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

Energy Conservation Standards

Preliminary Analysis for

General Service Lamps

January 20, 2015

Lucy deButts

Department of Energy

Building Technologies Office

GSL2013STD0051@ee.doe.gov
2

Welcome

• Introductions (around the room)

• Role of the Facilitator

• Ground Rules

– Speak one at a time.

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

this meeting.

– Be concise – share the ‘air-time’.

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

conversations.

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

recognized to speak.

• Housekeeping Items

• Agenda Review

• Opening Remarks
3

Agenda

9:00 – 9:30 AM Welcome, Introductions, Opening 

Statements, Overview

9:30 – 10:30 AM Scope of Coverage, Scope of Metrics

10:30 – 10:45 AM Break

10:45 – 11:15 AM Market and Technology Assessment, Screening 

Analysis

11:15 – 11:45 PM Engineering

11:45 – 12:00 PM Product Price Determination

12:00 – 1:00 PM Lunch

1:00 – 1:30 PM Energy Use, Life-Cycle Cost Analysis

1:30 – 2:00 PM Shipments, National Impact Analysis

2:00 – 2:30 PM Preliminary Manufacturer Impact Analysis, Notice of 

Proposed Rulemaking (NOPR) Analyses

2:30 – 2:45 PM Questions, Closing Remarks, Adjourn
4

Listening Via the Webcast

• The Department is broadcasting this meeting live over the 

Internet.

• DOE is providing the webcast to accommodate stakeholders 

that are unable to attend the public meeting in person.

• The web broadcast allows stakeholders to listen in and view 

the slides.

• All stakeholders are encouraged to submit written comments 

after the public meeting.
5

Purpose of the Public Meeting

• Present energy conservation standards DOE is considering for 

general service lamps (GSLs) in this preliminary analysis.

• Invite comment from participants on the analysis. 

• Discuss the next steps in the rulemaking.

• Encourage participants to submit data, information, summary 

statements, and written comments, including additional 

issues for discussion. 
6

Issues for Discussion

Issue box numbering corresponds to the Technical Support 

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

under docket number EERE-2013-BT-STD-0051, at 

http://www.regulations.gov/#!docketDetail;D=EERE-2013-BTSTD-0051. 

The deadline for submitting comments is February 9, 2015.

Issue Box: DOE welcomes comments, data, and information 

concerning its proposed standards for GSLs. Issues that correspond 

to those raised in DOE’s published material will be numbered in 

accordance with that material. Whether invited by an issue box or 

not, comments are welcome on any part of DOE’s analysis.
7

How to Submit Written Comments for GSLs

• In all correspondence, please refer to the GSL rulemaking by:

– Energy Conservation Standards for General Service Lamps;

– Docket Number EERE-2013-BT-STD-0051; and

– Regulatory Identification Number 1904-AD09.

• Email: GSL2013STD0051@ee.doe.gov

Postal: Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, 

Mailstop EE-2J

1000 Independence Avenue, SW

Washington, DC 20585-0121

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Suite 600

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: 202 586-2945

Comment Period closes: February 9, 2015 11:59 PM EDT
8

Presentation Overview

1 Overview; Scope of Coverage; Scope of Metrics

2 Market & Technology; Screening Analysis

3 Engineering Analysis

4 Product Price Determination

5 Energy Use; Life-Cycle Cost Analysis

6 Shipments; National Impact Analysis

7 Preliminary MIA; NOPR Analyses
9

Overview – Regulatory History

• Amendments to the Energy Policy and Conservation Act of 1975 (EPCA) in the 

Energy Independence and Security Act of 2007 (EISA) directed DOE to conduct 

two rulemaking cycles to evaluate standards for GSLs.

• This standards rulemaking constitutes the first cycle. The rulemaking must:

– Be initiated no later than January 1, 2014 and final rule published by January 1, 

2017; 

– Evaluate existing exemptions for certain incandescent lamps; 

– Not limit scope to incandescent technologies;

– Consider phased-in compliance dates; and

– Consider a minimum standard of 45 lumens per watt (lm/W) per the EISA 2007 

backstop criteria.

• This rulemaking also:

– Satisfies requirements for DOE to review existing standards for medium base 

compact fluorescent lamps (MBCFLs) which are included in the definition of GSL.

– Addresses 42 U.S.C. 6295(gg)(3) in which DOE is directed to incorporate standby 

mode and off mode energy use in any amended (or new) standard adopted after 

July 1, 2010, pursuant to 42 U.S.C. 6295(o).
10

Overview – GSL Rulemaking Schedule

Milestone Date

Notice of Public Meeting and Availability of Framework Document 9 December 2013

Notice of Public Meeting and Availability of Preliminary Technical 

Support Document 11 December 2014

Notice of Proposed Rulemaking (projected) December 2015

Final Rule (projected) December 2016

Compliance Date (projected) December 2019

2014 2015 2016 2017 2018 2019 2020
11

Overview – EPCA Factors

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

setting energy conservation standards.

EPCA Factors DOE Analysis

1. Economic impact on consumers and 

manufacturers

Life-Cycle Cost Analysis

Manufacturer Impact Analysis

2. Lifetime operating cost savings compared 

to increased cost for the product Life-Cycle Cost Analysis

3. Total projected energy savings National Impact Analysis 

4. Impact on utility or performance Engineering Analysis

Screening Analysis

5. Impact of any lessening of competition Manufacturer Impact Analysis

6. Need for national energy conservation National Impact Analysis

7. Other factors the Secretary considers 

relevant

Emissions Analysis

Utility Impact Analysis

Employment Impact Analysis
12

Scope of Coverage

• GSL includes several lamp types by definition: 

General service lamp includes general service incandescent lamps

(GSILs), compact fluorescent lamps (CFLs), general service lightemitting diode (LED) lamps, organic light-emitting diode (OLED) lamps, 

and any other lamps that the Secretary determines are used to satisfy 

lighting applications traditionally served by general service 

incandescent lamps; however, this definition does not apply to any 

lighting application or bulb shape excluded from the “general service 

incandescent lamp” definition or any general service fluorescent lamp 

or incandescent reflector lamp.

10 CFR 430.2
13

Scope of Coverage

• DOE considered the following when determining the GSL scope 

of coverage: 

– Lamp types explicitly listed in the definition of GSL:

• GSILs 

• CFLs

• General service LED lamps

• OLED lamps

– Any other lamps used to satisfy lighting applications traditionally served 

by GSILs that are GSLs.

– Lamp types that are not GSLs.

• DOE is considering not establishing standards for certain GSLs.
14

Scope of Coverage – GSILs 

• GSILs are included in the definition of GSL and are defined as follows:

General service incandescent lamp means a standard incandescent or 

halogen type lamp that is intended for general service applications; has a 

medium screw base; has a lumen range of not less than 310 lumens and not 

more than 2,600 lumens, or in the case of a modified spectrum lamp, not 

less than 232 lumens and not more than 1,950 lumens; and is capable of 

being operated at a voltage range at least partially within 110 and 130 volts. 

10 CFR 430.2

• Section 322 of the Consolidated Appropriations Act, 2014 (Public Law 113-

76 in part) states that none of the funds made available by the Act may be 

used to implement or enforce standards for GSILs, intermediate base 

incandescent lamps, and candelabra base incandescent lamps. Therefore, 

DOE will not be including these lamps in the GSL rulemaking at this time.
15

Scope of Coverage – CFLs

• The term “compact fluorescent lamp” was determined to apply 

to both integrated and non-integrated CFLs.

• DOE currently defines “medium base compact fluorescent 

lamp.” 

• DOE will define the term “compact fluorescent lamp” and other 

terms related to CFLs in the CFL TP rulemaking.

• DOE is considering not setting standards for certain CFLs within 

the GSL scope in this rulemaking. 
16

Scope of Coverage – LED Lamps

• General service LED lamps are included in the definition of GSL 

and can be integrated or non-integrated.

• DOE currently defines the term “light-emitting diode.” 

• DOE proposed a definition for “integrated LED lamp” in the LED 

TP SNOPR based on ANSI/IESNA RP-16.

• DOE does not currently have a definition for “general service 

LED lamp” and is considering the following definition in support 

of the scope:

• DOE is also considering not setting standards for certain LED 

lamps within the GSL scope in this rulemaking. 

General service light-emitting diode (LED) lamp means an integrated or nonintegrated LED lamp designed for use in general lighting applications (as 

defined in 430.2).
17

Scope of Coverage – OLED Lamps

• OLED lamps are included in the definition of GSL.

• DOE is considering defining OLED lamps in support of the scope:

Organic light-emitting diode or OLED lamp means an integrated or 

non-integrated lamp that uses OLEDs as the primary source as light.

Issue 4: OLED Lamps

DOE requests comment on its consideration to continue to not establish 

standards for OLED lamps in this rulemaking.

• DOE is considering not establishing standards for OLED lamps 

for the following reasons:

– OLED lamps are an emerging technology with limited commercial 

availability.

– It remains unclear if the efficacy of existing OLED products can be 

improved.
18

Scope of Coverage – Other Lamps

• DOE has the authority to consider additional lamps that it 

determines are used to satisfy lighting applications traditionally 

served by GSILs.

• DOE considered lamps with the following characteristics as 

meeting the definition of GSL:

– Utilize an ANSI base

– Are not a light fixture

– Operate at any voltage

– Intended to serve in general lighting applications

• General lighting application is defined as lighting that provides an interior or 

exterior area with overall illumination. 10 CFR 430.2

– Have a lumen output of 310 lumens or greater
19

Scope of Coverage – GSIL Exemptions

• 42 U.S.C. 6295(i)(6)(A)(i)(II) authorizes DOE to evaluate whether 

the 22 exemptions for incandescent lamps should be 

maintained or discontinued based in part on exempted lamp 

sales data.

• DOE cannot modify the existing exemptions for GSILs due to the 

Appropriations Rider.

GSIL Exemptions

Appliance Showcase Reflector

Plant Infrared Rough Service

Black light Traffic signal Shatter-resistant

Sign service Marine signal 3-way

Bug Mine service Vibration service

Silver bowl Left-hand thread Specific lamp shapes

Colored Marine
20

Scope of Coverage – Other Lamp Exemptions

• DOE determined that the exemptions for the lamp types listed in the 

GSIL definition do not automatically apply to lamp types other than 

GSILs.

• DOE conducted a separate assessment to determine if the GSIL 

exemptions should be continued by assessing whether the lamp type 

provides overall illumination and can be used in general lighting 

applications.

Exemption:

Does Not Provide Overall Illumination

No Exemption:

Provides Overall Illumination

Appliance Infrared Left-hand thread

Plant Traffic signal Marine

Black light Marine signal Reflector

Sign service Mine service Rough Service

Bug Shatter-resistant

Silver bowl 3-way

Colored Vibration service

Showcase Specific lamp shapes
21

Issues for Comment

Issue 2: Specialty Application CFLs and LED Lamps

DOE requests comment on the CFLs and LED lamps identified for specialty 

applications that cannot provide overall illumination and if there are other 

CFLs or LED lamps that should be considered. 

Issue 3: GSL Exemptions

DOE requests comment on the exemptions that DOE is considering providing 

for GSLs based on its assessment that the lamp types are intended for nongeneral applications. DOE also requests comment on its preliminary decision 

that 3-way lamps, vibration service lamps, rough service lamps, and shatterresistant lamps are able to provide overall illumination and therefore do not 

require an exemption from standards. 
22

Scope of Coverage – Standards

• DOE is also considering not setting standards for certain lamp 

types for reasons including the following:

– Low potential for energy savings 

– Technological infeasibility

– Restrictions from the Appropriations Rider

• The following slides summarize the lamp types included in the 

scope of this rulemaking and whether DOE is considering 

establishing standards for each lamp type.
23

Scope of Coverage – Standards

Integrated

Base Reflector/ NonReflectorTechnology Analyzed in 

PreAnalysis

Medium screw

Non-reflector

Incandescent No

CFL, LED Yes

Reflector Incandescent (non-IRL), CFL, LED No

Candelabra

Non-reflector

Incandescent No

CFL, LED No

Reflector

Incandescent No

CFL, LED No

Pin base

Non-reflector

Incandescent No

CFL, LED (GU24) Yes

Reflector Incandescent, CFL, LED No

Other (intermediate,

mogul)

Non-reflector

Incandescent No

CFL, LED No

Reflector Incandescent, CFL, LED No

* Rows in dark green are lamp types for which DOE is considering establishing standards.
24

Scope of Coverage – Standards

NonIntegrated

Base Reflector/ NonReflectorTechnology Analyzed in 

PreAnalysis

Screw base

Non-reflector Incandescent , CFL, LED No

Reflector Incandescent , CFL, LED No

Pin base

Non-reflector

Incandescent, LED No

CFL Yes

Reflector Incandescent, CFL, LED No

Other

Non-reflector Incandescent, CFL, LED No

Reflector Incandescent, CFL, LED No

* Rows in dark green are lamp types for which DOE is considering establishing standards.
25

Scope of Coverage – High Lumen Lamps

• DOE is considering not setting standards for high lumen lamps 

(> 2,600 lumens).

– DOE is unable to consider high lumen GSILs in this rulemaking.

– Establishing energy conservation standards for other high lumen lamps 

while not also addressing high lumen GSILs may increase national energy 

consumption.
26

Issues for Comment

Issue 5: Lamps Addressed in Other Rulemakings

DOE requests comment on its consideration to exclude from the scope of the 

GSL rulemaking lamps that are addressed in other rulemakings. 

Issue 6: Other Integrated Lamps

DOE requests comment on whether LED MR16 lamps are suitable 

replacements for incandescent/halogen reflector integrated MR16 lamps. DOE 

also requests comment on whether there are any integrated lamps with bases 

other than screw bases that have a significant market share. 

Issue 7: Other Non-Integrated Lamps

DOE identified screw base and pin base non-integrated lamps that meet the 

definition of GSL. DOE requests comment on whether there are any nonintegrated lamps with bases other than screw bases and pin bases that meet 

the definition of GSL and the market share of these lamps.
27

Scope of Coverage – Summary

• In summary, DOE is considering establishing standards in this 

rulemaking for the following lamp types only:

– Integrated, non-reflector, medium screw base lamps with a lumen 

output between 310 and 2,600 lumens;

– GU24 base, non-reflector lamps with a lumen output between 310 and 

2,600 lumens; and 

– Non-integrated, non-reflector, pin base, CFLs with a lumen output 

between 310 and 2,600 lumens. 
28

Scope of Coverage – Definitions

• DOE is considering defining the following terms in support of 

the scope: 

– Integrated lamp

– Non-integrated lamp

– Reflector

– Non-reflector 

– Light fixture

– Pin base lamp

– GU24 base

– Colored lamp

Issue 1: GSL Definitions

DOE requests comment on the definitions under consideration including 

“integrated lamp,” “non-integrated lamp,” “general service LED lamp,” “OLED 

lamp,” “colored lamp,” “reflector lamp,” “non-reflector lamp,” “light fixture,” 

“pin base lamp,” and “GU24 base.”
29

Scope of Metrics

• For MBCFLs, DOE has explicit authority to:

– Revise the five existing metrics (efficacy, lumen maintenance at 1,000 

hours, lumen maintenance at 40 percent of rated lifetime, rapid cycle 

stress, and lifetime);

– Establish requirements for additional metrics including color rendering 

index (CRI), power factor, operating frequency, and maximum allowable 

start time based on the ENERGY STAR® Program Requirements for CFLs 

Version 2.0; and

– Establish other requirements after considering energy savings, cost 

effectiveness, and consumer satisfaction. (42 U.S.C. 6295(bb)(2)-(3)) 

• DOE is considering the changes described on the next slide.
30

Scope of Metrics – Summary 

Metric Existing Standard Minimum Standard Considered

Efficacy Varies Discussed in Engineering

Lumen maintenance at 

1,000 hours

90 percent of initial lumen output at 

1,000 hours No change

Lumen maintenance at 

40 percent of lifetime

80 percent of initial lumen output at 40 

percent of lifetime No change

Rapid cycle stress Survive one cycle for every two hours 

of rated lifetime

MBCFL with start time > 100 

milliseconds (ms): survive one cycle per 

hour of rated lifetime or a maximum of 

15,000 cycles

MBCFLs with a start time of ≤ 100 ms: 

survive one cycle per every two hours 

of rated lifetime

Lifetime 6,000 hours 10,000 hours

Power factor None 0.5

CRI None 80

Start time None

The time needed for a MBCFL to 

become fully illuminated must be 

within one second of application of 

electrical power
31

Issue for Comment

Issue 8: MBCFL Metrics

Regarding existing metrics, DOE requests comment on maintaining the current 

lumen maintenance requirements. DOE also requests comment on the rapid 

cycle stress performance of commercially available MBCFLs and the 

appropriateness of requiring an increased lifetime of 10,000 hours for MBCFLs. 

Regarding metrics that DOE is considering adding, DOE requests comment on 

adding a requirement for power factor and its consideration of a standard for 

power factor of 0.5 or greater; CRI and its consideration of a standard for CRI of 

80 or greater; and the start time of MBCFLs and its consideration to require a 

start time of within one second of the application of electrical power. 

Regarding metrics that DOE is not considering adding, DOE requests comment 

on the consideration to not set a separate requirement for total harmonic 

distortion (THD); the consideration to not set a correlated color temperature 

(CCT) requirement; and the consideration to not set requirements for operating 

frequency.
32

Preliminary Analysis Stage

Framework

Document Prelim 

Analysis NOPR Final

Rule

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use & End 

Use Load

Characterization

Shipments

Analysis

National

Impact

Analysis

Life-Cycle

Cost and

Payback 

Period Analysis

Product Price 

Determination

Prelim

MIA
33

Presentation Overview

1 Overview; Scope of Coverage; Scope of Metrics

2 Market & Technology; Screening Analysis

3 Engineering Analysis

4 Product Price Determination

5 Energy Use; Life-Cycle Cost Analysis

6 Shipments; National Impact Analysis

7 Preliminary MIA; NOPR Analyses
34

Purpose of MTA and Screening Analysis

• Market and Technology Assessment (MTA)

− Determine product classes 

− Identify technology options to improve efficacy

• Screening Analysis

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

based on: 

• Technological feasibility;

• Practicability to manufacture, install, and service;

• Adverse impacts on product utility or product availability; and

• Adverse impacts on health or safety. 
35

Product Classes

• DOE divides covered products into classes by the type of energy 

used; capacity of the product; or other performance-related 

features that justify different standard levels, such as features 

affecting consumer utility.

• Product class factor: Integration of lamp components

– Integrated lamps are compact in size and require one lamp unit replacement 

which offers a utility to consumers

– Integrated self-ballasted lamps may be inherently less efficacious than nonintegrated lamps that have external ballasts

– DOE is considering defining “integrated lamp” and “non-integrated lamp” as 

follows:

Non-integrated lamp means a lamp that is not an integrated lamp.

Integrated lamp means a lamp that contains all components necessary for the starting and 

stable operation of the lamp, does not include any replaceable or interchangeable parts, and is 

connected directly to a branch circuit through an ANSI base and corresponding ANSI standard 

lamp-holder (socket).
36

Product Classes

• Product class factor: Lumen package

– Higher lumen packages offer a consumer utility

– Higher lumen output lamps currently cannot achieve the same levels of 

efficacy as lower lumen output lamps

– DOE is considering dividing lumen classes by 310-1,999 lumens and 2,000-

2,600 lumens

Integration of lamp components Lumen Package 

(lumens)

Integrated GSLs (e.g., self-ballasted CFL, integrated LED 

lamp)

310-1,999

2,000-2,600

Non-Integrated GSLs (e.g., externally ballasted CFL) 310-2,600

• Summary of GSL Product Classes:
37

Technology Options/Screening Analysis

CFL Technology Options

Highly Emissive 

Electrode Coatings

Higher Efficiency 

Lamp Fill Gas 

Composition

Higher Efficiency 

Phosphors Glass Coatings

Multi-photon 

Phosphors

Cold Spot 

Optimization

Improved Ballast 

Components

Improved Ballast 

Circuit Design

Change in Technology

LED Technology Options

Efficient Down 

Converters

- Quantum dot and 

nanophosphor

technologies

Improved Package 

Architectures

Improved Emitter 

Materials

Alternative Substrate 

Materials

Improved Thermal 

Interface Materials

Optimized Heat Sink 

Design

Active Thermal 

Management Systems Device Level Optics

Increased Light 

Utilization

Improved Driver 

Design

AC LEDs

Reduced Current 

Density

• DOE identified the technology options below that can improve lamp efficacy. 

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

meet the four screening criteria.
38

Issues for Comment

Issue 9: GSL Technology Options

DOE requests comment on the technology options under consideration for 

GSLs. Specifically, DOE also requests comment on the addition of reduced 

current density as a technology option.

Issue 10: GSL Product Classes

DOE is considering establishing three product classes for this rulemaking. DOE 

welcomes comments on the product class divisions it is considering for GSLs in 

this preliminary analysis. Further, DOE specifically requests comments on a 

product class division based on lumen package for the integrated GSLs. DOE 

also requests comments on its preliminary determination that a product class 

division based on standby mode operation is not warranted. 

Issue 11: GSL Design Options

DOE requests comments on the design options it is considering for GSLs.
39

Presentation Overview

1 Overview; Scope of Coverage; Scope of Metrics

2 Market & Technology; Screening Analysis

3 Engineering Analysis

4 Product Price Determination

5 Energy Use; Life-Cycle Cost Analysis

6 Shipments; National Impact Analysis

7 Preliminary MIA; NOPR Analyses
40

Engineering Analysis Methodology

Select certain representative product classes to be 

analyzed in the engineering analysis. 

Define characteristics of baseline lamps in each 

representative product class that serve as reference points 

to assess changes due to energy conservation standards. 

Identify more efficacious substitutes for each baseline 

lamp based on design options. 

Develop candidate standard levels (CSLs) that span the 

range of efficacy from the baseline to the maximum 

technologically feasible.

Scale results to product classes not analyzed.

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results
41

Representative Product Classes

• DOE chooses representative product classes to 

concentrate its analytical effort.

– DOE is considering analyzing all product classes shown in the 

table below as representative.

Lamp Type Lumen Output

Integrated GSLs (e.g., self-ballasted CFL, 

integrated LED lamp)

310-1,999

2,000-2,600

Non-Integrated GSLs (e.g., externally 

ballasted CFL) 310-2,600

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results
42

Baseline Lamps – Integrated GSLs

• The baseline model typically represents the most 

common, least efficacious model on the market for each 

representative product class.

• DOE is considering the following baseline for integrated 

GSLs:

Product 

Class

Lamp 

Shape

Base 

Type

Lamp 

Type

Nominal 

Wattage

Initial 

Lumens

Rated 

Efficacy Lifetime CCT

CRI

W lm lm/W hr K

Integrated 

Low Lumen 

(310-1,999

Lumens)

AShape E26 CFL 14 750 53.6 10,000 2,700 80

Integrated 

High Lumen

(2,000-2,600 

Lumens)

Spiral E26 CFL 32 2,000 62.5 10,000 2,700 80

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results
43

Baseline Lamps – Non-Integrated GSLs

• DOE is considering the following baseline for nonintegrated GSLs:

Product 

Class

Lamp 

Shape

Base 

Type

Lamp 

Type

Nominal 

Wattage

Rated 

Wattage

Initial 

Lumens

Rated 

Efficacy

Lifetime

CCT

CRI

W W lm lm/W hr K

NonIntegrated

(310-

2,600 

Lumens)

Double 

Tube G24q-3 CFL 26 26 1,710 65.8 10,000 4,100 82

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results

Issue 13: GSL Baseline Selection

DOE requests comment on the baseline units selected for each 

product class. 
44

More Efficacious Substitutes

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results

• DOE selected more efficacious replacement lamps to 

measure potential energy-saving improvements. 

• DOE identified more efficacious substitute lamps that:

– Saved energy or did not increase energy consumption relative to 

the baseline;

– Had light output within 10 percent of the baseline lamp’s light 

output when possible; and

– Had characteristics similar to the baseline lamp including base 

type.

• For integrated GSLs, DOE also ensured that the more 

efficacious LED lamp substitutes were marketed as 

omnidirectional to maintain the even distribution of 

light.
45

More Efficacious Substitutes – Integrated GSLs

• DOE is considering the following more efficacious 

substitutes for integrated GSLs:

Product 

Class

Lamp 

Shape

Base 

Type

Lamp 

Type

Nominal 

Wattage

Initial 

Lumens

Rated 

Efficacy Lifetime CCT

CRI

W lm lm/W hr K

Integrated 

Low 

Lumen 

(310-1,999

Lumens)

A-Shape* E26 CFL 14 750 53.6 10,000 2,700 80

Spiral E26 CFL 13 800 61.5 12,000 2,700 82

A-Shape E26 LED 12 800 66.7 25,000 2,700 82

A-Shape E26 LED 11 800 72.7 25,000 2,700 81

A-Shape E26 LED 10 800 80.0 25,000 2,700 82

A-Shape E26 LED 9.5 800 84.2 25,000 2,700 80

Integrated 

High 

Lumen

(2,000-

2,600 

Lumens)

Spiral* E26 CFL 32 2,000 62.5 10,000 2,700 80

Spiral E26 CFL 30 2,000 66.7 10,000 2,700 82

Spiral E26 CFL 29 2,200 75.9 12,000 2,700 82

*Row represents baseline lamp

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results
46

More Efficacious Substitutes – Non-Integrated GSLs

• DOE is considering the following more efficacious 

substitutes for non-integrated GSLs:

Product 

Class

Lamp 

Shape

Base 

Type

Lamp 

Type

Nominal 

Wattage

Rated 

Wattage

Initial 

Lumens

Rated 

Efficacy

Lifetime

CCT

CRI

W W lm lm/W hr K

NonIntegrated

Double 

Tube*

G24q3 CFL 26 26 1,710 65.8 10,000 4,100 82

Double 

Tube

G24q3 CFL 26 26 1,800 69.2 17,000 4,100 82

Double 

Tube

G24q3 CFL 21 26 1,525 72.6 20,000 4,100 82

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results *Row represents baseline lamp
47

Issue for Comment

Issue 14: More Efficacious Substitutes

DOE requests comment on the criteria used in selecting more efficacious 

substitute lamps in the integrated and non-integrated product classes and the 

characteristics of the lamps selected. 

In particular, for the integrated product class, DOE requests comment on its 

assumptions that more efficacious substitutes must have lumen output within 

10 percent of the baseline lamp and must be omnidirectional light sources.

For the non-integrated product class, DOE requests comment on its 

assumptions that more efficacious substitutes must have lumen output within 

10 percent of the baseline lamp-and-ballast system and the base type of the 

baseline lamp must be maintained for more efficacious substitutes. 
48

Non-Integrated GSL Systems

• To assess the performance of non-integrated GSLs, DOE used a 

systems approach and paired lamps with ballasts, capturing realworld energy use and light output. 

• DOE used manufacturer feedback and conducted a survey of the 

market to determine the most common non-integrated CFL ballasts 

by:

– Starting method;

– Number of lamps operated; and 

– Mode of operation.

• Based on this assessment, DOE analyzed one-lamp programmed 

start (PS) electronic ballasts.
49

Non-Integrated GSL Systems

• DOE selected lamp-and-ballast systems that are representative of 

the market.

CSL

Lamp Shape

Base Type

Lamp Type

Nominal Wattage

Rated Wattage

Initial LumensMean Lumens

Rated Efficacy

Lifetime

CCT

CRI

Number of Lamps

Starting Method

Ballast Factor

System Input 

Power

Ballast Luminous 

Efficiency (BLE)

System Initial Light 

Output

System Mean Light 

Output

W W lm lm lm/

W hr K W lm lm

Baseline Double 

Tube

G24q3 CFL 26 26 1,710 1,450 65.8 10,000 4,100 82 1 PS 1.04 30.0 90.2 1,778 1,508

CSL 1 Double 

Tube

G24q3 CFL 26 26 1,800 1,530 69.2 17,000 4,100 82 1 PS 1.04 30.0 90.2 1,872 1,591

CSL 1 Double 

Tube

G24q3 CFL 21 21 1,525 1,310 72.6 20,000 4,100 82 1 PS 1.04 24.4 89.5 1,586 1,362

Issue 15: Non-Integrated Ballast Pairing

DOE requests comment on the lamp-and-ballast systems selected for the nonintegrated product class.
50

Candidate Standard Levels

• DOE used commercially available lamps and their 

associated catalog efficacies to determine CSLs.

• To establish final minimum efficacy requirements for 

CSLs, DOE evaluated:

‒ Whether adjustments were necessary to the initial CSLs 

to ensure lamps were available across the entire lumen 

range; and 

‒ Publicly available compliance and testing verification 

databases to ensure the CSLs were achievable.

• For non-integrated GSLs, DOE also confirmed that 

consumers generally would not be required to change 

their fixture or base type at the higher CSL.

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results
51

Candidate Standard Levels – Integrated GSLs

• DOE is considering establishing CSLs based on an 

equation for efficacy using lumens as the input:

Efficacy = A – 29.42 × 0.9983^Lumens

• The following CSLs are under consideration for integrated 

GSLs:

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results

Representative Product Class Candidate 

Standard Level

Efficacy

lm/W

Integrated Low Lumen

(310 – 1,999 lumens)

CSL 1 67.6-29.42 × 0.9983^Lumens

CSL 2 74.2-29.42 × 0.9983^Lumens

CSL 3 80.2-29.42 × 0.9983^Lumens

CSL 4 87.5-29.42 × 0.9983^Lumens

CSL 5 90.8-29.42 × 0.9983^Lumens

Integrated High Lumen

(2,000 – 2,600 lumens)

CSL 1 67.6-29.42 × 0.9983^Lumens

CSL 2 74.2-29.42 × 0.9983^Lumens
52

Candidate Standard Levels – Integrated GSLs

CSL 1

CSL 2

CSL 3

CSL 4

CSL 5

Existing Standard

40.0

50.0

60.0

70.0

80.0

90.0

100.0

0 500 1000 1500 2000 2500 3000

Efficacy (lm/W)

Lumens (lm)

Baseline

CSL 1

CSL 2

CSL 3

CSL 4

CSL 5
53

Candidate Standard Levels – Non-Integrated GSLs

• DOE is considering establishing CSLs based on an 

equation for efficacy using lumens as the input.

Efficacy = A – 25.00 × 0.9989^Lumens

• The following CSL is under consideration for nonintegrated GSLs:

Representative Product 

Class

Candidate 

Standard Level

Efficacy

lm/W

Non-Integrated (310 – 2,600 

lumens) CSL 1 72.6-25.00 × 0.9989^Lumens

Select 

Representative 

Product Classes

Select Baseline 

Lamps

Identify More 

Efficacious 

Substitutes

Determine CSLs

Scale Results
54

Candidate Standard Levels – Non-Integrated GSLs

40.0

50.0

60.0

70.0

80.0

90.0

100.0

0 500 1000 1500 2000 2500 3000

Efficacy (lm/W)

Lumens (lm)

Baseline

CSL 1 - Full Wattage

CSL 1 - Reduced Wattage

CSL 1
55

Issues for Comment

Issue 17: CSL Equation Methodology

DOE requests comment on the methodology used to develop the CSL equations. In 

particular, DOE requests comment on the use of a lumens-based equation and the 

equation form itself.

Issue 12: GSL Data Approach

DOE welcomes comment on the data approach including any additional databases that 

should be considered.

Issue 18: Non-Integrated GSL Replacement Assumptions

DOE requests comment on its assumption that fixture compatibility would not be a 

common issue for non-integrated GSL replacements. DOE also requests comment on its 

assumption that consumer utility will not be lost with the base types that remain at CSL 

1.

Issue 16: Candidate Standard Levels

DOE requests comment on the CSLs under consideration for the integrated and nonintegrated product classes, including the max tech levels.
56

Presentation Overview

1 Overview; Scope of Coverage; Scope of Metrics

2 Market & Technology; Screening Analysis

3 Engineering Analysis

4 Product Price Determination

5 Energy Use; Life-Cycle Cost Analysis

6 Shipments; National Impact Analysis

7 Preliminary MIA; NOPR Analyses
57

Issue 19: Product Price Determination

DOE invites comment on the methodology and results for estimating enduser prices for GSLs. DOE also requests comment on the distribution 

channels and estimated percentage shipments through each channel.

Product Price Determination

• DOE estimated the end-user prices of GSLs directly, rather than developing 

manufacturing selling prices, because these lamps are difficult to reverseengineer (i.e., not easily disassembled).

• DOE averaged publically available retailer prices for representative unit and 

lamps with similar characteristics at each CSL, for each distribution channel.

• Based on shipment estimates through each channel, DOE applied the 

following weightings to develop a weighted average end-user price:

Small ConsumerBased Distributors

Large ConsumerBased 

Distributors

Electrical 

Distributors

State 

Procurement

Integrated GSLs 10% 75% 10% 5%

Non-Integrated GSLs 5% 10% 75% 10%
58

Presentation Overview

1 Overview; Scope of Coverage; Scope of Metrics

2 Market & Technology; Screening Analysis

3 Engineering Analysis

4 Product Price Determination

5 Energy Use; Life-Cycle Cost Analysis

6 Shipments; National Impact Analysis

7 Preliminary MIA; NOPR Analyses
59

Energy Use Characterization

• Purpose: 

– Develop estimates of average annual site energy use representative of 

consumers in the U.S. 

• Methodology:

– Annual energy use is based on multiplication of annual operating hours 

and lamp input power (provided by engineering analysis).

• Overall energy use reduced for lamps with lighting controls.
60

Energy Use Characterization

Residential Sector Annual Operating Hours

• Hours of Use (HOU) based on data from metering studies 

• Average HOU for all GSLs during the analysis period (beginning 1/1/20) 

assumed to be the same as the current average HOU for all GSLs

– Current higher HOU seen for CFLs assumed to be the result of disproportionate 

installation of CFLs in higher HOU sockets.

– HOU assumed to be the same at all efficiency levels during the analysis period.

• National weighted-average daily operating hours: 2.3 hrs/day

Issue 21: EISA 2007 Backstop Criteria

DOE requests any data suggesting that the EISA 2007 backstop criteria will not be met.

Issue 20: GSL Hours of Use

DOE seeks comment on its assumption that GSL operating hours will not vary by light 

source technology during the analysis period.
61

Energy Use Characterization

Commercial Sector Annual Operating Hours

• HOU based on data from the 2010 U.S. Lighting Market Characterization (LMC). 

• DOE did not explicitly analyze GSLs installed in the industrial sector.

– HOU for GSLs in the industrial sector assumed to be equal to the HOU for GSLs in 

the commercial sector.

• National weighted-average daily operating hours: 10.7 hrs/day
62

Energy Use Characterization

Lighting Controls

• Total energy use was reduced by 30% for all GSLs that operate on controls. 

Residential Sector:

• 14% of sockets are controllable, primarily with dimmers.

• Only 5% of CFLs are estimated to be dimmable.

• Fraction of LEDs used with controls is determined by the fraction of sockets which are 

controllable and the prevalence of “smart lamps.”

Commercial Sector:

• Due to building codes, an increasing fraction of GSLs is estimated to be installed on 

controls. 

Issue 23: Energy Savings from Lighting Controls

DOE requests data and information to help compare the energy use implications of using dimmers 

as opposed to other lighting controls.

Issue 22: Fraction of Dimmable GSLs in the Residential Sector

DOE requests comment on its approach regarding the dimmability of CFLs and LEDs.
63

Energy Use Characterization

Energy Use Results

Integrated Low Lumen:

(Lumen output ~ 800 lm)

Integrated High Lumen:

(Lumen output ~ 2,000 lm)

Non-Integrated:

(Lumen output ~ 1,700 lm)

CSL

Residential Commercial

Energy Use

(kWh/yr)

Savings

(kWh/yr)

Energy Use

(kWh/yr)

Savings

(kWh/yr)

0 11.6 0.0 46.3 0.0

1 10.8 0.8 43.0 3.3

2 8.9 2.7 39.7 6.6

3 8.2 3.4 36.4 9.9

4 7.4 4.2 33.1 13.2

5 7.1 4.6 31.4 14.9

CSL

Residential Commercial

Energy Use

(kWh/yr)

Savings

(kWh/yr)

Energy Use

(kWh/yr)

Savings

(kWh/yr)

0 26.6 0 106.0 0.0

1 24.9 1.7 99.2 6.6

2 24.1 2.5 95.9 9.9

CSL

Residential Commercial

Energy Use

(kWh/yr)

Savings

(kWh/yr)

Energy Use

(kWh/yr)

Savings

(kWh/yr)

0 24.9 0 99.2 0.0

1

24.9 0 99.2 0.0

20.3 4.6 80.7 18.4
64

LCC and PBP

• Purpose

– Provide an economic evaluation from the end-user’s perspective.

– Life-Cycle Cost (LCC) is the total cost to the consumer over the lifetime of a 

product. 

– Payback Period (PBP) is the time required to recover the increased purchase 

price of more energy-efficient products through reduced operating costs.

• Methodology

– Develop Monte Carlo sample of 10,000 purchasers.

– Develop lamp sample for integrated low lumen GSLs.

– Calculate LCC for each CSL by adding installed cost, lifetime operating costs, 

and disposal cost, and subtracting residual value.

– Calculate PBP for each CSL by dividing average increase in installed cost by 

average decrease in first-year operating cost.

– Calculate LCC savings based on market efficiency distributions in the base 

case and candidate standards cases.
65

LCC and PBP: Purchaser Sample

• To account for variability in parameters such as energy consumption and 

energy price, DOE developed a sample of 10,000 GSL purchasers. 

• Same sample used to determine average LCC at each CSL.

• Residential sector: 

– Randomly selected households from the 2009 Residential Energy 

Consumption Survey (RECS).

• Commercial sector: 

– Randomly selected buildings from the 2003 Commercial Buildings Energy 

Consumption Survey (CBECS).

– A selection weight was applied to each building.
66

LCC and PBP: Cost Inputs

• Electricity prices and trends were estimated using data from EIA. 

– Estimated price based on geographic location and economic sector.

• Discount rates were used to discount operating costs to year of purchase.

– Represent the opportunity cost of funds used to purchase GSLs. 

Issue 29: Installation Costs

DOE welcomes comment on its approach regarding installation costs.

• Total Installed Cost = Product Price + Sales Tax

– Price learning incorporated to account for decreases 

in manufacturing costs due to production experience.

• For CFLs, price learning was not applied to portion of 

lamp price attributable to rare earth oxides.

– Sales tax is determined by geographic location.

– Installation cost not included.

CSL Technology Price 

(2014$)

0 CFL $6.02

1 CFL $4.25

2 LED $30.12

3 LED $19.18

4 LED $15.28

5 LED $14.51

Integrated Low Lumen 2014 Prices 

from Product Price Determination
67

LCC and PBP: Lamp Sampling

• High variability seen in LED lamp price across lumen ranges

• For the integrated low lumen product class, lamps were sampled from four 

lumen ranges: 310-749, 750-1049, 1050-1489, and 1490-1999 lm

– Lamp data for 750-1049 lm range comes from engineering analysis

– To determine lamp data for the other lumen ranges, DOE:

• Scaled prices from product price determination using online retail price data 

• Used efficacy-to-lumen relationship developed in the engineering analysis

Market Shares by Lumen Range

Issue 24: Integrated Low Lumen GSL Market 

Distribution Estimates

DOE seeks comment on the market distribution 

estimates for the four lumen ranges analyzed as 

part of the integrated low lumen product class.

Data sources: 

Residential Sector: Cadeo Group, Residential Lighting End-Use Consumption Survey (RLEUCS), 

Commercial Sector: CA Retail Lighting Shelf Survey for pin-based CFLs
68

LCC and PBP: Operating Hours

Residential Sector

• To capture variability, HOU were sampled from location- and room-specific 

HOU distributions. 

– Allows for more realistic variability in HOU and for correlations between lumen 

output and HOU. 

Commercial Sector

• A triangular distribution was applied to average HOU for each building type.

– Minimum of 80% and a maximum of 120% of the corresponding average HOU.

Issue 26: Commercial Hours of Use Variability

DOE invites comments and data on its approach to account for variability in hours of use.
69

LCC and PBP: Lifetime

• Sector-specific probability of survival as a function of lamp age was modeled 

using Weibull distributions. Survival probability based on:

(1) the lamp’s rated lifetime (from the engineering analysis),

(2) sector-specific HOU distributions, and

(3) effects of on-time cycle length (for residential CFLs only).

– DOE also assumed no effect from dimming on either CFL or LED lifetime.

• Three lifetime scenarios were considered:

Scenario Name Description

Rated Lifetime Consumers use GSLs for their full rated lifetime.

Renovation-Driven 

Lifetime

The ‘rated lifetime’ scenario is truncated to account for lamp 

turnover during renovations or retrofits.

Early-Replacement 

Lifetime

The ‘rated lifetime’ scenario is truncated to model the 

assumption that the lifetime of LED GSLs is similar to that of 

consumer electronics (about 5 years).

Reference scenario 

Issue 27: GSL Service Life Scenarios

DOE invites comment on the three lifetime scenarios considered.
70

LCC and PBP: Lifetime

Residential Sector Modeling Results for the Reference Scenario

Issue 28: Lifetime Distribution Modeling

DOE invites comments and data on the assumptions and methodology used to 

calculate GSL survival probabilities as a function of GSL age.
71

LCC and PBP: Residual Value; Disposal Cost

• Residual value is the remaining value of surviving GSLs at the end of the 

LCC analysis period. Applied as a “credit” to the LCC.

• Residual value is based on an estimation of what the price of the same 

lamp would be at the end of the LCC analysis period.

– Includes the impact of price learning

– Discounted to the analysis start year

• Disposal cost represents the cost of disposing (e.g., recycling) lamps at the 

end of the lamp lifetime.

– CFLs:

• Residential sector: DOE assumed that consumers do not pay disposal costs. 

• Commercial sector: Estimated 10% of consumers pay average recycling costs of $1 

per lamp.

– DOE assumed no disposal costs for LEDs. 

Issue 31: Disposal Costs

DOE requests comment and data on the disposal cost assumptions.
72

LCC and PBP: LCC Savings Calculation

• LCC is the average cost if all consumers purchase at a particular CSL.

• LCC savings are the average cost savings if a standard is set at a particular 

CSL, considering the market efficiency distribution.

– Calculation yields fraction of consumers expected to experience a net cost.

• Market transformation approach to LCC savings considers the market 

efficiency distribution in both the base case (no standard) and each 

candidate standards case (standard set at a given CSL).

– Market share by technology type was based on historical shipments data.

– A consumer-choice model was used to project market efficiency distributions. 

• Approach accounts for consumers who would select more efficient GSL 

than the least efficacious lamp required by a standard.

– Consumers who purchased the most efficacious GSLs in the efficiency 

distribution in the base case were assumed to also purchase the most 

efficacious GSLs under a standard.
73

LCC and PBP: LCC Savings Calculation

Residential Sector Base Case and Candidate Standard

Case (CSC) Efficiency Distributions in 2020

Market Share (%)

Base Case CSC 1 CSC 2 CSC 3 CSC4 CSC 5

CSL 0 1.1 0.0 0.0 0.0 0.0 0.0

CSL 1 48.5 49.6 0.0 0.0 0.0 0.0

CSL 2 0.5 0.5 0.9 0.0 0.0 0.0

CSL 3 1.7 1.7 3.4 3.4 0.0 0.0

CSL 4 21.0 21.1 41.8 42.2 43.7 0.0

CSL 5 27.1 27.2 53.9 54.4 56.3 100.0

Total* 100.0 100.0 100.0 100.0 100.0 100.0

*May not sum to 100.0 due to rounding

Issue 30: LCC and Consumer Impacts from Potential Standards

LCC savings and the percent of consumers affected by a standard were determined using the 

base-case and standards-case efficiency distributions. DOE seeks comment on this approach.

Issue 25: Consumer Purchases in Standards Case Analyses

DOE seeks comment on the assumption that in the standards case consumers purchase lamps 

that are at least as efficient as the ones they would purchase in the absence of standards. 
74

LCC and PBP: Results

Integrated Low Lumen Product Class

CSL

Average Costs (2014$)

Simple 

Payback

(years)

Average 

Lifetime

Installed Cost (years)

First Year’s 

Operating 

Cost

Lifetime 

Operating 

Cost LCC

Residential Sector

0 6.2 1.6 5.6 11.8 --- 8.8

1 4.0 1.5 5.2 8.8 0 9.8

2 34.9 1.3 4.6 23.1 99.6 17.9

3 22.2 1.2 4.2 16.0 40.5 17.9

4 7.5 1.1 3.8 8.5 2.6 17.9

5 7.2 1.0 3.6 8.1 1.7 17.9

Commercial Sector

0 7.0 6.9 17.7 24.8 --- 2.2

1 4.4 6.4 16.5 20.2 0 2.8

2 45.7 6.0 15.3 37.9 40.0 6.3

3 29.1 5.5 14.0 28.4 15.3 6.3

4 7.7 5.0 12.8 17.2 0.4 6.3

5 7.3 4.8 12.2 16.4 0.2 6.3

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience Net Cost

Average 

Savings 

(2014$)

Residential Sector

0 0% 0.0

1 0% 0.0

2 27% -0.1

3 27% 0.0

4 25% 0.3

5 22% 0.5

Commercial Sector

0 0.0% 0.0

1 0.0% 0.0

2 1.1% 1.7

3 1.1% 1.7

4 0.8% 1.7

5 0.3% 2.1

TSD also includes LCC & PBP results for 2025 
75

LCC and PBP: Results

Integrated High Lumen Product Class

CSL

Average Costs (2014$)

Simple 

Payback

(years)

Average 

Lifetime

Installed Cost (years)

First Year’s 

Operating 

Cost

Lifetime 

Operating 

Cost LCC

Residential Sector

0 9.7 3.6 12.8 22.5 --- 8.8

1 10.1 3.4 12.0 22.1 1.5 8.8

2 10.8 3.3 11.6 21.3 3.1 9.8

Commercial Sector

0 9.7 12.4 31.6 41.5 --- 2.2

1 10.1 11.6 29.7 39.8 0.4 2.2

2 10.8 11.2 28.7 37.6 0.9 2.8

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience

Net Cost

Average 

Savings

(2014$)

Residential Sector

0 0% 0.0

1 6% 0.2

2 13% 0.5

Commercial Sector

0 0.0% 0.0

1 0.2% 0.5

2 1.2% 1.7

Non-Integrated Product Class

CSL

Average Costs (2014$)

Simple 

Payback

(years)

Average 

Lifetime

Installed Cost (years)

First Year’s 

Operating 

Cost

Lifetime 

Operating 

Cost LCC

Residential Sector

0 13.2 3.4 11.9 25.2 --- 8.8

1

14.2 3.4 11.9 22.8 N/A 11.6

15.7 2.8 9.7 21.1 4.0 12.5

Commercial Sector

0 13.2 11.6 29.6 42.9 --- 2.2

1

14.2 11.6 29.6 39.0 N/A 4.1

15.7 9.4 24.1 33.3 1.2 5.0

CSL

Life-Cycle Cost Savings

% of Consumers that 

Experience

Net Cost

Average 

Savings

(2014$)

Residential Sector

0 0% 0.0

1 12% 1.6

Commercial Sector

0 0.0% 0.0

1 5.4% 2.6
76

LCC and PBP: Alternative Analyses

Scenario Reference Assumption Alternative Assumption(s)

Lamp Service Lifetime

Lamp retirement driven by rated 

lifetimes or by renovations for longlived lamps (20-year cycle)

Rated Lifetime: Lamp retirement 

driven by rated lifetimes only (50-

year maximum lifetime)

Early Replacement: LED 

replacements driven by advances in 

technology (5-year cycle)

Rare Earth Oxide Price Constant price at June 2014 level High REO prices: 

Constant at 4.5 x June 2014 price

AEO Growth Reference economic growth Low economic growth

High economic growth

LCC Savings Approach Market transformation

Roll-up: Consumers who previously 

purchased a GSL below standard 

level analyzed buy least efficacious 

lamp available

LCC & PBP Start Year 2020 (assumed compliance year) 2025: 5 years after compliance year

Commercial Controls

Smart Lamp Incursion Will be discussed in National Impact Analysis (NIA) section

Smart Lamp Standby

Issue 37: Rare Earth Price Scenarios

DOE invites comment on the two rare earth materials price scenarios analyzed.
77

Presentation Overview

1 Overview; Scope of Coverage; Scope of Metrics

2 Market & Technology; Screening Analysis

3 Engineering Analysis

4 Product Price Determination

5 Energy Use; Life-Cycle Cost Analysis

6 Shipments; National Impact Analysis

7 Preliminary MIA; NOPR Analyses
78

Shipments Analysis

• Purpose

– Project GSL shipments over the 30-year analysis period (2020-2049) by 

product class and candidate standard level, in the base case and each 

of five CSCs corresponding to the CSLs.

• Method

– Shipments for each product class and sector are estimated using a 

stock-accounting methodology calibrated to historical shipments data

– Model accounts for product replacements, new construction, and 

demand to and from substitutes

– EISA 2007 backstop provision is assumed to take effect in 2020

– Shipments are disaggregated by efficiency level using a consumerchoice model sensitive to: 

• Lamp technology

• Price

• Lifetime

• Energy savings

• Mercury content
79

Shipments Analysis

The Consumer Choice Module projects market shares for each lamp option by 

lamp category and efficiency level, based on consumer sensitivity to price and 

other product features.

Details on the shipments analysis can be found in chapter 9 of the TSD.

Demand 

Module

Price 

Learning 

Module

Price

Product 

Features

Shipments by 

product class 

and efficiency 

level

To outside-ofscope 

substitutes

Demand for 

new 

construction

Demand for 

Replacements

Demand from 

Substitution
80

Shipments Analysis: Price Learning

• CFL and LED GSLs have historically exhibited approximate power law trends in price as a 

function of cumulative shipments: PP ∝ QQ−αα

• Recent trends for LEDs have been steeper than historical CFL trends1.

• Learning rate in the reference case is assumed equal for CFL and LED lamps.

• Price learning is not applied to the portion of a CFL’s price that is associated with rare 

earth elements. Rare earth price uncertainty is treated separately.

• Certain lamp options are assumed to be obsolete designs; their prices are held fixed.

Base Case Lamp Prices for Integrated Low Lumen 750-1049 lm Lamp category*

CSL Technology Price 

(2014$)

0 CFL $6.02

1 CFL $4.25

2 LED $30.12

3 LED $19.18

4 LED $15.28

5 LED $14.51

750-1049 lm

*Dashed lines represent fixed lamp prices

1Source: Gerke, B. et al., 2014, Lawrence Berkeley National Laboratory Report No. LBNL-6854E. 
81

Shipments Analysis: Price Learning

• In addition to the base learning trend, DOE incorporated exponential trends in 

incremental price for lamps with lumen output above 749 lm: ΔΔPP ∝ ee−ββββ

• Incremental price trends were based on recent observed trends1.

• In this preliminary analysis, DOE assumed that the incremental prices will eventually 

drop to zero. Base Case CSL 5 Lamp Prices for Integrated Low Lumen by Lamp Category

Issue 40: Incremental Price of Brighter LED GSLs

DOE is assuming that both the price of LED GSLs and the incremental price of brighter LED GSLs are 

falling. DOE requests comment and data on this assumption.

1Source: Gerke, B. et al., 2014, Lawrence Berkeley National Laboratory Report No. LBNL-6854E. 
82

Integrated Low Lumen Shipments

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

Issue 41: Pre-Compliance Year Shift Away from Incandescent GSLs

DOE requests comment on its assumptions about market shifts away from GSILs prior to 2020.

DOE made the following assumptions in its shipments analysis:

• The efficacy of each lamp option is constant over the analysis period.

• Some fraction of the GSIL market shifts to CFL/LED in each year prior to 2020; the 

remainder shifts in 2020 due to the backstop provision in EISA 2007.

– GSILs in the commercial sector are assumed to be negligible already, therefore the 

shift is assumed to occur only in the residential sector.

Integrated Low Lumen GSLs Shipments by Technology: Base Case and CSC 5

Dashed lines: base case. Solid lines: CSC 5.
83

Integrated High Lumen and Non-Integrated Shipments

Issue 34: Residential Integrated High Lumen GSLs

DOE requests comment and data on its assumptions about the prevalence of high 

lumen GSLs.

• DOE assumed that, throughout the analysis period, high lumen (>2,000 lumens) GSLs 

make up approximately 3% of all installed residential-sector GSLs with integrated 

ballasts or drivers.

• DOE assumed that non-integrated CFL GSLs will remain a constant fraction of the 

installed GSL stock in the commercial sector, after accounting for the incursion of 

integrated LED fixtures.

• DOE assumed that the reduced-wattage lamp option is a niche product and will remain a 

constant fraction of the non-integrated GSL shipments.

Issue 36: Non-Integrated CFL GSLs

DOE seeks comment and data on its assumptions about the continuing prevalence of 

non-integrated GSLs.
84

Shipments: Alternative Analyses

Scenario Reference Assumption Alternative Assumption(s)

Price Trends Lamp prices for CFLs and LED GSLs 

decrease at the same learning rate

Technology Specific: Learning rates 

specific to lamp technology 

None: Lamp prices remain fixed in 

real dollars at 2014 levels

Lamp Service Lifetime

Lamp retirement driven by rated 

lifetimes or by renovations for 

long-lived lamps (20-year cycle)

Rated Lifetime: Lamp retirement 

driven by rated lifetimes only (50-

year maximum lifetime)

Early Replacement: LED 

replacements driven by advances 

in technology (5-year cycle)

Integrated LED Incursion

Integrated LED luminaires fulfill 

15% of lumen demand at end of 

analysis period

None: No integrated LED incursion

High: Integrated LEDs fulfill 50% of 

lumen demand in 2049

Rare Earth Oxide Price Constant price at June 2014 level High REO prices: 

Constant at 4.5 x June 2014 price

Issue 39: LED Learning Rate Scenarios

DOE invites comment on the LED learning rate scenarios.

Issue 35: Integrated LED Fixture Penetration

DOE invites comment and data on the scenarios regarding integrated LED fixture penetration.
85

Issues for Comment

Issue 33: GSL Shipments Data

DOE requests any representative data on GSL shipments as they become 

available in order to improve the accuracy of the shipments analysis.

Issue 42: GSL Market Data

DOE requests comment and data on current market shares and market trends 

for GSLs in the commercial sector. 
86

National Impact Analysis

• Purpose

‒ Estimate the National Energy Savings (NES) and national Net Present 

Value (NPV) of consumer savings from GSLs shipped between 2020-

2049, under the various candidate standards cases, relative to the 

base case.

• Method

‒ Use the shipments model to estimate the total stock of GSLs in service 

each year.

‒ Develop annual series of national energy consumption and consumer 

costs.

‒ Account for the time-value of money at discount rates of 3 and 7 

percent.
87

NIA Results Reference Case

Details on the NIA can be found in chapter 10 of the TSD.

Full fuel cycle NES and NPV, for all product classes 

CSL 1 CSL 2 CSL 3 CSL 4 CSL 5

National Energy Savings FFC (quads)

Integrated Low Lumen (<2000 lm) 0.00 0.34 0.34 0.35 0.47

Integrated High Lumen (>2000 lm) 0.01 0.02 0.02 0.02 0.02

Non-Integrated (310-2600 lm) 0.00 0.00 0.00 0.00 0.00

Total* 0.02 0.36 0.36 0.37 0.50

NPV 3% Discount Rate (billion 2014$) 

Integrated Low Lumen (<2000 lm) 0.02 1.21 1.44 1.90 2.52

Integrated High Lumen (>2000 lm) 0.04 0.09 0.09 0.09 0.09

Non-Integrated (310-2600 lm) 1.95 1.95 1.95 1.95 1.95

Total* 2.01 3.25 3.47 3.94 4.56

NPV 7% Discount Rate (billion 2014$) 

Integrated Low Lumen (<2000 lm) 0.02 0.54 0.67 0.96 1.28

Integrated High Lumen (>2000 lm) 0.02 0.04 0.04 0.04 0.04

Non-Integrated (310-2600 lm) 0.96 0.96 0.96 0.96 0.96

Total* 1.00 1.55 1.68 1.96 2.28 *Total may not add due to rounding
88

NIA: Alternative Analyses

Scenario Reference Assumption Alternative Assumption(s)

Commercial Controls

Commercial floorspace utilizing 

lighting controls increases due to 

newer building standards

Fixed: Commercial floorspace 

utilizing lighting controls remains 

fixed at 2014 levels

Smart Lamp Incursion

Smart lamps make up 50% of 

residential LED GSL shipments at 

the end of the analysis period

None: No smart lamp incursion

High: Smart lamps make up 100% 

of residential LED GSLs at end of 

analysis period

Smart Lamp Standby No standby power associated with 

smart lamps

1 W: All smart lamps have an 

associated standby load of 1W

Rebound Rebound rates for residential and 

commercial sectors set to 0%

Low: Residential 8.5%, 

Commercial 1%

High: Residential and Commercial 

15%

Issues 43-46: Alternative Scenarios

DOE invites comment on the scenarios regarding the penetration of commercial lighting controls, 

LED GSLs with standby functionality (“smart lamps”), the rebound effect, and any other scenarios 

that should be considered.

• In addition to the alternative LCC and Shipments scenarios, DOE also 

considered the following alternative NIA scenarios.
89

Alternative Analyses: Selected Results

CSC 1 CSC 2 CSC 3 CSC 4 CSC 5

Reference Total FFC NES (quads) 0.02 0.36 0.36 0.37 0.50

Change from Reference

Early Replacement 17% 102% 101% 98% 70%

Rated Lifetime 5% 9% 10% 11% 14%

Technology-specific learning -6% -23% -23% -24% -18%

100% smart lamp incursion 4% 17% 17% 16% 9%

1W Smart lamp standby -7% -55% -54% -53% -40%

Full results available in the NIA spreadsheet tool

CSC 1 CSC 2 CSC 3 CSC 4 CSC 5

Reference Total NPV 7% discount (2014$) 1.00 1.55 1.68 1.96 2.28

Change from Reference

Early Replacement -1% -116% -101% -75% -57%

Rated Lifetime 22% -131% -95% -52% -35%

Technology-specific learning -1% 15% 9% 0% -2%

100% smart lamp incursion 0% 1% 1% 1% 1%

1W Smart lamp standby 0% -4% -4% -3% -3%
90

Presentation Overview

1 Overview; Scope of Coverage; Scope of Metrics

2 Market & Technology; Screening Analysis

3 Engineering Analysis

4 Product Price Determination

5 Energy Use; Life-Cycle Cost Analysis

6 Shipments; National Impact Analysis

7 Preliminary MIA; NOPR Analyses
91

Preliminary MIA

• Purpose

– The manufacturer impact analysis (MIA) identifies the impacts of 

energy conservation standards on manufacturers.

• Phase 1

– DOE creates an industry profile to characterize the industry and 

identify important issues that require consideration.

• Phase 2

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

questionnaire to guide subsequent discussions.

• Phase 3

– DOE interviews manufacturers and assesses the impacts of standards 

both quantitatively (using the Government Regulatory Impact Model) 

and qualitatively (impacts on competition, manufacturing capacity, 

direct employment, and regulatory burden).
92

Issues for Comment

Manufacturer Impact Analysis

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

data and/or information from interested parties that can assist in evaluating 

the potential impact on GSL manufacturers.

Manufacturer Subgroup Analysis

DOE requests feedback on subgroups to analyze and/or characteristics 

appropriate for a separate subgroup analysis.

Regulatory Flexibility Act Analysis

DOE invites interested parties to provide information regarding any small 

businesses that manufacture GSLs and should be consulted before DOE 

publishes a NOPR for this rulemaking.
93

NOPR Analyses

• LCC Subgroup Analysis

– Effects on various national consumer subgroups

• Manufacturer Impact Analysis

– Continue work begun in the preliminary MIA

• Employment Impact Analysis

– Indirect effects on national employment

• Utility Impact Analysis

– Effects on generation capacity of utilities

• Emissions Analysis

– Effects on airborne pollutant emissions

• Monetization of Emission Reductions Benefits

– Monetary benefits from emissions reduction

• Regulatory Impact Analysis

– Potential for non-regulatory approaches
94

How to Submit Written Comments for GSLs

• In all correspondence, please refer to the GSL rulemaking by:

– Energy Conservation Standards for General Service Lamps;

– Docket Number EERE-2013-BT-STD-0051; and

– Regulatory Identification Number 1904-AD09.

• Email: GSL2013STD0051@ee.doe.gov

Postal: Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, 

Mailstop EE-2J

1000 Independence Avenue, SW

Washington, DC 20585-0121

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Suite 600

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: 202 586-2945

Comment Period closes: February 9, 2015 11:59 PM EDT