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.gov2 

# 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 Remarks3 

# 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 P M 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 R ulemaking (NOPR) Analyses
2 :30

– 2:45 PM Questions, Closing Remarks, Adjourn4 

# 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

- BT

STD

- 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 EDT8 

# 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 Analyses9 

# 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:

– B e 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

– C onsider a minimum standard of 45 lumens per watt ( lm/W) per the EISA 2007 backstop criteria.



## • This rulemaking also:

– S atisfies requirements for DOE to review existing standards for medium base compact fluorescent lamps (MBCFLs) which are included in the definition of GSL.

– A ddresses 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 2015 2018 2014 2016 2017 2019 202011 

# 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 Analysis12 

# 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 light

emitting 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 430.213 

# 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 non

integrated 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 greater19 

# 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 Marine20 

# 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 shapes21 

# 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 non

general applications. DOE also requests comment on its preliminary decision that 3

- way lamps, vibration service lamps, rough service lamps, and shatter

resistant 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/ Non

Reflector Technology 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

Non

Integrated Base Reflector/ Non

Reflector Technology 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 non

integrated 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

– E stablish 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 power31 

# 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

MIA33 

# 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 Analyses34 

# 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 non

integrated 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

– H igher 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 Analyses40 

# 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 Results41 

# 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 Results42 

# 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) A

Shape 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 Results43 

# Baseline Lamps

– Non

- Integrated GSLs

• DOE is considering the following baseline for non

integrated GSLs:

Product

Class Lamp Shape Base Type Lamp TypeNominalWattageRatedWattageInitialLumensRatedEfficacyLifetimeCCT
CRI

W W lm lm/W hr K

Non

Integrated (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 b aseline lamp Select Representative Product Classes

Select Baseline Lamps

Identify More Efficacious Substitutes

Determine CSLs

Scale Results46 

# 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 TypeNominalWattageRatedWattageInitialLumensRatedEfficacyLifetimeCCT

CRI

W W lm lm/W hr K

Non

Integrated Double Tube* G24q

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

Double

Tube G24q

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

Double

Tube G24q

3 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 b aseline lamp47 

# 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 real

world 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:

– S tarting method ;

– N umber of lamps operated; and

– M ode 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.CSLLamp ShapeBase TypeLamp TypeNominal WattageRated WattageInitial LumensMean LumensRated EfficacyLifetimeCCTCRINumber of LampsStarting MethodBallast FactorSystem InputPowerBallast LuminousEfficiency (BLE)System Initial LightOutputSystem Mean LightOutput

W W lm lm lm/ W hr K W lm lm

Baseline Double Tube G24q

3 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 G24q

3 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 G24q

3 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 non

integrated 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:

‒ W hether adjustments were necessary to the initial CSLs to ensure lamps were available across the entire lumen range; and

‒ P ublicly 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 Results51 

# 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^Lumens52 

# 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 3000Efficacy (lm/W)

Lumens (lm) Baseline

CSL 1

CSL 2

CSL 3

CSL 4

CSL 553 

# 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 non

integrated 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 Results54 

# 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 3000Efficacy (lm/W)

Lumens (lm) Baseline
CSL 1 - Full Wattage
CSL 1 - Reduced Wattage

CSL 155 

# Issues for Comment

Issue 17: C SL 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 non

integrated 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 Analyses57 

## Issue 19: Product Price Determination DOE invites comment on the methodology and results for estimating end

user 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 reverse

engineer (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 Consumer

Based Distributors Large Consumer

Based 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 Analyses59 

# 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/day62 

# 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.

• O nly 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 18.464 

# 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.

• R esidential 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 Determination67 

# LCC and PBP: Lamp Sampling

• H igh 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 CFLs68 

# 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.

– M inimum 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

• S ector

- 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

.



## • T hree 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.

– C onsumers 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 (years) Installed Cost 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 202575 

# LCC and PBP: Results

Integrated High Lumen Product Class

CSL Average Costs (2014$) Simple Payback (years) Average Lifetime (years) Installed Cost 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 (years) Installed Cost 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% 2.676 

# LCC and PBP: Alternative Analyses

Scenario Reference Assumption Alternative Assumption(s)

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)

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
Will be d iscussed in National Impact Analysis (NIA) section Smart Lamp Incursion
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 Analyses78 

# 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

– S hipments 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 consumer

choice model sensitive to:

• L amp technology

• Price

• Lifetime

• Energy savings

• M ercury content79 

# 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

- of

scope substitutes Demand for

new construction

Demand for Replacements

Demand from Substitution80 

# 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 trends 1



### .

• 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

1 Source : 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: ΔΔ PP ∝ ee − ββββ



### • Incremental price trends were based on recent observed trends 1



### .

• 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 L amp 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

.

1 Source : 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 E nergy S avings (NES) and national N et P resent V alue (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 rounding88 

# 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 Analyses91 

# 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 approaches94 

# 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