ES-i

EXECUTIVE SUMMARY

TABLE OF CONTENTS

ES.1 OVERVIEW OF PRELIMINARY ANALYSIS ACTIVITIES................................... ES-1

ES.2 KEY RESULTS OF THE ANALYSIS ........................................................................ ES-3

ES.2.1 Determination of Scope .............................................................................. ES-3

ES.2.2 Market and Technology Assessment .......................................................... ES-4

ES.2.3 Screening Analysis...................................................................................... ES-5

ES.2.4 Engineering Analysis.................................................................................. ES-5

ES.2.5 Product Price Determination....................................................................... ES-6

ES.2.6 Energy Use Analysis................................................................................... ES-7

ES.2.7 Life-Cycle Cost and Payback Period Analyses .......................................... ES-9

ES.2.8 Shipments Analysis................................................................................... ES-11

ES.2.9 National Impact Analysis.......................................................................... ES-17

ES.2.9.1 National Energy Savings......................................................... ES-17

ES.2.9.2 Net Present Value of Consumer Benefits ............................... ES-18

ES.2.9.3 Summary of Alternative Analyses.......................................... ES-18

ES.2.10 Preliminary Manufacturer Impact Analysis.............................................. ES-22

ES.2.11 Other Analyses.......................................................................................... ES-22

ES.3 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT....................................... ES-22

ES.3.1 GSFL Scope .............................................................................................. ES-22

ES.3.2 GSFL Definitions...................................................................................... ES-23

ES.3.3 Market Trends........................................................................................... ES-23

ES.3.4 Technology Options.................................................................................. ES-23

ES.3.5 Product Classes......................................................................................... ES-23

ES.3.6 Market and Technology Assessment ........................................................ ES-23

ES.3.7 Screening Analysis.................................................................................... ES-23

ES.3.8 Representative Product Classes ................................................................ ES-24

ES.3.9 Baseline Lamps......................................................................................... ES-24

ES.3.10 More Efficacious Substitutes.................................................................... ES-24

ES.3.11 Lamp-and-Ballast Systems ....................................................................... ES-24

ES.3.12 Four-Foot T5 MiniBP HO Model Lamp................................................... ES-25

ES.3.13 Candidate Standard Levels ....................................................................... ES-25

ES.3.14 Compliance Requirements........................................................................ ES-25

ES.3.15 Scaling between Product Classes.............................................................. ES-25

ES.3.16 Engineering Analysis................................................................................ ES-25

ES.3.17 Product Price Determination..................................................................... ES-26

ES.3.18 GSFL Ballast Prices.................................................................................. ES-26

ES.3.19 Rare Earth Phosphor Availability ............................................................. ES-26

ES.3.20 Dimmed GSFL Systems ........................................................................... ES-26

ES.3.21 Lighting Controls Market Penetration ...................................................... ES-26

ES.3.22 Lighting Controls Performance Characteristics........................................ ES-26

ES.3.23 Operating Profiles for Energy Use Characterization ................................ ES-27

ES.3.24 Residential GSFL LCC Analysis.............................................................. ES-27

ES.3.25 Sales Tax in the LCC Analysis................................................................. ES-27
ES-ii

ES.3.26 Spacing Adjustments in the LCC Analysis............................................... ES-27

ES.3.27 LCC Analysis............................................................................................ ES-27

ES.3.28 T5s in the Residential Market................................................................... ES-28

ES.3.29 Shipments and NIA................................................................................... ES-28

ES.3.30 LCC Subgroups......................................................................................... ES-28

ES.3.31 Regulatory Flexibility Act Analysis ......................................................... ES-28

ES.3.32 Manufacturer Subgroup Analysis............................................................. ES-28

ES.3.33 Manufacturer Impact Analysis.................................................................. ES-28

ES.3.34 Valuing Airborne Emission Reductions ................................................... ES-28

ES.3.35 Regulatory Impact Analysis (RIA)........................................................... ES-29

ES.3.36 Trial Standard Levels................................................................................ ES-29

LIST OF TABLES

Table ES.2.1 GSFLs Included in the Scope of Coverage ..........................................................ES-3

Table ES.2.2 IRLs Included in the Scope of Coverage .............................................................ES-4

Table ES.2.3 Product Classes for GSFLs ..................................................................................ES-5

Table ES.2.4 Product Classes for IRLs......................................................................................ES-5

Table ES.2.5 Candidate Standard Levels for GSFL Representative Product Classes...............ES-6

Table ES.2.6 Candidate Standard Levels for the IRL Representative Product Classes ............ES-6

Table ES.2.7 Average Annual GSFL Operating Hours by Sector.............................................ES-7

Table ES.2.8 Average Annual IRL Operating Hours by Sector................................................ES-7

Table ES.2.9 Annual Energy Use by GSFL Product Class (Lamp-and-Ballast 

Replacement Scenario) ......................................................................................ES-8

Table ES.2.10 Annual Energy Use by IRL Product Class.........................................................ES-9

Table ES.2.11 Life-Cycle Cost and Payback Period Results for GSFLs (Lamp-andBallast Replacement) .......................................................................................ES-10

Table ES.2.12 Life-Cycle Cost and Payback Period Results for IRLs....................................ES-11

Table ES.2.13 Summary of Variable Assumptions for Shipments Scenarios.........................ES-14

Table ES.2.14 Effects of Candidate Standard Cases on Cumulative Shipments Compared 

to Base Case for GSFLs and IRLs, Best Estimate ...........................................ES-16

Table ES.2.15 Summary of Variable Assumptions for NIA Scenarios...................................ES-17

Table ES.2.16 Best Estimates of Cumulative National Energy Savings (quads) for GSFLs 

and IRLs...........................................................................................................ES-18

Table ES.2.17 Net Present Value for GSFLs and IRLs, Reference Scenario (billion 

2011$) ..............................................................................................................ES-18

Table ES.2.18 Alternative Scenario Variables ........................................................................ES-19

Table ES.2.19 The Impact of LED and Lighting Controls Penetration into the GSFL and 

IRL Markets on Cumulative Shipments for Two Candidate Standards 

Cases................................................................................................................ES-20

Table ES.2.20 Cumulative National Energy Savings (quads) for Alternative Analyses.........ES-20

Table ES.2.21 Cumulative Net Present Value for Alternative Analyses, 3% Discount Rate 

(2011$B) ..........................................................................................................ES-21

Table ES.2.22 Cumulative Net Present Value for Alternative Analyses, 7% Discount Rate 

(2011$B) ..........................................................................................................ES-21
ES-iii

LIST OF FIGURES

Figure ES.1.1 Flow Diagram of Analyses for the GSFL and IRL Rulemaking Process...........ES-2

Figure ES.2.1 LED Incursion Curves for GSFLs and IRLs, Best Estimate ............................ES-12

Figure ES.2.2 Inflation-Adjusted Rare Earth Oxide Price Index for Triband Phosphors 

used in Linear Fluorescent Lamps ..................................................................ES-13

Figure ES.2.3 Historical and Projected Shipments for GSFLs, Best Estimate........................ES-15

Figure ES.2.4 Historical and Projected Shipments for IRLs, Best Estimate ..........................ES-16
ES-1

EXECUTIVE SUMMARY

ES.1 OVERVIEW OF PRELIMINARY ANALYSIS ACTIVITIES

Section 6295(o)(3)(B) of 42 U.S.C. requires the U.S. Department of Energy (DOE) to 

establish energy conservation standards that achieve the maximum improvement in energy 

efficiency that is technologically feasible and economically justified. This executive summary 

highlights the activities associated with this preliminary analysis that DOE conducted when 

considering amended energy conservation standards for general service fluorescent lamps 

(GSFLs) and incandescent reflector lamps (IRLs). The executive summary also describes key 

results from DOE’s preliminary analysis and delineates issues on which DOE seeks comment.

Figure ES.1.1 presents a summary of the analytical components of the standards-setting 

process and illustrates how key results are generated. The focal point of the figure is the center 

column, labeled “Analyses.” The columns labeled “Key Inputs” and “Key Outputs” show how 

the analyses fit into the process and how they relate to each other. Key inputs are the types of 

data and other information that the analyses require. Some key information is obtained from 

public databases; DOE collects other inputs from interested parties or persons having special 

knowledge and expertise. Key outputs are analytical results that feed directly into the standardssetting process. The issues on which DOE seeks comment from interested parties derive from the 

key results that are generated by the preliminary analysis. Arrows connecting analyses show the 

types of information that feed from one analysis to another.
ES-2

Figure ES.1.1 Flow Diagram of Analyses for the GSFL and IRL Rulemaking Process 

Approaches , Key Inputs , Analyses , Key Outputs 

' ,am..-,"' O'Ocum,,'" 

· _",yfm;asro::;uo;; , .a... __ "" · 1Iio __ , • f'roduo< a.. ... 

. ......,- , Ma"'etand Technoio!ly • T octv>oIogy (Iotiofto , Assessment ·......"...o,......,om ._"""" .... , 

, 

, 

, -~- T_(Iotiofto .- o' E_tom .- , 

, • Dooion (Iotiofto Screening Analysis , 

· E".,..".....""""""'""" , 

, Dooion (Iotiofto • Dooion Ootion """"'""" · ...... ,_Co.t , 

·E".,.."."...,.,....,. , ·Co.t-""-,,_ , Engineermg Analysis 

,"""""'o,E.--n"" , 

, o~ Energy Use , c '0. E......,..., ,,",-

·Do''''Oio_~ , • ........ E.--n" .. (lJEC) ",. · E_ C ...... om , 

- Ma"mps for , 

I ~-

• RotoII'noo CoIoction "'" Product Poce , 

- Determillaboo , life-Cycle Cost and ·<;ro-CycIoCo.ts , 

. E.--n_ ,; r Paybac~ PeOOd .p.,.,..,.-

· ... _CO.ts ' Analysis · "-tononoo ~ _ Co.ts: 

· c " ",. , 

, ,

,-

- .E.--n_ 

·!lEe ., 

"0 

... - , ",. ·W_Co.ts 

.~- Shil>ments , 

, • '.-Co.ts 

• """,,,-t"'" ' ....,..t Analysis , • ......... E.--n so ..... , Nabooal Impact · __ v_ . ......,sm. ..... , Analysis • E.--nl'noo ' ....,..ts , .~ ..,... , 

, 

, Preliminal"j 

·Con ........ c __ 

....... ,-- , ·DHct~_ 

·A .. , _Co.ts , Ma nufacltl re r Impact 

, Analysis , 

P,eMni""y Analysis 

· s_ Commoots J Revise Preliminal"j I : • TrioI """"",,, lo .... (TSU ) 

Analyses , 

'Domoo<_ life-Cycle Cost 

: ·<;ro-CycIoCo.ts 

,.p -

StIb.Groop Analysis ' • _""Cub """ ....... ,-- : • s....Grooo CuM ... ·A .. , ,"0 .DHct~_ 

....... ,-_.- , Ma nufacltl re r Impact ' ·

.~ 

C ......... .. -

· GR'" • 

· 

IMty

...... '_

lood , ..,... 

F_om' Analysis 

~~t 

, - • N""""T · ......... E.--n so ..... Utilil"j Impact 

· ......... E.--n so ..... Analysis r -

::;;;.,,- · ......... f'roduo<Co.ts , 

, ._, . ......... 000<_ Co.ts Employment Impact - , 

Analysis : .......... ~-

.------ : . ___ Eo_ 

· ......... ~so ..... 

• N""""T ·""""""'v .... 0'--.- Emissions ,' • _.- """"",,,8000'",,0' 

, Analy sisl1dOlleb ",boo , 

.- , , , _'K , : • ......... E.--n so ..... Regulatol"j Impact ,· __ v_ , Analysis , , 

~obce of P""",_ Ru)emolOng (NOPIII 

, 

.~o'''''_Ro.''': , , , , Revise Analyses ' ·Ro ..... _ , • , _ Commoots , , , , , , 

, .......... 
ES-3

ES.2 KEY RESULTS OF THE ANALYSIS

ES.2.1 Determination of Scope

The Energy Policy and Conservation Act of 1975 (EPCA) established energy 

conservation standards for certain classes of GSFLs and IRLs, and required DOE to conduct two 

rulemaking cycles to determine whether these standards should be amended. (42 U.S.C. 6291(1), 

6295(i)(1) and (3)-(4)) EPCA also authorized DOE to adopt standards for additional GSFLs if 

such standards were warranted. (42 U.S.C. 6295(i)(5))

In this second rulemaking cycle, DOE identified additional fluorescent lamps for 

consideration and then assessed whether each lamp type (including those for which DOE has 

already established standards) met the criteria for prescribing new or amended 

standardsspecifically, potential for significant energy savings, technological feasibility, and 

economic justification. (42 U.S.C. 6295(o)(2)(A), (o)(3)) The following table summarizes all 

fluorescent lamps for which standards or amended standards are being considered in this 

rulemaking.

Table ES.2.1 GSFLs Included in the Scope of Coverage

Lamp Type Wattage (W)

4-foot medium bipin (MBP) linear (4-foot 

MBP) ≥ 25 W

2-foot MBP U-shaped (2-foot U-shaped) ≥ 25 W

8-foot single pin (SP) slimline ≥ 49 W

8-foot recessed double contact (RDC) high 

output (HO) All

4-foot T5, miniature bipin (MiniBP) standard 

output (SO) ≥ 25 W

4-foot T5, MiniBP HO ≥ 44 W

EPCA excludes from coverage fluorescent lamps that fall into any of the following 

categories:

 fluorescent lamps designed to promote plant growth;

 fluorescent lamps specifically designed for cold temperature applications;

 colored fluorescent lamps;

 impact-resistant fluorescent lamps;

 reflectorized or aperture lamps;

 fluorescent lamps designed for use in reprographic equipment;

 lamps primarily designed to produce radiation in the ultra-violet region of the spectrum;

and

 lamps with a color rendering index of 87 or greater.
ES-4

(42 U.S.C. 6291(30)(B)) Therefore, DOE does not consider standards for these types of GSFLs

in this rulemaking.

Table ES.2.2 outlines the IRLs included in the scope of coverage of this rulemaking.

Table ES.2.2 IRLs Included in the Scope of Coverage

Base Type Voltage Diameter Rated Wattage

E26 medium 

screw base

Between 115 

and 130 volts

Greater than

2.25 inches

Greater than or 

equal to 40 W and 

less than or equal to 

205 W

EPCA excludes from coverage IRLs that are colored or designed for rough or vibration 

service applications. (42 U.S.C. 6291(30)(C)(ii)) Further, the following lamps are not being 

considered in this rulemaking:

 lamps rated 50 W or less that are elliptical reflector (ER)30, bulged reflector (BR)30, 

BR40, or ER40;

 lamps rated 65 W that are BR30, BR40, or ER40 lamps; and

 lamps rated 45 W or less that are reflector (R)20.

ES.2.2 Market and Technology Assessment

A market and technology assessment characterizes the relevant markets and technology 

options. DOE addresses (1) manufacturer market share and characteristics, (2) existing 

regulatory and non-regulatory initiatives for improving product efficacy, and (3) trends in 

product characteristics and retail markets. This information provides data and resource material 

throughout the analysis.

DOE reviewed literature and interviewed manufacturers to develop an overall 

understanding of the GSFL and IRL industries. Industry publications—including trade journals, 

literature from manufacturers, government agencies, and trade organizations—provided the bulk 

of the information, which includes: (1) manufacturers and their market share, (2) shipments by 

lamp type, (3) lamp information, and (4) industry trends.

DOE used information about existing and past technology options and working 

prototypes to determine which technologies and combinations of technologies manufacturers use 

to attain higher performance levels. In consultation with interested parties, DOE developed a list 

of technologies to be considered. The technologies identified include all those DOE believes may 

improve efficacy. For GSFLs, DOE is considering the same technology options as those 

presented in the final rule published in July 2009 (hereafter the “2009 Lamps Rule”). 74 FR 

34080 (July 14, 2009). For IRLs, in addition to technology options presented in the 2009 Lamps 

Rule, DOE is considering ultraviolet (UV) phosphor glass coatings, electron stimulated 

luminescence, high reflectance filament supports, and permanent infrared reflector coating 

shroud as technology options. Additionally, for IRLs, DOE is considering removing luminescent 

gas as a technology option. See chapter 3 of this technical support document (TSD) for details.
ES-5

DOE generally divides covered products into product classes by the type of energy used, 

capacity, or other performance-related features that affect efficacy. Different energy conservation 

standards may apply to different product classes. (42 U.S.C. 6295(q)) DOE is considering 

maintaining the same product class divisions as those established in the 2009 Lamps Rule. Table 

ES.2.3 and Table ES.2.4 describe, respectively, the GSFL and IRL product classes DOE is 

considering in this rulemaking.

Table ES.2.3 Product Classes for GSFLs

Lamp Type Correlated Color 

Temperature (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

Table ES.2.4 Product Classes for IRLs

Lamp Type Diameter

in

Voltage

Standard Spectrum

> 2.5 ≥ 125 V

< 125 V

≤ 2.5 ≥ 125 V

< 125 V

Modified Spectrum

> 2.5 ≥ 125 V

< 125 V

≤ 2.5 ≥ 125 V

< 125 V

ES.2.3 Screening Analysis

DOE developed technology options for enhancing efficacy of GSFLs and IRLs in the 

technology assessment. In consultation with interested parties, DOE reviewed the GSFL and IRL 

options to assess whether the technologies are technologically feasible; practicable to 

manufacture, install, and service; would adversely impact product utility or availability; or would 

have adverse impacts on health and safety. See chapter 4 of this TSD for details.

ES.2.4 Engineering Analysis

In the engineering analysis, DOE chose certain product classes as representative and 

concentrated its analytical effort on those classes. Generally, DOE selected representative
ES-6

product classes based on the highest shipment volumes, although it also considered unique 

performance characteristics as appropriate. DOE then chose appropriate baseline models and 

identified more efficacious replacements. A baseline model is typically the most common, least 

efficacious product sold in a given product class. In cases where there was more than one

common, low efficacy product, DOE analyzed multiple baseline models. See chapter 5 of this 

TSD for details. Candidate standard levels (CSLs) were developed using catalog data and then 

adjusted based on efficacy data submitted to DOE for compliance purposes.a

Table ES.2.5 and Table ES.2.6 present the CSLs identified in the GSFL and IRL 

engineering analyses.

Table ES.2.5 Candidate Standard Levels for GSFL Representative Product Classes

Representative Product Class

CSL

lm/W

1 2

4-foot MBP ≤ 4,500 K 90.0 93.0

8-foot SP slimline ≤ 4,500 K 99.0 N/A

8-foot RDC HO ≤ 4,500 K 97.0 N/A

4-foot T5, MiniBP SO ≤ 4,500 K 98.2 N/A

4-foot T5, MiniBP HO ≤ 4,500 K 86.2 N/A

Table ES.2.6 Candidate Standard Levels for the IRL Representative Product Classes

Lamp Type Diameter Voltage CSL 1

lm/W

Standard Spectrum > 2.5 inches < 125 6.2P0.27

P = rated wattage of the lamp

ES.2.5 Product Price Determination

For this rulemaking, DOE estimated the end-user price of GSFLs and IRLs directly, 

rather than develop manufacturer selling prices (MSPs) from a bill of materials and manufacturer 

markup analysis. DOE selected this methodology because it is difficult to reverse-engineer 

GSFLs and IRLs, which are not easily disassembled.

In its review of publicly available prices, DOE observed a range of end-user prices paid 

for a lamp, depending on the distribution channel through which it is purchased. In line with its 

observation of public pricing, DOE developed three sets of GSFL discounts and three sets of IRL 

discounts from the blue book prices, representing low (State procurement), medium (large 

 

a Compliance data is publicly available on DOE’s Compliance Certification Database available here: 

www.regulations.doe.gov/certification-data/. 
ES-7

distributors, including do-it-yourself stores), and high (Internet retailers) lamp prices. See chapter 

7 of this TSD for details.

ES.2.6 Energy Use Analysis

The energy use analysis provides the basis for developing the energy savings used in the

life-cycle cost (LCC) analysis and subsequent analyses. For both GSFLs and IRLs, DOE 

developed average annual operating hours for each representative lamp type based on their 

application in different market sectors. Ballasts designed to operate GSFLs are not subject to the 

energy efficiency standards being developed in this rulemaking, but are considered in the energy 

use analysis for GSFLs because the input power of the complete lamp-and-ballast system is 

required to accurately characterize the energy use of the system. DOE determined the annual 

energy usage of the lamp-and-ballast systems by multiplying input power to the ballast (i.e., the 

rate of energy use) by the operating hours per year (i.e., the way customers use the lamp-andballast systems).

Table ES.2.7 and Table ES.2.8 summarize, respectively, the GSFL and the IRL average 

annual operating hours used in developing the energy use characterization.

Table ES.2.7 Average Annual GSFL Operating Hours by Sector

Sector Average Annual Operating Hours

hr/yr

Commercial 4,058

Industrial 4,585

Residential 648

Table ES.2.8 Average Annual IRL Operating Hours by Sector

Sector Average Annual Operating Hours

hr/yr

Commercial 4,496

Residential 761

Table ES.2.9 and Table ES.2.10 show the average annual electricity use in kilowatt-hours 

(kWh) for each baseline and more efficacious lamp or lamp-and-ballast system that DOE 

considers in this rulemaking. Table ES.2.9 displays the average annual energy consumption per 

system analyzed in the lamp-and-ballast replacement scenario using the U.S. average of annual 

operating hours for the most common sector for each GSFL product class. For more details on 

the energy use characterization, see chapter 6 of this TSD.
ES-8

Table ES.2.9 Annual Energy Use by GSFL Product Class (Lamp-and-Ballast Replacement 

Scenario)

Representative 

Product Class

Representative Lampand-Ballast System

Ballast Factor

(BF) and 

Nominal Lamp 

Wattage

Market 

Sector CSL

Annual Energy 

Use

kWh

4-foot MBP

≤ 4,500 K

2-lamp Instant Start 4-

foot MBP

0.88 BF 32 W

Commercial

Baseline 224.2

0.78 BF 32 W 1 200.5

0.88 BF 25 W 2 187.8

0.77 BF 32 W 2 196.2

0.87 BF 28 W 2 198.0

2-lamp Programmed 

Start 4-foot MBP

0.88 BF 32 W

Commercial

Baseline 227.1

0.88 BF 32 W 1 227.1

0.88 BF 25 W 2 190.8

0.88 BF 32 W 2 227.1

0.88 BF 28 W 2 204.5

4-lamp Instant Start 4-

foot MBP

0.87 BF 32 W

Commercial

Baseline 434.7

0.78 BF 32 W 1 393.0

0.87 BF 25 W 2 363.8

0.77 BF 32 W 2 389.7

0.87 BF 28 W 2 390.5

4-lamp Programmed 

Start 4-foot MBP

0.89 BF 32 W

Commercial

Baseline 450.6

0.88 BF 32 W 1 449.0

0.89 BF 25 W 2 378.1

0.88 BF 32 W 2 449.0

0.88 BF 28 W 2 399.7

2-lamp Instant Start 4-

foot MBP (Residential 

Ballasts)

0.87 BF 32 W

Residential

Baseline 36.6

0.83 BF 32 W 1 34.8

0.87 BF 25 W 2 30.7

0.83 BF 32 W 2 34.8

0.87 BF 28 W 2 33.0

8-foot SP slimline 

≤ 4,500 K

2-lamp Instant Start 8-

foot SP slimline

0.87 BF 59 W

Commercial

Baseline 433.2

0.85 BF 59 W 1 422.1

0.85 BF 54 W 1 400.6

0.85 BF 50 W 1 371.5

8-foot RDC HO

≤ 4,500 K

2-lamp Instant Start 8-

foot RDC HO

0.81 BF 86 W Industrial Baseline 680.6

0.81 BF 86 W 1 680.6

4-foot T5 MiniBP 

SO ≤ 4,500 K

2-lamp Programmed 

Start 4-foot T5 MiniBP 

SO

1.00 BF 28 W

Commercial

Baseline 245.1

0.95 BF 28 W 1 235.0

0.95 BF 26 W 1 220.3

0.95 BF 25 W 1 212.1

4-foot T5 MiniBP 

HO ≤ 4,500 K

2-lamp Programmed 

Start 4-foot T5 MiniBP 

HO

1.00 BF 54 W

Industrial

Baseline 534.1

1.00 BF 54 W 1 534.1

1.00 BF 50 W 1 497.4

1.00 BF 47 W 1 468.4
ES-9

Table ES.2.10 Annual Energy Use by IRL Product Class

Representative Product Class Representative

Lamp CSL

Commercial Annual 

Energy Use

kWh

Residential

Annual

Energy Use

kWh

Standard Spectrum;

> 2.5 inch diameter; < 125 V

1,500 hr, 60 W Baseline 269.7 45.7

3,000 hr, 60 W Baseline 269.7 45.7

4,400 hr, 55 W 1 247.3 41.9

ES.2.7 Life-Cycle Cost and Payback Period Analyses

The impacts of energy conservation standards on consumers often include a change in 

operating expense (usually decreased electricity expenses) and a change in purchase price 

(usually increased). The LCC of a product is the cost it incurs over its lifetime, taking into 

account both purchase price and operating expenses. The payback period (PBP) represents the 

time it takes to recover the additional installed cost of the more efficacious products through 

annual operating cost savings. DOE analyzes the net effect on consumers by calculating the LCC 

and PBP using the engineering performance data, the product price determination, and the 

energy use analysis.

Inputs to the LCC calculation include the installed cost to the consumer, operating 

expenses, lifetime of the product, and discount rates. Chapter 8 of this TSD provides a detailed 

description of the LCC and PBP analysis and the results. Table ES.2.11 and Table ES.2.12

present, respectively, the key findings for GSFLs and for IRLs.
ES-10

Table ES.2.11 Life-Cycle Cost and Payback Period Results for GSFLs (Lamp-and-Ballast 

Replacement)

Representative 

Product Class

Representative 

Lamp-and-Ballast 

System

Ballast 

Factor and 

Nominal 

Lamp 

Wattage

Market 

Sector CSL LCC

$

LCC 

Savings

$

PBP*

yr

4-foot MBP

≤ 4,500 K

2-lamp Instant Start 

4-foot MBP

0.88 BF 32 W

Commercial

Baseline 152.51 N/A N/A

0.78 BF 32 W 1 144.48 8.03 0.3

0.88 BF 25 W 2 143.16 9.35 2.3

0.77 BF 32 W 2 144.68 7.83 2.1

0.87 BF 28 W 2 143.65 8.86 1.5

2-lamp 

Programmed Start 

4-foot MBP

0.88 BF 32 W

Commercial

Baseline 226.11 N/A N/A

0.88 BF 32 W 1 232.11 -6.00 NER

0.88 BF 25 W 2 207.12 19.00 2.3

0.88 BF 32 W 2 232.15 -6.04 NER

0.88 BF 28 W 2 213.00 13.11 1.7

4-lamp Instant Start 

4-foot MBP

0.87 BF 32 W

Commercial

Baseline 275.92 N/A N/A

0.78 BF 32 W 1 261.48 14.44 0.3

0.87 BF 25 W 2 258.14 17.78 2.3

0.77 BF 32 W 2 265.69 10.22 2.6

0.87 BF 28 W 2 262.21 13.71 1.8

4-lamp 

Programmed Start 

4-foot MBP

0.89 BF 32 W

Commercial

Baseline 419.85 N/A N/A

0.88 BF 32 W 1 428.63 -8.78 8.8

0.89 BF 25 W 2 381.91 37.94 2.3

0.88 BF 32 W 2 430.72 -10.87 72.7

0.88 BF 28 W 2 389.23 30.62 1.5

2-lamp Instant Start 

4-foot MBP 

(Residential 

Ballasts)

0.87 BF 32 W

Residential

Baseline 98.57 N/A N/A

0.83 BF 32 W 1 96.88 1.69 3.1

0.87 BF 25 W 2 99.56 -0.99 11.7

0.83 BF 32 W 2 102.19 -3.62 25.9

0.87 BF 28 W 2 97.89 0.68 8.9

8-foot SP slimline 

≤ 4,500 K

2-lamp Instant Start 

8-foot SP slimline

0.87 BF 59 W

Commercial

Baseline 281.59 N/A N/A

0.85 BF 59 W 1 280.23 1.36 3.4

0.85 BF 54 W 1 272.75 8.84 2.0

0.85 BF 50 W 1 266.07 15.51 2.2

8-foot RDC HO ≤ 

4,500 K

2-lamp Instant Start 

8-foot RDC HO

0.81 BF 86 W Industrial Baseline 244.57 N/A N/A

0.81 BF 86 W 1 249.58 -5.01 NER

4-foot T5 MiniBP 

SO ≤ 4,500 K

2-lamp 

Programmed Start 

4-foot T5 MiniBP 

SO

1.00 BF 28 W

Commercial

Baseline 202.20 N/A N/A

0.95 BF 28 W 1 198.11 4.08 1.8

0.95 BF 26 W 1 194.59 7.60 1.1

0.95 BF 25 W 1 184.37 17.82 1.2

4-foot T5 MiniBP 

HO ≤ 4,500 K

2-lamp 

Programmed Start 

4-foot T5 MiniBP 

HO

1.00 BF 54 W

Industrial

Baseline 237.29 N/A N/A

1.00 BF 54 W 1 236.31 0.98 NER

1.00 BF 50 W 1 228.03 9.26 2.6

1.00 BF 47 W 1 221.03 16.25 2.1

*Entries of “NER” (no energy-saving replacement) indicate products that do not reduce operating costs.
ES-11

Table ES.2.12 Life-Cycle Cost and Payback Period Results for IRLs

Representative

Product Class

Representative

Lamp

Market 

Sector CSL LCC

$

LCC Savings

$

PBP

yr

Standard 

Spectrum; > 2.5 

inch diameter; <

125V

1,500 hr, 60 W

Commercial

Baseline 20.28 N/A N/A

4,400 hr, 55 W 1 14.55 5.73 9.1

3,000 hr, 60 W Baseline 29.16 N/A N/A

4,400 hr, 55 W 1 29.37 -0.22 4.6

1,500 hr, 60 W

Residential

Baseline 20.61 N/A N/A

4,400 hr, 55 W 1 16.58 4.03 15.1

3,000 hr, 60 W Baseline 29.87 N/A N/A

4,400 hr, 55 W 1 31.00 -1.13 15.3

ES.2.8 Shipments Analysis

Shipments projections are needed to calculate the national impacts of standards on energy 

use, net present value (NPV), and future manufacturer cash flows. The details of the modeling 

DOE used to estimate shipments in this rulemaking are described in chapter 9 of this TSD. The 

shipments model has four main interacting elements: (1) a lamp demand module, which 

estimates the demand for GSFL and IRL lighting for each year of the analysis period; (2) a price 

learning module, which projects future lamp and ballast prices based on historic price trends; (3) 

substitution matrixes, which specify the product choices available to consumers (lamps as well as 

lamp-and-ballast combinations for fluorescent lamps) depending on whether they are renovating 

lighting systems, installing lighting systems in new construction, or are simply replacing lamps; 

and (4) a module that assigns shipments to product classes and efficacy levels based on 

consumer sensitivities to first costs and operation and maintenance costs.

The shipments model assumes that lighting capacity demand per square foot of floor 

space remains constant. However, DOE expects lighting capacity demand for GSFLs and IRLs 

to be eroded by light-emitting diode (LED) lamp incursion. At the same time, increasing 

penetration of lighting system controls will reduce the lighting energy use per square foot in the 

reference case, by turning lights off or down when full light output is not desired. Therefore, 

DOE developed shipments scenarios that reflect its best estimates of LED incursion and lighting 

controls penetration in the GSFL and IRL markets. In addition, it determined the impact of these 

effects on the rulemaking by running scenarios that assumed no growth of LEDs and controls.

DOE also developed shipments scenarios to reflect uncertainties in the prices of rare 

earth oxides, which rose significantly in 2010 and 2011 and have since fallen. Rare earth oxides

are used in triband fluorescent lamp phosphors, which are used at higher concentrations in more 

efficient lamp models. As a result of manufacturer concerns over the increase in rare earth oxide 

prices, manufacturers sought an exception from GSFL standards scheduled to go into force on 

July 14, 2012, for lamps with relatively low triband phosphor concentrations (700 series T8) 

lamps. The new standard would have eliminated those products from the market. That exception 

was granted, extending the compliance date to July 14, 2014.b

 

b United States Department of Energy, Office of Hearings and Appeals. Case Nos: EXC-12-0001, EXC-12-0002, 

EXC-12-0003, April 16, 2012.
ES-12

The reference assumption for each variable reflects DOE’s best estimate. Alternative 

scenarios were run for uncertainty analyses and to determine the impact of certain key variables 

on the rulemaking. The shipments model generates shipments projections for the base case and 

each candidate standards case. In the best estimate scenario, all scenario variables are set to their 

reference (best estimate) values. 

The reference assumption for LED market penetration is based on projections developed 

for DOE’s Solid-State Lighting (SSL) Program.c DOE expects significant incursions into GSFL 

and IRL lighting capacity demand by LED lighting over the analysis period. Figure ES.3.1 

shows the reference case assumption for LED market penetration forecasts into the GSFL and 

IRL markets. DOE is considering adding scenarios for high and low LED market penetration in 

the notice of proposed rulemaking (NOPR) phase. In this preliminary analysis, DOE conducted a 

sensitivity analysis to determine the total impact that LED market penetration is expected to have 

on energy savings estimated for this rulemaking by comparing the reference scenario to a “No 

LED” case in which LED remained constant at today’s level.

Figure ES.2.1 LED Incursion Curves for GSFLs and IRLs, Best Estimate

The reference assumption for lighting system controls for the commercial sector is that 

State building code requirements for lighting controls remain constant, increasing the penetration 

of lighting controls as buildings are renovated, new buildings are constructed, and old buildings 

are retired. With all the highly populous states having adopted recent versions of the Federal 

model energy code (ASHRAE 90.1) or its equivalent,d DOE estimates that lighting controls will 

be implemented in almost 80 percent of commercial floor area by the end of the analysis period, 

assuming a 75 percent building code compliance rate (see appendix 9A of this TSD). Such a high 

penetration implies that almost all commercial floor area amenable to controls is expected to 

have them by 2046. The largest uncertainty is in the compliance rate. DOE is considering adding 

high (100 percent) and low (50 percent) compliance rate scenarios to its analysis in the NOPR 

phase. In this preliminary analysis, DOE conducted a sensitivity analysis to determine the impact 

 

c Navigant Consulting, Energy Savings Potential of Solid-State Lighting in General Illumination Applications, U.S. 

DOE, Solid State Lighting Program, January 2012.

d U.S. Department of Energy, Status of State Energy Code Adoption: www.energycodes.gov/status-state-energycode-adoption.
ES-13

that increasing penetration of lighting controls has on the energy savings estimated for this 

rulemaking by including a scenario in which commercial lighting controls are held constant at 

the current level. Residential lighting controls, which have less stringent building code 

requirements, are assumed to remain constant at today’s level.

The reference assumption for rare earth oxide prices is that they remain constant at the 

October 2012 level. As shown in Figure ES.2.2, rare earth oxide prices rose rapidly in 2010 to a 

peak in 2011, and have dropped almost monotonically to less than half their peak since then. 

Prior to 2010, prices were relatively stable from at least 2001. The future trajectory of rare earth 

oxide prices is highly uncertain. Therefore, DOE developed alternative scenarios for high and 

low prices reflecting the 2011 peak price and the 2006 – 2009 baseline average price. These were 

based on the price index shown in Figure ES.2.2, the development of which is described in 

chapter 9 of this TSD.

Figure ES.2.2 Inflation-Adjusted Rare Earth Oxide Price Index for Triband Phosphors

used in Linear Fluorescent Lampse f

The reference and alternative variable assumptions are summarized in Table ES.2.13.

 

e Metal Pages. Metal Prices. (Last accessed October 9, 2012.) <www.metal-pages.com>

f U.S. Department of Energy. Critical Materials Strategy. December 2011.

<http://energy.gov/sites/prod/files/DOE_CMS2011_FINAL_Full.pdf>
ES-14

Table ES.2.13 Summary of Variable Assumptions for Shipments Scenarios

Shipments Scenarios 

Variables Best Estimate Alternative 1 Alternative 2

LED market 

incursion

Ref: Increasing according to 

Figure ES.2.1

No LED: No additional

LED incursion

Lighting controls 

penetration

Ref: Commercial in-growth 

determined by today’s building 

codes (see appendix 9A of this 

TSD). Residential constant at 

today’s level.

Fixed: Constant controls 

penetration at today’s level

Rare earth oxide

(REO) prices Ref: Prices in October 2012 High: 2011 peak price Low: 2006 – 2009 average price

Figure ES.2.3 and Figure ES.2.4 show the historic and projected shipments of GSFLs and

IRLs for the reference scenario for the base case and two candidate standards cases. The All CSL 

1 case assumes that the standard for all products is set at CSL 1. The Max CSL case, set the 

standard for all products at their maximum CSL, as described in the engineering analysis. For 

IRLs, only the first option applies since all product classes include only one CSL. The reference 

scenario assumes the reference assumptions for all scenario variables. As shown in Figure 

ES.2.3, for the Max CSL standard case, when the standard is set to CSL 2 for 4-foot MBP lamps, 

their higher price shifts consumers away from that product class, reducing shipments of those 

lamps. Instead, consumers shift toward T5 MiniBP lamps, the standard for which is still at CSL 1 

(their maximum), increasing the shipments of T5 MiniBP lamps over the base case and the All 

CSL 1 case. 
ES-15

Figure ES.2.3 Historical and Projected Shipments for GSFLs, Best Estimateg

 

g

In some cases, the change in shipments between the candidate standards case and base case is so small that it is 

indistinguishable on the figure. In that case, the higher standard level overwrites the lower.
ES-16

Figure ES.2.4 Historical and Projected Shipments for IRLs, Best Estimate

Table ES.2.14 shows the cumulative shipments for the reference scenario for each of the 

modeled product class groupings for the two standards cases considered.

Table ES.2.14 Effects of Candidate Standard Cases on Cumulative Shipments Compared 

to Base Case for GSFLs and IRLs, Best Estimate

Product Class Groupings

Base Case All CSL 1 Max CSL*

Cumulative

Shipments

millions

Cumulative 

Shipments

millions

Change in 

Shipments 

Relative to 

Base Case

Cumulative 

Shipments

millions

Change in 

Shipments 

Relative to 

Base Case

4-foot MBP 5,082 4,989 -2% 4,814 -6%

8-foot SP slimline 46 46 1% 46 1%

8-foot RDC HO 20 22 12% 22 12%

4-foot T5, MiniBP SO 826 925 12% 1,097 33%

4-foot T5, MiniBP HO 867 861 -1% 863 0%

2-foot U-shaped 208 204 -2% 197 -5%

Total GSFL** 7,049 7,048 0% 7,040 0%

IRL Residential 498 329 -34% 329 -34%

IRL Commercial 66 60 -10% 60 -10%

Total IRL** 564 388 -31% 388 -31%

*The maximum CSL is CSL 2 for 4-foot MBP GSFLs and CSL 1 for all other GSFLs.

The maximum CSL for all IRLs is CSL 1.

** May not add due to rounding.
ES-17

ES.2.9 National Impact Analysis

The national impact analysis (NIA) estimates the following national impacts for a range 

of candidate standards cases for the two categories of lamps: (1) national energy savings; (2) 

monetary value of the energy savings due to standards; (3) increased total installed costs of the 

considered products due to standards; and (4) the NPV of the difference between the value of 

energy savings and increased total installed costs. DOE prepared a spreadsheet model to estimate

energy savings and national consumer economic costs and savings resulting from new standards. 

The NIA considers alternative options for future electricity prices, taken from DOE’s Annual 

Energy Outlook 2012 (AEO 2012) and lighting rebound rates (discussed in appendix 10C of this 

TSD). In addition, for reference and alternative scenarios the model computes the NPV assuming 

two discount rates, 3 percent and 7 percent. The reference and alternative assumptions are 

summarized in Table ES.2.15. The details of the NIA modeling are presented in chapter 10 of 

this TSD.

Table ES.2.15 Summary of Variable Assumptions for NIA Scenarios

NIA Scenario 

Variables Best Estimate Alternative 1 Alternative 2

Electricity Prices AEO 2012 reference 

forecast

AEO High: AEO 2012

high economic growth 

forecast

AEO Low: AEO 2012

low economic growth 

forecast

Rebound Rates 0% residential,

0% commercial

8.5% residential,

1% commercial

(Framework Proposal)

15% residential,

15% commercial

(NEMS assumption)

ES.2.9.1 National Energy Savings

The inputs for determining the national energy savings for each product class are: (1) 

lamps shipments; (2) annual energy consumption per unit; (3) the stocks of lamps in each year; 

(4) national energy consumption; and (5) site-to-primary energy and full fuel cycle (FFC) 

conversion factors. The lamp stocks were calculated by the shipments model for each year of the 

analysis period from the prior year’s stock, minus retirements, plus shipments, accounting for 

lamp and ballast lifetimes. DOE calculated the national electricity consumption in each year by 

multiplying the number of units of each product class and efficacy level in the stock by its power 

consumption and operating hours. The electricity savings is estimated from the difference in 

national electricity consumption between the base case (without amended efficacy standards) and 

the standards cases for lamps shipped during the 2017-2046 period. Electricity savings are then 

converted to primary energy savings at the power plant using conversion factors derived from the 

most recent version of the NEMS. DOE also estimated the total national energy savings using a 

FFC analysis, as described in chapter 10 of this preliminary TSD.

Table ES.2.16 shows the cumulative site electricity savings in terawatt-hours and the FFC 

national energy savings in quads for the reference scenario for both categories of lamps. As 

shown, the estimated national energy savings is more than four times higher for the Max CSL

case in which the standard for 4-foot MBP lamps is set at CSL 2. The estimated cumulative 

national energy savings for IRLs is small.
ES-18

Table ES.2.16 Best Estimates of Cumulative National Energy Savings (quads) for GSFLs

and IRLs 

Product Class

Groupings

All CSL 1 CSL Max*

Primary** Full Fuel Cycle†Primary** Full Fuel Cycle†

GSFL 0.90 0.94 4.3 4.5

IRL 0.13 0.14 0.13 0.14

*The maximum CSL is CSL 2 for 4-ft MBP GSFLs and CSL 1 for all other GSFLs.

The maximum CSL for all IRLs is CSL 1.

** Primary energy savings at the power plant.

†

See appendix 10B

ES.2.9.2 Net Present Value of Consumer Benefits

DOE calculated net monetary savings in each year as the difference between total savings 

in energy costs and increases in total product costs in the base case and standards cases. DOE 

calculated savings over the life of the products purchased from 2017 through 2046. The NPV is 

the difference between the present value of operating cost savings and the present value of 

increased total installed costs. In accordance with guidance provided by the Office of 

Management and Budget (OMB) to Federal agencies on regulatory analysis, DOE used discount 

rates of 7 percent and 3 percent to discount future costs and savings to the present. The NPV 

results for GSFLs and IRLs in the reference scenario are shown in Table ES.2.17. A negative 

NPV indicates that the costs of a standard at a given efficacy level exceed the savings. For 

GSFLs, both candidate standards cases show a positive NPV at both the 3 percent and 7 percent 

discount rate and the NPV is higher for the Max CSL case. For IRLs, only the All CSL 1 case 

applies, and this shows a positive NPV only for the 3 percent discount rate assumption.

Table ES.2.17 Net Present Value for GSFLs and IRLs, Reference Scenario (billion 2011$)

Product Class

Groupings

All CSL 1 CSL Max*

3% Discount

Rate

7% Discount

Rate

3% Discount

Rate

7% Discount

Rate

GSFL 2.0 0.83 23 13

IRL 0.040 -0.17 0.040 -0.17

*The maximum CSL is CSL 2 for 4-ft MBP GSFLs and CSL 1 for all other GSFLs.

The maximum CSL for all IRLs is CSL 1. 

ES.2.9.3 Summary of Alternative Analyses

This section summarizes the results of the alternative analyses. Table ES.2.18

summarizes the model inputs used (a) to characterize the uncertainties in the candidate standards 

case analyses, (b) to determine the impact of different rebound rate assumptions, (c) to determine 

the impact of increasing LED incursion and controls penetration into the GSFL and IRL markets, 

and (d) to test the effect of manufacturers meeting an IRL CSL 1 standard using short-lived 
ES-19

lamps, as described in chapter 5 of this TSD. The scenario variables are as described in Table 

ES.2.13 and Table ES.2.15.

Table ES.2.18 Alternative Scenario Variables

Scenario Variables

Analysis Type Scenario 

AEO 2012 

Economic 

Growth

Rebound 

Rate

Rare 

Earth 

Price

LED

Controls 

Adoption

Short IRL 

Life

(a)

Uncertainty Analyses

REO High Ref Ref* High Ref Ref No

REO Low Ref Ref* Low Ref Ref No

High Economic 

Growth High Ref* Ref Ref Ref No

Low Economic Growth Low Ref* Ref Ref Ref No

(b)

Rebound Scenarios

Framework Rebound Ref Framework** Ref Ref Ref No

NEMS Rebound Ref NEMS† Ref Ref Ref No

(c)

Impact Determination

Controls Ref Ref* Ref Ref Fixed No

LED Ref Ref* Ref Fixed Ref No

(d)

Alternative 

Technology

Scenario

IRL Short Life Ref Ref* Ref Ref Ref Yes

*Reference rebound rates are as follows: Commercial 0% and Residential 0%.

**Framework rebound rates are as follows: Commercial 1% and Residential 8.5%

†NEMS rebound rates are as follows: Commercial 15%, Residential 15%. 

Table ES.2.19 documents the estimated impact of the penetration LEDs and lighting 

controls on the cumulative shipments of the two categories of lamps for the two candidate 

standards cases: ALL CSL 1, in which the standard for all product classes are assumed to be set at 

CSL 1; and CSL Max, in which the standard for all product classes are assumed to be set at the 

highest CSL, which is CSL 2 for 4-ft MBP GSFLs and CSL 1 for all other lamps. As indicated, 

LEDs are expected to have a large impact on these lamp markets, greatly reducing the projected 

lamp shipments in the base case and the standards case.
ES-20

Table ES.2.19 The Impact of LED and Lighting Controls Penetration into the GSFL and 

IRL Markets on Cumulative Shipments for Two Candidate Standards Cases

GSFLs IRLs

millions of lamps shipped Impact millions of lamps shipped Impact

Best Estimate No LED 

Growth

Percent 

Change Best Estimate No LED Growth

Percent 

Change

Base Case 7,049 12,549 78% 564 3229 472%

All CSL 1 7,048 12,546 78% 388 2375 512%

Max CSL 7,040 12,531 78% 388 2375 512%

Best Estimate Fixed 

Controls

Percent 

Change Best Estimate Fixed Controls

Percent 

Change

Base Case 7049 7201 2% 564 564 ND*

All CSL 1 7048 7195 2% 388 388 ND*

Max CSL 7040 7179 2% 388 388 ND*

*Not detectable

Table ES.2.20 documents the FFC national energy savings estimated for all of the 

alternative analyses that affect the NES. In each case, the scenario result for the alternative 

analysis should be compared to the standard best estimate to determine the impact. As evident 

from the table, LED incursion has a large estimated impact on the rulemaking. Lighting controls 

also have a significant estimated impact on GSFLs, but not on IRLs, which are used mostly in 

the residential sector where controls penetration is assumed to remain fixed over the analysis 

period. Also, if manufacturers respond to a candidate standard for IRLs by using short-lived 

lamps that meet the standard, net energy savings is estimated to be less than half of what it would 

be in the absence of such a response.

Table ES.2.20 Cumulative National Energy Savings (quads) for Alternative Analyses

Analysis Type Scenario 

All CSL 1 Max CSL

IRL

GSFL

Total 

Rulemaking 

IRL

GSFL

Total 

Rulemaking 

Standard Best Estimate 0.138 0.938 1.08 0.138 4.52 4.65

Uncertainty 

Analyses

REO High 0.138 0.925 1.06 0.138 4.30 4.44

REO Low 0.138 0.941 1.08 0.138 4.59 4.73

Rebound 

Scenarios

Framework 

Rebound Rate 0.127 0.928 1.06 0.127 4.47 4.59

NEMS Rebound 0.118 0.797 0.915 0.118 3.83 3.96

Impact 

Determination

Controls 0.138 1.09 1.23 0.138 5.28 5.42

LED 0.689 1.79 2.48 0.689 7.78 8.47

Alternative 

Technology 

Scenario

IRL Short Life 0.0543 0.938 0.992 0.0543 4.52 4.57

Table ES.2.21 and Table ES.2.22 document the estimated NPV of two candidate 

standards cases for the alternative analyses assuming a 3 percent and 7 percent discount rate, 

respectively. As is evident from the tables, uncertainties in electricity prices resulting from 

differences in AEO 2012 economic growth rate scenarios introduce larger uncertainty into the 
ES-21

rulemaking than do uncertainties in rare earth oxide prices, the estimated impact of which is 

small. DOE does not include rebound effects in its NIA calculation (see appendix 10C of this 

TSD), therefore that alternative scenario is omitted from Table ES.2.21 and the following table.

Table ES.2.21 Cumulative Net Present Value for Alternative Analyses, 3% Discount Rate 

(2011$B)

Analysis Type Scenario 

All CSL 1 Max CSL

IRL

GSFL

Total 

Rulemaking 

IRL

GSFL

Total 

Rulemaking 

Standard Best Estimate 0.0403 1.95 1.99 0.0403 22.9 22.9

Uncertainty 

Analyses

REO High 0.0403 1.97 2.01 0.0403 22.5 22.6

REO Low 0.0403 1.94 1.98 0.0403 23.0 23.0

High Economic 

Growth 0.0449 2.12 2.16 0.0449 23.7 23.7

Low Economic 

Growth 0.0408 1.80 1.84 0.0408 22.2 22.3

Impact 

Determination

Controls 0.0409 2.66 2.70 0.0409 26.8 26.8

LED -0.00398 3.80 3.79 -0.00398 35.5 35.5

Alternative 

Technology 

Scenario

IRL Short Life -0.352 1.95 1.59 -0.352 22.9 22.5

Table ES.2.22 Cumulative Net Present Value for Alternative Analyses, 7% Discount Rate 

(2011$B)

Analysis Type Scenario 

All CSL 1 Max CSL

IRL

GSFL

Total 

Rulemaking 

IRL

GSFL

Total 

Rulemaking 

Standard Best Estimate -0.094 0.84 0.75 -0.094 12.7 12.6

Uncertainty 

Analyses

REO High -0.094 0.85 0.76 -0.094 12.7 12.6

REO Low -0.094 0.84 0.74 -0.094 12.7 12.6

High Economic 

Growth -0.093 0.91 0.82 -0.093 13.1 13.0

Low Economic 

Growth -0.093 0.78 0.69 -0.093 12.4 12.3

Impact 

Determination

Controls -0.093 1.1 1.1 -0.093 14.6 14.5

LED -0.365 1.4 1.1 -0.365 17.5 17.1

Alternative 

Technology 

Scenario

IRL Short Life -0.169 0.84 0.67 -0.169 12.7 12.5
ES-22

ES.2.10 Preliminary Manufacturer Impact Analysis

The manufacturer impact analysis (MIA) assesses the potential impacts of energy 

conservation standards on manufacturers, including effects on expenditures for capital 

conversion, marketing costs, shipments, and research and development costs. Potential impacts 

might lead to changes in manufacturing practices for GSFLs and IRLs. DOE identified potential 

impacts through interviews with manufacturers and other interested parties.

During interviews for this preliminary MIA, manufacturers identified six major areas of 

concern: (1) rare earth materials, (2) unknown impacts of the most recent GSFL and IRL 

standards adopted in the 2009 Lamps Rule, (3) testing burden, (4) technology shift, (5) product 

innovation, and (6) impact on the residential sector. See chapter 12 of this TSD for details.

ES.2.11 Other Analyses

The remaining chapters of this preliminary TSD address the following analyses, which 

will be performed for any NOPR issued for GSFLs and IRLs:

 The LCC analysis for subgroups evaluates the effects of energy conservation standards 

on various national customer subgroups (chapter 11);

 The utility impact analysis examines impacts of energy conservation standards on the 

generation capacity of electric utilities (chapter 14);

 The employment impact analysis examines the indirect effects of energy conservation 

standards on national employment (chapter 13);

 The emissions analysis examines the effects of energy conservation standards on various 

airborne emissions (chapter 15);

 The monetization of emissions analysis quantifies the impacts of reduced emissions as a 

result of energy conservation standards (chapter 16); and

 The regulatory impact analysis examines the national impacts of non-regulatory 

alternatives to mandatory energy conservation standards (chapter 17).

ES.3 ISSUES ON WHICH DOE SEEKS PUBLIC COMMENT

DOE is interested in receiving comment on all aspects of this preliminary analysis. DOE 

especially invites comment or data to improve DOE’s analyses, including information that will 

respond to the following questions and concerns raised in the development of this preliminary 

TSD.

ES.3.1 GSFL Scope

DOE is considering the following modifications to the minimum covered wattages of 

certain lamp types under the fluorescent lamp definition: changing the 8-foot SP slimline 

minimum wattage from 52 W to 49 W; changing the 4-foot MiniBP SO minimum wattage from 
ES-23

26 W to 25 W; and changing the 4-foot MiniBP HO minimum wattage from 49 W to 44 W. DOE 

seeks comment on the modifications to GSFL wattage limits under consideration.

ES.3.2 GSFL Definitions

Based on several queries received from the general public on the application of the 

exemptions listed in the definition of “general service fluorescent lamp,” DOE has decided to 

clarify certain terms. DOE is considering defining the following terms related to the definition of 

GSFLs: “impact-resistant fluorescent lamp, “reflectorized or aperture lamp,” “fluorescent lamp 

designed for use in reprographic equipment,” and “lamps primarily designed to produce radiation 

in the ultra-violet region of the spectrum.” DOE is also considering clarifying the terms 

“designed and marketed.” DOE requests comment on the definitions of terms related to GSFLs

under consideration.

ES.3.3 Market Trends

DOE believes that the overall fluorescent lamp market will increasingly shift away from 

T12 products due to the July 2012 lamp standards and the November 2014 ballast standards. 

DOE requests comment on the future availability of standards compliant T12 lamps. For IRLs, 

DOE noticed limited product offerings for modified spectrum lamps, lamps with diameters less 

than or equal to 2.5 inches, and lamps with voltages ≥ 125 V. DOE requests comment on the 

future availability of these products, or any combination thereof.

ES.3.4 Technology Options

DOE requests comment on the technology options being considered for both GSFLs and 

IRLs and any additional options that should be included. In particular, for GSFLs DOE 

acknowledges that the market may be shifting away from less efficient diameters and requests 

comment on whether the higher efficiency diameter technology option should be retained.

ES.3.5 Product Classes

For GSFLs, DOE defined product classes based on physical constraints of lamps (i.e., 

lamp shape and lamp length), lumen package (i.e., SO versus HO), and CCT. The 12 product 

classes are summarized in Table ES.2.3. For IRLs, DOE defined product classes based on lamp 

diameter, voltage, and spectrum. The eight product classes are summarized in Table ES.2.4. 

DOE seeks comments on the product classes under consideration for GSFLs and IRLs.

ES.3.6 Market and Technology Assessment

DOE requests comments on the overall methodology and results of the market and 

technology assessment for GSFLs and IRLs.

ES.3.7 Screening Analysis

DOE invites comment on the technology options eliminated during the screening 

analysis.
ES-24

ES.3.8 Representative Product Classes

DOE identified the following product classes as representative for GSFLs:

 4-foot MBP ≤ 4,500 K

 8-foot SP slimline ≤ 4,500 K

 8-foot RDC HO ≤ 4,500 K

 4-foot T5, MiniBP SO ≤ 4,500 K

 4-foot T5, MiniBP HO ≤ 4,500 K

DOE identified the following product class as representative for IRLs:

 Standard Spectrum, Voltage < 125 V, Diameter > 2.5 Inches

DOE requests comment on the representative product classes for GSFLs and IRLs.

ES.3.9 Baseline Lamps

DOE selected the most common and least efficacious lamps as baselines within each 

representative product class. DOE requests comment on the baseline units selected for both 

GSFLs and IRLs. In particular, for IRLs, DOE requests comment on its selection of two baseline 

lamps with similar efficacies, but distinct technologies and lifetimes.

ES.3.10 More Efficacious Substitutes

After choosing baseline lamps, DOE identified more efficacious substitutes. DOE chose 

more efficacious substitutes that were within 10 percent of the light output of the baseline lamp, 

when possible. DOE requests comment on the criteria used in selecting more efficacious 

substitute lamps, as well as the characteristics of the lamps selected.

In particular, for GSFLs, DOE requests comments on whether replacements of lamps 

and/or lamp-and-ballast systems that maintain less than 10 percent of the mean lumen output of 

the replaced system (such as 25 W 4-foot MBP lamps replacing 32 W 4-foot MBP lamps) occur 

in practice.

ES.3.11 Lamp-and-Ballast Systems

DOE paired each representative GSFL with a ballast to develop representative lamp-andballast systems. DOE used information from the fluorescent lamp ballasts final rule published in 

2011 (hereafter the “2011 Ballast Rule”; 76 FR 70548 [Nov. 14, 2011]), product catalogs, and 

manufacturer input to identify the ballast type that is used most commonly with each 

representative lamp type. DOE then calculated ballast efficiencies for each ballast type and 

wattage combination, based on catalog data and test data from the 2011 Ballast Rule. DOE 

requests comment on its methodology to identify representative lamp-and-ballast systems for 

GSFLs. DOE also requests comment on the characteristics of the replacement lamp-and-ballast 

systems analyzed, particularly the ballast luminous efficiency of each system and the BFs of the 

reduced wattage systems.
ES-25

ES.3.12 Four-Foot T5 MiniBP HO Model Lamp

For the 4-foot T5 MiniBP HO product class, DOE was unable to identify commercially 

available full wattage, higher efficacy replacements for the 4-foot T5 MiniBP HO baseline lamp. 

Therefore, DOE modeled a more efficacious full wattage lamp. DOE requests comment on the 

methodology and performance characteristics developed for this model lamp. In particular, DOE 

seeks information on the manufacturability and functionality of this lamp, as well as its efficacy, 

measured according to the DOE test procedure, when manufactured on a commercial scale.

ES.3.13 Candidate Standard Levels

After identifying more efficacious substitutes for each of the baseline lamps, DOE 

develops CSLs based on the consideration of several factors, including: (1) the design options 

associated with the specific lamps being studied (e.g., grades of phosphor for GSFLs, the use of 

infrared coatings for IRLs); (2) the ability of lamps across wattages to comply with the standard

level of a given product class; and (3) the max tech level. DOE requests comment on the CSLs 

under consideration for GSFLs and IRLs. In particular, DOE seeks comment on the 

appropriateness of developing a CSL 1 for the 4-foot T5 MiniBP HO product class.

ES.3.14 Compliance Requirements

DOE based its engineering analysis on performance data presented in manufacturer 

catalogs. To establish the final minimum efficacy requirements for each CSL, DOE analyzed the 

publicly available compliance data and evaluated whether any adjustments were necessary to 

account for the compliance efficacies of representative units and/or equivalent lamps. DOE 

invites comment on whether additional adjustments to the CSLs are needed to account for 

compliance requirements.

ES.3.15 Scaling between Product Classes

DOE extrapolated its analysis from representative product classes to those not directly 

analyzed by calculating appropriate scaling factors. DOE requests comment on the methodology 

and results of its scaling analysis. Specifically, with regards to IRL scaling, DOE requests 

comment on the use of double-ended versus singled-ended burners in large and small diameter 

lamps. Furthermore, DOE was unable to identify the specific Underwriters Laboratories (UL) 

safety standard mentioned by the National Electrical Manufacturers Association (NEMA) that 

requires a minimum distance between the halogen capsule and the glass envelope. DOE requests 

additional information on this UL safety standard including the standard number and minimum 

required distance.

ES.3.16 Engineering Analysis

DOE requests comments on the overall methodology and results of the GSFL and IRL 

engineering analyses.
ES-26

ES.3.17 Product Price Determination

In its review of publicly available prices, DOE observed a range of end-user prices paid 

for a lamp, depending on the distribution channel through which it was purchased. In line with its 

observation of public pricing, DOE developed three sets of GSFL discounts and three sets of IRL 

discounts from the blue book prices, representing low (State procurement), medium (large 

distributors, including do-it-yourself stores), and high (Internet retailers) lamp prices. DOE 

invites comment on its methodology and results for estimating end-user prices for GSFLs and 

IRLs.

ES.3.18 GSFL Ballast Prices

DOE utilized the end-user prices from the 2011 Ballast Rule to determine pricing for the 

fixed light output ballast replacements. DOE requests comment on the ballast prices developed, 

specifically the adjusted prices for dimming ballasts and the assumption that ballast pricing does 

not change between low and normal BF ballasts.

ES.3.19 Rare Earth Phosphor Availability

DOE requests comments on the specific impacts of an increase in rare earth phosphor 

prices due to decreased supply on the cost of lamps covered under this rulemaking as well the 

extent of the limited worldwide resources of rare earth phosphors and the impact of this shortage 

on the feasibility of meeting higher standards.

ES.3.20 Dimmed GSFL Systems

DOE requests comments on the dimmed fluorescent systems analyzed, in particular the 

lamp types included in the dimming scenarios and the assumption that light output and input 

power scale linearly for dimming systems.

ES.3.21 Lighting Controls Market Penetration

The energy savings projected in this rulemaking depends on the market penetration of 

lighting system controls. In the NIA analysis, DOE has assumed 75 percent compliance with 

State building code requirements for lighting controls in commercial buildings. DOE is 

considering adding high (100 percent) and low (50 percent) compliance rate scenarios to its 

analysis in the NOPR phase. DOE seeks relevant data on compliance rates with current State 

building code requirements. In this analysis, DOE has assumed that the use of lighting system 

controls in the residential sector remains fixed at its current level. DOE requests comment on the 

validity and appropriateness of this assumption.

ES.3.22 Lighting Controls Performance Characteristics

DOE requests any comments pertaining to the methodology used to account for lighting 

controls. Specifically, DOE requests comment on the assumption that the average reduction in 

system lumen output for GSFLs is 33 percent and the average reduction of lumen output for 

IRLs is 25 percent. DOE also invites comment on the assumption that 29 percent of halogen 
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IRLs operate on dimmers in the residential sector and 5.0 percent of halogen IRLs operate on 

dimmers in the commercial sector.

ES.3.23 Operating Profiles for Energy Use Characterization

To characterize the nation’s average use of GSFLs and IRLs for a typical year, DOE 

developed annual operating hours by sector using data published in the 2010 U.S. Lighting 

Market Characterization. DOE applied average annual operating hours based on each sector 

(Table ES.2.7 and Table ES.2.8) to calculate energy use. DOE welcomes comment on the enduse operating profiles for the lamp types covered under this rulemaking.

ES.3.24 Residential GSFL LCC Analysis

For the residential GSFL analysis, DOE assumes in the lamp failure event that GSFL 

consumers preserve their lamps when replacing a ballast and utilize the same lamps on the new 

ballast. This allows the lamps to live for their entire rated lifetime and obtains an upper bound for 

LCC savings in the residential sector. DOE requests comment on how likely consumers are to 

exhibit lamp preserving behavior.

ES.3.25 Sales Tax in the LCC Analysis

In the LCC analysis, DOE uses an average sales tax for all three sectors based on sales 

tax values for the 13 divisions and large states weighted by the percent of the total population in 

each division or large state. DOE is considering weighting the sales tax for the residential and 

commercial sectors based on the prevalence of residential or commercial buildings in each 

census division using Residential Energy Consumption Survey (RECS) and Commercial 

Buildings Energy Consumption Survey (CBECS) data, respectively. This may create a specific 

sales tax for each market sector due to the likelihood of different types of buildings to appear in 

certain areas of the country. DOE requests comment on this potential change for the NOPR.

ES.3.26 Spacing Adjustments in the LCC Analysis

During new construction and renovation, the spatial layout of fixtures in a building space 

is not constrained to any previous configuration. However, because DOE’s higher efficacy 

replacements generally maintain lumen output within 10 percent of the baseline system, DOE 

does not assume that spacing is changed in the primary LCC results for the new construction and 

renovation replacement event. DOE requests comment on the likelihood that fixture spacing is 

adjusted during new construction and renovation if systems considered for installation all have 

similar lumen outputs.

ES.3.27 LCC Analysis

DOE requests comments on the methodology and results of the LCC analysis for GSFLs 

and IRLs.
ES-28

ES.3.28 T5s in the Residential Market

In this analysis, DOE has modeled T5 SO lamps in the commercial sector only, because 

they appear to be a negligible fraction of the current residential market. In the absence of data to 

the contrary, DOE has assumed that T5 lamps will remain an unimportant fraction of the 

residential market throughout the analysis period. DOE seeks comment on the validity and 

appropriateness of this assumption, especially in the context of a standard level that could 

significantly increase the price of T8 lamps relative to T5 lamps.

ES.3.29 Shipments and NIA

DOE requests comments on the overall methodology used to develop shipment forecasts 

and estimate national energy savings and the NPV of those savings. In addition, DOE requests 

comment on current incentive programs that could affect future sales of GSFLs and IRLs.

ES.3.30 LCC Subgroups

Some subgroups might be adversely affected by potential energy conservation standards 

for GSFLs and IRLs. DOE is considering the following subgroups for analysis: low-income 

consumers, institutions of religious worship, and institutions serving low-income consumers. 

DOE is considering defining low-income consumers as residential consumers with incomes at or 

below the poverty line as defined by the U.S. Census Bureau. DOE welcomes additional 

suggestions for its LCC subgroup analysis.

ES.3.31 Regulatory Flexibility Act Analysis

DOE conducts a regulatory flexibility analysis that examines the impact on small entities 

and considers alternative ways of reducing negative impacts in the NOPR stage. DOE invites 

interested parties to provide information for any small businesses that manufacture GSFLs and 

IRLs and should be consulted before DOE publishes a NOPR.

ES.3.32 Manufacturer Subgroup Analysis

DOE considers the impacts on certain manufacturer subgroups that have different cost 

structures or operate within different regulatory frameworks in the NOPR stage. DOE requests 

feedback on subgroups to analyze and/or characteristics appropriate for subgroup analysis.

ES.3.33 Manufacturer Impact Analysis

DOE requests comment on its identification of key issues and requests data and 

information from interested parties that can assist in evaluating the potential impact on 

manufacturers.

ES.3.34 Valuing Airborne Emission Reductions

DOE will conduct an emissions analysis as part of the NOPR stage of this rulemaking. 

The primary environmental effect of energy conservation standards for GSFLs and IRLs is to 

reduce power plant emissions resulting from reduced consumption of electricity. DOE will 
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assess the impact on emissions of carbon dioxide (CO2), sulfur dioxide (SO2), nitrogen oxides 

(NOX), and mercury (Hg). DOE also plans on monetizing the emission reductions due to 

standards consistent with methods used in recent DOE standards rulemakings for other consumer 

products and commercial equipment. For example, the most recent interagency estimates of the 

potential global benefits resulting from reduced CO2 emissions in 2015, expressed in 2011$, 

were $6.1, $25.4, $41.0, and $77.7 per metric ton avoided. DOE invites comment on the 

approaches described in chapter 15 for monetizing the emission savings due to energy 

conservation standards.

ES.3.35 Regulatory Impact Analysis (RIA)

In the NOPR stage of this rulemaking, DOE will prepare a regulatory impact analysis to 

address the potential for non-regulatory approaches to supplant or augment energy conservation 

standards to improve the efficiency of GSFLs and IRLs on the market. DOE will attempt to base 

its assessment of non-regulatory initiatives on the actual impacts of any such initiatives to date

on these or other products, and will also consider other available information. DOE requests any 

available data or reports on the existing or past non-regulatory programs and their effectiveness, 

particularly as they relate to the product classes covered under this rulemaking.

ES.3.36 Trial Standard Levels

For the NOPR, DOE will develop trial standard levels (TSLs) based on the CSLs for 

GSFLs and IRLs. DOE is considering several criteria in developing the TSLs, including, but not 

limited to, minimum LCC, maximum NPV, and maximum technologically feasible efficiency. 

These TSLs may include combinations of CSLs and will consider the interaction between 

product classes. From the list of TSLs developed, DOE will select one as its proposed standard 

for the NOPR. DOE invites comment on the criteria it should use as the basis for selection of 

TSLs.