U.S. Department of Energy

Energy Conservation Program for Consumer Products 

and Commercial and Industrial Equipment 

Framework Document Public Meeting on

Energy Conservation Standards for General Ser

Fluorescent Lamps, Incandescent Reflector Lamp

General Service Incandescent Lamps

June 15, 2006

Washington, DC

Revised, June 20, 2006 

http://www.eere.energy.gov/buildings/appliance_standa

EE-2006-STD-0131 COMMENT 04.3
Welcome and Introduction 

• Introductions • Role of the Facilitator • Ground Rules (norms) 

– Listen as an ally – Use short, succinct statements/keep to the point – Hold sidebar conversations outside the room – Focus on issues, not personalities – One person speak at a time (raise hand to be recognize

your name for the record) 

– Turn down the volume on cell phones or place them on 

• Housekeeping Items • Agenda Review • Opening Remarks 

EE-2006-STD-0131 COMMENT 04.3
9:00 - 9:05 am 

9:05 - 9:20 am 9:20 - 9:35 am 9:35 – 11:00 am 11:00 - 11:15 am 11:15 – 12:00 pm 12:00 - 1:00 pm 

Morning Agenda 

Welcome Introductions, agenda review, openinremarks Rulemaking overview; analytical metproduct definitions ANOPR ANALYSES: Market and technology assessment Break Screening analysis and engineering aBreak for Lunch 

EE-2006-STD-0131 COMMENT 04.3
1:00 - 2:00 pm 

2:00 - 2:45 pm 2:45 - 3:00 pm 3:00 – 3:30 pm 3:30 - 4:00 pm 4:00 - 4:30 pm 4:30 - 5:00 pm 

Afternoon Agenda 

Markups for equipment price determinatiuse and end-use load characterization; acost and payback period analysis Shipments analysis and national impact aBreak NOPR ANALYSES: Revisions to ANOPR analyses and LCC analysis Manufacturer impact analysis Utility impact analysis, employment impaenvironmental assessment, and regulatoanalysis FINAL RULE Other issues and comments; closing rem

EE-2006-STD-0131 COMMENT 04.3
2

3

NOPR Analyses

1

ANOPR Analyses

4

Rulemaking Overview

5 Final Rule6 Closing Remarks

Public Meeting Agenda

Introduction 

2 3 

NOPR Analyses ANOPR Analyses 

4 

Rulemaking Overview 

5 Final Rule 6 Closing Remarks

EE-2006-STD-0131 COMMENT 04.3
Purpose of the Framework Document Public M

• Present the procedural and analytical approaches the U.

Department of Energy (DOE or the Department) anticipato evaluate energy conservation standards for: 

• General Service Fluorescent Lamps • Incandescent Reflector Lamps • General Service Incandescent Lamps (which include 

incandescent reflector and non-reflector lamps) 

• Provide a forum for public discussion of issues • Encourage stakeholders to submit data, information, and 

comments 

• Inform stakeholders and facilitate the rulemaking proces

EE-2006-STD-0131 COMMENT 04.3
Background 

• The Energy Policy and Conservation Act, as amended 

– Grants DOE the authority to regulate fluorescent and incandescent 

lamps 

– Established energy conservation standards for general service 

fluorescent lamps and incandescent reflector lamps

– Requires DOE to review and possibly amend the existing standards – Defines some terms applicable to these lamps 

• Federal Register - 71 FR 30834 (May 31, 2006) 

– Gives public notice of the public meeting and availability of the 

Framework Document being discussed today

– Encourages interested parties to submit comments 

• Framework Document 

– Provides an overview of the rulemaking process and encourages early 

stakeholder participation 

– Invites comments on proposed approach and issues 

– The Framework Document is available online at 

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

EE-2006-STD-0131 COMMENT 04.3
Energy Conservation Standard Rulemaking A

• This rulemaking bundles three products: General Service Fluore

Incandescent Reflector Lamps, and General Service Incandesce

• It addresses two ‘backlog’ requirements from 42 USC 6295(i)(3) 

(3) First review and possible amendment to General Service 

Fluorescent and Incandescent Reflector Lamp standards 

(5) Determine whether standards should apply to additional G

Service Fluorescent and General Service Incandescent L

General Service Fluorescent Lamps 

• First review and possible amendment • Determine if standards apply to other types 

Incandescent Reflector Lamps 

• First review and possible amendment • Determine if standards apply to other types* 

General Service Incandescent Lamps 

• Determine if standards apply to other types 

*Note: General Service Incandescent Lamp includes incandescent reflector and non-reflec

EE-2006-STD-0131 COMMENT 04.3
2

3

NOPR Analyses

1

ANOPR Analyses

4

Introduction

5 Final Rule6 Closing Remarks

Public Meeting Agenda

Rulemaking Overview 

1 3 

NOPR Analyses ANOPR Analyses 

4 

Introduction 

5 Final Rule 6 Closing Remarks

EE-2006-STD-0131 COMMENT 04.3
Rulemak

Stages of the Rulemaking Process

Federal Register notices 

Framework 

Document ANOPR NOPR Final Rule 

Stakeholder participation: 

– Public meetings and oral comments – Written comments on Federal Register notices, T

Support Documents and Analytical Spreadsheets 

– Consultative meetings 

EE-2006-STD-0131 COMMENT 04.3
Rulemak

Framework Document

Framework 

Document ANOPR NOPR Final Rule 

Today 

• Today’s public meeting covers the Framework Documen

rulemaking. 

• The Framework Document provides an overview of the 

rulemaking process and encourages early stakeholder participation. 

• The Department encourages all stakeholders to read the 

Framework Document, available at: 

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

EE-2006-STD-0131 COMMENT 04.3
ANOPR NOPR Final Rule

Rulemak

Analyses for Advance Notice of Proposed Rulemakin

Energy Use andEnd-Use Load Characterization 

Market and TechnologyAssessment 

ScreeningAnalysis 

EngineeringAnalysis 

Markups for EquipmentPrice Determination 

Life-Cycle Cost and PaybackPeriod Analysis 

Shipments Analysis 

Framework 

Document ANOPR NOPR Final Rule 

EE-2006-STD-0131 COMMENT 04.3
ANOPR NOPR Final Rule

Rulemak

Analyses for Notice of Proposed Rulemaking 

Framework 

Document 

Environmental Assessment 

Life-Cycle Cost Subgroup Analysis 

Manufacturer Impact Analysis 

Utility Impact Analysis 

Employment Impact Analysis 

Revise 

ANOPR 

Analyses 

ANOPR NOPR Final Rule 

EE-2006-STD-0131 COMMENT 04.3
ANOPR NOPR Final Rule

Rulemak

Analyses for Final Rule

Framework 

Document ANOPR NOPR

DOJ Review 

Revise 

NOPR 

Analyses 

Final 

Rule 

EE-2006-STD-0131 COMMENT 04.3
Framework Document ANOPR NOPR Final Rule 

Rulemak

Lamps Rulemaking Schedule

2006 2007 2006 2007 2008 2009 2010 2009 2010 2011 2012 

2012 

Milestone Date 

End of Comment Period on Framework June 2ANOPR Published in Federal Register NovembeNOPR Published in Federal Register OctobeFinal Rule Published in Federal Register JunEffective Date Jun

EE-2006-STD-0131 COMMENT 04.3
Rulemak

Test Procedures

• DOE established test procedures for fluorescent & incande

lamps on May 29, 1997. 62 FR 29222; Appendix R to Sub

of Part 430—Uniform Test Method for Measuring Average Efficacy and Color Rendering Index (CRI) of Electric Lamp

• The DOE test procedures for these lamps: 

– Apply to all lamps covered by this rulemaking. – Measure lamp efficacy* and color rendering index (CRI).** – Incorporate by reference specific industry standards. 

• DOE does not intend to update these test procedures for t

rulemaking. 

* Lamp efficacy: “the lumen output of a lamp divided by its wattage, expressed in lumen

(LPW).” (42 U.S.C. 6291(30)(M)) 

** Color rendering index (CRI): “the measure of the degree of color shift objects undergo 

illuminated by a light source as compared with the color of those same objects when illu

a reference source of comparable color temperature.” (42 U.S.C. 6291(30)(J)) 

EE-2006-STD-0131 COMMENT 04.3
Rulemak

Fluorescent Lamps 

EPCA defines “fluorescent lamp” as a low pressure mercury electric-dsource in which a fluorescing coating transforms some of the ultraviogenerated by the mercury discharge into light, including only the follo

1. 4-foot, medium bi-pin, straight-shaped lamps, rated wattage ≥ 

2. 2-foot, medium bi-pin, U-shaped lamps, rated wattage of ≥ 28. 

3. 8-foot, recessed double-contact, rapid start, high output lamps

nominal amperes, as defined in ANSI C78.1–1991.

4. 8-foot, single pin, instant start, slimline lamps, rated wattage o

defined in ANSI C78.3–1991. 

1 2 3 

EE-2006-STD-0131 COMMENT 04.3
Fluorescent 

Lamps 

Straight-shaped 

48” 

Medium Bi-pin 

≥ 28W 

U-shaped 

22-25” 

Medium Bi-pin 

≥ 28 W 

96” 

Recessed 

Double Contact 

95W 

0.8-Amp 

T12 

113W 

0.8 & 1.0­

Amp 

T12 

Rapid-Instant

44W 

T8 

40W 

T12 

40W 

T12 

40W 

T10 

34W 

T12 

32W 

T8 

Other 

lamps 

e.g. T8: 

30, 28W; 

... 

40W 

6” 

Center 

T12 

40W 

3-5/8” 

Center 

T12 

31W 

1-5/8” 

Center 

T8 

32W 

6” 

Center 

T8 

Other 

lamps 

e.g. 34W 

T12, ... 

Rulemak

EE-2006-STD-0131 COMMENT 04.3
Rulemak

General Service Fluorescent Lamps

EPCA defines “general service fluorescent lamp” as fluorescent lamp

be used to satisfy the majority of fluorescent applications, but does nany lamp designed and marketed for the following non-general ligh

applications: 

(1) Fluorescent lamps designed to (5) Reflectorized or aperture 

promote plant growth. (6) Fluorescent lamps design

(2) Fluorescent lamps designed for reprographic equipment.

cold temperature applications. 

(3) Colored fluorescent lamps. (7) Lamps primarily designed 

(4) Impact-resistant fluorescent radiation in the UV region

lamps. (8) Lamps with a CRI ≥ 82. 

EE-2006-STD-0131 COMMENT 04.3
Rulemak

Covered General Service Fluorescent L

~ 224 

available 

lamp models 

Plant growth Impact resistant 

Cold temperature 

Colored 

CRI ≥ 82 

Unknown 

0 models 0 models 1 models 

11 models 104 models 41 models 

32W 

T8 

~ 157 lamp models 

filtered out

EE-2006-STD-0131 COMMENT 04.3
Rulemak

Request for Comment

Item 1 The Department welcomes comment on the scope rulemaking, under the statutory requirement to consider addgeneral service fluorescent lamps. (42 U.S.C. 6295(i)(5)) 

EE-2006-STD-0131 COMMENT 04.3
Rulemak

Incandescent Lamps

EPCA defines “incandescent lamp” as a lamp in which light is prodfilament heated to incandescence by an electric current, including ofollowing: 

- Any lamp (commonly referred to as lower wattage 

non-reflector general service lamps, including any tungsten halogen lamp) that:

- has a rated wattage between 30-199 watts, 

- has an E26 medium screw base, 

- has a rated voltage or voltage range that lies at least 

partially in the range of 115-130 volts, and is not a 

reflector lamp. 

- Any incandescent reflector lamp. - Any general service incandescent lamp (high- or higher-wattag

that has a rated wattage above 199 (above 205 for a high w

reflector lamp). 

EE-2006-STD-0131 COMMENT 04.3
Rulemak

Incandescent Reflector Lamps 

EPCA defines “incandescent reflector lamp” as any 

lamp which: 

• is not colored or designed for rough or vibration 

service, 

• contains an inner reflective coating on the outer bulb 

to direct the light; 

• is an R, PAR or similar bulb shape (excluding ER 

or BR) with an E26 medium screw base; 

• has a rated voltage or voltage range that lies at least partially 

115 and 130 volts; 

• has a diameter that exceeds 2.75 inches; and 

• is either: 

– a low(er)-wattage reflector lamp that has a rated wattage 

40 and 205; or 

– a high(er)-wattage reflector lamp that has a rated wattage 

EE-2006-STD-0131 COMMENT 04.3
Rulemak

Incandescent Reflector Lamp Terms Defin

• The CFR provides definitions for terms used in EPCA’s def

of incandescent reflector lamps (cont’d.) 

– Colored incandescent lamp: an incandescent lamp designa

marketed as a colored lamp that has a CRI less than 50...; hcorrelated color temperature less than 2,500K or greater than has a lens containing 5% or more neodymium oxide; or contato suppress yellow and green portions of the spectrum and is designed, designated and marketed as a plant light. 

– Rough or vibration service incandescent reflector lamp: a r

lamp in which a C–11 (5 support), C–17 (8 support), or C–22 support) filament is mounted ...and that is designated and maspecifically for rough or vibration service applications. 

EE-2006-STD-0131 COMMENT 04.3
Rulemak

Incandescent Reflector Lamp Terms Defin

• The CFR provides definitions for terms used in EPCA’s def

of incandescent reflector lamps 

– ER Lamp: a reflector lamp with an elliptical section below the 

major diameter and ... 

– BR Lamp: reflector lamp that has a bulged section below the 

major diameter and ... A BR30 lamp has a lamp wattage of 8than 66 and a BR40 lamp has a lamp wattage of 120 or less. 

Item 2 The Department welcomes comment on how a more stringent standard for incandescent reflector lamps might impamarket share of ER and BR lamps. 

EE-2006-STD-0131 COMMENT 04.3
Rulemak

General Service Incandescent Lamps

• EPCA’s definition of “general service incandescent lamp” 

encompasses any incandescent lamp (other than a miniature or 

photographic lamp) that has an E26 medium screw base, a rated vrange at least partially within 115 and 130 volts, but does not incspecifically designed for: 

− Traffic signal, or street lighting − Code beacon, marine

service; signal, lighthouse, reprograph

− Airway, airport, aircraft, or other or other communication servic

aviation service; − Medical or dental service; 

− Marine, or marine signal service; − Microscope, map, 

− Photo, projection, sound microfilm, or other specialized 

reproduction, or film viewer service; equipment service; 

− Stage, studio, or television service; − Swimming pool, or other unde

− Mill, saw mill, or other industrial service; 

process service; − Decorative or showcase ser

− Mine service; − Producing colored light; 

− Headlight, locomotive, street railway, − Shatter resistance which has 

or other transportation service; protective coating; or 

− Heating service; − Appliance service. 

Note: The majority of these terms remain undefined by EPCA or DOE 

EE-2006-STD-0131 COMMENT 04.3
Request for Feedback

Item 4 The Department welcomes comment on which, if any, of the exemption categories in the statutory definition for general service incandescent lamps require clarification. 

EE-2006-STD-0131 COMMENT 04.3
Rulemak

Incandescent Lamps

Reflector Lamps Non-Refle

Low-wattage: 40-205 W Wattage

High-wattage: > 205 W 

General Service Non-reflector Lamps Low-wattage: 

Incandescent Lamps Non-reflector Lamps High-wattage: 

Reflector Lamps: Low and High-wa

EE-2006-STD-0131 COMMENT 04.3
Rulemak

General Service Incandescent Non-Reflector Lam

These general service incandescent non-reflector lamp shapeconsidered eligible for consideration under 42 USC 6295(i)(5)

A 15 A 19 G 25 

A 21 C 15 

A 23 

S 19 

P 25 T 1

PS 25 

PS 30 

EE-2006-STD-0131 COMMENT 04.3
Rulemak

Request for Feedback

Item 3 The Department welcomes comment on the issue of product coverage, specifically the requirement to consider addgeneral service incandescent lamps. (42 U.S.C. 6295(i)(5)) 

EE-2006-STD-0131 COMMENT 04.3
2

3

NOPR Analyses

14

Rulemaking OverviewIntroduction

5 Final Rule6 Closing Remarks

Public Meeting Agenda

ANOPR Analyses 

1 2 

NOPR Analyses Rulemaking Overview 

4 

Introduction 

5 Final Rule 6 Closing Remarks

EE-2006-STD-0131 COMMENT 04.3
Market and Technolo

Analyses for Advance Notice of Proposed Rule

Framework 

Document ANOPR NOPR Final Rule 

Energy Use andEnd-Use Load Characterization 

Market and TechnologyAssessment 

ScreeningAnalysis 

EngineeringAnalysis 

Markups for EquipmentPrice Determination 

Life-Cycle Cost and PaybackPeriod Analysis 

Shipments Analysis 

EE-2006-STD-0131 COMMENT 04.3
Market and Technolo

Purpose

• Characterize the market, lamps industry and measures t

efficacy. 

Method

• Identify and characterize manufacturers of lamps; • Estimate lamp type market shares (shipments) and trend

market; 

• Identify technologies that could improve lamp efficacy; a• Identify regulatory and non-regulatory initiatives intended 

improve the efficacy of lamps covered under this rulema

EE-2006-STD-0131 COMMENT 04.3
Market and Technolo

Relationship of Analyses

Market and 

Technology 

Assessment 

Product Classes 

Technology Options 

Screening Analysis 

Design Options 

Baseline Models 

Engineering Analysis 

Item 5 The Department welcomes information on shipments, manucosts, distribution channels and estimates of market shares for the considered in this rulemaking. In order for the data to be used to coenergy savings calculations, a degree of disaggregation (e.g., by prclass and wattage) is desirable. 

EE-2006-STD-0131 COMMENT 04.3
Market and Technolo

General Service Fluorescent Lamp Product C

• EPACT 1992 established 8 product classes based on lam

(from fluorescent lamp definitions) and wattage. 

• DOE is considering modifying the product classes for 4-fo

foot lamps to account for new market diversity in lamp dia

Lamp Type Nominal Lamp Wattage Min. CRI Min. Avg

4-foot medium bi-pin > 35 W 

≤ 35 W 

69 45 

75.0 75.0 

2-foot U-shaped > 35 W 

≤ 35 W 

69 45 

68.0 64.0 

8-foot slimline > 65 W 

≤ 65 W 

69 45 

80.0 80.0 

8-foot high output > 100 W 

≤ 100 W 

69 45 

80.0 80.0 

EE-2006-STD-0131 COMMENT 04.3
Market and Technolo

General Service Fluorescent Lamp Product C

Lamps with different diameters often require ballasts specifdesigned to operate those lamps. Therefore, T8 and T12 lanot usually interchangeable with each other. 

Lamp Type Lamp Diameter Nominal Lamp Wattage M

4-foot medium bi-pin > T8 > 35 W 

≤ 35 W 

≤ T8 > 35 W 

≤ 35 W 

2-foot U-shaped > T8 > 35 W 

≤ 35 W 

≤ T8 > 35 W 

≤ 35 W 

8-foot slimline T12 > 65 W 

≤ 65 W 

8-foot high output T12 > 100 W 

≤ 100 W 

EE-2006-STD-0131 COMMENT 04.3
Market and Technolo

Request for Feedback

Item 6 The Department welcomes comment on the modified pclasses it is considering for general service fluorescent lamps. includes whether specific lamp diameters or lamp diameter ranwould be more appropriate. 

The Department is also interested in comment on the CRI distinctions and wattage bins provided in the existing product classes. 

EE-2006-STD-0131 COMMENT 04.3
Market and Technolo

General Service Fluorescent Lamp Baseline M

To limit redundancy, DOE is proposing to analyze representaticlasses. From each representative product class, DOE would baseline model. 

Lamp Type Lamp Diameter Nominal Lamp Wattage Min. CRI Ba

4-foot > T8 > 35 W 69 (scalinear ≤ 35 W 45 34

≤ T8 > 35 W 69 (sca

≤ 35 W 45 32

2-foot > T8 > 35 W 69 40W

U-shaped ≤ 35 W 45 (sca

≤ T8 > 35 W 69 (sca

≤ 35 W 45 31W

8-foot T12 > 65 W 69 75

slimline ≤ 65 W 45 (sca

8-foot high T12 > 100 W 69 (scaoutput ≤ 100 W 45 95

EE-2006-STD-0131 COMMENT 04.3
Market and Technolo

Incandescent Reflector Lamp Product Clas

• EPACT 1992 established 6 product 

classes, grouping together lamp wattages. 

• DOE is considering using the same 

product classes. However, DOE is interested in whether these lamps would be better classified in different wattage ranges. 

• DOE considered separate product 

classes for spot versus flood reflector lamps. However, it appears that their efficacies are the same, so this consumer utility does not impact efficacy. 

Wattage M

40-50 watts 51-66 watts 67-85 watts 

86-115 watts 

116-155 watts 156-205 watts 

EE-2006-STD-0131 COMMENT 04.3
Market and Technolo

Request for Feedback

Item 7 The Department welcomes comment on the produ

classes it is considering for incandescent reflector lampsincludes whether the wattage ranges need to be refined. 

EE-2006-STD-0131 COMMENT 04.3
Market and Technolo

Incandescent Reflector Lamp Baseline Mo

• To limit redundancy, DOE is proposing to analyze 

representative product classes. From each representaproduct class, DOE would select a baseline model. 

Wattage Product Class # Baseline Mod

40-50 watts 13 (scale from 75W

51-66 watts 14 (scale from 75W

67-85 watts 15 75W PAR 

86-115 watts 16 (interpolate between 75

116-155 watts 17 150W PAR 

156-205 watts 18 (scale from 150

EE-2006-STD-0131 COMMENT 04.3
Market and Technolo

General Service Incandescent Lamp Product C

• In the ANOPR, DOE will publish the Secretary’s determi

whether to regulate general service incandescent lamps include high-wattage reflector lamps and non-reflector la

• DOE is considering product classes for non-reflector lam

– Wattage or lumen output, and – Design features or consumer utility 

(e.g., 3-way lamps, lamp coating, design voltage and rough 

• DOE is considering product classes for high-wattage refl

lamps by: 

– Wattage ranges to be consistent with product classes for lo

incandescent reflector lamp standards. 

– DOE will need to consider wattage ranges. 

EE-2006-STD-0131 COMMENT 04.3
Market and Technolo

Request for Feedback

Item 8 DOE welcomes comment on what, if any, product classshould consider for additional general service incandescent lamThis includes, for non-reflector lamps, whether the classes shobased on lamp coatings, wattage ranges, lamp design voltages lumen ranges, and whether 3-way lamps should be treated as separate product class. For high-wattage incandescent reflectDOE welcomes comment on any appropriate product class(es)

EE-2006-STD-0131 COMMENT 04.3
Market and Technolo

General Service Incandescent Lamp Baseline 

• Incandescent Non-Reflector Lamps: 

– DOE is still determining product classes and baseline mod– DOE understands that three A-line lamp wattages sold tod

dominate the A-line lamp market: 60W, 75W and 100W. 

– This information, along with stakeholder comments, will be 

considered when choosing representative product classes baseline models for non-reflector lamps. 

• DOE will also be evaluating high-wattage reflector lamps a

welcomes input on product classes and baseline models. 

EE-2006-STD-0131 COMMENT 04.3
Market and Technolo

Request for Feedback

Item 10 The Department welcomes comment on the represenproduct classes proposed in section 3.4. Additionally, theDepartment welcomes comment on the scaling of findings from representative product classes to other product classes that aranalyzed. Item 11 The Department welcomes comment on the baseline models identified for each of the representative product classesincludes specific technological information such as lamp size, wattage rating, CRI, CCT (correlated color temperature), operalife, etc. 

EE-2006-STD-0131 COMMENT 04.3
Scre

Analyses for Advance Notice of Proposed Rul

Framework 

Document ANOPR NOPR Final Rule 

Energy Use andEnd-Use Load Characterization 

Market and TechnologyAssessment 

ScreeningAnalysis 

EngineeringAnalysis 

Markups for EquipmentPrice Determination 

Life-Cycle Cost and PaybackPeriod Analysis 

Shipments Analysis 

EE-2006-STD-0131 COMMENT 04.3
Scre

Purpose 

 Screen out technology options that will not be considere

rulemaking for fluorescent and incandescent lamps 

Method 

 Each technology will be screened based on the following 

criteria: 

Health or safety of technologies 

Impacts on lamp utility or availability to consumers 

Practicability to manufacture, install and service 

Technological feasibility 

EE-2006-STD-0131 COMMENT 04.3
Scre

Initial Technology Options

General Service Fluorescent Lamps • Electrode materials & coatings 

• Glass and coatings • Lamp fill-gas composition • Phosphor materials Incandescent Reflector Lamps • Higher temperature incandescent light sources • Filament materials & coatings • Reflector materials & coatings • Lamp fill-gas 

EE-2006-STD-0131 COMMENT 04.3
Scre

Initial Technology Options (cont’d)

Incandescent Non-Reflector Lamps • Higher temperature incandescent light sources • Filament materials & coatings • Glass and coatings • Lamp fill-gas 

Item 9 The Department welcomes comment on the preliminary doptions identified in this section for each of the three lamp types. specifically, the Department welcomes comment on whether therother technologies or design features that it should consider and any, impacts they might have on safety, performance, and consuutility. 

EE-2006-STD-0131 COMMENT 04.3
Scre

Request for Feedback

Item 12 The Department welcomes comment on whetheDepartment’s analysis should allow incandescent (both reflector and additional general service incandescent) lalife to vary in order to increase efficacy? If so, what woua reasonable amount of variance (i.e., not a ‘significant adverse impact’) for reflector lamps and for general servincandescent lamps? The Department also welcomes comment on a reasonaamount of variance for life and correlated color tempera(CCT) on general service fluorescent lamps? 

EE-2006-STD-0131 COMMENT 04.3
Engin

Analyses for Advance Notice of Proposed Rule

Framework 

Document ANOPR NOPR Final Rule 

Energy Use andEnd-Use Load Characterization 

Market and TechnologyAssessment 

ScreeningAnalysis 

EngineeringAnalysis 

Markups for EquipmentPrice Determination 

Life-Cycle Cost and PaybackPeriod Analysis 

Shipments Analysis 

EE-2006-STD-0131 COMMENT 04.3
Engin

Purpose 

• To characterize the relationship between manufacturer 

price and lamp efficacy. 

Rulemaking An

• Life-Cycle Cost 

Payback Period 

• Manufacturer Im

Analysis 

• Employment Imp

Analysis 

Manufacturer Selling Price –

Efficacy Relationship 

Manufacturer

Selling Price 

Efficacy Level 

EE-2006-STD-0131 COMMENT 04.3
Establish 

Efficacy 

Levels

Engin

Engineering Analysis Methodology

Establish 

Efficacy 

Levels 

Analytical 

Report 

Data 

Collection & 

Interviews 

Develop

Engineering

Analysis

Curves 

Õ Determine efficacy levels for gathering data 

production. 

Õ Collect manufacturer design options and co

broken down by direct and indirect costs. Cinterviews with manufacturers to enhance uof efficacy improvements and associated co

Õ Prepare Engineering Analysis based on ma

data. Qualify cost-energy consumption relatinterview information and publicly available 

Õ Document the Engineering Analysis, provid

average manufacturer selling price associatefficacy level for each lamp analyzed. 

EE-2006-STD-0131 COMMENT 04.3
Engin

Manufacturer Production Cost

Manufacturer 

Production 

Cost 

+ = Manufacturer Markups

(Non-Production Costs) 

Manufac

Selling P

• Direct material • Sales, general & admin. 

• Direct labor • Research & development 

• Factory overhead • Interest 

• Depreciation • Profit 

• Manufacturer Production Cost 

– Conduct interviews with manufacturers – Develop cost – efficacy relationship – Qualify product costs using literature, raw material inpu– Retail price data 

EE-2006-STD-0131 COMMENT 04.3
Engin

Development of Engineering Analysis Cur

Manufacturers supplydata on baseline lampsto be analyzed from therepresentative productclasses. 

1 

Manufacturers supply data onimprovements in efficacy andassociated production costs 

2 

DOE reviewqualifies prcost data wadditional dpoints 

3 

BASELINE 

Lamp Efficacy 

Manufacturer

Production Cost 

Lamp Efficacy 

Manufacturer

Production Cost 

Lamp Effic

Manufacturer

Production Cost 

EE-2006-STD-0131 COMMENT 04.3
Engin

Manufacturer Interview Guide

• The baseline lamp should represent a popular model, wi

sales volume. 

• The efficacy improvements over the baseline should: 

– Not reduce the operating life of the lamp by more than X% – Hold lumen output to within Y% of the baseline lamp (i.e., a

increases, wattage must decrease so light output is ‘norma

– For fluorescent lamps, must be able to operate on the sam

the baseline lamp 

• Max tech – if cost were no object, the highest efficacy la

technologically achievable. 

EE-2006-STD-0131 COMMENT 04.3
Engin

Request for Feedback

Item 13 For each product class, the Department welcomes information on design options and incremental manufacturing for five lamp efficacy levels above the baseline, one of which wbe max tech. Detailed information on the lamp performance (eenergy consumption, light output, operating life, etc.) and the incremental manufacturing costs (e.g., material costs, labor cooverhead costs (excluding depreciation), building conversion cexpenditures, tooling/equipment conversion capital expenditurresearch and development (R&D) expenses, marketing expenetc.) would be welcome. Item 15 The Department welcomes feedback on its proposal normalize its engineering analysis around the lumen output of baseline lamp. 

EE-2006-STD-0131 COMMENT 04.3
Engin

Markups to Estimate Manufacturer Selling P

Manufacturer 

Production 

Cost 

+ = Manufacturer Markups

(Non-Production Costs) 

Manufac

Selling P

• Direct material • Sales, general & admin. 

• Direct labor • Research & development 

• Factory overhead • Interest 

• Depreciation • Profit 

• Examples of publicly available information: 

– SEC 10-K reports – Company annual reports – Dun and Bradstreet reports – Value Line industry statistics – Standard and Poor’s composite industry statistics – Ibbotson Associates reports 

EE-2006-STD-0131 COMMENT 04.3
Engin

Request for Feedback

Item 14 The Department welcomes comment on the proposeapproach to determining the relationship between manufactureselling price and lamp efficacy. Item 16 The Department welcomes comment on the markup approach proposed for developing estimates of manufacturer prices. 

EE-2006-STD-0131 COMMENT 04.3
Engin

Proprietary Designs

• The Department will evaluate all design options that are 

commercially available or present in a working prototypeincluding proprietary designs. 

• Proprietary designs will only be considered if they do not 

a unique path to a given efficacy level. 

• The confidentiality of manufacturers will be maintained. 

Outside Regulatory Changes

• Consider the effects to manufacturers of other regulatory 

outside of the standards rulemaking process. 

EE-2006-STD-0131 COMMENT 04.3
Engin

Regulatory Feedback

Item 17 The Department welcomes comment on whether therproprietary designs that the Department should consider for anthe lamps under consideration by this rulemaking, and if so, hoDepartment should acquire the cost data necessary for evaluathese designs. Item 18 The Department welcomes comment on whether theroutside issues that the Department should consider in its analygeneral service fluorescent lamps, incandescent reflector lampadditional general service incandescent lamps. Item 21 The Department welcomes comment on other engineissues that could impact the engineering analysis. 

EE-2006-STD-0131 COMMENT 04.3
Markups for Equipment Price 

Analyses for Advance Notice of Proposed Rule

Framework 

Document ANOPR NOPR Final Rule 

Energy Use andEnd-Use Load Characterization 

Market and TechnologyAssessment 

ScreeningAnalysis 

EngineeringAnalysis 

Markups for EquipmentPrice Determination 

Life-Cycle Cost and PaybackPeriod Analysis 

Shipments Analysis 

EE-2006-STD-0131 COMMENT 04.3
Markups for Equipment Price 

Purpose

• Develop overall distribution chain price markups from the 

manufacturer to the consumer 

• Establish the consumer prices for both baseline lamps a

at higher standard levels 

Distribution Channel Examples

Distribution Channel 1 Distribution Channel 2 Distribution Chann

Manufacturer Manufacturer Manufact

Distributor Distributor 

Contractor 

Consumer Consumer Consum

EE-2006-STD-0131 COMMENT 04.3
Markups for Equipment Price 

Request for Feedback

Item 22 The Department welcomes comment on the distributiochain for lamps, the key stakeholders in those distribution chaintypical markups applied by those stakeholders, and the overall markup from manufacturer selling price to retail shelf. 

The Department welcomes comment on the percentage of shipby distribution chain, for each lamp type. 

EE-2006-STD-0131 COMMENT 04.3
Energy Use and 

Analyses for Advance Notice of Proposed Rule

Framework 

Document ANOPR NOPR Final Rule 

Energy Use andEnd-Use Load Characterization 

Market and TechnologyAssessment 

ScreeningAnalysis 

EngineeringAnalysis 

Markups for EquipmentPrice Determination 

Life-Cycle Cost and PaybackPeriod Analysis 

Shipments Analysis 

EE-2006-STD-0131 COMMENT 04.3
Energy Use and 

Purpose 

• To calculate operating costs for the life-cycle cost and pa

period analyses. 

• To develop energy use and demand characteristics relev

each lamp type and its applicable sector. 

Method 

• Develop average energy use values from lamp wattage 

operating hour data. 

• Take into account variability by using a distribution of op

hours. 

• The Fluorescent Lamp Ballast Rulemaking provides insig

how DOE could consider lighting-HVAC interactions. 

EE-2006-STD-0131 COMMENT 04.3
Energy Use and 

Inputs 

• Lamp Wattage: Manufacturer information verified by cata

• Operating Hours: Distribution of values as used by the 

Fluorescent Lamp Ballast rulemaking. 

20% 18% 16% 14% 12% 10% 

8% 6% 4% 2% 0% 

1F40T12/ES 2F40T12/ES 2F96T12/ES 2F96T12HO/ES 

Probability

259 1088 1922 2719 3561 4389 5191 6115 6892 7718 873

Hours / Year 

Source: Fluorescent Lamp Ballast Rulemaking 

EE-2006-STD-0131 COMMENT 04.3
Energy Use and 

HVAC Interactions

• The Department could use the same methodology to co

HVAC interactions as used in the Fluorescent Lamp BaRule. 

– The Fluorescent Lamp Ballast Rulemaking estimated 

average savings of ~ 6.25% between 2003 and 2030 HVAC interactions (when a change in building stock efficiency over time was considered). 

• Building stock played an important role in the siz

national HVAC impact. 

– The Fluorescent Lamp Ballast Rulemaking included 

HVAC impact in the National Energy Savings (NES) by using a multiplier on total energy savings. The Runot include HVAC interactions with the Life-Cycle Coanalysis or the Net Present Value (NPV) calculation. 

EE-2006-STD-0131 COMMENT 04.3
Energy Use and 

Request for Feedback

Item 19 The Department welcomes recommendations on soof data that would provide end-use operating profiles for each the lamp types covered under this rulemaking. Item 20 The Department welcomes comment on whether the use operating profiles are different for each of the lamp types covered under this rulemaking, and if so, how. 

EE-2006-STD-0131 COMMENT 04.3
Life-Cycle Cost and Paybac

Analyses for Advance Notice of Proposed Rule

Framework 

Document ANOPR NOPR Final Rule 

Energy Use andEnd-Use Load Characterization 

Market and TechnologyAssessment 

ScreeningAnalysis 

EngineeringAnalysis 

Markups for EquipmentPrice Determination 

Life-Cycle Cost and PaybackPeriod Analysis 

Shipments Analysis 

EE-2006-STD-0131 COMMENT 04.3
Life-Cycle Cost and Paybac

Purpose 

• Assess the payback period (PBP) and the net life-cycle cos

impacts on the consumer of lamp efficacy standards. 

Method 

• LCC equals consumer price plus the sum of annual operat

discounted to a particular base year 

• Economic evaluation from the consumer perspective • Analysis implemented in an Excel® spreadsheet 

• Results are expressed as LCC difference (baseline minus 

level) 

• Simple Payback (years) is also calculated and reported 

Consumer Life 

Cycle Cost 

(Baseline and Standard) 

LCC impacts 

(difference betwee

Operating Cost baseline and standa

(Sum & discount to 

present value) 

First Cost 

(Consumer Price & 

Installation) 

EE-2006-STD-0131 COMMENT 04.3
Life-Cycle Cost and Paybac

Approach

• Because this rulemaking is only considering lamps, the LC

analyses will be based on socket-to-socket replacements. 

• Monte Carlo analysis will allow DOE to consider end-user 

and conduct sensitivity analyses. 

– Consider different end-use sectors by weighting input distribu– Correlate inputs where necessary (e.g., electricity price and s

• One LCC and PBP analysis result per representative prod

EE-2006-STD-0131 COMMENT 04.3
Lamp Price 

Contractor 

Markup Sales Tax Total Installed Cost 

End-User 

Direct Price 

OR 

Lamp 

Wattage 

Operating 

Hours 

Electricity 

Price 2012 

Annual Electricity 

Cost 

Annual Electricity 

Consumption 

Operating 

Cost 

Lifetime Operating 

Cost 

Payback 

Period 

Replacement 

Labor 

Only for 

Specific 

Cases 

Lamp Lifetime Lamp Price Discount Rate 

Electricity 

Price Trend 

Analysis 

Period 

Ballast 

Factor 

Life-Cycle Cost and Paybac

Input Va

EE-2006-STD-0131 COMMENT 04.3
Life-Cycle Cost and Paybac

Annual Energy Costs

• Energy prices are used to convert energy use to energy • The Department proposes to use a distribution of avera

electricity prices based on EIA Form 826 for the comme

industrial and residential building sectors. 

• The Department will use the Energy Information Admini

(EIA) Annual Energy Outlook 

(AEO) for projections of fu

average electricity prices (reference, high, and low scen

EE-2006-STD-0131 COMMENT 04.3
Life-Cycle Cost and Paybac

Probability 

Commercial Sector Electricity Prices, EIA 2

0.06 0.05 0.04 0.03 0.02 0.01 

0 

2.8 5.8 8.8 11.8 14.8 17.8 20.8 23.8 26.8 

Price (cents/kWh) 

EE-2006-STD-0131 COMMENT 04.3
Life-Cycle Cost and Paybac

Replacement Labor and Lamp Lifetime 

• Replacement Labor only applies to C&I sectors, where the 

efficient lamp lifetime is shorter or longer than the base cas

• Replacement Labor is a function of labor rates and duratio• The Department may consider the impact of spot versus g

lamping on lamp life and on replacement costs. 

Item 25 The Department welcomes comment on whether and develop maintenance, repair and installation costs for all three types. In particular, will policies of group re-lamping versus spolamping impact the installation costs differentially with standard levels? Item 26 DOE welcomes comment on appropriate lamp lifetimethe three lamps types covered in this rulemaking. For the comand industrial sectors, should group re-lamping be taken into consideration, and if so, how should the Department characteriimpact on lamp lifetimes? 

EE-2006-STD-0131 COMMENT 04.3
Life-Cycle Cost and Paybac

LCC Analysis Period

• Product lifetimes for the base case and standards case co

different, therefore DOE proposes to calculate a salvage v(discussed on next slide) to account for the value of an opeat the end of the analysis period. 

• LCC time period of analysis could be based on: 

– Variable Usage-Scaled Time Period: Constant baseline lamp 

Because usage patterns vary by customer, analysis period (yvary by customer (but would be the same in the base vs. stanfor each customer). 

– Fixed Usage-Scaled Time Period: Constant analysis period 

based on typical lamp life (hrs) and typical annual operating h

The Department welcomes input on which time period it should select for the LCC analysis. 

EE-2006-STD-0131 COMMENT 04.3
Life-Cycle Cost and Paybac

Salvage Value 

• A ‘salvage value’ of a lamp is the lamp replacement cost p

by the lamp’s remaining service life. 

SV

= CostLamp Rpl ⋅ 1

⎡⎢

⎢⎣

−

⎛

⎤ ⎜

⎜

⎞⎟⎟

Panalysis

− LifeLamp

n⋅ ⎥

⎥⎦ Life

⎝ Lamp

⎠

where: 

SV = total salvage value, CostLampRpl = cost of the replacement lamp, 

Panalysis = analysis period, 

n = number of lamp replacements within the analysis period, a

LifeLamp = average rated lamp life. 

EE-2006-STD-0131 COMMENT 04.3
Life-Cycle Cost and Paybac

Discount Rate 

• Discount rates are used to convert streams of annual op

expenses to present value in the LCC analysis. 

• DOE will derive a distribution of discount rates for each s

– Commercial and industrial sector discount rates by estimat

weighted average cost of capital (or WACC) for commerciaconsumers of lamps. 

– Residential sector discount rates from estimates of the inte

“finance cost” to purchase residential products. 

Item 24 The Department welcomes input on the proposed approaches for estimating discount rates for residential and commercial consumers of lamps covered under this rulemakin

EE-2006-STD-0131 COMMENT 04.3
Ship

Analyses for Advance Notice of Proposed Rule

Framework 

Document ANOPR NOPR Final Rule 

Energy Use andEnd-Use Load Characterization 

Market and TechnologyAssessment 

ScreeningAnalysis 

EngineeringAnalysis 

Markups for EquipmentPrice Determination 

Life-Cycle Cost and PaybackPeriod Analysis 

Shipments Analysis 

EE-2006-STD-0131 COMMENT 04.3
Ship

Purpose

• Quantify changes in lamp shipments due to potential new 

efficiency standards 

Method

• Establish a base-case shipment forecast (absent standa

takes into account market conditions and regulatory actio

(e.g., ballast regulation) 

• Develop revised shipments forecasts at each potential st

level 

– Consider only covered products in the base case, and – Use a “substitution analysis” to account for consumers who 

non-covered lamps at higher standard levels 

EE-2006-STD-0131 COMMENT 04.3
Ship

Substitution Analysis

• Approach: Consider consumer behavior in response to stan

(e.g., installing substitute lamps that are not covered lampsare not regulated) 

• Impact: The base-case sockets and associated energy savi

potential may be eroded (or increased) by consumers substcovered lamps 

• Elasticity: The substitution analysis will replace shipments d

elasticity (i.e., the Department proposes to assume consumwant to fill all sockets that are operating in the base case, bnecessarily with covered lamps) 

• Requirements: Substitute lamps should have similar light ou

similar lamp shape, and must operate in the basecase sock

• Apportion percentage of sockets migrating to substitute

• Percentages are likely to increase at higher standard le

EE-2006-STD-0131 COMMENT 04.3
Ship

Fluorescent Lamp Shipments

• There is limited publicly available information on shipme

fluorescent lamps and the breakdown between lamp typewattages 

• The Department needs to project shipments of fluoresce

over 30 years 

• Two possible approaches: 

– Shipment projection based on historical data – Shipment projection based on modeling the installed base 

fluorescent ballasts nationally 

EE-2006-STD-0131 COMMENT 04.3
Ship

Fluorescent Lamp Shipments – Historical D

• Approach: project future fluorescent shipments by type, w

and sector based on historical shipments 

• Possible sources: 

– Trade association data – U.S. Census – ballast shipments & lamp shipments 

(note: no lamp data since 1992)

– Distribution chains to estimate end-use sectors 

• Apply expert advice to adjust projection to account for im

existing and EPACT 2005 ballast standards. 

• Include a high, medium and low projection scenario, bas

different assumptions to bound the analysis 

• Approach is simple and transparent, facilitating stakehol

EE-2006-STD-0131 COMMENT 04.3
Ship

Fluorescent Lamp Shipments – Ballast Invento

• Approach: develop a model of the installed base of fluore

ballasts to predict shipments of fluorescent lamps

• Ballast Inventory Vintaging Model: 

– Consider three changes to installed base of ballasts that in

new (magnetic and electronic) ballasts: 

• New Construction – new fixtures that are installed each year d

space growth in a particular sector. 

• Replacements – ballast replacements due to failure. Conside

hours of end-use applications. 

• Retrofits – new fixtures replacing existing lamps and fixtures d

renovation or remodeling. 

– Calibrate with U.S. Census ballast shipments – Impact of new ballast regulations (DOE standard, EPACT 2

• Lamp shipments calculated from ballast inventory model 

operating hours

EE-2006-STD-0131 COMMENT 04.3
Ship

Incandescent Lamp Shipments

• Limited publicly available information on incandescent la

shipments, sectors and the breakdown between lamp typ

wattages 

• Develop a projection of shipments from historical data 

• Possible sources: 

– Trade association with total shipments – U.S. Lighting Market Characterization Volume I: National L

Inventory and Energy Consumption Estimate 

• Sockets by sector • Average operating hours 

– U.S. Census (although lamp data was last collected in 199

EE-2006-STD-0131 COMMENT 04.3
Ship

Data Needs

• The Department welcomes information to support its Shi

Analysis on: 

– Historical shipments of fluorescent lamps and incandescen

type and wattage 

– Breakdown of shipments by end-use sector – Information on distribution channels for fluorescent lamps a

incandescent lamps 

– Comments on trends or issues that may influence the proje

lamps 

EE-2006-STD-0131 COMMENT 04.3
Ship

Request for Feedback

The Department welcomes input on the data needs and approfor estimating lamp shipments. 

Item 27 The Department welcomes comment on the proposeaccounting methodology for new construction, replacements aretrofits for each of the lamp types covered in this rulemakingItem 28 The Department welcomes comment on how any amended standard for general service fluorescent lamps and incandescent reflector lamps, as well as a standard on generaservice incandescent lamps, might impact lamp shipments. TDepartment also invites input on market-pull programs that prthe adoption of more-efficacious lamps. 

EE-2006-STD-0131 COMMENT 04.3
National I

Analyses for Advance Notice of Proposed Rule

Framework 

Document ANOPR NOPR Final Rule 

Energy Use andEnd-Use Load Characterization 

Market and TechnologyAssessment 

ScreeningAnalysis 

EngineeringAnalysis 

Markups for EquipmentPrice Determination 

Life-Cycle Cost and PaybackPeriod Analysis 

Shipments Analysis 

EE-2006-STD-0131 COMMENT 04.3
National I

Purpose

• Determine the projected national energy savings and national 

net present value. 

Method

• Develops annual time series of national energy and economic • Utilizes the shipments model to estimate the total stock of imp

fluorescent and incandescent lamps in service each year 

• Utilizes the LCC to estimate cost and energy use per unit in a

year 

• Aggregates the costs and energy use for all years in the analy• Reports energy savings in Quads of primary energy consump• Reports estimates for economic impact as change in consume

Net Present Value (in constant year dollars) 

• Accounts for the time-value of money though defined discoun

EE-2006-STD-0131 COMMENT 04.3
Annual Energy

Consumption

Annual Energy

Annual Energy Consumption

Consumption

Base Case

Annual Energy

Consumption

Annual Ener

Consumptio

Annual Energy

Annual Energy Consumption

Consumption

Base Case

Annual Energy

Consumption

National I

National Energy Savings Flow Diagram

Base-Case Shipments 

Analysis Sta

Projection Cas

Base Case 2042 

Base Case 2015 

Base Case 2014 2013 

Base-Case 

Annual Energy 

Consumption 

2012 

Base Case 

Base Case 2015 

Base Case 2014 2013 

Standards-Case 

Annual Energy 

Consumption 

2012 

Base-Case 

Cumulative 

Energy Use 

Standards-Case 

Cumulative 

Energy Use 

Site to Source 

Energy 

Conversion 

National Energy 

Savings 

EE-2006-STD-0131 COMMENT 04.3
National I

National Consumer Net Present Value Flow D

Base-Case Shipments 

Analysis Standa

Projection Case P

Energy 

Cost 

(2012 – 

20XX) 

Cumulative 

Operating Cost 

Savings 

Cumulative 

Total Equipment 

Cost Increase 

Discount 

Rate 

Net Present 

Value 

Mainten. 

Cost 

(2012 – 

20XX) 

Equipment 

Cost 

(2012 – 

2042) 

Energy 

Cost 

(2012 – 

20XX) 

Mainten. 

Cost 

(2012 – 

20XX) 

EE-2006-STD-0131 COMMENT 04.3
National I

Request for Feedback

Item 29 The Department welcomes comment on the NES spreadsheet models used for estimating national impacts of amended energy conservation standards. 

EE-2006-STD-0131 COMMENT 04.3
2

31

ANOPR Analyses

4

Rulemaking OverviewIntroduction

5 Final Rule6 Closing Remarks

Public Meeting Agenda

NOPR Analyses 

1 2 

ANOPR Analyses Rulemaking Overview 

3 

Introduction 

5 Final Rule 6 Closing Remarks

EE-2006-STD-0131 COMMENT 04.3
Revise

ANOPR

Analyses

Analyses for Notice of Proposed Rulemak

Environmental Assessment 

Life-Cycle Cost Subgroup Analysis 

Manufacturer Impact Analysis 

Utility Impact Analysis 

Employment Impact Analysis 

Revise 

ANOPR 

Analyses 

Framework 

Document ANOPR NOPR Final Rule 

EE-2006-STD-0131 COMMENT 04.3
Revise

ANOPR

Analyses

Life-Cycle Cost Subgr

Analyses for Notice of Proposed Rulemak

Environmental Assessment 

Life-Cycle Cost Subgroup Analysis 

Manufacturer Impact Analysis 

Utility Impact Analysis 

Employment Impact Analysis 

Revise 

ANOPR 

Analyses 

Framework 

Document ANOPR NOPR Final Rule 

EE-2006-STD-0131 COMMENT 04.3
Life-Cycle Cost Subgr

Purpose 

• Analyze the economic impacts of standards on consume

subgroups who may be disproportionately impacted com

with the general user population 

Method 

• Extend the LCC analysis to examine the impacts for defi

subgroups 

Item 30 The Department welcomes comment on what, if any, consumer subgroups are appropriate in considering standards general service fluorescent lamps, incandescent reflector lampadditional general service incandescent lamps. 

EE-2006-STD-0131 COMMENT 04.3
Revise

ANOPR

Analyses

Manufacturer Imp

Analyses for Notice of Proposed Rulemak

Environmental Assessment 

Life-Cycle Cost Subgroup Analysis 

Manufacturer Impact Analysis 

Utility Impact Analysis 

Employment Impact Analysis 

Revise 

ANOPR 

Analyses 

Framework 

Document ANOPR NOPR Final Rule 

EE-2006-STD-0131 COMMENT 04.3
Manufacturer Imp

Legislative Requirements

• The Manufacturer Impact Analysis (MIA) fulfills a legislat

requirement to determine if a proposed standard is econjustified. 

– EPCA provides 7 factors to evaluate in determining whethe

efficiency standard is justified. Two factors are addressed 

• Economic impact of standards on manufacturers • Impacts of any lessening of competition in the industry 

– MIA format changes described in the 2006 report to Congr

http://www.eere.energy.gov/buildings/appliance_standards/2006_schedule_

• DOE will collect, evaluate, and report preliminary MIA d

ANOPR 

• Preliminary data includes: anticipated conversion capita

expenditures by efficiency level and anticipated direct eimpacts 

EE-2006-STD-0131 COMMENT 04.3
Manufacturer Imp

Purpose 

• Assess the impacts of standards on manufacturers 

• Identify and estimate impacts on manufacturer subgroup

may be more severely impacted than the industry as a w

• Examine the impact of cumulative regulatory burden on t

industry 

Method 

• Analyze industry cash flow and net present value throug

the Government Regulatory Impact Model (GRIM) 

• Interview manufacturers to refine inputs to the GRIM, de

subgroup analyses, and address qualitative issues 

Output 

• Industry Net Present Value impacts • Subgroup Net Present Value impacts • Other impacts 

EE-2006-STD-0131 COMMENT 04.3
Manufacturer Imp

Methodology

• The MIA consists of three main phases 

ANOPR 

Phase 1 Phase 2 Phase 3 

Industryprofile 

PreliminaryMIA Interviews 

Interviews 

Develop Develop & industrystraw-man interview wide /GRIM* guide subgroup

analyses 

Aemcocubu

* Government Regulatory Impact Model (GRIM) 

EE-2006-STD-0131 COMMENT 04.3
Industry Profile

» Evaluate current and past industry 

structure and market characteristics

» Produce an industry profile report 

with aggregated findings and characteristics

» Identify critical issues that require 

special consideration in the MIA, for example:

» Types or groups of manufacturers

» Access to technology» Potential regulatory scenarios

Preliminary MIA Inte

» Occurs during the engine

analysis

» Topics include:

» Shipment projections» Conversion costs» Product mix and profit» Market shares and ind

consolidation

» Cumulative regulatory 

Manufacturer Imp

Methodology: Phase 1 

• Consists of the industry profile and preliminary manufact

impact analysis interviews 

Industry Profile 

» Evaluate current and past industry

structure and market characteristics 

» Produce an industry profile report 

with aggregated findings and characteristics 

» Identify critical issues that require 

special consideration in the MIA,for example: 

» Types or groups of manufacturers 

» Access to technology 

» Potential regulatory scenarios 

Preliminary MIA Inter

» Occurs during the enginee

analysis 

» Topics include: 

» Shipment projections » Conversion costs » Product mix and profita» Market shares and indu

consolidation 

» Cumulative regulatory b

EE-2006-STD-0131 COMMENT 04.3
Straw-man GRIM

» Starting point for discussion of 

impacts

» Inputs include:

» Manufacturer prices» Shipment forecasts» Manufacturing cost estimates» Financial information

Interview Guide Prep

» Interview topics include:

» Engineering analysis» Shipments model» Cost structure and financ

parameters

» Conversion costs» Cumulative burden» Direct employment impac» Import / Export issues» Consolidation / competitiv» Replacement parts or refu» Impact of the standard’s e

Manufacturer Imp

Methodology: Phase 2

• Consists of the straw-man GRIM and interview guide pre

Straw-man GRIM 

» Starting point for discussion of 

impacts 

» Inputs include: 

» Manufacturer prices » Shipment forecasts 

» Manufacturing cost estimates 

» Financial information 

Interview Guide Prepa

» Interview topics include: 

» Engineering analysis » Shipments model 

» Cost structure and financia

parameters 

» Conversion costs » Cumulative burden » Direct employment impact

» Import / Export issues 

» Consolidation / competitive 

» Replacement parts or refu

» Impact of the standard’s ef

EE-2006-STD-0131 COMMENT 04.3
Manufacturer Interviews

» Confidential discussion of potential 

impacts resulting from standards, including:

» Obsolescence of existing manufacturing assets» Tooling» Investment

Assessment of Imp

» Assess competitive impac

smaller, significant manuf

» Assess cumulative regula

burden on manufacturers amended DOE standards regulatory actions

» Assess impacts on indust

employment levels

» Assess impacts on manu

subgroups

Manufacturer Imp

Methodology: Phase 3

• Consists of the manufacturer interviews, subgroup analy

assessment of industry impacts 

Manufacturer Interviews 

» Confidential discussion of potential

impacts resulting from standards, including: 

» Obsolescence of existing 

manufacturing assets » Tooling 

» Investment 

Assessment of Imp

» Assess competitive impac

smaller, significant manufa

» Assess cumulative regulat

burden on manufacturers amended DOE standards regulatory actions 

» Assess impacts on industr

employment levels 

» Assess impacts on manuf

subgroups 

EE-2006-STD-0131 COMMENT 04.3
Manufacturer Imp

Request for Feedback

Item 31 The Department welcomes comment on interviewing companies to assess manufacturer impacts, and the procedurethe Department should follow when scheduling interviews and requesting information. Item 32 If appropriate, what are potential subgroups of lamp manufacturers that should be considered in a manufacturer suanalysis? Item 33 The Department welcomes comment on what other regulations or pending regulations the Department should consits examination of cumulative regulatory burden. 

EE-2006-STD-0131 COMMENT 04.3
Revise

ANOPR

Analyses

Utility Imp

Analyses for Notice of Proposed Rulemak

Environmental Assessment 

Life-Cycle Cost Subgroup Analysis 

Manufacturer Impact Analysis 

Utility Impact Analysis 

Employment Impact Analysis 

Revise 

ANOPR 

Analyses 

Framework 

Document ANOPR NOPR Final Rule 

EE-2006-STD-0131 COMMENT 04.3
Utility Imp

Purpose

• Assess the overall impacts on domestic energy supplies 

would result from the imposition of standards. 

Method

• The Department proposes to use NEMS-BT, a variant of 

NEMS (National Energy Modeling System) developed anby DOE/EIA for their Annual Energy Outlook report, as thof the Utility Impact Analysis. 

• Use the energy savings calculated from the NES spread

analysis to reduce the sector electrical loads from the Bu

Demand Modules in NEMS-BT. 

• Energy savings translated to a reduction in the electrical 

faced by the utility system over time. 

Item 34 The Department welcomes input from stakeholders on proposed use of NEMS-BT to conduct the utility impact analysi

EE-2006-STD-0131 COMMENT 04.3
Revise

ANOPR

Analyses

Employment Imp

Analyses for Notice of Proposed Rulemak

Environmental Assessment 

Life-Cycle Cost Subgroup Analysis 

Manufacturer Impact Analysis 

Utility Impact Analysis 

Employment Impact Analysis 

Revise 

ANOPR 

Analyses 

Framework 

Document ANOPR NOPR Final Rule 

EE-2006-STD-0131 COMMENT 04.3
Employment Imp

Purpose

• Assess the overall impact on national employment from 

imposition of efficiency standards at differing levels. 

• Include both direct and indirect employment impacts. 

– Direct employment impacts are estimated in the manufactu

analysis 

– Indirect employment impacts result from shifting consumer 

expenditures among goods and services (“substitution effechanging equipment and energy costs (“income effect”) 

Method 

• The Department intends to use the IMSET (Impact of Se

Energy Technologies) model for the evaluation of indirec

employment impacts. 

Item 35 The Department welcomes feedback on its proposed approach to assessing employment impacts, both direct and in

EE-2006-STD-0131 COMMENT 04.3
Revise

ANOPR

Analyses

Environmental 

Analyses for Notice of Proposed Rulemak

Environmental Assessment 

Life-Cycle Cost Subgroup Analysis 

Manufacturer Impact Analysis 

Utility Impact Analysis 

Employment Impact Analysis 

Revise 

ANOPR 

Analyses 

Framework 

Document ANOPR NOPR Final Rule 

EE-2006-STD-0131 COMMENT 04.3
Environmental 

Purpose 

• Estimate national environmental impacts from new energ

efficiency standards for lamps covered under this rule. 

Method 

• The Department intends to use the environmental impac

predicted from the NEMS-BT modeling analysis used for Utility Impacts Analysis. Impacts calculated within NEMS 

– Quantities of U.S. emissions (CO2) and nitrogen oxides (N

power plants 

– Direct environmental Impacts from reduction of fossil fuel u

building level. 

– Any measurable impact from NEMS in terms of the trading 

sulfur dioxide (SO2) in the utility sector and subsequent imp

SO2 emissions. 

Item 36 The Department welcomes feedback on its proposed 

approach to assessing environmental impacts, both direct and indirect. 

EE-2006-STD-0131 COMMENT 04.3
Revise

ANOPR

Analyses

Regulatory Imp

Analyses for Notice of Proposed Rulemak

Environmental Assessment 

Life-Cycle Cost Subgroup Analysis 

Manufacturer Impact Analysis 

Utility Impact Analysis 

Employment Impact Analysis 

Revise 

ANOPR 

Analyses 

Framework 

Document ANOPR NOPR Final Rule 

EE-2006-STD-0131 COMMENT 04.3
Regulatory Imp

Purpose

• Explore the potential for non-regulatory alternative to new 

manufacturing efficiency standards 

Method

• Base the assessment on the actual impacts of any such 

to date, but will consider information presented regarding impacts that any existing initiative might have in the futur

EE-2006-STD-0131 COMMENT 04.3
2

3

NOPR Analyses

1

ANOPR Analyses

4

Rulemaking OverviewIntroduction

56 Closing Remarks

Public Meeting Agenda

1 2 

ANOPR Analyses Rulemaking Overview 

3 

Introduction 

Final Rule 

4 NOPR Analyses

6 Closing Remarks

EE-2006-STD-0131 COMMENT 04.3
Final Rule

Framework 

Document ANOPR NOPR Final Rule 

DOJ Review 

Revise 

NOPR 

Analyses 

EE-2006-STD-0131 COMMENT 04.3
2

3

NOPR Analyses

1

ANOPR Analyses

4

Rulemaking OverviewIntroduction

23

5 Final Rule46

Public Meeting Agenda

ANOPR Analyses Rulemaking Overview Introduction NOPR Analyses 

Closing Remarks 

Final Rule 

EE-2006-STD-0131 COMMENT 04.3
Clos

How to Submit Written Comments

• In all correspondence, please refer to the Fluorescent and Inc

Lamps Rulemaking by 

– Docket Number EE–2006–STD–0131, or – Regulatory Identification Number (RIN) 1904-AA92. 

• Email: fluorescent

_

and

_

incandescent

_lamps.rulemaking@e

• Postal Mail: Ms. Brenda Edwards-Jones 

U.S. Department of Energy Building Technologies Program, Mail Stop EE-2J 

Fluorescent and Incandescent Lamps RulemakingRIN 1904-AA92 1000 Independence Avenue, SW Washington, DC 20585-0121 

• Courier: Same as above, except “Room 1J-018” 

in place of “Mail Stop EE-2J”202-586-2945

• Comment period closes June 29, 2006. 

EE-2006-STD-0131 COMMENT 04.3