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CHAPTER 1. INTRODUCTION 

TABLE OF CONTENTS 

1.1 PURPOSE OF THE DOCUMENT ................................................................................. 1-1

1.2 OVERVIEW OF THE APPLIANCES AND COMMERCIAL EQUIPMENT 

STANDARDS PROGRAM ......................................................................................................... 1-1

1.3 OVERVIEW OF HIGH-INTENSITY DISCHARGE LAMP STANDARDS ................ 1-2

1.4 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS ................... 1-3

1.5 STRUCTURE OF THE DOCUMENT ............................................................................ 1-5

LIST OF TABLES 

Table 1.4.1 Analyses Under the Process Rule ............................................................................. 1-4
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CHAPTER 1. INTRODUCTION 

1.1 PURPOSE OF THE DOCUMENT 

This interim technical support document (TSD) provides the analytical approaches, 

inputs, and results associated with the U.S. Department of Energy’s (DOE’s) study of energy 

conservation standards for high-intensity discharge (HID) lamps. The interim TSD also serves to 

provide technical detail and is a compendium to the life-cycle cost (LCC) and payback period 

(PBP) and national impact analysis (NIA) spreadsheets that are posted on the DOE’s website for 

the interim analysis.a

1.2 OVERVIEW OF THE APPLIANCES AND COMMERCIAL EQUIPMENT 

STANDARDS PROGRAM 

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 interim analysis.b Before DOE 

determines whether to adopt a proposed energy conservation standard, it first solicits comments 

on the proposed standard. DOE designs any new or amended standard to achieve the maximum 

improvement in energy efficiency that is technologically feasible and economically justified. (42 

U.S.C. 6295(o)(2)(A)) To determine whether economic justification exists, DOE must review 

comments on the proposal and determine that the benefits of the proposed standard exceed its 

burdens to the greatest extent practicable, weighing the following seven factors: 

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

equipment subject to the standard; 

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

equipment compared to any increases in the price, initial charges, or maintenance 

expenses for the equipment that are likely to result from the imposition of the 

standard; 

(3) the total projected amount of energy savings likely to result directly from 

imposition of the standard; 

(4) any lessening of the utility or the performance of the equipment likely to result from 

imposition of the standard; 

(5) the impact of any lessening of competition, as determined in writing by the 

Attorney General, likely to result from imposition of the standard; 

 

a

 The interim analysis can be found here: 

http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23. 

b

 For editorial reasons, upon codification in the U.S. Code, Part C was re-designated Part A-1.
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(6) the need for national energy conservation; and 

(7) other factors the Secretary considers relevant. 

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

1.3 OVERVIEW OF HIGH-INTENSITY DISCHARGE LAMP STANDARDS 

As mentioned in the previous section, Title III, Part C of 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 interim analysis. 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)) 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 determinationcthat 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.d On February 28, 2012, DOE 

published a notice announcing the availability of the framework document, “Framework 

Document for High-Intensity Discharge Lamps,” and a public meeting to discuss the proposed 

analytical framework for the rulemaking. 77 FR 11785. DOE also posted the framework 

document on its website describing the procedural and analytical approaches DOE anticipated 

using to evaluate the establishment of energy conservation standards for HID lamps. 

DOE held the public meeting for the framework document on March 29, 2012,eto 

describe the various rulemaking analyses DOE would conduct, the methods for conducting them, 

and the relationship among the various analyses. This interim TSD provides the analytical 

approaches, inputs, and results for those analyses. 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)) 

 

c

 The 2010 HID lamps final determination is available at: 

www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23. 

d

DOE published a proposed test procedure NOPR on December 15, 2011. (76 FR 77914) Based on comments 

received on the test procedure NOPR and subsequent additional research, DOE is considering a supplemental notice 

of proposed rulemaking regarding potential revisions to and clarification of the proposed HID lamp test procedures.

e

 The framework document and public meeting information are available at: 

www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23. 
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This rulemaking also addresses 42 U.S.C. 6295(o) in which DOE is directed to incorporate 

standby mode and off mode energy use in any new or amended standard adopted after July 1, 

2010. Please see chapter 2 of this interim TSD for a detailed discussion on DOE’s consideration 

of standby and off mode energy consumption.

1.4 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS 

DOE considers stakeholder participation a very important part of the standards-setting 

process. DOE encourages the participation of all stakeholders during the comment period of each 

rulemaking stage. Beginning with the rulemaking framework document for HID lamps (hereafter 

the “framework document”) and during subsequent comment periods, interactions among 

stakeholders provide a balanced discussion of the information that is required for the standards 

rulemaking. 

In conducting the test procedure and the energy conservation standard rulemakings, DOE 

involves interested parties through formal public notifications (i.e., Federal Register notices). 

For this HID lamp energy conservation standards rulemaking, DOE will employ the procedures 

set forth in DOE’s Process Rule (Procedures for Consideration of New or Revised Energy 

Conservation Standards for Consumer Products, 61 FR 36974, July 15, 1996, 10 CFR Part 430, 

Subpart C, Appendix A) to the extent they are appropriate for developing energy conservation 

standards for the lamps covered under this rulemaking. 

Before DOE determines whether to establish energy conservation standards for HID 

lamps, it must first solicit comments on a proposed standard. (42 U.S.C. 6295(o)(2)(B)(i)) DOE 

must design each new standard for this equipment to achieve the maximum improvement in 

energy efficiency that is technologically feasible and economically justified, and would result in 

significant energy savings. (42 U.S.C. 6295(o)(2)(A) and (3)) To determine whether a proposed 

standard complies with these requirements, DOE must, after receiving comments on the 

proposed standard, determine whether the benefits of the standard exceed its burdens to the 

greatest extent practicable, weighing the seven factors described above. 

Subsequent to the publication of the framework document, the standards rulemaking 

process involves interim analyses followed by two additional formal, major public notices, which 

are published in the Federal Register. The interim analyses are designed to publicly vet the 

models and tools used in the rulemaking and to facilitate public participation before the proposed 

rule stage. After the interim analyses are vetted, DOE issues the first major notice, the notice of 

proposed rulemaking (NOPR), which presents a discussion of comments received in response to 

the framework document and the interim analyses of the impacts of standards on customers, 

manufacturers, and the nation; DOE’s weighing of the impacts; and the proposed standards. The 

second notice is the final rule, which presents a discussion of comments received in response to 

the NOPR; the revised analysis of the impacts of standards; DOE’s weighing of the impacts; the 

standards adopted by DOE; and the effective dates of the standards. 
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Table 1.4.1 Analyses Under the Process Rule 

Interim Analysis NOPR Final Rule*

Market and technology assessment Revised interim analyses Revised analyses

Screening analysis Life-cycle cost sub-group analysis

Engineering analysis Manufacturer impact analysis

Energy use characterization Utility impact analysis

Markup analysis Employment impact analysis

Equipment price determination Emissions analysis

Life-cycle cost and payback period analysis Monetization of Emissions

Shipments analysis Regulatory impact analysis

National impact analysis

Interim manufacturer impact analysis

* During the final rule phase, DOE considers the comments submitted by the U.S. Department of Justice concerning 

the impact of any lessening of competition that is likely to result from the imposition of the standard. (42 U.S.C. 

6295(o)(2)(B)(v))

As previously mentioned, on February 28, 2012, DOE published a notice announcing the 

availability of the framework document and a public meeting to discuss the proposed analytical 

framework for the rulemaking. 77 FR 11785. DOE also posted the framework document on its 

website here: 

www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23. 

DOE held a public meeting on March 29, 2012, to discuss procedural and analytical 

approaches to the rulemaking, and to inform and facilitate stakeholders’ involvement in the 

rulemaking process. The analytical framework presented at the public meeting described 

rulemaking analyses, such as the engineering analysis and the LCC and PBP analysis, the 

methods proposed for conducting them, and the relationships among the various analyses. See 

Table 1.4.1 for all the analyses discussed at the public meeting to be undertaken in each of the 

formal public rulemaking documents. PDF copies of the slides and other material associated with 

the public meeting are available at: 

www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23.

During the public meeting and the framework document comment period, stakeholders, 

including manufacturers, trade associations, environmental advocates, and other interested 

parties submitted several comments about the HID lamp rulemaking. The major issues discussed 

were: scope of coverage, metric, equipment classes, efficacy level approach, and shipment 

trends. Stakeholder comments submitted during the framework document comment period 

elaborated upon the issues raised at the public meeting. DOE considered all comments for this 

interim analysis and a detailed discussion of interested party comments will be included in the 

NOPR. 

As part of the information gathering and sharing process, DOE organized and held 

interviews with HID lamp manufacturers who operate in the U.S. market. DOE had five 

objectives for these interviews: (1) solicit feedback on the scope of coverage for the rulemaking; 

(2) solicit feedback on the engineering analysis; (3) solicit feedback on topics related to the 
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interim manufacturer impact analysis; (4) provide an opportunity early in the rulemaking process 

to express specific concerns to DOE; and (5) foster cooperation between manufacturers and 

DOE. During the manufacturer interviews, DOE discussed these and other issues regarding 

market data, distribution channels, anticipated customer responses to standards, production and 

equipment mix, conversion costs, and cumulative regulatory burden. Appendix 13A contains a 

complete copy of the interview guide. 

DOE incorporated the information gathered at the meetings into its engineering analysis 

(chapter 5), equipment price determination (chapter 6), and the interim manufacturer impact 

analysis (chapter 13). Following the publication of the interim analysis, DOE intends to hold 

additional meetings with manufacturers as part of the consultative process for the manufacturer 

impact analysis conducted during the NOPR phase. 

For the LCC, PBP, and NIA, DOE developed spreadsheets using Microsoft Excel®. The 

LCC and PBP spreadsheets calculate the economic impacts of replacing HID lamps with 

standard-compliant ones. The NIA spreadsheets calculate the national energy savings (NES) and 

national net present values (NPVs) at various efficacy levels and include a model that forecasts 

the impacts of energy conservation standards at various levels on equipment shipments. These 

spreadsheets are available on the DOE website at: 

www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23.

1.5 STRUCTURE OF THE DOCUMENT 

This interim TSD outlines the analytical approaches used in this rulemaking. The TSD 

consists of 18 chapters and four appendices. 

Chapter 1 Introduction: provides an overview of the appliance standards program 

and how it applies to the rulemaking for HID lamps, and outlines the 

structure of the document 

Chapter 2 Analytical Framework: describes the rulemaking process, and provides 

an overview of each analysis including rationale for preliminary 

determinations 

Chapter 3 Market and Technology Assessment: characterizes the HID lamp 

market and the technologies available for increasing efficacy, and 

outlines equipment classes 

Chapter 4 Screening Analysis: determines which technology design options are 

viable for consideration in the engineering analysis 

Chapter 5 Engineering Analysis: describes DOE’s approach to the engineering 

analysis, and established candidate standard levels based on lamp 

efficacy 

Chapter 6 Equipment Price Determination: describes DOE’s approach to 

determining the end-user prices for HID lamps 
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Chapter 7 Markups Analysis: discusses the methods DOE used for deriving 

manufacturer selling prices from end-user prices using manufacturerto-customer markups 

Chapter 8 Energy Use Characterization: discusses the sources and methods for 

developing energy use estimates for HID lamps 

Chapter 9 LCC and PBP Analyses: discusses the economic effects of standards 

and compares the LCC and PBP of HID lamps with and without higher 

energy conservation standards 

Chapter 10 Shipments Analysis: discusses the methods used for forecasting 

shipments with and without higher energy conservation standards 

Chapter 11 National Impact Analysis: describes the national forecast of energy 

consumption, efficacy of new lamps, and annual HID lamp sales in the 

absence or presence of new standards 

Chapter 12 Customer Sub-Group Analysis: discusses the methods to be used to 

study the effects of standards on a sub-group of HID lamp customers 

and compares the LCC and PBP of equipment with and without higher 

efficacy standards for these customers 

Chapter 13 Manufacturer Impact Analysis: discusses the methods to be used to 

study the effects of standards on the finances and profitability of HID 

lamp manufacturers, and presents interim manufacturer impact 

analysis results 

Chapter 14 Employment Impact Analysis: discusses the methods to be used to 

analyze the effects of standards on national employment 

Chapter 15 Utility Impact Analysis: discusses the methods to be used to study the 

effects of standards on electric utilities 

Chapter 16 Emissions Analysis: discusses the methods to be used to study the 

effects of standards on two pollutants, sulfur dioxide (SO2) and 

nitrogen oxides (NOx), as well as carbon emissions 

Chapter 17 Monetization of Emission Reductions Benefits: discusses the basis for 

the monetary values that will be used for the reduced emissions carbon 

dioxide (CO2) and nitrogen oxides (NOX) 

Chapter 18 Regulatory Impact Analysis: discusses the methods to be used to 

determine the impact of non-regulatory alternatives to energy 

conservation standards 
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Appendix 6A HID Ballast and Fixture Equipment Price Determination: describes the 

method used to determine the end-user prices for HID ballasts and 

fixtures 

Appendix 9A User Instructions for Life-Cycle Cost and Payback Period Spreadsheet 

Appendix 9B Estimation of Potential Equipment Price Trends for High-Intensity 

Discharge Lamps: describes the method used for estimating price 

trends 

Appendix 11A User Instructions for Shipments and NIA Spreadsheet 

Appendix 13A Interim Manufacturer Interview Guide 

Appendix 17A Social Cost of Carbon for Regulatory Impact Analysis Under 

Executive Order 12866