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.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 

# 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 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 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 discussion6 

# 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 EDT8 

# 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 Market & Technology; Screening Analysis 2
Engineering Analysis 3 1 Overview; Scope of Coverage



### Preliminary MIA; NOPR Analyses 7 Product Price Determination 410 

# 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

2013 2016 2012 2014 2015 2017 201812 

# 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 Analysis13 

# 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 W15 

# 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 430.216 

# 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 430.217 

# 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 MIA19 

# Presentation Overview

Energy Use; Life-Cycle Cost Analysis
Shipments; National Impact Analysis 5

6 Market & Technology; Screening Analysis 2
Engineering Analysis 3 1 Overview; Scope of Coverage



### Preliminary MIA; NOPR Analyses 7 Product Price Determination 420 

# 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 safety21 

# 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 lumenpackages 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 K25 

# 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 Phosphors30 

# 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 Lamps31 

## 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 Comment32 

## • 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 Analysis33 

# 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 Comment36 

# Presentation Overview

Energy Use; Life-Cycle Cost Analysis
Shipments; National Impact Analysis 5

6 Market & Technology; Screening Analysis 2
Engineering Analysis 3 1 Overview; Scope of Coverage



### Preliminary MIA; NOPR Analyses 7 Product Price Determination 437 

# 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 Results38 

# 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 Results39 

# 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 Results41 

# 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 Results42 

# 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, electronic43 

# 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 4,45444 

# 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 Results46 

# 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 Results47 

# 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 Results48 

# 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 Results50 

# 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 Results52 

# 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 Improve d

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 Results53 

# 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 Results54 

# 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 6.2P 0.27 P = wattage Select Representative Equipment Classes

Select Baseline Lamps
Identify More Efficacious Substitutes

Determine CSLs

Scale Results56 

# 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 Results58 

# 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 Market & Technology; Screening Analysis 2
Engineering Analysis 3 1 Overview; Scope of Coverage



### Preliminary MIA; NOPR Analyses 7 Product Price Determination 460 

# 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 Comment62 

# Presentation Overview

Energy Use; Life-Cycle Cost Analysis
Shipments; National Impact Analysis 5

6 Market & Technology; Screening Analysis 2
Engineering Analysis 3 1 Overview; Scope of Coverage



### Preliminary MIA; NOPR Analyses 7 Product Price Determination 463 

# 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/A64 

## 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 Comment65 

# 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 Value68 

# 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 CSL72 

# 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 -0.2275 

## 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 Comment76 

# Presentation Overview

Energy Use; Life-Cycle Cost Analysis
Shipments; National Impact Analysis 5

6 Market & Technology; Screening Analysis 2
Engineering Analysis 3 1 Overview; Scope of Coverage



### Preliminary MIA; NOPR Analyses 7 Product Price Determination 477 

# 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 B78 

# 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 trends80 

# 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

Outputs81 

### 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 40Percent Diffusion

Year Since Introduction Bass Diffusion Curve

O&M j (year n-1 ) First Cost

j (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$8.75O&M Cost ($/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 14000Value per unit(2005$)

Cumulative Shipments (millions)



### Learning Curve for GSFLs84 

# 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 ballast88 

# 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 0.2089 

# Shipments Analysis: Reference Case Shipments over the analysis period in the Reference case for all product class groupings

Shipments decline because of LED incursion

IRL90 

# 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 Outputs91 

# National Impact Analysis

Where: NES(y) = National Energy Saving in year y (quads), and AEC base 

### (y) = base case annual national energy consumption, considering the full fuel cycle, for all product classes combined in year y (quads), and AEC std 

### (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

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 B95 

# 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 price96 

# 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 Projections97 

### 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 Controls98 

## 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 Comment99 

### 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 Comment102 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 Market & Technology; Screening Analysis 2
Engineering Analysis 3 1 Overview; Scope of Coverage



### Preliminary MIA; NOPR Analyses 7 Product Price Determination 4105 

# 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 Analysis110 

# 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 approaches111 

# 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 (CO 2 

## ), sulfur dioxide (SO 2 

## ), nitrogen oxides (NO X 

## ), 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 CO 2 

## 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 EDT115 

# Closing Remarks/Questions