1 | Energy Efficiency and Renewable Energy eere.energy.gov

Energy Conservation Standards

Notice of Proposed Rulemaking for 

general service fluorescent lamps 

(GSFLs) and incandescent reflector 

lamps (IRLs)

May 1, 2014

Lucy deButts

Department of Energy

Building Technologies Program

EERE-2011-BT-STD-0006

GSFL-IRL_2011-STD-0006@ee.doe.gov
2

Welcome

• Introductions (around the room)

• Role of the Facilitator

• Ground Rules

- Speak one at a time.

- Say your name for the record – there will be a complete transcript of this 

meeting.

- Be concise – share the ‘air-time.’

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

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

recognized to speak.

• Housekeeping Items

• Agenda Review

• Opening Remarks
3

Public Meeting Agenda

9:00 – 9:25 am Welcome, Introductions, Opening Statements, Overview, 

Statute, Context

9:25 – 9:45 am Market and Technology Assessment, Screening Analysis

9:45 – 10:45 am Engineering Analysis

10:45 – 11:00 am Break

11:00 – 11:15 am Product Price Determination

11:15 – 12:00 pm Trial Standard Levels, Energy Use, Life-Cycle Cost Analysis

12:00 – 1:00 pm Lunch

1:00 – 2:00 pm Shipments, National Impact Analysis

2:00 – 2:30 pm Manufacturer Impact Analysis

2:30 – 3:00 pm Emissions/Monetization of Emissions, Utility Impact, 

Employment Impact, Regulatory Impact Analyses

3:00 – 3:15 pm Proposed Standard

3:15 – 3:30 pm Closing Remarks and Adjourn
4

Listening via the Webcast

• The Department is broadcasting this meeting live over the 

Internet. 

• DOE is providing the webcast to accommodate stakeholders 

that are unable to attend the public meeting in person. 

• The web broadcast allows stakeholders to listen in and view 

the slides.

• All stakeholders are encouraged to submit written comments 

after the public meeting. 
5

Purpose of Public Meeting

1. Present energy conservation standards DOE is proposing for 

GSFLs and IRLs in this notice of proposed rulemaking.

2. Invite comment from participants on the analysis.

3. Discuss the next steps for the rulemaking.

4. Encourage participants to submit data, information, 

summary statements, and written comments, including 

additional issues for discussion.
6

Issue for Discussion

Issue box numbering corresponds to the Technical Support 

Document’s Executive Summary, available at regulations.gov, 

under docket number EERE-2011-BT-STD-0006, at 

www.regulations.gov/#!documentDetail;D=EERE-2011-BT-STD0006-0045.

The deadline for submitting comments is June 30, 2014.

Issue Box: DOE welcomes comments, data, and information 

concerning standards being considered 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.
7

How to Submit Written Comments

• In all correspondence, please refer to the GSFL-IRL rulemaking by:

– Energy Conservation Standards for General Service Fluorescent Lamps 

and Incandescent Reflector Lamps;

– Docket Number EERE-2011-BT-STD-0006; and

– Regulatory Identification Number (RIN) 1904-AC43.

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

Postal: Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Mailstop 

EE-2J

1000 Independence Avenue, SW

Washington, DC 20585-0121

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Suite 600

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: 202 586-2945

Comment Period closes: June 30, 2014, 11:59 PM EDT
8

Opening Remarks

Meeting participants are invited to provide opening 

remarks or statements at this time.
9

Presentation Overview

Energy Use; Life-Cycle Cost Analysis

Shipments; National Impact Analysis

5

6

2 Market & Technology; Screening Analysis

Engineering Analysis, Product Price 

Determination 3

1 Overview; Scope of Coverage

7 Manufacturer Impact Analysis

4 Trial Standard Levels

Emissions, Utility, Employment, and Regulatory 

Impacts

Proposed Standard

8

9
10

Regulatory History

• The Energy Policy Act of 1992 (EPACT 1992) amended the Energy 

Policy and Conservation Act of 1975 (EPCA) by:

− Establishing standards for certain classes of GSFLs and IRLs; and

− Authorizing DOE to conduct two rulemaking cycles to revise and amend 

standards, and adopt standards for additional GSFLs, if warranted.

• On July 14, 2009, DOE completed the first rulemaking cycle by 

publishing a final rule amending existing standards for GSFLs and IRLs 

(hereafter “2009 Lamps Rule”). These standards required compliance 

starting in July 2012 (hereafter “July 2012 standards”). 

• On September 14, 2011, DOE initiated the second rulemaking cycle 

by publishing a framework document and held a public meeting on 

October 10, 2011. 

• On February 28, 2013, DOE published a notice announcing the 

availability of the preliminary analysis and held a public meeting on 

April 9, 2013. 
11

Current Standards - GSFLs

• The 2009 Lamps Rule prescribed the current energy conservation 

standards for GSFLs manufactured on or after July 14, 2012.

Lamp Type Correlated Color 

Temperature (CCT)

Minimum average 

lamp efficacy 

(lumens per watt 

[lm/W])

4-foot Medium Bipin (MBP) ≤ 4,500 K 89

> 4,500 K and ≤ 7,000 K 88

2-foot U-shaped ≤ 4,500 K 84

> 4,500 K and ≤ 7,000 K 81

8-foot Single Pin (SP) Slimline ≤ 4,500 K 97

> 4,500 K and ≤ 7,000 K 93

8-foot Recessed Double Contact (RDC) High 

Output (HO) 

≤ 4,500 K 92

> 4,500 K and ≤ 7,000 K 88

4-foot T5 Miniature BiPin (MiniBP) Standard 

Output (SO)

≤4,500 K 86

> 4,500 K and ≤ 7,000 K 81

4-foot T5 MiniBP HO ≤ 4,500 K 76

> 4,500 K and ≤ 7,000 K 72
12

Current Standards - IRLs

• The 2009 Lamps Rule prescribed the current energy conservation 

standards for IRLs manufactured after July 14, 2012. 

Rated lamp 

wattage

Spectrum Diameter 

(inches) Voltage Minimum average lamp 

efficacy (lm/W)

40-205 Standard

> 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

40-205 Modified

> 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

P = rated lamp wattage, in watts
13

2012 2013 2014 2015 2016 2017 2018

GSFL and IRL Rulemaking Schedule

Milestone Date

Notice of Public Meeting and Availability of Framework Document 14 September 2011

Notice of Public Meeting and Availability of Preliminary Technical 

Support Document 28 February 2013

Notice of Proposed Rulemaking 29 April 2014

Final Rule (legislative deadline) 14 July 2014

Final Rule (projected) December 2014

Compliance Date (projected) December 2017
14

EPCA Factors

42 U.S.C. 6295(o)(2)(B)(i) directs DOE to consider seven factors when 

setting energy conservation standards.

EPCA Factors DOE Analysis

1. Economic impact on consumers and 

manufacturers

Life-Cycle Cost Analysis

Manufacturer Impact Analysis

2. Lifetime operating cost savings compared 

to increased cost for the product Life-Cycle Cost Analysis

3. Total projected energy savings National Impact Analysis 

4. Impact on utility or performance Engineering Analysis

Screening 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

Emissions Analysis

Utility Impact Analysis

Employment Impact Analysis
15

Scope of Coverage: GSFLs

• The following GSFLs are currently covered by standards:

Lamp Type Rated Wattage

4-foot MBP  25 W

2-foot MBP U-shaped  25 W

8-foot SP slimline  52 W

8-foot RDC HO All

4-foot T5 MiniBP SO  26 W

4-foot T5 MiniBP HO  49 W

• DOE assessed extending coverage to additional GSFLs using the 

following criteria:

- If lamps meet the general description of “fluorescent lamp” and do not fall 

within exclusions specified in the “general service fluorescent lamp” definition;

- whether standards for lamps would result in significant energy savings; and 

- whether standards for lamps are technologically feasible and economically 

justified. 
16

Scope of Coverage: GSFLs

• Assessment of additional GSFLs to include under scope of coverage: 

- DOE is not evaluating standards for additional fluorescent lamp types.

- DOE is evaluating standards for additional wattages for the fluorescent lamp 

types already covered. 

Lamp Type Existing

Wattage Limits

Proposed Wattage

Limits

4-foot MBP  25 W No change

2-foot MBP U-shaped  25 W No change

8-foot SP slimline  52 W  49 W

8-foot RDC HO All No change

4-foot T5 MiniBP SO  26 W  25 W

4-foot T5 MiniBP HO  49 W  44 W
17

Scope of Coverage: GSFLs

• The “general service fluorescent lamp” definition provides specific 

exemptions. 

• DOE found certain exemptions could be further clarified. 

• DOE is proposing definitions for exemptions shown in bold above.

General service fluorescent lamp means any fluorescent lamp which can be used to 

satisfy the majority of fluorescent lighting applications, but does not include any 

lamp designed and marketed for the following nongeneral application:

(1) Fluorescent lamps designed to promote plant growth;

(2) Fluorescent lamps specifically designed for cold temperature applications;

(3) Colored fluorescent lamps;

(4) Impact-resistant fluorescent lamps;

(5) Reflectorized or aperture lamps;

(6) Fluorescent lamps designed for use in reprographic equipment;

(7) Lamps primarily designed to produce radiation in the ultra-violet region of the 

spectrum; and

(8) Lamps with a Color Rendering Index of 87 or greater.

10 CFR 430.2
18

Scope of Coverage: GSFLs

• DOE is also proposing definitions for the terms “700 series 

fluorescent lamp” and “designed and marketed” when used for 

lighting products.

700 series fluorescent lamp means a fluorescent lamp with a color rendering index 

(measured according to the test procedures outlined in Appendix R to subpart B of 

this part) that is in the range (inclusive) of 70 to 79.

Designed and marketed means that the intended application of the lamp is stated in 

a publicly available document (e.g., product literature, catalogs, packaging labels, and 

labels on the product itself). This definition is applicable to terms related to the 

following covered lighting products: fluorescent lamp ballasts; fluorescent lamps; 

general service fluorescent lamps; general service incandescent lamps; incandescent 

lamps; incandescent reflector lamps; medium base compact fluorescent lamps; and 

specialty application mercury vapor lamp ballasts.
19

Scope of Coverage: IRLs

• DOE is proposing standards for IRLs that meet the following 

definition in the scope of coverage:

• DOE is proposing standards for IRLs with wattages between 40 and 

205 W. 

Incandescent reflector lamp (commonly referred to as a reflector lamp) means any 

lamp in which light is produced by a filament heated to incandescence by an electric 

current, which: is not colored or designed for rough or vibration service applications 

that contains an inner reflective coating on the outer bulb to direct the light; has an R, 

PAR, ER, BR, BPAR, or similar bulb shapes with an E26 medium screw base; has a rated 

voltage or voltage range that lies at least partially in the range of 115 and 130 volts; has 

a diameter that exceeds 2.25 inches; and has a rated wattage that is 40 watts or higher.

10 CFR 430.2
20

NOPR Stage

Framework

Document 

Prelim 

Analysis NOPR 

Final

Rule

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use & End 

Use Load

Characterization

Shipments

Analysis

National

Impact

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Product Price 

Determination

Manufacturer 

Impact 

Analysis

Emissions 

Analysis

Employment 

Impact 

Analysis

Utility 

Impact 

Analysis

Regulatory 

Impact 

Analysis
21

Presentation Overview

Energy Use; Life-Cycle Cost Analysis

Shipments; National Impact Analysis

5

6

2 Market & Technology; Screening Analysis

Engineering Analysis, Product Price 

Determination 3

1 Overview; Scope of Coverage

7 Manufacturer Impact Analysis

4 Trial Standard Levels

Emissions, Utility, Employment, and Regulatory 

Impacts

Proposed Standard

8

9
22

Purpose of MTA and Screening Analysis

• Market and Technology Assessment (MTA)

 Determine product classes 

 Identify technology options to improve efficacy

• Screening Analysis

 Screen out technology options that DOE will not consider in the engineering 

analysis based on: 

1. Technological feasibility: incorporation in commercially available products or in 

working prototypes

2. Practicability to manufacture, install, and service: mass production and reliable 

installation and servicing could be achieved on the scale necessary to serve the 

relevant market at the time the standard requires compliance

3. Adverse impacts on product utility or product availability: significant adverse 

impact on the utility of the product to significant subgroups of consumers, or 

causing the unavailability of any covered product type with performance 

characteristics, features, sizes, capacities, and volumes that are substantially the 

same as products generally available in the United States at the time

4. Adverse impacts on health or safety: significant adverse impacts on health or 

safety
23

Product Classes

• DOE divides covered products into classes by:

– the type of energy used;

– capacity of the product; or

– other performance-related features that justify different standard levels, such 

as features affecting consumer utility.

• DOE establishes separate energy conservation standards for each 

product class.

• DOE is proposing to maintain the existing product class divisions for 

GSFLs and IRLs.
24

Product Classes: GSFLs

• DOE is proposing the following product class divisions for GSFLs: 

Lamp Type CCT

4-foot MBP

≤ 4,500 K

> 4,500 K

2-foot U-shaped

≤ 4,500 K

> 4,500 K

8-foot SP slimline

≤ 4,500 K

> 4,500 K

8-foot RDC HO

≤ 4,500 K

> 4,500 K

4-foot T5 MiniBP SO

≤ 4,500 K

> 4,500 K

4-foot T5 MiniBP HO

≤ 4,500 K

> 4,500 K

Correlated color temperature (CCT)

- Different CCT values offer different utility to 

consumers.

- Lamps with CCTs greater than 4,500 K show 

a decline in efficacy. 

Physical constraints (lamp shape/length)

- Different lamp geometries fit different 

building design/footprints. 

- Lamp length and shape impact efficacy.

Lumen package (quantity of light 

provided by a lamp-and-ballast)

- Different lumen packages used for different 

applications. 

- Lumen packages can impact efficacy (e.g., 

high lumen packages require ballasts that 

run at high currents, decreasing efficacy).
25

Spectrum Diameter 

(inches) Voltage

Standard

> 2.5

≥ 125 V

< 125 V

≤ 2.5

≥ 125 V

< 125 V

Modified

> 2.5

≥ 125 V

< 125 V

≤ 2.5

≥ 125 V

< 125 V

Product Classes: IRLs

• DOE is proposing the following product class divisions for IRLs: 

Spectrum

- Modified spectrum provide a different type of light 

(utility) than standard spectrum by absorbing a 

portion of visible light emitted from the filament.

- Modification of the spectral emission of the lamp 

decreases efficacy.

Diameter

- Smaller diameter lamps can fit in smaller fixtures, 

offering a unique utility. 

- Smaller diameter lamps have an inherently lower 

optical efficiency and cannot utilize the same 

technology options as larger diameter lamps.

Rated Voltage

- Most consumers operate 130 V lamps at 120 V resulting in longer lifetime, but reduced efficacy. 

Existing DOE test procedures require lamps rated at 130 V be tested at 130 V and lamps rated at 120 

V be tested at 120 V.

- Consequently, at a single standard for all voltages, 130 V lamps would not require as efficient 

technologies as 120 V lamps which may make 130 V lamps less costly to produce and cheaper, 

resulting in a migration to 130 V lamps and increased energy consumption. 
26

• DOE identified technology options that can improve lamp efficacy 

for GSFLs and IRLs. 

• DOE then reviewed technology options identified and assessed 

them using the following criteria:

– Technological feasibility

– Practicability to manufacture, install, and service

– Adverse impacts on product utility or availability to customers

– Adverse impacts on health or safety

Technology Options and Screening Analysis
27

Technology Options/Screening Analysis: 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 

• DOE identified the technology options below that can improve GSFL 

efficacy. 

• Of these technology options, DOE determined that all, except multiphoton phosphors, meet the four screening criteria.
28

Technology Options/Screening Analysis: IRLs

IRL Technology Options

Higher Temperature Operation Non-Tungsten-Halogen Regenerative Cycles

Novel Filament Materials Infrared Glass Coatings

Thinner Filaments

Higher Efficiency Reflector Coatings

(Higher Efficiency Gold Reflector Coatings)

Efficient Filament Orientation Permanent Infrared Reflector Coating Shroud

Efficient Filament Coiling Infrared Phosphor Glass Coatings

Microcavity Filaments UV Phosphor Glass Coatings

Crystallite Filament Coatings Corner Reflectors

High Reflectance Filament Supports Electron Simulated Luminescence

Higher Efficiency Inert Fill Gas Higher Efficiency Burners

(Higher Efficiency Burners for IRLs < 2.5 in.)

Higher Pressure Tungsten-Halogen Lamps

• DOE identified the technology options below that can improve IRL 

efficacy. 

• Of these technology options, DOE determined that all, except those 

in red, meet the four screening criteria.
29

Presentation Overview

Energy Use; Life-Cycle Cost Analysis

Shipments; National Impact Analysis

5

6

2 Market & Technology; Screening Analysis

Engineering Analysis, Product Price 

Determination 3

1 Overview; Scope of Coverage

7 Manufacturer Impact Analysis

4 Trial Standard Levels

Emissions, Utility, Employment, and Regulatory 

Impacts

Proposed Standard

8

9
30

Engineering Analysis Methodology

Select certain representative product classes to be 

analyzed in the engineering analysis.

Define characteristics of baseline lamps in each 

representative product class that serve as reference points 

to assess changes due to energy conservation standards. 

Identify more efficacious substitutes for each baseline 

lamp based on design options. 

Develop efficacy levels (ELs) that span the range of efficacy 

from the baseline to the maximum technologically 

feasible.

Scale results to product classes not analyzed.

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine ELs

Scale Results
31

Representative Product Classes: GSFLs

• DOE chooses representative product classes to 

concentrate its analytical effort.

– Representative product classes (in darker green) were chosen on 

a basis of high market volumes.

Lamp Type CCT

4-foot MBP

≤ 4,500 K

> 4,500 K

2-foot U-shaped

≤ 4,500 K

> 4,500 K

8-foot SP slimline

≤ 4,500 K

> 4,500 K

8-foot RDC HO

≤ 4,500 K

> 4,500 K

4-foot T5 MiniBP SO

≤ 4,500 K

> 4,500 K

4-foot T5 MiniBP HO

≤ 4,500 K

> 4,500 K

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine ELs

Scale Results
32

Baseline Lamps: GSFLs

• The baseline model typically represents the most 

common, least efficacious model on the market for each 

representative product class.

• For representative product classes in which there were no 

commercially available lamps at the existing standard 

level, DOE modeled baseline lamps.

– Modeled baselines for the 8-foot RDC HO, T5 MiniBP SO, and T5 

MiniBP HO product classes.

– Using the ANSI rated wattage of the most common, least 

efficacious commercially available lamp, calculated the required 

lumen output for the existing standard.

– Assumed modeled baseline lamp would have similar 

characteristics as the most common commercially available lamps 

in each product class. 

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine ELs

Scale Results
33

Baseline Lamps: GSFLs

Issue 2: GSFL Baselines

In the engineering analysis, DOE selects a baseline lamp as a reference point against 

which to measure changes resulting from energy conservation standards. DOE requests 

comments on the baseline lamps selected in this analysis for GSFLs.

Baseline 

Lamp

Lamp 

Diameter

Nominal 

Wattage

Rated 

Wattage

Rated 

Efficacy

(25 °C)

Initial 

Light 

Output

(25 °C)

Mean 

Light 

Output

(25 °C)

Life 

W W lm/W lm lm hr

4-foot MBP T8 32 32.5 89.2 2,900 2,725 24,000*

8-foot SP 

slimline T8 59 60.1 96.5 5,800 5,220 24,000

8-foot RDC 

HO T8 86 84.0 92.0 7,728 7,342 18,000

4-foot T5 

MiniBP SO T5 28 27.8 86.0 2,391 2,223 30,000

4-foot T5 

MiniBP HO T5 54 53.8 76.0 4,089 3,884 25,000

*Instant start lifetime.
34

More Efficacious Substitutes: GSFLs

• DOE selected more efficacious replacement lamps to 

measure potential energy-saving improvements. 

• More efficacious replacement lamps were identified by 

rated efficacy and characteristics similar to baseline lamps 

(e.g., rated life, color rendering index [CRI], and CCT)

Product 

Class

Lamp 

Diameter

Nominal 

Wattage

Rated 

Wattage

Rated 

Efficacy

Initial 

Light 

Output

Mean 

Light 

Output

Life

(IS)

CRI

W W lm/W lm lm hr

4-foot 

MBP

T8* 32 32.5 89.2 2,900 2,725 24,000 83

T8 32 32.5 90.0 2,925 2,770 21,000 85

T8 25 26.6 93.0 2,475 2,350 24,000 85

T8 32 32.5 95.4 3,100 2,945 24,000 85

T8 28 28.4 96.0 2,725 2,590 24,000 85

*Row represents baseline lamp

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine ELs

Scale Results
35

Issues for Comment: GSFLs

Issue 3: GSFL Lifetimes

For GSFLs, the baseline and more efficacious substitutes selected represent the most 

common lifetimes for each product class. DOE requests comment on the rated lifetimes 

of the GSFL baselines and more efficacious substitutes. 
36

Efficacy Levels: GSFLs

• DOE used commercially available lamps when possible 

and their associated catalog rated efficacies to determine 

ELs.

• To establish final minimum efficacy requirements for ELs, 

DOE analyzed publicly available compliance data and 

determined whether any adjustments were necessary to 

the initial ELs. 

• DOE only analyzed ELs at which a full wattage version of 

the lamp type was available due to the limited utility of 

reduced wattage lamps.

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine ELs

Scale Results
37

GSFL Systems

• To assess the performance of GSFLs, DOE used a systems approach 

and paired lamps with ballasts, capturing real-world energy use and 

light output. 

• Using manufacturer feedback and information from the 2011 

Ballast Rule, DOE determined the most common fluorescent lamp 

ballasts by starting method and number of lamps operated to 

establish lamp-and-ballast system pairings. 

Lamp Type Ballast Type

4-foot MBP

2-lamp IS, electronic

2-lamp PS, electronic

4-lamp IS, electronic

4-lamp PS, electronic

2-lamp IS for residential use, electronic

8-foot SP slimline 2-lamp IS, electronic

8-foot RDC HO 2-lamp IS, electronic

4-foot T5 MiniBP SO 2-lamp PS, electronic

4-foot T5 MiniBP HO 2-lamp PS, electronic
38

GSFL Systems

• DOE selected lamp-and-ballast systems that maintained mean lumen 

output within 10 percent of the baseline system when possible.

4-foot MBP Two-Lamp Programmed Start Lamp-and-Ballast Replacement

Efficacy 

Level

Lamp 

Diameter

Nominal 

Wattage

Rated 

Wattage

Rated 

Efficacy

Initial 

Lamp 

Light 

Output

Mean 

Lamp 

Light 

Output

Rated 

Life

Ballast 

Factor

System 

Input 

Power

BLE

System 

Mean 

Light 

Output

W W lm/W lm lm hr W lm

Baseline T8 32 32.5 89.2 2,900 2,725 40,000 0.88 56.0 91.2 4,796

EL 1 T8 32 32.5 90.0 2,925 2,770 30,000

0.88 56.0 91.2 4,875

0.72 47.1 88.7 3,989

EL 2 T8 25 26.6 93.0 2,475 2,350 40,000 0.88 47.0 90.6 4,136

EL 2 T8 32 32.5 95.4 3,100 2,945 40,000

0.88 56.0 91.2 5,183

0.72 47.1 88.7 4,241

EL 2 T8 28 28.4 96.0 2,725 2,590 40,000 0.88 50.4 90.9 4,558
39

Efficacy Levels: GSFLs

• The following are the proposed ELs:

CCT Lamp Type

Efficacy Levels at 25 °C

lm/W

1 2

≤ 4,500 K

4-foot MBP 90.0 92.4

8-foot SP slimline 98.2 99.0

8-foot RDC HO 94.0 97.6

4-foot T5 MiniBP SO 93.5 97.1

4-foot T5 MiniBP HO 82.7 N/A

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine ELs

Scale Results
40

Issues for Comment: GSFLs

Issue 5: Max Tech Levels

For GSFLs, DOE requests comment on the max tech levels identified in this analysis and 

more information on the accuracy of catalog and certification data which were used to 

identify these levels.

Issue 6: GSFL Efficacy Levels

DOE develops ELs based on three factors: (1) the design options associated with the 

specific lamps studied; (2) the ability of lamps across wattages to comply with the 

standard level of a given product class; and (3) the max tech EL. DOE requests comments 

on the methodology used to develop ELs for GSFLs as well as on the resulting ELs.

Issue 4: GSFL Systems

Because fluorescent lamps operate on a ballast in practice, DOE analyzed lamp-andballast systems in the engineering analysis, to more accurately capture real-world energy 

use and light output. DOE requests comments on its methodology for developing lampand-ballast systems as well as the results of these GSFL systems.
41

Scaling Results: GSFLs

• DOE scaled ELs to product classes not directly 

analyzed.

• Scaling factors for GSFLs account for differences in 

efficacy due to: higher CCT, shape (i.e., U-shaped).

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine ELs

Scale Results

Product Class Analyzed Not Analyzed Scaling Factor

CCT

4-foot MBP ≤ 4,500 K > 4,500 K 2% decrease

8-foot SP Slimline ≤ 4,500 K > 4,500 K 5% decrease

8-foot RDC HO ≤ 4,500 K > 4,500 K 2% decrease

4-foot T5 MiniBP SO ≤ 4,500 K > 4,500 K 6% decrease

4-foot T5 MiniBP HO ≤ 4,500 K > 4,500 K 5% decrease

2-foot U-shaped ≤ 4,500 K > 4,500 K 3% decrease

Shape 2-foot U-shaped 4-foot MBP 2-foot U-shaped 6% decrease
42

Issues for Comment: GSFLs

Issue 7: Scaling Factors

DOE develops scaling factors to scale the levels developed directly for the 

representative product classes and determine levels for product classes not analyzed 

directly. DOE requests comments on the scaling factors developed to scale GSFL 

product classes from the less than or equal to 4,500 K CCT lamps to the greater than 

4,500 K CCT lamps. DOE also requests comments on the scaling factor developed to 

scale from the 4-foot MBP product class to the 2-foot U-shaped product class. 
43

Issues for Comment: GSFLs

Issue 31: Impact on GSFL Utility/Performance

DOE requests comment on its assumption that there will be no lessening of utility or 

performance such that the performance characteristics, including lumen package, 

color quality, lifetime, and ability to dim, would be adversely affected for the GSFL 

efficacy levels. 

Issue 32: Impact on GSFL Features/Attributes

DOE requests comment on whether there are features or attributes, including physical 

constraints such as shape or diameter, of the more energy-efficient GSFL lamps that 

manufacturers would produce to meet the standards in this proposed rule that might 

affect how they would be used by consumers. DOE requests comment specifically on 

how any such effects should be weighed in the choice of standards for GSFLs for the 

final rule.
44

Representative Product Classes: IRLs

• DOE chooses representative product classes to 

concentrate its analytical effort.

– The representative product class (in darker green) was chosen 

on a basis of high market volume.

Spectrum Diameter (inches) Voltage

Standard

> 2.5 ≥ 125 V

< 125 V

≤ 2.5 ≥ 125 V

< 125 V

Modified

> 2.5 ≥ 125 V

< 125 V

≤ 2.5 ≥ 125 V

< 125 V

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine ELs

Scale Results
45

Baseline Lamps: IRLs

• The baseline model typically represents the most 

common, least efficacious model on the market for 

each representative product class.

Baseline Lamp Design Option

Initial Light 

Output

lm

Efficacy

lm/W

Lamp Lifetime

hr

60 W PAR38

Improved 

Halogen* 1,070 17.8 1,500

*Halogen lamp with an improved reflector.

Issue 8: Baseline Lamp

In the engineering analysis, DOE selects a baseline lamp as a reference 

point against which to measure changes resulting from energy 

conservation standards. DOE requests comments on the baseline 

lamp selected in this analysis for IRLs. 

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine ELs

Scale Results
46

More Efficacious Substitutes: IRLs

• DOE selected more efficacious replacement lamps to 

measure potential energy-saving improvements. 

• More efficacious replacement lamps were identified by 

lumen output within 10 percent of the baseline lamp 

when possible.

Substitute

Lamp

Design Option

Initial Light 

Output

lm

Efficacy**

lm/W

Lamp Lifetime

hr

55 W PAR38 HIR 980 18.5 2,500

55 W PAR38 Improved HIR* 1,120 18.5 4,200

*HIR lamp with an improved reflector.

**Efficacy values are based on data from DOE’s certification database.

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine ELs

Scale Results
47

Issues for Comment: IRLs

Issue 9: IRL Lifetimes

In the engineering analysis for IRLs, DOE observed lifetime changes for different 

technologies. DOE requests comment on the rated lifetimes of the baseline and more 

efficacious substitutes. 
48

Efficacy Levels: IRLs

• DOE used an equation-based approach to characterize a 

continuous relationship between lamp input power and 

lamp efficacy across wattages. 

• DOE used commercially available lamps and their 

associated catalog rated efficacies to determine ELs.

• To establish final minimum efficacy requirements for ELs, 

DOE analyzed publicly available compliance data and 

determined whether any adjustments were necessary to 

the initial EL. 

• The following is the proposed EL:

Efficacy Level Efficacy Requirement

lm/W

EL 1 6.2P0.27

P = wattage

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine ELs

Scale Results
49

Issues for Comment: IRLs

Issue 10: Max Tech Level

DOE requests comment on the max tech levels identified in this analysis and information 

on high efficacy IRLs including prototype lamps, specifically manufacturer costs and 

information on equipment required to produce high efficacy IRLs.
50

Scaling Results: IRLs

• DOE scaled ELs to product classes not directly analyzed.

• Scaling factors for IRLs account for difference in efficacy 

due to: spectrum, diameter, voltage. 

Analyzed Not Analyzed Scaling Factor

Spectrum Standard Modified 15% decrease

Diameter > 2.5 Inches ≤ 2.5 Inches 15.5% decrease

Voltage < 125 Volts ≥ 125 Volts 15% increase

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine ELs

Scale Results

Issue 11: Scaling between Product Classes

DOE has not found evidence that more efficacious small diameter, 

modified spectrum, or 130 V IRLs are not technologically feasible or 

practicable to manufacture, and therefore is proposing to increase 

efficacy levels for these lamp types. DOE requests comment on any 

technological barriers in manufacturing more efficacious small 

diameter, modified spectrum, or 130 V rated lamps for commercial 

production. 
51

Issues for Comment: IRLs

Issue 33: Impact on IRL Utility/Performance

DOE requests comment on its assumption that there will be no lessening of utility or 

performance such that the performance characteristics, including lumen package and 

lifetime, would be adversely affected for the IRL efficacy levels. 

Issue 34: Impact on IRL Features/Attributes

DOE requests comment on whether there are features or attributes, such as the shape 

or diameter, of the more energy-efficient IRL lamps that manufacturers would produce 

to meet the standards in this proposed rule that might affect how they would be used 

by consumers. DOE requests comment specifically on how any such effects should be 

weighed in the choice of standards for the IRLs for the final rule.
52

Issues for Comment: Engineering

Issue 1: Engineering Analysis

DOE requests comments on the overall methodology, assumptions, and results of the 

GSFL and IRL engineering analyses.
53

Product Price Determination

• DOE estimated the end-user prices of GSFLs and IRLs directly, rather 

than developing manufacturing selling prices, because these lamps 

are difficult to reverse-engineer (i.e., not easily disassembled).

• DOE developed three sets of discounts and corresponding prices, 

depending on the observed distribution channels for GSFLs and IRLs: 

– Low Price (State procurement, High Discount)

– Medium (Large distributors, including do-it-yourself stores, Medium Discount)

– High (Internet retailers, Low Discount)

• Based on shipment estimates through each channel, DOE applied 

85% to the large distributor price, 10% to the state procurement 

price, and 5% to the internet retail price to develop a weighted 

average end-user price used in the main LCC and NIA. 

• DOE used information from the 2011 Ballast Rule to determine enduser prices for fluorescent lamp ballasts. 
54

Issue 12: Product Price Determination

Because GSFLs and IRLs are difficult to reverse-engineer (i.e., not easily disassembled), 

DOE directly estimated end-user prices for lamps by establishing discounts from 

manufacturer suggested price lists. DOE requests feedback on the pricing methodology 

used in this analysis. 

Issues for Comment: Product Price Determination
55

Presentation Overview

Energy Use; Life-Cycle Cost Analysis

Shipments; National Impact Analysis

5

6

2 Market & Technology; Screening Analysis

Engineering Analysis, Product Price 

Determination 3

1 Overview; Scope of Coverage

7 Manufacturer Impact Analysis

4 Trial Standard Levels

Emissions, Utility, Employment, and Regulatory 

Impacts

Proposed Standard

8

9
56

GSFL Trial Standard Levels Analyzed

TSL 1 Least efficacious lamps on the market1

TSL 2 Same level of rare earth phosphor in all product classes

TSL 3 Max national energy savings (NES) without going to EL 2 on any product

TSL 4 Max consumer net present value (NPV)

TSL 5 Max Tech and Max NES (PROPOSED)

Trial Standard Level (TSL) Descriptions

IRL Trial Standard Level Analyzed

TSL 1 Max Tech (PROPOSED)

1There are currently no 8-foot RDC HO, T5 MiniBP SO or T5 MiniBP HO lamps on the market with efficacies at the baseline level. 

This TSL sets the standard for these lamps at an EL corresponding to the least efficacious lamps currently on the market.
57

Trial Standard Levels

GSFL Representative Product Classes

TSL 1

Current 

Market 

Min

TSL 2

Rare Earth 

Phosphor 

Level

TSL 3

Best NonEL 2

TSL 4

Max

NPV

TSL 5

Max

Tech

4-foot MBP, ≤ 4500K 0 0 1 2 2

8-foot SP slimline, ≤ 4500K 0 1 0 0 2

8-foot RDC HO, ≤ 4500K 1 2 1 1 2

4-foot T5 MiniBP SO, ≤ 4500K 1 1 1 1 2

4-foot T5 MiniBP HO, ≤ 4500K 1 1 1 1 1

IRL Representative Product Class TSL 1

Standard spectrum; > 2.5 inch diameter; < 125 V 1
58

Presentation Overview

Energy Use; Life-Cycle Cost Analysis

Shipments; National Impact Analysis

5

6

2 Market & Technology; Screening Analysis

Engineering Analysis, Product Price 

Determination 3

1 Overview; Scope of Coverage

7 Manufacturer Impact Analysis

4 Trial Standard Levels

Emissions, Utility, Employment, and Regulatory 

Impacts

Proposed Standard

8

9
59

Energy Use Characterization

• Annual energy consumption (kWh) 

= system input power x annual operating hours

• DOE used various sources to determine annual operating hours: 

- 2010 U.S. Lighting Market Characterization (LMC), 2011

- Energy Information Administration (EIA) Commercial Building Energy 

Consumption Survey (CBECS), 2003

- EIA Residential Energy Consumption Survey (RECS), 2009

- EIA Manufacturing Energy Consumption Survey (MECS), 2006

• DOE’s assumed annual operating hours capture variation across 

census divisions and large states, building types, lamp types, and 

lighting applications.

Sector

GSFL Average Annual

Operation

(hrs/yr)

IRL Average Annual

Operation

(hrs/yr)

Commercial 4,065 4,532

Residential 634 763

Industrial 4,587 N/A
60

Energy Use Characterization: Lighting Controls

• In a sensitivity analysis, DOE assessed impacts on life-cycle costs and 

payback periods for GSFLs and IRLs when operated on dimming systems. 

• To develop annual energy consumption for these dimming systems, DOE 

used the system input power ratings as a result of dimming and annual 

operating hours. 

• DOE made certain key assumptions to determine system input power 

ratings for dimmed GSFLs and IRLs. 

– GSFLs: On average a 33% lumen reduction (lamp-and-ballast); associated 

system input power reduction calculated based on characteristics of dimming 

ballasts analyzed; no change in lamp lifetime. 

– IRLs: On average a 20% wattage reduction, corresponding to a 25% reduction 

in lumens, and a lifetime multiplier of 3.94.

• For IRLs, DOE also assessed a scenario in which a certain percentage of the 

population used dimmers. DOE assumed this to be 29% for the residential 

sector and 5% for the commercial sector. 
61

LCC and PBP

• The life-cycle cost (LCC) analysis provides an economic evaluation 

from the end-user perspective.

• LCC equals end-user price plus the sum of annual operating costs 

discounted to a particular base year.

• If the lamp has remaining useful life at the end of the analysis 

period, a residual value is subtracted from the LCC.

• Results are expressed as LCC savings (baseline minus the standard 

level).

• Simple payback period (PBP) is also calculated and reported in this 

analysis.

LCC Results First Cost

(End-User Price + Installation Cost)

Operating Expenses

Convert to 

Present 

Value
62

LCC and PBP: Inputs

• DOE derived electricity prices and projections from 2011 EIA form 861 

data and EIA Annual Energy Outlook 2013 (AEO 2013).

• DOE based installation costs on labor time and labor rate data from 

the 2011 Ballast Rule, RS Means, and the U.S. Bureau of Labor 

Statistics.

• DOE assumed ballast lifetimes of 49,054 hours (commercial & 

industrial) and 9,514 hours (residential).

- Translates to approximately 12 years (commercial), 11 years (industrial), and 15 

years (residential)

- Consistent with the 2011 Ballast Rule and available “life measure” studies

• DOE calculated weighted-average discount rates from estimates for 

cost of capital (commercial & industrial) and estimates of interest 

(“finance cost”) to purchase residential products.

- Commercial = 5.1%

- Industrial = 6.3%

- Residential = 5.2%
63

LCC and PBP: Probability Updates

• In the NOPR, DOE determined the probability of a GSFL or IRL in a 

particular building type (whereas the Preliminary Analysis used 

building type alone) in each census division and large state using data 

published in the 2010 LMC in combination with CBECS, MECS, and 

RECS to determine a weighted average for:

- Electricity prices

- Sales tax

- Operating hours

Issue 13: Electricity Prices in the LCC Analysis

DOE used data published in the 2010 LMC in combination with CBECS, MECS, and RECS 

to determine an average weighted electricity price based on the probability of a GSFL or 

IRL in a particular building type in each census division and large state. DOE requests 

comment on its methodology of determining average weighted electricity prices in the 

LCC. 
64

LCC and PBP: Lamp Purchasing Events

• Event I: Lamp Failure

– The lamp fails and must be replaced.

• Event II: Ballast Failure (GSFLs only)

– The failure of the installed ballast triggers a lamp and ballast purchase.

• Event III: New Construction and Renovation

– New fixture installations where the lighting design can be completely new or 

changed.

Issue 14: Lamp Purchasing Events

DOE determined LCC savings and PBP results for different scenarios where consumers 

need to purchase a lamp (i.e., lamp failure, ballast failure, and new construction and 

renovation for GSFLs and lamp failure and new construction and renovation for IRLs). 

DOE requests comments on these lamp purchasing events developed for this analysis. 
65

Issues for Comment: LCC and PBP

Issue 16: LCC Analysis Period

DOE requests comment on its LCC analysis period assumptions. In particular, DOE 

requests comment on basing the analysis period on the baseline lamp life divided by 

the annual operating hours of that lamp for the IRL and the commercial and industrial 

sector GSFL analyses. DOE also requests comment on basing the analysis period on the 

useful life of the baseline lamp for a specific event for residential GSFLs. 

Issue 15: Lifetime Assumptions in the LCC Analysis

DOE conducts the LCC and PBP analyses over the lifetime of the product. DOE 

considered the impact of group relamping practices on GSFL lifetime in the commercial 

and industrial sectors. DOE requests comment on its spot and group relamping 

assumptions, particularly the percent of rated life at which group relamping occurs 

(85%). DOE also requests comment on its general approach to determining lamp 

lifetime for this analysis. 
66

GSFL LCC Results at Proposed Level: 4-ft MBP

Baseline Efficacy 

Level

LCC Savings

Event I: Lamp Failure

Event II: Ballast Failure 

and Event III: New 

Construction and 

Renovation

Weighted 

Average

4-foot MBP, 2-Lamp, Instant Start EL 2 -9.55 to 6.36 0.81 to 6.72

3.14*

4-foot MBP, 2-Lamp, Programmed Start EL 2 -9.55 to 16.09 -9.55 to 18.93

4-foot MBP, 4-Lamp, Instant Start EL 2 -19.10 to 11.58 1.05 to 11.35

4-foot MBP, 4-Lamp, Programmed Start EL 2 -19.10 to 32.08 -7.79 to 36.66

4-foot MBP, 2-Lamp, Instant Start, 

Residential Sector EL 2 -9.55 to -2.08 -7.17 to 0.06

* Weighted by shares of each product class in total projected shipments in 2017.
67

GSFL LCC Results at Proposed Level: 4-ft MBP (cont.)

• EL 2, Lamp Replacement, Commercial and Industrial

- Negative LCC savings for replacements with same wattage and ballast factor as 

baseline; Positive LCC savings for all others

• EL 2, Lamp-and-Ballast Replacement, Commercial and Industrial

- 2-lamp and 4-lamp IS: Positive LCC savings

- 2-lamp PS: Negative LCC savings for replacements with same wattage and 

ballast factor as baseline; Positive LCC savings for all others

- 4-lamp PS: Negative LCC savings for replacements with same wattage as 

baseline; Positive LCC savings for all others

• EL 2, Lamp Replacement, Residential

- Negative LCC savings

• EL 2, Lamp-and-Ballast Replacement, Residential

- Negative LCC savings except for one representative unit with positive LCC 

savings
68

GSFL LCC Results at Proposed Level: 4-ft T5 MiniBP HO

Product Class Efficacy Level

LCC Savings

Event I: Lamp Failure

Event II: Ballast 

Failure and Event III: 

New Construction 

and Renovation

Weighted Average

4-foot T5 MiniBP HO EL 1 -8.02 to 18.66 -8.02 to 18.66 2.28*

• EL 1, Lamp Replacement

- Negative LCC savings for replacements with same wattage and ballast factor as 

baseline; Positive LCC savings for all others

• EL 1, Lamp-and-Ballast Replacement

- Negative LCC savings for replacements with same wattage and ballast factor as 

baseline; Positive LCC savings for all others

* Weighted by shares of each product class in total projected shipments in 2017.
69

GSFL LCC Results at Proposed Level: 4-ft T5 MiniBP SO

Product Class Efficacy Level

LCC Savings

Event I: Lamp Failure

Event II: Ballast 

Failure and Event III: 

New Construction 

and Renovation

Weighted Average

4-foot T5 MiniBP SO EL 2 -6.22 to 5.68 7.18 to 22.42 2.76*

• EL 2, Lamp Replacement

- Commercial: Negative LCC savings for replacement with same wattage and 

ballast factor as baseline; Positive LCC savings for all others

- Industrial: Negative LCC savings for replacement with same wattage and ballast 

factor as baseline; Others: one positive LCC savings, one negative LCC savings

• EL 2, Lamp-and-Ballast Replacement

- Positive LCC savings

* Weighted by shares of each product class in total projected shipments in 2017.
70

GSFL LCC Results at Proposed Level: 8-foot SP slimline 

Product Class Efficacy Level

LCC Savings

Event I: Lamp Failure

Event II: Ballast 

Failure and Event III: 

New Construction 

and Renovation

Weighted Average

8-foot SP slimline EL 2 -8.63 to 2.36 -5.33 to 16.35 2.08*

• EL 2, Lamp Replacement

- Negative LCC savings except for one representative unit in the commercial sector 

with positive LCC savings

• EL 2, Lamp-and-Ballast Replacement

- Positive LCC savings except for one representative unit in the industrial sector 

with negative LCC savings

* Weighted by shares of each product class in total projected shipments in 2017.
71

GSFL LCC Results at Proposed Level: 8-foot RDC HO

Product Class Efficacy Level

LCC Savings

Event I: Lamp Failure

Event II: Ballast 

Failure and Event III: 

New Construction 

and Renovation

Weighted Average

8-foot RDC HO EL 2 -16.77 to -16.76 -16.77 to -16.76 -16.76*

• EL 2, Lamp Replacement

- Negative LCC savings

• EL 2, Lamp-and-Ballast Replacement

- Negative LCC savings

* Weighted by shares of each product class in total projected shipments in 2017.
72

IRL LCC Results at Proposed Level

EL 1 Representative Unit Efficacy Level

LCC Savings

Event I: Lamp Failure or 

Event III: New 

Construction and 

Renovation

Weighted Average

2,500 Hour 55 W HIR EL 1 2.65 to 3.44

2.95* 4,200 Hour 55 W Improved 

HIR EL 1 4.49 to 5.94

• EL 1, HIR

- Positive LCC savings

• EL 1, Improved HIR

- Positive LCC savings

* Weighted by shares of each product class in total projected shipments in 2017.
73

LCC Subgroup Analysis

• DOE examined two subgroups for the LCC Subgroup Analysis

– Low-Income Consumers

• EIA RECS data for consumers below the poverty line

• Using this EIA RECS data changed the probabilities of a GSFL or IRL within each 

building type and division or large state for the residential sector. These probabilities 

are used as inputs to the operating hours, electricity prices, and sales tax calculations

• Sign of LCC savings remained the same as main analysis in all cases

– Institutions that Serve Low-Income Populations

• Small non-profit groups

• Commercial discount rate of 9.6% (versus average discount rate of 5.1%)

• Sign of LCC savings remained the same except for the following, which shifted from 

positive to negative savings:

– 4-foot T5 MiniBP SO Product Class: Lamp replacement, EL 2, 26 W T5

– 8-foot SP Slimline Product Class: Lamp replacement and lamp-and-ballast 

replacement, EL 2, 50 W T8
74

Presentation Overview

Energy Use; Life-Cycle Cost Analysis

Shipments; National Impact Analysis

5

6

2 Market & Technology; Screening Analysis

Engineering Analysis, Product Price 

Determination 3

1 Overview; Scope of Coverage

7 Manufacturer Impact Analysis

4 Trial Standard Levels

Emissions, Utility, Employment, and Regulatory 

Impacts

Proposed Standard

8

9
75

Shipments and National Impact Analyses

Engineering 

Analysis

Product Price 

Determination

Energy Use & 

End Use Load 

Characterization

NIA Shipments 

Analysis

• Shipments Analysis

– Estimates GSFL-IRL shipments over the 30-year analysis period (2017-2046)

• National Impact Analysis

– Estimates the National Energy Savings (NES) from those shipments at various 

trial standards levels

– Estimates the Net Present Value (NPV) to GSFL-IRL consumers of the savings 

from those shipments at the various trial standards levels
76

Shipments Analysis

The Consumer Choice Module 

projects market shares by 

product class and efficiency 

level, based on consumer 

sensitivity to price and to 

operating and maintenance 

costs, computed per kilolumen.

Lumen 

Demand 

Module

 $1.00

 $5.75 0.00

0.50

1.00

 $1.00

 $3.25

 $5.25

 $7.25

 $9.25

O&M Cost ($/klm)

Probability

First Cost ($/klm)

Consumer Choice Module

Price 

Learning 

Module

To LEDs

First Cost

O&M Cost

PC 1 Shipments 

and lamp Market 

Shares

Renovations 

and new 

construction

Lamp 

Replacements

Details on the shipments analysis can be found in chapter 11 of the TSD.

PC 2 Shipments 

and lamp 

Market Shares
77

Shipments Analysis: Lumen Demand

LEDs are expected to erode the total lumen demand1satisfied both by 

GSFLs and IRLs. This is treated as an exogenous envelope on the 

shipments model.

GSFL LED (from GSFL)

LED (from IRL)

IRL

1 LED incursion based on projections from Energy Savings Potential of Solid-State Lighting in 

General Illumination Applications, NCI, DOE, 2012.
78

Shipments Analysis: GSFL Relamping

Probability of Relamping Ballast

Ballasts are populated with new lamps based on ballast age and the 

probability curves below. Consumers are assumed to remain in the 

same product class if they are simply replacing a failed lamp.

Peak for each curve occurs at 

average lifetime of a lamp 

installed on a given ballast

New ballasts always 

accompanied by new 

lamps
79

Shipments Analysis: Price Learning

*Price learning is not applied to the cost of a GSFL associated with rare earth 

elements. Rare earth price uncertainty is treated in a separate analysis.

Decreases in product price are accounted for by incorporating learning 

curves.

*
80

Shipments Analysis: Product Class Switching

Product class switching can occur in the consumer choice module when 

renovations and retrofits are undertaken. This can result in different 

market shares in the standards cases compared to the base case.

4-ft MBP 8-ft Slimline T8 T5 SO

Base Case TSL 5
81

Shipments Analysis: Reference Case

Shipments over the analysis period in the reference case for representative lamp types

Plots for all TSLs and shipments scenarios can be viewed in the NIA spreadsheet 

tool.

Shipments decline 

because of LED incursion

4ft MBP

T5 SO

T5 HO

8-ft Slimline

8-ft HO

IRL
82

Issues for Comment: Shipment Analysis

Issue 30: T5 Market Share and Product Class Switching

DOE seeks comment on the reasonableness of its shipment project for TSL 5, 

specifically, that standard output T5 lamps could increase from 3-4 % of the standard 

output GSFL market presently, to approximately 13 % of the same market by 2020, and 

approximately 30 % of the much attenuated (due to LED incursion) standard output 

GSFL market by 2046.

Issue 35: Product Class Switching

DOE requests comment on the consumer choice model that projects shifts in shipments 

between product classes and whether there are other factors (e.g. utility, costs to 

replace light fixtures, design incompatibility) that may preclude or limit that shifting that 

may not be considered in DOE’s analysis. 

Issue 29: First Costs as Consumer Choice Drivers

For the proposed GSFL standards, DOE requests comment on the reasonableness of its 

assumption that first cost is a significant driver of consumers' choice of product class, 

which results in the shipments analysis projecting a rapid shift from 4-foot MBP T8s to 

standard output T5s in the TSL 5 standards case. The TSL 5 standards case substantially 

increases first cost for 4-foot MBP T8s. 
83

National Impact Analysis

Where:

NES(y) = National Energy Savings in year y (quads)

AECbase(y) = base case annual national energy consumption in year y (quads)

AECstd(y) = standards case annual national energy consumption in year y (quads)

RF = rebound factor

μ(y) = full fuel cycle multiplier

National Energy Savings (primary) is calculated using the following equation:

National Net Present Value is calculated using the following equation. NPV was 

calculated using 3% and 7% discount rates:

NPV = PVS − PVC

NES y = AECbase y − AECstd y × RF × μ(y)

Where:

NPV = National net present value (2012$)

PVS = present value of operating cost savings (2012$)

PVC = present value of increase in total installed cost (2012$)
84

GSFL: NIA and Emissions Results

TSL 1 TSL 2 TSL 3 TSL 4 TSL 5

National Energy Savings FFC (quads) 0.21 0.21 0.89 3.0 3.5

CO2 Emissions Reductions (million metric tons) 10 10 44 150 170

NOX Emissions Reductions (thousand tons) 13 13 54 180 210

NPV 7% Discount Rate (billion 2012$) -0.39 -0.48 0.23 3.2 3.1

NPV of CO2(billion 2012$) * 0.35 0.35 1.5 4.9 5.6

NPV of NOX(billion 2012$) 0.01 0.01 0.05 0.2 0.2

Net Social Benefit 7% Discount Rate (billion 2012$) -0.03 -0.12 1.8 8.3 8.9

NPV 3% Discount Rate (billion 2012$) -0.49 -0.63 1.0 8.1 8.1

NPV of CO2(billion 2012$) * 0.35 0.35 1.5 4.9 5.6

NPV of NOX(billion 2012$) 0.02 0.02 0.09 0.3 0.3

Net Social Benefit 3% Discount Rate -0.12 -0.26 2.6 13.3 14

Details on the NIA can be found in chapter 12 of the TSD.

NES, NPV, and Emissions at 3% and 7%, for the 30 year analysis period, for all TSLs.

* Based on Social Cost of Carbon of $39.7 per metric ton for CO2.
85

National Impact Analysis: GSFL Reference Case

Plots for all TSLs and shipments scenarios can be viewed in the NIA spreadsheet tool.

GSFL Annual Energy Savings, TSL 5 GSFL Cumulative NPV, TSL 5
86

IRL: Overall Results

Full fuel cycle NES and NPV, at 3 and 7 percent, for the 30 year analysis period.

TSL 1

National Energy Savings FFC (quads) 0.013

CO2 Emissions Reductions (million metric tons) 0.70

NOX Emissions Reductions (thousand tons) 0.79

NPV 7% Discount Rate (billion 2012$) 0.18

NPV of CO2(billion 2012$) * 0.025 

NPV of NOX(billion 2012$) 0.001

Net Social Benefit 7% Discount Rate (billion 2012$) 0.21

NPV 3% Discount Rate (billion 2012$) 0.28

NPV of CO2(billion 2012$) * 0.025

NPV of NOX(billion 2012$) 0.002

Net Social Benefit 3% Discount Rate 0.31

* Based on Social Cost of Carbon of $39.7 per metric ton for CO2.
87

National Impact Analysis: IRL Reference Case

IRL Annual Energy Savings, TSL 1 IRL Cumulative NPV, TSL 1

Plots for all TSLs and shipments scenarios can be viewed in the NIA spreadsheet tool.
88

Alternative Shipments Analyses

Scenario Name Reference Assumption Alternative Assumption

Sensitivity Analyses

Rare earth oxide prices (higher 

assumed price)

Prices fixed at October 2013

levels.

High REO Prices: 3.4 times the 

October 2012 price

Xenon prices (higher assumed 

price)

Xenon prices remain at current 

levels throughout the analysis 

period

High Xe: Xe prices rise to 10 times 

current levels and remain for the 

analysis period.

Alternative technology (IRL 

lifetimes)

TSL 1 IRLs are all 55-watt lamps

with 2500 and 4200 hour 

lifetimes.

Short life: One 60 W lamp 

modeled to meet TSL 1 with 

lifetimes of 1,046.

Impact Analyses

LED market incursion Increasing LED incursion. No LED: No additional LED 

incursion

Lighting controls penetration

Growth of commercial controls 

determined by today’s building 

codes.

Fixed: Constant controls 

penetration at today’s level

Analysis Period 30-year analysis period (2017-

2046)

9-year Analysis: 2017-2026 

analysis period.
89

Alternative Analyses: High REO Prices

Rare earth oxide price indices used in alternative analysis

GSFL TSL 5 Reference High REO Change

NES FFC (quads) 3.46 3.64 5.2%

NPV (3%, billion 2012$) 8.08 8.51 5.3%

NPV (7%, billion 2012$) 3.13 3.31 5.8%

High REO price assumption
90

Alternative Analyses: High Xenon Price, Short IRL Life

IRL TSL 1

Reference Short Life Change

NES FFC (quads) 0.01 0.01 -9.5%

NPV (3%) (billion 2012$) 0.28 0.11 -60%

NPV (7%) (billion 2012$) 0.18 0.06 -66%

IRL High Xe price alternative scenario results

IRL TSL 1

Reference High Xe Change

NES FFC (quads) 0.01 0.01 -23%

NPV (3%) (billion 2012$) 0.28 0.28 0.44%

NPV (7%) (billion 2012$) 0.18 0.18 2.9%

IRL short life alternative scenario results
91

Issues for Comment: NIA

Issue 19: Rare Earth Oxides

DOE assumes in its reference shipment and NIA analyses that the future real price of 

rare earth oxides used in GSFLs will remain near current levels on average. In an 

alternative scenario analysis, DOE assumes that the future price of REOs is 3.4 times the 

current price on average, owing to market forces outside the rulemaking. Further, DOE 

estimates that the proposed standards would cause a maximum annual increase in 

demand for REOs of 296 tons in 2017, with lower demand increases in later years. DOE 

welcomes input on the reasonableness and appropriateness of these estimates and 

assumptions. 

Issue 20: Xenon Gas Price

DOE assumes in its reference shipments and national impacts analyses that the future 

price of xenon gas will remain near current levels on average. DOE further assumes in an 

alternative-scenario analysis that the future price of xenon gas may rise but that it is not 

likely to exceed ten times the current price on average. DOE welcomes input on the 

reasonableness and appropriateness of these assumptions. 
92

Reference Fixed Controls

Alternative Analyses: Fixed Controls*

Dimming Controls Switching Controls Total Lighting Capacity

Reference Fixed Controls

GSFL TSL 5 IRL TSL 1

Reference Fixed

Controls Change Reference FixedControls Change

NES FFC (quads) 3.46 3.18 -8.1% 0.01 0.01 0.79%

NPV (3%) (billion 2012$) 8.08 7.69 -4.8% 0.28 0.28 0.25%

NPV (7%) (billion 2012$) 3.13 2.98 -4.8% 0.18 0.18 0.27%

*DOE does not consider this scenario to be realistic; it is presented to show the impact of controls incursion on the analysis.

Lighting Capacity Under Controls
93

Issues for Comment: NIA

Issue 18: Reduced Wattage Lamps

DOE assumes in its shipments and NIA analyses that reduced wattage 4-ft MBP lamps 

can be coupled to dimming ballasts, but it assumes that no individual reduced wattage 

lamp option will be coupled to more than 10 % of the dimming ballasts in the installed 

stock, owing to performance problems that may arise in some applications. DOE 

welcomes input on the reasonableness and appropriateness of these assumptions. 

Issue 21: Controls

To improve DOE’s estimates of the potential impact of lighting controls on this 

rulemaking, DOE seeks input on the current fraction of GSFL ballast shipments that are 

dimming ballasts and the likely rate of growth of dimming ballasts in the future
94

NIA 

Scenarios 

Variables

Best Estimate Alternatives

Change from 

Reference Case, TSL 5 

(TSL 1 for IRL)

AEO Growth:

Affects only 

NPV

Ref: Electricity 

prices follow 

AEO’s reference 

economic growth 

projections.

AEO Low: Electricity prices 

follow AEO’s low economic 

growth projections.

NPV

3% discount -5.9%

7% discount -6.6%

AEO High: Electricity prices 

follow AEO’s high 

economic growth 

projections.

3% discount 10%

7% discount 13%

Rebound

Rate:

Affects only 

NES

Ref: Rebound 

rates for 

residential and 

commercial 

sectors set to 0%

Framework: Residential 

8.5%, Commercial 1%

NES

-1%

High: Residential and 

Commercial 15% -15%

Other Alternative Analyses

DOE also performed alternative analyses to assess uncertainty arising 

from the AEO economic growth rate and the rebound rate. These affect 

the NIA and not the shipments.
95

Issues for Comment: NIA

Issue 22: Rebound

DOE assumed zero direct rebound effect for efficiency improvements in GSFLs and IRLs, 

and conducted sensitivity analyses with alternative rebound rates. DOE welcomes 

comment on its assumptions and methodology for estimating the rebound effect 

including potential magnitudes of rebound effects.

Issue 17: Analysis Period

For this rulemaking, DOE analyzed the effects of this proposal assuming that the GSFLs 

and IRLs would be available to purchase for 30 years (consistent with other 

rulemakings) and undertook a sensitivity analysis using 9 years (a proxy for the timeline 

in EPCA for the review of certain products). DOE is seeking input, information and data 

on whether there are ways to refine the analytic timeline. 
96

Presentation Overview

Energy Use; Life-Cycle Cost Analysis

Shipments; National Impact Analysis

5

6

2 Market & Technology; Screening Analysis

Engineering Analysis, Product Price 

Determination 3

1 Overview; Scope of Coverage

7 Manufacturer Impact Analysis

4 Trial Standard Levels

Emissions, Utility, Employment, and Regulatory 

Impacts

Proposed Standard

8

9
97

MIA Overview

• Purpose

– To assess the 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; 

– To examine the impacts of standards on direct employment and 

manufacturing capacity; and

– To examine the cumulative regulatory impact on the 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 sub-group 

analysis, and address qualitative issues.
98

MIA Methodology

• Phase 1

– DOE creates an industry profile to characterize the market and identify 

important issues that require further investigation.

• Phase 2

– DOE prepares an industry cash-flow model and an interview questionnaire to 

guide subsequent discussions with manufacturers.

• Phase 3

– DOE interviews manufacturers and assesses the impacts of standards both 

quantitatively (using the Government Regulatory Impact Model) and 

qualitatively (impacts on competition, manufacturing capacity, employment, 

and regulatory burden).

Industry 

profile

Develop strawman GRIM

Develop 

interview 

guide

Interviews

& industry 

wide/

subgroup

analysis

Assess direct 

employment, 

competition, 

cumulative 

burdens

Phase 1 Phase 2 Phase 3
99

MIA Key Issues

• Rare Earth Oxides (REOs) in GSFLs

– Increasing the efficacy of GSFLs could require using significantly more REOs in 

GSFLs.

– This could result in another significant price increase of REOs, similar to that in 

2011.

• Impact of 2012 GSFL and IRL Energy Conservation Standards

– Manufacturers already made significant capital investments in order to comply 

with GSFL and IRL standards that went into effect in 2012.

– Amended standards could strand these substantial investments, as 

manufacturers have not fully recouped these costs.

• Technology Shift

– The market is already shifting to LEDs and these standards could cause 

manufacturers to divert resources away from the R&D of more efficacious 

lighting technologies with greater energy saving potential.
100

MIA Scenarios Analyzed

• DOE Modeled Two Markup Scenarios for GSFLs and IRLs.

– Flat Markup Scenario

– Preservation of Operating Profit Markup Scenario

• Least Severe for Manufacturers – Flat Markup Scenario

– In the flat markup scenario manufacturers fully pass through additional costs 

to their consumers and maintain their gross margin percentage in the 

standards case.

• Most Severe for Manufacturers – Preservation of Operating Profit 

Markup Scenario

– In the preservation of operating profit markup scenario manufacturers 

maintain the same total operating profit in absolute dollars in the standards 

case as in the base case, despite a higher level of investment. 
101

MIA INPV Results - GSFL

• Flat Markup (Least Severe for Manufacturers)

• Preservation of Operating Profit (Most Severe for Manufacturers)

Units Base 

Case

Trail Standard Level

1 2 3 4 5

INPV (2012$ millions) 1,542.5 1,584.4 1,580.3 1,663.1 1,901.1 1,939.7

Change in INPV

(2012$ millions) - 41.8 37.8 120.5 358.5 397.1

(%) - 2.7% 2.5% 7.8% 23.2% 25.7%

Product Conversion Costs (2012$ millions) - 0.9 2.0 5.3 7.5 9.1

Capital Conversion Costs (2012$ millions) - 1.0 11.0 3.0 5.5 29.5

Total Conversion Costs (2012$ millions) - 1.9 13.0 8.3 13.0 38.6

Units Base 

Case

Trail Standard Level

1 2 3 4 5

INPV (2012$ millions) 1,542.5 1,541.7 1,533.4 1,531.0 1,519.6 1,502.6

Change in INPV

(2012$ millions) - (0.9) (9.2) (11.5) (22.9) (39.9)

(%) - -0.1% -0.6% -0.7% -1.5% -2.6%

Product Conversion Costs (2012$ millions) - 0.9 2.0 5.3 7.5 9.1

Capital Conversion Costs (2012$ millions) - 1.0 11.0 3.0 5.5 29.5

Total Conversion Costs (2012$ millions) - 1.9 13.0 8.3 13.0 38.6
102

MIA INPV Results - IRL

• Flat Markup (Least Severe for Manufacturers)

• Preservation of Operating Profit (Most Severe for Manufacturers)

Units Base Case

Trail Standard Level

1

INPV (2012$ millions) 176.0 128.6

Change in INPV

(2012$ millions) - (47.5)

(%) - -27.0%

Product Conversion Costs (2012$ millions) - 6.1

Capital Conversion Costs (2012$ millions) - 65.4

Total Conversion Costs (2012$ millions) - 71.5

Units Base Case

Trail Standard Level

1

INPV (2012$ millions) 176.0 124.2

Change in INPV

(2012$ millions) - (51.8)

(%) - -29.5%

Product Conversion Costs (2012$ millions) - 6.1

Capital Conversion Costs (2012$ millions) - 65.4

Total Conversion Costs (2012$ millions) - 71.5
103

MIA Small Business Impacts

• DOE identified up to 21 potential GSFL small businesses and up to 15 

potential IRL small businesses.

– Since most small businesses are not the original manufacturers of GSFLs or 

IRLs, nor do they own the equipment used to produce GSFLs and IRLs, most 

small businesses will not have any capital conversion costs due to standards.

– However, since all small businesses have lower sales volumes, their product 

conversion costs are estimated to be significantly larger on a percentage of 

revenue basis compared to large manufacturers.

– Small businesses may not be able to pass on these higher per unit product 

conversion costs since market competition forces them to keep prices low.

• Some small businesses might not be able to or might choose not to 

make the investments necessary to meet the proposed standards.

Issue 36: Regulatory Flexibility Analysis

The Regulatory Flexibility Act requires DOE to determine if the proposed standards will 

have a significant economic impact on a substantial number of small entities. DOE 

requests comment on the potential impacts to GSFL and IRL small businesses at the 

proposed efficacy levels.
104

Issues for Comment: MIA

Issue 23: Distribution Chain Markup

To calculate the MSP, in the MIA, DOE determined the distribution chain markup for 

the GSFL and IRL industries. DOE invites comment on its methodology of using a 1.52 

distribution chain markup in combination with the medium end-user price to estimate 

the MSP of all GSFLs and IRLs.

Issue 26: Direct Domestic Manufacturing Impact

DOE quantitatively assessed the impacts of standards on direct employment. DOE 

seeks comment on the potential domestic employment impacts to GSFL and IRL 

manufacturers at the proposed efficacy levels.

Issue 24: Conversion Costs for IRL Manufacturers

As part of the MIA, DOE estimates the product and capital conversion costs that all 

manufacturers must make to comply with potential standards. DOE requests comment 

on the $6.1 product industry conversion costs and $65.4 capital industry conversion 

costs necessary for IRL manufacturers to comply with the proposed standards.
105

Issues for Comment: MIA

Issue 27: Cumulative Regulatory Burden Analysis

DOE seeks comment on the compliance costs of any other regulations GSFL or IRL 

manufacturers must make, especially if those regulations take place three years before 

or after the estimated compliance date of these proposed standards (2017).

Issue 28: Mercury Content of GSFLs in Response to GSFL Standards

DOE seeks comment on GSFL manufacturers potentially increasing the amount of 

mercury in GSFLs in order to comply with the proposed GSFL standards.
106

Presentation Overview

Energy Use; Life-Cycle Cost Analysis

Shipments; National Impact Analysis

5

6

2 Market & Technology; Screening Analysis

Engineering Analysis, Product Price 

Determination 3

1 Overview; Scope of Coverage

7 Manufacturer Impact Analysis

4 Trial Standard Levels

Emissions, Utility, Employment, and Regulatory 

Impacts

Proposed Standard

8

9
107

Emissions Analysis

• DOE estimates the cumulative emissions reductions resulting from amended 

energy conservation standards. DOE considers full-fuel-cycle emissions. 

Thus, both power plant emissions and “upstream” emissions are included in 

the analysis.

– Includes fugitive methane emissions.

Trial Standard Level

1 2 3 4 5

CO2(million metric tons) 10 10 44 150 170

NOx(thousand tons) 13 12 54 180 210

Hg (tons) 0.020 0.019 0.083 0.28 0.32

N2O (thousand tons) 0.17 0.16 0.71 2.5 2.8

CH4(thousand tons) 44 43 190 640 730

SO2(thousand tons) 15 15 65 220 250

Cumulative Emissions Reduction for Potential Standards of GSFLs

Details of the Analysis can be found in chapter 14 of the TSD.
108

Emissions Analysis

• DOE estimates the cumulative emissions reductions resulting from amended 

energy conservation standards. DOE considers full-fuel-cycle emissions. 

Thus, both power plant emissions and “upstream” emissions are included in 

the analysis.

– Includes fugitive methane emissions.

Trial Standard Level

1

CO2(million metric tons) 0.70

NOx(thousand tons) 0.79

Hg (tons) 0.0012

N2O (thousand tons) 0.0099

CH4(thousand tons) 2.7

SO2(thousand tons) 0.69

Cumulative Emissions Reduction for Potential Standards of IRLs

Details of the Analysis can be found in chapter 14 of the TSD.
109

Emissions Analysis: Monetization

• DOE uses the most current Social Cost of Carbon (SCC) values developed 

by interagency process.

- SCC is intended to be a monetary measure of the incremental damage resulting from 

greenhouse gas (GHG) emissions, including, but not limited to, agricultural productivity 

loss, human health effects, property damage from rising sea levels, and changes in the 

ecosystem

• The most recent (2013) U.S. government interagency estimates of the SCC 

for emissions in 2015, per metric ton avoided (in 2012 dollars): 

- $11.8 (average value from distribution with a 5% discount rate)

- $39.7 (average value from distribution with a 3% discount rate)

- $61.2 (average value from distribution with a 2.5% discount rate)

- $117 (95th-percentile value from distribution with a 3% discount rate) 

• The SCC in constant dollars increases over time

• DOE also monetizes the NOx emissions reductions resulting from amended 

standards. 

- Estimates of monetary value range from $468 to $4,809 per short ton 

- DOE calculated monetary benefits using a medium value of $2,639 per short ton

Details of the Analysis can be found in chapter 15 of the TSD.
110

CO2Emissions Monetization Results

TSL

SCC: $11.8 per 

metric ton

5% discount rate,

average

SCC: $39.7 per 

metric ton 

3% discount rate,

average

SCC: $61.2 per 

metric ton 

2.5% discount rate,

average

SCC: $117.0 per 

metric ton

3% discount rate,

95th percentile

1 81 350 550 1,100 

2 80 350 540 1,100 

3 340 1,500 2,300 4,500 

4 1,100 4,900 7,700 15,000 

5 1,300 5,600 8,900 17,000 

Details of the Analysis can be found in chapter 15 of the TSD.

Estimates of Net Present Value of CO2Emissions Reduction 

Under GSFL Trial Standard Levels (Million 2012$)
111

CO2Emissions Monetization Results

TSL

SCC: $11.8 per 

metric ton

5% discount rate,

average

SCC: $39.7 per 

metric ton 

3% discount rate,

average

SCC: $61.2 per 

metric ton 

2.5% discount rate,

average

SCC: $117.0 per 

metric ton

3% discount rate,

95th percentile

1 6.1 25 39 75

Details of the Analysis can be found in chapter 15 of the TSD.

Estimates of Net Present Value of CO2Emissions Reduction 

Under IRL Trial Standard Level 1 (Million 2012$)
112

Issues for Comment

Issue 25: SCC values

DOE solicits comment on the application of the new SCC values used to determine the 

social benefits of CO2 emissions reductions over the rulemaking period. In particular 

the agency solicits comment on the derivation of SCC values after 2050.
113

Utility Impact Analysis

• Purpose

- To estimate the changes in electric installed capacity and generation that 

result for each TSL 

• Method 

- The National Energy Savings is used to provide a stream of energy 

savings over the analysis period

- The Energy Information Administration’s National Energy Modeling 

System (NEMS) is modified to represent the impacts of DOEs standards 

program (modified code is known as NEMS-BT)

• Output

- Reductions in total electricity generation

- Reductions in primary fuel (coal, natural gas etc.) consumption

- Changes to the mix of electricity generation by fuel type

- Changes to total installed capacity

Details of the Analysis can be found in chapter 16 of the TSD.
114

Employment Analysis

• Purpose

- To estimate the net jobs created or eliminated nationally as a 

consequence of amended energy conservation standards, includes 

direct and indirect employment impacts

• Method 

- Uses the ImSET (Impact of Sector Energy Technologies) model for the 

evaluation of indirect employment impacts

- The changes in equipment and energy expenditures are taken from the 

National Energy Savings Analysis

- Direct employment impacts to the lighting industry are developed in the 

Manufacturer Impact Analysis (chapter 13)

• Output

- Change to commercial and energy sector employment as a 

consequence of amended energy conservation standards

Details of the Analysis can be found in chapter 17 of the TSD.
115

Regulatory Impact Analysis

• Purpose

- To investigate the national impacts of non-regulatory alternatives to 

mandatory amended energy conservation standards

• Method

- DOE modified NIA spreadsheet to represent the following nonregulatory alternatives

• Output

- National Energy Savings and Net Present Value for the non-regulatory 

alternatives

- Impact of non-regulatory alternatives on purchase price and use of 

energy-efficient equipment

• No new regulatory action • Manufacturer tax credits

• Customer rebates • Voluntary efficiency targets

• Customer tax credits • Bulk government procurement

Details of the Analysis can be found in chapter 18 of the TSD.
116

Presentation Overview

Energy Use; Life-Cycle Cost Analysis

Shipments; National Impact Analysis

5

6

2 Market & Technology; Screening Analysis

Engineering Analysis, Product Price 

Determination 3

1 Overview; Scope of Coverage

7 Manufacturer Impact Analysis

4 Trial Standard Levels

Emissions, Utility, Employment, and Regulatory 

Impacts

Proposed Standard

8

9
117

Proposed Standard (TSL 5): GSFLs

Lamp Type CCT (K) Proposed Level

(lm/W)

4-Foot Medium Bipin

≤ 4,500 92.4

> 4,500 90.6

2-Foot U-Shaped

≤ 4,500 86.9

> 4,500 84.3

8-Foot Slimline

≤ 4,500 99.0

> 4,500 94.1

8-Foot High Output

≤ 4,500 97.6

> 4,500 95.6

4-Foot Miniature Bipin 

Standard Output

≤ 4,500 97.1

> 4,500 91.3

4-Foot Miniature Bipin 

High Output

≤ 4,500 82.7

> 4,500 78.6
118

Proposed Standard (TSL 1): IRLs

Lamp Type Diameter

inches Voltage (V) Proposed Level(lm/W)

Standard 

Spectrum

40 W – 205 W

> 2.5

≥ 125 7.1P0.27

< 125 6.2P0.27

≤ 2.5

≥ 125 6.0P0.27

< 125 5.2P0.27

Modified 

Spectrum

40 W – 205 W

> 2.5

≥ 125 6.0P0.27

< 125 5.2P0.27

≤ 2.5

≥ 125 5.1P0.27

< 125 4.4P0.27

P = wattage
119

Summary of Notice of Proposed Rulemaking

• At TSL 5, the estimated national energy savings for products shipped in 

2017–2046, are 3.5 quads for GSFL. At TSL 1 estimated national energy 

savings for products shipped in 2017-2046, are 0.013 quads for IRL.

• For GSFLs, the NPV for products shipped between 2017 and 2046 is $3.1 

billion (at a 7-percent discount rate) and $8.1 billion (at a 3-percent 

discount rate), in 2012$. 

• For IRLs, the NPV for products shipped between 2017 and 2046 is $0.18 

billion (at a 7-percent discount rate) and $0.28 billion (at a 3-percent 

discount rate), in 2012$. 
120

How to Submit Written Comments

• In all correspondence, please refer to the GSFL-IRL rulemaking by:

– Energy Conservation Standards for General Service Fluorescent Lamps 

and Incandescent Reflector Lamps;

– Docket Number EERE-2011-BT-STD-0006; and

– Regulatory Identification Number (RIN) 1904-AC43.

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

Postal: Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Mailstop 

EE-2J

1000 Independence Avenue, SW

Washington, DC 20585-0121

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Suite 600

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: 202 586-2945

Comment Period closes: June 30, 2014, 11:59 PM EDT
121

Closing Remarks/Questions