1 | Energy Efficiency and Renewable Energy 

Test ProceduresNotice of Proposed Rulemaking forCeiling Fan Light KitsEnergy Conservation StandardsPreliminary Analysis for Ceiling FanLight KitsNovember 18, 2014

Lucy deButts

Department of EnergBuilding Technologie

TP: EE‐2014–BT–TP–

CFLK2014TP000

ECS: EERE‐2012‐BT‐S

CeilingFanLightKee.doe.gov
2

Welcome• Introductions (around the room)• Role of the Facilitator

• Ground Rules

- Speak one at a time.

- Say your name for the record – there will be a complete transc

meeting.

- Be concise – share the ‘air‐time.’

- Keep the focus here – cell phones on silent; limit sidebar conv

- Webinar participants turn phone on mute; “raise your hand” t

recognized to speak.

• Housekeeping Items

• Agenda Review

• Opening Remarks
3

Public Meeting Agenda: Morning

9:00 – 9:10 am Welcome and Introductions

Ceiling Fan Light Kit Proposed Test Procedures

9:10 – 9:30 am Opening Statements; TP Regulatory History; Rulem

9:30 – 10:10 am Existing Product Classes, Metrics, and Test Proced

Amendments to Current Test Procedures

10:10 – 10:50 am Proposed Test Procedures to Support Standards R

10:50 – 11:00 am Break11:00 – 11:35 am Updated Guidance on Accent Lighting; Clarificatio

430.32(s); Effective and Compliance Dates; Sampl

11:35 – 11:50 am Review Under the Regulatory Flexibility Act

11:50 am – 12:00 pm Closing Remarks12:00 – 1:00 pm Lunch
4

Public Meeting Agenda: Afternoon

Ceiling Fan Light Kit Energy Conservation StandarPreliminary Analysis

1:00 – 1:20 pm Opening Statements; ECS Regulatory History; Rule

1:20 – 1:40 pm Scope; Market & Technology Assessment

1:40 – 2:10 pm Screening and Engineering Analyses

2:10 – 2:20 pm Product Price Determination

2:20 – 2:30 pm Break

2:30 – 2:55 pm Energy Use; Life Cycle Cost Analyses

2:55 – 3:30 pm Shipments; National Impact Analyses

3:30 – 3:40 pm Preliminary Manufacturer Impact Analysis

3:40 – 3:50 pm NOPR Analyses

3:50 – 4:00 pm Closing Remarks and Adjourn
5

Listening via the Webcast• DOE is broadcasting this meeting live over the Intern• DOE is providing the webcast to accommodate stake

that are unable to attend the public meeting in perso

• The web broadcast allows stakeholders to listen in an

the slides.

• All stakeholders are encouraged to submit written co

after the public meeting.
6

Purpose of this Public Meeting1. Review statute and DOE actions for ceiling fan light 

2. Present DOE’s proposed test procedures for CFLKs

3. Present energy conservation standards DOE is cons

CFLKs in the Preliminary Analysis

4. Invite comment from participants on the test proce

Preliminary Analysis

5. Discuss the next steps for the rulemakings

6. Encourage participants to submit data, information, 

statements, and written comments, including additfor discussion
7

Proposed Ceiling Fan Light Kit (CFLK) Test Pro
8

Issue for Discussion

Issue box numbering corresponds to the list of issues published at t

the Test Procedure NOPR, available at regulations.gov, under docket 

EE‐2014–BT–TP–0007, athttp://www.regulations.gov/#!documentDetail;D=EERE‐2014‐BT‐TP

The deadline for submitting comments on the Test Procedure NOPR 

January 14, 2015

Issue Box: DOE welcomes comments, data, and information

concerning the proposed CFLKs test procedures. Issues that

correspond to those raised in DOE’s published material will b

numbered in accordance with that material. Whether invited 

issue box or not, comments are welcome on any part of DOE’

analysis.
9

How to Submit Written Comments

• In all correspondence, please refer to the CFLK test procedure 

by:

– Test Procedure for Ceiling Fan Light Kits;

– Docket Number EE‐2014–BT–TP–0007; and

– Regulatory Identification Number (RIN) 1904‐AD17.

• Email: CFLK2014TP0007@ee.doe.gov

Postal: Courier:Ms. Brenda EdwardsU.S. Department of Energy

Building Technologies Program,Mailstop EE‐5B

1000 Independence Avenue, SWWashington, DC 20585‐0121

Ms. Brenda EdwardsU.S. Department of Energy

Building Technologies Progra950 L’Enfant Plaza, SW

Washington, DC 20024Tel: 202 586‐2945

Test Procedure NOPR Comment Period closes: January 14, 2015, 1
10

Opening Remarks

Meeting participants are invited to provide ope

remarks or statements at this time.
11

CFLKs TP Rulemaking Schedule

Milestone Date

Test Procedure NOPR publishedBeginning of 75‐day comment period October 

End of 75‐day comment period January 

Final rule to establish any final test procedures for CFLKs 

Test Procedure effective date (projected) for amendments

to current CFLK TP (proposed Appendix V)

(30 days after f

Test Procedure compliance date (projected) for proposed

CFLK test procedure (proposed Appendix V1) to supportCFLK ECS rulemaking

Q

* Calendar y

2015 2016 2019
12

Regulatory History – Test Procedure

• Title III of the Energy Policy and Conservation Act (EPCA) e

the “Energy Conservation Program for Consumer Products 

Automobiles,” which includes CFLKs.

• The Energy Policy Act of 2005 (EPAct) amended EPCA and 

energy conservation standards for CFLKs, as well as requirthe CFLK test procedures.

• EPAct 2005 required the CFLKs test procedure be based on 

procedures referenced in the ENERGY STAR specifications f

light fixtures and compact fluorescent light bulbs.

• On December 8, 2006, DOE published a final rule in the Fe

Register for test procedures for CFLKs. 71 FR 71340.

• DOE is conducting this test procedure rulemaking for CFLK

42 U.S.C. 6295(r).
13

Regulatory History – Test Procedure

• The Energy Independence and Security Act of 2007 (EISA) 

requirements for test procedures:

• At least once every 7 years DOE must conduct an evaluatio

covered products and either amend the test procedures or 

determination in the Federal Register not to amend them.

• For test procedures of covered products that do not fully ac

standby‐mode and off‐mode energy consumption, EISA 200

DOE to amend its test procedures to account for standby‐m

mode energy consumption, unless it is technically infeasibl

• The existing test procedures for CFLKs are specified in App

Subpart B of part 430 of Title 10 of the CFR.
14

Scope of Coverage

• EPCA defines a CFLK as “equipment designed to provide li

ceiling fan that can be

• (A) integral, such that the equipment is attached to the ceili

to the time of retail sale; or

• (B) attachable, such that at the time of retail sale the equipm

physically attached to the ceiling fan, but may be included in

ceiling fan at the time of sale or sold separately for subsequ

attachment to the fan.”

(42 U.S.C. 6291(50)(A)and(B))

• Therefore, any equipment designed to provide light from 

that are defined as CFs under the CFs rulemaking will be in

the scope of the CFLK rulemaking.
15

CFLK Test Procedures NOPR Presentation Over

3 Proposed Test Procedures to Support Standards Rul1 Existing Product Classes, Metrics, and Test Procedu2 Proposed Amendments to Current Test Procedures4 Clarifications to the Energy Conservation Standards5 Determination of Represented Values
16

Current Test Procedure Applicability and Efficien

• Currently there are three product classes for

CFLKs and the metrics and test procedurerequirements vary by product class

Current Product Classes

Product

Class Description Efficiency Metric*

Test Proce

Design Sta

1 CFLKs with medium screw base (MSB) sockets Lamp efficacy (lm/W) Test procedu2 CFLKs with pin‐based fluorescent sockets System efficacy (lm/W) Test procedu

3 All other CFLKs Wattage Limiter Design stand

* CFLKs with medium screw‐base sockets must be packaged with lamps to fill all sockets and th

lamps must meet additional specifications in ENERGY STAR Program Requirements for Compac

Fluorescent Lamps, version 3.0. CFLKs with pin‐based sockets must also use an electronic ballapackaged with lamps to fill all sockets.
17

DOE’s Current Test Procedures

• DOE's test procedures for determining the efficiency for C

product class 1 and 2 are codified in Appendix V to subpar

430 of Title 10 of the CFR; DOE has not established a test 

product class 3 CFLKs.

Product

Class 1

Product

Class 2

“CFL Requirements for Testing” of the

“ENERGY STAR Program Requirements

for Compact Fluorescent Lamps,”

Version 3.0, which references IES LM‐

66‐00 for lamp efficacy measurements

“ENERGY STAR Program Requirem

for Residential Light Fixtures,” Ver

4.0, which references IES LM‐66‐0

and IES LM‐9‐99 for system efficac

measurements
18

Proposed Test Procedures: Two phase process

• DOE proposes to make minor clarifications and amendme

current test procedures (i.e., updates to test procedure re

• Because the amendments will not change the measured CF

efficiency, DOE proposes that the test procedure will be eff

days after publication and manufacturers must make any

representations with respect to energy use or efficiency of 

light kits beginning 180 days after publication of the final ru

Federal Register.

• As part of this NOPR, DOE proposes to add new test proce

would revise the methods for measuring the energy effic

CFLKs to support the concurrent energy conservation sta

rulemaking.

• DOE proposes new test procedures that support the standa

rulemaking for CFLKs and would be required at the complia

a potential amended CFLK standard.
19

CFLK Test Procedures NOPR Presentation Over

3 Proposed Test Procedures to Support Standards Rul1 Existing Product Classes, Metrics, and Test Procedu2 Proposed Amendments to Current Test Procedures4 Clarifications to the Energy Conservation Standards5 Determination of Represented Values
20

Proposed Amendments to Current Test Proced

• DOE’s intention with the proposed changes to the current CFLK test 

harmonize the represented values of lamp efficacy, wherever possi

covered lamp regulations.

• DOE believes this will reduce burden on CFLK manufacturers if they 

covered lamps rated pursuant to DOE’s regulations to be packaged 

• DOE proposes to make the following amendments to the current te

product classes 1 and 2:

Product

Class

Current Test Procedure Proposed Change to Cu

Procedure(s)

1

(MSB)

“CFL Requirements for Testing” of the

“ENERGY STAR Program Requirements for

Compact Fluorescent Lamps,” Version 3.0

DOE test procedure for MSB C10 CFR 430, subpart B, append

2

(Pin‐Base)

“ENERGY STAR Program Requirements for

Residential Light Fixtures,” Version 4.0

Current industry test procedur

IES LM‐66‐11 or IES LM‐9‐09System Efficacy would remain 
21

Proposed Amendments to Current Test Proced

Issue 1: CFLKs with MSB Lamps

DOE requests comments on the proposed changes for existin

procedures for CFLKs packaged with medium screw base lam

Issue 2: CFLKs with Pin‐Based Fluorescent Lamps

DOE requests comments on the proposed changes for existin

procedures for CFLKs packaged with pin‐based fluorescent lam
22

CFLK Test Procedures NOPR Presentation Over

3 Proposed Test Procedures to Support Standards Rul1 Existing Product Classes, Metrics, and Test Procedu2 Proposed Amendments to Current Test Procedures4 Clarifications to the Energy Conservation Standards5 Determination of Represented Values
23

Proposed Test Procedures to Support Standards R

• DOE is proposing to add new test procedures that would 

concurrent energy conservation standards rulemaking for 

Specifically, DOE is:

1. proposing to use an efficiency metric—efficacy (lm/W)—to 

the energy efficiency of all CFLKs

2. proposing to update the active mode test procedures to re

current DOE or industry lamp test procedures

3. NOT proposing to incorporate any energy consumption in 

off mode into the CFLK efficiency metric.
24

1. Proposed Metric

• DOE proposes to use efficacy, measured in lumens per w

quantify the energy efficiency of all CFLKs.

• Lamp Efficacy: For CFLKs with consumer‐replaceable lamp

• Luminaire Efficacy: For CFLKs with integral solid‐state ligh

circuitry
25

1. Proposed Metric

• Luminaire Efficacy

• The luminaire efficacy of each basic model of

CFLK with integral SSL circuitry would be

determined.

• “CFLKs with integral SSL circuitry” means:

1. CFLKs that have SSL drivers and/or light sources

(e.g., an LED array or module) that are notconsumer replaceable, or

2. CFLKs that have SSL drivers and light sources that

are consumer replaceable, but the SSL driver and

light source are separated by additional

intermediate circuitry within the CFLK (e.g., wiringbetween a replaceable driver and a replaceable

light source).
26

1. Proposed Metric

Lamp Efficacy Measurement Luminaire Efficacy Me

Consumer‐Replaceable Lamp

Non‐Replaceable SSLSource and Driver

Non‐ReplaceableSSL Driver

RS

(s
27

1. Proposed Metric

Issue 5: Efficacy Measurements of Lamps and Luminaires

DOE requests comments on its proposal to use lamp efficacy 

technically feasible and otherwise luminaire efficacy to deter

the efficiency of CFLKs.

Issue 7: CFLKs with Integral SSL Circuitry

DOE requests comment on its assessment that it is technically

infeasible to measure the lamp efficacy of CFLKs with integrat

circuitry either because it would require destructive disassem

the CFLK or measurement of consumer replaceable light sour

driver [without integrated circuitry], which would not result i

representations of the light source efficacy.
28

2. Proposed Active Mode Test Procedures

• DOE proposes to determine CFLK efficiency according to 

procedures for the given lamp, when possible, and with 

test procedures otherwise. DOE is currently engaged in te

procedure rulemakings for CFLs and integrated LED lamps

Lighting

Technology

Lamp or Luminaire

Efficacy Measured

Refere

Pro

Compact fluorescent lamps (CFLs) Lamp efficacy Appendix 

B of 10 CF

General service fluorescent lamps

(GSFLs) and general service

incandescent lamps (GSILs)

Lamp efficacy Appendix 

B of 10 CF

Other (non‐CFL and non‐GSFL)fluorescent lamps Lamp efficacy IES LM‐9‐0

Integrated LED lamps Lamp efficacy Appendix 

B of 10 CF

All other SSL lamps Lamp efficacy IES LM‐79

CFLKs with integrated SSL circuitry Luminaire efficacy IES LM‐79
29

2. Proposed Active Mode Test Procedures

• For CFLKs that utilize multiple lamp models, DOE propose

lamp model be tested according to the appropriate lamp 

procedure for each lamp type.

• Referencing existing DOE lamp test procedures will minimiz

testing burden (i.e., lamps already tested per DOE test proc

not require additional testing).

• For CFLKs that have both consumer replaceable lamps an

SSL circuitry, DOE proposes that lamp efficacy be reporte

consumer replaceable lamps and that luminaire efficacy 

for the CFLK integrated SSL circuitry, with the consumer r

lamps removed.
30

3. Standby/Off‐Mode Energy Consumption

• DOE is not proposing to incorporate energy consumption 

mode in the CFLK efficiency metric and has determined t

energy consumption in the off mode; therefore, DOE is no

standby or off mode test procedures.

• Standby mode energy consumption for light kits packaged 

measured as part of the proposed CF test procedure.

Issue 9: Standby/Off‐Mode Energy Consumption

DOE requests comment on its approach to addressing standb

power consumption in CFLKs.
31

CFLK Test Procedures NOPR Presentation Over

3 Proposed Test Procedures to Support Standards Rul5 Determination of Represented Values1 Existing Product Classes, Metrics, and Test Procedu2 Proposed Amendments to Current Test Procedures4 Clarifications to the Energy Conservation Standards
32

Clarifications to 10 CFR 430.32(s)

• CFLK energy conservation standards are codified in 10 CFR 

• DOE proposes to replace references to ENERGY STAR prog

requirements in 10 CFR 430.32(s) with tables that contain 

performance requirements. Performance requirements inclu

CFLKs packaged with MSB CFLs: lamp efficacy, lumen maintena

1,000 hours, lumen maintenance at 40% of lifetime, rapid cycle 

lifetimeCFLKs packaged with MSB light sources other than CFLs: lamp e

CFLKs packaged with pin‐based fluorescents: system efficacy, e

ballast required

• The current energy conservation requirements remain un
33

Updated Guidance on Accent Lighting

• DOE previously issued guidance on accent lighting used in 

stating, “DOE does not consider ceiling fan accent lighting 

a significant light source to be part of the 190‐watt limitat

class 3 CFLKs].”

• Because it is difficult to quantitatively define “a significant 

source” in a CFLK, and may result in inconsistency in the a

of CFLK standards, DOE proposes to:

1. withdraw the current guidance on accent lighting 30 da

publication of the final rule, and

2. consider all lighting packaged with any CFLK to be subje

conservation requirements.

Issue 4: Accent LightingDOE requests comment on its withdrawal of current guidance 

accent lighting in CFLKs and proposal to consider all lighting p

with all CFLKs to be subject to energy conservation requireme
34

CFLK Test Procedures NOPR Presentation Over

3 Proposed Test Procedures to Support Standards Rul5 Determination of Represented Values1 Existing Product Classes, Metrics, and Test Procedu2 Proposed Amendments to Current Test Procedures4 Clarifications to Energy Conservation Standards
35

Determination of Represented Values

• The requirements of 10 CFR 429.11 (“General sampling

requirements for selecting units to be tested”) are applica

CFLKs, except that, for CFLKs subject to a design standard

must meet the design standard.

• For each basic model of CFLK, the following requirements 

applicable for compliance with the current energy conse

standards:

CFLK Socket

Type

Bulb Type Included

in CFLK Package

Represented Values Shall 

Determined in Accordance W

MSB

CFL 10 CFR Part 429.35

Integrated LED 10 CFR Part 429.56

General ServiceIncandescent 10 CFR Part 429.27

Pin‐based Fluorescent 10 CFR 429.35

All Others Socket Types 10 CFR 430.32(s)(4)
36

Determination of Represented Values

• For each basic model of CFLK, the following requirements 

applicable for compliance with amended energy conserv

standards, if established:

Lamp Type Included in CFLK Package Represented Values 

Determined in Accord

CFL 10 CFR Part 429.35

General Service Fluorescent and Incandescent

Lamps 10 CFR Part 429.27

Integrated LED 10 CFR Part 429.56

Other Fluorescent Lamps (Not CFLs or GSFLs) 10 CFR Part 429.35Other SSL (not integrated LED) 10 CFR Part 429.56

CFLKs with Integrated SSL Circuitry 10 CFR 429.33
37

How to Submit Written Comments

• In all correspondence, please refer to the CFLK test procedure 

by:

– Test Procedure for Ceiling Fan Light Kits;

– Docket Number EE‐2014–BT–TP–0007; and

– Regulatory Identification Number (RIN) 1904‐AD17.

• Email: CFLK2014TP0007@ee.doe.gov

Postal: Courier:Ms. Brenda EdwardsU.S. Department of Energy

Building Technologies Program,Mailstop EE‐5B

1000 Independence Avenue, SWWashington, DC 20585‐0121

Ms. Brenda EdwardsU.S. Department of Energy

Building Technologies Progra950 L’Enfant Plaza, SW

Washington, DC 20024Tel: 202 586‐2945

Test Procedure NOPR Comment Period closes: January 14, 2015, 1
38

CFLK Energy Conservation Standards Preliminary 
39

How to Submit Written Comments for CFLKs

• In all correspondence, please refer to the CFLK rulemaking by:

– Energy Conservation Standards for Ceiling Fan Light Kits;

– Docket Number EERE‐2012‐BT‐STD‐0045; and

– Regulatory Identification Number (RIN) 1904‐AC87.

• Email: CeilingFanLightKits2012STD0045@ee.doe.gov

Postal: Courier:Ms. Brenda EdwardsU.S. Department of Energy

Building Technologies Program,Mailstop EE‐2J

1000 Independence Avenue, SWWashington, DC 20585‐0121

Ms. Brenda EdwardsU.S. Department of Energy

Building Technologies Progra950 L’Enfant Plaza, SW

Washington, DC 20024Tel: 202 586‐2945

Energy Conservation Standards TSD Comment Period clo

December 30, 2014, 11:59 PM EDT
40

Opening Remarks

Meeting participants are invited to provide ope

remarks or statements at this time.
41

CFLKs ECS Rulemaking Schedule

Milestone Da

Notice of Public Meeting and Availability of CFs and CFLKs

Framework Document March 

Notice of Public Meeting and Availability of CFLKs Preliminary

Technical Support Document October 

Notice of Proposed Rulemaking for CFLKs (projected) Q

Final Rule for CFLKs (projected) QCompliance Date for CFLKs (projected) Q

* Calendar quarters

2013 2014 2016 2017 2018 

2015 2019
42

Regulatory History: Energy Conservation Stand

• The Energy Policy Act of 2005 amended the Energy Policy a

Conservation Act of 1975 (EPCA) by adding CFLKs as covere

(42 U.S.C. 6295(ff))

− Provided DOE the ability to establish energy conservation sta

“ceiling fan light kits,” as defined by 42 U.S.C. 6291(50), and s

requirements for determining whether standards should be 

• On October 18, 2005, DOE published a final rule technical a

(70 FR 60407, 60413) codifying energy efficiency standards product classes of CFLKs.

• On January 11, 2007, DOE published a final rule technical a

codifying energy efficiency standards for a third product cla

72 FR 1270.

• DOE is conducting this energy conservation standards rulem

pursuant to 42 U.S.C. 6295(ff)(5).
43

CFLK ECS Pre‐Analysis Presentation Overview

3 Screening Analysis5 Product Price Determination1 Scope of Coverage6 Energy Use2 Market & Technology

11 Closing Remarks

4 Engineering Analysis7 Life-Cycle Cost Analysis8 Shipments; National Impact Analysis9 Preliminary MIA

10 NOPR Analyses
44

Scope of Coverage

• EPCA defines a CFLK as “equipment designed to provide li

ceiling fan that can be

• (A) integral, such that the equipment is attached to the ceili

to the time of retail sale; or

• (B) attachable, such that at the time of retail sale the equipm

physically attached to the ceiling fan, but may be included in

ceiling fan at the time of sale or sold separately for subsequ

attachment to the fan.”

(42 U.S.C. 6291(50)(A)and(B))

• Therefore, any equipment designed to provide light from 

that are defined as CFs under the CFs rulemaking will be in

the scope of the CFLK rulemaking.
45

CFLK ECS Pre‐Analysis Presentation Overview

3 Screening Analysis5 Product Price Determination1 Scope of Coverage6 Energy Use2 Market & Technology

11 Closing Remarks

4 Engineering Analysis7 Life-Cycle Cost Analysis8 Shipments; National Impact Analysis9 Preliminary MIA

10 NOPR Analyses
46

Market & Technology Assessment

• Purpose:

• Characterize the CFLK market

• Define product classes• Identify technology options

• Method:

• Identify and characterize manufacturers of CFLKs

• Identify existing regulatory and voluntary efficiency program

• Gather historical shipment and other relevant market data

• Estimate market trends• Identify measures that could improve efficiency
47

Market Assessment

• CFLKs used with low‐volume CFs

• Currently three product classes:

1. Medium screw base sockets

2. Pin‐based sockets (for externally‐ballasted fluorescent lam

3. All other CFLKs

Product

class

Shelf Surveys Online 

Market Share

by Product Class Base Type Market Share by Base Type Market Share by Product Class Marke

by Ba

1 15.1% Medium screw base 15.1% 16.9% 16

2 0.0% Pin‐based fluorescent 0.0% 0.5% 0

3 84.9%

Candelabra

(including mini

candelabra)

79.2%

82.4%

68

GU24 4.6% 12

Others (e.g., G9, GU

10, integral solid‐

state lighting)

1.2% 0

100% 100% 100% 10

Estimates of CFLK Market Shares in 2012 by Current Product Class and Socket Type:
48

Market Assessment

NPD Estimates of Historical Shipments of CFs:(source: NPD Group, 2007‐2011)DOE Estimates of Historical Shipments of CFs:(based on NPD data above, assuming ratio of CFs sold with and without CFLKs is equ

customers who did and did not specify)

Number of Units 2007 2008 2009 2010 

With CFLK 18,360,000 18,180,000 19,160,000 16,870.000 

Without CFLK 2,680,000 2,610,000 2,520,000 2,560,000 

Total 21,050,000 20,790,000 21,680,000 19,430,000 % with CFLK 87% 87% 88% 87% 

Number of Units 2007 2008 2009 2010 

With CFLK 14,899,594 15,485,300 16,015,248 14,414,909 Without CFLK 2,176,229 2,226,826 2,106,832 2,184,390 

Not Specified 3,970,371 3,080,311 3,561,611 2,830,707 
49

Market AssessmentIssue 1: CFLKs Sold with CFsDOE assumes that the majority of CFLKs are sold with CFs and did 

CFLKs sold separately in its analysis. DOE requests comment on th

assumption and available shipments data on CFLKs sold separately

Issue 8: CFLKs for High‐Volume CFs

DOE seeks answers to the following questions related to CFLKs designed f

volume fans:

• Do manufacturers anticipate that CFLKs designed for high‐volume fan

constitute a significant fraction of the CFLK market in the next 5 to 10 

• What range of lumen outputs are/would these products be designed 

• Would these CFLKs be likely to have any other unique characteristics t

common to the current market of CFLKs?
50

Considered Product Classes

• Pursuant to EPCA, DOE establishes different product classe

type of energy used; (2) capacity of the product; or (3) any performance‐related features that require different standa

such as features affecting consumer utility. (42 U.S.C. 6295

• DOE is considering redefining CFLKs from the current thre

classes into two products classes.

• New product class structure essentially combines the curren

classes 1 and 3 into the new product class 2.

Current

Product Class Description

1 Medium screw base (E26)

2

Pin‐based fluorescent(applies only to non‐integrally

ballasted lamps)

3 All other CFLKs

Proposed

Product Class D

1 CFLKs with 

ballasted o

2 All other C
51

Product ClassesIssue 7: CFLK Product Classes

DOE is considering a new product class structure that divides CFLK

product classes: Externally‐Ballasted/Driven CFLKs and All Other C

invites comment on this structure.

Issue 19: Production of Externally‐Driven LED CFLKs

DOE requests comment on whether manufacturers are currently p

expecting to produce CFLKs that use externally‐driven LED lamps.

Issue 4: DimmingDOE seeks data on the dimming functionality of current generatio

LED lamps, and specifically on the performance of those lamps wit

designed for their control. DOE seeks data on consumer satisfactio

dimming functionality of these systems. DOE also seeks input from

manufacturers as to whether they anticipate accommodating dim

functionality into the LED CFLK models they will offer for sale in th

years, and if so, what fraction of LED CFLKs would include such fun
52

Technology Options

• DOE is considering more efficacious light sources as the on

technology option to increase CFLK efficacy.

• DOE is not considering external ballasts or lighting controls

impact of these technologies cannot be measured by the p

CFLK test procedures.

Issue 5: Lighting Controls

DOE requests comment on its proposal not to include lighting con

technology option in this rulemaking.

Issue 6: CFLK Technology Options

DOE requests comment on lamps being considered as the technol

for CFLKs and any additional options that should be included.
53

CFLK ECS Pre‐Analysis Presentation Overview

3 Screening Analysis5 Product Price Determination1 Scope of Coverage6 Energy Use2 Market & Technology

11 Closing Remarks

4 Engineering Analysis7 Life-Cycle Cost Analysis8 Shipments; National Impact Analysis9 Preliminary MIA

10 NOPR Analyses
54

• DOE reviewed different technology options and assessed 

using the following criteria:

– Technological feasibility– Practicability to manufacture, install, and service

– Adverse impacts on product utility or availability to custom

– Adverse impacts on health or safety

• DOE did not screen out any technology options and there

considered more efficacious light sources as design optioengineering analysis.

Screening Analysis

Issue 10: Screening AnalysisDOE invites comment on the screening analysis.
55

CFLK ECS Pre‐Analysis Presentation Overview

3 Screening Analysis5 Product Price Determination1 Scope of Coverage6 Energy Use2 Market & Technology

11 Closing Remarks

4 Engineering Analysis7 Life-Cycle Cost Analysis8 Shipments; National Impact Analysis9 Preliminary MIA

10 NOPR Analyses
56

Select certain product classes to be analyze

engineering analysis.

Engineering Analysis Methodology

Define characteristics of models in each pr

that serve as reference points to assess cha

to energy conservation standards.

Identify more efficacious substitutes for ea

baseline model based on design options.

Develop candidate standard levels (CSLs) th

the range of efficacy from the baseline to t

maximum technologically feasible.

Scale results to product classes not analyze

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results
57

Representative Product Classes

Issue 11: Representative Product Classes

DOE requests comment on the representative pro

for CFLKs.

• DOE chooses representative product classes 

concentrate its analytical effort.

– Representative product classes were selecte

market volume or unique performance chara

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results

Product Class

All Other CFLKs

CFLKs with Externally‐Ballasted/Driven Lamps
58

• The baseline model typically represents the 

common, least efficacious lamp in a CFLK th

existing energy conservation standards.

 DOE identifies a baseline model in each rep

product class.

Baseline Lamps

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results
59

• For each baseline lamp, DOE selected more effic

replacement lamps, on the basis of initial efficac

potential energy‐saving improvements. DOE sele

efficacious substitutes under a lamp replacemen

a fixture replacement scenario.

– In the lamp replacement scenario, the more effic

with the same base type as the baseline lamp wa

– In the fixture replacement scenario, the more eff

substitute with a different base type than the ba

be selected and a change in number of fixture so

allowed.

– Both the lamp and fixture replacement scenario 

baseline lamp.

More Efficacious Substitutes: Substitution Scen

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results

Issue 13: Substitution Scenarios

DOE requests comment on the likelihood of CFLK 

selecting each substitution scenario and informat

alternative scenarios that manufacturers may cho
60

Candidate Standard Levels

• DOE considered an equation‐based approac

characterize a continuous relationship betwinput power and initial lamp efficacy.

• DOE used commercially available lamps and 

associated catalog rated efficacies to determ

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results
61

• For the All Other CFLK product class DOE ide

baseline lamp that represents the most com

efficacious lamp in a CFLK that meets existin

conservation standards.

All Other CFLKs: Baseline Lamp

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results

Bulb

Shape

Base

Type

Lamp

Type

Lamp

Wattage

Initial

Light

Output

Efficacy Lam

Lifeti

W lm lm/W hr

Spiral E26 CFL 14 730 52.1 10,0

* Used in fixture replacement scenario

Issue 12: Baseline Lamp

DOE requests comment on the baseline unit selecte

CFLKs.
62

Efficacy

Level

Lamp

Type

Base Type

Bulb

Shape

Wattage

Initial

Light

Output

Efficacy

CRI

W lm lm/W 

Baseline CFL E26 Spiral 14 730 52.1 82 2

CSL 1 CFL E26 Spiral 13 800 61.5 82 2CSL 2 CFL E26 Spiral 11 730 66.4 82 2CSL 3 LED E26 A19 10 700 70.0 75 3CSL 4 LED E26/E27 A19 9 680 75.6 80 3CSL 5 LED E26 G25 8 680 85.0 75 2

All Other CFLKs – Lamp Replacement Scenario:

More Efficacious Substitutes
63

All Other CFLKs – Fixture Replacement Scenario:

More Efficacious Substitutes

Efficacy

Level

Lamp

Type

Base

Type

Bulb

Shape

Fixture

Sockets

Lamp

Wattage

Fixture

Wattage

Lamp

Initial

Light

Output

Fixture

Initial

Light

Output

Efficacy

W W lm lm lm/W 

Baseline CFL E26 Spiral 2 14 28 730 1,460 52.1 

CSL 1 CFL E26 Spiral 1 23 23 1,500 1,500 65.2 CSL 2 CFL E26 Spiral 3 7 21 450 1,350 64.3 CSL 3 LED E26 A19 4 5 20 340 1,360 68.0 CSL 4 LED E26 A21 1 19 19 1,600 1,600 84.2 CSL 5 LED E26 A19 3 6 18 500 1,500 83.3 

Issue 14: More Efficacious Substitutes

DOE requests comment on the criteria used in selecting more efficac

substitute lamps, as well as the characteristics of the units selected f

CFLKs. DOE particularly requests comment on the lifetimes of the ba

substitute lamps.
64

All Other CFLKs: Candidate Standard Levels

• DOE considered an equation‐based approac

characterize a continuous relationship betwinput power and initial lamp efficacy.

• The following are CSLs under consideration:

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results

Candidate Standard Level Efficacy Requirement lm/W

CSL 1 73/(1+5*((W+10)‐1))

CSL 2 81/(1+5*((W+10)‐1))CSL 3 87/(1+5*((W+10)‐1))CSL 4 94/(1+5*((W+10)‐1))CSL 5 108/(1+5*((W+10)‐1))

W = rated lamp wattage
65

All Other CFLKs: Candidate Standard Levels

All Other CFLKs: Lamp and Fixture Replacement Scenarios
66

All Other CFLKs: Candidate Standard Levels

Issue 16: Candidate Standard Levels

DOE requests comment on the CSLs under consideration, including t

level, for All Other CFLKs. In particular, DOE requests comment on th

used to define the efficacy requirements at each CSL.
67

Externally‐Ballasted/Driven Product Class:

Lamp‐and‐Ballast Systems

• To assess the performance of CFLKs with Externally‐Ballast

Lamps, DOE used a systems approach and paired lamps wicapturing real‐world energy use and light output.

• DOE paired externally‐ballasted lamps with electronic balla

are required by existing CFLK standards and represent the 

common ballasts on the market.
68

Externally‐Ballasted/Driven Product Class:

Baseline Lamp

Bulb

Shape

Base

Type

Lamp

Type

Nominal

Wattage

ANSI

Rated

Wattage

System

Input

Power

Lamp

Initial

Light

Output

System

Initial

Light

Output

Lamp

Rated

Efficacy

Syste

Effica

W W W lm lm lm/W lm/

T9

Circular G10q

Fluores

cent 22 22.5 17.0 950 855 42.2 50.

Issue 12: Baseline Lamp

DOE requests comment on the baseline unit selected for CF

with Externally‐Ballasted or Driven Lamps.

* Used in fixture replacement scenario

• For the Externally‐Ballasted/Driven product class, DOE identified 

lamp that represents the most common, least efficacious lamp in 

• Baseline products in this class are subject to system efficacy stan

• DOE paired the baseline lamp with a ballast resulting in a system 

just meets standards.
69

Externally‐Ballasted/Driven Product Class:

More Efficacious Substitutes

Efficacy

Level Lamp Type Lamp Diameter

Nominal

Wattage

Rated

Wattage

System

Input

Power

Lamp

Initial

Light

Output

System

Initial

Light

Output

Lamp

Lifetime Ballast

Factor

W W W lm lm hr 

Baseline Fluorescent T9 22 22.5 17.0 950 855 12,000 0.9 

CSL 1 Fluorescent T9 20 19 14.3 920 828 12,000 0.9 

Efficacy

Level

Lamp

Type

Lamp

Diameter

Fixture

Sockets

Lamp

Wattage

Fixture

Wattage

System

Input

Power

Lamp

Initial

Light

Output

System

Initial

Light

Output

Lamp

Lifetime Starting

Method

Ba

Fac

W W W lm lm hr 

Baseline

Fluor‐

escent T9 1 22 22.5 17.0 950 855 12,000 RS 0

CSL 1 CFL ‐ 1 13 13 16.0 900 900 17,000 PS 1

Lamp Replacement Scenario

Fixture Replacement Scenario
70

Externally‐Ballasted/Driven Product Class:

More Efficacious Substitutes

Issue 13: More Efficacious Substitutes

DOE requests comment on the criteria used in selecting more effi

substitute lamps, as well as the units selected for Externally‐Balla

CFLKs. DOE particularly requests comment on the lifetimes of the 

and substitute lamps.

Issue 15: Lamp‐and‐Ballast SystemsDOE requests comment on the lamp‐and‐ballast systems selected 

Externally‐Ballasted/Driven CFLKs product class. In particular, DOE 

comment on the selection of electronic ballasts for the lamp‐and‐

systems.
71

Externally‐Ballasted/Driven Product Class:

Candidate Standard Levels

• DOE considered an equation‐based approac

characterize a continuous relationship betwinput power and initial lamp efficacy.

• The following CSL is under consideration:

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results

Candidate Standard Level Efficacy Requirement lm/W

CSL 1 62/(1+9*((W+12)‐1))

W = rated lamp wattage
72

Externally‐Ballasted/Driven Product Class:

Candidate Standard Levels

CFLKs with Externally‐Ballasted or Driven Lamps
73

Externally‐Ballasted/Driven Product Class:

Candidate Standard Levels

Issue 16: Candidate Standard Levels

DOE requests comment on the CSLs under consideration, including t

level, for Externally‐Ballasted/Driven CFLKs. In particular, DOE reque

on the equations used to define the efficacy requirements at each C
74

Scaling Between Product Classes

• In general, DOE scales CSLs to product class

directly analyzed.

• Because DOE chose to analyze all product c

representative no scaling was required.

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results
75

Engineering Analysis

Issue 17: Ballast Replacements

DOE requests comment on whether, and what fraction of, ballasts f

fluorescent lamps are designed to be replaceable by the consumer. 

requests comment on whether consumers generally replace the ba

with a consumer‐replaceable ballast if it fails, or if consumers repla

CFLK, assuming it is no longer operable.

Issue 20: Externally‐Driven LED Replacements

DOE requests comment on the practicality of externally‐driven LEDs 

module‐and‐driver systems) as replacements for externally‐ballaste

fluorescent or CFL lamps in CFLKs. Specifically, DOE requests inform

fixture changes necessary for such a replacement.

Issue 21: Externally‐Driven LED Efficacies

DOE requests information on the typical efficacy ranges for externaLEDs used in CFLKs. DOE requests information on what these efficac

represent (i.e., luminaire efficacy of the fixture, LED module alone, 

module‐and‐driver system).
76

Engineering Analysis

Issue 22: Engineering Analysis

DOE requests comments on the overall methodology and results of 

engineering analysis.
77

CFLK ECS Pre‐Analysis Presentation Overview

3 Screening Analysis5 Product Price Determination1 Scope of Coverage6 Energy Use2 Market & Technology

11 Closing Remarks

4 Engineering Analysis7 Life-Cycle Cost Analysis8 Shipments; National Impact Analysis9 Preliminary MIA

10 NOPR Analyses
78

• The efficiency of the CFLK is based on the efficacy of the la

which it is packaged.

• Therefore, DOE first developed the consumer price of the C

then determined the part of that price attributable to the l

component.

Product Price Determination
79

Consumer price of CFLK• DOE identified electrical/specialty (low prices); home cen

(medium prices); and lighting showrooms (high prices) as 

main CFLK distribution channels.

• DOE collected manufacturer suggested distributor net pri

data to calculate an average premium corresponding to th

consumer price of CFLKs for each distribution channel.

• Based on shipment estimates through each channel, DOE 

12% to the electrical/specialty price, 80% to the home cen

channel price, and 8% to the lighting showroom channel p

develop a weighted average CFLK consumer price.

Product Price Determination
80

Consumer price of CFLK attributable to lamp• Based on manufacturer feedback, DOE determined that fo

with a CFL or LED, the lamp component comprises an esti

15% of the CFLK consumer price.

• DOE applied this percentage to the weighted average CFL

consumer price to obtain the weighted average consumer 

the lamp packaged with the CFLK.

• In cases where DOE was unable to develop a consumer pr

CFLK with a representative lamp, DOE applied a ratio base

expected incremental cost of the representative lamp rela

baseline lamp.

Product Price Determination
81

Issue 24: CFLK and Lamp Price Percentages

DOE requests comment on its determination that a basic CFLK pack

ceiling fan comprises 20 percent of the consumer price of a ceiling f

kit. DOE also requests comment on its determination that a CFL or L

with a CFLK comprise 15 percent of the consumer price of the CFLK

Issue 25: Consumer Price Distribution Channel Weighting

DOE requests comment on the values of the percentages of shipme

through each of these distribution channels (electrical specialty, ho

and lighting showroom).

Issue 27: Ballast Prices

DOE requests comment on its assumption that the prices of the diff

electronic ballasts presented in the fixture replacement scenario ar

each other for the Externally‐Ballasted/Driven CFLKs product class.

Issue 26: Product Price Determination

DOE invites comment on its methodology and results for estimating 

prices for lamps packaged with CFLKs.

Product Price Determination
82

CFLK ECS Pre‐Analysis Presentation Overview

3 Screening Analysis5 Product Price Determination1 Scope of Coverage6 Energy Use2 Market & Technology

11 Closing Remarks

4 Engineering Analysis7 Life-Cycle Cost Analysis8 Shipments; National Impact Analysis9 Preliminary MIA

10 NOPR Analyses
83

Energy Use Characterization• Purpose:

• Develop annual energy use estimates for each efficiency le

• Methodology:

• Annual energy use (kWh) = annual operating hours x syste

• Annual Operating Hours:

• Residential Sector: DOE combined data on the rooms wher

located (from LBNL study) with data on operating hours for 

ceiling light fixtures by room type (from DOE’s 2012 Reside

End‐Use Consumption Survey (RLEUCS)).

• Commercial Sector: DOE used data on operating hours for 

technologies typically used in CFLKs for 14 commercial buil

from the 2010 U.S. Lighting Market Characterization (LMC)

Sector National Weighted Average Daily Operating Hours (hrs/day)

Commercial 10.6

Residential 1.4
84

Energy Use Characterization• System Input Power: DOE utilized the power consumptio

presented in the engineering analysis for representative l

lamp‐and‐ballast systems to develop system input power

• All Other CFLKs:

• DOE developed its estimate of the input power of CFLKs to ac

typical lumen output of CFLKs in the market.

• To estimate the average lumen output of All Other CFLKs, DO

store shelf survey data of CFs with light kits and CFLKs sold al

types, socket numbers, light source technologies, lamp wattaprices); and (2) lamp efficacy data from online retailers on th

lamps found in All Other CFLKs.

• CFLKs with Externally Ballasted or Driven Lamps:

• DOE did not scale their light output.
85

Energy Use Characterization

Lamp Efficacies Base Type Market Share (2012) Weighted A

CFLK Total 

Below restructured

baseline Candelabra 79% 1,663

Above restructured

baseline

E26 (MSB) 15% 1,960 GU24 5%

Vary All Other 1% (exclud

Total 100%
86

Energy Use CharacterizationResults

• CFLKs with Externally Ballasted or Driven Lamps:

• All Other CFLKs:

CSL

Residential Commercial

Energy Use

(kWh/yr)

Savings

(kWh/yr)

Energy Use

(kWh/yr)

Savings

(kWh/yr)

0 8.6 ‐ 66 ‐

1 7.7 0.9 59 7.2

CSL

Residential Commercial

Energy Use

(kWh/yr)

Savings

(kWh/yr)

Energy Use

(kWh/yr)

Savings

(kWh/yr)

0 19.0 ‐ 145 ‐

1 16.7 2.4 127 182 14.6 4.4 112 343 13.6 5.4 104 424 12.6 6.5 96 495 11.6 7.5 88 57

EnesavCSL valuengsceCSL (DOequshasce
87

Energy Use Characterization

Issue 23: Lumen Output of Pin‐Based Fluorescent CFLKs

To improve its energy use estimates, DOE seeks comment on the ty

lumen outputs of pin‐based fluorescent CFLKs.
88

CFLK ECS Pre‐Analysis Presentation Overview

3 Screening Analysis5 Product Price Determination1 Scope of Coverage6 Energy Use2 Market & Technology

11 Closing Remarks

4 Engineering Analysis7 Life-Cycle Cost Analysis8 Shipments; National Impact Analysis9 Preliminary MIA

10 NOPR Analyses
89

Life‐Cycle Cost (LCC) and Payback Period (PBP)• Purpose

• Provide an economic evaluation from the end‐user’s perspective.

• Life‐Cycle Cost (LCC) is the total purchaser cost over the life of a p

• Payback Period (PBP) is the time required to recover the increase

price of more energy‐efficient products through reduced operatin

• Method

• Develop Monte Carlo sample of 10,000 purchasers

• Determine total installed costs for each CSL.• Determine operating costs for first year and lifetime of product, in

lamp disposal costs, lamp replacements throughout the lifetime o

the residual value of lamps at the end of the CFLK lifetime

• Calculate PBP by dividing average increase in installed cost by ave

decrease in first‐year operating cost.

• Calculate LCC by adding installed cost and lifetime operating costs

• Calculate LCC savings by subtracting LCC of each CSL from LCC of 

absence of standards.
90

Purchaser Samples

• To account for variability in energy consumption, energy 

both, DOE developed a sample of 10,000 CFLK purchaser

• Residential sector:

• Randomly selected households from the subset of houses w

RECS 2009.

• DOE applied a selection weight to each household based o

of CFs in each household

• Commercial sector:

• Randomly selected buildings from the 2003 Commercial Bu

Energy Consumption Survey (CBECS) — excluding vacant bu

• DOE applied a selection weight to each building based on s

footage, number of lamps per 1000 ft2, and fraction of lam

light source technologies found in CFLKs

LCC and PBP
91

LCC and PBP

Market Efficiency Distribution by CSL

• Expected market share by CSL of CFLKs that consumers w

purchase in the compliance year in the absence of amend

standards.

• All Other CFLKs: DOE used LED incursion in combination w

consumer‐choice model to project the market distributio

shipments from 2012 to 2019.*

• Externally Ballasted/Driven CFLKs: Due to insufficient ma

DOE assumed an even split in market share between CSL 

* LED incursion, and the consumer choice model will be discussed in deta

Shipments Analysis section
92

LCC and PBP

Market Efficiency Distribution in Compliance Year 

• Percentage of sales at each CSL in the absence of amende

CSL Scenario*

Market

Share

(%)

CSL 0 50

CSL 1 Lamp Replacement 50

CSL 1 Fixture Replacement

Total 100

CSL Scenario*

M

S

Below CSL 0 

CSL 0 

CSL 1 Lamp Replacement 

Fixture Replacement

CSL 2 Lamp Replacement 

Fixture Replacement

CSL 3 Lamp Replacement 

Fixture Replacement

CSL 4 Lamp Replacement 

Fixture Replacement

CSL 5 Lamp Replacement 

Fixture Replacement

Total 

Externally Ballasted/Driven All Other CFLKs

*DOE assumed equal market shares for each engineering scenario
93

LCC and PBP

Total Installed Cost

• Total Installed Cost = Product Price + Sales Tax

• Product Price based on output of product price determin

• Includes the end‐user lamp and socket prices for each CFLK 

of lamps/sockets scaled by the same factor as total lumen o

• Also includes price learning for LEDs expected to occur by c

date (more detail provided in the shipments section).

• Sales Tax (including state and local sales tax) is determine

geographic location

• Installation cost not included because it was assumed not 

with CSL.
94

LCC and PBP

Operating Hours

• To capture variability in CFLK HOU for individual purchase

applied a triangular distribution to the average HOU.

• HOU distribution for each sample had a minimum of 80% a

maximum of 120% of the corresponding weighted average 

Electricity Prices

• Electricity prices and trends are estimated using data from 

• DOE used EIA’s Annual Energy Outlook (AEO) for projection

average energy prices (reference, high‐, and low‐growth sc
95

LCC and PBP• Used to discount operating costs to year of purchase (i.e. 

• Represents the opportunity cost of funds used to purchase 

• In the residential sector:

• For replacement CFLKs in existing homes:

• Used a distribution of debt and asset classes for purchasing a

• e.g., stocks, mutual funds, savings accounts, bonds, loan

• For CFLKs installed in new construction:

• Used a distribution of mortgage rates.

• In the commercial sector:

• Used a distribution of weighted average cost of capital.

Discount Rates
96

LCC and PBP

Lifetime

• Lifetime is the age at which the CFLK is retired from servi

• DOE used CF lifetime as a proxy for CFLK lifetime.

Maintenance and Repair Costs

• DOE considers lamp replacement costs for failed lamps to 

only repair and maintenance cost that varies with produc

efficiency.
97

LCC and PBP

Lamp Replacements

• DOE included in the LCC the cost to replace lamps that fa

the lifetime of the CFLK.

• Lamp replacement costs are the purchase costs of replacem

in the year the failed lamps are replaced, discounted to the 

start year.

• DOE assumes that CFLK lamps fail at the end of their avera

life (lamp lifetime divided by the lamp’s operating hours pe

• Replacement lamps:

• Have the same base type as failed lamps

• Provide an equivalent lumen output as failed lamps

• Prices do not include the CFLK manufacturer markup
98

LCC and PBP

Lamp Replacements: Externally Ballasted/Driven 

• DOE assumed that failed CFLK lamps are replaced with th

lamp that was originally packaged with the light kit.
99

LCC and PBP

Lamp Replacements: All Other CFLKs

• Lamp replacement options for low, medium, and high effica

• DOE used the engineering data for medium and high efficacy 

replacements and market research data for low efficacy lamp 

• Data used were efficacies, watts, prices (price learning applied 

lifetimes for each lamp replacement.

• LED incursion into the market for replacements lamps was bas

report. Fraction of low versus medium efficacy lamps was det

consumer‐choice model sensitive to price and operating cost
100

LCC and PBP

Disposal Cost

• Disposal cost represents the cost of disposing (e.g., recyc

at the end of the lamp lifetime.

• DOE found that, on average, disposing of a CFL costs abou

lamp.

• LED disposal costs assumed to be the same as for CFLs.

• Residential sector:

– DOE assumed that consumers do not pay recycling costs.

• Commercial sector:

– DOE assumed that consumers pay recycling costs for 10% o

LED lamp failures (average cost of $0.1 applied to all)
101

LCC and PBP

Residual Value

• Lamp residual value is the remaining value of the survivin

at the end of the CFLK lifetime.

– Residual value is applied as a “credit” to the LCC.

• DOE calculates the residual value for lamps based on the 

in the year the CFLK is retired, discounted to the analysis 
102

LCC and PBP

Externally Ballasted/Driven CFLKs Results

CSL

Average Costs

(2013$) Simple

Payback

(years)

Average

Lifetime

(years)

Installed Cost 

First Year’s

Operating

Cost

Lifetime

Operating

Cost

LCC

Residential Sector

0 $8.6 $1.1 $10 $19 ‐‐ 13.8 

1 $13 $1.0 $7.7 $20 33.7 13.8 

Commercial Sector

0 $8.6 $7.7 $81 $90 ‐‐ 13.8 

1 $13 $6.8 $76 $88 4.9 13.8 
103

LCC and PBP

Results: All Other CFLKs

CSL

Average Costs (2013$) Simple

Payback

(years)

Average

Lifetime

(years)

Installed

Cost

First Year’s

Operating

Cost

Lifetime

Operating

Cost

LCC

Residential Sector

0 $10.8 $2.4 $23.8 $34.6 0.5 13.8 

1 $10.9 $2.1 $20.5 $31.4 0.5 13.8 

2 $11.7 $1.9 $17.8 $29.5 0.6 13.8 

3 $24.2 $1.7 $14.2 $38.4 1.8 13.8 

4 $26.1 $1.6 $11.9 $38.0 2.0 13.8 

5 $27.5 $1.5 $9.90 $37.4 2.1 13.8 

Commercial Sector

0 $10.8 $16.9 $122 $133 0.1 13.8 

1 $10.9 $14.8 $116 $127 0.1 13.8 

2 $11.7 $13.0 $109 $120 0.1 13.8 

3 $24.2 $12.1 $113 $138 0.3 13.8 

4 $26.1 $11.2 $104 $130 0.3 13.8 

5 $27.4 $10.3 $96.0 $123 0.3 13.8 

Note: CSL 0 represents the baseline that DOE is considering for the redefined product classes.
104

LCC and PBP

Issue 3: CFLK Lifetime

For this preliminary analysis, DOE assumes that the lifetime of CFLK

to the lifetime of the CF. DOE invites comment, input, and data on t

of CFLKs.

Issue 18: Inseparable SSLs

DOE requests comment on whether and which components in CFL

solid‐state lighting components that are inseparable from the CFLK 

designed to be replaceable by the consumer. Specifically, DOE requ

information on which SSL components may be easily removable an

replaceable by consumers, and how such replacements would be p
105

LCC and PBP

Issue 28: CFLK Installation Costs

DOE welcomes comment on its approach of not including installati

the LCC analysis.Issue 29: CFLK Disposal Costs

DOE requests comment and relevant data on the disposal cost assu

the different light source technologies used in CFLKs.

Issue 32: Market Distribution of CFLKs by CSL and Product Class

DOE requests comment on the overall methodology and assumptio

as relevant data, on the market distribution of CFLKs by CSL for eac

class.
106

CFLK ECS Pre‐Analysis Presentation Overview

3 Screening Analysis5 Product Price Determination1 Scope of Coverage6 Energy Use2 Market & Technology

11 Closing Remarks

4 Engineering Analysis7 Life-Cycle Cost Analysis8 Shipments; National Impact Analysis9 Preliminary MIA

10 NOPR Analyses
107

• Purpose

– Quantify changes over time in product shipments due to po

amended energy efficiency standards over analysis period 

– Estimate the disaggregation of shipments into product clas

CSLs over time

• Method

– Total CFLK shipments estimated using a stock‐accounting m

calibrated to historical shipments data

– Model accounts for product replacements, new constructio

installations into existing buildings

– Shipments disaggregated by CSL using a modified consume

model

Shipments Analysis: Overview
108

Shipments Analysis

Input Data Description/Source

Replacements Historical shipments from Appliance Magazine, N

Energy Star. Retirement function from lifetime.

New Construction Annual Energy Outlook 2014, penetration from RE

Existing Buildings Estimate of increasing penetration from RECS

Market Share Model counts from in‐store visits and online retai
109

Shipments Analysis: Schematic

Replacements

New

Construction

New

Installations

Retirement FunctionHistorical ShipmentsAEO ProjectionRECS 2009

Total Shipments

Consumer‐ChoiceModel
110

• DOE assumed 88% of low‐volume CF shipments were pac

sold with CFLKs based on analysis of market data

• DOE assumed CFLKs were not purchased with high‐volum

• Market share by product class for 2012 based on in‐store 

surveys

– Externally‐Ballasted/Driven: 0.5%

– All Other CFLKs: 99.5%

• LED penetration estimated with an incursion curveShipments Analysis: Inputs & Assumptions

Issue 36: Sector Breakdown of CFLK Usage

DOE requests comments on its assumed breakdown of CFLK usage 

the residential sector and 5% commercial sector.
111

• Price learning applied to CFLKs that use solid‐state lightinShipments Analysis: Price Learning

Issue 30: CFLK Price Learning

DOE requests comment on the assumption that only LEDs will cont

undergo significant cost reduction due to price learning.
112

• Market shares for LED CFLKs modelled as a Bass diffusion Shipments Analysis: LED incursion
113

Shipments Analysis

Issue 33: CFLK Distributions by Technology and Sector

DOE assumed that the distribution of CFLKs by light source technol

commercial sector is the same as the light source technology distri

residential sector. DOE requests comment and input regarding this 

Issue 34: LED Penetration into CFLK Market

DOE estimated the market penetration of LEDs into the CFLK marke

diffusion curve. DOE requests comment on this approach.
114

• CFLK consumer‐choice model:

1. Market share first appropriated to LED by incursion curve

2. Remaining market share split between other CSLs assumi

manufacturers will choose the lowest first cost lamp optio

given socket type and lamp technology.

3. Market share for a given CSL is assumed to be divided eve

between lamp‐replacement and fixture‐replacement scen

• In standards case, options that do not meet standard are

eliminated and probabilities recalculated

Shipments Analysis: Consumer‐Choice Model
115

• DOE uses a relative price elasticity to estimate decrease i

shipments due to a price increase due to implementation 

standard

• Since low‐volume CFs and CFLKs are usually packaged tog

DOE also considered the impact of a CF standard on CFLK 

in its base case CFLK shipments scenario

Shipments Analysis: Impact of Standards
116

Shipments Analysis: Results

Externally Ballasted/Driven

All Other CFLKs
117

• Purpose

‒ Determine the projected national energy savings and consu

national net present value of a potential standard.

• Method

‒ Develop annual series of national energy and economic im

‒ Use the shipments model to estimate the total stock of CF

service each year.

‒ Aggregate the costs and energy use per unit in any given ye

‒ Report estimates for economic impact as change in consum

Net Present Value (NPV) (in constant year dollars).

‒ Account for the time‐value of money through defined disco

National Impact Analysis: Overview
118

National Impact Analysis: NIA Process

Shipments

Analysis

Life‐Cycle Cost

Analysis

Natio

Saving

Nati

Pres

(Billio

National

Energy

Savings

NationalEconomicImpacts

• NES and NPV are calculated for products shipped from 20

(including energy savings realized in later years by those p

Inputs NIA process

O
119

National Impact Analysis Inputs

Input Description

Total Installed Cost Per‐unit annual weighted‐average values as a function of CSL taken fr

analysis.

Repair and

Maintenance Costs

Relamping accounted for over course of CFLK lifetime depending on l

packaged with CFLK.

Annual Energy Use Per‐unit annual weighted‐average values as a function of CSL taken fr

analysis.

Base‐Case Efficiencies Shipments‐weighted efficiencies determined for the compliance year 

consumer‐choice model in the base case.

Standards‐CaseForecasted Efficiencies

Shipments‐weighted efficiencies determined for the compliance year 

consumer‐choice model for each potential standards case.

Energy Prices Average national forecasted energy prices from EIA AEO 2014 forecas

extrapolation to 2048.

Full‐Fuel Cycle Multiplier for the primary fuel (electricity) used by CFLKs.

Discount Rate 7 percent and 3 percent real from OMB’s Regulatory Analysis Guideli

Present Year Future expenses are discounted to the year 2014.

National Impact Analysis
120

National Impact Analysis

NES(y) (AEC (y) AEC (y)) RF μ(y)  base  std  

Where:NES(y) = National energy savings in year y (quads),

AECbase(y) = base case annual national energy consumption, conside

full‐fuel cycle, for all product classes combined in year y 

AECstd(y) = standards case annual national energy consumption, con

the full‐fuel cycle, for all product classes combined in ye

(quads),

RF = rebound rate factor = 1‐rebound rate, and

μ(y) = full‐fuel cycle multiplier

• National energy primary energy savings is calculated using 

following equation:
121

• Full‐fuel cycle (FFC) measure of energy and greenhouse g

other emissions is accounted for in this standards rulema

‒ DOE has published a Notice of Policy (NOP) stating its inten

incorporate FFC metrics into the cost‐benefit analysis. 76 F

(Aug. 18, 2011).

• Methodology is based on the calculation of an FFC multip

conversion factor, for the electricity used by the product.

National Impact Analysis: Full‐Fuel Cycle
122

National Impact Analysis

NPV  PVS  PVC

Where:NPV = National net present value (2013$)

PVS = present value savings in operating cost (including costs for

energy, repair, and maintenance in 2013$), and

PVC = present value of increase in total installed cost (including cost

for equipment and installation in 2013$)

• National Net Present Value is calculated using the followin

NPV was calculated using 3% and 7% discount rates:
123

National Impact Analysis: Lamp Replacement

Lamp Replacements

• DOE included in the NIA the cost to replace lamps that fa

the lifetime of the CFLK.

– Lamp replacement costs are the purchase costs of replacem

in the year the failed lamps are replaced.

– DOE assumes that CFLK lamps fail at the end of their avera

life (lamp lifetime divided by the lamp’s operating hours pe

– Replacement lamps:

• Have the same base type as failed lamps

• Provide an equivalent lumen output as failed lamps

• Prices do not include the CFLK manufacturer markup

– Consumer‐choice model to determine replacement lamp.
124

National Impact Analysis: Residual Value

Residual Value

• Lamp residual value is the remaining value of the survivin

at the end of the CFLK lifetime.

– Residual value is applied as a “credit” to the NIA.

• DOE calculates the residual value for lamps based on the 

in the year the CFLK is retired.
125

National Impact Analysis: FFC Net Energy Savin

Product

Class CSL 1 CSL2 CSL3 CSL4 

Externally‐Ballasted/Driven

0.0005

All Other 0.286 0.330 0.394 0.394 

Energy Savings (quads)
126

Product Class CSL 1 CSL2 CSL3 CSL4 

Externally‐Ballasted/Driven

(millions 2013$)

‐0.34

All Other

(billions 2013$) 3.39 3.66 3.89 3.89 National Impact Analysis: Net Present Value

Product Class CSL 1 CSL2 CSL3 CSL4 

Externally‐Ballasted/Driven

(millions 2013$)

‐0.37

All Other

(billions 2013$) 2.22 2.35 2.25 2.25 

NPV at 7% discount rate

NPV at 3% discount rate
127

CFLK ECS Pre‐Analysis Presentation Overview

3 Screening Analysis5 Product Price Determination1 Scope of Coverage6 Energy Use2 Market & Technology

11 Closing Remarks

4 Engineering Analysis7 Life-Cycle Cost Analysis8 Shipments; National Impact Analysis9 Preliminary MIA

10 NOPR Analyses
128

Preliminary MIA• Purpose

– The manufacturer impact analysis (MIA) identifies the impa

energy conservation standards on manufacturers.

• Phase 1

– DOE creates an industry profile to characterize the industry 

identify important issues that require consideration.

• Phase 2

– DOE prepares an industry cash‐flow model and an interview

questionnaire to guide subsequent discussions.

• Phase 3

– DOE interviews manufacturers and assesses the impacts of 

both quantitatively (using the Government Regulatory Imp

and qualitatively (impacts on competition, manufacturing c

direct employment, and regulatory burden).
129

MIA: Ceiling Fan Light Kit Issues for Comment

Issue 40: Manufacturer Impact Analysis

DOE requests comment on its identification of key issues and reque

information from interested parties that can assist in evaluating the 

impact on CFLK manufacturers.

Issue 38: Regulatory Flexibility Act Analysis

DOE invites interested parties to provide information regarding any 

businesses that manufacture CFLKs and should be consulted before 

publishes a NOPR.

Issue 39: Manufacturer Subgroup Analysis

DOE requests feedback on subgroups to analyze and/or characteris

appropriate for a separate subgroup analysis.

Issue 41: Manufacturer Markup

DOE requests comment on the manufacturer markup value of 1.37 

preliminary analysis.
130

CFLK ECS Pre‐Analysis Presentation Overview

3 Screening Analysis5 Product Price Determination1 Scope of Coverage6 Energy Use2 Market & Technology

11 Closing Remarks

4 Engineering Analysis7 Life-Cycle Cost Analysis8 Shipments; National Impact Analysis9 Preliminary MIA

10 NOPR Analyses
131

Monetizatioof Emission Reductions Benefits

Life-Cycle Cost Subgroup Analysis

Manufacturer Impact Analysis

Utility Impact Analysis

Employment Impact Analysis

Revise

Preliminary

Analysis

Framework

Document

Prelim

Analysis NOPR Final Rule

Analyses for Notice of Proposed Rulemaking (N

Emissions Analysis
132

NOPR Analyses

• LCC Subgroup Analysis

– Effects on various national consumer subgroups

• Manufacturer Impact Analysis

– Continue work begun in the preliminary MIA

• Employment Impact Analysis

– Indirect effects on national employment

• Utility Impact Analysis

– Effects on generation capacity of utilities

• Emissions Analysis

– Effects on airborne pollutant emissions

• Monetization of Emission Reductions Benefits

– Monetary benefits from emissions reduction

• Regulatory Impact Analysis

– Potential for non‐regulatory approaches
133

CFLK ECS Pre‐Analysis Presentation Overview

3 Screening Analysis5 Product Price Determination1 Scope of Coverage6 Energy Use2 Market & Technology

11 Closing Remarks

4 Engineering Analysis7 Life-Cycle Cost Analysis8 Shipments; National Impact Analysis9 Preliminary MIA

10 NOPR Analyses
134

Closing Remarks/Questions
135

How to Submit Written Comments for CFLKs

• In all correspondence, please refer to the CFLK rulemaking by:

– Energy Conservation Standards for Ceiling Fan Light Kits;

– Docket Number EERE‐2012‐BT‐STD‐0045; and

– Regulatory Identification Number (RIN) 1904‐AC87.

• Email: CeilingFanLightKits2012STD0045@ee.doe.gov

Postal: Courier:Ms. Brenda EdwardsU.S. Department of Energy

Building Technologies Program,Mailstop EE‐2J

1000 Independence Avenue, SWWashington, DC 20585‐0121

Ms. Brenda EdwardsU.S. Department of Energy

Building Technologies Progra950 L’Enfant Plaza, SW

Washington, DC 20024Tel: 202 586‐2945

Energy Conservation Standards TSD Comment Period clo

December 30, 2014, 11:59 PM EDT