Framework Document for

High-Intensity Discharge Lamps

U.S. Department of Energy

Office of Energy Efficiency and Renewable Energy

Building Technologies Program

February 21, 2012
ii

TABLE OF CONTENTS

1 INTRODUCTION ..................................................................................................................1

1.1 Overview of the Framework Document .....................................................................1

1.2 Authorities...................................................................................................................1

1.3 Coordinated Development of HID Lamps and MHLF Rulemakings.........................2

1.4 Overview of the Rulemaking Process.........................................................................3

1.4.1 Rulemaking Process and Participation of Interested Parties........................3

1.4.2 Interim Analyses..........................................................................................5

1.4.3 Notice of Proposed Rulemaking ..................................................................6

1.4.4 Final Rule.....................................................................................................7

1.5 Scope of Coverage ......................................................................................................7

1.5.1 Specific Lamp Categories under Consideration for the Scope of Coverage8

1.5.2 Summary of the Scope of Coverage ..........................................................11

1.5.3 Standby Mode and Off Mode Standards....................................................12

1.6 Test Procedures.........................................................................................................13

1.6.1 Statistical Values........................................................................................14

1.6.2 National Voluntary Laboratory Accreditation Program (NVLAP) ...........14

1.7 Metrics ......................................................................................................................15

1.7.1 Lamp Efficacy............................................................................................15

1.7.2 Input Wattage.............................................................................................16

1.7.3 Center-Beam Candlepower (Intensity) ......................................................16

1.7.4 Beam Lumens Per Watt .............................................................................16

2 OVERVIEW OF ANALYSES FOR RULEMAKING.........................................................17

3 MARKET AND TECHNOLOGY ASSESSMENT.............................................................19

3.1 Market Assessment ...................................................................................................19

3.1.1 Equipment Classes.....................................................................................20

3.2 Technology Assessment............................................................................................23

3.2.1 Mercury Vapor Lamps...............................................................................24

3.2.2 High-Pressure Sodium Lamps ...................................................................24

3.2.3 Metal Halide Lamps...................................................................................24

4 SCREENING ANALYSIS ...................................................................................................25

5 ENGINEERING ANALYSIS...............................................................................................26

5.1 Engineering Analysis Overview ...............................................................................26

5.2 Representative Equipment Classes...........................................................................26

5.3 Baseline Models........................................................................................................27

5.4 Identify Higher-Efficacy Lamp Replacements.........................................................28

5.5 Efficacy Levels .........................................................................................................29

5.6 Scaling Method .........................................................................................................30

5.7 Product Price Determination.....................................................................................30

5.8 Proprietary Designs...................................................................................................31

5.9 Outside Regulatory Changes Affecting the Engineering Analysis...........................31

6 ENERGY-USE CHARACTERIZATION............................................................................31

7 MARKUP ANALYSIS.........................................................................................................33

7.1 Distribution Channels...............................................................................................33

7.2 Markups ....................................................................................................................34
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8 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES .........................................34

8.1 Electricity Prices.......................................................................................................36

8.2 Life-Cycle Cost Discount Rates................................................................................37

8.3 Installation, Maintenance, and Repair Costs.............................................................37

8.4 HID Lamp Lifetimes.................................................................................................38

9 SHIPMENTS ANALYSIS ...................................................................................................39

9.1 Baseline Forecast ......................................................................................................39

9.2 Accounting Methodology .........................................................................................39

9.3 Standards’ Effect on HID Lamp Shipments.............................................................40

10 NATIONAL IMPACT ANALYSIS.....................................................................................41

10.1 Inputs to NES and NPV Forecasts............................................................................41

10.2 Calculation of National Energy Savings...................................................................42

10.3 Net Present Value of Consumer Savings..................................................................43

11 LIFE-CYCLE COST SUBGROUP ANALYSIS .................................................................43

12 MANUFACTURER IMPACT ANALYSIS.........................................................................44

12.1 Sources of Information for the Manufacturer Impact Analysis................................44

12.2 Industry Cash-Flow Analysis....................................................................................45

12.3 Manufacturer Subgroup Analysis.............................................................................45

12.4 Competitive Impacts Analysis..................................................................................46

12.5 Cumulative Regulatory Burden ................................................................................46

13 UTILITY IMPACT ANALYSIS..........................................................................................47

14 EMPLOYMENT IMPACT ANALYSIS..............................................................................47

15 EMISSIONS ANALYSIS.....................................................................................................48

15.1 Carbon Dioxide.........................................................................................................49

15.2 Sulfur Dioxide...........................................................................................................49

15.3 Nitrogen Oxides........................................................................................................49

15.4 Mercury.....................................................................................................................50

15.5 Particulate Matter......................................................................................................50

16 MONETIZING CARBON DIOXIDE AND OTHER EMISSIONS REDUCTIONS..........50

17 REGULATORY IMPACT ANALYSIS ..............................................................................51

APPENDIX A – LIST OF ITEMS FOR COMMENT..................................................................53

LIST OF TABLES

Table 1.1 Energy Conservation Standards Rulemaking Schedule for HID Lamps....................... 5

Table 3.1 Initial Proposed Equipment Classes ............................................................................ 22

Table 5.1 Representative Equipment Classes and Provisional Baseline Models ........................ 27

Table 8.1 Input to the Life-Cycle Cost and Payback Period Analyses........................................ 36

Table 10.1 Input Data, Factor, and Forecasts for the National Impact Analysis......................... 42

LIST OF FIGURES

Figure 2.1 Flow Diagram of Analyses Conducted for an Energy Conservation Standards 

Rulemaking................................................................................................................. 18
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LIST OF ABBREVIATIONS

ACEEE American Council for an Energy-Efficient Economy

AEO Annual Energy Outlook (Annual energy forecast published by EIA)

ANOPR advance notice of proposed rulemaking

ANSI American National Standards Institute

ASHRAE American Society of Heating, Refrigerating, and Air-Conditioning Engineers

atm atmosphere(s)

BOM bill of materials

CAIR Clean Air Interstate Rule

CAMR Clean Air Mercury Rule

CBCP center-beam candlepower 

CBECS Commercial Building Energy Consumption Survey by EIA

CCT correlated color temperature 

CFR Code of Federal Regulations

CIE Commission Internationale De L’Eclairage (int’l regulatory body)

cm

2 square centimeter(s)

CMH ceramic pulse-start metal halide

CO2 carbon dioxide

CRI color rendering index 

CSL candidate standard level

D.C. District of Columbia

DOE U.S. Department of Energy

DOJ U.S. Department of Justice

DSIRE Database of State Incentives for Renewables & Efficiency 

E26 Edison-base, 26 millimeters 

EGU electricity generating unit

EIA Energy Information Administration (DOE statistical and analytical agency)

EISA 2007 Energy Independence and Security Act of 2007

EPA U.S. Environmental Protection Agency

EPACT 1992 Energy Policy Act of 1992

EPACT 2005 Energy Policy Act of 2005

EPCA Energy Policy and Conservation Act of 1975

ER elliptical reflector (reflector lamp shape)

FR Federal Register

FTC Federal Trade Commission

GHG greenhouse gas 

GRIM Government Regulatory Impact Model 

GSFL general service fluorescent lamp

GSIL general service incandescent lamp

Hg mercury 

HID high-intensity discharge

HPS high-pressure sodium

IES Illuminating Engineering Society of North America

ImSET Impact of Sector Energy Technologies (PNNL-developed I/O model)

IRL incandescent reflector lamp
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K kelvin

kWh kilowatt-hour(s)

LCC life-cycle cost

LE lamp efficacy (an efficiency measure for visible light generation)

LED light-emitting diode (a type of SSL)

LEP light-emitting plasma

lm lumen(s) (a measurement of light flux.)

LMC U.S. Lighting Market Characterization

MECS Manufacturer Energy Consumption Survey (done for EIA by the Census)

MH metal halide

MHLF metal halide lamp fixture

MIA manufacturer impact analysis

MR multi-faceted reflector

MSP manufacturer selling price

MV mercury vapor

NEMA National Electrical Manufacturers Association

NEMS National Energy Modeling System (developed and used by EIA)

NEMS-BT National Energy Modeling System – Building Technologies

NES national energy savings

NESHAP national emissions standards for hazardous air pollutants

NIA national impact analysis

NOD notice of determination

NODA notice of data availability

NOPD notice of proposed determination

NOPM notice of proposed meeting

NOPR notice of proposed rulemaking

NOX nitrogen oxides

NPV net present value

NVLAP National Voluntary Laboratory Accreditation Program

OMB U.S. Office of Management and Budget

Pa pascal(s)

PAR parabolic-aluminized reflector (reflector lamp shape)

PBP payback period

PM particulate matter

PMH pulse-start metal halide

PNNL Pacific Northwest National Laboratory

quad quadrillion (1015) British thermal units 

RFI request for information

R reflector

SCC Social Cost of Carbon

SDG&E San Diego Gas & Electric

SEC U.S. Securities and Exchange Commission

SO2 sulfur dioxide

SSL solid-state lighting

TSD technical support document

TSL trial standard level
vi

U.S.C. United States Code 

W watt(s)
1

1 INTRODUCTION

The U.S. Department of Energy (DOE) Appliances and Commercial Equipment 

Standards Program, within the Office of Energy Efficiency and Renewable Energy’s Building 

Technologies Program, develops and promulgates test procedures and energy conservation 

standards for certain consumer products and commercial equipment. The process for developing 

standards involves analysis, public notice and comment, and consultation with interested parties. 

Interested parties include manufacturers, consumers, energy conservation and environmental 

advocates, State and Federal agencies, and any other groups or individuals with an interest in 

these standards and test procedures. 

1.1 Overview of the Framework Document 

The purpose of this framework document is to describe the procedural and analytical 

approaches DOE anticipates using to evaluate potential energy conservation standards for 

high-intensity discharge (HID) lamps (see section 1.2 for a discussion of the statutory authority 

for this rulemaking). This document is intended to inform interested parties of the process DOE 

will follow and to encourage and facilitate the input of interested parties during the rulemaking. 

This document serves as the starting point for developing energy conservation standards and is 

not a definitive statement on any issue to be determined in the rulemaking.

Section 1 of this document provides an overview of DOE’s rulemaking process. Sections 

2 through 17 discuss analyses DOE intends to conduct in determining whether to establish 

energy conservation standards for HID lamps, and if so at what level. DOE will maintain 

information about this rulemaking on its website at

http://www1.eere.energy.gov/buildings/appliance_standards/commercial/high_intensity_discharg

e_lamps.html.

Item 1 Although DOE invites comment on all aspects of the material presented in this 

document, several specific issues on which DOE seeks comment are set out in 

comment boxes like this one. DOE uses these comment boxes to highlight issues and 

ask specific questions regarding the approaches DOE plans to follow to conduct the 

analyses required for the energy conservation standards rulemaking. Such requests 

for feedback are numbered sequentially throughout the document and are repeated in 

appendix A.

1.2 Authorities 

Title III, Part C of the Energy Policy and Conservation Act of 1975 (EPCA), (42 U.S.C. 

6291–6317), as amended, established the Energy Conservation Program for Certain Industrial 

Equipment, which includes the HID lamps addressed in this framework document.1

 1 For editorial reasons, upon codification in the U.S. Code, Part C was re-designated Part A-1.

EPCA 

requires DOE to prescribe testing requirements for those HID lamps for which DOE makes a 

determination that energy conservation standards would be technologically feasible and 

economically justified, and would result in significant energy savings. 42 U.S.C. 6317(a)(1). 
2

EPCA further requires DOE, within 18 months of prescribing any testing requirements for HID 

lamps, to prescribe energy conservation standards for those lamps. 42 U.S.C. 6317(a)(2). Any 

standards would apply to lamps manufactured 36 months after the date the standards rule is 

published. 42 U.S.C. 6317(a)(3). 

DOE published a positive final determination2 that standards for certain HID lamps are 

technologically feasible, economically justified, and would result in a significant energy savings, 

estimated at 11.4 quadrillion British thermal units (quads) of cumulative energy savings over 30 

years. 75 FR 37975 (July 1, 2010). As a result of this determination, DOE is currently 

conducting a test procedure rulemaking for the specified lamps.3

1.5.3

In this framework document, 

DOE is considering standards for these HID lamps. During the standards rulemaking, DOE will 

decide whether and at what level(s) to promulgate energy conservation standards. The decision, 

which will incorporate public participation, will be based on the technological feasibility, 

economic justification, and energy savings of specific potential standard levels pursuant to the 

requirements of EPCA. (See, e.g., 42 U.S.C. 6295(o)-(p) and 6316(a)) DOE’s consideration of 

standby mode and off mode energy use for these standards is discussed in detail in section .

DOE received comments on the proposed determination (NOPD) for HID lamps from 

two interested parties: the American Council for an Energy-Efficient Economy (ACEEE) and 

San Diego Gas & Electric (SDG&E). These commenters encouraged DOE to hasten the issuance 

of an HID lamps energy conservation standards rulemaking and to combine a possible HID 

lamps energy conservation standards rulemaking with the ongoing metal halide lamp fixtures 

(MHLF) energy conservation standards rulemaking, or at least with the analysis. (Docket No. 

EERE-2006-DET-0112-001, ACEEE, No. 22 at p. 1; SDG&E, No. 23 at p. 2)4

1.3

DOE addresses 

this issue in section . 

1.3 Coordinated Development of HID Lamps and MHLF Rulemakings

Based on feedback from interested parties, DOE intends, to the extent feasible, to 

coordinate the development of its energy conservation standard rulemakings for HID lamps and 

metal halide lamp fixtures (MHLFs). DOE received comments on this subject in response to both 

its HID lamps final determination and MHLF framework document and preliminary analysis, 

with recommendations ranging from analyzing the equipment separately but including discussion 

of both in the same rulemaking document to regulating metal halide (MH) lamps and metal 

halide lamp fixtures collectively using a single system-based metric. This system-based metric 

would assess the performance of the lamp and fixture collectively, instead of separate metrics for 

each component. DOE has decided to develop the NOPRs for each rule separately because DOE 

is considering separate metrics for HID lamps and metal halide lamp fixtures. However, because 

 2 The 2010 HID lamps final determination is available at 

www1.eere.energy.gov/buildings/appliance_standards/commercial/high_intensity_discharge_lamps.html. 3 DOE published a proposed test procedure NOPR on December 15, 2011 (76 FR 77914) and expects to publish any 

final test procedures within 30 months of issuing the determination, or January 1, 2013.

4 A notation in the form “ACEEE, No. 22 at p. 1” refers to (1) a statement that was submitted by the American 

Council for an Energy-Efficient Economy and is recorded in the docket “Energy Conservation Program for 

Commercial and Industrial Equipment: High-Intensity Discharge (HID) Lamps,” Docket Number EERE-2006–

DET–0112 as comment number 22; and (2) a passage that appears on page 2 of that document.
3

data sources for the two rules are similar or the same (e.g., lamp lifetimes, electricity price data, 

etc.), they will be shared, as appropriate, between the rules. Following the NOPR stage, DOE 

will evaluate comments from interested parties and consider how best to coordinate the two final 

rules.

Item 2 DOE welcomes comments on how it should coordinate development of the final rules

for HID lamps and metal halide lamp fixtures.

1.4 Overview of the Rulemaking Process

1.4.1 Rulemaking Process and Participation of Interested Parties 

EPCA specifies that any standard DOE prescribes for commercial equipment shall be 

designed to achieve the maximum improvement in energy efficiency that is technologically 

feasible and economically justified. (42 U.S.C. 6295(o)(2)(A); 6316(a)) Moreover, EPCA states 

that the Secretary may not establish an amended or new standard if such standard would not 

result in a significant conservation of energy or is not technologically feasible or economically 

justified. (42 U.S.C. 6295(o)(3)(B); 6316(a)) When DOE evaluates any new or amended energy 

conservation standard for covered equipment under EPCA, DOE considers to the greatest extent 

practicable the following seven factors to determine whether a standard is economically justified: 

(1) the economic effect of the standard on the manufacturers and on the consumers of the 

equipment subject to such standard;

(2) the savings in operating costs throughout the estimated average life of the covered 

equipment in the type (or class) compared to any increase in the price, or in the initial 

charges for, or maintenance of the covered equipment which are likely to result from the 

imposition of the standard; 

(3) the total projected amount of energy (or as applicable, water) savings likely to result 

directly from the imposition of the standard; 

(4) any lessening of the utility or the performance of the covered products likely to result 

from the imposition of the standard; 

(5) the effect of any lessening of competition, as determined in writing by the U.S. Attorney 

General (Attorney General), that is likely to result from the imposition of the standard;

(6) the need for national energy and water conservation; and 

(7) other factors the Secretary considers relevant.

(42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))

Additional statutory requirements of general applicability for prescribing new or 

amended standards are set forth in 42 U.S.C. 6295(o)(1), (2)(B)(ii)-(iii), and (3)–(5), 42 U.S.C. 

6316(a), and other relevant sections of EPCA.

The process for developing energy conservation standards involves input from the public. 

Interested parties generally include manufacturers, end users, environmental advocates, State and 

Federal agencies, and other groups and individuals with an interest in energy conservation 

standards and test procedures. DOE considers the participation of interested parties to be a very 
4

important part of the rulemaking process. Accordingly, DOE encourages the participation of all 

interested parties during the comment period provided at each stage of the rulemaking. The 

broad array of interested parties who provide comments promotes a balanced discussion of 

critical information required to conduct the standards rulemaking, beginning with public 

comments on the framework document.

In conducting energy conservation standards rulemakings, DOE involves interested 

parties through various means. As discussed in further detail below, the standards rulemaking 

process involves four public notices, published in the Federal Register, and three public 

meetings (including the public notice and meeting associated with this framework document). 

This framework document provides details of the following stages of the rulemaking process:

• Interim Analyses (section 1.4.2). DOE plans to publish interim analyses to publicly vet 

the data, models, and tools that DOE expects to use in the rulemaking, and to facilitate 

public participation in developing the proposed rule. These data will include proposed 

equipment classes and candidate standard levels (CSLs), which span the range of 

efficacies from baseline equipment5

• Notice of Proposed Rulemaking (section 

to the most efficacious technology. DOE will hold a 

public meeting and webcast related to the interim analyses and will seek public comment.

1.4.3). The NOPR will present a discussion of 

comments received in response to the framework document and interim analyses; DOE’s 

analysis of the effects of potential standards on consumers, manufacturers, and the nation; 

DOE’s weighting of these effects; and the proposed standard levels for public comment.

DOE will hold a public meeting and webcast related to the NOPR and will again seek 

public comment.

• Final Rule (section 1.4.4). The final rule presents a discussion of comments received in 

response to the NOPR, the revised analysis of the effects of standards, DOE’s weighting 

of the effects, and any standard levels DOE is adopting. The final rule also establishes the 

compliance date of any standards.

DOE has prepared the following projected schedule shown in Table 1.1 for the HID lamps 

rulemaking.

 5 Within the broad equipment categories, DOE selected baseline lamps as representative equipment. Generally, a 

baseline lamp is one that represents the typical lamp sold. DOE selected specific characteristics such as certain 

CRIs, operating lifetimes, and light outputs to characterize the most common lamps consumers purchase. DOE 

selected multiple baseline lamps to ensure consideration of different high-volume lamps and their associated 

consumer economics. 
5

Table 1.1 Energy Conservation Standards Rulemaking Schedule for HID Lamps

Rulemaking Notice Publication Date

Framework Document February 2012

Interim Analyses (projected) August 2012

NOPR (projected) June 2013

Final Rule (projected) July 2014

EPCA provides that any energy conservation standard for HID lamps will apply to 

products manufactured on or after 36 months from publication of the final rule. (42 U.S.C 

6317(a)(3))

1.4.2 Interim Analyses

As part of its initial rulemaking activity, DOE typically identifies technology options for 

improving lamp efficacy and makes a preliminary determination regarding whether to retain each 

option for detailed analysis or to eliminate it from further consideration. This process includes a 

market and technology assessment (section 3) and a screening analysis (section 4). DOE applies 

four screening criteria in the screening analysis to determine which technology options to 

eliminate. These four criteria are: (1) technological feasibility; (2) practicability to manufacture, 

install, and service; (3) adverse impacts on product utility or availability; and (4) adverse impacts 

on health or safety. Technologies that meet the screening criteria are referred to as design options 

in the engineering analysis.

In preparing its interim analyses, DOE will consider CSLs for each equipment class in 

the engineering analysis (section 5).6

 When developing CSLs, DOE generally considers efficacy 

levels or design options that span the full range of technologically achievable efficiencies. The 

range of levels DOE typically analyzes includes:

• the baseline efficacy level (i.e., the minimum level), which is defined by the type of 

equipment with the lowest efficacy level currently sold on the market for a given 

category;

• levels that incorporate noteworthy technology design options or fill in large gaps between 

other efficacy levels considered;

• the level with the minimum LCC or greatest LCC savings; (or mean savings); and

• the highest efficacy level or lowest energy use level that is technologically feasible (i.e., 

maximum technologically feasible, or “max tech”).

DOE collects end-user price data, historical shipment data, shipment-weighted average 

efficacy data, and preliminary manufacturer impact data (e.g., capital conversion expenditures, 

marketing costs, and research and development costs) based on these CSLs. DOE will also

conduct other analyses, including: (1) the consumer life-cycle cost (LCC) and payback period 

(PBP) analyses (section 8); (2) the national impact analysis (NIA), which considers national 

energy savings (NES) and consumer net present value (NPV) (section 10); and (3) a preliminary 

 6 CSLs are a set of efficacy levels considered in the interim analysis that would span the range of lamp efficiencies 

from baseline equipment to maximum technologically feasible equipment.
6

manufacturer impact analysis (MIA) (section 6). DOE will use analytical models and tools to 

assess the different equipment classes at each CSL analyzed. Many of these analytical models 

and tools used to conduct the LCC and PBP analyses and to determine the NES and NPV of 

prospective standards are in the form of spreadsheets. 

In preparing the interim analyses, DOE will consider comments received in response to 

the framework document.7

DOE will post data and interim analytical results to its standards rulemaking website for 

review and comment. Posting interim results will enable interested parties to review the data and 

spreadsheet models that underpin the analyses, and can facilitate discussions among interested 

parties on potential joint recommendations for standard levels. DOE will use interested parties’ 

comments to refine the models for the next stage of the rulemaking analyses, in which DOE will 

propose specific efficacy levels for adoption.

The interim analysis will include an executive summary that provides 

an overview of the interim decisions, approaches, and results. This executive summary will also 

outline the issues on which DOE seeks comment. In addition to the executive summary, DOE 

will provide a technical support document (TSD) and analytical models to aid in review of the 

interim results. After publishing a notice of availability, DOE will provide a public comment 

period and hold a public meeting and webcast. DOE also encourages interested parties to 

develop joint recommendations for proposed standard levels.

1.4.3 Notice of Proposed Rulemaking

In developing the NOPR, DOE will consider and respond to all the comments received 

on the framework document and interim analysis. This process may result in revisions to the 

interim analysis, including the engineering and LCC analyses. At that point, DOE will conduct 

additional economic and environmental impact analyses. These analyses generally include a 

consumer LCC subgroup analysis (section 11), a complete MIA (section 12), a utility impact 

analysis (section 13), an employment impact analysis (section 14), an emissions analysis (section 

15), an analysis monetizing carbon dioxide and other emissions reductions (section 16) and a 

regulatory impact analysis (section 17).

DOE will describe the methodology used and make the results of all the analyses 

available on its website for review. Based on comments from interested parties, the analysis may 

be revised further. This analytical process concludes with the selection of proposed standard 

levels (if any) in the NOPR. DOE selects the proposed standard levels from the trial standard 

levels (TSLs) analyzed during the NOPR phase of the rulemaking. The NOPR, published in the 

Federal Register, will document the evaluation and selection of any proposed standard levels, 

along with a discussion of other TSLs considered but not selected (and the reasons DOE did not 

select them). 

For each equipment class, DOE will identify the max tech efficacy level. If DOE 

proposes a level lower than max tech, it will sequentially explain the reasons for eliminating 

higher levels, beginning with the highest level considered. DOE will present the analytical 

results in the NOPR and provide the details of the analysis in an accompanying TSD.

 7 As stated in section 1.4.3, DOE will provide written responses to these comments in the NOPR. 
7

DOE considers many factors in selecting proposed standards, as discussed in section

1.4.1. These factors are established in EPCA and take into consideration the benefits and costs of 

energy conservation standards. Additionally, DOE encourages interested parties to develop joint 

recommendations for standard levels. DOE will carefully consider any such recommendations in 

its decision process.

When DOE publishes the NOPR, it will provide the U.S. Department of Justice (DOJ) 

with copies of the NOPR and TSD to solicit feedback on the impact of the proposed standard 

levels on competition in the lighting industry. DOJ will review these standard levels to determine 

whether any lessening of competition is likely to result from the imposition of new standards. (42 

U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii)) Publication of the NOPR will be followed by a 60-day 

public comment period that includes a public meeting.

1.4.4 Final Rule

After publication of the NOPR, DOE will consider public comments it receives on the 

proposal and accompanying analyses. DOE will review the engineering and economic impact 

analyses and proposed standards in light of these comments and consider modifications where 

necessary. Before the final rule is issued, DOE will also consider any DOJ comments on the 

NOPR relating to the impacts of the proposed standard levels on competition to determine 

whether changes to these standard levels are needed. DOE will publish all DOJ comments and 

DOE’s responses as part of the final rule.

The standards rulemaking will conclude with publication of the final rule establishing any 

energy conservation standards for HID lamps. DOE will select any final standards level based on 

the complete record of the standards rulemaking. The final rule will promulgate any final 

standard levels and associated compliance date and explain the basis for their selection. The final 

rule will be accompanied by a final TSD.

1.5 Scope of Coverage

As previously mentioned, DOE is conducting this rulemaking to evaluate energy 

conservation standards for certain HID lamps for which DOE determined that energy 

conservation standards would be technologically feasible and economically justified, and would 

result in a significant conservation of energy. 

High-intensity discharge is the generic name for a family of lamps including mercury 

vapor, MH, and high-pressure sodium (HPS) lamps. Although low-pressure sodium lamps are 

often included in the family, they are not included in the definition set forth in EPCA, and are 

therefore not considered in this rulemaking. The definition for HID lamp, MV lamp, and MH 

lamp are defined by EPCA as follows:

High intensity discharge lamp means an electric-discharge lamp in which –

1. the light-producing arc is stabilized by the arc tube wall temperature; and

2. the arc tube wall loading is in excess of 3 watts/cm2

High intensity discharge lamps include mercury vapor, metal halide, and highpressure sodium lamps.
8

42 U.S.C. 6291(46)).

Mercury vapor lamp means a high-intensity discharge lamp in which the major 

portion of the light is produced by radiation from mercury typically operating at a 

partial vapor pressure in excess of 100,000 Pa (approximately 1 atm). Mercury 

vapor lamps include clear, phosphor-coated, and self-ballasted screw base lamps.

42 U.S.C. 6291(47).

Metal halide lamp is a high-intensity discharge lamp in which the major portion 

of the light is produced by radiation of metal halides and their products of 

dissociation, possibly in combination with metallic vapors. 

42 U.S.C. 6291(63).

HPS lamps are not defined in EPCA. DOE proposed a definition for these lamps in the 

HID lamp test procedure NOPR published on December 15, 2011 (hereafter the “test procedure 

NOPR”). 76 FR 77914. In this framework document, DOE is considering using the same 

definition for HPS lamp:

High-pressure sodium lamp is a high-intensity discharge lamp in which the major portion 

of the light is produced by radiation from sodium vapor operating at a partial pressure of about 

6.67 × 103 pascals (approximately 0.066 atmospheres or 50 torr) or greater.” 

76 FR 77914, 77917 (December 15, 2011).

DOE notes that manufacturers offer “electrodeless” HID lamps, which are also referred 

to as light-emitting plasma lamps. These lamps emit light in a related process, and may be a 

subcategory of MV, HPS, or MH lamps. Initial research indicates that the gas composition of 

electrodeless lamps might be most similar to MH lamps. DOE is seeking more information on 

whether electrodeless HID lamps are a subcategory of MV, HPS, or MH lamps.

1.5.1 Specific Lamp Categories under Consideration for the Scope of Coverage

DOE assessed the potential energy savings for the lamps identified in the final coverage 

determination by analyzing product availability, potential lamp designs that improve efficacy, 

and other factors (such as the potential to serve as a substitute for other regulated lamp types). 

For product availability, DOE obtained quantitative information from catalogs for 14 different 

manufacturers. 

HID lamps can differ from each other based on a variety of characteristics, such as input 

wattage, light output, directionality, ballast location, ballast type, lamp color, bulb shape, and 

base type. The following subsections provide a discussion of these features and describe the 

lamps DOE is considering including in the scope of coverage for this rulemaking.
9

1.5.1.1 Wattage 

In examining manufacturer catalogs, DOE found that HID lamps span wattages from 15 

watts (W) to 18,000 W, though these wattages varied according to lamp technology. Rated 

wattages range from 15 W to 18,000 W for MH lamps, from 35 W to 1,000 W for HPS lamps, 

and from 40 W to 2,000 W for MV lamps. DOE is considering covering a subset of the available 

wattages, as explained in the following paragraphs. 

For MH lamps, DOE is considering covering lamps with rated wattages between 50 W 

and 2,000 W. Based on entries in manufacturer catalogs, less than eight percent of MH lamps 

available have rated wattages less than 50 W. Similarly, DOE found only 2.3 percent of MH 

lamps to have rated wattages that exceed 2,000 W. The small number of product offerings in 

both these wattage ranges does not reflect significant potential energy savings. For this reason, 

DOE is considering including only MH lamps with rated wattages between 50 to 2,000 W in the 

scope of coverage. This is consistent with the preliminary scope of coverage in the energy 

conservation standards rulemaking for MHLFs.

8

For HPS and MV lamps, DOE is considering covering lamps with rated wattages 

between 50 W and 1,000 W. In its review of HPS and MV lamp catalogs, DOE found that less 

than five percent of the HPS catalog offerings and less than one percent of the MV catalog 

offerings had rated wattages less than 50 W. Similarly, DOE found only two MV lamps with 

rated wattages higher than 1000 W and no HPS lamps in this range. Given the small number of 

available products, DOE believes these lamps do not reflect significant potential energy savings. 

Therefore, DOE is considering including only HPS and MV lamps with rated wattages between 

50 W and 1,000 W in the scope of coverage.

DOE acknowledges that lumen output is closely related to wattage. Although DOE used 

wattage to define coverage in this section, DOE requests comments on the appropriateness of 

using lumen output to define the lamps included in coverage. If lumen output is preferred, DOE 

welcomes suggestions on the appropriate ranges for coverage.

1.5.1.2 Directionality of Lamps

Lamp light distribution is typically categorized as omni-directional or directional. Omnidirectional lamps emit light in all directions with approximately equal intensity, whereas 

directional lamps use a secondary optical element (e.g., reflector, lens, refractor, light guide) or a 

combination of elements to shape the light distribution into a particular pattern. In the test 

procedure NOPR, DOE proposed “directional lamp” be defined as a lamp emitting at least 80

percent light output within a solid angle of π (pi) steradians (corresponding to a cone with an 

angle of 120 degrees). 76 FR 77914, 77917 (December 15, 2011). 

DOE found that manufacturers offer both directional and omni-directional products for 

each of the three HID lamp types. By analyzing manufacturer catalogs, DOE found that slightly 

more than 10 percent of available HID lamps are directional. DOE believes, however, that the 

actual market share of directional HID lamps is much smaller. Because each lamp provides a 

 8 The metal halide lamp fixture preliminary TSD is available at 

www1.eere.energy.gov/buildings/appliance_standards/commercial/metal_halide_fixtures_prelim_tsd.html.
10

specific beam pattern, more product offerings exist for directional lamps than for omnidirectional lamps. Because DOE uses catalogs to determine market presence, the number of 

available directional lamps likely indicates a stronger presence than shipment data would 

indicate. Given the small market share, DOE does not believe these lamps represent significant 

potential energy savings. Therefore, DOE is considering not including directional lamps in the 

scope of coverage. DOE does not believe these lamps are suitable replacements for omnidirectional lamps due to their pattern of light distribution.

1.5.1.3 Ballast Location

HID lamps can be categorized by their ballast location (i.e., externally ballasted or selfballasted lamps). The vast majority of HID lamps are operated with an external ballast—meaning 

that the ballast is not located within the lamp body (socket and envelope). An external ballast can 

be located within the fixture or installed remotely from the fixture. If the ballast is integrated into 

the lamp, however, DOE refers to that configuration as a self-ballasted HID lamp. In the test 

procedure NOPR, DOE proposed to define self-ballasted lamps as a lamp unit that incorporates 

all elements that are necessary for the starting and stable operation of the lamp in a permanent 

enclosure, and that does not include any replaceable or interchangeable parts. 76 FR 77914, 

77918 (December 18, 2011). 

DOE found self-ballasted lamps for MH and MV lamp types, but not for HPS 

technology. In reviewing catalogs, DOE found less than one percent of MH lamps were selfballasted, whereas about 17 percent of MV lamps were self-ballasted. Self-ballasted HID lamps 

are often used in applications that compete with incandescent technology. These lamps have the 

advantage of increased efficacy and longer lifetimes relative to incandescent lamps, thereby 

decreasing maintenance costs. Given the small number of available self-ballasted HID lamps and 

the fact that consumers would likely choose incandescent technology if self-ballasted HID lamps 

were unavailable or more expensive, DOE does not believe there is significant potential for 

energy savings by regulating these products. Therefore, DOE is considering not including selfballasted lamps in the scope of coverage for this rulemaking.

1.5.1.4 Lamps Operated on Electronic Ballasts Only

In its market research, DOE found catalogs indicated that some HID lamps could be 

operated only by an electronic ballast. These lamps used MH technology only and accounted for 

1.5 percent of MH lamps overall. With such a small number of available products, DOE does not 

anticipate significant potential energy savings.

DOE also notes that there is no industry consensus test method for lamps that are

operated only by an electronic ballast. The test procedure NOPR specifies a magnetic reference 

ballast, but not an electronic reference ballast. For these reasons, DOE is considering not 

including lamps designed and labeled for use with electronic ballasts only in the scope of 

coverage for this rulemaking.

1.5.1.5 Correlated Color Temperature 

Another defining characteristic of an HID lamp is the correlated color temperature 

(CCT). In general terms, the CCT is a measure of the perceived color of the white light emitted 
11

from the lamp. In the test procedure NOPR, DOE proposes to define CCT as the absolute 

temperature of a blackbody whose chromaticity most nearly resembles that of the light source. 

76 FR 77914, 77930 (December 15, 2011) 

HID lamps are available with a variety of CCTs, depending on lamp type and design. For 

example, HPS lamps range in CCT from 1900 K to 2700 K, and MV lamps range in CCT from 

3200 K to 6800 K. In reviewing HID lamp catalogs, however, DOE found a much larger range 

for MH lamps, with products ranging in CCT from 2500 K to 50,000 K. 

DOE found that higher CCT lamps tend to be advertised for a specific application. For 

example, DOE found that all MH lamps with a CCT between 10,000 K and 50,000 K were 

advertised as aquarium lamps whereas MH lamps with a CCT between 7200 K and 9000 K were 

advertised as stage and studio lighting. In addition, DOE identified lamps with a CCT of 7000 K 

to be horticulture lamps. 

Overall, lamps with a CCT greater than or equal to 7000 K represent about two percent of 

all available MH lamps. Given the small number of available products, DOE does not believe 

these lamps represent significant potential energy savings. Therefore, DOE is considering not 

including high CCT lamps (with a CCT greater than or equal to 7000 K) in the scope of 

coverage.

1.5.1.6 Colored Lamps

DOE found a small number of HID lamps that were advertised as colored lamps (e.g., 

blue, green, orange, and magenta). DOE found these lamps only in the MH market, and they

represented about one percent of MH product offerings. This small market share indicates a lack 

of potential for significant energy savings. DOE believes some of these lamps could be excluded 

from the scope of coverage based on the CCT criteria discussed in the previous section, but 

requests comments on this conclusion and further input on a definition for these lamp types.

1.5.1.7 Specialty Applications

The Energy Policy Act of 2005 banned the sale of MV lamp ballasts, but exempted 

ballasts for certain specialty applications, such as quality inspection, industrial processing, or 

scientific use. DOE is considering excluding MV lamps operated by these ballasts from the 

scope of coverage. DOE requests comments on whether lamps for specialty applications have 

defining characteristics that differentiate them from lamps used for general illumination 

purposes. In addition, DOE welcomes comments on whether specialty applications relevant to 

MV technology can be served by HPS or MH technology.

1.5.2 Summary of the Scope of Coverage

In summary, DOE is considering including MH lamps with a rated wattage between 50 

W and 2,000 W, and MV and HPS lamps with a rated wattage between 50 W and 1,000 W in the 

scope of coverage. Within those wattage ranges, DOE is considering including MH lamps with 

CCTs between 2500 K and 6999 K, MV lamps with CCTs between 3200 K and 6800 K, and 

HPS lamps with CCTs between 1900 K and 2700 K in coverage.
12

DOE is considering excluding HID lamps designed and labeled for use with electronic 

ballasts only, directional HID lamps, self-ballasted HID lamps, and high CCT lamps from the 

scope of coverage. 

1.5.3 Standby Mode and Off Mode Standards

DOE has conducted an analysis of the potential for energy savings associated with the 

regulation of standby mode and off mode energy use in HID lamps. Similar to DOE’s conclusion 

in the July 2009 GSFL/IRL final rule (74 FR 34080, 34094 (July 14, 2009)), DOE has 

preliminarily determined that HID lamps that are subject of this rulemaking do not operate in 

standby mode or off mode. 

EPCA defines active mode as the condition in which an energy-using piece of equipment 

is connected to a main power source, has been activated, and provides one or more main 

functions (42 U.S.C. 6295)(gg)(1)(A)). Off mode is defined as the condition in which an energyusing piece of equipment is connected to a main power source, and is not providing any standby 

or active mode function. Id. Standby mode is defined as the condition in which an energy-using 

piece of equipment is connected to a main power source and offers one or more of the following 

user-oriented or protective functions: facilitating the activation or deactivation of other functions 

(including active mode) by remote switch (including remote control), internal sensor, or timer; or 

providing continuous functions, including information or status displays (including clocks) or 

sensor-based functions. Id.

To satisfy the EPCA definitions of standby mode and off mode (42 U.S.C. 6295(gg)(1)),

the lamp must not be providing any active mode function (i.e., emitting light). However, to reach 

such a state, the lamp must be entirely disconnected from the main power source (i.e., switched 

off), thereby not satisfying the requirements of operating in off mode. In addition, DOE believes 

that all covered equipment that meets the definition of HID lamp are single-function products 

and do not offer any secondary user-oriented or protective functions or continuous standby mode 

functions. Thus, HID lamps do not satisfy the EPCA definition of standby mode. While EPCA 

allows DOE to amend the mode definitions (42 U.S.C. 6295(gg)(1)(B)), DOE believes that the 

energy use of HID lamps is accounted for entirely in the active mode. Therefore, DOE is not 

considering addressing lamp operation in the standby and off modes in this rulemaking. DOE 

requests comments on this tentative conclusion.
13

Item 3 DOE welcomes comment on whether electrodeless HID lamps (also referred to as 

light-emitting plasma) are a subcategory of MV, HPS, or MH lamps.

Item 4 DOE welcomes comments on its decision to define the scope of coverage using rated 

wattage instead of lumen output and the range of wattages included in coverage.

Item 5 DOE welcomes comments on its decision to exclude HID lamps designed and labeled 

for use with electronic ballasts only, directional HID lamps, self-ballasted HID 

lamps, and high CCT lamps from the scope of coverage. DOE also requests 

comments on the unique characteristics of colored HID lamps. 

Item 6 DOE welcomes comments on whether lamps for specialty applications have defining 

characteristics that differentiate them from lamps used for general illumination 

purposes. In addition, DOE welcomes comments on whether specialty applications 

relevant to MV technology can also be served by HPS or MH technology.

Item 7 DOE welcomes comment on any additional lamps that should be excluded from the 

scope of coverage.DOE welcomes comments on the tentative decision to not include 

standby and off modes in the energy conservation standard.

1.6 Test Procedures

EPCA directs DOE to establish test procedures for HID lamps. DOE has proposed a test 

procedure through another rulemaking, the HID lamps test procedure (RIN: 1904-AC37), and is 

considering basing the test procedure on ANSI,9 Commission Internationale De L’Eclairage 

(CIE),10 and IES11

• ANSI C78.389-2004, HID Methods of Measuring Characteristics

documents, including the following:

• ANSI C78.379-2006, Classification of the Beam Patterns of Reflector Lamps

• CIE 13.3-1995, Method of Measuring and Specifying Colour Rendering Properties of 

Light Sources (E)

• CIE 15:2004, Colorimetry

• IESNA LM-47-01, Approved Method for Life-Testing of HID Lamps

• IESNA, LM-51-00, Approved Method for the Electrical and Photometric Measurements 

of High-intensity Discharge Lamps

If these ANSI, CIE, or IES test procedures are updated during the course of the test 

procedure rulemaking, DOE will consider updating its test procedure for HID lamps based on 

consideration of any such updates. As a result of discussion during the HID lamps test 

procedures public meeting (Docket No. EERE–2010-BT-TP-0044, Public Meeting Transcript, 

No. 5 at p. 121), DOE contacted the IES and found out that revisions of both IESNA LM-47 and 

 9 www.ansi.org/

10 www.cie.co.at/ 11 www.iesna.org/
14

LM-51 are nearing completion. As these documents are published, DOE will review and 

consider them in the context of its test procedure and standards rulemakings for HID lamps. 

During the HID lamps test procedure public meeting, NEMA requested more specific 

guidance regarding integrating sphere diameter for photometric testing. (Docket No. EERE–

2010-BT-TP-0044, Public Meeting Transcript, No. 5 at p. 77) DOE has reviewed LM-78-07, 

Approved Method for Total Luminous Flux Measurement of Lamps Using an Integrating Sphere 

Photometer and is considering including in the final rule. DOE seeks comments on integrating 

sphere specificity and elements of LM-78.

1.6.1 Statistical Values

During the HID lamps test procedure NOPR public meeting, GE, NEMA, OSRAM 

SYLVANIA, and Philips commented about the proposed statistical values related to HID lamps. 

NEMA and Philips also made mention of the European Union HID lamp standards. (Docket No. 

EERE-2010-BT-TP-0044, NEMA, Public Meeting Transcript, No. 5 at p. 80; OSRAM 

SYLVANIA, Public Meeting Transcript, No. 4 at p. 31; Philips, Public Meeting Transcript, No. 

5 at p. 110;) In response to these comments, DOE reviewed the sample size of HID lamps in 

other standards.

The European Union requires that member state authorities shall test a sample batch of 

minimum 20 lamps of the same model from the same manufacturer, randomly selected. The 

European Union requirement states that the batch shall comply with the regulation if the average 

results of the batch do not vary from the limit, threshold or declared values by more than 10

percent.

ENERGY STAR® is currently developing a lamp specification. However, HID lamps are 

part of the ENERGY STAR luminaire (light fixtures) requirements. For the source efficacy 

(initial) and minimum light output (lumens) requirements of ENERGY STAR luminaires the 

sample size is a minimum of three lamp-and-ballast models. ENERGY STAR requires ten 

samples for both lumen maintenance and CCT requirements in the luminaire specification. 

ENERGY STAR’s luminaire tolerance requirements vary according to the metric being used. 

For the source efficacy (initial) and minimum light output (lumens) requirements of ENERGY 

STAR luminaires, all of the samples tested must pass the efficacy and minimum light output. For 

both lumen maintenance and CCT, ENERGY STAR’s requirement is that at least 80 percent of 

the samples achieve the requirement. 

DOE notes that in 2010, NEMA provided comments regarding the appropriate sampling 

plan and certification requirements. NEMA stated that industry recommended using NEMA 

standard LSD-26 (Docket No. EERE-2010-BT-CE-0014, NEMA, No. 85 at p. 32). DOE was 

unable to find a copy of LSD-26 and seeks more information related to this standard.

1.6.2 National Voluntary Laboratory Accreditation Program (NVLAP)

During the HID lamps test procedure public meeting, NVLAP certification was 

discussed. NEMA commented that most testing is completed at the lamp factories and that the 

factories are not NVLAP certified. (Docket No. EERE-2010-BT-TP-0044, NEMA, No. 4 at p. 
15

16) Philips stated that they currently do testing, but not always in a NVLAP approved facility. 

(Docket No. EERE-2010-BT-TP-0044, Philips, No. 4 at p. 93) Finally, GE and NEMA 

commented on the differences between the same gear being tested in round-robin fashion 

between NVLAP laboratories and there could be a tolerance of four percent or more. (Docket 

No. EERE-2010-BT-TP-0044, GE, No. 4 at p. 101; NEMA, No. 4 at p. 1010) DOE researched 

comments submitted on NVLAP certification during its compliance, certification and 

enforcement rulemaking. DOE notes that NEMA stated that NVLAP had sufficient checks and 

balances and made the use of the most knowledgeable testing resources. (Docket No. EERE2010-BT-CE-0014, NEMA, No. 26 at p. 8) NEMA also stated that testing should take place at a 

NVLAP accredited laboratory and that measurement parameters should be limited to those 

explicitly identified in the statute using lamps (lumens per watt) as an example. (Docket No. 

EERE-2010-BT-CE-0014, NEMA, No. 85 at p. 30) DOE seeks clarification of these comments 

and additional information related to NVLAP certification.

Item 8 DOE welcomes additional comments related to the test procedure.

Item 9 DOE requests information related to NEMA Standard LSD-26.

Item 10 DOE seeks comment related to NVLAP accredited testing facilities.

Item 11 DOE seeks comment on the sample size proposed in the HID lamps test procedures 

and whether sample sizes in other standards would be more appropriate.

Item 12 DOE seeks comment on the tolerance values proposed in the HID lamps test 

procedures and whether tolerance values in other standards would be more 

appropriate. 

1.7 Metrics

To develop energy conservation standards related to HID lamps, DOE must select a 

metric for rating the performance of the lamps. Sections 1.7.1 through 1.7.4 discuss the different 

metrics DOE is considering for energy conservation standards for HID lamps. Because dimming 

is uncommon for HID lamps, DOE plans to assess products while operating at full light output, 

not at a reduced light output or dimmed state.

1.7.1 Lamp Efficacy

DOE is considering using initial lamp efficacy as the metric for potentially setting 

standards for HID lamps. Initial lamp efficacy is the ratio of light output divided by lamp input 

power at the beginning of the life of the lamp. DOE would establish a minimum lamp efficacy 

requirement for HID lamps.

DOE received comments on the HID lamps NOPD from NEMA stating that lamp 

efficacy is not an appropriate metric for directional lamps. (Docket No. EERE-2006-DET-0112,

NEMA, No. 21 at p. 2) DOE acknowledges that lamp efficacy does not fully characterize the 
16

efficacy of directional lamps, and, if necessary, will investigate a metric based on beam angle 

and intensity for these lamps.

1.7.2 Input Wattage

DOE is also considering using input wattage as the metric for setting standards for HID 

lamps. With this approach, DOE would require lamps of a particular light output to not exceed a 

maximum input wattage requirement. Because this metric focuses on energy consumption, it 

allows flexibility when selecting the individual system components.

1.7.3 Center-Beam Candlepower (Intensity)

Directional lamps are typically characterized by beam angle. Center-beam candlepower 

(CBCP) is correlated to beam angle; as beam angle increases, CBCP decreases. Should DOE 

decide to include directional lamps within the scope of coverage, an efficacy metric for 

directional HID lamps would need to capture this relationship.

In researching a possible directional lamp metric, DOE found that ANSI and IES have 

slightly different approaches to defining beam angle. ANSI defines beam angle as 50 percent of 

the CBCP, whereas IES defines beam angle as 50 percent of maximum intensity in that for some 

lamps the maximum intensity is not at nadir.

12

DOE notes that the ENERGY STAR specifications for SSL replacement lamps set a 

minimum intensity in CBCP at lamp nadir related to the beam angle of the lamp. For HID 

directional lamps, an appropriate metric could require a minimum CBCP related to the beam 

angle of the lamp for a given lamp shape and diameter. The methodology could include a scaling 

factor for different wattage lamps of the same shape and diameter. 

Because CBCP is correlated to beam angle, it may 

be better than the metric developed by IES for assessing efficacy of directional lamps. 

1.7.4 Beam Lumens Per Watt

Directional lamps can also be characterized by beam (or zonal) lumens. Beam lumens are 

defined as the light output cast within the region outlined by the beam angle. Lumens cast 

outside the beam angle region are not counted toward the beam lumen metric, and beam lumens 

can be thought of as “useful lumens.” Lamps that concentrate a higher percentage of total lumens 

inside the beam angle zone per input watt would generally be preferred by the consumer, because 

the lamp would better create a region of higher illumination to provide contrast against the 

background lighting. However, while beam lumens provide information about the average 

illumination within the region of interest, CBCP gives specific information about intensity at 

nadir. In addition, DOE notes that catalogs of directional HID lamps more frequently provide 

center-beam intensity than beam lumens.

 12 Nadir is the angle pointing directly downward from the lamp or luminaire, or 0°.
17

Item 13 DOE welcomes comments related to the appropriateness of lamp efficacy as one of 

the potential metrics in HID lamp energy conservation standards.

Item 14 DOE welcomes comments on developing a center-beam intensity metric related to 

directional lamps. DOE requests information on other possible metrics in 

development or other metrics that DOE should consider, including beam lumens per 

watt. DOE requests comments on the appropriate definition of beam angle.

2 OVERVIEW OF ANALYSES FOR RULEMAKING

The purpose of the analyses conducted in support of the standards rulemaking is to ensure 

that DOE selects energy conservation standards that achieve the maximum improvement in 

efficacy that is technologically feasible and economically justified, and will result in significant 

energy savings. Economic justification includes the consideration of economic impacts on 

domestic manufacturers and consumers, national benefits including environmental impacts, 

issues of consumer utility, and impacts from any lessening of competition. DOE expects the 

selection of such standards to achieve the maximum energy savings that are technologically 

feasible and economically justified without imposing an excessive financial burden on any 

particular party. 

The figure below summarizes the analytical components of the DOE standards-setting 

process. The analyses are presented in the center column. Each analysis has a set of key inputs, 

which are data and information required for the analysis. The identified approaches are the 

methods that DOE will use to obtain key inputs, which may vary depending on the information 

in question. For example, some key inputs exist in public databases; in support of this 

rulemaking, DOE will also develop relevant information or collect such information from 

interested parties or experts with special knowledge. Key outputs from each analysis feed 

directly into the rulemaking. Arrows indicate the flow of information among the various 

analyses. DOE ensures a consistent approach to its analyses throughout the rulemaking by 

considering each analysis as a part of the overall standards-setting framework.
18

Figure 2.1 Flow Diagram of Analyses Conducted for an Energy Conservation Standards 

Rulemaking

Utility Impact

Analysis 

Notice of Proposed Rulemaking (NOPR)

Final Rule

Approaches Key Inputs Analyses Key Outputs

Market and Technology

Assessment

Screening Analysis

Engineering Analysis

Product Price

Determination Life-Cycle Cost and 

Payback Period 

Analyses

National Impact

Analysis

Energy Use

Revise Pre-NOPR

Analyses

Life-Cycle Cost 

Sub-Group Analysis

Manufacturer Impact 

Analysis

Shipments

Analysis

Employment Impact

Analysis 

Revise Analyses

•

• Technology Options

• Industry Cash Flow

• Sub-Group Cash-Flow

• Direct Employment Impacts

• Competitive Impacts

• Cumulative Regulatory Burden

• Product Designs

• Life-Cycle Costs

• Payback Periods

• National Energy Savings

• Net Present Values

• National Employment Impacts

• Revised Results

• Characterize Industry

• Market Segmentation

• Non-Regulatory Programs

Framework Document

• Efficiency-Level Approach

• Design Option Approach

• Energy Prices

• Installation Costs

• Maintenance & Repair Costs

• Accounting Approach

• Backcast and Forecast

• Market Saturation

• Stakeholder Comments

• Demographics

• Manufacturer Interviews

• GRIM Analysis

• Emission Rates

• National Energy Savings

• Stakeholder Comments

• Identify Firms/Products 

• Historical Shipments

•Retail Price Collection and

Analysis

• Manufacturer Prices

• Average Costs

• Manufacturer Financial Data

Design Options

Product Classes

Retail 

Prices

Design Energy/ Use

Advance Notice of Proposed Rulemaking (ANO)

• Efficiency/Performance

• Commercial Products

Candidate

Standard 

Levels

• Analysis of Energy Use 

Data

Environmental

Assessment

Regulatory Impact

Analysis

Technology Options

• Emission Estimates

• Utility Load Factors

• National Energy Savings

• Non-Regulatory

Alternatives

• NEMS-BT

• ImSET

• NEMS-BT

• Design Options

• Energy Price Forecasts

• Site-to-Source Factors

• Energy-Efficiency Levels

• National Energy Savings

• National Product Costs

• National Operating Costs

• Utility Impacts

• Analysis of Market Data

• Analysis of Product Data

• Life-Cycle Costs

• Payback Periods

• Installation

Costs

• Maint Costs

• Repair Costs

• UEC

• Energy Prices

Annual Energy Use (UEC)

Preliminary 

Manufacturer Impact 

Analysis

• Manufacturer Prices

• Average Costs

• Conversion Capital Expenditures

• Direct Employment Impacts

• National Energy Savings

• Net Present Values

• Trial Standard Levels (TSLs)

TSLs

• Product Prototypes

Energy-Efficiency 

Levels

• Department of Justice Review

Product Designs

Utility Impact

Analysis 

Notice of Proposed Rulemaking (NOPR)

Final Rule

Approaches Key Inputs Analyses Key Outputs

Market and Technology

Assessment

Screening Analysis

Engineering Analysis

Product Price

Determination Life-Cycle Cost and 

Payback Period 

Analyses

National Impact

Analysis

Energy Use

Analyses

Life-Cycle Cost 

Sub-Group Analysis

Manufacturer Impact 

Analysis

Shipments

Analysis

Employment Impact

Analysis 

Revise Analyses

• Equipment Classes

• Technology Options

• Industry Cash Flow

• Sub-Group Cash-Flow

• Direct Employment Impacts

• Competitive Impacts

• Cumulative Regulatory Burden

• Product Designs

• Life-Cycle Costs

• Payback Periods

• National Energy Savings

• Net Present Values

• National Employment Impacts

• Revised Results

• Characterize Industry

• Market Segmentation

• Non-Regulatory Programs

Framework Document

• Efficiency-Level Approach

• Design Option Approach

• Energy Prices

• Installation Costs

• Maintenance & Repair Costs

• Accounting Approach

• Backcast and Forecast

• Market Saturation

• Stakeholder Comments

• Demographics

• Manufacturer Interviews

• GRIM Analysis

• Emission Rates

• National Energy Savings

• Stakeholder Comments

• Identify Firms/Products 

• Historical Shipments

•Retail Price Collection and

Analysis

• Manufacturer Prices

• Average Costs

• Manufacturer Financial Data

Design Options

Product Classes

Retail 

Prices

Design Energy/ Use

Interim Analyses

• Efficiency/Performance

• Commercial Products

Candidate

Standard 

Levels

• Analysis of Energy Use 

Data

Environmental

Assessment

Regulatory Impact

Analysis

Technology Options

• Emission Estimates

• Utility Load Factors

• National Energy Savings

• Non-Regulatory

Alternatives

• NEMS-BT

• ImSET

• NEMS-BT

• Design Options

• Energy Price Forecasts

• Site-to-Source Factors

• Energy-Efficiency Levels

Direct Employment

Impacts

• National Energy Savings

• National Product Costs

• National Operating Costs

• Utility Impacts

• Analysis of Market Data

• Analysis of Product Data

• Life-Cycle Costs

• Payback Periods

• Installation

Costs

• Maint Costs

• Repair Costs

• UEC

• Energy Prices

Annual Energy Use (UEC)

Preliminary 

Manufacturer Impact 

Analysis

• Manufacturer Prices

• Average Costs

• Conversion Capital Expenditures

• Direct Employment Impacts

• National Energy Savings

• Net Present Values

• Trial Standard Levels (TSLs)

TSLs

• Product Prototypes

Energy-Efficiency 

Levels

• Department of Justice Review

Product Designs
19

3 MARKET AND TECHNOLOGY ASSESSMENT

The market and technology assessment will provide information about the manufacturers 

and performance attributes of HID lamps (and ballasts and fixtures where applicable). This 

assessment is particularly important at the outset of the rulemaking for developing equipment 

classes and for identifying technology options that improve efficacy for each of the three lamp 

types.

3.1 Market Assessment

DOE will qualitatively and quantitatively characterize the structure of the market for HID 

lamps. In the market assessment, DOE will identify and characterize the manufacturers of this 

equipment; estimate market shares and trends; address regulatory and non-regulatory initiatives 

intended to improve the efficacy or reduce the energy use of covered lamps; and explore the 

potential for technological improvements in the design and manufacturing of such equipment.

The market assessment will establish the context for this rulemaking and serve as a 

resource to guide the analyses that follow. For example, DOE may use historical shipments and 

prices as indicators of future shipments and prices. Similarly, DOE plans to use market structure 

data for the MIA, data that will be particularly useful for assessing competitive effects. This 

phase also allows DOE to start researching design options by reviewing equipment literature and 

industry publications.

DOE recognizes that there may be limited publicly available information on national 

shipments, manufacturing costs, channels of distribution, and manufacturer market shares of HID 

lamps. This type of data is an important input for analyses that determine if energy conservation 

standards are economically justified and capable of achieving significant energy savings. 

Therefore, DOE encourages interested parties to submit data that will improve DOE’s 

understanding of the HID lamp market. 

Interested parties may submit confidential data to DOE, indicating in writing which data 

should remain confidential. Interested parties must submit confidential information to DOE 

according to the procedures outlined in 10 CFR 1004.11. Under 10 CFR 1004.11, any person 

submitting information that he or she believes to be confidential and exempt by law from public 

disclosure should submit two copies. One copy of the document must include all the information 

believed to be confidential, and the other copy must have the information believed to be 

confidential deleted. DOE will make its own determination about the confidential status of the 

information and treat it accordingly.13

 13 Factors that DOE considers when evaluating requests to treat submitted information as confidential include (1) a 

description of the items; (2) whether and why such items are customarily treated as confidential within the industry; 

(3) whether the information is generally known by or available from other public sources; (4) whether the 

information has previously been made available to others without obligation concerning its confidentiality; (5) an 

explanation of the competitive injury to the submitting person which would result from public disclosure; (6) a date 

after which such information might lose its confidential character; and (7) why disclosure of the information would 

be contrary to the public interest. 10 CFR 1004.11
20

DOE also works with confidential data provided by manufacturers and other 

organizations to prepare aggregated results for DOE’s analysis. These aggregated results do not 

divulge individual raw data, but enable other interested parties to comment on the aggregated 

dataset. NEMA is the trade association for manufacturers of HID lamps; DOE expects that 

NEMA will play an important role in providing market information, including information on 

manufacturers, market shares, and trends in the market.

DOE is creating a data set of commonly available HID equipment based on recent 

catalogs from small and large HID lamp manufacturers. DOE will use the resulting knowledge 

about equipment availability to evaluate how the market may respond to various standard levels 

(e.g., consumers substituting fixtures with pulse-start MH lamps over fixtures with probe-start 

MH lamps), and to gain insight on the performance attributes of various commercially available 

lamp technologies.

Item 15 DOE welcomes input on disaggregated market share and shipment data based on

input wattage for each HID lamp technology.

3.1.1 Equipment Classes

When necessary, DOE divides covered equipment into classes by (a) the type of energy 

used; (b) the capacity of the equipment; or (c) any other performance-related feature that justifies 

different standard levels, such as features affecting consumer utility. (42 U.S.C. 6295(q)) DOE 

then conducts its analyses and considers establishing standards to provide separate standard 

levels for each equipment class.

For HID lamps, DOE examined several possible characteristics or features that could 

warrant separation of covered equipment into different equipment classes, including:

• directionality; 

• ballast location;

• CCT; and

• light output in lumens.

Each of the listed characteristics or features is discussed below. DOE seeks feedback on

these product class divisions, as well as further subdivision of equipment classes by features that 

are not discussed in this document such as lamp orientation, base type, CRI,

14 coating, and safety 

rating (open versus enclosed). In addition, if DOE determines to include directional lamps within 

the scope of coverage, DOE would consider beam angle and lamp diameter as class-setting 

factors to further subdivide the directional lamp category discussed below. DOE is not 

considering lamp technology (MV, HPS, MH) to be a class-setting factor as CCT more directly 

accounts for the differences in consumer utility among the three lamp types.

 14 The test procedure NOPR has proposed to adopt the definition for CRI in 10 CFR 430.2, as “the measured degree 

of color shift objects undergo when illuminated by a light source as compared with the color of those same objects 

when illuminated by a reference source of comparable color temperature.” 76 FR 77914, 77930 (December 15, 

2011)
21

Directionality

The direction in which the light leaves the lamp can be separated into two main 

categories: directional and omni-directional. The directionality of the light requires different 

metrics to assess efficacy and thus creates a major distinction between HID lamps. Should DOE 

determine to include directional lamps within the scope of coverage, DOE would consider 

separating equipment classes based on this characteristic. 

Ballast Location

Ballasts are typically located externally to HID lamps. However, some directional and 

omni-directional HID lamps are self-ballasted. These self-ballasted lamps typically have lower 

efficacies and (or less intensity in the case of directional lamps) than externally ballasted lamps. 

Self-ballasted HID lamps often compete with incandescent, halogen, and compact fluorescent 

lamps and cannot be used as direct substitutes for externally ballasted lamps. Although the selfballasted HID lamps have lower performance compared to typical HID lamps, substituting them 

for alternative technologies can yield energy savings or cost savings through the increased 

lifetime of HID lamps relative to incandescent alternatives. Therefore, should DOE determine to 

include self-ballasted lamps within the scope of coverage, DOE would consider separate 

equipment classes for self-ballasted HID lamps, given their difference in efficacy and unique 

consumer utility. 

CCT

HID lamps are available with different CCT values

15 depending on lamp type and design. 

DOE reviewed lamp catalogs and found that CCT is related to lamp efficacy (i.e., higher CCT 

lamps generally have lower efficacy). Product usage indicates that some consumers specify 

lamps of a particular color temperature for certain applications, indicating CCT may provide 

utility to the consumer. For example, MH lamps (higher CCT) are typically specified rather than 

HPS lamps (lower CCT) for indoor commercial areas due to the whiter color temperature (and 

also higher CRI). Using CCT as a class-setting factor rather than lamp technology would allow 

for different lamp types to be subject to the same energy conservation standard as long as they 

display the same CCT. Based on the difference in efficacy and consumer utility, DOE is 

considering separating equipment classes by CCT. Should DOE determine to include high CCT 

lamps in this rulemaking, DOE would consider separate equipment classes for these lamps. 

Light Output

HID lamps are available with a variety of light outputs and input powers. DOE’s review 

of catalog data indicates that lamps of increased light output (or input power) are generally more 

efficacious. In addition, consumers require more or less light output from a lamp depending on 

the intended use for the lamp, indicating a consumer utility from this feature. Light output and 

input power are highly correlated (increased input power typically leads to increased light 

 15 The test procedure NOPR has proposed to adopt the definition for CCT in 10 CFR 430.2, as “the absolute 

temperature of a blackbody whose chromaticity most nearly resembles that of the light source.” 76 FR 77914, 77930 

(December 15, 2011)
22

output), but DOE’s view is that light output more directly addresses the feature valued by 

consumers. Therefore, based on the difference in lamp efficacy and consumer utility, DOE is 

considering establishing separate equipment classes on the basis of light output.

Table 3.1 presents DOE’s initial proposed equipment class structure.

Table 3.1 Initial Proposed Equipment Classes

Directionality Ballast 

Location CCT Range Lumen Range Equipment Class ID

Directional

SelfBallasted All All 1

Externally 

Ballasted All All 2

Omnidirectional

SelfBallasted All All 3

Externally 

Ballasted

1,900-2,500 K

1−3,000 lm 4A

3,001−5,000 lm 4B

5,001−8,000 lm 4C

8,001−11,000 lm 4D

11,001–20,000 lm 4E

20,001–40,000 lm 4F

40,001–100,000 lm 4G

>100,001 lm 4H

2,501-5,000 K

1–3,000 lm 5A

3,001–5,000 lm 5B

5,001–8,000 lm 5C

8,001–12,000 lm 5D

12,001–20,000 lm 5E

20,001–50,000 lm 5F

>50,001 lm 5G

5,001-6,999 K

1–3,000 lm 6A

3,001–5,000 lm 6B

5,001–8,000 lm 6C

8,001–12,000 lm 6D

12,001–20,000 lm 6E

20,001–50,000 lm 6F

>50,001 lm 6G
23

Item 16 DOE welcomes comments on the proposed equipment classes for HID lamps and 

additional approaches to defining classes in accordance with the requirements of 42 

U.S.C. 6295(q). Specifically, DOE seeks input on its proposal to establish equipment 

classes based on lumen output (rather than rated wattage) and CCT, and the 

appropriateness of the lumen output and CCT ranges selected.

Item 17 DOE seeks comment on whether the proposed equipment classes should be further 

subdivided by lamp orientation (also known as operating or burn position and 

typically includes vertical, horizontal, universal) or by other lamp characteristics 

(e.g., enclosed or open fixture rating, CRI, base type, coated or clear envelope). DOE 

also seeks comment on whether equipment classes should be separated based on lamp 

technology.

3.2 Technology Assessment

The technology assessment centers on understanding how equipment uses energy and on 

identifying measures that would improve the efficacy of HID lamps. Measures that improve 

equipment efficacy are called technology options, and they are based on existing technologies as 

well as working prototypes. In consultation with interested parties, DOE will create a list of 

technology options for consideration in this rulemaking. Following research into this list of 

technology options, DOE will consider each option in light of four screening criteria: (1) 

technological feasibility; (2) practicability to manufacture, install, and service; (3) adverse 

impacts on equipment utility or availability; and (4) adverse impacts on health or safety (see 

section 4). Those technology options that meet the four screening criteria are called design 

options; these options will be considered appropriate ways to improve the efficacy of the 

equipment in the engineering analysis, and will assist DOE in determining the max tech design.

DOE identifies technology options by reviewing manufacturer catalogs, recent trade 

publications, technical journals, and patent filings. DOE will also draw from a NEMA white 

paper, NEMA LSD 54-2010, The Strengths and Potentials of Metal Halide Lighting Systems,16

and a 2005 report from a DOE workshop that was widely attended by HID lamp manufacturers, 

lamp materials suppliers, and NEMA members. The report, High-intensity Discharge Lighting 

Technology Workshop Report,17

The following sections provide DOE’s initial assessment of technologies that improve the 

efficacy of HID lamps.

was also recommended by NEMA in its comments provided in 

response to the 2010 HID lamps NOPD (Docket No. EERE-2006-DET-0112, NEMA, No. 21 at 

p. 4).

 16 National Electrical Manufacturers Association, Lighting Systems Division. The Strengths and Potentials of Metal 

Halide Lighting Systems. Rosslyn, VA. Document LSD 54-2010. www.nema.org/stds/lsd54.cfm. 17 U.S. Department of Energy--Office of Energy Efficiency and Renewable Energy. High-intensity Discharge 

Lighting Technology Workshop Report. November 15, 2005. Washington, D.C. 

apps1.eere.energy.gov/buildings/publications/pdfs/corporate/hid_workshop-report.pdf.
24

3.2.1 Mercury Vapor Lamps

MV ballasts, other than specialty application MV ballasts, have been banned from import 

or production since January 1, 2008 (42 U.S.C. 6295 (ee)). This ban effectively limits the 

installation of new MV fixtures and ballasts, meaning the only MV lamps currently being sold 

are replacement lamps. DOE understands there is limited industry design emphasis on MV 

lamps, there are limited methods to improving efficacy of MV lamps, and that the more common 

pathway to increased efficacy is a change of technology to MH or HPS lamps.

3.2.2 High-Pressure Sodium Lamps

HPS lamps are very efficacious (up to 150 lumens per watt), but have intrinsically poor 

color quality. HID lamp catalogs do indicate that a range of HPS lamp efficacies are available, 

but at this time, DOE is not aware of the specific technology options that are used achieve 

different lamp efficacies. 

3.2.3 Metal Halide Lamps

DOE is aware of a limited set of technology options that could improve MH lamp 

efficacy. For this rulemaking, DOE intends to evaluate the following technology options:

• Pulse-Start Technology. Pulse-start lamps are typically more efficacious than probe-start 

lamps.

• Arc Tube Design. The arc tube generates the light for the lamp. Potential improvement

options include changing the material of the arc tube from quartz to ceramic and 

changing the size and shape of the arc tube. Some of these options may not, however, be 

compatible with all MH systems. For example, ceramic arc tubes are only used with lowfrequency pulse-start MH systems.

o Ceramic Arc Tubes. The 2005 HID workshop report estimated that the potential 

energy savings from ceramic arc tubes was 1.2 quads.

18

o Arc Tube Shape. The shape of the HID lamp arc tube relates to the efficacy of the 

lamp. Certain arc tube shapes (like formed or offset electrode) can be more 

efficacious than others for horizontal operating orientations. These arc tube shapes 

help position the lamp arc in a way that increases MH vapor pressure, leading to 

increased light output.

In the years since that 

workshop, significant industry research and development has been devoted to ceramic 

arc tube design. Manufacturers have introduced commercial ceramic pulse-start metal 

halide (CMH) lamps with higher efficacy and better color characteristics than quartz 

pulse-start MH lamps. CMH technology is not, as of 2012, made in lamp wattages 

above 400 W, so it will not be a technology option available for all equipment 

classes.

 18 High-intensity Discharge Lighting Technology Workshop Report, Nov. 15, 2005 at p. 6
25

• Novel Fill Gas. The 2005 HID workshop report estimated that the potential energy 

savings from using novel gases as arc tube fill gases in HID lamps is 0.7 quads.

19

• Lamp Electrodes. As presented in chapter 3 of the 2010 HID lamps final determination 

TSD, lamp electrodes represent roughly 10 percent of a lamp’s power loss (e.g., for a 

lamp rated at 400 W, nearly 40 W of that power is not generating light but is directed to 

the electrodes). Different electrode materials or designs could reduce these power losses. 

The 2005 HID workshop report estimated that the potential energy savings of improved

electrode design or electrodeless lamps are 0.2 and 0.6 quads, respectively.

20

Item 18 DOE welcomes comments on the preliminary technology options identified in this 

section, and on whether there are additional technology options it should consider.

4 SCREENING ANALYSIS

The purpose of the screening analysis is to screen out technology options that DOE will 

not analyze further in the engineering analysis. DOE will follow the process set forth below. 

DOE will develop a list of technology options (through its own research and in consultation with 

interested parties) as part of the technology assessment. The identified candidate technology 

options will encompass all those technologies that may improve the efficacy of HID lamps. 

Thereafter, DOE will review each technology option in light of the following four criteria:21

1. Technological feasibility. DOE will screen out technologies that are not incorporated in

commercially available products or working prototypes.

2. Practicability to manufacture, install, and service. If DOE determines that mass 

production of a technology in commercial equipment and reliable installation and 

servicing of the technology cannot be achieved on the scale necessary to serve the 

relevant market by the time of the compliance date of the standard, it will not consider 

that technology further.

3. Adverse impact on equipment utility or availability. If DOE determines that a technology 

will have a significant adverse impact on the utility of the relevant equipment for 

significant consumer subgroups, or will result in the unavailability of any covered 

equipment type with performance characteristics (including reliability), features, size,

capacities, and volumes that are substantially the same as equipment generally available 

in the United States at the time, it will not consider that technology further.

4. Adverse impacts on health or safety. If DOE determines that a technology will have

significant adverse impacts on health or safety, it will not consider that technology 

further.

 19 High-intensity Discharge Lighting Technology Workshop Report, Nov. 15, 2005 at p. 6 20 High-intensity Discharge Lighting Technology Workshop Report, Nov. 15, 2005 at p. 6 21 DOE’s Process Rule establishes procedures, interpretations, and policies to guide DOE in the consideration and 

promulgation of new or amended energy conservation standards under EPCA, including the four screening criteria. 

The Process Rule can be found at 10 CFR Part 430, subpart C, appendix A.
26

DOE will fully document its reasons for eliminating any technology options during the 

screening analysis, and will publish this documentation for interested parties to review as part of 

the interim analysis. Those technology options that meet the above screening criteria will be 

considered design options in the engineering analysis.

Item 19 DOE welcomes comments on how the above four screening criteria might apply to

technology options under consideration by DOE, and how the screening criteria 

apply to any additional technology option(s) that an interested party recommends to 

DOE.

5 ENGINEERING ANALYSIS

After conducting the screening analysis described in section 4, DOE will perform an 

engineering analysis based on the remaining design options that are available to improve lamp 

efficacy. The engineering analysis consists of estimating the energy use and cost of equipment at 

various levels of increased efficacy. Section 5.1 provides an overview of the engineering 

analysis; section 5.2 discusses representative equipment classes; section 5.3 discusses baseline 

models; section 5.4 discusses identification of higher-efficacy substitutes; section 5.5 describes 

efficacy levels; section 5.6 describes the scaling approach; section 5.7 describes the product price 

determination; section 5.8 discusses proprietary designs; and section 5.9 discusses cumulative 

regulatory burdens that might affect the engineering analysis.

5.1 Engineering Analysis Overview

The purpose of the engineering analysis is to determine the relationship between efficacy 

and end-user price. This relationship between price and efficacy serves as the basis for 

cost/benefit calculations to individual consumers in the LCC analysis and to the nation in the 

NIA. 

The engineering analysis will focus on selecting commercially available lamps that 

incorporate design options that improve efficacy. The engineering analysis will also identify the 

highest efficacy that is technologically feasible within each equipment class. DOE may 

determine the max tech model by investigating the existence of any HID lamp prototypes with 

higher efficacy than that present in commercially available models. The following is a summary 

of primary steps in the engineering analysis:

1. Select Representative Equipment Classes

2. Select Baseline Models

3. Identify More Efficacious Substitutes

4. Develop CSLs

5. Determine Lamp Price

5.2 Representative Equipment Classes

When a type of equipment is proposed to be divided into multiple equipment classes, 

DOE selects certain classes as representative and concentrates its analytical effort on these 

classes. Generally, DOE selects representative equipment classes based on the highest shipment 
27

volumes, although it will also consider unique performance characteristics as appropriate. The 

representative equipment classes are identified with gray shading in Table 5.1. For those 

equipment classes that are not analyzed, DOE scales CSLs from representative equipment 

classes through a process described in section 5.6. 

Item 20 DOE welcomes comments on the selection of representative equipment classes for 

HID lamps.

5.3 Baseline Models

Once representative equipment classes are established, DOE identifies baseline models 

that serve as reference points against which DOE can measure changes resulting from potential 

energy conservation standards. DOE will create a separate engineering analysis for each baseline 

model selected.

The baseline model is typically the most common, least efficacious equipment sold in a 

given 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. For example, MV lamps 

are the least efficacious lamp option for some equipment classes; however, MV lamps represent 

a very small portion of the market because many consumers have already transitioned to MH 

lamp technology. For this reason, DOE will select the both a MV lamp and MH lamp as 

baselines for most 2501–5000 K omni-directional lamp equipment classes. 

Table 5.1 shows the equipment classes that DOE has tentatively identified as 

representative equipment classes (indicated with gray shading) and related baseline models. 

Table 5.1 Representative Equipment Classes and Provisional Baseline Models

Directionality Ballast 

Location CCT Range Lumen Range Baseline Model(s) Equipment Class ID

Directional

SelfBallasted All All -- 1

Externally 

Ballasted All All -- 2

Omnidirectional

Selfballasted All All -- 3

Externally 

Ballasted

1,500-2,500K

1−3,000 lm -- 4A

3,001−5,000 lm 50 W HPS 4B

5,001−8,000 lm -- 4C

8,001−11,000 lm 100 W HPS 4D

11,001–20,000 lm -- 4E

20,001–40,000 lm 250 W HPS 4F

40,001–100,000 lm 400 W HPS 4G

>100,001 lm -- 4H

2,501-5,000K

1–3,000 lm -- 5A

3,001–5,000 lm 100 W MV

70 W Pulse-Start MH 5B

5,001–8,000 lm -- 5C

8,001–12,000 lm 175 W MV

150 W Probe-Start MH 5D
28

Directionality Ballast 

Location CCT Range Lumen Range Baseline Model(s) Equipment Class ID

12,001–20,000 lm 250 W MV

175 W Probe-Start MH 5E

20,001–50,000 lm 400 W MV

400 W Probe-Start MH 5F

>50,001 lm 1000 W Probe-Start MH 5G

5,001-6,999K

1–3,000 lm -- 6A

3,001–5,000 lm -- 6B

5,001–8,000 lm -- 6C

8,001–12,000 lm -- 6D

12,001–20,000 lm -- 6E

20,001–50,000 lm -- 6F

>50,001 lm -- 6G

Note: Gray shaded equipment classes are representative equipment classes.

Item 21 DOE welcomes comments on the selection of baseline models for the proposed 

representative equipment classes.

5.4 Identify Higher-Efficacy Lamp Replacements

DOE selects more efficacious lamps for each baseline lamp by considering technologies 

not eliminated in the screening analysis. DOE considers these technologies in the engineering 

analysis by analyzing commercially available lamps in which the design options are already 

incorporated. In identifying more efficacious lamp-and-ballast designs, DOE recognizes that a 

lamp’s lumen package and performance characteristics are important design criteria for 

consumers. DOE chooses more efficacious substitute lamps with performance characteristics 

similar to those of the baseline lamps. 

DOE notes that its analysis of energy consumption will be based on a lamp-and-ballast 

system because the lamp and ballast operate together in practice. DOE will consider the power 

losses of the ballast in addition to the lamp wattage to accurately model the impact of lamp 

efficacy standards.

In identifying more efficacious lamps, DOE will use a database of HID lamp catalog 

information, supplementing with test data when possible. DOE is considering selecting HID 

lamps for the analysis such that potential substitutions maintain light output of the lamp-andballast system within 10 percent of the mean lumens of the baseline system.22

One challenge in considering efficacy levels for HID lamps is ensuring that increased 

efficacy leads to reduced energy consumption rather than increased light output. Energy 

consumption can be reduced with increased efficacy though several pathways including:

This approach will 

accurately characterize the cost-effectiveness of a particular efficacy level if a consumer makes 

an informed decision that maintains light output.

 22 Because HID lamps (other than self-ballasted lamps) require a ballast to operate, DOE will pair a representative 

ballast with representative HID lamps to develop representative lamp-and-ballast systems. DOE’s analyses will use 

a representative input power for the entire lamp-and-ballast system.
29

1. A shift to reduced wattage lamps in response to the increased efficacy required by 

standards.

2. Respacing and reducing the number of fixtures to take into account the increased light 

output from each fixture.

DOE understands that respacing and reducing the number of fixtures is not always an option, 

even for a renovation or new construction purchasing event. DOE also recognizes that a reduced 

wattage lamp alternative may not be available for every lamp currently on the market. As a 

result, DOE may consider consumer behaviors resulting in under-illumination, over-illumination, 

or no energy savings in the NIA.

Item 22 DOE welcomes comments on more efficacious (and equal lumen output) substitutes 

for each proposed baseline model, up to and including the max tech lamp that would 

result in reduced energy consumption.

Item 23 DOE welcomes comment on the current and future availability of reduced wattage 

lamps and the practicality of reducing and respacing fixtures. DOE also invites 

comment on whether barriers exist to developing new lamps that would provide 

reduced wattage alternatives to today’s lamps.

5.5 Efficacy Levels

After identifying more efficacious substitutes for each baseline lamp-and-ballast system, 

DOE will develop CSLs, a set of efficacy levels considered in the interim analyses that spans the 

range of lamp efficacies from baseline equipment to equipment at the maximum technologically 

feasible level. Each CSL is analyzed in the LCC and NIA analyses. At the NOPR stage of the 

rulemaking process, DOE will propose energy conservation standard levels for each equipment 

class and invite public comment. 

Efficacy levels are generally based on consideration of several factors, including (1) 

design options associated with the specific lamps being studied; and (2) the maximum 

technologically feasible efficacy level. Furthermore, DOE will consider the impact of energy 

conservation standards on the overall efficiency of lighting systems. Lighting systems could exist 

whose optimal performance is achieved using a lamp that does not meet a high lamp efficacy 

requirement. DOE does not intend for a standard to eliminate lighting systems that save more 

energy than the savings due to increased lamp efficacy.

Finally, the equipment class structure described in section 3.1.1 reflects a “binned” 

efficacy level approach. In this approach, DOE would establish a constant lamp efficacy 

requirement for particular ranges of light output. Although a constant efficacy requirement 

simplifies standards for manufacturers, this approach would subject all lamps in a particular light 

output range to the same standard, which could encourage the market towards the higher light 

output (and higher input power) end of the bin. This could potentially negate energy savings 

associated with increasing lamp efficacy. Therefore, DOE is also considering an equation-based 

approach. An equation-based approach would establish lamp efficacy requirements as a function 
30

of light output, thus eliminating the need for equipment classes based on lumen output. As 

described in section 3.1.1, lamp efficacy tends to increase for lamps with higher light output, and 

an equation-based approach would allow DOE to account for this trend with a continuous 

relationship. 

Item 24 DOE welcomes comments on the use of an equation-based versus binned efficacy 

level approach for HID lamps.

Item 25 DOE welcomes input on whether highly efficacious lighting systems could be 

eliminated given a particular lamp efficacy requirement.

5.6 Scaling Method

For the equipment classes not analyzed directly, DOE plans to scale the engineering 

results and CSLs from the representative equipment classes based on efficacy ratios observed in 

catalog data or by extrapolation across lumen output using regression equations. For example,

DOE might calculate an average percent difference in efficacy between lamps in equipment class 

4A and 4B (representative class) and use this percent difference to scale the engineering results 

from equipment class 4B to 4A.

Item 26 DOE welcomes comments on its proposed approach to scale from representative 

equipment classes to classes not directly analyzed in the engineering analysis.

5.7 Product Price Determination

In this rulemaking, DOE plans to estimate end-user price directly, rather than develop 

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

DOE selected this methodology because it is difficult to reverse-engineer an HID lamp; they are 

not easily disassembled, and fill gas composition and partial pressures are difficult to assess. 

DOE is considering collecting manufacturer suggested price lists (hereafter “blue-book”) 

and applying a discount based on the distribution channel through which the lamp is purchased. 

DOE will gather price information from State procurement contracts, large electrical supply 

distributors, home-improvement/hardware stores, and other sources of publicly available enduser prices such as Internet retailers, to estimate the appropriate discounts. DOE will also add an 

estimate of sales tax to the end-user price estimates as necessary based on tax information 

provided by the Sales Tax Clearinghouse23

DOE seeks feedback on the sales distribution channels of HID lamps, as well as the 

allocation of market share between these channels. DOE also encourages interested parties to 

submit any relevant data that would improve DOE’s understanding of the cost-efficacy 

relationship of HID lamps. As discussed previously, DOE will present aggregated results in 

future stages of the rulemaking rather than confidential data received from interested parties. 

 23 Sales Tax Clearinghouse, Aggregate State Tax Rates. Available at: thestc.com/STrates.stm.
31

Item 27 DOE seeks comment on its end-user price approach for calculating the cost-efficacy

relationship for HID lamps. In particular, DOE seeks comment on typical distribution 

channels for HID lamps, as well as the allocation of market share between these 

channels.

5.8 Proprietary Designs

In its engineering and economic analyses, DOE will consider all design options that are 

commercially available or present in a working prototype, including proprietary designs. 

However, if a proprietary design is the only approach available to achieve a given efficacy level, 

then DOE will eliminate the efficacy level from further analysis. DOE will reject a standard level 

that can be met only with a single proprietary technology because it could result in an anticompetitive market, a principle consistently applied in past DOE rulemakings as economically 

unjustifiable. However, if a given energy efficacy level can be achieved by a number of design 

approaches, including a proprietary design, DOE will continue to examine the given efficacy 

level, in spite of the proprietary nature of a particular design. 

DOE is aware of manufacturer concerns about proprietary designs and will take steps to 

maintain the confidentiality of any proprietary data provided by manufacturers. This information 

will provide input to the competitive impacts assessment and other economic analyses.

Item 28 DOE seeks information regarding the existence of relevant proprietary designs for 

the HID lamps under consideration in this rulemaking. DOE also seeks comment on 

whether these proprietary designs are the only pathway to increase lamp efficacy.

5.9 Outside Regulatory Changes Affecting the Engineering Analysis

In conducting an engineering analysis, DOE considers the impacts of regulatory burdens 

outside of DOE’s energy conservation standards rulemaking process that can affect 

manufacturers of the covered equipment. Some regulatory requirements can also affect the 

efficacy or energy use of the HID lamps covered under this rulemaking. DOE will consider nonlamp (e.g., ballast, fixture, luminaire) regulatory requirements related to HID lamps, and attempt 

to identify all outside regulatory requirements that could affect the engineering analysis. The 

consideration of these requirements is closely related to the cumulative regulatory burden 

assessment that DOE will conduct as part of the MIA. Based on consideration of the comments 

received on the engineering analysis, DOE will make any necessary changes to its analysis.

Item 29 DOE welcomes comments on regulatory burdens and changes directly or indirectly 

related to HID lamps that should be considered in the engineering analysis.

Item 30 DOE welcomes comments on other engineering issues that could affect the 

engineering analysis.

6 ENERGY-USE CHARACTERIZATION
32

The purpose of the energy-use characterization is to estimate the energy usage in the 

baseline and higher-efficacy lamps considered in this rulemaking. This analysis, which is meant 

to represent typical energy usage in the field, is an input to both the LCC and PBP analyses and 

the NIA. The energy-use characterization enables DOE to determine the LCC and the PBP of 

more efficacious lamps in relation to the baseline lamp. 

For HID lamps, energy use is derived by multiplying the system input power rating by 

the annual operating hours. System power is defined as the total input power to the lamp-andballast system. Due to ballast inefficiencies, HID ballasts typically add between 8 percent and 27 

percent (the higher percentages are associated with the lower rated power lamps) of the lamp 

rated power to the system. For the LCC and PBP analyses in the 2010 HID lamps final 

determination, DOE surveyed the commercially available ballast input power ratings for given 

lamps, and used the median ballast input power for each type of lamp in the energy-use 

characterization. DOE proposes to review manufacturer catalogs for HPS and MV ballast input 

power values as it did for the determination. For MH ballast input power, DOE will review 

catalogs as well as ongoing analyses for the concurrent MHLF rulemaking. 

DOE plans to use data from the 2010 U.S. Lighting Market Characterization,24 the 

Energy Information Administration’s (EIA’s) 2003 Commercial Building Energy Consumption 

Survey (CBECS),25 and EIA’s 2006 Manufacturer Energy Consumption Survey (MECS)26

For the NOPR stage of this rulemaking, DOE will conduct a sensitivity analysis to 

determine how high and low estimates of energy use might affect the economic feasibility of any 

proposed energy conservation standards. DOE will also be able to correlate regional electricity 

prices and sales tax data to develop a more accurate distribution of the variability in consumer 

effects in the LCC analysis.

to 

estimate a distribution of operating hours for the different HID lamps by sector and census 

division. While the 2010 MECS data collection has started (four year cycle), these data are not 

yet available. The EIA studies provide information on the distribution of buildings within the 

United States by building type and census division. The LMC, which is based on thousands of 

building audits and surveys, provides national data on annual operating hours by building and 

lamp type for all sectors. These operating hours are further broken down by application for the 

commercial and industrial sectors. By comparing the LMC data with the EIA data, DOE will 

derive annual operating hours for census divisions and selected large states. This approach 

allows DOE to correlate the electricity price and sales tax distributions with the operating hours 

distributions of census divisions and selected large states in the LCC spreadsheet. 

 24 U.S. Department of Energy--Office of Energy Efficiency and Renewable Energy. Final Report: 2010 U.S. 

Lighting Market Characterization. 2012. Washington, D.C. 

http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf. 25 U.S. Department of Energy--Energy Information Administration. Commercial Building Energy Consumption 

Survey: Micro-level data, file 2 Building Activities, Special Measures of Size, and Multi-building Facilities. 2003. 

Washington, D.C. www.eia.doe.gov/emeu/cbecs/public_use.html. 26 U.S. Department of Energy-Energy Information Administration. Manufacturing Energy Consumption Survey, 

Table 1.4: Number of Establishments by First Use of Energy for All Purposes. 2006. Washington, D.C. 

www.eia.doe.gov/emeu/mecs/mecs2006/2006tables.html.
33

Item 31 DOE welcomes comments on whether median system input power is appropriate for 

characterizing lamp energy use.

Item 32 DOE welcomes comments on its proposed methodology to determine annual 

operating hours for covered HID lamps in the commercial and industrial sectors, and 

how operating hours may vary by lamp type and application.

7 MARKUP ANALYSIS

In its markup analysis, DOE will evaluate distribution channels for HID lamps to help 

develop end-user equipment prices for the LCC analysis and NIA. To relate end-user prices to 

MSPs used in the MIA, DOE will also estimate the price markups occurring in the identified 

distribution channels.

Although HID lamps are the covered equipment in this rulemaking, DOE must also 

consider the prices of ballasts and fixtures related to HID lamps because ballast and fixture 

prices can vary with lighting application (e.g., indoor versus outdoor). Some options considered 

in the proposed efficacy levels will require a new ballast, or possibly a new fixture (with a new 

ballast). Therefore, DOE must also consider the distribution channels for lamps, ballasts, and 

fixtures in determining equipment prices.

MSPs are inputs to the MIA (section 12). Because DOE is developing end-user prices 

from price schedules, it will need to derive MSPs for the MIA from end-user prices using 

manufacturer-to-consumer markups.

7.1 Distribution Channels

In generating end-user price inputs for the LCC analysis and NIA, DOE must identify 

distribution channels (i.e., how the equipment is distributed from the manufacturer to the 

consumer), and estimate relative sales volumes through each channel. DOE has identified the 

two primary distribution channels for HID lamps as follows:

Lamp Distribution Channel 1:

Lamp Manufacturer  Electrical Wholesaler (Distributor)  Contractor 

End-User of Lighting System

Lamp Distribution Channel 2:

Lamp Manufacturer  Electrical Wholesaler (Distributor)  End-User of 

Lighting System

For replacement HID ballasts, DOE assumes the following primary distribution channel:

Replacement Ballast Distribution Channel:

Ballast Manufacturer  Electrical Wholesaler (Distributor)  Contractor 

End-User of Lighting System
34

In 2009, DOE published the MHLF framework document27 that included a distribution 

channel for MH lamp fixtures. Because MH lamps are a subset of HID lamps, DOE assumes the 

same channel for HID fixtures:

HID Fixture Distribution Channel:

Fixture Manufacturer  Electrical Wholesaler (Distributor)  Contractor 

End-User of Lighting System

7.2 Markups

To help derive MSPs for the MIA, DOE will rely on economic data from public sources 

and industry input to determine the extent to which equipment is marked up from the 

manufacturer to the consumer. Publicly owned companies are required to disclose financial 

information on a regular basis by filing various forms with the U.S. Securities and Exchange 

Commission (SEC). Filed annually, SEC Form 10-K provides a comprehensive overview of the 

company’s business and financial conditions. To estimate manufacturer markups, DOE will use 

financial data from available 10-K reports from publicly owned lighting equipment 

manufacturers.28

Item 33 DOE welcomes suggestions and comments concerning its proposed approach for 

estimating consumer prices for HID lamps, ballasts, and fixtures.

Item 34 DOE welcomes comments on typical manufacturer, wholesaler, and contractor 

markups associated with HID lamps, ballasts, and fixtures.

8 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSES 

The effects of new or amended energy conservation standards on consumers include a 

change in operating expense (usually decreased) and a change in purchase price (usually 

increased). The LCC of equipment is the cost it incurs over its lifetime, taking into account both 

purchase price and operating expenses. The PBP represents the time it takes to recover the 

additional installed cost of the more-efficient equipment through annual operating-cost savings. 

DOE analyzes the net effect on consumers by calculating the LCC and PBP using the 

engineering performance data (section 5), the energy-use characterization data (section 5), and 

the markups analysis (section 7). Inputs to the LCC calculation include the installed cost to the 

consumer (purchase price plus installation cost), operating expenses, the lifetime of the 

equipment or another defined period of analysis, and a discount rate (see section 8.2, Life-Cycle

Cost Discount Rates). Inputs to the PBP calculation include the installed cost to the consumer 

and annual operating costs.

In addition to the LCC and PBP calculations, DOE will also conduct a rebuttable 

presumption analysis for HID lamps. Under 42 U.S.C. 6295(o)(2)(B)(iii), EPCA establishes a 

 27 The framework document for the 2009 MHLF (RIN: 1904-AC00) is available at 

www1.eere.energy.gov/buildings/appliance_standards/commercial/metal_halide_ecs_framework_pub_mtg.html. 28 10-K reports are filed with the U.S. Securities and Exchange Commission and are available at 

www.sec.gov/index.htm.
35

rebuttable presumption that a standard is economically justified if the Secretary finds that the 

additional cost to the consumer of purchasing equipment complying with an energy conservation 

standard level will be less than three times the value of the consumer’s first year of energy 

savings due to the standard as calculated under the applicable test procedure. DOE plans to use 

the average annual operating hours of the most common end-use application. Although the 

rebuttable presumption calculation is helpful in understanding that certain standard levels have 

shorter payback periods, DOE routinely conducts a full economic analysis that considers the full 

range of effects, including those to the consumer, manufacturer, nation, and environment, as 

required under 42 U.S.C. 6295(o)(2)(B)(i). The results of this more comprehensive analysis 

serve as the basis for DOE to evaluate the economic justification for a potential standard level 

(thereby supporting or rebutting the results of any preliminary determination of economic 

justification). Economic justification is based on a weighing of the seven statutory factors 

described in section 1.4.1. As part of its interim analyses, DOE will conduct the LCC and PBP 

analyses using typical values to reflect conditions in the field for equipment retail price and life, 

energy costs, energy usage, and discount rates. If DOE determines that there is significant 

variability in any of these inputs, it will conduct sensitivity analyses to determine how high and 

low estimates for each input affect the LCC and PBP. For any sensitivity analyses that it 

conducts, DOE will account for correlations that may exist between inputs (e.g., energy usage 

may be correlated to energy prices). The detailed impact calculation, which DOE will conduct 

for the NOPR, may include an assessment of effects on consumer subgroups, as described in 

section 11.

For the NOPR, DOE will carefully review all of the comments it receives on the LCC 

analysis, may evaluate additional parameters not included in the interim analyses, and will make 

any necessary revisions.

The following sections discuss the methodologies DOE plans to use to estimate energy 

prices; discount rates; maintenance, repair, and installation costs; and lifetimes for HID lamps. 

Table 8.1 lists some of the major inputs DOE anticipates it will use for the LCC and PBP 

analyses.
36

Table 8.1 Input to the Life-Cycle Cost and Payback Period Analyses

Input Description

Equipment Price The price of certain HID lamps will be established as described in section 

7, Markups Analysis. DOE will also consider price trends, as appropriate, 

in this rulemaking. 

Sales Tax Sales tax is applied to convert the product price to a final consumer price. 

Sales tax markups will be estimated as described in section 7, Markups 

Analysis.

Installation, Maintenance, 

and Repair Costs

These inputs represent the representative cost to consumers of installing 

HID lamps and (if required) replacing ballasts, and fixtures. DOE assumes 

that HID lamps will not require maintenance or repair during their service 

lifetimes.

Annual Operating Hours The annual operating hours are the estimated hours that HID lamps are in 

use over 1 year. Operating hours will be estimated as described in section 5, 

Energy-Use Characterization.

Equipment Energy 

Consumption Rate

The product energy consumption rate is the site-energy usage rate 

associated with operating the lamp system. This rate will be estimated as 

described in section 5, Energy-Use Characterization.

Electricity Prices Electricity prices used in the analysis are the national average price per 

kilowatt-hour (i.e., dollars/kilowatt-hour ($/kWh)) for that commercial and 

industrial applications pay. 

Electricity Price Trends Electricity price trends estimate the future cost of electricity. 

Lamp Lifetime Lamp lifetime is the number of hours a lamp is expected to be in operation 

before the lamp fails.

Discount Rate The discount rate is the rate at which DOE discounts future expenditures to 

establish their present value (3% or 7%).

Analysis Period The 30-year analysis period is the time span over which DOE calculates the 

LCC.

8.1 Electricity Prices

DOE will survey residential, commercial, and industrial energy tariffs29 as a means for 

establishing marginal electricity prices for consumers of HID lamps. DOE will also use data 

from CBECS30 to estimate building energy-use characteristics that affect electricity prices. DOE 

received comments during the HID lamp determination rulemaking that energy tariffs vary 

greatly even within a given state. (Docket No. EE-DET-03-001, PennDOT, No. 5 at p.1) If the 

tariff survey and EIA data demonstrate a large variability in electricity prices, DOE will conduct 

a sensitivity analysis to determine how high and low electricity price estimates might affect the 

economic feasibility of any energy conservation standards. DOE will use projections of national 

average energy prices—principally from the most recent EIA Annual Energy Outlook (AEO)

31

 29 Energy tariffs (utility industry term for the price of electricity calculated based on the type and market price of the 

fuel used, government subsidies, government and industry regulation, and even local weather patterns) vary widely 

from country to country, and may vary significantly from locality to locality within a particular country. DOE 

contractors maintain a database of hundreds of tariffs that can be used to calculate incremental energy bill impacts 

for a given utility from energy savings at 

—

as inputs for future energy prices in the LCC analysis. 

tariffs.lbl.gov. 30 See www.eia.doe.gov/emeu/cbecs. 31 See www.eia.doe.gov/oiaf/aeo/.
37

Item 35 DOE welcomes input on its proposed approach for estimating electricity prices in this 

analysis.

8.2 Life-Cycle Cost Discount Rates

Calculation of consumer LCC requires use of an appropriate discount rate. DOE uses the 

discount rate to determine the present value of lifetime operating expenses. Because consumers 

of HID lamps are typically commercial, industrial, and municipal entities, DOE will derive the 

discount rates for consumers of HID lamps by estimating the capital cost to companies that 

purchase related lighting equipment. The cost of capital is commonly used to estimate the 

present value of cash flows to be derived from a typical company project or investment. Most 

companies use both debt and equity capital to fund investments, so the cost of capital is the 

weighted-average cost of equity and debt financing. This corporate finance approach is referred 

to as the “weighted-average cost of capital.” However, because the set of commercial or 

industrial companies purchasing HID lamps may differ from those that purchase other equipment 

such as distribution transformers, each rulemaking requires development of its own targeted 

discount rates.

DOE will publish the discount rates and documentation on the derivation of these 

discount rates in the interim analyses and will invite interested parties to comment on consumer 

discount rates during the associated comment period. DOE will make necessary changes to the 

interim analyses based on the comments it receives on the LCC and PBP analyses, and will 

reflect those changes in the NOPR.

Item 36 DOE welcomes input on the planned approaches for estimating discount rates for 

consumers of the HID lamps covered under this rulemaking.

8.3 Installation, Maintenance, and Repair Costs

DOE typically considers expected changes to installation, maintenance, and repair costs 

for covered equipment due to new or amended standards. Often, small incremental changes in 

equipment efficiency would incur little or no change in installation, maintenance, and repair 

costs over baseline equipment. For equipment with significant efficacy improvements over the 

baseline, there may be increased installation, maintenance, and repair costs because such 

equipment is more likely to incorporate technologies that are not widely available or used. 

DOE intends to consider each of these costs in its LCC analysis of HID lamps, ballasts 

and fixtures as follows:

• Installation costs—DOE considers the total installed cost of a lamp to be the consumer 

product price (including sales taxes) plus the installation cost. This was the methodology 

used in the 2009 GSFL/IRL final rule (74 FR 34080, 34108 (July 14, 2009)) and the 

ER/BR framework document.32

 32 DOE’s framework document is available at: 

For the commercial, industrial, and municipal sectors, 

www1.eere.energy.gov/buildings/appliance_standards/residential/er_br_framework_public_meeting.html
38

DOE assumes an installation cost that is the product of the average labor rate and the time 

needed to install a lamp. 

DOE is aware that the costs for commercial and industrial sector lamp installations would 

vary depending on whether the relamping practices are based on group relamping (i.e., 

changing multiple lamps together, before the end of the average lamp lifetime) or spot 

relamping (i.e., changing only those lamps that have failed). However, DOE does not 

believe that existing relamping practices would necessarily change under an energy 

conservation standard.

Although the equipment under this rulemaking is a lamp, DOE is considering ballast and 

fixture replacement costs in its analysis. HID lamps are functionally related to specific 

ballast types, and fewer ballasts are interchangeable. Further, ballast replacement 

provides the consumer with a broader selection of efficacious HID lamps for a given 

lighting application.

In the 2009 GSFL/IRL final rule and ER/BR lamps framework document, DOE derived 

costs using RSMeans Electrical Cost Data,33 a reference book with extensive cost data, to 

obtain average labor times for installation as well as labor rates for electricians and 

helpers based on wage rates, benefits, and training costs. DOE proposes to use the most 

current version available of RSMeans Electrical Cost Data for the HID lamps 

rulemaking. DOE will also review industry literature for other installation cost data.

• Maintenance and repair costs—DOE did not include maintenance costs in the LCC 

analysis for the 2010 HID lamps final determination because DOE assumed HID lamps 

require no maintenance during their operational lifetime and are replaced upon failure (or 

dimming below acceptable levels) instead of repaired. 

Item 37 DOE welcomes comments on how to estimate installation costs for HID lamps. DOE 

specifically seeks comment on the availability and value of sources other than

RSMeans Electrical Cost Data to consider in estimating installation costs.

Item 38 DOE welcomes comments on whether relamping practices (i.e., group or spot 

relamping) would change if HID lamp life is affected by new energy conservation 

standards.

Item 39 DOE welcomes comments on whether maintenance or repair costs for HID lamps, 

ballasts or fixtures should be considered in this analysis.

8.4 HID Lamp Lifetimes

DOE will use information from manufacturer product catalogs, literature sources such as 

technical reports and conference proceedings, and input from manufacturers and other interested 

parties to establish HID lamp lifetimes for use in the LCC and subsequent analyses. 

 33 RSMeans Company, Inc., RSMeans Electrical Cost Data, Kingston, MA.
39

In the 2009 GSFL/IRL final rule, DOE adjusted rated lamp lifetimes to account for the 

effects of group relamping, effectively lowering the lifetime to approximately 91−94 percent of 

rated lifetime, depending on lamp type Chapter 8 of the TSD for the 2009 GSFL/IRL final rule34

Item 40 DOE welcomes comments on appropriate lifetimes for the HID lamps covered in this 

rulemaking, and how lamp life should be adjusted to reflect group relamping 

practices by lamp type and sector.

. 

DOE intends to investigate the prevalence of group and spot relamping of HID lamps by sector, 

and assess the practical effects of relamping practices on lamp lifetime.

9 SHIPMENTS ANALYSIS

DOE forecasts shipments of equipment to calculate the national effects of standards on 

energy use, NPV, and future manufacturer cash flows. DOE plans to develop shipments forecasts 

based on an analysis of key market drivers for HID lamps.

9.1 Baseline Forecast

To evaluate the various effects of new or amended standards, DOE develops a baseline 

shipments forecast against which to compare standards-case shipments forecasts at higher 

efficacy levels (based on the CSLs). DOE will design the baseline forecast to project what might 

happen to energy use and energy costs over time if energy conservation standards for the HID 

lamps under this rulemaking are not adopted. In determining the baseline forecast, DOE will 

consider historical shipments, the mix of efficacies currently sold in the absence of regulation, 

and how that mix might change over time. For these purposes, DOE seeks data on historical 

equipment shipments and the market shares of the different efficacy levels offered in each 

proposed equipment class. 

Item 41 DOE welcomes recommendations on sources of data for shipments of HID lamps by 

proposed equipment class. In addition, DOE welcomes comments on future long-term 

trends in HID lamp efficacy (e.g., market share of probe-start quartz MH versus 

pulse-start quartz and/or pulse-start ceramic MH) for the baseline shipments 

forecast.

9.2 Accounting Methodology 

DOE plans to determine annual shipments in the base case by accounting for new 

building construction, lamp replacements due to failure, and fixture retrofits (i.e., major 

remodeling where the fixture is replaced). Each of these three effects on the accounting 

methodology is discussed below:

• New construction applies to HID lamps in new fixtures that are installed each year due to 

floor space growth in a particular sector. DOE proposes to determine this by using the 

 34 See www1.eere.energy.gov/buildings/appliance_standards/residential/incandescent_lamps.html
40

National Energy Modeling System (NEMS) growth projection for the commercial and 

industrial sectors.

• Replacements apply to lamps that have failed or are retired from service via group 

relamping. DOE plans to base this calculation on lamp shipments and retirement rates

over the analysis period of 30 years.

• Retrofits apply to HID lamps and fixtures that are installed to replace existing lamps and 

fixtures during renovation or remodeling. This replacement generally occurs before a 

lamp has failed.

DOE intends to use an accounting model to prepare shipment scenarios for the baseline 

and the standards-level cases. The model will keep track of the aging and replacement of HID 

lamps given a projection of future HID lamp sales growth.

Item 42 DOE welcomes comments on the accounting methodology described above for each 

type of HID lamp covered in this rulemaking.

9.3 Standards’ Effect on HID Lamp Shipments

DOE will develop a set of shipment forecasts for covered lamps in each efficiency level 

analyzed, and will then use these standards-case forecasts to evaluate the effects of new

standards on lamp shipments. DOE derives standards-case forecasts from the same data sets it 

uses for baseline forecasts. However, because the standards-case forecasts take into account the 

increase in purchase price and the decrease in operating costs caused by new or amended 

standards, forecasted shipments typically deviate from the baseline. The magnitude of the 

difference between the standards-case and baseline shipment forecasts depends on the estimated 

purchase price increase, as well as the operating-cost savings from the new or amended standard.

Market-pull programs, such as consumer rebate programs that encourage the purchase of 

more-efficient HID lamps, ballasts, or fixtures, also affect standards-case shipment forecasts. In 

the TSD for the 2010 HID lamps determination, DOE examined non-regulatory incentive 

programs (Appendix A of the TSD for the 2010 HID lamp determination). The review of 

programs started with an online search using the DOE-funded Database of State Incentives for 

Renewables & Efficiency (DSIRE).35

Federal, State, and local regulatory efforts addressing HID lamps, ballasts, and fixtures 

can also affect lamp shipment forecasts. Effective 2010, the State of California had requirements 

for MH luminaires (MH lamp fixtures) that addressed not only ballast efficiency, but also 

elements of lumen maintenance of the lamp. Furthermore, between 2008 and 2010, 10 states and 

the District of Columbia prohibited the sale of certain probe-start MH lamp fixtures between 150 

and 500 W: Arizona, New York, Oregon, Rhode Island (effective 2008); District of Columbia, 

Maryland, Massachusetts, Vermont, and Washington (effective 2009); and California and 

Connecticut (effective 2010). Although these prohibitions pertain to the fixture and its installed 

DOE found programs in 23 states that specifically focus on 

HID lighting technology. Incentives exist for either installing new HID lamps or replacing HID 

lamps with non-HID lamps. 

 35 See www.dsireusa.org/.
41

ballast, the probe-start lamp used in these fixtures would also be significantly affected. To the 

extent that such State regulatory requirements exist, DOE will consider their effects on the 

forecast of both standards-case and baseline shipments.

Item 43 DOE welcomes comments on how proposed energy conservation standards might 

affect shipments of HID lamps. DOE also requests information on the HID lamp 

impact of existing market-pull programs, such as consumer rebate programs, to 

promote the adoption of more efficacious lamps.

10 NATIONAL IMPACT ANALYSIS

The NIA assesses cumulative NES and the cumulative national economic impacts of 

efficacy levels. The analysis measures economic impacts using the NPV metric, which represents 

the “net present value” (i.e., future amounts discounted to the present) of total customer costs and 

savings expected to result from new standards at specific efficacy levels. For a given efficacy 

level, DOE calculates the NPV, as well as the NES, as the difference between a baseline forecast 

and the standards-case forecasts.

10.1 Inputs to NES and NPV Forecasts

Analyzing effects of Federal energy conservation standards for HID lamps requires 

comparing projected energy use in the United States with and without energy conservation 

standards. The forecasts contain projections of unit energy use of new lamps, annual equipment 

shipments, the price of purchased equipment, and baseline and standards-case efficiencies. 

Derivations of the baseline shipment forecasts are discussed in section 9. Approaches to 

determine retail prices for equipment are described in section 7. Approaches to determine unit 

energy use are described in section 5.

The rebound effect is another input to the NIA. Consumers that encounter lower 

operating costs associated with more energy-efficient products may use that product more often 

than the less-efficient product. DOE’s rebound effect analysis accounts for any increase in 

consumer use. As in the 2009 GSFL/IRL Lamps Rule, DOE plans to incorporate the rebound 

effect that occurs after installation of energy-efficient lighting equipment. 74 FR 34080, 34115 

(July 14, 2009) In the 2009 GSFL/IRL Lamps Rule, DOE examined a summary of the literature 

regarding the rebound effect in relation to lighting equipment. Based on four studies, the 

summary estimated that, for a 100 percent increase in energy efficiency, values of “take-back” or 

rebound for residential lighting were between 5 and 12 percent of the energy consumption 

savings. In addition, with regards to a commercial firm’s response to higher-efficiency lighting, 

the summary estimated 0 to 2 percent for values of rebound for lighting. Therefore, in the 

calculation of NES due to energy conservation standards on lighting, DOE plans to use the 

rebound rate of 1 percent in the commercial sector estimated in the 2009 GSFL/IRL Lamps Rule.

See chapter 11 of the TSD for the 2009 GSFL/IRL Lamps Rule for a more complete discussion 

on the rebound effect. 

Table 10.1 describes some of the major inputs DOE anticipates it will develop for the NIA.
42

Table 10.1 Input Data, Factor, and Forecasts for the National Impact Analysis

Input Description of Data Sources

Shipments Annual shipments are developed as described in section 9, Shipment 

Analysis.

Stock of HID Lamps Calculated from the service life of lamps developed as described in 

section 8, Life-Cycle Cost and Payback Period Analyses, and annual 

shipments from HID lamps developed as described in section 9, 

Shipment Analysis.

Compliance Date of Standard 3 years after publication of final rule, assumed to be June 15, 2017.

Analysis Period 2017–2046 (30 years).

Base-Case Forecasted Efficiency Distribution of baseline shipments by efficacy level over time developed 

as described in section 9, Shipment Analysis.

Standards-Case Forecasted Efficiency Distribution of shipments by efficacy level for each standards case over 

time as described in section 9, Shipment Analysis.

Unit Energy Consumption (kWh/yr) Average energy use of HID lamps established as described in section 5, 

Energy-Use Characterization.

Total Installed Cost Described in section 7, Markups Analysis, and section 8, Life-Cycle 

Cost and Payback Period Analyses.

Electricity Price Forecast Established using AEO2011 forecasts as described in section 8, LifeCycle Cost and Payback Period Analyses.

Electricity Site-to-Source Conversion Varies yearly and is obtained from EIA AEO forecasts of electricity 

generation and electricity-related losses.

Discount Rate The rate at which DOE discounts future expenditures to establish their 

value in the present year. DOE will use 3- and 7-percent (real) discount 

rates.

Present Year The year 2012.

Rebound Effect 1% of total energy savings in the commercial and industrial sectors. 

Item 44 DOE welcomes comments on the proposed data, factor and forecast sources it 

anticipates using to develop inputs for the national impact analysis. 

Item 45 DOE welcomes comments as to whether more efficacious HID lamp designs would be 

operated more as a result of their increased efficacy (i.e., whether a positive rebound 

effect would be expected for this equipment) and if so how much longer would they be 

operated.

10.2 Calculation of National Energy Savings

DOE intends to calculate national energy use for each year beginning with the expected 

compliance date of the standards, estimating national electricity use for the base case and each 

potential standard level analyzed. To account for the stock of equipment affected by new 

standards, DOE plans to use a spreadsheet model that effectively multiplies annual shipment 

forecasts by unit energy savings.

In response to past comments from interested parties who asked for a simple, transparent 

model, DOE developed NIA spreadsheet models for its standards rulemakings starting in 1996. 
43

These models project energy savings and demonstrate how to account for the growth in efficacy 

over time.36

Item 46 DOE welcomes comments from interested parties on the NES spreadsheet models it 

plans to use for estimating national effects of new energy conservation standards for 

HID lamps.

Although these models are specific to each piece of equipment analyzed, their 

general framework is applicable to the entire HID lamp market. DOE expects that the NIA 

spreadsheet model will provide a stand-alone forecast of NES and NPV for HID lamps. DOE 

will make any necessary changes to the interim analyses based on the comments it receives, and 

incorporate those changes in the NOPR.

10.3 Net Present Value of Consumer Savings 

DOE calculates the national NPV of the consumer savings resulting from energy 

conservation standards in conjunction with the NES. It calculates annual energy expenditures 

from annual energy use by incorporating forecasted energy prices, using the shipment and 

average energy efficiency forecasts described in section 9, Shipment Analysis. DOE calculates 

annual equipment expenditures by multiplying the price per lamp by the forecasted shipments. 

The difference between a baseline and a standards-case scenario gives the national energy bill 

savings and increased equipment expenditure in dollars. For the HID lamp rulemaking, this 

differential will likely result in an NES offset against increased expenditures. The difference 

each year between projected energy bill savings and increased equipment expenditures is the net 

savings (if positive) or net costs (if negative). DOE will discount these annual values to the 

present time and sum them to provide a NPV. Because the national cost of capital may differ 

from the consumer cost of capital, the discount rate used in the NIA can be different from the 

rate used in the LCC. The national average aggregates the different costs of capital while the 

consumer cost of capital is more applicable to subsets of consumers. According to U.S. Office of 

Management and Budget (OMB) guidance, DOE will conduct two NPV calculations, one using a 

real discount rate of 3 percent and another using a real discount rate of 7 percent.37

11 LIFE-CYCLE COST SUBGROUP ANALYSIS

DOE will 

make any necessary changes to the analysis based on the comments it receives on the interim 

analyses.

At the NOPR stage of this rulemaking, DOE will conduct an LCC subgroup analysis. In 

this analysis, DOE assesses consumer effects by dividing consumers into subgroups and 

accounting for variations in key inputs to the LCC analysis. A consumer subgroup comprises a 

subset of the population more likely to be affected disproportionately by new or amended energy 

conservation standards (e.g., small businesses, minorities, low-income consumers, or seniors). 

The purpose of a subgroup analysis is to determine the extent of any such disproportionate effect. 

DOE will work with industry and other interested parties early in the rulemaking process to 

identify any subgroups for consideration. 

 36 Examples of NES spreadsheet models from previous rulemakings can be found on DOE’s website at 

www.eere.energy.gov/buildings/appliance_standards. 37 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003).
44

In comparing potential effects on the different consumer subgroups, DOE will evaluate 

variations in regional electricity prices, usage profiles, and installation costs that might affect the 

NPV of an energy conservation standard to certain consumer subgroups. To the extent possible, 

DOE will obtain estimates of the variability in each input and consider this variability when 

calculating consumer effects. DOE will discuss this variability with interested parties and likely 

sources of information.

Item 47 DOE welcomes comments from interested parties on which, if any, consumer

subgroups should be considered when developing standards for HID lamps.

12 MANUFACTURER IMPACT ANALYSIS

The purpose of the MIA is to identify and quantify the likely economic and employment 

impacts of new energy conservation standards on manufacturers of HID lamps. For the interim 

analyses, DOE will collect, evaluate, and report preliminary information on manufacturer 

impacts; this will include anticipated capital conversion costs, by efficacy level, and the 

corresponding anticipated effects on employment. DOE will invite further input on these issues 

during manufacturer interviews for the NOPR analysis.

DOE intends to conduct a separate MIA for each of three types of HID lamp covered 

under this rulemaking; however, DOE may combine all covered lamp types into a single MIA if 

it is determined that this approach is the most appropriate. In addition to financial effects, a wide 

range of quantitative and qualitative effects may occur following adoption of a new or amended 

standard, which may require changes to manufacturing practices. DOE will identify these 

potential effects through manufacturer interviews.

For the NOPR, DOE will supplement the results of the preliminary MIA with more 

detailed analyses (sections 12.1 through 12.5). DOE will conduct an industry-wide cash-flow 

analysis using the Government Regulatory Impact Model (GRIM – see section 12.2), identify 

and analyze subgroups of manufacturers whose businesses vary significantly from the industry as 

a whole, perform a competitive impacts assessment, and review the cumulative regulatory 

burden for the industry.

12.1 Sources of Information for the Manufacturer Impact Analysis

Many of the analyses described previously provide important information that DOE will 

use as inputs for the MIA. Such information includes end-user prices (section 5) marked down to 

MSPs using distribution channel information from the markup analysis (section 7) and shipment 

forecasts (section 9). DOE will supplement this information with information gathered during 

manufacturer interviews.

DOE will conduct interviews with manufacturers to gain insight into the range of 

potential effects from new standards. The interview process provides an opportunity for directly 

affected parties to express their views on important issues. During the interviews, DOE will 

solicit detailed information on the possible effects of new standards on manufacturing costs, 

equipment prices, sales, direct employment, capital assets, and industry competitiveness. Both 

qualitative and quantitative information are valuable in this analysis.
45

DOE will ask interview participants to identify confidential information, and DOE will 

determine whether the information submitted is entitled to confidential treatment. Factors that 

DOE considers when evaluating requests to treat submitted information as confidential include: 

(1) a description of the items; (2) whether and why such items are customarily treated as 

confidential within the industry; (3) whether the information is generally known by or available 

from other public sources; (4) whether the information has previously been made available to 

others without obligation concerning its confidentiality; (5) an explanation of the competitive 

injury to the submitting person that would result from public disclosure; (6) a date after which 

such information might lose its confidential character; and (7) why disclosure of the information 

would be contrary to the public interest. DOE will then consider the information gathered, as 

appropriate, in the energy conservation standard decision-making process.

DOE will collate the interview results and prepare a summary of the major issues and 

outcomes. This summary will become part of the TSD for this rulemaking.

12.2 Industry Cash-Flow Analysis

The industry cash-flow analysis will rely primarily on the GRIM. DOE uses the GRIM to 

analyze the financial effects of new or amended energy conservation standards on the industry 

that produces the equipment covered by the standard.

The GRIM uses a number of factors—annual expected revenues; manufacturer costs such 

as costs of goods sold; selling, general, and administrative costs; taxes; and capital expenditures 

(both ordinary capital expenditures and those related to standards)—to determine annual cash 

flows associated with a new standard, beginning with the announcement of the standard and 

continuing for several years after its implementation. DOE compares the results against baseline 

projections that involve no new or amended standards.

The financial effect of new or amended standards is the difference between the two sets 

of discounted annual cash flows. Other performance metrics, such as return on invested capital, 

are also available from the GRIM.

DOE will gather the inputs needed for the GRIM from two primary sources: (1) the 

analyses conducted to this point; and (2) interviews with manufacturers and other interested 

parties. Information gathered from previous analyses will include financial parameters, 

manufacturing costs, price forecasts, and shipment forecasts. Interviews with manufacturers and 

other interested parties will be essential in supplementing this information.

12.3 Manufacturer Subgroup Analysis

Average industry cost values may not reveal differential effects among HID lamp 

manufacturer subgroups. Smaller manufacturers, niche players, and manufacturers exhibiting a 

cost structure that differs significantly from the industry average may be affected differently by 

standards. Ideally, DOE would consider the effect on every firm individually. In highly 

concentrated industries, this may be possible. In industries having numerous participants, 

however, DOE uses the results of the market and technology assessment to combine 

manufacturers into subgroups, as appropriate. For HID lamps, DOE is interested in feedback 
46

about potential subgroups. The detailed manufacturer subgroup effect analysis will calculate cash 

flows separately for each class of manufacturer.

Item 48 DOE seeks comments on the subgroups of HID lamp manufacturers that it should 

consider in a manufacturer subgroup analysis.

12.4 Competitive Impacts Analysis

EPCA directs DOE to consider any lessening of competition likely to result from the 

imposition of new or amended standards. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It further directs the 

Attorney General to determine in writing the effects, if any, of any lessening of competition. (42 

U.S.C. 6295(o)(2)(B)(ii)) 

DOE will make a determined effort to gather firm-specific financial information and 

effects, and to report the aggregated effect of the new standard on manufacturers. The 

competitive impacts analysis will assess the effects on smaller manufacturers. DOE will base the 

assessment on manufacturing cost data and information collected from interviews with 

manufacturers. These interviews will focus on gathering information that will be helpful in 

assessing asymmetrical cost increases to some manufacturers; increased proportions of fixed 

costs; potentially increasing business risks; and potential barriers to market entry (e.g., 

proprietary technologies). DOE will provide the Attorney General with a copy of the NOPR for 

consideration in his evaluation of the effect of new standards on the lessening of competition.

DOE will publish the Attorney General’s letter and address any related comments in the final 

rule.

12.5 Cumulative Regulatory Burden

Other regulations may apply to the HID lamps covered under this rulemaking, and to 

other equipment produced by HID lamp manufacturers. Multiple regulations may result in a 

significant, cumulative regulatory burden on these manufacturers. DOE will consider the effects

of multiple, equipment-specific regulatory actions on these manufacturers. 

Regulations that could also affect the industry subject to this rulemaking include the 

following:

• Ongoing energy conservation standards rulemaking for MHLF;

• Amended energy conservation standards for GSFL and IRL established by DOE on July 

14, 2009 (74 FR 34080);

• New EPCA standards for medium-base compact fluorescent lamps and MV lamp ballasts 

(42 U.S.C 6295(bb)(1) and (ee));

• New EPCA standards for GSILs (42 U.S.C 6295(i)(1));

• New EPCA standards for MHLF (42 U.S.C. 6295 (hh));
47

• Existing and/or proposed State standards related to HID technology including lamps, 

ballast, and fixtures (e.g., California’s Metal Halide Luminaire Appliance Standards38

• State building energy codes lighting requirements (e.g., American Society of Heating, 

Refrigerating and Air-Conditioning Engineers (ASHRAE) Standard 90.1

), 

established consistent with 42 U.S.C. 6297(b)-(e); and

39

Item 49 DOE welcomes comments on other regulations or pending regulations it should 

consider in its examination of cumulative regulatory burden.

) established 

consistent with 42 U.S.C. 6297(f).

13 UTILITY IMPACT ANALYSIS

To estimate the effects of new energy conservation standards for HID lamps on the 

electric utility industry, DOE will use a variant of the EIA’s National Energy Modeling System 

named NEMS-BT.40

The utility impact analysis is a comparison between the NEMS-BT model results for the 

base case and standard cases. Outputs of the utility impact analysis usually parallel results that 

appear in the latest AEO, with some additions. Typical outputs of the utility impact analysis 

include forecasts of electricity sales, price, and avoided capacity. DOE plans to conduct the 

utility impact analysis as a scenario departing from the latest AEO Reference Case. In other 

words, DOE will model the anticipated energy savings effects from new energy conservation 

standards using NEMS-BT to generate forecasts that deviate from the AEO Reference Case.

NEMS is a large, multi-sector, partial-equilibrium model of the U.S. energy 

sector that EIA has developed over several years, primarily for preparing the AEO. NEMS 

produces a widely recognized, reference-case forecast for the United States through 2030 and is 

available to the public. 

41

Item 50 DOE seeks input on its plans to use NEMS-BT to conduct the utility impact analysis 

on the equipment covered under this rulemaking.

14 EMPLOYMENT IMPACT ANALYSIS

DOE estimates the effects of new or amended standards on employment for equipment 

manufacturers, relevant service industries, energy suppliers, and the economy in general. This 

 38 California Code of Regulations, Title 20, Section 1605.3(n)(2).

39 ASHRAE Standard 90.1-2007 is the current version of the standard. Section 9 of ASHRAE 90.1-2007 deals with 

lighting requirements. Available at www.ashrae.org. 40 For more information on NEMS, please refer to the U.S. Department of Energy, Energy Information 

Administration documentation. A useful summary is National Energy Modeling System: An Overview 2000, 

DOE/EIA-0581 (March 2000), available at tonto.eia.doe.gov/ftproot/forecasting/05812000.pdf. EIA approves use of 

the name NEMS to describe only an official version of the model without any modification to code or data. Because 

this analysis entails some minor code modifications and the model is run under various policy scenarios that are 

variations on EIA assumptions, DOE refers to the model by the name NEMS-BT. (“BT” refers to DOE’s Building 

Technologies Program, under whose aegis this work is performed.)

41 Several descriptions of NEMS-BT models from previous rulemakings, including general service fluorescent 

residential lamps and incandescent reflector lamps, can be found on DOE’s website at 

www.eere.energy.gov/buildings/appliance_standards/residential/pdfs/ch_14_lamps_standards_final_tsd.pdf.
48

analysis covers both direct and indirect employment effects. Direct employment effects are 

changes in the number of employees at the plants that produce the covered equipment, along 

with the affiliated distribution and service companies. DOE will evaluate direct employment 

effects in the MIA (section 6).

Indirect employment effects may result from expenditures shifting between goods (the 

substitution effect) and changes in income and overall expenditure levels (the income effect) that 

occur due to new or amended standards. DOE defines indirect employment effects from new or 

amended standards as net jobs eliminated or created in the general economy as a result of 

increased spending driven by increased equipment prices and reduced spending on energy.

The combined direct and indirect employment effects will be investigated in the 

employment impact analysis using the PNNL Impact of Sector Energy Technologies (ImSET) 

model.42 The ImSET model was developed for DOE’s Office of Planning, Budget, and Analysis 

to estimate the employment and income effects of energy-saving technologies in buildings, 

industry, and transportation. Compared with simple economic multiplier approaches, ImSET 

allows for more complete and automated analysis of the economic impacts of energy 

conservation investments.

DOE notes that ImSET is not a general equilibrium forecasting model, and understands 

the uncertainties involved in projecting employment impacts, especially changes in the later 

years of the analysis. Because ImSET does not incorporate price changes, the employment 

effects predicted by ImSET would over-estimate the magnitude of actual job impacts over the 

long run for this rule. Since input/output models do not allow prices to bring markets into 

equilibrium, they are best used for short-run analysis. DOE will therefore include a qualitative 

discussion of how labor markets are likely to respond in the longer term. In future rulemakings, 

DOE may consider the use other modeling approaches for examining long-run employment 

impacts.

DOE also notes that the employment impacts estimated with ImSET for the entire 

economy will differ from the employment impacts in the lighting manufacturing sector estimated 

in the MIA using the GRIM model. The methodologies used and the sectors analyzed in the 

ImSET and GRIM models are different.

Item 51 DOE requests feedback on its approach to assessing employment impacts on the 

equipment covered under this rulemaking.

15 EMISSIONS ANALYSIS

In the emissions analysis, DOE estimated the reduction in power sector emissions of 

carbon dioxide (CO2), nitrogen oxides (NOx), and mercury (Hg) using the NEMS-BT computer 

model. In the emissions analysis, NEMS-BT is run similarly to the AEO NEMS, except that HID 

lamps energy use is reduced by the amount of energy saved (by fuel type) due to each considered 

standard level. The inputs of NES come from the NIA spreadsheet model, while the output is the 

 42 Roop, J. M., M. J. Scott, and R. W. Schultz. ImSET: Impact of Sector Energy Technologies. 2005. PNNL15273. (Pacific Northwest National Laboratory, Richland, WA)(2005).
49

forecasted physical emissions. The net benefit of each considered standard level is the difference 

between the forecasted emissions estimated by NEMS-BT at that level and the AEO 2011

Reference Case.

15.1 Carbon Dioxide

In the absence of any Federal emissions control regulation of power plant emissions of 

CO2, a DOE standard is likely to result in reductions of these emissions. The CO2 emission 

reductions likely to result from a standard will be estimated using NEMS-BT and NES estimates 

drawn from the NIA spreadsheet model. The net benefit of the standard is the difference between 

emissions estimated by NEMS-BT at each standard level considered and the AEO Reference 

Case. NEMS-BT tracks CO2 emissions using a detailed module that provides results with broad 

coverage of all sectors and inclusion of interactive effects.

15.2 Sulfur Dioxide

SO2 emissions from affected electric generating units (EGUs) are subject to nationwide 

and regional emissions cap and trading programs, and DOE has preliminarily determined that 

these programs create uncertainty about the potential standards’ impact on SO2 emissions. Title 

IV of the Clean Air Act sets an annual emissions cap on SO2 for affected EGUs in the 48 

contiguous states and the District of Columbia (D.C.). SO2 emissions from 28 eastern states and 

D.C. were also limited under the Clean Air Interstate Rule (CAIR, 70 Fed. Reg. 25162 (May 12, 

2005)), which created an allowance-based trading program. Although CAIR has been remanded 

to EPA by the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit), see 

North Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008), it remained in effect temporarily, 

consistent with the D.C. Circuit’s earlier opinion in North Carolina v. EPA, 531 F.3d 896 (D.C. 

Cir. 2008). On July 6, 2011 EPA issued a replacement for CAIR, the Cross-State Air Pollution 

Rule. 76 FR 48208 (August 8, 2011). (See http://www.epa.gov/crossstaterule/). On December 

30, 2011, however, the D.C. Circuit stayed the new rules while a panel of judges reviews them, 

and told EPA to continue enforcing CAIR (see EME Homer City Generation v. EPA, No. 11-

1302, Order at *2 (D.C. Cir. Dec. 30, 2011)).

The attainment of emissions caps is typically flexible among EGUs and is enforced 

through the use of emissions allowances and tradable permits. Under existing U.S. 

Environmental Protection Agency (EPA) regulations, any excess SO2 emissions allowances 

resulting from the lower electricity demand caused by the imposition of an efficiency standard 

could be used to permit offsetting increases in SO2 emissions by any regulated EGU. However, if 

the standard resulted in a permanent increase in the quantity of unused emissions allowances, 

there would be an overall reduction in SO2 emissions from the standards. While there remains 

some uncertainty about the ultimate effects of efficiency standards on SO2 emissions covered by 

the existing cap and trade system, the NEMS-BT modeling system that DOE uses to forecast 

emissions reductions currently indicates that no physical reductions in power sector emissions 

would occur for SO2.

15.3 Nitrogen Oxides
50

Under CAIR, there is a cap on NOx emissions in 28 eastern states and the District of 

Columbia. All these states and D.C. have elected to reduce their NOx emissions by participating 

in cap and trade programs for EGUs. Therefore, energy conservation standards for HID lamps 

may have little or no physical effect on these emissions in the 28 eastern states and the D.C. for 

the same reasons that they may have little or no physical effect on NOX emissions. DOE is using 

the NEMS-BT to estimate NOx emissions reductions from possible standards in the states where 

emissions are not capped.

15.4 Mercury

In the absence of caps, a DOE energy conservation standard could reduce Hg emissions 

and DOE plans to use NEMS-BT to estimate these emission reductions. On December 21, 2011, 

EPA announced national emissions standards for hazardous air pollutants (NESHAPs) for 

mercury and certain other pollutants emitted from coal and oil-fired EGUs. 

(http://epa.gov/mats/pdfs/20111216MATSfinal.pdf) The NESHAPs do not include a trading 

program and, as such, DOE’s energy conservation standards would likely reduce Hg emissions. 

For the emissions analysis for this rulemaking, DOE plans to estimate mercury emissions 

reductions using NEMS-BT based on AEO2011, which does not incorporate the NESHAPs. 

DOE expects that future versions of the NEMS-BT model will reflect the implementation of the 

NESHAPs.

15.5 Particulate Matter

DOE acknowledges that particulate matter (PM) exposure can impact human health. 

Power plant emissions can have either direct or indirect impacts on PM. A portion of the 

pollutants emitted by a power plant are in the form of particulates as they leave the smoke stack. 

These are direct, or primary, PM emissions. However, the great majority of PM emissions 

associated with power plants are in the form of secondary sulfates, which are produced at a 

significant distance from power plants by complex atmospheric chemical reactions that often 

involve the gaseous (non-particulate) emissions of power plants, mainly SO2 and NOx. The 

quantity of the secondary sulfates produced is determined by a very complex set of factors 

including the atmospheric quantities of SO2 and NOx, and other atmospheric constituents and 

conditions. Because these highly complex chemical reactions produce PM comprised of different 

constituents from different sources, EPA does not distinguish direct PM emissions from power 

plants from the secondary sulfate particulates in its ambient air quality requirements, PM 

monitoring of ambient air quality, or PM emissions inventories. For these reasons, it is not 

currently possible to determine how the new standards impact either direct or indirect PM 

emissions. Therefore, DOE is not planning to assess the impact of these standards on PM 

emissions. Further, as described previously, it is uncertain whether efficiency standards will 

result in a net decrease in power plant emissions of SO2, which are now largely regulated by cap 

and trade systems.

Item 52 DOE seeks input on its plans to use NEMS-BT to conduct the environmental 

assessment for the equipment covered by this rulemaking.

16 MONETIZING CARBON DIOXIDE AND OTHER EMISSIONS REDUCTIONS
51

DOE plans to consider the estimated monetary benefits likely to result from the reduced 

emissions of CO2 and NOX that are expected to result from each of the standard levels 

considered.

In order to estimate the monetary value of benefits resulting from reduced emissions of 

CO2, DOE plans to use the most current Social Cost of Carbon (SCC) values developed and/or

agreed to by an interagency process. The SCC is intended to be a monetary measure of the 

incremental damage resulting from greenhouse gas (GHG) emissions, including, but not limited 

to, net agricultural productivity loss, human health effects, property damage from sea level rise, 

and changes in ecosystem services. Any effort to quantify and to monetize the harms associated 

with climate change will raise serious questions of science, economics, and ethics. But with full 

regard for the limits of both quantification and monetization, the SCC can be used to provide 

estimates of the social benefits of reductions in GHG emissions. 

At the time of this notice, the most recent interagency estimates of the potential global 

benefits resulting from reduced CO2 emissions in 2010, expressed in 2010$, were $4.9, $22.3, 

$36.5, and $67.6 per metric ton avoided. For emissions reductions that occur in later years, these 

values grow in real terms over time. Additionally, the interagency group determined that a range 

of values from 7 percent to 23 percent should be used to adjust the global SCC to calculate 

domestic effects, although DOE will give preference to consideration of the global benefits of 

reducing CO2 emissions. To calculate a present value of the stream of monetary values, DOE 

will discount the values in each of the four cases using the discount rates that had been used to 

obtain the SCC values in each case.

DOE recognizes that scientific and economic knowledge continues to evolve rapidly as to 

the contribution of CO2 and other GHG to changes in the future global climate and the potential 

resulting damages to the world economy. Thus, these values are subject to change. 

DOE also intends to estimate the potential monetary benefit of reduced NOX emissions 

resulting from the standard levels it considers. For NOx emissions, available estimates suggest a 

very wide range of monetary values for NOX emissions, ranging from $450 to $4,623 per ton in 

2010$).43 In accordance with OMB guidance, DOE will conduct two calculations of the 

monetary benefits derived using each of the economic values used for NOx, one using a real 

discount rate of 3 percent and another using a real discount rate of 7 percent.44

DOE does not plan to monetize estimates of Hg in this rulemaking. DOE is aware of 

multiple agency efforts to determine the appropriate range of values used in evaluating the 

potential economic benefits of reduced Hg emissions. DOE has decided to await further guidance 

regarding consistent valuation and reporting of Hg emissions before it once again monetizes Hg 

in its rulemakings. 

17 REGULATORY IMPACT ANALYSIS

 43 For additional information, refer to U.S. Office of Management and Budget, Office of Information and Regulatory 

Affairs, 2006 Report to Congress on the Costs and Benefits of Federal Regulations and Unfunded Mandates on 

State, Local, and Tribal Entities, Washington, DC. 44 OMB, Circular A-4: Regulatory Analysis (Sept. 17, 2003).
52

DOE will prepare a regulatory impact analysis in the NOPR and final rule stages of this 

rulemaking. This analysis will address the potential for non-regulatory approaches to supplant or 

augment new energy conservation standards to improve the efficacy of HID lamps on the 

market. DOE recognizes that voluntary and other non-regulatory efforts by manufacturers, 

utilities, and other interested parties can result in substantial energy efficiency improvements. 

DOE intends to analyze the likely impacts of non-regulatory initiatives on national energy 

savings. DOE intends to base its assessment on the actual impacts of any such initiatives to date, 

but also will consider information presented on the impacts that any existing initiative might 

have in the future.

DOE will prepare and submit to OMB the assessment of costs and benefits required 

under section 6(a)(3) of Executive Order 12866, “Regulatory Planning and Review,” 58 FR 

51735 (Oct. 4, 1993).
53

APPENDIX A – LIST OF ITEMS FOR COMMENT

This appendix lists all the items for comment contained in this framework document, and 

the page numbers on which those items can be found.

Item 1 Although DOE invites comment on all aspects of the material presented in this 

document, several specific issues on which DOE seeks comment are set out in 

comment boxes like this one. DOE uses these comment boxes to highlight issues and 

ask specific questions regarding the approaches DOE plans to follow to conduct the 

analyses required for the energy conservation standards rulemaking. Such requests for 

feedback are numbered sequentially throughout the document and are repeated in 

appendix A.................................................................................................................... 1

Item 2 DOE welcomes comments on how it should coordinate development of the final rules 

for HID lamps and metal halide lamp fixtures.............................................................. 3

Item 3 DOE welcomes comment on whether electrodeless HID lamps (also referred to as 

light-emitting plasma) are a subcategory of MV, HPS, or MH lamps. ...................... 13

Item 4 DOE welcomes comments on its decision to define the scope of coverage using rated 

wattage instead of lumen output and the range of wattages included in coverage. .... 13

Item 5 DOE welcomes comments on its decision to exclude HID lamps designed and labeled 

for use with electronic ballasts only, directional HID lamps, self-ballasted HID lamps, 

and high CCT lamps from the scope of coverage. DOE also requests comments on the 

unique characteristics of colored HID lamps.............................................................. 13

Item 6 DOE welcomes comments on whether lamps for specialty applications have defining 

characteristics that differentiate them from lamps used for general illumination 

purposes. In addition, DOE welcomes comments on whether specialty applications 

relevant to MV technology can also be served by HPS or MH technology. .............. 13

Item 7 DOE welcomes comment on any additional lamps that should be excluded from the 

scope of coverage.DOE welcomes comments on the tentative decision to not include 

standby and off modes in the energy conservation standard. ..................................... 13

Item 8 DOE welcomes additional comments related to the test procedure. .......................... 15

Item 9 DOE requests information related to NEMA Standard LSD-26. ............................... 15

Item 10 DOE seeks comment related to NVLAP accredited testing facilities......................... 15

Item 11 DOE seeks comment on the sample size proposed in the HID lamps test procedures 

and whether sample sizes in other standards would be more appropriate. ................. 15

Item 12 DOE seeks comment on the tolerance values proposed in the HID lamps test 

procedures and whether tolerance values in other standards would be more 

appropriate. ................................................................................................................. 15

Item 13 DOE welcomes comments related to the appropriateness of lamp efficacy as one of 

the potential metrics in HID lamp energy conservation standards. ............................ 17

Item 14 DOE welcomes comments on developing a center-beam intensity metric related to 

directional lamps. DOE requests information on other possible metrics in 

development or other metrics that DOE should consider, including beam lumens per 

watt. DOE requests comments on the appropriate definition of beam angle.............. 17

Item 15 DOE welcomes input on disaggregated market share and shipment data based on 

input wattage for each HID lamp technology............................................................. 20

Item 16 DOE welcomes comments on the proposed equipment classes for HID lamps and 

additional approaches to defining classes in accordance with the requirements of 42 
54

U.S.C. 6295(q). Specifically, DOE seeks input on its proposal to establish equipment 

classes based on lumen output (rather than rated wattage) and CCT, and the 

appropriateness of the lumen output and CCT ranges selected. ................................. 23

Item 17 DOE seeks comment on whether the proposed equipment classes should be further 

subdivided by lamp orientation (also known as operating or burn position and 

typically includes vertical, horizontal, universal) or by other lamp characteristics 

(e.g., enclosed or open fixture rating, CRI, base type, coated or clear envelope). DOE 

also seeks comment on whether equipment classes should be separated based on lamp 

technology................................................................................................................... 23

Item 18 DOE welcomes comments on the preliminary technology options identified in this 

section, and on whether there are additional technology options it should consider.. 25

Item 19 DOE welcomes comments on how the above four screening criteria might apply to 

technology options under consideration by DOE, and how the screening criteria apply 

to any additional technology option(s) that an interested party recommends to DOE.

..................................................................................................................................... 26

Item 20 DOE welcomes comments on the selection of representative equipment classes for 

HID lamps................................................................................................................... 27

Item 21 DOE welcomes comments on the selection of baseline models for the proposed 

representative equipment classes. ............................................................................... 28

Item 22 DOE welcomes comments on more efficacious (and equal lumen output) substitutes 

for each proposed baseline model, up to and including the max tech lamp that would 

result in reduced energy consumption. ....................................................................... 29

Item 23 DOE welcomes comment on the current and future availability of reduced wattage 

lamps and the practicality of reducing and respacing fixtures. DOE also invites 

comment on whether barriers exist to developing new lamps that would provide 

reduced wattage alternatives to today’s lamps............................................................ 29

Item 24 DOE welcomes comments on the use of an equation-based versus binned efficacy 

level approach for HID lamps..................................................................................... 30

Item 25 DOE welcomes input on whether highly efficacious lighting systems could be 

eliminated given a particular lamp efficacy requirement. .......................................... 30

Item 26 DOE welcomes comments on its proposed approach to scale from representative 

equipment classes to classes not directly analyzed in the engineering analysis......... 30

Item 27 DOE seeks comment on its end-user price approach for calculating the cost-efficacy 

relationship for HID lamps. In particular, DOE seeks comment on typical distribution 

channels for HID lamps, as well as the allocation of market share between these 

channels....................................................................................................................... 31

Item 28 DOE seeks information regarding the existence of relevant proprietary designs for the 

HID lamps under consideration in this rulemaking. DOE also seeks comment on 

whether these proprietary designs are the only pathway to increase lamp efficacy. .. 31

Item 29 DOE welcomes comments on regulatory burdens and changes directly or indirectly 

related to HID lamps that should be considered in the engineering analysis. ............ 31

Item 30 DOE welcomes comments on other engineering issues that could affect the 

engineering analysis.................................................................................................... 31

Item 31 DOE welcomes comments on whether median system input power is appropriate for 

characterizing lamp energy use................................................................................... 33
55

Item 32 DOE welcomes comments on its proposed methodology to determine annual 

operating hours for covered HID lamps in the commercial and industrial sectors, and 

how operating hours may vary by lamp type and application. ................................... 33

Item 33 DOE welcomes suggestions and comments concerning its proposed approach for 

estimating consumer prices for HID lamps, ballasts, and fixtures. ............................ 34

Item 34 DOE welcomes comments on typical manufacturer, wholesaler, and contractor 

markups associated with HID lamps, ballasts, and fixtures........................................ 34

Item 35 DOE welcomes input on its proposed approach for estimating electricity prices in this 

analysis........................................................................................................................ 37

Item 36 DOE welcomes input on the planned approaches for estimating discount rates for 

consumers of the HID lamps covered under this rulemaking..................................... 37

Item 37 DOE welcomes comments on how to estimate installation costs for HID lamps. DOE 

specifically seeks comment on the availability and value of sources other than 

RSMeans Electrical Cost Data to consider in estimating installation costs................ 38

Item 38 DOE welcomes comments on whether relamping practices (i.e., group or spot 

relamping) would change if HID lamp life is affected by new energy conservation 

standards. .................................................................................................................... 38

Item 39 DOE welcomes comments on whether maintenance or repair costs for HID lamps, 

ballasts or fixtures should be considered in this analysis. .......................................... 38

Item 40 DOE welcomes comments on appropriate lifetimes for the HID lamps covered in this 

rulemaking, and how lamp life should be adjusted to reflect group relamping 

practices by lamp type and sector. .............................................................................. 39

Item 41 DOE welcomes recommendations on sources of data for shipments of HID lamps by 

proposed equipment class. In addition, DOE welcomes comments on future long-term 

trends in HID lamp efficacy (e.g., market share of probe-start quartz MH versus 

pulse-start quartz and/or pulse-start ceramic MH) for the baseline shipments forecast.

..................................................................................................................................... 39

Item 42 DOE welcomes comments on the accounting methodology described above for each 

type of HID lamp covered in this rulemaking. ........................................................... 40

Item 43 DOE welcomes comments on how proposed energy conservation standards might 

affect shipments of HID lamps. DOE also requests information on the HID lamp 

impact of existing market-pull programs, such as consumer rebate programs, to 

promote the adoption of more efficacious lamps........................................................ 41

Item 44 DOE welcomes comments on the proposed data, factor and forecast sources it 

anticipates using to develop inputs for the national impact analysis.......................... 42

Item 45 DOE welcomes comments as to whether more efficacious HID lamp designs would 

be operated more as a result of their increased efficacy (i.e., whether a positive 

rebound effect would be expected for this equipment) and if so how much longer 

would they be operated. .............................................................................................. 42

Item 46 DOE welcomes comments from interested parties on the NES spreadsheet models it 

plans to use for estimating national effects of new energy conservation standards for 

HID lamps................................................................................................................... 43

Item 47 DOE welcomes comments from interested parties on which, if any, consumer 

subgroups should be considered when developing standards for HID lamps. ........... 44

Item 48 DOE seeks comments on the subgroups of HID lamp manufacturers that it should 

consider in a manufacturer subgroup analysis. ........................................................... 46
56

Item 49 DOE welcomes comments on other regulations or pending regulations it should 

consider in its examination of cumulative regulatory burden..................................... 47

Item 50 DOE seeks input on its plans to use NEMS-BT to conduct the utility impact analysis 

on the equipment covered under this rulemaking....................................................... 47

Item 51 DOE requests feedback on its approach to assessing employment impacts on the 

equipment covered under this rulemaking.................................................................. 48

Item 52 DOE seeks input on its plans to use NEMS-BT to conduct the environmental 

assessment for the equipment covered by this rulemaking......................................... 50