### U.S. DEPARTMENT OF ENERGY PUBLIC MEETING ON TEST PROCEDURES FOR GENERAL SERVICE FLUORESCENT LAMPS, INCANDESCENT REFLECTOR LAMPS, AND GENERAL SERVICE INCANDESCENT LAMPS
AND ENERGY CONSERVATION STANDARDS FOR GENERAL SERVICE FLUORESCENT LAMPS AND INCANDESCENT REFLECTOR LAMPS Room 8E-089 1000 Independence Avenue, SW Washington, DC 20585 March 10

- 11, 2008 

## Issues for Stakeholder Comment The U.S. Department of Energy (DOE) published an Advanced Notice of Proposed Rulemaking (ANOPR) regarding Energy Conservation Standards and a Notice of Proposed Rulemaking (NOPR) regarding Test Procedures for certain lamp types. While DOE invites comments from stakeholders on all aspects of the material presented in these notices, there are several issues in particular on which DOE seeks comment. These issues are highlighted throughout the NOPR and ANOPR presentations. The list of issues is reproduced below, grouped according to the session at which they will be discussed. Within those groupings, several issues are associated with those highlighted in Section V.E of the ANOPR or in Section IV.E of the NOPR and are numbered accordingly. Though un-numbered items do not appear in these sections of the ANOPR or NOPR, DOE seeks comment on these issues as well.



### 1. Test Procedures DOE seeks comment on the proposed test procedure reference updates, specifically , whether these updates to ANSI, IESNA, and CIE standards would introduce an additional testing burden or change the measurement of lamp efficacy. (Issue #1) DOE seeks comment on whether it should limit fluorescent lamp testing to low-frequency ballasts. (Issue #2) DOE seeks comment on whether fluorescent lamp efficacy should be calculated to the nearest tenth of a lumen per watt. (Issue #3) DOE seeks comment on the proposed incorporation by reference of the industry standard LM-9-1999 for measuring and determining CCT for fluorescent lamps. (Issue #4)



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### Issues for Comment

DOE seeks comment on its proposal that all GSFL that are considered to be in the same basic model must have similar CCTs. ( Issue #5) DOE seeks comment on the proposed reference ballast settings. (Issue #6) 

### DOE seeks comment on the proposed additions to the GSIL test procedure. (Issue #7) DOE seeks comment on its proposal to not incorporate a measure of off mode and standby mode energy consumption in its test procedures for GSFL, IRL, and GSIL. (Issue #8) 

### 2. Scope of Coverage DOE invites comment on its considered expansion of coverage of general service fluorescent lamps. (Issue #1) 

### 3. Engineering Analysis DOE invites comment on the possible approaches to handling the issue of CRI in setting GSFL efficacy standards. DOE invites comments on GSFL product classes. Specifically, DOE invites comment on whether T12 and T8 fluorescent lamps should be in the same product class. DOE also invites comments on whether there should be a CCT divider, how many groupings of CCT are appropriate, and what the CCT divider or dividers should be. (Issue #3) 

### DOE invites comment on the creation of product classes that encompass the full range of IRL wattages and the creation of a separated product class for modified spectrum lamps. (Issue #3) DOE invites comments on the selection of GSFL lamp-and-ballast designs from baseline to max-tech as well as the selection of GSFL candidate standard levels. DOE invites comments on the method used to scale to product classes with CCT > 4100K and the 2-foot U-shaped product class . (Issue #4) 

### DOE invites comment on the selection of IRL lamp designs from baseline to max-tech. DOE invites comment on whether the IRL candidate standard level represents the appropriate technology across all wattages.DOE invites comments on the method used to scale from a standard-spectrum lamp to a modifiedspectrum lamp. (Issue #4) 

### DOE requests feedback on the approach for developing end-user GSFL prices. DOE requests feedback on the approach for developing end-user IRL prices.

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### Issues for Comment

4. Life

- Cycle Cost Analysis DOE requests feedback on whether the average operating hours derived are a reasonable estimation of their end-uses. (Issue #6) DOE invites comments on the system power rating of the lamp-and-ballast systems analyzed. (Issue #7)

### DOE seeks comment on the use of residual value and on other possible approaches to calculating lifecycle costs for products with varying lifetimes. (Issue #8) DOE seeks comment on average labor times and labor rates. Specifically, DOE requests comment on how labor times will be affected by the 2005 National Electric Code. (Issue #9) DOE seeks comment on any other aspects related to the Life-Cycle Cost and Payback Period Analyses. 5. National Impacts Analysis DOE invites comment on the methodology and data sources used to estimate initial lamps stocks in 2011. (Issue #11) DOE invites comment on the fluorescent base-case and standards-case market share matrices. (Issue #10, Issue #12) DOE invites comment on the fluorescent base-case shipment forecasts. (Issue #11) DOE invites comment on appropriate standards -case voluntary magnetic T12 ballast retrofit rates for the 4-foot MBP and 8-foot SP slimline . (Issue #11) 

### DOE invites comment on the shipment scenarios analyzed and other scenarios DOE should analyze for GSFL. (Issue #12) DOE invites comment on the methodology used to incorporate emerging technologies in the base-case IRL forecast. (Issue #11) DOE invites comment on the assumptions discussed including IRL operating sectors, market shares of incandescent and halogen IRL, and market shares of exempted IRL. (Issue #11) DOE invites comment on the population of IRL base-case and standards-case market share matrices. (Issue #10, Issue #12) DOE invites comment on the national lumen output projection in both the standards case and base case. Specifically DOE invites comment on whether any shipment or stock adjustments are necessary in response to over-lighting or under-lighting. (Issue #11) DOE invites comment on standards-case shipment scenarios analyzed for incandescent reflector lamps. (Issue #12)



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### Issues for Comment

DOE invites comment on the HVAC interaction implemented in the commercial and residential sectors. DOE invites comment on the inclusion and the magnitude of the rebound effect for purposes analyzing the expected effects of this regulation. DOE invites comment on its usage of residual value to account for the remaining lifetime of lamps. 6. NOPR Analyses DOE requests feedback on the criteria it should use for basing the selection of Trial Standard Levels. (Issue #13) DOE welcomes comment on how LCC inputs may change for each consumer subgroup.



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