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 Downlight Parking Garage High Bay

Spotlight Low Bay

Area Floodlight Wall
-Pack Post
-Top Bollard2 | 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 

## Welcome3 | 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 Agenda4 | 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 Comments7 | 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 Market & Tech; Screening Analysis 2 Engineering Analysis 3 1 Overview, Statute, and Context

8 9 NOPR Analyses Final Questions / Discussion8 | 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 2012 2014 2016 2010 2015 2011 2009 201310 | 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 Overview, Statute, and Context 1 Engineering Analysis 3 2 Market & Tech; Screening Analysis

8 9 NOPR Analyses Final Questions / Discussion11 | 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 Stage12 | 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 Housing13 | 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 Pulse Start 150 ≤ W ≤ 500 88% Magnetic Probe Start 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 Procedures16 | 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 Operation17 | 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 Approaches19 | 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 pulse and 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: D OE 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 bi level 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 Classes24 | 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 Environment25 | 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 Cross Section 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 Overview, Statute, and Context 1 Market & Tech; Screening Analysis 2 3 Engineering Analysis

8 9 NOPR Analyses Final Questions / Discussion30 | 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 Stage31 | 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 CSLs32 | 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 CSLs34 | 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 1000Ballast 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 CSLs36 | 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 CSLsEfficiency Wattage 

### HybridEfficiency Wattage 

### EquationEfficiency 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 CSLs40 | 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 Ballast Efficiency 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 Overview, Statute, and Context 1 Market & Tech; Screening Analysis 2
4 Energy Use; Markup Analysis

8 9 NOPR Analyses Final Questions / Discussion43 | 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 Stage44 | 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 107045 | 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 4,09846 | 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 4,50947 | 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 Analysis49 | 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 fixtures50 | 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 Overview, Statute, and Context 1 Market & Tech; Screening Analysis 2

5 Life-Cycle Cost And Payback Period Analysis

8 9 NOPR Analyses Final Questions / Discussion52 | 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 Stage53 | 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 Calculation54 | Building Technologies Program eere.energy.gov 

## Life - Cycle Cost and Payback Period Analysis55 | 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 Inputs56 | 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/A57 | 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/A58 | 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 3.5659 | 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 Overview, Statute, and Context 1 Market & Tech; Screening Analysis 2

6 National Impact Analysis 8 9 NOPR Analyses Final Questions / Discussion61 | 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 Stage62 | 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 Analysis63 | 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 2050Projected Shipments

Year 

# Base-Case Shipments

70W 250W 400W 1000W64 | 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 2050Quadrillion 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 NPV67 | 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 2050NPV (billion 2010$)

Year 

## Net Present Value

70W 250W 400W 1000W68 | 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 Overview, Statute, and Context 1 Market & Tech; Screening Analysis 2

7 Preliminary MIA 8 9 NOPR Analyses Final Questions / Discussion69 | 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 2 Phase 3 Phase 170 | 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 Ballasts71 | 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 Overview, Statute, and Context 1 Market & Tech; Screening Analysis 2

8 NOPR Analyses 7 9 Preliminary MIA Final Questions / Discussion73 | 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 Rule74 | 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 Analyses75 | 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 Overview, Statute, and Context 1 Market & Tech; Screening Analysis 2

9 Final Questions / Discussion 7 8 Preliminary MIA NOPR Analyses78 | 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