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CHAPTER 1. INTRODUCTION 

TABLE OF CONTENTS 

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

1.2 OVERVIEW OF THE APPLIANCES AND COMMERCIAL EQUIPMENT 

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

1.3 OVERVIEW OF GSFL AND IRL STANDARDS ......................................................... 1-2

1.4 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS ................... 1-3

1.5 STRUCTURE OF THE DOCUMENT ............................................................................ 1-5

LIST OF TABLES 

Table 1.4.1 Analyses under the Process Rule .............................................................................. 1-4
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CHAPTER 1. INTRODUCTION 

1.1 PURPOSE OF THE DOCUMENT 

This preliminary technical support document (TSD) provides the analytical approaches, 

inputs, and results associated with the U.S. Department of Energy’s (DOE’s) study of energy 

conservation standards for general service fluorescent lamps (GSFLs) and incandescent reflector 

lamps (IRLs). The preliminary TSD also serves to provide technical detail and is a compendium 

to the life-cycle cost (LCC) and payback period (PBP) and national impact analysis (NIA) 

spreadsheets that are available on regulations.gov, docket number EERE–2011–BT–STD–0006

for the preliminary analysis at www.regulations.gov/#!docketDetail;D=EERE-2011-BT-STD0006.

a

1.2 OVERVIEW OF THE APPLIANCES AND COMMERCIAL EQUIPMENT 

STANDARDS PROGRAM 

Title III of the Energy Policy and Conservation Act of 1975 (EPCA; 42 U.S.C. 6291–

6317), as amended, established the “Energy Conservation Program for Consumer Products Other 

Than Automobiles,” which includes major household appliances.b

Subsequent amendments 

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

industrial equipment, including certain general service fluorescent and incandescent reflector 

lamps—the products that are the focus of this rulemaking. Before DOE determines whether to 

adopt a proposed energy conservation standard, it first solicits comments on the proposed 

standard. DOE designs any new or amended standard to achieve the maximum improvement in 

energy efficiency that is technologically feasible and economically justified. (42 U.S.C. 

6295(o)(2)(A)) To determine whether a standard is economically justified, DOE must review 

comments on the proposal and determine that the benefits of the proposed standard exceed its 

burdens to the greatest extent practicable, weighing the following seven factors: 

(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; 

 

a

 Information regarding the preliminary analysis can also be found here: 

www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/24. 

b

 Part B was re-designated Part A on codification in the U.S. Code for editorial reasons. 
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(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)) 

1.3 OVERVIEW OF GSFL AND IRL STANDARDS 

As mentioned in the previous section, Part B of Title III (42 U.S.C. 6291-6309), as 

amended, established the “Energy Conservation Program for Consumer Products Other Than 

Automobiles,” which includes the GSFLs and IRLs that are the subject of this rulemaking. In 

particular, amendments to EPCA in the Energy Policy Act of 1992 (EPAct 1992), P.L. 102-486, 

established energy conservation standards for certain classes of GSFLs and IRLs, and authorized 

DOE to conduct two rulemaking cycles to determine whether these standards should be 

amended. (42 U.S.C. 6291(1), and 6295(i)(1) and (3)-(4)) EPCA also authorized DOE to adopt 

standards for additional GSFLs, if such standards were warranted. (42 U.S.C. 6295(i)(5)) DOE 

completed the first cycle of amendments by publishing a final rule in July 2009 (hereafter the 

“2009 Lamps Rule”). 74 FR 34080 (July 14, 2009). The 2009 Lamps Rule addressed two 

statutory directives under 42 U.S.C. 6295(i) by amending existing energy conservation standards 

for GSFLs and IRLs (42 U.S.C. 6295(i)(3)) and adopting standards for additional GSFLs (42 

U.S.C. 6295(i)(5)). That rule also amended the definition of “colored fluorescent lamp” and 

“rated wattage” and adopted test procedures applicable to the newly covered GSFLs.c

This rulemaking is DOE’s second cycle of review to determine whether the standards in 

effect for GSFLs and IRLs should be amended and whether the standards should apply to 

additional GSFL types as directed by EPCA. (42 U.S.C. 6295(i)(3)-(4) and (5)) DOE developed 

the analytical framework in the “Energy Conservation Standards Rulemaking Framework 

Document for General Service Fluorescent Lamps and Incandescent Reflector Lamps” (August 

31, 2011).

d DOE presented this analytical approach to interested parties during a public meeting 

held on October 4, 2011 (hereafter the “framework public meeting”). 

 

c

 Information regarding the 2009 Lamps Rule can be found on regulations.gov, docket number EERE-2006-STD0131 at www.regulations.gov/#!docketDetail;D=EERE-2006-STD-0131. 

d

 The framework document is available at www.regulations.gov/#!documentDetail;D=EERE-2011-BT-STD-0006-

0002. 
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This rulemaking also addresses 42 U.S.C. 6295(gg)(3), in which DOE is directed to 

incorporate standby mode and off mode energy use in any new or amended standard adopted 

after July 1, 2010 pursuant to 42 U.S.C. 6295(o). Please see chapter 2 of this preliminary TSD 

for a detailed discussion of DOE’s consideration of standby and off mode energy consumption. 

1.4 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS 

DOE considers stakeholder participation a very important part of the standards-setting 

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

rulemaking stage. Beginning with the rulemaking framework document for GSFLs and IRLs 

(hereafter the “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 test procedure and the energy conservation standard rulemakings, DOE 

involves interested parties through formal public notifications (i.e., Federal Register notices). 

For this GSFL and IRL 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. 

Before DOE determines whether to amend energy conservation standards for GSFLs and 

IRLs, it must first solicit comments on a proposed standard. (42 U.S.C. 6295(o)(2)(B)(i)) DOE 

must design new standards 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 previously described. 

Subsequent to the publication of the framework document, the standards rulemaking 

process involves preliminary analyses followed by two additional formal, major public notices, 

which are published in the Federal Register. The preliminary analyses are designed to publicly 

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

proposed rule stage. After the preliminary analyses are vetted, DOE issues the first major notice, 

the notice of proposed rulemaking (NOPR), which presents a discussion of comments received in 

response to the preliminary analyses of the impacts of standards on consumers, manufacturers, 

and the nation; DOE’s weighing of the impacts; and the proposed standards. The second 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 compliance dates of the standards. 
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Table 1.4.1 Analyses under the Process Rule 

Preliminary Analysis NOPR Final Rule*

Market and technology assessment Revised preliminary analyses Revised analyses

Screening analysis Life-cycle cost sub-group analysis

Engineering analysis Manufacturer impact analysis

Energy use characterization Emissions analysis

Product price determination Monetizing CO2 and other emissions

Life-cycle cost and payback period analysis Utility impact analysis

Shipments analysis Employment impact analysis

National impact analysis Regulatory impact analysis

Preliminary manufacturer impact analysis

* During the final rule phase, DOE considers the comments submitted by the U.S. Department of Justice 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))

On September 14, 2011, DOE published a notice announcing the availability of the 

framework document and a public meeting to discuss the proposed analytical framework for the 

rulemaking. 76 FR 56678. DOE also posted the framework document on its website: 

www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/24.

DOE held the public meeting on October 4, 2011 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 LCC and PBP analysis, 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 and the stage at which the 

analyses are undertaken. PDF copies of the slides and other material associated with the public 

meeting are available at: 

www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/24.

During the public meeting and the framework document comment period,estakeholders, 

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

parties submitted several comments about the GSFL and IRL rulemaking. The major issues 

discussed were: scope of coverage, metrics, product classes, efficacy level approach, shipment 

trends, rare earth materials, and the unknown impacts of the 2009 Lamps Rule. A detailed 

discussion of stakeholder comments is available in chapter 2 of this TSD. 

 

e

 The National Electrical Manufacturers Association (NEMA) requested that DOE extend the comment deadline 

from the original October 31, 2011 to November 28, 2011. DOE agreed and moved the comment deadline 

accordingly. The notice extending the framework comment period is available at: 

www.regulations.gov/#!documentDetail;D=EERE-2011-BT-STD-0006-0011. 
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As part of the information gathering and sharing process, DOE organized and held 

interviews with GSFL and IRL manufacturers who operate in the U.S. market. DOE had five 

objectives for these interviews: (1) solicit feedback on the scope of coverage for the rulemaking; 

(2) solicit feedback on the engineering analysis; (3) solicit feedback on topics related to the 

preliminary manufacturer impact analysis; (4) provide an opportunity early in the rulemaking 

process to express specific concerns to DOE; and (5) foster cooperation between manufacturers 

and DOE. During the manufacturer interviews, DOE discussed these and other issues regarding 

market data, distribution channels, anticipated consumer responses to standards, production and 

equipment mix, conversion costs, and cumulative regulatory burden. Appendix 12A of this TSD 

contains a complete copy of the interview guide. 

DOE incorporated the information gathered at the meetings into its market and 

technology assessment (chapter 3 of this TSD), engineering analysis (chapter 5 of this TSD), 

product price determination (chapter 7 of this TSD), and the preliminary manufacturer impact 

analysis (chapter 12 of this TSD). Following the publication of the preliminary analysis, 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 NIA, DOE developed spreadsheets using Microsoft Excel®. The 

LCC and PBP spreadsheets calculate the economic impacts of replacing GSFLs and IRLs with 

more efficacious lamps. The NIA spreadsheet calculates the national energy savings (NES) and 

national net present value (NPV) at various candidate standard levels and includes a model that 

forecasts the impacts of energy conservation standards at various levels on product shipments. 

These spreadsheets are available on regulations.gov, docket number EERE-2011-BT-STD-0006

at www.regulations.gov/#!docketDetail;D=EERE-2011-BT-STD-0006. 

1.5 STRUCTURE OF THE DOCUMENT 

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

TSD consists of 17 chapters and 18 appendices. 

Chapter 1 Introduction: provides an overview of the appliance standards program 

and how it applies to the rulemaking for GSFLs and IRLs, and outlines 

the structure of the document 

Chapter 2 Analytical Framework: describes the rulemaking process, and provides 

an overview of each analysis including rationale for preliminary 

determinations 

Chapter 3 Market and Technology Assessment: characterizes the GSFL and IRL 

market and the technologies available for increasing efficacy, and 

outlines product classes 

Chapter 4 Screening Analysis: determines which technology options are viable 

for consideration in the engineering analysis 
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Chapter 5 Engineering Analysis: describes DOE’s approach to the engineering 

analysis, and establishes candidate standard levels based on lamp 

efficacy 

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

developing energy use estimates for GSFLs and IRLs 

Chapter 7 Product Price Determination: describes DOE’s approach to 

determining the end-user prices for GSFLs and IRLs 

Chapter 8 LCC and PBP Analyses: discusses the economic effects of standards 

and calculates the LCC and PBP of GSFLs and IRLs 

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, efficacy of new lamps, and annual GSFL and IRL sales 

in the absence or presence of new standards 

Chapter 11 Life-Cycle Cost Sub-Group Analysis: discusses the methods to be 

used to study the impacts of standards on sub-groups of GSFL and IRL 

consumers and to calculate the LCC and PBP for these consumers 

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

study the impacts of standards on the finances and profitability of 

GSFL and IRL manufacturers, and presents preliminary manufacturer 

impact analysis results 

Chapter 13 Employment Impact Analysis: discusses the methods to be used to 

analyze the effects of standards on national employment 

Chapter 14 Utility Impact Analysis: discusses the methods to be used to study the 

effects of standards on electric utilities 

Chapter 15 Emissions Analysis: discusses the methods to be used to study the 

effects of standards on sulfur dioxide (SO2), nitrogen oxides (NOx), 

mercury (Hg), and carbon dioxide (CO2) emissions 

Chapter 16 Monetization of Emission Reductions Benefits: discusses the methods 

to be used to study the effects of standards on monetary benefits likely 

to result from the reduced emissions of CO2 and NOX 

Chapter 17 Regulatory Impact Analysis: discusses the methods to be used to 

determine the impact of non-regulatory alternatives to energy 

conservation standards 
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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 general service fluorescent and incandescent reflector 

lamps 

Appendix 5A Four-Foot T5 Miniature Bipin High Output Model Lamp: details the 

development of an improved full wattage 4-foot T5 miniature bipin 

high output model lamp 

Appendix 5B Modified Spectrum Incandescent Reflector Lamps: describes how 

DOE adopted the Energy Policy and Conservation Act definition of 

“modified spectrum” for IRLs and developed the factor used to set the 

efficacy requirements for the modified spectrum IRL product class 

Appendix 6A Lighting Controls: describes how DOE evaluated the effects of 

lighting controls 

Appendix 7A Additional End-User Price Results: provides end-user price results for 

additional products considered in the LCC and NIA 

Appendix 7B Rare Earth Phosphor Availability and Pricing: reflects findings of 

DOE’s analysis of the rare earth phosphor market 

Appendix 7C Xenon Availability and Pricing: evaluates how the supply, market, 

and price of xenon affect its usability as a high-efficiency inert fill gas 

Appendix 8A User Instructions for LCC and PBP Spreadsheet 

Appendix 8B Supplementary LCC and PBP Results: provides results for the Monte 

Carlo and sensitivity analyses 

Appendix 8C Residential Discount Rate Distributions: provides the probability 

distributions used with real interest rates to develop a residential 

discount rate 

Appendix 8D Hot Shock in Incandescent Reflector Lamps: describes the impact of 

hot shock on LCC savings for IRLs 

Appendix 9A Lighting Controls Market Penetration Projection: describes the 

assumptions and analysis DOE used to project changes in the 

penetration of lighting controls 

Appendix 9B Modeling of Rare Earth Price Impacts: describes the analysis DOE 

used to project the impact of rare earth oxide prices on GSFL prices 
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Appendix 10A User Instructions for the NIA Spreadsheet 

Appendix 10B Full-Fuel-Cycle: summarizes the methods used to calculate full-fuelcycle (FFC) energy savings expected to result from new standards 

Appendix 10C Lighting Rebound: describes direct rebound effect and the analysis 

DOE used to establish its baseline rebound rate 

Appendix 12A Preliminary Manufacturer Interview Guide