1 | Building Technologies Program 

Pu

BUILDING TECHNOLOGIES PROGRAM

Energy Conservation Standards Framework Document forHigh-Intensity Discharge Lamps

Lucy deButtsDepartment of EnergEnergy Efficiency & Docket Number: EEHIDLamps-2010-ST

March 29, 2012
2 | Building Technologies Program 

• Introductions• Role of the Facilitator• Ground Rules

– Listen as an ally– Focus on issues– Use short, succinct statements/keep to the point– Hold sidebar conversations outside the room– One person speaks at a time (raise hand to be recognized; s

name for the record)

– Set cell phones to silent/vibrate

• Housekeeping Items• Agenda Review• Opening Remarks

Welcome and Introduction
3 | Building Technologies Program 

Morning Agenda

9:00 – 9:05 am9:05 – 9:20 am9:20 – 9:40 am9:40 – 10:15 am10:15 – 10:30 am10:30 – 11:00 am11:00 – 11:45 am11:45 am – 12:45 pm

WelcomeIntroductions and Agenda ReviewOpening RemarksRegulatory History, Rulemaking Overview, aCoverageBreakMarket and Technology Assessment and ScAnalysisEngineering Analysis and Product Price DetBreak for Lunch
4 | Building Technologies Program 

Afternoon Agenda

12:45 – 1:00 pm1:00 – 1:15 pm1:15 – 1:45 pm1:45 – 2:15 pm2:15 – 2:30 pm2:30 – 2:40 pm2:40 – 3:10 pm3:10 – 3:30 pm

Energy Use AnalysisMarkup AnalysisLife-Cycle Cost (LCC) and Payback Period AShipments Analysis, National Impact AnalysisLife-Cycle Cost Subgroup AnalysisBreakManufacturer Impact AnalysisUtility Impact Analysis, Employment Impact AEmissions Analysis, and Regulatory Impact AOther issues and comments; Closing remarks
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• The Department is broadcasting this meeting live over the • DOE is providing the webcast to accommodate stakehold

are unable to attend the public meeting in person. 

• The web broadcast allows stakeholders to listen in and vie

slides.

• All stakeholders are encouraged to submit written comme

the public meeting. 

Listening Via the Webcast
6 | Building Technologies Program 

Purpose of the Public Meeting

• Present the procedural and analytical approaches to evalu

conservation standards for HID lamps.

• Invite comment on the energy conservations standards fra

document.

• Discuss next steps in the rulemaking.• Encourage participants to submit data, information, summ

statements, and written comments, including additional issdiscussion.
7 | Building Technologies Program 

Request for Comment

Item 1: Although DOE invites comment on all aspects material presented in this document, several specific ison which DOE seeks comment are set out in commenboxes like this one. DOE uses these comment boxes thighlight issues and ask specific questions regarding tapproaches DOE plans to follow to conduct the analysrequired for the energy conservation standards rulema

Issue box numbering corresponds to the list of items publisheof the framework document, available at: http://www1.eere.energy.gov/buildings/appliance_standards/c

high_intensity_discharge_lamps.html. The deadline for submitting comments is April 12, 2012. 
8 | Building Technologies Program 

Opening Remarks

Meeting participants are invited to provide open

remarks or statements at this time. 
9 | Building Technologies Program 

Energy Use; Markup AnalysisLCC and Payback Period Analyses

Shipments Analysis; NIA AnalysisNOPR Analyses

Public Meeting Slides Topics

45672 Market and Technology; Screening3 Engineering; Product Price Determination

1 Overview; Scope of Coverage
10 | Building Technologies Program 

Regulatory History

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

Policy and Conservation Act of 1975 (EPCA) by adding HID covered equipment and requiring DOE to:

− Determine whether energy conservation standards for HID lam

technologically feasible and economically justified, and would significant energy savings;

− Prescribe testing requirements within 30 months for those HID 

which standards are justified; and

− Prescribe energy conservation standards within 18 months of 

testing requirements.

• On July 1, 2010, DOE published a positive final determinatio

HID lamps. 75 FR 37975. 

• On December 15, 2011, DOE published a notice of propose

rulemaking (NOPR) for test procedures for HID lamps. 76 F
11 | Building Technologies Program 

HID Lamps Rulemaking Schedule

2012 2014 2015 2013 2016 2017 

Milestone 

Framework Document Availability of the Interim Analysis (projected) Notice of Proposed Rulemaking (projected) Final Rule (projected) Compliance Date (projected) 

Item 2: DOE welcomes comments on how it should coordinate development of the final rules for HID lamps metal halide lamp fixtures (MHLF).
12 | Building Technologies Program 

EPCA Factors

42 U.S.C. 6295(o)(2)(B)(i) directs DOE to consider seven fasetting energy conservation standards.

EPCA Factors DOE Analys

1. Economic impact on consumers and 

manufacturers

Life-Cycle Cost An

Manufacturer Impact 

2. Lifetime operating cost savings compared 

to increased cost for the product Life-Cycle Cost An

3. Total projected energy savings National Impact An4. Impact on utility or performance Engineering Anal

Screening Analy

5. Impact of any lessening of competition Manufacturer Impact 6. Need for national energy conservation National Impact An7. Other factors the Secretary considers 

relevant

Environmental Asse

Utility Impact Ana

Employment Impact A
13 | Building Technologies Program 

Scope of Coverage: Definitions

• High-intensity discharge is the generic name for a family of 

including mercury vapor (MV), metal halide (MH), and highsodium (HPS) lamps. 

• Although low-pressure sodium lamps are often included in 

they are not included in the definition set forth in EPCA, antherefore not considered in this rulemaking. 

• Catalogs also offer “electrodeless” lamps (also referred to a

emitting plasma lamps) that may be a subcategory of MV, M

lamps. 

 Emit light in a process related to MV, MH, and HPS lamps. Gas composition appears most similar to MH lamps.

Item 3: DOE welcomes comment on whether electrodeHID lamps (also referred to as light-emitting plasma) arsubcategory of MV, HPS, or MH lamps.
14 | Building Technologies Program 

Scope of Coverage:Wattage and CCT

• HID lamps span a range of wattages, though these wattage

according to lamp technology. Initial light output could also describe the range of lamps available.

• Similarly, HID lamps are available with a variety of correlate

temperatures (CCT), depending on lamp type and design.

• DOE is considering only a subset of available wattages and 

because the excluded lamps represent a small number of aequipment, and therefore do not represent significant potensavings.
15 | Building Technologies Program 

Scope of Coverage: Summary

• DOE is considering including the following lamps in the sco

coverage:

• DOE is considering excluding the following lamps from the s

coverage:

 HID lamps designed and labeled for use with electronic balla Directional HID lamps Self-ballasted HID lamps Colored HID lamps Specialty application MV lamps

Lamp Type Rated Wattage CC

Metal Halide  50 and  2000 W  2500 and 

Mercury Vapor  50 and  1000 W  3200 and 

High Pressure Sodium  50 and  1000 W  1900 and 
16 | Building Technologies Program 

Scope of Coverage

Item 4: DOE welcomes comments on its decision to define scope of coverage using rated wattage instead of lumen ouand the range of wattages included in coverage.Item 5: DOE welcomes comments on its decision to excludlamps designed and labeled for use with electronic ballasts directional HID lamps, self-ballasted HID lamps, and high Clamps from the scope of coverage. DOE also requests comon the unique characteristics of colored HID lamps.
17 | Building Technologies Program 

Scope of Coverage

Item 6: DOE welcomes comments on whether lamps for spapplications have defining characteristics that differentiate from lamps used for general illumination purposes. In additDOE welcomes comments on whether specialty applicationrelevant to MV technology can also be served by HPS or Mtechnology.Item 7: DOE welcomes comment on any additional lamps should be excluded from the scope of coverage. DOE welcomes comments on the tentative decision to not standby and off modes in the energy conservation standard
18 | Building Technologies Program 

Metrics – Omnidirectional Lamps

• DOE is considering establishing a minimum initial lamp effic

requirement for HID lamps. Initial lamp efficacy is defined as light output divided by lamp input power at the beginning of 

the lamp.

• DOE is also considering setting a maximum lamp wattage r

based on initial lamp light output. 
19 | Building Technologies Program 

Metrics – Directional Lamps

• Should DOE decide to include directional lamps within the s

coverage, they would require a different metric to assess eff

• Directional lamps are typically characterized by beam angle

require a minimum center-beam candlepower (CBCP) relatebeam angle of the lamp for a given lamp shape and diamete

• Directional lamps can also be characterized by beam lumen

output within the region outlined by the beam angle); DOE cminimum beam lumens per input watt.
20 | Building Technologies Program 

Metrics

Item 13: DOE welcomes comments related to the appropriof lamp efficacy as one of the potential metrics in HID lamp conservation standards.Item 14: DOE welcomes comments on developing a centeintensity metric related to directional lamps. DOE requests information on other possible metrics in development or othmetrics that DOE should consider, including beam lumens watt. DOE requests comments on the appropriate definition beam angle.
21 | Building Technologies Program 

Energy Use; Markup AnalysisLCC and Payback Period Analyses

Shipments Analysis; NIA AnalysisNOPR Analyses

Public Meeting Slides Topics

45671 Overview; Scope of Coverage3 Engineering; Product Price Determination2 Market and Technology; Screening
22 | Building Technologies Program 

Steps in the Interim Analysis

Framework

Document

InterimAnalysis NOPR Final Rule

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Market & Technology Assessment

Markup Analysis
23 | Building Technologies Program 

Purpose of Market and Technology Assessment; Screening Analysis

• Market and Technology Assessment

 Determine equipment classes  Identify technology options to improve efficacy

• Screening Analysis

 Screen out technology options that DOE will not consider in 

engineering analysis based on (1) technological feasibility; (practicability to manufacture, install, and service; (3) adverson utility to consumers or availability; and (4) adverse impacor safety. 
24 | Building Technologies Program 

Equipment Classes

• DOE divides covered equipment into classes by:

 the type of energy used; capacity of the product; or  other performance-related features that justify different stan

such as features affecting consumer utility.

• DOE establishes separate energy conservation standards 

equipment class.

• DOE is considering establishing equipment classes based 

and initial light output.

• Because DOE is considering factors such as CCT and ligh

DOE is not considering separating equipment classes basetechnology (i.e., not by MH, MV, and HPS).
25 | Building Technologies Program 

Equipment Classes: CCT

• HID lamps are available with different CCT values dependin

type and design. 

• Equipment usage indicates that some customers specify lam

particular color temperature for certain applications, indicatinprovides utility to the consumer.

• CCT is related to lamp efficacy (i.e., higher CCT lamps gene

lower efficacy).

• Based on the difference in efficacy and consumer utility, DO

considering separating equipment classes by CCT.

Directionality Ballast Location CCT 

Omni-Directional Externally Ballasted

1900 2501 5001 
26 | Building Technologies Program 

Equipment Classes: Initial Light Output

• HID lamps are available with a variety of light outputs and in

Light output and input power are highly correlated (increased power typically leads to increased light output), but DOE find

output more directly addresses the feature valued by the cus

• Customers require more or less light output from a lamp dep

the intended use for the lamp, indicating consumer utility for feature.

• DOE’s review of catalog data indicates that lamps of increas

output (or increased input power) are generally more efficac

• Based on the difference in lamp efficacy and consumer utility

considering establishing separate equipment classes on the initial light output.
27 | Building Technologies Program 

Equipment Classes: Example

In summary, DOE proposed the following equipment classes:

Directionality Ballast Location CCT Range L

Omni-Directional Externally Ballasted

1900 – 2500 K

1  3,0

3,001  5,001  8,001  11,001 20,001 40,001 > 100,0

2501 – 5000 K

1 – 3,03,001 – 5,001 – 8,001 – 12,001 20,001 > 50,00

Continued
28 | Building Technologies Program 

Equipment Classes

Item 16: DOE welcomes comments on the proposed equipclasses for HID lamps and additional approaches to defininin accordance with the requirements of 42 U.S.C. 6295(q). Specifically, DOE seeks input on its proposal to establish eclasses based on lumen output (rather than rated wattage) CCT, and the appropriateness of the lumen output and CCselected.Item 17: DOE seeks comment on whether the proposed eqclasses should be further subdivided by lamp orientation (aknown as operating or burn position and typically includes horizontal, universal) or by other lamp characteristics (e.g., or open fixture rating, CRI, base type, coated or clear enveDOE also seeks comment on whether equipment classes sseparated based on lamp technology.
29 | Building Technologies Program 

Technology Options

• Measures that improve efficacy are called technology options

are based on existing technologies as well as working prototy

• MV lamps

 The common pathway to increased efficacy is a change of tec

MV to MH or HPS.

• HPS lamps

 HID lamp catalogs indicate a range of HPS lamp efficacies, bu

currently aware of the specific technology options used to achthe lamp efficacies.

 DOE does not consider other lamp technologies to be substitu
30 | Building Technologies Program 

Technology Options

Technology Option Description 

Starting Method Use pulse-start instead of probe-stArc Tube Design

Arc Tube Material Use ceramic rather than quartz arc Arc Tube Size Use formed or offset electrode

Arc Tube Fill Gas Use novel gasesLamp Electrodes Use electrodes with improved desig

• DOE is aware of a set of technology options that could imp

lamp efficacy. DOE intends to evaluate the following: 

Item 18: DOE welcomes comments on the preliminary techoptions identified in this section, and on whether there are atechnology options it should consider.
31 | Building Technologies Program 

Screening Analysis

• DOE will consider each technology option in light of four scree

 technological feasibility;  practicability to manufacture, install, and service; adverse effects on product utility or availability; and adverse effects on health or safety.

• Those technology options that pass the four screening criteria 

design options; these options will be considered in the engineanalysis as ways to improve efficacy.

Item 19: DOE welcomes comments on how the above fouscreening criteria might apply to technology options under consideration by DOE, and how the screening criteria appadditional technology option(s) that an interested party recommends to DOE.
32 | Building Technologies Program 

Energy Use; Markup AnalysisLCC and Payback Period Analyses

Shipments Analysis; NIA AnalysisNOPR Analyses

Public Meeting Slides Topics

45671 Overview; Scope of Coverage2 Market and Technology; Screening3 Engineering; Product Price Determination
33 | Building Technologies Program 

Steps in the Interim Analysis

Framework

Document

InterimAnalysis NOPR Final Rule

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Market & Technology Assessment

Markup Analysis
34 | Building Technologies Program 

Engineering Analysis Methodology

 Choose equipment classes to be analyzed in the en

analysis. 

 Identify baseline models in each representative equ

class that will serve as reference points to assess cdue to more stringent standard levels.

 Select more efficacious replacements for each base

based on design options.

 Develop candidate standard levels (CSLs) that rang

baseline to the maximum technologically feasible.

 Scale results to equipment classes not analyzed. Scale 

Results

Choose 

Representative 

Equipment 

Classes

Select Baseline 

Models

Identify Higher 

Efficacy

Replacements

Develop

Efficacy Levels
35 | Building Technologies Program 

Representative Equipment Classes and Baseline Models

• DOE chooses representative equipment cla

concentrate its analytical effort. 

 DOE selects representative equipment classe

high market volumes or unique performance 

 DOE selected 9 equipment classes as repres

• The baseline model typically represents the 

common, least efficacious model on the ma

 DOE identifies a baseline model in each repr

equipment class.

 In cases where a large portion of the market 

adopted a more efficacious lamp, DOE is conanalyzing two baseline models.

Scale 

Results

Choose 

Representative 

Equipment 

Classes

Select Baseline 

Models

Identify Higher 

Efficacy

Replacements

Develop

Efficacy Levels
36 | Building Technologies Program 

Representative Equipment Classes and Baseline Models

Class Description Baseli

Omni-Directional, Externally Ballasted

Lamps 1500-2500 K

3,001 – 5,000 lm 50 W HP8,001 – 11,000 lm 100 W H20,001 – 40,000 lm 250 W H40,001 – 100,000 lm 400 W H

Omni-Directional, Externally Ballasted 

Lamps 2501–5000 K

3,001 – 5,000 lm 100 W M

70 W Pu

8,001 – 12,000 lm 175 W M

150 W P

12,001 – 20,000 lm 250 W M

175 W P

20,001 – 50,000 lm 400 W M

400 W P

 50,001 lm 1000 W P

Scale 

Results

Choose 

Representative 

Equipment 

Classes

Select Baseline 

Models

Identify Higher 

Efficacy

Replacements

Develop

Efficacy Levels
37 | Building Technologies Program 

Representative Equipment Classes and Baseline Models

Scale 

Results

Choose 

Representative 

Equipment 

Classes

Select Baseline 

Models

Identify Higher 

Efficacy

Replacements

Develop

Efficacy Levels

Item 20: DOE welcomes comments on the serepresentative equipment classes for HID lamItem 21: DOE welcomes comments on the sebaseline models for the proposed representatequipment classes.
38 | Building Technologies Program 

Identify Higher Efficacy Replacements

• In identifying more efficacious lamps, DOE w

database of HID lamp catalog information.

• DOE chooses more efficacious replacements 

lumen outputs and performance characteristiCRI, CCT) to those of the baseline models, wreducing system input power.

• DOE notes that its analysis of energy consum

be based on a lamp-and-ballast system becalamp and ballast operate together in practice

Scale 

Results

Choose 

Representative 

Equipment 

Classes

Select Baseline 

Models

Identify Higher 

Efficacy

Replacements

Develop

Efficacy Levels
39 | Building Technologies Program 

Identify Higher Efficacy Replacements

Scale 

Results

Choose 

Representative 

Equipment 

Classes

Select Baseline 

Models

Identify Higher 

Efficacy

Replacements

Develop

Efficacy Levels

Item 22: DOE welcomes comments on more (and equal lumen output) substitutes for each baseline model, up to and including the max tthat would result in reduced energy consumptItem 23: DOE welcomes comment on the curfuture availability of reduced wattage lamps apracticality of reducing and respacing fixturesinvites comment on whether barriers exist to dnew lamps that would provide reduced wattagalternatives to today’s lamps.
40 | Building Technologies Program 

Develop Efficacy Levels

• After identifying the more efficacious substit

each baseline model, DOE will develop CSof efficacy levels considered in the interim athat span the range of lamp efficacies from to the maximum technologically feasible.

• CSLs for HID lamps are generally based on 

consideration of several factors, including:

 Design options associated with the specific l

being studied; and

 The maximum technologically feasible effica

Scale 

Results

Choose 

Representative 

Equipment 

Classes

Select Baseline 

Models

Identify Higher 

Efficacy

Replacements

Develop

Efficacy Levels
41 | Building Technologies Program 

Develop Efficacy Levels

• The equipment class structure reflects a “bi

approach, which establishes a constant lamrequirement for particular ranges of light ou

• Although a constant efficacy requirement si

standards for manufacturers, it would subjein a particular light output range to the same which could encourage the market towards light output (and higher input power) end of 

• DOE is also considering an equation-based 

which would establish lamp efficacy requirefunction of light output. Scale Results

Choose 

Representative 

Equipment 

Classes

Select Baseline 

Models

Identify Higher 

Efficacy

Replacements

Develop

Efficacy Levels
42 | Building Technologies Program 

Develop Efficacy Levels

Scale 

Results

Choose 

Representative 

Equipment 

Classes

Select Baseline 

Models

Identify Higher 

Efficacy

Replacements

Develop

Efficacy Levels

Item 24: DOE welcomes comments on the use equation-based versus binned efficacy level apHID lamps. Item 25: DOE welcomes input on whether highefficacious lighting systems could be eliminateparticular lamp efficacy requirement.
43 | Building Technologies Program 

Scale Results

• For the equipment classes not analyzed dir

DOE plans to scale the engineering results CSLs from the representative equipment cladata based on ratios observed in catalog daextrapolation using regression equations.

Scale 

Results

Choose 

Representative 

Equipment 

Classes

Select Baseline 

Models

Identify Higher 

Efficacy

Replacements

Develop

Efficacy Levels

Item 26: DOE welcomes comments on its proapproach to scale from representative equipmclasses to classes not directly analyzed in the engineering analysis.
44 | Building Technologies Program 

Issues for Discussion

Item 28: DOE seeks information regarding the existence orelevant proprietary designs for the HID lamps under consiin this rulemaking. DOE also seeks comment on whether thproprietary designs are the only pathway to increase lamp Item 30: DOE welcomes comments on other engineering ithat could affect the engineering analysis.
45 | Building Technologies Program 

Product Price Determination

• DOE plans to estimate end-user price directly, rather than d

manufacturer selling prices (MSP) from a bill of materials anmanufacturer markup analysis.

• DOE is considering collecting manufacturer suggested price 

books”) and applying a discount based on the distribution chthrough which the lamp is purchased.

• DOE will gather price information from State procurement co

large electrical supply distributors, home-improvement/hardwand other sources of publicly available end-user prices such retailers, to estimate the appropriate discounts.

Item 27: DOE seeks comment on its end-user price approaccalculating the cost-efficacy relationship for HID lamps. In paDOE seeks comment on typical distribution channels for HID as well as the allocation of market share between these cha
46 | Building Technologies Program 

Engineering; Product Price DeterminationLCC and Payback Period Analysis

Shipments Analysis; NIA AnalysisNOPR Analyses

Public Meeting Slides Topics

35671 Overview; Scope of Coverage2 Market and Technology; Screening4 Energy Use; Markup Analysis
47 | Building Technologies Program 

Steps in the Interim Analysis

FrameworkDocument

InterimAnalysis NOPR Final Rule

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Market & Technology Assessment

Markup Analysis
48 | Building Technologies Program 

• Purpose

– Develop annual energy use data for HID lamp and ballast sy

• Method

– Obtain data to develop a distribution of operating hours for H

by sector and census division. Data sources include:

• 2010 U.S. Lighting Market Characterization• EIA’s 2003 Commercial Building Energy Consumption S

(CBECS)

• EIA’s 2006 Manufacturing Energy Consumption Survey 

– Use system input power from engineering analysis.– Multiply system input power by the number of operating hou

Energy Use Analysis
49 | Building Technologies Program 

Issues for Discussion

Item 31: DOE welcomes comments on ballast input power aefficiency for lamp and ballast systems stock installed prior to effective date of standard. Item 32: DOE welcomes comments on its proposed methododetermine annual operating hours for covered HID lamps in tcommercial and industrial sectors, and how operating hours by lamp type and application.
50 | Building Technologies Program 

Steps in the Interim Analysis

FrameworkDocument

InterimAnalysis NOPR Final Rule

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Market & Technology Assessment

Markup Analysis
51 | Building Technologies Program 

• Purpose

– Determine MSP from HID lamp prices using manufacturer-to

markups to use in MIA.

– Characterize HID lamp distribution channels.

• Method

– Identify distribution channels. – Estimate the markups for each step from manufacturer to en

Derive MSP from end-user prices, developed at the price destage. 

Markups for Equipment Price Determination
52 | Building Technologies Program 

Markups for Equipment Price Determination

HID Lamp Distribution Channels:

Item 33: DOE welcomes suggestions and comments concerproposed approach for existing customer prices for HID lampand fixtures.Item 34: DOE welcomes comments on typical manufacturer, wholesaler, and contractor markups associated with HID lamballasts, and fixtures.

Lamp manuf. Wholesaler Contractor Lamp manuf. Wholesaler End userBallast manuf. Wholesaler Contractor Fixture manuf. Wholesaler Contractor 

12

Replacement HID Ballast Distribution Channels:Fixture Distribution Channels:
53 | Building Technologies Program 

Engineering; Product Price DeterminationEnergy Use; Markup Analysis

Shipments Analysis; NIA AnalysisNOPR Analyses

Public Meeting Slides Topics

34671 Overview; Scope of Coverage2 Market and Technology; Screening5 LCC and Payback Period Analysis
54 | Building Technologies Program 

Steps in the Interim Analysis

FrameworkDocument

InterimAnalysis NOPR Final Rule

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Market & Technology Assessment

Markup Analysis
55 | Building Technologies Program 

• Purpose

– Assess the LCC effects and PBP for customers of HID lamp

considered efficacy levels.

• Methodology

– LCC equals customer price plus the sum of annual operating 

the analysis period (baseline lamp lifetime divided by averaghours) discounted to a particular base year.

– Analysis will model the uncertainty and variability of inputs u

Carlo approach and probability distributions.

– Analysis will be implemented in MS Excel® spreadsheet com

Crystal Ball.®

Life-Cycle Cost and Payback Period Analysis

First Cost

(Customer Price +

Installation Cost)

Operating 

Expenses

Combine Changes 

in Costs

LCC Results

Convert to Present Value
56 | Building Technologies Program 

• Electricity prices are used to convert energy use to energy • DOE will use projections of national average energy price

commercial and industrial customers – from the most receAnnual Energy Outlook (AEO) – to project future energy pthe LCC analysis

Life-Cycle Cost and Payback Period Analysis – Energy Prices

Item 35: DOE welcomes input on the proposed methodology estimating electricity prices in this analysis.
57 | Building Technologies Program 

Life-Cycle Cost and Payback Period Analysis – Discount Rates

• DOE uses the discount rate to determine the present value 

operating expenses.

• DOE will derive a distribution of discount rates for the comm

industrial sectors.

– These distributions will be developed by estimating the weight

cost of capital (WACC) for commercial and industrial customelamps.

– WACC includes:

• Financial cost of any debt incurred to purchase equipment• Opportunity cost of any equity to purchase equipment.

Item 36: DOE welcomes input on the planned approaches fodiscount rates for customers of the HID lamps covered underulemaking.
58 | Building Technologies Program 

• DOE will evaluate how installation costs change with incre

efficacy. DOE will consider:

– Installation cost (labor rate x hours for labor) of a lamp– Installation cost for replacing a ballast– Installation cost for a fixture

• DOE will review and consider:

– RSMeans– Industry literature for other installation cost

• Repair and Maintenance costs: DOE assumes HID lamps 

maintenance during operational lifetime and are replaced failure or early retirement.

Life-Cycle Cost and Payback Period Analysis – Operating Costs
59 | Building Technologies Program 

Issues for Discussion

Item 37: DOE welcomes suggestions on how to estimate inscosts for HID lamps. DOE specifically seeks comment on the availability and value of sources other than RSMeans ElectriData to consider in estimating installation costs.Item 39: DOE welcomes comments on whether maintenance costs for HID lamps, ballasts or fixtures should be considered analysis. 
60 | Building Technologies Program 

Life-Cycle Cost and Payback Period Analysis – HID Lamp Lifetimes

• DOE will use information from:

– Manufacturer literature; – Various literature sources such as technical reports and confe

proceedings; and 

– Inputs from manufacturers and other interested parties. 

• In the 2009 GSFL/IRL, DOE adjusted rated lamp lifetimes t

the effects of group relamping – reducing life to 91%–94% 

lifetime.

• DOE is investigating group versus spot relamping.• Group relamping is less per lamp because labor is pooled.
61 | Building Technologies Program 

Issues for Discussion

Item 40: DOE welcomes comments on appropriate lifetimes HID lamps covered in this rulemaking, and how lamp life shoadjusted to reflect group relamping practices by lamp type anItem 38: DOE welcomes comments on whether relamping pr(i.e., group or spot relamping) would change if HID lamp life by new energy conservation standards.
62 | Building Technologies Program 

Engineering; Product Price DeterminationEnergy Use; Markup AnalysisLCC and Payback Period Analysis

NOPR Analyses

Public Meeting Slides Topics

34571 Overview; Scope of Coverage2 Market and Technology; Screening6 Shipments Analysis; NIA Analysis
63 | Building Technologies Program 

Steps in the Interim Analysis

FrameworkDocument

InterimAnalysis NOPR Final Rule

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Market & Technology Assessment

Markup Analysis
64 | Building Technologies Program 

• Purpose

– To project HID lamp shipments in the base-case and standa

calculate the effects of standards on energy savings and preof savings.

• Method

– The shipments model will rely on a range of data sources in

not limited to:

• Manufacturers and industry organizations, • National market reports,• National energy and lamp use surveys, and• Historical HID lamp shipments from NEMA. 

Shipments Analysis
65 | Building Technologies Program 

Issues for Discussion

Item 15: DOE welcomes input on disaggregated market shshipment data based on input wattage for each HID lamp teItem 41: DOE welcomes recommendations on sources of dshipments of HID lamps by proposed equipment class. In adDOE welcomes comments on future long-term trends in HID efficacy (e.g., market share of probe-start quartz MH versus start quartz and/or pulse-start ceramic MH) for the baseline projections.
66 | Building Technologies Program 

Shipments AnalysisShipments Model - Methodology

• Accounting methodology

‒ New Installations: Applies to HID lamps in new fixtures that a

each year from growth in a particular sector. DOE proposes tthis by using the National Energy Modeling System (NEMS) fgrowth projections for the commercial sector as well as historrates for put-in-place construction from Census.

‒ Replacements: HID lamps that have failed or retired from se

bases this calculation on lamp shipments and retirement rate

‒ Retrofits (early replacements): Applies to lamps and fixtures 

replacing existing equipment during renovation or remodelinreplacement generally occurs before a lamp has failed. 

Item 42: DOE welcomes comments on the accounting methodescribed for each type of HID lamp covered in this rulemaki
67 | Building Technologies Program 

• Provides the basis to compare projections for higher effici

(standards case).

• Depicts the situation where new or amended standards ar

adopted.

• Depicts the current and projected mix of HID lamp efficac

the absence of new regulation.

– DOE will develop projected market shares of equipment by e

under the base case. 

• Data requirements:

– Historical shipments– Breakdown of shipments by equipment class– Lifetime distributions

Shipments AnalysisBase-Case Shipments Projections
68 | Building Technologies Program 

Shipments AnalysisStandards Effects on HID lamps

• DOE develops standards-case projections from the same d

use to develop the base-case projections.

• Standards-case projections may also use purchase price i

operating cost savings to estimate shipments effects.

• DOE will also consider effects from market-pull programs.

Item 43: DOE welcomes comments on how proposed energconservation standards might affect shipments of HID lampsrequests information on the effect of existing market-pull prog(e.g., customer rebates) on HID lamps.
69 | Building Technologies Program 

Steps in the Interim Analysis

FrameworkDocument

InterimAnalysis NOPR Final Rule

ScreeningAnalysis

EngineeringAnalysis

Energy Use Characterization

ShipmentsAnalysis

Life-CycleCost andPayback Period Analysis

Market & Technology Assessment

Markup Analysis
70 | Building Technologies Program 

• Purpose

– To assess the aggregate effects at the national level of pote

conservation standards for each of the equipment classes, inet present value (NPV) of total customer economic effects energy savings (NES).

• Method

– DOE calculates annual equipment expenditures by multiplyi

per unit by projected shipments.

– The difference between base- and standards-case scenario

national energy bill savings and increased expenditure in do

– The difference each year between energy bill savings and in

equipment expenditures is the net savings (if positive) and nnegative).

National Impact Analysis
71 | Building Technologies Program 

National Impact AnalysisNES Flow Diagram

Base Case

Annual Energy

Consumption

2046

Base Case

Annual Energy

Consumption

2019

Base Case

Annual Energy

Consumption

2018

Base-Case

Annual Energy

Consumption

2017

Shipments

Analysis Sta

Pro

Base-Case Projections

Base Case

Annual Ener

Consumptio

Base Case

Annual Energy

Consumption

2019

Base Case

Annual Energy

Consumption

2018

Standards-Case

Annual Energy

Consumption

2017

Base-Case

Cumulative

Energy Use

Standards-Case 

Cumulative

Energy Use

Site-to-Source

Energy

Conversion

National Energy

Savings
72 | Building Technologies Program 

National Impact AnalysisNational Customer NPV Diagram

Shipments

Analysis

SPr

Energy Cost

(2017 – 2046)

Base-CaseProjections

Cumulative

Operating Cost 

Savings

Cumulative

Total Equipment

Cost Increase

Discount 

Rate

Net Present

Value

Repair & Maint.

Cost

(2017 – 2046)

Total Install 

Cost

(2017 – 2046)

Energy Cost

(2017 – 2046)

Repair & Mai

Cost

(2017 – 204
73 | Building Technologies Program 

Issues for Discussion

Item 44: DOE welcomes comments on the proposed data aprojection sources it anticipates using to develop inputs for thimpact analysis.Item 45: DOE welcomes comments as to whether more efficHID lamp designs would be operated more as a result of theincreased efficacy (i.e., whether a positive rebound effect woexpected for this equipment) and if so how much longer wouoperated.
74 | Building Technologies Program 

National Impact AnalysisCalculation of NES

• DOE intends to calculate national energy consumption fo

year beginning with the expected compliance date of the standards and over a 30-year period.

• DOE will use the DOE NES spreadsheet for standard ru

Item 46: DOE welcomes comment from interested parties on spreadsheet models it plans to use for estimating national effnew energy conservation standards for HID lamps.
75 | Building Technologies Program 

Engineering; Product Price DeterminationEnergy Use; Markup AnalysisLCC and Payback Period AnalysisShipments Analysis; NIA Analysis

Public Meeting Slides Topics

34561 Overview; Scope of Coverage2 Market and Technology; Screening7 NOPR Analyses
76 | Building Technologies Program 

Steps in the NOPR

NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Revise Interim Analysis

EmissioAnalysis

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

InterimAnalysis

FrameworkDocument

FinalRule
77 | Building Technologies Program 

• Purpose

– Analyze the economic effects of standards on customers, in

subgroups who may be affected disproportionately comparegeneral user population.

• Possible examples for HID lamps: utilities, municipalities

transportation facilities.

• Method

– Extend the LCC analysis to examine the effects for defined s– DOE will use inputs specific to each of the considered custo

subgroups.

Life-Cycle Cost Subgroup Analysis

Item 47: DOE welcomes comments from interested parties oany, customer subgroups should be considered when develostandards for HID lamps.
78 | Building Technologies Program 

Steps in the NOPR

NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Revise Interim Analysis

EmissioAnalysis

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

InterimAnalysis

FrameworkDocument

FinalRule
79 | Building Technologies Program 

• Purpose

– Assess the impacts of standards on manufacturers. – Identify and estimate impacts on manufacturer subgroups th

more severely impacted than the industry as a whole.

– Examine the impact of cumulative regulatory burden on the 

• Method

– Analyze industry cash flow and NPV through use of the Gov

Regulatory Impact Model (GRIM).

– Interview manufacturers to refine inputs to the GRIM, develo

analyses, and address qualitative issues.

Manufacturer Impact Analysis
80 | Building Technologies Program 

MIA Methodology

The MIA consists of three main phases: 

Industry profile

Develop strawman GRIM

Develop interview guide

Interviews& industrywide / subgroupanalyses

Phase 2 Phase 3

Initial MIA Interviews

Phase 1

Interim Analysis

NOPR

Item 48: DOE seeks comments on the subgroups of HID lammanufacturers that it should consider in a manufacturer subganalysis.Item 49: DOE welcomes comments on other regulations or regulations it should consider in its examination of cumulativregulatory burden.
81 | Building Technologies Program 

Steps in the NOPR

NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Revise Interim Analysis

EmissioAnalysis

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

InterimAnalysis

FrameworkDocument

FinalRule
82 | Building Technologies Program 

• Purpose

– Assess the overall effects on domestic energy supplies that w

from the imposition of standards. 

• Method

– DOE proposes to use National Energy Modeling System (NE

Building Technologies (BT) developed and used by DOE/EIA report, as the basis of the utility impact analysis.

– DOE will model the energy savings impacts from energy con

standards using NEMS-BT to generate projections that may dthe AEO reference case.

– Outputs of the utility impact analysis include projections of el

generation, and avoided capacity resulting from a comparisoand standards cases.

Utility Impact Analysis

Item 50: DOE seeks input on its plans to use NEMS-BT to coutility impact analysis on the equipment covered under this ru
83 | Building Technologies Program 

Steps in the NOPR

NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Revise Interim Analysis

EmissioAnalysis

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

InterimAnalysis

FrameworkDocument

FinalRule
84 | Building Technologies Program 

• Purpose

– Assess the overall effect on national employment from the im

energy conservation standards at differing levels.

– Include both direct and indirect employment impacts.– Direct employment impacts are estimated in the manufacture

analysis.

– Indirect employment impacts result from shifting customer ex

among goods and services (“substitution effect”) and changeand overall expenditure levels (“income effect”).

• Method

– DOE intends to use the Impact of Sector Energy Technologie

model for the evaluation of indirect employment impacts.

Employment Impact Analysis

Item 51: DOE requests feedback on its approach to assessinemployment impacts on the equipment covered under this ru
85 | Building Technologies Program 

Steps in the NOPR

NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Revise Interim Analysis

EmissioAnalysis

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

InterimAnalysis

FrameworkDocument

FinalRule
86 | Building Technologies Program 

• Purpose

– To report environmental effects resulting from energy conse

standards, including changes in power plant emissions. 

• Method

– DOE intends to use the emissions effects projected from the 

modeling analysis used for the Utility Impacts Analysis. 

• Carbon dioxide (CO2) will be the primary emissions repo• Existing legislation cap Sulfur Dioxide (SO2), so physical 

reductions will be zero or nearly zero from any single eneconservation standard. 

• Nitrogen Oxide (NOx) emissions will be reported for the 2

where emissions are not capped.

• Mercury (Hg) emissions will also be reported.

Emissions Analysis

Item 52: DOE seeks input on its plan to use NEMS-BT to conemissions analysis for the equipment covered by this rulema
87 | Building Technologies Program 

Monetization of Emission Reductions

• DOE intends to use the most current social cost of carbon 

values developed by interagency reviews.

– SCC is intended to be a monetary measure of the incrementa

resulting from greenhouse gas (GHG) emissions, including blimited to agricultural productivity loss, human health effects, damage from rising sea level, and changes in the ecosystem

• At present, the most recent interagency estimates of the p

global benefits resulting from reduced CO2 emissions in 20

$4.9, $22.3, $36.5, and $67.6 per metric ton in 2010 dollar

– For emission reductions that occur in later years, these value

real terms over time.

• DOE will also estimate the potential monetary benefit of re

NOx emissions resulting from the considered standard leve
88 | Building Technologies Program 

Steps in the NOPR

NOPR

Manufacturer

Impact 

Analysis

Utility

Impact 

Analysis

Employment

Impact

Analysis

Life-Cycle 

Cost 

Subgroup 

Analysis

Revise Interim Analysis

EmissioAnalysis

EngineeringAnalysis

Life-CycleCost &Payback PeriodAnalyses

National

Impact

Analysis

InterimAnalysis

FrameworkDocument

FinalRule
89 | Building Technologies Program 

• Purpose

– To investigate the national effects of non-regulatory alternati

compared with mandatory energy conservation standards.

– The non-regulatory alternatives that may be considered inclu

• Customer rebates; • Customer tax credits; • Manufacturer tax credits; • Voluntary efficiency targets; • Early replacement; and• Bulk government procurement.

• Method

– Modify NES spreadsheet model to consider non-regulatory s– Estimate effects of non-regulatory scenarios based on expe

the considered policies.

– Output will include NES and NPV of the non-regulatory alter

Regulatory Impact Analysis
90 | Building Technologies Program 

How to Submit Written Comments

• In all correspondence, please refer to the HID lamps rulemak

– High-Intensity Discharge Lamps Energy Conservation Standa– 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: April 12, 2012, 11:59 PM EDT

Postal: Courier:Ms. Brenda EdwardsU.S. Department of EnergyBuilding Technologies Program, Mailstop EE-2J1000 Independence Avenue, SWWashington, DC 20585-0121

Ms. Brenda EdwardsU.S. Department of EnergBuilding Technologies Pro950 L’Enfant Plaza, SWWashington, DC 20024Tel: 202 586-2945
91 | Building Technologies Program 

Relevant URLs

• DOE Appliance Standards

– http://www1.eere.energy.gov/buildings/appliance_standards/

• HID Lamps Energy Conservation Standard and Test Procedu

– http://www1.eere.energy.gov/buildings/appliance_standards/c

igh_intensity_discharge_lamps.html

• Metal Halide Lamp Fixture Energy Conservation Standard

– http://www1.eere.energy.gov/buildings/appliance_standards/c

metal_halide_lamp_fixtures.html
92 | Building Technologies Program 

Questions?