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

Energy Conservation Standards 

Preliminary analysis for general service 

fluorescent lamps (GSFLs) and 

incandescent reflector lamps (IRLs) 

April 9, 2013 

Lucy deButts 

Department of Energy 

Building Technologies Program 

EERE-2011-BT-STD-0006

GSFL-IRL_2011-STD-0006@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 

Public Meeting Agenda 

9:00 – 9:25 am Welcome, Introductions, Opening Statements, 

Overview, Statute, Context 

9:25 – 9:45 am Market and Technology Assessment, Screening 

Analysis 

9:45 – 10:45 am Engineering Analysis 

10:45 – 11:00 am Break 

11:00 – 11:15 am Product Price Determination 

11:15 – 12:00 pm Energy Use, Life-Cycle Cost Analysis 

12:00 – 1:00 pm Lunch 

1:00 – 1:45 pm Shipments, National Impact Analysis 

1:45 –2:05 pm Preliminary Manufacturer Impact Analysis, NOPR 

Analyses 

2:05 –2:15 pm Closing Remarks and 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 Public Meeting 

1. Present energy conservation standards DOE is considering for 

GSFLs and IRLs in this preliminary analysis 

2. Invite comment from participants on the analysis 

3. Discuss the next steps for the rulemaking 

4. Encourage participants to submit data, information, 

summary statements, and written comments, including 

additional issues for discussion 
6 

Issue for Discussion 

Issue box numbering corresponds to the Technical Support 

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

under docket number EERE-2011-BT-STD-0006, at 

www.regulations.gov/#!documentDetail;D=EERE-2011-BT-STD0006-0022. 

The deadline for submitting comments is May 13, 2013. 

 

Issue Box: DOE welcomes comments, data, and information 

concerning standards being considered for GSFLs and IRLs. 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 

• In all correspondence, please refer to the GSFL-IRL rulemaking by: 

– Energy Conservation Standards for General Service Fluorescent Lamps 

and Incandescent Reflector Lamps; 

– Docket Number EERE-2011-BT-STD-0006; and 

– Regulatory Identification Number (RIN) 1904-AC43. 

• Email: GSFL-IRL_2011-STD-0006@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: May 13, 2013, 11:59 PM EDT 
8 

Opening Remarks 

Meeting participants are invited to provide opening 

remarks or statements at this time. 
9 

Presentation Overview 

Energy Use; Life-Cycle Cost Analysis 

Shipments; National Impact Analysis 

5 

6 

2 Market & Technology; Screening Analysis 

3 Engineering Analysis 

1 Overview; Scope of Coverage 

7 Preliminary MIA; NOPR Analyses 

4 Product Price Determination 
10

Regulatory History 

• The Energy Policy Act of 1992 (EPACT 1992) amended the Energy 

Policy and Conservation Act of 1975 (EPCA) by: 

− Establishing standards for certain classes of GSFLs and IRLs; and 

− Authorizing DOE to conduct two rulemaking cycles to revise and amend 

standards, and adopt standards for additional GSFLs, if warranted.

• On July 14, 2009, DOE completed the first rulemaking cycle by 

publishing a final rule amending existing standards for GSFLs and IRLs 

(hereafter “2009 Lamps Rule”). These standards required compliance 

starting in July 2012 (hereafter “July 2012 standards”). 74 FR 34080 

(July 14, 2009). 

• On September 14, 2011, DOE initiated the second rulemaking cycle 

by publishing a framework document. 
11

GSFL and IRL Rulemaking Schedule 

Milestone Date 

Notice of Public Meeting and Availability of Framework Document 14 September 2011 

Notice of Public Meeting and Availability of Preliminary Technical 

Support Document 28 February 2013 

Notice of Proposed Rulemaking (projected) March 2014 

Final Rule (projected) November 2014 

Compliance Date (projected) November 2017 

2012 2013 2014 2015 2016 2017 2018
12

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 
13

Scope of Coverage: GSFLs 

• The following GSFLs are currently covered by standards: 

Lamp Type Rated Wattage (Watt, W)

4-foot medium bipin (MBP)  25 W 

2-foot MBP U-shaped  25 W 

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

8-foot recessed double contact (RDC) high 

output (HO) All 

4-foot T5 miniature bipin (MiniBP) 

standard output (SO)  25 W 

4-foot T5 MiniBP HO  44 W 

• DOE assessed extending coverage to additional GSFLs using the 

following criteria: 

- If lamps meet the general description of “fluorescent lamp” and do not fall 

within exclusions specified in the “general service fluorescent lamp” definition;

- whether standards for lamps would result in significant energy savings; and 

- whether standards for lamps are technologically feasible and economically 

justified. 
14

Scope of Coverage: GSFLs 

• Assessment of additional GSFLs to include under scope of coverage: 

- DOE is not considering additional fluorescent lamp types. 

- DOE is considering additional wattages for the fluorescent lamp types already 

covered. 

Lamp Type Existing 

Wattage Limits

Wattage Limits Under 

Consideration

4-foot MBP  25 W No change 

2-foot MBP U-shaped  25 W No change 

8-foot SP slimline  52 W  49 W 

8-foot RDC HO All No change 

4-foot T5 MiniBP SO  26 W  25 W 

4-foot T5 MiniBP HO  49 W  44 W 
15

Scope of Coverage: GSFLs 

• The “general service fluorescent lamp” definition provides specific 

exemptions. 

• DOE found certain exemptions could be further clarified. 

• DOE is considering providing definitions for exemptions shown in bold 

above. 

• DOE is also considering a definition for “designed and marketed” 

when it is used for lighting products. 

General service fluorescent lamp means any fluorescent lamp which can be used to 

satisfy the majority of fluorescent lighting applications, but does not include any 

lamp designed and marketed for the following nongeneral application: 

 (1) Fluorescent lamps designed to promote plant growth; 

 (2) Fluorescent lamps specifically designed for cold temperature applications; 

 (3) Colored fluorescent lamps; 

 (4) Impact-resistant fluorescent lamps; 

 (5) Reflectorized or aperture lamps; 

 (6) Fluorescent lamps designed for use in reprographic equipment; 

 (7) Lamps primarily designed to produce radiation in the ultra-violet region of the 

 spectrum; and 

 (8) Lamps with a Color Rendering Index of 87 or greater. 

10 CFR 430.2 
16

Scope of Coverage: IRLs 

• DOE is considering IRLs that meet the following definition in the 

scope of coverage: 

• DOE is considering standards for IRLs with wattages between 40 and 

205 W. 

Incandescent reflector lamp (commonly referred to as a reflector lamp) means any 

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

current, which: is not colored or designed for rough or vibration service applications 

that contains an inner reflective coating on the outer bulb to direct the light; has an R, 

PAR, ER, BR, BPAR, or similar bulb shapes with an E26 medium screw base; has a rated 

voltage or voltage range that lies at least partially in the range of 115 and 130 volts; has 

a diameter that exceeds 2.25 inches; and has a rated wattage that is 40 watts or higher. 

10 CFR 430.2 
17

Issues for Comment 

Issue 1: GSFL Scope 

DOE is considering the following modifications to the minimum covered 

wattages of certain lamp types under the fluorescent lamp definition: 

changing the 8-foot SP slimline minimum wattage from 52 W to 49 W; 

changing the 4-foot MiniBP SO minimum wattage from 26 W to 25 W; and 

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

seeks comment on the modifications to GSFL wattage limits under 

consideration. 

Issue 2: GSFL Definitions 

DOE is considering defining the following terms related to the definition of 

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

“fluorescent lamp designed for use in reprographic equipment,” and “lamps 

primarily designed to produce radiation in the ultra-violet region of the 

spectrum.” DOE is also considering clarifying the terms “designed and 

marketed.” DOE requests comment on the definitions of terms related to 

GSFLs under consideration. 
18

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
19

Presentation Overview 

Energy Use; Life-Cycle Cost Analysis 

Shipments; National Impact Analysis 

5 

6 

2 Market & Technology; Screening Analysis 

3 Engineering Analysis 

1 Overview; Scope of Coverage 

7 Preliminary MIA; NOPR Analyses 

4 Product Price Determination 
20

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: 

1. Technological feasibility: incorporation in commercially available products or in 

working prototypes 

2. Practicability to manufacture, install, and service: mass production and reliable 

installation and servicing could be achieved on the scale necessary to serve the 

relevant market at the time the standard requires compliance 

3. Adverse impacts on product utility or product availability: significant adverse 

impact on the utility of the product to significant subgroups of consumers, or 

causing the unavailability of any covered product type with performance 

characteristics, features, sizes, capacities, and volumes that are substantially the 

same as products generally available in the United States at the time 

4. Adverse impacts on health or safety: significant adverse impacts on health or safety 
21

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. 

• DOE establishes separate energy conservation standards for each 

product class. 

• DOE is considering maintaining the same product class divisions as 

the 2009 Lamps Rule for GSFLs and IRLs. 
22

Product Classes: GSFLs 

• Correlated color temperature (CCT) 

– CCT is a measure of the perceived color of white light emitted from the lamp, 

and therefore lamps with different CCT values can offer different utility to 

consumers. 

– As spectral emission is modified to change CCT, efficacy can vary. DOE 

determined lamps with CCTs greater than 4,500 K show a decline in efficacy. 

– DOE is considering establishing separate product classes for lamps with CCT 

less than or equal to 4,500 K and greater than 4,500 K. 

• Physical constraints – lamp shape/length 

– Because consumers may need to modify building design/footprint to 

substitute lamps of different geometries for one another, lamp shape and 

length affect utility. 

– Lamp geometry also affects efficacy (e.g., 8-foot linear lamps generally have 

higher efficacies than 4-foot linear lamps; 4-foot MBP linear lamps are more 

efficacious than 2-foot MBP U-shaped lamps). 

– DOE is considering establishing separate product classes based on lamp shape 

and length. 
23

Product Classes: GSFLs 

• Lumen Package 

– Lumen package is the quantity of light that a lamp-and-ballast system provides 

to a consumer. 

– DOE observed that consumers tend to use systems with different lumen 

packages for different applications (e.g., high lumen output systems for highceiling applications). 

– To obtain a high lumen package, lamps are designed to operate with ballasts 

that run the lamps at high currents, which also decreases lamp efficacy. 

– DOE is considering establishing separate product classes based on standard 

output and high output lumen packages. 
24

Product Classes: GSFLs 

• DOE is considering the following product classes for GSFLs: 

Lamp Type CCT 

4-foot MBP 

≤ 4,500 K

> 4,500 K 

2-foot U-shaped 

≤ 4,500 K

> 4,500 K 

8-foot SP slimline 

≤ 4,500 K

> 4,500 K 

8-foot RDC HO 

≤ 4,500 K

> 4,500 K 

4-foot T5 MiniBP SO 

≤ 4,500 K

> 4,500 K 

4-foot T5 MiniBP HO 

≤ 4,500 K

> 4,500 K 
25

Product Classes: IRLs 

• Spectrum 

– Modified spectrum lamps provide a different type of light (utility) than 

standard spectrum by absorbing a portion of the visible light emission emitted 

by the filament. 

– The same technologies that modify the spectral emission of the lamp also 

decrease efficacy. 

– DOE is considering establishing separate product classes for modified 

spectrum lamps and standard spectrum lamps.

• Diameter 

– Smaller diameter lamps can be installed in smaller fixtures offering a unique 

utility to consumers. 

– Smaller diameter lamps have an inherently lower optical efficiency than larger 

diameter lamps with similar filaments and cannot utilize the same technology 

options as larger diameter lamps due to spatial constraints. 

– DOE is considering establishing separate product classes for lamps with a 

diameter of 2.5 inches or less and lamps with a diameter greater than 2.5 

inches. 
26

Product Classes: IRLs 

• Rated Voltage 

– A large number of consumers operate 130 V lamps at 120 V (normal line 

voltage), which results in longer lifetime, but reduced efficacy. 

– Existing DOE test procedures require lamps rated at 130 V be tested at 130 V 

and lamps rated at 120 V be tested at 120 V. Therefore, at a single efficacy 

level for all voltages, 130 V lamps would not require as efficient technologies 

as 120 V lamps. 

– Consequently, a single standard for both 120 V and 130 V lamps may make 

130 V lamps less costly to produce and cheaper to purchase resulting in a 

migration to 130 V lamps and increased energy consumption. 

– Hence, DOE is considering establishing separate product classes for lamps with 

a rated voltage less than 125 V and lamps with a rated voltage greater than or 

equal to 125 V. 
27

Spectrum Diameter (inches) Voltage

Standard

> 2.5

≥ 125 V

< 125 V

≤ 2.5

≥ 125 V

< 125 V

Modified

> 2.5

≥ 125 V

< 125 V

≤ 2.5

≥ 125 V

< 125 V

Product Classes: IRLs 

• DOE is considering the following product classes for IRLs: 
28

Issues for Comment 

Issue 5: Product Classes 

For GSFLs, DOE defined twelve product classes based on physical constraints 

of lamps (i.e., lamp shape and lamp length), lumen package (i.e., SO versus 

HO), and CCT. For IRLs, DOE defined eight product classes based on lamp 

diameter, voltage, and spectrum. DOE seeks comments on the product 

classes under consideration for GSFLs and IRLs. 
29

Technology Options: GSFLs 

• The following technology options can improve GSFL efficacy: 

– Highly Emissive Electrode Coatings 

– Higher Efficiency Lamp Fill Gas Composition 

– Higher Efficiency Phosphors 

– Glass Coatings 

– Higher Efficiency Diameter 

– Multi-Photon Phosphors 
30

Technology Options: IRLs 

– Higher Temperature Operation 

– Novel Filament Materials 

– Thinner Filaments 

– Efficient Filament Placement 

– Efficient Filament Orientation 

– Efficient Filament Coiling 

– Microcavity Filaments 

– Crystallite Filament Coatings 

– High Reflectance Filament 

Supports 

– Higher Efficiency Inert Fill Gas 

– Higher Pressure TungstenHalogen Lamps 

– Non-Tungsten-Halogen 

Regenerative Cycles 

• The following technology options can improve IRL efficacy: 

– Infrared Glass Coatings 

– Higher Efficiency Reflector Coatings 

– Permanent Infrared Reflector Coating 

Shroud 

– IR Phosphor Glass Coatings 

– UV Phosphor Glass Coatings 

– Corner Reflectors 

– Electron Simulated Luminescence 

– Integrally Ballasted Low Voltage 

Lamps 
31

Issue 6: Market and Technology Assessment 

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

and technology assessment for GSFLs and IRLs. 

Issue 4: Technology Options 

DOE requests comment on the technology options being considered for both 

GSFLs and IRLs and any additional options that should be included. In 

particular, for GSFLs DOE acknowledges that the market may be shifting away 

from less efficient diameters and requests comment on whether the high 

efficiency diameter technology option should be retained. 

Issues for Comment 
32

• DOE reviewed different technology options and assessed them using 

the following criteria: 

– Technological feasibility 

– Practicability to manufacture, install, and service 

– Adverse impacts on product utility or availability to customers 

– Adverse impacts on health or safety 

Screening Analysis 
33

Screening Analysis: GSFLs 

GSFL Technology Options 

Highly Emissive Electrode Coatings Glass Coatings 

Higher Efficiency Lamp Fill Gas 

Composition 

Higher Efficiency Lamp Diameter 

Higher Efficiency Phosphors Multi-Photon Phosphors 

• DOE determined that all of the GSFL technology options, except 

multi-photon phosphors, meet the four screening criteria. 
34

Screening Analysis: IRLs 

IRL Technology Options 

Higher Temperature Operation Higher Pressure Tungsten-Halogen Lamps 

Novel Filament Materials Non-Tungsten-Halogen Regenerative Cycles 

Thinner Filaments Infrared Glass Coatings

Efficient Filament Placement

Higher Efficiency Reflector Coatings 

(Higher Efficiency Gold Reflector Coatings)

Efficient Filament Orientation Permanent Infrared Reflector Coating Shroud

Efficient Filament Coiling IR Phosphor Glass Coatings

Microcavity Filaments UV Phosphor Glass Coatings

Crystallite Filament Coatings Corner Reflectors

High Reflectance Filament Supports Electron Simulated Luminescence

Higher Efficiency Inert Fill Gas Integrally Ballasted Low Voltage Lamps

• DOE determined that all of the IRL technology options, except those 

in red, meet the four screening criteria. 
35

Issue 7: Screening Analysis 

DOE invites comment on the technology options eliminated during the 

screening analysis. 

Issues for Comment 
36

Presentation Overview 

Energy Use; Life-Cycle Cost Analysis 

Shipments; National Impact Analysis 

5 

6 

2 Market & Technology; Screening Analysis 

3 Engineering Analysis 

1 Overview; Scope of Coverage 

7 Preliminary MIA; NOPR Analyses 

4 Product Price Determination 
37

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 

Equipment 

Classes 

Select Baseline 

Lamps 

Identify More 

Efficacious 

Substitutes 

Determine CSLs 

Scale Results 
38

Representative Product Classes: GSFLs 

• DOE chooses representative product classes to 

concentrate its analytical effort. 

– Representative product classes (in darker green) were chosen on 

a basis of high market volumes. 

Lamp Type CCT 

4-foot MBP 

≤ 4,500 K

> 4,500 K 

2-foot U-shaped 

≤ 4,500 K

> 4,500 K 

8-foot SP slimline 

≤ 4,500 K

> 4,500 K 

8-foot RDC HO 

≤ 4,500 K

> 4,500 K 

4-foot T5 MiniBP SO 

≤ 4,500 K

> 4,500 K 

4-foot T5 MiniBP HO 

≤ 4,500 K

> 4,500 K 

Select 

Representative 

Equipment 

Classes 

Select Baseline 

Lamps 

Identify More 

Efficacious 

Substitutes 

Determine CSLs 

Scale Results 
39

Issues for Comment: GSFLs 

Issue 8: Representative Product Classes

DOE requests comment on the representative product classes for GSFLs. 
40

Baseline Lamps: GSFLs 

• The baseline model typically represents the most 

common, least efficacious model on the market for each 

representative product class. 

Baseline 

Lamp

Lamp 

Diameter

Nominal 

Wattage

Rated 

Wattage

Rated 

Efficacy

Initial 

Light 

Output

Mean 

Light 

Output

Life 

W W lm/W lm lm hr

4-foot MBP T8 32 32.5 89.2 2,900 2,725 24,000**

8-foot SP 

slimline T8 59 60.1 98.2 5,900 5,430 24,000

8-foot RDC 

HO T8 86 84.0 95.2 8,000 7,600 18,000

4-foot T5 

MiniBP SO* T5 28 27.8 104.3 2,900 2,697 30,000

4-foot T5 

MiniBP HO* T5 54 53.8 92.9 5,000 4,850 24,000

Issue 9: Baseline Lamps 

DOE requests comment on the baseline units selected for 

GSFLs. 

* Reflects lamp operation at 35 °C. **Instant start lifetime. 

Select 

Representative 

Equipment 

Classes 

Select Baseline 

Lamps 

Identify More 

Efficacious 

Substitutes 

Determine CSLs 

Scale Results 
41

More Efficacious Substitutes: GSFLs 

• DOE selected more efficacious replacement lamps to 

measure potential energy-saving improvements. 

• More efficacious replacement lamps were identified by 

rated efficacy and characteristics similar to baseline lamps 

(e.g., rated life, color rendering index [CRI], and CCT) 

Product 

Class 

Lamp 

Diameter

Nominal 

Wattage

Rated 

Wattage

Rated 

Efficacy

Initial 

Light 

Output

Mean 

Light 

Output

Life 

(IS) 

Life 

(PS) 

W W lm/W lm lm hr hr

4-foot 

MBP 

T8* 32 32.5 89.2 2,900 2,725 24,000 40,000

T8 32 32.5 90.0 2,925 2,770 21,000 30,000

T8 25 26.6 93.0 2,475 2,350 24,000 40,000

T8 32 32.5 95.4 3,100 2,941 24,000 40,000

T8 28 28.4 96.0 2,725 2,560 24,000 40,000

*Row represents baseline lamp 

Select 

Representative 

Equipment 

Classes 

Select Baseline 

Lamps 

Identify More 

Efficacious 

Substitutes 

Determine CSLs 

Scale Results 
42

GSFL Systems 

• To assess the performance of GSFLs, DOE used a systems approach 

and paired lamps with ballasts, capturing real-world energy use and 

light output. 

• Using manufacturer feedback and information from the 2011 

Ballast Rule, DOE determined the most common fluorescent lamp 

ballasts by starting method and number of lamps operated to 

establish lamp-and-ballast system pairings. 

Lamp Type Ballast Type 

4-foot MBP 

2-lamp IS, electronic 

2-lamp PS, electronic 

4-lamp IS, electronic 

4-lamp PS, electronic 

2-lamp IS for residential use, electronic 

8-foot SP slimline 2-lamp IS, electronic 

8-foot RDC HO 2-lamp IS, electronic 

4-foot T5 MiniBP SO 2-lamp PS, electronic 

4-foot T5 MiniBP HO 2-lamp PS, electronic 
43

GSFL Systems 

• DOE selected lamp-and-ballast systems that maintained mean lumen 

output within 10 percent of the baseline system when possible. 

4-foot MBP Two-Lamp Instant Start Lamp-and-Ballast Replacement 

Efficacy 

Level

Lamp 

Diameter

Nominal 

Wattage

Rated 

Wattage

Rated 

Efficacy

Initial 

Lamp 

Light 

Output

Mean 

Lamp 

Light 

Output

Rated 

Life

Ballast 

Factor

System 

Input 

Power

BLE

System 

Mean 

Light 

Output

W W lm/W lm lm hr W lm

Baseline T8 32 32.5 89.2 2,900 2,725 24,000 0.88 55.2 92.4 4,796

CSL 1 T8 32 32.5 90.0 2,925 2,770 21,000 0.78 49.4 91.6 4,321

CSL 2 T8 25 26.6 93.0 2,475 2,350 24,000 0.88 46.3 92.0 4,136

CSL 2 T8 32 32.5 95.4 3,100 2,941 24,000 0.77 48.3 92.4 4,529

CSL 2 T8 28 28.4 96.0 2,725 2,560 24,000 0.87 48.8 92.7 4,454
44

Issues for Comment: GSFLs 

Issue 11: Lamp-and-Ballast Systems 

DOE requests comment on its methodology to identify representative lampand-ballast systems for GSFLs. DOE also requests comment on the 

characteristics of the replacement lamp-and-ballast systems analyzed, 

particularly the ballast luminous efficiency of each system and the BFs of the 

reduced wattage systems. 

Issue 10: More Efficacious Substitutes 

After choosing baseline lamps, DOE identified more efficacious substitutes. 

DOE chose more efficacious substitutes that were within 10 percent of the 

light output of the baseline lamp, when possible. DOE requests comment on 

the criteria used in selecting more efficacious substitute lamps, as well as the 

characteristics of the lamps selected. 

In particular, DOE requests comments on whether replacements of lamps 

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

mean lumen output of the replaced system (such as 25 W 4-foot MBP lamps 

replacing 32 W 4-foot MBP lamps) occur in practice. 
45

Candidate Standard Levels: GSFLs 

• DOE used commercially available lamps when possible 

and their associated catalog rated efficacies to determine 

CSLs. 

• To establish final minimum efficacy requirements for 

CSLs, DOE analyzed publicly available compliance data 

and determined whether any adjustments were 

necessary to the initial CSLs. 

• DOE only considered CSLs at which a full wattage version 

of the lamp type was available due to the limited utility 

of reduced wattage lamps. 

Select 

Representative 

Equipment 

Classes 

Select Baseline 

Lamps 

Identify More 

Efficacious 

Substitutes 

Determine CSLs 

Scale Results 
46

Candidate Standard Levels: T5 HO Product Class 

• DOE’s analysis indicated no commercially available full 

wattage, higher efficacy replacements for the 4-foot T5 

MiniBP HO baseline lamp (see chapter 5 and appendix 5A of 

the TSD for additional information on the model lamp). 

Issue 12: 4-foot T5 MiniBP HO Model Lamp 

DOE requests comment on the methodology and performance 

characteristics developed for this model lamp. In particular, DOE seeks 

information on the manufacturability and functionality of this lamp, as 

well as its expected efficacy when manufactured on a commercial scale. 

CSL

Lamp 

Diameter

Nominal 

Wattage

Rated 

Wattage

Rated 

Efficacy

Initial 

Lamp Light 

Output (at 

35 °C)

Mean Lamp 

Light Output 

(at 35 °C)

Rated Life

W W lm/W lm lm hr

Baseline T5 54 53.8 92.9 5,000 4,850 24,000 

1 T5 54 53.8 97.3 5,237 4,871 30,000

Select 

Representative 

Equipment 

Classes 

Select Baseline 

Lamps 

Identify More 

Efficacious 

Substitutes 

Determine CSLs 

Scale Results 
47

Candidate Standard Levels: GSFLs 

• The following are CSLs under consideration: 

CCT Lamp Type 

Candidate Standard Level 

lm/W

1 2

≤ 4,500 K 

4-foot MBP 90.0 93.0 

8-foot SP slimline 99.0 N/A 

8-foot RDC HO 97.0 N/A 

4-foot T5 MiniBP SO* 98.2 N/A 

4-foot T5 MiniBP HO* 86.2 N/A 

* Reflects lamp operation at 25 °C.

Select 

Representative 

Equipment 

Classes 

Select Baseline 

Lamps 

Identify More 

Efficacious 

Substitutes 

Determine CSLs 

Scale Results 
48

Issues for Comment: GSFLs 

Issue 13: Candidate Standard Levels 

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

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

options associated with the specific lamps being studied (e.g., grades of phosphor); 

(2) the ability of lamps across wattages to comply with the standard level of a given 

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

consideration for GSFLs. In particular, DOE seeks comment on the appropriateness of 

developing a CSL 1 for the 4-foot T5 MiniBP HO product class based on the model 

lamp. 

Issue 14: Compliance Requirements 

DOE based its engineering analysis on performance data presented in manufacturer 

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

analyzed the publicly available compliance data and evaluated whether any 

adjustments were necessary to account for the compliance efficacies of 

representative units and/or equivalent lamps. DOE invites comment on whether 

additional adjustments to the CSLs are needed to account for compliance 

requirements. 
49

Scaling Results: GSFLs 

• DOE scaled CSLs to product classes not directly 

analyzed. 

• Scaling factors for GSFLs account for differences in 

efficacy due to: higher CCT, shape (i.e., U-shaped). 

Analyzed Not Analyzed Scaling Factor 

Shape 4-foot MBP 2-foot U-shaped 2% decrease 

Higher CCT ≤ 4,500 K > 4,500 K 2% decrease 

Select 

Representative 

Equipment 

Classes 

Select Baseline 

Lamps 

Identify More 

Efficacious 

Substitutes 

Determine CSLs 

Scale Results 
50

Issues for Comment: GSFLs 

Issue 15: Scaling between Product Classes 

DOE extrapolated its analysis from representative product classes to those not 

directly analyzed by calculating appropriate scaling factors. DOE requests 

comment on the methodology and results of its scaling analysis. 

Issue 16: Engineering Analysis 

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

engineering analyses. 
51

Representative Product Classes: IRLs 

• DOE chooses representative product classes to 

concentrate its analytical effort. 

– Representative product classes (in darker green) were chosen 

on a basis of high market volumes. 

Spectrum Diameter (inches) Voltage

Standard

> 2.5 ≥ 125 V

< 125 V

≤ 2.5 ≥ 125 V

< 125 V

Modified

> 2.5 ≥ 125 V

< 125 V

≤ 2.5 ≥ 125 V

< 125 V

Issue 8: Representative Product Classes

DOE requests comment on the representative product classes 

for IRLs. 

Select 

Representative 

Equipment 

Classes 

Select Baseline 

Lamps 

Identify More 

Efficacious 

Substitutes 

Determine CSLs 

Scale Results 
52

Baseline Lamps: IRLs 

• The baseline model typically represents the most 

common, least efficacious model on the market for 

each representative product class. 

– Because there is more than one common, low efficacy product, 

DOE is considering analyzing two baseline models. 

Baseline Lamp Design Option 

Initial Light 

Output 

lm

Efficacy 

lm/W 

Lamp Lifetime

hr

60 W PAR38 

Improved 

Halogen* 1,070 17.8 1,500

60 W PAR38 HIR 1,100 18.3 3,000 

*Halogen lamp with an improved reflector. 

Issue 9: Baseline Lamps 

DOE requests comment on the baseline units selected for IRLs. 

In particular, DOE requests comment on its selection of two 

baseline lamps with similar efficacies, but distinct technologies 

and lifetimes. 

Select 

Representative 

Equipment 

Classes 

Select Baseline 

Lamps 

Identify More 

Efficacious 

Substitutes 

Determine CSLs 

Scale Results 
53

More Efficacious Substitutes: IRLs 

• DOE selected more efficacious replacement lamps to 

measure potential energy-saving improvements. 

• More efficacious replacement lamps were identified by 

lumen output within 10 percent of the baseline lamp 

when possible. 

Substitute 

Lamp 

Design Option

Initial Light 

Output 

lm

Efficacy 

lm/W 

Lamp Lifetime

hr

55 W PAR38 Improved HIR* 1,100 20.0 4,400

*HIR lamp with an improved reflector 

Select 

Representative 

Equipment 

Classes 

Select Baseline 

Lamps 

Identify More 

Efficacious 

Substitutes 

Determine CSLs 

Scale Results 
54

Issues for Comment: IRLs 

Issue 10: More Efficacious Substitutes 

After choosing baseline lamps, DOE identified more efficacious substitutes. 

DOE chose more efficacious substitutes that were within 10 percent of the 

light output of the baseline lamp, when possible. DOE requests comment on 

the criteria used in selecting more efficacious substitute lamps, as well as the 

characteristics of the lamps selected. 
55

Candidate Standard Levels: IRLs 

• DOE used an equation-based approach to characterize a 

continuous relationship between lamp input power and 

lamp efficacy across wattages. 

• DOE used commercially available lamps and their 

associated catalog rated efficacies to determine CSLs. 

• To establish final minimum efficacy requirements for 

CSLs, DOE analyzed publicly available compliance data 

and determined whether any adjustments were 

necessary to the initial CSLs. 

• The following are CSLs under consideration: 

Efficacy Level Efficacy Requirement 

lm/W 

CSL 1 6.2P0.27

P = wattage

Select 

Representative 

Equipment 

Classes 

Select Baseline 

Lamps 

Identify More 

Efficacious 

Substitutes 

Determine CSLs 

Scale Results 
56

Issues for Comment: IRLs 

Issue 13: Candidate Standard Levels 

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

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

the design options associated with the specific lamps being studied (e.g., the use 

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

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

comment on the CSLs under consideration for IRLs. 

Issue 14: Compliance Requirements 

DOE based its engineering analysis on performance data presented in 

manufacturer catalogs. To establish the final minimum efficacy requirements for 

each CSL, DOE analyzed the publicly available compliance data and evaluated 

whether any adjustments were necessary to account for the compliance 

efficacies of representative units and/or equivalent lamps. DOE invites comment 

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

compliance requirements. 
57

Scaling Results: IRLs 

• DOE scaled CSLs to product classes not directly 

analyzed. 

• Scaling factors for IRLs account for difference in efficacy 

due to: spectrum, diameter, voltage. 

Analyzed Not Analyzed Scaling Factor 

Spectrum Standard Modified 15% decrease 

Diameter > 2.5 Inches ≤ 2.5 Inches 15.5% decrease

Voltage < 125 Volts ≥ 125 Volts 15% increase 

Select 

Representative 

Equipment 

Classes 

Select Baseline 

Lamps 

Identify More 

Efficacious 

Substitutes 

Determine CSLs 

Scale Results 
58

Issues for Comment: IRLs 

Issue 15: Scaling between Product Classes 

DOE extrapolated its analysis from representative product classes to those not 

directly analyzed by calculating appropriate scaling factors. DOE requests 

comment on the methodology and results of its scaling analysis. Specifically, 

DOE requests comment on the use of double-ended versus singled-ended 

burners in large and small diameter lamps. Furthermore, DOE was unable to 

identify the specific Underwriters Laboratories (UL) safety standard mentioned 

by NEMA that requires a minimum distance between the halogen capsule and 

the glass envelope. DOE requests additional information on this UL safety 

standard, including the standard number and minimum required distance. 

Issue 16: Engineering Analysis 

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

and IRL engineering analyses. 
59

Presentation Overview 

Energy Use; Life-Cycle Cost Analysis 

Shipments; National Impact Analysis 

5 

6 

2 Market & Technology; Screening Analysis 

3 Engineering Analysis 

1 Overview; Scope of Coverage 

7 Preliminary MIA; NOPR Analyses 

4 Product Price Determination 
60

Product Price Determination 

• DOE estimated the end-user prices of GSFLs and IRLs directly, rather 

than developing manufacturing selling prices, because these lamps 

are difficult to reverse-engineer (i.e., not easily disassembled).

• DOE observed a range of end-user prices paid for a lamp, depending 

on the distribution channel through which it is purchased. 

• DOE developed three sets of discounts from blue-book prices to 

represent lamp prices at the following levels for both GSFLs and IRLs: 

– Low (State procurement) 

– Medium (large distributors, including do-it-yourself stores) 

– High (internet retailers) 

• DOE used price data gathered after the July 2012 standards required 

compliance. 

• DOE used information from the 2011 Ballast Rule to determine enduser prices for fluorescent lamp ballasts. 
61

Issue 18: GSFL Ballast Prices 

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

pricing for the fixed light output ballast replacements. DOE requests comment 

on the ballast prices developed, specifically the adjusted prices for dimming 

ballasts and the assumption that ballast pricing does not change between low 

and normal ballast factor ballasts. 

Issue 17: Product Price Determination 

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

prices paid for a lamp, depending on the distribution channel through which it 

was purchased. In line with its observation of public pricing, DOE developed 

three sets of GSFL discounts and three sets of IRL discounts from the blue 

book prices, representing low (State procurement), medium (large 

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

prices. DOE invites comment on its methodology and results for estimating 

end-user prices for GSFLs and IRLs. 

Issues for Comment 
62

Presentation Overview 

Energy Use; Life-Cycle Cost Analysis 

Shipments; National Impact Analysis 

5 

6 

2 Market & Technology; Screening Analysis 

3 Engineering Analysis 

1 Overview; Scope of Coverage 

7 Preliminary MIA; NOPR Analyses 

4 Product Price Determination 
63

Energy Use Characterization 

• Annual energy consumption (kWh) 

 = system input power x annual operating hours 

• DOE used various sources to determine annual operating hours: 

- 2010 U.S. Lighting Market Characterization (LMC), 2011

- Energy Information Administration (EIA) Commercial Building Energy 

Consumption Survey (CBECS), 2003

- EIA Residential Energy Consumption Survey (RECS), 2009

- EIA Manufacturing Energy Consumption Survey (MECS), 2006

• DOE’s assumed annual operating hours capture variation across 

census divisions and large states, building types, and lighting 

applications. 

Sector 

GSFL Average Annual 

Operation 

(hrs/yr) 

IRL Average Annual 

Operation 

(hrs/yr) 

Commercial 4,058 4,496 

Residential 648 761

Industrial 4,585 N/A 
64

Issue 23: Operating Profiles for Energy Use Characterization 

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

DOE developed annual operating hours by sector using data published in the 

2010 U.S. Lighting Market Characterization. DOE applied average annual 

operating hours based on each sector to calculate energy use. DOE welcomes 

comment on the end-use operating profiles for the lamp types covered under 

this rulemaking. 

Issues for Comment 
65

Energy Use Characterization: Lighting Controls 

• In a sensitivity analysis, DOE assessed impacts on life-cycle costs and 

payback periods for GSFLs and IRLs when operated on dimming systems. 

• To develop annual energy consumption for these dimming systems, DOE 

used the system input power ratings as a result of dimming and annual 

operating hours. 

• DOE made certain key assumptions to determine system input power 

ratings for dimmed GSFLs and IRLs. 

– GSFLs: On average a 33% lumen reduction (lamp-and-ballast); associated 

system input power reduction calculated based on characteristics of dimming 

ballasts analyzed; no change in lamp lifetime. 

– IRLs: On average a 25% lumen reduction, corresponding to a 20% reduction in 

wattage, and a lifetime multiplier of 3.94. 

• For IRLs, DOE also assessed a scenario in which a certain percentage of the 

population used dimmers. DOE assumed this to be 29% for the residential 

sector and 5% for the commercial sector. 
66

Issues for Comment 

Issue 20: Dimmed GSFL Systems 

DOE requests comments on the dimmed fluorescent systems analyzed, in 

particular the lamp types included in the dimming scenarios and the 

assumption that light output and input power scale linearly for dimming 

systems. 

Issue 22: Lighting Controls Performance Characteristics 

DOE requests any comments pertaining to the methodology used to account 

for lighting controls. Specifically, DOE requests comment on the assumption 

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

the average reduction of lumen output for IRLs is 25 percent. DOE also invites 

comment on the assumption that 29 percent of halogen IRLs operate on 

dimmers in the residential sector and 5.0 percent of halogen IRLs operate on 

dimmers in the commercial sector. 
67

LCC and PBP 

• The life-cycle cost (LCC) analysis provides an economic evaluation 

from the end-user perspective. 

• LCC equals end-user price plus the sum of annual operating costs 

discounted to a particular base year. 

• If the lamp has remaining useful life at the end of the analysis 

period, a residual value is subtracted from the LCC. 

• Results are expressed as LCC savings (baseline minus the standard 

level).

• Simple payback period (PBP) is also calculated and reported in this 

analysis. 

LCC Results First Cost 

(End-User Price + Installation Cost) 

Operating Expenses 

Convert to 

Present 

Value 
68

LCC and PBP: Inputs 

• DOE derived electricity prices and projections from 2011 EIA form 861 

data and EIA Annual Energy Outlook 2012 (AEO 2012).

• DOE based installation costs on labor time and labor rate data from 

the 2011 Ballast Rule, RS Means, and the U.S. Bureau of Labor 

Statistics. 

• DOE assumed ballast lifetimes of 49,054 hours (commercial & 

industrial) and 9,723 hours (residential).

– Translates to approximately 12 years (commercial), 11 years (industrial), and 15 

years (residential) 

– Consistent with the 2011 Ballast Rule and available “life measure” studies 

• DOE calculated weighted-average discount rates from estimates for 

cost of capital (commercial & industrial) and estimates of interest 

(“finance cost”) to purchase residential products. 

– Commercial = 5.0% 

– Industrial = 5.6% 

– Residential = 5.2% 
69

Issues for Comment 

Issue 25: Sales Tax in the LCC Analysis 

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

sales tax values for the 13 divisions and large states weighted by the percent of 

the total population in each division or large state. DOE is considering 

weighting the sales tax for the residential and commercial sectors based on the 

prevalence of residential or commercial buildings in each census division using 

RECS and CBECS data, respectively. This may create a specific sales tax for each 

market sector due to the likelihood of different types of buildings to appear in 

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

for the NOPR. 
70

LCC and PBP: Lamp Purchasing Events 

• Event I: Lamp Failure 

– The lamp fails and must be replaced. 

• Event II: Ballast Failure (GSFLs only) 

– The failure of the installed ballast triggers a lamp and ballast purchase. 

• Event III: New Construction and Renovation 

– New fixture installations where the lighting design can be completely new or 

changed. 

Issue 24: Residential GSFL LCC Analysis 

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

GSFL consumers preserve their lamps when replacing a ballast and utilize the 

same lamps on the new ballast. This allows the lamps to live for their entire 

rated lifetime and obtains an upper bound for LCC savings in the residential 

sector. DOE requests comment on how likely consumers are to exhibit lamp 

preserving behavior. 
71

LCC and PBP: GSFL Results 

Baseline Candidate Standard 

Level

LCC Savings

Event I: Lamp Failure 

Event II: Ballast Failure and 

Event III: New Construction 

and Renovation 

4-Foot MBP, 2-Lamp, Instant 

Start

CSL 1 NR* 6.06 to 8.03 

CSL 2 4.81 to 9.53 4.86 to 9.35 

4-Foot MBP, 4-Lamp, Instant 

Start

CSL 1 NR 10.89 to 14.44 

CSL 2 9.12 to 18.00 5.45 to 17.78 

4-Foot MBP, 2-Lamp, Instant 

Start, Residential Sector

CSL 1 NR 1.69 

CSL 2 4.15 to 4.57 -3.62 to 0.68 

• Consumers purchasing higher efficacy 4-foot MBP lamps for use on 

instant start ballasts would experience positive LCC savings, except 

for consumers operating these systems in the residential sector. 

*NR: No lamp replacement for this event at the specified CSL 
72

LCC and PBP: GSFL Results 

Baseline Candidate Standard 

Level

LCC Savings

Event I: Lamp Failure 

Event II: Ballast Failure and 

Event III: New Construction 

and Renovation 

4-Foot MBP, 2-Lamp, 

Programmed Start

CSL 1 NR -6.00 to -5.55 

CSL 2 9.49 to 19.00 -6.04 to 19.00 

4-Foot MBP, 4-Lamp, 

Programmed Start

CSL 1 NR -8.78 to -8.31 

CSL 2 18.98 to 37.94 -11.12 to 37.94 

*NR: No lamp replacement for this event at the specified CSL 

• Consumers purchasing higher efficacy 4-foot MBP lamps for use on 

programmed start ballasts would experience positive LCC savings only 

for reduced wattage lamp replacements. 
73

LCC and PBP: GSFL Results 

Baseline Candidate Standard 

Level

LCC Savings

Event I: Lamp Failure 

Event II: Ballast Failure and 

Event III: New Construction 

and Renovation 

4-Foot T5 MiniBP HO CSL 1 9.26 to 22.33 0.91 to 22.33 

4-Foot T5 MiniBP SO CSL 1 0.64 to 12.43 2.80 to 17.82 

8-Foot SP Slimline CSL 1 1.47 to 10.78 0.21 to 15.51 

8-Foot RDC HO CSL 1 -5.01 -5.01 

• Consumers purchasing higher efficacy 4-foot T5 MiniBP HO, 4-foot T5 

MiniBP SO lamps, or 8-foot SP slimline lamps would experience 

positive LCC savings. 

• Consumers purchasing 8-foot RDC HO lamps would experience 

negative LCC savings. 
74

LCC and PBP: IRL Results 

• Consumers purchasing higher efficacy improved HIR lamps would 

experience positive LCC savings relative to the 1,500-hour improved 

halogen baseline lamp. 

• Consumers purchasing higher efficacy improved HIR lamps would 

experience negative savings relative to the 3,000-hour HIR baseline 

lamp. 

Baseline Candidate Standard Level

LCC Savings

Event I: Lamp Failure or Event III: 

New Construction and Renovation

1,500 Hour 60 W Improved Halogen CSL 1 4.03 to 5.73 

3,000 Hour 60 W HIR CSL 1 -1.13 to -0.22 
75

Issue 26: Spacing Adjustments in the LCC Analysis 

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

building space is not constrained to any previous configuration. However, 

because DOE’s higher efficacy replacements generally maintain lumen output 

within 10 percent of the baseline system, DOE does not assume that spacing is 

changed in the primary LCC results for the new construction and renovation 

replacement event. DOE requests comment on the likelihood that fixture 

spacing is adjusted during new construction and renovation if systems 

considered for installation all have similar lumen outputs. 

Issue 27: LCC Analysis 

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

for GSFLs and IRLs. 

Issues for Comment 
76

Presentation Overview 

Energy Use; Life-Cycle Cost Analysis 

Shipments; National Impact Analysis 

5 

6 

2 Market & Technology; Screening Analysis 

3 Engineering Analysis 

1 Overview; Scope of Coverage 

7 Preliminary MIA; NOPR Analyses 

4 Product Price Determination 
77

Shipments and National Impact Analyses 

• Shipments Analysis 

– Estimate GSFL-IRL shipments over the 30-year analysis period 

• National Impact Analysis 

– Estimate the National Energy Savings (NES) from various candidate standards 

cases over the analysis period 

– Estimate the Net Present Value (NPV) of the various candidate standards cases 

to GSFL-IRL consumers over the analysis period 

CSL 1 Max CSL 

NES 

Full Fuel 

Cycle 

NPV 3% 

(2011$) 

NPV 7% 

(2011$) 

NES 

Full Fuel 

Cycle 

NPV 3% 

(2011$) 

NPV 7% 

(2011$) 

GSFL 0.94 Quads $1.95 B $0.83 B 4.5 Quads $22.9 B $12.8 B 

IRL 0.14 Quads $0.04 B -$0.18 B 0.14 Quads $0.04 B -$0.18 B 

Total 1.08 Quads $2.0 B $0.66 B 4.7 Quads $22.9 B $12.6 B
78

Shipments Analysis: Candidate Standards Cases 

Product Class Grouping 

Base case 

(No new 

standards) 

All CSL1 

Standard 

Max CSL 

Standard 

GSFLs

4-foot MBP Baseline CSL1 CSL2 

8-foot SP slimline Baseline CSL1 CSL1 

8-foot RDC HO Baseline CSL1 CSL1 

4-foot T5, MiniBP SO Baseline CSL1 CSL1 

4-foot T5, MiniBP HO Baseline CSL1 CSL1 

IRLs

Standard Spectrum, >2.5 

inches, <125 V Baseline CSL1 CSL1 

• DOE modeled shipments for aggregated groupings of the product 

classes. 
79

Shipments Analysis: Main Elements of the Model 

• Lighting demand module 

– Estimates the demand for GSFL and IRL lighting for each year of the analysis 

period 

• Consumer choice module 

– Assigns shipments to product classes and efficacy levels based on consumer 

sensitivities to first costs and operation and maintenance costs 

• Price learning module 

– Projects future lamp and ballast prices based on historic price trends 
80

Shipments Analysis 

Product 

Shipments 

Engineering 

Analysis 

Product Price 

Determination 

Energy Use & End 

Use Load 

Characterization 

Lighting 

Demand 

Module 

Consumer 

Choice 

Module 

Price 

Learning 

• Shipments (and market shares) of product class groupings and 

technology options were projected for the period 2017-2046.

Inputs 

Shipment model process 

Outputs 
81

LED Incursion on GSFL and IRL Lumen Capacity 

Shipments Analysis: LED Incursion 

• LEDs are projected to erode the total lumen capacity satisfied both 

by GSFLs and IRLs. This is treated as an exogenous envelope on the 

shipments. 
82

0%

20%

40%

60%

80%

100%

0 10 20 30 40

Percent Diffusion

Year Since Introduction

Bass Diffusion Curve

O&Mj(year n-1) 

First Costj(year n-1)

Projected Market Shares in year n 

Feedback to reassign market share, because of 

Bass curve limitation of the adoption rate 

Projected Shipments in year n 

 $1.00

 $5.75 0.00

0.50

1.00

 $1.00

 $2.75

 $4.25

 $5.75

 $7.25

 $8.75

O&M Cost ($/klm)

Probability

First Cost ($/klm)

Logit Probability

Shipments Analysis: Consumer Choice Module 

• The Consumer Choice Module projects market shares based on 

consumer sensitivity to price and to operating and maintenance 

costs, computed per kilo-lumen (klm).

Market shares are also constrained by the 

adoption rate of new technology. 
83

Shipments Analysis: Price Learning 

• Systematic decreases in manufacturing costs due to production 

experience are accounted for by incorporating price learning 

curves.* 

*Price learning is not applied to the cost of a GSFL associated with rare earth 

elements. Rare earth price uncertainty is treated in a separate analysis. 

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

5.00

0 2000 4000 6000 8000 10000 12000 14000

Value per unit (2005$)

Cumulative Shipments (millions)

Learning Curve for GSFLs 
84

Shipments Analysis: Product Switching 

Product Class Grouping Ballast Type 

4-foot MBP 

4-foot MBP T12 Com/Ind

4-foot MBP T8 IS Com/Ind

4-foot MBP T8 PS Com/Ind* 

4-foot MBP T12 Res 

4-foot MBP T8 Res 

8-foot SP Slimline 

8-foot Single Pin T12 

8-foot Single Pin T8 

8-foot RDC HO 

8-foot RDC HO T12 

8-foot RDC HO T8 

T5 MiniBP SO 4-foot T5 SO 

T5 MiniBP HO 4-foot T5 HO 

IRL 

Technology

Options 

Baseline 1

Baseline 2

CSL 1 

• The product turnover part of the shipments model, which is based on 

installed stock, considers various possibilities for product substitution. 

*

Switching to 

programmed start 

T8 ballasts is driven 

by the adoption of 

controls outside the 

consumer choice 

model.
85

Issue 3: Market Trends 

DOE believes that the overall fluorescent lamp market will increasingly shift 

away from T12 products due to the July 2012 lamp standards and the 

November 2014 ballast standards. DOE requests comment on the future 

availability of standards compliant T12 lamps. For IRLs, DOE noticed limited 

product offerings for modified spectrum lamps, lamps with diameters less than 

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

on the future availability of these products, or any combination thereof. 

Issues for Comment 

Issue 28: T5s in the Residential Market 

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

because they appear to be a negligible fraction of the current residential 

market. In the absence of data to the contrary, DOE has assumed that T5 lamps 

will remain an unimportant fraction of the residential market throughout the 

analysis period. DOE seeks comment on the validity and appropriateness of this 

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

increase the price of T8 lamps relative to T5 lamps. 
86

Shipments Analysis: Product Turnover 

• The turnover model acts on shipments of Ballast Types for GSFLs and 

shipments of Technology Options for IRLs. 
87

Shipments Analysis: GSFL Relamping 

Ballast Relamping Probability 

• Ballasts are populated with new lamps based on ballast age and the 

probability curves below 

New ballasts always 

accompanied by new 

lamps 

Peak for each curve occurs at 

average lifetime of a lamp 

installed on a given ballast 
88

Shipments Analysis: GSFL Market Shares 

• Once the GSFL shipments are determined for each product class 

grouping, the consumer choice model is run again to allocate them 

among the CSLs. 

Product Class 

Grouping CSL Nominal Wattage Efficacy (rated)

Market Share 

2017

Base Case 

Market Share 

2046

Base Case 

T8

4-ft MBP

Baseline 32 89.2 0.31 0.30 

CSL1 32 90.0 0.29 0.28 

CSL2

32 95.4 0.14 0.14 

28 96.0 0.17 0.17 

25 93.0 0.10 0.11 

T8

8-ft Slimline

Baseline 59 98.2 0.29 0.28 

CSL1

59 99.0 0.23 0.23 

54 105.6 0.30 0.30 

50 108.0 0.19 0.20 

T8

8-ft HO

Baseline 86 95.2 0.59 0.59 

CSL1 86 97.6 0.41 0.41 

T5 SO

Baseline 28 104.3 0.25 0.25 

CSL1

28 109.7 0.28 0.25 

26 111.5 0.21 0.23 

25 116.0 0.26 0.28 

T5 HO

Baseline 54 92.9 0.36 0.34 

CSL1

54 97.3 0.26 0.25 

50 100.0 0.20 0.21 

47 102.1 0.17 0.20 
89

Shipments Analysis: Reference Case 

Shipments over the analysis period in the Reference case for all product class groupings 

Shipments decline 

because of LED incursion 

IRL 
90

National Impact Analysis: NIA Process 

Shipments 

Analysis 

Life-Cycle Cost 

Analysis 

National Energy 

Savings (Quads) 

National Net 

Present Value 

(Billions 2011 $) 

National 

Energy 

Savings 

National 

Consumer 

Economic 

Impacts 

• NES and NPV are calculated for products shipped from 2017-2046 

(including energy savings realized in later years by those products). 

Inputs 

NIA process 

Outputs 
91

National Impact Analysis 

NES(y) (y)(AEC AEC (y)) RF μ(y)  base  std 

Where: 

NES(y) = National Energy Saving in year y (quads), and 

AECbase(y) = base case annual national energy consumption, considering the full 

fuel cycle, for all product classes combined in year y (quads), and 

AECstd(y) = standards case annual national energy consumption, considering the 

full fuel cycle, for all product classes combined in year y (quads), and 

RF = rebound rate factor = 1-rebound rate 

μ(y) = full fuel cycle multiplier

• National energy primary energy savings is calculated using the 

following equation: 
92

National Impact Analysis 

 PVCPVSNPV

Where: 

NPV = National net present value (2011$) 

PVS = present value savings in operating cost (including costs for 

energy, repair, and maintenance in 2011$), and 

PVC = present value of increase in total installed cost (including costs 

for equipment and installation in 2011$)

• National Net Present Value is calculated using the following equation. 

NPV was calculated using 3% and 7% discount rates: 
93

National Impact Analysis: IRL Reference Case 

NES 

Full Fuel Cycle

NPV 3% 

(2011$) 

NPV 7% 

(2011$)

CSL 1 0.14 Quads $0.04 B $ -0.18 B

The reference case represents DOE’s best estimate of the impact of various CSLs.
94

National Impact Analysis: GSFL Reference Case 

Annual energy savings and cumulative NPV for reference case. 

NES 

Full Fuel Cycle

NPV 3% 

(2011$) 

NPV 7% 

(2011$)

CSL 1 0.9 Quads $1.9 B $ 0.8 B

Max CSL 4.5 Quads $ 22.9 B $ 12.8 B
95

Alternative Analyses 

• DOE conducted alternative analyses to gauge the importance of 

various assumptions on the shipments and NIA. 

Shipments Scenarios Variables Best Estimate Alternatives 

Alternative technology CSL 1 IRLs are all 55-watt lamps 

with 4400 hour lifetime. 

Short life: Two 60 W lamps 

modeled to meet CSL 1 with 

lifetimes of 1,046 and 2,564 hours.

Lighting controls penetration

Growth of commercial controls 

determined by today’s building 

codes.

Fixed: Constant controls 

penetration at today’s level

LED market incursion Increasing LED incursion. No LED: No additional LED 

incursion

Rare earth oxide prices Prices fixed at October 2012 

levels.

High: 2011 peak price 

Low: 2006 – 2009 average price 
96

Alternative Analyses: IRL Short Life 

• This scenario assumes there are two lamps that meet CSL 1, one 

with a lamp life of 1046 hours, the other with a lamp life of 2564 

hours.

Change from Reference Case 

NES Full 

Fuel Cycle 

NPV 

(3%) 

NPV 

(7%) 

CSL 1 -60% -970% -90%

Shipments Projections 
97

Shipments Projections 

• This scenario assumes the penetration of controls remain at fixed 

levels. 

Change from Reference Case 

NES Full 

Fuel Cycle 

NPV 

(3%) 

NPV 

(7%) 

IRL CSL 1 0% 1% 0%

GSFL 

CSL 1 16% 37% 41%

Max CSL 17% 17% 15%

Alternative Analyses: Fixed Controls 
98

Issue 21: Lighting Controls Market Penetration 

The energy savings projected in this rulemaking depends on the market 

penetration of lighting system controls. In the NIA analysis, DOE has assumed 

75 percent compliance with State building code requirements for lighting 

controls in commercial buildings. DOE is considering adding high (100 percent) 

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

phase. DOE seeks relevant data on compliance rates with current State 

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

lighting system controls in the residential sector remains fixed at its current 

level. DOE requests comment on the validity and appropriateness of this 

assumption. 

Issues for Comment 
99

Shipments Projections 

Alternative Analyses: No LED 

• This scenario assumes that the fraction of LED in the market remains 

at 2012 levels. 

Change from Reference Case 

NES Full 

Fuel Cycle 

NPV 

(3%) 

NPV 

(7%) 

IRL CSL 1 400% -110% -240%

GSFL 

CSL 1 90% 95% 70%

Max CSL 70% 55% 40%
100

Alternative Analyses: REO Prices 

Rare Earth Oxide Price indices used in alternative analysis 

(October 2012) 

Change from Reference Case 

NES Full 

Fuel Cycle 

NPV 

(3%) 

NPV 

(7%) 

REO Low 

CSL 1 0.3% -0.2% -0.3% 

Max CSL 2% 0.5% 0.1% 

REO High 

CSL 1 -1% 1% 2%

Max CSL -5% -1.5% -0.4% 
101

Issue 19: Rare Earth Phosphor Availability 

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

phosphor prices due to decreased supply on the cost of lamps covered under 

this rulemaking as well the extent of the limited worldwide resources of rare 

earth phosphors and the impact of this shortage on the feasibility of meeting 

higher standards. 

Issues for Comment 
102

NIA 

Scenarios 

Variables

Best Estimate Alternatives Change from 

Reference Case, CSL 1

Change from 

Reference Case, Max 

CSL 

AEO Growth: 

Affects only 

NPV

Ref: Electricity 

prices follow 

AEO’s reference 

economic growth 

projections.

AEO Low: Electricity prices 

follow AEO’s low economic 

growth projections.

NPV NPV 

3% discount -7% 3% discount -3%

7% discount -9% 7% discount -2%

AEO High: Electricity prices 

follow AEO’s high 

economic growth 

projections.

3% discount 9% 3% discount 3%

7% discount 11% 7% discount 3%

Rebound

Rate:

Affects only 

NES

Ref: Rebound 

rates for 

residential and 

commercial 

sectors set to 0%

Framework: Residential 

8.5%, Commercial 1%

NES NES 

-2% -2%

NEMS: Residential and 

Commercial 15% -15% -15%

Alternative Analyses 

• DOE also performed alternative analyses to assess uncertainty arising from 

the AEO economic growth rate and the rebound rate. These affect the NIA 

and not the shipments. 
103

Issue 29: Shipments and NIA 

DOE requests comments on the overall methodology used to develop 

shipment forecasts and estimate national energy savings and the net present 

value of those savings. In addition, DOE requests comment on current 

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

Issues for Comment 

DOE invites comments and recommendations on any other aspects related to 

the National Impact Analysis. 
104

Presentation Overview 

Energy Use; Life-Cycle Cost Analysis 

Shipments; National Impact Analysis 

5 

6 

2 Market & Technology; Screening Analysis 

3 Engineering Analysis 

1 Overview; Scope of Coverage 

7 Preliminary MIA; NOPR Analyses 

4 Product Price Determination 
105

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). 
106

Preliminary MIA: Key Issues 

• Rare Earth Materials 

– GSFL standards could potentially increase the demand for rare earth 

phosphors and adversely impact domestic production of GSFLs. 

– Majority of rare earth phosphor mines are in China, which imposes a quota on 

raw rare earth material exports, leaving manufacturers outside of China at a 

potential disadvantage. 

• Unknown Impacts of the July 2012 Standards 

– Amended standards may be developed without full knowledge of the impacts 

of the July 2012 standards on sales, shipments, and consumer preferences. 

• Testing Burden 

– Regulation of additional products would add to the existing test burden 

associated with standards for GSFLs and IRLs. 
107

Preliminary MIA: Key Issues 

• Technology Shift 

– Amended standards could potentially increase the prices of GSFLs and IRLs 

and accelerate the existing technological shift away from these products to 

alternatives, such as LEDs. 

• Product Innovation 

– Amended GSFL and IRL standards could potentially divert manufacturers’ 

resources from R&D in more efficient lighting technologies. 

• Impact on Residential Sector 

– The residential sector does not have long operating hours and amended 

standards may lead residential consumers of IRLs to opt for cheaper and less 

efficacious IRLs with shorter lifetimes. 

– Amended standards may force residential consumers of GSFLs to switch entire 

systems for minimal energy savings. 
108

Issues for Comment 

Issue 32: Manufacturer Subgroup Analysis 

DOE considers the impacts on certain manufacturer subgroups that have 

different cost structures or operate within different regulatory frameworks in 

the NOPR stage. DOE requests feedback on subgroups to analyze and/or 

characteristics appropriate for subgroup analysis. 

Issue 33: Manufacturer Impact Analysis 

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

and information from interested parties that can assist in evaluating the 

potential impact on manufacturers. 

Issue 31: Regulatory Flexibility Act Analysis 

DOE conducts a regulatory flexibility analysis that examines the impact on 

small entities and considers alternative ways of reducing negative impacts in 

the NOPR stage. DOE invites interested parties to provide information for any 

small businesses that manufacture GSFLs and IRLs and should be consulted 

before DOE publishes a NOPR. 
109

Monetization 

of Emission 

Reductions 

Benefits 

Life-Cycle 

Cost 

Subgroup 

Analysis 

Manufacturer 

Impact 

Analysis 

Utility 

Impact 

Analysis 

Employment 

Impact 

Analysis 

 Regulatory 

 Impact 

Analysis 

Revise 

Preliminary 

Analysis 

Framework 

Document 

Prelim 

Analysis NOPR 

 Final 

Rule 

Analyses for Notice of Proposed Rulemaking (NOPR) 

Emissions 

Analysis 
110

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 
111

Issues for Comment 

Issue 34: Valuing Airborne Emission Reductions 

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

rulemaking. The primary environmental effect of energy conservation standards 

for GSFLs and IRLs is to reduce power plant emissions resulting from reduced 

consumption of electricity. DOE will assess the impact on emissions of carbon 

dioxide (CO2), sulfur dioxide (SO2), nitrogen oxides (NOX), and mercury (Hg). DOE 

also plans on monetizing the emission reductions due to standards consistent 

with methods used in recent DOE standards rulemakings for other consumer 

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

estimates of the potential global benefits resulting from reduced CO2 emissions 

in 2015, expressed in 2011$, were $6.1, $25.4, $41.0, and $77.7 per metric ton 

avoided. DOE invites comment on the approaches described in Chapter 15 for 

monetizing the emission savings due to energy conservation standards. 
112

Issues for Comment 

Issue 35: Regulatory Impact Analysis (RIA) 

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

analysis to address the potential for non-regulatory approaches to supplant or 

augment energy conservation standards to improve the efficiency of GSFLs and 

IRLs on the market. DOE will attempt to base its assessment of non-regulatory 

initiatives on the actual impacts of any such initiatives to date on these or other 

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

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

their effectiveness, particularly as they relate to the product classes covered 

under this rulemaking. 
113

Issues for Comment 

Issue 30: LCC Subgroups 

Some subgroups might be adversely affected by potential energy conservation 

standards for GSFLs and IRLs. DOE is considering the following subgroups for 

analysis: low-income consumers, institutions of religious worship, and 

institutions serving low-income consumers. DOE is considering defining lowincome consumers as residential consumers with incomes at or below the 

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

suggestions for its LCC subgroup analysis. 

Issue 36: Trial Standard Levels 

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

GSFLs and IRLs. DOE is considering several criteria in developing the TSLs, 

including, but not limited to, minimum LCC, maximum NPV, and maximum 

technologically feasible efficiency. These TSLs may include combinations of CSLs 

and will consider the interaction between product classes. From the list of TSLs 

developed, DOE will select one as its proposed standard for the NOPR. DOE 

invites comment on the criteria it should use as the basis for selection of TSLs. 
114

How to Submit Written Comments 

• In all correspondence, please refer to the GSFL-IRL rulemaking by: 

– Energy Conservation Standards for General Service Fluorescent Lamps 

and Incandescent Reflector Lamps; 

– Docket Number EERE-2011-BT-STD-0006; and 

– Regulatory Identification Number (RIN) 1904-AC43. 

• Email: GSFL-IRL_2011-STD-0006@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: May 13, 2013, 11:59 PM EDT 
115

Closing Remarks/Questions