Rulemaking Framework Document for

General Service Fluorescent Lamps, Incandescent Reflector

Lamps, and General Service Incandescent Lamps

U.S. Department of Energy

Office of Energy Efficiency and Renewable Energy

Building Technologies Program

May 31, 2006

EE-2006-STD-0131 COMMENT 01.2
TABLE OF CONTENTS

1. INTRODUCTION .................................................................................................................. 1

1.1. The Appliances and Commercial Equipment Standards Program.................................. 2

1.2. Overview of Sub­categories of Lamps Covered............................................................. 3

1.2.1. Fluorescent Lamps.................................................................................................. 4

1.2.2. Incandescent Lamps................................................................................................ 6

1.3. Overview of the Rulemaking Process............................................................................. 8

1.3.1. Test Procedures....................................................................................................... 8

1.3.2. Rulemaking Process and Stakeholder Participation ............................................... 9

1.4. Advance Notice of Proposed Rulemaking.................................................................... 10

1.5. Notice of Proposed Rulemaking ................................................................................... 11

1.6. Final Rule...................................................................................................................... 12

2. ANALYSES FOR RULEMAKING..................................................................................... 12

3. MARKET AND TECHNOLOGY ASSESSMENT............................................................. 15

3.1. Market Assessment ....................................................................................................... 15

3.2. Product Classes............................................................................................................. 16

3.3. Technology Assessment................................................................................................ 19

3.4. Baseline Models............................................................................................................ 20

4. SCREENING ANALYSIS ................................................................................................... 24

5. ENGINEERING ANALYSIS............................................................................................... 25

5.1. Engineering Analysis Overview ................................................................................... 25

5.2. Engineering Analysis Approach ................................................................................... 26

5.3. Manufacturer Prices...................................................................................................... 27

5.4. Proprietary Designs....................................................................................................... 27

5.5. Outside Regulatory Changes Affecting the Engineering Analysis............................... 28

6. ENERGY USE AND END­USE LOAD CHARACTERIZATION .................................... 28

7. MARKUPS FOR EQUIPMENT PRICE DETERMINATION............................................ 29

8. LIFE­CYCLE COST AND PAYBACK PERIOD ANALYSIS .......................................... 30

8.1. Energy Prices................................................................................................................ 31

8.2. LCC Discount Rates ..................................................................................................... 31

8.3. Maintenance, Repair, and Installation Costs................................................................. 32

8.4. Lamp Lifetimes............................................................................................................. 32

9. SHIPMENTS ANALYSIS ................................................................................................... 33

9.1. Base­Case Forecast ....................................................................................................... 33

9.2. Accounting Methodology ............................................................................................. 34

9.3. Standards Impacts on Lamp Shipments........................................................................ 35

10. NATIONAL IMPACT ANALYSIS..................................................................................... 35

10.1. Inputs to Forecasts .................................................................................................... 35

10.2. Calculation of Energy Savings.................................................................................. 36

10.3. Net Present Value ..................................................................................................... 36

11. LIFE­CYCLE COST SUBGROUP ANALYSIS ................................................................. 37

12. MANUFACTURER IMPACT ANALYSIS......................................................................... 37

12.1. Sources of Information for the Manufacturer Impact Analysis................................ 38

12.2. Industry Cash Flow Analysis.................................................................................... 39

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EE-2006-STD-0131 COMMENT 01.2
12.3. Manufacturer Subgroup Analysis............................................................................. 39

12.4. Competitive Impacts Assessment ............................................................................. 39

12.5. Cumulative Regulatory Burden ................................................................................ 40

13. UTILITY IMPACT ANALYSIS.......................................................................................... 40

14. EMPLOYMENT IMPACT ANALYSIS.............................................................................. 41

15. ENVIRONMENTAL ASSESSMENT ................................................................................. 41

16. REGULATORY IMPACT ANALYSIS .............................................................................. 42

APPENDIX A – EPCA DIRECTIVES REGARDING FLUORESCENT AND

APPENDIX C – LAMP CATEGORIES IN EACH OF THE DEPARTMENT’S FOUR

INCANDESCENT LAMPS.......................................................................................................... 43

APPENDIX B ­ DEFINITIONS................................................................................................... 46

FLUORESCENT LAMP TYPES................................................................................................. 54

APPENDIX D – TEST PROCEDURE DETAILS....................................................................... 55

LIST OF TABLES

Table 1. EPCA Product Classes for General Service Fluorescent Lamps.................................... 16

Table 2. Proposed Product Class Modifications for General Service Fluorescent Lamps........... 17

Table 3. EPCA Product Classes for Incandescent Reflector Lamps ............................................ 18

Table 4. Proposed Representative Product Classes for General Service Fluorescent Lamps ...... 22

Table 5. Proposed Product Classes for Incandescent Reflector Lamps........................................ 23

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EE-2006-STD-0131 COMMENT 01.2
LIST OF ACRONYMS

AEO Annual Energy Outlook

ANOPR advance notice of proposed rulemaking

ANSI American National Standards Institute

ASHRAE American Society of Heating, Refrigerating and Air­Conditioning Engineers

BT Building Technologies Program

BR bulged reflector (type of reflector lamp)

CCT correlated color temperature

CFR Code of Federal Regulations

CFL compact fluorescent lamp

CIE International Commission on Illumination

CO2 carbon dioxide

CRI color rendering index

CSL candidate standard level

DOE U.S. Department of Energy

DOJ U.S. Department of Justice

EERE Office of Energy Efficiency and Renewable Energy

EIA Energy Information Administration

E.O. Executive Order

EPACT 1992 Energy Policy Act of 1992

EPACT 2005 Energy Policy Act of 2005

EPCA Energy Policy and Conservation Act

ER elliptical reflector (type of reflector lamp)

FR Federal Register

FTC Federal Trade Commission

GRIM Government Regulatory Impact Model

HID high intensity discharge lamp

IEC International Electrotechnical Commission

IESNA Illuminating Engineering Society of North America

ImSET Impact of Sector Energy Technologies

IR Infrared

LCC life­cycle cost

LPW lumens per watt

NECPA National Energy Conservation Policy Act of 1978

NEMA National Electrical Manufacturers Association

NEMS National Energy Modeling System

NES national energy savings

NOPR notice of proposed rulemaking

NOx nitrogen oxides

NPV net present value

OIRA Office of Information and Regulatory Affairs

OMB U.S. Office of Management and Budget

PAR parabolic aluminized reflector (type of reflector lamp)

R&D research and development

RIA regulatory impact analysis

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EE-2006-STD-0131 COMMENT 01.2
SG&A selling, general, and administrative costs

SO2 sulfur dioxide

T8, T10, T12 tubular fluorescent lamps, diameters of 1, 1.25 or 1.5 inches, respectively

TSD technical support document

TSL trial standard level

U.S.C. United States Code

W watts

WACC weighted­average cost of capital

iv

EE-2006-STD-0131 COMMENT 01.2
Rulemaking Framework Document for General Service Fluorescent Lamps,

Incandescent Reflector Lamps and General Service Incandescent Lamps

1. INTRODUCTION

The U.S. Department of Energy (the Department or DOE) Appliances and Commercial

Equipment Standards Program, of the Office of Energy Efficiency and Renewable Energy’s

(EERE’s) Building Technologies Program (BT), develops and promulgates test procedures and

energy conservation standards for consumer appliances and commercial equipment. The

Department is committed to expeditiously completing overdue or “backlog” rulemakings. A

DOE report submitted to Congress on January 31, 2006,1 identifies the rulemakings the

Department has scheduled for completion by June 2011 and explains many of the techniques the

Department will be applying to the rulemaking process in order to meet this schedule. The

Department will also continue to apply the procedures set forth in the Process Rule,2 to the extent

that they do not inhibit the completion of the rule by the scheduled dates.

The purpose of this document is to describe the procedural and analytical approaches the

Department anticipates using to evaluate energy conservation standards for general service

fluorescent lamps, incandescent reflector lamps and general service incandescent lamps. This

document is intended to inform stakeholders of the process that DOE will follow for the

standards rulemaking for these lamp types and to encourage and facilitate stakeholder input

during the rulemaking. This document is merely the starting point for developing standards and

is not a definitive statement with respect to any issue to be determined in the rulemaking.

Section 1 provides an overview of the rulemaking process. Sections 2 through 16 discuss

analyses DOE intends to conduct to fulfill the statutory requirements and guidance for this

standards rulemaking. Although DOE is bundling rulemaking activities for general service

fluorescent lamps, incandescent reflector lamps and general service incandescent lamps into a

single rulemaking, it will conduct separate analyses for each lamp type to determine whether

amended energy conservation standards are technologically feasible and economically justified.

In other words, for each of the lamp types examined in this rulemaking, the Department will

perform a separate set of analyses, including an engineering analysis, a life­cycle cost (LCC) and

payback period analysis, a national impact analysis, and a manufacturer impact analysis.

Information regarding this rulemaking will be maintained on the DOE website at:

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

1 On January 31, 2006, the Department submitted to Congress the Energy Conservation Standards Activities, which

was submitted pursuant to section 141 of the Energy Policy Act of 2005 (P.L. 109­58) and to the Conference Report

(109­275) to the Fiscal Year 2006, Energy and Water Development Appropriations Act. The report is available as a

PDF file on the DOE webpage at:

http://www.eere.energy.gov/buildings/appliance_standards/2006_schedule_setting.html. 2 Procedures for Consideration of New or Revised Energy Conservation Standards for Consumer Products (the

“Process Rule”), 61 FR 36974 (July 15, 1996); 10 CFR Part 430, Subpart C, Appendix A.

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EE-2006-STD-0131 COMMENT 01.2
While the Department invites stakeholder comment on all aspects of the material presented

in this document, several specific issues on which DOE seeks comment are set out in

comment boxes like this one. These comment boxes are used to highlight issues and ask

specific questions on the approaches the Department is proposing to follow to conduct the

analyses required for the standards rulemaking. These comment boxes are numbered

according to the section in which they appear.

1.1. The Appliances and Commercial Equipment Standards Program

The Energy Policy and Conservation Act (EPCA or the Act) of 1975 (42 U.S.C. 6291–

6309) established an energy conservation program for major household appliances. The

National Energy Conservation Policy Act of 1978 (NECPA) amended EPCA to add Part C of

Title III (42 U.S.C. 6311­6317), which established an energy conservation program for certain

industrial equipment. Additional amendments to EPCA have given DOE the authority to

regulate the energy efficiency of several products, including certain fluorescent and incandescent

lamps — the products that are the focus of this document. Amendments to EPCA in the Energy

Policy Act of 1992 (EPACT 1992), P.L. 102­486, established energy conservation standards for

residential, commercial and industrial general service fluorescent lamps and incandescent

reflector lamps, as well as requirements to conduct two cycles of rulemakings for determining

whether these standards should be amended.3 (42 U.S.C. 6295(i)(1) and (3)­(4)) In addition,

EPCA provides that within twenty­four months after Federal Trade Commission (FTC) labeling

requirements have become effective for general service fluorescent lamps and general service

incandescent lamps, DOE must initiate a rulemaking to determine if the standards in effect for

such lamps should be amended so that they would be applicable to additional general service

fluorescent and general service incandescent lamps. (42 U.S.C. 6295(i)(5)) Furthermore,

according to EPCA, DOE must publish a rule within eighteen months of initiating the

rulemaking. (42 U.S.C. 6295(i)(5)) The FTC published labeling requirements for covered lamps

on May 13, 1994, which had an effective date of May 15, 1995. 59 FR 25176. Previously, the

Department did not take action on the requirements of 42 U.S.C. 6295(i) because lamps were

assigned low priority based on public comment and potential energy savings estimates in the

priority setting process.4

Section 1.2 of this document provides detail on the distinction between fluorescent lamps

and general service fluorescent lamps, and between incandescent lamps, incandescent reflector

lamps and general service incandescent lamps. The following paragraphs discuss the statutory

requirements and actions that DOE is taking for each of the lamp types covered in this

rulemaking.

3 Although EPACT 1992 places regulatory authority, standards, and definitions for fluorescent and incandescent

lamps under the energy conservation program for consumer products (42 U.S.C. 6291–6309), these provisions also

apply to general service fluorescent and incandescent reflector lamps distributed for commercial use. (42 U.S.C.

6291(1))

4 See Appendix B to FY 2005 Preliminary Priority­Setting Summary Report on the DOE webpage at:

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

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EE-2006-STD-0131 COMMENT 01.2
EPCA establishes standards for general service fluorescent lamps, requiring that they meet

prescribed minimum efficacy levels per given color rendering index (CRI) levels,5 and further

requires that DOE conduct two cycles of rulemakings to determine if the standards should be

amended. (42 U.S.C. 6295(i)(1), (3)­(4)) In addition, the Act requires DOE to conduct a

rulemaking to determine if the standards in effect for fluorescent lamps should be amended so

that they would be applicable to additional general service fluorescent lamps. (42 U.S.C.

6295(i)(5)) In this rulemaking, DOE is conducting its first review to determine if the standards

should be amended, while fulfilling the additional statutory requirement that DOE determine if

the standards should be applicable to additional general service fluorescent lamps.

As with general service fluorescent lamps, EPCA also establishes energy conservation

standards for incandescent reflector lamps, requiring that certain lamps meet prescribed

efficacy levels, and directs DOE to conduct two cycles of rulemakings to determine if the

standards should be amended. (42 U.S.C. 6295(i)(1), (3)­(4)) In addition, the Act requires DOE

to conduct a rulemaking to determine if the standards for incandescent reflector lamps should be

amended so that they would be applicable to additional general service incandescent lamps.

(42 U.S.C. 6295(i)(5)) In this rulemaking, the Department is conducting its first review to

determine if the standards for incandescent reflector lamps should be amended. The Department

is also fulfilling the additional requirement that DOE determine whether the standards should

cover additional general service incandescent lamps, including additional incandescent reflector

lamps.

1.2. Overview of Sub­categories of Lamps Covered

This rulemaking covers certain types of fluorescent lamps and incandescent lamps.

Section 321(30) of EPCA (42 U.S.C. 6291(30)) contains definitions for “fluorescent lamps” and

“incandescent lamps” and the sub­categories of these lamps that are the subject of this

rulemaking. These sub­categories are as follows:

1. General service fluorescent lamps;

2. Incandescent reflector lamps; and

3. General service incandescent lamps (which include incandescent reflector lamps and nonreflector lamps).

In addition to the statutory definitions, the Department published definitions for terms

which supplement the statutory definitions for fluorescent and incandescent lamps.6 62 FR

29222 (May 29, 1997); 10 CFR section 430.2. These terms are listed and their definitions

5 The Act defines “lamp efficacy” as “the lumen output of a lamp divided by its wattage, expressed in lumens per

watt (LPW).” (42 U.S.C. 6291(30)(M)) It defines “color rendering index” (CRI) as “the measure of the degree of

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

when illuminated by a reference source of comparable color temperature.” (42 U.S.C. 6291(30)(J)) 6 These revised or additional terms include: “basic model,” ‘‘cold temperature fluorescent lamp,’’ ‘‘fluorescent

lamp,’’ and ‘‘incandescent lamp,’’ ‘‘BR incandescent reflector lamp,’’ ‘‘colored fluorescent lamp,’’ ‘‘colored

incandescent lamp,’’ ‘‘correlated color temperature,’’ ‘‘design voltage,’’ ‘‘ER incandescent reflector lamp,’’

‘‘incandescent reflector lamp,’’ ‘‘rated voltage,’’ ‘‘rated wattage,’’ ‘‘residential straight­shaped lamp,’’ ‘‘rough or

vibration service incandescent reflector lamp,’’ and ‘‘voltage range.’’

3

EE-2006-STD-0131 COMMENT 01.2
provided in Appendix B. The following sections describe in more detail the definitions for

fluorescent and incandescent lamps, as well as the three lamp types covered in this rulemaking.

1.2.1. Fluorescent Lamps

Section 321(30)(A) of EPCA (42 U.S.C. 6291(30)(A)) defines a fluorescent lamp as

a low pressure mercury electric­discharge source in which a fluorescing coating

transforms some of the ultraviolet energy generated by the mercury discharge into light, 

including only the following:

(i) Any straight­shaped lamp (commonly referred to as 4­foot medium bi­pin

lamps) with medium bi­pin bases of nominal overall length of 48 inches and

rated wattage of 28 or more.

(ii) Any U­shaped lamp (commonly referred to as 2­foot U­shaped lamps) with

medium bi­pin bases of nominal overall length between 22 and 25 inches and

rated wattage of 28 or more.

(iii) Any rapid start lamp (commonly referred to as 8­foot high output lamps) with

recessed double contact bases of nominal overall length of 96 inches and 0.800

nominal amperes, as defined in ANSI C78.1­1978 and related supplements.

(iv) Any instant start lamp (commonly referred to as 8­foot slimline lamps) with

single pin bases of nominal overall length of 96 inches and rated wattage of 52

or more, as defined in ANSI C78.3­1978 (R1984) and related supplement ANSI

C78.3a­1985.

The Act’s definition of fluorescent lamps establishes the Department’s scope of authority

in this rulemaking. Given the above definition for fluorescent lamps, the Department will not be

analyzing other types of lamps that might otherwise generally be considered fluorescent lamps.

For example, the Department will not be evaluating circline lamps, T5 lamps, or any other lamps

that fall outside the definition specified in the Act. In other words, for the purposes of defining

DOE’s regulatory authority over fluorescent lamps, Congress gave DOE authority only over a

subset of fluorescent lamps.

In the category of 8­foot lamps, the Department updated the EPCA definition for

fluorescent lamps in a final rule published May 29, 1997. 62 FR 29222. In that rulemaking,

DOE updated the two American National Standards Institute (ANSI) documents cited in the

statutory definition to ANSI C78.1­1991 and C78.3­1991.7 In this rulemaking, the Department is

inclined to limit the coverage of 8­foot linear recessed double contact lamps to 95W and 113W

T12 lamps since these are the only lamps contained in ANSI C78.1­1991 that are rated at “0.800

nominal amperes.” This amperage is an element of the above­quoted EPCA definition for a

ANSI C78.3­1978 is an ANSI­published guide to standard characteristics for instant­start and cold­cathode

fluorescent lamps. C78.1­1978 is the equivalent guide for rapid­start fluorescent lamps. Supplements to C78.3­

1978 and C78.1­1978 update the guides over time. In 1991, ANSI combined the original standards with their

supplements into C78.3­1991 and C78.1­1991, respectively. In 1997, DOE incorporated definitions for fluorescent

lamps into the Code of Federal Regulations (CFR). 62 FR 29238. DOE used the statutory definition, but replaced

‘ANSI C78.1­1978 and related supplements’ with ‘ANSI C78.1­1991’; and replaced ‘ANSI C78.3­1978 (R1984)

and related supplement C78.3a­1985’ with ‘C78.3­1991’.

4

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EE-2006-STD-0131 COMMENT 01.2
“fluorescent lamp.” (42 U.S.C. 6291(30)(A)(iii)) See Appendix C for an illustration of the lamp

categories in each of the four types of fluorescent lamps established by the Act.

1.2.1.1. General Service Fluorescent Lamps

Section 321(30)(B) of EPCA (42 U.S.C. 6291(30)(B)) defines general service fluorescent

lamps as

fluorescent lamps which can be used to satisfy the majority of fluorescent applications, 

but does not include any lamp designed and marketed for the following non­general

lighting applications:

(i) Fluorescent lamps designed to promote plant growth.

(ii) Fluorescent lamps specifically designed for cold temperature installations.

(iii) Colored fluorescent lamps.

(iv) Impact­resistant fluorescent lamps.

(v) Reflectorized or aperture lamps.

(vi) Fluorescent lamps designed for use in reprographic equipment.

(vii) Lamps primarily designed to produce radiation in the ultra­violet region of the

spectrum.

(viii) Lamps with a color rendering index of 82 or greater.

This statutory definition further narrows those fluorescent lamps that DOE has authority

to regulate. This definition is also important to this rulemaking because of the aforementioned

EPCA requirement that DOE conduct a rulemaking to determine if the standards in effect for

fluorescent lamps should be amended so that they would be applicable to additional general

service fluorescent lamps. (42 U.S.C. 6295(i)(5)) EPCA set standards for general service

fluorescent lamps according to those categories it uses for defining fluorescent lamps: (i) 4­foot

linear medium bi­pin; (ii) 2­foot U­shaped medium bi­pin; (iii) 8­foot linear recessed double

contact and (iv) 8­foot linear single pin. (42 U.S.C. 6295(i)(1)(A))

While this rulemaking is intended to comply with 42 U.S.C. 6295(i)(5), the Department

is not aware of any additional general service fluorescent lamps which meet the EPCA definition

and are not already regulated. Therefore, the Department does not have grounds for amending

the standards for general service fluorescent lamps to include additional general service

fluorescent lamps per 42 U.S.C. 6295(i)(5).8

Item 1 The Department welcomes comment on the scope of this rulemaking, under

the statutory requirement to consider additional general service fluorescent lamps. (42

U.S.C. 6295(i)(5))

The Department will still review and consider amending the existing standards for general service fluorescent

lamps required by 42 U.S.C. 6295(i)(3).

5

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EE-2006-STD-0131 COMMENT 01.2
1.2.2. Incandescent Lamps

Section 321(30)(C) of EPCA (42 U.S.C. 6291(30)(C)) defines an incandescent lamp as

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

current, including only the following:

(i) Any lamp (commonly referred to as lower wattage nonreflector general service

lamps, including any tungsten­halogen lamp) that has a rated wattage between

30 and 199 watts, has an E26 medium screw base, has a rated voltage or

voltage range that lies at least partially within 115 and 130 volts, and is not a

reflector lamp.

(ii) Any lamp (commonly referred to as a reflector lamp) which is not colored or

designed for rough or vibration service applications, that contains an inner

reflective coating on the outer bulb to direct the light, an R, PAR, or similar

bulb shapes (excluding ER [Elliptical Reflector] or BR [Bulged Reflector]) with

E26 medium screw bases, a rated voltage or voltage range that lies at least

partially within 115 and 130 volts, a diameter which exceeds 2.75 inches, and is

either ­­

(I) a low(er) wattage reflector lamp which has a rated wattage between

40 and 205 watts; or

(II) a high(er) wattage reflector lamp which has a rated wattage above

205 watts.

(iii) Any general service incandescent lamp (commonly referred to as a high­ or

higher­wattage lamp) that has a rated wattage above 199 watts (above 205

watts for a high wattage reflector lamp).

Concerning E26 medium screw bases, the Department intends to use the definition of

“medium screw base” as added to EPCA in section 135(a)(3) of the Energy Policy Act of 2005

(EPACT 2005), Public Law 109­58. (42 U.S.C. 6291(51)) This defines an Edison screw base

with the prefix E26 as that appearing in the “American National Standard for Electric Lamp

Bases,” ANSI/IEC C81.61–2003, published by the American National Standards Institute. This

version of C81.61 identifies four lamp base (cap) types with a prefix of E26, which are: singlecontact medium screw (E26/24); double­contact medium screw (E26d); skirted medium screw

for PAR lamps (E26/50x39); and extended skirted medium screw for R­lamps (E26/53x39). In

other words, for the purposes of defining DOE’s regulatory authority over incandescent lamps,

Congress gave DOE authority only over a subset of incandescent lamps.

1.2.2.1. Incandescent Reflector Lamps

EPCA defines an incandescent reflector lamp in subparagraph (C)(ii) of the definition for

incandescent lamps. (42 U.S.C. 6291(30)(C)(ii) and (30)(F)) In bullet form, the definition is:

Any incandescent lamp which:

• Is not colored or designed for rough or vibration service applications;

• Contains an inner reflective coating on the outer bulb to direct the light;

• Is an R, PAR or similar bulb shape (excluding ER or BR) with an E26

medium screw base;

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EE-2006-STD-0131 COMMENT 01.2
• Has a rated voltage or voltage range that lies at least partially in the range of

115 and 130 volts;

• Has a diameter that exceeds 2.75 inches; and

• Is either (I) a low(er)­wattage reflector lamp that has a rated wattage between

40 and 205; or (II) a high(er)­wattage reflector lamp that has a rated wattage

above 205.

This statutory definition of an incandescent reflector lamp specifically excludes ER and

BR lamps. (See Appendix B for the DOE definitions of ER and BR lamps). For this reason, the

Department will not consider ER and BR lamps in its review and possible amendment of the

reflector lamp energy conservation standards. However, the Department is aware that shipments

of these lamp shapes have increased significantly over the last decade. Therefore, the

Department will consider how the exemption for ER and BR lamps affects the national energy

savings analysis of the efficacy requirements for incandescent reflector lamps.

Item 2 The Department welcomes comment on how a more stringent standard for

incandescent reflector lamps might impact the market share of ER and BR lamps.

1.2.2.2. General Service Incandescent Lamps

Section 321(30)(D) of EPCA (42 U.S.C. 6291(30)(D)) defines a general service

incandescent lamp as

any incandescent lamp (other than a miniature or photographic lamp) that has an E26

medium screw base, a rated voltage range at least partially within 115 and 130 volts, and

which can be used to satisfy the majority of lighting applications, but does not include

any lamps specifically designed for ­­

(i) traffic signal, or street lighting service;

(ii) airway, airport, aircraft, or other aviation service;

(iii) marine or marine signal service;

(iv) photo, projection, sound reproduction, or film viewer service;

(v) stage, studio, or television service;

(vi) mill, saw mill, or other industrial process service;

(vii) mine service;

(viii) headlight, locomotive, street railway, or other transportation service;

(ix) heating service;

(x) code beacon, marine signal, lighthouse, reprographic, or other

communication service;

(xi) medical or dental service;

(xii) microscope, map, microfilm, or other specialized equipment service;

(xiii) swimming pool or other underwater service;

(xiv) decorative or showcase service;

(xv) producing colored light;

(xvi) shatter resistance which has an external protective coating; or

(xvii) appliance service.

7

EE-2006-STD-0131 COMMENT 01.2
Under EPCA, the term “general service incandescent lamp” applies both to certain

“incandescent reflector lamps” and to other non­reflector general service incandescent lamps. In

common parlance, however, incandescent reflector lamps are generally not understood to be

general service incandescent lamps. In considering whether to amend the EPCA standards to

make them applicable to additional general service incandescent lamps (per 42 U.S.C.

6295(i)(5)), the Department will evaluate lamps that: 1) meet the EPCA definitions for general

service incandescent lamps and incandescent reflector lamps, and 2) are not already regulated by

the incandescent reflector lamp standards.9 In addition, the Department will also consider nonreflector incandescent lamps that meet the EPCA definition for general service incandescent

lamps. In considering whether to amend existing standards for incandescent reflector lamps (per

42 U.S.C. 6295(i)(3)), the Department will evaluate lamps that meet the EPCA definition of

incandescent reflector lamps.

The majority of terms within the statutory definition for general service incandescent

lamps remain undefined. For example, neither EPCA nor the DOE regulations define the term

“decorative or showcase service.” From the Department’s initial assessment of available

products, it appears that several models of incandescent lamps in manufacturer catalogues within

the range of 40 to 100 watts could be classified as decorative. Given that the definitions

determine coverage of standards, the Department intends to develop and provide clarification on

the definition for general service incandescent lamps, where needed.

Item 3 The Department welcomes comment on the issue of product coverage, 

specifically the requirement to consider additional general service incandescent lamps.

(42 U.S.C. 6295(i)(5))

Item 4 The Department welcomes comment on which, if any, of the exemption

categories in the statutory definition for general service incandescent lamps require

clarification.

1.3. Overview of the Rulemaking Process

1.3.1. Test Procedures

The Department established test procedures for fluorescent and incandescent lamps on

May 29, 1997. 62 FR 29222. The test procedures incorporate by reference ANSI, Illuminating

Engineering Society of North America (IESNA) and International Commission on Illumination

(CIE) industry standards to measure lamp efficacy and CRI. Each CFR reference to an industry

standard applies to a particular year of publication. Appendix D presents a list of the industry

standards that are related to lamps covered under this rulemaking and that the Department

incorporated by reference in 10 CFR section 430.22.

This set of lamps includes high­wattage incandescent reflector lamps that are general service incandescent lamps.

The EPCA definition for incandescent reflector lamps distinguishes low­wattage (40 to 205 watts) from highwattage (above 205 watts) reflector lamps. (42 U.S.C. 6291(30)(C)(ii) and (30)(F)) The ECPA standards for

incandescent reflector lamps apply to the low­wattage incandescent reflector lamps. (42 U.S.C. 6295(i)(1))

8

9

EE-2006-STD-0131 COMMENT 01.2
The test procedures provide detailed measurement instructions for measuring the

performance of all lamps covered by this rulemaking: general service fluorescent lamps,

incandescent reflector lamps and general service incandescent lamps. The Department does not

intend to update the test procedures for these lamps as part of this rulemaking.

1.3.2. Rulemaking Process and Stakeholder Participation

When DOE evaluates new or amended standards for “covered products” under EPCA, it

must consider seven factors, to the greatest extent practicable. These seven statutory factors are:

(1) The economic impact of the standard on the manufacturers and consumers of the affected

product(s);

(2) The savings in operating costs throughout the estimated average life of the product(s)

compared to any increases in the initial cost, or maintenance expense;

(3) The total projected amount of energy savings likely to result directly from the imposition

of the standard;

(4) Any lessening of the utility or the performance of the product(s) likely to result from the

imposition of the standard;

(5) The impact of any lessening of competition, as determined in writing by the Attorney

General, that is likely to result from the imposition of the standard;

(6) The need for national energy conservation; and

(7) Other factors the Secretary considers relevant.

(42 U.S.C. 6295(o)(2)(B)(i)) Additional statutory requirements for prescribing new or amended

standards are set forth in 42 U.S.C. 6295(o)(1)­(2)(A), (2)(B)(ii)­(iii), and (3)­(4).

The process for developing standards involves analysis, public notice, and consultation

with interested parties. Such parties, collectively referred to as stakeholders, include

manufacturers, consumers, energy conservation and environmental advocates, State and Federal

agencies, and any other groups or individuals with an interest in energy conservation standards

and test procedures. The Department considers stakeholder participation to be a very important

part of the rulemaking process. The Department actively encourages the participation and

interaction of all stakeholders during the comment period of each rulemaking stage. The broad

array of stakeholders who provide comments promotes a balanced discussion of critical

information required to conduct the standards rulemaking, beginning with the public comment

on the Framework Document and during subsequent comment periods.

In conducting the test procedure rulemakings and the energy conservation standards

rulemakings, DOE involves stakeholders through a variety of means, including formal public

notifications (i.e., Federal Register notices). The standards rulemaking process involves three

formal, major public notices, which are published in the Federal Register. The first of the

rulemaking notices is an advance notice of proposed rulemaking (ANOPR, see section 1.4). The

ANOPR is designed to publicly vet the models and tools to be used in the rulemaking, and to

facilitate public participation before the proposed­rule stage. The second notice is a notice of

proposed rulemaking (NOPR, see section 1.4), which presents: a discussion of comments

received in response to the ANOPR; the analysis of the impacts of standards on consumers,

9

EE-2006-STD-0131 COMMENT 01.2
manufacturers and the nation; the Department’s weighting of the impacts; and the proposed

standards. The third notice is the final rule (see section 1.5), which presents: a discussion of

comments received in response to the NOPR; the revised analysis of the impacts of standards;

the Department’s weighting of the impacts; the standards adopted by DOE; and the effective

dates of the standards.

1.4. Advance Notice of Proposed Rulemaking

As part of its initial rulemaking activity, the Department typically identifies product

design options or efficiency levels that it will analyze in detail and those it should eliminate from

further consideration. This process includes a market and technology assessment (see section 3)

and a screening analysis (see section 4). These activities include consultations with stakeholders

and independent technical experts who can assist with identifying the key issues and design

options to be considered by the Department in the rulemaking. This Framework Document, the

public meeting and the opportunity for comment on this Framework Document are all intended

to initiate dialogue with stakeholders, and provide an opportunity for comment and input into the

structure and analytical approach proposed for this energy conservation standards rulemaking.

At the ANOPR stage, in addition to the market and technology assessment and screening

analysis, the other principal analyses the Department will be presenting include: the engineering

analysis (see section 5); the consumer LCC impact and payback period results (see section 8);

the national energy savings (NES) and consumer net present value (NPV) results (see section

10); and a preliminary manufacturer impact analysis (see section 12). In addition, in the ANOPR

Federal Register notice, the Department will publish the Secretary’s determination whether to

amend current standards to make them applicable to additional general service fluorescent and

general service incandescent lamps.10 (42 U.S.C. 6295(i)(5))

The ANOPR analysis will include candidate standard levels (efficiency levels) to

facilitate the stakeholder review of the spreadsheet models that underpin the analyses presented.

Stakeholder comments on the models will be used to refine them for the next stage of the

rulemaking analyses, where the Department will propose efficiency levels for comment. In the

ANOPR, the Department’s range of candidate standard levels for analysis will include the

maximum improvement in energy efficiency that is technologically feasible (“max tech”) and the

efficiency corresponding to the minimum LCC point. DOE generally selects efficiency levels or

design options for consideration that span the full range of technologically achievable

efficiencies.

Relative to a baseline model (see section 3.4 which discusses baseline models), the range

of levels analyzed typically includes:

• The highest energy efficiency level or lowest energy consumption level that is

technologically feasible (the “max tech” level);

As noted above, the Department is not aware of any additional general service fluorescent lamps which meet the

EPCA definition and are not already regulated. Therefore, the Department does not intend to amend the standards

for general service fluorescent lamps to include additional general service fluorescent lamps per 42 U.S.C.

6295(i)(5)

10

10

EE-2006-STD-0131 COMMENT 01.2
• The level with the lowest LCC; and

• Levels that incorporate noteworthy technologies or fill in large gaps between efficiency

levels of other levels considered.

The Department will make the spreadsheet tools and results from the ANOPR analyses

available on its website for review and will consider comments on them after the publication of

the ANOPR. When the Department publishes the ANOPR, the Department will also make

available a technical support document (TSD) containing the details of all the analyses

performed to date. Following publication of the ANOPR, the Department provides a 75­day

public comment period and holds one public meeting. At this point the Department encourages

stakeholders to develop joint recommendations for standard levels.

1.5. Notice of Proposed Rulemaking

For the NOPR, the Department starts by carefully reviewing and considering all the

comments received after the publication of the ANOPR. This process may result in revisions or

refinements to the ANOPR analyses, including the engineering analysis and life­cycle cost

analysis. DOE also conducts additional economic impact analyses. These analyses generally

include a consumer LCC sub­group analysis (see section 11), a complete manufacturer impact

analysis (see section 12), a utility impact analysis (see section 13), an employment impact

analysis (see section 14), an environmental assessment (see section 15), and a regulatory impact

analysis (see section 16).

The NOPR analytical process ends with the selection of proposed standard levels that

will be published in the NOPR. The Department selects these proposed standard levels from the

trial standard levels (TSLs) analyzed during the NOPR phase of the rulemaking. The NOPR

Federal Register notice will document the evaluation and selection of the proposed standard

level(s) (if any). The proposed standard levels would apply to both lamps covered under existing

standards as well as any additional lamps that the Secretary determined to regulate at the

ANOPR stage.

For each product class, the Department will identify the max tech efficiency level. If the

Department proposes a level lower than that, it will sequentially explain the reasons for

eliminating higher levels beginning with the highest level considered. The Department will

present the analysis results in the NOPR and the analysis details in an accompanying TSD.

The Department considers many factors in selecting proposed standards, as described

above in section 1.3.2. These factors and criteria are contained in the EPCA and take into

consideration the benefits, costs, and impacts of energy conservation standards. In addition, the

Department encourages stakeholders to develop joint recommendations for standard levels. The

Department will carefully consider such recommendations in its decision process.

When the Department publishes the NOPR, it will provide the Department of Justice

(DOJ) with a copy of the NOPR and TSD and will solicit feedback on the impact of the proposed

standard level on competition. DOJ will review these standard levels in light of any lessening of

competition that is likely to result from the imposition of standards. The Department will

consider the DOJ determination on the impacts of the proposed standard on competition in

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EE-2006-STD-0131 COMMENT 01.2
preparing the final rule. The NOPR is followed by a 75­day public comment period that includes

one public meeting.

1.6. Final Rule

DOE may revise its analyses after considering public comments on the NOPR. On the

basis of the public comments, DOE will review the engineering and economic impact analyses

and proposed standards and consider modifications where necessary.

After the publication of the NOPR, the Department will conduct a thorough review of all

analyses performed, and of the TSLs. Final revisions to the analyses and trial standard levels

will be made as appropriate.

Before the final rule is issued, the Department will consider DOJ comments on the NOPR

relating to the impacts of the proposed standard levels on competition to determine whether

changes to these standard levels are needed.

The standards rulemaking will conclude with the publication of the final rule. The

Department will select the final standard levels based on the complete record of the standards

rulemaking. The final rule will promulgate the final standard levels and their effective date and

explain the basis for their selection. The final rule will be accompanied by a final TSD.

2. ANALYSES FOR RULEMAKING

Ultimately, the Department intends to select energy conservation standards that achieve

the maximum improvement in energy efficiency that is technologically feasible, economically

justified, and will result in significant energy savings. The selection of such standards is

expected to achieve the maximum energy savings that are economically justified without putting

an unjust financial burden on any particular party. Economic justification includes the

consideration of economic impacts on domestic manufacturers and consumers, national benefits

including environmental impacts, issues of consumer utility, and impacts from any lessening of

competition. The purpose of the analyses conducted in support of the standards rulemaking is to

ensure that the final standards are technologically feasible, economically justified, and will result

in significant energy savings.

This section offers an overview of the DOE analytical methodology and discusses the

major components of the analyses DOE will conduct. A consistent approach to analysis

throughout the rulemaking will be ensured through the consideration of each analysis as a part of

the overall standards­setting framework.

Figure 1 summarizes the analytical components of the standards­setting process. The

analyses are presented in the center column. Each analysis has a set of key inputs, which are

data and information required for the analysis. “Approaches” are the methods that will be used

to obtain key inputs. For example, some key inputs exist in public databases, some will be

collected from stakeholders or experts with special knowledge, and some will be developed by

the project team in support of the rulemaking. The results of each analysis are key outputs,

12

EE-2006-STD-0131 COMMENT 01.2
which feed directly into the rulemaking. Dotted lines indicate the flow of information between

the various analyses.

13

EE-2006-STD-0131 COMMENT 01.2
Utility Impact

Analysis

Notice of Proposed Rulemaking (NOPR)

Final Rule

Approaches Key Inputs Analyses Key Outputs

Market and Technology

Assessment

Screening Analysis

Engineering Analysis

Markups for

Product Price

Determination Life­Cycle Cost and

Payback Period

Analysis

National Impact

Analysis

Energy and

Water Use

Revise ANOPR

Analyses

Life­Cycle Cost

Sub­Group Analysis

Manufacturer Impact

Analysis

Shipments

Analysis

Employment Impact

Analysis

Revise Analyses

• Product Classes

• Technology Options

• Industry Cash Flow

• Sub­Group Cash­Flow

• Direct Employment Impacts

• Competitive Impacts

• Cumulative Regulatory Burden

• Cost­Efficiency Relationship

• Life­Cycle Costs

• Payback Periods

• National Energy Savings

• Net Present Values

• National Employment Impacts

• Revised Results

• Characterize Industry

• Market Segmentation

• Non­Regulatory Programs

Framework Document

• Efficiency­Level Approach

• Design Option Approach

• Energy and Water Prices

• Installation Costs

• Maintenance & Repair Costs

• Accounting Approach

• Backcast and Forecast

• Market Saturation

• Stakeholder Comments

• Demographics

• Manufacturer Interviews

• GRIM Analysis

• Emission Rates

• National Energy Savings

• Stakeholder Comments

• Identify Firms/Products

• Historical Shipments

• Define Distribution Channels

• Economic Census Data

Analysis

• Retail Price Collection and

Analysis

• Manufacturer Prices

• Average Costs

• Manufacturer Financial Data

Design Options

Product Classes

Retail Prices

Design Energy/Water Use

Advance Notice of Proposed Rulemaking (ANOPR)

• Efficiency/Performance

• Manufacturing Cost

Candidate

Standard

Levels

• Analysis of Energy and

Water Use Data

Environmental

Assessment

Regulatory Impact

Analysis

Technology Options

• Emission Estimates

• Utility Load Factors

• National Energy Savings

• Non­Regulatory

Alternatives

• NEMS­BT

• IMBUILD

• NEMS­BT

• Design Options

• Energy Price Forecasts

• Site­to­Source Factors

• Energy­Efficiency Levels

Direct Employment

Impacts

• National Energy Savings

• National Product Costs

• National Operating Costs

• Utility Impacts

• Analysis of Market Data

• Analysis of Product Data

• Life­Cycle Costs

• Payback Periods

• Installation

Costs

• Maint Costs

• Repair Costs

• UEC & UWC

• Energy &

Water Prices

• Annual Energy Use (UEC)

• Annual Water Use (UWC)

Preliminary

Manufacturer Impact

Analysis

• Manufacturer Prices

• Average Costs

• Conversion Capital Expenditures

• Direct Employment Impacts

• National Energy Savings

• Net Present Values

• Trial Standard Levels (TSLs)

TSLs

• Product Prototypes

Energy­Efficiency

Levels

• Department of Justice Review

Figure 1. Flow Diagram of Analyses for the General Service Fluorescent Lamps,

Incandescent Reflector Lamps and General Service Incandescent Lamps Energy

Conservation Standard Rulemaking Process

14

EE-2006-STD-0131 COMMENT 01.2
3. MARKET AND TECHNOLOGY ASSESSMENT

The market and technology assessment will provide information about the manufacturers

of general service fluorescent lamps, incandescent reflector lamps and general service

incandescent lamps, and specifics about the performance attributes of these lamps. This

assessment is used throughout the rulemaking. However, it is particularly important at the outset

for developing product classes, and identifying technology design options to improve efficacy

(i.e., efficiency) for each of the lamp types.

3.1. Market Assessment

The Department will qualitatively and quantitatively characterize the structure of the

markets for general service fluorescent lamps, incandescent reflector lamps and general service

incandescent lamps. In the market assessment, the Department will characterize the

manufacturers, estimate market shares and trends, and address regulatory and non­regulatory

initiatives intended to improve the efficacy or reduce the energy consumption of covered lamps.

This market assessment will establish the context for this rulemaking, and serve as a

resource to guide the analyses that will follow. For example, the Department may use historical

shipments and prices as an indicator of future shipments and prices. Similarly, DOE will use

market structure data for the manufacturer impact analysis.

The Department recognizes that there is limited public information on national lamp

shipments, manufacturing costs, channels of distribution and manufacturers’ market shares. This

type of data would be extremely valuable for conducting analyses to determine if energy

conservation standards are economically justified and will result in significant energy savings.

Therefore, the Department encourages stakeholders to submit any available, applicable data to

the Department that pertains to these areas of interest and would assist the Department in gaining

a better understanding of the market and manufacturers of these lamp types.

Item 5 The Department welcomes information on shipments, manufacturing costs, 

distribution channels and estimates of market shares for the lamps considered in this

rulemaking. In order for the data to be used to conduct energy savings calculations, a

degree of disaggregation (e.g., by product class and wattage) is desirable.

The Department is creating a database of commonly available products based on the most

recent manufacturer catalogues from lamp manufacturers (e.g., GE Lighting, Osram/Sylvania,

Philips Lighting and others), as well as some of the smaller market participants. This model

database enables the Department to understand what is available in the market and compare

available products to statutory definitions. Subsequent knowledge about product availability will

be used to evaluate how the market may respond to various standard levels (e.g., consumers

substituting lamps that are not subject to regulation), as well as performance attributes of the

various commercially available lamp technologies (e.g., halogen).

15

EE-2006-STD-0131 COMMENT 01.2
3.2. Product Classes

The Department divides covered products into classes by: (a) the type of energy used;

and (b) capacity of the product or any other performance­related feature that justifies different

standard levels, such as features affecting consumer utility. (42 U.S.C. 6295(q)) For this

rulemaking on lamps, the Department intends to analyze general service fluorescent lamps,

incandescent reflector lamps and general service incandescent lamps separately, where

appropriate.

For general service fluorescent lamps, the Act contains eight product classes (42 U.S.C.

6295(i)(1)(A)), shown below in Table 1.

Table 1. EPCA Product Classes for General Service Fluorescent Lamps

Lamp Type Nominal Lamp Wattage

4­foot medium bi­pin > 35 W

≤ 35 W

2­foot U­shaped > 35 W

≤ 35 W

8­foot slimline > 65 W

≤ 65 W

8­foot high output > 100 W

≤ 100 W

The Department recognizes that following the establishment of these eight product

classes in EPACT 1992, the fluorescent lamp market has diversified and several new fluorescent

lamp diameters have gained market share.11 In particular, T8 lamps are much more prevalent

today than the T12 lamps which dominated when Congress passed EPACT 1992. In recognition

of this trend toward smaller diameter fluorescent lamps for certain lamp types, ANSI

promulgated industry standards for T8 and T10 lamps, some of which are covered products

under the Department’s definition of a fluorescent lamp (see Appendix C). The Department’s

review of manufacturer catalogues confirmed that 4­foot medium bi­pin and the 2­foot U­shape

both have covered products available in multiple diameters.

The Department recognizes that lamps with different diameters most often require

ballasts specifically designed to operate those lamps. Therefore, T8, T10 and T12 lamps are not

interchangeable with each other. While there are some ballasts on the market that can operate a

T8, T10 and T12 lamp, the majority of those sold operate just one of these lamps. In other

words, a T8 lamp cannot be retrofitted into a T12 socket without changing the ballast because of

the operational requirements of the T8 lamp. The need to retrofit a ballast if changing to a

Fluorescent lamp diameters are defined in eighths of an inch and the letter “T” designates a tubular shape. Thus,

industry nomenclature would refer to“T8” lamps as tubular fluorescent lamps having a diameter of one inch.

Similarly, “T12” lamps are fluorescent lamps with a diameter of one and a half inches.

16

11

EE-2006-STD-0131 COMMENT 01.2
different lamp type (e.g., from T12 to T8), compels the Department to differentiate product

classes according to lamp diameter. The Department believes this is in accordance with EPCA

requirements for developing product classes where “performance­related features” justify

different standard levels, such as features affecting consumer utility. (42 U.S.C. 6295(q)) These

differentiating performance­related features necessitate that the Department subdivide product

classes for these products.

Therefore, the Department is proposing to modify the product classification structure for

general service fluorescent lamps to one that specifically takes into account the diversity in lamp

diameters for 4­foot medium bi­pin and 2­foot U­shaped fluorescent lamps. These modified

product classes will allow for separate consideration of appropriate standard levels of these

different products. Table 2 presents product classes broken down by wattage and by ranges of

lamp diameters: “≤T8” and “>T8.” As an alternative to these (or other) lamp diameter ranges,

the Department could establish product classes according to specific lamp diameters (e.g., T8,

T10 and T12). Under this approach, the Department would also ensure that fluorescent lamp

energy conservation standards would be applicable to any other fluorescent lamp diameters that

may become available in the future. The Department would associate this “other fluorescent

lamps” category with one of the specific lamp diameters.

12 Table 2. Proposed Product Class Modifications for General Service Fluorescent Lamps

Lamp

Type

Lamp

Diameter

Nominal Lamp

Wattage

Minimum

CRI

Product

Class #

>T8 > 35 W 69 1

≤ 35 W 45 2

> 35 W 69 3

4­foot medium

bi­pin

≤T8

≤ 35 W 45 4

>T8 > 35 W 69 5

≤ 35 W 45 6

> 35 W 69 7

2­foot U­shaped

≤T8

≤ 35 W 45 8

8­foot slimline T12 > 65 W 69 9

≤ 65 W 45 10

8­foot high > 100 W 69 11

output

T12

≤ 100 W 45 12

While new lamp diameters such as T8 have also been introduced into the 8­foot slimline

and 8­foot high output lamp type classifications, these lamp types are not listed in ANSI C78.3­

1991 and C78.1­1991, respectively. As these ANSI standards are an element of the EPCA

definition for 8­foot fluorescent lamps, 8­foot T8 lamps are outside of the Department’s scope of

coverage (see definition of a general service fluorescent lamp, section 1.2.1).

To facilitate stakeholder comment on this proposal, the Department has labeled each of the product classes with a

number.

17

12

EE-2006-STD-0131 COMMENT 01.2
Finally, relating to fluorescent lamps, the Department is currently considering whether

any amendment is warranted to the minimum CRI levels for the proposed fluorescent lamp

product classes.

For incandescent reflector lamps, EPCA establishes six product classes shown below in

Table 3 (42 U.S.C. 6295(i)(1)(A)). The Department understands that while the scope of covered

products extends beyond the wattage range depicted in Table 3 – incandescent reflector lamps

with wattages exceeding 205 watts are a covered product (42 U.S.C. 6291(30)(C)(ii) and (F) and

6292(a)(14)) – this range of wattages still represents the bulk of market shipments and, therefore,

energy savings potential. The Department is considering using these product classes, or perhaps

modifying them slightly if the Department determines that the wattages common today might be

better classified in different wattage ranges. The Department is also considering whether spot

reflector lamps should be classified separately from flood reflector lamps, as they provide a

different utility and this characteristic of light beam spread is a performance­related feature that

may impact the efficacy of the lamp.

13 Table 3. EPCA Product Classes for Incandescent Reflector Lamps

Nominal Lamp Wattage Product Class #

40­50 watts 13

51­66 watts 14

67­85 watts 15

86­115 watts 16

116­155 watts 17

156­205 watts 18

For additional general service incandescent lamps (including high­wattage

incandescent reflector lamps and non­reflector lamps), the Act does not prescribe standards or

establish product classes. As part of the standards rulemaking analysis outlined in this

document, the Department will evaluate whether to develop standards for additional general

service incandescent lamps.

Should the Secretary determine to consider high­wattage incandescent reflector lamps for

energy conservation standards, the Department would need to establish product classes for these

lamps. To this end, the Department will consider establishing product classes for high­wattage

incandescent reflector lamps according to wattage to be consistent with existing (low­wattage)

incandescent reflector lamp standards. The Department’s initial review of manufacturer

catalogues indicates that lamps which meet both the general service incandescent lamp definition

and the incandescent reflector lamp definition extend up to 300 watts.

To facilitate stakeholder comment on this proposal, the Department has labeled each of the product classes with a

number.

18

13

EE-2006-STD-0131 COMMENT 01.2
For non­reflector general service incandescent lamps, the Department will evaluate

whether capacities or performance­related features warrant creation of product classes. Some of

the capacities and features being considered include: type of lamp coating, wattage bins (i.e.,

similar to the wattage bins as used for incandescent reflector lamps), lamp design voltage and

lumen output. In addition, the Department is considering creating a separate product class for 3­

way lamps, which function differently than conventional general service incandescent lamps and

which require unique sockets in order to operate with multiple settings.

Item 6 The Department welcomes comment on the modified product classes it is

considering for general service fluorescent lamps. This includes whether specific lamp

diameters or lamp diameter ranges would be more appropriate.

Item 7 The Department welcomes comment on the product classes it is considering

for incandescent reflector lamps. This includes whether the wattage ranges need to be

refined and whether spot and flood reflector lamps should be treated separately.

Item 8 The Department welcomes comment on what, if any, product classes the

Department should consider for additional general service incandescent lamps. This

includes, for non­reflector lamps, whether the classes should be based on lamp coatings, 

wattage ranges, lamp design voltages and/or lumen ranges, and whether 3­way lamps

should be treated as a separate product class. For high­wattage incandescent reflector

lamps, the Department welcomes comment on any appropriate product class(es).

3.3. Technology Assessment

The technology assessment centers on understanding how energy is used by the product

or equipment, and what changes are possible that would reduce that energy consumption. The

measures that improve the energy efficiency of the equipment are called “design options,” and

are often based on existing technology options, as well as prototype designs and concepts. In

consultation with stakeholders, the Department will develop a list of design options that can and

should be considered in this rulemaking. Initially, this list will include all those technologies

considered to be technologically feasible and will serve to establish the max tech design. In the

screening analysis, the Department will eliminate from consideration any design options that fail

to meet one of the four screening criteria, as discussed in section 4 of this document.

The Department is collecting information on design options that could be employed to

improve the efficacy of general service fluorescent lamps and general service incandescent

lamps, including incandescent reflector lamps. The Department will review manufacturer

catalogues, recent trade publications and technical journals, as well as consult with technical

experts. Presently, the Department is aware of a limited set of design options that could improve

the efficacy of these lamps. These design options are listed below.

The Department intends to evaluate the following design options for general service

fluorescent lamps:

19

EE-2006-STD-0131 COMMENT 01.2
• Electrode materials and coatings

• Lamp fill gas composition

• Phosphor materials (halophosphor versus triphosphor)

The Department is aware that some attempts to improve fluorescent lamp efficacy may also

modify lamp performance or other lamp characteristics. For example, electrode improvements to

increase efficacy may also affect the operating life of the lamp.

The Department intends to evaluate the following design options for incandescent

reflector lamps:

• Higher temperature incandescent light sources

• Filament materials and coatings

• Reflector materials and coatings

• Lamp­fill gas

Incandescent reflector lamp design options involving gas­fill improvements include

halogen, krypton and xenon lamps. Design options involving reflector coatings include infrared

(IR) reflective coatings. Higher temperature incandescent light sources could trade off higher

efficacy for lower­rated lamp life, a factor the Department will consider.

The following technologies and design options are relevant to other general service

incandescent lamps:

• Higher temperature incandescent light sources

• Filament materials and coatings

• Lamp­fill gas

General service incandescent lamps that make use of the gas­fill improvements include

halogen, krypton and xenon lamps. Again, higher temperature incandescent light sources could

trade off higher efficacy for lower rated lamp life, which the Department will consider.

Item 9 The Department welcomes comment on the preliminary design options

identified in this section for each of the three lamp types. More specifically, the

Department welcomes comment on whether there are other technologies or design

features that it should consider and what, if any, impacts they might have on safety, 

performance, and consumer utility.

3.4. Baseline Models

Once the Department establishes product classes, it will select baseline models as

reference points against which the Department can measure changes resulting from energy

conservation standards. The baseline model represents the characteristics of equipment in a

given product class. Typically, the baseline model would be a model that just meets current

required energy conservation standards. If no existing standards apply to a product, as is the case

20

EE-2006-STD-0131 COMMENT 01.2
with general service incandescent lamps (other than incandescent reflector lamps), the

Department will select baseline models that are typical of what is sold in the market today. A

baseline model encompasses lamp features and performance characteristics such as lamp shape,

wattage, correlated color temperature, color rending index, operating life, et cetera. Below, the

Department proposes certain characteristics for baseline models. However, the Department is

not defining all the detailed characteristics about the proposed baseline models until it receives

comment from stakeholders and can conduct further analysis.

The baseline models are used to conduct the engineering analysis and the LCC and

payback­period analyses. To determine energy savings and changes in manufacturer selling

price, the Department will compare each of the more efficacious lamps (i.e., lamps that

incorporate the design options to improve efficacy) with the baseline model.

In section 3.2, the Department identified twelve product classes for fluorescent lamps, six

product classes for incandescent reflector lamps (which could become twelve if spot and flood

reflector lamps are treated separately), and asked for stakeholder comment on how it should

classify general service incandescent lamps. The Department believes that for certain lamp

types, it may be possible to extrapolate the analyses of one class to another (e.g., extrapolate

minimum efficacy from one wattage to other wattages, and from one diameter to other

diameters). Furthermore, the Department believes that it may be redundant to conduct an

engineering analysis (see section 5) and a LCC analysis (see section 8) on a baseline model for

each product class. Once the Department determines which product classes to select as

representative of other product classes, it will need to select a lamp as a baseline model. DOE

will study these baseline models in the engineering analysis and LCC analysis.

For general service fluorescent lamps, the Department selected six representative

product classes from the twelve proposed in section 3.2, as shown in Table 4. To facilitate

stakeholder comment on this proposal, the Department will refer to product classes by number as

shown in the table. The Department proposes to select product class numbers 2 and 4 as the

representative product classes for analysis for 4­foot medium bi­pin lamps because these two

product classes represent the majority of the 4­foot medium bi­pin lamp sales. In addition, this

selection represents two distinct lamp types that frequently operate on two different ballasts

because the operational requirements of the lamps are different. Similarly, the Department

proposes to select product class numbers 5 and 8 for the 2­foot U­shaped lamps, thereby

capturing any variability between lamp types that require different ballasts to operate. DOE

would scale the results from these two representative product classes to all the other medium bipin and U­shaped lamp type product classes. For 4­foot medium bi­pin lamps, the Department is

proposing to use a 34W T12 baseline model for product class 4 and a 32W T8 baseline model for

product class 2. For the 2­foot U­shaped lamps, the Department is proposing to use a 40W T12

baseline model for product class 5 and a 31W T8 baseline model for product class 8. In the

ANOPR, the Department will define the baseline models in much more detail by specifying

additional lamp features and performance characteristics (e.g., correlated color temperature,

color rending index, operating life). However, the Department will wait to define the detailed

characteristics about these baseline models until it receives comments from stakeholders and can

conduct further market and technology analysis on fluorescent lamps.

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EE-2006-STD-0131 COMMENT 01.2
For 8­foot slimline fluorescent lamps, the statutory definition specifies two categories of

lamps that the Department can cover: 60W T12 lamps and 75W T12 lamps (see “linear 96­inch

single­pin lamps” in Appendix C).14 The Department proposes to select product class number 10

as the representative product class for 8­foot slimline fluorescent lamps because this group of

lamps is more prevalent in the market. Within this representative product class, the Department

is proposing to select a 60W T12 baseline model for its analysis. The Department will define

this baseline model in more detail by specifying additional lamp features and performance

characteristics based on stakeholder comments and further market and technology analysis.

For 8­foot high output fluorescent lamps, ANSI C78.1­1991 specifies two categories of

lamps that fall within the Department’s scope: 95W T12 lamps and 113W T12 lamps (see

“linear, 96­inch recessed double­contact” in Appendix C). The Department proposes to select

product class number 12 as the representative product class for 8­foot high output fluorescent

lamps because this group is more prevalent in the market. Within this representative product

class, the Department is proposing to select a 95W T12 baseline model for its analysis. As with

the lamps described above, the Department will define this baseline model in more detail by

specifying additional lamp features and performance characteristics based on stakeholder

comments and further market and technology analysis.

Table 4. Proposed Representative Product Classes for General Service Fluorescent Lamps

Lamp

Type

Lamp

Diameter

Nominal

Lamp

Wattage

Minimum

CRI

69

Product

Class #

1

Baseline Model /

Extrapolation

4­foot (scale from 34W/48T12/RS)

medium bipin

> T8 > 35 W

≤ 35 W 45 2 34W/48T12/RS

≤ T8 > 35 W 69 3 (scale from 32W/48T8/RS)

≤ 35 W 45 4 32W/48T8/RS

2­foot Ushaped

> T8 > 35 W 69 5 40W/23T12/U6/RS

≤ 35 W 45 6 (scale from 40W/23T12/U6/RS)

≤ T8 > 35 W 69 7 (scale from31W/23T8/U1/RS)

≤ 35 W 45 8 31W/23T8/U1/RS

8­foot

slimline

T12 > 65 W 69 9 (scale from 60W/96T12/SP)

≤ 65 W 45 10 60W/96T12/SP

8­foot high

output

T12 > 100 W 69 11 (scale from 95W/96T12/HO)

≤ 100 W 45 12 95W/96T12/HO

As discussed in section 3.2, EPCA establishes six product classes for incandescent

reflector lamps. Of these six product classes, the Department proposes to use product class

numbers 15 and 17 as the representative product classes for incandescent reflector lamps because

these two classes encompass high­volume wattage ratings and are well­bounded (i.e., not on

either extreme) within the range of wattages currently regulated (see Table 5). Furthermore, the

According to the ECPA definition, 8­foot slimline fluorescent lamps refer to those included in ANSI 78.3­1991.

22

14

EE-2006-STD-0131 COMMENT 01.2
Department is proposing to select parabolic aluminized reflector (PAR) lamps as the baseline

models for both of these product classes, as PAR lamps represent the majority of covered

incandescent reflector lamps available in the market. Within the two proposed representative

product classes, the Department proposes to select a 75W PAR lamp and a 150W PAR lamp as

the baseline models because these wattages are common in the market and they would

adequately represent the full range of covered lamp wattages. The Department will define the

baseline models in more detail once it has received comment on this proposal and completed its

market and technology assessment.

Table 5. Proposed Product Classes for Incandescent Reflector Lamps

Nominal Lamp

Wattage

Product

Class #

Baseline Model / Extrapolation

40­50 13 (scale from 75W)

51­66 14 (scale from 75W)

67­85 15 75W PAR

86­115 16 (interpolate between 75W and 150W)

116­155 17 150W PAR

156­205 18 (scale from 150W)

For additional general service incandescent lamps, neither EPCA nor DOE has

established product classes or any other classification structure since there are no energy

conservation standards. As discussed earlier, the Department is considering product classes for

non­reflector general service incandescent lamps based on wattage (consistent with incandescent

reflector lamps), lamp coatings, design voltages and/or lumen output. From information

published in late 2005, the Department understands that there are three A­line lamp wattages

sold today which dominate the general service incandescent lamp market: 60W, 75W and

100W.15 The Department will take this information into consideration, along with stakeholder

comments, when establishing product class(es) and selecting representative baseline model(s).

As with general service fluorescent lamps and incandescent reflector lamps, the Department will

examine if it is possible to extrapolate the analyses of one baseline model within a representative

product class to other (similar) product classes.

For high­wattage incandescent reflector lamps, the Department intends to establish

product classes based on wattage ratings for any additional lamps the Secretary determines to

consider for energy conservation standards. The Department intends to extrapolate its analysis

from incandescent reflector lamp representative product classes to these additional product

classes, where appropriate.

According to a 2004 National Electrical Manufacturers Association (NEMA) survey of its manufacturers, 60W,

75W and 100W lamps constitute over eighty percent of market sales for A­line lamps. Source: Pitsor, K. Letter to

Tim Tutt, John Wilson and Gary Flamm. December 14, 2005. Online at:

http://www.energy.ca.gov/appliances/2006rulemaking1/documents/2006­03­10_NEMA_ALINE_SURVEY_REPONSE_12­14­2005.PDF.

23

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EE-2006-STD-0131 COMMENT 01.2
Item 10 The Department welcomes comment on the representative product classes

proposed in section 3.4. Additionally, the Department welcomes comment on the scaling

of findings from the representative product classes to other product classes that are not

analyzed.

Item 11 The Department welcomes comment on the baseline models identified for each

of the representative product classes. This includes specific technological information

such as lamp size, wattage rating, CRI, CCT (correlated color temperature), operating

life, etc.

4. SCREENING ANALYSIS

The purpose of the screening analysis is to screen out technology design options that will

not be considered in the rulemaking for general service fluorescent lamps, incandescent reflector

lamps and additional general service incandescent lamps. DOE will screen out technology

design options according to four criteria, as noted below.

Through its own research and in consultation with interested parties, the Department will

develop a list of design options for consideration. Initially, the candidate design options or best

available technologies will encompass all those technologies that may be technologically

feasible. Following development of this initial list of design options, the Department will review

each design option or best available technology based on the following four criteria, as addressed

in sections 4(a)(4) and 5(b) of the Process Rule:

1. Technological feasibility. Design options that are not incorporated in commercially

available lamps or in working prototypes will not be considered further.

2. Practicability to manufacture, install, and service. If it is determined that mass

production of a design option or reliable installation and servicing of a design option

could not be achieved on the scale necessary to serve the relevant market by the time of

the effective date of the energy conservation standard, then that design option will not be

considered further.

3. Impacts on lamp utility to consumers. If a design option is determined to have significant

adverse impact on the utility of the lamp to significant subgroups of consumers, or result

in the unavailability of any covered lamp type with performance characteristics

(including reliability), features, size, capacities, and volumes that are substantially the

same as lamps generally available in the United States at the time, it will not be

considered further.

4. Safety of technologies. If it is determined that a design option will have significant

adverse impacts on health or safety, it will not be considered further.

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EE-2006-STD-0131 COMMENT 01.2
As discussed in the Technology Assessment section (see section 3.3), the Department

understands that for incandescent lamps, improvements in lamp efficacy are possible through

increasing the operating temperature of the filament, which can cause a reduction in operating

life. The Department may limit variation in incandescent lamp lifetime in order not to

significantly reduce lamp utility.

The reasons for eliminating any design options during the screening analysis will be fully

documented and published for stakeholder review and comment as part of the ANOPR.

Item 12 The Department welcomes comment on whether the Department’s analysis

should allow incandescent (both reflector and additional general service incandescent)

lamp life to vary in order to increase (or decrease) efficacy? If so, what would be a

reasonable amount of variance (i.e., not a ‘significant adverse impact’) for reflector

lamps and for general service incandescent lamps?

5. ENGINEERING ANALYSIS

After conducting the screening analysis, the Department performs an engineering

analysis based on the remaining design options that improve lamp efficacy. This section

provides an overview of the engineering analysis (section 5.1), discusses the Department’s

proposed approach (section 5.2), and addresses manufacturer prices (section 5.3), proprietary

designs (section 5.4), and regulatory burdens that might affect the engineering analysis

(section 5.5).

5.1. Engineering Analysis Overview

The purpose of the engineering analysis is to determine the relationship between the

manufacturer’s selling price and efficacy for general service fluorescent lamps and incandescent

reflector lamps. In addition, the Department will develop an engineering analysis for additional

general service incandescent lamps as part of its determination whether energy conservation

standards should be considered for these lamp types. In determining the price­efficacy

relationship, the Department will estimate the increase in the manufacturer selling price

associated with technological changes that increase the efficacy of the baseline models.

The Department will develop cost estimates for the engineering analysis (which it will

also use in the manufacturer impact analysis, see section 12) from detailed data on the cost of

incremental material, labor, and overhead. The Department will develop separate engineering

analyses for each of the baseline models identified in section 3.4. The Department intends to

develop industry­average, cost­efficacy relationships for these lamps based primarily on

manufacturer­supplied data. If needed, the Department may supplement this analysis with its

own cost estimates of specific design options.

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EE-2006-STD-0131 COMMENT 01.2
Therefore, the Department seeks design, efficacy, and cost information to develop a

detailed understanding of the cost of improving the efficacy of the various baseline model lamps.

In addition, the Department must identify the model with the highest efficacy that is

technologically feasible within each product class (i.e., the “max tech” model).

Item 13 For each product class, the Department welcomes information on design

options and incremental manufacturing costs for five lamp efficacy levels above the

baseline, one of which would be max tech. Detailed information on the lamp

performance (e.g., energy consumption, light output, operating life, etc.) and the

16 17 18 incremental manufacturing costs (e.g., material costs, labor costs, overhead costs

(excluding depreciation), building conversion capital expenditures, tooling/equipment

conversion capital expenditures, research and development (R&D) expenses, marketing

expenses, etc.) would be welcome.

5.2. Engineering Analysis Approach

For the engineering analysis, the Department will examine aggregated incremental

increases in the manufacturer production cost at specified efficiency levels (or efficacy levels in

the case of lamps). In support of this analysis, the Department intends to collect incremental cost

data from manufacturers. The cost data would represent the average incremental production cost

to improve the efficacy of a baseline model. The Department may supplement the manufacturerprovided cost data with its own cost estimates of particular design options. DOE would develop

design­option cost estimates via consultation with lighting experts and industry representatives

and/or further review of any available cost and performance information. The Department would

also use the cost data collected for the engineering analysis in the manufacturer impact analysis

(see section 12). If possible, the Department would then aggregate the cost numbers by

weighting each individual data point by company­level sales volumes for each product class.

To be useful in the manufacturer impact analysis, manufacturer cost information should

reflect the variability in baseline models, design strategies, and cost structures that exist among

manufacturers. If necessary, the Department will qualify any aggregated cost­efficacy data.

Information obtained through follow­up with manufacturers would assist this effort. These

16 Costs of raw materials including scrap that can be traced to final or end products. Direct material costs do not

include indirect material costs which are attributed to supplies that may be used in the production process but are not

assigned to final products (e.g., lubricating oil for production machinery).

17 The earnings of workers who assemble parts into a finished good or operate machines in the production process.

Direct labor includes the fringe benefits of direct laborers such as group health care, as well as overtime pay. Direct

labor does not include indirect labor which is defined as the earnings of employees who do not work directly in

assembling a product such as supervisors, janitors, stockroom personnel, inspectors, and forklift operators.

18 Factory overhead excluding depreciation. Factory overhead includes indirect labor, downtime, set­up costs,

indirect material, expendable tools, maintenance, property taxes, insurance on assets, and utility costs. Factory

overhead does not include selling, general, and administrative costs (SG&A); research and development (R&D);

interest; or profit (accounted for by the Department separately).

26

EE-2006-STD-0131 COMMENT 01.2
confidential interviews will provide a deeper understanding of the various combinations of

technologies used to increase lamp efficacy, and their associated manufacturing costs.

The Department will estimate the contribution of the depreciation of conversion capital

expenditures to the incremental overhead. During the interviews, the Department will gather

information about the capital expenditures needed to increase the efficacy of the baseline models

to various efficacy levels (i.e., conversion expenditures by efficacy). The Department will also

gather information about the depreciation method(s) used to expense the conversion

expenditures.

For the cost­efficacy curves, the Department intends to hold the lamp lumen output

constant at the level of the baseline model. Thus, as the lamps become more efficacious, they

will consume less electricity rather than produce more light. Holding lumen output constant

across the engineering analysis cost­efficacy curves is necessary to ensure that end­users are

supplied with an equivalent service under the base case and standards case scenarios.

The approach proposed above will enable the Department to characterize the costefficacy relationship for lamps across the entire efficacy range without relying solely on

simulation modeling. The Department will maintain the confidentiality of proprietary data,

while allowing the public to examine the cost and design assumptions that underlie the costefficacy estimates.

Item 14 The Department welcomes comment on the above­described approach to

determining the relationship between manufacturer selling price and lamp efficacy.

Item 15 The Department welcomes feedback on its proposal to normalize its

engineering analysis around the lumen output of each baseline lamp.

5.3. Manufacturer Prices

The Department plans to apply markups to convert manufacturer production costs to

manufacturer selling prices. The Department intends to estimate manufacturer markups from

publicly available financial information (e.g., Securities and Exchange Commission 10­K

reports).

Item 16 The Department welcomes comment on the markup approach proposed for

developing estimates of manufacturer selling prices.

5.4. Proprietary Designs

The Department will consider in its engineering and economic analyses all design options

that are commercially available or present in a working prototype, including proprietary designs.

The Department will consider a proprietary design in the subsequent analyses only if it is not a

27

EE-2006-STD-0131 COMMENT 01.2
unique path to a given lamp efficacy level. If the proprietary design is the only approach

available to achieve a given efficacy level, then DOE will reject the efficacy level (that can only

be achieved by a proprietary design) from further analysis. Furthermore, the Department is

sensitive to manufacturer concerns regarding proprietary designs and will make provisions to

maintain the confidentiality of any proprietary data submitted by manufacturers. This

information will provide input to the competitive impacts assessment and other economic

analyses.

Item 17 The Department welcomes comment on whether there are proprietary designs

that the Department should consider for any of the lamps under consideration by this

rulemaking, and if so, how the Department should acquire the cost data necessary for

evaluating these designs.

5.5. Outside Regulatory Changes Affecting the Engineering Analysis

In conducting an engineering analysis, the Department must consider the effects of

regulatory changes outside the Department’s statutory energy conservation standards rulemaking

process that can impact the manufacturers of the covered equipment. Some of these changes can

also affect the efficacy or energy consumption of the covered lamps. The Department will

attempt to identify all such outside engineering issues that could impact the engineering analysis.

The consideration of these issues is closely related to the cumulative regulatory burden

assessment that the Department will carry out as part of the manufacturer impact analysis.

Item 18 The Department welcomes comment on whether there are outside issues that

the Department should consider in its analysis of general service fluorescent lamps, 

incandescent reflector lamps and additional general service incandescent lamps.

6. ENERGY­USE AND END­USE LOAD CHARACTERIZATION

The purpose of the energy­use and end­use load characterization is to identify the way in

which products are used by consumers, and thereby determine the energy­savings potential of

energy­efficiency improvements. For the lamps in this rulemaking, this analysis will focus on

how end­users install and operate these lamps.

This analysis, which is an input to the LCC assessment and the national impact analysis,

is intended to capture and represent the typical energy consumption in the field. This usage

profile enables DOE to conduct a calculation to determine the LCC and the payback period of

more efficacious lamp technologies relative to the baseline lamp.

For incandescent lamps, the energy consumption is often simply the lamp wattage

multiplied by the number of operating hours in a given year. For general service fluorescent

28

EE-2006-STD-0131 COMMENT 01.2
lamps, the Department is aware that there are low­frequency and high­frequency ballasts in the

field, and that the same lamp type would have different performance characteristics depending

on the ballast used. Thus, in the energy­use and end­use load characterization that the

Department performs in this rulemaking, it will consider both types of ballasts.

The Department seeks to identify and obtain detailed data on the typical applications and

end­use profiles for the lamps considered in this rulemaking. If the range of energy use

determined for each lamp type is large enough, DOE will conduct a sensitivity analysis to

determine how high and low estimates of energy use might impact the economic feasibility of

any amended energy conservation standards.

Item 19 The Department welcomes recommendations on sources of data that would

provide end­use operating profiles for each of the lamp types covered under this

rulemaking.

Item 20 The Department welcomes comment on whether the end­use operating

profiles are different for each of the lamp types covered under this rulemaking, and if so,

how.

Item 21 The Department welcomes comment on other engineering issues that could

impact the engineering analysis.

7. MARKUPS FOR EQUIPMENT PRICE DETERMINATION

The Department uses manufacturer­to­consumer markups to convert the manufacturer

selling price estimates from the engineering analysis to consumer prices. It then uses these

markups in the LCC analysis, consumer payback period analysis, and national impact analysis.

Retail prices are needed for the baseline efficacy level and all other efficacy levels under

consideration. The Department will obtain these retail prices by applying manufacturer­toconsumer markups to manufacturer­selling­price estimates. To validate these markups, the

Department will attempt to collect data on existing prices in the market either by purchasing

large data sets or by downloading data from distributor internet sites.

Before it can develop markups, DOE must identify distribution channels (i.e., how a lamp

is distributed from the manufacturer to the consumer). Once it establishes proper distribution

channels for each of the lamp types, DOE will rely on economic census data from the U.S.

Census Bureau, as well as input from the lighting industry and subject matter experts to develop

an understanding of the markups applied as a lamp moves from the manufacturer to the

consumer. To the extent possible, the Department also will use collected retail price data to

determine overall manufacturer­to­consumer markups.

This analysis will generate retail prices based on the marked­up manufacturing prices

from the engineering analysis. Because the Department expects to generate a range of price

29

EE-2006-STD-0131 COMMENT 01.2
estimates, it plans to describe new retail prices within a range of uncertainty. If the range of

retail prices for each lamp type is large enough, the Department will conduct a sensitivity

analysis to determine how high and low estimates of retail price might impact the economic

feasibility of any potential amended energy conservation standard.

Item 22 The Department welcomes comment on the distribution chain for lamps, the

key stakeholders in those distribution chains, the typical markups applied by those

stakeholders, and the overall markup from manufacturer selling price to retail shelf.

8. LIFE­CYCLE COST AND PAYBACK PERIOD ANALYSIS

The effects of increased energy conservation standards on consumers include a change in

operating expense (usually decreased) and a change in purchase price (usually increased). In

carrying out rulemakings for other products, the Department has analyzed the net effect on

consumers by calculating the LCC and payback period analyses using the engineering

performance data (section 5), the energy­use and end­use load characterization data (section 6),

and the equipment retail prices (section 7). Inputs to the LCC calculation include the installed

cost to the consumer (purchase price plus installation cost), operating expenses (energy expenses,

and, if applicable, repair costs, and maintenance costs), the lifetime of the product or other

defined period of analysis, and a discount rate.

For the ANOPR, DOE will conduct the LCC analysis using typical values to reflect

conditions in the field for product retail price and life, energy costs, energy usage, and discount

rates. If the Department determines that there is significant variability in any of the above inputs,

it will conduct sensitivity analyses to determine how the LCC and payback period are impacted

by high and low estimates for each of the inputs. For any sensitivity analyses that it conducts,

the Department will account for correlations that may exist between inputs (e.g., energy usage

may be correlated to energy prices). The detailed impact calculation, which DOE will conduct

after the ANOPR, may include an assessment of impacts on subgroups of consumers, as

described in section 11.

Based on the results of the LCC analysis, DOE will select candidate standard levels

(CSLs) for the ANOPR analysis. The range of CSLs typically will include the lamp efficacy

level with the lowest LCC, the highest efficacy level that is technologically feasible, and other

levels DOE has not yet determined.

For the NOPR, the Department will carefully review all of the comments it received on

the ANOPR LCC analysis, make any necessary revisions to the analysis, and evaluate additional

parameters not included in the ANOPR analysis, if necessary.

For general service fluorescent lamps, incandescent reflector lamps and general service

incandescent lamps, DOE will need to determine input values for several variables. The

30

EE-2006-STD-0131 COMMENT 01.2
following sections discuss the methodologies DOE plans to use to develop: energy prices;

discount rates; maintenance, repair, and installation costs; and lamp lifetimes.

8.1. Energy Prices

For consumers of general service fluorescent lamps, incandescent reflector lamps and

additional general service incandescent lamps, the Department will review residential and

commercial energy price data from the Energy Information Administration (EIA) as a means for

establishing electricity prices. If the EIA data demonstrate a large variability in electricity prices,

DOE will conduct a sensitivity analysis to determine how high and low electricity price estimates

might impact the economic feasibility of any amended energy conservation standards. The

Department will use projections of national­average energy prices for residential, commercial

and industrial consumers to estimate future energy prices in its LCC analysis. The Department

will use EIA’s Annual Energy Outlook (AEO) as the principal source of projections for future

electricity prices.

Item 23 The Department welcomes input on the proposed methodology for estimating

current and future electricity prices.

8.2. LCC Discount Rates

The calculation of consumer LCC requires the use of an appropriate discount rate. For

residential consumers of general service fluorescent lamps, incandescent reflector lamps and

additional general service incandescent lamps, the Department plans to use the same approach

that it relied on to develop discount rates for residential furnaces and boilers—i.e., derive the

discount rates from estimates of the interest or “finance cost” to purchase residential products.

By applying the financial theory, the finance cost of raising funds to purchase residential

products can be interpreted as: (1) the financial cost of any debt incurred to purchase residential

products, principally interest charges on debt, or (2) the opportunity cost of any equity used to

purchase residential products, principally interest earnings on household equity. Household

equity is represented by holdings in assets such as stocks and bonds, as well as the return on

homeowner equity. The Department would obtain much of the data required to determine the

cost of debt and equity from the Federal Reserve Board’s triennial Survey of Consumer

Finances.

For commercial and industrial consumers of general service fluorescent lamps,

incandescent reflector lamps and additional general service incandescent lamps, the Department

plans to use the same approach it relied on for developing discount rates for commercial unitary

air conditioners and commercial consumers of distribution transformers. This approach involves

deriving the discount rates for commercial consumers by estimating the cost of capital of

companies that purchase commercial equipment. The cost of capital is commonly used to

estimate the present value of cash flows to be derived from a typical company project or

investment. Most companies use both debt and equity capital to fund investments, so the cost of

capital is the weighted­average cost of equity and debt financing. This corporate finance

approach is referred to as the weighted­average cost of capital (WACC). For instance, the set of

commercial or industrial companies purchasing lamps may differ from those who purchase large

31

EE-2006-STD-0131 COMMENT 01.2
unitary air conditioners or distribution transformers, which would result in different discount

rates being developed for this rulemaking.

The Department will publish the discount rates and associated documentation on the

derivation of these discount rates at the time of the ANOPR publication. Stakeholders will be

invited to comment specifically on the issue of consumer discount rates during the ANOPR

comment period.

Item 24 The Department welcomes input on the proposed approaches for estimating

discount rates for residential and commercial consumers of lamps covered under this

rulemaking.

8.3. Maintenance, Repair, and Installation Costs

Typically, the Department will take into consideration any expected changes to

maintenance, repair, and installation costs for the products covered in a rulemaking. Often, small

incremental changes in product efficiency would incur little or no change in repair and

maintenance costs over baseline products. For products with significant energy efficiency

improvements over the baseline, there may be increased repair and maintenance costs since those

products are more likely to incorporate technologies that are not widely available. For lamps, the

Department expects that maintenance and repair costs will be negligible, given that lamps

typically do not have replaceable parts. With regard to installation costs, the Department is

aware that there would be variability in the costs for commercial and industrial sector lamp

installations (both fluorescent and incandescent) depending on whether the re­lamping practices

are based on group re­lamping (i.e., changing all lamps in a section at the same time, before the

end of the average lamp lifetime) or spot re­lamping (i.e., changing only those lamps which have

failed). However, the Department does not believe that existing re­lamping practices would

necessarily change under an energy conservation standard. In addition, because the product

being considered under this rulemaking is a lamp, the Department is not intending to consider

ballast replacements in its analysis (i.e., the Department intends to only consider interchangeable

lamps as direct substitutes).

Item 25 The Department welcomes comment on whether and how to develop

maintenance, repair and installation costs for all three lamp types. In particular, will

policies of group re­lamping versus spot re­lamping impact the installation costs

differentially with standard levels?

8.4. Lamp Lifetimes

The Department will use information from catalogues, various literature sources and

input from manufacturers and other stakeholders to establish lamp lifetimes for use in the LCC

and subsequent analyses.

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EE-2006-STD-0131 COMMENT 01.2
For incandescent lamp technologies, as discussed in section 5, the Department recognizes

that one of the methods by which a lamp can be made more efficacious is by increasing the

operating temperature of the filament, which increases the evaporation rate of tungsten and

shortens the life of the lamp. Impacts such as these will be taken into account in the LCC

analysis through a clear understanding of the various lamp lifetimes relative to the baseline

model.

For commercial sector installations, as discussed in section 8.3, commercial entities may

employ policies of either group re­lamping or spot re­lamping. The apportionment of

commercial­sector floor­space to group and spot re­lamping is important, as it will impact the

practical lamp lifetime, meaning the period over which the LCC of a given lamp is captured.

Based on consideration of the comments received for the ANOPR, the Department will

make necessary changes to the analysis. These changes will be reflected in the documentation of

the NOPR.

Item 26 The Department welcomes comment on appropriate lamp lifetimes for the

three lamps types covered in this rulemaking. For the commercial and industrial sectors, 

should group re­lamping be taken into consideration, and if so, how should the

Department characterize its impact on lamp lifetimes?

9. SHIPMENTS ANALYSIS

Shipment forecasts are required in order to calculate the national impacts of standards on

energy, net present value (NPV), and future manufacturer cash flows. The Department plans to

develop shipments forecasts based on an analysis of key market drivers for the covered lamps.

9.1. Base­Case Forecast

To evaluate the various impacts of standards, the Department must develop a base­case

forecast against which to compare forecasts for higher efficiency levels. The base­case forecast

is designed to depict what will happen to energy consumption and energy costs over time if the

Department does not adopt new or amended energy conservation standards for the lamps covered

under this rulemaking. In determining the base­case forecast, the Department will consider

historical shipments, the mix of lamp efficacies sold under existing regulation (or, in the case of

general service incandescent lamps, absence of regulation), and how that mix might change over

time. For these purposes, the Department needs data on historical product shipments and the

market shares of the different efficiency levels offered in each product class.

The Department seeks data on historical lamp shipments for general service fluorescent

lamps, incandescent reflector lamps and general service incandescent lamps. The Department is

considering manufacturers and industry organizations as potential sources of such information.

Alternatively, to arrive at this information the Department is considering purchasing national

33

EE-2006-STD-0131 COMMENT 01.2
market reports, extrapolating from shipment data received by the California Energy Commission

in its State rulemaking on general service incandescent lamps, or extrapolating historical sales

data from the United States Bureau of Census. The United States Bureau of Census publishes

limited information on the quantity and dollar­value of product shipments. Census data for the

value of product shipments are available for years 1994­2004. Data for product shipment

quantities, for those companies with a shipment value of $100,000 or more, are available from

1997 to 2002. However, neither dataset disaggregates the lamps according to lamp type or

energy conservation standard product class. For fluorescent lamps, the Department may

calibrate its fluorescent lamp shipment estimates against shipment data for fluorescent lamp

ballasts, which specifies shipment quantities and values by ballast type; this data is available

from 2002 to 2005.

The Department hopes to collect shipment data within each product class, as well as

market share efficiency data (i.e., data on the distribution of product shipments by lamp

efficacy), if applicable, for each product class. The Department recognizes that this information

may be difficult to collect, and may, therefore, consider other methods to estimate the efficiency

distribution in the market. For instance, if market share efficiency data are not available, the

Department may develop, as a proxy, efficiency distributions based on available models and

information from subject matter experts.

9.2. Accounting Methodology

The Department proposes to determine annual shipments in the base case by accounting

for new building construction, lamp replacements due to failure and luminaire retrofits (i.e.,

major remodeling where the fixture is replaced). Each of these three impacts on the accounting

methodology is discussed below:

• New Construction – the new fixtures that are installed each year due to floor space

growth in a particular sector. The Department proposes to determine this by using the

NEMS growth projection for the residential and commercial sectors.

• Replacements – the lamps that have burned out. This calculation is based on a

comparison of the operating hours of the lighting technologies and the lamps

servicing an end­use application. To the extent that the Department uses a group relamping as opposed to spot re­lamping in the commercial sector lamp installations

(see section 8.3), the lamp replacement rate may increase.

• Retrofits – the lamps and fixtures replacing existing lamps and fixtures during

renovation or remodeling. This replacement generally occurs before a lamp has

burned out.

Item 27 The Department welcomes comment on the accounting methodology described

above for new construction, replacements and retrofits for each of the lamp types covered

in this rulemaking.

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EE-2006-STD-0131 COMMENT 01.2
9.3. Standards Impacts on Lamp Shipments

For each lamp type, the Department will develop a set of shipment forecasts for the

covered lamps for each set of standards analyzed. These standards­case forecasts will be used to

evaluate the impacts of standards on lamp shipments. Standards­case forecasts are derived using

the same data sets as base­case forecasts. However, because the standards­case forecasts take

into account the increase in purchase price and the decrease in operating costs caused by

standards, forecasted shipments typically deviate from the base case. The magnitude of the

difference between the standards­case and base­case shipment forecasts depend on the estimated

purchase­price­increase, as well as the operating­cost savings from the standard. In addition, for

lamps considered in this rulemaking, the Department will take into consideration substitute

lamps that may become more popular under various standards scenarios. In other words, if DOE

increased the standard for incandescent reflector lamps, there might be a migration away from

regulated lamps toward un­regulated substitutes such as ER, BR or other lamp shapes. Because

the purchase price tends to have a larger impact than operating cost on equipment purchase

decisions, standards­case forecasts typically do show an elasticity of demand, manifested as a

drop in shipments relative to the base case. For this rulemaking, changes in the elasticity of

demand will most likely result from the substitution of non­regulated technologies for regulated

technologies rather than from unused sockets.

Market­pull programs, such as consumer rebate programs that encourage the purchase of

more efficacious lamps and manufacturer tax credits that encourage the production of more

efficacious lamps, also affect standards­case forecasts. When such programs exist, the

Department considers their impact on the forecast of both standards­case and base­case

shipments.

Item 28 The Department welcomes comment on how any amended standard for

general service fluorescent lamps and incandescent reflector lamps, as well as a

standard on general service incandescent lamps, might impact lamp shipments. The

Department also invites input on market­pull programs that promote the adoption of

more­efficacious lamps.

10. NATIONAL IMPACT ANALYSIS

Section 8 discusses methods for estimating the LCC savings and payback period for

individual consumers. This section discusses the Department’s assessment of the aggregate

impacts at the national level. Measures of impact to be reported include the NPV of total

consumer LCC and national energy savings.

10.1. Inputs to Forecasts

Analyzing impacts of Federal energy conservation standards requires a comparison of

projected United States energy consumption with, and without, new or amended energy

conservation standards. The forecasts contain projections of unit energy consumption of new

35

EE-2006-STD-0131 COMMENT 01.2
lamps, annual equipment shipments, and the price of purchased equipment. The derivations of

the base­case shipments forecasts are discussed in section 9. Approaches to determine retail

prices for products are described in section 7, while approaches to determine unit energy

consumption are described in section 6.

10.2. Calculation of Energy Savings

The Department intends to calculate national energy consumption for each year

beginning with the expected effective date of the standards. It will calculate national electricity

consumption for the base case and each standard level analyzed. The Department plans to

perform this calculation through the use of a spreadsheet model that effectively multiplies annual

shipment forecasts by unit energy savings, thereby accounting for the stock of appliances

affected by standards.

In response to comments by stakeholders who asked for a simple, transparent model, the

Department developed NES spreadsheet models for its standards rulemakings starting in 1996.

The Department’s NES spreadsheet model will provide a credible, stand­alone forecast of

national energy savings and NPV for general service fluorescent lamps, incandescent reflector

lamps and additional general service incandescent lamps.

In other rulemakings, the Department prepared NES spreadsheet models to project energy

savings and to demonstrate how the growth in efficiency can be accounted for over time.19

Although these models are specific to each product, their general framework is applicable to the

lighting market, and, specifically, to the general service fluorescent lamps, incandescent reflector

lamps and additional general service incandescent lamps.

Item 29 The Department welcomes comment on the NES spreadsheet models used for

estimating national impacts of amended energy conservation standards.

10.3. Net Present Value

The Department calculates the national NPV of the energy conservation standards in

conjunction with the NES. It calculates annual energy expenditures from annual energy

consumption by incorporating forecasted energy prices, using the shipment and average energy

efficiency forecasts described in section 9. The Department calculates annual equipment

expenditures by multiplying the price per unit times the forecasted shipments. The difference

between a base­case and a standards­case scenario typically contributes to a national energy

savings off­set against increased expenditures on lamps. The difference each year between

energy bill savings and increased equipment expenditures is the net savings (if positive) or net

costs (if negative). The Department discounts these annual values to the present time and sums

them to give a net present value. According to U.S. Office of Management and Budget (OMB)

requirements, the Department will conduct two NPV calculations, one using a real discount rate

of three percent and the other using a real discount rate of seven percent (OMB, Circular A­4:

Several NES spreadsheet models from previous rulemakings, including fluorescent lamp ballasts, can be found on

the Department of Energy’s website at www.eere.energy.gov/buildings/appliance_standards/.

36

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EE-2006-STD-0131 COMMENT 01.2
Regulatory Analysis. 2003). Based on consideration of the comments received for the ANOPR,

the Department will make any necessary changes to the analysis and candidate standard levels

(CSLs).

11. LIFE­CYCLE COST SUBGROUP ANALYSIS

This section describes how DOE analyzes consumer impacts by dividing consumers into

subgroups and accounting for variations in key inputs to the LCC analysis. A consumer

subgroup comprises a subset of the population that is likely, for one reason or another, to be

impacted disproportionately by new or revised energy conservation standards. The purpose of a

subgroup analysis is to determine the extent of this disproportional impact. The Department will

work with stakeholders early in the rulemaking process to identify any subgroups for this

consideration. However, it will not analyze the consumer subgroups until the NOPR stage of the

analysis.

In comparing potential impacts on the different consumer subgroups, the Department will

evaluate variations in regional electricity prices, variations in usage profiles, and variations in

installation costs that might affect the NPV of an energy conservation standard to certain

consumer subgroups. To the extent possible, DOE may obtain estimates of the variability in

each input variable and consider this variability in its calculation of consumer impacts. It will

discuss with stakeholders the variability in each input variable and likely sources of information.

The Department intends to consider the impact of any new standards on consumer

subgroups.

Item 30 The Department welcomes comment on what, if any, consumer subgroups are

appropriate in considering standards for general service fluorescent lamps, incandescent

reflector lamps and additional general service incandescent lamps.

12. MANUFACTURER IMPACT ANALYSIS

Recently, the Department announced changes to the manufacturer impact analysis format

in a report issued to Congress on January 31, 2006 (as required by section 141 of EPACT 2005).

This report, entitled “Energy Conservation Standards Activities,” (Standards Activities) is

available on the DOE website at:

http://www.eere.energy.gov/buildings/appliance_standards/2006_schedule_setting.html.

Previously, DOE did not report any manufacturer impact analysis results during the

ANOPR phase; however, under this new format, DOE will collect, evaluate, and report

preliminary information and data in the ANOPR. (See Standards Activities, page 48) Such

preliminary information includes the anticipated conversion capital expenditures by efficiency

level and the corresponding, anticipated impacts on employment. The Department will invite

input on these issues during its ANOPR manufacturer interviews.

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The analysis of impacts on manufacturers is intended to provide the Department with an

assessment of the potential impacts of energy conservation standards on manufacturers of

general service fluorescent lamps, incandescent reflector lamps and additional general service

incandescent lamps. The Department intends to conduct a separate manufacturer impact analysis

for each of the lamp types covered under this rulemaking. In addition to financial impacts, a

wide range of quantitative and qualitative effects may occur following adoption of a standard

that may require changes to the manufacturing practices for these lamps. The Department will

identify these effects through interviews with manufacturers and other experts.

12.1. Sources of Information for the Manufacturer Impact Analysis

Many of the analyses described earlier provide important information that the

Department uses as inputs for the manufacturer impact analysis. Such information includes

financial parameters developed in the market assessment (section 3.1), manufacturing costs and

prices from the engineering analysis (sections 5.2 and 5.3), retail price forecasts (section 7), and

shipments forecasts (section 9). The Department supplements this information with information

gathered during manufacturer interviews. The interview process plays a key role in the

manufacturer impact analysis, since it provides an opportunity for interested parties to express

their views on important issues.

The Department will conduct detailed interviews with manufacturers to gain insight into

the range of potential impacts from standards. During the interviews, the Department will take

note of information on the possible impacts on manufacturing costs, equipment prices, sales,

direct employment, capital assets, and industry competitiveness. Both qualitative and

quantitative information are valuable. The Department will schedule interviews well in advance

to provide every opportunity for key individuals to be available.

The Department will ask interview participants to identify all confidential information

provided in writing or orally. It will consider the information gathered, as appropriate, in the

energy conservation standard decision­making process. The Department will also ask

participants to identify any information that they wish to have included in the public record, but

that they do not want to have associated with their interview. The Department will incorporate

this information into the public record, but will report it without attribution.

The Department will collate the interview results and prepare a summary of the major

issues and outcomes. This summary will become part of the technical support document for this

rulemaking.

Item 31 The Department welcomes comment on interviewing companies to assess

manufacturer impacts, and the procedures that the Department should follow when

scheduling interviews and requesting information.

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EE-2006-STD-0131 COMMENT 01.2
12.2. Industry Cash Flow Analysis

The industry cash flow analysis relies primarily on the Government Regulatory Impact

Model (GRIM). The Department uses the GRIM to analyze the financial impacts of more

stringent energy conservation standards on the industry that produces the products covered by

the standard.

The GRIM analysis uses a number of factors—annual expected revenues; manufacturer

costs such as costs of goods sold; selling, general, and administrative costs; taxes; and capital

expenditures (both ordinary capital expenditures and those related to standards)—to arrive at a

series of annual cash flows beginning from the announcement of the new standard and

continuing for several years after its implementation. The Department compares the results

against base­case projections that involve no new standards. The financial impact of new

standards is then the difference between the two sets of discounted annual cash flows. Other

performance metrics, such as return on invested capital, are also available from the GRIM.

The Department will gather this information from two primary sources: the analyses

conducted to this point, and interviews with manufacturers and other stakeholders. Information

gathered from previous analyses will include financial parameters, manufacturing costs, price

forecasts, and shipments forecasts. Interviews with manufacturers and other stakeholders will be

essential in supplementing this information.

12.3. Manufacturer Subgroup Analysis

It is possible that the use of average industry cost values will not adequately assess

differential impacts among subgroups of lamp manufacturers. The Department recognizes that

smaller manufacturers, niche players, and manufacturers exhibiting a cost structure that differs

largely from the industry average may be impacted differently by the imposition of standards.

Ideally, the Department would consider the impact on every firm individually. In highly

concentrated industries, this may be possible. In industries having numerous participants,

however, the Department will use the results of the market and technology assessment to group

manufacturers into subgroups, as appropriate.

Item 32 If appropriate, what are potential subgroups of lamp manufacturers that

should be considered in a manufacturer subgroup analysis?

12.4. Competitive Impacts Assessment

EPCA directs the Department to consider any lessening of competition that is likely to

result from an imposition of standards. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It further directs the

Attorney General to determine in writing the impacts, if any, of any lessening of competition.

(42 U.S.C. 6295(o)(2)(B)(ii)) The Department will make a determined effort to gather firmspecific financial information and impacts. The Department will then report the aggregated

impact of the standard on manufacturers. The competitive analysis will focus on assessing the

impacts to smaller, yet significant, manufacturers. DOE will provide the Attorney General with

a copy of the NOPR for consideration in his evaluation of the impact of standards on the

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EE-2006-STD-0131 COMMENT 01.2
lessening of competition. The Department will base the assessment on manufacturing cost data

and on information collected from interviews with manufacturers. The manufacturer interviews

will focus on gathering information that would help in assessing asymmetrical cost increases to

some manufacturers, increased proportion of fixed costs potentially increasing business risks,

and potential barriers to market entry (e.g., proprietary technologies).

12.5. Cumulative Regulatory Burden

The Department is aware that other regulations may apply to products covered under this

rulemaking, as well as to other equipment produced by the same manufacturers of products

covered under this rulemaking. Multiple regulations may result in a cumulative regulatory

burden on these manufacturers. The Department will seek to limit the overlapping effects on

manufacturers of DOE standards and other regulatory actions affecting the three types of covered

lamps and manufacturers of these lamps.

Regulations that could affect the industry impacted by this rulemaking include:

• New EPCA standards, prescribed in EPACT 2005, for medium­base compact

fluorescent lamps (CFL’s), mercury vapor lamp ballasts, torchiere fixtures and ceiling

fan light kits;

• Standards EPCA prescribes for fluorescent lamp ballasts, FTC labelling requirements,

and a determination on a standard for high intensity discharge (HID) lamps;

• Existing and/or proposed State standards for reflector lamps (i.e., ER and BR lamps),

general service incandescent lamps, enhanced spectrum incandescent lamps, metal

halide lamp fixtures, HID ballasts, and/or under­cabinet luminaires;

• State building energy codes lighting requirements (e.g. ASHRAE 90.1);

• Federal and State requirements regarding fluorescent and HID lamp disposal; and

• International standards, including Canada’s regulation of general service fluorescent

lamps, fluorescent lamp ballasts and incandescent reflector lamps.

Item 33 The Department welcomes comment on what other regulations or pending

regulations the Department should consider in its examination of cumulative regulatory

burden.

13. UTILITY IMPACT ANALYSIS

To perform the utility impact analysis, which will include an analysis of the electric

utility industry, the Department plans to use a variant of the EIA’s National Energy Modeling

System (NEMS), called NEMS­BT (BT is DOE’s Building Technologies Program). NEMS is a

large, multi­sectoral partial equilibrium model of the U.S. energy sector, used primarily for the

purpose of preparing the Annual Energy Outlook (AEO). NEMS­BT produces a widely

recognized reference case forecast for the United States through 2030 and is available in the

public domain. Outputs of the utility analysis can parallel results that appear in the latest AEO,

with some additions. Typical outputs include forecasts of sales, price, and avoided capacity.

The Department plans on conducting the utility impact analysis as a scenario departing from the

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EE-2006-STD-0131 COMMENT 01.2
latest AEO reference case. In other words, the energy savings impacts from amended energy

conservation standards will be modeled using NEMS­BT to generate forecasts that deviate from

the AEO reference case.20

Item 34 The Department welcomes input from stakeholders on its proposed use of

NEMS­BT to conduct the utility impact analysis.

14. EMPLOYMENT IMPACT ANALYSIS

The imposition of standards can impact employment both directly and indirectly. Direct

employment impacts are changes in the number of employees at the factories that produce the

covered lamp types, along with the affiliated distribution and service companies. The

Department will evaluate direct employment impacts in the manufacturer impact analysis, as

described in section 12. Indirect employment impacts may result from expenditures shifting

between goods (the substitution effect) and changes in income and overall expenditure levels

(the income effect) that occur due to the imposition of standards. The combined direct and

indirect employment impacts will be investigated in the employment impact analysis using the

Pacific Northwest National Laboratory’s ‘Impact of Sector Energy Technologies’ (ImSET)

model. ImSET was developed for the Department’s Office of Planning, Budget, and Analysis,

and estimates the employment and income effects of energy­saving technologies in buildings,

industry, and transportation. In comparison with simple economic multiplier approaches, ImSET

allows for more complete and automated analysis of the economic impacts of energy­efficiency

investments.

Item 35 The Department welcomes feedback on its proposed approach to assessing

national employment impacts, both direct and indirect.

15. ENVIRONMENTAL ASSESSMENT

The primary environmental effects of energy conservation standards for general service

fluorescent lamps and incandescent reflector lamps, and additional general service incandescent

lamps, are likely to be reduced emissions resulting from reduced electricity consumption. The

environmental impact analysis will track the impact of possible standards on three types of

energy­related emissions: carbon dioxide (CO2), oxides of nitrogen (NOx), and sulfur dioxide

(SO2). The Department intends to base these calculations on the NEMS­BT modeling work

proposed for the utility impact analysis. This approach has the advantage of examining the

marginal impact of standards for general service fluorescent lamps and incandescent reflector

Several NEMS­BT models from previous rulemakings can be found on the Department of Energy’s website at

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

41

20

EE-2006-STD-0131 COMMENT 01.2
lamps, and additional general service incandescent lamps, on the utility generation mix and the

subsequent environmental emissions.

Carbon emissions are tracked in NEMS­BT by a detailed module that produces robust

results because of its broad coverage of all sectors and inclusion of interactive effects. NEMSBT also includes a module for SO2­allowance trading and delivers a forecast of SO2­allowance

prices. It is important to note, however, that simulation of SO2 trading tends to imply that

physical emissions effects will be zero. However, there is an SO2 benefit from conservation in

the form of a lower emission permit price and, if big enough to be calculable by NEMS, this

value can be reported. NEMS­BT also has an algorithm for estimating NOx emissions from

power generation.

Item 36 The Department welcomes feedback on its proposed approach to assessing

national environmental impacts, both direct and indirect.

16. REGULATORY IMPACT ANALYSIS

Under the Process Rule, the Department is committed to exploring non­regulatory

alternatives to mandatory standards. In the NOPR stage, the Department will prepare a

regulatory impact analysis (RIA) pursuant to Executive Order (E.O.) 12866, “Regulatory

Planning and Review,” 58 FR 51735 (October 4, 1993), which is subject to review under the

Executive Order by the Office of Information and Regulatory Affairs (OIRA) at the Office of

Management and Budget. The regulatory impact analysis will address the potential for nonregulatory approaches to supplant or augment energy conservation standards to improve the

efficacy of general service fluorescent lamps and incandescent reflector lamps, and additional

general service incandescent lamps, on the market.

The Department recognizes that voluntary or other non­regulatory efforts by

manufacturers, utilities, and other interested parties can result in substantial efficacy

improvements. The Department intends to consider the likely effects of non­regulatory

initiatives on lamp energy use, consumer utility, and life­cycle costs. The Department will take

into account the actual impacts of any such initiatives to date, but also will consider information

presented regarding the impacts that any existing initiative might have in the future.

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EE-2006-STD-0131 COMMENT 01.2
APPENDIX A – EPCA DIRECTIVES REGARDING FLUORESCENT AND

INCANDESCENT LAMPS

This appendix provides a copy of the current requirements the Act sets forth for the

Department regarding fluorescent and incandescent lamps under 42 U.S.C. 6295(i).

(i) General service fluorescent lamps and incandescent reflector lamps

(1) (A) Each of the following general service fluorescent lamps and incandescent reflector

lamps manufactured after the effective date specified in the tables listed in this paragraph

shall meet or exceed the following lamp efficacy and CRI standards:

Fluorescent Lamps

Lamp Type Nominal Lamp Minimum Min Avg. Lamp Effective Date

Wattage CRI Efficacy (LPW) (Months)

4­foot medium > 35 W 69 75 36

bi­pin ≤ 35 W 45 75

2­foot U­ > 35 W 69 68 36

shaped ≤ 35 W 45 64

8­foot

slimline

> 65 W

≤ 65 W

69

45

80

80

18

8­foot high > 100 W 69 80 18

output ≤ 100 W 45 80

Incandescent Reflector Lamps

Nominal Lamp Min. Avg. Lamp Effective Date

Wattage Efficacy (LPW) (Months)

40­50 10.5 36

51­66 11.0 36

67­85 12.5 36

86­115 14.0 36

116­155 14.5 36

156­205 15.0 36

(B) For the purposes of the tables set forth in subparagraph (A), the term ``effective date''

means the last day of the month set forth in the table which follows October 24, 1992.

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EE-2006-STD-0131 COMMENT 01.2
(2) Notwithstanding section 6302(a)(5) of this title and section 6302(b) of this title, it shall not be

unlawful for a manufacturer to sell a lamp which is in compliance with the law at the time such

lamp was manufactured.

(3) Not less than 36 months after October 24, 1992, the Secretary shall initiate a rulemaking

procedure and shall publish a final rule not later than the end of the 54­month period beginning

on October 24, 1992, to determine if the standards established under paragraph (1) should be

amended. Such rule shall contain such amendment, if any, and provide that the amendment shall

apply to products manufactured on or after the 36­month period beginning on the date such final

rule is published.

(4) Not less than eight years after October 24, 1992, the Secretary shall initiate a rulemaking

procedure and shall publish a final rule not later than nine years and six months after October

24, 1992, to determine if the standards in effect for fluorescent lamps and incandescent lamps

should be amended. Such rule shall contain such amendment, if any, and provide that the

amendment shall apply to products manufactured on or after the 36­month period beginning on

the date such final rule is published.

(5) Not later than the end of the 24­month period beginning on the date labeling requirements

under section 6294(a)(2)(C) of this title become effective, the Secretary shall initiate a

rulemaking procedure to determine if the standards in effect for fluorescent lamps and

incandescent lamps should be amended so that they would be applicable to additional general

service fluorescent and general service incandescent lamps and shall publish, not later than 18

months after initiating such rulemaking, a final rule including such amended standards, if any.

Such rule shall provide that the amendment shall apply to products manufactured after a date

which is 36 months after the date such rule is published.

(6) (A) With respect to any lamp to which standards are applicable under this subsection or

any lamp specified in section 6317 of this title, the Secretary shall inform any Federal

entity proposing actions which would adversely impact the energy consumption or energy

efficiency of such lamp of the energy conservation consequences of such action. It shall

be the responsibility of such Federal entity to carefully consider the Secretary's

comments.

(B) Notwithstanding subsection (n)(1) of this section, the Secretary shall not be

prohibited from amending any standard, by rule, to permit increased energy use or to

decrease the minimum required energy efficiency of any lamp to which standards are

applicable under this subsection if such action is warranted as a result of other Federal

action (including restrictions on materials or processes) which would have the effect of

either increasing the energy use or decreasing the energy efficiency of such product.

(7) Not later than the date on which standards established pursuant to this subsection become

effective, or, with respect to high­intensity discharge lamps covered under section 6317 of this

title, the effective date of standards established pursuant to such section, each manufacturer of a

product to which such standards are applicable shall file with the Secretary a laboratory report

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EE-2006-STD-0131 COMMENT 01.2
certifying compliance with the applicable standard for each lamp type. Such report shall include

the lumen output and wattage consumption for each lamp type as an average of measurements

taken over the preceding 12­month period. With respect to lamp types which are not

manufactured during the 12­month period preceding the date such standards become effective, 

such report shall be filed with the Secretary not later than the date which is 12 months after the

date manufacturing is commenced and shall include the lumen output and wattage consumption

for each such lamp type as an average of measurements taken during such 12­month period.

45

EE-2006-STD-0131 COMMENT 01.2
APPENDIX B ­ DEFINITIONS

This appendix provides the CFR (10 CFR section 430.2) and USC (statutory) (42 U.S.C.

6291(30)) definitions for the lamp products covered under this rulemaking. These definitions do

not include fluorescent lamp definitions associated with fluorescent ballast standards.

Fluorescent Lamps

42 U.S.C. 6291(30)(A)

Except as provided in subparagraph (E), the term “fluorescent lamp” means a low

pressure mercury electric­discharge source in which a fluorescing coating transforms

some of the ultraviolet energy generated by the mercury discharge into light, including

only the following:

(i) Any straight­shaped lamp (commonly referred to as 4­foot medium bi­pin lamps)

with medium bi­pin bases of nominal overall length of 48 inches and rated

wattage of 28 or more.

(ii) Any U­shaped lamp (commonly referred to as 2­foot U­shaped lamps) with

medium bi­pin bases of nominal overall length between 22 and 25 inches and

rated wattage of 28 or more.

(iii)Any rapid start lamp (commonly referred to as 8­foot high output lamps) with

recessed double contact bases of nominal overall length of 96 inches and 0.800

nominal amperes, as defined in ANSI C78.1­1978 and related supplements.

(iv)Any instant start lamp (commonly referred to as 8­foot slimline lamps) with single

pin bases of nominal overall length of 96 inches and rated wattage of 52 or more, 

as defined in ANSI C78.3­1978 (R1984) and related supplement ANSI C78.3a1985.

10 CFR 430.2

Fluorescent lamp means a low pressure mercury electric­discharge source in which a

fluorescing coating transforms some of the ultraviolet energy generated by the mercury

discharge into light, including only the following:

(1) Any straight­shaped lamp (commonly referred to as 4­foot medium bi­pin lamps)

with medium bi­pin bases of nominal overall length of 48 inches and rated

wattage of 28 or more.

(2) Any U­shaped lamp (commonly referred to as 2­foot U­shaped lamps) with

medium bi­pin bases of nominal overall length between 22 and 25 inches and

rated wattage of 28 or more.

(3) Any rapid start lamp (commonly referred to as 8­foot high output lamps) with

recessed double contact bases of nominal overall length of 96 inches and 0.800

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

(4) Any instant start lamp (commonly referred to as 8­foot slimline lamps) with single

pin bases of nominal overall length of 96 inches and rated wattage of 52 or more, 

as defined in ANSI C78.3­1991.

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EE-2006-STD-0131 COMMENT 01.2
10 CFR 430.2

Residential straight­shaped lamp means a low pressure mercury electric­discharge

source in which a fluorescing coating transforms some of the ultraviolet energy

generated by the mercury discharge into light, including a straight­shaped fluorescent

lamp with medium bi­pin bases of nominal overall length of 48 inches and is either

designed exclusively for residential applications; or designed primarily and marketed

exclusively for residential applications.

(1) A lamp is designed exclusively for residential applications if it will not function

for more than 100 hours with a commercial high­power­factor ballast.

(2) A lamp is designed primarily and marketed exclusively for residential

applications if it:

(i) Is permanently and clearly marked as being for residential use only;

(ii) Has a life of 6,000 hours or less when used with a commercial highpower­factor ballast;

(iii)Is not labeled or represented as a replacement for a fluorescent lamp that

is a covered product; and

(iv)Is marketed and distributed in a manner designed to minimize use of the

lamp with commercial high­power­factor ballasts.

(3) A manufacturer may market and distribute a lamp in a manner designed to

minimize use of the lamp with commercial high­power­factor ballasts by:

(i) Packaging and labeling the lamp in a manner that clearly indicates the

lamp is for residential use only and includes appropriate instructions

concerning proper and improper use; if the lamp is included in a catalog

or price list that also includes commercial/industrial lamps, listing the

lamp in a separate residential section accompanied by notes about proper

use on the same page; and providing as part of any express warranty

accompanying the lamp that improper use voids such warranty; or

(ii) Using other comparably effective measures to minimize use with

commercial high­power­factor ballasts.

10 CFR 430.2

Rated wattage, with respect to 4­foot medium bi­pin T8, T10 or T12 lamps, means:

(1) If the lamp is listed in ANSI C78.1­1991, the nominal wattage of a lamp

determined by the lamp designation in Annex A.2 of ANSI C78.1­1991; or

(2) If the lamp is a residential straight­shaped lamp, the wattage a lamp consumes

when operated on a reference ballast for which the lamp is designed; or

(3) If the lamp is neither listed in ANSI C78.1­1991 nor a residential straight­shaped

lamp, the wattage a lamp consumes when using reference ballast characteristics

of 236 volts, 0.43 amps and 439 ohms for T10 or T12 lamps or reference ballast

characteristics of 300 volts, 0.265 amps and 910 ohms for T8 lamps.

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EE-2006-STD-0131 COMMENT 01.2
General Service Fluorescent Lamps

42 U.S.C. 6291(30)(B)

The term “general service fluorescent lamp” means fluorescent lamps which can be used

to satisfy the majority of fluorescent applications, but does not include any lamp designed

and marketed for the following non­general lighting applications:

(i) Fluorescent lamps designed to promote plant growth.

(ii) Fluorescent lamps specifically designed for cold temperature installations.

(iii) Colored fluorescent lamps.

(iv) Impact­resistant fluorescent lamps.

(v) Reflectorized or aperture lamps.

(vi) Fluorescent lamps designed for use in reprographic equipment.

(vii) Lamps primarily designed to produce radiation in the ultra­violet region of the

spectrum.

(viii) Lamps with a color rendering index of 82 or greater.

10 CFR 430.2

Basic model means all units of a given type of covered product (or class thereof)

manufactured by one manufacturer and—

* * * * *

(15) with respect to general service fluorescent lamps, means lamps that have

essentially identical light output and electrical characteristics – including lumens

per watt and color rendering index (CRI) – and that do not have any differing

physical or functional characteristics that affect energy consumption or efficacy.

10 CFR 430.2

Cold temperature fluorescent lamp means a fluorescent lamp specifically designed to

start at −20 [deg]F when used with a ballast conforming to the requirements of ANSI

Standard C78.1–1991, and is expressly designated as a cold temperature lamp both in

markings on the lamp and in marketing materials, including but not limited to catalogs, 

sales literature, and promotional material.

10 CFR 430.2

Colored fluorescent lamp means a fluorescent lamp designated and marketed as a

colored lamp, and with either of the following characteristics: a CRI less than 40, as

determined according to the method given in CIE Publication 13.2 (see 10 CFR 430.22), 

or a lamp correlated color temperature less than 2,500K or greater than 6,600K.

Incandescent Lamp

42 U.S.C. 6291(30)(C)

Except as provided in subparagraph (E), the term “incandescent lamp” means a lamp in

which light is produced by a filament heated to incandescence by an electric current, 

including only the following:

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(i) Any lamp (commonly referred to as lower wattage nonreflector general service

lamps, including any tungsten­halogen lamp) that has a rated wattage between 30

and 199 watts, has an E26 medium screw base, has a rated voltage or voltage

range that lies at least partially within 115 and 130 volts, and is not a reflector

lamp.

(ii) Any lamp (commonly referred to as a reflector lamp) which is not colored or

designed for rough or vibration service applications, that contains an inner

reflective coating on the outer bulb to direct the light, an R, PAR, or similar bulb

shapes (excluding ER or BR) with E26 medium screw bases, a rated voltage or

voltage range that lies at least partially within 115 and 130 volts, a diameter

which exceeds 2.75 inches, and is either–

(I) a low(er) wattage reflector lamp which has a rated wattage between

40 and 205 watts; or

(II) a high(er) wattage reflector lamp which has a rated wattage above

205 watts.

(iii)Any general service incandescent lamp (commonly referred to as a high­ or

higher­wattage lamp) that has a rated wattage above 199 watts (above 205 watts

for a high wattage reflector lamp).

10 CFR 430.2

Incandescent lamp means a lamp in which light is produced by a filament heated to

incandescence by an electric current, including only the following:

(1) Any lamp (commonly referred to as lower wattage non­reflector general

service lamps, including any tungsten halogen lamp) that has a rated wattage

between 30 and 199, has an E26 medium screw base, has a rated voltage or

voltage range that lies at least partially in the range of 115 and 130 volts, and

is not a reflector lamp.

(2) Any incandescent reflector lamp. [Emphasis added]

(3) Any general service incandescent lamp (commonly referred to as a high­or

higher­wattage lamp) that has a rated wattage above 199 (above 205 for a

high wattage reflector lamp).

42 U.S.C. 6291(30)(R)

The term “tungsten­halogen lamp” means a gas­filled tungsten filament incandescent

lamp containing a certain proportion of halogens in an inert gas.

42 U.S.C. 6291(51)21

The term “medium screw base” means an Edison screw base identified with the prefix E26 in the “American National Standard for Electric Lamp Bases”, ANSI–IEC C81.61­

2003, published by the American National Standards Institute.

10 CFR 430.2

Voltage range means a band of operating voltages as marked on an incandescent lamp, 

indicating that the lamp is designed to operate at any voltage within the band.

Section 135(a)(3) of EPACT 2005 (Public Law 109­58) adds 42 U.S.C. 6291(51).

49

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10 CFR 430.2

Rated voltage with respect to incandescent lamps means:

(1) The design voltage if the design voltage is 115V, 130V or between 115V and

130V:

(2) 115V if the design voltage is less than 115V and greater than or equal to 100V

and the lamp can operate at 115V; and

(3) 130V if the design voltage is greater than 130 V and less than or equal to 150 V

and the lamp can operate at 130V.

10 CFR 430.2

Design voltage with respect to an incandescent lamp means:

(1) The voltage marked as the intended operating voltage;

(2) The mid­point of the voltage range if the lamp is marked with a voltage range; or

(3) 120V if the lamp is not marked with a voltage or voltage range.

Incandescent Reflector Lamps

42 U.S.C. 6291(30)(F)

The term ``incandescent reflector lamp'' means a lamp described in subparagraph

(C)(ii).

Subparagraph (30)(C)(ii).

(ii) Any lamp (commonly referred to as a reflector lamp) which is not colored or

designed for rough or vibration service applications, that contains an inner

reflective coating on the outer bulb to direct the light, an R, PAR, or similar

bulb shapes (excluding ER or BR) with E26 medium screw bases, a rated

voltage or voltage range that lies at least partially within 115 and 130 volts, a

diameter which exceeds 2.75 inches, and is either–

(I) a low(er) wattage reflector lamp which has a rated wattage between

40 and 205 watts; or

(II) a high(er) wattage reflector lamp which has a rated wattage above

205 watts.

10 CFR 430.2

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

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

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

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

or similar bulb shape (excluding ER or BR) with an E26 medium screw base; has a rated

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

a diameter that exceeds 2.75 inches; and is either a low(er)­wattage reflector lamp that

has a rated wattage between 40 and 205; or a high(er)­wattage reflector lamp that has a

rated wattage above 205.

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10 CFR 430.2

Colored incandescent lamp means an incandescent lamp designated and marketed as a

colored lamp that has a CRI less than 50, as determined according to the method given in

CIE Publication 13.2 (see 10 CFR 430.22); has a correlated color temperature less than

2,500K or greater than 4,600K; has a lens containing 5 percent or more neodymium

oxide; or contains a filter to suppress yellow and green portions of the spectrum and is

specifically designed, designated and marketed as a plant light.

10 CFR 430.2

Rough or vibration service incandescent reflector lamp means a reflector lamp: in which

a C­11 (5 support), C­17 (8 support), or C­22 (16 support) filament is mounted (the

number of support excludes lead wires); in which the filament configuration is as shown

in Chapter 6 of the 1993 Illuminating Engineering Society of North America Lighting

Handbook, 8th Edition (see 10 CFR 430.22); and that is designated and marketed

specifically for rough or vibration service applications.

42 U.S.C. 6291(30)(I)

The term “bulb shape” means the shape of lamp, especially the glass bulb with

designations for bulb shapes found in ANSI C79.1­1980 (R1984).

10 CFR 430.2

BR incandescent reflector lamp means a reflector lamp that has a bulged section below

the bulb's major diameter and above its approximate base line as shown in Figure 1 (RB)

on page 7 of ANSI C79.1­1994. A BR30 lamp has a lamp wattage of 85 or less than 66

and a BR40 lamp has a lamp wattage of 120 or less.

10 CFR 430.2

ER incandescent reflector lamp means a reflector lamp with an elliptical section below

the bulb's major diameter and above its approximate baseline as shown in Figure 1 (RE)

on page 7 of ANSI C79.1­1994 (see 10 CFR 430.22) and a finished size and shape shown

in ANSI C78.21­1989 including the referenced reflective characteristics in part 7 of ANSI

C78.21­1989 (see 10 CFR 430.22).

10 CFR 430.2

Basic model means all units of a given type of covered product (or class thereof)

manufactured by one manufacturer and—

* * * * *

(16) With respect to incandescent reflector lamps, means lamps that have essentially

identical light output and electrical characteristics – including lumens per watt –

and that do not have any differing physical or functional characteristics that affect

energy consumption or efficacy.

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General Service Incandescent Lamps

42 U.S.C. 6291(30)(D)

The term “general service incandescent lamp” means any incandescent lamp (other than

a miniature or photographic lamp) that has an E26 medium screw base, a rated voltage

range at least partially within 115 and 130 volts, and which can be used to satisfy the

majority of lighting applications, but does not include any lamps specifically designed

for­­

(i) traffic signal, or street lighting service;

(ii) airway, airport, aircraft, or other aviation service;

(iii) marine or marine signal service;

(iv) photo, projection, sound reproduction, or film viewer service;

(v) stage, studio, or television service;

(vi) mill, saw mill, or other industrial process service;

(vii) mine service;

(viii) headlight, locomotive, street railway, or other transportation service;

(ix) heating service;

(x) code beacon, marine signal, lighthouse, reprographic, or other

communication service;

(xi) medical or dental service;

(xii) microscope, map, microfilm, or other specialized equipment service;

(xiii) swimming pool or other underwater service;

(xiv) decorative or showcase service;

(xv) producing colored light;

(xvi) shatter resistance which has an external protective coating; or

(xvii) appliance service.

All Covered Lamps

42 U.S.C. 6291(30)(G)

The term “average lamp efficacy” means the lamp efficacy readings taken over a

statistically significant period of manufacture with the readings averaged over that

period.

42 U.S.C. 6291(30)(H)

The term “base” means the portion of the lamp which connects with the socket as

described in ANSI C81.61­1990.

42 U.S.C. 6291(30)(J)

The term “color rendering index” or “CRI” means the measure of the degree of color

shift objects undergo when illuminated by a light source as compared with the color of

those same objects when illuminated by a reference source of comparable color

temperature.

42 U.S.C. 6291(30)(K)

The term “correlated color temperature” means the absolute temperature of a blackbody

whose chromaticity most nearly resembles that of the light source.

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42 U.S.C. 6291(30)(M)

The term “lamp efficacy” means the lumen output of a lamp divided by its wattage, 

expressed in lumens per watt (LPW).

10 CFR 430.2

Lamp Efficacy (LE) means the measured lumen output of a lamp in lumens divided by the

measured lamp electrical power input in watts expressed in units of lumens per watt

(LPW).

42 U.S.C. 6291(30)(N)

The term “lamp type” means all lamps designated as having the same electrical and

lighting characteristics and made by one manufacturer.

42 U.S.C. 6291(30)(O)

The term “lamp wattage” means the total electrical power consumed by a lamp in watts, 

after the initial seasoning period referenced in the appropriate IES standard test

procedure and including, for fluorescent, arc watts plus cathode watts.

42 U.S.C. 6291(30)(P)

The terms “life” and “lifetime” mean length of operating time of a statistically large

group of lamps between first use and failure of 50 percent of the group in accordance

with test procedures described in the IES Lighting Handbook­Reference Volume.

42 U.S.C. 6291(30)(Q)

The terms “lumen output” means total luminous flux (power) of a lamp in lumens, as

measured in accordance with applicable IES standards as determined by the Secretary.

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APPENDIX C – LAMP CATEGORIES IN EACH OF THE DEPARTMENT’S FOUR FLUORESCENT L

Notes: Per the statute’s definition of 8­foot fluorescent lamps, the Department has listed only those lamp types specified in ANSI C78.

1991. To provide a sense of what 4­foot lamps and 2­foot lamps with a rated wattage of 28 or more are currently available, the Departm

products specified in current ANSI publications with a rated wattage of 28 or more. The most current publications include ANSI 78.81

2006. The Department’s energy standards will also apply to EPCA­defined products on the market (including those specified and those 

ANSI publications). This would include any future products that may be introduced into the market, as noted by the icon labeled “othe

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APPENDIX D – TEST PROCEDURE DETAILS

This appendix lists the industry standards which the Department incorporated by

reference to test general service fluorescent lamps, incandescent reflector lamps and general

service incandescent lamps. Figures D.1­D.3 detail how to use industry standards to measure

lamp efficacy.

The industry standards incorporated by reference in the DOE test procedures include:

• ANSI C78.1–1991, “for Fluorescent Lamps—Rapid­Start Types—Dimensional and

Electrical Characteristics”,

• ANSI C78.2–1991, “for Fluorescent Lamps—Preheat­Start Types—Dimensional and

Electrical Characteristics of Fluorescent Lamps”,

• ANSI C78.3–1991, “for Fluorescent Lamps—Instant­Start and Cold­Cathode Types—

Dimensional and Electrical Characteristics”,

• ANSI C78.375–1991, “for Fluorescent Lamps—Guide for Electrical Measurements”,

• ANSI C82.3–1983 “for Reference Ballasts for Fluorescent Lamps”,

• Illuminating Engineering Society LM–9–88, “IES Approved Method for the Electrical

and Photometric Measurements of Fluorescent Lamps”,

• Illuminating Engineering Society of North America LM–16–1993, “IESNA Practical

Guide to Colorimetry of Light Sources”,

• Illuminating Engineering Society of North America LM–20–1994, “IESNA Approved

Method for Photometric Testing of Reflector­Type Lamps”,

• Illuminating Engineering Society of North America LM–45–91, “IES Approved Method

for Electrical and Photometric Measurements of General Service Incandescent Filament

Lamps”,

• Illuminating Engineering Society of North America LM–58–1994, “IESNA Guide to

Spectroradiometric Measurements”,

• International Commission on Illumination (CIE) Publication No. 13.2 1974, corrected

reprint 1993, “Method of Measuring and Specifying Color Rendering Properties of Light

Sources,” ISBN 3 900 734 39 9.

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Figure D. 1 Fluorescent Lamps

Testing a fluorescent lamp Per IES LM­9

Select lamp type

Set up reference

ballast Per ANSI C82.3

Per IES LM­54 Season lamp

Get lamp Per ANSI C78.1 and C78.3 specifications

Test lamp Per ANSI C78.375

Figure D. 2 General Service Incandescent Lamps

Figure D. 3 Incandescent Reflector Lamp Test Methods

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