CHAPTER 8. LIFE­CYCLE COST AND PAYBACK PERIOD ANALYSES

TABLE OF CONTENTS

8.1 INTRODUCTION ........................................................................................................... 8­1

8.1.1 General Approach for Life­Cycle Cost and Payback Period Analyses ............... 8­1

8.1.2 Overview of LCC and PBP Inputs....................................................................... 8­3

8.2 LIFE­CYCLE COST INPUTS ........................................................................................ 8­6

8.2.1 Definition ............................................................................................................. 8­6

8.2.2 Total Installed Cost Inputs................................................................................... 8­7

8.2.2.1 Installation Costs...................................................................................... 8­8

8.2.3 Operating Cost Inputs........................................................................................ 8­10

8.2.3.1 Operating Hours..................................................................................... 8­11

8.2.3.2 Power Rating.......................................................................................... 8­11

8.2.3.3 Electricity Prices.................................................................................... 8­12

8.2.3.4 Electricity Price Trend ........................................................................... 8­13

8.2.4 Lifetime.............................................................................................................. 8­16

8.2.5 Replacement Cost .............................................................................................. 8­16

8.2.6 Analysis Period .................................................................................................. 8­17

8.2.7 Discount Rate..................................................................................................... 8­18

8.2.7.1 Residential Discount Rate...................................................................... 8­18

8.2.7.2 Commercial Discount Rate.................................................................... 8­22

8.2.8 Effective Date of Standard................................................................................. 8­25

8.2.9 Residual Value................................................................................................... 8­26

8.3 PAYBACK PERIOD INPUTS...................................................................................... 8­26

8.3.1 Definition ........................................................................................................... 8­26

8.3.2 Rebuttable Presumption Payback Period........................................................... 8­27

8.3.3 Inputs.................................................................................................................. 8­28

8.4 LAMP PURCHASING EVENTS.................................................................................. 8­28

8.5 LIFE­CYCLE COST AND PAYBACK PERIOD RESULTS...................................... 8­30

8.5.1 Results for General Service Fluorescent Lamps................................................ 8­31

8.5.1.1 Product Class: Four­foot medium bipin ≤4,500K.................................. 8­31

8.5.1.2 Product Class: 8­Foot single pin slimline ≤4,500K............................... 8­43

8.5.1.3 Product Class: 8­foot recessed double contact HO ≤4,500K................. 8­51

8.5.2 Life­Cycle Cost Results for Incandescent Reflector Lamps.............................. 8­57

8.6 DETAILED RESULTS AND SENSITIVITY RUNS................................................... 8­61

REFERENCES .......................................................................................................................... 8­62

LIST OF TABLES

Table 8.1.1 Product Classes Analyzed in the LCC and PBP Analyses .......................... 8­3

Table 8.1.2 Summary Information of Inputs for the Life­Cycle Cost and Payback

Period Analyses ............................................................................................................... 8­6

Table 8.2.1 Inputs for Total Installed Costs................................................................ 8­7

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Table 8.2.2 Relamping Times for General Service Fluorescent Lamps and Incandescent

Reflector Lamps*............................................................................................................. 8­9

Table 8.2.3 Relamping and Lamp­and­Ballast Labor Cost for General Service

Fluorescent Lamps and Incandescent Reflector Lamps................................................. 8­10

Table 8.2.4 Inputs for Operating Costs..................................................................... 8­10

Table 8.2.5 Average Operating Hours by Sector and Lamp Type................................ 8­11

Table 8.2.6 Electricity Prices by Census Division, 2006.............................................. 8­12

Table 8.2.7 Average Percentage Shares of Household Debt and Equity Types........... 8­19

Table 8.2.8 Average Nominal and Real Interest Rates for Household Debt Classes... 8­20

Table 8.2.9 Average Nominal and Real Interest Rates for Household Equity Types .. 8­21

Table 8.2.10 Shares and Interest or Return Rates Used for Household Debt and Equity

Types.............................................................................................................................. 8­21

Table 8.2.11 Variables Used to Estimate Company Discount Rates............................ 8­23

Table 8.2.12 Real Discount Rates by Lamp Ownership Category ............................... 8­24

Table 8.2.13 Estimated Share of Lamp Purchases by Ownership Category in the

Commercial Sector......................................................................................................... 8­25

Table 8.2.14 Lamp Ownership by Sector ..................................................................... 8­25

Table 8.2.15 Average Discount Rate by Sector............................................................ 8­25

Table 8.4.1 Framework of Event­Type Scenarios for T12 Lamps................................ 8­30

Table 8.4.2 Framework of Event­Type Scenarios for T8 Lamps................................. 8­30

Table 8.5.1 LCC and PBP Results for a Three­Lamp 4­Foot 40W T12 Medium Bipin

System Operating in the Commercial Sector................................................................. 8­33

Table 8.5.2 LCC and PBP Results for a Three­Lamp 4­Foot 34W T12 Medium Bipin

System Operating in the Commercial Sector................................................................. 8­36

Table 8.5.3 LCC and PBP Results for a 3­Lamp 4­foot 32W T8 Medium Bipin System

Operating in the Commercial Sector.............................................................................. 8­39

Table 8.5.4 Summary of the LCC and PBP Results for a Three­Lamp 4­Foot 40W T12

Medium Bipin System Operating in the Commercial Sector ........................................ 8­41

Table 8.5.5 Summary of the LCC and PBP Results for a Three­Lamp 4­Foot 34W T12

Medium Bipin System Operating in the Commercial Sector ........................................ 8­41

Table 8.5.6 Summary of the LCC and PBP Results for a Three­Lamp 4­Foot 32W T8

Medium Bipin System Operating in the Commercial Sector ........................................ 8­42

Table 8.5.7 LCC and PBP Results for a Two­Lamp 8­Foot 75W T12 Single Pin Slimline

System Operating in the Commercial Sector................................................................. 8­44

Table 8.5.8 LCC and PBP Results for a Two­Lamp 8­Foot 60W T12 Single Pin Slimline

System Operating in the Commercial Sector................................................................. 8­46

Table 8.5.9 LCC and PBP Results for a Two­Lamp 8­Foot 59W T8 Single Pin Slimline

System Operating in the Commercial Sector................................................................. 8­48

Table 8.5.10 Summary of the LCC and PBP Results for a Two­Lamp 8­Foot 75W T12

Single Pin Slimline System Operating in the Commercial Sector................................. 8­49

Table 8.5.11 Summary of the LCC and PBP Results for a Two­Lamp 8­foot 60W T12

Single Pin Slimline System Operating in the Commercial Sector................................. 8­49

Table 8.5.12 Summary of the LCC and PBP Results for a Two­Lamp 8­Foot 59W T8

Single Pin Slimline System Operating in the Commercial Sector................................. 8­50

Table 8.5.13 LCC and PBP Results for a Two­Lamp 8­Foot 110W T12 Recessed Double

Contact HO System Operating in the Industrial Sector................................................. 8­52

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Table 8.5.14 LCC and PBP Results for a Two­Lamp 8­Foot 95W T12 Recessed Double

Contact HO System Operating in the Industrial Sector................................................. 8­54

Table 8.5.15 Summary of the LCC and PBP Results for a Two­Lamp 8­Foot 110W T12

Recessed Double Contact HO System Operating in the Industrial Sector .................... 8­56

Table 8.5.16 Summary of the LCC and PBP Results for a Two­Lamp 8­Foot 95W T12

Recessed Double Contact HO System Operating in the Industrial Sector .................... 8­56

Table 8.5.17 LCC and PBP Results for a 90W PAR38 Lamp Operating in the

Commercial Sector......................................................................................................... 8­58

Table 8.5.18 LCC and PBP Results for a 90W PAR38 Lamp Operating in the Residential

Sector ............................................................................................................................. 8­58

Table 8.5.19 LCC and PBP Results for a 75W PAR38 Lamp Operating in the

Commercial Sector......................................................................................................... 8­59

Table 8.5.20 LCC and PBP Results for a 75W PAR38 Lamp Operating in the Residential

Sector ............................................................................................................................. 8­59

Table 8.5.21 LCC and PBP Results for a 50W PAR30 Lamp Operating in the

Commercial Sector......................................................................................................... 8­60

Table 8.5.22 LCC and PBP Results for a 50W PAR30 Lamp Operating in the Residential

Sector ............................................................................................................................. 8­60

LIST OF FIGURES

Figure 8.1.1 Flow Diagram of Inputs for the Determination of LCC and PBP.............. 8­5

Figure 8.2.1 Residential Sector Electricity Price Trend ............................................... 8­14

Figure 8.2.2 Commercial Sector Electricity Price Trend.............................................. 8­15

Figure 8.2.3 Industrial Sector Electricity Price Trend .................................................. 8­15

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CHAPTER 8. LIFE­CYCLE COST AND PAYBACK PERIOD ANALYSES

8.1 INTRODUCTION

This chapter describes the analysis the U.S. Department of Energy (DOE) conducts to

evaluate the economic impacts on individual consumers of possible energy conservation

standards for general service fluorescent lamps (GSFL) and incandescent reflector lamps (IRL).

New standards usually decrease operating costs and increase purchase costs for consumers. This

chapter describes the three metrics used in this analysis to determine the impact of standards on

individual consumers:

Life­cycle cost (LCC) is the total (discounted) consumer cost over the analysis period

including purchase price, operating costs (including energy expenditures), and

installation costs.

Payback period (PBP) is the number of years it takes a customer to recover the generally

higher purchase price of a more energy­efficient product through the operating cost

savings of using the more energy­efficient product. The PBP is calculated as the change

in first cost divided by the change in operating costs in the first year.

Rebuttable payback period is a special case in which the PBP is calculated based on

laboratory conditions, specifically DOE test procedure inputs. DOE calculates the

aforementioned LCC and PBP using a range of inputs, which are designed to reflect

actual conditions.

Sections 8.2 and 8.3 discuss inputs to the LCC and PBP, respectively. Section 8.4

discusses the different purchasing events DOE analyzes, which affect consumer economics.

Section 8.5 presents the results for the LCC and PBP. Key variables and calculations are

presented for each metric. DOE performs the calculations discussed here using a series of

Microsoft Excel® spreadsheets developed for this rulemaking. Stakeholders are invited to

download and examine the spreadsheets, which are available at

http://www.eere.energy.gov/buildings/appliance_standards/residential/incandescent_lamps.html.

Appendix 8A presents details and instructions for using the spreadsheets. Appendix 8B presents

sensitivity results as well as results of the Monte Carlo model.

8.1.1 General Approach for Life­Cycle Cost and Payback Period Analyses

Recognizing that several inputs to the LCC and PBP analysis are either variable or

uncertain, DOE incorporates Monte Carlo simulation and probability distributions into its LCC

and PBP model. Appendix 8B contains a detailed set of results using Monte Carlo simulation.

DOE incorporates both Monte Carlo simulation and probability distributions by using Microsoft

Excel spreadsheets combined with Crystal Ball®, a commercially available add­in program.

The relationship between increasing selling price and increasing energy efficiency is the

predominant influence on the LCC and PBP results. However, other factors related to the

characteristics of the consumer using the products also affect the results. Based on the

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geographic region, sector, and application in which a consumer uses the lamps, factors such as

energy prices, sales tax, and energy usage can vary. By using the Monte Carlo simulation and

separate sensitivity runs, DOE accounts for this variability.

For the LCC and PBP analyses, DOE considers variability in the discount rate. DOE also

models variability in operating hours by sector, lamp type, and building applications. By

developing samples by building type, DOE can perform the LCC and PBP calculations and

account for the variability in operating hours, electricity price, and sales tax among a variety of

buildings. DOE uses the Energy Information Administration’s (EIA) 2001 Residential Energy

Consumption Survey (RECS), 2003 Commercial Buildings Energy Consumption Survey

CBECS, and 2002 Manufacturing Energy Consumption Survey (MECS) to develop samples by

building type, as well as U.S. Lighting Market Characterization: Volume I (LMC) to develop the

operating hour characteristics by application in those buildings. The LCC and PBP spreadsheets

present the results of the analysis as average values, relative to the baseline conditions.

(Appendix 8B presents more information on the distribution of results from the LCC and PBP

analysis, including the average and median PBP values and the percentages of trials which result

in positive or negative LCCs).

In the LCC and PBP analyses, DOE considers multiple pathways to energy savings.

Generally, consumers can choose when moving up in lamp efficacy whether to stay at the same

rated lamp wattage and have more light output, or move to a lower wattage and have the same or

roughly equivalent light output as the baseline lamp and lamp­and­ballast system. While

consumers clearly would have other choices in addition to those presented in the LCC, DOE

considers only energy­saving lamp designs and lamp­and­ballast designs in the LCC. Other

choices, such as substituting a lamp that is outside the scope of this rulemaking (e.g., exempted

65 Watt BR IRL) or substituting a lamp with a higher efficacy lamp that does not save energy are

addressed in the national impact analysis (NIA; Chapter 10).

For GSFL, DOE considers various scenarios that prompt consumers to buy a lamp or

lamp­and­ballast system in the base versus standards cases. Specifically, the “event” that

prompts the purchase of a new lamp (e.g., a lamp failure or a ballast failure) will influence the

cost­effectiveness of the consumer purchase decision. For example, depending on the candidate

standard level (CSL), a consumer may or may not have to purchase a new ballast to install a

more efficient lamp. Whether the consumer would have replaced the ballast absent standards

affects the economics of the substitution. DOE, therefore, bases the LCC and PBP analyses

around “lamp purchasing events.” For IRL where no ballast is involved, DOE simply analyzes

lamp failure scenarios. Section 8.4 discusses the lamp purchasing events for GSFL in more

detail. The LCC and PBP analyses spreadsheet reports results per purchasing event.

The LCC and PBP analyses time period for this rulemaking is the service life of the

longest baseline lamp, or a multiple thereof. By using this analysis period, LCC results are more

easily compared and contrasted for different CSLs. However, to account for any remaining lamp

life at the end of the analysis period and consistent with the Federal Energy Management

Program’s Life­Cycle Costing Manuali

, DOE designates a discounted residual value for lamps or

ballasts that have remaining value. For example, if a more efficient lamp expires before the end

of the analysis period, DOE assumes that the lamp is replaced during the analysis period and

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credits the unused lamp life of this replacement lamp back as a residual value at the end of the

analysis period.

DOE is conducting the LCC and PBP analyses on the baseline lamps from the

representative product classes identified in Chapter 3. Table 8.1.1 shows the set of four

representative product classes that DOE is evaluating in this analysis.

Table 8.1.1 Product Classes Analyzed in the LCC and PBP Analyses

General Service Fluorescent Lamps

4­Foot Linear Medium Bipin, ≤4,500K

8­Foot Linear Single Pin Slimline, ≤4,500K

8­Foot Linear Recessed Double­Contact High­Output (HO), ≤4,500K

Incandescent Reflector Lamps

Standard­Spectrum

8.1.2 Overview of LCC and PBP Inputs

As mentioned earlier, the LCC represents the total consumer expense over the analysis

period, including purchase expenses, operating costs (including energy expenditures), and

installation costs. DOE discounts future operating costs to the time of purchase and sums them

over the analysis period. Due to the large variance of lamp lifetimes, for this rulemaking, DOE

bases the analysis period on the longest life baseline lamp within a product class. The LCC

calculation credits back the “residual value” of a lamp, or lamp and ballast, if it has any

operating life remaining at the end of the analysis period. The residual value is the discounted

total installed cost of a lamp, or lamp and ballast, multiplied by the percentage of the remaining

life past the analysis period. The PBP represents the number of years it takes customers to

recover the purchase price of more energy­efficient equipment through lower operating costs.

The PBP is calculated as the change in first cost divided by the change in operating costs in the

first year.

DOE categorizes inputs to the LCC and PBP analysis as follows: (1) inputs for

establishing the purchase expense, otherwise known as the total installed cost; and (2) inputs for

calculating the expenses incurred during the operation of the lamp, otherwise know as the

operating cost. In addition, inputs to the LCC are used to calculate a residual value for any

remaining product lifetime beyond the analysis period and replacement costs for those lamps

whose service life is less than the analysis period.

The primary inputs for establishing the life­cycle cost and payback period are:

End­User Product Price: As discussed in Chapter 7, DOE starts with manufacturer catalog

(“blue­book”) pricing, and applies discounts to develop low, medium, and high prices for

all lamp types. The end­user product prices represent the consumer price before tax and

installation.

Sales Tax: DOE then applies sales tax to convert the end­user product price to a final

product price including sales tax. Chapter 7 describes the sales tax markup in detail.

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Installation Cost: This input represents the cost to the commercial or industrial customers of

installing the lamps or lamp systems. The installation cost represents all costs required to

install the lamp or lamp system but does not include the end­user product price. The

installation cost includes labor and overhead. Thus, the total installed cost equals the

end­user product price including sales tax plus the installation cost.

The primary inputs for calculating the operating cost include the following:

Annual Operating Hours: The annual operating hours are the hours that a lamp is estimated

to be in use during one year. The energy use characterization (Chapter 6) details how

DOE determines the lamp operating hours as a function of end­user sector, geographic

region, and building type.

Power Rating: The power consumption is the site­energy usage rate associated with

operating the lamp system. The energy use characterization (Chapter 6) details how DOE

determines the power ratings for the lamp and lamp­and­ballast systems considered in the

analyses.

Electricity Prices: DOE uses the average price per kilowatt­hour (i.e., $/kWh) paid by

customers. DOE determines electricity prices using national average residential,

commercial, and industrial electricity prices for the sample calculation. For the Monte

Carlo distribution, DOE uses average residential, commercial, and industrial values for

13 regions and large States. DOE develops all electricity price inputs using 2005 EIA

data.

Electricity Price Trends: DOE uses the EIA’s Annual Energy Outlook 2007 (AEO2007)ii to

forecast electricity prices. For the results presented in this chapter, DOE uses the

AEO2007 reference case to forecast future electricity prices.

Lifetime: Lifetime is the total hours in operation after which the consumer retires the lamp or

components of a lamp system from service.

Discount Rate: The discount rate is the rate at which DOE discounts future expenditures to

establish their present value.

Analysis Period: Analysis period is the time span over which DOE calculates the LCC.

The residual value calculation also uses all of the installed cost inputs as well as several

operating cost inputs. Figure 8.1.1 depicts the relationships between the installed cost, operating

cost, and residual value inputs for the calculation of the LCC and PBP. In this figure, the

rectangular boxes indicate the inputs, the parallelograms indicate intermediate calculated values,

and the diamond boxes indicate the analysis outputs (the LCC and PBP).

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End­User

Product Price

Sales Tax

Final

Product

Price

Installation

Cost

Total

Installed

Cost

Electricity

Prices Annual

Energy

Usage

Cost

PBP

Electricity

Price Trend

Discount Rate

Analysis

Period

Energy

Usage

Cost Over

Analysis

Period

Replacement

Cost

Operating

Cost Over

Analysis

Period

Residual

Value

LCC

Power Rating

Operating

Hours

Product

Lifetime

Service

Life

Energy

Consumption

Total

Replacement

Cost

Calculated

Value LCC Input LCCOutput

Legend

Figure 8.1.1 Flow Diagram of Inputs for the Determination of LCC and PBP

Table 8.1.2 summarizes the input values that DOE uses to calculate the LCC and PBP for

GSFL and IRL. Each row summarizes the total installed cost inputs, operating cost, replacement

cost, and residual value inputs, including the lifetime, discount rate, and electricity price trend.

DOE characterizes all of the total cost inputs with single­point values, but characterizes several

of the operating cost inputs with probability distributions that capture the input’s uncertainty

and/or variability in the Monte Carlo analysis. Table 8.1.2 also lists the chapter of the Technical

Support Document that details the inputs.

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Table 8.1.2 Summary Information of Inputs for the Life­Cycle Cost and Payback Period

Analyses

Factor Weighted­Average Value TSD Reference

Section

Total Installed Cost Primary Inputs

End­User Product Price Varies with lamp and ballast Chapter 7

Sales Tax Varies by census region Chapter 7

Installation Cost Varies by equipment installed and sector Chapter 8

Operating Cost Primary Inputs

Annual Operating Hours Vary by lamp type, sector, and building type. Chapter 6

Power Rating Varies with lamp type, and lamp or lamp­andballast system Chapter 6

Electricity Prices Vary by sector and census region Chapter 8

Electricity Price Trends Vary with price forecast scenario Chapter 8

Discount Rate Varies with sector Chapter 8

Analysis Period Varies with baseline lamp and annual operating

hours. Chapter 8

Replacement Cost and Residual Value Primary Inputs

Total Installed Cost Varies with lamp and ballast, census region,

equipment installed and sector Chapters 7, 8

Lifetime Varies with lamp and system Chapters 5, 8

Discount Rate Varies with sector Chapter 8

Analysis Period Varies with baseline lamp and annual operating

hours. Chapter 8

Sections 8.2 and 8.3 discuss the inputs depicted in this table of installed costs and

operating costs.

8.2 LIFE­CYCLE COST INPUTS

8.2.1 Definition

LCC is the total customer cost over the life of a product, including total installed costs,

operating costs, replacement costs, and residual value. Future operating costs and replacement

costs are discounted to the analysis start year (2012) and summed over the analysis period. The

residual value (if any) is credited back to the LCC, if the operating life of the standards case

technology exceeds that of the analysis period. The LCC is defined by the following equation:

N OCt t + RC RV LCC = IC +∑ t − N

t=1 (1+ r) (1+ r) Eq. 8.1

where

LCC = life­cycle cost ($),

IC = total installed cost ($),

N = analysis period,

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∑ = sum over the analysis period, from year 1 to year N,

OC = operating cost ($),

RC = replacement cost ($),

r = discount rate,

t = year for which operating cost or replacement cost is determined, and

RV = residual value for an analysis period, N.

Because DOE gathered most of its data for the LCC and PBP analyses in 2006, DOE

expresses all the costs in its LCC and PBP analyses in 2006 dollars.

8.2.2 Total Installed Cost Inputs

The total installed cost to the customer is defined by the following equation:

IC = FPP + INST

Eq. 8.2

where

FPP = final product price (i.e., customer price for the product only, including

sales tax), expressed in dollars, and

INST = installation cost or the customer price to install products (i.e., the cost for

labor and materials), expressed in dollars.

In the product price determination (Chapter 7), DOE develops end­user product prices

and sales taxes to derive final product prices. DOE then applies installation costs, where

necessary, to derive the total installed costs for use in the LCC. The table below shows inputs to

determine total installed costs.

Table 8.2.1 Inputs for Total Installed Costs

End­User Product Price ($)

Sales Tax ($)

Installation Cost ($)

The end­user product price is the average purchase price a consumer pays before sales tax

for lamp designs or lamp­and­ballast designs. The sales tax represents State and local sales taxes

applied to the end­user product price. It is a multiplicative factor that increases the end­user

product price. Installation cost is the cost to the customer of installing the lamps or lamp

systems, and only applies in the commercial and industrial sectors. The installation cost

represents all costs required to install the lamp or lamp­and­ballast system but does not include

the final product price. The installation cost includes labor and overhead. Thus, the total

installed cost equals the final product price plus the installation cost. DOE calculates the total

installed cost for the lamps analyzed based on the following equation:

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IC = FPP + INST

Eq. 8.3 = PRICE × MUTAX + INST

where

IC = total installed cost,

FPP = final product price,

INST = installation cost,

PRICE = end­user product price, and

MUTAX = sales tax mark up

Chapter 7 provides detail on the end­user product price and sales tax. Discussion on the

installation costs follows.

8.2.2.1 Installation Costs

DOE applies lamp and ballast installation costs only to lamps and lamp­and­ballast

systems installed in the commercial and industrial sectors. DOE assumes that in the residential

sector, the homeowner replaces the lamps and incurs no additional labor charge.

On September 19, 2000, DOE issued a final rule establishing energy conservation

standards for ballasts (hereafter referred to as ‘‘the 2000 Ballast Rule’’). 65 FR 56740 (Sept. 19,

2000); 10 CFR 430.23(m)(4). For GSFL, DOE obtains estimates of the prevalence of group

versus spot relamping from the 2000 Ballast Rule. DOE then weighs the spot and group

relamping times by the percent occurrence of spot versus group relamping to derive weighted

averaged relamping times. According to the 2000 Ballast Rule, group relamping occurs, on

average, 25 percent of the time for 4­foot medium bipin systems, 37 percent for 8­foot single pin

slimline systems, and 31 percent for 8­foot recessed double contact high­output systems.iii These

percentages are used to calculate an average time to change GSFL lamp designs.

To account for installation costs for IRL, DOE uses relamping time estimates from the RS

Means Electrical Cost Data, 2007 (RS Means).iv Table 8.2.2 lists average labor times to install a

lamp and a lamp and ballast (only for GSFL) for IRL and GSFL.

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Table 8.2.2 Relamping Times for General Service Fluorescent Lamps and Incandescent

Reflector Lamps*

Lamp Type

Spot Relamp

Time

minutes

Group Relamp

Time

minutes

Average

Relamp

Time

minutes

Time to Install

Lamps and

Ballasts

minutes

General Service Fluorescent Lamps (Commercial and Industrial)

2­Lamp Fixture­4­Foot Medium

Bipin 27.0 14.0 23.8

30.0

3­Lamp Fixture­4­Foot Medium

Bipin 27.5 14.5 24.3

35.0

2­Lamp Fixture­ 8­Foot Single Pin

Slimline 20.5 10.5 16.8

55.0

2­Lamp Fixture­8­Foot Recessed

Double Contact High­Output 26.5 13.5 22.5

60.0

Incandescent Reflector Lamps (Commercial and Industrial)

All 4.0 N/A

*GSFL labor times are obtained from the 2000 Ballast Rule. IRL labor times are obtained from RS Means.

For lamp­and­ballast installations, DOE derives labor rates for electricians and helpers

from RS Means. Labor rates are the sum of the wage rate, employer­paid fringe benefits (i.e.,

vacation pay, employer­paid health, and welfare costs), and any appropriate training and industry

advancement funds costs. An electrician’s average hourly rate with overhead and profit is

typically $65.35, and a helper’s average hourly rate is $42.40. DOE assumes that 50 percent of

the electrician labor rate and 50 percent of the helper labor rate comprise the lamp­and­ballast

installation rate.

For lamp replacements in the commercial sector, DOE assumes that the task is performed

by a general maintenance worker. The labor rate of $15.49 (adjusted to 2006$ from $15.01 in

2005) was obtained from the U.S. Bureau of Labor Statistics for a General Maintenance

Worker.v Using these labor rates and the labor times listed in Table 8.2.2, DOE derives the

average cost to install a lamp and the average cost to install a lamp and ballast.

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Table 8.2.3 Relamping and Lamp­and­Ballast Labor Cost for General Service Fluorescent

Lamps and Incandescent Reflector Lamps

Lamp Type Relamping Labor Cost

Labor Cost to Install

Lamps and Ballast

General Service Fluorescent Lamp (Commercial and Industrial)

2­Lamp Fixture, 4­Foot Medium Bipin $6.13 $26.94

3­Lamp Fixture, 4­Foot Medium Bipin $6.26 $31.43

2­Lamp Fixture, 8­Foot Single Pin Slimline $4.34 $49.39

2­Lamp Fixture, 8­Foot Recessed DoubleContact High­Output $5.80 $53.88

Incandescent Reflector Lamps (Commercial and Industrial)

All $1.03 N/A

8.2.3 Operating Cost Inputs

The operating cost represents the costs incurred in the operation of the lamp or lamp­andballast system. Table 8.2.4 lists the inputs for operating costs. The analysis period, discount

rate, and effective date of the standard are required for determining the operating cost and for

establishing the operating cost present value. The electricity consumption for the baseline and

other CSLs examined enable comparison of standards’ operating costs.

Table 8.2.4 Inputs for Operating Costs

Annual Operating Hours

Power Rating

Electricity Prices

Electricity Price Trends

Discount Rate

Analysis Period

The annual operating hours are the estimated hours that a lamp is in use during one year.

Power rating refers to the rate of site energy usage associated with operating the lamp or lampand­ballast system. Both the annual operating hours and power rating are used to calculate the

total annual energy consumption. Electricity prices used in the analysis are the price per

kilowatt­hour in cents or dollars (e.g., $/kWh) paid by each customer for electricity. DOE uses

electricity price trends to forecast electricity prices for future year analysis. These trends with

the electricity price and annual energy consumption are used to calculate the energy cost in each

year. DOE defines energy cost by the following equation:

OC = Econs × EP × EPT

= (PWR ×OH )× EP × EPT Eq. 8.4

where

OC = operating costs,

Econs = annual energy consumed,

EP = electricity price,

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EERE-2007-BT-TP-0013 COMMENT 05
EPT = electricity price trend factor relative to 2006,

PWR = power rating (rate of energy use, measured in watts), and

OH = annual operating hours.

The remainder of this section provides information about each of the above input

variables that DOE used to calculate the operating costs for GSFL and IRL.

8.2.3.1 Operating Hours

The energy use characterization (Chapter 6) details how DOE determines the annual

energy consumption for baseline and standard­compliant products. An important input to

determining the energy consumption is the total hours per year that the product is in operation.

The operating hours are also used to calculate the lamp service life, which is ultimately used in

calculating the total replacement cost and residual value.

As described in Chapter 6, DOE establishes operating hour distributions for GSFL and

IRL. In conjunction with data from LMC, DOE uses data from EIA’s CBECS 2003, RECS

2001, and the MECS 2002. These EIA studies provide information on the distribution of

buildings within the United States by building type and census division. DOE associates the

LMC’s operating hour data by building type with the EIA’s data by building type and census

division to derive operating hours by census division and large States. This allowed DOE to

correlate its electricity price distribution and sales tax distribution (see Chapter 7) with its

operating hour distribution by census division and large State in the LCC spreadsheet. Table

8.2.5 presents the mean operating hours for GSFL and IRL for each sector.

Table 8.2.5 Average Operating Hours by Sector and Lamp Type

Sector Lamp Category Average Annual Operating Hours

hours/year

Residential IRL 884

Commercial GSFL 3,435

IRL 3,451

Industrial GSFL 4,795

IRL 4,664

8.2.3.2 Power Rating

As described in the energy use and end load characterization (Chapter 6), DOE uses the

power rating (in watts) with the annual operating hours (in hours) to calculate the annual energy

usage (in kilowatt hours) of the lamp and lamp­and­ballast designs DOE considers.

General Service Fluorescent Lamps

Because a fluorescent lamp requires a ballast to operate, DOE analyzes these lamps as

systems consisting of both lamps and ballasts. Therefore, in both the “lamp only replacement”

and “lamp­and­ballast replacement” scenarios, the system input power represents the energy

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EERE-2007-BT-TP-0013 COMMENT 05
consumption rate of both the lamps and ballast, and therefore is different than simply the rated

lamp power. When each lamp is paired with ballasts with differing ballast factors (BFs), the

lamp systems have different power ratings. See Chapter 6 for detailed results showing power

ratings and annual energy consumption estimates given a BF and lamp power and operating

hours.

Incandescent Reflector Lamps

Because an IRL lamp system consists of only the lamp, the system’s annual energy use is

simply the product of the rated power and operating hours of the lamp. Detailed tables depicting

the power rating and annual energy consumption for all of the IRL lamp designs are available in

Chapter 6.

8.2.3.3 Electricity Prices

DOE estimates electricity prices for residential, commercial, and industrial consumers in

each of the 13 regions and large States by using EIA Form 861 data.vi Table 8.2.6 lists the 13

geographic regions. The EIA Form 861 data are published annually and include annual

electricity sales in kilowatt hours; revenues from electricity sales; and number of consumers for

the residential, commercial, and industrial sectors for every utility serving final consumers. The

calculation of an average electricity prices proceeds in two steps:

1) For each utility, estimate an average residential, commercial, or industrial price by

dividing the residential, commercial, or industrial revenues by residential, commercial, or

industrial sales.

2) Calculate a regional average price, weighting each utility with customers in a region

by the number of residential, commercial, or industrial consumers served in that region.

The calculation uses the most recent available EIA data at the time the analysis was

conducted, from 2005. Table 8.2.6 shows the results for each geographic region. Because DOE

conducted the LCC and PBP analyses in 2006$, it needed to convert all electricity prices into

2006$. To perform the necessary monetary conversion, DOE uses the consumer price index

(CPI) to convert the electricity prices from 2005$ to 2006$. As described in the following

section on electricity price trends, DOE normalizes energy prices to 2006. Therefore, to forecast

energy prices for any given future year, DOE establishes energy prices for 2006. In Table 8.2.6,

DOE uses data from the AEO2007 to estimate the electricity prices for 2006.vii DOE multiplies

the electricity price in 2005 by the ratio of the AEO2007­estimated residential, commercial, or

industrial prices for 2006 and 2005.

Table 8.2.6 Electricity Prices by Census Division, 2006

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EERE-2007-BT-TP-0013 COMMENT 05
Census Division

Electricity Prices,* 2006

Residential Commercial Industrial

2006$/kWh 2006$/kWh 2006$/kWh

New England $0.129 $0.105 $0.094

Middle Atlantic $0.110 $0.088 $0.059

East North Central $0.087 $0.075 $0.054

West North Central $0.082 $0.070 $0.075

South Atlantic $0.086 $0.074 $0.054

East South Central $0.078 $0.078 $0.065

West South Central $0.086 $0.079 $0.065

Mountain $0.089 $0.080 $0.058

Pacific $0.086 $0.084 $0.050

New York State $0.160 $0.097 $0.056

California $0.099 $0.087 $0.078

Texas $0.113 $0.106 $0.095

Florida $0.129 $0.121 $0.090

U.S. Weighted Average $0.100 $0.086 $0.070

* DOE converts dollars to 2006$ by multiplying costs in 2005$ by the ratio of 2006 CPI (201.6) to 2005 CPI

(195.3). DOE converts the price for 2005 to the price in 2006 by multiplying the 2005 price by the ratio of the

average AEO electricity price in 2006 to the average AEO electricity price in 2005.

8.2.3.4 Electricity Price Trend

The electricity price trend projects the future cost of electricity to 2030. DOE calculates

the LCC and PBP using three separate projections from AEO2007: reference, low economic

growth, and high economic growth. These three cases reflect the uncertainty of economic

growth in the forecast period. The high and low growth cases show the projected effects of

alternative growth assumptions on energy markets. DOE normalizes these three AEO2007

scenarios to the 2006 electricity price, and then uses that electricity price factor to scale the 2006

electricity prices. Figure 8.2.1 through Figure 8.2.3 show the residential, commercial, and

industrial electricity price trends, respectively, based on the three AEO2007 projections. The

LCC results presented in this chapter are based on the AEO2007 reference case.

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EERE-2007-BT-TP-0013 COMMENT 05
1.02

1.00

0.98

0.96

0.90

0.92

0.94

2000

Price Trend (2006=1)

2005 2010

High Growth

Reference

Low Growth

2015 2020

Year

2025 2030 2035

Figure 8.2.1 Residential Sector Electricity Price Trend

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EERE-2007-BT-TP-0013 COMMENT 05
1.02

1.00

0.98

0.96

0.94

0.86

0.88

0.90

0.92

2000

Price Trend (2006=1)

2005 2010

High Growth

Reference

Low Growth

2015 2020 2025 2030 2035

Year

Figure 8.2.2 Commercial Sector Electricity Price Trend

1.04

0.99

0.94

0.84

0.89

2000

Price Trend (2006=1)

2005 2010

High Growth

Reference

Low Growth

2015 2020

Year

2025 2030 2035

Figure 8.2.3  Industrial Sector Electricity Price Trend

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EERE-2007-BT-TP-0013 COMMENT 05
In the LCC spreadsheet, these electricity price trends are used to project electricity prices

into the future, which are then multiplied by the annual energy usage.  The resulting operating

costs are presented in both the LCC spreadsheets and the LCC results tables in this chapter.  

8.2.4 Lifetime

DOE defines lifetime as the age in hours in operation when a lamp or ballast is retired

from service.  DOE uses published manufacturing literature when available to derive lamp

lifetimes.  When published manufacturing literature on lamp lifetime is not available, DOE

derives lamp lifetimes in the engineering analysis (Chapter 5).  For GSFL, DOE bases its

calculation of lamp lifetimes for both base and standards case lamps on 3­hour start data. For

ballasts, DOE uses the average ballast lifetime used in the 2000 Ballast Rule (49,054 hrs).

Like the calculation of relamping costs, DOE averages the group versus spot relamping

impact on lifetime by their percent occurrence for GSFL.  DOE assumes a lamp subject to group

re­lamping practices operates for 75 percent of its rated life.  DOE obtained this estimate from

the 2000 Ballast Rule.  DOE then applies this life impact factor to the rated lifetimes from the

manufacturing literature for the GSFL it is analyzing.  For 4­foot medium bipin, the average

lifetime DOE uses in the analysis is 94 percent of the rated lifetime.  For 8­foot single pin

slimline, the average lifetime is 91 percent of the rated lifetime.  For 8­foot recessed double

contact HO, the average lifetime is 92 percent of the rated lifetime.  DOE does not assume an

impact on lifetime due to group re­lamping for IRL.

As discussed in the technology assessment (Chapter 3), many technology options to

improve GSFL and IRL efficiencies often affect the lifetime of the lamp.  For this reason, the

baseline and standard level designs for the LCC and PBP analyses have a wide range of

lifetimes.  

8.2.5 Replacement Cost

As stated earlier, the lifetime is the age (total hours in operation) at which the lamp or

components of a lamp system are retired from service.  The lifetime paired with the operating

hours yields the service life of the lamp in years.  Replacement costs are the labor and materials

costs associated with replacing a lamp at the end of its lifetime.  By using the service life and

replacement cost, one can calculate the total replacement cost each year. 

Replacement costs are the labor and materials costs associated with replacing a lamp at

the end of its lifetime.  Because the lifetimes of GSFL and IRL lamp designs vary within each of

their respective product classes, it is at times necessary to replace a lamp within the analysis

period.  Generally, if the analysis period is greater than the lamp service lifetime for a particular

baseline or standard level design, those lamps will require replacement to reach the end of the

analytical period.  Each year in which a lamp reaches the end of its life, a new lamp is purchased

and installed at the beginning of that year, and the first cost and installation cost are discounted

back to the base year of the analysis period.  During years in which replacement is necessary, 

DOE based the replacement costs on the total installed cost inputs, as seen in the following

equation:

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EERE-2007-BT-TP-0013 COMMENT 05
RC = FPPL + INSTL Eq. 8.5 = PRICEL × MUTAX + INSTL

where

RC = replacement cost, expressed in dollars,

FPPL = final product price (price for the product only) expressed in dollars,

INSTL = installation cost,

PRICEL = end­user product price expressed in dollars, and

MUTAX = sales tax.

For the years when no replacement is necessary, the replacement costs are set to zero.  

For GSFL, the replacement costs only include the end­user product price of the lamp and the

installation cost of the lamp, rather prices or costs associated with the entire lamp­and­ballast

system.  For the LCC and PBP analyses, DOE selects time periods of analysis that did not

require replacement of the ballast.  For this reason, only lamp price and labor costs are included

in the calculation of labor costs.  For IRL, because there is no ballast in the analysis, the

replacement cost is simply the total installed cost of the lamp itself.

8.2.6 Analysis Period

The analysis period is the time span over which the LCC is calculated.  To account for

variability in lifetime of lamp designs, DOE develops a consistent analytical time

period⎯comparing more efficacious lamps against a baseline lamp over the lifetime of the

longest­lived baseline lamp in a particular product class.  When this analysis period is shorter

than the lifetime of the replacement lamp, DOE accounts for the remaining life of the

replacement lamp as a residual value.  When the analysis period is longer than the lifetime of the

replacement lamp, a second replacement lamp is installed, and if any operating life of that

second replacement lamp remains at the end of the analysis period, then its residual value is

added back into the LCC.  By using the average annual operating hours paired with published

lamp lifetimes, DOE calculates the lamp service lifetime in years. 

DOE bases the analysis period on the longest baseline lamp life in a certain product class

divided by the annual operating hours of that lamp.  If the user chooses to run the LCC using

weighted average values (i.e., in “sample calculation” mode), then the analysis period is based on

the longest baseline lamp life divided by the average annual operating hours for that lamp in a

chosen sector, or a multiple thereof.  For example, the longest lived baseline IRL lamp is 3,000

hours.  If the user chooses to analyze this lamp in the commercial sector, then the analysis period

is the lamp lifetime of 3,000 hours divided by the average annual operating hours of IRL in the

commercial sector, 3,450 hours per year, or 0.9 years.  To allow users to compare the cost of IRL

lamps over multiple lamp lifetimes, one can select a multiple of this analysis period (i.e., 1.8, 2.7, 

or 3.6 years).  If the user chooses to run the LCC using the Monte Carlo simulation (i.e., in

“Crystal Ball” mode), the analysis period is based on the longest baseline lamp life divided by

the annual operating hours chosen by Crystal Ball®.  For example, the user may choose to run

IRL in the commercial sector using Crystal Ball®.  If Crystal Ball® selects a building that is used

for religious worship, the analysis period for IRL for that selection will be based on a lamp

lifetime of 3,000 hours divided by the annual operating hours of IRL in a building used for

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EERE-2007-BT-TP-0013 COMMENT 05
religious worship 1,609 hours per year, or 1.9 years.  Users cannot select a multiple of this

analysis period when using the Monte Carlo simulation.

8.2.7 Discount Rate

The discount rate is the rate at which DOE discounts future expenditures to establish their

present values.  DOE derives the discount rates for the lamps rulemaking separately for

residential and commercial/industrial consumers.  For residential consumers, DOE estimates the

discount rate by looking across all possible debt or asset classes that might be used to purchase

lamps.  For the commercial and industrial consumers, DOE estimates the cost of capital for

commercial and industrial companies by examining both debt and equity capital, and develops an

appropriately weighted average of the cost to the company of equity and debt financing. 

8.2.7.1 Residential Discount Rate

GSFL and IRL are comparatively low­cost products for households to replace.  With

retail prices under one dollar for certain lamp types, households typically purchase lamps as

needed.  DOE’s approach involves identifying all possible debt or asset classes that might be

used to purchase replacement equipment, including household assets that might be affected

indirectly.1

  DOE does not include debt from primary mortgages and equity of assets considered

non­liquid (such as retirement accounts), since these would likely not be used to finance

replacement lamp purchases.  DOE estimates the average shares of the various debt and equity

classes in the average U.S. household equity and debt portfolios using the Federal Reserve’s

Survey of Consumer Finances (SCF) data for 1989, 1992, 1995, 1998, 2001, and 2004.  Table

8.2.7 shows the average shares of each considered class.  DOE uses the mean share of each class

across the six survey years (15 years) as the basis for estimating household financing of lamps

and lighting equipment.

An indirect effect would arise if a household sold assets to pay off a loan or credit card debt that might have been

used to finance the actual lamp purchase.

8­18

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EERE-2007-BT-TP-0013 COMMENT 05
Table 8.2.7  Average Percentage Shares of Household Debt and Equity Types

Type 1989 SCF 1992 SCF 1995 SCF 1998 SCF 2001 SCF 2004 SCF

Mean

%

Home Equity Loans 4.3 4.5 2.7 2.8 2.8 4.4 3.6

Credit Cards 1.6 2.1 2.6 2.2 1.7 2.0 2.0

Other Installment Loans 2.8 1.7 1.4 1.7 1.1 1.3 1.7

Other Residential Loans 4.4 6.9 5.2 4.3 3.1 5.8 4.9

Other Line of Credit 1.1 0.6 0.4 0.2 0.3 0.5 0.5

Checking Accounts 5.8 4.7 4.9 3.9 3.6 4.2 4.5

Savings and Money Market 19.2 18.8 14.0 12.8 14.2 15.1 15.7

Certificate of Deposit (CD) 14.5 11.7 9.4 7.0 5.4 5.9 9.0

Savings Bond 2.2 1.7 2.2 1.1 1.2 0.9 1.5

Bonds 13.8 12.3 10.5 7.0 7.9 8.4 10.0

Stocks 22.4 24.0 25.9 36.9 37.5 28.0 29.1

Mutual Funds 8.0 11.1 20.9 20.1 21.3 23.4 17.5

Total 100 100 100 100 100 100 100

DOE estimates interest or return rates associated with each type of equity and debt.  The

data source for the interest rates for loans, credit cards, and lines of credit is the Federal Reserve

Board’s SCF in 1989, 1992, 1995, 1998, 2001, and 2004.  The top half of Table 8.2.8 shows the

average nominal interest rates in each year and the inflation rates used to calculate real rates.  For

home equity loans, DOE calculates effective interest rates in a similar manner as for mortgage

rates, since interest on such loans is tax deductible.  The bottom half of the table shows the

average effective real interest rates in each year and the mean rate across all the years.  Since the

interest rates for each debt carried by households in these years were established over 15 years, 

DOE believes they are representative of rates that may be in effect in 2012.

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EERE-2007-BT-TP-0013 COMMENT 05
Table 8.2.8  Average Nominal and Real Interest Rates for Household Debt Classes

Type 1989 SCF 1992 SCF 1995 SCF 1998 SCF 2001 SCF 2004 SCF

Mean

%

Nominal Interest Rates %

Home Equity Loans 11.5 9.6 9.6 9.8 8.7 5.7 9.2

Credit Cards* ­ ­ 14.2 14.5 14.2 11.7 13.6

Other Installment Loans 9.0 7.8 9.3 7.8 8.7 7.4 8.3

Other Residential Loans 8.8 7.6 7.7 7.7 7.5 6.0 7.5

Other Line of Credit 14.8 12.7 12.4 11.9 14.7 8.8 12.5

Inflation rate 4.82 3.01 2.83 1.56 2.85 2.66

Real Interest Rates %

Home Equity Loans 3.8 4.3 4.4 5.8 3.8 1.9 4.0

Credit Cards* ­ ­ 11.0 12.7 11.1 9.1 11.0

Other Installment Loans 4.9 5.8 7.0 6.6 6.1 5.4 6.0

Other Residential Loans 4.0 4.7 4.8 6.0 4.6 3.3 4.6

Other Line of Credit 9.6 9.4 9.3 10.2 7.3 6.0 8.7

* No interest rate data available for credit cards in 1989 or 1992.

To account for variation among new households, DOE samples a rate for each household

from a distribution of rates for each of the above debt classes.  DOE develops a probability

distribution of interest rates for each debt class based on the SCF data.  Appendix 8C presents the

probability distribution of interest rates for each debt class that DOE used in the LCC and PBP

analyses.

Similar rate data are not available from the SCF for the asset classes, so DOE derives

data for these classes from national historical data.  The interest rates associated with certificates

of deposit (CDs), viii savings bonds,ix and bonds (AAA corporate bonds) x

 are from Federal

Reserve Board time­series data 1977­2005.  DOE assumes rates on checking accounts to be zero.  

Rates on savings and money market accounts are from Cost of Savings Index data covering

1984­2005.xi  The rates for stocks are the annual returns on the Standard and Poor’s (S&P) 500

1977­2005.xii  The mutual fund rates are a weighted average of the stock rates (two­thirds

weight) and the bond rates (one­third weight) in each year from 1977 to 2005.  DOE adjusts the

nominal rates to real rates using the annual inflation rate in each year.  Average nominal and real

interest rates for the classes of assets are shown in Table 8.2.9.  Since the interest and return rates

for each asset type cover a range of time, DOE believes they are representative of rates that may

be in effect in 2012.

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EERE-2007-BT-TP-0013 COMMENT 05
Table 8.2.9  Average Nominal and Real Interest Rates for Household Equity Types

Type Average Nominal Rate % Average Real Rate %

Checking Accounts ­­ 0.0

Savings and Money Market 5.5 2.3

CDs 6.9 2.4

Savings Bonds 8.0 3.5

Bonds 8.8 4.2

Stocks 13.3 8.8

Mutual Funds 11.6 7.0

To account for variation among new households, DOE samples a rate for each household

from a distribution of rates for each of the above asset types.  DOE develops a normal probability

distribution of interest rates for each asset type by using the mean value and standard deviation

from the distribution.  Appendix 8C presents the probability distribution of interest rates for each

asset type that DOE used in the LCC and PBP analysis

Table 8.2.10 summarizes the mean real effective rates of each type of equity or debt.  

DOE determines the average share of each debt and asset using SCF data for 1989, 1992, 1995, 

1998, 2001, and 2004.  Each year of SCF data provides the debt and asset shares for U.S. 

households.  DOE averages the debt and asset shares over the six years of survey data to arrive at

the shares shown below.  The average rate across all types of household debt and equity, 

weighted by the shares of each class, is 5.6 percent.

Table 8.2.10  Shares and Interest or Return Rates Used for Household Debt and Equity

Types

Type

Average Share of Household

Debt Plus Equity

%* Mean Effective Real Rate %**

Home Equity Loans 3.6 4.0

Credit Cards 2.0 11.0

Other Installment Loans 1.7 6.0

Other Residential Loans 4.9 4.6

Other Line of Credit 0.5 8.7

Checking Accounts 4.5 0.0

Savings and Money Market Accounts 15.7 2.3

CDs 9.0 2.4

Savings Bonds 1.5 3.5

Bonds 10.0 4.2

Stocks 29.1 8.8

Mutual Funds 17.5 7.0

Total/Weighted­Average Discount Rate 100 5.6

* Not including primary mortgage or retirement accounts.

** Adjusted for inflation and, for home equity loans, loan interest tax deduction.

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EERE-2007-BT-TP-0013 COMMENT 05
8.2.7.2 Commercial Discount Rate

Most companies use both debt and equity capital to fund investments; for most

companies, therefore, the cost of capital is the weighted average of the cost to the firm of equity

and debt financing.xiii

DOE estimates the cost of equity financing using the Capital Asset Pricing Model

(CAPM).  The CAPM, among the most widely used models to estimate the cost of equity

financing, assumes that the cost of equity is proportional to the amount of systematic risk

associated with a firm.  For example, the cost of equity financing tends to be high when a firm

faces a large degree of systematic risk, and the cost tends to be low when the firm faces a small

degree of systematic risk.

The degree of systematic risk facing a firm and the subsequent cost of equity financing

are determined by several variables, including the risk coefficient of a firm (beta, or B), the

expected return on risk­free assets (Rf), and the additional return expected on assets facing

average market risk (known as the equity risk premium, or ERP).  The beta indicates the degree

of risk associated with a given firm, relative to the level of risk (or price variability) in the

overall stock market.  Betas usually vary between 0.5 and 2.0.  A firm with a beta of 0.5 faces

half the risk of other stocks in the market; a firm with a beta of 2.0 faces twice the overall stock

market risk.

Following this approach, the cost of equity financing for a particular company is by the

equation:

ke = Rf + (β × ERP) Eq. 8.6

where

ke = the cost of equity for a company, expressed in dollars,

Rf = the expected return of the risk free asset, expressed in dollars,

β = the risk coefficient, and

ERP = the expected equity risk premium, expressed in dollars.

The cost of debt financing (kd) is the yield or interest rate paid on money borrowed by a

company (raised, for example, by selling bonds).  As defined here, the cost of debt includes

compensation for default risk and excludes deductions for taxes.

DOE estimates the cost of debt for companies by adding a risk adjustment factor to the

current yield on long­term corporate bonds (the risk­free rate).  This procedure is used to

estimate current and future company costs to obtain debt financing.  The adjustment factor is

based on indicators of company risk, such as credit rating or variability of stock returns.

The discount rate of companies is the weighted average cost of debt and equity financing, 

less expected inflation.  DOE estimates the discount rate using the equation:

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EERE-2007-BT-TP-0013 COMMENT 05
k = ke × we + kd × wd Eq. 8.7

where

k = the (nominal) cost of capital, 

ke and kd = the expected rates of return on equity and debt, 

respectively, and

we and wd = the proportion of equity and debt financing, respectively.

The real discount rate deducts expected inflation from the nominal rate. 

The expected return on risk­free assets, or the risk­free rate, is defined by the current

yield on long­term Government bonds.xiv The ERP represents the difference between the

expected (average) stock market return and the risk­free rate.  As Table 8.2.11shows, DOE uses

an ERP estimate of 5.5 percent, which it took from the Damodaran Online site (a private website

associated with New York University’s Stern School of Business, which aggregates information

on corporate finance, investment, and valuation).xv

DOE calculates an expected inflation of 2.3 percent from the average of five quarters’

change in GDP prices.xvi  DOE obtained the cost of debt, percent debt financing, and systematic

firm risk from the Damodaran Online website.  Table 8.2.11 shows average values across all

private companies.  However, the cost of debt, percent debt financing, and systematic firm risk

vary by sector. 

Table 8.2.11  Variables Used to Estimate Company Discount Rates

Variable Symbol Average

Value

%

Source

Risk­Free Asset Return Rf 5.5 Bloomberg Professionalxvii

Equity Risk Premium ERP 5.5 Damodaran Online

Expected Inflation R 2.3 U.S. Bureau of Economic Analysis

Cost of Debt (After Tax) kd 9.0 Damodaran Online

Percent Debt Financing wd 27.0 Damodaran Online

Systematic Firm Risk B 0.99 Damodaran Online

In the commercial building sector, lamps are purchased and owned by commercial

building property owners, commercial companies, industrial companies and the Government. 

DOE uses a sample of 4,207 companies drawn from these owner categories to represent lamp

purchasers.  It took the sample from the list of companies included in the Value Line investment

surveyxviii and listed on the Damodaran Online website.  DOE obtained the cost of debt, the firm

beta, the percent of debt and equity financing, the risk­free return, and the equity risk premium

from Damodaran Online.

DOE estimates the cost of debt financing for these companies from the long­term

Government bond rate and the standard deviation of the stock price.xv  For Government­officetype owners, the discount rate represents an average of the Federal rate and the State and local

bond rate.  DOE drew the Federal rate directly from the U.S. Office of Management and Budget

discount rate for investments in Government building energy efficiency.xix  DOE estimates the

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EERE-2007-BT-TP-0013 COMMENT 05
State and local discount rate from the interest rate on State and local bonds between 1977 and

2001. xx  DOE uses this information to estimate the weighted­average cost of capital for the

sample of companies included in the commercial property owner, commercial, and industrial

company database.

The cost of capital may be viewed as the discount rate that should be used to reduce the

future value of typical company project cash flows.  It is a nominal discount rate, since

anticipated future inflation is included in both stock and bond expected returns.  Deducting

expected inflation from the cost of capital provides estimates of the real discount rate by

ownership category (see Table 8.2.12).  The mean real discount rate for these companies varies

between 3.3 percent (Government offices) and 7.5 percent (industrial companies).

Table 8.2.12  Real Discount Rates by Lamp Ownership Category

Ownership Category SIC

Codes*

Mean Real

Discount Rate

%

Standard

Deviation

%

Number of

Observations

Industrial Companies 1 ­ 4 7.5 3.2 2,409

Commercial Companies 5 ­ 8 7.3 4.7 1,773

Commercial Property Owners 6720 4.5 0.9 8

Government Offices N/A 3.3 2.1 25

* SIC Codes refer to the U.S. Standard Industrial Classification system.

Source: Lawrence Berkeley National Laboratory (LBNL) calculations based on firms sampled from the Damodaran

Online website as performed for the distribution transformers rulemaking.

DOE’s approach for estimating the cost of capital provides a measure of the discount rate

spread as well as the average discount rate.  DOE infers the discount rate spread by ownership

category from the standard deviation, which ranges between 0.9 percent and 4.7 percent (Table

8.2.12).  

Different combinations of commercial property owners and commercial, industrial, and

Government buyers purchase the lamp types considered in the LCC analysis.  Accordingly, DOE

constructs the discount rates associated with each building sector from different combinations of

commercial property owner, commercial, industrial, and Government rates.  

To estimate the share of each ownership category in total commercial sector purchases of

lamps, DOE uses the share of each category in total commercial building square footage with

lighting provided by EIA’s 2003 CBECS.xxi Table 8.2.13 presents the estimated shares of

commercial lamp purchases by ownership category of commercial building space.

8­24

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.2.13 Estimated Share of Lamp Purchases by Ownership Category in the

Commercial Sector

Ownership Category Percent

Property Owners and Managers 22.3

Industrial Firms 10.1

Commercial Firms 54.8

Government 12.8

Source: 2003 CBECS.

* The share of total square footage occupied by property owners is actually 44.6%. However, in some of these

buildings, the tenants purchase lamps. DOE assumes that this is the case for half of the square footage occupied by

property owners. DOE allocates this quantity among the other categories in proportion to their shares of total square

footage.

Table 8.2.14 presents the distribution of lamp ownership for the commercial and

industrial lighting sectors.

Table 8.2.14  Lamp Ownership by Sector

Sector Property Owners

%

Industrial

Companies

%

Commercial

Companies

%

Government

%

Industrial 0 100 0 0

Commercial 22.3 10.1 54.8 12.8

Sources: Commercial, CBECS; Industrial, DOE estimate.

DOE estimates discount rate distributions for the different sectors as a weighted average

of the distributions for the different ownership types.  The resulting weighted average discount

rates are 7.5 percent for the industrial sector and 6.2 percent for the commercial sector.  Table

8.2.15 summarizes the weighted average discount rates in all three sectors.

Table 8.2.15  Average Discount Rate by Sector

Sector Discount Rate

%

Industrial 7.5

Commercial 6.2

Residential 5.6

8.2.8 Effective Date of Standard

The effective date is the date when a new standard becomes operative, i.e., the date by

which lamp manufacturers must manufacture products that comply with the standard.  DOE’s

publication of a final rule in this standards rulemaking is scheduled for completion in June 2009.  

The effective date of any new energy conservation standards for these lamps must be 3 years

after the final rule is published, (42 U.S.C. 6295(i)(3) and (i)(5)), which will be June 2012.  DOE

calculates the LCCs for all consumers as if each would purchase a new product in the year the

standard takes effect.  However, DOE bases the cost of the equipment on the most recent

available data; all dollar values are expressed in 2006$.

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EERE-2007-BT-TP-0013 COMMENT 05
8.2.9 Residual Value

The residual value represents the remaining value of a lamp or a ballast from the end of

the period of analysis to the end of the service life of the lamp or ballast.  Since the analysis

period is based is based the lifetime of the longest­lived baseline lamp, DOE assumes lamps with

lifetimes shorter than the analysis period are replaced.  To account for the remaining value of

these lamps (with remaining life) to the consumer, the LCC model applies this residual value as a

“credit” at the end of the analysis period, and discounts it back to the start of the analysis period. 

This methodology is shown in Equation 8.1, where DOE presents how it incorporates residual

value into its LCC calculation.  The equation for residual value is as follows:

RV = IC ⋅

⎧

⎨

⎩

SL − PAnalysis [

SL

− (n ⋅ SL) ⎫

⎬

⎭

] Eq. 8.8

where

IC = total installed cost of the product,

n = the number of replacements within the analysis period, 

SL = the service life of the product, and

PAnalysis = the analysis period.

DOE determines the residual value of the product by linearly prorating the replacement

cost (i.e., total installed cost) by the remaining service life.  For example, consider a $10 lamp

that has a service life of 5 years and is used to replace a baseline lamp that a service life of 3

years.  Since the baseline lamp defines the analysis period, DOE would calculate the residual

value of the lamp design as (2 ÷5) x $10, or $4.  Thus, the residual value in equation 8.1 would

be $4, and that value would be discounted back to the start of the time period of analysis.  This

equation is used for both lamps and ballasts installed by consumers.

8.3 PAYBACK PERIOD INPUTS

8.3.1 Definition

The PBP is the amount of time it takes the consumer to recover the assumed higher

purchase cost of a more energy­efficient product as a result of lower operating costs. 

Numerically, the PBP is the ratio of the increase in purchase cost (i.e., from a less efficient

design to a more efficient design) to the decrease in annual operating expenditures.  This type of

calculation is known as a “simple” PBP, because is does not take into account changes in

operating cost over time or the time value of money.  That is, the calculation is done at an

effective discount rate of zero percent.

The equation for PBP is:

PBP Δ = Δ

IC

OC Eq. 8.9

8­26

EERE-2007-BT-TP-0013 COMMENT 05
where

PBP  = payback period in years,

�IC = difference in the total installed cost between the more efficient

standard level; equipment (efficiency levels 1, 2, etc.) and the

baseline (efficiency level 0) equipment, and

�OC = difference in annual operating costs.

PBPs are expressed in years.  PBPs greater than the life of the product mean that the

increased total installed cost of the more efficient product is not recovered in reduced operating

costs over the lifetime of that product.  Because all lamp designs and lamp­and­ballast designs in

the LCC and PBP analyses save energy and thus yield a positive �OC, PBPs that are negative

indicate that the total installed cost of the equipment that meets the more efficient CSL is less

than that of the baseline.

8.3.2 Rebuttable Presumption Payback Period

Section 325(o)(2)(B)(iii) of EPCA establishes a rebuttable presumption that a standard

for GSFL or IRL is economically justified if the Secretary finds that “the additional cost to the

consumer of purchasing a product complying with an energy conservation standard level will be

less than three times the value of the energy. . . savings during the first year that the consumer

will receive as a result of the standard, as calculated under the applicable test procedure . . . .”

(42 U.S.C. 6295(o)(2)(B)(iii))  This rebuttable presumption test is an alternative path to

establishing economic justification, as compared to consideration of the seven factors set forth in

42 U.S.C. 6295(o)(2)(B)(i)(I)­(VII).

DOE’s lamp test procedures measure the rate of light output per unit power consumption

of a lamp (i.e., lumens per watt; lm/W) rather than a measurement of energy consumption (i.e., a

measurement over a duration or operating time period).  Therefore, to calculate energy savings

for the rebuttable presumption payback period, one would need to multiply the rate of power

consumption of a lamp times the usage profile of that lamp.  For IRL, energy savings

calculations in the LCC and PBP analyses use both the relevant test procedures as well as the

relevant usage profile.  Because DOE calculates payback periods in a methodology consistent

with the rebuttable presumption test for IRL in the LCC and payback period analyses, DOE is

not performing a stand­alone rebuttable presumption analysis for IRL, as it is already embodied

in the LCC and PBP analyses.  For GSFL, DOE believes that the rate of energy consumption of

the lamp­and­ballast system is a more accurate measure of real world power consumption than

the rate of power consumption of the lamp as measured on a reference ballast as prescribed by

the test procedure.2

  Because calculations of energy savings in the LCC are based under realworld conditions, DOE will also rely on standard payback periods for GSFL.  

2 For example, T8 lamps which are often operated on high­frequency electronic ballasts, may be tested and

measured on a line­frequency (60 Hz) reference ballast using DOE’s test procedure, resulting in different

performance characteristics than this lamp would exhibit in the field, operated on an electronic ballast.

8­27

EERE-2007-BT-TP-0013 COMMENT 05
8.3.3 Inputs

The data inputs to PBP are the total installed cost of the product to the customer for each

CSL and the annual (first year) operating costs for each CSL.  The inputs to the total installed

cost are the final product price and the installation cost.  The inputs to the operating costs are the

lamp or lamp­and­ballast system power rating, annual operating hours, and electricity cost.  The

PBP uses the same inputs as the LCC calculation described in section 8.2, except that electricity

price trends are not required.  Since the PBP is a “simple” (undiscounted) PBP, the required

electricity cost is only for the year in which a new efficiency standard is to take effect—in this

case, 2012.  The electricity price DOE uses in the PBP calculation for electricity cost is the price

projected for 2012, expressed in 2006$, but not discounted to 2006.  DOE does not use discount

rates in the PBP calculation.

8.4 LAMP PURCHASING EVENTS

DOE designs the LCC and PBP analyses for this rulemaking around scenarios where

consumers need to replace a lamp; DOE collectively refers to these as, “lamp purchasing

events.”  Each of these events may present the consumer with a different set of lamp or lampand­ballast designs and therefore a different set of LCC savings for a certain CSL.  For GSFL, 

DOE has identified five possible scenarios under which consumers would purchase a lamp and

potentially be affected by an energy conservation standard.  These scenarios are: 1) lamp failure, 

2) standards­induced retrofit, 3) ballast failure, 4) ballast retrofit and 5) new construction/

renovation.  

For IRL, due to the fact that there is no ballast involved, the scenario for the incandescent

lamp product classes is simply a lamp failure.  For GSFL, the five lamp purchasing events are

described in more detail below.  In addition to these descriptions, 

Table 8.4.1 and Table 8.4.2 summarize the lamp purchasing events considered in this analysis.

• Lamp failure:  This event reflects a scenario in which a lamp either fails (spot relamping) or is about to fail (group re­lamping) and must be replaced.  In the absence of the

energy conservation standard, generally, an identical lamp would have been installed as a

replacement.  However, under an energy conservation standard, a standards­compliant lamp

that operates on the existing ballast is required.  Thus, the first consumer response to a lamp

failure is expected to be a simple lamp replacement with the same type of lamp.  A second

response occurs for owners of T12 systems.  Unlike T8 lamps, there are some standard levels

that a T12 lamp cannot meet.  Therefore, at certain levels, these users would be required to

purchase a new lamp­and­ballast system to meet the standard.  

• Standards­induced retrofit:  This is a scenario in which an increase in the energy

conservation standard induces end­users to retrofit both lamps and ballasts (whereas, in the

base case, they would otherwise have installed only a lamp).  This lamp purchasing event

only applies to users with T12 lamps because, unlike T8 lamps, there are certain standard

levels that a T12 lamp cannot meet.  This event contemplates a scenario where users, under

8­28

EERE-2007-BT-TP-0013 COMMENT 05
an energy conservation standard, can no longer purchase a T12 replacement lamp for their

T12 ballast.  For this scenario, DOE assumes a uniform age distribution of T12 lamps

throughout the nation.  Based on this age distribution, the average T12 lamp is halfway

through its lifetime.  Therefore, consumers in the base case purchase a lamp after the average

T12 lamp has died (i.e., after it has lived through the second half of its lifetime).  Consumers

in the standards case may choose to change their lamps and ballasts early, instead of waiting

for their T12 lamps to fail. Therefore, in the standards case, a lamp­and­ballast purchase

would occur at the beginning of the analysis, before the average lamp being replaced has

failed.  

• Ballast failure:  This is a scenario in which the installed has failed.  DOE recognizes that

energy conservation standards set by the 2000 Ballast Rule and the Energy Policy Act of

2005 (EPACT 2005), Pub. L. 109­58, are effective in 2010 and may affect the types of

systems available to the consumer to purchase.  These standards ban the sale of magnetic 4­

foot medium bipin and 8­foot single pin slimline ballasts.  In addition, DOE expects that

sales of magnetic ballasts that operate 8­foot recessed double contact HO lamps will be

minimal after 2012.  Therefore, in the baseline, users who had a magnetic or electronic T12

ballast would be expected to replace it with an electronic T12 ballast and corresponding

standards­compliant lamp (if available).  Users who had a T8 ballast fail would be expected

to replace it with a T8 ballast and corresponding standards­compliant lamp.  However, in the

standards case, end­users would select a standards­compliant lamp­ballast combination such

that the system light output never drops below 10 percent of the baseline system. 

• Ballast retrofit:  DOE applies this event only to T12 users because the majority of ballasts

that are currently being retrofitted are T12 lamp­and­ballast systems, according to industry

experts. Absent standards, end­users may decide to retrofit their old ballasts and lamps to

save energy.  With standards, end­users will also retrofit their old lamp­and­ballast systems, 

but with standards­compliant lamps.  DOE assumes that end­users continue to use the

existing fixture and replace only the ballast.  Because the spatial layout in the building space

is a constrained by the number of fixtures, light output of the replacement lamp­and­ballast

system never drops below 10 percent of the baseline system. 

• New construction and renovation:  This lamp purchasing event encompasses all the new

fixture installations where the lighting design will be completely new or can be completely

changed.  This scenario is only applicable to those baseline lamps that are usually used in

new construction and renovation (4­foot T8 medium bipin, 8­foot T8 single pin slimline, and

8­foot T12 recessed double contact HO).  In response to this event, the spatial layout of

fixtures in the building space is not constrained to any previous configuration.  Because new

fixtures can be installed, consumers could install a lamp­and­ballast system that would not

maintain the light output of the baseline system.  For instance, if light output of the standards

case system is lower than the base case system, consumers can increase the number of

standards case lamp­and­ballast systems installed in the building by a certain percentage to

maintain the light output of base case lamp­and­ballast systems.

Table 8.4.1 and Table 8.4.2 outline the events and actions taken by stakeholders in

response to those events both in the base case and the standards case.  

8­29

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.4.1 Framework of Event­Type Scenarios for T12 Lamps

Event Base Case

Action

Standards Case

Action

Type 1. Lamp Failure (a) Installs a T12 lamp. Installs a lower­wattage, higher efficacy

lamp, where the system light output never

drops below 10 percent of the baseline

system.

(b) Installs a T12 lamp. Installs a T12 or T8 electronic ballast and

lamp, where the system light output never

drops below 10 percent of the baseline

system.

Type 2. StandardsInduced Retrofit

Replace lamp halfway through analysis

period.*

Installs a new T12 or T8 electronic ballast

and lamp, where the system light output

never drops below 10 percent of the

baseline system.

Type 3. Ballast

Failure

Installs a T12 electronic ballast and lamps

in the existing fixture.

Installs a new T12 or T8 ballast and lamps,

where the system light output never drops

below 10 percent of the baseline system.

Type 4. Ballast

Retrofit

Installs a T8 electronic ballast and lamps in

the existing fixture.

Installs a new T12 or T8 ballast and lamps,

where the system light output never drops

below 10 percent of the baseline system.

Type 5. New

Construction and

Renovation

Installs a new T12 system. Installs a new T12 or T8 system that is

where the system light output never drops

below 10 percent of the baseline system.

Light output can be maintained through

spacing.

* Note: Event Type 2 represents a standards­induced retrofit where lamps are substituted before the end of their

lifetime. DOE assumed that lamps lived to half of their average lifetime when substituted under this scenario.

Table 8.4.2  Framework of Event­Type Scenarios for T8 Lamps

Event Base Case Action Standards Case Action

Type 1. Lamp Failure Installs a lamp.

Installs a lower­wattage, higher efficacy

lamp, where the system light output never

drops below 10 percent of the baseline

system.

Type 3. Ballast

Failure

Installs a T8 electronic ballast and lamps in

the existing fixture.

Installs new T8 ballast and lamps, where the

system light output never drops below 10

percent of the baseline system.

Type 5. New

Construction and

Renovation

Installs a new T8 system.

Installs a new T8 system, where the system

light output never drops below 10 percent of

the baseline system. Light output can be

maintained through spacing.

8.5 LIFE­CYCLE COST AND PAYBACK PERIOD RESULTS

This section presents LCC results for each lamp and lamp­and­ballast design DOE

considers.  This section uses the terms “positive LCC savings” and “negative LCC savings.”

When a standard results in “positive LCC savings,” the life cycle cost of the standards­compliant

8­30

EERE-2007-BT-TP-0013 COMMENT 05
lamp is less than the life­cycle cost of the baseline lamp and the consumer benefits.  A consumer

is adversely affected when a standard results in “negative LCC savings” (i.e., when the life­cycle

cost of the standards­compliant lamp is higher than the life­cycle cost of the baseline lamp).

As stated earlier, DOE conducts a series of LCC calculations for each baseline lamp.  For

GSFL, DOE considers lamp­only substitutions as well as lamp­and­ballast substitutions.  For

IRL, DOE considers lamp­only substitutions.  In all cases, DOE considers only designs that save

energy and which maintain light output above a maximum 10 percent decrease from the baseline

lamp or system.  

All replacement options are designed around lamp purchasing events.  For GSFL, DOE

identified five possible events where consumers would purchase a lamp, and therefore be

affected by an energy conservation standard.  These events are lamp failure, standards­induced

retrofit, ballast failure, ballast retrofit, and renovation/new construction.  The LCC spreadsheet

calculates the LCC impacts for each of these scenarios separately.  Examining the impacts on

each scenario separately allows one to view the results of many subgroup populations in the LCC

analysis.  

8.5.1 Results for General Service Fluorescent Lamps

DOE is analyzing three representative product classes for GSFL:  4­foot medium bipin

≤4,500K, 8­foot single pin slimline ≤4,500K, and 8­foot recessed double contact HO ≤4,500K.  

This section presents the results for each of these representative product classes and for each

baseline lamp.  The results are presented by lamp purchasing event and by whether a consumer

purchases a lamp or a lamp and ballast, both of which influence the LCC and PBP results.

8.5.1.1 Product Class: Four­foot medium bipin ≤4,500K

For the 4­foot medium bipin ≤4,500K product class, DOE analyzes three baseline lamps:

40W T12, 34W T12, and 32W T8.  For each baseline lamp, DOE analyzes multiple lamp

substitutions with each lamp substitution corresponding to CSL efficacy requirements of 92.4, 

85.0, 90.0, 92.3, or 95.4 lm/W. 

Table 8.5.1 presents the findings of the LCC and PBP analyses on the first 4­foot medium

bipin baseline GSFL.  This table presents the LCC and PBP results for the 40W T12 baseline

lamp operating in the commercial sector.  Key inputs consist of using AEO2007 reference case

electricity prices, an analysis period of 5.5 years, and medium­range lamp and ballast prices.  

The results for Event Type 1 (lamp failure) show that the LCC of the baseline 40W T12

on a magnetic ballast is higher than the LCC of the 34W T12 on a magnetic ballast that meets

CSL3.  Any CSL beyond CSL3 for this baseline would require a lamp­and­ballast replacement.  

As discussed in the engineering analysis (Chapter 5), although a 34W T12 lamp is often

considered a reduced wattage replacement of the 40W T12 lamp, there were no lamp options that

emitted enough lumens to fall within 10 percent of the baseline system lumens.  The highest

efficacy 34W T12 lamp replacement is shown below.  The system light output of this lamp­and8­31

EERE-2007-BT-TP-0013 COMMENT 05
ballast design is 10.3 percent less than that of the baseline system.  The same drop in lumen

output is also exhibited by the 34WT12 lamp on an electronic ballast of the same BF.

The results for Event Type 2 show that consumers that replace a functioning 40W T12

lamp on a magnetic ballast with a high efficacy T8 lamp on an electronic ballast benefit from

lower LCCs at all CSLs above CSL2.  Event Type 3 represents consumers who are already faced

with replacing both a lamp and a ballast.  The baseline ballast for this event is assumed to be an

electronic T12, since the ballast standards from the 2000 Ballast Rule and EPACT 2005 would

be effective in 2010.  Consumers prompted by this event would experience positive LCC savings

if they purchase a high efficacy 4­foot T8 lamp on an electronic ballast at all CSLs. 

8­32

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.1 LCC and PBP Results for a Three­Lamp 4­Foot 40W T12 Medium Bipin System Operating in the Commercial

Sector

Event

Type Response

Candidate

Standard

Level

Rated

Lamp

Efficacy

lm/W

Design Option LCC$ LCC Savings $ Installed Price $

Operating

Cost

Savings

One Year

$

Payback

Period

yr

Mean

Lumens

from

Baseline

%

1:

Lamp

Failure

Baseline Baseline 80.0 40 W T12 & 0.95 BF Mag3 171.93 N/A 13.78 N/A N/A 0.0

Lamp

Repl.4 CSL3 91.2 34 W T12 & 0.88 BF Mag 154.45 17.48 24.94 5.71 2.0 ­10.3

Lamp &

Ballast

Repl.

CSL1 82.5 40 W T12 & 0.88 BF Elec 181.63 ­9.70 71.60 5.80 10.0 ­3.5

CSL2 85.0 40 W T12 & 0.87 BF Elec 182.53 ­10.60 76.24 5.98 10.4 ­2.7

CSL2 86.2 32.5 W T8 & 1.18 BF Elec 182.07 ­10.13 64.20 3.95 12.8 8.7

CSL3 90.0 40 W T12 & 0.87 BF Elec 182.80 ­10.86 76.54 5.98 10.5 3.3

CSL3 91.2 34 W T12 & 0.88 BF Elec 163.67 8.27 76.15 10.15 6.1 ­10.3

CSL3 90.8 32.5 W T8 & 1 BF Elec 165.35 6.58 67.30 8.34 6.4 ­1.0

CSL4 92.3 32.5 W T8 & 0.88 BF Elec 146.40 25.53 60.05 11.27 4.1 ­8.3

CSL4 95.0 30 W T8 & 1 BF Elec 159.52 12.42 68.58 10.54 5.2 ­2.0CSL5 95.4 32.5 W T8 & 0.88 BF Elec 147.78 24.15 61.61 11.27 4.2 ­6.2CSL5 97.3 28 W T8 & 1 BF Elec 146.92 25.01 67.98 13.18 4.1 ­6.4CSL5 96.0 25 W T8 & 1.18 BF Elec 161.61 10.32 72.34 9.77 6.0 ­1.7

2:

StandardsInduced

Retrofit

Baseline Baseline 80.0 40 W T12 & 0.95 BF Mag 165.57 N/A 13.78 N/A N/A 0.0

Lamp &

Ballast

Repl.

CSL1 82.5 40 W T12 & 0.88 BF Elec 181.63 ­16.07 71.60 5.80 10.0 ­3.5

CSL2 85.0 40 W T12 & 0.87 BF Elec 182.53 ­16.97 76.24 5.98 10.4 ­2.7CSL2 86.2 32.5 W T8 & 1.18 BF Elec 182.07 ­16.50 64.20 3.95 12.8 8.7

CSL3 90.0 40 W T12 & 0.87 BF Elec 182.80 ­17.23 76.54 5.98 10.5 3.3

CSL3 91.2 34 W T12 & 0.88 BF Elec 163.67 1.90 76.15 10.15 6.1 ­10.3

CSL3 90.8 32.5 W T8 & 1 BF Elec 165.35 0.21 67.30 8.34 6.4 ­1.0

CSL4 92.3 32.5 W T8 & 0.88 BF Elec 146.40 19.17 60.05 11.27 4.1 ­8.3

CSL4 95.0 30 W T8 & 1 BF Elec 159.52 6.05 68.58 10.54 5.2 ­2.0

CSL5 95.4 32.5 W T8 & 0.88 BF Elec 147.78 17.79 61.61 11.27 4.2 ­6.2

CSL5 97.3 28 W T8 & 1 BF Elec 146.92 18.65 67.98 13.18 4.1 ­6.4CSL5 96.0 25 W T8 & 1.18 BF Elec 161.61 3.96 72.34 9.77 6.0 ­1.7

3 Throughout the GSFL results tables, descriptions such as “40W T12 & 0.95 BF Mag” are used. The first term (e.g., 40W) is the rated wattage, the second is the

lamp diameter (e.g., T12), the third is the ballast factor of the ballast (e.g., 0.95 BF), and the fourth is the ballast type (e.g., “Mag” for Magnetic or “Elec” for

Electronic).

4 Throughout the following tables, Replacement is referred to as “Repl.”, and New Construction and Renovation is referred to as “New Const.” and “Renov.”,

respectively

8­33

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.1 LCC and PBP Results for a Three­Lamp 4­Foot 40W T12 Medium Bipin System Operating in the Commercial

Sector (continued)

Event

Type Response

Candidate

Standard

Level

Rated

Lamp

Efficacy

lm/W

Design Option LCC$ LCC Savings $ Installed Price $

Operating

Cost

Savings

One Year

$

Payback

Period

yr

Mean

Lumens

from

Baseline

%

3: Ballast

Failure

Baseline Baseline 80.0 40 W T12 & 0.88 BF Elec 175.02 N/A 64.99 N/A N/A ­7.4*

Lamp &

Ballast Repl.

CSL1 82.5 40 W T12 & 0.87 BF Elec 180.80 ­5.78 71.60 0.18 35.9 ­4.6

CSL2 85.0 40 W T12 & 0.87 BF Elec 182.53 ­7.52 76.24 0.18 61.0 ­2.7CSL3 90.0 40 W T12 & 0.87 BF Elec 182.80 ­7.78 76.54 0.18 62.6 3.3

CSL3 91.2 34 W T12 & 0.88 BF Elec 163.67 11.35 76.15 4.35 2.6 ­10.3

CSL3 90.8 32.5 W T8 & 1 BF Elec 165.35 9.67 67.30 2.54 0.9 ­1.0

CSL4 92.3 32.5 W T8 & 0.88 BF Elec 146.40 28.62 60.05 5.47 0 ­8.3

CSL4 95.0 30 W T8 & 1 BF Elec 159.52 15.50 68.58 4.74 0.8 ­2.0

CSL5 95.4 32.5 W T8 & 0.88 BF Elec 147.78 27.24 61.61 5.47 0 ­6.2

CSL5 97.3 28 W T8 & 1 BF Elec 146.92 28.10 67.98 7.38 0.4 ­6.4

CSL5 96.0 25 W T8 & 1.18 BF Elec 161.61 13.41 72.34 3.97 1.9 ­1.7

4: Ballast

Retrofit

Baseline Baseline/CSL

2 86.2 32.5 W T8 & 1.18 BF Elec 182.07 N/A 64.20 N/A N/A 8.7

Lamp &

Ballast Repl.

CSL3 90.0 40 W T12 & 0.87 BF Elec 182.80 ­0.73 76.54 2.04 6.1 3.3

CSL3 91.2 34 W T12 & 0.88 BF Elec 163.67 18.40 76.15 6.20 1.9 ­10.3

CSL3 90.8 32.5 W T8 & 1 BF Elec 165.35 16.71 67.30 4.39 0.7 ­1.0

CSL4 92.3 32.5 W T8 & 0.88 BF Elec 146.40 35.67 60.05 7.32 0 ­8.3

CSL4 95.0 30 W T8 & 1 BF Elec 159.52 22.55 68.58 6.59 0.7 ­2.0

CSL5 95.4 32.5 W T8 & 0.88 BF Elec 147.78 34.28 61.61 7.32 0 ­6.2

CSL5 97.3 28 W T8 & 1 BF Elec 146.92 35.15 67.98 9.23 0.4 ­6.4

CSL5 96.0 25 W T8 & 1.18 BF Elec 161.61 20.46 72.34 5.82 1.4 ­1.7

* Comparative lumens are sometimes non­zero for baseline T12 electronic systems under Event Type 3 and 4 (ballast failure and retrofit) because the lumen

package is compared to a system with a T12 magnetic ballast. DOE chose to compare these systems for these events because it recognizes that though federal

regulations will prohibit the use of magnetic ballasts, future purchasers may still seek the current lumen package delivered by current T12 magnetic systems.

8­34

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.2 presents the findings of the LCC and PBP analyses on a second baseline 4­

foot medium bipin GSFL.  This table presents the LCC and PBP results for the 34W T12

baseline lamp operating in the commercial sector.  Key inputs consist of using AEO2007

reference case electricity prices, an analysis period of 5.5 years, and medium­range lamp and

ballast prices.  Note that lamp replacement for Event Type 1 is not shown because there are no

energy­saving lamp replacement options for a 34W T12 lamp. 

Results for Event Type 2 show that consumers that replace their magnetic T12 systems

with electronic T8 systems will have positive LCC savings at all CSLs above CSL2.  Results for

Event Type 3 show that consumers that purchase a electronic T8 systems instead of electronic

T12 systems experience positive LCC savings at CSLs up to and including CSL5.

8­35

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.2 LCC and PBP Results for a Three­Lamp 4­Foot 34W T12 Medium Bipin System Operating in the Commercial

Sector

Event

Type Response

Candidat

e

Standard

Level

Rated

Lamp

Efficacy

lm/W

Design Option LCC$ LCC Savings $ Installed Price $

Operating

Cost

Savings

One Year

$

Payback

Period

yr

Mean

Lumens

from

Baseline

%

1: Lamp

Failure

Baseline Baseline 77.9 34 W T12 & 0.88 BF Mag 143.44 N/A 11.04 N/A N/A 0.0

Lamp &

Ballast

Repl.

CSL1 82.4 34 W T12 & 0.88 BF Elec 156.35 ­12.91 65.93 4.44 12.4 7.0

CSL2 85.3 34 W T12 & 0.86 BF Elec 161.71 ­18.26 72.96 4.81 12.9 10.9

CSL2 86.2 32.5 W T8 & 0.88 BF Elec 144.65 ­1.21 56.52 5.56 8.2 9.6

CSL3 90.8 32.5 W T8 & 0.78 BF Elec 136.74 6.70 59.62 8.00 6.1 4.4

CSL3 91.2 34 W T12 & 0.86 BF Elec 162.00 ­18.56 76.15 4.81 13.5 18.5

CSL4 92.3 32.5 W T8 & 0.75 BF Elec 132.09 11.36 60.05 8.73 5.6 5.6

CSL4 95.0 30 W T8 & 0.78 BF Elec 133.34 10.11 60.90 9.67 5.2 3.3

CSL5 95.4 32.5 W T8 & 0.75 BF Elec 133.47 9.98 61.61 8.73 5.8 8.0CSL5 97.3 28 W T8 & 0.78 BF Elec 121.38 22.06 60.30 12.16 4.1 ­1.3

CSL5 96.0 25 W T8 & 0.88 BF Elec 125.13 18.32 64.66 11.18 4.8 ­0.9

2:

Standards

­Induced

Retrofit

Baseline Baseline 77.9 34 W T12 & 0.88 BF Mag 138.35 N/A 11.04 N/A N/A 0.0

Lamp &

Ballast

Repl.

CSL1 82.4 34 W T12 & 0.88 BF Elec 156.35 ­18.00 65.93 4.44 12.4 7.0

CSL2 85.3 34 W T12 & 0.86 BF Elec 161.71 ­23.36 72.96 4.81 12.9 10.9

CSL2 86.2 32.5 W T8 & 0.88 BF Elec 144.65 ­6.31 56.52 5.56 8.2 9.6

CSL3 90.8 32.5 W T8 & 0.78 BF Elec 136.74 1.60 59.62 8.00 6.1 4.4

CSL3 91.2 34 W T12 & 0.86 BF Elec 162.00 ­23.66 76.15 4.81 13.5 18.5

CSL4 92.3 32.5 W T8 & 0.75 BF Elec 132.09 6.26 60.05 8.73 5.6 5.6

CSL4 95.0 30 W T8 & 0.78 BF Elec 133.34 5.01 60.90 9.67 5.2 3.3

CSL5 95.4 32.5 W T8 & 0.75 BF Elec 133.47 4.88 61.61 8.73 5.8 8.0

CSL5 97.3 28 W T8 & 0.78 BF Elec 121.38 16.96 60.30 12.16 4.1 ­1.3

CSL5 96.0 25 W T8 & 0.88 BF Elec 125.13 13.22 64.66 11.18 4.8 ­0.9

3: Ballast

Failure

Baseline Baseline 77.9 34 W T12 & 0.88 BF Elec 152.66 N/A 62.25 N/A N/A 0.0

Lamp &

Ballast

Repl.

CSL1 82.4 34 W T12 & 0.86 BF Elec 154.69 ­2.02 65.93 0.37 10.0 4.5

CSL2 85.3 34 W T12 & 0.86 BF Elec 161.71 ­9.05 72.96 0.37 29.0 10.9

CSL2 86.2 32.5 W T8 & 0.88 BF Elec 144.65 8.01 56.52 1.12 0.0 9.6

CSL3 90.8 32.5 W T8 & 0.78 BF Elec 136.74 15.92 59.62 3.56 0.0 4.4

CSL3 91.2 34 W T12 & 0.86 BF Elec 162.00 ­9.34 76.15 0.37 37.7 18.5

CSL4 92.3 32.5 W T8 & 0.75 BF Elec 132.09 20.58 60.05 4.29 0.0 5.6

CSL4 95.0 30 W T8 & 0.78 BF Elec 133.34 19.33 60.90 5.22 .0.0 3.3

CSL5 95.4 32.5 W T8 & 0.75 BF Elec 133.47 19.19 61.61 4.29 0.0 8.0

CSL5 97.3 28 W T8 & 0.78 BF Elec 121.38 31.28 60.30 7.72 0.0 ­1.3

CSL5 96.0 25 W T8 & 0.88 BF Elec 125.13 27.53 64.66 6.74 0.4 ­0.9

8­36

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.2 LCC and PBP Results for a Three­Lamp 4­Foot 34W T12 Medium Bipin System Operating in the Commercial

Sector (continued)

Event

Type Response

Candidate

Standard

Level

Rated

Lamp

Efficacy

lm/W

Design Option LCC$ LCC Savings $ Installed Price $

Operating

Cost

Savings

One Year

$

Payback

Period

yr

Mean

Lumens

from

Baseline

%

4: Ballast

Retrofit

Baseline Baseline/ CSL2 86.2 32.5 W T8 & 0.88 BF Elec 144.65 N/A 56.52 N/A N/A 9.6

Lamp &

Ballast

Repl.

CSL3 91.2 34 W T12 & 0.86 BF Elec 162.00 ­9.34 76.15 0.37 37.7 18.5

CSL3 90.8 32.5 W T8 & 0.78 BF Elec 136.74 15.92 59.62 3.56 0 4.4

CSL4 92.3 32.5 W T8 & 0.75 BF Elec 132.09 20.58 60.05 4.29 0 5.6CSL4 95.0 30 W T8 & 0.78 BF Elec 133.34 19.33 60.90 5.22 0 3.3

CSL5 95.4 32.5 W T8 & 0.75 BF Elec 133.47 19.19 61.61 4.29 0 8.0

CSL5 97.3 28 W T8 & 0.78 BF Elec 121.38 31.28 60.30 7.72 0 ­1.3

CSL5 96.0 25 W T8 & 0.88 BF Elec 125.13 27.53 64.66 6.74 0.4 ­0.9

8­37

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.3 presents the findings of an LCC and PBP analyses on a third baseline 4­foot

medium bipin GSFL.  This table presents the LCC and PBP results for the 32W T8 baseline lamp

operating in the commercial sector.  Key inputs consist of using AEO2007 reference case

electricity prices, an analysis period of 5.5 years, and medium­range lamp and ballast prices. 

Event Type 1 (lamp failure) displays results for consumers who must replace a baseline

lamp with a higher efficacy lamp.  For this event, installing reduced wattage lamps is the only

opportunity for energy savings.  For these design options, positive LCC savings are possible at

CSLs up to and including CSL5.  The lowest LCC meets CSL5, assuming a 25W lamp is used

with a 9.5 percent reduction in mean lumens from the baseline.  All options for event types 2 and

5 (ballast failure and new construction and renovation) have positive LCC savings.  The lowest

LCC meet CSL5, assuming a 25W lamp is used.

8­38

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.3 LCC and PBP Results for a 3­Lamp 4­foot 32W T8 Medium Bipin System Operating in the Commercial Sector

Event

Type Response

Candidate

Standard

Level

Rated

Lamp

Efficac

y

lm/W

Design Option LCC$ LCC Savings $ Installed Price $

Operating

Cost

Savings

One Year

$

Payback

Period

yr

Mean

Lumens

from

Baseline

%

1: Lamp

failure

Baseline Baseline/CSL2 86.2 32.5 W T8 & 0.88 BF Elec 119.09 N/A 11.79 N/A N/A 0.0

Lamp

Repl.

CSL4 95.0 30 W T8 & 0.88 BF Elec 117.68 1.41 16.16 1.91 2.3 6.3

CSL5 97.3 28 W T8 & 0.88 BF Elec 105.43 13.65 15.56 4.46 0.8 2.6

CSL5 96.0 25 W T8 & 0.88 BF Elec 99.56 19.52 19.93 5.62 1.4 ­9.5

3: Ballast

Failure

Baseline Baseline/CSL2 86.2 32.5 W T8 & 0.88 BF Elec 144.65 N/A 56.52 N/A N/A 0.0

Lamp &

Ballast

Repl.

CSL3 90.8 32.5 W T8 & 0.78 BF Elec 136.74 7.91 59.62 2.44 1.3 ­4.7

CSL4 92.3 32.5 W T8 & 0.75 BF Elec 132.09 12.56 60.05 3.17 1.1 ­3.6

CSL4 95.0 30 W T8 & 0.78 BF Elec 133.34 11.31 60.90 4.10 1.1 ­5.7

CSL5 95.4 32.5 W T8 & 0.75 BF Elec 133.47 11.18 61.61 3.17 1.6 ­1.4

CSL5 97.3 28 W T8 & 0.88 BF Elec 131.00 13.65 60.30 4.46 0.8 1.6

CSL5 96.0 25 W T8 & 0.88 BF Elec 125.13 19.52 64.66 5.62 1.4 ­9.5

5: New

Const. and

Renov

Baseline Baseline/CSL2 86.2 32.5 W T8 & 0.88 BF Elec 144.65 N/A 56.52 N/A N/A 0.0

Lamp &

Ballast

Repl.

CSL3 90.8 32.5 W T8 & 0.78 BF Elec 136.74 7.91 59.62 2.44 1.3 ­4.7

CSL4 92.3 32.5 W T8 & 0.75 BF Elec 132.09 12.56 60.05 3.17 1.1 ­3.6

CSL4 95.0 30 W T8 & 0.78 BF Elec 133.34 11.31 60.90 4.10 1.1 ­5.7

CSL5 95.4 32.5 W T8 & 0.75 BF Elec 133.47 11.18 61.61 3.17 1.6 ­1.4

CSL5 97.3 28 W T8 & 0.88 BF Elec 131.00 13.65 60.30 4.46 0.8 1.6

CSL5 96.0 25 W T8 & 0.88 BF Elec 125.13 19.52 64.66 5.62 1.4 ­9.5

8­39

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.4 to Table 8.5.6 summarize the range of LCC and PBP results for the 4­foot

medium bipin product class.  Only the most relevant events under each baseline lamp are shown.  

In general, one finds that a CSL at or above CSL4 would induce the replacement of T12

magnetic ballasts with electronic T8 ballasts, as no 40W or 34W T12 lamps can meet these

CSLs.  For all baseline lamps, and for all ballast replacement events, there are design options

with positive LCC savings at CSLs above CSL1.  For the T8 baseline lamp, positive LCC

savings are possible at CSLs above CSL2. 

8­40

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.4 Summary of the LCC and PBP Results for a Three­Lamp 4­Foot 40W T12 Medium Bipin System Operating in

the Commercial Sector

Candidate

Standard

Level

Rated Lamp

Efficacy

lm/W

LCC Savings

$

Payback Period

yr

Event 1: Lamp

Failure

(Lamp

Replacement)

Event 2:

Standards­Induced

Retrofit

(Lamp & Ballast

Replacement)

Event 3: Ballast

Failure

(Lamp & Ballast

Replacement)

Event 1: Lamp

Failure

(Lamp

Replacement)

Event 2:

StandardsInduced Retrofit

(Lamp & Ballast

Replacement)

Event 3: Ballast

Failure

(Lamp & Ballast

Replacement)

CSL1 82.5 N/A ­16.07 ­5.78 N/A 10.0 35.9

CSL2 85.0 to 86.2 N/A ­16.97 to ­16.50 ­7.52 N/A 10.4 to 12.8 61.0

CSL3 90.0 to 91.2 17.48 ­17.23 to 1.90 ­7.78 to 11.35 2.0 6.1 to10.5 0.9 to 62.6

CSL4 92.3 to 95.0 N/A 6.05 to 19.17 15.50 to 28.62 N/A 4.1 to 5.2 0 to 0.8

CSL5 95.4 to 97.3 N/A 3.96 to 18.65 13.41 to 28.10 N/A 4.1 to 6.0 0 to 1.9

Table 8.5.5 Summary of the LCC and PBP Results for a Three­Lamp 4­Foot 34W T12 Medium Bipin System Operating in

the Commercial Sector

Candidate

Standard

Level

Rated Lamp

Efficacy

lm/W

LCC Savings

$

Payback Period

yr

Event 2:

Standards­Induced

Retrofit

(Lamp & Ballast

Replacement)

Event 3: Ballast

Failure

(Lamp & Ballast

Replacement)

Event 2:

StandardsInduced Retrofit

(Lamp & Ballast

Replacement)

Event 3: Ballast

Failure

(Lamp & Ballast

Replacement)

CSL1 82.4 ­18.00 ­2.02 12.4 10.0

CSL2 85.3 to 86.2 ­23.36 to ­6.31 ­9.05 to 8.01 8.2 to12.9 0 to 29.0

CSL3 90.8 to 91.2 ­23.66 to 1.60 ­9.34 to 15.92 6.1 to 13.5 0 to 37.7

CSL4 92.3 to 95.0 5.01 to 6.26 19.33 to 20.58 5.2 to 5.6 0

CSL5 95.4 to 97.3 4.88 to 16.96 19.19 to 31.28 4.1 to 5.8 0 to 0.4

8­41

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.6 Summary of the LCC and PBP Results for a Three­Lamp 4­Foot 32W T8 Medium Bipin System Operating in the

Commercial Sector

Candidate

Standard

Level

Rated Lamp

Efficacy

lm/W

LCC Savings

$

Payback Period

yr

Event 1: Lamp

Failure

(Lamp

Replacement)

Event 3: Ballast

Failure and Event 5:

New Construction

and Renovation

(Lamp & Ballast

Replacement)

Event 1: Lamp

Failure

(Lamp

Replacement)

Event 3: Ballast

Failure and Event 5:

New Construction

and Renovation

(Lamp & Ballast

Replacement)

CSL1 N/A N/A N/A N/A N/A

CSL2 N/A N/A N/A N/A N/ACSL3 90.8 N/A 7.91 N/A 1.3

CSL4 92.3 to 95.0 1.41 11.31 to 12.56 2.3 1.1

CSL5 95.4 to 97.3 13.65 to 19.52 11.18 to 19.52 0.8 to 1.4 0.8 to 1.6

8­42

EERE-2007-BT-TP-0013 COMMENT 05
8.5.1.2 Product Class: 8­Foot single pin slimline ≤4,500K

For the 8­foot single pin slimline ≤4,500K product class, DOE is analyzing three baseline

lamps:  75W T12, 60W T12, and 59W T8.  For each baseline lamp, DOE analyzes multiple lamp

substitutions with each lamp substitution corresponding to a CSL efficacy requirement of 87.3, 

92.0, 94.8, 98.2, and 101.5 lm/W. 

Table 8.5.7 presents the findings of the LCC and PBP analyses on the first baseline 8­foot

single pin slimline GSFL.  This table presents the LCC and PBP results for the 75W T12

baseline lamp operating in the commercial sector.  Key inputs consist of using AEO2007

reference case electricity prices, an analysis period of 4 years, and medium­range lamp and

ballast prices. 

The results for Event 1 show that the LCC of the baseline 75W T12 on a magnetic ballast

is higher than the LCC of the 60W T12 on a magnetic ballast that meets CSL3.  Any CSL above

CSL3 for this baseline would require a lamp­and­ballast replacement.  As discussed in the

engineering analysis (Chapter 5), although a 60W T12 lamp is often considered a reduced

wattage replacement of the 75W T12 lamp, there are no lamp options with a CCT of 4,100K that

emit enough lumens to fall within 10 percent of the baseline system lumens.  Shown below is the

highest efficacy 4,100K, 60W T12 lamp replacement.  The system light output of this lamp­andballast design is 13 percent less than that of the baseline system.

The results for Event 2 show that consumers who replace a functioning 75W T12 lamp

on a magnetic ballast with a high efficacy T8 lamp on an electronic ballast benefit from lower

LCCs at CSL5.  All CSLs greater than CSL3 can only be met by replacing the baseline ballast.  

Event 3 represents consumers who are already faced with replacing both a lamp and a ballast.

The baseline ballast for this event is assumed to be an electronic T12, since the ballast standards

from the 2000 Ballast Rule and EPACT 2005 would be effective in 2010. Consumers prompted

by this event experience positive LCC savings if they purchase a high efficacy T8 lamp on an

electronic ballast at CSL5.

8­43

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.7 LCC and PBP Results for a Two­Lamp 8­Foot 75W T12 Single Pin Slimline System Operating in the Commercial

Sector

Event Response

Candidate

Standard

Level

Rated

Lamp

Efficac

y

lm/W

Design Option LCC$ LCC Savings $ Installed Price $

Operating

Cost

Savings

One Year

$

Payback

Period

yr

Mean

Lumens

from

Baseline

%

Event 1:

Lamp

Failure

Baseline Baseline 85.6 75 W T12 & 0.94 BF Mag 166.98 N/A 16.03 N/A N/A 0.0

Lamp Repl. CSL3 97.5 60.5 W T12 & 0.88 BF Mag 136.54 30.44 19.30 8.69 0.4 ­13.1

Lamp &

Ballast

Repl.

CSL1 87.3 75 W T12 & 0.85 BF Elec 181.75 ­14.77 93.89 7.06 11.0 ­5.7

CSL2 92.0 75 W T12 & 0.85 BF Elec 178.15 ­11.17 95.79 7.06 11.3 ­2.5CSL3 94.8 60.1 W T8 & 1.18 BF Elec 193.71 ­26.73 108.44 2.19 42.1 9.0

CSL5 101.5 60.1 W T8 & 0.88 BF Elec 152.78 14.20 91.39 12.28 6.1 ­8.1

Event 2:

StandardsInduced

Retrofit

Baseline Baseline 85.6 75 W T12 & 0.94 BF Mag 158.96 N/A 16.03 N/A N/A 0.0

Lamp &

Ballast

Repl.

CSL1 87.3 75 W T12 & 0.85 BF Elec 181.75 ­22.79 93.89 7.06 11.0 ­5.7

CSL2 92.0 75 W T12 & 0.85 BF Elec 178.15 ­19.19 95.79 7.06 11.3 ­2.5CSL3 94.8 60.1 W T8 & 1.18 BF Elec 193.71 ­34.75 108.44 2.19 42.1 9.0

CSL5 101.5 60.1 W T8 & 0.88 BF Elec 152.78 6.18 91.39 12.28 6.1 ­8.1

Event :

Ballast

Failure

Baseline Baseline 85.6 75 W T12 & 0.88 BF Elec 176.61 N/A 87.52 N/A N/A ­6.4

Lamp &

Ballast

Repl.

CSL1 87.3 75 W T12 & 0.85 BF Elec 181.75 ­5.14 93.89 0.82 7.8 ­5.7

CSL2 92.0 75 W T12 & 0.85 BF Elec 178.15 ­1.54 95.79 0.82 10.1 ­2.5CSL5 101.5 60.1 W T8 & 0.88 BF Elec 152.78 23.83 91.39 6.03 0.6 ­8.1

Event 4:

Ballast

Retrofit

Baseline Baseline/CSL3 94.8 60.1 W T8 & 1.18 BF Elec 193.71 0.00 108.44 0.00 N/A 9.0

Lamp &

Ballast

Repl. CSL5 101.5 60.1 W T8 & 0.88 BF Elec 152.78 40.93 91.39 10.08 0 ­8.1

8­44

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.8 presents the findings of LCC and PBP analyses on a second baseline 8­foot

single pin slimline GSFL.  This table presents the LCC and PBP results for the 60W T12

baseline lamp operating in the commercial sector.  Key inputs consist of using AEO2007

reference case electricity prices, an analysis period of 4 years, and medium­range lamp and

ballast prices.   Note that a lamp replacement in Event 1 is not shown because there are no

energy­saving lamp replacement options for a 60W T12 lamp. 

Event 2 represents consumers who respond to higher lamp standards by replacing a

functioning 60W T12 system with a new lamp and ballast.  For this event, consumers experience

negative LCC savings at all CSLs.  Event 3 represents consumers who are already faced with

replacing both a lamp and a ballast.  The baseline ballast for this event is assumed to be an

electronic T12, since the ballast standards from the 2000 Ballast Rule and EPACT 2005 would

be effective in 2010.  Consumers prompted by this event experience positive LCC savings if they

purchase a high efficacy T8 lamp on an electronic ballast since the cost of the ballast is reduced

by the cost of the baseline ballast.

8­45

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.8 LCC and PBP Results for a Two­Lamp 8­Foot 60W T12 Single Pin Slimline System Operating in the Commercial

Sector

s men Lu Mean

Baseline from %

0.0

6.7

13.5

10.0

3.2

3.6

10.1

0.0

6.7

13.5

10.0

3.2

3.6

10.1

0.0

6.7

13.5

3.2

3.6

10.1

10.0

3.2

3.6

10.1

Period Payback

yr

N/A

14.8

15.420.7

11.312.411.6

N/A

14.8

15.420.7

11.312.4

11.6

N/A

5.7

9.92.7

3.6

3.4

N/A

1.3

1.7

1.8

Cost Operating

One Savings

Year $

N/A

5.16

5.163.58

6.946.386.94

N/A

5.16

5.163.58

6.946.38

6.94

N/A

0.82

0.822.602.04

2.60

N/A

3.36

2.80

3.36

Price Installed$

11.20

87.37

90.7985.30

89.6890.06

91.39

11.20

87.37

90.7985.30

89.6890.06

91.39

82.69

87.37

90.7989.68

90.0691.39

85.30

89.68

90.0691.39

Savings LCC $

N/A

­19.18

­18.71­17.95­10.81

­8.12

­10.08

N/A

­24.78

­24.31­23.55­16.42­13.73­15.68

N/A

­3.04

­2.56

5.33

8.026.06

N/A

7.13

9.827.87

LCC$

131.19

150.37

149.89149.13142.00139.31141.27

125.58

150.37

149.89149.13142.00139.31141.27147.33150.37149.89142.00139.31141.27149.13142.00139.31141.27

Option Design

60.5 W T12 & 0.88 BF Mag

60.5 W T12 & 0.85 BF Elec

60.5 W T12 & 0.85 BF Elec

60.1 W T8 & 0.88 BF Elec60.1 W T8 & 0.78 BF Elec

57 W T8 & 0.78 BF Elec

60.1 W T8 & 0.78 BF Elec

60.5 W T12 & 0.88 BF Mag

60.5 W T12 & 0.85 BF Elec

60.5 W T12 & 0.85 BF Elec

60.1 W T8 & 0.88 BF Elec60.1 W T8 & 0.78 BF Elec

57 W T8 & 0.78 BF Elec

60.1 W T8 & 0.78 BF Elec

60.5 W T12 & 0.88 BF Elec60.5 W T12 & 0.85 BF Elec60.5 W T12 & 0.85 BF Elec

60.1 W T8 & 0.78 BF Elec

57 W T8 & 0.78 BF Elec

60.1 W T8 & 0.78 BF Elec60.1 W T8 & 0.88 BF Elec60.1 W T8 & 0.78 BF Elec

57 W T8 & 0.78 BF Elec

60.1 W T8 & 0.78 BF Elec

Lamp Rated

Efficacy

lm/W

87.6

92.697.594.898.2

101.8

101.5

87.6

92.697.594.898.2

101.8

101.5

87.6

92.697.598.2

101.8

101.5

94.8

98.2

101.8

101.5

Candidate

Level Standard

Baseline/CSL

1

CSL2

CSL3CSL3CSL4CSL5CSL5

Baseline/CSL

1

CSL2

CSL3CSL3CSL4CSL5CSL5

Baseline/CSL

1

CSL2

CSL3CSL4CSL5CSL5

Baseline/CSL

3

CSL4

CSL5CSL5

Response

Baseline

Lamp &

BallastRepl.

Baseline

Lamp &

BallastRepl.

Baseline

Lamp &

BallastRepl.

Baseline

Lamp &

BallastRepl.

Event

Event 1:

LampFailure

Event 2:

StandardsInducedRetrofit

Event 3:

BallastFailure

Event 4:

BallastRetrofit

8­46

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.9 presents the findings of LCC and PBP analyses on 8­foot single pin slimline

GSFL.  This table presents the LCC and PBP results for the 59W T8 baseline lamp operating in

the commercial sector.  Key inputs consist of using AEO2007 reference case electricity prices, an

analysis period of 4 years, and medium­range lamp and ballast prices. 

The results for Event 1 show that the LCC of the baseline 59W T8 on an electronic

ballast is higher than the LCC of the 57W or 55W T8 on an electronic ballast that meets CSL5.  

Event 3 represents consumers who must replace both a lamp and a ballast.  Consumers prompted

by this event will experience positive LCC savings if they purchase a T8 lamp that meets CSL5.

Table 8.5.10 to Table 8.5.12 summarize the range of results for the 8­foot single pin

slimline product class.  Only the most relevant events under each baseline lamp are shown.  In

general, one finds that a CSL at or above CSL4 would induce the replacement of T12 magnetic

ballasts with electronic T8 ballasts, as there are no 60W or 75W T12 lamps that meet these

CSLs. For T12 baseline lamps, there are design options with positive LCC savings at CSLs

above CSL3 for certain lamp purchasing events.  For the T8 baseline lamp, positive LCC savings

are possible at CSLs up to and including CSL5. 

8­47

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.9 LCC and PBP Results for a Two­Lamp 8­Foot 59W T8 Single Pin Slimline System Operating in the Commercial

Sector

Event

Type Response

Candidate

Standard

Level

Rated

Lamp

Efficacy

lm/W

Design Option LCC$ LCC Savings $ Installed Price $

Operating

Cost

Savings

One Year

$

Payback

Period

yr

Mean

Lumens

from

Baseline

%

Event 1:

Lamp

Failure

Baseline Baseline/

CSL3 94.8 60.1 W T8 & 0.88 BF Elec 117.58 N/A 12.61 N/A N/A 0.0

Lamp Repl. CSL5 101.8 57 W T8 & 0.88 BF Elec 112.41 5.17 17.37 1.44 3.3 6.2

CSL5 103.6 55 W T8 & 0.88 BF Elec 109.31 8.27 16.56 2.93 1.3 5.6

Event 3:

Ballast

Failure

Baseline Baseline/

CSL3 94.8 60.1 W T8 & 0.88 BF Elec 149.13 N/A 85.30 N/A N/A 0.0

Lamp and

Ballast

Repl.

CSL4 98.2 60.1 W T8 & 0.85 BF Elec 150.06 ­0.92 89.68 1.01 4.3 2.2

CSL5 101.8 57 W T8 & 0.85 BF Elec 142.57 6.57 90.06 1.85 2.6 2.6CSL5 101.5 60.1 W T8 & 0.78 BF Elec 141.27 7.87 91.39 3.36 1.8 0.1

CSL5 103.6 55 W T8 & 0.88 BF Elec 140.86 8.27 89.25 2.93 1.3 5.6

Event 5:

New Const.

and

Renovation

Baseline Baseline/

CSL3 94.8 60.1 W T8 & 0.88 BF Elec 149.13 N/A 85.30 N/A N/A 0.0

Lamp &

Ballast

Repl.

CSL4 98.2 60.1 W T8 & 0.85 BF Elec 150.06 ­0.92 89.68 1.01 4.3 2.2

CSL5 101.8 57 W T8 & 0.85 BF Elec 142.57 6.57 90.06 1.85 2.6 2.6

CSL5 101.5 60.1 W T8 & 0.78 BF Elec 141.27 7.87 91.39 3.36 1.8 0.1

CSL5 103.6 55 W T8 & 0.88 BF Elec 140.86 8.27 89.25 2.93 1.3 5.6

8­48

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.10 Summary of the LCC and PBP Results for a Two­Lamp 8­Foot 75W T12 Single Pin Slimline System Operating

in the Commercial Sector

Candidate

Standard

Level

Rated Lamp

Efficacy

lm/W

LCC Savings

$

Payback Period

yr

Event 1: Lamp

Failure

(Lamp

Replacement)

Event 2:

Standards­Induced

Retrofit

(Lamp & Ballast

Replacement)

Event 3: Ballast

Failure

(Lamp & Ballast

Replacement)

Event 1: Lamp

Failure

(Lamp

Replacement)

Event 2:

StandardsInduced Retrofit

(Lamp & Ballast

Replacement)

Event 3: Ballast

Failure

(Lamp & Ballast

Replacement)

CSL1 87.3 N/A ­22.79 ­5.14 N/A 11.0 7.8

CSL2 92.0 N/A ­19.19 ­1.54 N/A 11.3 10.1CSL3 94.8 to 97.5 30.44 ­34.75 N/A 0.4 42.1 N/A

CSL4 N/A N/A N/A N/A N/A N/A N/A

CSL5 101.5 N/A 6.18 23.83 N/A 6.1 0.6

Table 8.5.11 Summary of the LCC and PBP Results for a Two­Lamp 8­foot 60W T12 Single Pin Slimline System Operating in

the Commercial Sector

Candidate

Standard

Level

Rated Lamp

Efficacy

lm/W

LCC Savings

$

Payback Period

yr

Event 2: StandardsInduced Retrofit

(Lamp & Ballast

Replacement)

Event 3: Ballast

Failure

(Lamp & Ballast

Replacement)

Event 2:

StandardsInduced Retrofit

(Lamp & Ballast

Replacement)

Event 3: Ballast

Failure

(Lamp & Ballast

Replacement)

CSL15 87.6 N/A N/A N/A N/A

CSL2 92.6 ­24.78 ­3.04 14.8 5.7

CSL3 94.8 to 97.5 ­24.31 to ­23.55 ­2.56 15.4 to 20.7 9.9

CSL4 98.2 ­16.42 5.33 11.3 2.7

CSL5 101.5 to 101.8 ­15.68 to ­13.73 6.06 to 8.02 11.6 to 12.4 3.4 to 3.6

Because the 60W T12 baseline exceeds CSL1, there are no energy saving design options at this level. There are, however, energy saving design options at

CSL1 for the 75W T12 baseline.

8­49

5

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.12 Summary of the LCC and PBP Results for a Two­Lamp 8­Foot 59W T8 Single Pin Slimline System Operating in

the Commercial Sector

Candidate

Standard

Level

Rated Lamp

Efficacy

lm/W

LCC Savings

$

Payback Period

yr

Event 1:

Lamp Failure

(Lamp

Replacement)

Event 3: Ballast Failure

and Event 5: New

Construction and

Renovation

(Lamp & Ballast

Replacement)

Event 1: Lamp

Failure

(Lamp Replacement)

Event 3: Ballast Failure

and Event 5: New

Construction and

Renovation

(Lamp & Ballast

Replacement)

CSL1 N/A N/A N/A N/A N/A

CSL2 N/A N/A N/A N/A N/ACSL3 N/A N/A N/A N/A N/ACSL4 98.2 N/A ­0.92 N/A 4.3

CSL5 101.5 to 103.6 5.17 to 8.27 6.57 to 8.27 1.3 to 3.3 1.3 to 2.6

8­50

EERE-2007-BT-TP-0013 COMMENT 05
8.5.1.3 Product Class: 8­foot recessed double contact HO ≤4,500K

For the 8­foot recessed double contact HO ≤4,500K product class, DOE analyzed two

baseline lamps:  a 110W T12 and a 95W T12.  Each lamp was analyzed at five CSLs with

efficacy requirements of 85.5, 87.6, 91.9, and 95.3 lm/W. 

Table 8.5.13 presents the findings of LCC and PBP analyses on the 8­foot recessed

double contact HO GSFL.  This table presents the LCC and PBP results for the 110W T12

baseline lamp operating in the industrial sector.  Key inputs consist of using AEO2007 reference

case electricity prices, an analysis period of 3.2 years, and medium­range lamp and ballast prices.

Note that for Event 1, the LCC of the baseline 110W T12 on an electronic ballast is

higher than the LCC of both 95W T12 on an electronic ballast that meets CSL2 and CSL3

respectively.  The results for Event 2 show that consumers would not benefit by replacing a

functioning 110W T12 electronic system halfway through its lifetime with a high efficacy T8

lamp electronic system.  Because baseline users face the cost of a new ballast and lamps in the

base case, Event 3 consumers would experience positive LCC savings if they purchase a high

efficacy T8 system or a 95W T12 lamp rather than a low­efficacy 110W T12 electronic system.  

Event 5 represents consumers who are renovating an existing building or constructing a new

building.  Consumers in this scenario can change the spacing of the T8 HO system to achieve the

same lumens as the baseline T12 system.  In this scenario, the lowest LCC occurs at CSL2.

8­51

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.13 LCC and PBP Results for a Two­Lamp 8­Foot 110W T12 Recessed Double Contact HO System Operating in the

Industrial Sector

s men Lu Mean

Baseline from %

0.0

­7.7­6.1

3.8

­9.8

­8.2

­7.0­6.4

0.0

3.8

­9.8

­8.2­7.0­6.4

0.0

3.8

­9.8

­8.2

­7.0­6.4

0.0

3.8

­9.8

­8.2

­7.0­6.4

0.0

3.8

­9.8

­8.2

­7.0

0.0

­6.7

1.1

Period Payback

yr

N/A

0.0

1.6

48.5

7.6

8.7

8.86.5

N/A

48.5

7.6

8.78.86.5

N/A

6.1

0.0

1.2

1.21.4

N/A

6.1

0.0

1.2

1.21.4

N/A

6.1

0.0

1.2

1.2

5.4

3.8

4.1

Cost Operating

Year One Savings $

0.00

7.99

7.99

1.90

10.67

10.67

10.6715.91

0.00

1.90

10.67

10.6710.6715.91

0.00

1.90

10.67

10.67

10.6715.91

0.00

1.90

10.67

10.67

10.6715.91

0.00

1.90

10.67

10.67

10.67

7.35

10.61

10.61

Price Installed $

19.57

19.89

32.21

111.67

100.46

112.78

113.40122.63

19.57

111.67

100.46

112.78113.40122.63

100.14

111.67

100.46

112.78113.40122.63

100.14

111.67

100.46

112.78113.40122.63

100.14

111.67100.46

112.78113.40119.40119.73122.63

Savings LCC $

0.00

15.84

3.52

­34.22

­5.27

­17.59­18.22

2.74

0.00

­44.05

­15.11­27.43­28.05

­7.10

0.00

­7.69

21.25

8.93

8.31

29.26

0.00

­7.69

21.25

8.93

8.31

29.26

0.00

­7.69

21.25

8.93

8.319.29

12.44

10.06

LCC$

151.62

135.78

148.10185.84

156.89

169.21169.84148.88

141.79

185.84

156.89

169.21169.84148.88

178.14

185.84

156.89

169.21169.84148.88

178.14

185.84

156.89

169.21169.84148.88

178.14

185.84

156.89

169.21169.84168.85165.70168.09

Option Design

113 W T12 & 0.9 BF Elec

97 W T12 & 0.9 BF Elec

97 W T12 & 0.9 BF Elec

113 W T12 & 0.88 BF Elec

97 W T12 & 0.88 BF Elec97 W T12 & 0.88 BF Elec97 W T12 & 0.88 BF Elec

86 W T8 & 0.88 BF Elec

113 W T12 & 0.9 BF Elec

113 W T12 & 0.88 BF Elec

97 W T12 & 0.88 BF Elec97 W T12 & 0.88 BF Elec97 W T12 & 0.88 BF Elec

86 W T8 & 0.88 BF Elec

113 W T12 & 0.9 BF Elec

113 W T12 & 0.88 BF Elec

97 W T12 & 0.88 BF Elec97 W T12 & 0.88 BF Elec97 W T12 & 0.88 BF Elec

86 W T8 & 0.88 BF Elec

113 W T12 & 0.9 BF Elec

113 W T12 & 0.88 BF Elec

97 W T12 & 0.88 BF Elec97 W T12 & 0.88 BF Elec97 W T12 & 0.88 BF Elec

86 W T8 & 0.88 BF Elec

113 W T12 & 0.9 BF Elec

113 W T12 & 0.88 BF Elec

97 W T12 & 0.88 BF Elec97 W T12 & 0.88 BF Elec97 W T12 & 0.88 BF Elec

86 W T8 & 0.88 BF Elec86 W T8 & 0.81 BF Elec86 W T8 & 0.81 BF Elec

Lamp Rated

Efficacy

lm/W

80.1

86.1

87.683.286.187.688.995.3

80.1

83.2

86.187.688.995.3

80.1

83.2

86.187.688.995.3

80.1

83.2

86.187.688.995.3

80.1

83.2

86.187.688.991.993.095.3

Candidate

Level Standard

Baseline

CSL2

CSL3CSL1CSL2CSL3CSL3CSL5

Baseline

CSL1

CSL2CSL3CSL3CSL5

Baseline

CSL1

CSL2CSL3CSL3CSL5

Baseline

CSL1

CSL2CSL3CSL3CSL5

Baseline

CSL1

CSL2CSL3CSL3CSL4CSL4CSL5

Response

Baseline

Lamp Repl.

Lamp &

Ballast

Repl.

Baseline

Lamp &

Ballast

Repl.

Baseline

Lamp &

Ballast

Repl.

Baseline

Lamp &

Ballast

Repl.

Baseline

Lamp &

Ballast

Repl.

Event

Event 1:

Lamp

Failure

Event 2:

StandardsInduced

Retrofit

Event 3:

Ballast

Failure

Event 4:

Ballast

Retrofit

Event 5:

New Const.

and Renov.

8­52

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.14 presents the findings of LCC and PBP analyses on 8­foot recessed double

contact high­output GSFL.  This table presents the LCC and PBP results for the 95W T12

baseline lamp operating in the industrial sector.  Key inputs consist of using AEO2007 reference

case electricity prices, an analysis period of 3.2 years, and medium­range lamp and ballast prices.  

Note that lamp replacements in Event 1 are not shown because there are no energy­saving lamp

replacement options for a 95W T12 lamp. 

The results for Event 2 show that consumers would not benefit by replacing a functioning

95W T12 electronic system halfway through its lifetime with a high efficacy T8 lamp electronic

system.  Because they face the cost of a new ballast and lamps in the base case, Event 3

consumers would experience positive LCC savings if they purchase a high efficacy T8 system

rather than a low efficacy T12 electronic system.  Event 5 represents consumers who are

renovating an existing building or constructing a new building.  Consumers in this scenario can

change the spacing of the T8 HO system to achieve the same lumens as the baseline T12 system.  

In this scenario, the lowest LCC occurs at CSL4.

8­53

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.14 LCC and PBP Results for a Two­Lamp 8­Foot 95W T12 Recessed Double Contact HO System Operating in the

Industrial Sector

s men Lu Mean

Baseline from %

0.0

6.9

7.69.0

­0.1

1.3

1.00.0

6.9

7.69.0

­0.1

1.3

1.00.0

6.9

7.6

9.0

­0.1

1.3

1.0

­0.1

1.0

0.0

6.9

7.6

9.0

­0.1

1.3

1.0

Period Payback

yr

N/A

64.8

37.037.213.3

13.410.2

N/A

64.8

37.037.213.3

13.410.2

N/A

4.6

6.9

7.13.2

3.2

2.6

N/A

0.3

N/A

4.6

6.9

7.13.2

3.2

2.6

Cost Operating

One Savings

Year $

N/A

1.34

2.682.687.92

7.92

10.69

N/A

1.34

2.682.687.92

7.92

10.69

N/A

1.34

2.68

2.687.927.92

10.69

7.92

10.69

N/A

1.34

2.68

2.687.927.92

10.69

Price Installed$

13.75

100.46

112.78113.40119.40

119.73122.63

13.75

100.46

112.78113.40119.40

119.73122.63

94.32

100.46

112.78

113.40119.40

119.73122.63119.40

122.63

94.32

100.46

112.78

113.40119.40

119.73122.63

Savings LCC $

N/A

­29.96

­39.57­40.20­14.28­17.21­13.62

N/A

­36.86

­46.48­47.10­21.19­24.12­20.53

N/A

­3.43

­13.05­13.67

12.25

9.32

12.90

N/A

0.65

N/A

­3.43

­13.05­13.67

12.25

9.32

12.90

LCC$

129.64

159.60

169.21169.84143.92146.85143.26

122.73

159.60

169.21169.84143.92146.85143.26

156.17

159.60

169.21169.84143.92146.85143.26143.92

143.26

156.17

159.60

169.21169.84143.92146.85143.26

Option Design

97 W T12 & 0.9 BF Elec

97 W T12 & 0.89 BF Elec

97 W T12 & 0.88 BF Elec97 W T12 & 0.88 BF Elec

86 W T8 & 0.88 BF Elec

86 W T8 & 0.88 BF Elec86 W T8 & 0.81 BF Elec

97 W T12 & 0.9 BF Elec

97 W T12 & 0.89 BF Elec

97 W T12 & 0.88 BF Elec97 W T12 & 0.88 BF Elec

86 W T8 & 0.88 BF Elec

86 W T8 & 0.88 BF Elec86 W T8 & 0.81 BF Elec

97 W T12 & 0.9 BF Elec

97 W T12 & 0.89 BF Elec

97 W T12 & 0.88 BF Elec97 W T12 & 0.88 BF Elec

86 W T8 & 0.88 BF Elec

86 W T8 & 0.88 BF Elec86 W T8 & 0.81 BF Elec86 W T8 & 0.88 BF Elec86 W T8 & 0.81 BF Elec

97 W T12 & 0.9 BF Elec

97 W T12 & 0.89 BF Elec

97 W T12 & 0.88 BF Elec97 W T12 & 0.88 BF Elec

86 W T8 & 0.88 BF Elec

86 W T8 & 0.88 BF Elec86 W T8 & 0.81 BF Elec

Lamp Rated

Efficacy

lm/W

82.5

86.1

87.688.991.993.095.382.5

86.1

87.688.991.993.095.382.5

86.1

87.688.991.993.095.391.9

95.3

82.5

86.1

87.688.991.993.095.3

Candidate

Level Standard

Baseline

CSL2

CSL3CSL3CSL4CSL4CSL5

Baseline

CSL2

CSL3CSL3CSL4CSL4CSL5

Baseline

CSL2

CSL3CSL3

CSL4

CSL4CSL5

Baseline/CSL

4

CSL5

Baseline

CSL2

CSL3CSL3CSL4CSL4CSL5

Response

Baseline

Lamp &

BallastRepl.

Baseline

Lamp &

BallastRepl.

Baseline

Lamp &

BallastRepl.

Baseline

Lamp &

BallastRepl

Baseline

Lamp &

BallastRepl.

Event

Event 1:

LampFailure

Event 2:

StandardsInducedRetrofit

Event 3:

BallastFailure

Event 4:

BallastRetrofit

Event 5:

New Const.

and Renov

8­54

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.15 to Table 8.5.16 summarize the range of results for the 8­foot recessed

double contact product class.  Only the most relevant events under each baseline lamp are

shown.  In general, one finds that a CSL at or above CSL3 would induce the replacement of T12

electronic ballasts with electronic T8 ballasts, as no 95W or 110W T12 lamps meet these CSLs.  

This migration may result in negative LCC savings for consumers who would not otherwise

replace their T12 electronic system. 

8­55

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.15 Summary of the LCC and PBP Results for a Two­Lamp 8­Foot 110W T12 Recessed Double Contact HO System

Operating in the Industrial Sector

Candidate

Standard

Level

Rated Lamp

Efficacy

lm/W

LCC Savings

$

Payback Period

yr

Event 1: Lamp

Failure

(Lamp

Replacement)

Event 2:

Standards­Induced

Retrofit

(Lamp & Ballast

Replacement)

Event 3: Ballast

Failure

(Lamp & Ballast

Replacement)

Event 1: Lamp

Failure

(Lamp

Replacement)

Event 2:

StandardsInduced Retrofit

(Lamp & Ballast

Replacement)

Event 3: Ballast

Failure

(Lamp & Ballast

Replacement)

CSL1 83.2 NA ­44.05 ­7.69 NA 48.5 6.1

CSL2 86.1 15.84 ­15.11 21.25 0.0 7.6 0.0

CSL3 87.6 to 88.9 3.52 ­28.05 to ­27.43 8.31 to 8.95 1.6 8.7 to 8.8 1.2

CSL4 91.9 to 93.0 NA NA NA NA NA NA

CSL5 95.3 NA ­7.10 29.26 NA 6.5 1.4

Table 8.5.16 Summary of the LCC and PBP Results for a Two­Lamp 8­Foot 95W T12 Recessed Double Contact HO System

Operating in the Industrial Sector

Candidate

Standard Level

Rated Lamp

Efficacy

lm/W

LCC Savings

$

Payback Period

yr

Event 2:

Standards­Induced

Retrofit

(Lamp & Ballast

Replacement)

Event 3: Ballast

Failure and Event 5:

New Construction

and Renovation

(Lamp & Ballast and

Replacement)

Event 2:

StandardsInduced

Retrofit

(Lamp &

Ballast

Replacement)

Event 3: Ballast

Failure and Event 5:

New Construction

and Renovation

(Lamp & Ballast and

Replacement)

CSL1 NA NA NA NA NA

CSL2 86.1 ­36.86 ­3.43 64.8 4.6

CSL3 87.6 to 88.9 ­47.10 to ­46.48 ­13.67 to ­13.05 37.0 to 37.2 6.9 to 7.1

CSL4 91.9 to 93.0 ­24.12 to ­21.19 9.32 to 12.25 13.3 to 13.4 3.2

CSL5 95.3 ­20.53 12.90 10.2 2.6

8­56

EERE-2007-BT-TP-0013 COMMENT 05
8.5.2 Life­Cycle Cost Results for Incandescent Reflector Lamps

The following tables present the findings of the LCC and PBP analyses on standardspectrum IRL.  Table 8.5.17 provides the LCC and PBP results for a 90W PAR38 lamp

operating in the commercial sector.  These results are based on the AEO2007 reference case

electricity prices, an analysis period of 0.9 years, and medium­range lamp prices.  Note that the

lowest LCC occurs with the improved HIR lamp design at CSL3. 

Table 8.5.18 provides the LCC and PBP results for a 90W PAR38 lamp operating in the

residential sector.  These results are based on the AEO2007 reference case electricity prices, an

analysis period of 3.4 years, and medium­range lamp prices.  Note that the lowest LCC occurs

with the improved HIR lamp design at CSL3.

Table 8.5.19 provides the LCC and PBP results for a 75W PAR38 lamp operating in the

commercial sector.  These results are based on the AEO2007 reference case electricity prices, an

analysis period of 0.9 years, and medium­range lamp prices.  Note that the lowest LCC occurs

with the improved HIR lamp design at CSL3. 

Table 8.5.20 provides the LCC and PBP results for a 75W PAR38 lamp operating in the

residential sector.  These results are based on the AEO2007 reference case electricity prices, an

analysis period of 3.4 years, and medium­range lamp prices.  Note that the lowest LCC occurs

with the improved HIR lamp design at CSL3.

Table 8.5.21 provides the LCC and PBP results for a 50W PAR30 lamp operating in the

commercial sectors.  These results are based on the AEO2007 reference case electricity prices, an

analysis period of 0.9 years, and medium­range lamp prices.  Note that the lowest LCC occurs

with the improved HIR lamp design at CSL3. 

Table 8.5.21 provides the LCC and PBP results for a 50W PAR30 lamp operating in the

residential sectors.  These results are based on the AEO2007 reference case electricity prices, an

analysis period of 3.4 years, and medium­range lamp prices.  Note that the lowest LCC occurs

with the improved HIR lamp design at CSL3.  

8­57

EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.17 LCC and PBP Results for a 90W PAR38 Lamp Operating in the Commercial Sector

Event Response

Candidate

Standard

Level

Rated

Lamp

Efficacy

lm/W

Design Option LCC$ LCC Savings $ Installed Price $

Operating

Cost

Savings

One Year

$

Payback

Period

yr

Initial

Lumens

from

Baseline

%

Event1:

Lamp

Failure

Baseline Baseline 14.6 90W, 14.6 lm/W & 2,500 hrs, Halogen 28.99 N/A 6.16 N/A N/A 0.0

Lamp

Repl CSL1 16.6 79W, 16.6 lm/W & 3,000 hrs, Improved Halogen 25.82 3.17 7.55 2.70 0.5 0.0

CSL2 18.0 70W, 18,lm/W & 3,000 hrs, HIR 23.92 5.08 7.73 4.91 0.3 ­3.8

CSL3 19.8 66W, 19.8,lm/W & 4,000 hrs, Improved HIR 22.18 6.81 9.05 5.89 0.5 0.0

Table 8.5.18 LCC and PBP Results for a 90W PAR38 Lamp Operating in the Residential Sector

Event Response

Candidate

Standard

Level

Rated

Lamp

Efficacy

lm/W

Design Option LCC$ LCC Savings $ Installed Price $

Operating

Cost

Savings

One Year

$

Payback

Period

yr

Initial

Lumens

from

Baseline

%

Event1:

Lamp

Failure

Baseline Baseline 14.6 90W, 14.6 lm/W & 2,500 hrs, Halogen 29.07 N/A 5.13 N/A N/A 0.0

Lamp

Repl CSL1 16.6 79W, 16.6 lm/W & 3,000 hrs, Improved Halogen 26.50 2.57 6.52 0.93 1.5 0.0

CSL2 18.0 70W, 18,lm/W & 3,000 hrs, HIR 24.40 4.67 6.70 1.69 0.9 ­3.8

CSL3 19.8 66W, 19.8,lm/W & 4,000 hrs, Improved HIR 23.05 6.03 8.01 2.02 1.4 0.0

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EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.19 LCC and PBP Results for a 75W PAR38 Lamp Operating in the Commercial Sector

Event Response

Candidate

Standard

Level

Rated

Lamp

Efficacy

lm/W

Design Option LCC$ LCC Savings $ Installed Price $

Operating

Cost

Savings

One Year

$

Payback

Period

yr

Initial

Lumens

from

Baseline

%

Event

1:

Lamp

Failure

Baseline Baseline 14.0 75W, 14 lm/W & 2,500 hrs, Halogen 25.53 N/A 6.16 N/A N/A 0.0

Lamp

Repl. CSL1 15.9 66W, 15.9 lm/W & 3,000 hrs, Improved Halogen 22.81 2.71 7.55 2.21 0.6 0.0

CSL2 17.5 60W, 17.5 lm/W & 3,000hrs, HIR 21.60 3.92 7.73 3.68 0.4 0.0

CSL3 19.1 55W, 19.1 lm/W & 4,000 hrs, Improved HIR 19.64 5.89 9.05 4.91 0.6 0.0

Table 8.5.20 LCC and PBP Results for a 75W PAR38 Lamp Operating in the Residential Sector

Event Response

Candidate

Standard

Level

Rated

Lamp

Efficacy

lm/W

Design Option LCC$ LCC Savings $ Installed Price $

Operating

Cost

Savings

One Year

$

Payback

Period

yr

Initial

Lumens

from

Baseline

%

Event

1:

Lamp

Failure

Baseline Baseline 14.0 75W, 14 lm/W & 2,500 hrs, Halogen 25.28 N/A 5.13 N/A N/A 0.0

Lamp

Repl. CSL1 15.9 66W, 15.9 lm/W & 3,000 hrs, Improved Halogen 23.21 2.07 6.52 0.76 1.8 0.0

CSL2 17.5 60W, 17.5 lm/W & 3,000hrs, HIR 21.87 3.41 6.70 1.27 1.2 0.0

CSL3 19.1 55W, 19.1 lm/W & 4,000 hrs, Improved HIR 20.26 5.02 8.01 1.69 1.7 0.0

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EERE-2007-BT-TP-0013 COMMENT 05
Table 8.5.21 LCC and PBP Results for a 50W PAR30 Lamp Operating in the Commercial Sector

Event Response

Candidate

Standard

Level

Rated

Lamp

Efficacy

lm/W

Design Option LCC$ LCC Savings $ Installed Price $

Operating

Cost

Savings

One Year

$

Payback

Period

yr

Initial

Lumens

from

Baseline

%

Event

1:

Lamp

Failure

Baseline Basline 11.6 50W, 11.6 lm/W & 3,000 hrs, Halogen 17.12 N/A 5.56 N/A N/A 0.0

Lamp

Repl. CSL1 14.0 44.3W, 14 lm/W & 3,000 hrs, Improved Halogen 17.19 ­0.07 6.95 1.40 1.0 6.9

CSL2 15.0 41.3W, 15 lm/W & 3,000 hrs, HIR 16.67 0.45 7.12 2.14 0.7 6.9

CSL3 17.0 40W, 17 lm/W & 4,000 hrs, Improved HIR 15.70 1.42 8.44 2.46 1.2 17.2

Table 8.5.22 LCC and PBP Results for a 50W PAR30 Lamp Operating in the Residential Sector

Event Response

Candidate

Standard

Level

Rated

Lamp

Efficacy

lm/W

Design Option LCC$ LCC Savings $ Installed Price $

Operating

Cost

Savings

One Year

$

Payback

Period

yr

Initial

Lumens

from

Baseline

%

Event

1:

Lamp

Failure

Baseline Basline 11.6 50W, 11.6 lm/W & 3,000 hrs, Halogen 17.17 N/A 4.52 N/A N/A 0.0

Lamp

Repl. CSL1 14.0 44.3W, 14 lm/W & 3,000 hrs, Improved Halogen 17.12 0.05 5.91 0.48 2.9 6.9

CSL2 15.0 41.3W, 15 lm/W & 3,000 hrs, HIR 16.54 0.64 6.09 0.73 2.1 6.9

CSL3 17.0 40W, 17 lm/W & 4,000 hrs, Improved HIR 15.99 1.18 7.41 0.84 3.4 17.2

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EERE-2007-BT-TP-0013 COMMENT 05
8.6 DETAILED RESULTS AND SENSITIVITY RUNS

DOE presents more detailed results and sensitivity runs LCC analysis in Appendix 8B.  

These results include Monte Carlo probability distributions, price sensitivity scenarios, and

operating hour sensitivity scenarios.

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EERE-2007-BT-TP-0013 COMMENT 05
  

REFERENCES

i

 Fuller, Sieglinde K. and Stephen R. Peterson. National Institute of Standards and Technology

Handbook 135, 1996 Edition.  Life­Cycle Costing Manual for the the Federal Energy

Management Program.   Prepared for U. S. Department of Energy.  Federal Energy Management

Program.  Office of the Assistant Secretary for Conservation and Renewable Energy. February

1996.  Washington, D.C.  http://fire.nist.gov/fire/firedocs/build96/PDF/b96121.pdf

ii U.S. Department of Energy. Energy Information Administration.  Annual Energy Outlook 2007

with Projections to 2030.  February 2007.  Washington, D.C.  

http://www.eia.doe.gov/oiaf/aeo/index.html.

iii U.S. Department of Energy. Energy Efficiency and Renewable Energy. Office of Building

Research and Standards.  Technical Support Document:  Energy Efficiency Standards for

Consumer Products:  Fluorescent Lamps Ballast Proposed Rule.  Appendix A.  Engineering

Analysis Supporting Documentation.  January 2000.  Washington, D.C.  

http://www.eere.energy.gov/buildings/appliance_standards/residential/pdfs/appendix_a.pdf. 

ivR. S. Means Company, Inc.  2007 RS Means Electrical Cost Data.  2007.  R. S. Means

Company, Inc.  Kingston, Massachusetts.

v

 U.S.  Department of Labor.  Bureau of Labor Statistics.  May 2005 Occupational Employment

and Wage Estimates.  National Cross­Industry Estimates.  2005.  Washington, D.C.

http://www.bls.gov/oes/oes_dl.htm. 

vi U.S. Department of Energy. Energy Information Administration.  Form EIA­861 for 2005.  

2005.  Washington, D.C.

http://www.eia.doe.gov/cneaf/electricity/page/eia861.html. 

vii U.S. Department of Energy. Energy Information Administration.  Annual Energy Outlook

2007 with Projections to 2030.  February, 2007.  Washington, D.C.  

http://www.eia.doe.gov/oiaf/archive/aeo07/pdf/aeotab_3.pdf

viii The Federal Reserve Board.  Federal Reserve Statistical Release, Selected Interest Rates, 

Historical Data, Instrument: CDs (secondary market), Maturity: 6­month, Frequency: Annual, 

Description: Average rate on 6­month negotiable certificates of deposit (secondary market), 

quoted on an investment basis.  2006.  Washington, D.C.

http://www.federalreserve.gov/releases/H15/data.htm.

ix The Federal Reserve Board.  Federal Reserve Statistical Release, Selected Interest Rates, 

Historical Data, Instrument: State and local bonds, Maturity: 20­year, Frequency: Monthly, 

Description: Bond buyer go 20­bond municipal bond index.  2006.  Washington, D.C.

http://www.federalreserve.gov/releases/H15/data.htm. 

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EERE-2007-BT-TP-0013 COMMENT 05
x

 The Federal Reserve Board.  Federal Reserve Statistical Release, Selected Interest Rates, 

Historical Data, Instrument:  Corporate bonds/Moody’s Seasoned AAA, Frequency: Annual, 

Description: Moody’s yield on seasoned corporate bonds – all industries, AAA.  2006.  

Washington, D.C.  

http://www.federalreserve.gov/releases/H15/data.htm.

xi  Mortgage­X.  Mortgage Information Service: Cost of Savings Index (COSI) Index History. 

2006.  http://mortgage­x.com/general/indexes/default.asp.  The September, 12, 2007 material

from this website is available in Docket # EE–2006–STD–0131.  For more information, contact

Brenda Edwards Jones at (202) 586 2945.

xii  Damodaran Online.  The Data Page: Historical Returns on Stocks, Bonds, and Bills – United

States.  2006.  http://pages.stern.nyu.edu/~adamodar.  The September 12, 2007 material from this

website is available in Docket # EE–2006–STD–0131.  For more information, contact Brenda

Edwards Jones at (202) 586 2945.

xiii Modigliani, F. and M. Miller.  The Cost of Capital, Corporation Finance and the Theory of

Investment.  American Economic Review. 1958. (June): pp. 261­297.

xiv Bondsonline Group Inc.  Bonds Online.  2003.  http://www.bondsonline.com. The February

22, 2003 material from this website is available in Docket #86.  For more information, contact

Brenda Edwards Jones at (202) 586 2945.

xv Damodaran, A. Damodaran Online. 2003.  (Last accessed February 2003.)

http://pages.stern.nyu.edu/~adamodar/New_Home_Page/data.html.  The February 2003 material

from this website is available in Docket #86.  For more information, contact Brenda Edwards

Jones at (202) 586 2945.

xvi U.S. Department of Commerce. Bureau of Economic Analysis.  GDP price change:  Q3, 2000

­Q3, 2001.  2002.  http://www.bea.gov/national. The February 2003 material from this website

is available in Docket #86.  For more information, contact Brenda Edwards Jones at (202) 586

2945.

xvii Bloomberg, L. P.  Bloomberg Professional.  2003.  

http://about.bloomberg.com/professional/profservice.html The February 2003 material from this

website is available in Docket #86.  For more information, contact Brenda Edwards Jones at

(202) 586 2945.

xviii Value Line.  Value Line Investment Survey.  2003.  http://www.valueline.com. The January

2003 material from this website is available in Docket #86.  For more information, contact

Brenda Edwards Jones at (202) 586 2945.

xix U.S. Office of Management and Budget.  Circular No. A­94. Appendix C.  2002.    

http://www.whitehouse.gov/omb/circulars/a094/a94_appx­ c.html. The November 2002 material

8­63

EERE-2007-BT-TP-0013 COMMENT 05
from this website is available in Docket #86.  For more information, contact Brenda Edwards

Jones at (202) 586 2945.

xx Federal Reserve Board.  Statistics:  Releases and Historical Data ­ Selected Interest Rates –

State and Local Bonds.  2002.  http://www.federalreserve.gov/releases/h15/data.htm. The

February 2003 material from this website is available in Docket #86.  For more information, 

contact Brenda Edwards Jones at (202) 586 2945.

xxi U.S. Department of Energy­Energy Information Administration.  Commercial Buildings

Energy Consumption Survey: Commercial Energy Uses and Costs.  2003.  Washington, D.C.

http://www.eia.doe.gov/emeu/cbecs/.

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EERE-2007-BT-TP-0013 COMMENT 05