1 | Building Technologies Program eere.energy.gov

The Parker Ranch installation in Hawaii

APPLIANCE STANDARDS PROGRAM

Energy Conservation Standards 

Preliminary Analysis

for Metal Halide Lamp Fixtures

Tina Kaarsberg, PhD

Department of Energy 

Energy Efficiency and Renewable Energy

MHLF-2009-STD-0018@ee.doe.gov

April 18, 2011

Source: Lithonia Lighting

Canopy

Roadway

Parking Garage Downlight High Bay

Spotlight

Low Bay

Area

Wall-Pack Floodlight Post-Top

Bollard
2 | Building Technologies Program eere.energy.gov

• Introductions

• Role of the Facilitator

• Ground Rules (norms)

- Listen as an ally

- Use short, succinct statements/keep to the point

- Hold sidebar conversations outside the room

- One person speaks at a time (raise hand to be recognized; state 

your name for the record)

- Set cell phones, etc. to silent/vibrate

• Housekeeping Items

• Agenda Review

• Opening Remarks

Welcome
3 | Building Technologies Program eere.energy.gov

9:00 – 9:10 am Welcome, Introductions, Opening Statements

9:10 – 10:15 am Overview, Statute, Context, Market and Technology 

Assessment, Screening Analysis

10:15 – 10:30 am Break

10:30 – 11:15 am Engineering Analysis

11:15 – 11:40 am Energy Use, Markup Analysis

11:40 am – 12:30 pm Lunch

12:30 – 1:30 pm Life-Cycle Cost and Payback Period Analysis, Shipments, 

National Impact Analysis

1:30 – 1:40 pm Preliminary Manufacturer Impact Analysis

1:40 – 1:50 pm NOPR Analyses

1:50 – 2:00 pm Closing Remarks and Adjourn

Public Meeting Agenda
4 | Building Technologies Program eere.energy.gov

1. Present DOE’s proposed energy conservation standard 

preliminary analysis

2. Seek comment from participants on the standard analysis

3. Discuss the next steps for the rulemaking

Purpose of Public Meeting

Workshop participants are invited to provide summary 

comments or statements at this time. 
5 | Building Technologies Program eere.energy.gov

Issue for Discussion

Issue Box: DOE welcomes comments, data, and information 

concerning its standards preliminary analysis for metal halide 

lamp fixtures (MHLFs). Issues that correspond to those raised 

in DOE’s published material will be numbered in accordance 

with that material. This presentation also includes some new 

issues not specifically mentioned in the published material, 

and those have been labeled as such. Whether invited by an 

issue box or not, comments are welcome on any part of DOE’s 

analysis.

www1.eere.energy.gov/buildings/appliance_standards/commercial/pdfs/mhlf_pa_tsd_exec_summary.pdf

Issue box numbering corresponds to the Technical Support 

Document’s Executive Summary (ES), available at:
6 | Building Technologies Program eere.energy.gov

In all correspondence, include all of the following:

– Energy Conservation Standards for Metal Halide Lamp Fixtures

– Docket Number EERE-2009–BT–STD–0018

– Regulatory Identification Number (RIN) 1904–AC00

Email: MHLF-2009-STD-0018@ee.doe.gov

Comment period closes: Monday, 16 May 2011

DOE Seeks Comments on its Proposal

Postal Mail: 

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program

Mailstop EE-2J

1000 Independence Avenue, S.W.

Washington, DC 20585-0121

Courier: 

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program

950 L’Enfant Plaza, S.W., 6th Floor

Washington, DC 20024 

Telephone: (202) 586-2945

Submission of Comments
7 | Building Technologies Program eere.energy.gov

Energy Use; Markup Analysis

Life-Cycle Cost And Payback Period Analysis

National Impact Analysis

Preliminary MIA

Presentation Overview

4

5

6

7

2 Market & Tech; Screening Analysis

3 Engineering Analysis

1 Overview, Statute, and Context

8

9

NOPR Analyses

Final Questions / Discussion
8 | Building Technologies Program eere.energy.gov

Regulatory History

Energy Policy and Conservation Act (EPCA) of 1975

• Established energy conservation standards and test procedures 

for certain commercial equipment.

Energy Independence and Security Act (EISA) of 2007 

• Prescribed standards for MHLFs by requiring that they contain 

ballasts meeting defined efficiency levels.

• Directed DOE to develop a test procedure for ballasts in MHLFs 

based on ANSI C82.6-2005.

• Directed DOE to incorporate standby and off mode in this 

standards rulemaking.

• Directed DOE to amend standards for MHLFs, publish a final 

rule by January 1, 2012, and publish a revision to that rule by 

January 1, 2019.
9 | Building Technologies Program eere.energy.gov

Metal Halide Lamp Fixtures 

Rulemaking Schedule

Milestone Date

Framework Document Published December 30, 2009

Federal Register Notice of Public Meeting and Availability of 

the Preliminary Technical Support Document April 2011

Issue Final Rule (Scheduled) January 2012

Effective Date (Estimated) January 2015

2008 2009 2010 2011 2012 2013 2014 2015 2016
10 | Building Technologies Program eere.energy.gov

Energy Use; Markup Analysis

Life-Cycle Cost And Payback Period Analysis

National Impact Analysis

Preliminary MIA

Presentation Overview

4

5

6

7

1 Overview, Statute, and Context

3 Engineering Analysis

2 Market & Tech; Screening Analysis

8

9

NOPR Analyses

Final Questions / Discussion
11 | Building Technologies Program eere.energy.gov

Framework

Document

Preliminary

Analysis

NOPR Final

Rule

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use & 

End Use Load

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for

Equipment

Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis

Preliminary Analysis

Rulemaking Stage
12 | Building Technologies Program eere.energy.gov

Metal Halide Lamp Fixture Definition

• EISA 2007 defines metal halide (MH) lamp fixtures:

– “Metal Halide Lamp Fixture. The term ‘metal halide lamp fixture’ means a 

light fixture for general lighting application designed to be operated with a 

metal halide lamp and a ballast for a metal halide lamp.” (42 U.S.C. 

6291(64))

• EISA 2007 established ballast efficiency standards for certain metal 

halide fixtures.

Lamp

Ballast

Housing
13 | Building Technologies Program eere.energy.gov

Current Scope of Coverage

Minimum Ballast 

Efficiency

Wattage Range

Ballast Type

Currently Regulated Metal Halide Lamp 

Fixtures as per EISA 2007

PulseStart

150 ≤ W ≤ 

500

88%

Magnetic 

ProbeStart

150 ≤ W ≤ 

500

94%

Non-Pulse-Start 

Electronic

150 ≤ W ≤ 

250

90%

250 < W 

≤ 500

92%

42 U.S.C. 6295(hh)(1)(A)

(Regulated lag, 480V electronic, and certain 150W fixtures exempted)
14 | Building Technologies Program eere.energy.gov

Expansion of Scope 

• Expansion of scope considered:

– Include MHLFs that operate lamps rated from 50 to 50 W and above 

500W.

– Include fixtures rated only for 150 W lamps, wet locations, and 

ambient air temperatures higher than 50 °C, currently excluded from 

EISA standards.

• DOE has no current plans to cover fixtures that use regulated lag 

ballasts and fixtures that use electronic ballasts that operate at 480 V.

Issue ES4: DOE invites comment on its proposed scope of coverage.
15 | Building Technologies Program eere.energy.gov

• DOE published a test procedure final rule on March 9, 2010 

based on ANSI C82.6-2005 (10 CFR part 431.324). This rule 

had no provisions for testing high-frequency ballasts.

• Manufacturers have suggested using an updated version of 

ANSI C82.6 once available.

• Current test procedure is nonspecific regarding the input 

voltage for efficiency testing.

– Most ballasts can operate at multiple input voltages.

– DOE is consider amending the test procedure to require testing 

at all input voltages and reporting an average of the results.

Test Procedures
16 | Building Technologies Program eere.energy.gov

• EISA directs DOE to amend test procedures to include standby and 

off mode energy consumption (42 U.S.C. 6295(gg)(3)(A)).

• In theory, metal halide ballasts can be designed with auxiliary control 

devices, which could consume energy in standby mode.

• “DALI” interface used in fluorescent, for example, but DOE hasn’t 

observed that metal halide lighting

• Furthermore, DOE believes that off mode is not relevant to metal 

halide lamp fixtures.

• DOE tentatively concluded that it cannot establish a standard that 

incorporates a standby mode or an off mode energy use.

Standby and Off Mode Operation
17 | Building Technologies Program eere.energy.gov

Issues for Discussion

Issue ES2: DOE requests comment on whether it should amend its 

current test procedure for metal halide lamp ballasts to include 

specification of voltage when testing for efficiency. Of particular 

interest is whether efficiency is affected by the voltage or the number 

of operating voltages. 

DOE also seeks comment on any other appropriate changes to the 

current test procedure for metal halide lamp ballasts, based on 

findings from its preliminary analysis for metal halide lamp fixtures.

Issue ES1: DOE requests comment on expected updates to ANSI 

C82.6-2005 and on the status of the revised version of the document.

Issue ES3: DOE invites comments on the issues of standby mode 

and off mode.
18 | Building Technologies Program eere.energy.gov

• Although MHLFs may be composed of a lamp, ballast, and 

other fixture components, EISA 2007 set minimum efficiency 

requirements for the ballast only.

• DOE is considering whether amended standards could 

address the ballast only, the ballast and the lamp, or the 

ballast, lamp, and remaining, optical portion of the fixture.

• A lamp/ballast metric would have the advantage of allowing 

manufacturers to pursue efficacy gains wherever they were 

most economical.

• A fixture metric could have the benefit of encouraging fixtures 

that distributed light more effectively.

System Approaches
19 | Building Technologies Program eere.energy.gov

Lamp-Ballast System Approach

• Metric given in terms of lamp lumens and ballast input watts.

• Potential Benefits

– Provides design flexibility to pursue most economical gains.

– Some of the highest efficacy lamps may not be compatible with all 

ballast types.

• Potential Drawbacks

– Many fixtures are shipped without lamps, and DOE would need to 

specify how to assess compliance in those cases – possibly a table 

of standard lamps.

– Ongoing high-intensity discharge (HID) lamp rulemaking could 

present possible conflicts.
20 | Building Technologies Program eere.energy.gov

Issue for Discussion

Issue ES5: DOE invites comment on:

(1) the specific lamp efficacy values that could be included in a 

table of standard lamps; 

(2) examples of systems that could benefit from this approach; 

(3) the manufacturer impacts and feasibility of a lamp-ballast 

system standard in addition to a lamp-specific standard that 

could result from the ongoing HID lamps rulemaking; and

(4) whether consumers could and would re-lamp fixtures with 

lamps less efficacious than those with which they were sold.
21 | Building Technologies Program eere.energy.gov

• Fixtures can absorb significant amounts of light, and illuminate 

locations unproductive to the application.

• Fixture Efficiency is the ratio of light leaving the fixture to light 

leaving the lamp.

• Fitted Target Efficacy (FTE) evaluates the efficacy with which a 

fixture delivers uniform illumination to a rectangular area.

• Target Efficacy Rating (TER) measures the lumens per watt 

emitted by a fixture that fall on a target area specified by application.

Fixture System Approach

Issue ES7: DOE requests comments on its decision not to use a 

fixture system approach.
22 | Building Technologies Program eere.energy.gov

• DOE may set design standards that prohibit or mandate certain features in a 

type of equipment (42 U.S.C. 6295(hh)(4)). DOE is considering:

• Pulse-Start Requirement

• Controls/Reduced Wattage Requirement

Design Standard

Issue ES22: DOE requests comment on mean lumen differences between pulseand probe-start lamps at 70, 250, 400, and 1000 W, and on any other information 

that would help it assess potential energy savings of prohibiting probe-start. DOE 

also requests comment on a design standard that prohibits probe-start ballasts.

Issue ES6: DOE may consider a federal design standard similar to California’s Title 

20 and requests comments on the feasibility of this action and the expected 

consumer preferences for occupancy sensors, dimming, or reduced wattage lamp 

pairings. DOE also seeks comment on the expected change in lumen output and 

initial efficacy when moving from regular to reduced wattage versions of lamps.

Issue ES10: DOE understands that metal halide lamps are often dimmed using bilevel capacitors in conjunction with relays, motion sensors, or photocells. DOE 

requests comment on the cost of employing these methods to save energy and on 

usage patterns that would allow DOE to estimate the energy they could save.
23 | Building Technologies Program eere.energy.gov

• DOE may establish separate equipment classes and evaluate 

separate standards for those classes.

• DOE divides covered equipment into classes by:

– The type of energy used

– Capacity of the equipment or other performance-related 

features that justify different standard levels, such as 

features affecting consumer utility (42 U.S.C. 6295(q))

• EISA 2007 set standards for MHLFs by:

– Rated lamp wattage

– Ballast type

– Pulse

– Magnetic Probe

– Non-pulse-start Electronic

Potential Equipment Classes
24 | Building Technologies Program eere.energy.gov

• DOE examined characteristics or features commonly found in 

commercially available equipment.

• DOE examined the following six possible characteristics that 

could warrant separation into different equipment classes:

Potential Equipment Classes

Affects Utility and 

Ballast Efficiency

• Wattage

Does Not Affect Utility 

and Ballast Efficiency

• Input Voltage

• Number of Lamps per 

Ballast

• Starting Method

• Electronic Configuration 

and Circuit Type

• Fixture Environment
25 | Building Technologies Program eere.energy.gov

• Most ballasts can operate at different input voltages.

• DOE identified no prevailing relationship between efficiency and input 

voltage (e.g., higher voltages are not always more efficient).

• DOE preliminarily decided to include all voltages in a single class.

• One possible exception may be 480 V ballasts, which DOE tested to be 

slightly less efficient.

• Commenters at the framework meeting suggested separate classes for 

ballasts above and below 300 input volts.

Equipment Classes: Input Voltage

Issue ES12: DOE is interested in information about efficiency variation with 

voltage, and whether DOE’s testing is representative of the market. DOE 

also seeks comment on whether it would be appropriate to establish a 

separate equipment class for ballasts operating above 300 V and, if so, 

why quint-input-voltage ballasts should belong in one class or the other.
26 | Building Technologies Program eere.energy.gov

• Different applications require different light output (lamp wattage), 

impacting consumer utility.

• Ballast efficiency tends to increase with higher lamp wattages.

• DOE preliminarily decided to set classes by rated lamp wattage.

Equipment Classes: Wattage

Rated Lamp Wattage Equipment Class

≥ 50 W and < 150 W 1

≥ 150 W and ≤ 250 W 2

> 250 W and ≤ 500 W 3

> 500 W 4

Issues ES11, ES13-15: DOE seeks comment on the outlined MHLF 

equipment classes, and on the different features of fixtures that may 

affect efficiency and utility including, but not limited to, wattage, 

voltage, number of lamps per ballast, electronic configuration and 

circuit types, starting method, and features related to application.
27 | Building Technologies Program eere.energy.gov

Ballast Technology Options

The following technology options can improve ballast efficiency:

Ballast Type Technology Option

Magnetic

Improved Core Steel

Copper Wiring

Increased Stack Height

Increased Conductor CrossSection

Electronic Ballast

Ballast Type Technology Option

Electronic

Improved

Components

Magnetics

Diodes

Capacitors

Transistors

Improved 

Circuit Design

Integrated 

Circuits

Issue ES8: DOE requests information on the feasibility, performance 

improvement, and cost of the technology options, as well as any recent 

developments in their technical maturity.
28 | Building Technologies Program eere.energy.gov

• Technology options are screened using the following 

criteria:

– Technological feasibility

– Practicability to manufacture, install, and service

– Adverse impacts on product utility or availability to 

customers

– Adverse impacts on health or safety

• Amorphous steels are not currently used in metal halide 

ballasts but are available in other products.

• DOE did not screen out any technology options.

Screening Analysis

Issue ES16: DOE invites comment on whether amorphous 

steels, and electrical components more efficient than those 

currently used in ballasts, are technologically feasible and 

practicable to manufacture.
29 | Building Technologies Program eere.energy.gov

Energy Use; Markup Analysis

Life-Cycle Cost And Payback Period Analysis

National Impact Analysis

Preliminary MIA

Presentation Overview

4

5

6

7

1 Overview, Statute, and Context

2 Market & Tech; Screening Analysis

3 Engineering Analysis

8

9

NOPR Analyses

Final Questions / Discussion
30 | Building Technologies Program eere.energy.gov

Framework

Document

Preliminary

Analysis

NOPR Final

Rule

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use & 

End Use Load

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for

Equipment

Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis

Preliminary Analysis

Rulemaking Stage
31 | Building Technologies Program eere.energy.gov

 Choose representative wattages and fixtures to be 

analyzed in the engineering and life-cycle cost analyses. 

 Define characteristics of models in each equipment class 

which will serve as reference points to assess changes due 

to energy conservation standards. 

 Identify more efficient substitutes from a database of 

commercially available metal halide lamp ballasts.

 Develop candidate standard levels (CSLs) that span the 

range of efficiency from the baseline to the maximum 

technologically feasible. 

 Determine manufacturer selling price for baseline ballasts 

and their more efficient substitutes.

Select 

Representative 

Wattages and 

Fixtures

Define Baseline 

Models

Select More 

Efficient 

Substitutes

Develop MSPs

Engineering Analysis:

Methodology

Develop CSLs
32 | Building Technologies Program eere.energy.gov

• For each equipment class, DOE selected the most 

commonly sold wattage as representative.

• DOE also identified several fixture types to serve as 

representative for each wattage.

Representative Wattages & Fixtures

Equipment 

Class

Rated Lamp 

Wattage

Rep. 

Wattage Rep. Fixture Types

1 ≥50 W and 

<150 W 70 W Canopy

2 ≥150 W and 

≤250 W 250 W Low-Bay, Canopy, Wall-Pack

3 >250 W and 

≤500 W 400 W Flood, High-Bay, 

Parking/Area 4 >500 W 1000 W

Select 

Representative 

Wattages and 

Fixtures

Define Baseline 

Models

Select More 

Efficient 

Substitutes

Develop MSPs

Develop CSLs

Issue ES17: DOE requests comment on its selection of 

representative wattages and fixtures.
33 | Building Technologies Program eere.energy.gov

• A baseline model either (1) just meets current 

Federal standards and provides basic consumer 

utility or (2) represents the least efficient commonly 

sold ballast when no standard exists.

• To determine energy savings and changes in price, 

DOE compares each higher efficiency level with the 

baseline unit.

Baseline Models

Representative 

Wattage

Baseline Model Characteristics

Electronic 

Configuration

Circuit 

Type

Ballast 

Efficiency

Current 

Federal

Standard

70 W Magnetic CWA 72.3% (none)

250 W Magnetic CWA 88% 88%

400 W Magnetic CWA 88% 88%

1000 W Magnetic CWA 91.9% (none)

Select 

Representative 

Wattages and 

Fixtures

Define Baseline 

Models

Select More 

Efficient 

Substitutes

Develop MSPs

Develop CSLs
34 | Building Technologies Program eere.energy.gov

• Probe-start systems may be less efficacious than pulse-start 

systems.

• DOE may add a probe-start baseline to the 70 W and 1000 W 

representative wattages.

• Consumers replacing probe-start systems could either use 

fewer pulse systems of the same wattage or the same 

number of reduced-wattage systems.

Adding a Probe-start Baseline

New Issue 1: DOE requests comment on the potential addition 

of a probe-start baseline to the 70 W and 1000 W 

representative wattages.
35 | Building Technologies Program eere.energy.gov

70.0

75.0

80.0

85.0

90.0

95.0

100.0

0 200 400 600 800 1000

Ballast Efficiency (%)

Rated Lamp Wattage (W)

Magnetic

Electronic

• DOE tested ~50 ballasts to identify more efficient 

substitutes.

Tested Ballasts

Select 

Representative 

Wattages and 

Fixtures

Define Baseline 

Models

Select More 

Efficient 

Substitutes

Develop MSPs

Develop CSLs
36 | Building Technologies Program eere.energy.gov

Issues for Discussion

Issue ES21: DOE uses a high frequency electronic ballast as a 

representative unit for CSL4 in the >250 W and ≤500 W class.

DOE requests comment on the appropriateness of using high 

frequency electronic ballasts as representative units, 

particularly with respect to lamp and ballast compatibility 

concerns.

Issue ES23: DOE also requests comment on whether 1000 W 

electronic metal halide ballasts are technologically feasible and 

the potential for this technology to emerge in the future.
37 | Building Technologies Program eere.energy.gov

CSLs: Bins vs. Equation

Issue ES20: DOE has preliminarily chosen to set 

standards using bins for all equipment classes, but 

requests comment on whether any wattage bin would 

require the use of an equation to accurately represent 

the relationship between wattage and efficiency.

Select 

Representative 

Wattages and 

Fixtures

Define Baseline 

Models

Select More 

Efficient 

Substitutes

Develop MSPs

Develop CSLs

Efficiency

Wattage

Hybrid

Efficiency

Wattage

Equation

Efficiency

Wattage

Bins

• DOE considered three approaches for developing 

candidate standard levels.
38 | Building Technologies Program eere.energy.gov

Candidate Standard Levels

Equipment 

Class

Ballast Efficiency

Baseline CSL1 CSL2 CSL3 CSL4

50-150 W 72.3% 76.1% 88.2% 89.5% -150-250 W 88.0% 90.5% 91.5% 93.2% 93.6%

250-500 W 88.0% 90.0% 91.7% 92.7% 93.9%

>500 W 91.9% 92.6% 93.3% -- -Issue ES18: DOE requests comment on the identified CSLs.

Issue ES19: DOE believes that no CSL in this rulemaking requires 

the use of a proprietary technology. DOE requests comment on this 

conclusion.
39 | Building Technologies Program eere.energy.gov

• Manufacturer production costs are made up of 

material and labor costs derived from ballast and 

fixture teardown analyses.

• Two methods of applying markup to ballasts

– Ballast MPC marked up either once or twice 

depending on whether ballast is made by fixture 

manufacturer.

Manufacturer Selling Price

Manufacturer 

Production 

Cost (MPC)

Manufacturer

Markups 

Manufacturer 

= Selling Price

• Direct Material

• Direct Labor

• Factory Overhead

• Depreciation

• Sales & marketing

• Research & 

development

• Interest

• Profit

Select 

Representative 

Wattages and 

Fixtures

Define Baseline 

Models

Select More 

Efficient 

Substitutes

Develop MSPs

Develop CSLs
40 | Building Technologies Program eere.energy.gov

• Electronic ballasts may need modifications to replace magnetic ballasts, 

including transient protection (~$30-70), heat sinks, and 120 V taps.

MPC – Electronic Ballast Additions

Issue ES9: DOE requests comment on electronic ballast thermal issues 

and how to appropriately address heat buildup in fixtures, on specific 

reliability concerns associated with electronic ballasts, and any other 

issues relating to adverse impacts on consumer utility. DOE also seeks 

comment on the cost of inline transient protection, heat sinks and other 

thermal protections, on the addition of a 120 V tap to electronic ballast, 

and on applications in which such measures are needed.
41 | Building Technologies Program eere.energy.gov

Manufacturer Selling Price

Equipment 

Class CSL BallastEfficiency

Ballast 

MPC

Empty Fixture 

Cost Fixture MSP

250-500 W

Baseline 88.0% $24.25 $132.77 $135.71

CSL1 90.0% $32.77 $132.77 $148.24

CSL2 91.7% $38.54 $132.77 $156.72

CSL3 92.7% $63.95 $132.77 $184.63

CSL4 93.9% $77.43 $132.77 $204.44

Issue ES23: DOE requests comment on the maximum technologically 

feasible ballast efficiency and its associated MSP.

Issue ES24: DOE requests comment on its estimates of manufacturer 

production costs (published in Chapter 2 of the Technical Support 

Document), as well as DOE’s estimates of the manufacturer markup.
42 | Building Technologies Program eere.energy.gov

Engineering Analysis

Life-Cycle Cost And Payback Period Analysis

National Impact Analysis

Preliminary MIA

Presentation Overview

3

5

6

7

1 Overview, Statute, and Context

2 Market & Tech; Screening Analysis

4 Energy Use; Markup Analysis

8

9

NOPR Analyses

Final Questions / Discussion
43 | Building Technologies Program eere.energy.gov

Framework

Document

Preliminary 

Analysis NOPR Final

Rule

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use & 

End Use Load

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for

Equipment

Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis

Preliminary Analysis

Rulemaking Stage
44 | Building Technologies Program eere.energy.gov

• Annual energy use (kWh) 

= system input power x annual operating hours

• DOE developed measured input power for representative 

MHLF systems in the engineering analysis

Energy Use Characterization-1

Representative 

Wattage

Ballast Input Power (W)

Baseline CSL1 CSL2 CSL3 CSL4

70 W 96.8 92.0 78.4 76.8

250 W 284 276 273 268 267

400 W 455 444 436 432 426

1000 W 1090 1080 1070
45 | Building Technologies Program eere.energy.gov

• DOE developed annual operating hours with data from 

DOE surveys (LMC, CBECS, MECS)

• DOE’s assumed annual operating hours capture variation 

across census divisions and large States, building types, 

and lighting applications

Energy Use Characterization-2

Sector

Average Annual

Operation

(hrs/yr)

Commercial 3,720

Industrial 4,748

Outdoor Stationary 4,098
46 | Building Technologies Program eere.energy.gov

Energy Use Characterization Results

Representative 

Wattage

Annual Energy Use (kWh)

Baseline CSL1 CSL2 CSL3 CSL4

70 W 389 368 314 306

250 W 1,161 1,129 1,116 1,095 1,091

400 W 1,857 1,816 1,782 1,763 1,741

1000 W 4,578 4,543 4,509
47 | Building Technologies Program eere.energy.gov

Issue for Discussion

Issue ES27: DOE developed annual operating hours by sector using 

data published in the U.S. Lighting Market Characterization: Volume 

I, the Commercial Building Energy Consumption Survey, and the 

Manufacturer Energy Consumption Survey. DOE assumed that all 

fixture equipment classes analyzed could be used in the three 

evaluated sectors (i.e., commercial, industrial, and outdoor 

stationary). DOE welcomes comment on the basis and assignment of 

these end-use operating profiles for the ballast types covered under 

this rulemaking.
48 | Building Technologies Program eere.energy.gov

• DOE developed markups to relate manufacturer selling 

prices (MSP) to end-user fixture prices

• DOE used a fixture distribution channel, MSPs from

the engineering analysis, and company balance sheets 

(SEC form 10-K)

• DOE’s analysis yielded baseline and incremental markups

Markups Analysis
49 | Building Technologies Program eere.energy.gov

Markups Analysis

Distribution Channel Baseline 

Markup

Incremental 

Markup

OEM Fixture Manufacturer --- --Electrical Wholesaler 1.23 1.05

Contractor 1.13 1.13

Sales Tax 1.07 1.07

Weighted Overall Baseline Markup 1.39 ---

Weighted Overall Incremental Markup --- 1.19

• Baseline markups include overhead costs, 

employee benefits, etc.

• Incremental markups capture the additional 

costs companies incur from handling more 

expensive fixtures
50 | Building Technologies Program eere.energy.gov

Issue for Discussion

Issue ES29: In the framework document, DOE solicited 

comment on typical metal halide lamp fixture pricing and 

distributor and contractor markups. Unable to obtain any 

detailed pricing or markup data for the preliminary 

analyses, DOE developed wholesaler markups using 

financial data from U.S. Securities and Exchange 

Commission form 10-K reports for publicly-owned 

companies. DOE seeks comment on typical markups, as 

well as metal halide lamp fixture pricing data that it could 

use to verify the price markups it developed for the 

preliminary analysis.
51 | Building Technologies Program eere.energy.gov

Engineering Analysis

Energy Use; Markup Analysis

National Impact Analysis

Preliminary MIA

Presentation Overview

3

4

6

7

1 Overview, Statute, and Context

2 Market & Tech; Screening Analysis

5 Life-Cycle Cost And Payback Period Analysis

8

9

NOPR Analyses

Final Questions / Discussion
52 | Building Technologies Program eere.energy.gov

Framework

Document

Preliminary 

Analysis NOPR Final

Rule

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use & 

End Use Load

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for

Equipment

Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis

Preliminary Analysis

Rulemaking Stage
53 | Building Technologies Program eere.energy.gov

• Life-Cycle Cost (LCC)

– Sum of installed cost and total operating costs over the entire 

lifetime of a fixture

• Payback Period (PBP)

– Time (in years) in which an initially more expensive (and 

efficient) fixture will pay itself off due to decreased annual 

operating costs

LCC-PBP Calculation
54 | Building Technologies Program eere.energy.gov

Life-Cycle Cost and

Payback Period Analysis
55 | Building Technologies Program eere.energy.gov

Equipment Lifetime

Interior Fixture 20 years

Exterior Fixture 25 years

Magnetic Ballast 50,000 hours

Electronic Ballast 30,000 hours

70W Lamp 12,000 hours

250W Lamp 15,000 hours

400W Lamp 20,000 hours

1000W Lamp 12,000 hours

• Lifetime values determine how frequently equipment 

needs to be maintained or replaced

LCC-PBP Analysis Lifetime Inputs
56 | Building Technologies Program eere.energy.gov

LCC-PBP Analysis Results

70W 

Equipment

Class

CSL Power

(W)

Efficiency

(%)

LCC

Savings 

($)

PBP

(yrs)

70W

Baseline 96.8 72.3

1 92.0 76.1 $23.72 0.52

2 78.4 89.3 -$73.05 N/A

3 76.8 91.1 -$87.74 N/A
57 | Building Technologies Program eere.energy.gov

LCC-PBP Analysis Results

250W/400W

Equipment

Class

CSL Power

(W)

Efficiency

(%)

LCC

Savings 

($)

PBP

(yrs)

250W

Baseline 284 88.0

1 276 90.5 $26.04 3.33

2 273 91.5 $24.51 5.86

3 268 93.2 -$227.74 N/A

4 267 93.6 -$209.85 N/A

400W

Baseline 455 88.0

1 444 90.0 $21.10 6.33

2 436 91.7 $42.93 5.62

3 432 92.7 -$260.12 N/A

4 426 93.9 -$301.56 N/A
58 | Building Technologies Program eere.energy.gov

LCC-PBP Analysis Results

1000W 

Equipment

Class

CSL Power

(W)

Efficiency

(%)

LCC

Savings 

($)

PBP

(yrs)

1000W

Baseline 1088 91.9

1 1080 92.6 $20.99 5.26

2 1072 93.3 $53.98 3.56
59 | Building Technologies Program eere.energy.gov

Issue for Discussion

Issue ES30: In addition to the assumed lifetime values for 

fixtures and ballasts, DOE used median rated lifetimes for 

lamps. These average values suggest that a majority of 

failures occur later in the service lifetime. DOE seeks 

comment on its assumed lifetimes for fixtures, ballasts, and 

lamps, and how they may vary within the representative 

equipment classes, as well as the distribution of failures 

around the average values. In particular, DOE seeks 

comment on how many years beyond their average 

lifetimes that equipment can remain in service.
60 | Building Technologies Program eere.energy.gov

Engineering Analysis

Energy Use; Markup Analysis

Life-Cycle Cost And Payback Period Analysis

Preliminary MIA

Presentation Overview

3

4

5

7

1 Overview, Statute, and Context

2 Market & Tech; Screening Analysis

6 National Impact Analysis

8

9

NOPR Analyses

Final Questions / Discussion
61 | Building Technologies Program eere.energy.gov

Framework

Document

Preliminary 

Analysis NOPR Final

Rule

Market & 

Technology

Screening

Analysis

Engineering

Analysis

Energy Use & 

End Use Load

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for

Equipment

Price

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Preliminary 

Manufacturer 

Impact 

Analysis

Preliminary Analysis

Rulemaking Stage
62 | Building Technologies Program eere.energy.gov

• DOE estimated historical fixture shipments using MHLF 

shipments data from the U.S. Census Current Industrial 

Reports (1993-2001) and NEMA HID lamp shipments 

(1990-2008)

• DOE found that approximately 37 percent of lamp 

shipments from 1993-2001 corresponded to fixtures 

shipments

• DOE calculated installed stock based on estimated 

lifetimes

• Finally, DOE developed base-case and standards-case 

shipment projections based on:

– fixture lifetimes

– replacement and fixture demand growth rates

– retirement and emerging technology penetration rates, e.g., 

in which other technologies displace metal halide lamp 

fixtures

Shipments Analysis
63 | Building Technologies Program eere.energy.gov

Shipments Analysis Results

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

1,600,000

1,800,000

2,000,000

2010 2020 2030 2040 2050

Projected Shipments

Year

Base-Case Shipments

70W

250W

400W

1000W
64 | Building Technologies Program eere.energy.gov

Issues for Discussion

Issue ES31: DOE used publicly available lamp fixture 

shipment data from the U.S. Census, data from the 2010 HID 

Lamps Determination, confidential NEMA shipment data, and 

market trend information from manufacturers to develop a 

baseline for MHLF from 1990–2008. DOE requests comment 

on this approach, as well as shipment data to validate its 

methodology. 

Issue ES32: DOE projected future fixture shipments based on 

assumed trends in replacement, retirement, and emerging 

technology rates. DOE requests comments on the magnitude 

and timing of its forecasted fixture shipments trends (e.g., 

rising and declining shipments, plateaus, etc.) as well as the 

impacts of current regulatory initiatives on future fixture 

shipments.
65 | Building Technologies Program eere.energy.gov

• National energy savings (NES) and net present value 

(NPV) calculated for period from 2015-2044

National Impacts Analysis (NIA)

Shipments 

Model

National 

Energy 

Savings

National

Economic

Impacts

LCC 

Analysis 

Results and 

Other Inputs

National 

Energy Savings 

(Quads)

National 

Net Present Value 

($ billions)
66 | Building Technologies Program eere.energy.gov

National Impact Analysis Results

0.000

0.010

0.020

0.030

0.040

0.050

0.060

0.070

0.080

0.090

2010 2015 2020 2025 2030 2035 2040 2045 2050

Quadrillion Source BTUs

Year

National Energy Savings

• National energy savings increase over time, but eventually 

level off due to emerging technologies

– All equipment classes under a maximum energy savings 

scenario, regardless of NPV
67 | Building Technologies Program eere.energy.gov

• Net present value rises (shipments) then falls 

(discounting), but varies between equipment class, CSL

– All equipment classes under a shift 2 scenario (max NES 

with positive NPV)

National Impact Analysis Results

0.0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

2010 2020 2030 2040 2050

NPV (billion 2010$)

Year

Net Present Value

70W

250W

400W

1000W
68 | Building Technologies Program eere.energy.gov

Engineering Analysis

Energy Use; Markup Analysis

Life-Cycle Cost And Payback Period Analysis

National Impact Analysis

Presentation Overview

3

4

5

6

1 Overview, Statute, and Context

2 Market & Tech; Screening Analysis

7 Preliminary MIA

8

9

NOPR Analyses

Final Questions / Discussion
69 | Building Technologies Program eere.energy.gov

Manufacturer Impact Analysis

Overview

Phase 1

• DOE creates an industry profile to characterize the industry and identify 

important issues that require consideration.

Phase 2

• DOE prepares an industry cash-flow model and an interview questionnaire to 

guide subsequent discussions.

Phase 3

• DOE interviews manufacturers and assesses the impacts of amended 

standards both quantitatively (using the Government Regulatory Impact Model) 

and qualitatively (impacts on competition, manufacturing capacity, employment, 

and regulatory burden).

Industry 

profile

Develop 

straw-man 

GRIM

Develop 

interview 

guide

Interviews

& 

industrywide / 

subgroup

analyses

Assess direct 

employment, 

competition, 

cumulative 

burden

Phase 1 Phase 2 Phase 3
70 | Building Technologies Program eere.energy.gov

Preliminary Manufacturer Impact 

Analysis – Key Issues

• Impacts on Profitability

– Manufacturers may not be able to pass on cost increases to customers, 

particularly in the price-sensitive OEM channel

• Market Erosion

– Market is shifting toward LEDs and fluorescent technologies, and standards 

could accelerate this migration by increasing prices

• Opportunity Cost of Investments

– Resources available for the development of new products may decrease 

because existing products may need to be redesigned

• Product Conversion Costs/ Testing Burden

• System Approach

– Drawbacks to use of a system efficiency metric

• Absence of ANSI Test Procedure for Higher Frequency Ballasts
71 | Building Technologies Program eere.energy.gov

Preliminary Manufacturer Impact 

Analysis – Key Issues (Continued)

Issue ES35: DOE requests comment on its identification of 

key issues and requests data and information from interested 

parties that can assist in evaluating the potential impact on 

manufacturers.

Issue ES26: DOE recognizes and seeks to mitigate the 

overlapping effects on manufacturers of new or amended DOE 

standards and other regulatory actions affecting the same 

equipment. DOE invites comment on regulations applicable to 

ballast and fixture manufacturers that contribute to their 

cumulative regulatory burden.
72 | Building Technologies Program eere.energy.gov

Engineering Analysis

Energy Use; Markup Analysis

Life-Cycle Cost And Payback Period Analysis

National Impact Analysis

Presentation Overview

3

4

5

6

1 Overview, Statute, and Context

2 Market & Tech; Screening Analysis

8 NOPR Analyses

7

9

Preliminary MIA

Final Questions / Discussion
73 | Building Technologies Program eere.energy.gov

Analyses for Notice of Proposed 

Rulemaking (NOPR)

Environmental 

Assessment

Life-Cycle 

Cost 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Utility 

Impact 

Analysis

Employment 

Impact 

Analysis

Regulatory

Impact 

Analysis

Revise

Preliminary

Analysis

Framework

Document

Preliminary 

Analysis NOPR Final

Rule
74 | Building Technologies Program eere.energy.gov

• LCC Subgroup Analysis

– effects on various national consumer subgroups

• Manufacturer Impact Analysis

– continue work begun in the preliminary MIA

• Utility Impact Analysis

– effects on generation capacity of utilities

• Employment Impact Analysis

– indirect effects on national employment

• Environmental Assessment

– effects on airborne pollutant emissions

• Regulatory Impact Analysis

– potential for non-regulatory approaches

NOPR Analyses
75 | Building Technologies Program eere.energy.gov

Issue for Discussion

Issue ES33: Some groups might be adversely affected 

by the amended energy conservation standards for 

MHLFs. DOE will consider the subgroups: medium to 

high-end retail, grocery, big-box retail, schools, 

community centers, sport facilities including clubs, 

industrial, warehousing, various types of facilities with 

outdoor area lighting, and owners of streets and 

roadways. DOE welcomes additional suggestions for its 

LCC subgroup analysis.
76 | Building Technologies Program eere.energy.gov

Trial Standard Levels in NOPR

• In the NOPR phase of the rulemaking, DOE will develop trial 

standard levels (TSLs) based on candidate standard levels for 

metal halide lamp fixtures

• DOE is considering developing TSLs based on, but not limited 

to, combinations of efficiency levels, minimum LCC, maximum 

NPV, and maximum technologically-feasible efficiency

• From the list of TSLs developed, DOE will select one as its 

proposed standard for the NOPR.
77 | Building Technologies Program eere.energy.gov

Engineering Analysis

Energy Use; Markup Analysis

Life-Cycle Cost And Payback Period Analysis

National Impact Analysis

Presentation Overview

3

4

5

6

1 Overview, Statute, and Context

2 Market & Tech; Screening Analysis

9 Final Questions / Discussion

7

8

Preliminary MIA

NOPR Analyses
78 | Building Technologies Program eere.energy.gov

In all correspondence, include all of the following:

– Energy Conservation Standards for Metal Halide Lamp Fixtures

– Docket Number EERE-2009–BT–STD–0018

– Regulatory Identification Number (RIN) 1904–AC00

Email: MHLF-2009-STD-0018@ee.doe.gov

Comment period closes: Monday, 16 May 2011

DOE Seeks Comments on its Proposal

Postal Mail: 

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program

Mailstop EE-2J

1000 Independence Avenue, S.W.

Washington, DC 20585-0121

Courier: 

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program

950 L’Enfant Plaza, S.W., 6th Floor

Washington, DC 20024 

Telephone: (202) 586-2945

Submission of Comments