2 | Building Technologies Program eere.energy.gov

Combined Meeting on Energy 

Conservation Standards & Test 

Procedures for Fluorescent and 

Incandescent Lamps

Tina Kaarsberg, PhD

BUILDING TECHNOLOGIES PROGRAM

Department of Energy

Energy Efficiency & Renewable Energy

GSFL-IRL_2011-STD-0006@ee.doe.gov, 

Lamps-2011-TP-0012@ee.doe.gov

October 4, 2011
3 | Building Technologies Program eere.energy.gov

• Introductions (around the room)

• Role of the Facilitator

• Ground Rules (norms)

- Listen as an ally

- Use short, succinct statements/keep to the point

- Hold sidebar conversations outside the room

- One person speaks at a time (raise hand to be recognized; state 

your name for the record)

- Set cell phones to silent/vibrate

• Housekeeping Items

• Agenda Review

• Opening Remarks

Welcome
4 | Building Technologies Program eere.energy.gov

Agenda - Morning

Introduction

9:00 – 9:30 am Welcome, Introductions, Opening Statements

Test Procedure

9:30 – 9:40 am Overview

9:40 – 10:15 am Updates to Industry Standards: GSFL, GSIL, IRL

10:15 – 10:30 am Break

10:30 – 10:50 am New GSIL Lifetime Test Procedure

10:50 – 11:00 am Questions/Discussion
5 | Building Technologies Program eere.energy.gov

Agenda - Afternoon

Energy Conservation Standard

11:00 am–12:00 pm Overview; Scope of Coverage; Market & 

Technology; Screening Analyses

12:00 – 1:00 pm Lunch Break

1:00 – 1:45 pm Engineering Analysis

1:45 – 2:15 pm Product Price Determination; Energy Use

2:15 – 2:30 pm Break

2:30 – 3:30 pm Life-Cycle Cost and Payback Period Analysis

3:30 – 4:00 pm Shipment Analysis; National Impact Analysis

4:00 – 4:35 pm NOPR Analyses; Next Steps

4:35 – 5:00 pm Questions/Discussion

5:00 – 5:10 pm Closing Remarks
6 | Building Technologies Program eere.energy.gov

Purpose of the Public Meeting

• Present DOE’s proposed test procedures for general service 

fluorescent lamps (GSFLs), general service incandescent lamps 

(GSILs), and incandescent reflector lamps (IRLs) and DOE’s 

proposed framework for GSFL and IRL energy conservation 

standards.

• Invite comment on the test procedure notice of proposed rulemaking 

(NOPR) and energy conservation standards framework document. 

• Discuss next steps in the rulemakings.

• Invite participants to provide summary comments or statements and 

raise additional issues for discussion. 
7 | Building Technologies Program eere.energy.gov

Issues for Discussion

Issue Box: DOE welcomes comments, data, and information 

concerning its proposed test procedures for GSFLs, GSILs, 

and IRLs and framework for GSFLs and IRLs. Issues that 

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

numbered in accordance with that material. Whether invited by 

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

DOE’s analysis.

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

each document, available at: 

1. Test Procedure NOPR, published September 14, 2011: 

http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/gsfl_gsil_irl_nopr_tp.pdf

Comment Period Ends: November 28, 2011

2. Framework, published September 14, 2011: 

http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/gsfl_irl_ecs_framework.pdf

Comment Period Ends: October 31, 2011
8 | Building Technologies Program eere.energy.gov

Test Procedures for General Service 

Fluorescent, General Service Incandescent, 

and Incandescent Reflector Lamps Notice 

of Proposed Rulemaking

Tina Kaarsberg, PhD

BUILDING TECHNOLOGIES PROGRAM

Department of Energy

Energy Efficiency & Renewable Energy

Docket Number: EERE-2011-BT-TP-0012

Lamps-2011-TP-0012@ee.doe.gov

October 4, 2011
9 | Building Technologies Program eere.energy.gov

Test Procedure Agenda

2

4

Background and Legal Authority

2 Updates to Industry Standards: GSFL, GSIL, IRL

1 Overview

3 New GSIL Lifetime Test Procedure
10 | Building Technologies Program eere.energy.gov

Regulatory History – Test Procedure

Energy Policy and 

Conservation Act, 1975 

(EPCA)

Established energy conservation standards and methods of test 

procedure development for consumer products. 

1994 Interim Rule, 59 FR 

49468; 1997 Final Rule, 62 

FR 29221

1994 Interim Rule established test procedures for GSFLs, 

GSILs, and IRLs. 1997 Final Rule revised these test 

procedures. 

2009 Lamps Test 

Procedure, 74 FR 31829

2009 Lamps Standards,

74 FR 34080

Revised test procedures for GSFLs, IRLs, and GSILs. 

Adopted standards and test procedures for additional types 

of GSFLs. 

Revise existing test procedures for GSFLs, IRLs, and 

GSILs. Adopt test procedure for GSIL lamp lifetime.

Current Test Procedure 

Rulemaking

Energy Independence and 

Security Act (EISA 2007)

Required DOE to review test procedures for all covered 

products at least once every seven years. Established lamp 

lifetime requirement for GSILs. 
11 | Building Technologies Program eere.energy.gov

Test Procedure Rulemaking Process

Milestone Date

Notice of Proposed Rulemaking (NOPR) September 14, 2011

Final Rule (projected) January 2012

Compliance Date (projected) June 2012

NOPR Final

Rule

Today
12 | Building Technologies Program eere.energy.gov

• Statutory obligation to review test procedures at least once every 

seven years requires DOE to: 

(1) Amend the test procedure to improve measurement representativeness or 

accuracy or reduce burden; or 

(2) Determine that such amendments are unnecessary. (42 U.S.C. 6293(b)(1)(A))

• NOPR examines industry best practices and technical 

developments relevant to GSFL, GSIL, IRL test procedures.

• NOPR proposes to update references to industry standards in the 

existing DOE test procedures for GSFLs and GSILs.

• Proposes a new test procedure for measuring lamp lifetime of 

GSILs. 

Test Procedure Overview

Issue 1: DOE requests comments on all aspects of DOE’s test 

procedures for GSFLs, GSILs, and IRLs. 
13 | Building Technologies Program eere.energy.gov

Test Procedure Agenda

2

4

Background and Legal Authority

2 Updates to Industry Standards: GSFL, GSIL, IRL

1 Overview

3 New GSIL Lifetime Test Procedure
14 | Building Technologies Program eere.energy.gov

The following updates to industry standards for the GSFL and 

GSIL test procedures are proposed. 

Updates to Industry Standards 

Incorporated by Reference

Currently 

Referenced 

Standard

Updated Standard to 

be Referenced Title

ANSI C78.812005, ANSI 

C78.81-2003

ANSI C78.81-2010

American National Standard for Electric 

Lamps-Double-Capped Fluorescent LampsDimensional and Electrical Characteristics

IESNA LM-9-1999 IES LM-9-2009

IES Approved Method for the Electrical and 

Photometric Measurement of Fluorescent 

Lamps

IESNA LM-452000 IES LM-45-2009

IES Approved Method for the Electrical and 

Photometric Measurement of General Service 

Incandescent Filament Lamps
15 | Building Technologies Program eere.energy.gov

DOE proposes to update all references to ANSI C78.81 (both 2003 

and 2005) to ANSI C78.81-2010.

• ANSI C78.81 addresses dimensional and electrical characteristics 

for double-capped fluorescent lamps.

• ANSI C78.81-2010 adds high-frequency and low-frequency lamp 

specifications for 25-watt (W), 28W, and 30W, reduced-wattage 4foot T8 medium bipin (MBP) lamps.

• The low-frequency reference ballast specifications in ANSI C78.812010 for these lamps have no impact because they are identical to 

the specifications DOE currently directs manufacturers to use for 

those fluorescent lamps in section 4.1.2.1 of Appendix R.

ANSI C78.81-2010 for GSFLs
16 | Building Technologies Program eere.energy.gov

DOE proposes to update IESNA LM-9-1999 to the more recent 

version IES LM-9-2009 for fluorescent lamps.

1. Addition of guidance for high-frequency testing: root mean 

square (RMS) voltage regulation, instrument frequency 

response, reference ballast impedance, circuit setup. 

2. Modifies lamp stabilization method to require more consecutive 

measurements be taken until stabilization criterion is met. 

3. Addition of lamp stabilization guidance unique to T5 linear 

fluorescent lamps. 

4. Adds impedance thresholds for voltage and current inputs to 

multimeter and power sources.

IES LM-9-2009 for GSFLs
17 | Building Technologies Program eere.energy.gov

DOE proposes to update IESNA LM-45-2000 to the more recent version 

IES LM-45-2009 for incandescent lamps.

1. Modifies lamp stabilization method requiring measurements to 

continue until stability criteria is met. 

2. Modifies voltage and current regulation tolerances for AC power 

source.

3. Modifies instrument tolerances for AC voltage, current and wattage.

4. Adds impedance thresholds for voltage and current inputs to 

multimeter.

5. Adds a requirement for the degree of spectral match of the photodetector measurements to the V(λ) function. 

IES LM-45-2009 for GSILs
18 | Building Technologies Program eere.energy.gov

Issues for Discussion

Issue 3: DOE requests comments on its proposed incorporation of 

IES LM-45-2009, and its tentative conclusion that the update would 

neither significantly affect lamp efficacy values nor impose an undue 

testing burden.

Issue 2: DOE requests comments on its proposed incorporation of 

IES LM-9-2009, and its tentative conclusion that the update would 

neither significantly affect measured lamp efficacy nor increase the 

testing burden. In particular, DOE requests comments on the impact 

on lamp efficacy of high-frequency testing amendments and 

modifications to the lamp stabilization procedure in IES LM-9-2009.
19 | Building Technologies Program eere.energy.gov

Existing IRL test procedure incorporates IESNA LM-20-1994. 

10 CFR part 430, subpart B, Appendix R

• Revised edition of the standard has not been published.

• Not aware of any current best practices or technical 

developments that necessitate modifications to the IRL test 

procedure.

Test Procedures for IRLs

Issue 4: DOE requests comment on whether any amendments to 

the IRL test procedure are necessary and welcome any suggestions 

for amendments. 
20 | Building Technologies Program eere.energy.gov

Test Procedure Agenda

2

4

Background and Legal Authority

2 Updates to Industry Standards: GSFL, GSIL, IRL

1 Overview

3 New GSIL Lifetime Test Procedure
21 | Building Technologies Program eere.energy.gov

• EISA 2007 amended EPCA by prescribing GSIL minimum rated 

lifetime requirements to be phased in between January 2012 and 

January 2014.

• Proposed GSIL Lifetime Test Procedure 

− Industry standard: IESNA LM-49-2001, “IESNA Approved Method for Life 

Testing of Incandescent Filament Lamps.” 

o Coincides with rated voltage testing prescribed in the IESNA Lighting 

Handbook.

o Referenced by Federal Trade Commission in regulations for product 

labeling.

− Definition of “rated lifetime for general service incandescent lamps”: rated 

lifetime is the length of operating time between first use and failure of 50 

percent of the prescribed sample size.

− Sample size of 20 lamps.

GSIL Lifetime Test Procedure 

Overview
22 | Building Technologies Program eere.energy.gov

IESNA LM-49-2001: Summary

• Prescribes lifetime testing at a rated voltage.

• Requires lamp to be checked for failure at regular intervals and 

cooled on a daily basis.

• Provides instrument specifications for voltage, current and 

frequency.

• Specifies test conditions for vibration, temperature and airflow.

• Addresses lamp orientation, spacing, handling, marking of lamps, 

and lamp holder specifications. 
23 | Building Technologies Program eere.energy.gov

• DOE proposes to disallow use of accelerated lifetime testing

− LM-49 permits accelerated lifetime testing for non-halogen GSILS; few 

non-halogen GSILs will meet 2012 energy conservation standards.

− Difficult to conduct for halogen lamps due to the 

tungsten-halogen regenerative cycle which is 

designed around certain operating 

temperatures. 

− Accurate scaling factors will require numerous 

comparison tests and need to be developed 

for each lamp design.

IESNA LM-49-2001: Accelerated 

Lifetime Testing

Accelerated Lifetime 

Testing

• Operate lamps at 

overvoltage, increasing 

operating temperature and 

shortening lamp lifetime

• Use empirically derived 

scaling factors to 

determine full lifetime of 

lamp
24 | Building Technologies Program eere.energy.gov

DOE proposes a minimum sample size of 20 lamps.

• Minimum of two lamps per month for seven months of production 

out of a 12-month period

• Consistent with statutory definition of lifetime which requires 

“statistically large group of lamps.” (42 U.S.C. 6291(30)(P)) 

• Consistent with required sample size of 21 lamps for measuring 

lamp efficacy.

GSIL Lifetime Testing: Sample Size
25 | Building Technologies Program eere.energy.gov

Issues for Discussion

Issue 5: DOE requests comment on its proposal to adopt IESNA 

LM-49-2001 as the standard for GSIL lifetime testing.

Issue 6: DOE requests comments on its proposal to disallow 

accelerated lifetime testing as part of the GSIL test procedure.

Issue 7: DOE requests comments on its proposal to require a 

minimum sample size of 20 lamps for GSIL lifetime measurements. 
26 | Building Technologies Program eere.energy.gov

GSIL Certification Requirements

Issue 8: DOE requests comment on its proposal regarding GSIL 

certification filing requirements. 

GSIL new model filing requirements are similar to those for 

GSFLs and IRLs.

• Initial certification report describing the methodology by which it 

was determined the model meets or exceeds standards 

submitted prior to or concurrent with distribution of new model.

• Final certification report based on full sampling provisions to be 

submitted one year following the start of manufacturing of new 

model.
27 | Building Technologies Program eere.energy.gov

Issues for Discussion

Issue 9: DOE seeks comment regarding whether the proposed 

amendments in today’s NOPR would have a significant economic 

impact on any small entities. In particular, DOE requests comments 

on its preliminary analysis of initial setup and labor costs for 

conducting lifetime testing of GSILs. 
28 | Building Technologies Program eere.energy.gov

In all correspondence, include all of the following:

– Test Procedures for General Service Fluorescent Lamps, General Service 

Incandescent Lamps, and Incandescent Reflector Lamps

– Docket Number: EERE-2011-BT-TP-0012

– Regulatory Identification Number (RIN): 1904-AC45

Contact Information:

Email: Lamps-2011-TP-0012@ee.doe.gov

URL:http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/gsfl_gsil_irl

_nopr_tp.pdf

Comment period closes: November 28, 2011 midnight EDT

Postal Mail: 

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program

Mailstop EE-2J

1000 Independence Avenue, S.W.

Washington, DC 20585-0121

Courier: 

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program

950 L’Enfant Plaza, S.W., 6th Floor

Washington, DC 20024 

Telephone: (202) 586-2945

DOE Seeks Comments on its 

Proposed Test Procedure
29 | Building Technologies Program eere.energy.gov

Questions?
30 | Building Technologies Program eere.energy.gov

BUILDING TECHNOLOGIES PROGRAM

Energy Conservation Standards 

Framework for General Service 

Fluorescent Lamps and Incandescent 

Reflector Lamps

Tina Kaarsberg, PhD

Department of Energy

Energy Efficiency & Renewable Energy

Docket Number: EERE-2011-BT-STD-0006

GSFL-IRL_2011-STD-0006@ee.doe.gov 

October 4, 2011
31 | Building Technologies Program eere.energy.gov

Public Meeting Agenda

2

3

4

Background and Legal Authority

5

2 Market & Technology; Screening Analyses

4 Product Price Determination; Energy Use

5

1 Overview; Scope of Coverage

6

Life-Cycle Cost and Payback Period Analyses

Shipment Analysis; National Impact Analysis

7 NOPR Analyses

3 Engineering Analysis
32 | Building Technologies Program eere.energy.gov

Regulatory History - Standards

Energy Policy and 

Conservation Act, 1992

Established standards for certain classes of GSFLs 

and IRLs; authorized DOE to conduct two rulemaking 

cycles to revise and amend and adopt standards for 

additional GSFLs, if warranted.

First revision of standards for GSFLs and IRLs. 2009 Lamps Standards 

Rule,

74 FR 34080

Set standards for and expanded definition of IRLs to 

include lamps with a diameter between 2.25 and 2.75 

inches, as well as elliptical reflector (ER), bulged 

reflector (BR), parabolic aluminized reflector (PAR), 

bulged parabolic aluminized reflector (BPAR), or 

similar bulb shapes. Exempted certain IRLs. 

Energy Independence and

Security Act of 2007 

(EISA 2007)

Second review of GSFL and IRL standards. 

Determines if coverage should be expanded to other 

GSFL types.

Current Standards 

Rulemaking
33 | Building Technologies Program eere.energy.gov

Standards Rulemaking Process

Framework

Document NOPR

Final

Rule

Today

Preliminary 

Analysis

Milestone Date

Framework Document September 14, 2011

Notice of Public Meeting and Availability of the Preliminary 

Technical Support Document (projected) September 2012

Notice of Proposed Rulemaking (NOPR) (projected) August 2013

Final Rule (projected) April 2014

Compliance Date (projected) April 2017
34 | Building Technologies Program eere.energy.gov

The Energy Policy and 

Conservation Act (EPCA)

Factor Analysis

1. Economic impact on consumers 

and manufacturers

Life-cycle cost analysis;

Manufacturer impact analysis

2. Lifetime operating cost savings Life-cycle cost analysis

3. Total projected energy savings National impact analysis

4. Impact on utility and performance Screening analysis;

Engineering analysis

5. Impact of any lessening of 

competition Manufacturer impact analysis

6. Need for national energy 

conservation National impact analysis

7. Other factors the Secretary 

considers relevant

Environmental assessment;

Utility impact analysis;

Employment impact analysis

EPCA directs DOE to consider seven factors when setting energy 

conservation standards.
35 | Building Technologies Program eere.energy.gov

2012 GSFL Standards

Lamp Type CCT

Energy 

conservation 

standard (lm/W)

4-foot Medium Bipin (MBP) ≤4500 K 89

>4500 K and ≤7,000K 88

2-foot U-shaped ≤4500 K 84

>4500 K and ≤7,000K 81

8-foot Single Pin (SP) Slimline ≤4500 K 97

>4500 K and ≤7,000K 93

8-foot Recessed Double Contact 

(RDC) High Output (HO) 

≤4500 K 92

>4500 K and ≤7,000K 88

4-foot T5 Miniature BiPin (MiniBP) 

Standard Output (SO)

≤4500 K 86

>4500 K and ≤7,000K 81

4-foot T5 MiniBP HO ≤4500 K 76

>4500 K and ≤7,000K 72

Energy conservation standards set for GSFLs by the 2009 Lamps 

Rule will become effective July 14, 2012. 
36 | Building Technologies Program eere.energy.gov

2012 IRL Standards

Lamp Type Diameter

(inches)

Voltage Energy conservation 

standard (lm/W)

Standard 

Spectrum

> 2.5 ≥125 V 6.8*P0.27

<125 V 5.9*P0.27

≤ 2.5 ≥125 V 5.7*P0.27

<125 V 5.0*P0.27

Modified 

Spectrum

> 2.5 ≥125 V 5.8*P0.27

<125 V 5.0*P0.27

≤ 2.5 ≥125 V 4.9*P0.27

<125 V 4.2*P0.27

Energy conservation standards set for IRLs by the 2009 Lamps 

Rule will become effective July 14, 2012. 

Note: P is equal to the rated lamp wattage, in watts.
37 | Building Technologies Program eere.energy.gov

Scope of Coverage: GSFLs

• Covered GSFL Types

− 4-foot medium bipin (MBP) (≥ 25W);

− 2-foot U-shaped lamps, MBP (≥ 25W);

− 8-foot high output (HO) lamps, rapid start (RS) lamp, recessed double 

contact (RDC) bases;

− 8-foot slimline lamps, instant start (IS) lamp, single pin bases, ( ≥ 52W);

− 4-foot miniature bipin (MiniBP) standard output (SO), (≥ 26W); 

− 4-foot MiniBP high output (HO), (≥ 49W).

• Additional GSFL Types

− 2009 Lamps Rule expanded GSFL coverage to 4-foot MiniBP lamps.

− In this rulemaking DOE is considering the following additional GSFLs:

o Pin-based compact fluorescent lamps (CFLs)

o Non-linear fluorescent lamps (e.g., circline)

o Fluorescent lamps with non-standard lengths (e.g., 2-,3-,5-foot)
38 | Building Technologies Program eere.energy.gov

Scope of Coverage: IRLs

• Covered IRL Types

− Reflector type: reflector (R), ER, BR, PAR, BPAR, or similar bulb shapes 

with an E26 medium screw base; 

− Rated voltage between 115 and 130 volts; 

− Diameter that exceeds 2.25 inches; 

− Rated wattage that is 40 watts or higher;

− Not colored or designed for rough or vibration service applications that 

contains an inner reflective coating on the outer bulb to direct the light. 

• Lamps not subject to EPACT 1992 and July 2012 standards 

− Lamps rated at 50 watts or less that are ER30, BR30, BR40, or ER40; 

− Lamps rated at 65 watts that are BR30, BR40, or ER40 lamps; and 

− Lamps rated at 45 watts or less that are R20.

• Standards for these lamps are being set in a separate rulemaking. 
39 | Building Technologies Program eere.energy.gov

Issues for Discussion

Item 2: DOE welcomes comment on additional GSFLs and 

IRLs that should be included for this rulemaking. For 

suggested additional lamp types, DOE requests market and 

shipment information as well as potential for efficacy 

improvements and energy savings.
40 | Building Technologies Program eere.energy.gov

• In this rulemaking, DOE plans to reevaluate the lumens/watt 

(lm/w) metric for measuring IRL efficacy. 

• DOE is considering application efficacy (AE) as a metric. 

− AE is a type of directional lumens per watt. 

− Quantifies lamp effectiveness in terms of lamp delivering light to 

targeted locations.

− Average luminous flux within a desired solid angle per unit power.

Application Efficacy IRL Metric

Item 1: DOE welcomes comment on establishing a new directional 

metric for IRL efficacy standards. 

AE =

Luminous flux/power (lm/w)

Solid angle (steradians) = candelas/watt 
41 | Building Technologies Program eere.energy.gov

Public Meeting Agenda

2

3

4

Background and Legal Authority

5

2 Market & Technology; Screening Analyses

4 Product Price Determination; Energy Use

5

1 Overview; Scope of Coverage

6

Life-Cycle Cost and Payback Period Analysis

Shipment Analysis; National Impact Analysis

7 NOPR Analyses

3 Engineering Analysis
42 | Building Technologies Program eere.energy.gov

Purpose of Market and Technology;

Screening Analysis

• Market and Technology Assessment

– Determine product classes

– Identify the technology options to improve lamp efficacy

• Screening Analysis

– Screen out technology options that DOE will not consider in the 

engineering analysis based on (1) technological feasibility; (2) 

practicability to manufacture, install, and service; (3) adverse impacts on 

utility to consumers or availability; and (4) adverse impacts on health or 

safety. 
43 | Building Technologies Program eere.energy.gov

Issues for Discussion

Item 3: DOE welcomes information on shipments, productfeature and efficiency trends, distribution channels and 

estimates of market shares for the lamps considered in this 

rulemaking. For the data to be used to conduct energy savings 

calculations, please provide appropriate groupings (e.g., by 

product class and wattage). 
44 | Building Technologies Program eere.energy.gov

Product Classes

• DOE divides covered products into classes by:

– The type of energy used;

– Capacity of the product; or

– Any other performance-related features that require different 

standard levels, such as features affecting consumer utility. 

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

• DOE establishes separate energy conservation standards for 

each product class.
45 | Building Technologies Program eere.energy.gov

Product Classes: GSFLs

• GSFL product class factors under consideration

− physical constraints of lamps (i.e., lamp shape and length); 

− lumen package or quantity of light provided by lamp-ballast 

system (i.e., standard versus high output); and

− correlated color temperature (CCT). 

• GSFL product classes being considered:

Product Class #

Lamp Type CCT ≤4500 K CCT >4500 K 

4-foot Medium Bipin (MBP) #1 #2

2-foot U-shaped #3 #4

8-foot Single Pin (SP) Slimline #5 #6

8-foot Recessed Double Contract 

(RDC) High Output (HO) #7 #8

4-foot T5 Miniature BiPin (MiniBP) 

Standard Output (SO) #9 #10

4-foot T5 MiniBP HO #11 #12
46 | Building Technologies Program eere.energy.gov

Issues for Discussion

Item 4: DOE welcomes comment on the 12 product classes it 

is considering for general service fluorescent lamps. In 

particular, DOE welcomes comment on maintaining two 

separate product classes for T5 lamps. 
47 | Building Technologies Program eere.energy.gov

Product Classes: IRLs

• IRL product class factors under consideration

− lamp spectrum;

− lamp diameter; and 

− rated voltage. 

• IRL product classes under consideration

Product Class #

Diameter

(inches)

Voltage Standard 

Spectrum

Modified

Spectrum

> 2.5 ≥125 V #1 #2

<125 V #3 #4

≤ 2.5 ≥125 V #5 #6

<125 V #7 #8
48 | Building Technologies Program eere.energy.gov

Issues for Discussion

Item 5: DOE welcomes comment on the product classes it is 

considering for incandescent reflector lamps. 
49 | Building Technologies Program eere.energy.gov

Technology Options: GSFLs

GSFL Technology Options

Highly Emissive Electrode 

Coatings

Glass Coatings 

Higher Efficiency Lamp Fill 

Gas Composition 

Higher Efficiency Lamp Diameter 

Higher Efficiency Phosphors Multi-Photon Phosphors 
50 | Building Technologies Program eere.energy.gov

Rare-earth Phosphors Availability 

and Pricing

• Lamp efficacy can be improved by increasing phosphor UV 

absorption; increasing its emission of radiation in the visible 

spectrum; or increasing the thickness of the phosphor layer. 

• 2009 Lamps Rule analyzed the rare earth phosphor market in 

response to manufacturer concerns that GSFL standards would 

drive up prices of key rare earths phosphors/ cost of lamps; and 

whether there were sufficient recoverable phosphor sources. 

• DOE welcomes comments, new information relating to this issue. 

− Composition of rare-earth phosphors being used in lamps;

− Estimate of additional rare-earth phosphors necessary to go to higher 

standards;

− Current/historical prices and availability of rare-earth phosphors; 

− Assessment and future predictions on the relationship between lamp 

costs and prices of rare-earth phosphors. 
51 | Building Technologies Program eere.energy.gov

Technology Options: IRLs

IRL Technology Options

Higher-Temperature Operation Higher-Pressure Tungsten-Halogen 

Lamps 

Microcavity Filaments Non-Tungsten Regenerative Cycles 

Novel Filament Materials Infrared Glass Coatings 

Thinner Filaments Infrared Phosphor Glass Coating

Efficient Filament Coiling Integrally Ballasted Low-Voltage 

Lamps 

Crystallite Filament Coatings Higher-Efficiency Reflector Coatings 

Efficient Filament Orientation Trihedral Corner Reflectors 

Higher-Efficiency Inert Fill Gas Efficient Filament Placement 

Luminescent Gas 
52 | Building Technologies Program eere.energy.gov

Issues for Discussion

Item 7: DOE welcomes comments regarding the technologies 

that were screened out for the 2009 Lamps Rule, including 

whether it is still appropriate to screen out these technologies 

and whether any additional technology options should be 

screened out for this rule. 

Item 6: DOE welcomes comments on all of the technology 

options it is considering for this rule, including any omissions 

or revisions for the GSFLs and IRLs covered in this 

rulemaking. DOE also requests information on the feasibility, 

performance, impacts, and cost of the technology options—

especially those reflecting recent technological developments. 
53 | Building Technologies Program eere.energy.gov

Public Meeting Agenda

2

3

4

Background and Legal Authority

5

2 Market & Technology; Screening Analyses

4 Product Price Determination; Energy Use

5

1 Overview; Scope of Coverage

6

Life-Cycle Cost and Payback Period Analysis

Shipment Analysis; National Impact Analysis

7 NOPR Analyses

3 Engineering Analysis
54 | Building Technologies Program eere.energy.gov

Choose representative product classes and lamp 

types to be analyzed in the engineering and life-cycle 

cost analysis. 

Choose 

Representative 

Product Classes

Define Baseline 

Models

Engineering Analysis:

Methodology

Scale to Product 

Classes Not 

Analyzed

Develop Efficacy 

Levels 

Identify 

Replacements

Define characteristics of baseline models in each 

representative product class.

Select more efficacious lamps for each baseline lamp 

or lamp-and-ballast system based on design options.

Develop efficacy levels (ELs) that range from the 

baseline to the maximum technology feasible.

Scale results to product classes not analyzed.
55 | Building Technologies Program eere.energy.gov

Representative Product Classes and 

Baselines: GSFLs

DOE plans to consider the following lamp types with 

a correlated color temperature less than or equal to 

4,500 Kelvin (K) as representative.

Choose 

Representative 

Product Classes

Define Baseline 

Models

Scale to Product 

Classes Not 

Analyzed

Develop Efficacy 

Levels 

Identify 

Replacements

Baseline Lamp Lamp 

Diameter

Nominal 

Watts

Rated Efficacy Initial Light 

Output

W lm/W lm

4-Foot MBP T8 32 92.3 3,000 

8-Foot SP Slimline T8 59 98.2 5,900 

8-Foot RDC HO T8 86 91.9 7,900 

4-Foot T5 MiniBP SO T5 28 104.3 2,900 

4-Foot T5 MiniBP HO T5 54 92.9 5,000 

Rated efficacy is based on rated wattage and initial light output. See 10 CFR 430.2 for the definition of rated 

wattage. 

*Please note this table was revised 10/4/2011 to remove an extra row for the 8-foot RDC HO that was 

mistakenly included in the table in the previous version of the presentation and also a definition for rated 

efficacy was added. 
56 | Building Technologies Program eere.energy.gov

Issue for Discussion

Item 10: DOE welcomes comments on the baseline lamps it is 

considering for GSFLs in this rulemaking and whether they are 

representative of products sold on the market in 2012. In 

particular, DOE requests comment on whether the baseline 

lamps under consideration have lower efficacies than their 

catalog-rated efficacy values. Additionally, DOE requests 

comment on whether it is appropriate to analyze only a T8 

baseline for GSFL. 

Item 9: DOE welcomes comments on the product classes that 

it has selected to analyze as representative for this rulemaking. 
57 | Building Technologies Program eere.energy.gov

Representative Product Classes and 

Baselines: IRLs

DOE is considering IRLs with standard-spectrum, 

voltage ratings less than 125 volts (V) and diameters 

greater than 2.5 inches as representative. 

Choose 

Representative 

Product Classes

Define Baseline 

Models

Scale to Product 

Classes Not 

Analyzed

Develop Efficacy 

Levels 

Identify 

Replacements

Baseline Lamp Technology 

Option

Efficacy Initial Light 

Output 

Lamp 

Lifetime

lm/W lm hr

40W PAR30 Improved HIR 17.0 680 4,000

55W PAR38 Improved HIR 19.1 1,050 4,000

66W PAR38 Improved HIR 19.8 1,310 4,000

Item 11: DOE welcomes comments on the baseline 

lamps it is considering for IRLs in this rulemaking and 

whether they are representative of the products 

expected to be sold on the market in 2012. In particular, 

DOE requests comment on the expected lifetime and 

wattage of IRLs. 

Note: Halogen Infrared (HIR) 
58 | Building Technologies Program eere.energy.gov

• Select more efficacious lamps for each baseline lamp 

by considering technology options not eliminated in 

the screening analysis. 

• Consider lamps that (1) emit lumens greater than or 

equal to the lumen output of the baseline lamp, or 

below by less than 10 percent; and (2) result in energy 

savings. 

• Use database of commercially available GSFLs and 

IRLs to identify higher-efficacy replacements. 

Identify Higher-Efficacy 

Replacements

Choose 

Representative 

Product Classes

Define Baseline 

Models

Scale to Product 

Classes Not 

Analyzed

Develop Efficacy 

Levels 

Identify 

Replacements
59 | Building Technologies Program eere.energy.gov

• Develop efficacy levels (ELs) based on three factors: 

1) the design options associated with the specific lamps 

being studied; 

2) the ability of lamps across wattages to comply with the 

EL of a given product class; and 

3) the maximum technologically feasible (max tech) 

efficacy level. 

• DOE is not considering efficacy levels that would 

require the use of reduced-wattage GSFLs due to 

potentially limited utility of these lamps. 

• DOE is using certification reports to determine 

reported efficacies of the lamps to develop 

continuous equations. 

Develop Efficacy Levels

Choose 

Representative 

Product Classes

Define Baseline 

Models

Scale to Product 

Classes Not 

Analyzed

Develop Efficacy 

Levels 

Identify 

Replacements
60 | Building Technologies Program eere.energy.gov

Develop Efficacy Levels: GSFLs

• Based on review of commercially available 

lamps, considering EL1 as the max tech level 

set by the 2009 Lamps Rule. 

Choose 

Representative 

Product Classes

Define Baseline 

Models

Scale to Product 

Classes Not 

Analyzed

Develop Efficacy 

Levels 

Identify 

Replacements

Lamp Type CCT EL1

lm/W

4-Foot MBP ≤ 4,500K 93

8-Foot SP Slimline ≤ 4,500K 98

8-Foot RDC HO ≤ 4,500K 95

4-Foot T5 MiniBP SO ≤ 4,500K 90

• Exception: 4-foot T5 MiniBP HO for which only 

one standard proposed and reduced-wattage 

lamps not considered. 
61 | Building Technologies Program eere.energy.gov

Develop Efficacy Levels: IRLs

Choose 

Representative 

Product Classes

Scale to Product 

Classes Not 

Analyzed

Define Baseline 

Models

Develop Efficacy 

Levels 

Identify 

Replacements

Lamp Type

Efficacy Level 

Equation* Lamp Type EL1

lm/W lm/W

Standard

Spectrum, > 2.5 

inches, < 125V 6.4P0.27 

40W PAR30 19.1

51.7W PAR38 20.3

60W PAR38 21.0

Based on review of commercially available 

lamps, considering establishing EL1 as the max 

tech level set by the 2009 Lamps Rule. 

Note: P = wattage; Parabolic aluminized reflector (PAR); 30, 38 are diameters in 1/8th inches
62 | Building Technologies Program eere.energy.gov

Issues for Discussion

Item 13: DOE also welcomes comments on the potential 

efficacy levels identified and whether higher efficacy levels can 

be achieved through redesign of commercially available 

products. In addition, DOE requests comments on whether 

GSFL efficacy levels should be based on reduced-wattage 

lamps. 

Item 12: DOE welcomes comments on the methodology it is 

considering to select higher-efficacy lamp designs. 

Item 8: DOE welcomes comments on the overall methodology 

for the engineering analysis. 
63 | Building Technologies Program eere.energy.gov

• Develop scaling factors by comparing the efficacy 

level of the representative product class to 

compliance reports for the non-representative 

product class. 

• Considering using the scaling factors developed 

in the 2009 Lamps Rule

Scaling Products Not Analyzed

Choose 

Representative 

Product Classes

Scale to Product 

Classes Not 

Analyzed

Define Baseline 

Models

Develop Efficacy 

Levels 

Identify 

Replacements
64 | Building Technologies Program eere.energy.gov

• Proposed Scaling Factors for GSFLs

– Reduction factor of 6.5 percent for 2-foot U-Shaped 

lamps from 4-foot MBP. 

– Reduction factors within the range of 1.1 to 6.0 percent 

for lamps with CCTs above 4,500K from lamps with 

CCTs below or equal to 4,500K. 

• Proposed Scaling Factors for IRLs

– Reduction factor of 15 percent for modified-spectrum 

IRL lamps from standard spectrum. 

– Reduction factor of 15.5 percent for small-diameter 

lamps from large diameter. 

– Increase by 15 percent for lamps operating at greater 

than or equal to 120V from those operating at less than 

120V. 

Scaling Products Not Analyzed

Choose 

Representative 

Product Classes

Scale to Product 

Classes Not 

Analyzed

Define Baseline 

Models

Develop Efficacy 

Levels 

Identify 

Replacements
65 | Building Technologies Program eere.energy.gov

Issues for Discussion

Item 14: DOE welcomes comments on the methodology to 

scale to products not directly analyzed and the specific scaling 

factors it is considering. 
66 | Building Technologies Program eere.energy.gov

Issues for Discussion

Item 15: DOE welcomes comments on proprietary designs it 

should be aware of for the GSFLs and IRLs that are the 

subject of this rulemaking. 

Item 16: DOE welcomes comments on regulatory burdens or 

changes that should be considered in the engineering 

analysis.

Item 17: DOE welcomes comments on other engineering 

issues that could affect the engineering analysis. 
67 | Building Technologies Program eere.energy.gov

Public Meeting Agenda

2

3

4

Background and Legal Authority

5

2 Market & Technology; Screening Analyses

4 Product Price Determination; Energy Use

5

1 Overview; Scope of Coverage

6

Life-Cycle Cost and Payback Period Analysis

Shipment Analysis; National Impact Analysis

7 NOPR Analyses

3 Engineering Analysis
68 | Building Technologies Program eere.energy.gov

Product Price Determination

• Purpose

− To determine a relationship between efficacy levels and enduser prices. 

• Methodology

− Based on discounts applied to blue book prices (published end-user 

prices), from distributors, state contracts, and other public sources, 

calculate low, medium, high range of prices for each lamp.

− Use medium price ranges in the life-cycle cost (LCC) and national 

impact analysis (NIA); conduct low and high price analyses in LCC.

− For lamps where blue book prices are not available, extrapolate from 

available lamp prices. 

− Apply sales tax determined from State and local taxes from data 

provided by the Sales Tax Clearinghouse (data represented weighted 

averages that included county and city rates).

− Conduct a price trends analysis and investigate several methods for 

forecasting future prices per DOE guidance. 
69 | Building Technologies Program eere.energy.gov

Issues for Discussion

Item 19: DOE welcomes comments on the methodology it is 

considering for lamp prices and sales tax estimates for this 

rulemaking. DOE also welcomes comment on the price 

forecasting methodologies it is considering. 
70 | Building Technologies Program eere.energy.gov

• Purpose

− To identify how products are used by consumers, and thereby 

determine the energy savings potential of energy efficiency 

improvements. 

• Methodology

− Annual energy consumption (kWh) 

= system input power x annual operating hours

− Use various sources to determine annual operating hours for the 

commercial, residential, and industrial sectors including: 

o Lighting Market Characterization (LMC), 2011

o Energy Information Administration (EIA) Commercial Building 

Energy Consumption Survey (CBECS), 2003

o EIA Residential Energy Consumption Survey (RECS), 2009

o EIA Manufacturing Energy Consumption Survey (MECS), 2006

Energy Use Calculation 
71 | Building Technologies Program eere.energy.gov

Issues for Discussion

Item 18: DOE welcomes comments on the methodology it is 

considering to determine energy use. In particular, DOE 

requests comments on its approach to calculate operating 

hours for the covered lamps. 
72 | Building Technologies Program eere.energy.gov

Public Meeting Agenda

2

3

4

Background and Legal Authority

5

2 Market & Technology; Screening Analyses

4 Product Price Determination; Energy Use

5

1 Overview; Scope of Coverage

6

Life-Cycle Cost and Payback Period Analysis

Shipment Analysis; National Impact Analysis

7 NOPR Analyses

3 Engineering Analysis
73 | Building Technologies Program eere.energy.gov

Life-Cycle Cost and

Payback Period Analysis

• Purpose

− Assess the net LCC and PBP for a consumer due to energy conservation 

standards under several scenarios/events (e.g. new construction, 

replacement, renovation). 

• Methodology

− LCC equals consumer price plus the cumulative of annual operating costs 

over the analysis period (baseline lamp lifetime divided by average 

operating hours) discounted to a particular base year.

− Results expressed as LCC difference (baseline minus standard level).

− Simple payback (years) is also calculated and reported.

Consumer Life 

Cycle Cost

(Baseline and 

Standard)

LCC impacts

(difference between

baseline and standard)

First Cost

(Consumer Price & 

Installation)

Operating Cost

(Sum & discount to 

present value)
74 | Building Technologies Program eere.energy.gov

• Total Installed Price (First Cost)

− Purchase price: product price, sales tax.

− Installation cost: labor rate, time needed to install lamp (minutes).

o Derive average labor times, rates, and costs using the latest “RS Means 

Electrical Cost Data” and data from the U.S. Bureau of Labor Statistics.

• Total Operating Cost

− Electricity consumption: lamp wattage, operating hours.

− Electricity cost: electricity price, projected electricity price trend.

o Derive average regional prices for 13 geographic areas consisting of nine 

Census Divisions with four large States, treated separately. (EIA-861, 2009)

o Use the EIA’s Annual Energy Outlook (AEO) for projections of future average 

electricity prices (reference, high, and low scenarios).

Life-Cycle Cost and

Payback Period Analysis
75 | Building Technologies Program eere.energy.gov

Life-Cycle Cost and

Payback Period Analysis

• Use the discount rate to determine the present value operating 

expenses over the analysis period.

• Derive discount rates from estimates of the interest or “finance 

cost” to purchase products.

• Finance cost of raising funds to purchase products can be:

− Financial cost of any debt incurred to purchase products.

− Opportunity cost of any equity used to purchase products.
76 | Building Technologies Program eere.energy.gov

Issues for Discussion

Item 20: DOE welcomes comments on the approach it is 

considering to conduct the LCC and PBP analyses. 
77 | Building Technologies Program eere.energy.gov

Public Meeting Agenda

2

3

4

Background and Legal Authority

5

2 Market & Technology; Screening Analyses

4 Product Price Determination; Energy Use

5

1 Overview; Scope of Coverage

6

Life-Cycle Cost and Payback Period Analysis

Shipment Analysis; National Impact Analysis

7 NOPR Analyses

3 Engineering Analysis
78 | Building Technologies Program eere.energy.gov

• Shipments Analysis

− To estimate lamp shipments and the product mix of the stock over the 

analysis period in the base cases and standards cases.

• National Impact Analysis

− To estimate the National Energy Savings (NES) from energy conservation 

standards at different levels over the analysis period (30 years, 20172046)

− To estimate the national economic impact on the nation, or the Net 

Present Value (NPV), from energy conservation standards at different 

levels over the analysis period (30 years, 2017-2046).

Purpose: Shipments Analysis/National 

Impact Analysis (NIA)
79 | Building Technologies Program eere.energy.gov

• Historical Shipments

− Use shipments from NEMA and other publicly available sources to 

estimate historical shipments of each lamp. 

• Installed Stock

− Calculate installed stock lamps using historical shipments and average 

lamp lifetime. 

• Develop shipment forecasts (2017-2046)

− Apply growth, emerging technologies, and shipment assumptions. 

− Develop market-share matrices with the percentage market share of each 

lamp type taking into account efficacy, power rating, light output, and 

lifetime of the lamp and lamp-and-ballast designs.

Shipments Analysis Methodology
80 | Building Technologies Program eere.energy.gov

NES and NPV Inputs

• National Energy Savings (2017-2046) = Annual energy 

consumption (Base Case - Standards Case)

− Installed Stock

− Unit Annual Energy Consumption

− Electricity Site-to-Source Conversion Factors

o Conversion factors forecast using latest Annual Energy Outlook

− Rebound Rate

o Commercial and Industrial sectors: 1 percent, Residential sector: 

8.5 percent

• Net Present Value (2017-2046) = Operating cost savings -

Increased total installed costs (present value)

− Shipments

− Per Unit Installed Cost

− Electricity Prices

− Discount Rate – 7 percent and 3 percent real per OMB.
81 | Building Technologies Program eere.energy.gov

Issues for Discussion

Item 22: DOE requests input on the potential impact of new 

energy conservation standards on shipments of GSFLs and 

IRLs. DOE also requests input on any other federal, state, and 

local programs that currently exist to promote the adoption of 

more-efficient lamps. 

Item 21: DOE seeks information on historical shipments of 

GSFLs and IRLs for each product class covered under this 

rulemaking, as well as industry-trend data regarding relative 

growth in each product class. 
82 | Building Technologies Program eere.energy.gov

Issues for Discussion

Item 23: DOE welcomes comment on the data sources it 

anticipates using to develop inputs for the national impact 

analysis. 

Item 24: DOE welcomes comments on the quantitative and 

theoretical underpinnings of the rebound effect as well as 

results from newer studies of the size and sign of the rebound 

effect for residential, commercial, industrial, and municipal 

consumers. 
83 | Building Technologies Program eere.energy.gov

Issues for Discussion

Item 26: DOE welcomes comments on the inputs and 

methodology to calculate NES and NPV. 

Item 25: DOE welcomes comments on the NES spreadsheet 

models it plans to use for estimating national impacts of 

amended energy conservation standards for GSFLs and IRLs. 

DOE also welcomes comments on the inputs to the models 

and the sources used for determining the inputs. 
84 | Building Technologies Program eere.energy.gov

Public Meeting Agenda

2

3

4

Background and Legal Authority

5

2 Market & Technology; Screening Analyses

4 Product Price Determination; Energy Use

5

1 Overview; Scope of Coverage

6

Life-Cycle Cost and Payback Period Analysis

Shipment Analysis; National Impact Analysis

7 NOPR Analyses

3 Engineering Analysis
85 | Building Technologies Program eere.energy.gov

• Purpose

– To assess the economic impacts of standards on manufacturers;

– To identify and estimate impacts on manufacturer sub-groups that may 

be more severely affected than the industry as a whole; and

– To examine the direct employment impacts, manufacturing capacity, 

and the cumulative regulatory impact on the manufacturing industry.

• Methodology

– Analyze industry cash flow and industry net present value (INPV) 

through use of the Government Regulatory Impact Model (GRIM); and

– Interview manufacturers to refine inputs to the GRIM, develop subgroup analyses, and address qualitative issues.

Manufacturer Impact Analysis (MIA)
86 | Building Technologies Program eere.energy.gov

Industry 

profile

Develop 

strawman 

GRIM*

Develop 

interview 

guide

Interviews 

& industrywide/ 

subgroup 

analyses

Assess direct 

employment, 

manufacturing 

capacity, and 

cumulative 

burden

Finalize

MIA 

results 

for 

NOPR

Phase 2

* Government Regulatory Impact Model (GRIM)

Phase 1 Phase 3

Manufacturer Impact Analysis:

Overview
87 | Building Technologies Program eere.energy.gov

Issues for Discussion

Item 28: DOE welcomes comments on its methodology for 

assessing the impacts on product manufacturers covered 

under this rulemaking. DOE also requests information on 

manufacturing costs. 
88 | Building Technologies Program eere.energy.gov

• Life-Cycle Cost Subgroup Analysis

− Effects on various national consumer subgroups

• Utility Impact Analysis 

− Impacts on the generation capacity of utilities

• Employment Impact Analysis

− Indirect impacts on overall national employment

• Environmental Assessment

− Effects of airborne pollutant emission reductions

• Regulatory Impact Analysis

− Impacts of non-regulatory alternatives

Other NOPR Analyses
89 | Building Technologies Program eere.energy.gov

Issues for Discussion

Item 27: DOE plans to assess the impacts on low-income 

households, institutions of religious worship, and institutions 

serving low-income consumers, and seeks input regarding 

which other consumer subgroups it should consider in this 

rulemaking. 

Item 29: DOE welcomes comments on the approach it is 

considering to assess the impacts of potential standards under 

this rulemaking on electric utilities. 

Item 30: DOE welcomes comments on the approach it is 

considering to assess national indirect employment impacts as 

a result of energy conservation standards. 
90 | Building Technologies Program eere.energy.gov

Issues for Discussion

Item 31: DOE seeks input on its plans to use latest version of 

EIA’s National Energy Modeling System (NEMS-BT) to 

conduct the environmental assessment for the products 

covered by this rulemaking. 

Item 32: DOE welcomes comments on the methodology it is 

considering for the regulatory impact analysis. 
91 | Building Technologies Program eere.energy.gov

In all correspondence, include all of the following:

– Energy Conservation Standards for General Service Fluorescent Lamps and 

Incandescent Reflector Lamps

– Docket Number: EERE-2011-BT-STD-0006

– Regulatory Identification Number (RIN):1904-AC43

Contact Information:

Email: GSFL-IRL_2011-STD-0006@ee.doe.gov

URL:http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/gsf

l_irl_ecs_framework.pdf

Comment period closes: October 31, 2011, midnight EDT

Postal Mail: 

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program

Mailstop EE-2J

1000 Independence Avenue, S.W.

Washington, DC 20585-0121

Courier: 

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program

950 L’Enfant Plaza, S.W., 6th Floor

Washington, DC 20024 

Telephone: (202) 586-2945

DOE Seeks Comments on its 

Framework Proposal
92 | Building Technologies Program eere.energy.gov

• In all correspondence, include all of the following:

– Test Procedures for General Service Fluorescent Lamps, General Service 

Incandescent Lamps, and Incandescent Reflector Lamps

– Docket Number: EERE-2011-BT-TP-0012

– Regulatory Identification Number (RIN):1904-AC45

• Contact Information

Email: Lamps-2011-TP-0012@ee.doe.gov

URL:http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/gsfl

_gsil_irl_nopr_tp.pdf

Comment period closes: November 28, 2011 midnight EDT

Postal Mail: 

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program

Mailstop EE-2J

1000 Independence Avenue, S.W.

Washington, DC 20585-0121

Courier: 

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program

950 L’Enfant Plaza, S.W., 6th Floor

Washington, DC 20024 

Telephone: (202) 586-2945

DOE Seeks Comments on its Test 

Procedure Proposal
93 | Building Technologies Program eere.energy.gov

Questions?
94 | Building Technologies Program eere.energy.gov

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