Lucy deButts Department of Energy Energy Efficiency and Renewable Energy Email: high_intensity_discharge_lamps@ee.doe.gov 

# Energy Conservation Standards Interim Analysis

for High

- Intensity Discharge Lamps

April 2, 20132 

# Welcome

• Introductions (around the room)

• Role of the Facilitator

• Ground Rules

– Speak one at a time.

– Say your name for the record

– there will be a complete transcript of this meeting.

– Be concise

– share the ‘air

- time ’.

– Keep the focus here

– cell phones on silent; limit sidebar conversations.

– Webinar participants turn phone on mute; ‘raise your hand’ to be recognized
to speak.



## • Housekeeping Items

• Agenda Review

• Opening Remarks3 

# Agenda

9:00 am

– 9:20 am Welcome, Introductions, Opening Statements

9:20 am

– 10:30 am Overview, Statute, Context, Scope, Market and Technology Assessment, Screening Analysis

10:30 am

– 10:45 am Break

10:45 am

– 11:30 am Engineering Analysis, Equipment Price Determination

11:30 am

– 11:45 am Energy Use Analysis, Markups Analysis

11:45 am – 12:45 pm Lunch
12:45 pm

– 1:45 pm Life

- Cycle Cost and Payback Period Analysis , Shipments Analysis, National Impact Analysis
1:45 pm

– 1:55 pm Interim Manufacturer Impact Analysis
1:55 pm

– 2:05 pm NOPR Analyses
2:05 pm

– 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 the Public Meeting

• Present standards DOE is considering for high

- intensity 

## discharge (HID) lamps

.

• Invite comment on the interim analysis technical support 

## document (TSD).

• Discuss next steps in the rulemaking.

• Invite participants to provide summary comments or statements and raise additional issues for discussion.6 

# Issues for Discussion

Issue box numbering corresponds to the list of issues included in the 

### Executive Summary, available at: http://www.regulations.gov/#! documentDetail;D=EERE

- 2010

- BT

- STD

- 0043

- 0016



### The deadline for submitting comments is May 17, 2013

. Issue Box: DOE welcomes comments, data, and information concerning the standards it is considering for HID lamps. 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 HID Lamps rulemaking by:

– High

- Intensity Discharge Lamps Energy Conservation Standard 

### Rulemaking,

– Docket Number EERE

- 2010

- BT

- STD

- 0043 , and



### – Regulatory Identification Number (RIN) 1904

- AC36.

• Email : HIDLamps

- 2010

- STD

- 0043@ee.doe.gov

• Comment period closes: May 17, 2013, 11:59 PM EDT 

### 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

- 29458 

# Opening Remarks

Meeting participants are invited to provide opening remarks or statements at this time.9 

# Public Meeting Slides Topics

1 Overview; Scope



### 2 Market & Technology; Screening Analysis

3 Engineering; Equipment Price Determination

4 Energy Use; Markups Analysis



### 5 Life

- Cycle Cost & Payback Period Analysis

6 Shipments Analysis; National Impact Analysis

7 Interim MIA; NOPR Analyses10 

# HID Lamps Rulemaking Schedule

2013 2016 2012 2014 2015 2017 2018

Milestone Date Framework Document February 2012 Interim Analysis February 2013 Notice of Proposed Rulemaking (projected) October 2013
Final Rule (projected) July 2014 Compliance Date (projected) July 201711 

# 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 Environmental Assessment Utility Impact Analysis Employment Impact Analysis12 

# Scope

• High

- intensity discharge is the generic name for a family of lamps that includes mercury vapor (MV), high

- pressure sodium (HPS), and metal halide (MH ).



### • DOE assessed HID lamps to determine which lamps met the criteria for considering new standards ( i.e. , which HID lamps had potential for significant energy savings, technological feasibility, and economic justification).



### • DOE is considering only a subset of available wattages and correlated color temperatures (CCTs) because the excluded lamps represent a small market 

### share, and therefore do not represent significant potential energy savings

.13 

# Scope: Summary

• DOE is considering standards for the following lamps:



### • DOE is not considering standards for the following lamps: Directional HID lamps; Self

- ballasted HID lamps; HID lamps intended for use with electronic ballasts only; Pulse

- start MH lamps with color rendering index (CRI ) ≥95; Colored MH lamps (CRI <40); MV lamps labeled for use with specialty applications; and Electrodeless HID lamps. Lamp Type Rated Wattage (Watt, W) CCT (Kelvin, K)

Mercury Vapor 50 W and 1000 W 3200 K and 6800 K
High

- Pressure Sodium 50 W and 1000 W 1900 K and 2700 K

Metal Halide 50 W and 2000 W 2800 K and <7000 K14 

### Issue 2: Colored MH Lamp Definition DOE considered adopting the European Union’s (EU) definition of white light. However, DOE determined in the interim analysis that a colored MH lamp could be effectively defined using CRI. DOE requests comment on this conclusion and whether consistency with the EU definition would be beneficial.



### Issue 3: Specialty Application Mercury Vapor Lamps DOE is aware of certain specialty applications, such as quality inspection, industrial processing, or scientific uses, including fluorescent microscopy and ultraviolet curing, that can only be served by MV lamps and not any other HID or solid

- state technologies. DOE requests comment on excluding individually labeled specialty application MV lamps from consideration for standards. 

# Scope

Issue 1: High

- CRI Lamps For MH lamps, DOE found that lamps with CRI ≥95 could not reach the same levels of efficacy as lower

- CRI lamps. For the interim analysis, DOE did not consider standards for pulse

- start MH lamps with CRI ≥95. DOE requests comment on this preliminary determination.15 

### Issue 4: Electrodeless HID Lamps DOE determined that “electrodeless HID lamps” meet the EPCA definition of HID lamp. These lamps meet the four main specifications of an HID lamp: (1) the arc tube wall loading is in excess of three watts/cm 2 ; (2) the light

- producing arc is stabilized by the arc tube wall temperature; (3) the lamp is either a MV, HPS, or MH lamp; and (4) the lamp is an “electric

- discharge lamp.” However, based on their small market share and lack of an industry consensus test method, DOE is not considering standards for electrodeless HID lamps. DOE requests comment on this determination and whether additional information is necessary to define this exclusion.



### Issue 5: Scope DOE seeks comment on the scope and listed exclusions considered in the interim analysis. 

# Scope16 

# Public Meeting Slides Topics

1 Overview; Scope



### 2 Market & Technology; Screening Analysis

3 Engineering; Equipment Price Determination

4 Energy Use; Markups Analysis



### 5 Life

- Cycle Cost & Payback Period Analysis

6 Shipments Analysis; National Impact Analysis

7 Interim MIA; NOPR Analyses17 Framework Document Interim

Analysis NOPR Final Rule

Market & Technology
Screening Analysis Engineering

Analysis

Energy Use Analysis

Shipments Analysis National Impact Analysis Markups Analysis Life

- Cycle Cost and Payback Period Analysis Equipment Price Determination

Interim
MIA 

# Interim Analysis Rulemaking Stage18 

# Purpose of MTA and Screening Analysis

• Market and Technology Assessment (MTA) Determine equipment 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; (2) Practicability to manufacture, install, and service; (3) Adverse impacts on utility to consumers or availability; and (4) Adverse impacts on health or safety.19 

# Equipment Classes

• DOE establishes separate energy conservation standards for each equipment 

### class

.

• DOE divides covered equipment into classes by:

– 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 is considering establishing equipment classes based on factors that 

### affect utility and lamp efficacy:

– CCT

– Wattage

– Bulb Finish

– Luminaire Characteristic20 

### • Equipment usage indicates that some customers specify lamps of a 

### particular color temperature for certain applications, indicating CCT provides utility to the customer.

• DOE’s analysis of commercially available lamp catalog data determined 

### that CCT is correlated with lamp efficacy (lamps with lower CCT typically have higher efficacy).

• Given the impact on both consumer utility and lamp efficacy, DOE is 

### considering establishing separate equipment classes for different CCT
ranges. 

# Equipment Classes

- CCT21 

### • HID lamps are available with a variety of light outputs and input powers. 

### When observing manufacturer catalog data, DOE observed that light output and lamp input power (wattage) are highly correlated (increased 

### input power leads to increased light output).

• Because customers require varying light levels depending on the application and location of the lamp, wattage provides distinct utility to 

### the customer.

• DOE also found a positive correlation between wattage and efficacy, where lamps with higher wattages had higher efficacies.

• Given the impact on both consumer utility and lamp efficacy, DOE is 

### considering establishing separate equipment classes based on wattage. 

# Equipment Classes

- Wattage22 

### • DOE’s analysis of commercially available lamp catalog data determined 

### that HID lamp manufacturers offer clear and coated (also denoted in catalogs as diffuse, frosted, white, or deluxe white) lamps.

• Coated lamps reduce glare and are often specified for applications in 

### which glare would be undesirable.

• Coated lamps are less efficacious because the coating blocks some visible light.

• Given the impact on both consumer utility and lamp efficacy, DOE is considering establishing separate equipment classes for clear versus coated lamps. 

# Equipment Classes

- Bulb Finish23 

### • Open

- rated lamps are those tested and approved for use in open 

### luminaires. They are characterized by specific safety measures, including the requirement to have a glass shroud that surrounds the arc tube to 

### protect the surrounding area in the event of arc tube rupture.

• Enclosed

- rated lamps do not have the glass shroud surrounding the arc tube and must be used in enclosed fixtures to satisfy safety requirements 

### in the event of lamp rupture. Thus, the shroud safety

- feature in open

rated lamps offers unique utility to the customer.

• The presence of a shroud in open

- rated lamps reduces lamp efficacy by 

### blocking some of the lamp’s visible light.

• Given the impact on both consumer utility and lamp efficacy, DOE is considering establishing separate equipment classes for enclosed

- rated


### versus open

- rated lamps. 

# Equipment Classes

- Luminaire Characteristic24 CCT Range Wattage Bulb Finish Luminaire Characteristic

1900 K and ≤2800 K 50 W and ≤1000 W Clear Enclosed Open Coated Enclosed

Open

2800 K and ≤4500 K 50 W and ≤400 W Clear Enclosed Open Coated Enclosed

Open

400 W and ≤1000 W Clear Enclosed Open Coated Enclosed

Open

1000 W and ≤2000 W Clear Enclosed Open Coated Enclosed

Open

4500 K and <7000 K 50 W and ≤400 W Clear Enclosed Open Coated Enclosed

Open

400 W and ≤1000 W Clear Enclosed Open Coated Enclosed

Open

1000 W and ≤2000 W Clear Enclosed Open Coated Enclosed

Open 

# Equipment Classes25 

### Issue 9: Luminaire Characteristic When separating MH lamp equipment classes according to luminaire characteristic, DOE considered open

- rated lamps, enclosed

- rated lamps, and S

- rated lamps . DOE requests comment on the separation of equipment classes by luminaire characteristic, as well as the applications of F

- rated lamps and how they should be categorized within DOE’s equipment class structure

.



### Issue 10: Equipment Classes DOE defined equipment classes based on CCT, wattage, bulb finish, and luminaire characteristic. DOE seeks comments on these equipment classes. 

### Issue 8: Bulb Finish DOE requests comment on its definition of coated lamps

. 

# Equipment Classes26 

# Market and Technology Assessment

Lamp Type Technology Options Description
Mercury Vapor (MV) Change Lamp Type Use HPS or MH technology instead of MV technology

Metal Halide (MH) Arc Tube Design Ceramic Arc

Tubes Use ceramic metal halide

(CMH) technology instead of quartz MH lamps

Arc Tube Shape Design the shape of the arc

tube so that it facilitates an increase in MH vapor pressure.

Starting Method Use pulse

- start technology instead of probe

- start technology 

### The following technology options can improve lamp efficacy:

*DOE is considering whether manufacturing the arc tubes out of sapphire rather 

### than polycrystalline alumina (PCA) might be a feasible means of improving the efficacy of high

- pressure sodium lamps.27 

### Issue 7: Technology Options The technology option to achieve higher efficacy in HPS lamps may be to construct the arc tubes out of a sapphire material instead of polycrystalline alumina. DOE seeks information on this technology, including whether it meets DOE’s screening criteria. DOE requests comment on the technology options considered and any additional options that should be considered.



### Issue 11: Market and Technology Assessment DOE requests any general comments on the methodology and results of the market and technology assessment. 

# Market and Technology Assessment28 

### • DOE reviewed and assessed the technology options using the

following criteria:

– Technological feasibility;

– Practicability to manufacture, install, and service;

– Adverse impacts on product utility or availability to customers; and

– Adverse impacts on health or safety.



### • DOE determined that all of the technology options for mercury vapor 

### and metal halide lamps met all four screening criteria. 

# Screening Analysis

Issue 12: Screening Analysis DOE invites comment on whether the technology options, and in particular sapphire arc tube technology, meet DOE’s screening criteria.29 

# Public Meeting Slides Topics

1 Overview; Scope



### 2 Market & Technology; Screening Analysis

3 Engineering; Equipment Price Determination

4 Energy Use; Markups Analysis



### 5 Life

- Cycle Cost & Payback Period Analysis

6 Shipments Analysis; National Impact Analysis

7 Interim MIA; NOPR Analyses30 

# Interim Analysis Rulemaking Stage

Framework Document Interim

Analysis NOPR Final Rule

Market & Technology
Screening Analysis Engineering

Analysis

Energy Use Analysis

Shipments Analysis National Impact Analysis Markups Analysis Life

- Cycle Cost and Payback Period Analysis Equipment Price Determination

Interim
MIA31 Select certain equipment classes to be analyzed in the engineering analysis. 

# Engineering Analysis Methodology

Identify more efficacious substitutes for each baseline model based on design options.

Scale results to equipment classes not analyzed. Select Representative Equipment Classes

Select Baseline Lamps

Identify More Efficacious Substitutes

Determine CSLs

Scale Results Define characteristics of baseline models in each equipment class

which will serve as reference points to assess changes due to energy conservation standards.

Develop candidate standard levels (CSLs) that span the range of efficacy from the baseline to the maximum technologically feasible

. 

# 



# 







# 32 CCT Range Wattage Bulb Finish Luminaire Characteristic 1900 K and
2800 K 50 W and 1000 W Clear Enclosed

2800 K and
4500 K 50 W and 400 W Clear Enclosed

400 W and 1000 W Clear Enclosed

1000 W and 2000 W Clear Enclosed 

# Representative Equipment Classes

Issue 13: Representative Equipment Classes DOE requests comment on the use of these four equipment classes as representative. 

### • DOE chooses representative equipment classes on which to concentrate its analytical effort

– Representative equipment classes were chosen on the basis of high market volumes or unique performance characteristics

. Select Representative Equipment Classes

Select Baseline Lamps

Identify More Efficacious Substitutes

Determine CSLs

Scale Results33 

### • The baseline model typically represents the most common,

least efficacious model on the market. DOE identifies a baseline model in each representative equipment class. In cases where a large portion of the market has already adopted a more efficacious lamp, DOE is considering analyzing two baseline models. 

# Baseline Lamps

CCT Range Wattage Bulb Finish Luminaire

Characteristic Representative

Lamp Type Baseline

Lamp Type Baseline

Wattage

>2800 K and ≤4500 K ≥50 W

and
400 W Clear Enclosed 100 W MV MV 100 Pulse MH 70

175 W MV MV 175

Pulse MH 100

250 W MV MV 250

Probe MH 175

400 W MV MV 400

Probe MH 250
400 W MH Probe MH 400 

### Issue 14: Baseline Lamps DOE requests comment on the baseline units selected. Select Representative Equipment Classes

Select Baseline Lamps

Identify More Efficacious Substitutes

Determine CSLs

Scale Results34 

### • For each baseline lamp, DOE selected more efficacious

replacement lamps, on the basis of initial efficacy, to measure 

### potential energy

- saving improvements. More efficacious replacement lamps were identified by:

– When possible, mean lumens within 10 percent of the baseline lamp.

– Similar initial lumens, operating orientation, rated life, CRI, bulb shape, and base type. 

### Example Representative Lamp Type

– 250 W MV 

# More Efficacious Substitutes

CSL Lamp

Type Wattage

W CCT
K Initial
Lumens Initial

Efficacy lm/W Mean
Lumens Mean

Efficacy lm/W Operating Orientation

Baseline MV 250 4000 12,500 50.0 10,000 40.0 Universal Baseline MH/CSL 1 Probe

MH 175 4000 13,500 77.1 9100 52.0 Universal

CSL 2 Pulse

MH 150 3400 13,300 88.7 10,000 66.7 Universal

CSL 3 CMH 100 3000 9500 95.0 7600 76.0 Universal Select Representative Equipment Classes

Select Baseline Lamps

Identify More Efficacious Substitutes

Determine CSLs

Scale Results35 

# More Efficacious Substitutes

Issue 15: More Efficacious Substitutes DOE requests comment on the criteria used in selecting more efficacious substitute lamps, as well as the units selected.36 

# HID Systems

• To analyze an energy conservation standard’s impact on system performance, a ballast is paired with each representative lamp.

• Using manufacturer input and independent research, DOE determined the 

### ballast type and efficiency most commonly used with each representative lamp type.

Lamp Technology Lamp Starting Method Lamp Arc Tube

Material Ballast Type

MV N/A N/A MV magnetic

HPS N/A N/A HPS magnetic

MH Probe Quartz MH probe magnetic
MH Pulse Quartz MH pulse magnetic
MH Pulse Ceramic MH electronic37 

# HID Systems

• DOE preliminarily determined that standards

- induced lamp changes also 

### require installation of a new HID fixture.

– Existing fixture unlikely to physically fit different lamp

- and

- ballast 

### system size.

– Existing fixture and new lamp

- and

- ballast system combination will 

### result in non

- optimal optics.

– Retrofitting old fixtures creates safety concerns and can result in the 

### decertifying of the fixture’s Underwriters Laboratory (UL) rating.

Issue 18: Ballasts DOE requests comment on the ballast types and ballast efficiencies chosen for each lamp type to calculate lamp

- and

- ballast system wattage.38 

# Candidate Standard Levels

• DOE considered an equation

- based approach to 

### characterize a continuous relationship between lamp input power and initial lamp efficacy for each equipment class.

• Power, linear, and constant function regression curves were 

### used to delineate CSLs in each equipment class. Select Representative Equipment Classes

Select Baseline Lamps

Identify More Efficacious Substitutes

Determine CSLs

Scale Results39 

# Candidate Standard Levels

250 W MV Representative Lamp Type >2800 K and ≤4500 K , ≥50 W and ≤4 00 W

c lear, enclosed equipment class40 

# Candidate Standard Levels

>2800 K and ≤4500 K , ≥50 W and ≤ 2000 W

c lear, enclosed equipment classes

Lamp Wattage (W) Initial Lamp Efficacy (lm/W)



### Issue 16: Candidate Standard Levels DOE requests comment on the equations developed for the CSLs in each of the representative equipment classes

.41 

# Scaling Between Equipment Classes

• DOE scaled CSLs to equipment classes not directly analyzed.

• DOE identified pairs of lamps in which the only difference 

### between the lamps was the parameter under consideration for scaling.



### • Scaling factors account for percent difference in initial efficacy due to the following parameters:

– Bulb Finish

– Luminaire Characteristic



### – CCT



### Issue 19: Scaling Between Equipment Classes DOE requests comment on the methodology and result of this scaling analysis and, in particular, whether the scaling factor between the CCT ranges should be a function of wattage. Select Representative Equipment Classes

Select Baseline Lamps

Identify More Efficacious Substitutes

Determine CSLs

Scale Results42 

### Issue 17: Reporting Requirements DOE based its engineering analysis on performance data presented in manufacturer catalogs. At this time, DOE does not have third party test data or compliance reports with which to analyze the variation in test data and the impact of reporting requirements. DOE invites comment on whether an adjustment to the CSLs is needed to account for the reporting requirements and other sources of variation

. 

# Engineering Analysis

Issue 20: Engineering Analysis DOE requests any comments pertaining to the methodology and results of the engineering analysis

.43 

### • DOE estimated the end

- user price of HID lamps directly, rather than developing manufacturing selling prices, because HID lamps are difficult


### to reverse

- engineer ( i.e . not easily disassembled; arc tube salts and fill gas are impractical to assess).

• 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 

### HID lamp prices at the following levels:

– State procurement (low)

– Electrical distributors (medium)

– Internet retailers (high)



### • DOE used teardown data, as well as ballast blue

- book data, to estimate 

### manufacturer production costs (MPCs) of ballasts and fixtures. The MPCs were marked up to manufacturer selling prices (MSPs) to account for non



### production costs and manufacturer profit. 

# Equipment Price Determination44 

### Issue 22: HID Ballast and Fixture Price Determination DOE invites comment on its methodology and results for estimating MSPs for HID ballasts and fixtures. 

### Issue 21: HID Lamp Price Determination DOE invites comment on its methodology and results for estimating end

- user prices for HID lamps

. 

## Equipment Price Determination 

# Equipment Price Determination45 

# Public Meeting Slides Topics

1 Overview; Scope



### 2 Market & Technology; Screening Analysis

3 Engineering; Equipment Price Determination

4 Energy Use; Markups Analysis



### 5 Life

- Cycle Cost & Payback Period Analysis

6 Shipments Analysis; National Impact Analysis

7 Interim MIA; NOPR Analyses46 

# Interim Analysis Rulemaking Stage

Framework Document Interim

Analysis NOPR Final Rule

Market & Technology
Screening Analysis Engineering

Analysis

Energy Use Analysis

Shipments Analysis National Impact Analysis Markups Analysis Life

- Cycle Cost and Payback Period Analysis Equipment Price Determination

Interim
MIA47 

# Energy Use Analysis

• Annual energy consumption (kWh)

= system input power x annual operating hours



### • DOE developed input power for representative HID fixtures (lamp + ballast power) in the engineering analysis.



### • DOE developed annual operating hours:

– With data from DOE survey ( LMC 2010 ); and

– Capturing variation across building types and applications.



### Sector Average Annual Operation 

### ( hours/year )
Commercial 3,961
Industrial 6,113 Outdoor Stationary / Stadium 4,493 / 77848 

# Issues for Discussion

Issue 23: Operating Hours
To characterize the nation’s average use of HID lamps for a typical year, DOE developed annual operating hours by sector using data published in the 2010 U.S. Lighting Market Characterization . DOE assumed that all lamp equipment 

### classes analyzed (Table ES.2.2) could be used in the three evaluated sectors ( i.e. , commercial, industrial, and outdoor stationary), and applied average 

### annual operating hours based on each sector (Table ES.2.4).

DOE welcomes comment on the basis and assignment of these end

- use operating profiles for the lamp types covered under this rulemaking

.49 

# Interim Analysis Rulemaking Stage

Framework Document Interim

Analysis NOPR Final Rule

Market & Technology
Screening Analysis Engineering

Analysis

Energy Use Analysis

Shipments Analysis National Impact Analysis Markups Analysis Life

- Cycle Cost and Payback Period Analysis Equipment Price Determination

Interim
MIA50 

# Markups Analysis

• For Interim Stage:

– Markups were not used for lamps prices as they were developed as end user prices.

– Markups were developed for ballasts and fixture prices since manufacturer selling prices (MSP) were supplied with engineering analysis.

– DOE used SEC form 10

- K data and did not differentiate baseline and incremental markups.

– Final Markup = Average Wholesaler Markup x Contractor Markup

= 1.24 x 1.13 = 1.39



### • For NOPR Stage:

– Will need markups for MIA (Manufacturer Impact Analysis) to estimate lamp MSPs from end user prices.

– Will consider lower markup (1.15) for lamps to represent high volume and lower
cost.51 

# Public Meeting Slides Topics

1 Overview; Scope



### 2 Market & Technology; Screening Analysis

3 Engineering; Equipment Price Determination

4 Energy Use; Markups Analysis



### 5 Life

- Cycle Cost & Payback Period Analysis

6 Shipments Analysis; National Impact Analysis

7 Interim MIA; NOPR Analyses52 

# Interim Analysis Rulemaking Stage

Framework Document Interim

Analysis NOPR Final Rule

Market & Technology
Screening Analysis Engineering

Analysis

Energy Use Analysis

Shipments Analysis National Impact Analysis Markups Analysis Life

- Cycle Cost and Payback Period Analysis Equipment Price Determination

Interim
MIA53 

# LCC

- PBP Calculation

Life

- Cycle Cost (LCC)
Sum of installed costs and total operating costs over the entire lifetime of a fixture:


### IC

– Installed Costs
OC

– Operating Cost
RC

– Replacement Costs



### Simple Payback Period (PBP) Time in years in which a more efficient (and initially more expensive) system will pay itself off due to decreased annual operating costs:54 

# Life

- Cycle Cost and Payback Period Analysis

Analysis Unit: F ixture55 

# LCC and PBP Analysis

– Triggering Events

Lamp Failure

– Base case

– lamp replacement

– Standards case

– fixture replacement



### Ballast Failure

– Base case

– ballast and lamp replacement

– Standards case

– fixture replacement



### Fixture Failure

– Base case

– fixture replacement

– Standards case

– fixture replacement56 

# LCC

- PBP Analysis Inputs

Installed Cost Inputs

– End

- user equipment price

• Lamps

• Ballasts

• Fixtures

– Sales tax by state (7.09% US average, Sales Tax Clearinghouse )

– Installation costs

– from RS Means 2011

• $73/hr electrician labor plus servicing equipment

• Vary by wattage and application:

» Fixture $160

- $535

» Ballast $147

- $297

» Lamp $94

- $25457 

# LCC

- PBP Analysis Inputs

Operating Cost Inputs

– Electricity price (form EIA

- 826 2012 data and AEO 2012 )

– Discount rate:

• DOE calculated weighted

- average discount rates from estimated costs of capital

• Commercial: 4.5%

• Industrial: 4.3%

• Outdoor Stationary: 3.4 %

– Lifetimes:

• Fixtures: interior

– 20 years, exterior

– 25 years

• Ballasts : magnetic

-- 50,000 hours, electronic

-- 40,000 hours


### Replacement Cost Inputs

– Lamps and ballasts lifetimes and prices, equipment price trend based on
AEO 2011 deflators58 

# LCC

- PBP Analysis Results
Lamp Event , >2800 K and ≤4500 K; ≥50 W to <400 W ; clear; and enclosed

- rated

CSL Repr.

Lamp Type Lamp Type LCC $ LCC Savings $ Installed

Cost $ Oper. Cost Savings $ PBP

yr

Baseline MV

100 W MV MV 100 W 629

--- 193

--- --- 1 N/A

--- --- --- --- --- Baseline MH / 2 pulse MH 70 W 740 (111) 346 42 19.7
3 CMH 50 W 682 (53) 379 134 7.6 Baseline MH / 2 100 W MV pulse MH 70 W 1,035

--- 193

--- --- 3 CMH 50 W 1,143 (108) 379 75 22.6 Baseline MV
175 W MV MV 175W 808

--- 182

--- --- 1 N/A

--- --- --- --- --- Baseline MH / 2 pulse MH 100 W 896 (88) 419 149 8.7
3 CMH 70 W 859 (51) 463 230 6.7 Baseline MH / 2 175 W MV pulse MH 100 W 1,187

--- 201

--- --- 3 CMH 70 W 1,429 (242) 463 20 N/A Baseline MV

250 W MV MV 250 W 1,048

--- 212

--- --- Baseline MH / 1 probe MH 175 W

--- --- --- --- --- 2 pulse MH 150 W 1,147 (99) 526 216 7.9 3 CMH 100 W 1,034 14 569 371 5.2 Baseline MH / 1
250 W MV probe MH 175 W 2,225

--- 213

--- --- 2 pulse MH 150 W 2,144 81 526 394 8.6 3 CMH 100 W 1,728 497 569 853 4.559 

# Issues for Discussion

Issue 24: Lifetimes


### For the LCC

- PBP analysis and shipment projections, DOE assumed HID lamp fixture lifetimes of 20 years for interior fixtures and 25 years for exterior 

### fixtures. DOE assumed lifetimes of 40,000 hours for electronic ballasts, and 50,000 hours for magnetic ballasts. DOE also used an average of lamp 

### lifetimes at different operating orientations for lamp lifetimes in each equipment class. These average values suggest that a majority of failures 

### occur later in the service lifetime.

DOE seeks comment on its assumed lifetimes for fixtures, ballasts, and lamps, and how they may vary within the representative equipment classes, 

### as well as the distribution of failures around the average values.60 

# Public Meeting Slides Topics

1 Overview; Scope



### 2 Market & Technology; Screening Analysis

3 Engineering; Equipment Price Determination

4 Energy Use; Markups Analysis



### 5 Life

- Cycle Cost & Payback Period Analysis

6 Shipments Analysis; National Impact Analysis

7 Interim MIA; NOPR Analyses61 

# Interim Analysis Rulemaking Stage

Framework Document Interim

Analysis NOPR Final Rule

Market & Technology
Screening Analysis Engineering

Analysis

Energy Use Analysis

Shipments Analysis National Impact Analysis Markups Analysis Life

- Cycle Cost and Payback Period Analysis Equipment Price Determination

Interim
MIA62 

# Shipments Analysis

• The shipments analysis ties the life

- cycle costs of individual lamps and 

### fixtures to the national

- level quantities analyzed in the national impact analysis.

• Inputs to the shipments analysis include lamp equipment classes and candidate standard levels, their associated historical shipments and future market trends.63 

# Shipments Analysis

• DOE has historical HID lamp shipments data from NEMA (1990

- 2010 ).

• DOE reviewed industry forecasts related to technologies.

• Finally, DOE developed base

- case and standards

- case shipment 

### projections based on:

– L amp lifetimes;

– R eplacement and lamp demand growth/decline rates; and

– R etirement and emerging technology penetration rates, e.g. , in which fluorescent and LEDs technologies displace HID.64 

# Shipments Analysis Results

• In general, HID lamp shipments decrease over time due to retirement and emerging technologies that replace their use.65 

# Issues for Discussion

Issue 25: Shipments
For this rulemaking, DOE used lamp shipment data previously published in 

### the HID lamps final determination, NEMA lamp shipment data (2002

– 2010) provided by manufacturers, and market trend information from 

### manufacturers to develop historical shipment data for lamps from 1990

– 2010.

DOE requests comment on this approach, and would welcome actual HID 

### lamp shipment data to validate its methodology.66 

# Issues for Discussion

Issue 26: Shipments


### DOE modeled lamp purchasing events ( e.g. , replacement and new construction) and applied growth rate and replacement rate assumptions to develop annual shipment projections. DOE based future lamp shipments on the 2010 HID lamps final determination; DOE assumes that these trends 

### integrate various regulatory and non

- regulatory initiatives in the lighting marketplace.

DOE requests comment on the magnitude and timing of its projected lamp 

### shipment trends ( e.g. , rising and declining shipments, plateaus) as well as the effects of current regulatory initiatives on future HID lamp shipments

.67 

# Issues for Discussion

Issue 27 : Standards

- Induced Market Shifts 

### In the shipments analysis, DOE assumes that a portion of the market shifts to LED, induction, and linear fluorescent sources. DOE requests comments on this assumption as well as on the likelihood and magnitude of an additional market shift to non

- HID technologies in response to standards.

If a standards

- induced shift is expected, DOE requests further comments on: (1) which equipment classes, applications, or fixture types would experience the shift; (2) which non

- HID technologies would replace HID; 

### and (3) on what basis an equivalent non

- HID replacement would be specified by a customer ( e.g. , fixture light output, lamp mean lumens, etc.).68 

# National Impact Analysis (NIA)

National energy savings (NES) and net present value (NPV) are calculated for the lamps shipped from 2017 to 2046.

Shipments Model National Energy Savings (Quads of Source B tu) National

Net Present Values ($billions) LCC Analysis Results and Other Inputs69 

# NIA Results: National Energy Savings

Cumulative energy savings (Quads of source BTU) : CSL 1 CSL 2 CSL 3

0.63 1.16 4.6770 

# NIA Results: National NPVs

(5.00) (4.00) (3.00) (2.00) (1.00) - 1.00 2.00 National NPV for HID Lamps, Shipped in 2017

- 2046, 3% discount rate

CSL 1 CSL 2 CSL 3 (5.00) (4.00) (3.00) (2.00) (1.00) - 1.00 2.00 National NPV for HID Lamps, Shipped in

2017

- 2046, 7% discount rate

CSL 1 CSL 2 CSL 3

Cumulative NPV s (billion 2012$):
3% discount 7% discount

CSL 1 CSL 2 CSL 3

(12.26) (15.96 ) (14.30) CSL 1 CSL 2 CSL 3

(9.40) (12.48) ( 13.96)71 

# Public Meeting Slides Topics

1 Overview; Scope



### 2 Market & Technology; Screening Analysis

3 Engineering; Equipment Price Determination

4 Energy Use; Markups Analysis



### 5 Life

- Cycle Cost & Payback Period Analysis

6 Shipments Analysis; National Impact Analysis

7 Interim MIA; NOPR Analyses72 

# Interim Analysis Rulemaking Stage

Framework Document Interim

Analysis NOPR Final Rule

Market & Technology
Screening Analysis Engineering

Analysis

Energy Use Analysis

Shipments Analysis National Impact Analysis Markups Analysis Life

- Cycle Cost and Payback Period Analysis Equipment Price Determination

Interim
MIA73 

### • Purpose

– To identify 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, employment, and regulatory burden). 

# Manufacturer Impact Analysis

- Overview74 

### • Energy Savings from Replacement HID Lamps

– New energy conservation standards may not lead to significant energy savings.

– HID ballasts and fixtures typically work with only one lamp type and wattage.

– Customers may simply replace a failed lamp with an equal

- wattage lamp, and accept higher lumen output (given more efficacious lamps), rather than incur the high cost of replacing the ballast or fixture as well.



### • Testing Burden

– New standards may add testing requirements to manufacturers and could necessitate an increase the size of current test laboratories and the number of

man

- hours associated with compliance testing.



### • Technology Shift

– A technological shift away from HID lighting, and towards LEDs and fluorescent technologies is already underway, and HID standards may accelerate the process due to potential price increases.



### • Product Innovation

– HID lamp rulemaking could shift resources away from the R&D of more efficient lighting technologies, such as LEDs. 

# Interim Manufacturer Impact Analysis Key Issues75 

# Manufacturers of HID Lamps

Issue 6: Small Business Manufacturers of High

- Intensity Discharge Lamps Although the HID lamp market is predominantly controlled by large manufacturers, DOE conducts a study of small businesses that manufacture HID lamps for the NOPR stage of this rulemaking analysis. DOE invites interested parties to provide information for any small businesses that manufacture HID lamps and should be consulted before DOE publishes a NOPR.76 

# Analyses for Notice of Proposed Rulemaking (NOPR)

Environmental Assessment & Emissions Monetization Customer Subgroup Analysis Manufacturer

Impact Analysis Utility

Impact Analysis Employment

Impact Analysis Regulatory Impact Analysis Revise Interim Analysis Framework

Document Interim

Analysis NOPR Final Rule77 

# NOPR Analyses

Customer Subgroup Analysis

– Effects on various national customer subgroups.


### Manufacturer Impact Analysis (continued )


### Utility Impact Analysis

– Effects on generation capacity of utilities.


### Employment Impact Analysis

– Indirect effects on national employment.



### Environmental Assessment

– Effects on airborne pollutant emissions.



### Monetization of Emission Reductions Benefits

– Monetary values for reduced emissions of carbon dioxide and nitrogen oxides.


### Regulatory Impact Analysis

– Potential for non

- regulatory approaches.78 

# Issues for Discussion

Issue 28: Customer Subgroups
Some subgroups might be adversely affected by potential energy 

### conservation standards for HID lamps. DOE has preliminarily identified the following subgroups: medium to high

- end retail, grocery, big

- box retail, schools, community centers, sport facilities, industrial, warehousing, various types of facilities with outdoor area lighting, and owners of streets and roadways ( e.g. , property owners, municipalities, 

### and state and federal departments of transportation).

DOE welcomes additional suggestions for its customer subgroup analysis.79 

# Issues for Discussion

Issue 29: Valuing Airborne Emission Reductions 

### DOE 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, in the case of CO 2 

### , the most recent interagency estimates of the potential global benefits resulting from reduced CO 2 

### emissions in 2015 were $6.2, $25.7, $41.5, and $78.7 per metric ton in 2012 dollars.

DOE invites comments on the approaches for monetizing the emission savings due to energy conservation standards.80 

# How to Submit Written Comments

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

– High

- Intensity Discharge Lamps Energy Conservation Standard 

### Rulemaking,

– Docket Number EERE

- 2010

- BT

- STD

- 0043 , and



### – Regulatory Identification Number (RIN) 1904

- AC36

• Email : HIDLamps

- 2010

- STD

- 0043@ee.doe.gov

• Comment period closes: May 17, 2013, 11:59 PM EDT 

### 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