandescent lamps. A PDF

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copy of the Framework Document is available at

http://www.eere.energy.gov/buildings/appliance_standards/residential/pdfs/lamps_framework.pd

f.

DOE held a public meeting on June 15, 2006 (hereafter “public meeting”), to discuss

procedural and analytical approaches to the rulemaking, and to inform and facilitate

stakeholders’ involvement in the rulemaking process. The analytical framework presented at the

public meeting described rulemaking analyses, such as the engineering analysis and the lifecycle cost (LCC) and payback period (PBP) analyses, the methods proposed for conducting

them, and the relationships among the various analyses. See Table 1.4.1 for all the analyses

discussed at the public meeting to be undertaken in each of the formal public rulemaking

documents. PDF copies of the slides and other material associated with the public meeting are

available at

http://www.eere.energy.gov/buildings/appliance_standards/residential/lamps_meeting_061506.ht

ml.

During the public meeting and the Framework Document comment period, stakeholders,

including manufacturers, trade associations, environmental advocates, and other interested

parties submitted several comments about the lamps rulemaking. The major issues discussed

were: (1) the rulemaking’s scope of coverage and definition of exemptions; (2) the development

of product classes; (3) lamp life variation; (4) selection of representative lamps for analysis and

baseline models; (5) appropriate methods and sources for developing end­user price estimates;

(6) updating test procedures; (7) the methodology for developing shipment estimates; (8) the

need for system­based analysis for GSFL (i.e., analyzing a lamp and a ballast in some scenarios);

(9) the impact of higher efficacy lamps on building space conditioning loads; and (10) the use of

tiered versus average electricity rates. Stakeholder comments submitted during the Framework

Document comment period elaborated upon the issues raised at the public meeting. DOE

worked with its contractors to address these issues in the analyses. Detailed discussion of

stakeholder comments is available in the ANOPR Federal Register notice for this rulemaking.

As part of the information gathering and sharing process, DOE organized and held

interviews with three lamp manufacturers who operate in the U.S. lamps market. DOE had four

objectives for these interviews: (1) solicit feedback on the draft engineering analysis (including

methodology, prices, and lamp technologies); (2) solicit feedback on topics related to the

preliminary manufacturer impact analysis; (3) provide an opportunity early in the rulemaking

process to express specific concerns to DOE; and (4) foster cooperation between manufacturers

and DOE.

Two general topics related to the preliminary manufacturer impact analysis were

discussed during each of the interviews: (1) lamp information and (2) preliminary manufacturer

impact. Each topic contained around four to six issues, depending on the lamp type. These

issues generally included market data, distribution channels, anticipated consumer responses to

standards, production and product mix, conversion costs, and cumulative regulatory burden,

among other issues. Appendix 12A contains a complete copy of the interview guides.

DOE incorporated the information gathered at the meetings into its engineering analysis

(Chapter 5) and the preliminary manufacturer impact analysis (Chapter 12). Following the

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publication of the ANOPR and the ANOPR public meeting, DOE intends to hold additional

meetings with manufacturers as part of the consultative process for the manufacturer impact

analysis conducted during the NOPR phase.

For the LCC, PBP and national impact analyses (NIA), DOE developed spreadsheets

using Microsoft Excel®. The LCC and PBP spreadsheets calculate the economic impacts of

replacing products with standard­compliant ones. The NIA spreadsheets calculate the national

energy savings (NES) and national net present values (NPVs) at various energy efficiency levels

and include a model that forecasts the impacts of energy conservation standards at various levels

on product shipments. These spreadsheets are available on the DOE website at

http://www.eere.energy.gov/buildings/appliance_standards/.

1.5 STRUCTURE OF THE DOCUMENT

This ANOPR TSD outlines the analytical approaches used in this rulemaking. The TSD

consists of 14 Chapters, an environmental assessment, a regulatory impact analysis, and

appendices.

Chapter 1 Introduction: provides an overview of the appliance standards

program and how it applies to the rulemaking for GSFL and IRL, and

outlines the structure of the document

Chapter 2 Analytical Framework: describes the rulemaking process step by step

Chapter 3 Market and Technology Assessment: characterizes the fluorescent and

incandescent lamps market and the technologies available for

increasing lamp efficacy, and outlines product classes

Chapter 4 Screening Analysis: determines which technology design options are

viable for consideration in the engineering analysis

Chapter 5 Engineering Analysis: discusses the sources and methods for

developing the lamp and lamp­and­ballast designs analyzed and

selecting candidate standard levels

Chapter 6 Energy Use Characterization: discusses the sources and methods for

developing energy use estimates for fluorescent and incandescent

lamps

Chapter 7 Product Price Determination: discusses the sources and methods used

to develop end­user prices for the lamps and lamp­and­ballast designs

analyzed

Chapter 8 Life­Cycle Cost and Payback Period Analyses: discusses the

economic effects of standards and compares the LCC and PBP of

fluorescent and incandescent lamps with and without higher energy

conservation standards

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Chapter 9 Shipments Analysis: discusses the methods used for forecasting

shipments with and without higher energy conservation standards

Chapter 10 National Impact Analysis: describes the national forecast of energy

consumption, efficiency of new lamps, and annual fluorescent and

incandescent lamp sales in the absence or presence of new standards

Chapter 11 Life­Cycle Cost Sub­Group Analysis: discusses the methods to be

used to study the effects of standards on a subgroup of fluorescent and

incandescent lamp consumers and compares the LCC and PBP of

equipment with and without higher efficiency standards for these

consumers

Chapter 12 Manufacturer Impact Analysis: discusses the methods to be used to

study the effects of standards on the finances and profitability of

fluorescent and incandescent lamp manufacturers, and presents

preliminary manufacturer impact analysis results

Chapter 13 Utility Impact Analysis: discusses the methods to be used to study the

effects of standards on electric utilities

Chapter 14 Employment Impact Analysis: discusses the methods to be used to

analyze the effects of standards on national employment

Environmental Assessment for General Service Fluorescent Lamps and Incandescent

Reflector Lamps: discusses the methods to be used to study the effects

of standards on two pollutants, sulfur dioxide (SO2) and nitrogen

oxides (NOx), as well as carbon emissions

Regulatory Impact Analysis for General Service Fluorescent Lamps and Incandescent

Reflector Lamps: discusses the methods to be used to determine the

impact of non­regulatory alternatives to energy conservation standards

Appendix AA Acronyms and Abbreviations: provides a set of acronyms and

abbreviations used throughout the TSD.

Appendix 3A Lighting Definitions in the United States Code and Code of Federal

Regulations: provides a set of existing statutory and regulatory

definitions for fluorescent and incandescent lamps

Appendix 5A Engineering Results Used in the Shipments and National Impacts

Analyses: provides the characteristics of lamp designs and lamp­andballast designs considered in the shipments and NIA

Appendix 6A Energy End Use Characterization Results Used in the National

Impacts Analysis: provides the characteristics of lamp designs and

lamp­and­ballast designs considered in the NIA.

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Appendix 7A Additional End­User Price Results: provides end­user price results for

additional products considered in the NIA (e.g., compact fluorescent

lamps)

Appendix 8A User Instructions for Life­Cycle Cost and Payback Period Spreadsheet

Appendix 8B Supplementary Life­Cycle Cost and Payback Period Results: provides

results for the Monte Carlo and sensitivity analyses

Appendix 8C Residential Discount Rate Distributions

Appendix 9A Supplementary Scenarios for the Shipments Analysis: provides

additional inputs and results for the shipments analysis

Appendix 10A User Instructions for Shipments and NIA Spreadsheet

Appendix 10B Supplementary Scenarios for the National Impacts Analysis: provides

results for additional NIA scenarios

Appendix 12A Preliminary Manufacturer Interview Guide

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