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, 2013
2

Welcome

• Introductions (around the room)

• Role of the Facilitator

• Ground Rules

– Speak one at a time.

– Say your name for the record – there will be a complete transcript of this 

meeting.

– Be concise – share the ‘air-time’.

– Keep the focus here – cell phones on silent; limit sidebar conversations.

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

to speak.

• Housekeeping Items

• Agenda Review

• Opening Remarks
3

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 Adjourn
4

Listening Via the Webcast

• The Department is broadcasting this meeting live over the 

Internet.

• DOE is providing the webcast to accommodate stakeholders 

that are unable to attend the public meeting in person.

• The web broadcast allows stakeholders to listen in and view 

the slides.

• All stakeholders are encouraged to submit written comments 

after the public meeting.
5

Purpose of 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: 202 586-2945
8

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 Analyses
10

HID Lamps Rulemaking Schedule

2012 2013 2014 2015 2016 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 2017
11

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 Analysis
12

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 K
14

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/cm2; (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. 

Scope
16

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 Analyses
17

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 Stage
18

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 Characteristic
20

• 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 - CCT
21

• 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 - Wattage
22

• 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 Finish
23

• 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 openrated 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 Characteristic
24

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 Classes
25

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 Classes
26

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 Assessment
28

• 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 Analyses
30

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

MIA
31

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 Results
33

• 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 Results
34

• 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 Results
35

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 electronic
37

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 Results
39

Candidate Standard Levels

250 W MV 

Representative Lamp Type

>2800 K and ≤4500 K, ≥50 W and ≤400 W

clear, enclosed equipment class
40

Candidate Standard Levels

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

clear, 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 Results
42

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 nonproduction costs and manufacturer profit.

Equipment Price Determination
44

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 Determination
45

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 Analyses
46

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

MIA
47

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 / 778
48

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

MIA
50

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 Analyses
52

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

MIA
53

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: Fixture
55

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 replacement
56

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 - $254
57

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 deflators
58

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 4.5
59

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 Analyses
61

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

MIA
62

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:

– Lamp lifetimes;

– Replacement and lamp demand growth/decline rates; and

– Retirement 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.

 -

 2

 4

 6

 8

 10

 12

 14

 16 Millions

Historical and Projected HID Lamp Shipments, 2000 - 2046

HPS

MV

probe MH

pulse MH

CMH
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 Btu)

National 

Net Present 

Values 

($billions)

LCC Analysis 

Results and 

Other Inputs
69

NIA Results: National Energy Savings

Cumulative energy savings

(Quads of source BTU): 

CSL 1 CSL 2 CSL 3

0.63 1.16 4.67

 -

 0.0500

 0.1000

 0.1500

 0.2000

 0.2500

 0.3000

 0.3500

 0.4000 Quads BTU

National Energy Savings for HID Lamps, Shipped in 2017-2046 

CSL 1

CSL 2

CSL 3
70

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 NPVs (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 Analyses
72

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

MIA
73

• 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 - Overview
74

• 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 Issues
75

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

Rule
77

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 CO2, the most recent interagency estimates of the 

potential global benefits resulting from reduced CO2 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