May 25, 2010

Energy Conservation Standards for General Service Fluorescent Lamps and Incandescent Reflector Lamps

Proposed Rule

Score: 27 / 60

Additional details
Department of Energy
Regulatory Identification Number
Rule Publication Date


Department of Energy is proposing amended energy conservation standards for general service fluorescent lamps and incandescent reflector lamps and new energy conservation standards for certain additional general service fluorescent lamps not currently covered by the standards.

Visit the Department of Energy's website to view the Regulatory Impact Analysis for this Propsed Rule.



There are twelve criteria within our evaluation within three broad categories: Openness, Analysis and Use. For each criterion, the evaluators assign a score ranging from 0 (no useful content) to 5 (comprehensive analysis with potential best practices). Thus, each analysis has the opportunity to earn between 0 and 60 points.

Criterion Score


1. How easily were the RIA , the proposed rule, and any supplementary materials found online?
The RIA could not be not found through or; in fact, the NPRM could only be located on the DOE's website. A call was needed to find the “technical support document," which contains the RIA and much other analysis.
2. How verifiable are the data used in the analysis?
When data is used, it is often without a source or only sourced to other DOE analyses. It is impossible for the reader to verify certain analytical techniques, for example, the use of the ImSET model in the Employment Impact Analysis. There are many dead links to surveys and other documents.
3. How verifiable are the models and assumptions used in the analysis?
There is only one peer-reviewed publication cited in the entire RIA; the models are assumed to be self-evident (presumably). However, other analyses in the “technical document” are mentioned in the RIA as supporting models. Other DOE analyses outside the technical document are cited in the RIA. Thus while the models and assumptions are not necessarily bolstered by peer-reviewed publications, there is an attempt made to justify them with evidence from other government publications.
4. Was the analysis comprehensible to an informed layperson?
Much of the economic analysis involves complex allusions to technical discussions. While this is clearly outlined earlier in the analysis, it is difficult for a non-lighting engineer to keep track of the concepts being discussed. As a standalone chapter, the RIA is not very comprehensible even to an economist. It references much other analysis (that is not in the RIA or proposed rule) as the bases for its cost and benefits estimations.


5. How well does the analysis identify the desired outcomes and demonstrate that the regulation will achieve them?
Does the analysis clearly identify ultimate outcomes that affect citizens’ quality of life?
Tha analysis provides consumer cost savings due to energy efficiency, plus environmental benefits.
Does the analysis identify how these outcomes are to be measured?
Outcomes are measured by changes in national energy use and net present value of savings to consumers.
Does the analysis provide a coherent and testable theory showing how the regulation will produce the desired outcomes?
Various proposals to induce energy-efficient bulb adoption are discussed, but the reasons why they would work or wouldn't are not very well described.
Does the analysis present credible empirical support for the theory?
Only one paper is cited (other than other DOE papers) for empirical evidence on one option.
Does the analysis adequately assess uncertainty about the outcomes?
Various policies are considered and each projected energy savings is given a range; however, many assumptions going into calculating those ranges contain some uncertainty that is not addressed. A Monte Carlo analysis was performed.
6. How well does the analysis identify and demonstrate the existence of a market failure or other systemic problem the regulation is supposed to solve?
Does the analysis identify a market failure or other systemic problem?
The analysis claims that consumers misperceive energy savings due to information costs or asymmetric information. It also suggests there are external environmental benefits.
Does the analysis outline a coherent and testable theory that explains why the problem (associated with the outcome above) is systemic rather than anecdotal?
Possible theories are mentioned.
Does the analysis present credible empirical support for the theory?
DOE solicited data that would allow it to test market failure theories, but did not test the theories because it received no data.
Does the analysis adequately assess uncertainty about the existence or size of the problem?
The analysis does not address uncertainty.
7. How well does the analysis assess the effectiveness of alternative approaches?
Does the analysis enumerate other alternatives to address the problem?
The analysis provides a very broad list of nine alternatives, including non-regulatory actions (best practice).
Is the range of alternatives considered narrow (e.g., some exemptions to a regulation) or broad (e.g., performance-based regulation vs. command and control, market mechanisms, nonbinding guidance, information disclosure, addressing any government failures that caused the original problem)?
Various incentive mechanisms to encourage consumers (other than command-and-control regulations) are considered.
Does the analysis evaluate how alternative approaches would affect the amount of the outcome achieved?
A nice table presents the outcomes under all the approaches.
Does the analysis adequately address the baseline? That is, what the state of the world is likely to be in the absence of federal intervention not just now but in the future?
Baseline assumes there will be no energy savings from current levels in future years unless there is regulatory action. This seems implausible.
8. How well does the analysis assess costs and benefits?
Does the analysis identify and quantify incremental costs of all alternatives considered?
The proposed rule's costs are well identified and quantified, but not those of alternative options.
Does the analysis identify all expenditures likely to arise as a result of the regulation?
Yes, if the only relevant option is the proposed standard.
Does the analysis identify how the regulation would likely affect the prices of goods and services?
There is a section devoted to this, but the way the price of high-efficiency bulbs is calculated leaves much to be desired (no supply-and-demand analysis).
Does the analysis examine costs that stem from changes in human behavior as consumers and producers respond to the regulation?
See above—the analyses ignore most of economics insights into human behavior.
If costs are uncertain, does the analysis present a range of estimates and/or perform a sensitivity analysis?
In separate chapters in the technical document (not in the RIA chapter), costs are addressed using existing data in regression analyses. Electricity price trends are included in these analyses, which to some degree address uncertainty. There is no specific section addressing the uncertainty of costs, however, in the RIA.
Does the analysis identify the alternative that maximizes net benefits?
Given the options considered, yes.
Does the analysis identify the cost-effectiveness of each alternative considered?
No, but this could be calculated from the results.
Does the analysis identify all parties who would bear costs and assess the incidence of costs?
Chapters of the technical support document consider effects on different types of manufacturers, consumers, utilities, and employment.
Does the analysis identify all parties who would receive benefits and assess the incidence of benefits?
There's only a cursory discussion.


9. Does the proposed rule or the RIA present evidence that the agency used the analysis?
The NPRM refers to analysis to choose the option that saves the most energy and is economically justified; this is indirect evidence the RIA was used. A graphic in the "analytical Framework" chapter shows how various parts of the analysis are supposed to affect various decisions.
10. Did the agency maximize net benefits or explain why it chose another alternative?
It did not elect the most stringent standard, saying the costs outweighed the benefits.
11. Does the proposed rule establish measures and goals that can be used to track the regulation's results in the future?
Tha analysis does not establish performance measures and goals, however the DOE could presumably track effects on energy usage in the future to get a handle on this.
12. Did the agency indicate what data it will use to assess the regulation's performance in the future and establish provisions for doing so?
The analysis does not address this topic.
Total 27 / 60