Energy Conservation Standards 

General Service Fluorescent Lamps and Incand

Lamps 

Notice of Proposed Rulemaking 

Public Meeting 

Building Technologies Program

Office of Energy Efficiency and Renewable E

U.S. Department of Energy

February 3, 2009

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

EE-2006-STD-0131 COMMENT 38.3
 Purposes

• To invite comment on the proposed energy conservation 

three (TSL 3) for general service fluorescent lamps (GSFincandescent reflector lamps (IRL), and to receive recomalternatives;

• To present methodologies and characterize results of the • To discuss specific issues related to each analysis;• To seek input from interested parties on methodologies, 

sources, and results from the analyses; and

• To describe the next steps.

 Comments from Participants

• Participants are invited to provide summary comments o• Participants are invited to raise additional issues for disc• NOPR comment period closes 60 days after publication 

Purpose of the Public Meeting 

Comments From Participants

EE-2006-STD-0131 COMMENT 38.3
Statutory Authority – the Energy Po

Conservation Act (EPCA) as ame

 This rulemaking addresses requirements of 42 USC 6

(3) To review and possibly amend standards fofluorescent lamps and incandescent reflector la(5) To determine whether standards should appgeneral service fluorescent lamps

 The Energy Independence and Security Act of 2007 (

EPCA (42 U.S.C. 6295(g)(10),(cc)) to prescribe standaservice incandescent lamps, so DOE is not proposinthese products.

EE-2006-STD-0131 COMMENT 38.3
DOE Actions on GSFL and 

 Test Procedures

• Notice of Proposed Rulemaking (NOPR), proposing tes

IRL, published in the Federal Register on March 13, 200

• Final Rule for GSFL and IRL to be published by June 30

 Energy Conservation Standards

• Notice of availability of the Framework Document publis

FR 30834.

• Advance Notice of Public Rulemaking (ANOPR) publish

FR 13620.

• Technical Support Document (TSD) posted on DOE we• Notice of Proposed Rulemaking (NOPR) issued by DOE • Publication of NOPR in the Federal Register [pending]• Final Rule scheduled for June 2009.

EE-2006-STD-0131 COMMENT 38.3
EPCA directs DOE to consider seven facto

energy conservation standard

Factor Ana

1. Economic impact on consumers 

and manufacturers

Life-cycle cost analyManufacturer impact 

2. Lifetime operating cost savings Life-cycle cost analy3. Total projected energy savings National impact analy4. Impact on utility or performance Screening analysis

Engineering analysis

5. Impact of any lessening of 

competition

Manufacturer impact 

6. Need for national energy 

conservation

National impact analy

7. Other factors the Secretary 

conside

rs relevant

Environmental assesUtility impact analysi

Employment impact 

EE-2006-STD-0131 COMMENT 38.3
Proposed Amended Energy Conservation St

(TSL 3) (Issues #16, #17)

Lamp Type Correlated 

Color 

Temperature

Propos

(

≤ 4,500K 

> 4,500K 

≤ 4,500K 

> 4,500K 

≤ 4,500K 

> 4,500K 

≤ 4,500K 

> 4,500K 

≤ 4,500K 

> 4,500K 

≤ 4,500K 

> 4,500K 

4-foot miniature bipin high 

output

4-foot miniature bipin 

standard output

8-foot high output

8-foot slimline

2-foot U-shaped

4-foot medium bipin

EE-2006-STD-0131 COMMENT 38.3
Proposed Amended Energy Conservation St

(TSL 3) (Issues #16, #17)

DOE seeks comment on the proposed standard levDOE seeks comment on potential approaches to masavings while mitigating impacts to certain GSFL cosubgroups (e.g. maintaining T12 lamps in the reside

EE-2006-STD-0131 COMMENT 38.3
Proposed Amended Energy Conservation Stand

(Issues #16, #18)

Lamp Type Lamp Diameter Rated Voltag

≥ 125 

< 125 

≥ 125 

Standard Spectrum, 

40 Watts - 205 Watts

Modified Spectrum, 

40 Watts - 205 Watts

< 125 

≥ 125 

< 125 

≥ 125 

< 125 

≤ 2.5 inches

> 2.5 inches

≤ 2.5 inches

> 2.5 inches

P is the rated wattage of the lamp.

EE-2006-STD-0131 COMMENT 38.3
Proposed Amended Energy Conservation Stand

(Issues #16, #18)

DOE seeks comment on the proposed standard leveDOE seeks comment on other technology pathways utilized to meet IRL TSL 5, whether these pathways madverse effects on consumer utility or the ability for mass-produced, manufacturer costs associated with and resulting consumer product prices for lamps thastandard level.

EE-2006-STD-0131 COMMENT 38.3
 Opening Remarks

• At this time, DOE welcomes opening remarks from inter

NOPR for GSFL and IRL

Opening Remarks and Comments from 

Parties on the Proposed Energy Conserva

Openin

EE-2006-STD-0131 COMMENT 38.3
1. The scope of covered products DOE considered in this rulemaking 

decision to cover 4-foot T5 miniature bipin SO and 4-foot T5 minia

2. DOE’s decision to amend the definition of “colored fluorescent lam

CCT greater than 7,000K

3. The appropriateness of establishing separate product classes for 

rated lamp voltage

4. The appropriateness of establishing separate product classes for 4

and 4-foot T5 miniature bipin HO lamps

5. The added 4-foot MBP residential sector engineering analysis, par

baseline system (lamp and ballast)

6. The performance characteristics (e.g., lumen output, lifetime, watt

GSFL and IRL model lamps DOE used in the engineering analysis properties of the T5 halophosphor GSFL baseline lamps and the imuses xenon as a fill gas (the lamp established for TSL1)

7. The efficacy levels DOE considered for IRL, in particular the adde

Summary of Issues on which DOE seek

NOPR issues #1-7

EE-2006-STD-0131 COMMENT 38.3
8. The efficacy levels DOE used for each GSFL product class-- partic

use compliance report data to establish GSFL efficacy levels

9. The methodology DOE used to scale efficacy levels from represen

product classes DOE did not analyze (i.e., 2-foot U-shaped lamps GSFL; modified spectrum lamps, lamps with diameters less than owith rated voltage greater than 125V)

10. The choice of ballast lifetimes DOE used in the commercial, reside

and operating hours for GSFL in the residential sector

11. The growth rates DOE used in the residential sector IRL and GSF

market penetration of emerging technologies in the IRL and GSFL T5 lamp shipment forecasts

12. Base-case market-share matrices and standards-case market-sha

GSFL -- particularly the percentage of GSFL consumers with sufficthose consumers who will choose a lower-BF ballast or reduced-wlumen output under standards) by market segment

Summary of Issues on which DOE seek

NOPR issues #8-12

EE-2006-STD-0131 COMMENT 38.3
13. The methodology and inputs DOE used for the manufacturer impa

DOE’s assumptions regarding markups, capital costs, conversion 

14. The determination of the environmental impacts of the proposed ru

for valuing the CO2, NOx, SOx, and Hg emissions savings due to 

15. The appropriateness of trial standard levels DOE considered for G

the combinations of efficacy levels of each GSFL product class

16. The proposed standard levels for GSFL and IRL

17. Potential approaches to maximize energy savings while mitigating 

consumer subgroups, for instance the maintaining of T12 lamps in 

18. Other technology pathways that may be utilized to meet IRL TSL5

may have any adverse effects on consumer utility or the ability for produced, manufacturer costs associated with these pathways, anproduct prices for lamps that meet this standard level

Summary of Issues on which DOE seek

NOPR issues #13-18

EE-2006-STD-0131 COMMENT 38.3
 DOE conducted a determination to expand covera

GSFL

 The NOPR proposes to extend coverage to the fo

(1) 2-foot U-shaped lamps with a rated wattage ≥ 25 and 

(2) 4-foot medium bipin (MBP) lamps with a rated wattag

(3) 4-foot miniature bipin (MiniBP), straight-shaped, stan

with rated wattage ≥ 26;

(4) 4-foot MiniBP, straight-shaped, high output (HO) lam

51;

(5) 8-foot recessed double contact (RDC), rapid start, HO 

defined in ANSI Standard C78.1–1991;

(6) 8-foot RDC, rapid start, HO lamps (other than 0.800 

defined in ANSI Standard C78.1–1991; and

(7) 8-foot single pin (SP) instant start slimline lamps, with 

not defined in ANSI Standard C78.3–1991.

DOE seeks comment on the scope of covered produthis rulemaking – specifically, DOE’s decision to cominiature bipin SO and 4-foot T5 miniature bipin HO 

GSFL Determination

(Issue #1)

EE-2006-STD-0131 COMMENT 38.3
 To amend the scope of EPCA’s coverage of GSF

to revise its existing definition of “colored fluore

 “Colored fluorescent lamp” means either:

• a fluorescent lamp designated and marketed as a c

CRI less than 40, as determined according to the mPublication 13.2 (10 CFR 430.22)

• a fluorescent lamp designed and marketed as a co

correlated color temperature (CCT) less than 2,500

• a fluorescent lamp with a CCT greater than 7,000K

DOE seeks comment on the decision to amend the d“colored fluorescent lamp” to include lamps with a 7,000K

Definition of Colored Fluorescent 

(Issue #2)

EE-2006-STD-0131 COMMENT 38.3
DOE invites comments on the appropriateness of estaproduct classes for 4-foot T5 miniature bipin SO and 4bipin HO lamps.

GSFL Product Classes (Issue #

 DOE established product classes by:

• the type of energy used• capacity, or other performance-related 

features that affect efficiency

• factors such as the utility of the product 

to users

 T8 and T12 lamps are grouped into 

the same product classes

 DOE established separate product 

classes for T5 lamps because their physical constraints and lumen package prevent them from being used as direct replacements for T8 and T12 lamps in many applications

Lamp T

4-foot mediu

2-foot U-s

8-foot single p

8-foot RD

4-foot miniatur

4-foot miniatur

Yellow indicates repr

EE-2006-STD-0131 COMMENT 38.3
IRL Product Classes

(Issue #3)

 Established product classes based on 

lamp diameter, voltage, and spectrum.

 Diameter provides a distinct utility to 

the consumer (such as the ability of reduced diameter lamps to be installed in smaller fixtures). Smaller diameter lamps generally have lower efficacies.

 Setting separate product classes for 

130V lamps preserves the energy savings intended by the standards.

• Current test procedures allow for 130V lamps to have low

efficacies (at 120V) than 120V lamps, possibly resulting i130V lamps.

DOE invites comments on the appropriateness of estaproduct classes for IRL by lamp diameter and rated la

Lamp Typ

Standard 

Spectrum, 

40W-205W 

Modified 

Spectrum, 

40W to 205W

Yellow indicates 

EE-2006-STD-0131 COMMENT 38.3
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employ

Impac

Analysis

EE-2006-STD-0131 COMMENT 38.3
Engineering Analysis

 Purpose

• The engineering analysis identifies baseline lamps or la

systems and their higher-efficacy alternatives.

 Methodology

• Choose representative product classes• Select baseline lamps• Develop efficacy levels• Scale to product classes not analyzed

EE-2006-STD-0131 COMMENT 38.3
DOE invites comments on the properties of the T5 halbaseline lamps

T5 Baseline and Higher Efficacy L

(Issue #6)

Nominal 

Wattage

EL 

W 

Baseline/0 54 1 54 

1 51 

1 28 104.3 2,9002 28 109.7 3,0502 26 111.5 2,900Baseline/0 28 86.0 2,391

W lm/W lm

Initial Light 

Output

Rated 

Efficacy

Nominal 

EL Wattage

4-Foot T5 MiniBP Standard Output 4-Foot T5 Min

 Based on comments received, DOE developed mo

halophosphor lamps as baselines for the 4-foot Mproduct classes.

 Higher-efficacy lamps were based on commercial

product.

EE-2006-STD-0131 COMMENT 38.3
4-foot MBP Baseline Lamps in the Resid

(Issue #5)

 DOE analyzed 4-foot MBP lamps in the residentia DOE chose a 40W T12 lamp as the baseline in the 

This residential baseline lamp has a lower efficacshorter lifetime (15,000 hours) than the typical 40W in the commercial sector.

 DOE paired the baseline lamp with a low power fa

magnetic T12 ballast with a ballast factor of 0.68 apower of 70W.

 Higher-efficacy lamps are the same in both the co

residential sectors.

 Residential lamps are subject to the same efficacy 

commercial lamps.

DOE invites comments on the added 4-foot medium bsector engineering analysis, particularly the choice of system (lamp and ballast).

EE-2006-STD-0131 COMMENT 38.3
GSFL Efficacy Levels 

 Higher lamp efficacy is achieved by:

• Phosphor manipulation – move from halophosphor (60

(700 and 800 series)

• Shifting from T12 to T8 diameter – EL 4 and EL 5 elim

lamps become the only standards-compliant lamp opti

Efficacy Design Option for Each Baseli

Level 40W T12 34W T12 

EL0 700 series 600 series EL1 Improved 700 series 

or 800 series

700 series 

EL2 800 series 800 series EL3 Improved 800 series 

EL4 Impro

lam

EL5 Impro

Eliminates All T12s

Example: 4-Foot MBP Product Class 

EE-2006-STD-0131 COMMENT 38.3
GSFL Efficacy Levels

(Issue #8)

 For the NOPR, DOE modified its EL values 

for all product classes to accurately characterize how GSFL would comply under standards.

 Rated lamp efficacy is not appropriate to 

establish minimum efficacy requirements because:

• ANSI designated rated wattages can differ from 

measured wattage

• Using rated lamp efficacy does not account for 

lot-to lot production variability

Effica

Leve

EL1 EL2 EL3 EL4 EL5 

 DOE used compliance report data to determine minim

requirements for each EL

DOE invites comments on the ELs for each GSFL proparticularly, DOE’s decision to use compliance reporGSFL efficacy levels. 

8-Fo

W

EE-2006-STD-0131 COMMENT 38.3
Baseline

EPCA

EL 1EL 2

EL 3

EL 4EL 5

9.0

11.013.015.017.019.021.023.0

20 30 40 50 60 

Lamp P

Lamp Efficacy (lm/W)

IRL Efficacy Levels

 Higher lamp efficacy can 

be achieved by using:

• Higher efficiency fill gas• Higher pressure halogen 

capsule

• More efficient reflector• Higher temperature 

operation

• IR coatings

Baseline/EPCA: Halogen (3,000 hr)EL1: Improved Halogen (Xenon) (3,000 hr)EL2: Long-Life HIR (6,000 hr) 

Improved Halogen (Silver) (3,000 hr)

EL3: HIR (3,000 hr)EL4: Improved HIR (4,000 hr)EL5: Improved HIR Plus (4,200 hr)

EE-2006-STD-0131 COMMENT 38.3
 EL1 can be achieved by an improved halogen lam

xenon, a higher efficiency inert fill gas.

• Incorporating xenon results in ~4% improvement in effic

 EL2 can be met with both an improved halogen la

silverized reflector and a long-life (6,000 hour) HIR 

 EL5 is based on an HIR lamp with a lifetime of 4,2

only commercially available product that meets thproprietary silverized reflector. However, DOE bebe achieved by using advanced IR coatings.

DOE invites comments on the efficacy levels considerparticular EL1 and EL5. DOE also invites comments on the performance charalumen output, lifetime, wattage) established for IRL mthe engineering analysis – specifically, the properties halogen IRL that uses xenon as a fill gas (the lamp es

IRL Efficacy Levels

(Issues #6, #7)

EE-2006-STD-0131 COMMENT 38.3
Scaling to Other Fluorescent Lamp Prod

Product Classes with CCT > 45

(Issue #9)

 DOE needed to scale from a representative produ

corresponding fluorescent product class with CC

 DOE decided to establish a separate scaling facto

product class

 After analyzing catalog data for the lumen output 

greater than 4,500K and less than 4,500K, DOE forecommendation to be consistent with commerciaproduct and adopted these efficacy reductions.

 Reductions range from 2.6% to 7.2%

DOE invites comments on the methodology used to from representative product classes to high CCT lam

EE-2006-STD-0131 COMMENT 38.3
Scaling to Other Fluorescent Lamp Prod

2-Foot U-shaped with CCT 

≤ 45

(Issue #9)

 DOE used manufacturer catalog data to develop e

shaped lamps with similar technology impact as 4levels

 DOE then used compliance reports to determine t

commercially-available lamps would comply.

 Due to limited compliance report data, where data 

DOE used the same percentage efficacy reductionlamps as it did for 4-foot MBP lamps.

 Reductions from 4-foot MBP efficacy levels range 

DOE invites comments on the methodology used to sfrom representative product classes to 2-foot U-shape

EE-2006-STD-0131 COMMENT 38.3
Scaling to Other IRL Product Cla

Modified Spectrum Lamps

(Issue #9)

 DOE identified several IRL with modified-spectrum

their performance with standard (i.e., non modifiedlamps.

 DOE assessed the efficacy differences between st

modified spectrum IRL by measuring the efficacies available IRL. 

 By analyzing this test data, DOE established that a 

19% from the standard-spectrum efficacy levels wappropriate for modified spectrum IRL.

DOE invites comments on the methodology used to sfrom representative product classes to modified spec

EE-2006-STD-0131 COMMENT 38.3
Scaling to Other IRL Product Cla

Lamps with Smaller Diameter

(Issue #9)

 A smaller diameter IRL has an inherently lower op

a larger diameter lamp given a similar filament size

 To determine an appropriate scaling factor for IRL 

less than or equal to 2.5 inches, DOE examined the efficacy differences between the PAR20 lamp and PAR38 counterpart by comparing catalog efficacy lamp type from several lamp manufacturers. 

 In its analysis, DOE found that the reduction in eff

the reduction in lamp diameter was approximately 

DOE invites comments on the methodology used to sfrom representative product classes to smaller diame

EE-2006-STD-0131 COMMENT 38.3
Scaling to Other IRL Product Cla

Higher Voltage Lamps

(Issue #9)

 Lamps rated at 130V use different test procedures 

at 120V

 DOE derived an efficacy scaling factor which woul

equivalent performance of both classes of IRL wheunder the same voltage conditions

 DOE determined that a lamp operating at 130V wo

efficacious than a lamp of a similar wattage operat

DOE invites comments on the methodology used to sfrom representative product classes to higher voltage 

EE-2006-STD-0131 COMMENT 38.3
Request for Additional Comm

DOE invites comments on any other issues pertaininEngineering Analysis.

EE-2006-STD-0131 COMMENT 38.3
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employ

Impac

Analysis

EE-2006-STD-0131 COMMENT 38.3
Life-Cycle Cost and Payback Period 

 Purpose

• To analyze the economic impacts of possible standards 

consumers

 Approach

• Life-Cycle Cost (LCC) calculated for all baseline lamps a

efficiency alternatives in each product class in order to checonomic impacts on each type of consumer

• Various events that trigger the purchasing of a lamp are c• Each product class analyzed in relevant sectors: comme

residential

• At some standard levels, there are multiple pathways to s

reduced-wattage lamps or lamp and ballast combinations power). For these levels, a range of LCC results are pres

EE-2006-STD-0131 COMMENT 38.3
Why Do Consumers Buy Lamp

 Various events that trigger the purchasing of a lamp 

economics. DOE analyzes five such events:

Lamp Failure - a lamp fails and must be replaced.

Standards-Induced Retrofit - an increase in the effi

prompts end-users to retrofit lamps and ballasts whthey would otherwise only replace the lamp; only foBallast Failure - an existing ballast fails and the con

new lamp and ballast.Ballast Retrofit – consumers who were going to vo

existing lamp and ballasts do so, and at certain ELbeing forced to a higher standard.New Construction and Renovation - all the new fixtthe lighting design will be new or can be completel

;;

;

;

Presented in 

the NOPR

EE-2006-STD-0131 COMMENT 38.3
Key Inputs to LCC

Input Description

Consumer Product Price Applied discounts to manufacturer catalog 

Sales Tax Derived from the Sales Tax Clearinghouse

Installation Cost Labor rates from RS Means and U.S Burea

Labor times from 2000 Ballast Rule and RS installation times from 2000 Ballast Rule adinstallation of luminaire disconnect.

Disposal Cost Included a recycling cost for GSFL in the c

sectors.

Annual Operating Hours Determined operating hours by associating 

operating hours data (U.S. Lighting Market regional distributions of various building typ

Discount Rate Based on the finance cost of raising funds 

Residential: 5.6%, Commercial: 7.0%, Indu

Product Energy Consumption Rate

GSFL system power and IRL lamp power bmanufacturer literature. GSFL system powand lamp wattage.

Electricity Prices 2006 EIA Form 861 data

Electricity Price Trends EIA’s AEO2008

EE-2006-STD-0131 COMMENT 38.3
Fluorescent Ballast Lifetim

(Issue #10)

 DOE evaluated several different data sources to d

lifetime of a ballast: manufacturer literature on bahistorical sales data of ballasts; and “measure life

 DOE used “measure life” reports because these r

represented the true service life of a ballast in the 

• Commercial sector: Ballast “measure life” varied betwee

Therefore, DOE used the ballast lifetime of 14.2 years (the 2000 Ballast Rule.

• Residential sector: DOE used ballast “measure life” of 1

EE-2006-STD-0131 COMMENT 38.3
Residential Fluorescent Lamp L

 In the residential sector GSFL analysis, DOE analy

and high operating hours

 Under average operating hours (789 hours/year), la

limited to 15 years due to ballast or fixture replacesituation there is no lamp failure event.

 To model lamp replacements, DOE used high oper

hours/year) resulting in a lamp lifetime of 12.5 yealamp has on average 2.5 years of useful life before fixture is replaced.

DOE invites comments on the choice of ballast lifetimcommercial, residential, and industrial sectors and tfor GSFL in the residential sector.

EE-2006-STD-0131 COMMENT 38.3
GSFL LCC and Installed Cost Re

(4-foot MBP operating in the Commerc

Consumers can 

often achieve 

greater savings 

by voluntarily 

purchasing at 

higher efficiency 

levels.

Requiring the 

retrofit of a ballast 

at EL4 and EL5 

results in large 

increased 

installation costs.

EE-2006-STD-0131 COMMENT 38.3
GSFL LCC and Installed Cost Re

(4-foot MBP residential)

EE-2006-STD-0131 COMMENT 38.3
IRL LCC and Installed Cost Res

EE-2006-STD-0131 COMMENT 38.3
Request for Additional Comm

DOE invites comments on any other issues pertaininand Payback Period Analyses.

EE-2006-STD-0131 COMMENT 38.3
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employ

Impac

Analysis

EE-2006-STD-0131 COMMENT 38.3
Purpose

 Shipments Analysis

• To estimate lamp shipments and the product mix of the 

2042) in the base case and standards case.

 National Impact Analysis

• To estimate the National Energy Savings (NES) from G

standards at different levels.

• To estimate the national economic impact on the nation 

Value (NPV)) from GSFL and IRL efficacy standards at 

EE-2006-STD-0131 COMMENT 38.3
 Estimate base-case shipment forecasts (2012-2042)

• Develop shipment models that account for shipments due 

– Lamp Replacements– Ballast Replacements (only GSFL)– Fixture Replacement (only GSFL)– Renovation– New Construction

• Historical shipments used to generate initial lamp stocks a

shipments model.

• Included base-case shipment scenarios to account for the 

lighting technologies (e.g., LED, R-CFL, CMH) into the GS

• Established market-share matrices to characterize the pro

shipments and stock.

 Estimate standards-case shipments forecasts (2012

• Developed with same data as used to estimate base-case • Included several standards-case scenarios to model poss

to standards.

Approach

EE-2006-STD-0131 COMMENT 38.3
Growth Rates

(Issue #11)

DOE invites comments on the growth rates used in thGSFL and IRL shipments analysis.

 Forecasted growth in commercial and industrial flo

residential buildings 

• Used AEO 2008 for commercial floor space and residenti

forecasts

• Used Manufacturer Energy Consumption Survey (MECS) 

calculate the industrial sector floor space growth.

 Accounted for historical trends in number of lamps 

household 

• Used a California study to estimate the average number o

cans in homes constructed from 2001 to 2005

• Based on distributions of home age and building growth, 

average number of GSFL and recessed cans in homes fr

• Average residential growth rates – GSFL: 1%; IRL: 2.6%

EE-2006-STD-0131 COMMENT 38.3
Emerging Technologies

(Issue #11)

DOE invites comments on the market penetration of etechnologies in the GSFL and IRL shipments analysis

 To account for the market penetration of other light

the GSFL and IRL markets, DOE modeled two basescenarios:

• Existing Technologies – forecasts the penetration of techn

available and have reached maturation in terms of price a

• Emerging Technologies - forecasts the penetration of ma

those that are still undergoing significant changes in price 

 Methodology to establish market penetration foreca

• Estimated price and performance forecasts of LEDs and C• Calculated payback period of LEDs, CMH, and R-CFL co• Used payback period and market penetration relationship

Existing Technologies Additional Emerging T

GSFL GSFL (including T5) LED, CMHIRL IRL, R-CFL LED, CMH

EE-2006-STD-0131 COMMENT 38.3
GSFL Shipments: 4-foot MB

 4-foot T8 MBP shipments grow due to new construction 

foot T12 and 8-foot T12 SP Slimline systems

 2000 Ballast Rule effectively eliminates the sale of 4-foo

ballasts causing T12 lamp shipments to decline. Remaiare for installation on residential and electronic ballasts

0.00.10.20.30.40.50.60.7

2000 2010 2020 2030 

Year

Shipments (billions)

4-foot T8 Existing Tech. Forecast 4-foot T12 Forecast4-foot T8 Emerging Tech. Forecast 4-foot T8 Historical4-foot T12 Historical

EE-2006-STD-0131 COMMENT 38.3
GSFL Shipments: 8-foot SP Sli

0.000.010.020.030.040.050.06

2000 2010 2020 2030 

Year

Shipments (billions)

8-foot T8 SP Forecast 8-foot T12 SP Fo8-foot T8 SP Historical 8-foot T12 SP Hi

 8-foot T8 SP slimline shipments show slight growth due 

some 8-foot T12 SP slimline systems

 2000 Ballast Rule effectively eliminates the sale of 8-foo

ballasts causing T12 lamp shipments to decline. Remain

are for installation on electronic ballasts.

EE-2006-STD-0131 COMMENT 38.3
GSFL Shipments: 8-foot RDC 

0.0000.0050.0100.0150.0200.0250.0300.035

2000 2010 2020 2030 

Year

Shipments (billions)

8-foot T8 RDC HO Forecast 8-foot T12 RDC HO 8-foot T8 RDC HO Historical 8-foot T12 RDC HO 

 Historical shipments in 2006 and 2007 show large declin

HO shipments.

 8-foot RDC HO shipments are projected to continue to d

penetration of other technologies (4-foot T5 MiniBP HO 

EE-2006-STD-0131 COMMENT 38.3
GSFL Shipments: 4-foot T5 MiniBP S

(Issue #11)

DOE invites comments on the T5 lamp shipment fore

0.000.020.040.060.080.100.12

2000 2010 2020 2030 

Year

Shipments (billions)

4-foot T5 MiniBP SO Existing Tech. Forecast4-foot T5 MiniBP SO Emerging Tech. Forecast4-foot T5 MiniBP HO Forecast

 4-foot T5 MiniBP SO shipments grow due to new const

penetration into the 4-foot MBP and 8-foot SP slimline 

 4-foot T5 MiniBP HO shipments grow due to new const

penetration into the 8-foot RDC HO and HID markets.

EE-2006-STD-0131 COMMENT 38.3
Incandescent Reflector Lamp Sh

0.000.050.100.150.200.25

2000 2004 2008 2012 2016 2020 2024 2028 2032 2

Year

Shipments (billions)

Existing Technology Base-Case Emerging Technology Base-CasHistorical Shipments

 Historical shipments in 2006 and 2007 indicate decline i

models decreased IRL shipments due to penetration of 

technologies.

 Emerging technologies reach saturation and IRL shipme

2020 due to new construction.

EE-2006-STD-0131 COMMENT 38.3
GSFL Base-Case Market Share Ma

4-foot T8 MBP Commercial System ShipmentsSystem Characteristic 2012 2042

32W 92% 25%30W 1% 10%28W 3% 20%25W 4% 45%

EL2 49% 20%EL3 29% 3%EL4 15% 57%EL5 7% 20%

0.88 90% 66%

0.78 5% 24%0.71 5% 10%

Ballast Factor

Lamp EfficacyLamp Wattage

4-foot T12 MBP System Sh

Electronic 

Magnetic 

Ballast

EL3 EL2 EL1 EL0 

Lamp Efficacy

34W 

Lamp 40W WattageSystem CoCharacteristic

 Base-case market share matrices characterize the d

shipments during the analysis period.

EE-2006-STD-0131 COMMENT 38.3
Base-Case Market-Share Matrices

 DOE analyzed three lumen packages:

• 27% at 580 lumens (50W Halogen baseline)• 32% at 1,050 lumens (75W Halogen baseline)• 41% at 1,310 lumens (90W Halogen baseline)

Commercial Stock 

2011 2042 

0 Halogen 78% 46% 1 Improved Halogen (Xenon) 0% 0% 2 Long-life HIR 5% 12% 4 Improved HIR 5% 12% 2 Improved Halogen (Silver) 3% 5% 3 HIR 10% 25% 5 Improved HIR Plus 0% 0% EL Lamp Design

EE-2006-STD-0131 COMMENT 38.3
GSFL and IRL Standards-Case Scenario

 Roll-up

• Only consumers purchasing below the trial standard level 

decisions in the standards case. 

• These consumers generally purchase the lowest first cos

 Shift

• All consumers reevaluate lamps and ballast purchase dec• Consumers currently purchasing the lowest efficacy optio

cost standards compliant lamp.

• Percentage of consumers purchasing at higher efficacy le

maintained (when possible) in the standards case.

 For GSFL, Roll-up and Shift are modeled in the com

and residential sectors.

 For IRL, in the base-case all residential consumers 

baseline (halogen) level. Therefore, the Shift scenacommercial sector. 

EE-2006-STD-0131 COMMENT 38.3
GSFL Standards-Case Scenarios: Light

 DOE established the lighting expertise scenarios to 

degrees of consumer education regarding lighting o

 High Lighting Expertise Scenario

• Assumes all consumers have high lighting expertise and re

migrating to reduced-wattage lamps or lower ballast factorlumen output and saving energy

 Market Segment-Based Lighting Expertise Scenario

• Incorporates some low expertise consumers who, in respo

purchase the same wattage lamp on the same ballast (thu

• Percentage of high expertise consumers determined base

Probability of High 

Lamp Purchase Event Commercial R

Renovation 69% 

New Construction 78% 

Retrofit 92% 

Ballast Replacement 8% 

Fixture Replacement 34% 

EE-2006-STD-0131 COMMENT 38.3
IRL Standards-Case Scenarios: Produc

 DOE established IRL scenarios to model the effect 

to exempted ER and BR lamps and R-CFLs in respo

 No Product Substitution Scenario

• Assumes all consumers who purchase regulated IRL in th

do so in the standards-case

 Product Substitution Scenario

• Assumes some consumers will migrate toward the exemp

R-CFL replacements in response to standards.

• R-CFL increased market penetration was based on the pa

with replacing a standards-compliant lamp with a R-CFL.

• 65W BR lamp increased market penetration in the comme

based on the payback period

• 65W BR lamp increased market penetration in the residen

increased first-cost of standards-compliant lamps.

EE-2006-STD-0131 COMMENT 38.3
Base-Case and Standards-Case Market S

(Issue #12)

DOE requests comment on the base-case market-shastandards-case market-share matrices for IRL and Gthe percentage of GSFL consumers with sufficient lig(i.e., those consumers who will choose a lower-BF bawattage lamp to maintain lumen output under standasegment

EE-2006-STD-0131 COMMENT 38.3
Request for Additional Comm

DOE invites comments on any other issues pertaininImpact Analysis.

EE-2006-STD-0131 COMMENT 38.3
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employ

Impac

Analysis

EE-2006-STD-0131 COMMENT 38.3
 Purpose

• To develop a list of standard levels from which impact

proposed standard level is selected.

 Method 

● Efficacy levels cover a range of efficacies and can incl

̶ Most energy efficient level (max tech);̶ Efficiency level with the lowest life-cycle cost;̶ Efficiency levels with noteworthy technologies; an

● Each trial standard level consists an efficacy level sele

class

● NOPR analyses assess impacts for trial standard leve

Selection of Trial Standard Lev

EE-2006-STD-0131 COMMENT 38.3
Selection of Trial Standard Levels – 

(Issue #15)

Representative Product Class TSL 1 TSL 2 T

4-Foot Medium Bipin, CCT 

≤ 4,500K EL1 EL2 

8-Foot Single Pin Slimline, CCT 

≤ 4,500K EL1 EL2 

8-Foot RDC HO, CCT 

≤ 4,500K EL1 EL2 

4-Foot Miniature Bipin T5 SO, CCT 

≤ 4,500K EL1 EL1 

4-Foot Miniature Bipin T5 HO, CCT 

≤ 4,500K EL1 EL1 

Representative Product Class Minimum Efficacy 

TSL 1 TSL 2 T

4-Foot Medium Bipin, CCT 

≤ 4,500K 78 81 

8-Foot Single Pin Slimline, CCT 

≤ 4,500K 89 93 

8-Foot RDC HO, CCT 

≤ 4,500K 83 87 

4-Foot Miniature Bipin T5 SO, CCT 

≤ 4,500K 103 103 

4-Foot Miniature Bipin T5 HO, CCT 

≤ 4,500K 89 89 

DOE invites comments on the appropriateness of triaconsidered for GSFL, in particular the combinations oeach GSFL product class.

EE-2006-STD-0131 COMMENT 38.3
GSFL National Energy Savings 

Net Present Value Results

0.02.04.06.08.0

10.012.014.0

TSL 1 TSL 2 TSL 3 TSL 4 

Energy Savings (quad)

High NES Low NES High NLow NPV 7% High NPV 3% Low NP

EE-2006-STD-0131 COMMENT 38.3
Selection of Trial Standard Levels 

(Issue #15)

Representative Product Class TSL 1 TSL 2 TSL 

Standard Spectrum, Diameter > 2.5in, Voltage < 125

EL1 EL2 EL3 

Representative Product Class Minimum Efficacy Re

TSL 1 TSL 2 TSL 3 

Standard Spectrum, Diameter > 2.5in, Voltage < 125

4.6P0.27 4.8P0.27 5.5P0.

DOE invites comments on the appropriateness of triconsidered for IRL.

P is the rated wattage of the lamp

EE-2006-STD-0131 COMMENT 38.3
IRL National Energy Savings a

Net Present Value Results

0.00.51.01.52.02.53.0

TSL 1 TSL 2 TSL 3 TSL 4 

Energy Savings (quad)

High NES Low NES High NLow NPV 7% High NPV 3% Low N

EE-2006-STD-0131 COMMENT 38.3
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employ

Impac

Analysis

EE-2006-STD-0131 COMMENT 38.3
Consumer Subgroup Analys

Con

 Purpose

• To evaluate the potential impacts of new or amended sta

subgroups that may be disproportionately impacted as copopulation.

 Method

• DOE identified low-income consumers, houses of worship

institutions that serve low-income populations, and consusystems as consumer subgroups.

• DOE adjusted the electricity prices, operating hours, and 

LCC model to calculate LCC savings and simple payback consumer subgroup.

 Output

• Determined that the LCC savings and simple payback pe

subgroups were in most cases similar to those results for 

EE-2006-STD-0131 COMMENT 38.3
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employ

Impac

Analysis

EE-2006-STD-0131 COMMENT 38.3
Manufacturer Impact Analysi

Manu

 Purpose

• To assess the impacts of standards on general service fl

(GSFL) and incandescent reflector lamps (IRL) manufac

• To identify and estimate impacts on manufacturer sub-gr

severely impacted than the industry as a whole;

• To examine the impact of cumulative regulatory burdens 

 Method 

• Analyze industry cash flow and net present value through 

Government Regulatory Impact Model (GRIM); and

• Interview manufacturers to refine inputs to the GRIM, de

analyses, and address qualitative issues.

EE-2006-STD-0131 COMMENT 38.3
Manufacturer Impact Analysis Pr

Manu

 The MIA consists of three phases:

Industry profile

Develop straw-man GRIM*

Develop interview guide

Interviews

& industrywide / 

subgroup

analyses

Assesemplocompecumuburde

Phase 2

* Government Regulatory Impact Model (GRIM)

Phase 1 Pha

EE-2006-STD-0131 COMMENT 38.3
GSFL Key Issues addressed in th

Manu

 Margin impacts

• DOE learned in interviews that higher efficacy lamps ea

than baseline products

• Higher TSLs could commoditize premium products by re

differentiator

• Reduction in product portfolio

 High cost to convert existing T12 lines to T8.  Issues with the availability and price of rare earth 

EE-2006-STD-0131 COMMENT 38.3
GSFL INPV Results by TSL

 The GSFL MIA analyzed the scenarios that bound 

on INPV

• Flat markup scenario under the Existing Technologies b

high lighting expertise, and a shift in efficacy distribution

• Four-tier markup scenario under the Emerging Technol

with market-based lighting expertise, and a roll-up in eff

Man

EE-2006-STD-0131 COMMENT 38.3
GSFL INPV Results by TSL (co

 General Service Fluorescent Lamps

• Flat markup scenario under the Existing Technologies ba

high lighting expertise, and a shift in efficacy distributions 

• Four-tier markup scenario under the Emerging Technolog

with market-based lighting expertise, and a roll-up in effic

Man

Units Base Case Trial Sta

12 

INPV (2007$ millions) 575 668 638 4

(2007$ millions) - 93 63 (1

(%) - 16.09% 11.02% -24

Change in 

INPV

(%) - 8.18% 8.31% 11

Change in (2007$ millions) - 49 50 

INPV

INPV (2007$ millions) 602 652 653 6

1 2

Units Base Case Trial Sta

EE-2006-STD-0131 COMMENT 38.3
IRL Key Issues addressed in the 

Manu

 Emerging technologies are eroding the IRL marke Higher efficiency products are currently produced 

• Standards would require high capital conversion costs to 

production volume of these higher efficacy products

• These high capital conversion costs could be made ove

volume 

 Competitive concerns (patented technology)  Issues with the price and availability of Xenon

EE-2006-STD-0131 COMMENT 38.3
IRL INPV Results by TSL

 The IRL MIA analyzed the scenarios that bound th

INPV

• Existing Technologies base case reflecting the no produ

with a shift in efficacy distributions. 

• Emerging Technologies base case reflecting the produc

a roll-up in efficacy distributions

Man

EE-2006-STD-0131 COMMENT 38.3
INPV Results by TSL (cont.)

 Incandescent Reflector Lamps

• Existing Technologies base case reflecting the no produ

scenario with a shift in efficacy distributions. 

• Emerging Technologies base case reflecting the produc

scenario with a roll-up in efficacy distributions

Man

Units Base Case Trial Sta

12 

INPV (2007$ millions) 207 191 149 1

(2007$ millions) - (16) (58) (

(%) - -7.69% -27.87% -36

Change in 

INPV

(%) - -1.55% -19.36% -23

Change in (2007$ millions) - (4) (52) (6

INPV

INPV (2007$ millions) 267 263 215 2

1 2

Units Base Case Trial Sta

EE-2006-STD-0131 COMMENT 38.3
Manufacturer Impact Analysi

(Issue #13)

 DOE invites comment on the methodology and in

manufacturer impact analysis – specifically DOE’regarding the manufacturer production cost assucapital costs, conversion costs, and stranded ass

 DOE invites comment on the ability of GSFL manu

maintain current margins through the differentiatiother means. DOE also seeks comment on how tdifferentiate products might vary over time. 

 DOE invites further comment on how small busin

impacted by standards on GSFL and IRL.

Man

EE-2006-STD-0131 COMMENT 38.3
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employ

Impac

Analysis

EE-2006-STD-0131 COMMENT 38.3
 Purpose

• To investigate the effects on utilities from reduced energy 

demand due to potential standards.

 Method 

• Use National Energy Savings Results; and• Use the EIA’s National Energy Modeling System (NEMS-B

Building Technologies Program.

 Output

• Change in electricity sales and price by region;• Change in the mix of electricity generation; and• Change in installed capacity and generation.

Utility Impact Analysis

EE-2006-STD-0131 COMMENT 38.3
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employ

Impac

Analysis

EE-2006-STD-0131 COMMENT 38.3
 Purpose

• To report net jobs created or eliminated nationally as a con

amended energy conservation standards. Employment imindirect impacts.

 Method 

• Uses the Impact of Sector Energy Technologies (ImSET) m

indirect employment impacts;

• Estimate changes in employment in the overall United Sta

from changes in expenditures in the various sectors of the 

• Estimate changes in costs and benefits using the NIA ana• Direct employment impacts are addressed in the Manufac

 Output

• Change in employment in national economy, other than in 

being regulated, as a consequence of the amended energ

Emp

Employment Impact Analysis

EE-2006-STD-0131 COMMENT 38.3
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employ

Impac

Analysis

EE-2006-STD-0131 COMMENT 38.3
 Purpose

• To report environmental impacts as a consequence of the 

conservation standards, including changes in power plant 

 Output

• Reduction in power plant emissions of carbon dioxide (CO

NEMS-BT computer model.

• Ranges of estimates for reductions in oxides of nitrogen (N

mercury (Hg) emissions were developed using current powrates and generation reductions from NEMS-BT.

• Sulfur dioxide (SO2) emission was not included due to the 

Clean Air Act Amendments of 1990. Impact on SO2 emiss

estimated as too small to significantly affect value of emissthe cap.

• Monetized value of reductions in CO2, NOX, and Hg.

En

Environmental Assessment

EE-2006-STD-0131 COMMENT 38.3
Issues for which DOE seeks com

(Issues # 14)

DOE seeks comment on the determination of the anenvironmental impacts of the proposed rule, particurespect to the methods for valuing the expected CO2

emissions savings due to the proposed standards. 

En

EE-2006-STD-0131 COMMENT 38.3
NOPR Analyses Flow Diagram

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

Revise ANOPR Analyses

Trial Standard Levels

Consumer Subgroup Analysis

Manufacturer 

Impact 

Analysis

Utility Impact Analysis

Employ

Impac

Analysis

EE-2006-STD-0131 COMMENT 38.3
 Purpose

• To investigate the national impacts due to non-regulato

compared to mandatory energy conservation standards

• The non-regulatory alternatives that DOE analyzed inclu

– No New Regulatory Action;– Consumer Rebates;– Consumer Tax Credits; – Manufacturer Tax Credits;– Voluntary Energy-Efficiency Targets (ENERGY STAR); an– Bulk Government Purchases

 Method

• Modify NIA spreadsheet model to consider the above sc

affect on adoption of products at the proposed standard 

 Output

• National Energy Savings and Net Present Value of the 

alternatives.

Re

Regulatory Impact Analysis

EE-2006-STD-0131 COMMENT 38.3
1. The scope of covered products DOE considered in this rulemaking 

decision to cover 4-foot T5 miniature bipin SO and 4-foot T5 minia

2. DOE’s decision to amend the definition of “colored fluorescent lam

CCT greater than 7,000K

3. The appropriateness of establishing separate product classes for 

rated lamp voltage

4. The appropriateness of establishing separate product classes for 4

and 4-foot T5 miniature bipin HO lamps

5. The added 4-foot MBP residential sector engineering analysis, par

baseline system (lamp and ballast)

6. The performance characteristics (e.g., lumen output, lifetime, watt

GSFL and IRL model lamps DOE used in the engineering analysis properties of the T5 halophosphor GSFL baseline lamps and the imuses xenon as a fill gas (the lamp established for TSL1)

7. The efficacy levels DOE considered for IRL, in particular the adde

Summary of Issues on which DOE seeks comment 

EE-2006-STD-0131 COMMENT 38.3
8. The efficacy levels DOE used for each GSFL product class-- partic

use compliance report data to establish GSFL efficacy levels

9. The methodology DOE used to scale efficacy levels from represen

product classes DOE did not analyze (i.e., 2-foot U-shaped lamps GSFL; modified spectrum lamps, lamps with diameters less than owith rated voltage greater than 125V)

10. The choice of ballast lifetimes DOE used in the commercial, reside

and operating hours for GSFL in the residential sector

11. The growth rates DOE used in the residential sector IRL and GSF

market penetration of emerging technologies in the IRL and GSFL T5 lamp shipment forecasts

12. Base-case market-share matrices and standards-case market-sha

GSFL -- particularly the percentage of GSFL consumers with sufficthose consumers who will choose a lower-BF ballast or reduced-wlumen output under standards) by market segment

Summary of Issues on which DOE seeks comment 

EE-2006-STD-0131 COMMENT 38.3
13. The methodology and inputs DOE used for the manufacturer impa

DOE’s assumptions regarding markups, capital costs, conversion 

14. The determination of the environmental impacts of the proposed ru

for valuing the CO2, NOx, SOx, and Hg emissions savings due to 

15. The appropriateness of trial standard levels DOE considered for G

the combinations of efficacy levels of each GSFL product class

16. The proposed standard levels for GSFL and IRL

17. Potential approaches to maximize energy savings while mitigating 

consumer subgroups, for instance the maintaining of T12 lamps in 

18. Other technology pathways that may be utilized to meet IRL TSL5

may have any adverse effects on consumer utility or the ability for produced, manufacturer costs associated with these pathways, anproduct prices for lamps that meet this standard level

Summary of Issues on which DOE seeks comment - 

EE-2006-STD-0131 COMMENT 38.3
Request for Additional Comm

DOE invites comments on any remaining issues pertNOPR.

EE-2006-STD-0131 COMMENT 38.3
How to Submit Comments...

 Public Meeting – Oral comments will be captured in the tran

part of the public record.

 Written comments – NOPR comment period closes 60 days 

Federal Register.Reference docket #: EE–2006–STD–0131 and/or RIN #: 1

Email: fluorescent_and_incandescent_lamps.rulemaki

Mail: Ms. Brenda Edwards

U.S. Department of EnergyBuilding Technologies Program, Mailstop EE–21000 Independence Avenue, SW.Washington, DC 20585–0121.Telephone: (202) 586–2945.

Courier: Ms. Brenda Edwards

U.S. Department of EnergyBuilding Technologies Program950 L’Enfant Plaza, SW., 6th Floor,Washington, DC 20024.

EE-2006-STD-0131 COMMENT 38.3