# NOTICE OF PROPOSED DETERMINATION

TEC HNICAL SUPPORT DOCUM ENT : ENERGY

EFFICIENCY PROGRAM FOR CONSUMER

PRODUCTS AND CERTAIN COMMERCIAL AND INDUSTRIAL EQUIPMENT:

HIGH- INTENSITY DISCHARGE LAMPS

October 2014

U.S. Department of Energy Assistant Secretary Office of Energy Efficiency and Renewable Energy Building Technologies Program Appliances and Commercial Equipment Standards Washington, DC 20585This Document was prepared for the Department of Energy by staff members of Navigant Consulting, Inc. and Pacifi c Northwest National LaboratoryCHAPTER 1. INTRODUCTION

TABLE OF CONTENTS

1.1 PURPOSE OF THE DOCUM ENT ................................................................................. 1-1

1.2 OVERVIEW OF THE APPL IANCES AND COMMERCIA L 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 ............................................................................ 1-6

LIST OF TABLES

Table 1.4.1 Analyses under the Process Rule .............................................................................. 1-4

1-iCHAPTER 1. INTRODUCTION

1.1 PURPOSE OF THE DOCUMENT

This technical support document (TSD ) is a standalone report that provides the technical analyses supporting the information in the notice of proposed determination ( NOPD ) for highintensity discharge (HID) lamps.

1.2 OVERVIEW OF THE APPLIANCES AND COMMERCIAL EQUIPMENT

STANDARDS PROGRAM

Title II I, Part C of t he Energy Policy and Conservation Act of 1975 (42 U.S.C. 6291– 6317; EPCA ), as amended, established the Energy Conservation P rogram for Certain Industrial Equipment, which includes the HID lamps addressed in this NOPD

. a Additional amendments to EPCA have given the U.S. Department of Energy (DOE) the authority to regulate the energy efficiency of several products, including HID lamps, the equipment that is the focus of this

document.

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 analysis and determine that the benefits of any p otential 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 customers 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 amoun t 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 For editorial reasons, upon codification in the U.S. Code, Part C was re

- designated Part A

- 1.

1-1(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

The following summarizes the pertinent legislative and regulatory history for HID lamps. DOE is conducting its first rulemaking cycle to consider energy conservation standards for HID lamps. 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) )

On July 1, 2010, DOE published a positive final determination b (hereafter the “2010 determination”) that standards for certain HID lamps are technologically feasible, economically justified, and would result in a significant energy savings. 75 FR 37975. As a result of the 2010 determination, DOE is currently conducting a test procedure rulemaking for the specified lamps, c as well as conducting this HID rulemaking which led to a second proposed determination.

Initially, DOE began an energy conservation standards rulemaking in response to the positive 2010 determination. On February 28, 2012, DOE posted the rulemaking framework document for HID lamps (h ereafter the “f ramework document”) on its website describing the procedural and analytical approaches DOE anticipated using to evaluate the costs and benefits of energy conservation standards for HID lamps. DOE held the public meeting for the framework

document (hereafter the “framework public meeting”) on March 29, 2012, to describe the various rulemaking analyses DOE would conduct, the methods for conducting them, and the

relations hip among the various analyses. d

On February 28, 2013, DOE published the i nterim analysis for the HID rulemaking and an announcement of a public meeting to discuss the considered energy conservation standards.

b The 2010 HID lamps final determination is available through : http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23

.

c DOE published a proposed test procedure NOPR on December 15, 2011 (76 FR 77914) and a Supplemental Notice of Proposed Rulemaking (SNOPR) on May 22, 2014 ( 79 FR 29631 ).

d The framework document and public meeting information are available through: http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23

.

1-278 FR 13566. DOE also posted the i nterim TSD on its website describing interim methodologies and results. DOE held the p ublic meeting for the interim analysis on April 2, 2013. e

After completing the revised analysis for the originally planned notice of proposed rulemaking (NOPR), DOE found that standards were no longer justified based on technological feasibility and economic justification. Therefore, DOE is proceeding with a second determination. Today’s NOPD tentatively determines that standards for HID lamps are not justified (a negative determination).

This NOPD 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 NOPD TSD for a d etailed discussion on DOE’s consideration of standby and off mode energy consumption.

1.4 PROCESS FOR SETTING ENERGY CONSERVATION STANDARDS

DOE considers the participation of interested parties a very important part of the

standards

- setting process. DOE encour ages the participation of all stakeholders during the comment period of each rulemaking stage. Beginning with the f ramework document and continuing through subsequent comment periods, interactions among interested parties provide a

balanced discussion of t he information that is required for the standards rulemaking.

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

involves interested parties through formal public notifications ( i.e.

, Federal Register n otices).

For this NOPD , 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 analyzing potential energy conservation standards for the HID lamps

.

Before DOE determines whether to establish energy conservation standards for HID lamps , it must first solicit comments on potential standard s. (42 U.S.C. 6295(o )( 2 )(B)(i)) If DOE

were to come to a positive determination, DOE must design each new standard for this equipment to achieve the maximum improvement in energy efficiency that is technologically

feasible

, economically justified , and would result in significant energy savings. (42 U.S.C. 6295(o) (2)(A) and (3)) To determine whether a potential standard complies with these requirements , DOE must , after receiving comments on the proposed determination , conclude

whether the benefits of a potential standar d exceed its burdens to the greatest extent practicable, weighing the seven factors described in section 1.2

.

e The interim TSD and interim public meeting information are available through : http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23

.

1-3Subsequent to the publication of the framework document, the standards rulemaking process involves several notices published in the Federal Register

. The interim analyses are presented in a notice and 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 typically issues the NOPR, which presents a discussion of comments received in response to the interim analyses of the impacts of standards on customers, manufacturers, and the nation; DOE’s weighing of the impacts; and the proposed stand ards. However after completing the revised analysis for the originally planned NOPR, DOE found that standards were no longer justified based on technological feasibility and economic justification. As such, the NOPR was replaced with this NOPD. The last notice is the final determination , which presents a discussion of comments received in response to the NOPD ; the revised analysis of the impacts of standards;

and DOE’s we ighing of the impacts.

Table 1.4.1 Analyses u nder the Process Rule

Interim Analysi s NOP D Final Determination *

Market and technology assessment Revised interim analyses Revised NOPD analyses

Screening analysis

Engineering analysis

Energy use characterization

Markup a nalysis

Equipment price determination

Life

- cycle cost and payback period analys is

Shipments analysis

National impact analysis

Interim manufacturer impact analysis

* During the final determination 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

availabi lity of the framework document and a public meeting to discuss the proposed analytical framework for the rulemaking. 77 FR 11785. DOE also posted a link to the f ramework document

on its website here: http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23

.

DOE held the framework public meeting on March 29, 2012, to discuss procedural and analytical approaches to the rulemaking, and to inform and facilitate the involvement of interested parties in the rulemaking process. The analytical f ramework presented at the framework public meeting d escribed rulemaking analyses, such as the engineering analysis and

the life

- cycle cost ( LCC ) and payback period ( PBP ) analyses, the methods proposed for

1-4conducting them, and the relationships among the various analyses. See Table 1.4.1 for all the analyses discussed at the f ramework public meeting to be undertaken in each of the formal public rulemaking documents. PDF copies of the slides and o ther material associated with the public meeting are available through: http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23

.

During the framework public meeting and the framework document comment period, interested parties , including manufacturers, trade associations, environmental advocates, and

others submitted comments about the HID lamp rulemaking. The major issues discussed were : (1) scope of coverage, (2) metric, (3) equipment classes, (4) efficacy level approach, and (5) shipment trends. Stakeholder comments submitted during the framework document comment period elaborated upon the issues raised at the public meeting. A detailed discussion of comments from interested parties is available in chapter 2 of the NOPD TSD.

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. DO E 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

interim manufacturer impact analysis (MIA); ( 4 ) pr ovide 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 12 A of the

interim TSD contains a compl ete copy of the interview guide.

DOE published a notice announcing th e availability of the interim analysis on Februa ry 28, 2013 (78 FR 13566), and held a public meeting on April 2 , 20 13. At this meeting, DOE presented the methodologies and results of the analyses set forth in the interim TSD . Interested parties discussed the following major issues at the public meeting: the scope of the rulemaking, the considered equipment classes, sapphire arc tubes as a design option for high-pressure sodium lamps , engineering analysis (including the repres entative units, baselines, and candidate standard levels [CSLs] ), the LCC and PBP analyses

, and the shipment analysis.

Comments received since publication of the February 2013 notice, including those

received at the April 20 13 public meeting, have contributed to DOE’s proposed resolution of the

issues in this NOPD . A detailed discussion of comments from interested parties is available in chapter 2 of this NOP D TSD

.

Following the publication of the interim analysis and the interim analysis public meeting, DOE held additional meetings with manufacturers as part of the consultative process for the manufacturer impact analysis conducted during the NOPD phase. The interviews covered several key issues, including: scope, market and technology assessment, markups and profitability, shipment projections, financial parameters, conversion costs, cumulative regulatory burden, direct employment assessment, manufacturing capacity and non-U.S. sales, impact on competition, HID ballast impacts, and impacts on small busine ss.

1-5For the LCC, PBP , and national impact analysis ( 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 spreadsheet s 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 through: http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23

. In these

NOPD analyses, DOE tentatively det ermines that energy conservation standards for HID lamps do not meet the requirements found in EPCA that such standards be economically justified. (42 U.S.C. 6295(o)) Therefore, in this NOPD stage, DOE proposes a negative determination

.

1.5 STRUCTURE OF THE DOCUMENT

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

consists of 12 chapters and 9 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: d escribes the rulemaking process, provid es an overview of each analysis, including rationale for proposed conclusions, and discusses comments received during the framework

an d interim analysis public meetings and comment periods

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: determ ines 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 establishes efficacy levels based on lamp efficacy

Chapter 6 Equipment P rice Determination: describes DOE’s process for establishing the end- user prices for HID lamps

Chapter 7 Markups Analysis: discusses the process DOE used to develop enduser equipment prices of ballasts and fixtures for the LCC

- PBP analysis and NIA; the marku ps analysis also relates lamp end

- user prices to the manufacturer selling prices used in the MIA

Chapter 8 Energy Use Analysis: discusses the process for generating energy use

estimates for HID lamps

1-6Chapter 9 LCC and PBP Analys is : discusses the economic effects of standards

on customers and compares the LCC and PBP of HID lamps with and without potential new energy conservation standards

Chapter 10 Shipments Analysis: discusses the methods used for forecasting shipments with and without higher energy conservation standards

Chapter 11 N IA : assesses the aggregate impacts at the national level of potential energy conservation standards as measured by the NPV of total customer economic impacts and NES

Chapter 12 Manufacturer Impact Analysis: discusses the effects of standards on the finances and profitability of HID lamp manufacturers, and presents manufacturer impact analysis results

Appendix 5A Alternative Starting Method Lamps: presents the methodology and resulting of identifying lamps comparable to the representative units but with the alternative starting method

Appendix 5B HID Replacement Pathways: presents the methodology used in modeling the replacement pathways customers would follow in response to HID lamp standards

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 L CC and PBP Spreadsheet

Appendix 9B Estimation of Potential Equipment Pri ce Trends for H ID Lamps

Appendix 11A User Instructions for Shipments and NIA Spreadsheet

Appendix 11B Full-Fuel-Cycle M ultipliers

Appendix 12A Manufacturer Interview Guide

Appendix 12B Government Regulatory Impact Model Overview

1-7CHAPTER 2. ANALYTICAL FRAMEWORK

TABLE OF CONTENTS

2.1 INTRODUCTION ............................................................................................................ 2-1

2.2 BACKGROUND .............................................................................................................. 2-2

2.2.1 Rulemaking History for High- Intensity Discharge Lamps ........................................... 2-2

2.2.2 Test Procedures ............................................................................................................. 2-3

2.2.3 Standby and Off Mode Energy Consumption ............................................................... 2-4

2.3 LAMPS ANALYZED IN TH IS DETERMINATION ..................................................... 2-5

2.3.1 Definitions ..................................................................................................................... 2-5

2.3.2 Spec ific Lamp Categories under Consideration ............................................................ 2-6

2.3.2.1 Wattage .................................................................................................................. 2-8

2.3.2.2 Correlated Color Temperature ............................................................................. 2-10

2.3.2.3 Directional Lamps ................................................................................................ 2-11

2.3.2.4 Self

- Ballasted Lamps ........................................................................................... 2-12

2.3.2.5 Lamps Designed to Operate Exclusively on Electronic Ballasts ......................... 2-14

2.3.2.6 High

- CRI Lamps .................................................................................................. 2-15

2.3.2.7 Colored MH Lamps ............................................................................................. 2-17

2.3.2.8 Lamps for Specialty Applications ........................................................................ 2-18

2.3.2.9 Electrodeless Lamps ............................................................................................ 2-23

2.3.2.10 F- rated Lamps ...................................................................................................... 2-24

2.3.2.11 Summary .............................................................................................................. 2-25

2.3.3 Comb ined Rulemakings .............................................................................................. 2-25

2.3.4 Metric .......................................................................................................................... 2-26

2.3.4.1 Initial Efficacy ..................................................................................................... 2-26

2.3.4.2 Metric for Directional Lamps .............................................................................. 2-27

2.4 MARKET AND TECHNOLOG Y ASSESSMENT ....................................................... 2-28

2.4.1 Market Assessment ..................................................................................................... 2-28

2.4.1.1 Manufacturers of High-Intensity Discharge Lamps ............................................ 2-28

2.4.1.2 Regulatory and Non

- Regulatory Programs .......................................................... 2-28

2.4.1.3 High -Intensity Discharge Lamp Shipments ......................................................... 2-29

2.4.2 Technology Options .................................................................................................... 2-30

2.4.2.1 Mercury Vapor Lamps ......................................................................................... 2-31

2.4.2.2 High

- Pressure Sodium Lamps ............................................................................. 2-31

2.4.2.3 Metal Halide Lamps ............................................................................................. 2-32

2.4.3 Equipment Classes ...................................................................................................... 2-35

2.4.3.1 Directionality ....................................................................................................... 2-38

2.4.3.2 Ballast Location ................................................................................................... 2-38

2.4.3.3 CCT ...................................................................................................................... 2-39

2.4.3.4 Wattage ................................................................................................................ 2-40

2.4.3.5 Bulb Finish ........................................................................................................... 2-41

2.4.3.6 Luminaire Characteristic ...................................................................................... 2-42

2-i2.4.3.7 Lamp Operating Orientation ................................................................................ 2-43

2.4.3.8 CRI ....................................................................................................................... 2-44

2.4.3.9 Standby Lamps ..................................................................................................... 2-44

2.4.3.10 Summary .............................................................................................................. 2-45

2.5 SCREENING ANALYSIS ............................................................................................. 2-46

2.5.1 HPS Lamps .................................................................................................................. 2-47

2.5.2 MH Lamps ................................................................................................................... 2-48

2.5.3 Summar y ..................................................................................................................... 2-49

2.6 ENGINEERING ANALYSIS ......................................................................................... 2-50

2.6.1 Approach ..................................................................................................................... 2-50

2.6.1.1 Repr esentative Equipment Classes ...................................................................... 2-52

2.6.2 Baseline Lamps ........................................................................................................... 2-53

2.6.3 More Efficacious Substitutes ...................................................................................... 2-56

2.6.3.1 Energy Savings Pathways .................................................................................... 2-56

2.6.3.2 Higher Efficacy Substitutes ................................................................................. 2-59

2.6.3.3 Proprietary Designs .............................................................................................. 2-61

2.6.4 Efficacy Levels ............................................................................................................ 2-62

2.6.4.1 Binned Approach versus Equation-Based Approach ........................................... 2-62

2.6.4.2 Highly Efficacious Lighting Systems .................................................................. 2-64

2.6.4.3 Results .................................................................................................................. 2-64

2.6.5 HID Systems ............................................................................................................... 2-66

2.6.5.1 Ballasts ................................................................................................................. 2-66

2.6.5.2 Fixtures ................................................................................................................ 2-70

2.6.5.3 Re placement Options ........................................................................................... 2-72

2.6.6 Scaling to Equipment Classes Not Analyzed .............................................................. 2-74

2.7 EQUIPMENT PRICE DETE RMINATION ................................................................... 2-76

2.7.1 HID Lamps .................................................................................................................. 2-76

2.7.2 HID Ballasts and Fixtures ........................................................................................... 2-77

2.8 MARKUPS ANALYSIS ................................................................................................ 2-78

2.9 ENERGY USE ANALYSIS ........................................................................................... 2-79

2.10 LIFE

- CYCLE COST AND PAYBACK PERIOD ANALYSIS .................................... 2-79

2.11 SHIPMENTS ANALYSIS ............................................................................................. 2-81

2.12 NATIONAL IMPACT ANALYSIS ............................................................................... 2-82

2.13 MANUFACTURER IMPACT ANALYSIS .................................................................. 2-84

2.13.1 Discussion of Comments ............................................................................................. 2-85

2.13.2 Regulatory Flexibility Act ........................................................................................... 2-86

2.14 PROPOSED DETERMINATION .................................................................................. 2-86

2.14.1 Technological Feasibility ............................................................................................ 2-87

2.14.2 Significance of Energy Savings .................................................................................. 2-87

2.14.3 Economic Justification ................................................................................................ 2-87

2.14.4 Conclusions ................................................................................................................. 2-88

REFERENCES .......................................................................................................................... 2-89

2- iiLIST OF TABLES

Table 2.3.1 CCTs and Wattages Analyzed in NOPD ................................................................ 2-25 Table 2.4.1 Historical Shipments of HID Lamps from 1990-2010 ........................................... 2-30 Table 2.4.2 Equipment Classes Considered in Framework Document ..................................... 2-36 Table 2.4.3 Equipment Clas ses Considered in Interim Analysis ............................................... 2-37 Table 2.4.4 Equipment Classes Analyzed in NOPD.................................................................. 2-45 Table 2.5.1 Framework Document and Interim Analysis HID Lamp Design Options ............. 2-47 Table 2.5.2 NOPD HID Lamp Design Options ......................................................................... 2-50 Table 2.6.1 Representative and Scaled Equipment Classes for HID Lamps ............................. 2-53 Table 2.6.2 Efficacy Level Descriptions for the Representative Equipment Classes in NOPD 2-66 Table 2.6.3 Representative Ballast Types for the Interim Analysis .......................................... 2-68 Table 2.6.4 NOPD Magnetic Ballast Efficiencies ..................................................................... 2-69

Table 2.6.5 NOPD Electronic Ballast Efficiencies .................................................................... 2-70 Table 2.6.6 Scaling Factors Calculated in In terim Analysis ...................................................... 2-75 Table 2.6.7 NOPD Scaling Factors ............................................................................................ 2-76

2- iiiCHAPTER 2. ANALYTICAL FRAMEWORK

2.1 INTRODUCTION

The Energy Policy and Conservation Act of 1975, as amended, requires the U.S. Department of Energy (DOE) to prescribe test requirements and energy conservation standards

for those high

- intensity discharge (HID) lamps for which DOE determines that standards would be technologically feasible and economically justified, and result in significant energy savings

. (42 U.S.C. 6317) This chapter describes the general analytical framework that DOE use d in analyzing potential standards for HID lamps with respect to these criteria . The analytical framework is a description of the methodology, the analytical tools, and relationships among the various analyses that are part of this proposed determination . For example, the methodology that addresses the statutory requirement for economic justification includes analyses of life

- cycle cost (LCC); economic impact on manufacturers and users; national benefits; impacts, if any, on utility companies; and impacts, if any, from lessening competition among manufacturers.

The analyses performed in the notice of proposed determination ( NOP D ) stage and reported in this TSD include:

• A market and technology assessment to characterize the HID lamp market, identify technology options that improve efficacy, and develop equipment classes

• A screening a nalysis to review each technology option and determine if it is technologically feasible; practicable to manufacture, install, and service; would adversely affect lamp utility or availability; or would have adverse impacts on health and safety

• An engineering analysis to study representative lamps and lamp-and- ballast systems used as substitutes for baseline lamps, to select efficacy levels ( E Ls ), and to determine lamp -and- ballast system power ratings

• An equipment price determination to determine end- user equipment prices for representative HID lamps and manufacturer selling prices their associated ballasts and

fixtures

• A marku ps analysis to evaluate distribution channels to develop end- user equipment prices of ballasts and fixtures for the LCC ana lysis and national impact analysis (NIA); the marku ps analysis also relates lamp end

- user prices to the manufacturer selling prices (MSPs) used in the manufacturer impact analysis (MIA )

• An energy use analysis to determine the energy usage of the HID lamps considered in

this NOPD

2-1• An LCC analysis that calculates, at the customer level, the discounted savings in operating costs throughout the estimated average life of the HID lamps considered in

this NOPD , compared to any increase in the installed costs likely to result directly from imposition of the standard

• A payback period (PBP) analysis to estimate the amount of time it takes customers to recover the higher purchase expense of more efficacious lamps through lower operating costs

• A shipments analysi s to estimate yearly shipments of covered HID lamps over the analysis period

• An NIA that assesses the aggregate impacts at the national level of potential energy conservation standards as measured by the net present value (NPV) of total customer economic impacts and national energy savings (NES)

• An MIA that estimates the financial impact of standards on HID lamp manufacturers and calculates impacts on competition, employment at the manufacturing plant, and manufacturing capacity

In response to comments received on the NOPD , DOE may revise its analyses before publishing the final determination

.

As described in more detail throughout this TSD, DOE conducted a two- phase review of

the specific lamp types that fall within DOE’s definition of “HID lamp” to de fine which lamps would be analyzed in this NOPD. DOE first analyzed the potential for energy savings and the technological feasibility of energy conservation standards. For the HID lamps that passed those criteria, DOE conducted a full economic analysis (i ncluding the LCC analysis, NIA, and MIA ) to determine if standards would be economically justified (see chapters 9, 11, and 12 of the NOPD TSD).

2.2 BACKGROUND

2.2.1 Rulemaking History for High

- Intensity Discharge Lamps

Pursuant to the Energy Policy and Conservation Act of 1975 ( EPCA ), DOE published a positive final determination a (hereafter the “ 2010 determination”) that standards for certain HID lamps are technologically feasible, economically justified, and would result in significant energy savings. 75 FR 37975 (July 1, 2010). As a result of th e 2010 determination, DOE initiated a test procedure rulemaking for the specified lamps (see section 2.2.2 ). b

DOE also initiated an energy conservation standards rulemaking in response to the positive 2010 determination. On February 28, 2012, DOE published in the Federal Register an announcement of the availability of a framework document for energy conservation standards for

a The final determination is available at: www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23

. b DOE published a test procedure SNOPR on May 22, 2014 (79 FR 29631).

2-2HID lamps, as well as and notice of a public meeting. DOE held a public meeting on March 29, 2012 to receive feedback in response to the framework document.

DOE gathered additional information and performed interim analyses to develop potential energy conservation standards for HID lamps. On February 28, 2013, DOE published in

the Federal Register an announcement of the availability of the interim technical support document (the interim TSD) and notice of a public meeting (hereafter, the “February 2013 notice”) to discuss and receive comments on the following matters: (1) the equipment classes DOE planned to analyze; (2) the analytical framework, models, and the tools that DOE used to evaluate standards; (3) the results of the interim analyses performed by DOE; and (4) potential standard levels that DOE could consider. 78 FR 13566. In the February 2013 notice, DOE requested comment on issues that would affect energy conserva tion standards for HID lamps or that DOE should address in the following analysis stage . The interim TSD is available at: www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23

.

The interim TSD summarized the activities DOE undertook in developing standards for HID lamps. It also described the analytical framework that DOE uses in this rulemaking, including a description of the methodology, the analytical tools, and the relationships among the various analyses that are part of the rulemaking. The interim TSD presented and described in detail each analysis DOE performed up to that point, including descriptions of inputs, sources, methodologies, and results.

The public meeting for the interim analysis took place on April 2, 2013. At this meeting, DOE presented the methodologies and results of the analyses set forth in the interim TSD. Interested parties discussed the following major issues at the public meeting: the scope of the

int erim analysis , equipment classes, sapphire arc tube technology, engineering analysis (including the representative units, baselines, and CSLs), the LCC and PBP analyses, and the shipment analysis.

Thi s chapter of the NOPD TSD responds to the issues raise d in the comments received for both the framework document and the interim analysis. After revisiting the interim analyses based on stakeholder comments and reviewing updated information, DOE found that standards for HID lamps would not be technologically feasible and economically justified, and would not result in significant energy savings . Therefore, in today’s NOPD, DOE is proceeding with a

second (negative) determination.

2.2.2 Test Procedures

EPCA sets forth generally applicable criteria and procedures for DOE’s adoption and amendment of test procedures. (42 U.S.C. 6314) Manufacturers of covered equipment must use these test procedures to certify to DOE that their equipment complies with EPCA energy conservation standards and to quantify the efficiency of their equipment. In addition , these test procedures must be used whenever testing is required in an enforcement action to determine whether covered equipment complies with EPCA standards.

On December 15, 2011, DOE published a NOPR in which it proposed test procedures for HID lamps. 76 FR 77914 . DOE addressed the test procedure s NOPR at a public meeting on January 19, 2012. Comments received in response to the test procedures NOPR and a transcript

2-3of the public meeting are available at www.regulations.gov , docket number EERE -2010- BT

- TP

0044. DOE received comments from interested parties suggesting that DOE’s test procedures for HID lamps should be harmonized with similar, relevant international test procedures, and that DOE should pursue using test data already collected in accordance with international requirements. DOE also received comments on its proposals to measure lamp color characteristics, lumen maintenance, and directional characteristics. Other comments received focused on the proposed sampling plan, laboratory accreditation requirements, and the

instrumentation r equirements for test apparatus.

Based on comments received on the test procedures NOPR and subsequent additional research, DOE proposed revisions to and clarification of the proposed HID lamp test procedures.

DOE published these revisions and clarifications in a test procedures supplemental notice of proposed rulemaking (SNOPR) on May 22, 2014. c The analysis in this NOPD is based upon the test procedures proposed in the test procedure NOPR, as modified by the SNOPR

. If DOE makes a final determination that HID lamp standards would not be technologically feasible and economically justified, DOE does not plan to issue a final rule fo r the HID lamp test procedure.

In the public meeting for the interim analysis of the HID lamps energy conservation rulemaking, NEMA commented that HID tolerances should be referenced to NEMA LSD -63- 2012, which is based on NIST Technical Note 1297. (NEMA, Public Meeting Transcript, No. 23 at p. 73) d DOE notes that the application of LSD- 63

- 2012 for HID lamp tolerances is addressed in section C.2.b of the HID lamps test procedure SNOPR. c 79 FR 29631, 29641 (May 22, 2014) In the SNOPR, DOE proposes to incorporate the manufacturing variability numbers of each HID lamp type from LSD-63-2012 to determine the confidence interval used for reporting lamp efficacy.

2.2.3 Standby and Off Mode Energy Con sumption

EPCA defines active mode as the condition in which an energy-using piece of equipment is connected to a main power source, has been activated, and provides one or more mainfunctions. (42 U.S.C. 6295)(gg)(1)(A)) Off mode is defined as the condition in which an energyusing piece of equipment is connected to a main power source, and is not providing any standby

or active mode function. Id . Standby mode is defined as the condition in which an energy-using piece of equipment is connected to a main power source and offers one or more of the following

user

- oriented or protective functions: facilitating the activation or deactivation of other functions (including active mode) by remote switch (including remote control), internal sensor, or timer; or providing continuous functions, including information or status displays (including clocks) or

sensor -based functions. Id

.

For the framework document, DOE conducted an analysis of the applicability of standby mode and off mode energy use for HID lamps. Similar to DOE’s conclusion in the July 2009

c The SNOPR for the HID lamps TP rulemaking was published in the Federal Register on May 22, 2014

. 79 FR 29632. The HID lamp test procedure SNOPR is available at: http://www1.eere.energy. gov/buildings/appliance_standards/rulemaking.aspx/ruleid/21

. d A notation in the form ‘‘ NEMA, Public Meeting Transcript, No. 23 at p. 73 ’’ identifies a comment that DOE has received and included in the docket of this rulemaking. This particular notation re fers to a comment: (1) submitted by NEMA during the interim analysis public meeting on February 28, 201 3 ; (2) in the transcript of that public meeting, document number 2 3 in the docket of this rulemaking; and (3) appearing on page 73 of the transcript.

2-4general service fluorescent lamp (GSFL) and incandescent reflector lamp ( IRL ) final rule (74 FR 34080, 34094 (July 14, 2009)), DOE tentatively determined that HID lamps that are subject of

this NOPD do not operate in standby mode or off mode. HID lamps do not offer any secondary

user -oriented or protective functions or continuous standby mode functions. Because all energy use of HID lamps is accounted for in the active mode, DOE did not plan to consider standards

for la mp operation in the standby and off modes.

In response to the framework document, NEMA and Philips Lighting (Philips) agreed with DOE that standby and off mode does not apply to HID lamps. (NEMA, No. 11 at p. 6; Philips, Public Meeting Transcript, No. 12 a t p. 36) DOE preliminarily determined not to address lamp operation in the standby and off modes in the interim analysis. Having received no further

comment, in this NOPD DOE does not consider lamp operation in standby and off modes as applicable to HID la mps.

2.3 LAMPS ANALYZED IN THIS DETERMINATION

In t his section , DOE discusses definitions of HID lamps relevant to the analysis in this

NOPD and its determin ation of the HID lamp types analyzed . DOE analyz ed each of these specific lamp categories according to the criteria prescribed by EPCA

 energy savings potential, technological feasibility, and economic justification. (42 U.S.C. 6295(o)(2)(A) and 6317)

DOE assessed a lamp category’s potential for energy savings using lamp availability in manufacturer catalog s as a proxy for market share, which was then reevaluated in light of feedback obtained during manufacturer interviews. For HID lamp availability, DOE obtained quantitative information from lamp catalogs of 15 different manufacturers. DOE also conducted evaluations of technological feasibility and economic justification.

2.3.1 Definitions

HID is the generic name for a family of lamps including mercury vapor (MV), metal halide (MH), and high-pressure sodium (HPS) lamps. Although low- pressure sodium lamps are

often included in the HID family, the definition for HID lamp set forth in EPCA requires the arc tube wall loading to be greater than three watts per centimeter. Because low -pressure sodium lamps do not satisfy this requirement, they are not included in the definition of HID lamps according to the definition set forth in EPCA, and are therefore not considered in this

determination . The definitions for HID lamp, MV lamp, and MH lamp are established by EPCA

as follows:

High intensity discharge lamp means an electr ic -discharge lamp in which –

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

2. T he arc tube wall loading is in excess of 3 watts/cm 2

High intensity discharge lamps include mercury vapor, metal halide, and high-pressure sodium

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

Mercury vapor lamp means a high-intensity discharge lamp, including clear, phosphorcoated, and self

- ballast ed screw base lamp s, in which the major portion of the light is

2-5produced by radiation from mercury typically operating at a partial vapor pressure in excess of 100,000 Pa ( approximately 1 a tm). (42 U.S.C. 6291(47)(A) and (B))

Metal halide lamp means a high-intensity discharge lamp in which the major portion of the light is produced by radiation of metal halides and their products of dissociation, possibly in combination with metallic vapors. (42 U.S.C. 6291(63))

HPS lamps are not currently defined in EPCA . DOE proposed a definition for these lamps in the HID lamp test procedure S NOPR , as follows:

High

- pressure sodium lamp means a high -intensity discharge lamp in which the major portion of the light is produced by radiation from sodium vapor operating at a partial pressure of 6,67 0 Pa ( approximately 0.066 atmospheres or 50 Torr) or greater.

2.3.2 Specific Lamp Categories under Consideration

In the framework document, DOE created a data set of commonly available HID lamps based on catalogs from small and large HID lamp manufacturers. DOE used the resulting

information about equipment availability to evaluate how the market may respo nd to various standard levels, and to gain insight on the performance attributes of various commercially available technologies. The availability of different lamp types was used as an approximation of their relative shipment volumes. In the framework document, DOE discussed considering standards for MH lamps with rated wattages from 50 watts (W) – 2000 W, and HPS and MV lamps with rated wattages 50 W – 1000 W. Within those wattage ranges, DOE considered

standards for MH lamps with CCTs from 2500 Kelvin (K) – 6999 K, MV lamps with CCTs from

3200 K – 6800 K, and HPS lamps with CCTs from 1900 K – 2700 K.

In addition to restricting the lamps under consideration for standards by wattage and CCT, DOE also discussed removing from consideration certain categories of HID lamps. In the framework document, the lamp types not considered for standards were HID lamps designed to operate exclusively on electronic ballasts, directional HID lamps, self-ballasted HID lamps, highCCT lamps, and specialty application MV lamps from consideration for standards . DOE requested comment from interested parties on the types of HID lamps under consideration for regulation.

Earthjustice commented that it is not a sound practice for DOE to e xclude certain lamp types because of low market share while using catalog data as the indicator of market share. Earthjustice contended that actual sales data would provide a more accurate picture of the energy savings potential of the lamps DOE was considering excluding, and that DOE should request market share data for lamps and adjust which lamps are considered for standards accordingly. (Earthjustice, No. 9 at p. 1) NEMA and GE Consumer and Industrial of General Electric, Inc. ( GE ) commented that they a gree with these proposed exclusions. (NEMA, No. 11 at p. 4; NEMA, No. 11 at p. 6; GE, Public Meeting Transcript, No. 12 at p. 26) As discussed in the following sections, DOE received specific comments from interested parties in response to individual exclusions, as well as on exclusions that had not been considered by DOE in the

framework document.

2-6For the interim analysis and this NOP D TSD , DOE supplemented the information it gained from manufacturer catalog data with shipment data provided by manufacturers during interviews. In the interim analysis, DOE maintained the CCT and wattage ranges considered in the framework document for MH, MV, and HPS lamps. DOE also maintained exclusions for directional lamps, self

- ballasted lamps, lamps designed to operate exclusively on electronic ballasts, and MV lamps for specialty applications. DOE also excluded from consideration for standards electrodeless HID lamps, which were preliminarily determined to be a type of HID lamp but lacked significant market penetration and an industry consensus test method. DOE also

introduced t wo additional exclusions that target lamps with unique photometric characteristics at the expense of efficacy: high CRI lamps (greater than or equal to a CRI of 95) and colored MH lamps (less than a CRI of 40). In the interim analysis, DOE preliminarily determined that the modified list of lamps excluded from analysis effectively exempts specialty lamps with a CCT greater than or equal to 7000 K, and removed the high-CCT lamp exclusion introduced in the framework document. NEMA commented that they agreed with DOE’s exclusions. (NEMA, No. 24 at p. 4) As discussed in the following sections, DOE received specific comments from interested parties in response to individual exclusions, as well as on exclusi ons that had not been considered by DOE in the interim analysis document.For today’s NOPD, DOE tentatively determined that sapphire arc tube technology is not a valid technology option for increased efficacy in HPS lamps (see section 2.4.2.2 for further details). As a result, DOE has tentatively determined there are no technology options to increase the efficacy of HPS lamps, indicating standards for this lamp techn ology are not technologically feasible. Therefore, DOE performed no further economic analyses for HPS lamps to determine whether standards would be economically justified.

DOE analyzes standards in today’s NOPD for MH lamps with rated wattages 50 W

– 2000 W, and MV lamps with rated wattages 50 W – 1000 W. Within those wattage ranges, DOE analyzes standards for MH and MV lamps with CCTs greater than or equal to 2800 K and less

than 7000 K. Because DOE tentatively determined standards for HPS lamps are not

t echnologically feasible , wattage and CCT ranges for HPS lamps are not discussed

.

In the NOPD , DOE revised the proposed exclusions from the interim analysis, and does not analyze standards for : HPS lamps; directional lamps; self

- ballasted lamps; lamps desi gned to operate exclusively on electronic ballasts; electrodeless HID lamps; high

- CRI lamps (greater than or equal to a CRI of 95); colored MH lamps (less than a CRI of 40); and lamps for specialty applications ( MV lamps that are double -ended, do not have a screw base, and have no outer bulb ; and HID lamps that have 5000 K – 6999 K CCT, do not have a screw base, and have non-Tshaped bulbs).

In response to the framework document and interim analysis, DOE requested comment on all topics affecting the decisi on of which lamps are considered for potential energy conservation standards in both the framework document and interim analysis. DOE receivedcomment on covered wattages and CCT ranges and the exclusion of directional lamps, selfballasted lamps, lamps de signed to operate exclusively on electronic ballasts, high- CRI lamps, colored MH lamps, lamps for specialty applications, and electrodeless HID lamps from analysis for potential standards. In support of the exclusions discussed in today’s NOPD, DOE respond s to these comments in the sections that follow.

2-72.3.2.1 Wattage

In examining manufacturer catalogs, DOE found that HID lamps span wattages from 15 W to 18,000 W, though the exact ranges vary according to lamp technology. Rated wattages range from 15 W to 24 ,000 W for MH lamps, from 35 W to 1000 W for HPS lamps, and from 40 W to 2000 W for MV lamps. DOE is considering analyz ing a subset of the available wattages, as explained in the following paragraphs.

In the framework document, DOE considered establishing standards for MH lamps with rated wattages greater than or equal to 50 W and less than or equal to 2000 W. NEMA, GE, and Philips proposed limiting the applicability of standards to MH lamps within 50 W and 1000 W, because products greater than 1000 W are not used in general lighting applications. (NEMA, No. 11 at p. 6; GE, Public Meeting Transcript, No. 12 at p. 25; Philips, Public Meeting Transcript, No. 12 at p. 36) NEMA commented that there are no standard 2000 W single- ended MH lamps, and recommended excluding 1500 W and 2000 W single- and double-ended MH lamps from the

consideration for standards as the primary application of stadium lighting has limited operating hours. (NEMA, No. 11 at p. 3) The CA IOUs commented that they do not believe that lamps with inp ut wattages greater than 1000 W have unique operating or technology requirements, or provide any specialty application that would limit their ability to meet standards. CA IOUs also commented that the high wattage lamps that manufacturers claimed to be in the low use niche market of stadium lighting are also advertised for use in other general lighting applications, such as floodlighting of buildings and monuments and area lighting in harbors and building sites. CA IOUs noted that DOE should consider the high wattage of these lamps in addition to their market share to determine the potential for significant energy savings. (CA IOUs, No. 8 at pp. 1-2)

In the interim analysis, DOE determined based on its review of catalog data that 1000 W – 2000 W MH lamps are used in general lighting applications. DOE analyzed the 50 W – 2000 W range (including 1500 W and 2000 W lamps) and identified a range of efficacies and available design options, indicating the technological feasibility of standards for these lamps. In the interim LCC analysis and NIA, DOE preliminarily determined that standards for this wattage range could be economically justified and result in significant energy savings. For these reasons, DOE preliminarily determined that MH lamps with rated watta ges greater than or equal to 50 W and less than or equal to 2000 W should be considered for standards in the interim analysis.

In response to the interim analysis, NEMA and GE again commented that MH lamps

above 1000 W should be excluded because these tend to be niche products for specialty applications, and are characterized by low operating hours, relatively short lives, and high lumen output requirements. (NEMA, No. 24 at p. 6; GE, Public Meeting Transcript, No. 12 at p. 25) DOE reviewed catalog data for lamps between 1000 W and 2000 W, and tentatively determined that although lamps for special ty applications exist in this wattage range, the exemptions outlined

in section 2.3.2.8 effectively target those specialty lamps. In th is NOPD, DOE tentatively

determined that standards for non- exempt lamps in this wattage range could result in significant energy savings and are technologically feasible. As such, DOE analyzes the economic justification of standards for MH lamps between 1000 W and 2000 W in th is NOPD. DOE has also tentatively determined that standards for MH lamps with rated wattages greater than or equal to 50 W (and less than or equal to 2000 W) have potenti al for energy savings and are

2-8technologically feasible. As such, DOE also conducted a full economic analysis on these MH lamps in this NOPD to determine whether standards would be economically justified

.

In the framework document, DOE considered covering MV lamps with rated wattages greater than or equal to 50 W and less than or equal to 1000 W. In its review of MV lamps in catalogs, DOE found that less than one percent of MV lamps had rated wattages less than 50 W. Similarly, DOE found only two MV lamps with rated wattages higher than 1000 W. Given the small number of available products, DOE determined that these lamps do not present significant potential energy savings. Therefore, DOE considered analyzing only those MV lamps with rated wattages between gr eater than or equal to 50 W and less than or equal to 1000 W in the interim analysis. NEMA, GE, and Philips agreed with the wattage ranges for MV lamps. (NEMA, No. 11 at p. 3; GE, Public Meeting Transcript, No. 12 at p. 25; Philips, Public Meeting Transcri pt, No. 12 at p. 36)

In the interim analysis, DOE reviewed updated lamp catalog data, and reached the same conclusions about the wattage ranges considered for MV lamps in the framework document . As such, in the interim analysis, DOE preliminarily determine d to analyze MV lamps with rated wattages greater than or equal to 50 W and less than or equal to 1000 W.

DOE received no adverse comments relating to the wattages of MV lamps analyz ed in

the framework document and interim analysis. I n th is NOPD , DOE tentatively determined that standards for MV lamps with rated wattages greater than or equal to 50 W and less than or equal to 1000 W have potential for energy savings and are technologically feasible. As such, DOE also conducted a full economic analysis o n these MV lamps in this NOPD to determine whether standards would be economically justified.

In the framework document, DOE considered covering HPS lamps with rated wattages greater than or equal to 50 W and less than or equal to 1000 W. In its review of HPS lamps in catalogs, DOE found no HPS lamps with rated wattages higher than 1000 W. Given the absence of available products above 1000 W , DOE determined that this group of lamps does not present significant potential energy savings. Therefore, DOE considered including only those HPS lamps with rated wattages greater than or equal to 50 W and less than or equal to 1000 W in the framework document. In response to the framework document, NEMA, GE, and Philips agreed with the wattage range identified for HPS lamps. (NEMA, No. 11 at p. 3; GE, Public Meeting Transcript, No. 12 at p. 25; Philips, Public Meeting Transcript, No. 12 at p. 36)

In the interim analysis, DOE reviewed updated lamp catalog data, and reached the same conclusions about the wattage ranges considered for HPS lamps in the framework document . As such, in the interim analysis, DOE preliminarily determined to include HPS lamps with rated wattages greater than or equal to 50 W and less than or equal to 1000 W in the analysis. However

in th is NOPD

, because DOE tentatively determined standards for HPS lamps were not technologically feasible (see section 2.3.2.2 ), DOE does not conduct a full economic analysis on HPS lamps to determine whether standards would be economically justified.

In summary, in th is NOPD, DOE conducts a full economic analysis on standards for MV lamps with rated wattages between greater than or equal to 50 W and less than or equal to 1000 W, and MH lamps with rated wattages greater than or equal to 50 W and less than or equal to

2000 W.

2-92.3.2.2 Correlated Color Temperature

A defining characteristic of HID lamps is CCT. In general terms, the CCT is an approximation of the appearance of the light sour ce expressed in kelvin where lower values are considered warm white light and high values are considered cool white light. EPCA defines CCT as the absolute temperature of a blackbody whose chromaticity most nearly resembles that of the light source. (42 U.S.C. 6291 (30)(K)). HID lamps are available with a variety of CCTs, depending on lamp type and design. For example, DOE found that MV l amps range in CCT from 3200 K to 6800 K, while MH lamps rang e in CCT from 2500 K to 50,000 K.

During analysis for the framework document, DOE found that higher CCT lamps tend to be advertised for a specific application. For example, DOE found that nearly all MH lamps with a CCT between 10,000 K and 50,000 K were advertised as aquarium lamps, whereas MH lamps with a CCT between 7200 K and 9000 K were advertised as stage and studio lighting. In addition, DOE identified lamps with a CCT of 7000 K to be advert ised as horticulture lamps.

In the framework document, DOE did not consider standards for HID lamps with a CCT greater than or equal to 7000 K. These lamps represent less than five percent of all MH and MV lamps based on catalog availability, and were pred ominantly special application lamps (advertised for use in aquariums, stage and studio lighting, or horticulture). OSRAM SYLVANIA (OSI ) commented that the CCT range should not extend beyond 6000 K, because lamps at CCTs higher than that are for very specia lized applications, such aquarium lighting, and not for general lighting. (OSI, Public Meeting Transcript, No. 12 at p. 26; OSI, Public Meeting Transcript, No. 12 at p. 47)

For the interim analysis, DOE determined, based on a review of catalog data, that s ome of the 6000 K to 7000 K lamps are marketed for specialty applications ( e.g. , horticulture, stage and studio); however, a number of lamps in this CCT range are also advertised for general lighting applications. Because these CCTs also include lamps for general lighting , DOE

continued to consider standards for lamps with CCTs from 6000 K to 7000 K in the interim analysis. In summary, DOE considered covering MH and MV lamps with greater than or equal

to 2800 K to less than 7000 K CCT in the interim analysi s. Lamp catalogs show a large number of lamp offerings across these CCT ranges at a full range of efficacy , suggesting the potential for significant energy savings and the technological feasibility of standards.

In response to the interim analysis, NEMA c ommented that lamps with CCTs greater than 4500 K should be exempted from standards due to their small market share and limited number of products available. (NEMA, No. 24 at p. 2; NEMA, No. 24 at pp. 7-8) Available information indicates, however, that lam ps with greater than 4500 K and less than 7000 K CCT

do not represent a small market share and do not have a limited number of products available, as this CCT range shows a large number of lamp offerings. DOE reviewed lamp catalogs and tentatively determin ed that this CCT range represent s over ten percent of the MH lamp offerings and over 25 percent of MV lamp offerings , suggesting the potential for significant energy savings . Catalogs also showed a wide variety of efficacies, and that lamps of these CCTs share the same design options, indicating standards would be technologically feasible. As such, in the NOPD, DOE conducts a full economic analysis on standards for lamps with greater than 45 00 K

and less than 7000 K CCT.

2-10In response to the framework documen t, NEMA noted that there is little potential energy savings available for lamps from 1900 K – 2500 K, as the HPS lamps sold in this range are already some of the most efficient HID lamps available. If HPS lamps were removed from the market by standards, customers would be forced to switch to lower efficacy, white light lamps. (NEMA, No. 11 at p. 13) In the interim analysis, DOE also preliminarily determined that there were no commercially available options for HPS lamps below 2800 K that had improved

effica cy. DOE, however, modeled a technology option for HPS lamps using sapphire arc tube technology for improved efficacy in the interim analysis. See section 2.4.2.2 for details.

Commenting on the interim analysis, NEMA stated that HPS lamps (effectively defined as those with CCTs from 1900 K – 2700 K) should be excluded from consideration for

standards , due to their lack of technology options to achieve higher efficacies. NEMA also added that these lamps only operate during off -peak load times, and their long lifetimes present a testing burden. (NEMA, Public Meeting Transcript, No. 23 at pp. 30, 41, 55; NEMA, No. 24 at pp. 4, 6-7)

After considering the comments on the interim analysis, and additional feedback from manufacturer interviews, DOE tentatively determine s for this NOPD that sapphire arc tube technology should not be included as a technology optio n for increased efficacy in HPS lamps (see section 2.4.2.2 for further details). As a result, there were no technology o ptions for increasing the efficacy of HPS lamps, indicating standards for this lamp type was not technologically feasible. Therefore, in th is NOPD, DOE is not conducting a full economic analysis on standards for HPS lamps to determine whether standards wou ld be economically justified

.

In summary, in th is NOPD, DOE conducts a full economic analysis on standards for MV and MH lamps with CCTs greater than or equal to 2800 K and less than 7000 K. Further, DOE is not conducting a full economic analysis on standa rds for lamps with CCTs greater than or equal to 1900 K and less than 2800 K (effectively, HPS lamps).

2.3.2.3 Directional Lamps

Lamp light distribution is typically categorized as omnidirectional or directional. Omnidirectional lamps emit light in all directions with approximately equal intensity, whereas directional lamps use a secondary optical element ( e.g. , reflector, lens, refractor, light guide) or a

combination of element s to shape the light distribution into a particular pattern. In the test procedure SNOPR, DOE proposed “directional lamp” be defined as a lamp emitting at least 80 percent light output within a solid angle of π (pi) steradians (corresponding to a cone with an angle of 120°), including a reflector within the structure of the lamp. 79 FR 29631 (May 22, 2014)

In the framework document, DOE considered excluding directional HID lamps from

consideration for standards . Because each directional lamp provides a spec ific be am pattern, a larger number of directional lamp offerings are needed to meet all customer needs, a fact that manufacturers indicated explains their low shipment volume relative to their representation in catalogs. Given their small market share, DOE determined these lamps did not represent significant energy savings potential.

2-11In response to the framework document, NEMA and GE commented that they agree with these proposed exclusions. (NEMA, No. 11 at pp. 4, 6; GE, Public Meeting Transcript, No. 12 atp. 26) In contrast, CA IOUs suggested that HID lamps, including both directional and selfballasted lamps, comprise up to a quarter of the total market for directional lighting applications. For this reason, CA IOUs cited comments they provided to the HID lamps test procedure NOPR for establishing appropriate test procedures for these lamps, and commented that DOE should consider standards for directional HID lamps. (CA IOUs, No. 8 at p. 2) The Northwest Energy Efficiency Alliance (NEEA) commented that it would be premature of DOE to exclude directional lamps from the analysis based on catalog availability without looking at the shipment numbers to find the actual market share of directional HID lamps. NEEA additionally commented that directional lamps coul d replace omnidirectional lamps in fixtures for new installations that provide directionality of light source. If directional lamps are not covered by standards, it could lead to a market shift from omnidirectional to directional lamps. As such, NEEA urged DOE to include directional lamps in consideration for standards. (NEEA, No. 10 at p. 1) NEMA and GE agreed with directional lamps not being considered for standards. (NEMA, No. 11 at pp. 4, 6; GE, Public Meeting Transcript, No. 12 at p. 26)

By analyzing m anufacturer catalogs, DOE found that slightly less than 10 percent of available HID lamps are directional, though manufacturers indicated in interviews that the actual

market share is much smaller

– less than one percent. Given their small market share, DO E does not believe these lamps represent significant energy savings potential. Furthermore, the pattern of light distribution of these lamps makes them unacceptable replacements for omnidirectional lamps. While directional HID lamps may be a large portion of the directional lamp market, adoption of energy conservation standards could increase the price of these lamps or eliminate them altogether, thereby shifting the market towards less efficient incandescent lamps. Therefore, DOE did not considering standa rds for directional lamps in the interim analysis.

In response to the interim analysis, NEMA agreed with DOE on excluding directional lamps from consideration for standards. (NEMA, Public Meeting Transcript, No. 23 at p. 29)

DOE received no adverse comment s on the interim analysis, and continues to find that standards for directional HID lamps do not have the potential for significant energy savings and thus did not conduct a full economic analysis on standards for directional lamps in this NOPD

.

2.3.2.4 Self

- Ball asted Lamps

HID lamps can also be categorized by their ballast location ( i.e. , externally ballasted or

self

- ballasted lamps). The vast majority of HID lamps are operated with an external ballast

— meaning that the ballast is not located within the lamp body (socket and envelope). An external ballast can be located within the fixture or installed remotely from the fixture. If the ballast is integrated into the lamp, however, DOE refers to that lamp as “self

- ballasted.” In the test procedure SNOPR, DOE proposed to define self -ballasted lamps as a lamp unit that incorporates all elements that are necessary for the starting and stable operation of the lamp in a permanent enclosure and that do not include any replaceable or interchangeable parts. 79 FR 29631 (May 22, 2014)

In the framework document, DOE identified self- ballasted MH and MV lamps, but did

not identify self

- ballasted HPS lamps . In reviewing catalogs, DOE found that less than one percent of MH lamps were self

- ballasted, whereas about 17 percent of MV lamps were self

2-12ballasted. Self

- ballasted HID lamps are often used in applications that compete with incandescent technology. Self

- ballasted HID lamps have the advantage of increased efficacy and longer lifetimes relative to incandescent lamps, thereby decre asing maintenance costs. Given the

small number of available self -ballasted HID lamps, and the concern that customer s could switch

to incandescent technology if self- ballasted HID lamps were made unavailable or more expensive by standards, DOE does not bel ieve there is significant potential for energy savings by regulating these products. Therefore, DOE considered not including self- ballasted lamps in

consideration for standards in the framework document.

NEMA and GE agreed with self -ballasted HID lamps not being considered for standards. (NEMA, No. 11 at pp. 4, 6, 14; GE, Public Meeting Transcript, No. 12 at p. 26) To provide support for exclusion of self- ballasted lamps, OSI commented that self

- ballasted MV lamps are incandescent replacements that have very low shipment volume, while self

- ballasted MH lamps are halogen replacements that are only used in the niche market of retail. (OSI, Public Meeting Transcript, No. 12 at pp. 29-30)

NEEA and CA IOUs disagreed with n ot considering standards for self- ballasted lamps in

the framework document. NEEA commented that the market share of self

- ballasted HID lamps isincreasing as a result of utility incentive programs and a general market shift, and is causing selfballasted HID lamps to replace incandescent lamps. NEEA hoped to avoid the potential market

shift of the installation of self -ballasted lamps in new construction in lieu of externally ballasted lamps by including these lamps in consideration for standards . (NEEA, No . 10 at p. 2) CA IOUs indicated that HID lamps (including both directional and self -ballasted lamps) comprise up to a quarter of the total market for directional lighting applications. Because this represents a significant portion of the directional lamp m arket, CA IOUs suggested that self

- ballasted HID lamps should be considered for standards. (CA IOUs, No. 8 at p. 2)

In the interim analysis, DOE updated its market analysis . The results of the analysis

continued to show that these lamps hav e a market share of less than one percent , indicating that regulating self -ballasted HID lamps would not result in significant energy savings. While directional HID lamps may be a significant portion of the directional lamp market, as indicated by CA IOUs , they do not co nstitute potential for significant energy savings. All self

- ballastedMH lamps are directional, and would not be considered for standards for that reason. Selfballasted MH lamps are not commercially available in typical omnidirectional applications,

minim izing the risk of self- ballasted lamps serving as a substitute for regulated products. Furthermore, adoption of energy conservation standards could increase the price of these lamps or eliminate them altogether, thereby shifting the market towards less eff icient incandescent lamps. Given the lack of significant potential for energy savings by regulating these lamps, DOE preliminarily determined to exclude self

- ballasted lamps from consideration for standards in the interim analysis.

In response to the interim analysis, NEMA agreed with DOE on excluding self

- ballasted lamps from consideration for standards. (NEMA, Public Meeting Transcript, No. 23 at p. 29)

DOE received no adverse comments on the interim analysis, and continues to find that standards

for self -ballasted lamps do not have potential for significant energy savings. As such, DOE is not conducting a full economic analysis on standards for self

- ballasted lamps in this NOPD

.

2-132.3.2.5 Lamps Designed to Operate Exclusively on Electronic Ballasts

In its market re search, DOE found catalogs that indicated some HID lamps were designed to operate exclusively on electronic ballast s. In the framework document, DOE indicated that lamps designed to operate exclusively on electronic ballasts currently represent a small sha re of the HID market and therefore may not represent significant energy savings. DOE also noted there is no industry consensus test method for lamps designed to operate exclusively on electronic ballasts. At the time of publication of the framework documen t, the test procedure NOPR specified a magnetic reference ballast but not an electronic reference ballast. For these reasons, DOE considered not including lamps designed to operate exclusively on electronic

ballasts in consideration for standards in the framework document.

In response to the framework document, NEMA and GE agreed with not considering standards for lamps designed to operate exclusively on electronic ballasts. (NEMA, No. 11 at pp. 4, 6; GE, Public Meeting Transcript, No. 12 at p. 26) Addition ally, NEMA noted that certain newer lamp types intended for operation on electronic ballasts should be excluded from consideration for standards. (NEMA, No. 11 at p. 15) OSI commented that most of the electronic ballasts being developed right now are for the MH family and are typically very low wattage. OSI also noted that the speed with which electronic ballasts become adopted by the market might depend on the ballast efficiencies adopted in the metal halide lamp fixture ( MHLF ) rulemaking,

hereafter referr ed to as the 2014 MHLF rule. e (OSI, Public Meeting Transcript. No. 12 at pp. 27- 28) Philips commented that the adoption of lamps designed to operate exclusively on electronic ballasts will likely be slower because there is already a huge installed base with magnetic ballasts, so even as the market share for these lamps grows it will likely be small. (Philips, Public Meeting Transcript, No. 12 at p. 28)

NEEA noted that many ceramic metal halide ( CMH ) lamps can be operated only on electronic ballasts and that the market share of these lamps will likely increase significantly in

the future . NEEA urged DOE to include lamps designed to operate exclusively on electronic

ballasts in consideration for standards. (NEEA, No. 10 at p. 2) CA IOUs commented that they expect electronically ballasted HID systems, particularly those with CMH lamps, to be the dominant HID systems in the coming years because they offer a combination of controllability, efficacy, lamp life, and light quality that will compete with LEDs. CA I OUs also pointed out how they already offer rebate incentives to push the market towards pulse- start MH or CMH systems with electronic ballasts and some of these types of lamps are already common in Europe and are gaining popularity in the United States. (CA IOUs, No. 8 at p. 2) CA IOUs commented at the framework public meeting that within three to five years lamps designed to operate exclusively on electronic ballasts will represent a much larger share of the market. (CA IOUs, Public Meeting Transcript, No. 12 at p. 27)

In the framework document, DOE did not consider standards for these lamp types, primarily because of the absence of industry consensus test methods. For the interim analysis,

DOE preliminarily determined that an industry consensus test method was still absent, and that these lamps represent a small market share (less than one percent) based on feedback during

e T he final rule for the MHLF rulemaking was published in the Federal Register on February 10, 2014

. 79 FR 7745

. For more information on this rulemaking, see http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/16

.

2-14manufacturer interviews. DOE recognizes that a number of CMH lamps on the market are designated as for use with electronic ballasts onl y, and that CMH lamps have been a growing sector of the HID market. However, CMH lamps are among the most efficacious HID lamps commercially available, so they will likely be unaffected by potential standards. Because of this, DOE is not anticipating that this exclusion would allow customers to use less efficacious products not covered by standards. As a result, DOE did not consider energy conservation standards for HID lamps designed to operate exclusively on electronic ballasts in the interim analysis. f

In the interim analysis, NEMA stated that DOE should exclud e lamps designed to operate exclusively on electronic ballasts from consideration for standards. (NEMA, Public Meeting Transcript, No. 23 at p. 29) DOE received no further comments on the proposed exclusion of these types of lamps from consideration for standards. Upon revision of analyses, DOE continues to find that standards for lamps that operate exclusively on electronic ballasts do not have potential for significant energy savings. As such, DOE is not analyzing the economic justification of standards for lamps designed to operate exclusively on electronic ballasts in this

NOPD

.

2.3.2.6 High

- CRI Lamps

Typical CRIs for HID lamps are different depending on lamp type. For example, the typical CRI for HPS la mps is lower than the typical CRI for MH lamps. What is considered high

CRI for HPS lamps differs from what is considered high -CRI for MH lamps. For that reason, DOE separates the lamp types when discussing the potential exclusions for high- CRI lamps.

High

- CRI HPS Lamps . In the framework document, DOE did not identify high- CRI

HPS lamps as a category to be exempted from energy conservation standards. In written comments on the framework document, NEMA noted that less efficacious and higher CRI HID

sources a re needed for some applications. (NEMA, No. 11 at p. 20) In the framework public meeting, GE recommended that DOE exclude high- CRI, low

- CCT lamps from consideration for

standards ( e.g. , HPS lamps with higher than typical CRI ). (GE, Public Meeting Transcript, No. 12 at p. 26) GE noted that there is a unique utility to the high- CRI HPS lamps. While they still have a very large yellow component to their emitted light, they provide a high CRI at a very low chromaticity. GE said they are a niche product used in few applications, mostly specialty outdoor applications, architecture, or landscape designer use, and DOE should consider exempting them

from consideration for standards. (GE, Public Meeting Transcript, No. 12 at p. 26 and pp. 30-31) NEEA responde d that it is not clear what the application is for these high -CRI, low- CCT lamps. However, NEEA commented that if DOE found these lamps provide distinct consumer utility and cannot achieve the same efficacy as other HID lamps, a separate equipment class ma y be warranted, but an exemption from standards is not necessarily justified. (NEEA, No. 10 at p. 2)

For the interim analysis, DOE investigated high-CRI lamps. During interviews, manufacturers indicated the market share of high

- CRI HPS lamps is less than o ne percent of the total industry HPS lamp shipments and thus would not have potential for significant energy savings. However, if these lamps were excluded and DOE were to establish a minimum efficacy

f DOE notes that it can still analyze an EL generally only met by CMH lamps, but it would base that level on CMH lamps that are not electronic

- ballast

- only lamps.

2-15for HPS lamps that would exceed the efficacy of high- CR I HPS lamps, there is the possibility that the market could shift to the unregulated, high-CRI HPS lamps. While high- CRI HPS lamps would provide reduced light output for a given wattage, customers may prefer the high- CRI HPS lamps due to the possibility of the unregulated lamp being offered at a lower cost (relative to a

standard

- compliant, traditional HPS lamp) and their compatibility with existing HPS ballasts and fixtures. Because alternative high -CRI lamp technologies exist in the wattage and CCT ranges under consideration, and to ensure the realization of energy savings associated with adopted standards, DOE preliminarily determined in the interim analysis that these lamps should be

considered for standards.

In response to the interim analysis, DOE did not receive further comment about considering high

- CRI HPS lamps for standards. In this NOPD, DOE has tentatively determined that standards for HPS lamps are not technologically feasible (see section 2.3.2 ). As such, DOE is not conducting a full economic analysis on standards for HPS lamps (including high- CRI HPS lamps ) to determine whether standards would be economically justified.

High

- CRI MH Lamps

. In the framewo rk document, DOE did not identify high- CRI lamps as a category to be exempted from energy conservation standards. NEMA comment ed that less efficacious and higher CRI HID sources are needed for some applications. (NEMA, No. 11 at p. 20)

For the interim anal ysis, DOE observed that MH lamps are available with CRI values up to 100, though a typical value for a pulse-start quartz MH lamp is about 65. The highest CRI MH lamps, those with CRI values greater than or equal to 95, utilize pulse- start (quartz and cera mic) technology. These high

- CRI pulse -start MH lamps are predominantly offered by one company (over 80 percent of product offerings for pulse- start MH lamps with CRI values greater than or equal to 95), indicating that these products are intended for a low volume, niche market. For this reason, DOE believes that high- CRI pulse

- start MH lamps do not have potential for significant energy savings. DOE notes that pulse- start MH lamps with CRI values greater than or equal to 95 often exhibit lower efficacy than other pulse-start MH lamps. If DOE did not establish

standards for high- CRI pulse

- start MH lamps but established a minimum efficacy for other MH lamps that exceeded the efficacy of high

- CRI pulse

- start MH lamps, DOE finds it unlikely that the market would shift to the unregulated, high- CRI pulse

- start MH lamps. High

- CRI pulse

- start MH lamps are not likely to be a low cost substitute for standards- compliant lamps, because a high- CRI MH lamp is not currently a cost -saving option. Furthermore, for certain standard levels, transitioning to a high

- CRI pulse

- start lamp could require a purchase of a new pulse

- start ballast and fixture. Because of their small market share and limited potential for energy savings, DOE did not consider standards for pulse- start MH lam ps with CRI values greater than or equal

to 9 5 CRI in the interim analysis.

In response to the interim analysis, NEMA and the Edison Electric Institute ( EEI ) supported high-CRI product exemptions to parallel the GSFL rulemaking. (NEMA, Public Meeting Transcript, No. 23 at p. 19; EEI, Public Meeting Transcript, No. 23 at pp. 20-21) NEMA, however, suggested defining high- CRI lamps as greater than 87 CRI, instead of greater than 95 CRI, to harmonize with the GSFL rulemaking. (NEMA, Public Meeting Transcript, No. 23 at p. 19, 29; NEMA, No. 24 at pp. 2-3, 8)

2-16DOE reassessed its analysis o f high- CRI MH lamps and found lamps available between 87 and 95 CRI that met the highest ELs in this analysis, indicating that even the highest standards analyzed would not e liminate the utility of high- CRI lamps . DOE determined a CRI of 95 to be the threshold point to preserve high-CRI lamp products in the market, based on the observation that MH lamp efficacy decreases significantly at and above a CRI of 95. Additionally, DO E tentatively determined that the 87 CRI threshold in the GSFL rulemaking is specific to that technology and the effects of different phosphor mixes on efficacy and CRI. In

this NOPD, DOE tentatively determined that standards for high

- CRI MH lamps (CRI gre ater than or equal to 95) do not have potential for significant energy savings. As such, DOE is not conducting a full economic analysis on high-CRI MH lamps to determine whether standards for these lamps would be economically justified.

2.3.2.7 Colored MH Lamps

D OE found a small number of HID lamps that were advertised as colored lamps ( e.g. , blue, green, orange, and magenta). For the framework document, DOE identified these lamps only with MH technology, representing about one percent of MH product offerings. The small market share and the unavailability of more efficacious substitutes for colored MH lamps indicate a lack of potential for significant energy savings. Additionally, colored MH lamps are

not suitable substi tutes for non- colored MH lamps.

In response to the framework document, NEMA commented that colored HID lamps are most commonly used for entertainment purposes, not general lighting, and have very limited sales and very low operating hours. (NEMA, No. 11 at p. 4) BLV Licht und Vakuumtechnik GmbH (BLV) commented that the potential standards should be limited to white light lamps only, similar to European standards. BLV commented that white lamps could be defined with limits around the black body curve. g Specialty lamps that would not fit in this definit ion include: ultraviolet ( UV )- source lights for water disinfection; tanning; UV curing; lamps for aquatic systems; and colored lamps for special environmental conditions. The consumer utility of these lamps is driven by application and not efficacy, and for this reason, BLV recommended that only white light MH lamps should be included in consideration for standards. (BLV, No. 4 at p. 1) NEMA and GE agreed with colored lamps not being considered for standards. (NEMA, No. 11 at pp. 4, 6; GE, Public Meeting Transcript, No. 12 at p. 26)

In the interim analysis, DOE preliminarily determined that colored HID lamps are predominantly MH lamps and considered colored MH lamps for exclusion. DOE considered defining colored MH lamps by adopting the European Union’s (EU) definition of white light, which sets chromaticity requirements based on coordinates of the CIE 1931 chromaticity diagram. However, DOE preliminarily determined that a colored MH lamp could be effectively defined as having a CRI less than 40. DOE received no adverse comment about the exclusion of colored MH lamps and did not consider them for energy conservation sta ndards in the interim analysis.

In the interim analysis, NEMA stated that DOE should not consider standards for colored

MH lamps. (NEMA, Public Meeting Transcript, No. 23 at p. 29) Additionally, NEMA

g A black body curve is a graphic of the energy density of a black body for a continuous range of wavelengths in the blackbody spectrum, at specific temperatures.

2-17recommended the adoption of the EU definition of white light in harmonization with international standards. (NEMA, Public Meeting Transcript, No. 23 at p. 23; NEMA, No. 24 at p. 3)

For this NOPD , DOE received no adverse comments to the exclusion of colored MH lamps and still finds that the small market share and the unavailability of more efficacious substitutes for colored MH lamps indicate a lack of potential for significant energy savings . As

su ch, DOE is not conducting a full economic analysis on colored MH lamps to determine whether standards would be economically justified. DOE reviewed market data for colored MH lamps, and tentatively determined that the CRI definition (<40 CRI) for colored M H lamps targets the same group of lamps that fall within the EU’s definition of white light. The EU definition uses xy-chromaticity coordinates in its definition, and this information is not available in lamp catalogs for DOE to assess the market availabil ity of these lamps. For this reason, in this

NOPD DOE continues to define colored MH lamps as those with a CRI less than 40

.

2.3.2.8 Lamps for Specialty Applications

EPCA bans the sale of MV lamp ballasts, but exempted ballasts for certain specialty applications, such as quality inspection, industrial processing, or scientific use. (42 U.S.C. 6295(ee)) In the framework document, DOE did not consider standards for MV lamps operated by these ballasts. In an effort to identify lamps that require exemptions from standa rds, DOE also requested comment on whether lamps for specialty applications have defining characteristics that differentiate them from lamps used for general illumination purposes.

In response to the framework document, DOE received comments from stakehold ers to aid in defining specialty application lamps, including MV and MH lamps . NEMA commented that specialty application lamps should be defined as HID lamps with bases other than medium, medium skirted, or mogul screw bases. For MV lamps, these applications would include front end projectors, rear projection televisions, video and data projection, medical, photometry, photofinishing, microscopy, reprography, industrial curing, photo- polymerization (UV curing), integrated circuits (microchips), microlithography, liquid crystal displays (LCD), printed circuit boards (PCB), wafer cleaning and other applications. For MH lamps, these applications would include film and TV production, stage lighting, theater, concerts, club & disco lighting, architectural lightin g, entertainment lighting, exhibition lighting, spotlights and attraction lighting, sports stadium lighting, solar simulation, professional and high speed photography,

fiber optic illumination systems, UV curing, horticulture, aquarium lighting, and other uses. OSI suggested that specialty application MV lamps could be labeled and sold only for the specially applications, similar to how the ballasts are currently sold. (OSI, Public Meeting Transcript, No. 12 at p. 36) NEMA also commented that there are also specialty applications for medium, medium skirted and mogul screw- base d lamps. These include inspection, UV curing, masking, silk screening, blacklight, counterfeit detection and purification systems for clear MV lamps as well as high

- CRI HPS, horticultur al and aquarium lighting.

DOE determined that specialty application lamps should not be defined by screw base

type because there are a number of HID lamps in the market that do not have medium, medium skirt, or mogul screw bases and are used for general li ghting ( e.g. , CMH lamps with bi-pin bases). Therefore, in the interim analysis, DOE preliminarily determined that these kinds of nonscrew

- base d general lighting lamps should be considered for standards.

2-18In response to the framework document, NEMA also commented that all of the lamps in these specialty applications are low volume and provide little opportunity for energy savings. (NEMA, No. 11 at p. 5) OSI also commented that specialty applications include plant growth and aquarium lighting because they each are designed to give light output in specific parts of the color spectrum, which makes them less useful in general lighting applications. (OSI, Public

Meetin g Transcript, No. 12 at pp. 33, 35) EEI commented that because specialty application MV

fixtures will be greatly limited in their annual use compared to other general lighting HID fixtures, the payback period for increased efficacy for specialty application MV lamps would be very long. For that reason, EEI supported removing specialty application MV l amps from consideration for standards. (EEI, Public Meeting Transcript, No. 23 at pp. 24-25)

In the interim analysis, DOE considered excluding from energy conservation standards MV lamps individually labeled for specialty application, incl uding the intende d application. DOE reasoned that MH lamps for specialty applications were appropriately addressed by other exemptions ( e.g. , the CCT range under consideration for standards). DOE requested comment on whether MV lamps for use in specialty applications could be sold with a specialty application

label.

In response to the interim analysis, NEMA commented that specialty lamps could not be labeled for their intended application. NEMA commented that manufacturers have limited to no knowledge of the end user of these lamps, or the intended application, so the label cannot be a determining factor for exemption from standards. (NEMA, Public Meeting Transcript, No. 23 at pp. 25-27; NEMA, No. 24 at p. 3) NEMA also provided DOE with a non- exhaustive list of specialty a pplications that should be exempted from standards: UV curing, photoprinting, pet, aquarium, aquaculture, solar panel processing, materials testing, horticulture, high- definition television, sports, film, institutional and educational, R&D, and stage and t heater lamps. (NEMA, Public Meeting Transcript, No. 23 at pp. 30-31; NEMA, No. 24 at p. 4) Additionally, CA IOUs also recommended creating a definition for specialty lamps that will prevent their use in non-specialty applications. (CA IOUs, No. 26 at p. 8) CA IOUs suggested DOE to consider using measurements of the spectrum of light ( i.e. , spectral power densities) provided by different types of specialty lamps, as a metric to define and distinguish them from lamps for general lighting purp oses. (CA IOUs, N o. 26 at p. 8)

DOE acknowledges that using labeling requirements as a means of exemption would not be an effective way to characterize the end -use application of a particular lamp. DOE also determined that any exemption for specialty lamps should not encou rage their use in non

specialty applications. DOE reviewed HID lamp catalogs and identified various types of MV and MH specialty lamps, including those listed by NEMA. DOE tentatively determined that although some lamps used in specialty applications have unique photometric properties, spectral power density (SPD) data is not available for all lamps in catalogs, and as such, DOE cannot create a definition for specialty lamps using an SPD metric. DOE reviewed the identified specialty lamp categories to deter min e if standards for such lamps were technologically feasible.

DOE reviewed horticulture lamps in catalogs and observed that these lamps are predominantly available in HPS and MH technologies. In th is NOPD , DOE is not conducting a full economic analysis t o determine the economic justification of standards for any HPS lamps (see section 2.3.2 ), including HPS horticulture lamps . MH horticulture lamps are available wit h

2-19greater than 2800 K CCTs and are characterized by their optimized light output in the blue light region of their SPDs. DOE found similar CCT, CRI, and wattage availabilities in MH horticulture lamps a nd MH lamps used in general illumination, and tentativ ely determined that the only advertised difference of MH horticulture lamps is an optimized light spectrum. However, the light spectrum varies from lamp to lamp, and no one factor is used in lamp datasheets to differentiate horticulture lamps from general use lamps. Many MH horticulture lamps have CCT s greater than 7000 K, which is a CCT range not under consideration for standards. In considering standards for MH lamps, DOE cannot distinguish between 2800 K

– 7000 K lamps that are used for horticulture versus 2800 K – 7000 K lamps used for general lighting based on the spectral power distribution. Furthermore, some horticulture lamps in this CCT range are also labeled for general lighting. Finally, DOE found 2800 K – 7000 K lamps

labeled for horticulture are capable of reaching the highest ELs analyzed in this NOPD

, indicating standards would not eliminate this utility from the market. For these reasons, DOE decided that standards for MH lamps used for horticulture are technologically feasible and could result in significant energy savings and is thus considering the economic justification of standards for these lamps in the economic analysis in this NOPD.

DOE reviewed aquarium lamps in catalogs and characterized these lamps as having CCTs ranging from 30 00 K to 50,000 K. A quarium lamps with CCTs greater than or equal to 7000 K (a CCT range not under consideration for standards) are exclusively labeled for aquarium applications, and are advertised for their deeper light penetration in water. DOE observed that aquarium lamps with CCTs less than 7000 K were cross-listed with general lighting applications, and shared similar CCT, CRI, and wattage availabilities as lamps used in general lighting applications. Furthermore, DOE found 2800 K – 7000 K lamps labeled for aquarium use are capable of reaching the highest ELs analyzed in this NOPD , indicating standards would not eliminate this utility from the market. For these reasons, DOE determined that standards for MH lamps used for aquariums are technologically fea sible and could result in significant energy savings and is thus considering the economic justification of standards for these lamps in the economic analysis in this NOPD.

DOE also researched several other lamp categories. DOE reviewed pet lamps in catalogs and found that these lamps are all either directional or self

- ballasted; for the reasons stated in sections 2.3.2.3 and 2.3.2.4, DOE is not considering the economic justification of standards for these lamps in the econom ic analysis in this NOPD. DOE also reviewed high-definition

television (HDTV) lamps in catalogs and tentatively determined these are HID lamps with high CRIs used to provide the best possible viewing quality to spectators. These HDTV lamps reach the highes t levels of efficacy analyzed in this NOPD, so DOE considers the economic justification of standards for these lamps in the economic analysis. DOE came to a similar conclusion regarding lamps for sports lighting. Because these lamps are able to reach the highest levels of efficacy, DOE considers the economic justification of standards for lamps for sports lighting in the economic analysis. DOE also identified some directional specialty lamps used in light-focusing applications ( e.g. , endoscopy, fiber optic applications). DOE is not, however, considering the economic justification of standards for these lamps because of their directional qualities.

In this NOPD , DOE characterized other specialty applications that would require exemptions based on their unique utility and inability to meet the highest EL s considered in the

2-20engineering analysis. DOE categorized these specialty lamps into two groups: MV lamps for specialty applications, and entertainment lamps , which are discussed in detail below.

MV Lamps for Sp ecialty Applications

. DOE requested comment in the framework document on whether specialty applications relevant to MV technology can be served by HPS or MH technology. In the framework public meeting, DOE received numerous comments from stakeholders that supported the exclusion of MV specialty lamps from consideration for standards. NEMA commented that specialty applications for MV lamps could not be served by MH or HPS lamps due to the need for the UV light that MV lamps can produce. (NEMA, Public Meeting Transcript, No. 12 at p. 32) NEMA also noted that while LEDs may eventually replace MV technology in many applications, the required level of UV light in certain applications exceeds the capability of solid

- state lighting ( SSL ) substitutes at this time. MV lamps produce a much higher amount of UV light in a smaller package. NEMA also notes that specialty MV lamps are often used on exempted ballasts that are labeled for specialty application use only. (NEMA, No. 11 at p. 5) OSI commented that that UV output in LEDs is limited and not sufficient for applications using MV lamps for UV output. (OSI, Public Meeting Transcript, No. 12 at p. 35) OSI also pointed out that MV ballasts were banned by the Energy Independence and Security Act of 2007 (Pub. L. 110-140 ; EISA 2007) , except ballasts for specialty applications, which are still available if they are properly labeled as such. OSI recommended somethi ng similar should be considered for clear MV lamps used in UV curing and inspection applications to exclude them from consideration for standards. (OSI, Public Meeting Transcript, No. 12 at pp. 26-27, 35-36) OSI, however, cautioned that there are some diff iculties defining specialty MV lamps. Clear MV lamps with medium screw bases, mogul screw bases, and medium skirted screw bases are all used in outdoor illumination, but also have utility as UV curing and for inspection purposes. These specialty application lamps would need to be very closely defined or labeled to allow for the use of these lamps in the UV curing and inspection applications. (OSI, Public Meeting Transcript, No. 12 at pp. 33-34) NEMA and GE agreed with MV lamps for specialty applications not being considered for standards. (NEMA, No. 11 at pp. 4, 6; GE, Public Meeting Transcript, No. 12 at p. 26)

In the interim analysis, DOE did not consider standards for MV lamps individually labeled for specialty application to preserve the market presence of the lamps intended for use

with specialty application MV ballasts. With respect to the concerns about how to accurately define specialty applications to allow their continued use in specialty applications but not general lighting, DOE requested input on using the specialty application label to determine this exclusion

from standards.

In response to the interim analysis, NEMA agreed with DOE on excluding specialty MV lamps ; however, NEMA disagreed with the assertion that these lamps are currently labeled for their intended applications. (NEMA, Public Meeting Transcript, No. 23 at pp. 25-27, 29) In

contrast, CA IOUs suggested DOE evaluate the ability of MH lamps to be used in specialty applications, and recommend ed exempting only MV lamps whose application s cannot be served by MH lamps. (CA IOUs, No. 26 at p. 8)

In this NOPD, DOE investigated methods to remove them from consideration for

standards based on technical characteristics . DOE reviewed lamp catalogs along with NEMA’s list of specialty lamps, and identified several specialty applications in which MV lamps are used,

2-21such as quality inspection, material testing, industrial processing, scientific uses ( e.g. , fluorescent microscopy), and UV curing. Based on their reduced UV output, DOE tentatively dete rmined that MH technology cannot act as a direct substitute for MV technology in applications where high levels of UV light are required. Without higher efficacy replacements, standards for MV lamps for specialty applications are not technologically feasib le. DOE considered using a UV intensity metric to ex clude this group of lamps from consideration for standards; however, this data is not usually available in catalogs. DOE analyzed common characteristics of lamps listed specifically for specialty MV lamps , including those used in UV applications, and created an exemption that targets this group of lamps based on these characteristics. DOE observed that some of these lamps are directional, and as such, DOE is not considering the economic justification of st andards for these lamps in the economic analysis . DOE tentatively determined that these lamps are typically double-ended, do not have screw bases, and have no outer bulb. These types of lamps are used exclusively for specialty, UV

- related applications and not general lighting.

In this NOPD, DOE does not consider the economic justification of standards for MV lamps used in specialty applications. DOE tentatively determines to define this exemption as MV lamps that are double- ended and do not have a screw base h or an outer bulb.

Entertainment Lamps. Another category of specialty application lamps includes those that serve the entertainment industry. In response to the interim analysis, NEMA provided DOE with a list of specialty lamps that included film, st age, and theater lamps primarily served by MH technology. (NEMA, Public Meeting Transcript, No. 23 at pp. 30-31; NEMA, No. 24 at p. 4) DOE reviewed specialty lamp catalogs and observed a family of HID lamps predominantly used in the entertainment sector, w hich is typically advertised as lamps for stage, theater, studio, film, and daylight simulation applications, among others (hereafter referred to as entertainment lamps). Entertainment lamps are characterized by short arc gaps and have a more compact desig n and enhanced optics control. OSI commented in response to the framework document that these lamps have short arc tubes and short arcs that yield more precise optical control and high internal pressures. Often they have short usable life due to the combination of small size, high lumen output, and low lumen maintenance. (OSI, Public Meeting Transcript, No. 12 at pp. 32-33)

DOE tentatively determined that although some of these entertainment lamps share similar photometric properties with those used in gene ral lighting purposes, their dedicated optics and shorter lifetimes render them inadequate replacements for general illumination. DOE tentatively determined that because entertainment lamps have a unique utility , and do not meet the highest ELs that some general lighting HID lamps meet , standards for these lamps would not be technologically feasible. DOE sought out a set of criteria that would exempt lamps exclusively advertised for use in entertainment applications that have the short arcs, short

lifetimes , and lower efficacy indicative of this lamp type. I n th is NOPD , DOE does not consider the economic justification of standards for entertainment lamps , defined as HID lamps that have

CCTs of 5000 K – 6999 K, do not have a screw base, 5 and have non-T-shaped bulbs. i

h As defined by ANSI C81.61

- 2009

– Specifications for bases (Caps) for Electrical Lamps

. i As defined by ANSI C79.1

- 2002

– Nomenclature for Glass Bulbs Intended for Use with Electric Lamps

.

2-222.3.2.9 Electrodeless Lamps

In the framework document, DOE found that manufacturers offer “electrodeless” HID lamps, which are also referred to as “light

- emitting plasma” (LEP) lamps. These lamps emit light in a process related to conventional HID lamps, and initial research indicates that the gas composition of electrodeless lamps might be mo st similar to MH lamps. DOE requested comment in the framework document on whether electrodeless HID lamps could be considered a subcategory of MV, HPS, or MH lamps.

Venture Lighting International (Venture ) commented that an electrodeless lamp is a new lamp technology that is powered by radio frequency energy to heat the gas for the emission of light. Venture also commented that only a few companies are manufacturing t he lamps, and that Venture cannot predict where the market will go. (Venture, Public Meeting Transcript, No. 12 at pp. 21- 22) GE stat ed that electrodeless lamps are a niche product

, and there is limited investment in the technology. (GE, Public Meeting Transcript, No. 12 at p. 22) NEMA stated that electrodeless HID lamps are most similar to MH lamps, but are not a subgroup of MH lamps. Electrodeless lamps have no ANSI standards and there are none currently being developed. (NEMA, No. 11 at p. 3) NEMA furthe r commented that electrodeless HID lamps are not a proven technology and currently have very low market share. (NEMA, No. 11 at p. 16) NEMA also pointed out that electrodeless lamps operate on electronic ballasts, which meant they would potentially be exem pted from standards because DOE was considering exempting lamps that could operate only on electronic ballasts. (NEMA, Public Meeting Transcript, No. 12 at p. 23) NEMA and GE agreed with electrodeless HID lamps not being considered for standards. (NEMA, No . 11 at pp. 4, 6; GE, Public Meeting Transcript, No. 12 at p. 26)

In the interim analysis, DOE preliminarily determined that electrodeless HID lamps meet the definition of an HID lamp. (42 U.S.C. 6291(46)) Electrodeless HID lamps generate light through a process similar to that in other HID lamps, but couple power to the arc tube through means other than electrodes. Based on comments received in response to the framework document, the lighting industry generally considers electrodeless HID lamps to be a separate lamp technology, and not a subset of HID lamps. However, DOE preliminarily determined that the definition of HID lamp does not make a distinction between lamps that do or do not have

electrodes. j The definition of HID lamp has four specifications: (1 ) the arc tube wall loading is in

excess of three W /cm 2 ; (2) the light -producing arc is stabilized by the arc tube wall temperature; (3) the lamp is either a MV, HPS, or MH lamp; and (4) the lamp is an “electric

- discharge lamp.” Electrodeless HID lamps mee t both the first and second criteria based on the high power density contained in the gaseous chamber. Regarding the third criteria, electrodeless HID lamps have a similar gas mixture to and produce light in the same manner as MH lamps, and meet the EPCA

d efinition of a MH lamp. For the fourth criteria, the term electric -discharge lamp is not defined in DOE’s regulations. DOE did not find an industry definition of this term, so DOE reviewed industry’s usage of “electric

- discharge lamp” in available technical literature. Based on this review, DOE considered an electric

- discharge lamp to be any device that uses a flow of electric charge in a gas to generate visible light through collision of charged particles and possibly other processes. Electrodeless HID lam ps use this mechanism for generating light, and therefore meet

j See chapter 3 of the interim analysis TSD for further discussion of the electrodeless HID lamps’ definition,

available at http://www.regulations.gov/#!documen tDetail;D=EERE

- 2010

- BT

- STD

- 0043

- 0016

.

2-23the fourth specification of an HID lamp. Thus, DOE determined preliminarily that “electrodeless HID lamps” meet the definition of an HID lamp.

Although DOE considers electrodeless HID lamps to be a type of HID lamp, electrodeless HID lamps have very small market share (less than one percent) and do not have an industry consensus test method. DOE has evaluated this information and did not consider standards for electrodeless HID lamps in the int erim analysis. DOE requested comments regarding this determination and whether additional information is necessary to define this

exclusion.

In response to the interim analysis, NEMA agreed with DOE on excluding electrodeless HID lamps from consideration for standards. (NEMA, Public Meeting Transcript, No. 23 at p. 29; NEMA, No. 24 at p. 4) DOE received no further comments on the decision to remove electrodeless HID lamps from consideration for standards or the definition under consideration in

the interim analysis. For this NOPD, DOE found that electric -discharge lamp is defined in

ANSI/IES RP -16- 2010 as a lamp in which light (or radiant energy near the visible spectrum) is produced by the passage of an electric current through a vapor or a gas. Electrodele ss HID lamps use this mechanism for generating light, and therefore DOE still finds that they meet the fourth specification of an HID lamp. Thus, DOE tentatively determines that “electrodeless HID lamps”

meet the definition of an HID lamp in this NOPD

. However, DOE again notes the small market share of electrodeless HID lamps (indicating standards for them do not have potential for significant energy savings), as well as the lack of an industry consensus test method for these lamps. As such, DOE does not consider the economic justification of standards for electrodeless HID lamps in th is NOPD

.

2.3.2.10 F- rated Lamps

In the interim analysis, DOE noted that in addition to the luminaire characteristics of open-rated and enclosed-rated, another category exists for F-rated lamps. DOE did not, however, find any F- rated lamps available in its review of manufacturer catalogs. In the interim analysis, DOE requested comment on the applications of F-rated lamps, and how they should be categorized within DOE’s analysis.

In res ponse to the interim analysis, NEMA commented that F -rated lamps are doubleended lamps that require an enclosed luminaire to meet industry safety standards for containment in the event of lamp rupture, and to provide a UV attenuation barrier and lens inte rlock because the lamps have no outer jacket. (ANSI C78.380- 2007) NEMA also explained that because the effective actinic UV output of these lamps exceeds 6 mW/klm, special equipment is required for photometric testing. These specialty lamps represent 1 -2 p ercent of the total HID lamps sold in the United States, and there are no technology alternatives to these lamps. The typical applications are stadium lighting, stage lighting, and studio/film lighting. For these reasons,

NEMA stated that F

- rated lamps sho uld be excluded from consideration for standards . (NEMA, Public Meeting Transcript, No. 23 at p. 40; NEMA, No. 24 at p. 6-7)

Through NEMA’s comments and the manufacturer interviews conducted for this NOPD

, DOE found that F

- rated lamps consist exclusively o f double-ended lamps with wattages greater

than 1000 W that are primarily used in stadium applications. S everal of these F

- rated lamps currently found on the market meet the highest ELs analyzed in the NOPD for wattages greater

2-24than 1000 W. As discussed in section 2.3.2.1 , standards for lamps with rated wattages greater than 1000 W have potential for significant energy savings and are also technologically feasible.

A s such, DOE also conducted a full economic analysis on these lamps in this NOPD to determine whether standards would be economically justified.

2.3.2.11 Summary

For th is NOPD, DOE considers the economic justification of standards for MH lamps with rated wattage s of greater than or equal to 50 W and less than or equal to 2000 W, and MV lamps with rated wattage s of greater than or equal to 50 W and less than or equal to 1000 W. Within those wattage ranges, DOE is analyzing standards for MH lamps with CCTs greater than or equal to 2800 K and less than 7000 K, and MV lamps with CCTs greater than or equal to 3200

K and less th an or equal to 6800 K. Table 2.3.1 provides a summary of the wattage and CCT ranges analyzed in this NOPD

.

Table 2.3.1 CCTs and Wattages Analyzed in NOPD

Lamp Type Range Covered

Wattage

W MV 50

- 1000

MH 50

- 2000

CCT

K MV 3200

- 6800

MH 2800

- 6999

Because DOE determined that standards for the following lamp types are either not technologically feasible or would not result in significant energy savings, DOE does not include these lamp types in the economic analysis in this NOPD : directional HID lamps ; self

- ballasted HID lamps; lamps designed to operate exclusively on electronic ballasts; high- CRI lamps (greater than or equal to 95 CRI); colored MH lamps (less than 40 CRI); MV lamps that are double-ended, do not have a screw base, and have no outer bulb; HID lamps that have a CCT of 5000 K – 6999 K, do not have a screw base, and have non-T- shaped bulbs; and electrodeless HID lamps.

2.3.3 Combined Rulemakings

In the framework document, DOE asked for comment on how to best coordinate th is HID lamp rulemaking an d the 2014 MHLF rule. DOE discussed plans to publish separate NOPRs for the two rulemakings, but to coordinate the development of the final rules for HID lamps and

MHLF s.

NEMA agreed with DOE that the two rules should not be combined, as they must be

maint ained separately due to the myriad combinations of products. Additionally, the reporting of products that fall under a combined standard would be unnecessarily confusing and challenging. (NEMA, No. 11 at p. 2) NEMA also asked that DOE remember that the 201 4 MHLF rule impacts new fixture installations, while this HID rulemaking impacts both new fixture installations as well as the replacement lamp market. Additionally, NEMA mentioned that the

2014 MHLF rule does not impact the ballasts used in HPS luminaires , and the MV ballasts do

2-25not need to be considered because they have already been eliminated by federal legislation. (NEMA, No. 11 at p. 2; NEMA, Public Meeting Transcript, No. 12 at p. 18)

For the interim analysis, DOE continued to use shared data sources between the two rulemakings and completed the HID interim analysis separately from the 2014 MHLF rule. DOE continued with the same approach for th is NOPD , analyzing the potential HID lamp standards separately from those for MHLFs. DOE’s analysis of HID lamps assumes that MHLFs purchased

after the February 10, 2017 compliance date of the 2014 MHLF rule use ballasts compliant with those adopted standards , hereafter referred to as the 2017 MHLF standards.

2.3.4 Metric

In considering energy conservation standards for HID lamps, DOE must select a metric for rating the performance of the lamps. In the framework document, DOE considered a number of potential metrics for the energy conservation standards of HID lamps. DOE discussed initial lamp efficacy and input wattage as the metric for setting standards for HID lamps. DOE also considered using center

- beam candlepower (CBCP) and beam lumens per watt to characterize the beam of directional lamps. Because dimming is uncommon for HID lamps, DOE planned to assess products operating at full light output, not at a reduced light output or dimmed state. In the framework document, DOE requested comment on lamp efficacy as a potential metric for

omnidirect ional lamps and on developing a center- beam intensity metric related to directional lamps.

2.3.4.1 Initial Efficacy

NEMA agreed with DOE’s approach of using initial lamp efficacy and plans to assess products while operating at full light output. (NEMA, No. 11 at p. 9) NEMA also commented that the regulatory metrics for HID lamps should be based on laboratory measurements under carefully controlled reference conditions. (NEMA, No. 11 at p. 2) OSI also agreed with using initial lumen output as a metric, measuring aft er 100 hours of operation so the lamp achieves stability. (OSI, Public Meeting Transcript, No. 12 at p. 39) NEMA stated that in response to the

HID lamp test procedure NOPR (December 15, 2011, 76 FR 77914), DOE should use the definition of lamp efficacy in RP -16. NEMA subsequently commented that the IES does not use the term lamp efficacy in RP

- 16, and suggested DOE instead use lamp luminous efficacy as a metric, measured after 100 hours of operation for initial values. (NEMA, Public Meeting Transcript, No. 12 at pp. 39-40; NEMA, No. 11 at p. 9)

NEEA and CA IOUs commented that DOE should use the metric mean lamp efficacy rather than initial lamp efficacy. Mean lamp efficacy is used by designers to represent performance over the useful life of the lamp. (NEEA, No. 10 at p. 2; CA IOUs, No. 8 at p. 4) CA IOUs commented that many HID lamps of the same wattage and initial lumens will not have equivalent mean lumens. (CA IOUs, No. 8 at p. 4) The Appliance Standards Awareness Project ( ASAP ) commented that lumen main tenance has a direct relationship to energy use because when lighting designers use mean lumens to select a lamp, they would need to specify higher wattage lamps if the lamp has poor lumen maintenance. (ASAP, Public Meeting Transcript, No. 12 at p. 41)

2-26GE acknowledged that lighting designers do consider mean lumens, but new construction and new design represent a small percentage of HID lamp sales. GE commented that the 2014 MHLF rule could affect the new construction market for MH lighting, while the primary focus of the HID lamps rulemaking should be on the replacement lamp market. In the HID replacement market, customers will typically be locked into a certain HID system once it is designed and installed. This provides limited opportunity for energy savings through usage of reduced wattage lamps with increased mean lumens or lumen maintenance. (GE, Public Meeting Transcript, No. 12 at pp. 42-44)

In the interim analysis, DOE continued to evaluate lamps at full light output, based on carefully controlled laboratory measurements. In the interim analysis, DOE considered using initial lamp efficacy, mean lamp efficacy, and wattage as metrics with which to establish

standards f or HID lamps. DOE preliminarily determined not to set standards in terms of maximum allowable wattage for a given lamp light output, due to the drawbacks of using light output as a class -setting factor highlighted in section 2.4.3.2 . DOE also considered the costs and benefits of mean efficacy versus initial efficacy. In a review of catalog data, DOE found lamps with higher mean la mp efficacy tended to also have higher initial lamp efficacy . While it was not constant correlation across all lamps

, this fact highlighted that the differential impact of standards defined by mean versus initial lamp efficacy is minimal . Mean lamp efficac y data

would take much longer for manufacturers to collect than initial lamp efficacy data, greatly increasing the test burden on manufacturers. Based on the smaller testing burden and marginal difference in impact of initial versus mean efficacy, DOE prel iminarily determined to use initial lamp ef ficacy in the interim analysis. With regard to using the term lamp efficacy instead of NEMA’s suggestion of lamp luminous efficacy, DOE notes that the interim analysis was consistent with the ongoing HID lamps test procedure rulemaking, which used the term lamp efficacy in the test procedure NOPR. 76 FR 77914 (December 15, 2011 ).

In response to the interim analysis, OSI commented that when replacing lamps, lumens are important . OSI stated, however, that it was uncl ear whether initial lumens or mean lumens was the more important factor . (OSI, Public Meeting Transcript, No. 23 at p. 126) NEEA commented that typically a customer would design their space based upon the mean lumen output. It would not make sense to design a space for the first day of operation, using initial lumens, and then not care what it is going to look like in a year, so that is why mean lumen outputs are used. (NEEA, Public Meeting Transcript, No. 23 at pp. 126-127)

DOE has determined that mean lumens most likely drive decisions by lighting designers.

This concept was reaffirmed by manufacturers during interviews. For these reasons, DOE use s mean lumens when determining if a replacement lamp is an acceptable substitute for an existing lamp in this NOPD . However, DOE continues to use initial efficacy as the regulated metric due to concerns with the larger testing burden that would result from regulating mean efficacy.

2.3.4.2 Metric for Directional Lamps

In the framework document, DOE considered excluding directional HID lamps from

consideration for standards . NEMA suggested that if these products become covered in future rulemakings, DOE should adopt the ANSI definition of beam angle and CBCP. (NEMA, No. 11 at p. 10) GE commented that new metrics for directional lamps based on zonal lumen and CBCP would be complex to develop, and that they did not recommend developing them for an HID

2-27rulemaking. (GE, Public Meeting Transcript, No. 12 at pp. 40-41) OSI and NEMA also

commented that if directional lamps are excluded, then there is no reason to develop a metric for that specific type of lamp. (OSI, Public Meeting Transcript, No. 12 at p. 40; NEMA, No. 11 at p.

9 ) Because DOE did not consider standards for directional lamps in the interim analysis , DO E did not develop or analyze potential metrics for these lamps . DOE maintains this approach for

the NOPD

.

2.4 MARKET AND TECHNOLOG Y ASSESSMENT

For DOE’s analysis of the economic justification of energy conservation standards for HID lamps in today’s NOPD, DOE gathered information that provides an overall picture of the market for the equipment concerned, including the nature and market characteristics of the equipment and the industry structure. As in a typical standards rulemaking, t his activity consists of both quantitative and qualitative analysis based primarily on publicly available information. The subjects addressed in the market and technology assessment include the major manufacturers, equipment classes, market trends, shipments of the covered lamps, re gulatory and non-regulatory programs, and technologies that could be used to improve the efficacy of HID lamps.

DOE reviewed existing literature and spoke with manufacturers to gain an understanding of the HID lamp industry in the United States. Industry publications ( e.g. , manufacturer catalogs, trade journals), government agencies (Environmental Protection Agency, California Energy Commission [CEC], etc.), and trade organizations provided the bulk of the information. Using this information, DOE assessed t he overall state of the industry, lamp manufacturing and market shares, shipments by lamp type, general technical information on HID lamps, and industry

trends.

The following discussion summarizes DOE’s analytical approach. A more detailed discussion on DOE’s approach can be found in chapter 3 of the NOP D TSD.

2.4.1 Market Assessment

2.4.1.1 Manufacturers of High

- Intensity Discharge Lamps

The majority of the domestic market share of HID lamps is held by four major

manufacturers: GE , OSI, Philips , and Venture. The lighting divisions of several of these companies manufacture other products such as fluorescent lamps, halogen lamps, LEDs, and compact fluorescent lamps (CFLs).

Of all the manufacturers that sell domestically, the majority belong to N EMA , a trade association that represents electrical product manufacturers, including HID lamp manufacturers. NEMA provides an organizational framework for manufacturers of lighting products to work together on projects that affect their industry and business.

2.4.1.2 Regulatory and Non -Regulatory Programs

Several regulatory and non- regulatory programs affect the market for HID lamps. Canadian and European regulatory initiatives relevant to HID lamps covered by this

determination and the HID ballasts that operate these lamps are currently in place or under

2-28development. While the following summary is not exhaustive in describing all regulatory action related to HID lamps, it indicates notable initiatives that characterize recent developments in the lighting market. Chapt er 3 of this NOP D TSD discusses these regulatory programs and initiatives in additional detail and presents a summary of non- regulatory programs that affect the HID

market.

The HID lamps rulemaking requirements in the U nited S tates are described in section

2.2.1 . DOE has also adopted minimum ballast efficiency standards for certain MH ballasts sold

with new fixtures. e In addition to U.S. federal requirements, several other organizations have standards that apply to HID lamps or HID ballasts

. Natural Resources Canada (NRCan) has proposed k minimum efficiency standards for certain MH ballasts sold with new fixtures. In Europe, Commission Regulation No 245/2009 (March 18, 2009) and its revision No 347/2010 (April 21, 2010) establish lamp efficacy and ballast efficiency requirements for certain HID lamps and ballasts. Chapter 3 of the NOP D TSD further details these lamp efficacy and ballast efficiency requirements.

NEMA commented in response to the framework document that there is a movement toward limiting mercury that can be used in lamps in both Canada and Europe, and that such efforts to reduce mercury content in HID lamps would also reduce the efficacy of lamps. (NEMA, No. 11 at p. 23) DOE notes that in the interim analysis and this NOPD, all technology options and efficacies considered in the analysis are ev aluated based on current regulations, including mercury regulation. DOE cannot account for future mercury regulations that are not yet finalized in its analysis of potential HID lamps standards.

2.4.1.3 High

- Intensity Discharge Lamp Shipments

To calculate the NES from potential energy conservation standards for HID lamps, DOE estimates shipment volumes disaggregated by lamp type. In chapter 3 of the NOPD TSD, DOE uses two sets of HID lamp shipments that NEMA provided for the periods 1990 to 2002 and 2003 to 2008, and NEMA HID lamp indices data for 2010. 1 DOE notes that t he HID lamps in the shipment values include lamps that are not analyzed in this determination ( e.g. , colored lamps and directional lamps).

DOE uses this data for two main purposes. First, the shipm ent data and market trend information contributes to the shipments analysis and base case forecast for HID lamp shipments (see c hapter 10 of the NOPD TSD for additional detail). DOE analyzes historical shipment data

on market trends and calibrat es forecast assumptions with recent data. Second, DOE uses the data to develop the installed stock of HID lamps for the NIA (see c hapter 11 of the NOPD TSD for additional detail).

Table 2.4.1 shows the estimated historical shipments of HID lamps from 1990 to 2010. Discussions with lighting experts ( e.g. , informal dialogue with the DOE SSL Program, designers, and specifiers) and la mp manufacturers indicate an expectation for some migration of the HID lamp market to LED lamp systems in outdoor applications and fluorescent lamp systems in indoor applications.

k See http://oee.nrcan.gc.ca/regulations/bulletins/4817

2-29Table 2.4.1 Historical Shipme nts of HID Lamps from 1990-2010

Year Unit Shipments (millions) by Year

HPS MV Pulse

MH & CMH Probe

MH Total *

1990 7.4 6.2

— 5.7 19.3

1991 8.2 4.5

— 5.5 18.2

1992 8.8 4.7

— 6.4 19.9

1993 9.7 4.6

— 7.3 21.6

1994 10.6 4.8

— 8.7 24.1

1995 10.8 4.5

— 10.5 25.8

1996 11.9 4.4 0.05 11.5 27.9

1997 11.9 3.5 0.1 13.1 28.6

1998 12.2 2.8 0.4 15.0 30.4

1999 12.6 3.0 0.9 17.2 33.4

2000 11.5 1.8 1.2 16.8 31.4

2001 11.5 2.6 2.7 15.6 32.4

2002 11.7 2.4 3.7 15.0 32.9

2003 11.5 2.3 4.7 14.5 32.9

2004 11.3 2.5 7.2 12.7 33.7

2005 13.9 2.6 7.9 13.6 37.8

2006 11.8 2.7 7.9 14.0 36.4

2007 11.2 2.3 7.9 14.1 35.5

2008 10.9 1.8 7.3 13.0 33.1

2009 10.2 1.5 8.6 9.2 29.6

2010 10.2 1.5 9.8 8.8 30.3

* Because of rounding, values may not sum to the total.

2.4.2 Technology Options

The following sections detail the technology options that DOE is considering in this

determination as viable means of increasing the efficacy of HID lamps.

2-302.4.2.1 Mercury Vapor Lamps

MV ballasts, other than specialty application MV ballasts, ha ve been banned from import or production in the United States since January 1, 2008. (42 U.S.C. 6295(ee)) This ban effectively limits the installation of new MV fixture and ballasts, meaning the only MV lamps currently being sold are replacement lamps. DOE understands there is limited industry design emphasis on MV lamps, and that there are limited methods to improving the efficacy of MV lamps. Thus in the framework document and interim analysis, DOE found that the only pathway to increase efficacy is a cha nge of technology to MH lamps. DOE received no adverse

comments, and continues to use change of technology as the sole technology option for MV lamps in this NOPD

.

2.4.2.2 High

- Pressure Sodium Lamps

HPS lamps are already very efficacious (up to 150 lumens per watt ), but have intrinsically poor color quality. In the framework document, DOE noted that HID lamp catalogs do not indicate that a range of HPS lamp efficacies is available, and thus DOE did not identify any technology options for HPS lamps.

In the interim analysis, DOE identified academic papers that indicated potential increases in efficacy were possible by constructing the arc tubes out of a sapphire ( single crystal aluminum

oxide ) material. Several manufacturers produced an HPS lamp with a sapphire arc tube, the first appearing in the late 1970s. Manufacturers have since discontinued production of these lamps, though DOE does not have information on the specific causes of the discontinuance. Sapphire has improved light transmission characte ristics that would allow for a moderate improvement in efficacy. However, the sapphire material introduces unique design difficulties because of its tendency to expand differently along each of its three axes. When sapphire is formed into an arc tube, this asymmetry in material expansion may result in rupture of the arc tube. Through research and manufacturer feedback, DOE estimated HPS lamp efficacy could increase by five percent when changing from arc tubes made of polycrystalline alumina ( PCA ) to sapphir e arc tubes.

In response to the interim analysis, NEMA noted that sapphire arc tube technology was deemed not feasible today by industry, and noted that the increased transmission allowed by sapphire material does not translate into an equivalent increase in lumen output. (NEMA, No. 24 at p. 5, 9- 10). NEMA also noted that sapphire arc tubes have safety concerns because they are much more likely to fail catastrophically due to manufacturing defects (such as inclusions, voids, and low angle boundaries). Because of this, sapphire arc tube HPS lamps would have to be housed in enclosed fixtures for safe operation, while all HPS lamps commercially available today are rated for use in open fixtures. (NEMA, Public Meeting Transcript, No. 23 at pp. 47-49, 52; NEMA, N o. 24 at p. 6)

DOE determined that the increase in transmission associated with using sapphire material instead of PCA does not necessarily result in an equal increase in efficacy. This is because the material does not transmit all wavelengths uniformly, w hich affects the perceived brightness of the light. Because these lamps are no longer manufactured, DOE cannot empirically validate the potential increase in efficacy using sapphire arc tubes. Additionally, HPS lamps using sapphire arc tubes are much more susceptible to catastrophic failure and would require enclosed fixtures

2-31for safe operation. Currently all HPS lamps that are commercially available can be used in open fixtures. An enclosed fixture would reduce the efficacy of the sapphire HPS system (due to absorption in the lens used to enclose the fixture) and likely negate any small increase in efficacy gained from using sapphire arc tubes. For these reasons, DOE determined that the use of sapphire arc tubes would not increase the efficacy of HPS lamps in practice. As such, DOE no longer identifies sapphire arc tubes as a valid technology option for HPS lamps in this NOPD.

In response to the interim analysis, CA IOUs commented that DOE should evaluate the true range of efficacy among HPS lamps and use this data to inform potential standards analyses. CA IOUs added that there is variability in the order of 3 -5 percent present in ELs for HPS manufacturer catalogs, and recommended DOE conduct independent testing of HPS lamps. This efficacy testing of various wattages and from multiple manufacturers used to evaluate the true savings potential of efficacy standards for HPS lamps. (CA IOUs, No. 26 at pp. 8-9)

While there is a small amount of variation in efficacies when analyzing catalog data

across all manufa cturers, DOE found that when isolating the HPS lamps offered for any single manufacturer, the only variation in efficacy correlated to changes in utility such as high

- CRI HPS lamps. Based on this review of manufacturer catalogs and from the manufacturer in terview process, DOE concluded that this small variation found in HPS lamps from manufacturer to manufacturer is more likely attributed to variation in testing and reporting practices between

manufacturers , and not from any technology option differenc es.

Based on additional analysis of catalog data and removal of sapphire arc tubes as a technology option, DOE does not identify any valid technology options for HPS lamps in this

NOPD . Therefore, DOE tentatively determined standards for HPS lamps are not technologically feasible and did not consider the economic justification of standards for HPS lamps in the economic analysis in this NOPD

.

2.4.2.3 Metal Halide Lamps

In the framework document, DOE identified a number of technology options that couldimprove MH lamp efficacy. These technology options included changing from probe- to pulsestart technology, improving arc tube design through the use of ceramic arc tubes o r changing the arc tube shape, using novel fill gas, and improving the lamp electrode design.

Starting Method

. In the framework document, DOE included pulse- start technology as a technology option for MH lamps, stating that pulse- start lamps are typically more efficacious than probe- start lamps. In response to the framework document, NEMA commented that pulsestart lamps do not always have higher initial efficacy than probe- start lamps. NEMA also commented that the difference between probe- and pulse- start systems is addressed adequately in

the 2014 MHLF rule. (NEMA, No. 11 at p. 15) GE commented that pulse- start lamps do not necessarily outperform probe- start lamps in terms of initial efficacy. Additionally, GE mentioned that the switch from probe- start to pulse

- start is not simple, as a new ballasting system would have to be installed with the current fixture. (GE, Public Meeting Transcript, No. 12 at pp.59-60)

GE also stated that DOE should take into account other rulemakings related to HID lamps, such as the fixture rulemaking that is already forcing a transition in new fixture design. (GE, Public Meeting Transcript, No. 12 at p. 60)

2-32DOE reanalyzed efficacy data from manufacturer catalogs in the interim analysis to

determine the commercially available efficacies of probe

- start versus pulse

- start lamps. DOE

found that in terms of the most efficacious MH lamps, pulse- start MH lamps reached higher levels of efficacy than p rob e- start MH lamps. Thus in the interim analysis, DOE continued to consider starting method as a technology option for MH lamps up to 1000 W. Above 1000 W, DOE did not include pulse- start lamps as a design option because DOE found no such lamps commercially availabl e. While starting method is addressed in the 2014 MHLF rule, that rulemaking impacts only ballasts sold in new fixtures. Because t his HID lamp determination covers all HID lamps, including the replacement lamp market, the impact of each rule overlaps only in certain cases. DOE considers such overlap in the cumulative regulatory burden analysis, discussed in chapter 12 of the NOPD TSD.

In response to the use of starting method as a technology option in the interim analysis

, NEMA, OSI , and GE commented that there is very little difference between probe and pulsestart technologies in terms of energy savings. (OSI, Public Meeting Transcript, No. 23 at pp. 123-126; GE, Public Meeting Transcript, No. 23 at p. 128; NEMA, No. 24 at p. 6) OSI later

comment ed that pulse -start technology allows for superior lumen maintenance and higher mean lumens than probe-start lamps. (OSI, Public Meeting Transcript, No. 23 at p. 129)

CA IOUs commented that they are not aware of any major technical barriers that prevent pulse- sta rt MH lamp systems above 1000 W from being built. CA IOUs recommended that DOE analyze the technical feasibility of this technology option and model these potential products’ performance to develop higher tier CSLs. CA IOUs also added that higher wattage p ulse

- start MH systems will likely yield significant energy savings though the incremental energy efficiency gains from these more advanced designs decreases as the technology becomes more efficient. CA IOUs believes this decrease in incremental efficiency gains is the reason manufacturers have not pursued these design options. (CA IOUs, No. 26 at pp. 7-8)

For this NOPD , DOE reanalyzed the effic a cies of probe-start versus pulse- start lamps

. While DOE still finds that at most wattages the max

- tech quartz MH lamp is pulse -start and not probe- start, on average there is no difference in initial efficacy between probe -start and pulsestart lamps. Furthermore, DOE investigated potential rationale for increased initial efficacy for pulse versus probe- start MH lamps. DOE found that all options for altering initial efficacy remain the same when comparing the two starting methods, and there is no technical reason for pulse- start lamp s having higher maximum initial efficacies than probe- start lamps. The probestart lamp does have an additional electrode in the arc tube, but DOE found no evidence that this structural difference impacts initial efficacy. For these reasons, DOE has tentatively determined to not include starting method as a technology option for MH lamps in this NOPD . Regarding the wattage applicability of pulse-start MH lamps, DOE found that pulse- start lamps are available above 1000 W, but many of them have been removed from consideration for standards ( e.g. , lamps used for entertainment purposes). Because DOE is no longer considering starting method as a MH lamp technology option in this NOPD , DOE does not analyze the technical feasibility of starting method as a technology option above 1000 W.

Ceramic Arc Tubes

. In the framework document, DOE considered the use of ceramic arc tubes instead of quartz arc tubes to be a technology option for 50 W – 400 W MH lamps . NEMA agreed that CMH technology is not, as of 2012, made in lamp wattages above 400 W, and so it

2-33will no t be a technology option available for all equipment classes. (NEMA, No. 11 at p. 15) Conversely, ASAP commented that DOE should consider not just where the CMH technology is being applied today but where it is evolving, where it may be or could be applied, and if it could be applied to higher wattage lamps given that the standard will not go into effect until 2017. (ASAP, Public Meeting Transcript, No. 12 at pp. 62-63)

For the interim analysis, DOE continued to use ceramic arc tubes as a technology option only for MH lamps from 50 W to 400 W , because CMH lamps at higher wattages were still not commercially available. In response to the interim analysis, CA IOUs commented that they are not aware of any major technical barriers that prevent CMH lamps above 500 W being built. CA IOUs recommended that DOE analyze the technical feasibility of this technology option and model these potential products’ performance to develop higher tier CSLs. CA IOUs also added that higher wattage CMH will likely yield significant energy savings, though the incremental energy efficiency gains from these more advanced designs decreases as the technology becomes more efficient. CA IOUs believes this decrease in incremental efficiency gains is the reason manufacturers have not pursued these design options (CA IOUs, No. 26 at pp. 7-8)

For this NOPD

, DOE learned from manufacturer interviews that manufacturers generally agree that it is technologically feasible to produce higher wattage CMH lamps on an individual lamp basis , but that the m ass manufacturing difficulties and economics behind doing so are the

main reason s these lamps are not found on the market. For that reason, DOE is including ceramic

arc tubes from 50 W – 2000 W as a technology option in this NOPD

.

Arc Tube Optimization. In the framework document, DOE suggested optimizing the arc tube shape as a potential technology option for MH lamps . By reshaping the arc tube to increase MH vapor pressure, the light output and efficacy of the lamp increases. In response to the

framework document, NEMA agreed in general with DOE’s analysis of technology improvement options for MH arc tube shape. (NEMA, No. 11 at p. 15) NEMA also provided additional discussion on how arc tube shape affects lamp efficacy. NEMA stated that lamps with shaped arc tubes (which are designed to operate in one specific position) can be more efficacious initially than universal lamps, but the universal lamps help end users avoid incorrectly installing lamps designed to fit in only one specific position and do not re sult in reduced lifetime

. Also with universal lamps, there is only one lamp to stock and all fixtures can use the same lamp. There are also applications that require universal lamps ( e.g. , floodlights and area lighting). Furthermore, NEMA stated the increase in efficacy of lamps with shaped arc tubes and designed for one specific operating position will not decrease the number of fixtures required. (NEMA, No. 11 at pp. 15-16) While NEMA agr eed on a technical basis that the shape of the HID lamp arc tube relates to the efficacy of the lamp, they commented that designs are specific to individual company and generally proprietary. (NEMA, No. 11 at p. 16)

Available information supports NEMA’s de scription of the interaction between arc tube shape, efficacy, and operating orientation. DOE also notes that its analysis assumes the use of universal lamps, and that any potential standards are based on universal lamp efficacy, when possible. l In doing so, DOE ensures that universal lamps, which might be inherently less

l Certain representative lamps were unable to be universal lamps, due to unavailability of a universal lamp with the other desired characteristics ( e.g. , base typ e, bulb shape). In each of these instances, DOE ensured that either there

2-34efficacious

, are not removed from the market by standards. DOE received no adverse comments and continues to include arc tube shape as a technology option in the interim analysis.

In response to the interim analysis, DOE received no adverse comments on the inclusion of arc tube shape as a technology option. Through manufacturer interviews, DOE collected more details on a number of methods used to optimize the arc tube construction. These methods include changing the thickness of quartz, optimizing electrode positioning, improving the purity

of the materials , and improving the manufacturing processes to ensure the consistency and quality of the arc tube construction . These are all methods tha t contribute to arc tube optimization, and have tradeoffs with one another (e.g., changing the thickness of the quartz to improve the construction might have a negative impact on potential electrode positioning).

In this NOPD , DOE includes arc tube optimization as a technology option.

Fill Gas Optimization . In the framework document, DOE included novel fill gas as a technology option for MH lamps. NEMA stated that it is aware of one lamp maker currentlyusing a novel fill gas, which allows a reduced wattage lamp to run on existing probe and pulsestart ballasts with a 10 percent energy savings. (NEMA, No. 11 at p. 16) NEMA commented that novel fill gas compositions are individual company specific and generally proprietary. (NEM A, No. 11 at p. 16) In the interim analysis and this NOPD , DOE no longer included novel fill gases as a technology option for the reasons NEMA stated

.

Rather than using “novel” fill gases as a technology option in this NOPD, DOE considered other technology options involving the arc tube fill gas. Through manufacturer interviews, DOE received feedback that changing the gas fill pressure and altering the fill gas chemistry can change the efficacy of a MH lamp, though not beyond commercially available

efficaci es. For this NOPD , DOE includes fill gas optimization as a technology option.

Electrodes

. In the framework document, DOE considered improved electrode design and materials as a potential technology option. NEMA disagreed with DOE, commenting that industry has not identified improved electrodes as a means to improve lamp efficacy. NEMA recommended that DOE contact individual manufacturers for reports on their attempts and experience with this approach. (NEMA, No. 11 at p. 16) DOE discussed electrode design w ith manufacturers during individual interviews. DOE found that no technology option were available for improving electrodes beyond the performance levels found in commercially available lamps. For the interim analysis and this NOPD , DOE did not consider el ectrode design and material to be a technology option.

2.4.3 Equipment Classes

In analyz ing the potential for energy conservation standards, DOE divides equipment into classes by: (a) the type of energy used, (b) the capacity of the equipment, or (c) any other performance- related features that justify different standard levels, considering the impact of any

was a universal lamp at that wattage that exceeded the initial efficacy of the representative unit, or that all lamps on the market at that wattage and equipment class were non

- unive rsal, thus ensuring that no wattage could have universal lamps eliminated by potential standards.

2-35particular feature on consumer utility. (42 U.S.C. 6295(q)) DOE then considers standard levels

for each equipment class based on the criteria set forth in 42 U.S.C. 6295(o).

In the framework document, DOE considered several potential class

- setting factors for HID lamps, including directionality, ballast location, CCT, and light output in lumens. In the framework document, DOE outlined an equipment class structure using all four of these characteristics, as shown below in Table 2.4.2

.

Table 2.4.2 Equipment Classes Considered in Framework Document

Directionality Ballast

Location CCT Range

K Lumen Range

lm

Directional Self

- Ballasted All All

Externally

Ballasted All All

Omnidirectional Self

- Ballasted All All

Externally

Ballasted 1900

- 2500 1- 3,000

3,001

- 5,000

5,001

- 8,000

8,001

- 11,000

11,001

- 20,000

20,001

- 40,000

40,001

- 100,000

>100,001

2501

- 5000 1- 3,000

3,001

- 5,000

5,001

- 8,000

8,001

- 12,000

12,001

- 20,000

20,001

- 50,000

>50,001

5001

- 6999 1- 3,000

3,001

- 5,000

5,001

- 8,000

8,001

- 12,000

12,001

- 20,000

20,001

- 50,000

>50,001

For the interim analysis

, DOE revised its equipment class structure based on comments received on the framework document (these comments are discussed in the sections below). DOE considered CCT, wattage, bulb finish, luminaire characteristic, bulb shape, base type, and lamp operat ing orientation as potential equipment class

- setting factors. In the interim analysis,

2-36DOE preliminarily determined that CCT, wattage, bulb finish, and luminaire characteristic were the only factors affecting both consumer utility and efficacy. Therefore, in the interim analysis DOE analyzed the 28 equipment classes for HID lamps shown in Table 2.4.3

.

Table 2.4.3 Equipment Classes Considered in Interim Analysis

CCT Range

K Wattage

W Bulb

Finish* Luminaire

Characteristic**

≥ 1900 and ≤2800 ≥ 50 and ≤1000 Clear Enclosed

Open

Coated Enclosed

Open

> 2800 and ≤4500 ≥ 50 and ≤400 Clear Enclosed

Open

Coated Enclosed

Open

> 400 and ≤1000 Clear Enclosed

Open

Coated Enclosed

Open

> 1000 and ≤2000 Clear Enclosed

Open

Coated Enclosed

Open

> 4500 and <7000 ≥ 50 and ≤400 Clear Enclosed

Open

Coated Enclosed

Open

> 400 and ≤1000 Clear Enclosed

Open

Coated Enclosed

Open

> 1000 and ≤2000 Clear Enclosed

Open

Coated Enclosed

Open

* MV lamps regardless of bulb finish are placed in the clear equipment classes for their respective CCT and wattage.
** MV and HPS lamps are placed in the enclosed equipment classes for their respective wattage

and CCT.

2-37As discussed in the following sections, several interested parties commented on the equipment classes from the framework document and interim analysis , as well as the other class

setting factors that DOE discussed.

2.4.3.1 Directionality

Lamps can be considered ei ther directional or omnidirectional depending on the light pattern they create. Because there is a major distinction between the metrics used to assess the efficacy of directional and omnidirectional lamps, it would be necessary for these two types of lamp s to be subject to different standards. Thus, directional and omnidirectional lamps would require separate equipment classes. In the framework document, DOE suggested that if directional lamps were under consideration for standards, DOE would then consider establishing equipment classes based on this characteristic.

In written comments in response to the framework document, NEMA commented that directionality should not be used as a class- setting factor because NEMA disagreed with directional lamps having standards considered for them. (NEMA, No. 11 at p. 13) As discussed

in section 2.3.2.3 , DOE preliminarily determined in the interim analysis that directional lamps

wo uld not be considered for standards. Because DOE standards were not under consideration for directional HID lamps, DOE removed directionality as an equipment class

- setting factor in the interim analysis.

DOE received no comment to the contrary. In addition, DOE does not consider the economic justification of standards for directional lamps in the economic analysis in this NOPD

. As a result, DOE continues to exclude directionality as an equipm ent class -setting factor.

2.4.3.2 Ballast Location

Most HID lamps are operated by an external ballast. However, some HID lamps have a ballast integral to the lamp and are said to be “self

- ballasted.” These lamps typically have lower efficacies than externally ballasted lamps. Self

- ballasted HID lamps often compete with

incandes cent lamps , halogen lamps , and CFLs , and cannot be used as direct substitutes for externally ballasted HID lamps. Although the self

- ballasted HID lamps have lower performance compared to typical HID lamps, the use of self- ballasted HID lamps in place of the lessefficacious technologies they are known to replace can yield energy savings. Furthermore, selfballasted HID lamps could require a different metric than externally ballasted lamps, necessitating a separate equipment class. Therefore, in the framework document, DOE considered the possibility of placing s elf

- ballasted lamps in a separate equipment class.

NEMA commented that ballast location should not be used as a class

- setting factor because NEMA disagreed with considering standards for self -ballasted lamps. (NEMA, No. 11 at p. 13) As discussed in section 2.3.2.4 , DOE preliminarily determined for the interim analysis

not to consider standards for self- ballasted lamps. Because DOE standards were not under

considerati on for self- ballasted HID lamps, DOE removed ballast location as an equipment class

setting factor in the interim analysis

.

DOE received no adverse comment on this determination. DOE also does not consider the economic justification of standards for self -b allasted lamps in the economic analysis in this

2-38NOPD . As a result , DOE continues to exclude ballast location as an equipment class -setting

factor

.

2.4.3.3 CCT

HID lamps are available with different CCTs depending on lamp type and design. Equipment usage indicates that some customers specify lamps of a particular color temperature for certain applications, indicating CCT may provide unique consumer utility

. For example, MH lamps (higher CCT) are typically specified rather than HPS lamps (lower CCT) for indoor commercial areas due to whiter color temperature (and also higher CRI). DOE also reviewed lamp catalogs and found that CCT is related to lamp efficacy ( i.e.

, lamps with higher CCT generally have lower efficacy). Based on the difference in efficacy and cons umer utility, DOE considered an equipment class structure in the framework document using three CCT ranges: 1900 K – 2500 K, 2501 K – 5000 K, and 5001 K – 6999 K.

CA IOUs commented that CCT bins will effectively separate HID lamps by lamp technology and ap plication. For example, lamps less than or equal to 2500 K are HPS lamps used historically in street lighting, while lamps greater than 2500 K are more often used in indoor retail settings. (CA IOUs, No. 8 at pp. 3- 4) CA IOUs also commented that a lamp’s CCT is a more useful than its technology type in identifying a lamp’s likely application. (CA IOUs, No. 8 at p. 4) OSI commented that lamps with different CCTs have distinct utility due to their being suited to distinct applications, and that a change in CCT often leads to a change in light output. (OSI, Public Meeting Transcript, No. 12 at pp. 51-52)

CCT can affect both efficacy and utility. As such, DOE retained CCT as an equipment

class

- setting factor in the interim analysis. After further analysis, howev er, DOE revise d the boundaries used to separate lamps into CCT bins. Lamps with CCTs from 1900 K – 2800 K are almost entirely HPS lamps, m which have the highest efficacy of all HID lamp types. DOE then divided the remaining CCT range into two groups: 2801 K – 4500 K and 4501 K – 6999 K. These CCT ranges include almost all MH and MV lamps. m DOE found that lamps with CCTs exceeding 4500 K tend to exhib it decreased efficacy compared to lamps in the 2800 K – 4500 K range. As a result, DOE created an equipment class division at that point. Thus in the interim analysis , equipment classes were split according to CCTs of 1900 K – 2800 K, 2801 K – 4500 K,

and 4501 K – 6999 K.

DOE is not considering the economic justification of standards for HPS lamps in full economic analysis in this NOPD , as discussed in section 2.3.2.2 . As such, in this NOPD

, DOE removed the equipment class for 1900 K – 2800 K lamps. Regarding the remaining CCT divisions, DOE received no adverse comment. In this NOPD

, DOE retain s the struct ure from the interim analysis, but changes the 2800 K boundary so that the 2800 K to 4500 K range is inclusive of the 2800 K MH lamps. These 2800 K MH lamps were previously grouped with HPS lamps to serve as a substitute for high

- CRI HPS lamps , but can now be included with the rest of the MH lamps.

m There are a small number of MH lamps at 2800 K, representing less than one percent of available MH lamps.

2-392.4.3.4 Wattage

HID lamps are available with a variety of light outputs, which are directly correlated to the input powers of the lamps (higher input wattage typically results in higher light output). Because the applica tion and location of a lamp will determine how much light is needed, varying levels of light output provide distinct consumer utility . Additionally, DOE determined through an initial review of manufacturer lamp catalogs that HID lamps with greater light ou tput (and usually, therefore, greater input power) were generally more efficacious than lamps with lesser light outputs (and consequently lesser input power). Because light output and wattage both affect lamp efficacy and consumer utility, DOE used light output to separat e equipment classes.

B ecause light output more directly addresses the feature valued by cus tomer s, DOE established separate equipment classes based on li ght output instead of wattage in the framework document.

NEMA and GE disagreed with DOE’s plan to use lumen output as a class-setting factor. They commented that by using a lumen output approach, lamps of the same wattage could be placed in different equipment classes based on physical construction, parameters like bulb finish and luminaire characteristic, or variability in lumen output and measurements. (NEMA, No. 11

at p p. 14, 18; GE, Public Meeting Transcript, No. 12 at pp. 50-51) NEMA suggested organizing equipment classes by wattage because lamps are typically identified by wattage and have to operate on the designated wattages of the installed base of ballasts. NEMA recommended an alternative equipment class structure, using directionality, ballast location, CCT range, and wattage range as the class -setting factors. (NEMA, No. 11 at pp. 13-14; NEMA, Public Meeting Transcript, No. 12 at p. 53) In contrast, CA IOUs agreed that lumen output is useful for understanding the utility of a lamp, and commented that the lumen output method could be workable with certain changes. CA IOUs stated tha t other lamp properties such as color rendering and luminaire characteristic could be used to create additional equipment classes such that the appropriate standard is applied to each lamp type with a unique utility. (CA IOUs, No. 8 at p. 4)

As previously mentioned, increased light output (resulting from increased wattage) impacts consumer utility, because customers require varying light levels depending on the application and location of the lamp. When identifying potential equipment classes in the interim analysis, DOE preliminarily determined that the equipment class structure needed to include either lumen output or lamp wattage. DOE decided that the use of light output as a class-setting factor could result in HID lamps of the same wattage ( even when controlling for the lamp properties that CA IOUs mentioned) being placed in separate equipment classes and therefore subject to different standards. DOE also received feedback that customers typically choose lamps (particularly replacement lamps) based on the wattage rather than the lumen output. Manufacturers categorize their lamps in terms of wattage, in part because it serves the role of identifying which ballasts can be paired with the lamp. As a result, in the interim analysis DOE preliminarily determined that it was more appropriate to use wattage rather than light ou tput as a
class

- setting factor.

DOE also preliminarily determined that lamp wattage often directly affects the efficacy of a lamp. When examining manufacturer catalog data in the interim ana lysis, all other lamp characteristics remaining constant, DOE observed that HID lamp efficacy generally increases with increasing lamp wattage. This correlation is observed at least in part because there are

2-40certain fixed losses within a lamp associated wi th current passing through the electrodes (known as end losses) and with thermal losses from the arc to the arc tube wall. When the wattage increases, the fixed losses are a smaller portion of the overall losses, thus ma king the lamp more

efficacious.

DOE observed that the same design options were not available at all wattages. For example, CMH lamps were available only at 400 W and below, pulse- start MH lamps were

available only at 1000 W and below, and probe- start MH lamps were the only lamp type

avai lable above 1000 W through 2000 W. Therefore, in the interim analysis, DOE further

subdivided the 2801 K – 4500 K and 4501 K – 7000 K CCT ranges based on lamp wattage. In these two CCT ranges, DOE created separate equipment class divisions for the following wattage ranges: (1) ≥50 W and ≤400 W; (2) >400 W and ≤1000 W; and (3) >1000 W and ≤2000 W. These three wattage ranges will be written out throughout this document as 50 W – 400 W, 401

W – 1000 W, and 1001 W – 2000 W, respectively. For consideration of th e 1900 K – 2800 K CCT range in the interim analysis , wattage divisions were not necessary because the same energy saving alternatives were available at all of the wattages. DOE received no adverse comment on the use of wattage as an equipment

- class

- setting factor and the exclusion of lumen output as an equipment

- class

- setting factor in the interim analysis . DOE continues to use wattage as an equipment class -setting factor in this NOPD

.

DOE also did not receive adverse comment on the selected wattage divisio ns for equipment classes. I n this NOPD , lamps are separated into equipment classes for the wattage ranges of 50 W – 400 W, 401 W

– 1000 W, and 1001 W

– 2000 W.

2.4.3.5 Bulb F inish

DOE did not use bulb finish as an equipment class- setting factor in the framework document. Philips expressed concern about setting an efficacy standard that would be more difficult for a coated lamp to meet, as coated lamps are often less efficacious than their clear counterparts. Philips also noted that certain applications require coated lamps, which therefore have distinct utility in addition to the difference in efficacy. (Philips, Public Meeting Transcript, No. 12 at p. 84) NEMA agreed, commenting tha t coated lamps generally have lower lumen outputs than clear lamps, but offer unique consumer utility. ( NEMA , Public Meeting Transcript, No. 12 at pp. 49-50)

After reviewing manufacturer catalogs, DOE determined that coated MH lamps are inherently less efficacious than clear MH lamps . DOE also determined Philips that it would be difficult for a coated lamp to meet the same standard as a clear lamp, because coated lamps are inherently less efficacious. Through conversations with manufacturers, DOE found t hat clear and coated lamps have distinct utilities. For MH lamps , a coating is often applied to reduce the glare perceived by the customer. Because of the difference in efficacy and utility, DOE separate d equipment classes by clear and coated lamps in the interim analysis.

For MV lamps, coated lamps are more efficacious than their clear counterparts are because the coating on MV lamps converts considerable UV light output into visible light, thereby increasing the efficacy of the lamp. DOE preliminarily determined that an equipment class division was not necessary for MV lamps based on bulb finish because the CCT equipment class divisions already separate coated MV lamps from clear MV lamps. DOE found all clear

2-41MV lamps included in the analysis have a CCT of 4501 K – 6999 K, while all coated MV lamps included in the analysis are 2801 K – 4500 K. Because clear MH lamps are the most likely replacements for coated MV lamps in the applicable CCT ranges, DOE concluded that MV lamps should be categorized in the cle ar bulb finish equipment classes (regardless of the bulb finish of the MV lamp itsel f).

In reviewing catalogs for the interim analysis, DOE observed that HID lamps are offered with several different bulb finishes, such as clear, coated, diffuse, frosted, w hite, or deluxe white. Some of these labels apply to only certain types of HID lamps. For example, in addition to being classified as coated, DOE found that HPS lamps were sometimes labeled as diffuse, MH lamps

were sometimes labeled as frosted, and MV lamps were sometimes labeled as white or deluxe

white. DOE preliminarily determined that the difference between these terms was generally due to differences in marketing instead of anything related to the technology itself. Although coated HID lamps may have different names, most coated lamps have phosphor coatings applied to the inner wall of the outer bulb, which clear lamps do not have. Therefore, in the interim analysis, DOE defined “coated lamps” as all lamps that are not clear because the terms coated, diffuse, frosted, white, or deluxe white typically represent the same or nearly the same bulb finish within a lamp technology.

In response to the interim analysis, NEMA agreed with DOE’s definition of coated lamps. (NEMA, Public Meeting Transcript, No. 23 at p. 39; NEMA, No. 24 at p. 5) DOE did not receive any adverse commen ts on the definition of coated lamps. In this NOPD , DOE continues separating equipment classes by bulb finish, and places all MV lamps in the equipment class for clear lamps

.

2.4.3.6 Luminaire Characteristic

DOE did not use luminaire characteristic as an equipment class

- setting factor in the framework document. Philips expressed concern about setting an efficacy standard that would be more difficult for protected (or open

- rated) lamps to meet because these lamps are less efficacious than their unprotected (or enclo sed

- rated) counterparts are . Regarding utility, Philips noted that there are certain applications, such as gymnasiums or grocery stores, where protected lamps are required. (Philips, Public Meeting Transcript, No. 12 at p. 84) NEMA added that

luminaire cha racteristic impacts lumen output in addition to providing additional containment properties for safety. ( NEMA , Public Meeting Transcript, No. 12 at pp. 49- 50) OSI commented that there are advantages of being able to use open fixtures as opposed to enclosed fixtures, such as the lighting system’s staying clean longer and improved lumen maintenance over the life of the lamp. (OSI, Public Meeting Transcript, No. 12 at pp. 84- 85)

In its research for the interim analysis, DOE found that MH lamps are frequently l isted with a luminaire characteristic, typically open

- rated or enclosed -rated, to indicate in which type of fixture the lamps should be used. An open fixture does not have a physical barrier that separates the lamp from the space that is to be illuminated. Instead, open- rated lamps have a glass shroud that surrounds the arc tube to protect the environment and any occupants around the lamp in the event of arc tube rupture, or “non- passive failure.” An enclosed fixture has a physical barrier that separates th e lamp from the space that is to be illuminated. Enclosed -rated lamps do not have the glass shroud surrounding the arc tube and must be used in enclosed fixtures to satisfy safety requirements. DOE also found commercially available lamps that were labeled as

2-42S-rated. S-rated lamps do not have a glass shroud around the arc tube, but can be used in openrated fixtures under certain defined conditions that ensure safety. Because S-rated lamps do not feature a shroud, DOE preliminarily determined they are compa rable to enclosed

- rated lamps and thus grouped S- rated lamps with enclosed

- rated lamps.

Protected, or open- rated, lamps are less efficacious than enclosed -rated lamps due to the addition of a protective glass shroud around the arc tube of open- rated lamps. Because of this difference in efficacy and the distinct utility of open-rated lamps, DOE added luminaire characteristic as an equipment class

- setting factor in the interim analysis

.

In response to the interim analysis, NEMA agreed with separating equipment classes by luminaire characteristic, and with grouping enclosed -rated and S- rated lamps together. (NEMA, Public Meeting Transcript, No. 23 at pp. 39-40; NEMA, No. 24 at p. 5) DOE received no

adverse comments and continues separating equipment classes by luminaire characteristic . DOE

also groups enclosed -rated and S-rated lamps together in the equipment classes in this NOPD

.

2.4.3.7 Lamp Operating Orientation

DOE did not use lamp operating orientation as an equipment class- setti ng factor in the framework document. DOE found that catalogs indicate whether an HID lamp is designed to operate either at a specific orientation or at multiple orientations. In reviewing commercially available catalog data, DOE identified several operatin g orientations, including the universal, horizontal, and vertical orientations, as well as the degrees of operating tolerance associated with

each

With regard to the framework document, OSI commented that position-specific operating

orientations and univer sal operating orientations both have distinct utilities. Position

- specific lamps have an arc tube configuration based on the position in which that lamp can be operated.

Position

- specific lamps also have specific base types and may not fit properly in stan dard sockets. OSI explained that lamps with one specific operating orientation can also be misapplied and installed in the incorrect direction. Conversely, universal lamps are used in applications where aiming at orientations between vertical and horizonta l is necessary, and because they can be operated in any position they cannot be misapplied. OSI also pointed out that universal lamps are more efficacious in the vertical position than the horizontal position. (OSI, Public Meeting Transcript, No. 12 at pp. 52-53)

The flexibility of universal lamps is important to their utility. However, in analyzing efficacy data from manufacturer catalogs, DOE did not find any consistent trends between available operating orientations and efficacy. Because of this, DOE did not use operating orientation as an equipment class

- setting factor in the interim analysis. However, because of the distinct utility of universal lamps and the potential for optimization in position

- specific lamps, whenever possible DOE selected a universal lamp as a representative unit in th e interim analysis

. This selection of universal lamps was done in order to avoid setting a standard that would be

attainable only by position- specific lamps, as discussed further in section 2.6.2

.

DOE received no adverse comments

. In this NOPD DOE retain s the approach of not using operating orientation as an equipment class-setting factor but selecting universal lamps as

represent ative units whenever possible.

2-432.4.3.8 CRI

CRI is the measured degree of color shift objects undergo when illuminated by a light source as compared with the color of those same objects when illuminated by a reference source of comparable color temperature. (10 CFR 430.2) CRI ranges from zero (for monochromatic light sources) to 100 (for a light source that closely mimics the color rendering properties of natural light). The CRI of HID lamps vary based on lamp technology, application, and environment in which the lamp is being designed to operate.

DOE did not use CRI as an equipment class-setting factor in the framework document. OSI stated that for some lamp technologies, addition of a coating will improve CRI at the expense of reducing efficacy. (OSI, Public Meeting Transcript, No. 12 at pp. 51-52)

For the interim analysis, DOE further analyzed CRI and its correlation with efficacy.

DOE identif ied pairs of lamps that had as many of the same characteristics and specifications as possible, but different CRIs, and compared their efficacies. Overall, DOE found that changing

the CRI did not have a predictable effect on efficacy. However, DOE did find two specific exceptions with CRI and efficacy correlations. First, the coating on a MV lamp will in crease both its CRI and efficacy. However, coated MV lamps (and thus those with higher CRI) are already in separate equipment classes from the clear MV lamps (and thus those with lower CRI) due to the effect that the coating has on CCT, as discussed furthe r in section 2.4.3.3 . Second,

DOE analyzed particularly high-CRI lamps due to the unique utility they offer customers, and

found a relationship between CRI and lamp efficacy for especially high- CRI MH lamps. DOE found pulse-start MH lamps with CRIs greater than or equal to 95 could not meet as high of an efficacy as MH lamps with lower CRIs . Instead of separating equipment classes by CRI, DOE

d id not consider standards for pulse- start MH lamps with a CRI greater than or equal to 95 in the interim analysis, as discussed in section 2.3.2.6 . Aside from the CRI of coated MV lamps and high- CRI pulse

- start MH lamps, DOE found that CRI generally does not impact efficacy of commercially available lamps . In accordance with the resu lts of this analysis , DOE preliminarily determined not to use CRI as an equipment class

- setting factor in the interim analysis.

DOE received no adverse comment and does not separat e equipment classes by CRI in

this NOPD

.

2.4.3.9 Standby Lamps

In the framework docu ment, DOE did not consider separate equipment classes for standby, or double arc tube, lamps. OSI commented that standby lamps have two distinct

utilities . First, standby lamps have longer lamp life times. Second, standby lamps provide a higher degree of safety in buildings, because if one of the arc tubes fails then the other would stay lit. NEMA noted that these lamps are generally less efficacious than lamps that are not standby. ( NEMA , Public Meeting Transcript, No. 12 at pp. 49-50)

DOE recognizes that standby lamps could offer unique utilities to customers. However, DOE analyzed the average efficacy of standby lamps compared to traditional, single arc tube lamps and did not find any conclusive trends to suggest that standby lamps are less efficacious. Because the addition of a second arc tube in standby lamps does not affect efficacy, DOE

2-44preliminarily determined not to establish a separate equipment class for standby lamps in the interim analysis.

DOE did not receive any adverse comments regarding establishing separate equipment

classes for standby lamps and does not separat e standby lamps into a different equipment class in

this NOPD

.

2.4.3.10 Summar y

In this NOPD

, DOE uses CCT, wattage, bulb finish, and luminaire characteristic as the equipment- class -setting factors. DOE, therefore, analyzed the 24 equipment classes for HID lamps shown in Table 2.4 .4

.

Table 2.4.4 Equipment Classes Analyzed in NOPD

CCT Range

K Wattage

W Bulb

Finish* Luminaire

Characteristic**

> 2800 and ≤4500 ≥ 50 and ≤400 Clear Enclosed

Open

Coated Enclosed

Open

> 400 and ≤1000 Clear Enclosed

Open

Coated Enclosed

Open

> 1000 and ≤2000 Clear Enclosed

Open

Coated Enclosed

Open

> 4500 and <7000 ≥ 50 and ≤400 Clear Enclosed

Open

Coated Enclosed

Open

> 400 and ≤1000 Clear Enclosed

Open

Coated Enclosed

Open

> 1000 and ≤2000 Clear Enclosed

Open

Coated Enclosed

Open
* MV lamps regardless of bulb finish are placed in the clear equipment classes for their respective CCT and wattage. ** MV lamps are placed in the enclosed equipment classes for their respective wattage and

CCT.

2-452.5 SCREENING ANALYSIS

For the screening analysis, DOE consults with industry, technical experts, and other interested parties to develop a list of technology options for consideration and to determine which technology options to consider further and which to screen out.

Section 325(o)(2) of EPCA requires that any new standard achieve the maxi mum improvement in energy efficiency determined to be technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)) Appendix A to subpart C of 10 CFR part 430, “Procedures, Interpretations, and Policies for Consideration of New or Revised Energy Conservation

Standards for Consumer Products” (the Process Rule), sets forth procedures to guide DOE in its consideration and promulgation of new or revised energy conservation standards. These procedures elaborate on the statutory criteria provided in 42 U.S.C. 6295(o) and, in part, eliminate problematic technologies early in the process of prescribing an energy conservation standard. In particular, sections 4(b)(4) and 5(b) of the Process Rule provide guidance to DOE for determining which design op tions are unsuitable for further consideration:

Technological feasibility

. DOE will consider technologies incorporated in commercial products or in working prototypes to be technologically feasible.

Practicability to manufacture, install, and service

. If mass production and reliable installation and servicing of a technology in commercial products could be achieved on the scale necessary to serve the relevant market at the time the standard comes into effect, then DOE will consider that technology practic able to manufacture, install, and service.

Adverse impacts on product utility or product availability

. If DOE determines a technology would have significant adverse impacts on the utility of the product to significant subgroups of customers, or would result in the unavailability of any covered equipment type with performance characteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as equipment generally available in the United States at the time, it will not consider this technology further.

Adverse impacts on health or safety . If DOE determines that a technology will have significant adverse impacts on health or safety, it will not consider this technology further.

In the framework document and the interim analysis, DOE identified the design options

listed in Table 2.5.1 as technologies that could improve HID lamp efficacy and pass the screening criteria discussed above (with the exception of sapphire arc tube technology, for which DOE sought more information on whether that design option satisfied the screening criteria). For further details on these design options, see chapter 3 of the NOP D TSD . DOE received several comments, discussed below, in response to the design options presented.

2-46Table 2.5.1 Framework Document and Interim Analysis HID Lamp Design Options

Lamp

T echnology Framework

Document Design Options Interim Analysis Design Option Description

Mercury Vapor (MV) Change Lamp Type Change Lamp Type Use HPS or MH technology instead of MV technology

H igh

- Pressure Sodium (HPS) N/A Sapphire Arc Tubes Manufacture the arc tube of HPS lamps out of sapphire instead of PCA

Metal Halide (MH) Ceramic Arc Tubes Ceramic Arc Tubes Use CMH technology instead of quartz MH lamps

Arc Tube Shape Arc Tube Shape Design the shape of the arc tube so that it facilitates an increase in MH vapor pressure

Starting Method Starting Method Use pulse

- start technology instead of probe

- start technology

Novel Gas N/A Use novel gases as arc tube fill gases in MH lamps

Electrode Materials and Design N/A Different electrode materials or designs could reduce power losses

In response to the framework document screening analysis, NEMA stated that DOE should focus on the maximum technologically feasible and practical to manufacture design, but emphasized that there are many practical limitations in HID lamps. NEMA stated that previous rulemakings have been compromised by claims of prototype, one-off designs that have not been evaluated for their practicality and affordability. Additionally, prototype lamps should not be included because prototype technology has, by definition, not been validated in actual manufacturing conditions or in real life applications. NEMA concluded that DOE should never

determine the max -tech model based on HID lamp prototypes that are not commercially available. (NEMA, No. 11 at p. 17; NEMA, Public Meeting Transcript, No. 12 at p. 68) OSI

comm ented that DOE should not use prototype lamps as proof of what is possible in mass production and installation in the field. (OSI, Public Meeting Transcript, No. 12 at p. 69) DOE

understand s that there are numerous limitations to HID systems because of the various components required for a full system and unique compatibility i ssues they present. Consistent with the process rule, DOE does consider working prototypes, as appropriate, when considering design options. (10 CFR 430, subpart C, appendix A, sectio n 4(a)(4)(i)) However there are no working prototypes to im prove the efficacy of HID lamps to consider in this NOPD, so DOE only considers design options included in lamps that are commercially available on a large scale.

2.5.1 HPS Lamps

Regarding HPS lamps, in the interim analysis, DOE found that the superior light transmission characteristics of sapphire material compared to quartz material would lead to improved lamp efficacy if sapphire were used for arc tubes in HPS lamps. DOE estimated that when using sapphire instead of quartz, the light output and thus efficacy would increase by five

2-47percent. In response to the interim analysis, NEMA commented that sapphire arc tubes as a technology option for HPS lamps do not meet DOE’s screening criteria. (NEMA, No. 24 at p. 4)

NEMA noted in response to the interim analysis that, in terms of technological feasibility, sapphire arc tube HPS lamps were evaluated by industry in the 1970s. NEMA was not certain how those arc tubes were fabricated, but they may have been cored from a boule rather than continuously pulled. The technology was deemed not to be feasible today by industry. In addition, because of the material properties of sapphire, it would not be technologically feasible to draw a sapphire tube in a way to produc e a fully closed tube. New sealing technologies would need to be developed and the probable use of PCA end plugs would reduce the light output. (NEMA, Public Meeting Transcript, No. 23 at pp. 47-49, 52; NEMA, No. 24 at p. 6) NEMA also commented that the use of sapphire arc tubes with reduced lamp wattage s would not be feasible because the ballast s to run these reduced wattage HPS lamps do not exist, and these reduced wattage lamps would not be able to use existing ballasts. (NEMA, No. 24 at p. 7, 9-10)

From the practicability to manufacture, install, and service perspective, NEMA commented that because HPS lamps are very long-lived lamps, they would require significant life testing before being brought to market. (NEMA, No. 24 at p. 6) In addition, NEMA

comm ented commercially available sapphire tubing has limited selections of internal diameter

– outer diameter combinations, which limits the ability for manufacturers to optimize arc tube design. (NEMA, Public Meeting Transcript, No. 23 at p. 48; NEMA, No. 24 at p. 6)

From an adverse impacts to product utility and availability perspective, NEMA noted that commercially pulled single crystal alumina is inappropriate for use as arc tubes in HID lamps. Commercially available sapphire tubing is manufactured with the c

- axis parallel to the length, and this particular orientation makes the arc tube vulnerable to twinning , or mechanical instability

, at its operati ng temperature. Twinning can result in catastrophic failure of the lamp during operation. (NEMA, Public Meeting Transcript, No. 23 at pp. 47-49; NEMA, No. 24 at p.

6- 7) NEMA also commented that there is insufficient data regarding the reliability and lifetime for sapphire arc tubes. (NEMA, No. 24 at p. 5)

Lastly in terms of adverse impacts on health and safety, NEMA stressed the safety concerns of sapphire arc tubes because sapphire arc tube HPS lamps are much more likely to fail catastrophically due to manufacturing defects —such as inclusions, voids, and low angle boundaries. (NEMA, Public Meeting Transcript, No. 23 at pp. 47-49, 52; NEMA, No. 24 at p. 6)

A s discussed in section 2.4.2.2 , DOE found that sapphire arc tubes are not a valid technology option for HPS lamps in this NOPD

. As such , DOE did not consider sapphire arc tube technology in the screening analysis, and this technology will not be considered as a design option in the engineering analysis.

2.5.2 MH Lamps

As discussed in section 2.4.2.3 , DOE removed starting method as a technology option because any difference in efficacy between pulse

- start and probe-start lamps was found to be minimal. Thus, DOE no longer considers starting method in the screening analysis. DOE did not receive comment on any of the other design options presented in the framework document or

2-48interim analysis and continues to con sider those design options as pass ing the screening criteria

in this NOPD . In conversations with manufacturers, DOE also found a number of other methods that can be used to optimize the arc tube construction and construction process. These methods include changing the gas fill pressure, changing the thickness of quartz, altering the fill gas chemistry, optimizing electrode construction and positioning, improving the purity of the

materials and gases, and improving the manufacturing processes to ensure the consistency and quality of the arc tube construction. These are all methods that go into the optimization of the arc tube construction, and have tradeoffs with one another ( e.g. , changing the thickness of the quartz to improve the construction might have a negative impact on potential electrode positioning). Combined with improved design of the arc tube shape (which was considered as a design option

in the framework document and interim analysis), these methods to optimize the arc tube construction are included as subcategories of the arc tube optimization design option listed in

Table 2.5.2

.

For this NOPD , DOE also included the use of ceramic arc tubes for MH lamps from 50

W – 2000 W as a technology option. Because ceramic arc tubes are used in commercially available MH lamps from 50 W – 400 W, DOE considers this technology option in this NO PD as a design option. However for wattages from 401 W – 2000 W, DOE was not able to find ceramic arc tubes in commercially available MH lamps

. n Manufacturer s stated in interviews that the reason they are not found commercially available is because of the manufacturing difficulties present when made in large quantities . While ceramic arc tubes for lamps above 400 W are technologically possible to create on an individual scale in laboratory conditions, these manufacturing difficulties would result in a very costly lamp, which may not be able to be produced at a large enough scale to serve the entire market. DOE tentatively determined that

ceramic arc tubes for 401 W – 2000 W lamps do not pass the practicable to manufacture, install,

and service criterion of t he screening analysis. In this NOPD , DOE continued to not consider

ceramic arc tubes a design option for 401 W – 2000 W lamps

.

2.5.3 Summary

The design options used for this NOPD are summarized below in Table 2.5.2

.

n There is one example of a CMH lamp in this watta ge range. It is an 860 W CMH lamp that is designed to be used on a 1000 W ballast and can operate on both probe

- start and pulse

- start ballasts. Because of its unusual nature, and moreover because it employs proprietary technology, DOE does not use this lam p as an example of CMH lamps being commercially available from 401 W

– 2000 W.

2-49Table 2.5.2 NOPD HID Lamp Design Options

Lamp T echnology Design Option Description

Mercury Vapor (MV) Change Lamp Type Use MH technology instead of MV technology

Metal Halide (MH) Ceramic Arc Tubes (50 W

– 400 W) Use CMH technology instead of quartz MH lamps

Arc Tube Optimization Design the shape of the arc tube so that it facilitates an increase in MH vapor pressure; change the thickness of quartz ; alter the fill gas chemistry ; optimize electrode positioning ; improve the purity of

the materials ; and improv e the manufacturing processes to ensure the consistency and quality of the

arc tube construction

Fill Gas Optimization Optimize the gas fill pressure and chemistry

2.6 ENGINEERING ANALYSIS

2.6.1 Approach

For this NOPD , DOE derives ELs in the engineering analysis and lamp end- user prices in the equipment price determination. DOE also developed ballast and fixture MSPs in the equipment price determination because a change of ballast and fixture is often required when switching to a more efficacious lamp. For this NOPD , DOE also developed MSPs for brackets and sockets that come in lamp -and- ballast retrofit kits because customers will sometimes also have the option of keeping the fixture housing and installing a new lamp-and- ballast system. These systems will often require a change in the socket used and brackets for mounting the ballast. The engineering analysis focuses on selecting commercially available lamps that incorporate design options that improve efficacy. Chapter 5 of the NOPD TSD discusses all of the information typically contained in the engineering analysis . This NOPD TSD also has two appendices to chapter 5 that contain additional information DOE used when creating the engineering models for this analysis. While chapter 5 discu sses the representative units selected for analysis, appendix 5A of the NOPD TSD presents the lamps identified as comparable to the representative units but with an alternative starting method. These additional lamps were identified to ensure that the engineering models captured the unique costs of both probe- start and pulse- start MH lamps (since both are commonly used), regardless of whether a probe

- start or pulse- start lamp was identified as the representative unit. Additionally, while a typical engineering analysis will directly analyze non-compliant products being replaced with compliantproducts, DOE found in this NOPD that simply modeling compliant lamps replacing noncompliant lamps does not capture the entirety of the actual customer economics. In ce rtain situations, customers will have the option or the requirement of replacing multiple parts of the HID lighting system ( e.g. lamp, ballast, or fixture). Customers with non- compliant systems will have a wide range of potential options for making their lighting systems compliant, so appendix

5B of the NOPD TSD discusses criteria DOE used to model customer selection behavior for each lamp and ballast replacement option. Chapter 6 of the NOPD TSD discusses the equipment price determination for HID lamps, wh ile appendix 6A of the NOPD TSD discusses the

2-50equipment price determination for HID ballasts, fixtures, and retrofit system components. The following discussion summarizes the general ste ps of the engineering analysis:

Determine Representative Equipment Classes . When multiple equipment classes exist, to streamline analysis, DOE selects certain classes as “representative,” primarily because of their high market volumes and unique performance characteristics. DOE then adapts the ELs from representative equipm ent classes to those equipment classes it does not analyze directly.

Baseline Lamps and Representative Lamp Types

. Because no federal energy conservation standards exist for HID lamps, the baseline lamps represent the most common, least efficacious lamps sold within the equipment class. For each baseline lamp, DOE selected more efficacious replacement lamps to measure potential energy saving improvements. DOE refers to the baseline lamp and its more efficacious replacements collectively herein as a “represe ntative lamp type.” The representative lamp type is named by its baseline unit . For example, the 400 W MV representative lamp type refers to the 400 W MV baseline lamp and all of its more efficacious replacements.

DOE uses performance data presented in man ufacturer catalogs to determine lamp efficacy. DOE also considers other lamp characteristics in choosing the most appropriate baseline for each equipment class. These characteristics include the wattage and lamp t echnology ( i.e.

, MH or MV) , among others . For some of the representative lamp types, DOE selects multiple baseline models to ensure consideration of different high-volume lamps and their associated customer economics. For example, although MH lamps are not the least efficacious products available, the HID market has largely shifted away from MV lamps and customers of MH lamp -and- ballast systems incur different costs than customers of MV lamp -and- ballast systems. For these reason s , DOE selects both MV and MH lamp s as baselines for certain equipmen t classes.

DOE notes that the baseline lamps selected are intended to reflect both the lowest efficacy lamps available and lamps that are commonly used. Within the representative lamp types that have two baselines, MV lamps are the least efficacious but ar e not the most commonly used lamps in these equipment classes. By assigning the designation of baseline to both a MV and MH lamp, the analysis will capture the lowest efficacy lamps available for both technology types. The designation of a lamp as a baseline is used as a point of reference for the LCC analysis (discussed in chapter 9 of th is NOP D TSD). The use of multiple baselines does not impact the overall energy savings calculations discussed in section 2.9 . The energy savings calculations are based on estimates of the shipments of lamps at each EL (including baselines) without standards and the expected change in shipments at each EL that would occur with

standa rds.

More Efficacious Substitutes . DOE selects commercially available HID lamps with efficacies above baseline as replacements for the baseline model(s) in each representative equipment class. When selecting more efficacious substitute lamps, DOE considers only design options that meet the criteria outlined in the screeni ng analysis (see section 2.5 ).

In this NOPD , DOE consider ed a number of different potential path ways a customer might choose when identifying replacements that are more efficacious. DOE analyzed the

2-51possibility of customers replacing the whole fixture, retrofitting the existing fixture with a new lamp -and- ballast system, and replacing just the lamp. Each of these options can also be paired with a reduced wattage lamp or a lamp with equal wattage to the baseline.

Determine Efficacy Levels . DOE develops ELs based on: (1) the design options associated with the equipment class studied and (2) the max

- tech EL for that class. As just noted

and as discussed in section 2.6.4 , DOE’s ELs are based on catalog data.

2.6.1.1 Representative Equipment Classes

As previously described, DOE selects certain equipment classes as representative. The 24 equipment classes analyz ed in this NOPD (based on CCT, lamp wattage, bulb f inish, and luminaire characteristic) and the criteria used for development are presented in section 2.4.3 . Of these equipment classes, DOE analyze d three as representative. For CCT, DOE considered the

2800 K – 4500 K CCT range to be representative. Based on lamp catalogs and manufacturer interviews, MH and MV lamps are available in both the 2800 K – 4500 K and 4501 K – 6999 K CCT ranges, but the 2800 K –4500 K CCT range includes the more commonly shipped lamps. For bulb finish, DOE chose clear lamps to be representative because clear lamps a re more commonly shipped than coated lamps. Finally, for luminaire characteristic, DOE chose enclosed

rated to b e representative because enclosed -rated lamps are more commonly shipped than openrated lamps. Table 2.6.1 lists all of the equipment classes, and highlights the equipment classes that DOE selected as representative. These representative equipment classes are the same as those chosen for the interim analysis, with the exception of the 2800 K – 4500 K CCT range (this

is inclusive of 2800 K in the NOPD , but did not include 2800 K in the interim analysis). DOE requests comment on the representative equipment classes analyzed in this NOPD

.

2-52Table 2.6.1 Representative and Scaled Equipment Classes for HID Lamps

CCT Range Wattage Bulb Finish* Luminaire

Characteristic** Representative or Scaled Equipment Class

2800 K

– 4500 K 50 W

– 400 W Clear Enclosed Representative

Open Scaled

Coated Enclosed Scaled

Open Scaled

401 W

– 1000 W Clear Enclosed Representative

Open Scaled

Coated Enclosed Scaled

Open Scaled

1001 W

– 2000 W Clear Enclosed Representative

Open Scaled

Coated Enclosed Scaled

Open Scaled

4501 K

– 6999 K 50 W

– 400 W Clear Enclosed Scaled

Open Scaled

Coated Enclosed Scaled

Open Scaled

401 W

– 1000 W Clear Enclosed Scaled

Open Scaled

Coated Enclosed Scaled

Open Scaled

1001 W

– 2000 W Clear Enclosed Scaled

Open Scaled

Coated Enclosed Scaled

Open Scaled

* MV lamps regardless of bulb finish are placed in the clear equipment classes for their respective CCT and wattage.
** MV lamps are placed in the enclosed equipment classes for their respective wattage and CCT.

2.6.2 Baseline Lamps

Once representative equipment classes are established, DOE identifies baseline models that serve as reference points against which DOE can measure changes resulting from potential energy conservation standards. The baseline model is typically the most common, least efficacious equipment sold in a given equipment class. In cases where a large portion of the market has already adopted a more efficacious lamp, DOE considers analyzing two baseline models. For example, MV lamps are the least efficacious lamp opt ion for some equipment classes; however, MV lamps represent a very small portion of the market because many customers have already transitioned to other HID technologies. For this reason, in the framework document DOE considered selecting both a MV and a MH lamp as baseline for most 2501 K – 5000 K omnidirectional equipment classes. In the framework document, DOE selected 13 baseline models in nine representative equipment classes.

2-53NEMA recommended an alternative equipment class structure based on wattage instead of lumen output, and also suggested 12 specific baseline lamp types to be used with this alternative equipment class structure. (NEMA, No. 11 at pp. 18-19) CA IOUs commented that the 70 W HPS lamp should be included as a baseline lamp because it is the most common HID lamp used in streetlights in California. (CA IOUs, No. 8 at p. 5) OSI questioned the existence of the baseline 150 W probe- start MH lamp included in the framework document. OSI commented that outside of one 150 W probe- start lamp desig ned to operate with 175 W ballasts, all medium

screw -based lamps at 150 W are pulse-start. (OSI, Public Meeting Transcript, No. 12 at p. 73) Venture also commented that there is a 150 W probe- start lamp that is designed to operate with a

175 W ballast as a replacement lamp

. (Venture, Public Meeti ng Transcript, No. 12 at p. 73)

As discussed in section 2.4.3 , DOE revised the equipment class structure for the interim analysis. This change also required a reassessment of the baseline units. In the interim analysis, DOE changed its selection of baseline lamps to reflect the new equipment class structure based

on wattage instead of lumen output, as suggested by NEMA’s equipment class structure and baseline lamps. Based on feedback during manufacturer interviews and the comment from CA

IOUs , DOE included a 70 W HPS lamp as a baseline. In researching manufacturer ca talogs, DOE identified the 150 W probe- start MH lamp that is used as a retrofit on a 175 W ballast, but also identified several lamps and ballasts advertised as 150 W probe- start MH lamps and

ballasts . While DOE confirmed the existence of 150 W probe- start MH lamps, in the interim analysis DOE used a 175 W probe- start MH lamp as a baseline instead of a 150 W probe

- start MH lamp because 175 W probe- start MH lam ps are more commonly sold.

After considering the comments received in response to the framework doc ument and the changes to the equipment class structure, DOE analyze d 17 baseline lamps, spanning 12 representative lamp types in the interim analysis. This structure continued using both MV and MH lamps as baseline lamps in the appropri ate representative l amp types.

In response to the interim analysis, EEI commented that MV lamps should not be used as a baseline technology. EPACT 2005 banned the manufacture or import of MV ballasts, and as a

result

, MV lamps have had the lowest shipments of any HID lamp sin ce 2005 and their sales

have further declined since the ban on MV ballasts took effect in 2008. From the utilities’ experience , when an old MV fixture reaches end of life , a new technology replace s it . Because of this and the fact that MV lamps comprise le ss than five percent of HID lamp shipments, EEI recommended that DOE not use MV lamps as a baseline technology. Using MV as a baseline technology would skew any future analysis and may result in overstated operating cost savings. EEI instead suggests it wo uld be more appropriate for DOE to use a weighted average of the current shipment mix, as it would better reflect the current efficacy of HID products that are actually in use. (EEI, Public Meeting Transcript, No. 23 at pp. 12-14; EEI, No. 25 at pp. 2-3)

NEMA commented that the baseline lamps within the 2800 K – 4500 K, 50 W – 1000 W classes should all be MV lamps because they are the least efficacious products in these categories. Because it is not possible with HID to pick lamps that are both the least efficacious and highest volume of sales, the primary factor between these two should always be efficacy. NEMA stated that DOE should always select the lamp with the lowest efficacy for the baseline and, within the least efficacious lamps, select the lamp wit h the highest volume, which would lead the HID baseline lamp to always be MV. (NEMA, Public Meeting Transcript, No. 23 at p.

2-5461; NEMA, No. 24 at p. 7) NEMA commented that there is a large difference in initial efficacy in going from MV to MH lamps but little to be gained in going from probe- start MH to pulse

start MH lamps, so in the interest of gaining the greatest effect, the DOE should start with the least efficacious lamp. Using the most popular lamp in a given class could result in setting the

most eff icacious lamp as the baseline, which is counterintuitive. Furthermore, NEMA commented that setting the baseline for all lamps at the MV level would better justify the analysis attempting to make CSL 1 levels feasible. (NEMA, No. 24 at p. 2) NEMA also

reque sted clarification as to how a lamp can be a baseline and a CSL 1. (NEMA, No. 24 at p. 7)

As mentioned previously, when DOE selects baseline lamps, they are to serve as reference points at each representative equipment class against which DOE measures chan ges in energy use and price resulting from potential energy conservation standards. Typically, if federal energy conservation standards exist for a product, DOE will assume a baseline model is one that just meets existing standards and provides basic consu mer utility. However when no previous standards exist, as is the case for HID lamps, DOE chooses baselines that represent the least efficacious product or the highest volume product within the representative parameters defined.

In this NOPD , DOE selects a MV baseline and a MH baseline for certain equipment classes. These selections were made because, while MV lamps are the least efficacious HID lamps, a majority of the market has already shifted to MH lamps. By selecting a MV and MH baseline lamp in these i nstances, DOE’s analysis is able to accurately capture economic impacts of potential standards for customers who still use MV technology as well as those who already use MH technology. The base case shipments scenario apportions shipments to each EL (inclu ding each baseline) based on market share. Using this shipment distribution, the NIA calculates the weighted average economic impact. In this way

, a MH lamp represent s both the baseline and E L

1 because while it can be a more efficacious substitute for a M V lamp, the least efficacious MH lamp may also be representative of the lamp us ed by a majority of the market.

Another source of confusion with selecting multiple baselines was the levels of standards DOE could potentially propose. DOE can determine not to set an EL above one or both baselines

if DOE’s analyses indicate that such a decision would be the most appropriate option for an equipment class. If DOE did not set an EL above the least efficacious baseline, DOE would in effect not set a standard for that particular equipment class.

Both of these points can be further clarified with an example. One baseline unit DOE

selected in this NOPD is a 250 W MV lamp. However

, a majority of customers that require this level of light have already shifted to MH technology. To account for this, DOE also selected a 175 W quartz MH lamp to represent the MH baseline, as well as representing EL1 relative to the MV baseline. DOE also selected the more efficacious substitutes of a 150 W quartz MH lamp at EL2 and a 100 W CMH lamp at EL3. In this scenario, if an EL1 standard were selected, DOE would model the remaining MV users switching to compliant technologies, while the existing

MH customers at EL1 (or baseline MH) would not be affected. If an EL2 standard were selected, DOE would model both the MV and MH baseline customers switching to compliant technologies. DOE could also determine that an EL1 standard is not economically jus tified . This would result in DOE not proposing standards, and all customers would keep their existing lamp technology . DOE also notes that it is the base case shipments that drive energy savings and NPV changes, not just the baseline units selected.

2-55One ad ditional change to the baseline units chosen in the NOPD was the wattage of a MH baseline. In the interim analysis, DOE selected a 100 W MH lamp as the MH baseline that was included in the 175 W MV representative lamp type. In this NOPD , that baseline was changed to a 150 W MH baseline lamp. DOE changed this baseline because 150 W was tentatively determined to be a more common wattage for MH lamps than 100 W. DOE requests comment on

th e inclusion of a 150 W MH lamp as a baseline selection.

Lastly, as discus sed in section 2.4 , DOE does not consider starting method as a design option in this NOPD

. In t he interim analysis , DOE assumed that probe- start lamps were less efficacious than pulse

- start lamps, so all MH baseline selections were probe

- start lamps . EL1 and EL2 now represent standard efficacy quartz MH and high efficacy quartz MH, respectively, instead of probe- start MH a nd pulse- start MH. The baseline lamps are selected independent of starting method, so if a pulse-start lamp happens to be the MH lamp with appropriate characteristics for the baseline lamp (see chapter 5 of this NOPD TSD for details about criteria

for base line lamp selection) then it is an acceptable baseline lamp selection. In this NOPD , the MH baseline lamps DOE selected are probe -start MH at 175 W and 400 W, and pulse- start MH at 70 W, 150 W, 250 W, 750 W, 1000 W, and 2000 W. DOE requests comment on the decision that MH baseline lamps can be either probe

- start or pulse

- start lamps.

2.6.3 More Efficacious Substitutes

After selecting baseline models, DOE used publicly available catalog data to determine more efficacious units for analysis within each representative equipment class. DOE selected a maximum technologically feasible MH lamp for each representative equipment class based on commercially available equipment. After conducting a survey of the MH market and the research fields that support the market, DOE c oncluded that, within a given equipment class, no working prototypes exist that have a distinguishably higher efficacy than the currently available MH lamps. As such, the highest efficacy units analyzed in the engineering analysis represent the most

effica cious tier of commercially available equipment.

DOE received several comments, discussed below, on the higher efficacy HID lamps considered in the framework document and in the interim analysis.

2.6.3.1 Energy Savings Pathways

Customers with HID systems have a num ber of options for their more efficacious substitute lamps, due to the variety of lamp technologie s available and wattages that could provide the same light output. This section analyzes the issues relevant to these different design pathways.

Fixture Spaci ng versus Reduced Wattage . In the framework document, DOE acknowledged that one of the large challenges in considering ELs for HID lamps is ensuring that increased efficacy leads to reduced energy consumption rather than increased light output. Energy consumption can be reduced with increased efficacy through two main pathways:

1. Shifting to reduced wattage lamps in response to the increased efficacy required by

standards.

2-562. Re -spacing and reducing the number of fixtures to take into account the increased light output from each fixture.

In the framework document, DOE indicated that re-spacing and reducing the number of fixtures is not always an option, even for a renovation or new construction purchasing event. DOE also recognized that a reduced wattage lamp al ternative might not be available for every lamp currently on the market.

As a result, DOE planned to target energy savings by replacing a higher wattage lamp with a reduced wattage lamp of equivalent lumen output. OSI commented that because ballasts are manufactured at designated wattages, the HID lamps used on those ballasts need to be the same wattage. It is this operating wattage, and not the amount of light output from the lamp, which drives energy savings. As such, OSI stated that rulemakings regulating fixtures and

ballasts , rather than HID lamps, would result in energy savings. (OSI, Public Meeting Transcript, No. 12 at pp. 55-56) OSI also commented that although it offers a 360 W lamp designed for operation on a 400 W ballast (thus reducing overall lamp-and- ballast system power), such

reduced wattage options are not always available. One reason for this is that lamp voltage varies with lamp wattage, but the lamp voltage must fall within the ballast’s tolerance range. Additionally, the difference in light level for certain reduced wattage replacements ( e.g

. , 250 W to 175 W) could potentially be too great for the reduced wattage lamp to be a suitable replacement. (OSI, Public Meeting Transcript, No. 12 at pp. 78-79) Philips comment ed that it is highly unlikely that manufacturers will develop a reduced wattage lamp for every standard

watt age because a ballast is not always available to operate those reduced wattages. Additionally,

m anufacturers are placing emphasis on LED systems as replacements for a large part of the lighting market, resulting in fewer resources to develop the HID market . (Philips, Public Meeting Transcript, No. 12 at pp. 78-80) GE stat ed that the products on the HID market today are likely to remain the only type of products available for customers. (GE, Public Meeting Transcript, No. 12 at p. 79) GE also commented that the energy savings in a lamps rulemaking would occur

because a custom er would have to switch lamp technologies and reduce the wattage of the fixtures. While such wattage reductions from changing technologies would reduce energy use, GE point ed out that this would require an entire fixture replacement and such a replacement would not likely be cost effective. (GE, Public Meeting Transcript, No. 12 at pp. 56- 57)

In the interim analysis, DOE acknowledged that energy savings could not be achieved simply by implementing reduced wattage HID lamps designed to operate on full watta ge ballasts. These lamps are not available in a wide enough array of light outputs, wattages, and applications to be a practical means to energy savings. Instead, in the interim analysis, DOE modeled energy savings in the LCC analysis by assuming customers would have to replace an entire fixture (including the lamp-and- ballast system) at a reduced wattage, as GE noted. See chapter 9 of the NOPD TSD for discussion of the cost effectiveness of each purchase option.

In response to the framework document, and referring to the energy saving pathway that involves using fewer lamps but each with higher light output , NEMA stated that re -spacing and reducing the number of luminaires is not always an option. Unlike fluorescent luminaire retrofits and renovations, the ballast and lamps are not as easily modified in existing HID fixtures. HID luminaire layouts are based on the building layout with other systems in the space, such as electrical distribution systems and task locations. All tend to preclude changing fixtur e spacing

2-57or quantity to save energy. It is therefore not often possible or practicable to re-space existing fixtures. (NEMA, No. 11 at p. 20) Cooper Lighting (hereafter “Cooper”) also commented that the idea of changing fixture spacing is impractical beca use the vast majority of installations are done with a fixed conduit system. These systems have fixed terminations where luminaires are located, so re-spacing luminaires would require conduits to be moved and hanging systems to be redone. Such renovations would be very expensive and time consuming. (Cooper, Public Meeting Transcript, No. 12 at pp. 75-76) OSI stated that often it is the location of existing building systems, such as ductwork and sprinkler heads, that determine where the lighting fixture

can be located. OSI provided the example that positioning sprinkler heads, for safety and insurance reasons, would take precedence over the ideal location for the luminaire. (OSI, Public Meeting Transcript, No. 12 at pp. 76-77) NEMA also added that if lamps with position- specific operating orientation were used as replacements for universal orientation lamps (due to the fact that position- specific lamps can be optimized to be more efficacious), it would not decreas e the

number of fixtures used . (NEMA, No. 11 at pp. 15-16)

In the interim analysis, DOE stat ed that re -spacing new or existing fixtures is often not an option and thus using fewer but higher light output HID lamps is rarely an option for achieving energy savings. Instead, energy savings would result fr om reducing the operating wattage of the HID system. DOE found that standards for HID lamps could potentially realize energy savings through customers maintaining the same number of reduced wattage , high efficacy fixtures. Thus, in the interim analysis , DO E modeled energy savings from this reduction in fixture wattage, and not from the use of a reduced wattage lamp designed for a full wattage ballast. With regard to concerns over reduced light output accompanying reduction in lamp power, DOE point ed out that when selecting reduced wattage substitutes, DOE maintained mean light output to within ten percent of the baseline when possible. o DOE also assumed in the interim analysis that such a change in lamp technology or wattage will necessitate a change in ball ast and fixture. DOE also recognize d that this might not always be cost effective, and that DOE weighs both the costs and energy savings in its analysis. With regard to NEMA’s comment about lamps with position-specific operating orientation, DOE understand s that the potentially increased efficacy of position-specific lamps over universal operation lamps will not lead to energy savings. The wattages of an existing universal lamp and replacement position- specific lamp would still be equivalent, and as such po sition -specific lamps are not used as a design option. Additionally, DOE avoided using lamps with position-specific operating orientation as a representative unit whenever possible, instead focusing on universal lamps in the interim engineering analysis.

DOE received no adverse comments in response to the interim analysis and continues to model potential energy savings from reducing the wattage of HID systems rather than reducing the number of HID lighting systems. DOE also continues to avoid the use of lam ps with position- specific operating orientation as a representative unit whenever possible in this NOPD. l

Lamp and Ballast Compatibility . In response to the interim analysis, NEMA commented

that DOE should not assum e that lesser -wattage lamps can be inserted into existing fixture and ballast combinations. Even where this is physically possible, owing to socket constraints, a

o When selecting more efficacious substitutes, it was not always possible to stay within ten percent mean lumens of the MV baseline and the MH baseline. When this was the case, DOE selected a more efficacious substitute that is within ten percent mean lumens as the MV baseline, and as close to ten percent mean lumens as possible to the MH

baseline.

2-58lesser

- wattage l amp put in place of a higher wattage lamp will be driven at the output level specified by the ballast ( e.g ., a 200 W HID lamp fitted in place of a 250 W lamp in a 250 W ballast will be driven at 250 W). This results in no energy savings and shorter lamp li fe. For HID products, efficacy and wattage must be analytically separated. (NEMA, No. 24 at p. 3) GE noted that you cannot install a 400 W lamp in a 250 W system just because it is more efficient. (GE, Public Meeting Transcript, No. 12 at pp. 84-85)

DOE understands that reduced wattage lamps cannot typically be replaced directly on to existing full wattage ballasts. In the NOPD , the reduced wattage replacement scenarios DOE analyzes are full fixture replacement, lamp -and- ballast retrofit within the existin g fixture housing, and reduced wattage lamps specifically designed to operate on full wattage ballasts. These reduced wattage retrofit lamps are not common in today’s market, but they are offered for select wattages. They include reduced wattage pulse

- star t MH lamps for full wattage probe

- start MH ballasts, reduced wattage probe

- start MH lamps for full wattage MH probe

- start ballasts, and reduced wattage probe- start MH lamps for reduced wattage MV ballasts. DOE pairs a lamp only with a ballast designed to o perate that particular type of lamp. DOE considered these lamps as replacement options only in situations where they met an EL higher than the lamp they would be replacing and where otherwise compatible. Chapter 5 of the NOPD TSD details the two

reduced wa ttage retrofit lamps that were used in DOE’s analysis.

In response to the interim analysis, CA IOUs stat ed that there is no need to redesign lighting systems to achieve energy savings because, in all cases, there is a clear and established

market for ener gy savings options to improve existing fixtures or to be installed in new fixtures. Reduced wattage lamps were designed to be the simplest way for customer s to save energy, and pulse- start MH and CMH lamp -and- ballast systems have also been designed as ener gy saving options to replace less efficacious HID lighting options of set fixed wattages. (CA IOUs, No. 26 at p. 4)

DOE has determined that it is unlikely that, in response to standards, a customer would redesign their lighting layout. DOE does not model such a scenario in this NOPD . In its analysis, DOE chose more efficacious substitutes that would match the mean light output of existing fixtures so that they would not have to be re-spaced. One of the options DOE investigated, as suggested by CA IOUs, w as the use of reduced wattage lamps with existing fixtures. As

discussed in section 2.6.3.2 , DOE also recognizes that not every customer will select these reduced wattage, increased efficacy options. A portion of the market will maintain their current wattage and simply find a system at that wattage that will comply with standards while increasing light output. This option also assumes building managers do not alter their lighting layout.

2.6.3.2 Higher Efficacy Substitutes

DOE selects more efficacious lamps for each baseline lamp by considering technologies not eliminated in the screening analysis. DOE considers these technologies in the engineering analysis by analyzing commercially available lamps in which the design options are already incorporated. In identifying more efficaci ous designs, DOE recognizes that a lamp’s lumen package and performance characteristics are important design criteria for customers. DOE chooses more efficacious substitute lamps with performance characteristics similar to those of the baseline lamps. In t he framework document, DOE asked for comment on more efficacious

2-59(and equal lumen output) substitutes for each proposed baseline model, up to and including the

max -tech lamp, that would result in reduced energy consumption.

In the framework document, DOE s tated that many customers have switched from MV to MH technology and as a result, MH lamps could be used as more efficacious substitutes for MV lamps. NEMA commented that, on the contrary, customers who have transitioned away from

MV have also selected HPS technology. The transition is application dependent, with MH generally replacing MV indoors and HPS generally replacing MV outdoors, NEMA commented. (NEMA, No. 11 at p. 18) OSI also commented that in indoor applications, MV is typically replaced with MH o r fluorescent technologies, while in outdoor applications, MV is generally replaced with HPS, and more recently, lamp technologies have also been transitioning to LEDs. (OSI, Public Meeti ng Transcript, No. 12 at p. 77)

DOE acknowledges that MV customers ar e transitioning to MH and HPS systems, in addition to non-HID technology. As discussed in section 2.11 , the shipments a nalysis discusses the shipment trends relating to customers previously using MV. However, for the interim analysis, DOE directly analyzed only MH substitutes for MV lamps, because the similarity in CCT places those lamps in the same equipment class.

In the interim analysis, more efficacious substitutes were selected to save energy and, when possible, maintain mean lumens within ten percent of the baseline lamps. DOE also sought to keep other characteristics as similar as possible, such as initial lumen outp ut, operating orientation, rated life, CRI, bulb shape, and base type. DOE proposed the use of several higher efficacy substitutes for HID lamps. Probe

- start MH lamps were proposed as substitutes for MV lamps, pulse- start MH lamps were proposed as substitu tes for probe

- start MH lamps, and CMH lamps were proposed as substitutes for quartz MH lamps.

NEMA commented that the only four lamp technologies available in the 2800 K – 4500 K, 50 W – 1000 W classes in the interim analysis are MV, probe

- start MH, pulse

- start MH, and CMH. If analyzed properly, MV should be the only baseline, and MH lamps should be

considered for more efficacious le vels. (NEMA, No. 24 at pp. 7-8)

In this NOPD , DOE continues to analyze both probe- start and pulse -start MH lamps, but

DOE no longer uses starting method as a technology option to define different ELs (see section

2.5 ). At each wattage of quartz MH lamps, DOE found a range of efficacies available. As

discussed in section 2.6 , DOE found that there are a number of ways to optimize the arc tube construction of a quartz MH lamp to improve efficacy. When investigating the range of efficacies available, DOE often found that the same light output was available from quartz MH lamps at different wattages. For example, DOE found a 175 W quartz MH lamp and a 150 W quartz MH lamp that have the same mean lumens. As such, DOE developed two ELs using quartz MH technology. In th e previous example, a customer can select the 150 W quartz MH lamp as a more efficacious substitute for the 175 W quartz MH lamp. For th is NOPD, DOE analyzed up to three more efficacious subst itute lamps for the MV baselines corresponding to standard efficacy quartz MH, high efficacy quartz MH, and CMH lamps. These more efficacious

2-60substitute lamps maintain mean lumens within ten percent of the baseline. p DOE also sought to keep other lamp char acteristics constant from baseline to higher efficacy substitute. More efficacious substitute lamps had the same bulb shape and base type as baseline, and DOE selected units that maintained characteristics such as CCT, CRI, and rated lifetime as much as

fe asible. DOE requests comment on its selection of more efficacious substitute lamps.

In this NOPD , DOE also analyze d the customers who choose to comply with standards by purchasing a higher efficacy lamp at an equal wattage. While a customer switching to a more efficacious lamp at the same wattage would obtain increased light output with no energy savings, DOE still found customers might choose to do so for reasons such as convenience or upfront

cost. These customer decisions are discussed in detail in sect ion 2.6.5.3 . To accurately model the customers who choose an equal wattage, DOE identified higher efficacy, equal wattage substitutes at each EL for each representative unit for which such a lamp was available. For each representative unit, DOE selected an equal wattage lamp with an efficacy that as closely as possible meets each higher EL, while keeping the same starti ng method, bulb shape, and base type. Sometimes exceptions had to be made to this process, such as EL3- compliant CMH lamps not being available at 175 W, 250 W, 320 W, or 400 W. The specifications of these equal wattage units can be found in chapter 5 of th e NOP D TSD. DOE requests comment on the decision to include equal wattage replacement lamps, as well as the methodology used to select the equal wattage replacement lamps.

Lastly, DOE determined for this NOPD that customers currently using probe- start lam ps versus pulse- start lamps will have different replacement purchase options. For example, a customer with an existing 250 W pulse-start MH system would not have the option to purchase a compliant 250 W probe- start lamp to install in their system. Instead, that customer would have to purchase a compliant 250 W pulse- start lamp as an equal wattage lamp replacement. To fully model these customer choices, DOE added pulse -start and probe- start lamp prices for replacement lamps at all applicable ELs. The prices associated with these lamps are discussed in

further detail in section 2.7

.

2.6.3.3 Proprietary Designs

In its engineering and economic analyses, DOE will consider all design options that are commercially available or present in a working prototype, including proprietary designs. However, if a proprietary design is the only approach available to achieve a gi ven EL, DOE will eliminate the EL from further analysis. DOE will reject a standard level that can be met only with a single proprietary technology because it could result in an anti- competitive market. However, if a given EL can be achieved by a number of design approaches, including a proprietary design, DOE will continue to examine the given EL.

In the framework document, DOE requested information regarding the existence of proprietary designs for the HID lamps under consideration in this standards anal ysis . NEMA replied that it could not comment, but that individual manufacturers may choose to do so during

p When selecting more efficacious substitutes, it was not always possible to stay within ten percent mean lumens of the MV baseline and the MH baseline. When this was the case, DOE selected a more efficacious substitute that is within ten percent mean lumens as the MV baseline, and as close to ten percent mean lumens as possible to the MH

baseline.

2-61their confidential interviews. (NEMA, No. 11 at p. 23; NEMA, Public Meeting Transcript, No. 12 at p. 92) GE and OSI both commented that there is prop rietary technology that is relevant to

the HID standards analysis , but that they could not publicly comment further. (GE, Public Meeting Transcript, No. 12 at p. 92; OSI, Public Meeting Transcript, No. 12 at p. 93) In the interim analysis, DOE ensured that the lamps that were analyzed as more efficacious substitutes did not include proprietary designs. DOE received no comment on the interim analysis or feedback during manufacturer interviews that the lamps DOE analyzed required proprietary designs and inclu des the same technologies in this NOPD

.

2.6.4 Efficacy Levels

After identifying more efficacious substitutes for each baseline lamp -and- ballast system, DOE develops ELs, a set of efficacy levels that span the range of lamp efficacies from baseline equipment to equipment at the maximum technologically feasible level. Each EL is analyzed in the LCC and NIA analyses.

2.6.4.1 Binned Approach versus Equation

- Based Approach

In the framework document, DOE considered an equipment class structure that reflected a “binned” EL approach, or a constant-value approach. With this method, DOE would establish a constant lamp efficacy requirement for particular ranges of light output. Although a constant efficacy requirement simplifies standards for manufacturers, this approach would subje ct all lamps in a particular equipment class to the same standard, which could encourage the market towards the higher wattage end of the bin, where the standard would be relatively less stringent. This could potentially negate energy savings associated wi th increasing lamp efficacy.

DOE also stated its intent to consider an equation-based approach. Based on the equipment class structure in the framework document, an equation-based approach would establish lamp efficacy requirements as a function of light output, thus eliminating or reducing

the need for separate equipment classes based on lumen output. q Lamp efficacy tends to increase for lamps with higher light output, and an equation-based approach would allow DOE to account for this trend with a continuous relationship.

DOE received several comments expressing concern that equation -based ELs would not

work for HID standards . NEMA commented that it was not aware of a suitable equation

- based efficacy approach, especially considering the difficulty that would arise when factoring in

differences in HID lamp construction such as changes in CRI, bulb finish, and luminaire characteristic. NEMA instead stated a preference for standards that utilize wattage bins. (NEMA, No. 11 at p. 21) Venture also commented that because of how many variables there are in H ID lamps (bulb finish, lamp operating orientation, CCT, lamp chemistry), it would be too complex to find an equation that covers everything. However, within very narrow parameters, such as shifting from one lamp to a second lamp that is identical except for the bulb finish, equations could be used to accurately model efficacy. (Venture, Public Meeting Transcript, No. 12 at p. 91-

92 ) GE commented that it does not believe an equation

- based approach is practical. Standards for HID lamps will have the largest impact on existing systems, and GE finds that for those

q Lumen output was used for equipment classes and to determine potential ELs in the framework document. In the interim analysis and this NOPD, lumen output was replaced with wattage as the equipment class

- setting factor. See

section 2.4.3.4 for further discussion on this switch from lumen output to wattage.

2-62systems a binned approach will be most effective. (GE, Public Meeting Transcript, No. 12 at pp. 81-83)

In contrast, CA IOUs commented that, after analyzing Philips’s online catal ogs of MH lamps, they found that higher wattage products are more efficacious and that a relationship can be reasonably developed to scale the efficacies of lamps at different wattages. (CA IOUs, No. 8 at p. 3) CA IOUs went on to suggest that within a single CCT bin, an equation- based standard should be used to scale the range of luminous outputs. (CA IOUs, No. 8 at p. 4) ASAP also encouraged DOE to consider an equation- based approach if one can be developed that represents the relationship between lumen output and efficacy. (ASAP, Public Meeting Transcript, No. 12 at p. 88)

In response to concerns about using an equation- based approach

, DOE considered an alternative binned system in the interim analysis that would set equipment class bins by wattage

and set a constant efficacy requirement for every wattage within that bin. However, in such a binned approach, DOE would have to create several additional equipment classes to accommodate the range of wattages encompassed by a representative lamp type. For exampl e, in

the 2800 K – 4500 K CCT range, DOE could create an equipment class for lamps with wattages between 100 and 250 W (the 250 W MV representative lamp type) that would encompass the 250 W MV baseline and the more efficacious, lower wattage probe

- start, p ulse-start, and CMH replacements. However, when analyzing these potential equipment class divisions based on wattage, DOE noticed that the wattage of the highest efficacy replacements for certain baselines overlapped with a neighboring equipment class. For example, the 100 W CMH replacement for the 250 W MV baseline lamp in the previously mentioned potential equipment class has the same wattage as: (1) a 100 W pulse

- start MH replacement for a 175 W MV baseline lamp and (2) a 100 W MV baseline lamp. For these reasons, DOE did not use a binned approach in the interim analysis.

In addition to considering stakeholder comments on an equation-based approach, DOE also conducted additional analysis. DOE isolated lamps based on lamp construction and

characteristics i n an attempt to identify the relationship between wattage and efficacy. DOE analyz ed lamps within the same equipment classes ( i.e.

, same wattage range, CCT range, bulb finish, and luminaire characteristic ). DOE used power-law function regression curves to best fit the representative units in each equipment class. DOE addresses variability in lamp characteristics (bulb finish, CCT, etc.) by assigning equation-based ELs to individual equipment classes, rather than developing one equation to set standards for all lamps.

In the interim analysis, DOE developed three equation-based ELs in the 2801 K – 4500 K CCT, clear and enclosed, 50 – 400 W equipment class ( representing probe- start MH, pulse

- start MH, and CMH levels), two ELs in the 401 W – 1000 W range (representing probe-start MH, and pulse-start MH levels), and one EL in the 1001 W – 2000 W range (representing the probe- start MH level). DOE also developed one equation-based EL in the 1900 K – 2800 K, 50 W – 1000 W equipment class for HPS lamps in the interim analysis.

NEMA agreed generally with the interim analysis approach to use power functions and power function regression curves to best fit the published data, because lamp efficacy increases

non- linearly with increased wattage. (NEMA, Public Meeting Transc ript, No. 23 at pp. 71-72; NEMA, No. 24 at p. 8) CA IOUs also supported DOE’s proposal to take an equation- based approach to standards for HID lamps, as it creates a smooth standard level to mirror the natural

2-63progression of lamp efficacy as a function of wattage. Alternatively, a n approach that sets a single, fixed standard for each wattage bin would not impact products of different wattages in an equivalent manner. CA IOUs noted that this could lead to clustering of products at edges of each wattage bin w here the standard is least stringent. (CA IOUs, No. 26 at p. 1-2)

DOE did not receive any adverse comments to the equation- based approach used in the interim analysis. In this NOPD , DOE continues to us e equations to set ELs within each equipment class, whi le separating lamps with certain efficacy altering characteristics into different equipment classes ( e.g. , bulb finish). In th is NOPD, DOE analyzes three equation

- based ELs in the 2800 K – 4500 K, clear and enclosed, 50 W – 400 W equipment class (representing standard efficacy quartz MH, high efficacy quartz MH, and CMH levels), two ELs in the 401 W – 1000 W range (representing standard efficacy quartz MH, and high efficacy quartz MH levels), and one EL in the 1001 W – 2000 W range (representing the high efficacy quartz MH level). As

detailed in section 2.3.2.2

, DOE tentatively determined that standards for HPS lamps are not technologically feasible; therefore, DOE does not consider the economic justification of standards for HID lamps in the economic analysis. As suc h, ELs were not developed and analyzed for HPS lamps in this NOPD . DOE requests comment on the methodology used to

determine ELs in this NOPD

.

2.6.4.2 Highly Efficacious Lighting Systems

In the framework document, DOE requested comment on whether highly efficaciou s lighting systems would be eliminated given a particular lamp efficacy requirement. The concern was that lamp efficacy standards could inadvertently eliminate the most efficient HID system available for a given application. NEMA did not know of any highly efficacious lighting systems

that wou ld be eliminated with a high efficacy lamp standard, although NEMA did caution DOE not to eliminate critical applications (such as those requiring high CRI). (NEMA, No. 11 at p. 21)

DOE received no adverse comments and determined that the standards being considered in the interim analysis would not inadvertently eliminate any highly efficacious lighting systems. DOE received no further comments on highly efficacious lighting systems after the interim analysis

and still finds that the standards being analyze d in this NOPD would not inadvertently eliminate any highly efficacious lighting systems. DOE d iscusses whether standards should be considered for critical applications such as those requiring high CRI in section 2.3.2.6

.

2.6.4.3 Results

In the interim analysis, DOE modeled each CSL equation to represent a particular technology option. After separating out by equipment classes and technology op tions, DOE proposed three CSLs in the 50 W – 400 W representative equipment class, two CSLs in the 401

W – 1000 W representative equipment class, and one CSL in the 1001 W – 2000 W

r epresentative equipment class.

NEMA commented that the constants used in t he equations by DOE are not set properly to match the technology platforms for sale. CSL 1 should be met by most, if not all, probe- start MH lamps; CSL 2 should be met by all pulse-start MH lamps; and CSL 3 should be met by all CMH lamps. (NEMA, No. 24 at p. 8) To match the technology platforms available in the market, NEMA provided DOE with its own suggestions for the equations of CSL curves that were less stringent than those proposed in the interim analysis at most wattages. NEMA also noted that

DOE is u sing manufacturer catalog ratings for the basis of the proposed equations, and because

2-64different manufacturers can choose to make conservative or aggressive claims in their catalogs, DOE cannot focus simply on aggressive claim statements for setting these effic a cy requirements. DOE thus must include and take into account the conservative catalog ratings as well. (NEMA, No. 24 at p. 8)

CA IOUs commented that , conversely, the CSLs used by DOE in the interim analysis were too low. (CA IOUs, No. 26 at pp. 2) CA IOUs plotted quartz arc tube MH lamps with both clear and coated bulbs, as well as open and enclosed ratings, against DOE’s proposed standards and found that there are several quartz MH products that far exceed CSL 1 and CSL 2 throughout the full wattage range. Some clear, enclosed

- rated lamps even exceeded CSL 3, which is meant to represent CMH level performance. CA IOUs suggested that DOE should increase its proposed CSLs to be more representative of the average performance of the products.

CA IOUs recom mended at least a five to ten percent increase over CSLs considered in the interim analysis at the lower wattage ranges, with an increase to about 109 lumens per watt (lm/W) above 1000 W. (CA IOUs, No. 26 at p. 2)

In general, DOE selected CSLs in the inter im analysis to represent a particular design option, and to just allow the representative units of a particular design option. They we re not
levels that we re meant to represent the average efficacy of that technology, nor were they meant to allow every lamp (or only the most efficacious) of a particular technology. They we re meant to reflect the representative units, which are the lamps in the representative equipment classes deemed to be characteristic of the most commonly used lamps. NEMA had concerns tha t certain lamp catalog data selected would be overly aggressive. This was a concern repeated in manufacturer interviews, particularly that small manufacturers seeking a competitive advantage may report aggressively high efficacy data in their catalogs. In the interim analysis, DOE did not select the most efficacious lamps of a particular technology to be a representative unit. Additionally, when selecting representative units, DOE prioritized lamps produced by the

manufacturers with seemingly more conservative claims , because those would be most representative of the performance of lamps installed in the market. Additionally, t he more efficacious representative units that DOE selected maintained mean lumens within 10 percent of the baseline units when possible.

Since publication of the interim analysis, DOE has updated its database of manufacturer catalog data. In light of this updated catalog data, as well as the changes made to the categories of lamps being analyzed and the engineering approach, DOE has reexamined its selection of representative units for this NOPD . See section 2.6.2 and 2.6.3 for complete detail of the representative unit selection. I n this NOPD , the ELs were again modeled to ensure that they allowed the representative units of a particul ar design option to just meet them. The changes in

ELs reflect the NOPD ’s updated representative units.

In the 2800 K – 4500 K, 50 W – 400 W, clear and enclosed representative equipment class, DOE identified three ELs above the baseline. EL 1 corresponds to standard efficacy quartz MH lamps, EL 2 corresponds to high efficacy quartz MH lamps, and EL 3 corresponds to the typical efficacy of CMH lamps.

2-65In the 2800 K – 4500 K, 401 W – 1000 W, clear and enclosed representative equipment class, DOE identified two ELs above the baseline. EL 1 corresponds to the standard efficacy quartz MH lamps and EL 2 corresponds to high efficacy quartz MH.

In the 2800 K – 4500 K, 1001 W – 2000 W, clear and enclosed representative equipment class, DOE identified one EL above the baseline. EL 1 corresponds to the high efficacy quartz MH lamps.

Table 2.6.2 summarizes all of the functions and efficacies describing each equipment

class to be analyzed in the NOPD . DOE requests comment on the described ELs.

Table 2.6.2 Efficacy Level Descriptions for the Representative Equipment Classes in NOPD

Representative Equipment Class Minimum Initial Efficacy (lm/W) *

EL 1 EL 2 EL 3

2800 K

– 4500 K, 50 W

– 400 W, clear/enclosed 38.5 × P 0.1350 44.4 × P 0.1350 40.4 × P 0.1809

2800 K

– 4500 K, 401 W

– 1000 W, clear/enclosed 0.0116 × P + 81.8 0.0116 × P + 95.1 N/A

2800 K

– 4500 K, 1001 W

– 2000 W, clear/enclosed 93.4 N/A N/A

* P is defined as the rated wattage of the lamp.

2.6.5 HID System s

In this NOPD , DOE is considering standards only for HID lamps. However, HID lamps are just one component of an HID lighting system. HID lamps must be paired with specific ballasts to regulate the current and power supplied to the lamp. These lamp-and- ballast systems are then housed in an HID lamp fixture r to protect the components, enable mounting, and direct the light to the target area. When considering changes to HID lamps, DOE recognizes the importance of also analyzing the impact on both the ballast and the fixture. Additional components may also be required if placing a new lamp-and- ballast system in an existing fixture, including an appropriate lamp socket and ballast brackets.

2.6.5.1 Ballasts

In the framework document, DOE stated that its analysis of energy consumption would be based on a lamp -and- ballast system because the lamp and ballast operate together in practice. This approach would include the power losses of the ballast in addition to the lamp wattage to accurately model the impact of lamp standards.

GE commen ted that a customer currently using a probe-start MH lamp would have to purchase and install a new ballast to use a pulse

- start MH lamp. (GE, Public Meeting Transcript, No. 12 at pp. 59-60) Available information supports GE’s comment, and DOE also found th at a change to a more efficacious lamp often involves different technology. For example, when moving from a MV lamp to a more efficacious MH lamp, the change in technology necessitates a change in ballast. A ballast for a MV lamp is designed differently th an a ballast for a MH lamp,

r Here, DOE uses the term “fixture” to refer to the enclosure that houses the lamp and ballast.

2-66and those differences affect the performance characteristics of the ballast, including the ballast efficiency. For the interim analysis, DOE assumed that changing from one lamp technology to another ( e.g. , MV to MH, probe- start MH to pulse- start MH, quartz MH to CMH) while reducing wattage would require a change in ballast , and thus require the purchase of a new fixture.

During the framework meeting, CA IOUs commented that there are some pulse- start MH lamps designed to be operated by a probe- start ballast. (CA IOUs, Public Meeting Transcript, No. 12 at p. 62) Philips clarif ied that some newly developed CMH lamps (which typically

operate only on pulse-start technology) work on probe- start ballasts. (Philips, Public Meeting

Transcr ipt, No. 12 at p. 62) DOE recognizes that pulse-start MH lamps that operate on probestart ballasts are manufactured, but they have a very small market share and are not offered at many wattages. For these reasons, DOE assumed in the interim analysis that for a vast majority of probe- start to reduced wattage pulse

- start MH lamp replacements, a new ballast will be required.

With regard to system energy usage, NEMA commented that system efficiency is dependent on ballast technology and design, and so these factors must be incorporated when determining system efficiency. (NEMA, No. 11 at p. 24) Because HID lamps require a ballast to operate, DOE paired each representative HID lamp in the interim analysis with a representative ballast to develop representative l amp -and-ballast systems. Through catalog review and manufacturer interviews, DOE preliminarily determined for the interim analysis that a new ballast is generally required when an HID lamp is replaced with a more efficacious substitute

because the more eff icacious substitute lamp had a lower wattage. DOE has found that the performance characteristics of a ballast

— most importantly ballast efficiency

— change with wattage. Therefore, to identify an energy conservation standard’s impact on system performance,

th e correct ballast needs to be paired with each representative lamp. For the interim analysis, DOE assumed that any change in lamp wattage or technology necessitates a change of ballast.

While a customer could replace the lamp without a change in ballast in certain situations, DOE found that it was more likely that a customer would replace the ballast as well. Thus, DOE

assumed in the interim analysis that all customers used the more common method of replacing the ballast when changing to a new, compliant la mp.

B allast efficiency must be carefully assigned based on the ballast used with each lamp technology . In the interim analysis, DOE preliminarily determined through analysis of HID ballast catalogs and manufacturer input the appropriate ballast type for each lamp technology. For HPS, MV, and probe- start MH ballasts, a vast majority of the commercially available options DOE identified were magnetic, so DOE selected magnetic ballasts as representative. For quartz pulse- start MH and CMH ballasts, there are magnetic and electronic options commercially available. DOE found ballasts used with pulse- start MH lamps were more commonly magnetic, so DOE selected magnetic ballasts as representative. DOE found that ballasts used with CMH lamps are more commonly electronic, so DOE used electronic MH ballast s with all representative CMH lamps. These ballast type to lamp t echnology pairings are shown in Table

2.6.3 . Next , DOE determined the efficiency of each representative ballast type at all of the analyzed wattages in the interim analysis. For MHLFs subject to the minimum ballast efficiencies required by E PCA (42 U.S.C. 6295(hh)) , DOE assumed the efficiency of the representative ballast type would just me e t th ose minimum requirements. For all other fixture types, DOE assumed ballast efficiencies representative of the least efficient representative ballast

2-67type on the market. Once the efficiencies were determined, DOE used the ballast efficiency and lamp wattage to calculate the overall system power. The total power required, in watts, was calculated by dividing the lamp wattage by the ballast efficiency. By using total system wattage, instead of only the wattage of the lamp, DOE ensured in the interim analysis that ELs increase lamp efficacy while also decreasing lamp -and- ballast system power.

Table 2.6.3 Representative Ballast Types for the Interim Analysis

Lamp Technology Lamp Starting Method Lamp Arc Tube Material Ballast Type

HPS N/A N/A HPS magnetic

MV N/A N/A MV magnetic

MH Probe Quartz MH magnetic

MH Pulse Quartz MH magnetic

MH Pulse Ceramic MH electronic

In response to the interim analysis, NEMA commented that because the HID standards would apply only to lamps, and not the overall HID systems, ballast performance characteristics

are irrelevant to standards for lamp energy efficacy. However, NEMA did note that for simple energy use calculations catalog ballast efficiency data should be adequate. (NEMA, No. 2 4 at p. 9) DOE does not analyze the regulation of ballast efficiency in this NOPD. However, DOE continues to account for any changes in bal last efficiency (typically ballast efficiency decreases in the reduced wattage system relative to the full wattage system) and energy use that correspond

to a change in lamp technology or lamp wattage. In addition to changes in lamp wattage, energy savings from HID lamp standards would also be affected by the characteristic ballast efficiency.

In this NOPD , DOE revised its assumption that any change in lamp wattage or technology necessitates a change in ballast. In the interim analysis, DOE assumed a customer would replace the lamp and ballast in response to standards. DOE still finds that this is the more likely scenario in most situations due to compatibility and convenience concerns. However, DOE

also models the minority of customers who choose different energy saving pathways, which include replac ing a lamp -and- ballast system within an existing fixture. This additional analysis of replacement options is discussed in section 2.6.5.3

.

In this NOPD , DOE also expanded its ballast pairing to account for a number of different

scenarios. T o accurately account for the energ y that could be saved by this NOPD, DOE characterizes the ballast efficiencies of fixtures a customer can buy after the compliance date of potential HID standards , as well as the ballast efficiencies of customers’ existing fixtures. Fixtures purchased after the compliance date of any potential HID lamps standards would have

to comply with the 2017 MHLF standards. 10 CFR 431.326(c),(d), and (e) Customers’ existing fixtures can be characterized by three different types of ballast efficiencies : (1) fixtures not covered by either E ISA 2007 (42 U.S.C. 6295(hh)) or the 2017 MHLF standards, (2) fixtures covered by E ISA 2007 (42 U.S.C. 6295(hh)) but not the 2017 MHLF standards, and (3) fixtures covered by the 2017 MHLF standards

. Fixtures are assumed to have effici encies compliant with

the 2017 MHLF standards if they are covered by the scope of the 2014 MHLF rule and purchased after its compliance date of February 10, 2017 . Fixtures are assumed to have E ISA

2007 compliant efficiencies if they are purchased after Jan uary 1, 2009 but before February 10, 2017 and are covered by the scope of E ISA 2007 (42 U.S.C. 6295(hh)) . Otherwise, fixtures are

2-68assumed to have the least efficient ballast commercially available at that wattage and ballast

type. For all fixtures with electronic ballasts, DOE assumes the ballast efficiency to be equal to

that of the least efficient electronic ballast commercially available at that wattage . This is

because electronic ballast efficiencies are more efficient than the 2017 MHLF standards an d the minimum ballast efficiencies required by E ISA 2007. (42 U.S.C. 6295(hh)) The various ballasts and potential efficiencies are shown in Table 2.6.4 and Table 2.6.5 . DOE requests comment on the ballast efficiencies used in this engineering analysis to calculate energy use.

Table 2.6.4 NOPD Magnetic Ballast Efficiencies

Ballast Type Wattage Least Efficient (%) EISA 2007 (%) 2017 MHLF Standard (%)

Magnetic MH 50 69.4 N/A 76.1

Magnetic MH 70 72.0 N/A 78.2

Magnetic MH 100 77.0 N/A 80.2

Magnetic MH 150* 81.0 N/A 82.4

Magnetic MH 175 81.4 88.0 88.0

Magnetic MH 200 83.3 88.0 88.0

Magnetic MH 250 79.6 88.0 88.8

Magnetic MH 320 79.0 88.0 89.6

Magnetic MH 400 86.0 88.0 90.3

Magnetic MH 575 89.8 N/A 91.0

Magnetic MH 750 91.0 N/A 91.0

Magnetic MH 875 90.0 N/A 92.3

Magnetic MH 1000 92.0 N/A 93.6

Magnetic MH 1500 92.0 N/A N/A

Magnetic MH 2000 95.0 N/A N/A

Magnetic MV 100 83.0 N/A N/A

Magnetic MV 175 85.0 N/A N/A

Magnetic MV 250 87.0 N/A N/A

Magnetic MV 400 89.0 N/A N/A

Magnetic MV 1000 92.0 N /A N/A

Magnetic HPS 250 84.0 N/A N/A

*150 W ballasts are assumed to be in fixtures that are rated for use in wet locations and ambient temperatures greater than 50 o C, and thus are excluded from EISA 2007.

2-69Table 2.6.5 NOPD Electronic Ballast Efficiencies

Ballast Type Wattage Least Efficient (%)

Electronic MH 50 89.0

Electronic MH 70 90.0

Electronic MH 100 90.0

Electronic MH 150 90.0

2.6.5.2 Fixtures

During the framework public meeting, DOE asked stakeholders about the feasibility of inserting a new lamp -and-ballast system into an existing fixture housing. Cooper and GE commented that it would be difficult to retrofit an existing MV fixture to accommod ate a replacement MH system. (Cooper, Public Meeting Transcript, No. 12 at p. 65; GE, Public Meeting Transcript, No. 12 at pp. 66-67) Cooper also said that because currently installed MV fixtures are likely very old, a customer is more likely to simply cha nge the entire fixture rather than trying to fit a new lamp-and-ballast system into the existing fixture. (Cooper, Public Meeting Transcript, No. 12 at p. 67) NEMA commented that the general recommendation is to completely replace the fixture if changing MH technologies. For example, you cannot switch a MH probe- start to MH pulse

- start without extensively retrofitting the fixture. If one tries to retrofit an existing probe -start MH fixture, one must not only replace the ballast, but also the internal wiring and socket because of the high pulse voltages the ballast will deliver. In some cases, it may not be possible to replace the ballast because there is not enough space within the housing for other components ( e.g. , a pulse

- start igniter) and the ballast may never have been UL tested and approved in that housing. (NEMA, No. 11 at p. 19) OSI agreed in the framework public meeting, stating that not only would the ballast need to be changed when going from probe-start to pulse-start, but the socket and wiring of the fixture also would need to be changed to take the high voltage required for a pulse-start system. (OSI, Public Meeting Transcript, No. 12 at pp. 60-61) Cooper agreed with these points and added that an igniter also must be added into the new electrical circuit to strike a pulse -start lamp, which many fixtures may not permit. (Cooper, Public Meeting Transcript, No. 12 at pp. 61-62) Because of these challenges retrofitting a probe- start fixture with a pulse

- start lamp

- an d-ballast system, OSI recommended that DOE analyze the cost of changing technologies, taking into account a customer replacing the entire fixture and not just the lamp and ballast. (OSI, Public Meeting Transcript, No. 12 at p. 75)

According to OSI, another consideration with changing the lamps within an existing fixture is the issue of redirected energy. OSI stated that when placing a lamp into a fixture for which that lamp was not designed, if the arc tube is not correctly position ed within the optical system of the fixture, the reflector could redirect energy back into the arc tube, causing the arc tube to self-destruct. (OSI, Public Meeting Transcript, No. 12 at p. 65) Cooper also commented that differences between an original lamp and replacement lamp such as light center lengths s and other dimensions could cause issues with proper light distribution. (Cooper, Public Meeting Transcript, No. 12 at p. 66)

s Light center length is the distance between the center of the arc tube and a reference plane, typically the bottom of the lamp base.

2-70CA IOUs stated that customers are more likely to replace only the lamp -and-bal last combination. Based on their involvement in advanced lighting program implementation and experience with advanced lighting system installers, CA IOUs find that geometry constraints are rarely an issue when upgrading from probe- start MH to pulse

- start M H. Many pulse

- start MH ballasts advertise compatibility with existing fixtures. Additionally, in some cases, the ballast and igniter are located outside the fixture and remotely operate the lamp. Such systems would not be subject to any fixture space requirements and thus would not require fixture replacement. CA IOUs also recommended that DOE consider products such as the Philips AllStart lamps, which are designed to work with existing probe-start ballasts and would allow customers to realize energy saving s through only lamp replacement. (CA IOUs, No. 8 at p. 4)

In the interim analysis, DOE found it more likely that a customer would replace the entire fixture than take the steps necessary to ensure compatibility of the new lamp in an existing

fixture. While there are a number of situations in which replacing just the lamp or the lamp-andballast system within an existing fixture would be feasible, including the examples provided by CA IOUs, DOE preliminarily determined in the interim analysis that full fixtu re replacement was the more likely cus tomer response to save energy.

With regard to the recommendation by CA IOUs that DOE consider products like the Philips AllStart lamps, DOE found that this product would work on probe- start and pulse

- start
ballasts. Ho wever, DOE did not find other products on the market that had this functionality. Because Philips is the only company found to be making such lamps commercially, the technology was not considered a technology option in the interim analysis.

Based on comments received by stakeholders and information learned in manufacturer interviews, DOE assumed that lamp -and-ballast replacements by customers would typically necessitate a fixture change to allow the fixture housing to be properly designed for the dimensional and thermal needs of the new lamp-and- ballast system. The interim analysis also assumed that retrofitting existing fixtures would often require additional costs that would make such replacements not cost effective, and customers would avoid them. DOE thu s assumed in the interim analysis that any changes in the lamp -and- ballast systems necessitate a fixture change, and calculated the cost of the lamps, ballasts, and fixtures for each level of lamp efficacy analyzed (including the baseline). DOE modeled fix ture replacements as affecting the price of a lamp -and- ballast system to the customer, but not affecting the performance.

In this NOPD , DOE analyz ed additional purchase options relative to the interim analysis. While full fixture replacement was the most l ikely option, DOE found that the analyses for HID lamp standards could be made more accurate by also modeling potential customer responses that did not require full fixture replacement, taking into account the unique costs such replacements would require. Thus, DOE changed its models to capture more options customers have when faced with purchasing a more efficacious lamp in response to standards. As mentioned in the interim analysis, due to costs and compatibility customers would mo re often opt to replace an entire fixture instead of retrofit ting an existing one with a new lamp-and- ballast system. However, DOE has tentatively determined that there are instances where lamp -and- ballast retrofits would not require a change in ballast. One of the concerns with retrofitting a lamp -andballast system in an existing fixture was that the new retrofit system could potentially be larger ( e.g. , going from a probe- start system to a pulse

- start system that will require an additional

2-71igniter). It is important to consider, however, that often these replacement systems will be at reduced wattage and thus the size of the ballast itself will decrease and be easier to fit in the fixture. In terms of optics, customers retrofitting an existing fixture with a new lamp -and- ballast system can identify a replacement lamp that has the same bulb shape and base type in order to fit optimally into the existing fixture optics. Lastly, while acknowledging that retrofitting an old fixture with a new lamp -and- ballast system can decertify a fi xture’s UL rating, DOE has tentatively determined that if this method is cost effective, there are customers who would implement it. DOE is modeling a minority of customers, in specific replacement options where it is feasible and cost effective, retrofitt ing their old fixture with a new lamp -and- ballast system instead of replacing the entire fixture. These replacement options are discussed in more detail in

section 2.6.5.3

.

In this NOPD , DOE assumed that certain fixtures could be retrofitted with a new lamp

and-ballast system. DOE also acknowledges that this is not an option for every customer, and so

the models used in th is NOPD assume a distribution between each of the replacement options based on their cost and availability. DOE also accounted for the additional costs for retrofitting,

which is detailed in section 2.7 . DOE requests comment on the decision to i nclude replacement pathways other than full fixture replacement in this NOPD

.

2.6.5.3 Replacement Options

As discussed in section 2.6.5.2 , DOE assumed in the interim analysis that any change in lamp required by new standards would result in customers replacing their entire fixture. DOE found that there would be issues that would stop customers from replacing just the lamp or just the lamp and ba llast, such as the fact that in many cases

, the retrofit systems would likely not fit in the existing fixtures. Because of this, DOE assumed in the interim analysis that customers would be more likely to replace the entire fixture instead of retrofitting a nd all customers were modeled as using this pathway.

In response to the interim analysis, ASAP commented that analysis of potential standard

levels must be based on the lowest -cost replacement option. In many cases, the lowest- cost option may not be a repl acement of the entire fixture, but rather lamp or lamp -and- ballast replacement. Some customers may not choose the lowest

- cost option in a standards case. However, this additional cost relative to the lowest-cost option cannot be attributed to the

standard because customers would be able to select the lower -cost option. (ASAP, No. 27 at p. 1)

In this NOPD , DOE analyzed several options that customers could choose when faced with new HID energy conservation standards. DOE models energy savings and cost savings based on the expected customer response. DOE has consulted with manufacturers of both lamps and fixtures to determine the frequency with which customers would select particular options in response to standards. Minimizing the first cost t o the customer was one factor in determining how often an option was selected. Purchase option selection distributions are discussed in section

2.9

.

NEEA and CA IOUs both commented that DOE’s analysis assumes every user’s response to potential HID lamp standards will be to purchase a brand new fixture that meets the new standard levels in the event of both lamp failure and ballast failure. In most lamp failure scenarios in the standards case, a full fixture replacement will not be needed because there are

2-72lamp -and- ballast retrofits that allow the fixture to remain. (NEEA, No. 28 at p. 1; CA IOUs, No. 26 at p. 2, 4) ASAP and CA IOUs commented on several other options customers would have in the standards case. They commented that customers could install a high efficacy, reduced wattage retrofit MH lamp that can be used on existing probe- start ballasts. ASAP and CA IOUs again g ave the example of the Philips AllStart lamp, which was designed as a simple

- to

- install retrofit solution that can quickly and easily improve the efficiency of existing HID fixtures. Other reduced wattage lamps from Venture and GE can be used to upgrade ex isting fixture efficiency to provide the same light output and lower power, without additional modifications to the ballast or fixture. (ASAP, No. 27 at p. 1; CA IOUs, No. 26 at pp. 2- 3) ASAP and CA IOUs also commented that customers have the option of ins talling lamp -and- ballast retrofit kits into existing fixtures. There are products marketed as lamp -and- ballast retrofit kits for HID systems from Simkar, Venture, GE, Philips, and Metrolight; and these are designed to serve the exact purpose of upgrading a lamp -and- ballast system within an existing fixture as a viable alternative to full fixture replacement. CA IOUs also provided several examples of case studies that describe the process of upgrading HID fixtures using these lamp-and- ballast retrofit kits t o reduce energy consumption. (ASAP, No. 27 at p. 1; CA IOUs, Public Meeting Transcript, No. 23 at p. 65; CA IOUs, No. 26 at p. 2-4)

In response to these comments, DOE researched all HID technology under consideration for standards that a customer would have when presented with energy conservation standards. Based

on stakeholder feedback and market analysis, DOE assumed in the NOPD that purchase options

customers could choose from when adopting a standards- compliant lamp are :

1. Replacing the existing fixture with a new fixture that houses a compliant lamp with increased efficacy and reduced wattage;

2. R etrofitting the existing fixture with a compliant lamp -and- ballast replacement kit with increased efficacy and reduced wattage;

3. Replacing the lamp with a compliant retrofit lamp that has increased efficacy and reduced wattage, but is designed to operate on the full wattage ballasts;

4. Replacing the existing fixture with a new fixture that houses a compliant lamp with increased efficacy at the same wattage;

5. R etrofitting the existing fixture with a compliant lamp -and- ballast replacement kit with increased efficacy at the same wattage; and

6. R eplacing the lamp with a compliant lamp that has increased efficacy at the same

wattage.

The lamps identified for use with options 1 and 2 are the same, with the difference being option 1 uses an entire new fixture, while option 2 uses a lamp-and- ballast retrofit kit (including new socket and bracket for the ballast). Option 3 requires a different lamp specifically designed

to allow th e ballast to operate below its full wattage. Options 4, 5, and 6 all use the same lamp,with the difference being that option 4 uses an entire new fixture, while option 5 uses a lampand- ballast retrofit kit (including new socket and bracket for the ballas t), and option 6 uses the compliant lamp with the existing fixture and ballast. The details of the lamps s elected are in chapter 5 and appendices 5A and 5B of the NOP D TSD. DOE requests comment on the six replacement options analyzed in this NOPD

.

2-73In this NOPD, DOE identified which of the six purchase options were considered depending

on the characteristics of the HID system being replaced and which component of the HID system failed to trigger the decision to install a new, standards

- compliant lamp. When t he HID lamp reached the end of life, any of the six options would generally be feasible to ensure the new system is compliant. When the ballast reached the end of life, a customer could follow options 1, 2, 4, or 5 because they would need a new ballast in addition to a new lamp. Finally, when the entire fixture has reached the end of life, or in a new construction scenario, a customer would have to replace the entire fixture and would be presented with options 1 and 4. Appendix 5B of the NOPD TSD goes into further detail about the process of identifying commercially available replacements in each of these scenarios.

For each baseline lamp and more efficacious, reduced wattage substitute lamps, DOE tentatively determined what type of lamp would be available in response to standards. Whenever possible, the existing lamp is replaced with a lamp of the same starting method ( e.g. , an EL1 probe-start MH lamp would be replaced with an EL2 probe- start MH lamp, if available). MV lamps, in general, were replaced with p ulse- start MH lamps. The full set of replacement lamp rules, as well as details behind the ballast and fixtures selected for each replacement option, can be found in appendix 5B to the NOP D TSD.

2.6.6 Scaling to Equipment Classes Not Analyzed

For the equipment classes not analyzed directly, DOE discussed a n approach in theframework document to scale the engineering results and ELs from the representative to nonrepresentative equipment classes based on efficacy ratios observed in catalog data or by extrapolatio n across lumen output using regression equations. For example, DOE could calculate an average percent difference in efficacy among lamps in different equipment classes (one representative and one not) and use this percent difference to scale the engineerin g results from the representative to the non

- representative equipment class.

A number of stakeholders expressed concern that linear scaling between representative

and non- representative equipment classes would not be feasible. NEMA commented that linear

sc aling might not work well for discharge lamps because HID lamps are generally non- linear. (NEMA, No. 11 at p. 17) NEMA suggested this would mean that any scaling that would take place would have to account for non- linear effects and lamp designs that have value in the market place ( e.g. , bulb finish and luminaire characteristic). (NEMA, No. 11 at p. 22) OSI also commented that HID lamps are non-linear, so while scaling works for halogen lamps, OSI does not expect scaling to work for HID lamps. (OSI, Public Meeting Transcript, No. 12 at p. 72) OSI further commented that issues of scaling coated versus clear, open

- rated versus enclosed -rated, standby versus not standby, different CCT, different CRI, and different lamp operating orientation could be unworkable. (OSI, Public Meeting Transcript, No. 12 at p. 89) In contrast,

CA IOUs suggested that bulb finish, luminaire characteristic, and other properties could be used to adjust standard levels or to set different classes as appropr iate. (CA IOUs, No. 8 at p. 3)

In the interim analysis, DOE analyzed HID lamp catalog data and found it was possible to develop relationships between initial efficacy and the equipment

- class

- setting factors (clear versus coated lamps, enclosed

- rated versus open

- rated lamps, and lamps in the 2800 – 4500 K and 4501 K – 6999 K CCT ranges). DOE identif ied pairs of lamps in which the only difference between the lamps was the parameter under consideration for scaling. For example, to identify

2-74the scaling factor between clear lamps and coated l amps, DOE identified pairs of lamps within two equipment classes that were manufactured by the same manufacturer, within the same lamp family, and differed only by bulb finish. DOE calculated the average percentage change in initial efficacy for each of these pairs. These averages are used to directly calculate the scaling factors.

In analyzing commercially available lamps, in the interim analysis, DOE found each scaling factor ( one each for bulb finish, luminaire characteristic, and CCT range) to be indepe ndent. Therefore, to scale from a representative equipment class to a scaled equipment class, DOE applied each scaling factor that corresponds to the difference between the two classes. For example, to calculate the EL of the 2800 – 4500 K, 50 W – 400 W, coated and open equipment class, DOE multiplied the EL of the 2800 – 4500 K, 50 W – 400 W, clear and enclosed equipment class by both the bulb finish scaling factor and the luminaire characteristic scaling factor. Table 2.6 .6 summarizes all scaling factors calculated.

Table 2.6.6 Scaling Factors Calculated in Interim Analysis

Bulb Finish Luminaire

Characteristic CCT Range

Scaling Factor* 0.946 0.955 0.880

*T o calculate the efficacy requirement for a scaled equipment class, the representative equipment class equation is multiplied by each scaling factor of the characteristics of the equipment class that differ from the representative class.

In response to the interim analysis, NEMA commented that it supported the use of a scaling factor and family of curves to accommodate clear, coated, open

- and enclosed

- rated lamp combinations. (NEMA, Public Meeting Transcript, No. 23 at p. 72; NEMA, No. 24 at p. 10)

NEMA recommended , however, that DOE clearly state that for each lamp characteristic a scaling factor is allowed to account for the efficacy losses. NEMA recommended 6 percent for coated lamps, 6 percent for open -rated lamps, and 12 percent for coated and open-rated lamps. (NEMA, No. 24 at p. 9)

NEMA also commented that a manufacturer of a significant line of MH lamps with a

CCT of 5000 K did not support the proposed scaling factor of 0.88 that was used in the interim analysis. Th is manufacturer’s ratings show a 0.75 scaling factor compared to sim ilar pulse

- start MH lamps, while no other “major” MH manufacturers had more than a single model with a CCTgreater than 4500 K. (NEMA, No. 24 at p. 2) NEMA also emphasized that high-CRI and highCCT lamps are niche products, which should not have standards considered for them due to their small market share and limited number of products available. However, if DOE includ es them, then scaling factors larger than 12 percent are needed. (NEMA, No. 24 at p. 8)

In the NOPD , DOE updated its set of lamp data from publicly available manufacturer catalogs and recalculated the scaling factors based on this new data set. DOE also updated its methodology for scaling factor calculation. Previously, DOE identified pairs of lamps from the same manufacturer with one in a representative equipment class and the other in a scaled equipment class that only differs by the characteristic being scaled for (bulb coating, luminaire enclosure, and CCT), while keeping all other characteristics as identical as possible (such as bulb shape, base type, operating orientation, CRI). The differences in initial efficacy of these pairs

2-75were then used to calculate the scaling factors. For th is NOPD , DOE allowed pairs of lamps that were not in representative equipment classes to be used in the ca lculations. For example, if there were a pair of lamps where one was enclosed -rated and coated and the other was open-rated and coated, they would not have been used in determining the interim analysis scaling factors because neither was in a representativ e equipment class. However, DOE used this type of pair in

the NOPD

, which this greatly increased the data set DOE used for calculating scaling factors. The new scaling factors used in th is NOPD are shown in Table 2.6.7 . DOE requests comment on the scaling factors used in this NOPD

.

Table 2.6.7 NOPD Scaling Factors

Scaling Factor*

Bulb Finish Luminaire

Characteristic CCT

Interim Analysis 0.946 0.955 0.880

NOPD 0.945 0.950 0.812

*T o calculate the efficacy requirement for a scaled equipment class, the representative equipment class equation is multiplied by each scaling factor of the characteristics of the equipment class that differ from the representative class.

2.7 EQUIPMENT PRICE DETERMINATION

The equipment price determination describes the methodology followed in developing

end- user prices for HID lamps, and associated ballasts, fixtures, and retrofit kit components (brackets and sockets) analyzed in this NOPD.

2.7.1 HID Lamps

In the framework document, DOE discussed an approach to estimate end- user prices for HID lamps directly, rather than to develop MSPs from a bill of materials and manufacturer markup analysis, because it is difficult to reverse -engineer HID lamps. DOE described the plan

to collec t manufacturer suggested price lists (hereafter “blue -book prices”) and apply a discount based on the distribution channel through which the lamp is purchased. In the framework document, DOE requested feedback on the sales distribution channels of HID lamp s, as well ason the allocation of market share among these channels. NEMA responded that although NEMAmember companies cannot comment on pricing, individual companies might choose to comment during confidential manufacturer interviews. (NEMA, No. 11 at p. 22)

For the interim analysis, DOE observed a range of end -user prices paid for a lamp, depending on the distribution channel through which it is purchased. In line with its observation of public pricing, DOE developed three sets of discounts from blue-bo ok prices, representing low (State procurement), medium (electrical distributors), and high (Internet retailers) lamp prices for HID lamps. Starting with a consistent set of aggregated blue-book prices, DOE calculated an average discount ratio for each end -user. DOE found the discount did not vary with wattage or lamp technology, and therefore applied a single discount for all lamps to estimate end-user prices. For the representative lamps for which blue-book prices were unavailable, DOE extrapolated pricin g from lamps whose blue-book prices were available. This was done by using

the blue- book prices of similar lamps from an alternative manufacturer or by interpolating

2-76between blue-book prices of lamps with different wattages within the same lamp family. DOE invited comment on its methodology and results for estimating end- user prices for HID lamps.

In response to the interim analysis, NEEA commented that several municipalities have granular lamp and fixture pricing data that may be available for DOE’s use. ( NEEA, Public Meeting Transcript, No. 23 at pp. 90-91) DOE obtained some lamp price info from municipalities; however, this pricing data was only available for HPS lamps. Because DOE tentatively determined not to include HPS lamps in the full economic analy sis in this NOPD, DOE did not incorporate this pricing information into its analysis for this NOPD

.

DOE received no adverse comment regarding its interim analysis lamp pricing approach

and results. For th is NOPD , DOE continued using the pricing methodology described in the interim analysis to estimate lamp prices. However, DOE update d several inputs to the calculations including: updated blue-book prices, State procurement contracts, and online retail prices. DOE calculated an average blue -book discount for HID lamps purchased through State procurement contracts, and used this discount to develop low end- user prices. Similarly, DOE calculated an average blue -book discount for HID lamps purchased through Internet retailers, and used this discount to develop high end- user prices. For medium end

- user prices, DOE modified its methodology from the interim analysis. Because DOE was unable to obtain an updated list of price quotes from an electrical distributor, the medium end- user discount factors

were calculated a s the mean of the low and high end-user price discounts. DOE then used this

medium blue -book discount factor to calculate the medium end- user prices.

2.7.2 HID Ballasts and Fixtures

DOE understands that an energy conservation standard that requires higher efficacy,

reduced wattage lamps may require customers to purchase a new ballast and fixture. Therefore, for the interim analysis, DOE also developed prices for the HID ballasts and fixtures used with the representative HID lamps. Developing MSPs for ballas ts and fixtures involved two main inputs, a teardown analysis to develop the manufacturer production costs (MPCs) and a manufacturer markup analysis to arrive at the MSPs.

DOE performed teardown analyses of MH ballasts and fixtures to estimate the MPCs.

DO E also was able to use teardown data from the 2014 MHLF rule because of the similarity in manufacturers and covered equipment. 79 FR 7745 (February 10, 2014). To estimate the MPCs for MV ballasts, DOE applied the average discount between the MH ballast MPCs and MH

ballast blue -book values to the MV ballast blue-book values.

Using feedback from interviews of HID fixture manufacturers and fixture data sheets, t
DOE assumed that the MPCs of HPS and MV fixtures were equivalent to comparable MHLFs. Because MV fixtures are generally used in similar applications as MHLFs, DOE used the same MPCs for MV fixtures and MHLFs of the same wattage. Similarly, because HPS fixtures are typically used in outdoor applications, DOE used only the MPCs of MH fixtures used in outdoor applications to assign HPS fixture MPCs. As discussed in section 2.3.2.1

, DOE is not analyzing the economic justification of standards for HPS lamps in the NOPD economic analysis

.

t Fixture datasheets frequently cross list a single fixture for multiple lamp technologies.

2-77To mark up the ballast and fixture MPCs to MSPs, DOE estimated a manufacturer markup multiplier. This markup accounts for the non-production costs and profit. For the interim analysis, DOE assumed the same manufacturer markup for MV and MH ballasts and a separate manufacturer markup for MV and MH fixtures. These two technologies are typically manufactured by the same companies and often in the same facilities. DOE preliminarily determined that the manufacturer markups derived as part of the 2014 MHLF rule were applicable to all ballasts and fixtures considered in analysis of HID lamp standards.

DOE invited comment on its methodology and results for estimating MSPs for HID

ballasts and fixtures in the int erim analysis, and received no adverse comment. DOE continued with the same approach for th is NOPD . However, DOE synchronized the ballast and fixture pricing inputs with the MHLF final rule. 79 FR 7745 (February 10, 2014). Key changes to the MHLF final rule included separate prices for indoor versus outdoor fixtures (the same price was used for both in the MHLF NOPR analysis), revised ballast efficiency requirements and corresponding prices.

For this NOPD , DOE also analyz es lamp -and- ballast retrofit kits as one of the purchase options in the engineering. DOE used existing teardown data to estimate ballast bracket and lamp

socket MPCs. DOE tentatively determined that ballast brackets are typically the same size across

ballast s of different wattages, and thus their MPCs do not vary. DOE tentatively determined that lamp socket MPCs have a slight difference between different rated wattages and across different base types. DOE established separate prices for medium and mogul base sockets with maximum wattages of 660 W, 1500 W, and 2000 W. DOE also established prices for non- screw

- base d sockets with maximum wattages of up to 660 W. DOE then marked up these ballast bracket and lamp socket MPCs using ballast manufacturer markups to estimate MSPs for ballast

- retrofit kits. DOE requests comment on the ballast bracket and lamp sockets MSPs and the methodology used to develop those prices.

See chapter 6 and appendix 6A of th is NOP D TSD for additional detail on the equipment price determination. DOE requests comment on the methodology and results of the equipment price determination.

2.8 MARKUPS ANALYSIS

Markups are multipliers that relate MSPs to end

- user purchase prices, and vary with the distribution channel through which customers purchase the equipment. In the framework document, DOE discussed an approach to estimate end- user prices for representative HID lamp designs directly ( see section 2.7.1 above ), and estimate price markups to calculate end

- user prices from MSPs for HID ballasts and fixtures as inputs to the LCC and PBP analysis, and the

NIA . DOE described a primary distribution channel for HID ballasts and fixtures as from the

manufacturer to an electrical wholesaler ( i.e. , electrical distributor), who in turn sells it to a contractor, who sells it to the end user. OSI noted that ballasts and fixtures could be also sold by a manufacturer or wholesaler directly to an end

- user ( OSI , Public Meeting Transcript, No. 12 at pp. 103-104), but did not receive any specific distribution channel proportions in response to the framework document. DOE also described potential HID lamp distribution channels, and several commenters suggested additional lamp distribution channels. (Cooper, Public Meeting Transcript, No. 12 at pp. 105-106 ; NEMA, No. 11 at pp. 25- 26 ; Philips, Public Meeting

Tran script, No. 12 at pp. 104-105)

2-78For the interim analysis, DOE based its markups for HID ballasts and fixtures on their being sold via an electrical wholesaler, who in turn sells it to a contractor, who sells it to the end

user

. DOE also discussed an approach to derive HID lamp MSPs from end

- user price s for the

NOPD MIA . Interviewed lamp manufacturers indicated that distribution channel markups range from 10 to 50 percent, and are typically around 15 to 30 percent. DOE described using a markup of 1.15 to derive HID lamp MSPs from end- user prices, as thi s lower markup would be more representative of high-volume, lower- price equipment. DOE invited comment on its methodology and results for estimating markups for HID ballasts and fixtures , and deriving lamp

MSPs for the MIA , and received no adverse comment. DOE implemented its interim analysis approach for the NOPD . Chapter 7 of the NOPD TSD provides additional detail on the markups analysis for developing end- user prices for HID ballasts and fixtures.

2.9 ENERGY USE ANALYSIS

The energy use analysis provides est imates of annual energy use for representative HID lamp -and- ballast systems that DOE evaluates in the LCC and PBP analysis and the NIA. In the framework document, DOE discussed a planned approach to estimate energy use by multiplying annual usage (in hours per year) by the system input power (in watts). To derive annual energy usage, DOE would use data published in the 2010 U.S. Lighting Market Characterization (2010 LMC) 2 and other sources. GE agreed with this approach, and OSI recommended that DOE’s commercial operating hour estimates also properly reflect retail operations. (GE, Public Meeting Transcript, No. 12 at p. 100 ; OSI , Public Meeting Transcript, No. 12 at pp. 100-101)

For the interim energy use analysis, DOE developed operating hour distributions for the commercial, industrial, and outdoor stationary sectors using data from the 2010 LMC , which includes operating hours for retail building types ( e.g. , food stores, malls, non- mall retail). DOE invited comment on its energy us e analysis and operating hour estimates in the interim analysis, and received no adverse comment. DOE continued with the same approach for the NOPD

. See chapter 8 of th is NOPD TSD for additional detail on the energy use analysis

. DOE requests comment on methods to improve DOE’s energy use analysis, as well as any data supporting alternate operating hour estimates or assumptions regarding dimming of HID lamp-and- ballast

systems.

2.10 LIFE

- CYCLE COST AND PAYBACK PERIOD ANALYSIS

Energy conservation standards on equipment usually reduce operating expenses and

increase initial end

- user prices. DOE analyzed the net effect of potential new standards on end users by evaluating the net LCC using the cost- effic acy relationship derived in the engineering analysis, as well a s the energy usage and costs derived from the energy use analysis. The LCC is the total customer expense over the life of the equipment, consisting of purchase, installation, and operating costs (expenses for energy use, maintenance, and repair). To comput e the operating costs, DOE discounted future operating costs to the time of purchase and summed them over the lifetime of the equipment. The PBP is the estimated amount of time (in years) it takes customers to recover the increased purchase cost (including installation) of more efficient equipment through lower operating costs. DOE calculates the PBP by dividing the change in purchase cost (normally higher) by the change in first

- year annual operating cost (normally lower) that results from the more efficie nt standard.

2-79In the framework document, DOE discussed its general approach to developing the LCC and PBP model, and received several comments regarding LCC inputs. DOE described surveying energy tariffs on a state- by

- state basis as a means for establishing marginal electricity prices for HID lamp customers. NEMA recommended that DOE also consult the Edison Energy Institute for additional regional price and user information. (NEMA, Public Meeting Transcript, No. 12 at p. 108) Rega rding installation and maintenance costs, DOE invited comment on labor costs and typical relamping practices. GE cited RS Means as a source of electrical labor rates, and noted that labor rates can vary by location. (GE, Public Meeting Transcript, No. 12 at p. 110) Two manufacturers commented that HID lamps are generally spot relamped. (GE, Public Meeting Transcript, No. 12 at pp. 109, 113- 114; OSI , Public Meeting Transcript, No. 12 at pp. 112-113)

For the interim analysis, DOE estimate d electricity prices for commercial, industrial , and outdoor stationary sectors using publicly available, state- level U.S. Energy Information

Administration ( EIA ) Form 826 dat a, 3 and received no adverse comment. DOE used data collected for its July 2010 HID lamps determination

, 4 labor rates for electricians from RS

Means

, 5 and other research ( e.g. , DOE GATEWAY demonstration project results u to verify RS

Means labor rates) to estimate installation costs for the LCC and PBP analysis. EEI and NEEA

comment ed that RS Means estimates are high, and that it should consider other information sources for installation costs. (EEI, No. 25 at p. 2; NEEA, No. 28 at p. 2) For the NOPD analysis, DOE also referenced Sweets Electrical Cost Guide, 6 noting in general that, in combination with

RS Means estimates, it produced installation cost estimates consistent with those used in the interim LCC and PBP analysis. DOE also assumed that all lamp replacements were spot replacements, and received no adverse comment.

For equipment lifetimes in the interim LCC and PBP analysis, DOE assumed that magnetic lamp ballasts last for 50,000 hours and electronic lamp ballasts last for 40,000 hours. Similarly, HID lamp lifetimes vary by lamp technology and equipment class. DOE assumed that ballast and

lam p lifetimes could vary due to both physical failure and economic factors ( e.g. , early replacements due to retrofits). ASAP and CA IOUs comment ed that DOE analysis did not fairly account for the early retirement of replacement fixtures in the standards case . (ASAP, No. 27 at p.2; CA IOUs, No. 26 at pp. 4-6) CA IOUs suggested an approach that adjusts the analysis period to capture the remaining portion of the replacement fixture’s lifetime and accounts for the “salvage value” of the replacement fixture at the end of the analysis period. CA IOUs also suggested that high -quality fixtures might remain in service far longer than the average 20 years and 25 years assumed by DOE for interior and exterior applications, respectively. (CA IOUs, No. 26 at pp. 4- 6) To ca ptur e the value of equipment with remaining life at the end of the analysis period, DOE included the discounted residual values of fixtures, ballasts, and lamps in its LCC and PBP analysis for this NOPD . DOE also used a distribution of fixture, ballast, and lamp lifetimes, which captures both early failures and customers using fixtures beyond the average

lifetimes.

Responding to the interim analysis, CA IOUs and NEEA commented that pulse- start MH

and CMH lamp designs provides better lumen maintenance than baseline technologies, and that these differences should be considered in DOE’s analysis as it relates to lamp lifetimes. NEEA

u DOE GATEWAY reports are available at: http://www1.eere.energy.gov/buildings/ssl/gatewaydemos_results.html

2-80further noted that lumen maintenance is important in instances where lamps ar e replaced when light output drops below 70 percent of initial values. (CA IOUs, No. 26 at p. 6 ; NEEA, No. 28 at p. 2) DOE notes that while the “L 70 ” metric ( i.e. , the operating hours at which light output declines to 70 percent of initial output) is widel y accepted in characterizing LED sources, it is not a common metric for HID sources. IES LM-47 (Life Testing of HID Lamps) 7 specifies that, for life testing purposes, photometric measurements are made at 40 percent and 70 percent of lamp life, for comparis on to initial light output. IES DG-4-03 (Design Guide for Roadway Lighting Maintenance) 8 recommends group relamping at two- thirds to three

- quarters (approximately 67 percent to 75 percent) of rated lamp life. This IES guidance suggests that

lumen maintenan ce at 70 percent of rated lamp life is potentially useful in designing HID lighting installations, but is explicitly grounded in percentage of lifetime and not a lumen maintenance (light output) percentage. I n its review of manufacturer literature, DOE als o could not find any instances where mean lumen values for HID lamps were reported for 70 percent of

rated life. Further, based on manufacturer comments, DOE assumed for its interim and NOPD analyses that spot relamping ( i.e. , upon lamp failure) is the predominant relamping method for HID lamps. As a result, DOE believes its average lamp lifetimes adequately characterize the improved operating lifetimes of pulse- start MH and CMH lamps, and retained this approach for

its NOPD analysis.

DOE designed the interim LCC and PBP analysis around scenarios where customers need to purchase an HID lamp. The three “triggering events” that were modeled were lamp purchase (replacement lamp), lamp and ballast purchase (lamp that is purchased when failed ballast is replaced), and fixture purchase (fixture replacement or new construction). These are the base

case events. In the standards case, all three of these events were assumed to require the purchase

of a new fixture. Several commenters stated that DOE should also co nsider retrofit lamps and

kits as an alternative to a full ballast and fixture replacement. ( ASAP, No. 27 at p. 1; CA IOUs, No. 8 at p. 4; EEI, No. 25 at p. 1; NEEA, No. 28 at p. 1) DOE incorporated a range of standards case purchase options in its NOPD an alysis, with availability of options dependent on the particular triggering event. In the case of existing fixture failure, only fixture replacements are considered in the standards case. For ballast failures, both full fixture replacement and ballast

retr ofit kits are analyzed. Lamp failures entail options of full fixture replacement, ballast

- retrofit kits, and lamp retrofits. ASAP further noted that DOE’s analysi s of potential standard levels must be based on the lowest-cost replacement option, which may not be replacement of the entire

fixture but rather a la mp or lamp/ballast replacement. (ASAP, No. 27 at p. 1 ) DOE’s NOPD analysis modeled each of the replacement options, including the lowest-cost option, appropriate to each of the triggering events described above.

Chapter 9 and appendices 9A and 9B of the NOPD TSD provide details on the spreadsheet model and all the inputs to the LCC and PBP analysis. DOE requests comment on methods to improve DOE’s equipment price projections, as well as any data supporting alternate methods.

2.11 SHIPMENTS ANALYSIS

Projections of equipment shipments are needed to calculate the national effects of standards on energy use, NPV, and future manufacturer cash flows. In the framework document, DOE discussed a planned approach to develop shipment projections based on an analysis of key market drivers for each considered HID lamp type, with shipments of equipment driven by new

2-81construction, stock replacements, and other types of purchases. DOE invited comment on its planned shipments analysis approach in the framework document, and received no adverse

comment.

For the interim analysis, DOE implemented the general approach described in the framework document, developing a shipments model that takes an accounting approach, tracking

mark et shares of each equipment class and the vintage of units in the existing stock. Stock accounting uses equipment shipments as inputs to estimate the age distribution of in- service equipment stocks for all years. The age distribution of in- service equipmen t stocks is a key input to calculations of both the NES and the NPV, because operating costs for any year depend on the age distribution of the stock. To characterize customer behavior under potential new standards, DOE developed a “roll- up” shipment scena rio. The roll- up scenario represents a standards case in which all equipment in the base case that do not meet the standard would roll up to meet the

new standard level. Customers who in the base case ( i.e. , absent standards) purchase fixtures

above the standard level are not affected as they are assumed to continue to purchase the same

base case fixture in the roll -up scenario. The roll- up scenario characterizes customers primarily driven by the first cost of the fixture.

In the interim shipments analys is, DOE calculated the installed fixture stock using

historical lamp shipment data from NEMA and DOE sources , and projected shipments for future years. DOE estimated the installed stock during the analysis period based on the average service

lifetime of ea ch lamp type. CA IOUs commented that DOE’s triggering events for HID lamp purchases resulted in a disparity between total stock of equipment in the base case and standards case, which they believe must be equal to accurately model the energy savings and co st effectiveness of potential standards. (CA IOUs, No. 26 at pp. 6-7) DOE verifies that total equipment stocks are preserved in the base case and standards case in the NOPD shipments analysis.

For more detail on the shipments analysis, see chapter 10 of t h e NOPD TSD. DOE
requests comment on whether its shipment projections are reasonable and likely to occur . DOE also requests comment on how potential new standards could affect the rate at which HID lamp customers transition to non-HID technology, and any impediments that would prevent switching

to non- HID lighting to garner further energy savings.

2.12 NATIONAL IMPACT ANALYSIS

The NIA assesses the NPV of total end -user LCC and NES. In the framework document, DOE discussed a planned general approach to develop its NIA model to determine the NPV and NES for the performance levels considered for the equipment classes analyzed. DOE invited comment on its planned NIA approach in the framework document, and received no adverse

comment.

For the interim analysis, DOE implemented the general approach described in the framework document, preparing an NIA spreadsheet model to forecast energy savings and the national economic costs and savings resulting from potential new standards. In determining NES,

DOE calculated the n ational energy consumption by multiplying the number of units, or stock, of HID lamp -and- ballast systems (by vintage, which represents the age of the equipment) by the unit energy consumption (also by vintage). Then, DOE calculated national annual energy savings

2-82from the difference between national energy consumption in the base case (without new effic acy standards) and in each higher efficacy standards case. DOE estimated energy consumption and savings based on site energy, and converted the electricity consumption and savings to source

energy. DOE also estimated full

- fuel -cycle (FFC) energy savings, which consider the energy consumed in extracting, processing, and transporting primary fuels ( i.e. , coal, natural gas, petroleum fuels), and thus present a more complete picture of the impacts of energy effic acy standards. DOE’s approach is based on calculation of an FFC multiplier for each of the energy types used by covered equipment. 76 FR 51282 (August 18, 2011), as amended at 77 FR 49701 (August 17, 2012). Cumulative energy savings are the sum of the annual NES, which DOE determined over specific time periods.

In determining NPV, DOE calculate d net savings each year as the difference between total operating cost savings and increases in total installed costs (including price and installation cost).

DOE calculate d savings over the life of the equipment, accounting for differences in yearly energy rates. DOE calculate d NPV as the difference between the present value of operating cost savings and the present val ue of increased total installed costs. DOE discounted future costs and savings to 2013 with a discount factor. DOE calculated increases in total installed costs as the product of the difference in the total installed cost between the base case and standards case , and the annual shipments in the standards case. Because purchase costs of the higher efficacy equipment in the standards case are generally greater than the purchase costs of equipment in the base case, price increases appear as negative values in the NPV. DOE expressed operating cost savings as decreases in operating costs associated with the lower energy consumption of equipment in the standards case compared to the base effic acy case. Total operating cost savings are the product of savings per unit and the number of units of each vintage surviving in a particular year.

The NIA evaluates impacts over a period corresponding with the lifetime of equipment

sold over a 30- year period, starting with the year that manufacturers must first comply with new standards. EEI commented that this long- term assessment is not appropriate for HID lamps, which have comparatively shorter operating lifetimes. (EEI, No. 25 at pp. 3-4 ) DOE’s assumption that HID lamps would be available to purchase for 30 years allows DOE to better capture the long

- term impacts of potential new standards, and is consistent with DOE analyses for other products and commercial equipment.

In response to the interim analysis, EEI also commented that DOE should incorporate in its baseline energy usage all changes to interior lighting power densities, exterior lighting power densities, and lighting control requirements published in the latest editions of ASHRAE 90.1 and the International Energy Conservation Code, Residential and Commercial Chapters . EEI

contended that using any other baseline would overstate any energy and economic savings resulting from potential new standards. Incorporating these requirements would reduce the baseline energy usage of many HID fixtures and therefore should lower the energy usage baseline for any analysis. (EEI, No. 25 at pp. 4-5) DOE acknowledges that these requirements can reduce HID system energy usage in the absence of potential new standards; however, it is beyond the scope of this determination to project the implementation of, compliance with, and resulting energy savings from these requirements over DOE’s economic analysis periods. DOE

notes that its NOPD analysis did not incor porate these requirements, but nonetheless illustrated that new HID lamp standards would not provide net economic benefits for the Nation.

2-83DOE’s interim shipments analysis accounted for non- HID technologies ( e.g. , LED, highintensity fluorescent) penetrati ng the HID marketplace and eroding lamp shipments in the base

case and standards case. CA IOUs commented that DOE should account for savings from a

standards -induced market shift to other more efficient technologies in the NIA. (CA IOUs, No. 26 at pp. 9- 11 ) DOE recognizes this effect but, consistent with rulemakings for other products and commercial equipment, confines projected economic benefits to the regulated technology. DOE believes that its shipment projections capture the main effect of migration to other lighting technologies, and illustrate a significant decrease in total HID lamp shipments. DOE reserved the standards case shipments scenario to characterize the purchasing behaviors of remaining HID lamp customers, and retained its NIA approach for this NOPD

.

Chapter 11 and appendices 11A and 11B of the NOPD TSD provide details on the spreadsheet model and all the inputs to the NIA.

2.13 MANUFACTURER IMPACT ANALYSIS

DOE conducted an MIA to estimate the financial impact of potential energy conservation standards on manufacturers of the analyzed HID lamps. The MIA also estimates the impact potential standards could have on domestic employment, manufacturing capacity, manufacturer subgroups, and the cumulative regulatory burden. The MIA has both quantitative a nd qualitative aspects. The quantitative aspect of the MIA primarily relies on the Government Regulatory Impact Model (GRIM), an industry cash -flow model customized for HID lamps analyzed in this rulemaking. The key GRIM inputs are industry cost structure data, MPCs, and shipments, as well as assumptions about manufacturing markups and conversion costs. The key MIA output is the industry net present value (INPV). DOE used the GRIM to calculate cash flows using standard accounting principles and to compare c hanges in INPV between a base case and various ELs for each equipment class (the standards case). The difference in INPV between the base and standards cases represents the financial impact of potential standards on manufacturers of the analyzed HID lamps. DOE employed different assumptions about manufacturer markups to produce ranges of results that represent the uncertainty about how HID lamp manufacturers could respond to potential standards. The qualitative part of the MIA addresses factors such as

manu facturing capacity; characteristics of, and impacts on, any particular subgroup of manufacturers; impacts on competition; and the cumulative regulatory burden of HID lamp manufacturers. The complete MIA is outlined in chapter 12 of this NOPD TSD.

DOE cond ucted the MIA in three phases. In phase 1, “Industry Profile,” DOE prepared an industry characterization. In phase 2, “Industry Cash Flow,” DOE used publicly available information developed in phase 1 to adapt the GRIM structure to facilitate the analysis of potential energy conservation standards for HID lamps. In phase 3, “Subgroup Impact Analysis,” DOE conducted interviews with manufacturers representing more than 80 percent of domestic HID lamp sales analyzed by this rulemaking. During these interviews, DOE discussed engineering, manufacturing, procurement, and financial topics specific to each company, and also obtained each manufacturer’s view of the industry as a whole. The interviews provided valuable information DOE used to evaluate the impacts of potential standards on manufacturer cash flows, manufacturing capacities, and employment levels.

2-842.13.1 Discussion of Comments

Interested parties commented on the assumptions and results of the both the framework document and the interim analysis. Comments address ed the potential shift to other lighting technologies in response to potential HID lamp standards, diverting resources from alternative investments, and the testing and certification burden of potential new standards. DOE addresses

these comments below.

CA IOUs commented that the MIA should account for the accelerated market shift to fluorescent technologies and LEDs that they believe would result if HID standards were implemented. They stated that an additional standards-induced shift could be modeled by

i ncreasing the rate of market penetration of alternative lighting sources in the standards cases. (CA IOUs, Public Meeting Transcript, No. 23 at p. 134) Based on the shipment analysis DOE does not believe the HID lamp market would increasingly migrate from HID technologies to alternate lighting technologies, such as fluorescents and LEDs, in direct response to HID lamp standards. While DOE recognizes that fluorescents and LEDs are continuing to capture more of the lighting markets serviced by HID lamps, DOE does not believe that HID lamp standards being set would increase this shift to fluorescents and LEDs. Therefore, this market shift to fluorescents and LEDs is captured in the base case shipment scenario and is not analyzed as a

standards

- induced market shift. DOE excludes the revenue from fluorescents and LEDs earned by manufacturers who also produce HID lamps in the GRIM because the revenue stream would be present in both the base case and the standards cases, resulting in no net impact on the change

in I NPV.

Cooper stated that very few resources are being invested in HID lamps and fixtures. Cooper maintained that instead, most lighting manufacturers are investing their limited resources in LEDs, which is the lighting technology that they believe will be most relevant in the next five years. (Cooper, Public Meeting Transcript, No. 12 at p. 80) DOE recognizes the opportunity cost associated with any investment, and that manufacturers would need to spend capital to meet any potential HID lamp standards that they would not have to spend if no standards are proposed for HID lamps . The allocation of company resources among different lighting technologies is a complex business decision that each individual manufacturer will ultimately have to make.

M anufacturers m ust determine the extent to which they will balance investment in the HID lamp market with investment in emerging technologies, such as LEDs. The se companies will have to weigh tradeoffs between deferring investments and deploying additional capital. DOE includes

the costs to manufacturers of meeting all analyzed ELs for each equipment class in its analysis.

At the framework public meeting Philips commented that new energy conservation standards for HID lamps would cause manufacturers to incur significant t esting and reporting requirements, which would be especially burdensome for small manufacturers. (Philips, Public Meeting Transcript, No. 12 at pp. 143-144) OSI added that the costs would be significantly more if mean or maintained lumens were required to be tested instead of initial lumens. Because HID lamps are very long-lived equipment, testing mean or maintained lumens would require manufacturers to burn the lamps for thousands of hours and incur huge electricity bills just to test the equipment. (OSI, Public Meeting Transcript, No. 12 at p. 144) At the interim analysis public meeting, NEMA commented that product conversion costs, especially testing costs, would be overly burdensome on manufacturers. They contended that the testing laboratories at many

2-85companies do not have the capacity to handle the increased testing load that would be driven by any new standards and consequently these companies would have to make significant investments to increase capacity. (NEMA, No. 24 at p. 12) At the framework public meeting, NEMA also commented that these potential increases in testing and compliance costs increase the overall cumulative regulatory burden on lighting manufacturers as most lighting manufacturers also produce several other lighting technologies subje ct to regulation. DOE recognizes that manufacturers would need to spend capital to meet any potential HID lamp standards that they would not have to spend in the absence of HID lamp standards . DOE included potential product conversion costs that would have to be incurred by manufactu rers at each EL in its analysis, including the costs NEMA mentioned in their comment. Also, because DOE is not proposing standards for HID lamps, the cumulative regulatory burden on lighting

manufacturers would not be increased due to this NOPD.

2.13.2 Regulatory Flexibility Act

DOE reviewed the proposed determination under the provisions of the Regulatory Flexibility Act and the policies and procedures published on February 19, 2003. The proposed determination finds standards are not j ustified, resulting in a negative determination. No energy conservation standards are proposed in this NOPD. On the basis of the foregoing, DOE certifies that the proposed determination, if adopted, would have no significant economic impact on a substantial number of small entities. Accordingly, DOE has not prepared an IRFA for this proposed determination. DOE will transmit this certification and supporting statement of factual basis to the Chief Counsel for Advocacy of the Small Business Administration for review under 5 U.S.C. 605(b).

2.14 PROPOSED DETERMINATI ON

DOE analyzed the benefits and burdens of several potential ELs for HID lamps that we re the subject of the interim analysis. DOE received comment that DOE should require a level of efficacy that cannot be met by MV lamps. CA IOUs stated that the Energy Policy Act of 2005 (EPACT 2005) banned manufacturing and importation of MV ballasts except those used for specialty applications. However, because the MV ballasts installed prior to the ban could take

deca des to reach end of life, the phase-out of MV technology will still take many years. To accelerate the elimination of MV technology, CA IOUs commented that the standards proposed should effectively ban MV lamps for general illumination by requiring efficac ies that cannot be met with MV technology. (CA IOUs, No. 8 at p. 5) Similarly, NEMA commented that DOE should select a standard level that specifies the least stringent EL analyzed as the efficacy standard, as it represents MH lamps with double the efficac y of baseline MV lamps. NEMA goes on to say that more efficient ELs represent only a small increase in efficacy that cannot be economically justified. (NEMA, No. 24 at p. 8) In this NOPD, DOE tentatively determined that the benefits did not outweigh the burdens at any potential standard level, including a potential

standard level that would effectively eliminate MV lamps

.

As required by EPCA, this NOPD analyzes whether standards should be established for HID lamps based on the criteria of technological fea sibility, economic justification, and likelihood for standards to result in significant energy savings. (42 U.S.C. 6317(b)(1)) DOE is to set standards for HID lamps only if potential standards meet all three of these requirements, each

of which is discusse d below.

2-862.14.1 Technological Feasibility

EPCA mandates that DOE determine whether energy conservation standards for HID lamps would be “technologically feasible.” (42 U.S.C. 6317(a )(1)) DOE proposes to determine that standards for HPS lamps would not be technologically feasible due to the lack of technology options discussed in section 2.4.2.2 . DOE proposes to determine that energy conservation

standards for other HID l amps (MV and MH lamps) would be technologically feasible because they can be satisfied with HID lighting systems currently available on the market.

2.14.2 Significance of Energy Savings

EPCA also mandates that DOE determine whether energy conservation standards for HID lamps would result in “significant energy savings.” (42 U.S.C. 6317(a )(1)) Today’s proposed determination estimates that a standard for HID lamps would result in energy savings

of up to 1.6 quads over a 30- year analysis period (20 17–2046)

. See chapter 11 of the NOPD TSD for additional detail on the national energy savings. Therefore, DOE proposes to determine that potential energy conservation standards for HID lamps would result in significant energy savings.

2.14.3 Economic Justification

EPCA requires DOE to determine whether energy conservation standards for HID lamps

would be economically justified

. (42 U.S.C. 6317(b)(1)) DOE conducted an LCC analysis to

estimate the net costs and benefits to users from increased effic a cy in the considered HID lamps.

DOE then aggregated the results from the LCC analysis to estimate national energy savings and national economic impacts. DOE also conducted an MIA to estimate the financial impact of potential energy conservation standards on manufacturers. See chapters 9, 11, and 12 of the NOPD TSD for the results of the LCC, NIA, and MIA analyses respectively.

DOE first considered the most efficacious level, EL 3, which is applicable only to the 50

W

– 400 W equipment class. EL3 would have a negative NPV at both a 7-percent and 3-percent discount rate. EL3 could result in HID lamp manufacturers experiencing a loss in INPV. On the basis of the negative NPV and decrease in industry value for HID lamp manufacturers, DOE determined that the EL3 standard was not economically justified.

DOE then considered the next most efficacious level, EL2, which applies to the 50 W –

400 W and 401 W – 1000 W equipment classes. EL2 results in a negative NPV for all applicable equipment cla sses at both a 7

- percent and 3 -percent discount rate. Available designs result in positive mean LCC savings for the 50 W – 400 W equipment class and negative mean LCC savings for the 401 W – 1000 W equipment class. However, a majority of consumers affected by the standard experience a net cost at EL2 in all applicable equipment classes. EL2 could result in HID lamp manufacturers experiencing a loss in INPV for the applicable equipment classes. On the basis of the negative NPV, majority of consumers affected by the standard experiencing a net cost, and potential decrease in industry value for HID lamp manufacturers, DOE determined that an EL2 standard was not economically justified.

DOE finally considered EL1, which would apply to all equipment classes. DOE’s NPV analysis indicates that all equipment classes have a negative or negligible NPV at a 7

- percent and

2-873-percent discount rate for EL1. A vailable designs result in negative mean LCC savings for all

three of the representative equipment classes at E L 1, wi th a majority of consumers affected by the standard experiencing a net cost

. EL1 could result in HID lamp manufacturers experiencing a loss in INPV for all equipment classes. On the basis of the negative NPV, negative mean LCC savings, majority of consumers affected by the standard experiencing a net cost, and decrease in industry value for HID lamp manufacturers, DOE determined that an EL1 standard was not economically justified.

2.14.4 Conclusions

DOE tentatively determined that potential standards for HID lamps are either not technologically feasible or not economically justified. DOE will consider all comments received on this proposed determination in issuing any final determination of whether standards for HID lamps would be technologically feasible and economically justified, and would result in significant energy savings, If DOE determines that all of these criteria are met, DOE must prescribe test procedures and energy conservation standards for HID lamps. If DOE determines

that one or more of the criteria are not met, DOE will not consider establishing test procedures and standards for these lamps.

2-88REFERENCES

1 U.S. Census Bureau. Manufacturing, Mining, and Construction Statistics . Current Industrial Reports, Electric Lighting Fixtures, MA335L. 2001. (Last accessed March 2, 2012).

www.cen sus.gov/mcd/

2 U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Final Report: 2010 U.S. Lighting Market Characterization. 2012. Washington, D.C. http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010- lmc

- final

- jan -2012.pdf

.

3 U.S. Energy Information Administration. Form EIA -826 Detailed Data . EIA: Washington,

D.C. www.eia.gov/cneaf/electricity/page/eia826.html

4 U.S. Department of Energy– Office of Energy Efficiency and Renewable Energy . Energy Conservation Program for Consumer Equipment: Preliminary Technical Support Document: High -Intensity Discharge Lamps. 2010. Washington, D.C. www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/60

5 R.S. Means Company, Inc. 2010 RS Means Electrical Cost Data . 2010. Kingston, MA.

6 Sweets

- McGraw Hill Construction. Sweets Electrical Cost Guide 2013 . 2012. Vista, CA.

7 Illuminating Engineering Society. IES LM -47-12: Approved Method for Life Testing of High Intensity Discharge Lamps . 2012. New York, NY.

8 Illuminating Enginee ring Society. IES DG -4-03: Design Guide for Roadway Lighting

Maintenance . 2003. New York, NY.

2-89CHAPTER 3. MARKET AND TECHNOLOG Y ASSESSMENT

TABLE OF CONTENTS

3.1 INTRODUCTION

........................................................................................................... 3-1

3.2 LAMPS ANALYZED BY TH IS DETERMINATION

................................................... 3-1

3.2.1 Definitions

............................................................................................................ 3-1

3.2.1.1 High

- Intensity Discharge Lamp

............................................................... 3-2

3.2.1.2 Mercury Vapor Lamp .............................................................................. 3-2

3.2.1.3 Metal Halide Lamp

.................................................................................. 3-2

3.2.1.4 High

- Pressure Sodium Lamp

................................................................... 3-3

3.2.2 Characteristics of Lamps Considered for Analysis .............................................. 3-3

3.2.2.1 Wattage

.................................................................................................... 3-3

3.2.2.2 CCT

.......................................................................................................... 3-4

3.2.2.3 Directional Lamps

.................................................................................... 3-5

3.2.2.4 Self

- Ballasted Lamps

............................................................................... 3-5

3.2.2.5 Lamps Designed to Operate Exclusively on Electr onic Ballasts

............. 3-6

3.2.2.6 High

- CRI Lamps

...................................................................................... 3-7

3.2.2.7 Colored MH Lamps ................................................................................. 3-8

3.2.2.8 Lamps for Specialty Applications

............................................................ 3-8

3.2.2.9 Electrodeless Lamps

................................................................................ 3-9

3.2.2.10 F-Rated Lamps .................................................................................. 3-10

3.2.3 Summary

............................................................................................................ 3-10

3.3 MARKET ASSESSMENT

............................................................................................ 3-11

3.3.1 Trade Associations

............................................................................................. 3-11

3.3.2 Manufacturers of High-Intensity Discharge Lamps .......................................... 3-12

3.3.3 Small Businesses

................................................................................................ 3-13

3.3.4 Regulatory Programs

......................................................................................... 3-13

3.3.4.1 Federal Energy Conservation Standards ................................................ 3-13

3.3.4.2 Canadian Energy-Efficiency Standards ................................................. 3-16

3.3.4.3 European Energy-Efficiency Regulations .............................................. 3-16

3.3.5 Non

- Reg ulatory Initiatives

................................................................................. 3-19

3.3.5.1 Federal Energy Management Program .................................................. 3-20

3.3.5.2 ENERGY STAR

.................................................................................... 3-20

3.3.5.3 Energy Efficient Commercial Building Deduction ................................ 3-22

3.3.5.4 Efficiency Vermont ................................................................................ 3-22

3.3.5.5 Pacific Gas and Electric

......................................................................... 3-22

3.3.5.6 San Diego Gas and Electric Company ................................................... 3-23

3.3.5.7 Omaha Public Power District

................................................................. 3-24

3.3.5.8 Lyon-Lincoln Electric Cooperative, Inc. ............................................... 3-25

3.3.5.9 North Carolina Municipal Power Agency 1 .......................................... 3-25

3.3.6 High -Intensity Discharge Lamp Shipments ....................................................... 3-26

3.4 TECHNOLOGY ASSESSMEN T .................................................................................. 3-29

3.4.1 Basic Structure and Operation of HID Lamps ................................................... 3-29

3.4.2 Mercury Vapor Lamps ....................................................................................... 3-32

3-i3.4.2.1 Lamp Construction

................................................................................. 3-32

3.4.2.2 Lamp Operation

..................................................................................... 3-34

3.4.3 High

- Pressure Sodium Lamps

........................................................................... 3-35

3.4.3.1 Lamp Construction

................................................................................. 3-36

3.4.3.2 Lamp Operation

..................................................................................... 3-38

3.4.4 Metal Halide Lamps

........................................................................................... 3-41

3.4.4.1 Lamp Construction

................................................................................. 3-41

3.4.4.2 Lamp Operation

..................................................................................... 3-48

3.4.5 HID Ballasts

....................................................................................................... 3-50

3.4.5.1 Magnetic Ballasts

................................................................................... 3-50

3.4.5.2 Electronic Ballasts

................................................................................. 3-52

3.4.6 HID Fixtures

...................................................................................................... 3-55

3.4.7 HID Lamp Technology Options

........................................................................ 3-55

3.4.7.1 Mercury Vapor Lamps ........................................................................... 3-55

3.4.7.2 High

- Pressure Sodium Lamps

............................................................... 3-56

3.4.7.3 Metal Halide Lamps

............................................................................... 3-56

3.4.7.4 Summary

................................................................................................ 3-57

3.5 EQUIPMENT CLASSES

.............................................................................................. 3-58

3.5.1 Directionality

..................................................................................................... 3-58

3.5.2 Ballast Location

................................................................................................. 3-58

3.5.3 CCT

.................................................................................................................... 3-59

3.5.4 Wattage

.............................................................................................................. 3-59

3.5.5 Bulb Finish ......................................................................................................... 3-61

3.5.6 Luminaire Characteristic

.................................................................................... 3-62

3.5.7 Lamp Operating Orientation .............................................................................. 3-64

3.5.8 CRI

..................................................................................................................... 3-65

3.5.9 Standby Lamps ................................................................................................... 3-66

3.5.10 Bulb Shape ......................................................................................................... 3-66

3.5.11 Base Type

........................................................................................................... 3-66

3.5.12 Equipment Class Summary ................................................................................ 3-67

REFERENCES

.......................................................................................................................... 3-68

LIST OF TABLES

Table 3.3.1 MHLF Standards from 2014 Final Rule ................................................................. 3-15 Table 3.3.2 Canadian Proposed Standards for HID Lamp Ballasts ........................................... 3-16 Table 3.3.3 Minimum Efficacy EU Requirements for HPS Lamps with a Color Rendering Index (Ra) ≤ 60 (Second Stage) ........................................................................................................... 3-17 Table 3.3.4 Lumen Maintenance and Lamp Survival Factors for HPS Lamps (Second Stage) 3-18

Table 3.3.5 Minimum Efficacy EU Requirements for MH Lamps with Ra ≤ 60 and for HPS Lamps with Ra > 60 (Second Stage) ......................................................................................... 3-18 Table 3.3.6 Minimum Efficacy EU Requirements for other HID Lamps (Second Stage) ........ 3-18 Table 3.3.7 Minimum Efficacy EU Requirements for MH Lamps (Third Stage) ..................... 3-19 Table 3.3.8 Lumen Maintenance and Lamp Survival Factors for MH Lamps (Third Stage) .... 3-19 Table 3.3.9 FEMP Efficiency Requirements for Federal Purchases ......................................... 3-20

3- iiTable 3.3.10 ENERGY STAR Residential and Commercial Directional Luminaire Requirements

................................................................................................ .................................................... 3-21

Ta ble 3.3.11 ENERGY STAR Residential Non- Directional Luminaire Requirements ............ 3-21 Table 3.3.12 PG&E HID Lamp and Fixture Rebates (2013-2014) ........................................... 3-23 Table 3.3.13 SDG&E HID Lamp and Fixture Rebates ............................................................. 3-24 Table 3.3.14 OPPD 2013 Retrofit and Replacement Incentives ................................................ 3-25 Table 3.3.15 Historical Shipments of HID Lamps .................................................................... 3-29 Table 3.4.1 Building Blocks of an HID Ballast and Associated Characteristics ....................... 3-54 Table 3.4.2 NOPD HID Lamp Technology Options ................................................................. 3-57 Table 3.5.1 Equipment Class Divisions Based on CCT ............................................................ 3-59 Table 3.5.2 Equipment Class Divisions Based on Wattage ....................................................... 3-61 Table 3.5.3 Equipment Class Divisions Based on Bulb Finish ................................................. 3-62 Table 3.5.4 Equipment Class Divisions Based on Luminaire Characteristic ............................ 3-64 Table 3.5.5 HID Lamps NOPD Equipment Classes .................................................................. 3-67

LIST OF FIGURES

Figure 3.3.1 Shipments of HID Lamps ...................................................................................... 3-26 Figure 3.3.2 HID Lamp Market Share by Lamp Type .............................................................. 3-27 Figure 3.3.3 2010 HID Lamp Market Share .............................................................................. 3-28 Figure 3.4.1 Light Emission Process of an HID Lamp .............................................................. 3-31 Figure 3.4.2 Mercury Vapor Lamp Construction 23 .................................................................... 3-33 Figure 3.4.3 Mercury Vapor Spectral Power Distributions ....................................................... 3-35 Figure 3.4.4 High -Pressure Sodium Lamp Construction ........................................................... 3-37 Figure 3.4.5 Cross Section of a Typical Se al Assembly for an HPS Lamp with a Ceramic Arc

Tube ........................................................................................................................................... 3-38 Figure 3.4.6 High

- Pressure Sodium Spectral Power Distributions ............................................ 3-40 Figure 3.4.7 Operation Limits for 400 W HPS Lamp................................................................ 3-41 Figure 3.4.8 Metal Halide Lamp Construction .......................................................................... 3-42 Figure 3.4.9 Common Conf igurations for Horizontal Metal Halide Lamps .............................. 3-43 Figure 3.4.10 Common MH Arc Tubes: (a) Ovoid, (b) Pinched Body ..................................... 3-44 Figure 3.4.11 CMH Lamp Arc Tube Design ............................................................................ 3-45 Figure 3.4.12 Metal Halide Lamp Arc Tube Designs ................................................................ 3-45 Figure 3.4.13 Metal Halide Spectral Power Distributions ......................................................... 3-49 Figure 3.4.14 Core and Coil Assembly of a Magn etic Ballast .................................................. 3-51 Figure 3.4.15 Electronic HID Ballast ........................................................................................ 3-53 Figure 3.4.16 Electronic HID Ballast Block Diagram ............................................................... 3-53

3- iiiCHAPTER 3. MARKET AND TECHNOLOG Y ASSESSMENT

3.1 INTRODUCTION

This chapter consists of four sections: lamps analyzed by this determination

, the market assessment, the technology assessment, and equipment classes. The lamps analyzed by this

determination section describes the categories of high- intensity discharge ( HID ) lamps that

would be considered for potential standards in the notice of proposed determination (NOPD)

. The market assessment provides an overall picture of the market for the equipment concerned, including the nature of the equipment, industry structure, and manufacturer market shares; regulatory and non- regulatory efficiency imp rovement programs; and market trends and quantities of equipment sold. The technology assessment identifies a list of technologies to

consider in the screening analysis. The equipment classes section discusses the equipment

classes the U.S. Department of Energy ( DOE ) is analyzing for this NOPD and how they were developed.

The information DOE gathers from the market and technology assessment serves as resource material for use throughout the NOPD . DOE considers both quantitative and qualitative

information from publicly available sources and interested parties.

3.2 LAMPS ANALYZED BY TH IS DETERMINATION

In t his section , DOE discusses definitions of HID lamps relevant to the analysis in this

NOPD , and its determination of the HID lamp types analyzed . DOE first ana lyzed the potential energy savings of the HID lamp types that fall within the definition of “HID lamp” specified in

the Energy Policy and Conservation Act of 1975 (42 U.S.C. 6291–6317; EPCA) , as well as the technological feasibility of more efficient lamps for each type. For the HID lamps that passed those criteria, DOE conducted a full economic analysis with the LCC analysis, NIA, and MIA (see chapters 9, 11, and 12) to determine whether standards would be economically justified.

DOE assessed a lamp cate gory’s potential for energy savings initially using lamp catalog data as a proxy for market share, the values for which w ere then revised and vetted using feedback obtained during manufacturer interviews. For HID lamp availability, DOE obtained quantitativ e information from lamp catalogs of 15 different manufacturers. DOE also conducted evaluations of technological feasibility and economic justification.

3.2.1 Definitions

The Code of Federal Regulations (CFR) currently defines HID, mercury vapor (MV), and

metal halide (MH) lamps , but does not define high- pressure sodium (HPS) lamps . The following sections describe in more detail the definitions in the CFR and those that were proposed in the

3-1HID lamps final determination a (hereafter the “2010 determination”) and H ID lamps test procedure supplemental notice of proposed rulemaking (S NOPR ). b

3.2.1.1 High

- Intensity Discharge Lamp

The CFR defines high- intensity discharge lamp (10 CFR 431.282) as follows:

High intensity discharge lamp means an electric -discharge lamp in which— (1) The light-producing arc is stabilized by the arc tube wall temperature; and (2) The arc tube wall loading is in excess of 3 W atts/cm 2 , including such lamps as mercury vapor, metal halide, and high- pressure sodium lamps.

3.2.1.2 Mercury Vapor Lamp

The CFR defin es mercury vapor lamp (10 CFR 431.282) as follows:

Mercury vapor lamp means a high-intensity discharge lamp, including clear, phosphorcoated, and self

- ballasted screw base lamps, in which the major portion of the light is produced by radiation from mercury typically operating at a partial vapor pressure in excess of 100,000 Pa ( approximately 1 atm ).

The CFR also defines specialty application mercury vapor lamp ballast (10 CFR 431.282)

as follows: Specialty application mercury vapor lamp ballast means a mercury vapor lamp ballast

that— (1) Is designed and marketed for operation of mercury vapor lamps used in quality inspection, industrial processing, or scientific use, including fluorescent microscopy and ul traviolet curing; and (2) In the case of a specialty application mercury vapor lamp ballast, the label of

which

— (i) Provides that the specialty application mercury vapor lamp ballast is ‘For specialty applications only, not for general illumination’; and (ii) Specifies the specific applications for which the ballast is designed.

3.2.1.3 Metal Halide Lamp

The CFR currently defines metal halide lamp (10 CFR 431.322) as follows:

Metal halide lamp means a high

- intensity discharge lamp in which the major portion of the light is produced by radiation of metal halides and their products of dissociation, possibly in combination with metallic vapors.

a The 2010 HID lamps final determination was published on July 1, 2010 and is available at: http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23

. b The HID lamp test procedure SNOPR was published by DOE on May 22, 2014 and is available at: http://www1.eere.energy.gov/buildings/appl iance_standards/rulemaking.aspx/ruleid/21

.

3-23.2.1.4 High

- Pressure Sodium Lamp

The CFR does currently not define HPS lamps. However, the 2010 determination and test proced ure SNOPR proposed to adopt the A merican National Standards Institute (ANSI) C82.9- 1996 definition of high- pressure sodium lamp:

High

- pressure sodium lamp means a high -intensity discharge lamp in which the major portion of the light is produced by radiation from sodium vapor operating at a partial pressure of 6,670 Pa (approximately 0.066 atmospheres or 50 Torr ) or greater. 79 FR 29631 ( May 22 , 2014)

3.2.2 Characteristics of Lamps Considered for Analysis

HID lamps can differ from each other due to a variety of characteristics that affect performance, such as wattage, correlated color temperature (CCT), directionality, ballast location, ballast type requirements , color rendering index (CRI), color of emitte d light, and use of electrodes. The following subsections provide a discussion of these features and describe the lamps that DOE decided to analyze standards for in this NOPD

.

3.2.2.1 Wattage

In examining manufacturer catalogs, DOE found that HID lamps span wattages from 15 watts (W) to 24,000 W, though these wattages varied according to lamp technology. Rated wattages range from 15 W to 24,000 W for MH lamps, from 35 W to 1000 W for HPS lamps, and from 40 W to 2000 W for MV lamps. DOE decided to analyze a subset o f the available wattages, as explained in the following paragraphs.

For HPS lamps, DOE tentatively determined standards for HPS lamps were not technologically feasible due to the lack of technology options (see section 3.4.7.2 ). Therefore, DOE does not conduct a full economic analysis on HPS lamps to determine whether standards would be economically justified.

For MH lamps, DOE decided to analyze standards for lam ps with rated wattages ≥50 W
and ≤2000 W , h ereafter expressed as “50 W

– 2000 W.” Based on data collected from manufacturer catalogs, about eight percent of commercially available MH lamps have rated wattages less than 50 W. DOE found about three percent o f commercially available MH lamps have rated wattages that exceed 2000 W. The small number of HID lamp offerings at low wattages does not suggest significant potential energy savings. Similarly , at high wattages, both the small number of available lamp mod els and their low operating hours provide limited energy savings potential. Conversely, as described in chapter 5 of th is NOPD technical support document (TSD) , DOE has identified a range of efficacies and design options available for MH lamps between 50 W and 2000 W, indicating technological feasibility for standards. DOE also tentatively determined that standards could result in significant energy savings. For these reasons, DOE is conducting a full economic analysis to determine whether standards would b e economically justified for MH lamps rated 50 W

– 2000 W in this NOPD . This wattage range

3-3analyzed is consistent with the wattage range analyzed in the energy conservation standards rulemaking for metal halide lamp fixtures (MHLFs). c

For MV lamps, DOE is analyzing standards for lamps with rated wattages ≥ 50 W and ≤

1000 W , h ereafter expressed as “50 W

– 1000 W.” In its review of MV lamp catalogs, DOE found that less than one percent of the MV catalog offerings had rated wattages less than 50 W. Similarly, DOE found only two MV lamps (less than one percent) with rated wattages higher than 1000 W. Given the small number of available products, DOE believes these lamps do not reflect significant potential energy savings. Therefore, DOE is conducting a full economic analysis to determine whether standards would be economically justified for those MV lamps

rated 50 W – 1000 W. MH lamps in this wattage range have demonstrated the potential for significant energy savings if they are used as replacements for these MV lamps. These types of replacements are also already common, so energy savings from replacing MV lamps are technological ly feasible.

3.2.2.2 CCT

Another defining characteristic of an HID lamp is the CCT . In general terms, the CCT is an approximation of the appearance of the light source expressed in kelvins (K) where the lower values are considered warm white light and high values are considered cool white light. In the

HID test procedure SNOPR, DOE proposed to define CCT as the absolute temperature of a blackbody whose chromaticity most nearly resembles that of the light source. b

HID lamps are available with a varie ty of CCTs, depending on lamp type and design. For example, MV lamps range in CCT from 3200 K to 6800 K , while MH lamps have a much larger range in CCT with products ranging in CCT from 2800 K to 50,000 K. d HPS lamps range in

CCT from 1900 K to 2700 K.

DO E found that higher CCT lamps tend to be advertised for a specific, specialized application. For example, DOE found that nearly all MH lamps with a CCT between 10,000 K and 50,000 K were advertised as aquarium lamps, and MH lamps with a CCT between 7200 K and 9000 K were advertised as stage and studio lighting. In addition, DOE identified lamps with

a CCT of 7000 K to be advertised as horticulture lamps.

Overall, lamps with a CCT greater than or equal to 7000 K represent less than five percent of all avail able MH lamp models

, based on catalog availability . Given the small number of available products and their specialized applications, DOE does not believe these lamps represent significant potential energy savings. Therefore, DOE is not conducting a full ec onomic analysis to determine whether standards would be economically justified for lamps with a CCT greater than or equal to 7000 K.

For HID lamps less than 2800 K, DOE found there were no technology options available for improving efficacy. The only lamps available in these CCT ranges are HPS lamps , and DOE

c More information about the MHLF rulemaking, including the final rule TSD is available through: http://www1.eere. energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/16

. d Some directional MH lamps are available with a CCT as low as 2500 K.

3-4tentatively determined that no technology options are available for improving the efficacy of HPS lamps (see section 3.4.7.2 ). Therefore, DOE does not conduct a full economic analysis to determine whether standards would be economically justified for HID lamps with a CCT less

than 2800 K.

In summary, DOE is conducting a full economic analysis to determine whether standards would be economically justified for the following CCT ranges in this determination : ≥3200 K
and ≤6800 K for MV lamps , and ≥2800 K and <7000 K for MH lamps . Lamp catalogs show a large number of lamp offerings in these CCT ranges wit h varying efficacies , suggesting the potential for significant energy savings and the technological feasibility of such savings.

3.2.2.3 Directional Lamps

Lamp light distribution is typically categorized as omnidirectional or directional.

Omni directional lamps emi t light in all directions with approximately equal intensity, whereas directional lamps use a secondary optical element ( e.g., reflector, lens, refractor, light guide) or a combination of elements to shape the light distribution into a particular pattern. In the HID test procedure SNOPR, DOE proposed “ directional lamp ” be defined as a lamp emitting at least 80 percent light output within a solid angle of π steradians (corresponding to a cone with an angle of 120 degrees) and including a reflector within the structure of the lamp

. b

DOE found that manufacturers offer both directional and omnidirectional lamps for each of the HID lamp types. By analyzing manufacturer catalogs, DOE found that less than 10 percent of available HID lamps are directional. Lamp manufacturers noted during interviews, however, that the actual market share of directional HID lamps is much smaller than their catalog representation indicates . Because each directional lamp provides a specific beam pattern, a larger number of directional lamp offerings are needed to meet all customer needs. M anufacturers

indicated that this fact belies their low shipment volume relative to their representation in catalogs. Given their small market share, DOE does not believe directional lamps represent significant energy savings potential. Furthermore, the pattern of light distribution of these lamps makes them unacceptable replacements for omni directional lamps. Therefore, DOE is not conducting a full economic analysis to determine whether standards would be economically justified for directional lamps in this NOPD

.

3.2.2.4 Self

- Ballasted Lamps

HID lamps can be also categorized by their ballast location ( i.e. , externally ballasted or

self

- ballasted lamps). The vast majority of HID lamps are operated with an external ballast, meaning that the ballast is not located within the lamp body (socket and envelope). An externa l ballast can be located within the fixture or installed separately from the fixture ( e.g., at the base of a pole-mounted fixture). When a ballast that is integrated into the lamp, however, DOE refers

to this as a self

- ballasted HID lamp. In the HID test procedure SNOPR, DOE proposed to define

“ self

- ballasted lamp ” as a lamp unit that incorporates all elements that are necessary for the starting and stable operation of the lamp in a permanent enclosure and that does not include any replaceable or inte rchangeable parts. b

3-5A survey of the market revealed that MH and MV lamp types are both available in self

ballasted models. In reviewing catalogs, DOE found less than one percent of MH lamps were

self

- ballasted, whereas about 17 percent of MV lamps were self

- ballasted. Of these self

- ballasted lamps, most are also directional lamps and, as discussed in the previous section, DOE is not analyzing stand ards for directional lamps . Many of the remaining omnidirectional , self

- ballasted lamps, which span a range from 1 6 0 W to 750 W, are marketed as replacements for incandescent technology. MV lamps have increased efficacy and longer lifetimes relative to incandescent lamps. DOE does not believe that regulating self- ballasted HID lamps would result in significant energy savings. Instead, adoption of energy conservation standards for these self

- ballasted lamps could increase the price of these lamps or eliminat e them altogether, thereby shifting the market

towards less

- efficient incandescent lamps. Given the small number of available self

- ballasted HID lamps and the expectation that customers would likely choose incandescent technology if

self

- ballasted HID lamp s were regulated , DOE does not believe there is significant potential for energy savings by regulating these lamps. Therefore, DOE is not conducting a full economic analysis to determine whether standards would be economically justified for self

- ballasted lamps

in this NOPD

.

3.2.2.5 Lamps Designed to Operate Exclusively on Electronic Ballasts

In its market research, DOE found that catalogs indicated that some HID lamps could be operated only by an electronic ballast. DOE conducted additional research on these lamps and found that they tend to be newer models with uncommon rated wattages. Furthe rmore, DOE discovered that the reason that such lamps are designated for exclusive use with an electronic

ballast stems from A NSI lamp datasheets . ANSI only provides specifications for operating HID lamps with magnetic ballasts, regardless of whether a lamp can operate on an electronic ballast as well. When a manufacturer develops a new lamp with a rated wattage that is already included

in ANSI C78.43-2007 e or ANSI C78.44-2008 f standards, the lamp will be compatible with the magnetic ballast specifications reported on the ANSI datasheet. For a lamp with a new rated wattage to be added to the ANSI datasheets, however, ANSI requires that (1) at least two manufacturers independently produce a lamp model at the new wattage and (2) they, along with

an ANSI commit tee, agree on the standardized operating specifications. In a situation where a manufacturer is the sole producer of a lamp with an unlisted wattage, the manufacturer often conducts research and development only for electronic operation of that lamp, leadi ng to the designation of electronic ballast only.

DOE notes that there is not an industry consensus test method for HID lamps designed to operate exclusively on electronic ballasts DOE is also not proposing test methods for lamps that only can be operate d with electronic ballasts in the HID test procedure SNOPR

. b Furthermore, lamps designated as electronic ballast only are typically among the most efficacious lamps on the

e ANSI C78.43

- 2007 American National Standard for Electric Lamps

— Single

- Ended Metal Halide Lamps is a standard publis hed by ANSI that sets forth the physical and electrical requirements for single

- ended MH lamps operated on 60 hertz (Hz) ballasts to ensure interchangeability and safety and is available for download at: http://webstore.ansi.org/RecordDetail.aspx?sku=NEMA+ANSI+ANSLG+C78.43:2007

f ANSI C78.44

- 2008 American National Standard for Electric Lamps

— Double

- Ended Metal Halide Lamps is a standard published by ANSI that sets for th the physical and electrical requirements for double

- ended MH lamps operated on 60 Hz ballasts to ensure interchangeability and safety and is available for download at: http://webstore.ansi.org/RecordDetail.aspx?sku=NEMA+ANSI+ANSLG+C78.44:2008

3-6market, so DOE would not anticipate the adoption of standards to affect the commercially available lamp efficacies of this lamp category. DOE also received feedback that these lamps represent a small market share (less than one pe rcent, based on feedback during manufacturer interviews) . Due to their very small market share, regulations for these lamps do not have significant potential for energy savings. Thus, for this NOPD, DOE is not conducting a full economic analysis to determine whether standards would be economically justified for HID lamps marketed for exclusive use with electronic ballasts.

3.2.2.6 High

- CRI Lamps

CRI is the measure of the degree of color shift objects undergo when illuminated by a light source as compared with the color of those same objects when illuminated by a reference source of comparable color temperature. (42 U.S.C. 6291(30)(J)) CRI ranges from zero for monochromatic light sources to 100 f or a light source that closely mimics the color rendering

pro perties of the reference source. HID lamps are available over a range of CRIs depending on the type, application, and environment in which the lamp is intended to operate. Typical CRIs for HID lamps are different depending on lamp type. For example, the ty pical CRI for HPS lamps is

lower than the typical CRI for MH lamps. It then follows that what is considered high

- CRI for HPS lamps is different from what is considered high-CRI for MH lamps. For that reason, DOE separates the lamp types when discussing the potential exclusions for high- CRI lamps.

High

- CRI HPS Lamps

. When looking at the CRIs of HPS lamps, DOE found that HPS lamps typically have CRIs from 20 to 30. However, a minority of HPS lamps have CRIs from 65 to 85, though this increase in CRI comes with decreased efficacy. Because of this, DOE investigated whether high -CRI HPS lamps should be considered separately in this NOPD

. However, as discussed in section 3.2.2.2 , DOE has tentatively determined that standards for HPS lamps are not technologically feasible in this NOPD . As such, DOE is not conducting a full economic analysis to determine whether standards would be economically justified for HPS lamps, which includes high- CRI HPS lamps.

High

- CRI MH Lamps

. DOE observed that MH lamps are available with CRI values up to 100, though a typical value for a pulse-start quartz MH lamp is about 65. The highest CRI MH lamps, those with CRI values greater than or equal to 95, utilize pulse- start (quartz and ceramic) technology. These high- CRI pulse -start MH lamps are predominantly offered by one company (over 80 percent of product offerings of lamps with CRI values greater than or equal to 95 coming from the same manufacturer ), indicating that these products are intended for a low volume, niche market. DOE notes that pulse- start MH lamps with CRI values greater than or equal to 95 often exhibit lower efficacy than other pulse-start MH lamps. If DOE did not establish standards for these lamps but established a minimum efficacy for MH lamps that exceeded the efficacy of high

- CRI pulse

- start MH lamps, it is unlikely that the market would shift to the unregulated, high- CRI pulse

- start MH lamps. High

- CRI pulse

- start MH lamps are not likely to be a low cost substitute for standards

- compliant l amps, because a high

- CRI MH lamp is not currently a cost-saving option. For these reason s , DOE believes that high

- CRI pulse

- start MH lamps do not have potential for significant energy savings and DOE is not conducting a full economic analysis to determine whether standards would be economically justified for high- CRI

3-7MH lamps. Upon review of its analyses, DOE tentatively determined to define high- CRI lamps

in this NOPD as those with CRI greater than or equal to 95.

3.2.2.7 Colored MH Lamps

DOE found a small number of MH lamps within the covered CCT ranges that were advertised as colored lamps ( e.g. , blue, green, orange, and magenta). These colored lamps represent less than two percent of MH lamp catalog offerings. This small market share indicates a lack of potential for significant energy savings. DOE determined to identify and defin e these colored lamps by CRI, based on the observation that these lamps have very low CRI, such that they emit light that appears colored. Because of their unique colored light output, such lamps are used for specialized applications and are unsuitable substitutions for other white- light emitting HID lamps. By examination of HID lamp offerings currently on the market, DOE tentatively

determined that advertised colored MH lamps generally have a CRI less than 40. Because of the lack of potential for significant energy savings, DOE is not conducting a full economi c analysis to determine whether standards would be economically justified for colored MH lamps (those that fall below a CRI of 40) in this NOPD

.

DOE also considered adopting the European Union’s (EU) definition of white light, which sets chromaticity requirements based on coordinates of the CIE 1931 chromaticity diagram. g However, DOE tentatively determined that a colored MH lamp could be effectively defined using the simpler CRI criteria specified in the previous paragraph and decided to define the lamps as those with a CRI less than 40.

3.2.2.8 Lamps for Specialty Applications

The Energy Policy Act of 2005 (EPACT 2005) banned the sale of MV lamp ballasts, but exempted ballasts for certain specialty applications, such as quality inspection, industrial processing, or scientific use, including fluorescent microscopy and ultraviolet (UV) curing. These applications cann ot be served by other HID or solid -state lighting technologies due to the applications’ unique need for the UV light emitted by MV sources. In th is NOPD , DOE tentatively determined that using labeling requirements as a means of exemption would not be an effective way to characterize the end

- use application of a particular lamp. DOE reviewed HID lamp catalogs and identified various types of MV and MH specialty lamps. DOE tentatively determined that although some lamps used in specialty applications have unique photometric properties, spectral power density (SPD) data is not available for all lamps in catalogs, and as such, DOE cannot create a definition for specialty lamps using an SPD metric. DOE reviewed specialty lamp categories that were identified to determine if standards were technologically

feasible.

MV Lamps for Specialty Applications. DOE reviewed lamp catalogs , along with

manufacturer -provided lists of specialty lamps, and identified several specialty applications in

g For the complete EU definition of “white light source”, please see the Official Journal of the European Union, Commission Regulation (EC) No. 245/2009 of 18 March 2009 at: http://eur

lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:076:0017:0044:EN:PDF

.

3-8which MV lamps are used , such as quality inspection, material testing, industrial processing, scientific uses ( e.g. , fluorescent microscopy), and UV curing. DOE tentatively determined that MH technology cannot act as a direct substitute for MV technology in applications where high

leve ls of UV light are required . Without such higher efficacy replacements being an option, DOE

has tentatively determined that standards for MV lamps for specialty applications are not technologically feasible . DOE considered using a UV light metric to exempt this group of lamps from standards; however, DOE tentatively determined that UV light metrics are not always available in catalogs. DOE analyzed common characteristics of specialty MV lamps, including those used in UV applications, and created an exemption rule that targets this group of lamps based on these characteristics. DOE observed that some of these lamps are directional, and as such, they are already not being included in potential standards . DOE also observed other common properties of MV lamps used in specialty applications and tentatively determined not to
include in consideration for standards lamps having all three of the following characteristics: 1)

double- ended ; 2) do not have screw bases ; h and 3) have no outer bulb. Removing from

consideration for standards MV lamps with all three of these characteristics would ensure that UV curing and similar specialty lamps are not elimina ted from the market. Accordingly, in th is NOPD, DOE has tentatively determined that standards for MV lamps used in specialty applications are not technologically feasible and will not be included in the full economic analysis to determine whether standard s would be economically justified . DOE defines these specialty MV lamps as MV lamps that are double -ended, do not have a screw base, h and have no

outer bulb.

Entertainment Lamps. DOE also reviewed specialty lamp catalog s and observed a family of HID lamps predominantly used in the entertainment industry, which is typically advertised as lamps for stage, theat er , studio, film, among other applications (hereafter referred to as entertainment lamps). Entertainment lamps are characterized by smaller arc gaps, a more compact design , and enhanced control of optics. DOE also identified these types of HID lamps being used in daylight simulation applications. After analyzing the common characteristics of entertainment lamps, DOE f ound that they can be accurately separated from general lighting lamps as those lamps that have all three of the following characteristics: 1) have a CCT of 5000

K – 6999 K, 2) do not have a screw base, h and 3) have a bulb shape that is not T-shaped. i DOE tentatively determined that although some of these entertainment lamps share similar photometric properties used in general lighting purposes, the ir dedicated optics and shorter lifetimes render them inadequate replacements for general illumination. DOE tentatively determined that because entertainment lamps have unique consumer utility, and because they typically have lower efficacies than the high er efficacy HID lamps used in general lighting and analyzed in this NOPD, standards for entertainment lamps would not be technologically feasible. As such, DOE determined not to include the previously defined entertainment lamps in the full economic analysis to determine whether standards would be economically justified.

3.2.2.9 Electrodeless Lamps

DOE has tentatively determined that “electrodeless HID lamps” meet the definition of an HID lamp as defined in section 3.2.1.1 . Electrodeless HID lamps generate light through a similar

h As defined by ANSI C81.61

- 2009

– Specifications for bases (Caps) for Electrical Lamps

. i As defined by ANSI C79.1

- 2002

– Nomenclature for Glass Bulbs Intended for Use with Electric Lamps

.

3-9process, but couple power to the arc tube through means other than electrodes. Based on

comments receiv ed in response to the framework document, the lighting industry generally considers electrodeless HID lamps to be a separate lamp technology, and not a subset of HID lamps. However, DOE tentatively determined that the definition of HID lamp as defined in

section 3.2.1.1 does not make a distinction between lamps that do or do not have electrodes.

The definition of HID lamp has four main specifications : (1) the arc tube wall loading is

in excess of 3 W /cm 2 ; (2) the light

- producing arc is stabilized by the arc tube wall temperature; (3) the lamp is either a n MV, HPS, or MH lamp; and (4) the lamp is an “electric

- discharge lamp.” Electrodeless HID lamps me et both the first and second criteria based on the high power density contained in the gaseous chamber. Regarding the third criteria, electrodeless HID lamps have a similar gas mixture to and produce light in the same manner as MH lamps, and meet the

EPCA definition of a MH lamp. For the fourth criteria, the term electric

- discharge lamp is not defined in DOE’s regulations. DOE found that electric- discharge lamp is defined in ANSI/IES

RP -16-2010 as a lamp in which light (or radiant energy near the visible spectrum) is produced by the passage of an electric current through a vapor or a gas. Electrodeless HID lamps use this mechanism for generating light, and therefore DOE finds that they meet the fourth specification of an HID lamp. Thus, DOE tentatively determined that “electrodeless HID lamps” meet the definition of an HID lamp.

Although DOE considers electrodeless HID lamps to be a type of HID lamp, electrodeless HID lamps have a market share of less than one percent , which indicates standards for them do not have potential for significant energy savings . Additionally, electrodeless HID lamps do not have an industry consensus test method. DOE has evaluated this information and is not conducting a full economic analysis to determine whether standards would be economically justified for electrodeless HID lamps in this NOPD

.

3.2.2.10 F-R ated Lamps

DOE noted that, in addition to open- rated and enclosed

- rated, the luminaire characteristic of a MH lamp can be categorized as F -rated. An F -rated lamp is one that is double-ended, requires an enclosed luminaire to meet industry safety standards for containment in the event of lamp rupture, and provide a UV attenuation barrier and lens interlock because of the lack of outer jacket. (ANSI C78.380-2007) F- rated lamps consist e xclusively of double- ended lamps with wattages greater than 1000 W that are primarily used in stadium applications. Several of

these F -rated lamps currently found on the market meet the highest ELs analyzed in thie NOPD

for wattages greater than 1000 W. As discussed in section 3.2.2.1 , standards for lamps with rated wattages greater than 1000 W have potential for significant energy savings and are also technological ly feasible. As such, DOE also conducted a full economic analysis on these lamps in this NOPD to determine whether standards would be economically justified.

3.2.3 Summary

In summary, DOE concludes that energy conservation standards for MH lamps with a rated wattage of 50 W – 2000 W, and MV lamps with a rated wattage of 50 W – 1 000 W are technologically feasible and have the potential for energy savings , and these lamps will be

3- 10included in the full economic analysis to determine whether standards would be economically justified in this NOPD . Within those wattage ranges, DOE is analyzing standards for MH lamps with CCTs 2800 K – 6999 K and MV lamps with CCTs 3200 K – 6800 K.

In this NOPD

, DOE is not including directio nal HID lamps, self

- ballasted HID lamps, lamps designed to operate exclusively on electronic ballasts, high- CRI lamps ( i.e. , those with a CRI greater than or equal to 95), colored MH lamps ( i.e.

, MH lamps with a CRI less than 40)

, specialty application MV lamps ( i.e. , MV lamps that are double-ended, do not have a screw base,

and have no outer bulb ), entertainment lamps ( i.e. , lamps that have a CCT of 5000 K – 6999 K,

do not have a screw base, and have a bulb shape that is not T-shaped) , and electrodeless HID lamps in the full economic analysis to determine whether standards would be economically justified

. DOE is also not analyzing standards for lamp with CCT less than 2800 K (HPS lamps).

3.3 MARKET ASSESSMENT

The following market assessment identifies the manufacturer trade association and domestic manufacturers of HID lamps; discusses manufacturer market share, regulatory programs, and non- regulatory initiatives; defines product classes; provides historical shipment data, shipment projections, and equipmen t lifetime estimates; and summarizes market performance data.

3.3.1 Trade Associations

The National Electrical Manufacturers Association (NEMA) is the trade association for HID lamps. NEMA’s Lighting Systems Division is one of eight product divisions, performs

n umerous technical projects including MH lamp -and- ballast compatibility research and lighting application white papers, and supports the lighting industry on other activities including industry positions on legislative and regulatory initiatives. 1 The division’s approximately 45 member companies comp ose 75 to 80 percent of the domestic HID lamp market in terms of lamp sales. In addition to HID lamps, NEMA’s Lighting Systems Division also oversees products such as lighting controls, luminaires, solid- state li ghting, and other lighting technologies. NEMA provides an organization through which manufacturers of lighting equipment can work together on projects that affect their industry and business. NEMA’s activities relating to energy efficiency include the foll owing:

• “Advising ... DOE and executive agencies on lighting research and market

transformation needs

• Participating in the climate change discussions with the Administration and Congress

• M onitoring energy -efficiency rulemakings and standards affecting lighting products by

DOE and states

• Promoting the national voluntary luminaire rating and information program under the National Lighting Collaborative

3- 11• S upporting adoption of new ASHRAE/IESNA 90.1 lighting provisions

• Advising the DOE Federal Energy Management Program on energy- efficient lighting

recommendations

• Coordinating with the DOE and Environmental Protection Agency Energy Star ® Buildings and Energy Star voluntary product labeling program s

• A dvocating market -based approaches to enhance the use and penetration of energyefficient technologies.” 2

3.3.2 Manufacturers of High

- Intensity Discharge Lamps

The following list contains the names of manufacturers that produce HID lamps:

• EiKO Limited

• EYE Lighting

• Fulham Incorporated

• General Electric Consumer & Industrial

• Global Energy & Lighting

• W.W. Gra inger, Inc.

• Halco Lighting Technologies

• Havells Ltd.

• Howard Industries

• Litetronics International, Inc.

• OSRAM SYLVANIA

• Philips Lighting

• Technical Consumer Products, Inc.

• Ushio America, Inc.

• Venture Lighting International

• Westinghouse Lighting

Four manufacturers hold the majority of the domestic market share of HID lamps:

• GE Consumer and Industrial of General Electric, Inc. (hereafter, “ GE ”)

• OSRAM SYLVANIA of Siemens AG (hereafter, “ OSRAM SYLVANIA ”)

• Philips Lighting (hereafter, “Philips”)

• Venture Lighting International (hereafter, “Venture”)

The lighting divisions of some of these companies also manufacture other products, such

as fluorescent lamps, halogen lamps, light- emitting diodes (LEDs), and compact fluorescent lamps (CFLs).

3- 123.3.3 Small Businesses

Small businesses may be particularly affected by the promulgation of energy conservation standards for HID lamps. The Small Business Administration (SBA) lists small business size standards that are matched to industries as they are described in the North American Industry Classification System (NAICS). A size standard is the maximum size that a for -profit company can be and still qualify as a small business for f ederal government programs. These size standards are generally the average annual receipts or the average employment of a firm. For HID lamps, the size standard is matched to NAICS code 335310, Electric Lamp Bulb and Part Manufacturing , which has a size standard of 1,000 employees or fewer. 3

DOE studies the potential impacts on these small businesses in detail as part of the manufacturer impact analysis. For more information, see chapter 12 of this NOPD TSD.

3.3.4 Regulatory Programs

Several f ederal and international regulatory programs affect the market for HID lamps in

the United States. The following section summarizes U.S., Canadian, and European regulatory initiatives relevant to the lamps covered by this NOPD . While the following discussion is not exhaustive in describing all regulatory action related to HID lamps, it provides detail on some notable initiatives that characterize recent developments in the lighting market.

3.3.4.1 Federal Energy Conservation Standards

HID Lamps. EPCA established an energ y conservation program for certain industrial equipment. (42 U.S.C. 6311–6317) The Energy Policy Act of 1992 (EPACT 1992), Pub. L. No. 102–486, 106 Stat. 2776 amended EPCA to expand title III to include HID lamps in the program. Specifically, EPACT 1992 amended section 346 of EPCA to provide in paragraph (a) that the Secretary of Energy must prescribe testing requirements and energy conservation standards for those HID lamps that the Secretary determines that standards “would be technologically feasible and economically justified, and would result in significant energy savings.” (42 U.S.C. 6317(a)(2))

DOE conducted previous analyses to estimate the likely range of energy savings and economic benefits that would result from energy conservation standards for HID lamps. These documents were published in June 2003 and December 2004. j DOE then conducted additional analyses on the impacts of energy conservation standards and published supporting technical documents in April 2010 and July 2010. 75 FR 22031 (April 27, 2010) and 75 FR 37975 (July 1, 2010) The July 2010 final determination concluded that energy conservation standards for HID lamps are technologically feasible, economically justified, and would result in significant energy savings, culminating in a positive final determination.

j These documents may be accessed on DOE’s webpage at: www1.eere.energy.gov/buildings/appliance_standards/commercial/pdfs/hid_draft_report.pdf and www1.eere.energy.gov/buildings/appliance_standards/commercial/pdfs/hid_energy_savings_report.pdf

, respectively

.

3- 13On February 21, 2012, DOE published a framework document for HID lamps that explained the analyses that DOE would conduct to evaluate establishing energy conservation standards for HID lamps. k On February 28, 2013, DOE published notice of public meeting and availability of the interim TSD that provides the analytical approaches, inputs, results, and technical detail associated with this energy conservation standard

. This NOPD takes the feedback received and research conducted since the interim analysis and reanalyzes whether standards for HID lamps would be technologically feasible, economically justified, and would result in significant potential energy savings.

Metal Halide Lamp Fixtures . As amended by EISA 2007, EPCA regulates metal halide lamp fixtures designed to be operated with lamps rated greater than or equal to 150 watts (W) but less than or equal to 500 W by prescribing performance requirements for the metal halide ballasts used in those metal halide lamp fixtures.For t his 150 to 500 W metal halide lamp wattage range, metal halide lamp fixtures must contain:

(i) a pulse

- start metal halide ballast with a minimum ballast efficiency of 88 percent; (ii) a magnetic probe

- start ballast with a minimum ballast efficiency of 94 percent; or (iii) a nonpulse

- start electronic ballast with

— (I) a minimum ballast efficiency of 92 percent for wattages greater than 250 W;

and (II) a minimum ballast efficiency of 90 percent for wattages less than or equal to

250 W.

(U.S.C. 6292 (hh)(1)( A))

In addition to prescribing minimum efficiency requirements for the previously described metal halide ballasts contained in metal halide lamp fixtures, EISA 2007 amended EPCA to exclude the following types of metal halide lamp fixtures from the statu torily prescribed energy

conservation standards:

(i) fixtures with regulated lag ballasts; (ii) fixtures that use electronic ballasts that operate at 480 volts; or (iii) fixtures that

— (I) are rated only for 150 watt lamps; (II) are rated for use in wet l ocations, as specified by the National Electrical Code 2002, section 410.4(A); and (III) contain a ballast that is rated to operate at ambient air temperatures above 50° C, as specified by UL [Underwriters Laboratories] 1029– 2001 [“Standard for High

- Intens ity

- Discharge Lamp Ballasts”].

(42 U.S.C. 6292 (hh)(1)(B))

On February 10, 2014, DOE published a final rule for MHLFs c to comply with the requirement of two rulemaking cycles to review and amend the energy conservation standards

k This document may be accessed on DOE’s webpage at: www1.eere.energy.gov/buildings/appliance_standards/pdfs/hid_ecs_framework_document.pdf

.

3- 14for MHLFs. The final rule prescribed standards for a wider range of wattages , and increased minimum ballast efficiency standards where it was deemed technologically feasib le, economically justified, and that there was significant potential for energy savings. These amended MHLF standards, found in Table 3.3.1 , applies to metal halide la mp fixtures manufactured on or after February 10, 2017. 79 FR 7745 (February 10, 2014)

Table 3.3.1 MHLF Standards from 2014 Final Rule

Designed to be Operated with Lamps of the Following Rated Lamp Wattage Tested Input Voltage ‡‡ Minimum Standard Equation ††

%

≥50 W and ≤100 W Tested at 480 V (1/(1+1.24 × P^(

- 0.351)))

– 0.020††

≥50 W and ≤100 W All others 1/(1+1.24×P^(

- 0.351))

>100 W and <150† W Tested at 480 V (1/(1+1.24×P^(

- 0.351)))

– 0.020

>100 W and < 150† W All others 1/(1+1.24×P^(

- 0.351))

≥150‡ W and ≤250 W Tested at 480 V 0.880

≥150‡ W and ≤250 W All others For ≥150 W and ≤200 W: 0.880
For >200 W and ≤250 W:

1/(1+0.876×P^(

- 0.351))

>250 W and ≤500 W Tested at 480 V For >250 and <265 W: 0.880
For ≥265 W and ≤500 W: (1/(1+0.876×P^(

- 0.351))

– 0.010

>250 W and ≤500 W All others 1/(1+0.876×P^(

- 0.351))

>500 W and ≤1000 W Tested at 480 V For >500 W and ≤750 W: 0.900
For >750 W and ≤1000 W:

0.000104×P+0.822 For >500 W and ≤1000 W: may not utiliz e a probe

- start ballast

>500 W and ≤1000 W All others For >500 W and ≤750 W: 0.910
For >750 W and ≤1000 W:

0.000104×P+0.832 For >500 W and ≤1000 W: may not utilize a probe

- start ballast †Includes 150 W fixtures that are fixtures rated only for 150 W lamps; rated for use in wet locations, as specified by

the NFPA 70

- 2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029

– 2007. ‡Excludes 150 W fixtures that are fixtures r ated only for 150 W lamps; rated for use in wet locations, as specified by

the NFPA 70

- 2002, section 410.4(A); and containing a ballast that is rated to operate at ambient air temperatures above 50 °C, as specified by UL 1029

– 2007. ††P is defined as the ra ted wattage of the lamp the fixture is designed to operate. ‡‡Tested input voltage is specified in 10 CFR 431.324

79 FR 7745 (February 10, 2014)

3- 15In addition to prescribing minimum efficiency requirements for the previously described

metal halide ballasts contained in metal halide lamp fixtures, the 2014 MHLF final rule excluded the following types of metal halide lamp fixtures from the statutorily prescribed energy

conservation standards:

(i) fixtures with regulated lag ballasts; (ii) fixtures th at use electronic ballasts that operate at 480 volts; or (iii) fixtures that use high

- frequency electronic ballasts.

79 FR 7745 (February 10, 2014)

3.3.4.2 Canadian Energy

- Efficiency Standards

The Natural Resources Canada (NRCan) Office of Energy Efficiency does not currently regulate the energy efficiency of HID lamps in Canada. However, NRCan Office of Energy Efficiency proposed to amend Canada’s Energy Efficiency Regulations to include certain HID lamp ballasts in May 2010. 4 The HID lamp ballasts covered in the Canadian rulemaking do not include regulated lag ballasts, electronic ballasts that operate at 480 V, ballasts rated only for 150 W lamps, ballasts rated and marketed for use in wet locations, or ballasts rated and marketed to operate at ambient air tempe ratures above 50 °C. Table 3.3.2 shows the proposed Canadian standards for HID lamp ballasts.

Table 3.3.2 Canadian Proposed Standards for HID Lamp Ballasts

Ballast Type Lamp Rated Wattage Minimum Rated Ballast Efficiency

Magnetic Probe Start 150

- 500 W 94 %

Pulse Start 150

- 500 W 88 %

Non Pulse Start

Electronic 150

- 250 W 90 %

251

- 500 W 92 %

The Canadian standards listed above apply to residential and commercial ballasts. Canadian standards consider an input voltage of 347 V in addition to 120 V and 277 V, which is

consistent with the Canadian electrical distribution network. Canadian standards also require a minimum power factor of 0.9 (consistent with U.S. standards) for all ballasts except residential

ballasts. Amendment 13, published in November 2011, updated the previous regulatory standards proposals to apply only to MH lamp ballasts used in new fixtures and to exclude ballasts intended for use as replacement ballasts and ballasts that are used with lamps rated between 150 and 500 watts, inclusive.

3.3.4.3 European Energy

- Efficiency Regulations

Commission Regulation (EU) No 347/2010 (April 21, 2010) amended Commission Regulation (EC) No 245/2009 (March 18, 2009), which implemented Directive 2005/32/EC

3- 16(July 6, 2005) of the European Parliament and the Council of the European Union and amended

Council Directive 92/42/EEC and Directiv es 96/57/EC and 2000/55/EC (September 18, 2000) to establish a framework for setting energy

- efficiency requirements for energy -using equipment, including HID lamps and the ballasts and luminaires that are used with these lamps. The energy

efficiency requirements apply to equipment available on the market and do not differentiate requirements by lamp application. 5 6

The European energy- efficiency requirements regulate the covered equipment in stages. First stage requirements began in 2010 and did not cover HID lamps. Second stage requirements begin in 2013, requiring HID lamps to comply with the efficacies and performances listed in the

Table 3.3.3 through Table 3.3.6 , unless otherwise noted. Third stage requirements begin in 2018, requiring HID lamps to reach the efficacies and performances listed le vels in the Table 3.3.7 and

Table 3.3.8 . The EU assigns different requirements to HID lamps based on the nomi nal wattage

and bulb finish l ( i.e., clear versus not clear).

In addition to lamp efficacy, the EU includes requirements for lamp lumen maintenance factor , or LLMF, and lamp survival factor , or LSF, in its regulations. LLMF describes how bright a lamp rema ins as a percentage of the original brightness after a given period of time. LSF describes how long a lamp lasts before ceasing to function and requiring replacement due to cessation of function and is expressed as a percentage of the number of lamps still working after a specified period of time. Both of these factors are used in the European energy

- efficiency requirements.

Table 3.3.3 Minimum Efficacy EU Requirements for HPS Lamps with a Color Rendering

Inde x (Ra) m ≤ 60 (Second Stage)

Nominal Lamp Wattage Rated Lamp Efficacy for Clear Lamps* Rated Lamp Efficacy

– Not Clear Lamps*

W ≤ 45 ≥ 60 ≥ 60

45 < W ≤ 55 ≥ 80 ≥ 70

55 < W ≤ 75 ≥ 90 ≥ 80

75 < W ≤ 105 ≥ 100 ≥ 95

105 < W≤ 155 ≥ 110 ≥ 105

155 < W ≤ 255 ≥ 125 ≥ 115

255 < W ≤ 605 ≥ 135 ≥ 130

*These requirements also apply to HPS retrofit lamps designed to operate on high

- pressure MV lamp ballasts beginning in 2016.

l Bulb finish is discussed in more detail in section 3.5.5

.

m The term color rendering index or CRI (also expressed as Ra) means the measure of the degree of color shift objects undergo when illuminated by a light source as compared with the color of those same objects when illuminated by a reference source of comparable color temperature. 42 U.S.C. 6291(30)(J)

3- 17Table 3.3.4 Lumen Maintenance and Lamp Survival Factors for HPS Lamps (Second Stage)

HPS Lamp Category and Burning Hours for

Measurement Lamp Lumen

Maintenance

Factor* Lamp Survival

Factor*

W ≤ 75
12,000 burning

hours Ra ≤ 60 > 0.80 > 0.90

Ra > 60 > 0.75 > 0.75

All retrofit lamps designed to operate on a MV ballast > 0.75 > 0.80

W < 75
16,000 burning

hours Ra ≤ 60 > 0.85 > 0.90

Ra > 60 > 0.70 > 0.65

All retrofit lamps designed to operate on a MV ballast > 0.75 > 0.55

*These requirements also apply to retrofit lamps designed to operate on high

- pressure MV lamp ballasts beginning in 2016.

Table 3.3.5 Minimum Efficacy EU Requirements for MH Lamps with Ra ≤ 60 and for HPS Lamps with Ra > 60 (Second Stage)

Nominal Lamp Wattage Rated Lamp Efficacy for Clear Lamps Rated Lamp Efficacy

– Not Clear Lamps

W ≤ 55 ≥ 60 ≥ 60

55 < W ≤ 75 ≥ 75 ≥ 70

75 < W ≤ 105 ≥ 80 ≥ 75

105 < W≤ 155 ≥ 80 ≥ 75

155 < W ≤ 255 ≥ 80 ≥ 75

255 < W ≤ 405 ≥ 85 ≥ 75

Table 3.3.6 Minimum Efficacy EU Requirements for other HID Lamps (Second Stage)

Nominal Lamp Wattage Rated Lamp Efficacy*

W ≤ 40 ≥ 50

40 < W ≤ 50 ≥ 55

50 < W ≤ 70 ≥ 65

70 < W ≤ 125 ≥ 70

125 < W ≥ 75

*These requirements apply to all other HID lamps that are not

covered in Table 3.3.3 through Table 3.3.5 beginning in 2016.

3- 18Table 3.3.7 Minimum Efficacy EU Requirements for MH Lamps (Third Stage)

Nominal Lamp Wattage Rated Lamp Efficacy

for Clear Lamps Rated Lamp Efficacy

– Not Clear Lamps

W ≤ 55 ≥ 70 ≥ 65

55 < W ≤ 75 ≥ 80 ≥ 75

75 < W ≤ 105 ≥ 85 ≥ 80

105 < W≤ 155 ≥ 85 ≥ 80

155 < W ≤ 255 ≥ 85 ≥ 80

255 < W ≤ 405 ≥ 90 ≥ 85

Table 3.3.8 Lumen Maintenance and Lamp Survival Factors for MH Lamps (Third Stage)

Burning Hours Lamp Lumen

Maintenance Factor Lamp Survival Factor

12,000 > 0.80 > 0.80

An additional definition was added to 2009/245/EC from 2010/347/EU for a “blended lamp ” as follows:

“(o) ‘Blended lamp’ means a lamp containing a mercury vapor lamp and an incandescent lamp filament connected in series in the same bulb. ” Exemptions from the requirements include the following: “(c) blended high intensity discharge lamps havi ng: 6% or more of total radiation of the range 250-780 nm in the rage of 250-400 nm;

and 11% or more of total radiation of the range 250-780 nm in the rage of 630-780 nm;

and 5% or more of total radiation of the range 250-780 nm in the range of 640-700 nm; (d) blended high intensity discharge lamps having: The peak of the radiation between 315-300 nm (UVA) or 280-315 nm (UVB); (g) high intensity discharge lamps with Tc>7000K; (h) high intensity discharge lamps having a specific effective UV output > 2 mW/kl m; and (i) high intensity discharge lamps not having lamp cap E27, E40, PGZ12.”

3.3.5 Non -Regulatory Initiatives

DOE reviewed several national, regional, and local voluntary programs that promote the use of energy -efficient lighting in the United States. These include the Federal Energy Management Program’s (FEMP’s) program for energy -efficient lighting, the ENERGY STAR Program, the Energy Efficient Commercial Deduction, Efficiency Vermont, the Pacific Gas and Electric rebate program, the San Diego Gas and Electric Energy Efficiency Business Incentives program, the Omaha Public Power District incentives program, the Lyon- Lincoln Electric Cooperative, Inc. incentive program, and the North Carolina Municipal Power Agency 1. The following sections summarize some of these programs for the HID lamps covered by this NOPD

.

3- 19While it is not an exhaustive list, the discussion provides detail on some notable initiatives that characterize recent developments in the lighting market.

3.3.5.1 Federal Energy Management Program

FEMP helps federal buyers identify and purchase energy- efficient products, including certain HID lamps. Section 104 of EPACT 2005 requires that each agency incorporate energyefficiency criteria consistent with ENERGY STAR and FEMP -designated products for “...all procurements involving energy consuming products and systems...” Executive Order 13123 and Federal Acquisition Regulation (FAR) section 23.704 direct agencies to purchase products in the upper 25 percent of energy efficiency. 64 FR 30851, 30854 (June 8, 1999). FEMP provides recommendations for how to purchase the energy-efficient products, including the MH lamps

shown in Table 3.3.9

. 7 FEMP also offers buyers support tools such as efficiency guidelines, costeffectiveness examples, and a cost calculator, as well as training, on

- site audits, demonstrations, and design assistance.

Table 3.3.9 FEMP Efficiency Requirements for Federal Purchases

MH Lamps

Upward Efficiency Lamp Wattage Required Luminaire Efficacy Rating (LER)

Closed Fixture Open Fixture

0% 150

– 399 W ≥50 ≥49

400

– 999 W ≥62 ≥69

≥1000 W ≥84 ≥76

1– 10% 150

– 399 W ≥68 ≥49

400

– 999 W ≥73 ≥75

≥1000 W ≥71 ≥96

11

– 20% 150

– 399 W ≥70 ≥55

400

– 999 W ≥76 ≥81

≥1000 W ≥82 ≥87

20% 150

– 399 W ≥76 ≥80

400

– 999 W ≥76 ≥70

≥1000 W ≥87 ≥93

Upward efficiency is the portion of light directed up by the fixture. Both high bay and low

- bay HID luminaires are available with opaque reflectors, which direct all or most of the light downward, and with transparent reflectors, which direct some light up.

3.3.5.2 ENERGY STAR

ENERGY STAR is a joint program of DOE and the Environmental Protection Agency (EPA) designed to protect the environment by promoting energy- efficient products and practices. 8 ENERGY STAR specifies criteria for residential lighting fixtures, which contain three parts: a lamp, a ballast, and the fixture that holds the lamp and ballast. Products that qualify for the ENERGY STAR label may not use magnetic ballasts in indoor fixtures. The ENERGY STAR specifications also define criteria for lamp start time, power factor, lamp current crest

3- 20factor, ballast operating temperature, electromagnetic interference, frequency, transient protection, end-of- life protection, dimming, and safety. 9

ENERGY STAR also specifies criteria for certain luminaires. To qualify a luminaire for ENERGY STAR, the luminaire must first be identified as directional or non

- directional (omnidirectional), then residential or commercial. HID lamps may be used to meet both the

directional and non- directional ENERGY STAR requirements. Table 3.3.10 and Table 3.3.11 summarize all of the necessary qualifications to meet the ENERGY STAR residential and

commercial directional and residential non

- directional luminaire requirements, respectively. 10

Table 3.3.10 ENERGY STAR Residential and Commercial Directional Luminaire Requirements

Luminaire Type ENERGY STAR Residential Requirements

Initial Efficacy Minimum Initial Lumen Output

Cove Mount 45 lm/W 200 lumens per lineal foot

Downlights 42 lm/W ≤ 4.5 ” aperture: 345 lumens

> 4.5 ” aperture: 575 lumens

Accent Lights 35 lm/W 200 lumens per head

Outdoor Post

Mounted 35 lm/W 300 lumens

Luminaire Type ENERGY STAR Commercial Requirements

Initial Efficacy Minimum Initial Lumen Output

Downlights 42 lm/W ≤ 4.5 ” aperture: 345 lumens

> 4.5 ” aperture: 575 lumens

Table 3.3.11 ENERGY STAR Residential Non

- Directional Luminaire Requirements

Effective ENERGY STAR Requirements*

Initial Efficacy Minimum Initial Lumen Output

Until September 1,

2013 ≥ 65 lm/W per lamp

- ballast platform** 800 lumens from lamp

- ballast platform with the exception of chandeliers and bath vanity luminaires featuring ≥ heads which shall provide a minimum of 450 lumens per head. After September 1,

2013 ≥ 70 lm/W per lamp

- ballast platform**

* MH, ceramic MH (C MH), or HPS lamps can be used to meet these requirements.
**These initial efficacy requirements have the exception of covered and dimmable versions of the

GU24 based self

- ballasted lamps that are required to meet reduced efficacy requirements as outlined in qualifica tion requirements for those lamps.

EPA is currently developing a new product specification for l amps that will replace existing CFL and integral LED lamp specifications. EPA published a Version 1.0 Specification

3- 21updating testing requirements, performance tiers, labeling requirements, and various other requirements, but did not specify performance characteristics of HID lamps. 11

3.3.5.3 Energy Efficient Commercial Building Deduction

EPACT 2005 created the Energy Efficient Commercial Buildings Deduction (26 U.S.C 179D), which establishes a tax deduction of up to $1.80 per square foot for building owners who incur expenses for energy -efficiency upgrades that reduce energy costs by 50 percent or more. Effective for property in service from January 1, 2006 through December 31, 2008, the deduction allows partial deduction of $0.60 per square foot for improvements in interior lighting designed to reduce energy costs by one -third of the 50 percent requirement. Though the statute does not specify required lamp types or efficacies, it does call for an overall reduction in lighting power density (to qualify, the lighting power density must be below the minimum required by the ASHRAE/IES 90.1), encouraging the use of higher- performance and reduced

- wattage HID lamp -and- ballast sy stems. The Emergency Economic Stabilization Act of 2008 (HR-1424), approved and signed on October 3, 2008, extends the benefits of EPACT 2005 through December 31, 2013.

3.3.5.4 Efficiency Vermont

Efficiency Vermont provides technical assistance, rebates, and other financial incentives to help Vermont households and businesses reduce energy costs with energy-efficient equipment, lighting, and other approaches. They are operated by the nonprofit organization Vermont Energy Investment Corporation under an appointment issued by the Vermont Public Service Board. Efficiency Vermont and the Burlington Electric Department partner with electrical distributors to offer contractors and commercial lighting customers efficient lamp replacements in order to reduce lighting energy consumption through the SMARTLIGHT Program. Through this program, Efficiency Vermont pays the incremental cost of energy- efficient lighting products directly to the distributor to help contractors and commercial lighting customers afford more

energy- effic ient replacement lamps. Reduced

- wattage MH lamps are included in the eligible products through SMARTLIGHT. SMARTLIGHT offers payments ranging from $10 to $20 for

reduced -wattage MH lamps from four manufacturers for lamps ranging from 60 W to 950 W. 12

3.3.5.5 Pacifi c Gas and Electric

Pacific Gas and Electric (PG&E) offers rebates for businesses who purchase approved

energy- efficient products for their companies. Funding for the rebate program is first

- come, first

serve until their allocated funds are exhausted or the program ends , whichever comes first. PG&E offers rebates for several HID lamps and fixtures that meet their energy

- efficiency requirements, summarized in Table 3.3.12

. 13

3- 22Table 3.3.12 PG&E HID Lamp and Fixture Rebates (2013-2014)

Description Rebate/Unit Measure

Indoor HID Fixtures with Electronic Ballasts

Existin g > 400 W Lamp, ≤ 600 W New Lamp (Tier 1) * $ 20.00 /fixture

Existing > 400 W Lamp, ≤ 750 W New Lamp (Tier 2) * $ 15.00 /fixture

Existing 400 W Lamp, ≤ 250 W New Lamp $ 10.00 /fixture

Existing 176

- 399 W Lamp, ≤ 150 W New Lamp $ 10.00 /fixture

Existing 101

- 175 W Lamp, ≤ 125 W New Lamp $ 10.00 /fixture

Existing ≤ 100 W Lamp, ≤ 70 W New Lamp $ 5.00 /fixture

Outdoor HID Fixtures with Electronic Ballasts

Existing > 400 W Lamp, ≤ 750 W New Lamp $ 20.00 /fixture

Existing 400 W Lamp, ≤ 250 W New Lamp $ 15.00 /fixture

Existing 201

- 399 W Lamp, ≤ 175 W New Lamp $ 15.00 /fixture

Existing 176

- 200 W Lamp, ≤ 125 W New Lamp $10.00/fixture

Existing 101

- 175 W Lamp, ≤ 100 W New Lamp $ 10.00 /fixture

Existing ≤ 100 W Lamp, ≤ 70 W New Lamp $ 5.00 /fixture

* See section 3.3.4.2 for information on energy

- efficiency standards set by the CEC

. Tier 1 refers to lamps that comply with standards set for lamps manufactured on or after January 1, 2010, and Tier 2 refers to lamps that comply with standards set for lamps man ufactured on or after January 1, 2015

.

In order to receive the PG&E rebates for purchasing the indoor and outdoor HID fixtures with electronic ballasts, the business must install new pulse

- start MH fixtures or retrofits with electronic HID ballasts. Furthermore, the retrofit kits and new fixtures must be equipped with

pu lse

- start MH or ceramic MH ( CMH ) lamps and electronic ballasts that are compatible with controls and capable of dimming or bi-level functionality. The new fixtures must not exceed the

“ new lamp ” wattages that are listed in Table 3.3.12 . The new lamp wattage is the total lamp -only wattage. Outdoor street and roadway installations do not qualify. 14

3.3.5.6 San Diego Gas and Electric Company

The San Diego Gas and Electric Company (SDG&E) operates a program called Energy Efficiency Business Incentives (EEBI) that offers incentive payments to any commercial, industrial, or agricultural customer who pays the public goods charge and/or demand-side management surcharge for energy -efficiency projects that involve the installation of new, highefficiency equipment or systems. The qualifying projects may consist of the retrofit of existing equipment. Incentives through EEBI are paid based on the quantity of kilowatt- hours (kWh) saved from the installation of the new equipment or system. The incentive for lighting is $0.05 per kWh and $100 per peak kW. Program incentive funds will be allocated on a first- come, first

serve basis until all funds are commit ted, or until October 15, 2014 , whichever comes first. 15

SDG&E also offers rebates for business entities that purchase and install higher efficiency HID fixtures and lamps. These rebates are summarized in Table 3.3.13

. 16

3- 23Table 3.3.13 SDG&E HID Lamp and Fixture Rebates

Description Rebate/Unit Measure

Indoor Pulse

- Start MH and CMH Fixtures with Electronic Ballast

251

- 600 W New Lamp $ 20.00 /fixture

601

- 750 W New Lamp $ 15.00 /fixture

176

- 250 W New Lamp $ 10.00 /fixture

126

- 175 W New Lamp $ 10.00 /fixture

≤ 125 W New Lamp $ 10.00 /fixture

≤ 70 W New Lamp (Pulse

- Start MH only) $ 5.00 /fixture

Outdoor Pulse

- Start MH and CMH Fixtures with Electronic Ballast

251

- 750 W New Lamp $ 20.00 /fixture

176

- 250 W New Lamp $ 15.00 /fixture

126

- 175 W New Lamp $ 15.00 /fixture

101

- 125 W New Lamp $ 10.00 /fixture

71

- 100 W New Lamp $ 10.00 /fixture

≤ 70 W New Lamp $ 5.00 /fixture

CMH

≤ 75 W New CMH Fixtures $45.00/fixture

Similar to PG&E, in order to receive the rebate for both indoor and outdoor fixtures with electronic ballasts, SDG&E requires new pulse

- start MH fixtures or retrofit kits with electronic

ballasts. Also, the retrofit kits and new fixture must be equipped with pulse- start MH or CMH lamps and electronic ballasts that are compatible with controls and capable of dimming or bi

level functionality. The retrofit kits may also be used on existing MV, probe- start MH, or HPS fixtures. In order to receive the rebate for CMH fixtures and lamps, the business must replace existing incandescent, parabolic aluminum reflector ( PAR ) halogen, or PAR halogen

incandescent reflector lamps wit h one listed in Table 3.3.13 for accent lighting, flood lighting, or down lighting in indoor installations.

3.3.5.7 Omaha Public Power District

The Omaha Publ ic Power District (OPPD) offers lighting incentives to commercial and industrial customers for replacing and retrofitting their current lighting systems to more energy

efficient ones. Table 3.3.14 summarizes the financial incentives that OPPD offers related to HID retrofits and replacements

. 17 18

3- 24Table 3.3.14 OPPD 2013 Retrofit and Replacement Incentives

Current System Proposed System Incentive Amount/Unit

400 to 999 W HID Reduced W Direct MH Replacement $26.00

320 to 350 W pulse

s tart MH Reduced W Direct pulse -s tart MH Replacement $18.00

250 to 399 W HID Reduced W Direct MH Replacement $ 15.00

175 to 249 W HID Reduced W Direct MH Replacement $ 15.00

3.3.5.8 Lyon- Lincoln Electric Cooperative, Inc.

Lyon- Lincoln Electric Cooperative, Inc. (LLEC) is a rural electric cooperative that provides services to its members including developing energy- efficient solution s for buildings, homes, transportation, power systems and industry, and energy- efficient products for their members. LLEC also provides lighting rebates for new and retrofit applications. They require that retrofit systems result in a net load reduction in kW from that of the existing lighting system. The LLEC lighting rebate program provides rebates only for indoor lighting. 19

Although LLEC did not list the rebate amounts, the eligible rebates are as follows:

• Replacing an incandescent, HPS, or MV fixture w ith an MH fixture with the MH lamp wattage lower than the existing lamp wattage

• Replacing an incandescent or MV fixture with an HPS fixture with the HPS lamp wattage lower than the existing lamp wattage

• Replacing an incandescent, halogen, MV, HPS, MH, or pulse- start MH fixture with a CMH lamp fixture with the lamp wattage lower than the existing lamp wattage

• Replacing an incandescent, MV, HPS, or MH with a pulse- start MH fixture with the lamp wattage lower than the existing lamp wattage 20

3.3.5.9 North Carolina Municipal Power Agency 1

The North Carolina Municipal Power Agency 1 (NCMPA1) consists of 19 cities and towns in North Carolina. It funds several energy

- efficiency programs available to the NCMPA1 participants to encourage energy conservation and efficient en ergy use. In February 2009, NCPMA1 launched the Hometown Green program, which runs the NCMPA1 Lighting RebateProgram and provides commercial and industrial customers with rebate incentives for energyefficient technologies. This program provides examples of anticipated projects that include replacing HID lamps with T -8 or T- 5 fluorescent lamps. The NCMPA1 Lighting Rebate Program grants a rebate of $0.35 per watt saved, with a maximum rebate of $25,000 per customer based on total energy saved from energy- ef ficient lighting retrofits to existing buildings. Minimum operating hours per year of 1,800 are required to be eligible for incentives. All fixtures, lamps,

and ballasts must be Underwriters Laboratories Inc. (UL) certified and meet applicable codes and

re gulations. 21

3- 253.3.6 Hi gh- Intensity Discharge Lamp Shipments

Awareness of annual lamp shipment trends is an important aspect of the market assessment and the development of this NOPD . For this NOPD , DOE used two sets of HID lamp shipments that NEMA provided for the periods 1990 to 2002 and 2003 to 2008. 22 DOE also obtained NEMA HID lamp indices series and confidential shipments from NEMA for 2009 and 2010. Based on manufacturer feedback from interviews, NEMA represents 100 percent of domestic HID lamp production and 75 to 80 percent of national HID lamp sales. The HID lamps in the shipment values include colored and directional lamps, which DOE is not analyzing in this

NOPD

.

DOE used this data for two main purposes. First, the shipment data and market trend information contributed to the shipments analysis and base- case forecast for HID lamps. By using historical shipment data and expert opinion on market trends and calibratin g forecast assumptions with recent data, DOE believes it has based the shipments model and base

- case forecasts on a sound dataset. Second, DOE used the data to develop the installed stock of HID lamps for the national impact analysis (chapter 11 of this NO PD TSD). Based on its understanding of trends in the market, DOE estimated how the market would respond to various potential standard levels.

The historical shipment data for HID lamps is broken down into the main HID lamp technologies including MV, MH, and HPS lamps. Figure 3.3.1 depicts the historical shipments of each lamp type and the projected shipments through 2010.

Figure 3.3.1 Shipments of HID Lamps - 2.0 4.0 6.0 8.0 10.0 12.0 14.0 16.0 18.0 20.0

1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010Shipments (millions)

Year High Pressure Sodium

Mercury Vapor

Probe-Start MH

Pulse-Start and Ceramic MH

3- 26In 1990, pulse- start MH and CMH lamps were a new lamp technology, while the other HID lamp types were established in the domestic market. HPS, MV, and probe- start MH lamps shared similar shipments b ecause they were the three main lamp types used for indoor and outdoor commercial and industrial applications. As customers requested more- efficient lamps, the shipments of pulse- start MH and CMH lamps began to increase, while the less

- efficient MV lamp sh ipments began to drop. HPS lamps, although efficient compared to the other HID lamp types, have a lower color temperature than the other HID lamp types, resulting in a yellow color. Because of this, the shipments of HPS lamps remained relatively steady whi le the whiter -light MH lamps increased in shipments in more recent years. Although probe-start and pulse- start MH lamps provide similar color temperatures, the pulse

- start MH lamps are generally more efficient than the probe- start, leading to a decrease in probe- start MH shipments in recent years. Furthermore, recent regulation set by EISA 2007 required higher efficiency MH ballasts, further transitioning shipments from probe-start to pulse- start and CMH lamps in recent years, as shown

in Figure 3.3.1

.

Figure 3.3.2 HID Lamp Market Share by Lamp Type

As previously mentioned, shipments of HPS, MV, and probe- start MH lamps were

similar in 19 90 when they were the main commercial and industrial lamp types. As the moreefficient HPS and MH lamps were introduced to the market, MV lamps quickly ceded market share to MH lamps. In 1990, MV lamps represented approximately 32 percent of all HID lamp shipments, whereas in 2010 they comprised approximately five percent. From 2000 onward, pulse- start and C MH lamps gained market share because of their energy efficiency and superior color characteristics. Between 2004 and 2008, the market began to stabilize , with no drastic redistribution of market share between HID lamp types. In anticipation of the January 1, 2009 0% 10% 20% 30% 40% 50% 60%

1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010Market Share

Year High Pressure Sodium

Mercury Vapor

Probe-Start MH

Pulse-Start and Ceramic MH

3- 27effective date of an EISA 2007 provision that effectively prohibited the use of probe- start MH

ballasts with luminaires containing lamps between 150-500W, pulse- start and C MH lamps began to absorb some of the market share of probe -start MH lamps in 2008. Since then, pulse- start and

C MH lamps market share has increased at the expense of probe-start MH lamps. The 2010

market share distribution betwe en lamp types is shown in Figure 3.3.3

.

Figure 3.3.3 2010 HID Lamp Market Share

Table 3.3.15 shows the breakdown of HID lamp shipments 1990 to 2010. As previously mentioned, all HID lamp shipments include colored and directional lamps, which DOE is not considering for energy conservation standards in this NOPD

. 34%

5% 33% 29% HPS

MV Probe MH

Pulse MH

and CMH

3- 28Table 3.3.15 Historical Shipments of HID Lamps

Unit Shipments (millions) by Year

HPS MV Pulse

MH & CMH Probe MH Total*

1990 7.4 6.2

--- 5.7 19.3

1991 8.2 4.5

--- 5.5 18.2

1992 8.8 4.7

--- 6.4 19.9

1993 9.7 4.6

--- 7.3 21.6

1994 10.6 4.8

--- 8.7 24.1

1995 10.8 4.5

--- 10.5 25.8

1996 11.9 4.4 0.05 11.5 27.9

1997 11.9 3.5 0.1 13.1 28.6

1998 12.2 2.8 0.4 15.0 30.4

1999 12.6 3.0 0.9 17.2 33.4

2000 11.5 2.8 1.3 16.8 31.4

2001 11.5 2.1 2.7 15.6 32.4

2002 11.7 2.3 3.8 15.0 32.9

2003 11.5 2.3 4.7 14.5 32.9

2004 11.3 2.3 7.2 12.7 33.7

2005 13.9 2.3 7.9 13.6 37.8

2006 11.8 2.7 7.9 14.0 36.4

2007 11.2 2.3 7.9 14.1 35.5

2008 10.9 1.8 7.3 13.0 33.1

2009 10.2 1.5 8.6 10.9 29.6

2010 10.2 1.5 9.9 8.8 30.3

*Because of rounding, values may not sum to the total.

3.4 TECHNOLOGY ASSESSMENT

The purpose of the technology assessment is to develop a preliminary list of technologies that could be used to improve the efficacy of HID lamps. The following assessment provides a description of the basic construction and operation of MV, HPS, and MH lamps, including technology options to improve efficacy.

3.4.1 Bas ic Structure and Op eration of HID Lamps

All HID lamps produce light by converting electrical energy into kinetic energy of moving electrons, which is then converted into radiation primarily through collisional excitation of gaseous atoms. 23 The gaseous atoms are contained in an arc tube inside the bulb of the lamp and are typically metals, such as mercury or sodium, or halide compounds of metals. 24 S tarter

gas es that ionize at relatively low pressures are also present —usually argon or xenon or a mixture of argon, neon, or xenon, depending on the type of HID lamp. 24 HID l amps also contain buffer gas es, which serve to increase the pressure inside the arc tube to vaporize the light

3- 29producing molecules. The arc tube also contains electrodes, typically made of tungsten, that

deliver an electric field to the arc tube.

The outer bulb that conta ins the arc tube is made of soft or hard glass (though usually hard glass)

. n It protects the arc tube and internal electrical connections from being exposed to theenvironment. The atmosphere in the outer bulb is often a vacuum—though sometimes a lowpress ure gas such as nitrogen is present in the outer bulb—in order to prevent oxidation of the arc tube metal parts and to reduce gaseous convective heat loss from the arc tube. 24 The outer bulb also acts as a shield to prevent direct contact with the inner arc tube during lamp handling and installation. If a quartz arc tube is handled directly, the salts present in human perspiration

can deposit on to the surface of the silica wall of the arc tube. These salts provide crystal nuclei onto which the amorphous silica can crystallize. Over extended lamp operation, the crystallized areas can grow such that the differential expansion between crystalline quartz and vitreous silica

could cause failure of the arc tube. 23

While the outer bulb transmits light, it absorbs most of the UV radiation emitte d by the arc tube. The outer bulb is sometimes coated with a diffusing material to decrease source brightness of the lamp. The diffusing coating is typically a color-correcting phosphor that converts the UV radiation emitted by the arc tube to visible light in order to improve the lamp’s overall color rendering properties and sometimes efficacy. o 24 The outer bulb also contains

electrical wir ing, which conducts electricity to the arc tube, and structural components to support the arc tube. Other components such as resistors or diodes, which help start the arc discharge, and getters, components that purify the atmosphere in the outer lamp by re moving trace gases, may also be present within the outer bulb. 24 Finally, HID lamps usually have screw bases, though some lamps have special bi -pin bases or pairs of single- contact bases at each end of the lamp.

When voltage is applied across the electrodes, free electrons get accelerated within the arc tube until an arc is ignited between the main electrodes. The heat generat ed by this process

causes the metal or MH atoms in the arc tube to vaporize, diffuse into the arc, and, in the case of

MH lamps, the metal halides dissociate. In the arc stream, free electrons collide with the gaseous metal atoms, thereby exciting the elec trons within the atoms to higher, unstable energy states. As the electrons drop back to the stable or ground energy state, they emit electromagnetic radiation that is equivalent to the energy difference between the excited energy state and stable energy

state. 23 The free electrons again collide with the gaseous atoms, excite the atoms’ electrons, and the entire process is repeated. 23 This process is shown schematically in the following Figure

3.4.1

.

n Hard, or borosilicate, glass has a higher melting point and lower coefficient of expansion than soft glass. Hard glass, therefore, can wit hstand higher temperatures and pressures than soft glass.

o The color

- correcting properties of the phosphor diffusing coating have the largest effect on MV lamps because MV lamps emit the most UV radiation.

3- 30Figure 3.4.1 Light Emission Process of an HID Lamp The excited state is unstable; therefore, the atom
emits electromagnetic radiation as it falls to a lower
energy state, which may or may not be the ground

state.

Electrical energy in the form of
current (i.e.

, free moving,
accelerated electrons) Atom within the arc tube of the HID
lamp that exists in its ground

energy state Atom in the excited state after

the external electron collision

Electromagnetic spectrum

3- 313.4.2 Mercury Vapor Lamps

MV lamps were introduced in the 1930s and were the first commercially available HID lamps. The CRI of these lamps is relatively poor, such that most objects appear to have distorted colors. For example, orange and red appear brownish, and blue, green, and yellow are emphasized. 24 Therefore, MV lamps are primarily used in applications that are not frequently occupied by people. Typical applications include outdoor security, street lighting, and landscape lighting. However, more- efficient HPS and MH lamps are replacing MV lamps in some of these applications.

Based on a review of manufacturer catalogs, p the initial efficacy of MV lamps ranges

from 31 lm/W to 64 lm/W, with typical initial efficacies around 45 lm/W. The CCT typically ranges from 3200 K to 6800 K, wh ile CRI typically ranges from 15 to 50. The higher CRI values are achievable through the use of phosphor coatings on the inside of the outer bulb. The typical rated life of MV lamps is about 24,000 hours.

3.4.2.1 Lamp Construction

Figure 3.4.2 shows the detailed construction of an MV lamp. MV lamps produce light when an electric current is passed through mercury vapor. Mercury, along with argon, which is used as the starter gas, is contained within an arc tube typically made of fused silica (quartz). Current conductor ribbons made of molybdenum are sealed into the ends of the arc tube. 24 This

seal is the lead

- in connector that transmits current to the lamp electrodes. Directly sealing the silica arc tube to the molybdenum ribbons ensures a hermetic seal because, despite a difference in coefficients of expansion, the molybdenum foil can yield plastically (permanently deforming under stress) under high thermal stresses. 23 The ability to withstand high- temperature is important because the minimum wall temperature of the arc tube in MV lamps is typically in

excess of 357 ° C, the boiling point of mercury. 23

p Fifteen HID lamp manufacturer catalogs were reviewed to create a database of approximately 2500 HID lamps.

3- 32Figure 3.4.2 Mercury Vapor Lamp Construction 23

In addition to the starter gas and mercury, the arc tube also contains electrodes, which are usually made of tungsten. The emission material in the electrodes, which comprises several

metall ic oxides, is embedded within the turns of a tungsten coil and protected by an outer tungsten coil. 24 The arc tube of most MV lamps also contai ns an auxiliary starting electrode, which is placed near one of the main electrodes and connected to the opposite main electrode through a current- limiting resistor. q , 24 The inclusion of a starting electrode allows the arc to strike at 50 percent of the starting voltage that would be required without it. 23

The arc tube is enclosed within an outer bulb that is usually elliptical in shape, made of hard (borosilicate) glass, and contains a stable, low -pressure gas, which is generally nitrogen or, in rare cases, a vacuum. 24 In addition to the functions described in section 3.4.1 , the outer bulb serves a particularly important function in MV lamps: that of absorbing UV radiation. The emission spectrum of mercury includes unusually high radiation in the UV wavelengths that penetrates the silica walls of the ar c tube. Without the outer bulb, the UV rays present in the emitted light could harm people exposed to the light by causing severe sunburns or a painful burn to the conjunctiva of the eye. 23 Though the borosilicate glass of the outer bulb absorbs much of the UV light, the inner surface of the outer bulb is usually coated with phosphor coatings, which reduce UV tran smittance further by converting s ome of the emitted UV rays into visible light. 24 Generally, the phosphor is chosen to emit in the red region, thereby significantly improving the color rendering of the lamp. In doing so, the phosphor coating also slightly improves efficacy.

q Some special MV lamps do not use a starter electrode, but instead require a high open

- circuit voltage to ionize the argon starting gas until an arc can strike across the electrodes. These two -e lectrode MV lamps are uncommon and are used in specialty applications. 24

3- 333.4.2.2 Lamp Operation

The majority of MV lamps are probe- start lamps, which have a starting electrode adjacent

to one of the main electrodes. r The voltage gradient across this small gap between the starting and adjacent electrodes is high enough to ionize the argon gas. As electrons are freed by this ionization process, they are accelerated by the electric field between the main electrodes until an arc strikes between the main electrodes. After an arc is established between the main electrodes, a bimetal switch removes the starting electrode from the circuit.

Because mercury has a low vapor pressure, it cannot be vaporized until sufficient heat is generated in the ar c tube. Therefore, argon is used as a starter gas at pressures of 2.4 to 4.8 kPa to facilitate lamp starting. 25 Because it ionizes more readily than mercury, argon is first to ionize and is responsible for establishing an arc between the main electrodes. On ce an arc has been struck, heat generated within the arc tube begins to vaporize the mercury and the process continues until all the mercury is evaporated. 24 The time required from starting the lamp to vaporizing the mercury is known as the warm-up time. At the end of the warm-up period, the lamp operates at steady state with all of the mercury evaporated.

When the lamp is first ignited, the arc tube is at ambient temperature and the mercury pressure is low. 23 The lamp voltage is low at the instant the arc strikes but rises through the

warm -up phase until the arc attains a stable vapor pressure. The operating pressure depends on the amount of mercury in the lamp and varies between 200 to 400 kPa in most lamps. 24 For a lamp to reach these high operating pressures, the arc tube must warm up to a minimum of

500 ° C; it typically takes five to seven minutes to reach this operating temperature and pressure.

During the warm -up phase, the arc stream changes from a bluish glow, which is produced when argon is ionized, to a blue-green light once mercury starts vaporizing. The blue- green light increases greatly in luminance and becomes concentrated along the axis of the arc tube as more

m ercury vaporizes. 24 Once a MV lamp is turned off, the lamp will not reignite until the mercury pressure has decreased substantially and the arc tube cools down sufficiently, to approximately

125 ° C. 23 The vapor pressure must decrease to the point where the arc can restrike at the

avail able voltage for the lamp to restart. 24 The time required for hot restart of the lamp, or restriking the arc after a momentary power loss and sufficient cooling, is between three to six minutes for most MV lamps.

MV lamps produce light when an electric current is passed through mercury vapor at high pressure. During steady state operation, the spectral power distribution of the lamp depends on the pressure at which the lamp operates. At higher operating pressures, the majority of the emitted radiation is in the longer wavelengths because the electrons within the mercury atom are excited to higher energy states. As the electrons fall back to lowe r energy states, they emit light with longer wavelengths. These longer wavelengths fall in the visible region of the electromagnetic spectrum with the five principle visible spectrum lines of mercury at 404.7, 435.8, 546.1, 577, and 599 nm. 24 These lines are consistent with the greenish -blue light of MV

r Some special MV lamps do not use a starter electrode, but instead require a high open

- circuit voltage to ionize the argon starting gas until an arc can strike across the electrodes. These two

- electrode MV lamps are uncommon and include specialty applications. 24

3- 34lamps. Figure 3.4.3 shows the spectral power distribution for MV lamps. At extremely high pressure, there is also a tendency of the line spectrum to spread into wider bands. 24

Along with emissions in the visible spectrum, a significant portion of the energy emitted by MV lamps is in the UV region with wavelengths of 185.0 and 253.7 nm. Phosphor coating s applied on the inside wall of the outer bulb help convert some of the emitted UV rays to visible radiation. In general, the phosphor is selected such that it converts UV radiation to emit in the red region of the spectrum. 23 Because there is no radiation in the red region of the mercury spectrum, this greatly improves the color of the phosphor-coated lamp. The phosphor used most commonly for coating MV lamps is a vanadate phosphor, which emits long-wavelength radiation in the orange-red region of the visible spectrum. 24 This phosphor is also blended with others to produce cooler or warmer colors as needed. The use of phosphors improves the efficacy and color rendering of MV lamps. Phosphor- coated MV lamps are often preferred over clear lamps due to their improved color rendering. 23

Figure 3.4.3 Mercury Vapor Spectral Power Distributions 24

Over the operating life of MV lamps, lumen depreciation occurs due to the deposition of evaporated electrode material on the walls of the arc tube. 23 The process of evaporation and deposition of the electrode emission material initially deposits a white material on the inner surface of the arc tube, which eventually turns black . Th e emission material is deposited on the walls of the arc tube very slowly because it has to evaporate and diffuse through mercury vapor, which is a very heavy gas at high pressure. 23 Therefore, MV lamps have a long average rated life and excellent maintenance of light output over the life of the lamp. At 24,000 hours, a typical MV lamp continues to emit 75 percent of its initial light output. 23 The lamp reaches the end of its life when the electrodes are exhausted and when the starting voltage exceeds the open

- circuit voltage. 24

3.4.3 High

- Pressure Sodium Lamps

HPS lamps were introduced in the 1960s and are generally the most efficacious lamps within the HID family. However , the color rendering of these lamps is poor and they are

3- 35therefore used in applications where color characteristics are not crucial. 26 The most common application of HPS lamps is for street lighting applications, though they are common in exterior, security, and industrial lighting applications as well. The initial efficacy of HPS lamps ranges

from 32 lm/W to 153 lm/W, with typical initi al efficacies around 100 lm/W.

The CCT and CRI ranges of typical HPS lamps are not as varied as other HID lamps, with CCT typically ranging from 1900 K to 2200 K and CRI typically ranging from 20 to 25. In addition to standard HPS lamps, HPS lamps with higher CCT and CRI values are available, but such lamps have lower efficacy compared to typical HPS lamps. HPS lamps have a very long life

with a typical rated life of 24,000 hours.

3.4.3.1 Lamp Construction

Figure 3.4.4 shows the basic components of an HPS lamp. As the name suggests, HPS lamps produce light when current is passed through sodium vapor at high pressure. Consistent with typical HID lamp constructio n, HPS lamps have an inner arc tube and an outer bulb. Arc tube materials that are used in other HID lamps, such as quartz, cannot be used for HPS lamps because sodium is highly corrosive, particularly at high temperatures. Instead, the arc tube of

HPS lam ps is made of polycrystalline alumina (ceramic, or PCA), which is resistant to the corrosive nature of sodium at high temperatures and has a high melting point. 24 Polycrystalline alumina is translucent, yet it transmits more than 90 percent of the light. 24 For a brief period beginning in the late 1970s, some manufacturers also produced HPS lamps with a synthetic sapphire arc tube. Like PCA , sapphire is a form of aluminum oxide (Al 2 O 3 ). However, it is grown as a single crystal from molten alumina. As such, it is far purer and denser, and its

super ior mechanical properties allow it to withstand a higher wall loading and achieve higher efficacy. Furthermore, DOE found academic papers indicating tha t because sapphire is a transparent crystal, allowing a higher transmittance of light as compared to PCA, there was potential for increases in efficacy by constructing the arc tubes out of sapphire. 27 However, DOE

has received feedback from manufacturers th at this increase in efficacy is not necessarily true ( see chapter s 2 and 4 of this NOPD TSD). Additionally, these lamps are no longer in production due to costly materials and manufacturing processes.

The contents of the arc tube include electrodes, sodium and mercury amalgam s as the light- emitting gas, and xenon as the starter gas. The sodium and mercury amalgam typically forms at the coldest spot within the arc tube. 28 An advantage of including the amalgam reservoir inside the arc tube is that HPS lamps can be operated in any physical orientation; therefore, HPS lamps cannot be misinstalled. 28

s An amalgam is an alloy of mercury. Sodium and mercury amalgam is an alloy of sodium and mercury.

3- 36Figure 3.4.4 High

- Pressure Sodium Lamp Construction 24

Because the ceramic used to make the arc tube of HPS lamps is crystalline, it cannot be

flame -worked (fused to metal by melting), like glass or quartz, to make conventional electrode seals. Therefore, an end cap, usually made of niobium, is brazed t or welded u to the electrode

lead -in wire and support. Niobium is used because it has a thermal expansion coefficient that is very close to that of translucent ceramic, and it therefore maintains a seal as the ceramic expands and contracts with temperature variation. This end cap assembly is then fastened to the ceramic arc tube by a brazing v or frit -sealing technique. w 23 Figure 3.4.5 shows the cross section of a typical seal assembly for an HPS lamp.

t Brazing is a process to join metals wherein a filler material is heated above its melting point and distributed

between two or more close

- fitting parts by capillary action.

u Welding is a process to join materials, usually metals or thermoplastics, by mel ting the materials to be joined and adding a filler material to form a pool of molten material. When the molten material cools, it becomes a strong joint. Welding differs from brazing in that in welding the materials to be joined are also melted, while they are not melted in brazing.

v The brazing technique to attach the end cap assembly to the inner arc tube use a molten metal or metals that have a high affinity for both the alumina surface and the niobium end cap. These filler materials typically lack “we ttability” with the alumina surface, but the advantage of brazing is that the filler materials are relatively nonpermeable to sodium metal. Therefore, sodium losses from the arc tube are minimized.

w A frit seal employs a glassy or crystalline material of a lower melting point than alumina as a “glue” with which to stick on the end cap and inner arc tube. An advantage of the frit seal is that it “wets” the alumina surface better than the brazes do and tolerates a wider variation in spacing between the end c ap and inner arc tube. The disadvantage of using a frit seal is that frit

- sealed lamps show a higher rate of sodium loss from the arc tube than braze

- sealed ones.

3- 37Figure 3.4.5 Cross Section of a Typical Seal Assembly for an HPS Lamp with a Ceramic

A rc Tube 23

3.4.3.2 Lamp Operation

HPS lamps produce light by the same basic mechanism as other HID lamps: an arc, sustained by a voltage across the operating electrodes, ionizes the gas into a plasma, excites the metal atom electrons to a higher energy state, and light is emitted as the gaseous atoms fall back

to their ground energy state from the excited state. However, the starting mechanism is unique because the compact arc tube diameter and the presence of metal end caps used for sealing the electrodes to the arc tube preclude the use of a starting electrode. 23 24 Instead, a high-voltage pulse sta rts the lamp. When the high- voltage pulse is applied across the electrodes within the arc tube, xenon gas is first ionized, which facilitates striking the arc. After sufficient heat is generated by the arc, the sodium and mercury amalgam begins vaporizing. 26 The mercury vapor raises the gas pressure and operating voltage within the arc tube, which facilitates the sodium vapor’s production of light once sufficient pressure is reached within the arc tube.

The phase before the sodium vaporizes sufficiently to produce a steady yellow light is known as the warm-up time. HPS lamps typically warm up for two to four minutes. 29 During

warm -up, HPS lamps pass through three distinct color phases. First, the lamp produces light of a sky blue color as the xenon ignites. As the mercury vaporizes, it emits a bluish color. As the sodium vaporizes, the lamp finally stabilizes at the characteristic yellow

- white light. 30 After A: alumina arc tube

B: niobium or stainless steel exhaust tube C: niobium end cap D: pinch seal

E: electrode

F: frit or braze seal G: exhaust port

3- 38turning off an HPS lamp, either manually or due to power failure, it must cool down before the arc can restrike. The lamp generally requires one minute to restrike. 29

While argon and neon are typically used as starter gases for other HID lamp technologies, xenon is used in HPS lamps because it has a lower thermal conductivity. This reduces gas conduction losses, thereby increasing the efficacy of the lamp. The HPS lamp also uses relati vely high xenon pressures improv ing efficacy at the expense of a higher starting voltage. A typical xenon pressure in the arc tube is about 20 kPa. 31 The sodium- to

- mercury atomic ratio in the arc is approximately two or three atoms of sodium to one atom of mercury.

Mercury, the buffer gas used to facilitate increasing the pressure within the arc tube to vaporize sodium, has several other benefits. It is easier to handle and dispense sodium as an amalgam of mercury rather than pure sodium. Further , the blue

- green spectral emission of mercury combines with the yellow-orange of sodium to improve the color rendition of the lamp.

Once the lamp is warmed up and enough sodium has been vaporized to operate in steady state, the lamp radiates energy in the visible sp ectrum, though the color of emitted light depends on pressure, with higher sodium pressures broadening the emission spectrum and improving CRI. The lamp produces a yellow- white light, which is created as the green -blue light of the mercury spectrum add s to the yellow-orange light of the sodium spectrum. 23 A t sodium pressures

of 27 kPa or higher, the resulting spectrum is a nearly continuous one, w ith spectral absorption

lines at 589 .0 nm and 589.6 nm. These gaps in the emission spectrum , known as the D- lines of sodium, occur when photons in the characteristic monochromatic yellow -orange of low- pressure sodium are self -absorbed by nearby particles and re radiated in random directions, effectively scattering these photons into other wavelengths. The leftmost panel of Figure 3.4.6 shows the

resulti ng spectral power distribution for a typical HPS lamp. Further increasing the sodium pressure within the arc tube broadens the emission spectrum and improves the color rendering qualities of the lamp at the expense of efficacy. 31 As sodium pressure increases beyond an optimal pressure, the rate of photon absorption increases, effectively widening the D- lines and shifting the emission spectrum int o the infrared region. HPS lamps with CCT s of 2200 K to 2700

K and CRI between 65 and 85 have been developed by employing this method. These high- CRI lamp s have shorter life (with a median of about 10,000 hours) and lower initial efficacy (between 32 and 94 lm/W, with a median of 57 lm/W) than standard HPS lamps. 24 The rightmost panel of Figure 3.4.6 shows the spectral power distribution of a high-C RI lamp.

3- 39Figure 3.4.6 High

- Pressure Sodium Spectral Power Distributions 24

The operating voltage of the arc tube in an HPS lamp increases over the life of the lamp. 24 The cause for the increase in voltage is primar ily due to the loss of sodium in the arc tube over the lamp life and the resulting change in the ratio of the sodium and mercury amalgam. 32

Sodiu m is lost through several methods, such as leakage from the arc tube, reactions with the arc tube wall, and sodium loss to the electrode emission material. 32 Toward s the end of the lamp’s operating life, the voltage of the lamp may increase beyond the ballast’s capability to sustain the arc across the electrodes. When this happens, the lamp extinguishes, cools down, and turns on again. This cycli ng pattern repeats for a long time, usually until the lamp is replaced. 32 If the lamp is not replaced within a reasonable period of time, the lamp may require more voltage than the ballast is designed to provide and the ballast may fail permanently.

To overcome the issue of end -of-life cycling of HPS lamps, the industry introduced noncycling HPS lamps in the 1990s. These lamps operate on standard HPS ballasts but modify the conditions within the arc tube to prevent cycling. The electrode emissive coating material can be changed to decrease sodium losses to the emitter. 32 Other methods have included dosing the lamp such that it is unsaturated in mercury and saturated in sodium. 32 Adjusting the arc tube wall temperature and xenon pressure to reduce sodium loss due to reaction with the arc tube wall has

also been researched. 32 A starting aid is used in these lamps because the breakdown voltage of xenon increases with increasing pressure. These lamps gradually become fully unsaturated in the useful operating regime towards the end of life

. 32

HPS lamps can be manufactured as retrofit lamps for MV lamp ballasts. These HPS lamps have an additional coil, called a starting aid, around the arc tube inside the outer bulb, which is connected through a thermal circuit breaker to the electrode at the opposite end of thetube. On applying a potential, the starting aid works similarly to the starting electrode in probestart MV and MH lamps in that ionization between the starting aid and adjacent electrode eventually allows an arc to form between the electrodes. 28 These retrofit lamps use a combination of argon and neon gas as the starter gas instead of the xenon that is typically used in HPS lamps.

Due to the unique voltage requirements of an HPS lamp, special care must be taken when selecting a ballast for an HPS lamp -and- ballast system. That is, the ballast of an HPS lamp must

3- 40accommodate the changing voltage over the lamp’s life in order to maintain an acceptable average wattage. ANSI has developed standards for the maximum and minimum permission lamp wattage and voltage for each nominal lamp voltage. The permissible operating parameters for a 400 W HPS lamp are shown in Figure 3.4.7 as an example.

Figure 3.4.7 Operation Limits for 400 W HPS Lamp 29

3.4.4 Metal Halide Lamps

MH lamps were commercially introduced in the 1960s and have since evolved into the most versatile lamp of the HID family, finding common use in applications such as roadway, sports fields, landscape, industrial, retail, floodlighting, and vehicular headlamps. They are very similar to MV lamps in basic construction, but the addition of a variety of metal halides to the gas composition gives them very good color rendering properties, with products available with

CRI v alues ranging from 60 to 100 and CCT ranging from 2500 K to 50,000 K. x The efficacy of

omnidirectional MH lamps is also much improved over that of omnidirectional MV lamps, with initial efficacy ranging from 54 to 12 7 lumens per watt. The typical rated life of MH lamps is about 15,000 hours. MH arc tubes can be made of either quartz or ceramic, and the lamps can employ either a probe- start or pulse

- start mechanism for arc ignition.

3.4.4.1 Lamp Construction

MH lamps are constructed similarly to MV lamps with some notable differences. The arc tube of MH lamps is usually smaller than those of MV lamps of equivalent wattages and is often

formed into a non- cylindrical shape to improve temperature uniformity in different operating positions. 33 The arc tube can be made of fused quartz or ceramic and contains two main electrodes, a starting electrode in the case of probe

- start MH lamps, argon as the starter gas, mercury as the buffer gas, and one or more metal halide compounds to improve the spectral

emission of th e lamp. The basic construction of a MH lamp is depicted in Figure 3.4.8

.

x Some directional MH lamps are available with a CCT as low as 2500 K.

3- 41Figure 3.4.8 Metal Halide L amp Construction 24

Arc Tube Construction

. MH lamps can be manufactured for dedicated horizontal operation, for dedicated vertical operation, or as a universal lamp that is capable of operating in either horizontal or vertical orientation. The orientation of the lamp affects the temperature gradient of the arc tube, in turn affecting lumen output and color. Excessive wall loading on the arc tube wall can also decrease life by approximately 25 percent. 34 Dep ending on the operating orientation of the lamp, the arc tube shape is designed to optimize lumen output and color. For instance, lamps that are designed for operating exclusively in the horizontal orientation have an arc tube that is bow-shaped to follow the natural upward bowing of the arc during operation due

to convection currents. The bow- shaped arc tube prevents migration of the chemicals by restricting them to the ends of the arc tube. 24 Another design of an arc tube for horizontal operation is an asymmetric arc tube in which the electrodes are lower in the arc tube body, rather than the center. This design allows the arc to bow to the center line of the ar c tube and prevents the arc from being too close to the top of the arc tube wall, causing its temperature to increase. 24
Figure 3.4.9 shows these two common configurations for horizontal MH lamp arc tubes. MH lamps that are designed to operate in the horizontal orientation generally have a special base and socket, called position oriented mogul base (POMB), which ensure that the arc tube is properly oriented during installation and operation.

3- 42Figure 3.4.9 Common Configurations for Horizontal Metal Halide Lamps 24

The first MH lamps were probe -start MH lamps. The arc tube of probe- start MH lamps is made of quartz only. The classic arc tube design is generally referred to as pinched body and is

shown in Figure 3.4.10

. 24 Probe- start MH la mps have a secondary starting electrode, similar to MV lamps, that is used to start the lamp. The lamp also contains a system that provides for either shorting of the starting electrode to the main electrode or opening the starting electrode circuit after the lamp has started to prevent electrolysis in the fused silica between the starting electrode

and main electrode— especially when a halide such as sodium iodide is used in the lamp —which can greatly shorten lamp life. 24 A bimetal switch is typically used in the starter circuit to serve this function. The location and type of the switch could potentially restrict the lamp operating position because the bimetal sw itch needs to achieve a certain temperature for it to function. 24

Pulse

- start MH lamps have also been designed with ovoid- shaped quartz arc tubes. These arc tubes are commonly referred to as formed

- body arc tubes because the arc tubes are formed in a mold using high- pressure gas. 24 The formed shape of the arc tube has several benefits. For example, the contours of the arc tube wall better follow the shape of the arc and allow a more uniform thermal profile for the arc t ube. 24 The formed shape further allows the chemicals in the arc tube to heat up more rapidly compared to the pinched body arc tube, allowing formed-body arc tubes to warm up approximately three times faster than pinched body arc tubes of the same

wattage. 24 The formed- body arc tube also has much smaller pinch seal are as, thereby reducing conductive heat loss through the pinch seals, where the temperature of the MH pool is generally lower than the rest of the arc tube. This reduction in the size of the pinch seals improves the efficacy of lamps with formed -body arc tubes. The magnitude of the efficacy improvement is more prominent in lower- wattage lamps because the pinch seal area in these lamps comprises a greater part of the total thermal mass of the arc tube. 24 The smaller pinch seal does not permit the inclusion of a starting electrode; therefore, all MH lamps with formed -body arc tubes have only two main electrodes within the arc tube and employ the pulse- start mechanism. 24

3- 43Figure 3.4. 10 Common MH Arc Tubes: (a) Ovoid, (b) Pinched Body 24

The arc tube walls of MH lamps usually operate at very high temperatures, in the range

of 725–750 ° C. However , it is important to ensure that the ends of the arc tube do not lose too much heat, especially for lamps that operate in the vertical position. To avoid this, the end of the arc tube is carefully contoured and a press seal design is used along with the application of a

heat -insulating coating that reduces the infrared radiation leaving the arc tube ends. 23 Zirconium oxide is typically used for coating the arc tube ends because it has good reflectivity in the infrared region and reflects the infrared radiation from the electrode back into the arc tube, thereby raising the end temperature. 23 Coating the ends of the arc tube also increases the vaporization of the metal halides during operation. 24

CMH lamps, the newest technology development for MH lamps, have an arc tube made of translucent polycrystalline alumina and were developed and commercialized in North

America in the 1990s. 35 The arc tube of these lamps is typically cylindrical in shape and can withstand metal iodide salt temperatures that are about 300 ° C higher than quartz arc tubes can

withstand. 35 The higher operating temperature and pressure permitted by the ceramic arc tube in these lamps makes them more efficacious than quartz MH lamps. Further, the color consistency, color rendering, life, and lumen maintenance of these lamps are also remarkabl y improved. 35
CMH lamps are designed to operate exclusively on pulse-start ballasts and thus do not have a

starter

- electrode. While the arc tube of CMH lamps is made of the same material as HPS lamps, the technique used to seal the electrodes into the arc tube is not the same. This is because the niobium end cap and sealing frit used in HPS lamps would be rapidly corroded by the liquid and gaseous MH compounds, causing leakage from the arc tube. 36 Instead, a special design, as shown

in Figure 3.4 .11 , is employed in CMH lamps, which consists of an extended plug, a niobium

lead -in, a molybdenum lead-through, and the sealing frit that completely covers the niobium and partially covers the molybdenum. 36 The frit is made of a mixture of aluminum, silicon, and rareearth oxides, making it more resistant to corrosion compared to the frit employed in typical HPS

3- 44lamps. 36 This design, which is a variation of the HPS lamp construction, reduces the frit temperature to an acceptable level, and the frit layer reduces the transport rate to and from the

niobium surface. 36 A disadvantage of this construction is the possible formation of cracks in the alumina plug due to differences in the thermal expansion coefficients between the molybdenum

lead -through and the alumina plug. This issue can be overcome either by using coiled molybdenum lead-through to redirect the stresses or by using molybdenum-alumina composite material that has a thermal coefficient expansion that closely matches that of alumina. 36

Figure 3.4. 11 CMH Lamp A rc Tube Design 36

Figure 3.4.12 shows the arc tube designs of probe- start quartz MH, pulse

- start quartz MH, and CMH lamps

.

Figure 3.4. 12 Metal Halide Lamp Arc Tube Designs 33

3- 45Additive Compounds. The choice of the metal halide compound(s) that is introduced in the MH arc tube is governed by the vapor pressure of the compound at the coldest spot of the arc

tube. 23 A reasonable coldest -spot temperature in the arc tube of MH lamps is 1000 K, and the vapor pressure of the metal should be 130 Pa or higher a t this temperature for the intensity of the spectra to be strong enough to produce a brilliant white light. 23 Introducing the metal atom in

MH lamps as a metal halide compound ( i.e., instead of pure metal) has two important benefits. First, nearly all metal halide compounds have vapor pressures greater than 130 Pa at 1000 K. 23
That is, at the arc tube operating temperature, metal halides are more volatile than pure metals and, therefore, normal arc tube wall temperatures are sufficient to obtain the emission properties

of the metal. 24 Second, with the exception of fluoride compounds, almost none of the metal halide compounds react appreciably with silica, unlike pure metals tha t react chemically with

fused silica. 23 These advantages allow nearly any metal of the periodic table —including those

with more desirable emiss ion spectra—to be introduced into the MH lamp arc tube, instead of the three or four metals otherwise possible. 23 This allows manufacturers a greater degree of flexibility in optimizing operating temperature and pressure (and therefore efficacy) and color rendering.

The MH compounds selected must meet t wo additional requirements. The compound must be stable at the wall temperature of the arc tube, while also being unstable at the temperatures corresponding to the light

- emitting part of the arc column. 23 Iodide compounds satisfy these stability criteria the best among the halide compounds and therefore, metal iodide compounds are the preferred additives in MH lamps. 23 The final requirement is that the room temperature vapor pressure of the compound must be sufficiently low. This requirement is necessary because even a small amount of halide compounds in the vapor phas e at the time of ignition greatly increases the starting voltage. 23 In addition to satisfying the stability criteria, the iodide compounds of most metals meet the low vapor pressure at room temperature requirement

as well.

There are approximately 50 metal iodide compounds that can be used in different combinations in MH lamps. 23 If two metals are used at a time in the arc tube of MH lamps, the number of possible combinations, without varying concentrations, is 1,225. 23 Wit h the addition of more metals, the possible combinations are several hundred thousand. With such a large number of possibilities, the choice of MH compounds is typically made based on the desired radiation spectrum from the lamp. 23 For example, lamps for general lighting applications are typically white and utilize compounds that produce wavelengths across the visible spectrum. Photocopy or graphic arts applications typically require light sources with light in the blue and

near

- UV parts of the spectrum and therefore select additives that produce strong lines in this

spectrum. 23

In order to prevent metal condensation on the walls of the arc tube, excess iodine must be in the gas phase near the arc tube wall to ensure that the equilibrium between gaseous metal and metal iodide is strongly shifted towards the metal iodide compound. However, this cannot be accomplished by excess iodine itself . This is because excess iodine typically forms the diatomic iodine molecule, I 2 , near the arc tube wall, whose gas is purple and highly light-absorbing. 23

The refore , excess iodine is typically introduced in the form of mercury iodide, HgI 2 , which is

3- 46unstable compared to diatomic iodine but is also transparent. The excess iodine combines with the metal vapor to form metal iodide, thereby preventing condensation of the metal on the arc

tube walls. 23 The ratio of iodine- to -mercury is typically controlled between 0.2 and 0.8. 23

Alkali metal iodides, such as iodides of lithium, sodium, potassium, rubidium, and cesium, are generally added to the arc tube of MH lamps to overcome the issues of constricted, poorly wall- stabilized arcs and the resulting electrical resistance. 23 The addition of alkali metal iodides, which have a lower ionization potential, to the arc tube “ fattens ” the arc. They do so by allowing free electrons to be present in the lower

- temperature regions of the arc, thereby generating higher temperatures in that region and allowing more current to flow through the

arc. 23 The overall effect of this phenomenon is increased arc current and decreased arc voltage for a given lamp wattage. 23 Sodium iodide is typically preferred as the alkali iodide to be introduced in the arc tube because of the strong emission in the yellow region of the spectrum of sodium, which increases the lumen output of the lamp. 23

Function of Mercury in Metal Halide Lamps. In addition to providing a suitable means to introduce excess iodine, mercury is an essential component in the arc tube of MH lamps for

several oth er reasons. First, it provides a high total pressure in the arc tube during lamp operation while still having a low pressure at ignition, thereby allowing the lamp to be ignited at a reasonable starting voltage. 23 High pressure during lamp operation is required to ensure that the

dissociated metal and iodine atoms do not diffuse from the core of the arc to the arc tube wall because this phenomenon would lead to very significant loss of energy resulting in an inefficient lamp. 23 Second, the presence of mercury ensures that any free iodine that is present in the arc tube during lamp starting is not present as diatomic iodine. This is important because the presence of free diatomic iodine vapor during lamp ignition makes the starting voltage very high due to the strong electron-attaching properties of diatomic iodine. 23

Protective Shroud Cover. In some single- ended MH lamps, a transparent glass sleeve, called a shroud, is used to surround the arc tube. A thin-walled shroud is u sed as a heat shield because it allows the arc tube to achieve a uniform temperature while retarding sodium loss in lamps that contain sodium. 24

MH lamps operate at pressures far exceeding atmospheric pressure (generally 10 to 15 atmospheres), and therefore there is a danger of violent rupture to lamps that are weakened by chemical degradation, manufacturing defect, or damage. As a precaution, a heavier shroud i s used in lamps that are rated for open fixtures in order to contain hot lamp fragments in the event of an arc tube rupture. A quartz arc tube may rupture because of devitrification, which is a process wherein some sections of the quartz arc tube become crystalline while adjacent regions remain in the amorphous state, giving rise to regions of different thermal expansion. 37 These regions of different thermal expansion within the same quartz arc tube cause the quartz to weaken and possibly crack. 37 In the case where an arc tube ruptures from violent failure, the heavy shroud prevents the outer jacket of the lamp from breaking as well, thereby preventing humans from coming into contact w ith the chemicals from within the arc tube as well as the resultant broken glass. 24 Therefore, it is very important that an open luminaire be relamped with an open-rated lamp only. Lamps that are rated for enclosed fixtures only must be operated in an enclosed luminaire that is designed to contain any hot fragments of an arc tube rupture. 24 The

3- 47industry has developed unique socket and base combinations for open- rated medium and mogul base lamps to prevent user misapplication. 24 The industry has also developed S-rated lamps, which do not have a protective shroud, but may be installed in open fixtures if mounted base up, cycled off for at least 15 minutes a week, and re lamped at 70 percent of rated lifetime, in adherence with manufacturer and NEMA guidelines. 38 The safety of these lamps is somewhat controversial; as such, changes to the 2005 National Electrical Code (NEC), effective January 1, 2005, eliminating the option of installed S-rated lamps in open luminaires for those i nstallations regulated by the NEC. Some manufacturers still offer S- rated lamps. 39

Another advantage of lamps with protective shrouds is that the shroud reduces UV radiation emitted from the lamp compared to MH lamps without a shroud. 37 However, the safety benefits of a shroud come at the cost of reduced efficacy as the shroud also blocks some of the lamp’s visible light.

Outer Bulb Construction. The outer bulb of MH lamps is typically elliptical in shape and is usually made of borosilicate glass. The environment of the outer bulb either contains a low

pressure inert gas such as nitrogen or is a vacuum, which controls the arc tube temperature and prevents oxidation of electrical components. 24 Decreasing the gas pressure in the outer bulb increases the arc tube temperature for a given wall loading because the lower gas pressure in the outer bulb reduces convective cooling of the arc tube. 23 While some manufacturers achieve this by providing an evacuated outer jacket, others accomplish it be using a slightly smaller arc tube in a gas- filled outer jacket. 23

Most MH lamps also contain getters, or chemical additives in the outer bulb that reduce or eliminate impurities present in the outer jacket. These impurities are predominantly hydrogen and carbon. If the impurities are present in the outer bulb of an MH lamp in sufficient concentrations, they can corrode the lamp support structure and electrodes, thereby compromising performance of the lamp. 24

The outer bulb can also be characterized by its bulb finish— that is, whether the inner wall of the outer bulb is coated with phosphors. Phosphor coating is generally used in MH lamps to create a more diffuse light source. 24 Phosphor-coated bulbs block some of the light emitted from the arc tube, leading to lower overall efficacy compared to clear lamps.

Finally, some MH lamps either have no outer jacket or they have an outer jacket that is made from fused silica and transmits UV energy. These lamp s must be operated only in those fixtures that have a cover glass that provides UV filtration. 24

3.4.4.2 Lamp Operation

In addition to the argon and mercury present in MV lamps, MH lamps contain various

metal halides. 24 It is the metal atom of the metal halide compound that emits light when an excited electron falls back to lower energy states in a MH lamp.

Probe- start MH lamps start with the aid of a starting electrode, similar to the starting method of MV lamps. A key difference between MH and MV lamps, however, is that the

3- 48starting voltage of MH lamps is higher than that for MV lamps because of the presence of the

metal halides. 23 24 Pulse -start MH lamps do not have a starting electrode and instead use an igniter to provide enough voltage across the main electrodes to initiate a n arc. 24 Once an arc is initiated between the main electrodes, the lamp is in the warm -up phase, during which the color of the discharge continues to change as the metal halides warm up, evaporate, and get incorporated into the arc. 24 MH lamps typically require between three to five minutes to warm up. If a MH lamp is turned off, it takes longer to cool down and reignite than a MV lamp. This is because the smaller arc tube of a MH lamp necessitates a higher operating temperature. 24 The restrike time in the conventional pinched body arc tube is often 15 minutes or longer. In contrast, pulse- start MH lamps can restrike in as little as 4 to 5 minutes because of the higher pulse (starting) voltages. 24 29

Once the lamp color and electrical characteristics stabilize, the lamp enters steady state operation. During this phase, when the lamp attains its full operating temperature, all the mercury is vaporized, which results in a high- pressure, wall

- stabilized arc. 23 As the metal iodides migrate closer to the arc tube walls, they evaporate and diffuse into the high- temperature arc column where they dissociate. 23 The dissociated metal atoms are ionized and excited, causing them to emit light. Once the metal atoms diffuse towards the cooler walls of the arc tube, they recombine with the iodine atoms that are present in the cooler gas near the walls to reform me tal

iodide molecules. 23 The cycle is then repeated with metal iodides moving into the hightemperature arc and dissociating to emit light from the metal atoms. 24 The partial pressure of metal vapor at the arc axis is typically between 1.3 and 13 kPa and is comparable to the partial pressure of metal iodide vapor at th e walls. 23

The emitted spectrum is dependent on the metal atom or atoms present in the arc tube and their characteristic emission spectra. 23 The emitted spectrum of a MH lamp typically consists of the spectrum of the metals with the mercury spectrum superimposed. 23 While some metals produce visible radiation at a single wavelength, other metals may produce several discrete wavelengths across the visible and UV spectra, and many other metals may produce a continuous

spectru m of radiation. 24 Often, blends of metal halides are used to obtain the desired spectrum, and hence, the desired color characteristics of the lamp.

Figure 3.4. 13 Metal Halide Spectral Power Distributions 24

3- 493.4.5 HID Ballasts

HID ballasts are “ devices that, by means of resistance, inductance, capacitance, or electronic elements, singly or in combination, control the current, voltage, and waveform for proper lamp starting and operation.” (A NSI C82.9-1996). The following sections discuss basic ballast operation of both ballast types: electromagnetic (magnetic) and electronic.

A ballast has three primary functions:

1. To establish an electric arc through the lamp

2. To limit current through the lamp after ignition

3. To compensate for variations in line voltage and ensure consistent lum en output

Magnetic ballasts were the first technology used to operate lamps; electronic ballasts were developed later because of their higher efficiency. The following sections provide additional discussion on these types of ballasts.

3.4.5.1 Magnetic Ballasts

HID magnetic ballast technology is older than electronic ballast technology, and used today for its low cost and tolerance of harsh environments. The primary feature of a magnetic ballast is one or more coils of magnet wire around an iron core; because of thi s they are often

called “ core and coil ” ballasts. Apart from the igniter of pulse

- start ballasts, magnetic ballasts contain no power electronics and are, therefore, better equipped to survive voltage transients and high temperatures.

The main components of a magnetic ballast are a magnetic choke to limit the current, a

step -up transformer to obtain a high starting voltage, and a capacitor that corrects for the ballast’s low power factor. Magnetic ballasts operate at an input frequency of 60 Hz and operate the lamp(s) at the same frequency.

The main core and coil assembly consists of a capacitor and laminated transformer steel wound with copper or aluminum magnet wire. The assembly is infused with a potting material ( e.g. , hot asphalt, epoxy) containing fi ber such as silica and housed in a steel case. Figure 3.4.14 presents a view of a typical core and coil assembly.

3- 50Source: GE Lighting Figure 3.4. 14 Core and Coil Assembly of a Magnetic Ballast

The cor e and coil assembly functions as a voltage transformer and current limiter (choke). A capacitor enables the ballast to use energy from the alternating

- current power line more efficiently; the ballast is then referred to as a high power factor ( HPF ) or powe r factor ( PF ) corrected ballast. The purpose of the insulating material is to conduct heat away from the transformer coils and ensure tightness of the transformer coils to eliminate vibration noise.

Particularly at lower wattages, magnetic ballasts are less energy efficient than electronic ballasts. These ballasts also lose energy as heat in the transformer windings. In order of increasing cost and complexity, HID magnetic ballasts have the following types of circuits: linear reactor (reactor), high

- reacta nce autotransformer (HX-HPF), constant- wattage autotransformer (CWA), constant

- wattage isolated (CWI), and magnetically regulated lag (mag

reg or regulated lag). In general, extra circuitry helps the ballast maintain a constant power output through variations in input voltage.

Linear Reactor. Reactor ballasts are the simplest, smallest, cheapest, and most efficient type of magnetic ballast. Though a capacitor is often employed for PF correction, a reactor ballast can be as simple as a mere inductor in series with the load. A reactor ballast drops more voltage as current increases, stabilizing lamp current at the appropriate point. The major drawback of a reactor ballast is its suscept ibility to line voltage variation; the commonly used ratio is a 5 percent voltage dip produces a greater than 10 percent power dip. Furthermore, the ballast can only limit current and has no ability to modify voltage, meaning the line voltage must

be suffi cient to run the lamp, often limiting reactor ballasts to 277 V applications.

High

- Reactance Autotransformer (HX

- HPF). With high- reactance autotransformers, the addition of a capacitor to the primary circuit makes it possible for the ballast to provide a n
HPF . The HPF autotransformer is usually designed with an extra capacitor winding within its copper windings in order to provide a more economical and efficient system. The HX- HPF

ballast’s PF can be increased to about 90 percent by combining the extended windings with the capacitor. The input current is reduced, as in the HPF reactor. Lamp performance and wattage are also regulated at plus or minus 5 percent. Currently, HX- HPF ballasts are commonly used with HID lamps that are rated at 150 W or less.

Cons tant -Wattage Autotransformer. The CWA ballast type should be used where a stabilized light output is required. CWA is an HID ballast type that comes in a fairly small

3- 51economical size, yet still provides a reasonable degree of wattage regulation. The CWA ba llast also offers the advantage of a n HPF , low line extinguishing voltage, and line starting currents that are lower than operating currents. The CWA type of ballast is the most commonly used HID ballast in North America today.

Unlike the HX -HPFs, which u se a capacitor as a parallel component, the capacitor on a CWA ballast type is used in series with the lamp. This alignment provides the lamp with a more stable wattage when voltage on the branch circuit fluctuates. As the capacitor is performing an import ant ballasting function, it is referred to as a lead circuit. CWA is the most common ballast topology because of its ability to resist line voltage changes and for its lower starting current demands. Although some CWA units rated for lower than 150 W are sold, wattages higher than 150 W are firmly CWA territory.

Constant

- Wattage Isolated Transformer (CWI)

. CWI ballasts are nearly identical toCWA ballasts in both structure and function, the primary difference being a conventional twocoil transformer in pl ace of the single-coil autotransformer. At a very slight efficiency cost, CWI ballasts provide better protection against voltage transients, as the low and high sides of the ballast are coupled only magnetically. Though common in Canada, few CWI ballasts a re sold in

the United States.

Magnetically Regulated Lag. Regulated lag ballasts are the largest, heaviest, and most expensive topology. Three distinct circuits collaborate to provide the greatest degree of resistance to voltage variation, and regulated lag ballasts may even sustain lamps through voltage drops of 30 percent. Regulated lag ballasts were exempted from standards in EISA 2007 and account for a very small (less than one percent) fraction of the North American ballast market. Due to their large size and high cost, regulated lag ballasts are unlikely to be substitutes for CWAs or other ballast types.

3.4.5.2 Electronic Ballasts

Depending on wattage, electronic ballasts might be between 2 and 20 percent more efficient than their magnetic counterparts are . Electronic ballasts can be roughly divided into low- and high-frequency types that, respectively, operate lamps far below or above frequency ranges prone to acoustic resonance. Most low- frequency electronic (LFE) ballasts drive their lamps with a “square” wave, while high-frequency electronic (HFE) units usually produce sinusoids. Although HFE units are thought by some to be more efficient because of smallercircuitry components and the elimination of a power processing stage from the ballast, highefficie ncy electronic HID ballasts can be found operating lamps at both high and low frequencies

. Figure 3.4.15 depicts a typical electronic HID ballast.

3- 52Source: GE Lighting Figure 3.4. 15 Electronic HID Ballast

Figure 3.4. 16 presents a functional block diagram example of a fixed -light output electronic ballast. Auxiliary functions performed by a typical electronic ballast include electromagnetic interference (EMI) filtering to block ballast -generated noise, input rectification,

PF correction for sinusoidal input current, a direct

- current (DC) filter, a direct

- current to alternating

- current (DC -AC) inverter, a feedback/controller for high-frequency operation, and a final output stage to power the lamp.

Figure 3.4. 16 Electron ic HID Ballast Block Diagram 40

Table 3.4.1 provides a description of each component in a typical electronic HID ballast, the efficiency impact of these components, and the waveform at each stage of the ballast circuit.

3- 53Table 3.4.1 Building Blocks of an HID Ballast and Associated Characteristics

Circuit Stage Function Efficiency Impact Waveform

(not to scale)

EMI Filter Impedes EMI by providing a high impedance path to EMI and a low impedance path to the desired input. The circuit also protects against high

- voltage spikes. Very Low

Input Rectifier Begins to convert incoming AC to DC using

diodes. A full

- bridge rectifier, one type of input rectifier, is composed of four diodes,

which “ rectify ” the full AC waveform as shown in the waveform on the right. The current is not in phase with the voltage. Low

Power Factor

Correction Corrects the current so it is in phase with the voltage. P F correction can be achieved through a buck or boost

- converter circuit topology. Low

- Medium

DC Filter Reduces “ ripple ” of the DC current waveform using capacitors. The most common type of capacitor used is the electrolytic capacitor. Low

DC

- AC Inverter and Output Stage Converts incoming DC to AC, sets the current to the lamp, and provides a high

- voltage pulse to start the lamp. The full

- bridge (with integrated buck converter) circuit is one type of circuit topology that can be used to accomplish this task. High

Feedback/Controller An integrated circuit (IC) that controls the frequency output of the DC

- AC inverter. Low N/A t V

t V, I

t V, I

t V

t

V

3- 543.4.6 HID Fixtures

The basic function of an HID fixture is to hold the lamp, supply electric power to the lamp via a ballast, and sometimes, direct the light as desir ed. A fixture typically comprises the lamp, ballast, ballast housing or structure, optics, and wiring. y An HID fixture is typically sold with the lamp and ballast required for the intended application. However, a particular fixture can often hold more than one type of lamp and ballast combination. For example, a high bay fixture for maintenance or storage areas may operate with an HPS lamp and ballast as well as a MH lamp and ballast.

If an HID lamp must be retrofitted in an existing fixture, it is important to ensure that the lamp wattage matches that of the ballast. A higher wattage lamp on a lower

- wattage ballast causes the lamp to operate at a lower efficacy, and the life of the lamp may decrease. Further, the starting and operating voltages of the retr ofit lamp must match that of the lamp being replaced. For example, HPS lamps that require a high-voltage pulse to start may not operate on probe- start MV or MH ballasts that start lamps with lower voltage requirements. Certain MH lamps that have an operati ng voltage close to that of MV lamps may work in a MV fixture.

Finally, while it is important to match the electrical characteristics and operating requirements of the lamp with those of the ballast, it is also necessary to ensure that the retrofit

HID la mp matches the fixture constraints and safety requirements. For instance, MV fixtures that are not enclosed cannot protect against possible lamp rupture of an installed MH lamp. Such a fixture may only use retrofit lamps that are rated for open enclosures. Retrofitting some fixtures may also void the UL safety certification. It is a lso important to ensure that the retrofit lamp does not negatively impact the light distribution of the fixture. Some fixtures cannot adjust to small variations in the position o f the arc tube within the fixture, thereby decreasing the quality of light emitted. Therefore, it is important to ensure that the lamp being retrofitted meets all criteria before installing it in an existing fixture.

3.4.7 HID Lamp Technology Options

The following sections summarize the technology options that DOE is analyzing in this

NOPD as viable methods of increasing the efficacy of HID lamps. Please see sections 3.4.2 through 3.4.4 for more detailed descriptions of each technology option.

3.4.7.1 Mercury Vapor Lamps

Change Lamp Type. MV ballasts, other than specialty application MV ballasts, have been banned from import or production in the United States since January 1, 2008. (42 U.S.C. 6295 (ee)) This ban effectively limits the installation of new MV fixtures and ballasts, meaning the only MV lamps currently being sold are replacement lamps. DOE understands that there is limited industry design emphasis on MV lamps, that there are limited methods to improving the efficacy of MV lamps, and that the common pathway increase efficacy is a change of technology to MH or HPS lamps.

y In some cases, the b allast may be installed external to the fixture. For example, the ballast is installed inside the pole in lighting applications that use pole

- mounted fixtures.

3- 553.4.7.2 High

- Pressure Sodium Lamps

HPS lamps are very efficacious (up to 150 lm/W ), but have intrinsically poor color quality. DOE’s research found only one option to investigate regarding potentially increased efficacy in HPS lamps :

Sapphire Arc Tubes

. The arc tube assembly contains the gases that are excited to generate light. The arc tubes in current commercially available HPS lamps are constructed of a ceramic material known as polycrystalline alumina (PCA). Through its own research, DOE found academic papers that indicated potential increases in efficacy were possible by constructing the arc tubes out of a sapphire material, or single crystal aluminum oxide. Sapphire has improved light transmission character istics that could allow for a moderate improvement in efficacy. Several manufacturers produced an HPS lamp with a sapphire arc tube, the first appearing in the late 1970s. Manufacturers have since discontinued production of these lamps. At this time, lamps using sapphire arc tube technology are not available commercially or in a working prototype.

However, DOE determined that the increase in transmission associated with using sapphire material instead of PCA does not necessarily result in an equal increase in efficacy. This is because the material does not transmit all wavelengths uniformly, which affects the perceived brightness of the light. Because these lamps are no longer manufactured, DOE cannot empirically validate the potential increase in efficacy using sapphire arc tubes. Additionally, DOE has received feedback that HPS lamps using sapphire arc tubes are much more susceptible to catastrophic failure and would require enclosed fixtures for safe operation. Currently all HPS lamps that are commerciall y available can be used in open fixtures. An enclosed fixture would reduce the efficacy of the sapphire HPS system (due to absorption in the lens used to enclose the fixture) and likely negate any small increase in efficacy gained from using sapphire arc tubes. For these reasons, DOE determined that the use of sapphire arc tubes would not increase the efficacy of HPS lamps in practice. As such, DOE no longer finds sapphire arc tubes to be a valid technology option for HPS lamps in this NOPD.

3.4.7.3 Metal Halide Lamps

DOE is aware of several technology options that can improve MH lamp efficacy. DOE intends to evaluate the following technology options in this NOPD :

Starting Method. DOE investigated the use of starting method as a technology option, after finding that, at most wattages, the most efficacious quartz MH lamps are pulse -start and not probe- start. However, further analysis revealed that on average there is not a difference in initial efficacy between probe -start and pulse-start lamps. Additionally when investigating all other options for increasing the efficacy of MH lamps, DOE found that all options for altering initial efficacy remain the same when comparing the two starting methods, and there is no technical reason for one lamp having a higher maximum initial efficacy than the other. While the probestart lamps have an additional electrode in their arc tubes, DOE found no evidence that this structural difference impacts initial efficacy. For these reasons, DOE is not considering starting method a technology option for improving the efficacy of MH lamps in this NOPD

.

3- 56Ceramic Arc Tubes. Manufacturers have introduced commercial pulse

- start MH lamps that change the material of the arc tube from quartz to ceramic. These ceramic metal halide lamps have high er efficacy and better color characteristics than quartz pulse

- start MH lamps.

Arc Tube Optimization

. Potential improvement options for the arc tube include changing the size and shape of the arc tube to facilitate an increase in MH vapor pressure, changi ng the thickness of the quartz, optimizing the electrode construction and positioning, improving the purity of the materials , and improving the manufacturing processes to ensure the consistency and quality of the arc tube construction. These are all method s that contribute to arc tube optimization, and have tradeoffs with one another ( e.g. , changing the thickness of the quartz to improve the construction might have a negative impact on potential electrode positioning).

Fill Gas Optimization. Through manufacturer interviews, DOE found that changing the gas fill pressure and altering the fill gas chemistry can change the efficacy of a MH lamp. This type of alteration cannot, however, be used to alter the efficacies of MH lamps beyond commercially available efficacies.

Electrodes. DOE also considered using improved electrode design and materials as a technology option for improving the efficacy of MH lamps. After discussions with manufacturers, DOE found that no technology options were available for improving electrodes beyond the performance levels found in commercially available lamps. For this reason, DOE did not consider electrode design and material to be a technology option for improving the efficacy of MH lamps in this NOPD

.

3.4.7.4 Summary

Table 3.4.2 below summarizes the technology options identified for HID lamps in this

NOPD

.

Table 3.4.2 NOPD HID Lamp Technology Options

Lamp Type NOPD Technology Option Description

MV Change Lamp Type Use MH technology instead of MV technology

MH Ceramic Arc Tubes Use CMH technology instead of quartz MH lamps

Arc Tube Optimization Design the shape of the arc tube so that it facilitates

an increase in MH vapor pressure ; chang e the thickness of quartz ; optimiz e electrode positioning ; improv e the purity of the materials ; and improv e manufacturing processes to ensure the consistency and quality of the arc tube

Fill Gas Optimization Optimize the gas fill pressure and chemistry

3- 573.5 EQUIPMENT CLASSES

In general, when evaluating energy conservation standards, DOE divides covered equipment into classes by: (a) the type of energy used; and (b) capacity of the product or (c) any other performance- related feature that justifies different standard levels, such as features affecting consumer utility. (42 U.S.C. 6295(q)) DOE then conducts its analysis and considers standards for each equipment class.

Discussed below, DOE considered several possible characteristics or features of HID lamps that could warrant separation of covered equipment into different equipment classes, including:

• directionality,

• ballast location,

• CCT

,

• wattage,

• bulb finish,

• luminaire characteristic,

• lamp operating orientation,

• CRI

,

• standby lamps,

• bulb shape, and

• base type.

3.5.1 Directionality

Lamps can be considered either directional or omnidirectional depending on the light pattern they create. Because there is a major distinction between the metrics used to assess the efficacy of dire ctional and omnidirectional lamps, it would be necessary for these two types of lamps to be subject to different standards. However, as noted in section 3.2.2.3 , DO E is not analyzing standards for directional HID lamps. Because DOE is not conducting a full economic analysis to determine whether standards would be economically justified for directional HID lamps, DOE does not analyze directionality as an equipment class

- setting factor.

3.5.2 Ballast Location

Most HID lamps are operated by an external ballast. However, some HID lamps have a ballast integral to the lamp and are said to be “self

- ballasted.” These lamps typically have lower efficacies than externally ballasted lamps. Self

- ballasted HID lamps often compete with incandescent, halogen, and CFLs and cannot be used as direct substitutes for externally ballasted HID lamps. However

, as discussed in section 3.2.2.4 , DOE is not analyz ing standards for self

balla sted HID lamps. Because DOE is not conducting a full economic analysis to determine whether standards would be economically justified for self -ballasted HID lamps, DOE does not analyze ballast location as an equipment class

- setting factor.

3- 583.5.3 CCT

In general terms, CCT represents the color appearance of a light source and is expressed

in kelvins (K). z The higher the CCT, the cooler or more blue the light appears, and the lower the CCT, the warmer or more red the light appears. HID lamps are available with a wide range of CCT values depending on lamp type and design. DOE’s analysis of commercially available lamp catalog data concluded that CCT is correlated with lamp efficacy. DOE tentatively determined that higher CCT lamps were less efficacious than lower CCT lamps of the same wattage.

DOE found identifiable differences in the initial efficacies available for lamps with CCT

values 2800 K – 4500 K and 4501 K – 6999 K. aa For example, a 250 W lamp with a CCT from

2800 K to 4500 K has a maximum initial efficacy of over 100 lm/W, and a 250 W lamp with a

CCT from 4501 K to 6999 K has a maximum initial efficacy of about 80 lm/W.

Because CCT is a n approximation of the color ap pearance of a lamp, customers typically specify different CCTs for different applications. For example, in indoor applications, customers typically seek a higher CCT to provide a whiter light for occupants. Because of these preferences, DOE believes that C CT offers unique consumer utility.

Because CCT affects HID lamp efficacy and impacts consumer utility, DOE determined to establish separate equipment classes based on CCT. These equipment class divisions are presented in Table 3.5.1

.

Table 3.5.1 Equipment Class Divisions Based on CCT

CCT Range

≥ 2800 K and ≤4500 K

> 4500 K and <7000 K

3.5.4 Wattage

HID lamps are available with a variety of light outputs, or lumen outputs, and input powers, or wattages. Light output and input power are highly correlated ( increased input power typically leads to increased light output) . DOE’s initial review of manufacturer lamp catalogs for

the framework document found that HID lamps with increased light output (and therefore increased input power) were generally more efficacious than lamps with lower light outputs (and consequently lower input power). Because customers typically require specific light output from a lamp depending on the intended use for the lamp, in the framework document DOE considered establishing separate equipment classes based on light output.

z The test procedure S NOPR has proposed to adopt the definition for CCT in 10 CFR 430.2, as “the absolute temperature of a blackbody whose chromaticity most nearly resembles that of the light source.” The SNOPR was published by DOE on May 22, 2014 and is currently available for download at: www.eere.energy.gov/buildings/appliance_standards/commercial/high_intensity_discharge_lamps.html

.

aa DOE uses this shorthan d to refer to the CCT value ranges of ≥ 2800 K and ≤ 4500 K and > 4500 K and < 7000 K

, respectively.

3- 59In the interim analysis , h owever, DOE noted that the u se of light output as a class

- setting factor could result in HID lamps of the same wattage being placed in separate equipment classes

and th erefore subject to different standards. DOE received feedback that customers typically choose lamps based on the wat tage, in part because it serves the role of identifying which ballasts can be paired with the lamp. As a result, and for the additional reasons discussed below,

DOE determined in this NOPD to separate equipment classes based on wattage

.

DOE is analyzing o nly HID lamps with rated wattages from 50 W – 1000 W for MV lamps and from 50 W – 2000 W for MH lamps. These restrictions of wattages for the lamps analyzed in this NOPD are based on the commercial availability of these HID lamps.

When examining manufacturer catalog data, all other features remaining constant, DOE observed that HID lamp efficacy generally increases with increasing lamp wattage. This correlation is because there are certain fixed losses within a lamp associated with current passing through the electrodes (known as end losses) and with thermal losses from the arc to the arc tube wall. When the wattage increases, the fixed losses are a smaller portion of the overall losses, thus making the lamp more efficacious.

In addition to affect ing efficacy, DOE believes that lamp wattage impacts consumer utility. Typically, a lamp with a higher wattage will provide more light. Because customers require varying light levels depending on the application and location of the lamp, lamp wattage provi des consumer utility. Further, ballasts are typically designed to operate specific lamp wattages, indicating that a change in lamp wattage often requires a change in ballast. Therefore,

in this NOPD , D OE uses wattage as a potential class

- setting factor rat her than lumen output. However, DOE continues to use lumen output as a factor when selecting higher- efficacy lamp replacements.

Because DOE decided to use equations to relate efficacy and wattage, the efficacy levels ( EL s) analyzed in this NOPD account for the observed trend of increasing efficacy with increasing lamp wattage. The reasoning and methodology for this decision is further explained in chapter 5 of th is NOPD TSD . However, even when using an equation to relate efficacy and wattage, DOE observe d that the same design options were not available at all wattages. For example, CMH lamps were only commercially available at 400 W and below. Because of trends in wattage and efficacy, as well as variation in available design options based on wattage, DOE divided equipment classes based on lamp wattage. DOE created separate equipment class divisions for the following wattage ranges: (1) ≥50 W and ≤400 W; (2) >400 W and ≤1000 W; and (3) >1000 W and ≤2000 W. These three wattage ranges will be written out thr oughout this

document as 50 W – 400 W, 401 W – 1000 W, and 1001 W – 2000 W, respectively. These equipment class divisions are presented in Table 3.5.2

.

3- 60Table 3.5.2 Equipment Class Divisions Based on Wattage

CCT Range Wattage

≥ 2800 K and ≤4500 K ≥ 50 W and ≤400 W

> 400 W and ≤1000 W

> 1000 W and ≤2000 W

> 4500 K and <7000 K ≥ 50 W and ≤400 W

> 400 W and ≤1000 W

> 1000 W and ≤2000 W

3.5.5 Bulb Finish

In reviewing catalogs, DOE observed that HID lamps are offered with several different bulb finishes, such as clear, coated, frosted, white, or deluxe white. Some of these labels apply to only certain types of HID lamps. For example, in addition to being cl assified as coated, DOE

found that some MH lamps were labeled as frosted lamps and some MV lamps were labeled as white or deluxe lamps. DOE tentatively determined that the difference between these terms was generally due to differences in marketing techniques. However, across all manufacturers, DOE

notes that most coated lamps have phosphor coatings applied to the inner wall of the outer bulb, whereas clear lamps do not have this coating. Therefore, for this NOPD , DOE defines “ coated lamps ” as all lamps that are not clear because the terms coated, frosted, white, or deluxe white typically represent the same or nearly the same bulb finish within a lamp type.

The coating on a lamp blocks a portion of the light produced by the arc tube from leaving the lamp. Thus, coated lamps should have lower efficacies than their clear counterparts. By comparing pairs of coated and clear lamps, all other lamp characteristics and features remaining the same or similar, DOE found that the presence of a coating on MH lamps redu ced overall lamp efficacy. However, for MV lamps, DOE tentatively determined that coated lamps were more efficacious than their clear counterparts. Based on manufacturer feedback during interviews, DOE found that this relationship exists because MV lamps g enerate a large amount of UV light and the phosphor coating on MV lamps converts the UV light into visible light, thereby increasing the efficacy of the lamp.

DOE believes that a coated lamp offers unique consumer utility for each HID lamp type.

For MH lamps, a coating is often applied to reduce the glare perceived by the customer. For MV lamps, a coating often impacts the CCT and efficacy of the lamp. As discussed above, DOE believes that CCT offers unique consumer utility.

Given the impact on efficacy and consumer utility, DOE analyzed separate equipment classes for clear and coated MH lamps in their respective wattage and CCT ranges. For MV lamps, DOE tentatively determined that an equipment class division was not necessary because the CCT equipment c lass divisions already separate coated MV lamps from clear MV lamps.

DOE found that all clear MV lamps analyzed in this NOPD have a CCT 4501 K – 6999 K, while all coated MV lamps analyzed are 2800 K – 4500 K. Because clear MH lamps are the most likely repl acements for coated MV lamps in the applicable CCT ranges, DOE determined that

3- 61MV lamps should be categorized in the clear bulb finish equipment classes (regardless of the bulb finish of the MV lamp itself). These equipment class divisions are presented in Table 3.5.3

.

Table 3.5.3 Equipment Class Divisions Based on Bulb Finish

CCT Range Wattage Bulb Finish*

≥ 2800 K and ≤4500 K ≥ 50 W and ≤400 W Clear

Coated

> 400 W and ≤1000 W Clear

Coated

> 1000 W and ≤2000 W Clear

Coated

> 4500 K and <7000 K ≥ 50 W and ≤400 W Clear

Coated

> 400 W and ≤1000 W Clear

Coated

> 1000 W and ≤2000 W Clear

Coated

* MV lamps, regardless of bulb finish, are placed in the clear equipment class for their respective CCT and wattage.

3.5.6 Luminaire Characteristic

MH lamps are frequently listed with a luminaire characteristic, typically open

- rated or

enclosed -rated, to indicate in which type of fixture the lamps should be used. An open fixture does not have a physical barrier that separates the lamp from the space t hat is to be illuminated. Open- rated lamps have a glass shroud that surrounds the arc tube to protect the environment and any occupants around the lamp in the event of arc tube rupture. bb An enclosed fixture has a physical barrier that separates the lamp from the space that is to be illuminated. Enclosed- rated lamps do not have the glass shroud surrounding the arc tube and must be used in enclosed fixtures to satisfy safety requirements. cc DOE also found commercially available lamps that were

labeled as S

- rat ed. dd S-rated lamps do not have a glass shroud around the arc tube, but can be used in open-rated fixtures under certain defined conditions. Because S-rated lamps do not feature a shroud, DOE tentatively determined their efficacy potential would be comparab le to

traditional enclosed

- rated lamps

.

bb D OE proposes to adopt the ANSI C7 8. 380

- 2007 definition of open

- rated: “Lamp may be used in an open luminaire. The effective antic UV output of the lamp shall not exceed 2 mW/klm for a non

- reflector lamp or 2 mW/(m 2 ∙klx) for a reflector lamp. Metal halide Type O lamps must meet specified containment test requirements.”

cc D OE proposes to adopt the ANSI C7 8. 380

- 2007 definition of enclosed

- rated: “Lamp may be used in an enclosed luminaire that meets industry standards for containment in the event of lamp rupture. The effective antic UV output of the lamp shall not exceed 2 mW/klm for a non

- reflector lamp or 2 mW/(m 2 ∙klx) for a reflector lamp.”

dd ANSI C7 8. 380

- 2007 d efines S

- rated lamps as: “Lamp may be used in an open luminaire if position restrictions are followed. Otherwise, the lamp requires an enclosed luminaire that meets industry standards for containment in the event of lamp rupture. Specific containment test requirements do not apply to this type of lamp. The effective a c tinic UV output of the lamp shall not exceed 2 mW/klm for a non

- reflector lamp or 2 mW/(m 2 ∙klx) for a reflector lamp. This letter is not to be used for luminaire designation on lamps other than metal halide. ”

3- 62DOE notes that luminaire characteristic applies only to MH lamps. This is because MH lamps typically operate at temperatures and pressures significantly higher than that of other HID lamps. By comparing pairs of open- rated and enclosed

- rated MH lamps in which all other lamp

characteristics and features are the same or similar, DOE tentatively determined that enclosed

rated MH lamps are more efficacious than their open

- rated counterparts. DOE attributes the efficacy g ain to the removal of the shroud that covers the entire arc tube and blocks a portion of light from leaving the lamp. Because the shroud is a safety feature that is required for open fixtures, DOE believes open-rated lamps offer unique consumer utility.

Given the impact on both consumer utility and lamp efficacy, DOE analyzed separate equipment classes for enclosed

- rated versus open

- rated lamps in this NOPD . For analysis

purposes , DOE placed MV lamps in the same equipment class as enclosed

- rated MH lamps because they do not have a protective glass covering. MV lamps are analyzed compared to the same energy conservation standards as enclosed

- rated lamps, even though DOE recognizes that these lamps could be used in open fixtures in practice. These equipment class divisions are presented in Table 3.5.4

.

3- 63Table 3.5.4 Equipment Class Divisions Based on Luminaire Characteristic

CCT Range Wattage Bulb

Finish* Luminaire

Characteristic**

≥ 2800 K and ≤4500 K ≥ 50 W and ≤400 W Clear Enclosed

Open

Coated Enclosed

Open

> 400 W and ≤1000 W Clear Enclosed

Open

Coated Enclosed

Open

> 1000 W and ≤2000 W Clear Enclosed

Open

Coated Enclosed

Open

> 4500 K and <7000 K ≥ 50 W and ≤400 W Clear Enclosed

Open

Coated Enclosed

Open

> 400 W and ≤1000 W Clear Enclosed

Open

Coated Enclosed

Open

> 1000 W and ≤2000 W Clear Enclosed

Open

Coated Enclosed

Open

* MV lamps regardless of bulb finish are placed in the clear equipment classes for their respective CCT and wattage.
** MV lamps are placed in the enclosed equipment classes for their respective wattage and

CCT.

3.5.7 Lamp Operating Orientation

Catalogs indicate whether an HID lamp is designed to operate at either a specific orientation or at several orientations. In DOE’s review of commercially available catalog data, DOE identified several operating orientations, including the universal, horizontal, and vertical orientations, as well as the degrees of operating tolerance associated with those orientations.

DOE believes that there are distinct differences in consumer utility for operating orientations because applications s erved by certain luminaires can frequently only operate a lamp in a specific orientation. For example, street and area luminaires typically position the lamp in a

3- 64horizontal orientation, while indoor high bay luminaires typically use a vertical (base

- up) orientation. Some lamps are designed specific to the horizontal or vertical operating orientations, but some lamps are designed to operate in any orientation. These lamps have the advantage of inventory reduction (because one lamp can serve all orientations), the utility of being able to aim the lamp in any direction, and ease of installation (lamps cannot be installed in the wrong orientation, which would result in reduced performance).

Manufacturers frequently provide performance data for a universal lamp operated in both the vertical and horizontal orientations. In theory, because universal lamps cannot be optimized specifically to the vertical or horizontal orientation, they would have a reduced maximum efficacy relative to a position specific lamp. However, DOE analyzed the efficacy of universal lamps operated in the vertical orientation compared with vertical -only lamps and horizontal-only lamps and did not find conclusive indication of whether universal lamps were more or less

efficacious than vertical or horizontal lamps. In addition, DOE found no conclusive evidence of a difference in efficacy between vertical

- only and horizontal -only lamps.

Without conclusive evidence of lamp operating orientation impacting efficacy, DOE does

not analyze operating o rientation as a class

- setting factor in this NOPD. However, DOE recognizes that the operating orientation is important when determining higher- efficacy lamp replacements. Higher

- efficacy replacements , along with how DOE accounts for operating

orientation i n the engineering analysis, are discussed in chapter 5 of th is NOPD TSD.

3.5.8 CRI

CRI is the measured degree of color shift objects undergo when illuminated by a light source as compared with the color of those same objects when illuminated by a reference source of comparable CCT . CRI ranges from zero for monochromatic light sources to 100 for a light source that closely mimics the color rendering properties of the reference source. HID lamps are available and demanded over a range of CRIs depending on the type, application, and environment in which the lamp is intended to operate.

DOE considered CRI as a potential class -setting factor due to the unique consumer utility that high -CRI lamps may provide customers. Researching the HID lamp market, DOE found a

relat ionship between CRI and lamp efficacy (increased CRI corresponded to decreased efficacy) for high-CRI MH lamps. This trend was strongest for quartz MH lamps, for which lamps with CRI greater than 80 may not meet the same standard levels as quartz MH lamps with CRI less than 80. However, DOE identified CMH lamps as an available technology that provides highCRI without compromising efficacy and could serve as a more efficacious substitute for highCRI quartz lamps that potentially would not meet standards. CMH lamp substitutes were found to be available at most wattages, and the absence of CMH lamps at certain wattages for which there were quartz offerings likely reflects current customer demand rather than any inherent limitations of CMH technology. DOE notes, however, that CMH lamps with CRI greater than 95 often exhibit lower efficacy than other CMH lamps. However, as discussed in section 3.2.2.6

, DOE is not analyzing standards for lamps with a CRI greater than or equal to 95 in this NOPD

.

3- 65Though certain CRI s do impart unique consumer utility, DOE found that CRI generally does not impact efficacy within the equipment classes under consideration. Therefore, DOE did not analyze CRI as a class

- setting factor.

3.5.9 Standby Lamps

Standby, or double arc, lamps offer unique consumer utility. Standby lamps have longer lifetimes, and they provide a higher degree of safety in buildings because if one of the arc tube fails then the other arc tube remains lit. However after analyzing the average efficacy of standby lamps compared to traditional, single arc tube lamps, DOE did not find any conclusive trends to suggest that standby lamps are any more or less efficacious than single arc tube lamps. Because the addition of a second arc tube in standby lamps does not affect efficacy, DOE does not analyze standby lamps in a separate equipment class from single arc tube lamps in this NOPD

.

3.5.10 Bulb Shape

The bulb shape reflect s the overall size and shape of a lamp. Bulb shapes are indicated by combinations of letters while lamp diameters are indicated by numeric values, in eighths of an inch. For example, a BT37 lamp is a blown tubular lamp with a diameter of 37 eighths of an inch, or 4.625 inches. Common HID lamp shapes are BD (blown dimpled), BT (blown tubular), ED (elliptical dimpled), ET (elliptical tubular), and T (tubular). The bulb is meant to contain and protect the main light -producing portion of the lamp ( i.e., the arc tube and electrodes).

By comparing pairs of lamps in which bulb shape was the only characteristic that differed, DOE did not find any direct impact on efficacy associated with a change in bulb shape ( e.g., from ED17 to BT17), bulb size ( e.g., from ED17 to ED28), or the combination of the two. For that reason, DOE does not analyze bulb shape as a class

- setting factor in this NOPD

.

Although DOE is not separating equipment classes based on bulb shape, DOE recognizes that the bulb shape (or any other physical dimensions) could be a factor when determining higher- efficacy lamp replacements. Higher

- efficacy replacements are discussed in chapter 5 of

this NOPD TSD.

3.5.11 Base Type

HID lamps have different base types depending on the fixture and socket with which the lamp are designed to operate. The most common base type is a screw base, which includes both medium screw bases (E26) and mogul screw bases (E39 for enclosed fixtures, EX39 for open fixtures, and EP39 for orientation- specific lamps). Mogul screw bases are typically used at higher wattages, whereas medium screw bases are typically used at lower wattages.

By comparing pairs of lamps in which base type was the only characteristic that differed, DOE’s analysis indicated that base type does not impact the effic acy of HID lamps. Therefore,

DOE does not analyze base type as a class

- setting factor in this NOPD

.

3- 66Similar to bulb shape, DOE recognizes that base type could be a factor in selecting higher- efficacy lamp replacements and considers base type in the engineering analysis, discussed in chapter 5 of th is NOPD TSD.

3.5.12 Equipment Class Summary

The equipment class divisions are presented in Table 3.5.5

.

Table 3.5.5 HID Lamps NOPD Equipment Classes

CCT Range Wattage Bulb

Finish* Luminaire

Characteristic**

> 2800 K and ≤4500 K ≥ 50 W and ≤400 W Clear Enclosed

Open

Coated Enclosed

Open

> 400 W and ≤1000 W Clear Enclosed

Open

Coated Enclosed

Open

> 1000 W and ≤2000 W Clear Enclosed

Open

Coated Enclosed

Open

> 4500 K and <7000 K ≥ 50 W and ≤400 W Clear Enclosed

Open

Coated Enclosed

Open

> 400 W and ≤1000 W Clear Enclosed

Open

Coated Enclosed

Open

> 1000 W and ≤2000 W Clear Enclosed

Open

Coated Enclosed

Open

* MV lamps regardless of bulb finish are placed in the clear equipment classes for their respective CCT and wattage.
** MV lamps are placed in the enclosed equipment classes for their respective wattage and

CCT.

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< http://www.oppd.com/prodconsump10g/groups/web/documents/webcontent/22_007476.pdf>

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3- 71CHAPTER 4. SCREENING ANALYSIS

TABLE OF CONTENTS

4.1 INTRODUCTION

............................................................................................................ 4-1

4.2 DISCUSSION OF TECHNOLOGY OPTIONS

............................................................... 4-2

4.3 DESIGN OPTIONS NOT SCREENED OUT OF THE ANALYSIS

.............................. 4-2

4.3.1 Change Lamp Type ............................................................................................ 4-2

4.3.2 Ceramic Arc Tubes

............................................................................................. 4-2

4.3.3 Arc Tube Optimization

....................................................................................... 4-3

4.3.4 Fill Gas Optimization

......................................................................................... 4-3

4.3.5 Summary of Design Options Not Screened Out ................................................ 4-3

4.4 DESIGN OPTIONS SCREENED OUT OF THE ANALY SIS

....................................... 4-4

4.4.1 Ceramic Arc Tubes

............................................................................................. 4-4

4.4.2 Summary of Design Options Screened Out of the Analysis .............................. 4-5

LIST OF TABLES

Table 4.2.1 HID Lamp Technology Options ............................................................................... 4-2 Table 4.3.1 Design Options Not Screened Out of the Analysis ................................................... 4-4 Table 4.4.1 Design Options Screened Out of the Analysis .......................................................... 4-5

4-iCHAPTER 4. SCREENING ANALYSIS

4.1 INTRODUCTION

This chapter discusses the U.S. Department of Energy’s (DOE’s) screening analysis of the technology options identified for high- intensity discharge (HID) lamps. As discussed in chapter 3 of the notice of proposed determination (NOPD) technical support docu ment (TSD), DOE consults with industry, technical experts, and other interested parties to develop a list of technology options for consideration. The purpose of the screening analysis is to determine which options to consider further and which to screen o ut.

Section 325(o)(2) of the Energy Policy and Conservation Act (EPCA) provides that any new or revised standard must be designed to achieve the maximum improvement in energy efficiency that is determined to be technologically feasible and economically ju stified. (42 U.S.C. 6295(o)(2)) In view of the EPCA requirements appendix A to subpart C of title 10, Code of Federal Regulations (CFR), part 430 (10 CFR part 430), Procedures, Interpretations, and Policies or Consideration of New or Revised Energy Conserv ation Standards for Consumer

Products (the Process Rule) sets forth procedures to guide DOE in its consideration and promulgation of new or revised energy conservation standards. These procedures elaborate on the statutory criteria provided in 42 U.S.C. 6296(o) and, in part, eliminate problematic technologies early in the process of prescribing or amending an energy conservation standard. In particular, sections 4(b)(4) and 5(b) of the Process Rule provide guidance to DOE for determining which design options are unsuitable for further consideration:

1. Technological feasibility. DOE will consider technologies incorporated in commercial products or in working prototypes to be technologically feasible.

2. Practicability to manufacture, install, and service. If mass production and reliable installation and servicing of a technology in commercial products could be achieved on the scale necessary to serve the relevant market at the time the standard comes into effect, then DOE will consider that technology practicable to manufacture, install, and service.

3. Adverse impacts on product utility or product availability. If DOE determines a technology would have significant adverse impact on the utility of the product to significant subgroups of consumers, or would result in the unavailability of any covered product type with performance characteristics (including reliability), features, sizes, capacities, and volumes that are substantially the same as products generally available in the United States at the time, it will not co nsider this technology further.

4. Adverse impacts on health or safety. If DOE determines that a technology will have significant adverse impacts on health or safety, it will not consider this technology further.

4-14.2 DISCUSSION OF TECHNOLOGY OPTIONS

Several well

- established engineering practices and techniques exist for improving the efficacy of an HID lamp. Switching from a less efficacious HID technology to a more efficacious HID technology, such as replacing mercury vapor (MV) technology with metal halide (MH) technology , allows customers to realize energy savings while retaining their desired light

outputs. Additionally, q uartz MH technology can be replaced with ceramic metal halide (CMH) technology , which is able to withstand greater temperatures and pressures, and thus result in higher efficacy. There are also methods for optimizing the arc tube or the fill gas of MH lamps that result in increased efficacy. Table 4.2.1 presents a general summary of the options a manufacturer may use to improve efficacy in HID lamps.

Table 4.2.1 HID Lamp Technology Options

Lamp Type NOP D Design Option Description

MV Change Lamp Type Use MH technology instead of MV technology

MH Ceramic Arc Tubes Use CMH technology instead of quartz MH lamps

Arc Tube Optimization Design the shape of the arc tube so that it facilitates an increase in MH vapor pressure; change the thickness of

quartz ; optimize electrode positioning ; improve the purity

of the materials ; and improve the manufacturing processes to ensure the consistency and quality of the arc tube

construction

Fill Gas Optimi zation Optimize the gas fill pressure and chemistry

4.3 DESIGN OPTIONS NOT SCREENED OUT OF THE ANALYSIS

This section discusses the technology options that DOE considers viable means of improving the efficacy of HID lamps.

4.3.1 Change Lamp Type

MV ballasts, other than specialty application MV ballasts, have been banned from import or production in the United States since January 1, 2008. (42 U.S.C. 6295 (ee)) This ban effectively limits the installation of new MV fixtures and ballasts, meaning the only MV lamps

cur rently being sold are replacement lamps. DOE understands that there is limited industry design emphasis on MV lamps, that there are limited methods to improving the efficacy of MV lamps, and that the common pathway for improving efficacy is a change of tec hnology to MH or HPS lamps.

4.3.2 Ceramic Arc Tubes

Manufacturers have introduced commercial pulse

- start CMH lamps up to 400 W with higher efficacy and better color characteristics than quartz pulse

- start MH lamps. Ceramic arc tubes are able to operate with high er temperatures and pressures in the arc tube, which allows

4-2them to have increased efficacy. Because CMH lamps are not commercially available above 400
W, a DOE only screened in ceramic arc tubes for 50 W

– 400 W lamps

. Ceramic arc tubes for 401

W – 1000 W are discussed in section 4.4.1

.

4.3.3 Arc Tube Optimization

Potential improvement options for the arc tube include changing the size and shape of the arc tube to facilitate an increase in MH vapor pressure, changing the thickness of the quartz, optimizing the electrode construction and positioning, improving the purity of the materials, and improving the manufacturing processes to ensure the consistency and quality of the arc tube construction. These are all methods that contribute to arc tube optimization, and have tradeoffs with one another ( e.g. , changing the thickness of the quartz to improve the construction might have a negative impact on potential electrode positioning).

4.3.4 Fill Gas Optimization

Through manufacturer interviews, DOE found that changing the gas fill pressure and altering the fill gas chemistry can change the efficacy of a MH lamp. This type of alteration cannot, howeve r, be used to alter the efficacies of MH lamps beyond commercially available

efficacies.

4.3.5 Summary of Design Options Not Screened Out

Table 4.3.1 summari zes the design options that DOE did not screen out of the analysis.

a There is one example of a CMH lamp in this wattage range. It is an 860 W CMH lamp that is designed to be used on a 1000 W ballast and can operate on both probe

- start and pulse

- start ballasts. Because of its unusual nature, and moreover because it employs proprietary technology, DOE does not us e this lamp as an example of CMH lamps being commercially available from 401 W

– 1000 W.

4-3Table 4.3.1 Design Options Not Screened Out of the Analysis

Lamp Type NOP D Design Option Description

MV Change Lamp Type Use MH technology instead of MV technology

MH Ceramic Arc Tubes
(50 W

– 400 W) Use CMH technology instead of quartz MH lamps

Arc Tube Optimization Design the shape of the arc tube so that it facilitates an increase in MH vapor pressure; change the thickness of quartz ; optimize electrode positioning ; improve the purity of the materials ; and improve the manufacturing processes to ensure the consistency and quality of the arc tube construction

Fill Gas Optimization Optimize the gas fill pressure and chemistry

4.4 DESIGN OPTIONS SCREENED OUT OF THE ANALYSIS

This section addresses the technologies that DOE screened out, having considered the following four factors: (1) technological feasibility; (2) practicability to manufacture, install, and service; (3) adverse impacts on product utility to consumers; and (4) adverse impacts on health or safety.

4.4.1 Ceramic Arc Tubes

DOE analyzed the possibility of using ceramic arc tubes for MH lamps from 50 W – 2000

W to determine their ability to meet the screening criteria. While CMH lamps are commercially available from 50 W – 400 W and thus were not screened out of the analysis, DOE was not able to find ceramic arc tubes in commercially available MH lamps from 401 W – 2 000 W. a Through manufacturer interviews, DOE determined that the reason they are not found commercially available is because of the manufacturing difficulties present when made in large quantities.

Whi le ceramic arc tubes for lamps above 400 W are technologically possible to create on an individual scale in laboratory conditions, these manufacturing difficulties would result in a very costly lamp, which may not be able to be produced at a large enough s cale to serve the entire

market. DOE determined that ceramic arc tubes for 401 W – 2000 W lamps do not pass the practicable to manufacture, install, and service criterion of the screening analysis. In this NOPD

, DOE does not consider ceramic arc tubes a de sign option for 401 W – 2000 W.

4-44.4.2 Summary of Design Options Screened Out of the Analysis

Table 4.4.1 shows the criteria DOE used to screen sapphire arc tubes for HPS lamps and ceramic arc tubes for MH lamps from 401 W – 2 000 W out of the analysis.

Table 4.4.1 Design Options Screened Out of the Analysis

Lamp Type Design Option Screening Criteria

MH Ceramic Arc Tubes
(401 W – 2 000 W) Practicability to manufacture, install, and service

4-5CHAPTER 5. ENGINEERING ANALYSIS

TABLE OF CONTENTS

5.1 INTRODUCTION

........................................................................................................... 5-1

5.2 METHODOLOGY OVERVIEW

.................................................................................... 5-1

5.3 REPRESENTATIVE EQUIPMENT CLASSES

............................................................. 5-2

5.3.1 Baseline Lamps and Representative Lamp Types

............................................... 5-4

5.4 HIGHER

- EFFICACY REPLACEMENT S ..................................................................... 5-6

5.5 EFFICACY LEVELS

...................................................................................................... 5-8

5.5.1 General Methodology .......................................................................................... 5-8

5.5.2 Efficacy Levels

.................................................................................................... 5-8 5.5.2.1 Efficacy Levels for 2800 K – 4500 K, 50 W – 400 W Representative Equipment Class

.................................................................................................. 5-9 5.5.2.2 Efficacy Levels for 2800 K – 4500 K, 401 W – 1000 W Represen tative Equipment Class

................................................................................................ 5-10 5.5.2.3 Efficacy Levels for 2800 K – 4500 K, 1001 W – 2000 W Representative Equipment Class

................................................................................................ 5-11 5.5.2.4 Efficacy Levels Summary ...................................................................... 5-12

5.6 HID SYSTEMS

............................................................................................................. 5-13

5.6.1 Replacement Options ......................................................................................... 5-13

5.6.2 Ballasts

............................................................................................................... 5-15

5.6.3 Lamp -and- Ballast Retrofit Kits

.......................................................................... 5-18

5.6.4 Fixtures

.............................................................................................................. 5-18

5.6.5 Replacement L amps

........................................................................................... 5-19

5.7 DETAILED DISCUSSION OF REPRESENTATIVE LA MP TYPES

........................ 5-20

5.7.1 100 W Mercury Vapor Representative Lamp Type

........................................... 5-20

5.7.1.1 Baseline Models ..................................................................................... 5-20

5.7. 1.2 Efficacy Levels and More Efficacious Substitutes

................................ 5-21 5.7.1.3 Engineering Summary ........................................................................... 5-24

5.7.2 175 W Mercury Vapor Representative Lamp Type

........................................... 5-26

5.7.2.1 Baseline Models ..................................................................................... 5-26 5.7.2.2 Efficacy Levels and More Efficacious Substitutes ................................ 5-26 5.7.2.3 Engineering Summary ........................................................................... 5-29

5.7.3 250 W Mercury Vapor Representative Lamp Type

........................................... 5-31

5.7.3.1 Baselin e Models

..................................................................................... 5-31 5.7.3.2 Efficacy Levels and More Efficacious Substitutes ................................ 5-31 5.7.3.3 Engineering Summary ........................................................................... 5-34

5.7.4 400 W Mercury Vapor Representative Lamp Type

........................................... 5-36

5.7.4.1 Baseline Models ..................................................................................... 5-36 5.7.4.2 Efficacy Levels and More Efficacious Substitutes ................................ 5-36 5.7.4.3 Engineering Summary ........................................................................... 5-40

5.7.5 400 W Metal Halide Representative Lamp Type

.............................................. 5-42

5.7.5.1 Baseline Models ..................................................................................... 5-42 5.7.5.2 Efficacy Levels and More Efficacious Substitutes ................................ 5-42

5-i5.7.5.3 Engineering Summary ........................................................................... 5-45

5.7.6 1000 W Mercury Vapor Representative Lamp Type ......................................... 5-47

5.7.6.1 Baseline Models ..................................................................................... 5-47 5.7.6.2 Efficacy Levels and More Efficacious Substitutes ................................ 5-47 5.7.6.3 Engineering Summary ........................................................................... 5-50

5.7.7 1000 W Metal Halide Representative Lamp Type

............................................ 5-52

5.7.7.1 Baseline Models ..................................................................................... 5-52 5.7.7.2 Efficacy Levels and More Efficacious Substitutes ................................ 5-52 5.7.7.3 Engineering Summary ........................................................................... 5-55

5.7.8 2000 W Metal Halide Representative Lamp Type

............................................ 5-57

5.7.8.1 Baseline Models ..................................................................................... 5-57 5.7.8.2 Efficacy Levels and More Efficacious Substitutes ................................ 5-57 5.7.8.3 Engineering Summary ........................................................................... 5-60

5.7.9 Summary of Representative Lamp Type Efficacy Levels

................................. 5-62

5.8 SCALING TO EQUIPMENT CLASSES NOT ANALYZED

...................................... 5-64

5.8.1 Bulb Finish ......................................................................................................... 5-65

5.8.2 Luminaire Characteristic

.................................................................................... 5-65

5.8.3 CCT Range

......................................................................................................... 5-66

5.8.4 Scaling Summary ............................................................................................... 5-66

5.9 EFFICACY LEVEL SUMMA RY

................................................................................. 5-66

LIST OF TABLES

Table 5.3.1 Representative and Scaled Equipment Classes for HID Lamps ............................... 5-4 Table 5.3.2 Baseline Lamps ......................................................................................................... 5-6 Table 5.5.1 Efficacy Levels for 2800 K – 4500 K, 50 W – 400 W Representative Equipment

Class ............................................................................................................................................. 5-9 Table 5.5.2 Efficacy Levels for 2800 K – 4500 K, 401 W – 1000 W Representative Equipment

Class ........................................................................................................................................... 5-11 Table 5.5.3 Efficacy Level for 2800 K – 4500 K, 1001 W – 2000 W Representative Equipment

Class ........................................................................................................................................... 5-12 Table 5.5.4 Representative Equipment Class Efficacy Levels .................................................. 5-13 Table 5.6.1 Representative Ballast Types .................................................................................. 5-16 Table 5.6.2 Magnetic Ballast Efficiencies ................................................................................. 5-17

Table 5.6.3 Electronic Ballast Efficiencies ................................................................................ 5-17 Table 5.6.4 Retrofit Lamps ........................................................................................................ 5-19 Table 5.7.1 Baseline Lamps for the 100 W MV Representative Lamp Type ............................ 5-21 Table 5.7.2 Summary of the ELs for the 100 W MV Representative Lamp Type .................... 5-21 Table 5.7.3 Lamp Designs for the 100 W MV Representative Lamp Type - Reduced Wattage .. 5-

22 Table 5.7.4 Lamp Designs for the 100 W MV Representative Lamp Type - Equal Wattage ... 5-23 Table 5.7.5 Engineering Summary for 100 W MV Representative Lamp Type - Reduced Wattage ...................................................................................................................................... 5-24 Table 5.7.6 Engineering Summary for 100 W MV Representative Lamp Type - Equal Wattage 5-

25 Table 5.7.7 Baseline Lamps for the 175 W MV Representative Lamp Type ............................ 5-26

5- iiTable 5.7.8 Summary of the ELs for the 175 W MV Representative Lamp Type .................... 5-27 Table 5.7.9 Lamp Designs for the 175 W MV Representative Lamp Type - Reduced Wattage .. 5-

28 Table 5.7.10 Lamp Designs for the 175 W MV Representative Lamp Type - Equal Wattage . 5-28 Table 5.7.11 Engineering Summary for 175 W MV Representative Lamp Type - Reduced Wattage ...................................................................................................................................... 5-29

Tabl e 5.7.12 Engineering Summary for 175 W MV Representative Lamp Type - Equal Wattage

................................................................................................ .................................................... 5-30 Table 5.7.13 Baseline Lamps for the 250 W MV Representative Lamp Type .......................... 5-31 Table 5.7.14 Summary of the ELs for the 250 W MV Representative Lamp Type .................. 5-32 Table 5.7.15 Lamp Designs for the 250 W MV Representative Lamp Type - Reduced Wattage 5-

33 Table 5.7.16 Lamp Designs for the 250 W MV Representative Lamp Type - Equal Wattage . 5-33 Table 5.7.17 Engineering Summary for 250 W MV Representative Lamp Type - Reduced Wattage ...................................................................................................................................... 5-34 Table 5.7.18 Engineering Summary for 250 W MV Representative Lamp Type - Equal Wattage

................................................................................................ .................................................... 5-35 Table 5.7.19 Baseline Lamps for the 400 W MV Representative Lamp Type .......................... 5-36 Table 5.7.20 Summary of the ELs for the 400 W MV Representative Lamp Type .................. 5-37 Table 5.7.21 Lamp Designs for the 400 W MV Representative Lamp Type - Reduced Wattage 5-

38 Table 5.7.22 Lamp Designs for the 400 W MV Representative Lamp Type - Equal Wattage . 5-39 Table 5.7.23 Lamp Designs for the 400 W MV Representative Lamp Type - Retrofit Lamps 5-40 Table 5.7.24 Engineering Summary for 400 W MV Representative Lamp Type - Reduced Wattage ...................................................................................................................................... 5-40 Table 5.7.25 Engineering Summary for 400 W MV Representative Lamp Type - Equal Wattage

................................................................................................ .................................................... 5-41 Table 5.7.26 Engineering Summary for 400 W MV Representative Lamp Type - Retrofi t Lamps

................................................................................................ .................................................... 5-41 Table 5.7.27 Baseline Lamps for the 400 W MH Representative Lamp Type .......................... 5-42 Table 5.7.28 Summary of the ELs for the 400 W MH Representative Lamp Type .................. 5-43 Table 5.7.29 Lamp Designs for the 400 W MH Representative Lamp Type - Reduced Wattage 5-

44 Table 5.7.30 Lamp Designs for the 400 W MH Representative Lamp Type - Equal Wattage . 5-44 Table 5.7.31 Lamp Designs for the 400 W MH Representative Lamp Type

- Retrofit Lamps 5-45 Table 5.7.32 Engineering Summary for 400 W MH Representative Lamp Type - Reduced Wattage ...................................................................................................................................... 5-45 Table 5.7.33 Engineering Summary for 400 W MH Representative Lamp Type - Equal Wattage

................................................................................................ .................................................... 5-46 Table 5.7.34 Engineering Summary for 400 W MH Representative Lamp Type - Retrofit Lamps

................................................................................................ .................................................... 5-46 Table 5.7.35 Baseline Lamps for the 1000 W MV Representative Lamp Type ........................ 5-47 Table 5.7.36 Summary of the ELs for the 1000 W MV Representative Lamp Type ................ 5-48 Table 5.7.37 Lamp Designs for the 1000 W MV Representative Lamp Type - Reduced Wattage

................................................................................................ .................................................... 5-49 Table 5.7.38 Lamp Designs for the 1000 W MV Representative Lamp Type - Equal Wattage 5-49

5- iiiTable 5.7.39 Engineering Summary for 1000 W MV Representative Lamp Type - Reduced Wattage ...................................................................................................................................... 5-50 Table 5.7.40 Engineering Summary for 1000 W MV Representative Lamp Type - Equal Wattage

................................................................................................ .................................................... 5-51 Table 5.7.41 Baseline Lamps for the 1000 W MH Representative Lamp Type ........................ 5-52 Table 5.7.42 Summary of the ELs for the 1000 W MH Representative Lamp Type ................ 5-53 Table 5.7.43 Lamp Designs for the 1000 W MH Representative Lamp Type - Reduced Wattage

................................................................................................ .................................................... 5-54 Table 5.7.44 Lamp Designs for the 1000 W MH Representative Lamp Type - Equal Wattage 5-54 Table 5.7.45 Engineering Summary for 1000 W MH Representative Lamp Type - Reduced Wattage ...................................................................................................................................... 5-55 Table 5.7.46 Engineering Summary for 1000 W MH Representative Lamp Type - Equal Wattage

................................................................................................ .................................................... 5-56 Table 5.7.47 Baseline Lamp for the 2000 W MH Representative Lamp Type ......................... 5-57 Table 5.7.48 Summary of the EL for the 1000 W MV Representative Lamp Type .................. 5-58 Table 5.7.49 Lamp Designs for the 2000 W MH Representative Lamp Type - Reduced Wattage

................................................................................................ .................................................... 5-59 Table 5.7.50 Lamp Designs for the 2000 W MH Representative Lamp Type - Equal Wattage 5-59 Table 5.7.51 Engineering Summary for 2000 W MH Representative Lamp Type - Reduced Wattage ...................................................................................................................................... 5-60 Table 5.7.52 Engineering Summary for 2000 W MH Representative Lamp Type - Equal Wattage

................................................................................................ .................................................... 5-61 Table 5.8.1 Scaling Factors ........................................................................................................ 5-66 Table 5.9.1 Efficacy Level Equations ........................................................................................ 5-67

LIST OF FIGURES

Figure 5.5.1 Efficacy Levels for 2800 K – 4500 K CCT, 50 W – 400 W Representative Equipment Class ........................................................................................................................ 5-10 Figure 5.5.2 Efficacy Levels for 2800 K – 4500 K, 401 W – 1000 W Representative Equipment

Class ........................................................................................................................................... 5-11 Figure 5.5.3 Efficacy Level for 2800 K – 4500 K CCT, 1001 W – 2000 W Representative Equipment Class ........................................................................................................................ 5-12 Figure 5.5.4 Efficacy Levels for Representative Equipment Classes ........................................ 5-13 Figure 5.7.1 Efficacy Levels for the 100 W MV Re presentative Lamp Type ........................... 5-22 Figure 5.7.2 Efficacy Levels for the 175 W MV Representative Lamp Type ........................... 5-27 Figure 5.7.3 Efficacy Levels for the 250 W MV Representative Lamp Type ........................... 5-32 Figure 5.7.4 Efficacy Levels for the 400 W MV Representative Lamp Type ........................... 5-37 Figure 5.7.5 Efficacy Levels for the 400 W MH Representative Lamp Type ........................... 5-43 Figure 5.7.6 Efficacy Levels for the 1000 W MV Representative Lamp Type ......................... 5-48 Figure 5.7.7 Efficacy Levels for the 1000 W MH Representative Lamp Type ......................... 5-53 Figure 5.7.8 Efficacy Level for the 2000 W MH Representative Lamp Type .......................... 5-58 Figure 5.7.9 2800 K – 4500 K, 50 W – 400 W Representative Equipment Class ..................... 5-62 Figure 5.7.10 2800 K – 4500 K, 401 W – 1000 W Representative Equipment Class ............... 5-63 Figure 5.7.11 2800 K – 4500 K , 1001 W – 2000 W Representative Equipment Class ............ 5-64

5- ivCHAPTER 5. ENGINEERING ANALYSIS

5.1 INTRODUCTION

The U.S. Department of Energy (DOE) performed an engineering analysis to study representative lamps used as substitutes for baseline lamps, to select efficacy levels (ELs) , and to analyze lamp -and- ballast system power ratings

. First, DOE selects representative equipment classes to analyze. It then selects lamps that represent the baseline efficacy

, as well as more efficacious substitutes for those baseline lamps. DOE uses the more efficacio us lamps to develop

ELs. While DOE establishes ELs based on lamp designs for the engineering analysis, it also develops lamp -and- ballast systems for use in the life -cycle cost (LCC) analysis and national impact analysis (NIA) because lamps and ballasts ope rate together in practice.

In energy conservation rulemakings for other equipment, DOE often develops costefficiency relationships in the engineering analysis. However, for this high

- intensity discharge ( HID ) lamp notice of proposed determination ( NOPD ), DOE derives an EL and lamp-and- ballast system power for each representative system in the engineering analysis and end- user prices in the equipment price determination. By combining the results of the engineering analysis and the equipment price determination, DOE derives typical inputs for use in the LCC and NIA. See chapter 6 and appendix 6A of the NOPD technical support document ( TSD ) for discussion of DOE’s methodology for determining equipment prices.

5.2 METHODOLOGY OVERVIEW

DOE bases the engineering ana lysis on commercially available lamps that incorporate the design options identified in the technology assessment and screening analysis ( see chapter 3 of the NOPD TSD for details of the technology assessment and chapter 4 of the NOPD TSD for details of the screening analysis ). DOE took the following four steps in the engineering analysis:

Determine Representative Equipment Classes : When multiple equipment classes exist,

DOE streamlines analysis by select ing certain classes as “representative,” primarily because of their high market volumes and unique performance characteristics. DOE then adapts the ELs from representative equipment classes to those equipment classes it does not analyze directly.

Baseline Lamps and Representative Base Types : Because no federal energy conservation standards exist for HID lamps, the baseline lamps represent the most common, least efficacious lamps sold within the equipment class. For each baseline lamp, DOE selected more efficacious replacement lamps to meas ure potential energy saving improvements. DOE refers to the baseline lamp and its more efficacious replacements collectively herein as a “representative lamp type.” The representative lamp type is named by its baseline unit . For example, the 400 W mercury vapor ( MV ) representative lamp type refers to the 400 W MV baseline lamp and all of its more efficacious replacements.

5-1DOE uses performance data presented in manufacturer catalogs to determine lamp efficacy for each baseline unit . DOE also considers other lamp characteristics in choosing the most appropriate baseline for each equipment class. These characteristics include the wattage and lamp type ( i.e.

, metal halide [MH] or MV) , among others. For some of the representative lamp types, DOE selects multiple baseline models to ensure consideration of different highvolume lamps and their associated customer economics. For example, although MH lamps are not the least efficacious products available, the HID market has largely shifted away from MV lamps and cust omers of MH lamp -and- ballast systems incur different costs than customers of MV lamp -and- ballast systems. For these reason s , DOE selects both MV and MH lamp s as baselines for certain equipment classes.

DOE notes that the baseline lamps selected are intend ed to reflect not only the lowest efficacy lamp types available, but also lamps that are commonly used. Within the representative lamp types that have two baselines, MV lamps are the least efficacious but are not the most commonly used lamps in these equipment classes. By assigning the designation of baseline to both a MV and MH lamp, the analysis will capture the lowest efficacy lamps available for both technology types. The designation of a lamp as a baseline is used as a point of reference for the

LCC analysis (discussed in chapter 9 of th is NOP D TSD). The use of multiple baselines does not impact the overall energy savings calculations. The energy savings calculations are based on estimates of the shipments of lamps at each EL (including baselines) without standards and the expected change in shipments at each EL that would occur with standards.

More Efficacious Substitutes: DOE selects commercially available HID lamps with efficacies above baseline as replacements for the baseline model(s) in each representative equipment class. When selecting more efficacious substitute lamps, DOE only considers design options that meet the criteria outlined in the screening analysis (chapter 4 of this NOPD TSD).

In this NOPD , DOE considers a number of different potential pathways a customer might choose when identifying replacements that are more efficacious. DOE analyzed the possibility of customers replacing the whole fixture, retrofitting the existing fixture with a new lamp -andballast system, and replacing just the lamp. Each of these options can also be paired with a reduced wattage or a lamp with equal wattage to the baseline

.

Determine Efficacy Levels

. DOE develops ELs based on: (1) the design options associated with the specific lamps studied and (2) the maximum technologically feasible (max

tech) EL for that class

. DOE’s ELs are based on efficacy values found in manufacturer catalog

data.

The sections that follow discuss how DOE applies this methodology to each equipment class to create the engin eering analysis.

5.3 REPRESENTATIVE EQUIP MENT CLASSES

As discussed in the market and technology assessment (chapter 3 of the NOPD TSD),

DOE created 24 equipment classes based on correlated color temperature (CCT ), wattage, bulb finish, and luminaire characteristic. Of these equipment classes, DOE chose to analyze three as

5-2representative. For CCT, DOE considered the ≥ 2800 K to ≤4500 K range (hereafter referred to as

the 2800 K – 4500 K CCT range) to be representat ive. Based on lamp catalogs and manufacturer interviews, DOE found that MH and MV lamps are available in both the 2800 K – 4500 K CCT range and >4500 and <7000 K (hereafter referred to as the 4501 K – 6999 K CCT range), but the former of the two ranges includes the more commonly shipped lamps. For bulb finish, DOE chose to analyze clear lamps as representative because DOE determined that clear lamps were more commonly shipped than coated lamps. a Finally, for luminaire characteristic, DOE chose to analyze en closed

- rated lamps as representative because DOE determined that enclosed

- rated MH lamps are more commonly shipped than open- rated MH lamps

. b Table 5.3.1 lists the representative equipment classes and those classes not analyzed directly (scaled equipment classes).

a Clear lamps are more commonly shipped for MH lamps in the 2800 K

– 4500 K CCT range. The MV lamps that are in this CCT range are all coated. Because these equipment classes are predominantly made up of MH lamps and there is only one available bulb finish for MV lamps in these classes, DOE will refer to these classes as being

“clear ,” although the MV lamps within them will be coated. Chapter 3 of the NOPD TSD describes the equipment class categorization of MV lamps.

b While MV lamps do not have open vs. enclosed luminaire characteristic, DOE determined in chapter 3 of the

NOPD TSD t hat MV lamps would be placed in the enclosed equipment classes.

5-3Table 5.3.1 Representative and Scaled Equipment Classes for HID Lamps

CCT Range Wattage* Bulb

Finish** Luminaire

Characteristic † Representative or Scaled Equipment Class

2800 K

– 4500 K 50 W

– 400 W Clear Enclosed Representative

Open Scaled

Coated Enclosed Scaled

Open Scaled

401 W

– 1000 W Clear Enclosed Representative

Open Scaled

Coated Enclosed Scaled

Open Scaled

1001 W – 2 000 W Clear Enclosed Representative

Open Scaled

Coated Enclosed Scaled

Open Scaled

4501 K

–

6999 K 50 W

– 400 W Clear Enclosed Scaled

Open Scaled

Coated Enclosed Scaled

Open Scaled

401 W

– 1000 W Clear Enclosed Scaled

Open Scaled

Coated Enclosed Scaled

Open Scaled

1001 W

– 2000 W Clear Enclosed Scaled

Open Scaled

Coated Enclosed Scaled

Open Scaled

* The wattage ranges of the equipment classes are ≥50 and ≤400 W, >400 W and ≤1000 W, and >1000 W and ≤2000 W, but for the sake of simplicity are referred to in this NOP D TSD as 50 W

– 400 W, 401 W – 1 000 W,

and 1001 W

– 2000 W , respectively.
** MV lamps regardless of bulb finish are placed in the clear equipment classes for their respective CCT and

wattage.
† MV lamps are placed in the enclosed equipment classes for their respective wattage and CCT.

5.3.1 Baseline Lamps and Representative Lamp Types

Once the representative equipment classes for analysis were identified

, DOE selected baseline lamps to analyze in each class. Because no f ederal energy conservation standards exist for HID lamps, the baseline lamps represent the most common, least efficacious lamps sold within the equipment class. Fo r each baseline lamp, DOE selected more efficacious replacement lamps to measure potential energy -saving improvements. DOE refers to the baseline lamp and its

more efficacious , reduced- wattage replacements collectively herein as a “representative lamp

5-4type .” The representative lamp type is named by its baseline unit. For example, the 400 W MV representative lamp type refers to the 400 W MV baseline lamp and all of its more efficacious

, reduced

- wattage replacements.

In certain cases in which two lamp technologies ( e.g., MV and MH) are included in the same representative lamp type, DOE selected multiple baseline lamps to ensure consideration of

different customer economics . For example, MV lamps are the least efficacious lamp option for some equipment c lasses; however, MV lamps represent a small portion of the market because many customers have already transitioned to MH technology. For this reason, DOE selects both a MV lamp and a MH lamp as baselines for certain representative lamp types.

DOE notes th at the baseline lamps selected are intended to reflect not only the lowest efficacy lamp types available, but also lamps that are commonly used. Within the representative lamp types that have two baselines, MV lamps are the least efficacious lamps in the equipment

classes but are not the most commonly used. By assigning the designation of baseline to both a

MV and a MH lamp, the analysis will capture the lowest efficacy lamps available for both technology types. The designation of a lamp as a baseline is us ed as a point of reference for the

LCC analysis (discussed in chapter 9 of the TSD). The energy savings calculations in chapter 8

of the NOPD TSD are based on estimates of the shipments of lamps at each EL (including baselines) with and without any potenti al standards.

For the 2800 K – 4500 K, 50 W

– 400 W

, clear

, enclosed equipment class (hereafter

referred to as the 2800 K – 4500 K, 50 W

– 400 W representative equipment class)

, DOE chose to analyze nine baseline lamps, spanning five different representat ive lamp types. After examining catalog data and interviewing manufacturers, DOE concluded that both MV and MH technologies are available in this equipment class. Because MV lamps are consistently the least efficacious lamps in this equipment class , DOE se lected the most common MV lamps as baseline lamp s. When a MH lamp could serve as a higher

- efficacy replacement lamp for a MV baseline lamp, DOE analyzed both the MV lamp and the reduced wattage MH lamp as baselines. In addition to the MH lamps that were id entified to be reduced wattage replacements for MV lamps

and MH baselines

, DOE also selected a 400 W MH baseline lamp to analyze . Including th is MH baseline lamp ensured DOE accurately characterized the HID lamp market because th is 400 W MH baseline lamp r epresent s a high shipment volume. DOE decided to analyze MV lamps with wattages of 100, 175, 250, and 400 W and MH lamps with wattages of 70, 150, 175, 250, and

400 W as baselines. These nine baselines are summarized below in Table 5.3.2

.

For the 2800 K – 4500 K, 401 W – 1000 W

, clear , enclosed equipment class (hereafter

referred to as the 2800 K – 4500 K, 401 W – 1000 W representative equipment class) , DOE analyzed two baseline lamp s representing two separate representative lamp types . Based on catalog availability and manufacturer feedback , DOE found the most common , least efficient lamp i n this equipment class to be a 1000 W MV lamp and thus chose to analyze a 1000 W MV

baseline

. DOE also selected a 1000 W MH baseline lamp to analyze. This baseline was included because 1000 W MH lamps represent high shipment volumes, as determined by catalog availability and manufacturer input. These two baseline lamps for the 2800 K – 4500 K, 401 W –

1000 W representative e quipment class are shown below in Table 5.3.2

.

5-5For the 2800 K – 4500 K, 1001 W

– 2000 W

, clear

, enclosed equipment class (hereafter

referred to as the 2800 K – 4500 K, 1001 W

– 2000 W representative equipment class) , DOE analyzed only one baseline . In order to characterize the highest wattage of the equipment class, DOE chose a 2000 W probe- start MH lamp as the baseline , as shown below in Table 5.3.2

. MV lamps are not present in this equipment class because there are no commercially available MV lamps above 1000 W. As such, this NOPD is only considering standards for MV lamps with wattages of 50 W

– 1000 W

.

Table 5.3.2 Baseline Lamps

CCT Range Wattage Bulb

Finish* Luminaire

Characteristic** Representative Lamp Type Baseline Lamp Type Baseline Wattage

2800 K

– 4500 K 50 W

– 400 W Clear Enclosed 100 W MV MV 100

MH 70

175 W MV MV 175

MH 150

250 W MV MV 250

MH 175

400 W MV MV 400

MH 250

400 W MH MH 400

401 W

– 1000 W Clear Enclosed 1000 W MV MV 1000

1000 W MH MH 1000

1001 W

– 2000 W Clear Enclosed 2000 W MH MH 2000

*MV lamps regardless of bulb finish are placed in the clear equipment classes for their respective CCT and

wattage. ** MV lamps are placed in the enclosed equipment classes for their respective wattage and CCT.

5.4 HIGHER

- EFFICACY REPLACEMENT S

After choosing a baseline lamp for each representative lamp type, DOE searched for commercially available HID lamps that would serve as more efficacious substitutes on the basis of initial efficacy. When identifying these reduced wattage lamps that could r eplace baselines, DOE considered a number of criteria. Most importantly, more efficacious substitutes were selected to save energy and, when possible, have mean lumens within 10 percent of the mean lumens of the baseline lamp. DOE also sought to keep other characteristics as similar as possible, such as initial lumen output, operating orientation, rated life, color rendering index (CRI), bulb shape, and base type. With regard to operating orientation, DOE notes that universal lamps were selected as represen tative units whenever available. In doing so, DOE ensures that universal lamps, which might be inherently less efficacious than position specific lamps, are not removed

from the market by standards. c

c Certain representative lamps were unable to be universal lamps, due to unavailability of a universal lamp with the other desired characteristics ( e.g. , base type, bulb shape). In each of th ese instances, DOE ensured that either there

5-6DOE analyzed all quartz MH lamps and found that the var iation in efficacy found with quartz MH technology justified two ELs . At each wattage of quartz MH lamps, DOE found a range of efficiencies available. As discussed in chapter 4 of this NOPD TSD , DOE found that there are a number of ways to optimize the arc tube construction of a quartz MH lamp to improve

effic acy. When investigating the range of effica cies available, DOE often found that the same light output was available from quartz MH lamps at different wattages. For example, DOE found a 175 W quartz MH lamp and a 150 W quartz MH lamp with the same mean lumen output. In this example, a customer can select the 150 W quartz MH lamp as a more efficacious substitute for the 175 W quartz MH lamp. For this NOPD , DOE analyzed up to three more efficacious, reduced wattage substitute lamps ( compared to a MV baseline) corresponding to standard efficacy quartz MH, high efficacy quartz MH, and ceramic metal halide ( CMH ) lamps. These more efficacious substitute lamps maintained mean lumens within ten percent of the baseline. d
DOE also sought to keep other lamp characteristics consistent from baseline to higher- efficacy substitute. More efficacious substitute lamps had the same bulb shape and base type as baseline, and DOE selected units that maintained characteristics such as CCT, CRI, and rated lifetime as

much as feasible. For each quartz MH level, DOE selected one lamp as representative and used this lamp’s performance characteristics in its engineering modeling. However to accurately

reflect the c usto mer economics , DOE also identified when a lamp with the alternative starting method ( i.e. , if the representative EL1 lamp was probe-start, DOE also identified when a pulsestart MH lamp was commercially available at that wattage and EL) was available and determined the price of this alternative starting method lamp. See appendix 5A for details of this process for identifying alternative starting method lamps.

DOE also analyze d customers who choose to comply with standards by purchasing a higher- efficacy lamp that has a wattage equal to that of the baseline lamp. While a customer switching to a more efficacious lamp at the same wattage would only provide increased light output with no energy savings, DOE still found customers may choose to do so for reasons such

as conv enience or initial cost. To model the customers who choose lamps with equal wattage, DOE identified higher- efficacy, equal wattage substitutes for each representative unit at each EL

. For each representative unit, DOE selected an equal wattage lamp with an efficacy that meets each higher EL as close as possible , while keeping the same starting method, bulb shape, and base type. Sometimes exceptions had to be made to this process, such as not selecting EL3 compliant CMH lamps at 175 W, 250 W, 320 W, or 400 W because none are commercially

available

.

In its analysis, DOE considered all design options that are commercially available or present in a working prototype, including proprietary designs. However, if a proprietary design is the only approach available to achieve a given EL, then DOE will eliminate the EL from further analysis. DOE will reject a standard level that can be met only with a single proprietary

was a universal lamp at that wattage that exceeded the initial efficacy of the representative unit, or that all lamps on the market at that wattage and equipment class were non

- universal, thus ensuring that no w attage could have universal lamps eliminated by potential standards.

d When selecting more efficacious substitutes, it was not always possible to stay within ten percent mean lumens of both the MV baseline and the MH baseline. When this was the case, DOE s elected a more efficacious substitute that is within ten percent mean lumens as the MV baseline, and as close to ten percent mean lumens as possible to the

MH baseline.

5-7technology because it could result in an anti- competitive market, a principle consistently applied in past DOE rulemakings as economically unjustifiable. However, if a given EL can be achieved by a number of design approaches, including a proprietary design, DOE will continue to examine the given EL, in spite of the proprietary nature of a particular design.

5.5 EFFICACY LEVELS

5.5.1 General Methodology

In its analysis of available data, DOE found that initial lamp efficacy tends to increase with increased wattage. DOE considered two options to capture this trend when establishing ELs: (1) a constant-value appro ach, in which the same standard is established for all lamps within an equipment class, and (2) an equation-based approach, in which a relationship between lamp input power and initial lamp efficacy is determined for each equipment class. To consider a

con stant -value approach, in which all lamp wattages within an equipment class are required to meet a single standard, DOE would have to create several additional equipment classes to accommodate the range of wattages encompassed by a representative lamp type. For example, in the 2800 K – 4500 K range, DOE could create an equipment class for lamps with wattages between 100 W and 250 W that would encompass the 250 W MV baseline and the more efficacious, lower

- wattage quartz MH , and CMH replacements (the 250 W MV representative lamp type). However, using equipment class divisions based on wattage would result in the wattage of the highest- efficacy replacements for certain baselines being overlapped with a neighboring equipment class. For example, the 100 W CMH replacement for the 250 W MV baseline lamp in the hypothetical 100 W to 250 W equipment class has the same wattage as both

a 100 W high efficacy quartz MH replacement for a 175 W MV baseline lamp and a 100 W MV baseline lamp. Furthermore, a const ant -value approach could result in a market shift to the higher-wattage end of any equipment class, as those lamps are naturally able to achieve higher efficacy than lower

- wattage lamps. For these reasons, DOE decidednot to pursue a constantvalue approac h and to instead employ an equation-based approach in this NOPD

.

5.5.2 Efficacy Levels

When developing EL equations, DOE modeled each equation to represent a particular design option. In doing so, DOE designed each EL equation to allow the representative units o f a particular design option to meet efficacy standards . For example, DOE developed an EL equation for each more efficacious replacement for a MV baseline, such as a standard efficacy

quartz MH , high efficacy quartz MH , and CMH lamp.

DOE analyzed each equipment class to determine the appropriate E Ls. To develop equations, DOE used function regression curves to best fit the representative units in each equipment class, according to an equation using the form of one of the following:

Initial lamp efficacy (lm/W) = Coefficient × (Lamp input power [W]) ^ Exponent

Initial lamp efficacy (lm/W) = Coefficient × (Lamp input power [W]) + Constant

5-8Initial lamp efficacy (lm/W) = Constant

Using the available data, DOE identified which of the equation types was most appropriate for each equipment class and calculated the relevant coefficient , exponent, and constant for each E L equation.

5.5.2.1 Effi ca cy Levels for 2800 K – 4500 K, 50 W – 400 W Representative Equipment Class

In the 2800 K – 4500 K CCT ra nge, which contains the majority of MV and MH lamps, DOE observed that the same lamp technologies were not available at all available lamp wattages. Therefore, DOE separate d equipment classes by wattage as discussed in chapter 3 of the NOPD

TSD . For all products in these equipment classes , DOE sought to maintain continuity of the E L equations across all covered wattages. Ensuring continuity between equipment classes prevents lamps of slightly different input power being subject to very different s tandards. In a case where a higher- wattage lamp is subject to a less stringent standard, the market might shift to increased wattage, negating potential energy savings.

For lamps with wattages of 50 W – 400 W, DOE analyzed five representative lamp types. In this equipment class, a power trend of the following form proved to be the best fit for the

available data:

Initial lamp efficacy (lm/W) = Coefficient × (Lamp input power [W]) ^ Exponent

DOE identified three E Ls above the baseline, which represent com mercially available standard efficacy quartz MH, high efficacy quartz MH, and C MH lamps , respectively . DOE plotted initial lamp efficacy as a function of lamp input power for lamps in this equipment class

and determined that the data was best modeled by a power function with an exponent less than one ( i.e. , a concave power function)

. ELs 1 and 2, which represent MH lamps with the traditional quartz arc tube, both have an exponent value of 0.1350 . This differs from EL 3, which has an exponent value of 0.1808 and represents MH lamps with ceramic arc tubes. The higher exponent results in a steeper slope throughout the wattage range. The ELs for lamps 50 W

– 400 W are depicted in Table 5.5.1 and Figure 5.5 .1 belo w.

Table 5.5.1 Effic a cy Levels for 2800 K – 4500 K, 50 W – 400 W Representative Equipment

Class

Effic a cy Level Technology Level Equation

E L 1 Standard Efficacy Quartz MH lm/W = 38 .5 × W 0. 1350

E L 2 High Efficacy Quartz MH lm/W = 44.4 × W 0. 1350

E L 3 CMH lm/W = 4 0.4 × W 0.1808

5-9Figure 5.5.1 Effic acy Levels for 2800 K – 4500 K CCT, 50 W – 400 W Representative Equipment Class

5.5.2.2 Effic a cy Levels for 2800 K – 4500 K, 401 W – 1000 W Representative Equipment Class

For lamps with wattages of 401 W

– 1000 W , DOE analyzed two representative lamp types. In this equipment class, a linear trend of the following form proved to be the best fit for

the available data:

lm/W = coefficient × (lamp input power) + constant

The coefficient for each EL was determined by fitting a line, anchored to the endpoints of the EL equations in the 50 W

– 400 W range, such that the representative units for the 401 W

– 1000 W range met the appropriate EL. The E Ls for lamps 401 W

– 1000 W are depicted in Table

5.5.2 and Figure 5.5.2 below

. 60 70 80 90 100 110 120 130

50 100 150 200 250 300 350 400Initial Lamp Efficacy (lm/W)

Lamp Wattage (W) EL1

EL2

EL3

5-10Table 5.5.2 Ef fic a cy Levels for 2800 K – 4500 K, 401 W – 1000 W Representative Equipment Class

Effic a cy Level Technology Level Equation

EL 1 Standard Efficacy Quartz MH lm/W = 0. 0 116 × W + 81.8

E L 2 High Efficacy Quartz MH lm/W = 0. 01 73 × W + 9 2.8

Figure 5.5.2 Effic acy Levels for 2800 K – 4500 K, 401 W – 1000 W Representative Equipment Class

5.5.2.3 Effic a cy Levels for 2800 K – 4500 K, 1001 W – 2000 W Representative Equipment Class

For lamps with wattages of 1001 W – 2000 W, DOE analyzed one representative lamp type. The EL 1 equation represents high efficacy quartz MH technology and is a constant efficacy requirement of 9 3.4 lm/W . This EL was determined by connecting a horizontal line (slope of zero) through the 1000 W endpoint of EL 1 in the 401 W

– 1000 W range to the end of the 1001 W – 2000 W range, such that the representative units for the 1001 W – 2000 W range 60 70 80 90 100 110 120 130

400 500 600 700 800 900 1000Initial Lamp Efficacy (lm/W)

Lamp Wattage (W) EL1

EL2

5-11met the appropriate EL

. The EL for lamps 1001 W – 2000 W is depicted in Table 5.5 .3 and Figure 5.5.3 below.

Table 5.5.3 Effic a cy Level for 2800 K – 4500 K, 1001 W – 2000 W Representative Equipment Class

Effic a cy Level Technology Level Equation

E L 1 High Efficacy Quartz MH lm/W = 9 3.4

Figure 5.5.3 Effic acy Level for 2800 K – 4500 K CCT, 1001 W – 2000 W Representative Equipment Class

5.5.2.4 Effic a cy Levels Summary

A summary of the EL descriptions and equations for all analyzed equipment classes is presented in Table 5.5.4 and Figure 5.5.4

. 60 70 80 90 100 110 120 130

1000 1200 1400 1600 1800 2000Initial Lamp Efficacy (lm/W)

Lamp Wattage (W) EL1

5-12Table 5.5.4 Representative Equipment Class Effic a cy Levels

CCT Range Wattage Range EL Technology Level Equation

2800 K

– 4 500 K 50 W – 4 00 W E L 1 Standard Efficacy Quartz MH lm/W = 38 .5 × W 0.1350

E L 2 High Efficacy Quartz MH lm/W = 44.4 × W 0. 1 350

E L 3 CMH lm/W = 4 0.4 × W 0. 1 80 8

401 W

– 1000 W E L 1 Standard Efficacy Quartz MH lm/W = 0.0 116 × W + 81.8

E L 2 High Efficacy Quartz MH lm/W = 0.01 73 × W + 9 2.8

1001 W

– 2000 W E L 1 High Efficacy Quartz MH lm/W = 9 3.4

Figure 5.5.4 Effic a cy Levels for Representative Equipment Classes

5.6 HID SYSTEMS

In this NOPD , DOE is only analyzing standards for HID lamps. However, HID lamps are just one component of an HID lighting system. HID lamps must be paired with specific ballasts to regulate the current and power supplied to the lamp. These lamp-and- ballast systems are then

housed in an HID fixture e in order to protect the components, enable it to be mounted in the desired location, and direct the light to the target area. When considering changes to HID lamps, DOE recognizes the importance of also analyzing the impact on both the ballast and the fixture. Additional components may also be required if placing a new lamp-and- ballast system in an existing fixture, including an appropriate lamp socket and ballast brackets.

5.6.1 Replacement Options

DOE models several options that customers could choose when faced with new HID energy conservation standards. The energy savings and cost savings calculated are based on the

e Here, DOE uses the term “fixture” to refer to the enclosure that houses the lamp and ballast. 60 70 80 90 100 110 120 130

0 500 1000 1500 2000Initial Lamp Efficacy (lm/W)

Lamp Wattage (W) EL1 EL2 EL3

5-13expected customer response. DOE researched all options (within HID technology under consideration for standards) a customer would have when presented with energy conservation standards. Based on manufacturer feedback and market analysis, DOE analyzed the possibility of customers replacing the whole fixture, retrofitting the existing fixture with a new lamp -andballast system, and replacing just the lamp. Each of these options can also be used with a reduced wattage lamp or a lamp with a wattage equal to the existing system. These result in the following six options for customers when presented with energy conservation standards:

1) replacing the existing fixture with a new fixture that houses a compliant lamp with increased efficacy and reduced wattage;

2) retrofitting the existing fixture with a compliant lamp -and- ballast replacement kit with increased efficacy and reduced wattage;

3) replacing the lamp with a compliant retrofit lamp that has increased efficacy and runs at a reduced wattage when operated on the full wattage ballast;

4) replacing the existing fixture with a new fixture that houses a compliant lamp with increased efficacy at the same wattage;

5) retrofitting the existing fixture with a compliant lamp -and- ballast replacement kit with increased efficacy at the same wattage; and

6) replacing the lamp with a compliant lamp that is increased efficacy at the same

wattage.

The lamps used for options 1 and 2 are the same, with the difference being option 1 uses

an entire new fixtur e, while option 2 uses a lamp -and- ballast retrofit kit (including new socket and bracket for the ballast). Option 3 requires a separate type of lamp that is specifically designed to allow the ballast to operate below its full wattage. Options 4, 5, and 6 a ll use the same lamps, with the difference being that option 4 uses an entire new fixture, while option 5 uses a lamp -and-ballast retrofit kit (including new socket and bracket for the ballast), and option 6 assumes that the compliant lamp is placed in the existing fixture and ballast. The details of each of these lamps selected are discussed in chapter 5 of this NOPD TSD.

In this NOPD , DOE modeled customers choosing one of the six replacement options depending on which component of their HID system failed . If just the HID lamp reache s the end

of its life, any of the six options would be feasible options in order to ensure the new system is compliant. If the ballast reache s the end of its life, a customer could follow options 1, 2, 4, or 5

because each of these options includes a new ballast. If the fixture itself reached the end of its life, a customer would have to replace the entire fixture and could choose options 1 or 4.

For each replacement option chosen DOE determined what type of lamp would be available. Whenever possible, the existing lamp is replaced with a lamp of the same technology ( e.g. , a probe-start lamp would be replaced with a compliant probe- start lamp, if available). MV lamps, in general, were replaced with pulse

- start MH lamps. The full set of rules that DOE

5-14followed to identify which system components would be used for each replacement pathway can be found in appendix 5B of this NOPD TSD.

5.6.2 Ballasts

Because HID lamps require a ballast to operate, DOE pairs each representative HID lamp with a representative ballast . When modeling a customer replacing an entire fixture or installing a lamp -and- ballast retrofit system, it is important to consider the efficiency of the ballast involved in the new system to determine energy savings. DOE has found that the performance

characteristics of a ballast

— most importantly

, ballast efficiency

— change with wattage. Therefore in order to properly identify an energy conservation standard’s impact on overall system performance, the correct ballast needs to be paired with each representative lamp. For this

NOPD , DOE assumes that any change in operating lamp wattage necessitates a change in ballast.

In addition to a change in wattage, more efficacious lamps often utilize different technology. For example, when moving from a MV lamp to a MH lamp , the change in technology necessitates a change in ballast. A ballast for a MV lamp is designed and operated differently than a ballast for a MH lamp, and those differences affect the performance

characteristics of the ballast , including the ballast efficiency. This difference in ballast performance based on ballast type can also be found based on starting method of MH ballasts and magnetic versus electronic MH ballasts. For this NOPD , DOE assumes that changing from one lamp technology to another ( e.g. , MV to MH, probe- start MH to pulse

- start MH, and quartz MH to CMH) necessitates a change in ballast , though there are some exceptions. See appendix

5B for details

.

DOE analyzed HID ballast catalogs and received manufacturer input to determine the

ballast type that is most commonly used with each representative lamp type. In the HID market, ballasts can be classified as either magnetic or electronic. Magnetic ballasts are larger, more

robust to high temperature s and voltage transients , and less expensive than electronic ballasts. Electronic ballasts have recently become more popular due to their high efficiencies, but they

still have a lower market share than magnetic ballasts. When DOE analyzed the MV ballasts on the market, the available products were almost entirely magnetic, so DOE paired magnetic MV ballasts with the MV representative lamp types. When determining which ty pe of ballast to use

for the MH representative lamp types , DOE analy zed the probe- start MH, pulse

- start MH, and CMH lamps separately. DOE determined that magnetic ballasts are more commonly used than

electronic ballasts with probe-start and pulse- start quartz MH lamps. In surveying the current market for CMH lamps, however , DOE found that electronic ballasts are typically paired with CMH lamps. Therefore, DOE used an electronic MH ballast with all representative CMH lamps and a magnetic MH ballast with all representative probe -start and pulse- start MH lamps

. f Table

5.6.1 below summarizes the representative ballast types used with each representative lamp type.

f For some replacement scenarios where a customer is only replacing the lamp on an existing pulse

- start magnetic ballast system with an EL3 lamp, DOE assumed the CMH lamp would be used on the existing magnetic pulse

- start
ballast. It is also feasi ble for a quartz lamp to be operated with an electronic ballast, even though that scenario is not modeled in this NOPD. Additionally when the purchase option selected is a lamp

- and

- ballast re trofit and the ballast being replaced is magnetic, a customer shi fting to a CMH lamp is assumed to use a replacement ballast that is pulse

start magnetic. This assumption is made because, while CMH lamps can run on pulse

- start magnetic or pulse

- start

5-15Table 5.6.1 Repr esentative Ballast Types

Lamp Technology Lamp Starting Method Lamp Arc Tube Material Ballast Type

MV N/A N/A MV magnetic

MH Probe Quartz MH magnetic

MH Pulse Quartz MH magnetic

MH Pulse Ceramic MH electronic

DOE’s ballast pairing also accounts for a number of different scenarios. In order to accurately account for the energy that could be saved by potential standards in this NOPD , DOE

characterize d the ballast efficiencies of fixtures a customer can buy both before and after the compliance date of potential standards . Fixtures purchased after the compliance date of th ese potential standards must have ballasts that comply with the energy conservation standards rulemaking for metal halide lamp fixtures ( MHLFs ), hereaf ter referred to as the 2014 MHLF

rule

. g Fixtures purchased before the compliance date of th ese potential standards can be characterized by two different types of ballast efficiencies, those with ballasts covered by the Energy Independence and Security Act of 2007 (EISA 2007) and those with ballasts not covered by EISA 2007 . Fixtures are assumed to have EISA 2007 compliant efficiencies if they are purchased after the compliance date of EISA 2007 and are covered by the scope of EISA 2007. Otherwise, fixtures are assumed to not have EISA 2007 and instead are assumed to have the least efficient ballast efficiency commercially available for that wattage and ballast type. O ne exception to these rules is if the ballast is electronic, then the ballast efficiency is assumed to be the least efficient electronic ballast commercially available. This is because electronic ballast

efficiencies are more efficient than the requirements of the 2014 MHLF rule and EISA 2007 standards. The various ballasts and potential efficiencies are shown in Table 5.6.2 and Table

5.6.3 below.

electronic ballasts, the existing fixtures in these situations are ass umed to be designed for use with magnetic ballasts and not electronic ballasts. Use with electronic ballasts requires design modifications to the fixture, so the fixture is not assumed to have been designed for use with an electronic ballast.

g The final rule in this MHLF rulemaking was published in the Federal Register on February 10, 2014. 79 FR 7745. For more information on this rulemaking, see http://www 1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/16

.

5-16Table 5.6.2 Magnetic Ballast Efficiencies

Ballast Type Wattage Least Efficient (%) EISA 2007 (%) 2014 MHLF rule (%)

Magnetic MH 50 69.4 N/A 76.1

Magnetic MH 70 72.0 N/A 78.2

Magnetic MH 100 77.0 N/A 80.2

Magnetic MH 150* 81.0 N/A 82.4

Magnetic MH 175 81.4 88.0 88.0

Magnetic MH 200 83.3 88.0 88.0

Magnetic MH 250 79.6 88.0 88.8

Magnetic MH 320 79.0 88.0 89.6

Magnetic MH 400 86.0 88.0 90.3

Magnetic MH 575 89.8 N/A 91.0

Magnetic MH 750 91.0 N/A 91.0

Magnetic MH 875 90.0 N/A 92.3

Magnetic MH 1000 92.0 N/A 93.6

Magnetic MH 1500 92.0 N/A N/A

Magnetic MH 2000 95.0 N/A N/A

Magnetic MV 100 83.0 N/A N/A

Magnetic MV 175 85.0 N/A N/A

Magnetic MV 250 87.0 N/A N/A

Magnetic MV 400 89.0 N/A N/A

Magnetic MV 1000 92.0 N/A N/A

Magnetic HPS 250 84.0 N/A N/A

*150 W ballasts are assumed to be in fixtures that are rated for use in wet locations and ambient temperatures greater than 50 o C, and thus are excluded from EISA 2007.

Table 5.6.3 Electronic Ballast Efficiencies

Ballast Type Wattage Least Efficient (%)

Electronic MH 50 89.0

Electronic MH 70 90.0

Electronic MH 100 90.0

Electronic MH 150 90.0

Once DOE determined the efficiency of each representative ballast type , DOE used the ballast efficiency and lamp wattage to calculate the overall system power . The total power required, in watts, was calculated by dividing the lamp wattage by the ballast efficiency. By using this total system energy figure, instead of only the wattage of the lamp, DOE ensures that it

will consider ELs that increas e lamp efficacy while also decreas ing system power.

5-175.6.3 Lamp

- and

- Ballast Retrofit Kits

DOE also analyzed the possibility that a customer will install a lamp -and- ballast retrofit kit in an existing fixture. As stated previously, a number of manufacturers offer a line of products called retrofit kits. These kits can come with a lamp, ballast, lamp socket, and ballast brackets,

and are intended to allow customers to install a n HID system with a new technology or wattage in an existing fixture. DOE notes that ballast efficiency standards from EISA 2007 and the 2014

MHLF rule only apply to ballasts sold in new fixtures. Ballasts sold individually, or as a part of retrofit kits, are not subject to standards. In order to calculate the system power use of retrofit kits, DOE made the assumption that customers would opt to replace their existing ballast s with ballasts the meet the same standard level of their existing system. As discussed previously, the efficiency of an existing system will differ based on whether at the time of purchase it had to comply with EISA 2007, the 2014 MHLF rule, or no standar ds at all. See section 5.6.2 for these ballast efficiencies. The manufacturer selling prices ( MSPs ) of these retrofit kits are discussed in appendix 6A of this NOPD TSD. Further details of these replacement pathways can be found in appendix 5B of this NOPD TSD.

5.6.4 Fixtures

As described previously, when replacing a n HID lamp with a more efficacious substitute, a change in ballast is often required. After seeking input from manufacturers of both HID lamp s and HID fixtures , DOE determined that these changes to the lamp -and- ballast system could also necessitate a change in the fixture. This fixture replacement is needed for several reasons.

Certain r eplacement lamp -and- ballast systems will be a dif ferent size, and will not fit into the existing fixture. Changing lamp-and- ballast systems risks resulting in non- optimal optics withthe existing fixture, because fixtures are designed to optimize the light output for a specific lampand- ballast system. Lastly, retrofitting an old fixture with a new lamp -and- ballast system may create safety concerns and result in the decertifying o f the fixture’s Underwriters Laboratories Inc. ( UL ) rating. h For these reasons, DOE assumes in this NOPD that changes in the lamp -andballast system necessitate a change in fixture in many cases . DOE models these fixture replacements as impacting the price of a lamp

- and -ballast system to the customer, but not impacting the performance. See appendix 6A of this NOPD TSD for more information on the pricing of HID fixtures , and appendix 5B of this NOPD TSD for details of when a new fixture is required.

However, DOE did learn that there are certain specific instances where lamp -and- ballast retrofits would not require a change in fixture . While some replacement systems will be of a different size, the retrofit scenarios DOE is modeling are typically instan ces where the wattage is being reduced and thus the size will likely drop. In terms of optics, customer s that choose to retrofit an existing fixture with a new lamp -and- ballast system can identify a replacement lamp that has the same bulb shape and base ty pe in order to fit optimally into the existing fixture optics. Lastly, while acknowledging that retrofitting an old fixture with a new lamp-and- ballast

h UL, or Underwriters Laboratories, is an organization that independently certifies a wide variety of product safety, including luminaires. When HID fixture manufacturers submit pro ducts for safety certification, the UL certification is only valid using the lamp

- and

- ballast system that was sold and tested with the fixture. Any modifications to the fixture, such as replacing the lamp and/or ballast will void the UL certification.

5-18system can decertify a fixture’s UL rating, DOE has tentatively determined that some customers
would sti ll choose to do so. Thus DOE is modeling a portion of customers, in specific replacement options where it is technologically feasible, retrofitting existing fixture s with a new lamp -and- ballast system s instead of replacing the entire fixture.

5.6.5 Re placement L amps

DOE noted that there are lamp replacement options that do not require the ballast or fixture to change. One option is replacing the lamp with a compliant retrofit lamp with increased efficacy , but has reduced wattage and is designed to operate on the full wattage ballasts. While these retrofit type lamps have shown minimal market penetration, they are offered by a number of different manufacturers. Their intended use is for a customer to be able to replace a lamp by inserting a new lamp type directly into their existing system, and get quick and convenient energy savings from such a switch. While they are not an option for every representative lamp type, DOE does identify some instances where they are viable for this analysis. These instances

are outlined in Table 5.6.4

.

DOE only found a few examples of reduced wattage retrofit lamps that met an EL above baseline. These lamps do not retain mean lumens within ten percent of baseline lamps like the reduced wattage lamp replacements, instead resulting in reduced light levels. However

, DOE still includes these lamps in the engineering analysis because they are specifically designed to replace the full wattage lamps , and they provide immediate energy savings to customers who use them.

DOE acknowledges that when these lamps are operating on the ballast, the ballast efficiency will decrease below full efficiency. DOE did not find any literature that quantified the exact impact on the ballast efficiency. Instead, DOE received input from manufacturers during the interview process, resulting in the decision to use a simple scalar rather than estimating second order impacts on ballast efficiency. The ballast efficiencies for these systems are calculated assuming that the total losses from the full wattage system would equal the total losses from the reduced wattage system. For example, if a 400 W ballast has an efficiency of 88.0% it would have about 54.5 W of losses. If a 360 W retrofit lamp was used with the 400 W ballast, DOE would assume that the 360 W system would have 54.5 W of losses and result in a ballast efficiency of 360/(360+54.5) or 86.9%.

Table 5.6.4 Retrofit Lamp s

Lamp Wattage Lamp Type Ballast Wattage Ballast Type Initial Efficacy (lm/W)

325 Probe

- start MH 400 MV 86.2

360 Probe

- start MH 400 Probe

- start MH 102.8

The other replacement path that does not require a change in ballast or fixture is replacing

the lamp with a compliant lamp that has increased efficacy at the same wattage. In this scenario,

customer s already have MH system s and when the lamps need to be replaced, they purchase more efficacious lamp s that are compatible with the existing system s. Doing so will result in the customer receiving more light output, with no energy savings. However because such a replacement is convenient and low- cost

, many customers are assumed to choose this replacement

5-19pathway. In this scenario, the ballast efficiency will remain the same as before the lamp was replaced

, because the ballast itself is not changed.

5.7 DETAILED DISCUSSION OF REPRESENTATIVE LAMP TYPES

The following sections discuss the criteria used and the lamp models selected for each of

the eight representative lamp types used in the engineering analysis.

5.7.1 100 W Mercury Vapor Representative Lamp Type

The 2800 K – 4500 K, 50 W

– 400 W representative equipment class contains five representative lamp types. In this section, DOE analyzes the 100 W MV representative lamp type for this equipment class.

5.7.1.1 Baseline Models

DOE selected baseline lamps as reference points from which DOE measured changes resulting from potential energy conservation standards. As discussed in section 5.3.1 , a baseline lamp is typically the most common, least efficacious lamp sold in a given equipment class. To determine energy savings and changes in price, DOE compared each higher EL with the baseline

unit.

DOE considered a number of criteria when selecting which commercially available lamp would serve as a baseline. First, as discussed in section 5.3.1 , DOE selected a 100 W MV lamp as a baseline lamp because MV lamps have the lowest efficacy among HID lamps, and 100 W is one of the most commonly shipped wattages of MV lamps. Then, DOE identified typical characteristics for these types of lamps ( i.e., CRI, rated life, bulb shape, base type, and operating orientation). Among all 100 W MV lamps within the representative equipment class that had the most common characteristics, DOE selected the least efficacious 100 W MV lamp as the

baseline. Table 5.7.1 describes the characteristics of the 100 W MV baseline lamp.

DOE also considered a MH baseline with similar characteristics, including mean lumen output, for the 100 W MV representative lamp type. This second baseline lamp was selected to account for the different high- volume lamps within the representative lamp type and their associated customer economics. Even though MV lamps are the least efficacious lamps in this equipment class, a large portion of the market has already transitioned from MV technology to MH technology. T he least efficacious MH lamp with similar characteristics to the 100 W MV

baseline was a 70 W quartz MH lamp.

5-20Table 5.7.1 Baseline Lamp s for the 100 W MV Representative Lamp Type

EL Lamp Type Wattage

W CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

Baseline MV 100 3900 40.0 2800 Universal

MH

Baseline /EL 1 S tandard E fficacy Quartz MH 70 3000 78.6 3000 Universal

5.7.1.2 Effic a cy Levels and More Efficacious Substitutes

As outlined in chapter 4 of this NOPD TSD , DOE identified several design options to improve the efficacy of MV and MH lamps. At the MV level, the only option DOE identified was a switch to a more efficacious technology, such as MH. At the MH level, the means to improve efficacy included the use of ceramic arc tubes, arc tube optimization, and fill gas optimization. These design options are the basis upon which DOE developed E Ls. Fina lly, D OE tentatively determined the maximum improvement in efficacy that was technologically feasible for HID lamps, as required by section 325(o) of EPCA. (42 U.S.C. 6295(o))

Table 5.7.2 Summary of the ELs for the 100 W MV Representative Lamp Type

EL Technology Level Initial Efficacy Requirement

MH Baseline /E L 1 Standard Efficacy Quartz MH lm/W = 38 .5 × W 0.1 350

E L 2 High Efficacy Quartz MH lm/W = 44.4 × W 0.1350

E L 3 CMH lm/W = 40.4 × W 0. 180 8

Figure 5.7.1 illustrates the three ELs on a plot with the representative units for the 100 W MV representative lamp type. The squares represent the representative units selected by DOE for each of the technologies in this representative lamp type, while the lines correspond to the three

E Ls.

5-21Figure 5.7.1 Effic a cy Levels for the 100 W MV Representative Lamp Type

Below, Table 5.7.3 summarizes the lamp designs for the 100 W MV baseline and the reduced wattage, increased efficacy replacement options. As discussed in section 5.4 , DOE also identified lamps compliant with each EL that did not require a change in wattage for customers who would opt not to reduce wattage as a result of standards. When available, DOE iden tified equal wattage options at higher ELs for each baseline lamp and reduced wattage replacement option below the max

- tech level . These equal wattage lamps are represented by black triangles in Figure 5.7.1 and are summarized in Table 5.7.4

.

Table 5.7.3 Lamp Designs for the 100 W MV Representative Lamp Type
- Reduced Wattage

EL Lamp Type Wattage W CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

Baseline MV 100 2800 40.0 2800 Universal

MH Baseline /E L 1 Standard Efficacy Quartz MH 70 3000 78.6 3000 Universal

EL2* N/A N/A N/A N/A N/A N/A

E L 3 CMH 50 2750 82.0 2750 Universal

* There are no EL2 lamps in this representative lamp type, but the EL2 equation is still applicable to this

wattage range. 0 20 40 60 80 100 120

45 50 55 60 65 70 75 80 85 90 95 100Initial Lamp Efficacy (lm/W)

Wattage (W) EL1

EL2

EL3
MV Baseline Representative Unit
MH Baseline/ EL 1 Representative Unit

EL 3 Representative Unit
Equal Wattage Units

5-22Table 5.7.4 Lamp Designs for the 100 W MV Representative Lamp Type - Equal Wattage

EL Lamp Type Wattage W CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

100 W MV Baseline

EL1 Standard Efficacy Quartz MH 100 4000 81.0 5800 Universal

EL2 High Efficacy Quartz MH 100 4200 84.0 5800 Universal

EL3 CMH 100 3000 95.0 7600 Universal

70 W Standard Efficacy Quartz MH EL1

EL2 High Efficacy Quartz MH 70 4000 80.0 3640 Universal

EL3 CMH 70 3000 88.6 4700 Universal

5-235.7.1.3 Engineering Summary

The following tables summarize the engineering characteristics for each baseline lamp and lamp replacement option in the 100 W MV representative lamp type.

Table 5.7.5 Engineering Summary for 100 W MV Representative Lamp Type - Reduced WattageELLamp TypeStarting MethodArc TubeWattageWCCTKInitial LumensInitial Efficacylm/WMean LumensChange in Mean LumensFrom Baseline%Mean Efficacylm/WOperating OrientationBulb FinishBallast TypeBallast Efficiency%Lamp-and-Ballast SystemPowerW

Baseline MV N/A N/A 100 3900 4000 40.0 2800 N/A 28.0 Universal Coated MV Magnetic 83.0 120.5

MH

Baseline /

E L 1 N/A Pulse Quartz 70 4000 5500 78.6 3000 +7.1% 42.9 Universal Clear MH Magnetic 78.2 89.5

E L 2 * N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

E L 3 MH Pulse Ceramic 50 3000 4100 82.0 2750

- 1.8% 55.0 Universal Clear MH

Electroni

c 89.0 56.2

* There are no EL2 lamps in this representative lamp type, but the EL2 equation is still applicable to this wattage range.

5-24Table 5.7.6 Engineering Summary for 100 W MV Representative Lamp Type - Equal WattageELLamp TypeStarting MethodArc TubeWattageWCCTKInitial LumensInitial Efficacylm/WMean LumensMean Efficacylm/WOperating OrientationBulb FinishBallast TypeBallast Efficiency%Lamp-and-BallastSystem PowerW

MH Baseline/EL 1 MH Pulse Quartz 100 4000 8100 81.0 5800 58.0 Universal Clear MH Magnetic 80.2 124.7

EL 2 N/A Pulse Quartz 100 4200 8400 84.0 5800 58.0 Universal Clear MH Magnetic 80.2 124.7

EL 3 MH Pulse Ceramic 100 3000 9500 95.0 7600 76.0 Universal Clear MH

Electronic 90.0 111.1

EL 2 MH Pulse Quartz 70 4000 5600 80.0 3600 52.0 Universal Clear MH Magnetic 78 .2 89.5

EL 3 MH Pulse Ceramic 70 3000 6200 88.6 4700 67.1 Universal Clear MH

Electronic 88.0 79.5

5-255.7.2 175 W Mercury Vapor Representative Lamp Type

The 2800 K – 4500 K CCT, 50 W

– 400 W representative equipment class contains five representative lamp types. In this section, DOE analyzes the 175 W MV representative lamp type for this equipment class.

5.7.2.1 Baseline Models

DOE selected baseline lamp s as reference points from which DOE measured changes resulting from potential energy conservation standards. As discussed in section 5.3.1 , a baseline lamp is typically the most common, least efficacious lamp sold in a given equipment class. To determine energy savings and changes in price, DOE compared each higher EL with the baseline

unit.

DOE considered a number of criteria when selecting which commercially available lamp would serve as a baseline. First, as discussed in section 5.3.1

, DOE selected a 1 75 W MV lamp as a baseline lamp because MV lamps have the lowest efficacy among HID lamps, and 175 W is one of the most commonly shipped wattages of MV lamps. Then, DOE identified typical characteristics for these types of lamps ( i.e., CRI, rated life, bul b shape, base type, and operating orientation). Among all 175 W MV lamps within the representative equipment class that had the most common characteristics, DOE selected the least efficacious 175 W MV lamp as the

baseline. Table 5.7.7 describes the characteristics of the 175 W MV baseline lamp.

DOE also considered a MH baseline with similar characteristics, including mean lumen output, for the 175 W MV representative lamp type. This second baseline lamp was selected to account for the different high- volume lamps within the representative lamp typ e and their associated customer economics. Even though MV lamps are the least efficacious lamps in this equipment class, a large portion of the market has already switched from MV technology to MH technology. The least efficacious MH lamp with similar char acteristics to the 175 W MV

baseline was a 150 W quartz MH lamp.

Table 5.7.7 Baseline Lamp s for the 175 W MV Representative Lamp Type

EL Lamp Type Wattage W CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

Baseline MV 175 3700 45.1 7400 Universal

MH Baseline /EL 1 Standard Efficacy Quartz MH 150 3000 86.0 8000 Universal

5.7.2.2 Effic a cy Levels and More Efficacious Substitutes

As outlined in chapter 4 of this NOPD TSD, DOE identified several design options to improve the efficacy of MV and MH lamps. At the MV level, the only option DOE identified was a switch to a more efficacious technology, such as MH. At the MH level, means to improve efficacy included use of ceramic arc tubes, arc tube optimizati on, and fill gas optimization . These design options are the basis upon which DOE developed E Ls. Finally, DOE tentatively

5-26determined the maximum improvement in efficacy that was technologically feasible for HID lamps, as required by section 325(o) of EPCA. (42 U.S.C. 6295(o))

Table 5.7.8 Summary of the EL s for the 175 W MV Representative Lamp Type

EL Technology Level Initial Efficacy Requirement

MH Baseline /E L 1 Standard Efficacy Quartz MH lm/W = 38.5 × W 0.1350

E L 2 High Efficacy Quartz MH lm/W = 44.4 × W 0.1350

E L 3 CMH lm/W = 40.4 × W 0.1808

Figure 5.7.2 illustrates the three E Ls on a plot with the representative units for the 175 W MV representative lamp type. The squares represent the representative units selected by DOE for

each of the tec hnologies in this representative lamp type, while the lines correspond to the three

E Ls.

Figure 5.7.2 Effic a cy Levels for the 175 W MV Representative Lamp Type

Table 5.7.9 summarizes the lamp designs for the 1 75 W MV baseline and the reduced wattage, increased efficacy replacement options. As discussed in section 5.4 , DOE also identified lamps compliant with each EL that did not require a change in wattage for customers who would opt not to reduce wattage as a result of standards. When available, DOE iden tified equal wattage 0 20 40 60 80 100 120

55 70 85 100 115 130 145 160 175 190Initial Lamp Efficacy (lm/W)

Wattage (W) EL1

EL2

EL3
MV Baseline Representative Unit MH Baseline/ EL 1 Representative Unit

EL 2 Representative Unit
EL 3 Representative Unit
Equal Wattage Units

5-27options at higher ELs for each baseline lamp and reduced wattage, increased efficacy replacement option below the max

- tech level . These equal wattage lamps are represented by black triangles in Figure 5.7.2 and are summarized in Table 5.7 .10

. When a row is marked as

“ N/A, ” it indicates a compliant lamp at that p articular wattage and EL was not commercially available within the representative equipment class

.

Table 5.7.9 Lamp Designs for the 1 75 W MV Representative Lamp Type
- Reduced Wattage

EL Lamp Type Wattage

W CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

Baseline MV 175 3700 45.1 7400 Universal

MH Baseline /E L 1 Standard Efficacy Quartz MH 150 3000 75.0 8000 Universal

EL 2 High Efficacy Quartz

MH 100 4000 68.0 7200 Universal

E L 3 CMH 75 3000 90.0 6708 Universal

Table 5.7.10 Lamp Designs for the 1 75 W MV Representative Lamp Type - Equal Wattage

EL Lamp Type Wattage

W CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

175 W MV Baseline

MH Baseline /EL 1 Standard Efficacy Quartz MH 175 4000 77.7 7400 Universal

EL 2 High Efficacy Quartz MH 175 4000 91.4 12

, 800 Universal

EL3 N/A N/A N/A N/A N/A N/A

150 W Standard Efficacy Quartz MH EL1

EL 2 High Efficacy Quartz MH 150 4300 93.3 11

, 000 Universal

EL 3 CMH 150 4200 100.0 10

, 500 Universal

100 W High Efficacy Quartz MH EL2

EL 3 CMH 100 3000 95.0 7600 Universal

5-285.7.2.3 Engineering Summary

The following tables summarize the engineering characteristics for each baseline lamp and lamp replacement option in the 175 W MV representative lamp type.

Table 5.7.11 Engineering Summary for 1 75 W MV Representative Lamp Type - Reduced WattageELLamp TypeStarting MethodArcTubeWattageWCCTKInitial LumensInitial Efficacylm/WMean LumensChange in Mean Lumens FromBaseline%Mean Efficacylm/WOperating OrientationBulb FinishBallast TypeBallast Efficiency%Lamp-and-Ballast SystemPowerW

Baseline MV N/A N/A 175 3700 7900 45.1 7400 N/A 42.3 Universal Coated MV Magnetic 85.0 205.9

MH Bas eline/

EL 1 MH Pulse Quartz 150 3000 12900 86.0 8000 + 8.1 53.3 Universal Clear MH Magnetic 82.4 182.0

EL 2 MH Pulse Quartz 100 4000 9000 90.0 7200

- 2.7 72.0 Universal Clear MH Magnetic 80.2 124.7

EL 3 MH Pulse Ceramic 70 3000 7800 111.4 6700

- 9.4 95.8 Universal Clear MH

Electronic 88.0 79.5

5-29Table 5.7.12 Engineering Summary for 1 7 5 W MV Representative Lamp Type - Equal WattageELLamp TypeStarting MethodArc TubeWattageWCCTKInitial LumensInitial Efficacylm/WMean LumensChange in Mean Lumens FromBaseline%Mean Efficacylm/WOperating OrientationBulb FinishBallast TypeBallast Efficiency%Lamp-and-Ballast SystemPowerW

MH Baseline/

EL 1 MH Probe Quartz 175 4000 13,600 77.7 7400 N/A 42.3 Universal Clear MH Magnetic 88.0 198.9

EL 2 MH Probe Quartz 175 4000 16,000 91.4 12,800 +73.0 73.1 Universal Clear MH Magnetic 88.0 198.9

EL 2 MH Pulse Quartz 150 4300 14,000 93,3 11,000 +48.6 73.3 Universal Clear MH Magnetic 82.4 182.0

EL 3 MH Pulse Ceramic 150 4200 15,000 100.0 10,500 +41.9 70.0 Universal Clear MH

Electronic 92.1 162.9

EL 3 MH Pulse Ceramic 100 3000 9500 95.0 7600 +2.7 76.0 Universal Clear MH

Electronic 90.0 111.1

5-305.7.3 250 W Mercury Vapor Representative Lamp Type

The 2800 K – 4500 K CCT, 50 W

– 400 W representative equipment class contains five representative lamp types. In this section, DOE analyzes the 250 W MV representative lamp type for this equip ment class.

5.7.3.1 Baseline Models

DOE selected baseline lamp s as reference points from which DOE measured changes resulting from potential energy conservation standards. As discussed in section 5.3.1 , a baseline lamp is typically the most common, least efficacious lamp sold in a given equipment class. To determine energy savings and changes in price, DOE compared each higher EL with the baseline

unit.

DOE considered a nu mber of criteria when selecting which commercially available lamp would serve as a baseline. First, as discussed in section 5.3.1 , DOE selected a 250 W MV lamp as a baseline lamp because MV lamps have the lowest efficacy among HID lamps, and 250 W is one of the most commonly shipped wattages of MV lamps. Then, DOE identified typical characteristics for these types of lamps ( i.e., CRI, rated life, bulb shape, base type, and operating orientation). Among all 250 W MV lamps within the representative equipment class that had the most common characteristics, DOE selected the least efficacious 250 W MV lamp as the

baseline. Table 5.7.13 describes the characteristics of the 250 W MV baseline lamp.

DOE also considered a MH baseline with similar characteristics, including mean lumen output, for the 250 W MV representative lamp type. This second baseline lamp was selected to account for the different high- volume lamps within the representative lamp type and their associated customer economics. Even though MV lamps are the least efficacious lamps in this equipment class, a large portion of the market has already switched from MV technology to MH technology. As described in section 5.3.1 , the least efficacious MH lam p with similar

characteristics to the 250 W MV baseline was a 175 W quartz MH lamp.

Table 5.7.13 Baseline Lamp s for the 250 W MV Representative Lamp Type

EL Lamp Type Wattage

W CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

Baseline MV 250 3900 44.8 7840 Universal

MH Baseline

/EL 1 Standard Efficacy Quartz MH 175 4000 77.7 7400 Universal

5.7.3.2 Effic a cy Levels and More Efficacious Substitutes

As outlined in chapter 4 of this NOPD TSD , DOE identified several design options to improve the efficacy of MV and MH lamps. At the MV level, the only option DOE identified was a switch to a more efficacious technology, such as MH. At the MH level, means to improve efficacy included use of cerami c arc tubes, arc tube optimization, and fill gas optimization . These

5-31design options are the basis upon which DOE developed E Ls. Finally, DOE tentatively determined the maximum improvement in efficacy that was technologically feasible for HID lamps, as requ ired by section 325(o) of EPCA. (42 U.S.C. 6295(o))

Table 5.7.14 Summary of the EL s for the 250 W MV Representative Lamp Type

EL Technology Level Initial Efficacy Requirement

MH Baseline /E L 1 Standard Efficacy Quartz MH lm/W = 38.5 × W 0.1350

E L 2 High Efficacy Quartz MH lm/W = 44.4 × W 0.1350

E L 3 CMH lm/W = 40.4 × W 0.1808

Figure 5.7.3 illustrates the three E Ls on a plot with the representative units for the 250 W MV representative lamp type. The squares represent the representative units selected by DOE for each of the four technologies in this representative lamp type, while the lines correspond to the

three E Ls.

Figure 5.7.3 Effic a cy Levels for the 250 W MV Representative Lamp Type

Table 5.7.15 summarizes the lamp designs for the 250 W MV baseline and the reduced wattage, increased efficacy replacement options. As discussed in section 5.4 , DOE also ident ified lamps compliant with each EL that did not require a change in wattage for customers who would opt not to reduce wattage as a result of standards. When available, DOE identified equal wattage 0 20 40 60 80 100 120

75 100 125 150 175 200 225 250 275Initial Lamp Efficacy (lm/W)

Wattage (W) EL1

EL2

EL3 MV Baseline Representative Unit MH Baseline/ EL 1 Representative Unit

EL 2 Representative Unit
EL 3 Representative Unit Equal Wattage Units

5-32options at higher ELs for each baseline lamp and reduced wa ttage, increased efficacy replacement option below the max

- tech level . These equal wattage lamps are represented by black triangles i n Figure 5.7.3 and are summarized in Table 5.7 .16

. When a row is marked as

“ N/A, ” it indicates a compliant lamp at that particular wattage and EL was not commercially available within the representative equipment class.

Table 5.7.15 Lamp Designs for the 250 W MV Representative Lamp Type
- Reduced Wattage

EL Lamp Type Wattage

W CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

Baseline MV 250 3900 44.8 7840 Universal

MH Baseline /E L 1 Standard Efficacy Quartz MH 175 4000 77.7 7400 Universal

EL 2 High Efficacy Quartz

MH 150 4000 90.0 7200 Universal

E L 3 CMH 100 3700 100.0 8000 Universal

Table 5.7.16 Lamp Designs for the 250 W MV Representative Lamp Type - Equal Wattage

EL Lamp Type Wattage

W CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

250 W MV Baseline

MH

Baseline/EL 1 Standard Efficacy Quartz MH 250 4000 82.0 13

, 500 Universal

EL 2 High Efficacy Quartz

MH 250 4000 100.0 19

, 000 Universal

EL3 CMH 250 3700 112.0 23,800 Universal

175 W Standard Efficacy Quartz MH EL1

EL 2 High Efficacy Quartz

MH 175 4000 91.4 4000 Universal

EL3 N/A N/A N/A N/A N/A N/A

150 W High Efficacy Quartz MH EL2

EL 3 CMH 150 4200 100.0 10

, 500 Universal

5-335.7.3.3 Engineering Summary

The following tables summarize the engineering characteristics for each baseline lamp and lamp replacement option in the 250 W MV representative lamp type.

Table 5.7.17 Engineering Summary for 250 W MV Representative Lamp Type - Reduced WattageELLamp TypeStarting MethodArc TubeWattageWCCTKInitial LumensInitial Efficacylm/WMean LumensChange in Mean LumensFrom Baseline%Mean Efficacylm/WOperating OrientationBulb FinishBallast TypeBallast Efficiency%Lamp-and-Ballast SystemPowerW

Baseline MV N/A N/A 250 3900 11,200 44.8 7800 N/A 31.4 Universal Coated MV Magnetic 87.0 287.4

MH

Baseline/

EL 1 MH Probe Quartz 175 4000 13,500 77.7 7400

- 5.6 42.3 Universal Clear MH Magnetic 88.0 198.9

EL 2 MH Probe Quartz 150 4000 13,500 90.0 7200

- 8.2 48.0 Universal Clear MH Magnetic 82.4 182.0

EL 3 MH Pulse Ceramic 100 3700 10,000 100.0 8000 + 2.0 80.0 Universal Clear MH

Electronic 90.0 111.1

5-34Table 5.7.18 Engineering Summary for 250 W MV Representative Lamp Type
- Equal WattageELLamp TypeStarting MethodArc TubeWattageWCCTKInitial LumensInitial Efficacylm/WMean LumensMean Efficacylm/WOperating OrientationBulb FinishBallast TypeBallast Efficiency%Lamp-and-BallastSystem PowerW

MH

Baseline/

EL 1 MH Probe Quartz 250 4000 20,500 82.0 13,500 54.0 Universal Clear MH Magnetic 88.8 281.5

EL 2 MH Pulse Quartz 250 4000 25,000 100.0 19,000 76.0 Universal Clear MH Magnetic 88.8 281.5

EL 3 MH Pulse Ceramic 250 3700 28,000 112.0 23,800 95.2 Universal Clear HPS Magnetic 84.0 297.6

EL 2 MH Probe Quartz 175 4000 16,000 91.4 12,800 73.1 Universal Clear MH Magnetic 88.0 198.9

EL 3 MH Pulse Ceramic 150 4200 15,000 100.0 10,500 70.0 Universal Clear MH

Electronic 92.1 108.6

5-355.7.4 400 W Mercury Vapor Representative Lamp Type

The 2800 K – 4500 K CCT, 50 W

– 400 W representative equipment class contains five representative lamp types. In this section, DOE analyzes the 400 W MV representative lamp type

for this e quipment class.

5.7.4.1 Baseline Models

DOE selected baseline lamp s as reference points from which DOE measured changes resulting from potential energy conservation standards. As discussed in section 5.3.1 , a baseline lamp is typically the most common, least efficacious lamp sold in a given equipment class. To determine energy savings and changes in price, DOE compared each higher EL with the baseline

unit.

DOE considered a number of criteria when selecting which commercially available lamp would serve as a baseline. First, as discussed in section 5.3.1 , DOE selected a 400 W MV lamp as a baseline lamp because MV lamps have the lowest efficacy among HID lamps, and 400 W is one of the most commonly shipped wattages of MV lamps. Then, DOE identified typical characteristics these types of lamps ( i.e., CRI, rated life, bulb shape, base type, and operating orientation). Among all 400 W MV lamps within the representative equipment class that had these common characteristics, DOE selected the least efficacious 400 W MV lamp as a baseline.

Table 5.7.19 describes the characteristics of the 400 W MV baseline lamp.

DOE also considered a MH baseline with similar characteristics, including mean lumen output, for the 400 W MV representative lamp type. This second baseline lamp was selected to account for the different high- volume lamps within the representative lamp type and their associated customer economics. Even though MV lamps are the least efficacious lamps in this equip ment class, a large portion of the market has already switched from MV technology to MH technology. As described in section 5.3.1 , the least efficacious MH lamp wi th similar

characteristics to the 400 W MV baseline was a 250 W quartz MH lamp.

Table 5.7.19 Baseline Lamp s for the 400 W MV Representative Lamp Type

EL Lamp Type Wattage

W CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

Baseline MV 400 3900 56.5 15

, 820 Universal

MH Baseline /EL 1 Standard Efficacy Quartz MH 250 3800 88.0 15

, 400 Universal

5.7.4.2 Effic a cy Levels and More Efficacious Substitutes

As outlined in chapter 4 of this NOPD TSD, DOE identified several design options to improve the efficacy of MV and MH lamps. At the MV level, the only option DOE identified was a switch to a more efficacious technology, such as MH. At the MH level, means to improve efficacy included use of ceramic arc tubes, arc tube optimization, and fill gas optimization . These design options are the basis upon which DOE developed E Ls. Finally, DOE tentatively

5-36determined the maximum improvement in efficacy that was technologically feasible for HID lamps, as required b y section 325(o) of EPCA. (42 U.S.C. 6295(o))

Table 5.7.20 Summary of the EL s for the 400 W MV Representative Lamp Type

EL Technology Level Initial Efficacy Requirement

MH Baseline /E L 1 Standard Efficacy Quartz MH lm/W = 38.5 × W 0.1350

E L 2 High Efficacy Quartz MH lm/W = 44.4 × W 0.1350

E L 3 CMH lm/W = 40.4 × W 0.1808

Figure 5.7.4 illustrates the three E Ls on a plot with the representative units for the 400 W MV representative lamp type. The squares represent the representative units selected by DOE for

each of the fou r technologies in this representative lamp type, while the lines correspond to the

three E Ls. Note that the 250 W EL3 lamp is shown as both an EL3 representative unit and an equal wattage unit. This is because the 250 W CMH lamp can serve as the EL3 representative unit that is reduced wattage compared to the 400 W MV baseline, but it can also serve as the EL3 equal wattage unit compared to the 250 W MH baseline/EL1 representative unit.

Figure 5.7.4 Effic a cy Levels for the 400 W MV Representative Lamp Type 0 20 40 60 80 100 120

125 150 175 200 225 250 275 300 325 350 375 400Initial Lamp Efficacy (lm/W)

Wattage (W) EL1

EL2

EL3 MV Baseline Representative Unit MH Baseline/ EL 1 Representative Unit
EL 2 Representative Unit EL 3 Representative Unit Equal Wattage Units

5-37Table 5.7.21 summarizes the lamp designs for the 400 W MV baseline and the reduced wattage, increased efficacy rep lacement options. DOE notes that when looking for EL3 lamps with a reduced wattage from EL2, none were found that had mean lumens within ten percent of the baseline. The reduced wattage lamp with mean lumens closest to the 400 W MV baseline lamp was a 150 W CMH lamp with over 20 percent fewer mean lumens. Because this EL3 lamp selection had a reduced mean lumen output compared to baseline that exceeded the ten percent threshold, DOE also identified an EL3 lamp that increased the mean lumen output by more than the ten percent threshold at 250 W. Both of these EL3 lamps were used as replacement options for the 400 W MV representative lamp type.

As discussed in section 5.4 , DOE also identified lamps compliant with each EL that did not require a change in wattage for customers who would opt not to reduce wattage as a result of

standards. When available, DOE identified equal wattage options at higher ELs for each baseline lamp and reduced wattage, increased efficacy replacement option below the max

- tech level

. These equal wattage lamps are represented by black triangles in Figure 5.7 .4 and are summarized

in Table 5.7.22

.

The 400 W MV representative lamp type also has a retrofit lamp as one of its reduced wattage options. This lamp can be used with the existing 400 W MV ballast and give a customer energy savings. See Table 5.7.21

. When a row is marked as ‘N/A’, it indicates a compliant lamp at that particular wattage and EL was not commercially available within the representative equipment class

.

Table 5.7.21 Lamp Designs for the 400 W MV Representative Lamp Type
- Reduced Wattage

EL Lamp Type Wattage

W CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

Baseline MV 400 3900 56.5 15

, 820 Universal

MH Baseline /EL 1 Standard Efficacy Quartz

MH 250 3800 88.0 15

, 400 Universal

EL 2 High Efficacy Quartz MH 200 4000 95.0 16

, 340 Horizontal

EL 3 CMH 150 3000 100.0 12

, 450 Universal

EL 3 CMH 250 * 3700 112.0 23

, 800 Universal

*A second EL3 unit was chosen to account for the customers who would find the 150 W EL 3 unit, which reduces mean lumens by more than ten percent, an unacceptable replacement.

5-38Table 5.7.22 L amp Designs for the 400 W MV Representative Lamp Type - Equal Wattage

EL Lamp Type Wattage

W CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

400 W MV Baseline

MH

Baseline/EL 1 Standard Efficacy Quartz MH 400 4000 90.0 23

, 400 Universal

EL 2 High Efficacy Quartz

MH 400 4000 100.0 32

, 000 Universal

EL3 N/A N/A N/A N/A N/A N/A

250 W Standard Efficacy Quartz MH EL1

EL 2 High Efficacy Quartz

MH 250 4000 100.0 19

, 000 Universal

EL3 CMH 250 3700 112.0 23,800 Universal

200 W High Efficacy Quartz MH EL2

EL3 N/A N/A N/A N/A N/A N/A

5-39Table 5.7.23 Lamp Designs for the 400 W MV Representative Lamp Type
- Retrofit Lamps

EL Lamp Type Wattage

W Ballast Wattage Ballast Type CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

MH Baseline/ EL 1 Standard Efficacy Quartz MH 325 400 MV 4000 86.2 12,200 Universal

5.7.4.3 Engineering Summary

The following tables summarize the engineering characteristics for each baseline lamp and lamp replacement option in the 400 W MV representative lamp type. At E L 3, a lamp was not commercially available that maintained mean lumens within 10 percent. While DOE sought to maintain higher-efficacy substitutes within 10 percent, in the absence of su ch lamps DOE acknowledges that customers are still going to purchase replacement lamps. DOE identified a lamp with more than 10 percent greater mean lumens and a lamp with less than 10 percent fewer mean lumens, assuming these would be the next best option s.

Table 5.7.24 Engineering Summary for 400 W MV Representative Lamp Type - Reduced WattageELLamp TypeStarting MethodArc TubeWattageWCCTKInitial LumensInitial Efficacylm/WMean LumensChange inMean LumensFrom Baseline%Mean Efficacylm/WOperating OrientationBulb FinishBallast TypeBallast Efficiency%Lamp-and-Ballast SystemPowerW

Baseline MV N/A N/A 400 3900 22,600 56.5 15,800 N/A 39.6 Universal Coated MV Magnetic 89.0 449.4

MH

Baseline

E L 1 MH Pulse Quartz 250 3800 22,000 88.0 15,400

- 2.7 61.6 Universal Clear MH Magnetic 88.8 281.5

E L 2 MH Pulse Quartz 200 4000 19,000 95.0 16,300 + 3.3 81.7 Horizontal Clear MH Magnetic 88.0 227.3

E L 3 MH Pulse Ceramic 150 3000 15,000 100.0 12,400

- 21.3 83.0 Universal Clear MH Electronic 92.1 162.9

EL 3 MH Pulse Ceramic 250 3700 28,000 112.0 23,800 + 50.4 95.2 Universal Clear HPS Magnetic 84.0 297.6

5-40Table 5.7.25 Engineering Summary for 400 W MV Representative Lamp Type - Equal WattageELLamp TypeStarting MethodArc TubeWattageWCCTKInitial LumensInitial Efficacylm/WMean LumensMean Efficacylm/WOperating OrientationBulb FinishBallast TypeBallast Efficiency%Lamp-and-Ballast SystemPowerW

MH Baseline/EL 1 MH Probe Quartz 400 4000 36,000 90.0 23,400 58.5 Universal Clear MH Magnetic 90.3 443.0

EL 2 MH Probe Quartz 400 4000 40,000 100.0 32,000 80.0 Universal Clear MH Magnetic 90.3 443.0

EL 2 MH Pulse Quartz 250 4000 25,000 100.0 19,000 76.0 Universal Clear MH Magnetic 88.8 281.5

Table 5.7.26 Engineering Summary for 40 0 W MV Representative Lamp Type
- Retrofit LampsELLamp TypeStarting MethodArc TubeWattageWCCTKInitial LumensInitial Efficacylm/WMeanLumensChange inMeanLumensFromBaseline%Mean Efficacylm/WOperating OrientationBulb FinishBallast TypeBallast Efficiency%Lamp-and-Ballast SystemPowerW

MH

Baseline/

E L 1 MH Probe Quartz 325 4000 28,000 86.2 12,200

- 22.7 37.5 Universal Clear MV Magnetic 86.8 374.4

5-415.7.5 400 W Metal Halide Representative Lamp Type

The 2800 K – 4500 K CCT, 50 W

– 400 W representative equipment class contains five representative lamp types. In this section, DOE analyzes the 400 W MH representative lamp type for this equipment class.

5.7.5.1 Baseline Models

DOE selected baseline lamp s as reference points from which DOE measured changes resulting from potential energy conservation standards. As discussed in section 5.3.1 , a baseline lamp is typically the most common, least efficacious lamp sold in a given equipment class. To determine energy savings and changes in price, DOE compared each higher EL with the baseline

unit.

DOE considered a number of criteria when selecting which commercially available lamp would serve as a baseline lamp. First, as discussed in section 5.3.1 , DOE selected a 400 W MH lamp as a baseline lamp because of its relatively high shipment volume. Then, DOE identified typical characteristics for these types of lamps ( i.e., CRI, rated life, bulb shape, base type, and operating orientation). Unlike the other four representative lamp types in this equipment class, DOE only included one baseline lamp. While a 400 W MH baseline lamp did not match any of the lumen packages of a MV baseline, because of its high shipment volume a 400 W MH baseline was analyzed. Among all 400 W MH lamps within the representative equipment class that had the most common characteristics, DOE selected the least efficacious 400 W MH lamp as

the baseline. Table 5.7.27 describes the characteristics of the 400 W MH baseline lamp.

Table 5.7.27 Baseline Lamp s for the 400 W MH Representative Lamp Type

EL Lamp Type Wattage

W CCT

K Initial

Lumens Initial Efficacy

lm/W Mean

Lumens Mean Efficacy

lm/W Operating

Orientation

MH

Baseline/

E L 1 Standard Efficacy Quartz

MH 400 4000 36,000 90.0 24,000 60.0 Universal

5.7.5.2 Effic a cy Levels and More Efficacious Substitutes

As outlined in chapter 4 of this NOPD TSD, DOE identified several design options to improve the efficacy of standard efficacy MH lamps . These design options include use of ceramic arc tubes, arc tube optimization, and fill gas optimization, and are the b as is upon which DOE developed ELs and optimizing arc tube constructi on and switching from quartz arc tubes to ceramic arc tubes. Finally, DOE tentatively determined the maximum improvement in efficacy that is technologically feasible for HID lamps, as requir ed by section 325(o) of EPCA. (42 U.S.C. 6295 (o))

5-42Table 5.7.28 Summary of the EL s for the 400 W MH Representative Lamp Type

EL Technology Level Initial Efficacy Requirement

MH Baseline/ E L 1 Standard Efficacy Quartz MH lm/W = 38.5 × W 0.1350

E L 2 High Efficacy Quartz MH lm/W = 44.4 × W 0.1350

E L 3 CMH lm/W = 40.4 × W 0.1808

Figure 5.7.5 illustrates the three ELs on a plot with the representative units for the 400 W MH representative lamp type. The squares represent the representative units selected by DOE for each of the three technologies in this representative lamp type, while the lines correspond to the

three E Ls.

Figure 5.7.5 Effic a cy Levels for the 400 W MH Representative Lamp Type

Table 5.7.29 summarizes the lamp designs for the 400 W MH baseline and the reduced wattage, increased efficacy replacement options. As discussed in section 5.4 , DOE also identified lamps compliant with each EL that did not require a change in wattage for customers who would opt not to reduce wattage as a result of standards. When available, DOE identified equal wattage options at higher ELs for each baseline lamp and reduced wattage, increased efficacy replacement option below the max

- tech level . These equal wattage lamps are represented by black triangles in Figure 5.7.5 and are summarized in Table 5.7 .30

. When a row is marked as 0 20 40 60 80 100 120

225 250 275 300 325 350 375 400Initial Lamp Efficacy (lm/W)

Wattage (W) EL1

EL2

EL3 MH Baseline/ EL 1 Representative Unit

EL 2 Representative Unit

EL 3 Representative Unit
Equal Wattage Units

5-43“ N/A, ” it indicates a compliant lamp at that particular wattage and EL was not commercially available within the representative equipment class

.

The 400 W MH representative lamp type also has a retrofit lamp as one of its reduced wattage options. This lamp can be used with the existing 400 W MH ballast and give a customer energy savings. See Table 5.7.31

.

Table 5.7.29 Lamp Designs for the 400 W MH Representative Lamp Type
- Reduced Wattage

EL Lamp Type Wattage

W CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

MH

Baseline/E L 1 Standard Efficacy Quartz MH 400 4000 90.0 24

, 000 Universal

EL 2 High Efficacy Quartz MH 320 4000 96.9 26

, 000 Universal

E L 3 CMH 250 3700 112.0 23

, 800 Universal

Table 5.7.30 Lamp Designs for the 400 W MH Representative Lamp Type - Equal Wattage

EL Lamp Type Wattage

W CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

400 W Standard Efficacy Quartz MH EL1

EL 2 High Efficacy Quartz MH 400 4000 100.0 32

, 000 Universal

EL3 N/A N/A N/A N/A N/A N/A

320 W High Efficacy Quartz MH EL2

EL3 N/A N/A N/A N/A N/A N/A

5-44Table 5.7.31 Lamp Designs for the 400 W MH Representative Lamp Type
- Retrofit Lamps

EL Lamp Type Wattage

W Ballast Wattage Ballast Type CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

EL 2 High Efficacy Quartz MH 360 400 Probe

- start MH 4000 102.8 23,000 Base Up

5.7.5.3 Engineering Summary

The following tables summarize the engineering characteristics for each baseline lamp and lamp replacement option in the 400 W MH representative lamp type.

Table 5.7.32 Engineering Summary for 400 W MH Representative Lamp Type - Reduced WattageELLamp TypeStarting MethodArc TubeWattageWCCTKInitial LumensInitial Efficacylm/WMean LumensChange in Mean LumensFrom Baseline%MeanEfficacylm/WOperating OrientationBulb FinishBallast TypeBallast Efficiency%Lamp-and-Ballast SystemPowerW

Baseline N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

MH

Baseline

/E L 1 MH Probe Quartz 400 4000 36,000 90.0 24,000 N/A 60.0 Universal Clear MH Magnetic 86.0 465.1

E L 2 MH Pulse Quartz 320 4000 31,000 96.9 26,000 + 8.3 81.3 Universal Clear MH Magnetic 89.6 357.1

E L 3 MH Pulse Ceramic 250 3700 28,000 112.0 23,800

- 0.8 95.2 Universal Clear HPS Magnetic 84.0 297.6

5-45Table 5.7.33 Engineering Summary for 400 W MH Representative Lamp Type - Equal WattageELLamp TypeStarting MethodArc TubeWattageWCCTKInitialLumensInitial Efficacylm/WMean LumensMean Efficacylm/WOperating OrientationBulb FinishBallast TypeBallast Efficiency%Lamp-and-Ballast SystemPowerW

EL 2 MH Probe Quartz 400 4000 40,000 100.0 32,000 80.0 Universal Clear MH Magnetic 90.3 443.0

Table 5.7.34 Engineering Summary for 40 0 W MH Representative Lamp Type
- Retrofit LampsELLamp TypeStarting MethodArc TubeWattageWCCTKInitial LumensInitial Efficacylm/WMean LumensChange inMeanLumensFromBaseline%Mean Efficacylm/WOperating OrientationBulb FinishBallast TypeBallast Efficiency%Lamp-and-Ballast SystemPowerW

EL 2 MH Probe Quartz 360 4000 37,000 102.8 23,000

- 4.2 63.9 Base Up Clear MH Magnetic 84.7 425.0

5-465.7.6 1000 W Mercury Vapor Representative Lamp Type

The 2800 K – 4500 K CCT, 401 W

– 1000 W representative equipment class contains two representative lamp types. In this section, DOE analyzes the 1000 W MV representative lamp type for this equipment class.

5.7.6.1 Baseline Models

DOE selected baseline lamp s as reference points from which DOE measured changes resulting from potential energy conservation standards. As discussed in section 5.3.1 , a baseline lamp is typically the most common, least efficacious lamp sold in a given equipment class. To determine energy savings and changes in price, DOE compared e ach higher EL with the baseline

unit.

DOE considered a number of criteria when selecting which commercially available lamp would serve as a baseline. First, as discussed in section 5.3.1 , DOE selected a 1000 W MV lamp as a baseline lamp because MV lamps have the lowest efficacy among HID lamps, and 1000 W is one of the most commonly shipped wattages of MV lamps. Then, DOE ide ntified typical characteristics for these types of lamps ( i.e., CRI, rated life, bulb shape, base type, and operating orientation). Among all 1000 W MV lamps within the representative equipment class that had the most common characteristics, DOE selected the least efficacious 1000 W MV lamp as the

baseline. Table 5.7.35 describes the characteristics of the 1000 W MV baseline lamp.

Table 5.7.35 Baseline Lamp s for the 1000 W MV Representative Lamp Type

EL Lamp Type Wattage

W CCT

K Initial

Lumens Initial Efficacy

lm/W Mean

Lumens Mean Efficacy

lm/W Operating

Orientation

Baseline MV 1000 4000 58,000 58.0 49

, 500 48.5 Universal

MH

Baseline/

EL 1 Standard Efficacy Quartz

MH 750 4000 68,000 90.7 47

, 600 63.5 Horizontal

5.7.6.2 Effic a cy Levels and More Efficacious Substitutes

As outlined in chapter 4 of this NOPD TSD , DOE identified several design options to improve the efficacy of MV and MH lamps. At the MV level, the only option DOE identified was a switch to a more efficacious technology, such as MH. At the MH level, the only means to improve efficacy was arc tube optimization and fill gas optimization, because CMH lamps are not commercially available at these wattages. T hese design options are the basis upon which DOE developed ELs. Finally, DOE tentatively determined the maximum improvement in efficacy that was te chnologically feasible for HID lamps, as required by section 325(o) of EPCA. (42 U.S.C. 6295 (o))

5-47Table 5.7.36 Summary of the EL s for the 1000 W MV Representative Lamp Type

EL Technology Level Initial Efficacy Requirement

MH Baseline/ E L 1 Standard Efficacy Quartz MH lm/W = 0.0116 × W + 81.8

E L 2 High Efficacy Quartz MH lm/W = 0.0173 × W + 92.8

Figure 5.7.6 illustrates the two ELs on a plot with the representative units for the 1000 W MV representative lamp type. The squares represent the representative units selected by DOE for

each of the two technologies in this representative lamp type, while the lines correspond to the

two E Ls.

Figure 5.7.6 Effic a cy Levels for the 1000 W MV Representative Lamp Type 0 20 40 60 80 100 120

400 450 500 550 600 650 700 750 800 850 900 950 1000Initial Lamp Efficacy (lm/W)

Wattage (W) EL1

EL2

EL3
MV Baseline Representative Unit
MH Baseline/ EL 1 Representative Unit

EL 2 Representative Unit

Equal Wattage Units

5-48Table 5.7.37 summarizes the lamp designs for the 1000 W MV baseline and the reduced wattage, increased efficacy replacement options. As discussed in section 5.4 , DOE also identified lamps compliant with each EL that did not require a change in wattage for customers who would opt not to reduce wattage as a result of standards. When available, DOE identified equal wattage options at higher ELs for each baseline lamp and reduced wattage, increased efficacy replacement option below the max

- tech level

. These equal wattage lamps are represented by black triangles in Figure 5.7 .6 and are summarized in Table 5.7.38

.

Table 5.7.37 Lamp Designs for the 1000 W MV Representative Lamp Type - Reduced Wattage

EL Lamp Type Wattage

W CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

Baseline MV 1000 4000 58.0 48

, 500 Universal

MH Baseline /E L 1 Standard Efficacy Quartz MH 750 4000 90.7 47

, 600 Horizontal

EL 2 High Efficacy Quartz MH 575 4000 104.3 48

, 000 Base Up

Table 5.7.38 Lamp Designs for the 1000 W MV Representative Lamp Type - Equal Wattage

EL Lamp Type Wattage

W CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

1000 W MV Baseline

MH Baseline /EL 1 Standard Efficacy Quartz MH 1000 3400 110 .0 77

, 000 Horizontal

EL 2 High Efficacy Quartz MH 1000 3700 115.0 82

, 000 Universal

750 W Standard Efficacy Quartz MH EL1

EL 2 High Efficacy Quartz MH 750 4000 106.7 76

, 000 Universal

5-495.7.6.3 Engineering Summary

The following tables summarize the engineering characteristics for each baseline lamp and lamp replacement option in the 1000 W MV representative lamp type.

Table 5.7.39 Engineering Summary for 1000 W MV Representative Lamp Type - Reduced WattageELLamp TypeStarting MethodArc TubeWattageWCCTKInitial LumensInitial Efficacylm/WMean LumensChange in Mean LumensFrom Baseline%Mean Efficacylm/WOperating OrientationBulb FinishBallast TypeBallast Efficiency%Lamp-and-Ballast SystemPowerW

Baseline MV N/A N/A 1000 4000 58,000 58.0 48,500 N/A 48.5 Universal Coated MV Magnetic 92.0 1087.0

MH

Baseline/

E L 1 MH Pulse Quartz 750 4000 68,000 90.7 47,600

- 1.9 63.5 Horizontal Clear MH Magnetic 91.0 824.2

E L 2 MH Pulse Quartz 575 4000 60,000 104.3 48,000

- 1.0 83.5 Base Up Clear MH Magnetic 91.0 631.9

5-50Table 5.7.40 Engineering Summary for 1000 W MV Representative Lamp Type - Equal WattageELLamp TypeStarting MethodArc TubeWattageWCCTKInitial LumensInitial Efficacylm/WMean LumensChange in MeanLumensFrom Baseline%Operating OrientationBulb FinishBallast TypeBallast Efficiency%Lamp-and-Ballast SystemPowerW

MH

Baseline/EL 1 MH P uls e Quartz 1000 34 00 1 10 ,000 1 10 .0 79,000 +62.9 Horizont al Clear MH Magnetic 93.6 1068.4

EL 2 MH Probe Quartz 1000 3700 115,000 115.0 82,000 +69.1 Universal Clear MH Magnetic 93.6 1068.4

EL 2 MH Pulse Quartz 750 4000 80,000 106.7 76,000 +56.7 Universal Clear MH Magnetic 91.0 824.2

5-515.7.7 1000 W Metal Halide Representative Lamp Type

The 2800 K – 4500 K CCT, 401 W

– 1000 W representative equipment class contains two representative lamp types. In this section, DOE analyzes the 1000 W MH representative lamp type for this equipment class.

5.7.7.1 Baseline Models

DOE selected baseline lamp s as reference points from which DOE measured changes resulting from potential energy conservation standards. As discussed in section 5.2, a baseline lamp is typically the most common, least efficacious lamp sold in a given equipment class. To determine energy savings and chang es in price, DOE compared each higher EL with the baseline

unit.

DOE considered a number of criteria when selecting which commercially available lamp would serve as a baseline. First, as discussed in section 5.3.1 , DOE selected a 1000 W MH lamp as a baseline lamp because of its relatively high shipment volume. Then, DOE identified typical characteristics for these types of lamps ( i.e., CRI, rated life, bulb shape, base type, and operating orientation). Unlike the other representative lamp type in this equipment class, DOE only included one baseline lamp. A 1000 W MH baseline lamp did not match any of the lumen packages of a MV baseline, but because of its high shipment volume, a 1000 W MH baseline was analyzed. Among all 1000 W MH lamps within the representative equipment class that had the most common characteristics, DOE selected the least efficacious 1000 W MH lamp as the

baseline. Table 5.7.41 describes the characteristics of the 1000 W MH baseline lamp.

Table 5.7.41 Baseline Lamps for the 1000 W MH Representative Lamp Type

EL Lamp Type Wattage

W CCT

K Initial

Lumens Initial Efficacy

lm/W Mean

Lumens Mean Efficacy

lm/W Operating

Orientation

MH

Baseline /

EL 1 Standard Efficacy Quartz

MH 1000 3400 110,000 110.0 77,000 77.0 Horizontal

5.7.7.2 Effic a cy Levels and More Efficacious Substitutes

As outlined in chapter 4 of th is NOPD TSD , DOE identified several design options to improve the efficacy of MH lamps. The only means to improve efficacy for this representative lamp type was arc tube optimization and fill gas optimization, because CMH lamps are not commercially available at these wattages. These design options are the basis upon which DOE developed E Ls. Finally, DOE tentatively determined the maximum improvement in efficacy that was technologically feasible for HID lamps, as required by section 325(o) of EPCA (42 U.S.C. 6295 (o))

5-52Table 5.7.42 Summary of the EL s for the 1000 W MH Representative Lamp Type

EL Technology Level Initial Efficacy Requirement

MH Baseline/ E L 1 Standard Efficacy Quartz MH lm/W = 0.0116 × W + 81.8

E L 2 High Efficacy Quartz MH lm/W = 0.0173 × W + 92.8

Figure 5.7.7 illustrates the two ELs on a plot of the 1000 W MH representative lamp type. The squares represent the representative units selected by DOE for each of the two technologies in this representa tive lamp type, while the lines correspond to the two E Ls.

Figure 5.7.7 Effic a cy Levels for the 1000 W MH Representative Lamp Type 0 20 40 60 80 100 120

400 450 500 550 600 650 700 750 800 850 900 950 1000Initial Lamp Efficacy (lm/W)

Wattage (W) EL1

EL2

EL3

MH Baseline/ EL 1 Representative Unit

EL 2 Representative Unit

Equal Wattage Units

5-53Below, Table 5.7.43 summarizes the lamp designs for the 1000 W MH baseline and the reduced wattage, increased efficacy replacement options. As discussed in section 5.4 , DOE also identified lamps compliant with each EL that did not require a change in wattage for customers who would opt not to reduce wattage as a result of standards. When available, DOE identified equal wat tage options at higher ELs for each baseline lamp and reduced wattage, increased efficacy replacement option below the max

- tech level

. These equal wattage lamps are represented by black triangles in Figure 5.7 .7 and are summarized in Table 5.7.44

.

Table 5.7.43 Lamp Designs for the 1000 W MH Representative Lamp Type - Reduced Wattage

EL Lamp Type Wattage

W CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

MH Baseline /E L 1 Standard Efficacy Quartz MH 1000 3400 110.0 77

, 000 Horizontal

EL 2 High Efficacy Quartz MH 875 4000 109.7 82

, 500 Universal

Table 5.7.44 Lamp Designs for the 1000 W MH Representative Lamp Type - Equal Wattage

EL Lamp Type Wattage

W CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

1000 W Standard Efficacy Quartz MH EL1

EL 2 High Efficacy Quartz MH 1000 3700 115.0 82

, 000 Universal

5-545.7.7.3 Engineering Summary

The following tables summarize the engineering characteristics for each baseline lamp and lamp replacement option in the 1000 W MH representative lamp type.

Table 5.7.45 Engineering Summary for 1000 W MH Representative Lamp Type - Reduced WattageELLamp TypeStarting MethodArc TubeWattageWCCTKInitial LumensInitial Efficacylm/WMean LumensChange in Mean Lumens FromBaseline%Mean Efficacylm/WOperating OrientationBulb FinishBallast TypeBallast Efficiency%Lamp-and-BallastSystem PowerW

Baseline N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Baseline/

E L 1 MH Pulse Quartz 1000 3400 110,000 110.0 77,000 N/A 77.0 Horizontal Clear MH Magnetic 91.8 1089.3

E L 2 MH Pulse Quartz 875 4000 96,000 109.7 82,500 + 7.1 94.3 Universal Clear MH Magnetic 92.3 948.0

5-55Table 5.7.46 Engineering Summary for 1000 W MH Representative Lamp Type - Equal WattageELLamp TypeStarting MethodArc TubeWattageWCCTKInitial LumensInitial Efficacylm/WMean LumensMean Efficacylm/WOperating OrientationBulb FinishBallast TypeBallast Efficiency%Lamp-and-BallastSystemPowerW

E L 2 MH Probe Quartz 1000 3700 115,000 115.0 82,000 82.0 Universal Clear MH Magnetic 93.6 1068.4

5-565.7.8 2000 W Metal Halide Representative Lamp Type

The 2800 K – 4500 K, 1001 W

– 2000 W representative equipment class contains one representative lamp type. In this section, DOE analyzes the 2000 W MH representative lamp

type.

5.7.8.1 Baseline Models

DOE selected baseline lamp s as reference points f rom which DOE measured changes resulting from potential energy conservation standards. As discussed in section 5.3.1 , a baseline lamp is typically the most common, least efficacious lamp sold in a given equipment class. To determine energy savings and changes in price, DOE compared each higher EL with the baseline

unit.

DOE considered a number of criteria when selecting which commercially available lamp would serve as a baseline. First, as discussed in section 5.3.1 , DOE selected a 2000 W MH lamp to capture the highest wattage analyzed in this NOPD. Then, DOE identified typical characteristics for these types of lamps ( i.e., CRI, rated life, bulb shape, base type, and operating orientation). Among all 2000 W MH lamps within the repr esentative equipment class that had the most common characteristics, DOE selected the least efficacious 2000 W MH lamp as the

baseline. Table 5.7.47 describes the cha racteristics of the 2000 W MH baseline lamp. As mentioned previously, DOE would have preferred to have the baseline lamp be of universal operating orientation. However, none of the 2000 W HID lamps commercially available is advertised as universal operatin g orientation.

Table 5.7.47 Baseline Lamp for the 2000 W MH Representative Lamp Type

EL Lamp Type Wattage

W CCT

K Initial

Lumens Initial Efficacy

lm/W Mean

Lumens Mean Efficacy

lm/W Operating

Orientation

Baseline Standard Efficacy Quartz

MH 2000 4000 170,000 85.0 153,000 76.5 Horizontal

5.7.8.2 Effic a cy Levels and More Efficacious Substitutes

DOE identified arc tube optimization and fill gas optimization as design options to improve standard efficacy quartz MH lamps. These design options are the basis upon which DOE developed E Ls. DOE also tentatively determined that these high efficacy quartz MH lamps are the maximum improvement in efficacy that is technologically feasible, as required by section 325(o) of EPCA (42 U.S.C. 6295(o))

This equipment class does not contain MV lamps because this NOPD is only considering standards for MV lamps up to 1000 W. As such, EL 1 corresponds to high efficacy quartz MH lamp compared to the baseline quartz MH lamp model.

5-57Table 5.7.48 Summary of the EL for the 1000 W MV Representative Lamp Type

EL Technology Level Initial Efficacy Requirement

E L 1 High Efficacy Quartz MH lm/W = 93.4

Figure 5.7.8 illustrates the EL on a plot with the representative units for the 2000 W MH representative lamp type. The squares represent the representative units selected by DOE for each of the two technologies in this representative lamp type, while the line corresponds to the

E L.

Figure 5.7.8 Effic a cy Level for the 2000 W MH Representative Lamp Type 0 20 40 60 80 100 120

1000 1100 1200 1300 1400 1500 1600 1700 1800 1900 2000Initial Lamp Efficacy (lm/W)

Wattage (W) EL1

Baseline Representative Unit

EL 1 Representative Unit

Equal Wattage Units

5-58Table 5.7.49 summarizes the lamp designs for the 2000 W MH baseline and the reduced wattage, increased efficacy replacement options. As discussed in section 5.4 , DOE also identified lamps compliant with each EL that did not require a change in wattage for customers who would opt not to reduce wattage as a result of standards. When available, DOE identified equal wattage options at higher ELs for each baseline lamp and reduced wattage, increased efficacy replacement option below the max

- tech level

. These equal wattage lamps are represented by black triangles in Figure 5.7 .8 and are summarized in Table 5.7.50

.

Table 5.7.49 Lamp Designs for the 2000 W MH Representative Lamp Type - Reduced Wattage

EL Lamp Type Wattage

W CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

MH Baseline Standard Efficacy Quartz MH 2000 4000 85.0 153

, 000 Horizontal

EL 1 High Efficacy Quartz MH 1500 3700 103.3 140

, 000 Universal

Table 5.7.50 Lamp Designs for the 2000 W MH Representative Lamp Type - Equal Wattage

EL Lamp Type Wattage

W CCT

K Initial Efficacy

lm/W Mean

Lumens Operating

Orientation

2000 W Standard Efficacy Quartz MH Baseline

EL 1 High Efficacy Quartz MH 2000 4000 100.0 170

, 000 Horizontal

5-595.7.8.3 Engineering Summary

The following tables summarize the engineering characteristics for each baseline lamp and lamp replacement option in the 2000 W MH representative lamp type.

Table 5.7.51 Engineering Summary for 2000 W MH Representative Lamp Type - Reduced WattageELLamp TypeStarting MethodArc TubeWattageWCCTKInitial LumensInitial Efficacylm/WMean LumensChange in Mean Lumens FromBaseline%Mean Efficacylm/WOperating OrientationBulb FinishBallast TypeBallast Efficiency%Lamp-and-BallastSystem PowerW

Baseline MH Pulse Quartz 2000 4000 170,000 85.0 153,000 N/A 76.5 Horizontal Clear MH Magnetic 95.0 2105.3

E L 1 MH Probe Quartz 1500 3700 155,000 103.3 140,000

- 8.5% 93.3 Universal Clear MH Magnetic 92.9 1614.6

5-60Table 5.7.52 Engineering Summary for 2000 W MH Representative Lamp Type - Equal WattageELLamp TypeStarting MethodArc TubeWattageWCCTKInitial LumensInitialEfficacylm/WMean LumensMean Efficacylm/WOperating OrientationBulb FinishBallast TypeBallast Efficiency%Lamp-and-BallastSystemPowerW

E L 1 MH Pulse Quartz 2000 4000 200,000 100.0 170,000 85.0 Horizontal Clear MH Magnetic 95.0 2105.3

5-615.7.9 Summary of Representative Lamp Type Effic a cy Levels

The figures below depict the E L equations for each representative equipment class on a plot of the representative lamp models selected.

Figure 5.7.9 2800 K – 4500 K, 50 W – 400 W Representative Equipment Class 0 20 40 60 80 100 120

50 75 100 125 150 175 200 225 250 275 300 325 350 375 400Initial Lamp Efficacy (lm/W)

Wattage (W) EL1

EL2

EL3 MV Baseline Representative Unit MH Baseline/ EL 1 Representative Unit
EL 2 Representative Unit

5-62Figure 5.7. 10 2800 K – 4500 K, 401 W – 1000 W Representative Equipment Class 0 20 40 60 80 100 120

400 450 500 550 600 650 700 750 800 850 900 950 1000Initial Lamp Efficacy (lm/W)

Wattage (W) EL1

EL2

MV Baseline Representative Unit

MH Baseline/ EL 1 Representative Unit

EL 2 Representative Unit

5-63Figure 5.7. 11 2800 K – 4500 K , 1001 W – 2000 W Representative Equipment Class

5.8 SCALING TO EQUIPMENT CLASSES NOT ANALYZED

DOE identified and selected certain equipment classes as “representative” equipment classes on which to concentrate its analytical effort. DOE chose these representative equipment classes primarily due to their high market volumes. To scale ELs to equipment classes not directly analyzed, DOE focused its analytical efforts on data reported by manufacturers in their publically

- available HID lamp catalogs for lamps

.

To develop relationships between clear and coated bulb finish, enclosed- ratedand openrated l uminaire characteristic, and the CCT ranges of 2800 K – 4500 K and 4501 – 6999 K , DOE identified pairs of lamps in which the only difference between the lamps was the parameter under consideration for scaling. For example, to identify the scaling factor be tween clear lamps and coated lamps, DOE identified pairs of lamps within the two equipment classes that were made by the same manufacturer, within the same lamp family, and differed only by bulb finish. DOE calculated the average percentage change in initial efficacy for each of these pairs

. These averages are used to directly calculate the scaling factors. Additionally, based on data analysis 0 20 40 60 80 100 120

1000 1100 1200 1300 1400 1500 1600 1700 1800 1900 2000Initial Lamp Efficacy (lm/W)

Wattage (W) EL1

MV Baseline Representative Unit

MH Baseline/ EL 1 Representative Unit

5-64and manufacturer interviews, DOE tentatively determined that each of these scaling characteristics are independent and do not influence each other. Thus, in order to obtain the efficacy requirement for an equipment class with coated, open -rated lamps, the equation for comparable clear, enclosed -rated lamps would be simply multiplied by both the bulb finish and

luminair e characteristic scaling factors.

5.8.1 Bulb Finish

As discussed in chapter 3 of this NOPD TSD, manufacturers offer HID lamps in either clear or coated bulb finishes. The coating on a lamp blocks a portion of the light produced by the arc tube from leaving the lamp. Thus, coated lamps have lower efficacy than their clear counterparts. By comparing pairs of coated and clear lamps, all other features remaining approximately the same, DOE concluded that coating on MH lamps reduced overall lamp efficacy. For MV lamps , DOE determined that coated lamps were more efficacious than their clear counterparts because MV lamps generate a large amount of ultraviolet (UV) light and the coating on MV lamps converts the UV light into visible light, thereby increasing the efficacy of the lamp. i

DOE found no correlation between wattage and bulb finish efficacy difference and thus kept one constant scaling factor across all wattages . As explained in chapter 3 of this NOPD

TSD , DOE classified MV lamps into the clear equipment classes regardless of actual bulb finish, and thus MV lamps were not used to determine bulb finish scaling factors. DOE found that

coated MH lamps were on average 5. 5 percent less efficacious than clear MH lamps. Th erefore, the equations for the 2800 K – 4500 K, clear equipment classes were multiplied by a scaling factor of 0.945 to obtain the equations for the 2800 K – 4500 K CCT, c oated equipment classes. These scaling factors are summarized in Table 5.8 .1

.

5.8.2 Luminaire Characteristic

As discussed in chapter 3 of this NOPD TSD, DOE found that MH lamps can be offered as either open

- rated or enclosed

- rated. One of the requirements for a MH lamp to be labeled as open-rated is having a glass shroud that surrounds the arc tube to protect the environment and any occupants around the lamp in the event of arc tube rupture. After analyzing data and interviewing manufacturers, DOE concluded that this glass shroud on MH lamps reduces overall lamp efficacy by reducing light transmittance.

Similar to the bulb finish scaling factor, DOE found no correlation between lamp wattage or efficacy and scaling factor . DOE found that in the 2800 K – 4500 K CCT representative equipment classes

, open

- rated lamps were on average 5.0 percent less efficacious than clear lamps. Therefore, the equations for 2800 K – 4500 K, enclosed- rate d equipment classes were multiplied by a scaling factor of 0.9 50 to obtain the equations for the 2800 K – 4500 K CCT

, open- rated equipment classes. This scaling factor is shown in Table 5.8.1

.

i Cl ear and coated finishes are offered for MV lamps. However, the coated MV lamps are only offered in the 2800 K

– 4500 K CCT range, and clear MV lamps are only offered in the 4501 K

– 6999 K CCT range. DOE chose to include MV lamps in the clear equipment classes, regardless of the actual bulb finish. See chapter 3 of this NOPD

TSD for further details.

5-655.8.3 CCT Range

As discussed in chapter 3 of this NOPD TSD, within the two CCT ranges DOE used to separate equipment classes, MH and MV lamps are found in both the 2800 K – 4500 K and 4501 – 6999 K ranges. However , DOE found that the 2800 K – 4500 K lamps are much more common, having over ten times as many listings in manufacturer catalogs compared to the lamps in the 4501 – 6999 K range. Thus, the 2800 K – 4500 K range was regarded as representative, and DOE focused its analytical eff orts on these lamps, choosing to scale to the 4501 K – 6999 K

range.

DOE identified pairs of lamps from the same manufacturer and lamp families that only differed by these CCT ranges. DOE found the data exhibited some variation across lamp wattage

but th e overall trend was inconclusive; therefore, DOE again calculated an average scaling factor to be applied at all wattages when going from the 2800 K – 4500 K range to the 4501 K – 6999

K range. DOE found that on average the lamps in the 2800 K – 4500 K range were 18.8 percent more efficacious than lamps in the 4501 K – 6999 K range. Thus, the equations for the medium equipment classes were multiplied by a scaling factor of 0. 812 to obtain the equations for the

4501 K – 6999 K equipment classes. This scaling factor is shown in Table 5.8.1

.

5.8.4 Scaling Summary

In analyzing commercially available lamps, DOE found each scaling factor (bulb finish,

luminaire characteristic , and CCT range) to be independent

. Therefore, to scale from a representative equipment class to a scaled equipment class, DOE applied each scaling factor that corresponded to the differences between the two classes. Table 5.8.1 summarizes all the scaling

factors calculated.

Table 5.8.1 Scaling Factors

Bulb Finish Luminaire

Characteristic CCT Range

Scaling Factor* 0.94 5 0.95 0 0. 8 12

*In order to calculate the efficacy requirement for a scaled equipment class, the representative equipment class equation is multiplied by each scaling factor of the characteristics of the equipment class that differ from the representative class.

5.9 EFFICACY LEVEL SUMMARY

Table 5.9.1 shows the equations for all equipment classes, both representative and scaled, after using the scaling factors discussed in the previous section.

5-66Table 5.9.1 Effic a cy Level EquationsCCT RangeWattageBulb Finish*LuminaireCharacteristic**EL1 EquationEL2 EquationEL3 Equation

2800 K

– 4500 K 50 W

– 400 W Clear Enclosed lm/W = 38.5 × P 0.1350 lm/W = 44.4 × P 0.1350 lm/W = 40.4 × P 0.1808

Open lm/W = 0.950 × (38.5 × P 0.1350 ) lm/W = 0.950 × (44.4 × P 0.1350 ) lm/W = 0.950 × (40.4 × P 0.1808 )

Coated Enclosed lm/W = 0.945 × (38.5 × P 0.1350 ) lm/W = 0.945 × (44.4 × P 0.1350 ) lm/W =

0.945 × (40.4 × P 0.1808 )

Open lm/W = 0.945 × 0.950 × (38.5 × P 0.1350 ) lm/W = 0.945 × 0.950 × (44.4 × P 0.1350 ) lm/W =

0.945 × 0.950 × (40.4 × P 0.1808 )

401 W

– 1000

W Clear Enclosed lm/W = 0.0116 × P+81.8 lm/W = 0.0173 × P+92.8 N/A

Open lm/W = 0.950 × (0.0116 × P+81.8) lm/W = 0.950 × (0.0173 × P+92.8) N/A

Coated Enclosed lm/W = 0.945 × (0.0116 × P+81.8) lm/W = 0.945 × (0.0173 × P+92.8) N/A

Open lm/W = 0.945 × 0.950 × (0.0116 × P+81.8) lm/W = 00.945 × 0.950 × (0.0173 × P+92.8) N/A

1001

W

– 2000

W Clear Enclosed lm/W = 93.4 N/A N/A

Open lm/W = 0.950 × 93.4 N/A N/A

Coated Enclosed lm/W = 0.945 × 93.4 N/A N/A

Open lm/W = 0.945 × 0.950 × 93.4 N/A N/A

4501 K

– 6999 K 50 W

– 400 W Clear Enclosed lm/W = 0.812 × (38.5 × P 0.1350 ) lm/W = 0.812 × (44.4 × P 0.1350 ) lm/W = 0.812 × (40.4 × P 0.1808 )

Open lm/W = 0.812 × 0.950 × (38.5 × P 0.1350 ) lm/W = 0.812 × 0.950 × (44.4 × P 0.1350 ) lm/W =

0.812 × 0.950 × (40.4 × P 0.1808 )

Coated Enclosed lm/W = 0.812 × 0.945 × (38.5 × P 0.1350 ) lm/W = 0.812 × 0.945 × (44.4 × P 0.1350 ) lm/W =

0.812 × 0.945 × (40.4 × P 0.1808 )

Open lm/W = 0.812 × 0.945 × 0.950 × (38.5 × P 0.1350 ) lm/W = 0.812 × 0.945 × 0.950 × (44.4 × P 0.1350 ) lm/W =

0.812 × 0.945 × 0.950 × (40.4 × P 0.1808 )

5-67CCT RangeWattageBulb Finish*LuminaireCharacteristic**EL1 EquationEL2 EquationEL3 Equation

401 W

– 1000

W Clear Enclosed lm/W = 0.812 × (0.0116 × P+81.8) lm/W = 0.812 × (0.0173 × P+92.8) N/A

Open lm/W = 0.812 × 0.950 × (0.0116 × P+81.8) lm/W = 0.812 × 0.950 × (0.0173 × P+92.8) N/A

Coated Enclosed lm/W = 0.812 × 0.945 × (0.0116 × P+81.8) lm/W = 0.812 × 0.945 × (0.0173 × P+92.8) N/A

Open lm/W = 0.812 × 0.945 × 0.950 × (0.0116 × P+81.8) lm/W = 0.812 × 0.945 × 0.950 × (0.0173 × P+92.8) N/A

1001

W

– 2000

W Clear Enclosed lm/W = 0.812 × 93.4 N/A N/A

Open lm/W = 0.812 × 0.950 × 93.4 N/A N/A

Coated Enclosed lm/W = 0.812 × 0.945 × 93.4 N/A N/A

Open lm/W = 0.812 × 0.945 × 0.950 × 93.4 N/A N/A

* MV lamps regardless of bulb finish are placed in the clear equipment classes for their respective CCT and wattage.
** MV lamps are placed in the enclosed equipment classes for their respective wattage and CCT.

5-68CHAPTER 6. EQUIPMENT PRICE DETERMINATION

TABLE OF CONTENTS

6.1 INTRODUCTION

........................................................................................................... 6-1

6.2 METHODOLOGY

.......................................................................................................... 6-1

6.3 RESULTS

........................................................................................................................ 6-3

LIST OF TABLES

Table 6.3.1 End

- User Lamp Prices

– Reduced Wattage Replacement Options .......................... 6-3

Table 6.3.2 End

- User Lamp Prices – Equivalent Wattage Replacement Options ....................... 6-5

Table 6.3.3 End

- User Lamp Prices

– Reduced Wattage Retrofit Lamps .................................... 6-6

6-iCHAPTER 6. EQUIPMENT PRICE DETERMINATION

6.1 INTRODUCTION

This chapter describes the methodology the U.S. Department of Energy (DOE) followed in developing end- user prices for the high

- intensity discharge (HID) lamps analyzed in this notice of proposed determination (NO PD) . In energy conservation standards rulemakings, DOE often develops cost-efficiency relationships in the engineering analysis. Then, DOE applies markups to derive end- user prices. F or this NOPD , DOE derived efficacy levels (ELs) in the engineering analys is (chapter 5 of th is NOPD technical support document [ TSD ]). The equipment price determination in this chapter develops end- user prices directly for lamps

because reverse

- engineering a lamp is impractical ; t he lamps are not easily disassembled, and fill

g as composition and partial pressures are difficult to assess. By combining the results of the engineering analysis and the equipment price determination, DOE derived typical inputs for use

in the life

- cycle cost (LCC) analysis (chapter 9 of this NOPD TSD) and the national impact analysis (NIA ; chapter 11 of th is NOPD TSD ).

Because DOE recognizes that customers may be required to purchase new ballast s and

fixture s to accommodate higher efficacy HID lamps, DOE also developed prices for HID ballasts and fixtures. Appendix 6A of th is NOPD TSD describes the methodology used to derive the manufacturer selling prices ( MSPs ) for the representative HID ballasts and fixture s that are analyzed in the engineering analysis.

6.2 M ETHODOLOGY

In its review of publicly available prices, DOE observed a range of end

- user prices paid for a lamp, depending on the distribution channel through which the lamp is purchased. In line

with its ob servation of public pricing, DOE developed three different end- user prices to characterize the range of prices available in the three main distribution channels: state procurement, large electrical distributors, and Internet retailers. DOE first collect ed manufacturer suggested price lists (hereafter referred to as “blue books ”) . Starting with aggregated blue -book prices, DOE calculated an average discount ratio for each end

- user. State procurement contracts typically offered the greatest discounts off blue-book prices, approximately 82 percent off the blue-book aggregate . These contracts represent large purchases and therefore reflect steep discounts. Customer prices were generally higher at electrical supply distributors (with a discount of approximately 75 percent - the average of the low and high distribution channel

discounts ), which represent typical prices for commercial institutions. Prices were the highest at Internet retailers (with a discount of approximately 68 percent) because customers typically purchase from Internet retailers in small volumes. DOE applied these discounts to the aggregated

blue-book prices of lamps at each EL . DOE found that the discount did not vary with wattage or lamp technology, and theref ore applied a single discount for all lamps to estimate end

- user prices. After generating end- user prices, DOE added sales tax and installation costs, where

6-1appropriate, to derive the total, installed end- user cost for the LCC analysis (chapter 9 of th is

N OPD TSD ).

DOE analyzed lamp prices for reduced wattage and equal wattage replacement options outlined in the engineering analysis (chapter 5 of th is NOPD TSD)

. For the representative lampsfor which blue-book prices were unavailable, DOE extrapolated pricing from lamps whose bluebook prices were available. This was done by using the blue- book prices of similar lamps from an alternative manufacturer or by interpolating between blue-book prices of lamps with different wattages within the same lamp family.

In the engineering analysis (chapter 5 of this NOPD TSD), DOE chose one metal halide ( MH ) lamp to model at the efficacy levels of EL1 and EL2 ( e.g. , a 250 W probe- start EL1 lamp).

However

, to accurately reflect the potential effect of efficacy standards, D OE also accounted for customers with lamps at EL1 and EL2 that had the alternative starting method compared to the representative lamps ( e.g. , a 250 W pulse- start lamp with EL1 efficacy) when they were available. The performance of these alternative starti ng method lamps are assumed to be the same as the representative lamp, but the separate prices of the alternative starting method lamps

are found in the Table 6.3 .1 and Table 6.3.2 . These alternative starting method lamps are discussed in more detail in appendix 5A of this NOPD TSD.

For verification purposes, DOE also compared th e calculated high end- user prices to high ( Internet retail) prices observed in the market. Ratios between the different ELs and starting

methods were compared for relative size and pricing trends. DOE utilized these ratios as a quality check to further support the calculated pricing for all lamps , including those for which

blue- book prices were not available.

6-26.3 RESULTS

Table 6.3.1 and Table 6.3 .2 summarize the low, medium, and high end- user prices for reduced wattage HID lamp replacement options and equal wattage HID lamp replacement options, respectively

. Table 6.3.3 summarizes the l ow, medium, and high end- user prices for reduced wattage retrofit HID lamps. Prices for the representative HID ballasts and fixture s are presented in appendix 6A.

Table 6.3.1 End

- User Lamp Prices

– Reduced Wattage Replacement Options

Lamp Characteristics * Lamp End

- User Prices (2011$)

EL Lamp Type Starting Method Wattage Low Medium High

Baseline MV

- 100 $ 17.57 $ 24.10 $ 30.62

EL 1/Baseline MH Standard efficacy quartz MH Standard efficacy quartz MH P robe

P ulse ** 70

70 N/A

-- -- $ 19.51 $ 26.76 $ 34.01

EL 2 N/A

- -- -- -- -- EL 3 CMH

- 50 $ 20.95 $ 28.73 $ 36.51

Baseline MV

- 175 $ 8.58 $ 11.77 $ 14.96

EL 1/Baseline MH Standard efficacy quartz MH Standard efficacy quartz MH Probe

Pulse ** 150

150 $ 21.43
$ 18.16 $ 29.39
$ 24.90 $ 37.35
$ 31.65

EL 2 High efficacy quartz MH High efficacy quartz MH Probe

Pulse ** 100

100 N/A

-- -- $ 24.47 $ 33.56 $ 42.65

EL 3 CMH

- 70 $ 34.36 $ 47.13 $ 59.89

Baseline MV

- 250 $ 10.82 $ 14.84 $ 18.85

EL 1/Baseline MH Standard efficacy quartz MH Standard efficacy quartz MH Probe **

Pulse 175

175 $ 14.87
$ 28.86 $ 20.39
$ 39.57 $ 25.91
$ 50.29

EL 2 High efficacy quartz MH High efficacy quartz MH Probe **

Pulse 150

150 $ 24.14
$ 19.86 $ 22.10
$ 27.23 $ 42.06
$ 34.61

EL 3 CMH

- 100 $ 28.69 $ 39.34 $ 50.00

Baseline MV

- 400 $ 14.64 $ 20.07 $ 25.51

EL 1/Baseline MH Standard efficacy quartz MH Standard efficacy quartz MH Probe

Pulse ** 250

250 $ 21.48
$ 20.37 $ 29.46
$ 27.94 $ 37.43
$ 35.51

EL 2 High efficacy quartz MH High efficacy quartz MH Probe

Pulse ** 200

200 N/A

-- -- $ 26.63 $ 36.52 $ 46.61

EL 3 CMH

- 150

250 $ 26.54
$ 30.23 $ 36.40
$ 41.46 $ 46.26
$ 52.69

6-3Lamp Characteristics * Lamp End

- User Prices (2011$)

EL Lamp Type Starting Method Wattage Low Medium High

Baseline N/A

- -- -- -- --

EL 1/Baseline Standard efficacy quartz MH Standard efficacy quartz MH Probe **

Pulse 400

400 $ 23.89
$ 30.09 $ 32.77
$ 41.26 $ 41.64
$ 52.43

EL 2 High efficacy quartz MH High efficacy quartz MH Probe

Pulse ** 320

320 N/A

-- -- $ 31.60 $ 43.33 $ 55.06

EL 3 CMH

- 250 $ 30.23 $ 41.46 $ 52.69

Baseline MV

- 1000 $ 36.11 $ 49.52 $ 62.93

EL 1/Baseline MH Standard efficacy quartz MH Standard efficacy quartz MH Probe

Pulse ** 750

750 N/A

-- -- $ 57.25 $ 78.51 $ 99.77

EL 2 High efficacy quartz MH High efficacy quartz MH Probe

Pulse ** 575

575 N/A

-- -- $ 41.46 $ 56.86 $ 72.26

Baseline N/A

- -- -- -- --

EL 1/Baseline MH Standard efficacy quartz MH Standard efficacy quartz MH Probe **

Pulse 1000

1000 $ 49.35 $ 67.68 $ 86.01

N/A

-- --

EL 2 High efficacy quartz MH High efficacy quartz MH Probe

Pulse ** 875

875 N/A

-- -- $ 48.61 $ 66.66 $ 84.71

Baseline Standard efficacy quartz MH Pulse 2000 $ 70.66 $ 96.90 $ 123.14

EL 1 High efficacy quartz MH Probe **

Pulse 1500

1500 $ 53.62 $ 73.52 $ 93.44

N/A

-- -- * All lamp replacement options displayed are clear and enclosed with a correlated color temperature ( CCT ) between 2800 K and 4500 K. MV lamps

, regardless

of bulb finish

, are placed in the clear equipment classes for their respective CCT and wattage. Additionally, MV lamps are placed in the encl osed equipment classes for their respective wattage and CCT. **Where pulse

- and probe

- start lamp option s are presented, the starting method indicated corresponds to the representative lamp for the equipment class.

6-4Table 6.3.2 End

- User Lamp Prices

– Equivalent Wattage Replacement Options

Lamp Characteristics Lamp End

- User Prices (2011$)

EL Lamp Type Starting Method Wattage Low Medium High

EL 1 Standard efficacy quartz MH Standard efficacy quartz MH Probe

Pulse ** 70

70 N/A

-- -- $ 19.51 $ 26.76 $ 34.01

EL 2 High efficacy quartz MH High efficacy quartz MH Probe

Pulse ** 70

70 N/A

-- -- $ 22.24 $ 30.51 $ 38.77

EL 3 CMH

- 70 $ 34.36 $ 47.13 $ 59.89

Baseline MV

- 100 $ 17.57 $ 24.10 $ 30.62

EL 1 Standard efficacy quartz MH Standard efficacy quartz MH Probe

Pulse ** 100

100 N/A

$ 19.73 $ 27.05 $ 34.38

EL 2 High efficacy quartz MH High efficacy quartz MH Probe

Pulse ** 100

100 N/A

-- -- $ 24.47 $ 33.56 $ 42.65

EL 3 CMH

- 100 $ 28.69 $ 39.34 $ 50.00

EL 1 Standard efficacy quartz MH Standard efficacy quartz MH Probe

Pulse ** 150

150 $ 21.43 $ 18.16 $ 29.39 $ 24.90 $ 37.35 $ 31.65

EL 2 High efficacy quartz MH High efficacy quartz MH Probe

Pulse ** 150

150 $ 24.14 $ 19.86 $ 33.10 $ 27.23 $ 42.06 $ 34.61

EL 3 CMH

- 150 $ 30.61 $ 41.97 $ 53.34

Baseline MV

- 175 $ 8.58 $ 11.77 $ 14.96

EL 1 Standard efficacy quartz MH Standard efficacy quartz MH Probe **

Pulse 175

175 $ 14.87 $ 28.86 $ 20.39 $ 39.57 $ 25.91 $ 50.29

EL 2 High efficacy quartz MH High efficacy quartz MH Probe **

Pulse 175

175 $ 32.84 $ 38.36 $ 45.04 $ 52.61 $ 57.24 $ 66.86

EL 3 N/A

- -- -- -- --
Baseline N/A

- 250 $ 10.82 $ 14.84 $ 18.85

EL 1 Standard efficacy quartz MH Standard efficacy quartz MH Probe

Pulse ** 250

250 $ 21.48 $ 20.37 $ 29.46 $ 27.94 $ 37.43 $ 35.51

EL 2 High efficacy quartz MH High efficacy quartz MH Probe

Pulse ** 250

250 $ 21.61

-- $ 29.63

-- $ 37.66

-- EL 3 CMH

- 250 $ 38.57 $ 52.89 $ 67.21

6-5Lamp Characteristics Lamp End

- User Prices (2011$)

EL Lamp Type Starting Method Wattage Low Medium High

Baseline MV

- 400 $ 14.64 $ 20.07 $ 25.51

EL 1 Standard efficacy quartz MH Standard efficacy quartz MH Probe **

Pulse 400

400 $ 23.89 $ 30.09 $ 32.77 $ 41.26 $ 41.64 $ 52.43

EL 2 High efficacy quartz MH High efficacy quartz MH Probe **

Pulse 400

400 $ 26.42 $ 35.05 $ 36.23 $ 48.07 $ 46.04 $ 61.09

EL 1 Standard efficacy quartz MH Standard efficacy quartz MH Probe

Pulse ** 750

750 N/A

-- -- $ 57.25 $ 78.51 $ 99.77

EL 2 High efficacy quartz MH High efficacy quartz MH Probe

Pulse ** 750

750 N/A

-- -- $ 75.62 $ 103.70 $ 131.78

Baseline MV

- - 1000 $ 36.11 $ 49.52 $ 62.93

EL 1 Standard efficacy quartz MH Standard efficacy quartz MH Probe **

Pulse 1000

1000 $ 42.67 $ 58.51 $ 74.36

N/ A

-- --

EL 2 High efficacy quartz MH High efficacy quartz MH Probe **

Pulse 1000

1000 $ 56.35
$ 54.41 $ 77.28
$ 74.62 $ 98.21
$ 94.83

Baseline Standard efficacy quartz MH Standard efficacy quartz MH Probe

Pulse ** 2000

2000 N/A

-- -- $ 70.66 $ 96.90 $ 123.14

EL 1 High efficacy quartz MH High efficacy quartz MH Probe

Pulse ** 2000

2000 N/A

-- -- $ 67.93 $ 93.15 $ 118.38
* All lamp replacement options displayed are clear and enclosed with a CCT between 2800 K and 4500 K. MV lamps

, regardless of bulb finish

, are placed in the clear equipment classes for their respective CCT and wattage. Additionally, MV lamps are placed in the enclosed equipment classes for their respective wattage

and CCT. **Where pulse

- and probe

- start lamp option s are presented, the starting method indicated corresponds to the representative lamp for the equipment class.

Table 6.3.3 End

- User Lamp Prices – Reduced Wattage Retrofit Lamps

Lamp Characteristics Lamp End

- User Prices (2011$)

EL Lamp Type Starting Method Wattage Low Medium High

Baselin e N/A

-- 100

-- -- -- EL 1/Baseline MH N/A

-- 70

-- -- --
EL 2 N/A

-- -- -- -- --
EL 3 N/A

-- 50

-- -- --

6-6Lamp Characteristics Lamp End

- User Prices (2011$)

EL Lamp Type Starting Method Wattage Low Medium High

Baseline N/A

-- 175

-- -- --

EL 1/Baseline MH N/A --

-- 150

150 -- -- --

EL 2 N/A

-- 100

-- -- --
EL 3 N/A

-- 70

-- -- --
Baseline N/A

-- 250

-- -- --

EL 1/Baseline MH N/A --

-- 175

175 -- -- --

EL 2 N/A --

-- 150

150 -- -- --

EL 3 N/A

-- 100

-- -- --
Baseline N/A

-- 400

-- -- -- EL 1/Baseline MH Standard efficacy quartz MH Probe 325 $ 17.66 $ 39.03 $ 49.60

EL 2 N/A

-- 200

-- -- --

EL 3 N/A --

-- 150

250 -- -- --

Baseline N/A

-- -- -- -- --

EL 1/Baseline N/A --

-- 400

400 -- -- --

EL 2 High efficacy quartz MH Probe 360 $ 28.46 $ 39.03 $ 49.60

EL 3 N/A

-- 250

-- -- --
Baseline N/A

-- 1000

-- -- -- EL 1/Baseline MH N/A

-- 750

-- -- --
EL 2 N/A

-- 575

-- -- --
Baseline N/A

-- -- -- -- -- EL 1/Baseline MH N/A

-- 1000

-- -- --
EL 2 N/A

-- 875

-- -- --
Baseline N/A

-- 2000

-- -- --

EL 1 N/A

-- 1500

-- -- -- * All lamp replacement options displayed are clear and enclosed with a CCT between 2800 K and 4500 K. MV lamps

, regardless of bulb finish

, are placed in the clear equipment classes for their respective CCT and wattage. Additionally, MV lamps are placed in the enclosed equipment classes for their respective wattage

and CCT.

**Wher e pulse

- and probe

- start lamp options are presented, the starting method indicated corresponds to the representative lamp for the equipment class.

6-7CHAPTER 7. MARKUPS ANALYSIS

TABLE OF CONTENTS

7.1 INTRODUCTION .............................................................................................................. 7-1

7.1.1 Distribution Channels ............................................................................................. 7-1

7.1.2 Markup Calculation Methodology .......................................................................... 7-1

7.2 ESTIMATION OF WHOLES ALER, CONTRACTOR, AN D SALES TAX MARKUPS 7-3

7.2.1 Financial Information Sources ................................................................................ 7-3

7.2.2 Sales Tax ................................................................................................................. 7-4

REFERENCES ............................................................................................................................ 7-6

LIST OF TABLES

Table 7.2.1 Gross Profit Margins for Electrical Wholesalers * ..................................................... 7-4 Table 7.2.2 Calculated Electrical Wholesaler Baseline Markups for HID Lamp Ballasts and

Fixtures ................................................................................................................ 7-4

Table 7.2.3 State and Local Sales Tax Rates ............................................................................... 7-5

7-iCHAPTER 7 . MARKUPS ANALYSIS

7.1 INTRODUCTION

This technical support document (TSD) chapter describes the methodology the U.S. Department of Energy (DOE) followed in developing markups for the notice of proposed

determination ( NOPD ) analysis for high

- intensity discharge (HID) lamps.

In this rulemaking , DOE estimated end

- user prices for representative HID lamp designs directly, rather than develop the manufacturer selling prices ( MSPs ) from a bill of materials and manufacturer markup analysis ( NOPD TSD chapter 6). DOE selected this methodology because

i t is difficult to reverse -engineer HID lamps; they are not easily disassembled, and fill gas composition and partial pressures are difficult to assess. For the NOPD stage of this rulemaking, DOE also used estimated markups to develop MSPs for HID lamps for the manufacturer impact analysis (MIA, as described in chapter 12 of the NOPD TSD).

DOE understands that an energy conservation standard that requires higher- efficacy lamps may require customers to purchase a new ballast and fixture. DOE estimated price markups in its markups analysis to calculate end- user prices from MSPs for HID ballasts

, fixtures , and related equipment as inputs to the life

- cycle cost (LCC) and payback period (PBP) analysis, and the national impact analysis (NIA) (chapters 9 and 11, respectively, of the NOPD TSD). Appendix 6A of the NOPD TSD describes the process by which DOE developed manufacturer production costs and MSPs for HID ballasts and fixtures.

7.1.1 Distribution Channels

The appropriate markups for determining customer equipment prices depend on the type of distribution channels through which equipment moves from manufacturers to purchasers. At each point in the distribution channel, companies mark up the price of the equipment to cover their business costs and profit margin. Fo r the NOPD analysis, DOE assumed that an HID ballast or fixture manufacturer sells the equipment to an electrical wholesaler ( i.e. , electrical distributor), who in turn sells it to a contractor, who sells it to the end user.

7.1.2 Markup Calculation Methodology

At each point in the distribution channel, companies apply a “markup” to the MSP to cover their business costs and profit margin. DOE models this markup as a multiplier. In financial statements, gross profit is the difference between the company revenue an d the company cost of sales. It includes all corporate overhead costs (sales, general, and administration), materials and labor costs, research and development and interest expenses, depreciation and taxes, and profits. In order for sales of equipment to contribute positively to company cash flow, the equipment’s markup must be greater than the sum of cost of sales and business costs for that equipment. DOE calculates the end

- user sales price by multiplying the MSP by the various markups and applying sales tax.

The end -user prices and installation costs are key inputs to the LCC and PBP analysis, and the NIA. Through use of the distribution channel markups and installation costs, DOE can

7-1calculate the first costs that customers would face under the various e fficacy levels evaluated. DOE evaluates the tradeoff between the increase in first cost and the resulting energy cost savings at each efficacy level in the LCC and PBP analysi s ( NOPD TSD chapter 9) and NIA analysis ( NOPD TSD chapter 11 ).

The following equation shows how DOE determined the equipment prices for ballasts

and fixtures:



### ) ( TAX CONT WHOLE MFR END 

### MU MU MUPP ×× ×= Eq. 7.1

Where:

END P = equipment price to the end- user ($),

MFR P = MSP of baseline or standard- level equipment ($),

WHOLE MU = wholesaler markup,

CONT MU = contractor markup, and

TAX MU = sales tax markup.

For the equipment subject to potential energy conservation standards, markups are typically differentiated between a “baseline markup” and an “incremental markup.” The baseline markup would relate the MSP of baseline equipment to a wholesaler sales price, and the incremental markup would relate change s in the MSP of higher- efficacy equipment to changes in the wholesaler sales price. As discussed previously, DOE estimated end

- user prices for representative HID lamp designs directly; therefore, DOE did not estimate baseline and incremental markups for HID lamps. DOE needed to estimate markups for HID ballasts and fixtures to generate end -user prices as inputs to the LCC-PBP analysis and NIA. DOE applied baseline markups only to the MSPs for ballast s, fixture s, and related equipment because DOE

does not ex pect the cost structure for this ancillary equipment to vary with efficacy levels for HID lamps. Therefore, incremental markups were not used to develop end- user prices for HID

ballasts

, fixtures , and related equipment.

The following equations show the cal culation of baseline markups:



### ) (

_ _ _ BASE WHOLE BASE MFR BASE WHOLE 

### MU P P × = Eq. 7.2



### ) (

_ _ _ BASE CONT BASE WHOLE BASE CONT 

### MU P P × = Eq. 7.3



### ) (

_ _ TAX BASE CONT BASE END 

### MU P P × = Eq. 7.4

Where:

BASE MFR P

_ = MSP of baseline equipment ($),

7-2BASE WHOLE P

_ = wholesaler selling price of baseline equipment ($),

BASE CONT P

_ = contractor selling price of baseline equipment ($),

BASE END P

_ = end -user purchase price for baseline equipment ($),

BASE WHOLE MU

_ = wholesaler markup for baseline equipment,

BASE CONT MU

_ = contractor markup for baseline equipment, and

TAX MU = sales tax markup.

7.2 ESTIMATION OF WHOLES ALER, CONTRACTOR

, AND SALES TAX

MARKUPS

7.2.1 Financial Information Sources

Publicly owned companies are required by law to disclose financial information on a regular basis by filing different forms with the U.S. Securities and Exch ange Commission (SEC).

F iled annually, the SEC form 10-K provides a comprehensive overview of the company’s

business and financial conditions. Relevant information in the 10- K report includes the company’s revenues and direct and indirect costs. For the wh olesaler markup, DOE used 10- K reports from publicly owned lighting fixture manufacturers and electrical wholesalers, respectively

. The financial figures necessary for calculating the company markup are net sales, costs of sales, and gross profit. The inco me statement section of the 10

- K reports often lists these figures. DOE used averages of the financial figures spanning 2008 to 2012 to calculate the markups.

DOE used the following equations to calculate the gross profit and gross profit margins:

Gross Profit ($) = Net Sales

– Cost of Sales Eq. 7.5

Gross Prof it Margin Gross Prof it

Net Sales =

Eq. 7.6

To calculate the time

- average gross profit margin for each company , DOE first summed the gross profit for all the years and then divided the result by the sum of the net sales for the

same years. DOE then used the gross profit margins to calculate baseline markups on existing equipment ( i.e. , prior to efficacy changes resulting from enactment of potential standards). Each

company ’s baseline markup was calculated as:



### Sales ofCost Sales Net
) Margin Profit Gross 1( 1 Markup Baseline =

− =

Eq. 7.7

Table 7.2.1 contain s the calculated gross profit margins for a sample of electrical

wholesalers

.

7-3Table 7.2.1 Gross Profit Margin s for Electrical Wholesalers *

Company Financial Figure
$ Year

2012 2011 2010 200 9 200 8

A Net Sales 5,413,281 5,374,800 4,616,377 4,377,882 5,400,154

Cost of Sales 4,394,919 4,379,541 3,749,736 3,522,932 4,354,935

Gross Profit 1,018,362 995,259 866,641 854,950 1,045,219

Gross Profit Margin ( % ) 18.8 18.5 18.8 19.5 19.4

Average Gross Profit Margin: 19.0 %

B Net Sales 6,579,301 6,125,718 5,063,862 4,263,954 6,110,840

Cost of Sales 5,247,855 4,889,149 4,065,425 3,724,061 4,904,164

Gross Profit 1,331,446 1,236,569 988,437 539,893 1,206,676

Gross Profit Margin ( % ) 20.2 20.2 19.7 12.7 19.7

Average Gross Profit Margin: 18.5 %

* Unless noted, all numbers are in thousands of dollars. This table includes 2008, 2009, 2010, 2011, and

2012 SEC 10

- K reports.

The baseline markup covers non-production costs and profit. Table 7.2.2 shows the

baseline markups using this method for electrical wholesalers

.

Table 7.2.2 Calculated Electrical Wholesaler Baseline Markups for HID Lamp Ballasts and

Fixtures

Company Baseline Markup

Wholesaler A 1.23

Wholesaler B 1.2 3 Average 1. 23

7.2.2 Sales Tax

The sales tax rate represents s tate and local sales taxes applied to ballasts, fixtures , and related equipment, and is a multiplicative factor that increases the end

- user cost . DOE obtained

information on s tate and local sales tax from the Sales Tax Clearinghouse ( Table 7.2.3 ). 1 These data represent weighted averages that include county and city rates. DOE also calculated a national population- weighted average sales tax for use in the NIA, where DOE did not use a distribution of inputs. 2

Table 7.2.3 shows the distribution of sales tax rates that DOE devel oped for the LCC and PBP analysi s. The distribution ranges from a minimum of 0 percent in some states to a maximum of 9.45 percent in Tennessee (as shown in Table 7.2.3 ), with a national weighted average of

7.13 percent.

7-4Table 7.2.3 State and Local Sales Tax Rates

State Combined State

and Local Tax Rate

% State Combined State

and Local Tax Rate

% State Combined State

and Local Tax Rate

%

Alabama

Alaska

Arizona

Arkansas

California

Colorado

Connecticut

Delaware

D.C.

Florida Georgia

Hawaii

Idaho

Illinois

Indiana

Iowa

Kansas 8.55

1.35

7.15

8.40

8.45

6.10

6.35

0.00

6.00

6.65

7.10

4.40

6.05

8.05

7.00

6.85

8.05 Kentucky

Louisiana

Maine Maryland

Massachusetts Michigan

Minnesota Mississippi

Missouri

Montana

Nebraska

Nevada New Hampshire New Jersey

New Mexico

New York

North Carolina 6.00

8.75

5.00

6.00

6.25

6.00

7.20

7.00

7.45

0.00

6.00

7.85

0.00

6.95

6.60

8.40

6.90 North Dakota

Ohio

Oklahoma Oregon Pennsylvania

Rhode Island

South Carolina

South Dakota

Tennessee

Texas

Utah

Vermont Virginia Washington West Virginia

Wisconsin Wyoming 5.95

6.80

8.40

0.00

6.40

7.00

7.20

5.40

9.45

7.95

6.70

6.05

5.00

8.90

6.05

5.45

5.50

National Averag e 7.13

7-5REFERENCES

1. The Sales Tax Clearinghouse. State Aggregate Tax Rates . 1999-2014. STC: Garnet Valley,

PA < http://thestc.com/STrates.stm > (Last accessed June 24, 2013)

2. U.S. Census Bureau. State Totals: Vintage 2012, Annual Estimates of the Resident Population for the United States, Regions, States, and Puerto Rico . 2012. U.S. Department of Commerce: Suitland, MD. < www.census.gov/popest/data/state/totals/2012/index.html > (Last

accessed July 15, 2013)

7-6CHAPTER 8. ENERGY USE ANALYSIS

TABLE OF CONTENTS

8.1 PURPOSE OF THE DOCUMENT .................................................................................... 8-1

8.2 HIGH

- INTENSITY DISCHARGE LAMP SYSTEM OPERATING HOURS ................. 8-1

8.3 RESULTS OF THE ENERG Y USE ANALYSIS .............................................................. 8-4

REFERENCES ............................................................................................................................ 8-5

LIST OF TABLES

Table 8.2.1. Average Annual HID Lamp System Operating Hours by Sector ............................ 8-2

LIST OF FIGURES

Figure 8.2.1 Commercial Sector Annual Operating Hour Distribution by Building Type.......... 8-2 Figure 8.2.2. Industrial Sector Annual Operating Hour Distribution by Building Type ............. 8-3 Figure 8.2.3 Outdoor Stationary Sector Annual Operating Hour Distribution by Installation Type .................................................................................................. 8-3

8-iCHAPTER 8. ENERGY USE ANALYSIS

8.1 PURPOSE OF THE DOCUM ENT

This chapter presents the methodology the U.S. Department of Energy (DOE) follow ed to estimate the annual energy use of the high

- intensity discharge (HID) lamp designs DOE

consider ed in the HID lamp notice of proposed determination ( NOPD ) analys e s. Ballasts will not be regulated under the potential HID lamps rulemaking; however, the input power of the complete lamp

- and

- ballast system must be considered for the energy use analysis. The results of this analysis, which represent typical energy use in the field, are critical inputs to the life

- cycle cost (LCC) and payback period (PBP) analysis ( NOPD technical support document (TSD)

c hapter 9) and the national impact analysis (NIA ; NOPD TSD c hapter 11) . DOE requires information on annual energy use to determine the potential energy and operating cost savings to

customer s from the use of more efficient equipment.

DOE determine d the annual energy use of the representative HID lamp

- ballast

- fixture systems (herein “HID lamp systems”) using information on their measured input power ( i.e.

, the rate of energy they use ) and the way customers use them ( i.e. , operating hours per year). The engineering analysis ( NOPD TSD c hapter 5) provides the input power ratings of representative HID lamp systems . The following sections discuss the inputs and calculations DOE used to develop annual operating hours and annual energy use for the equipment considered in this analysis.

8.2 HIGH

- INTENSITY DISCHARGE LAMP SYSTEM OPERATING HOURS

To characterize the country’s average use of HID lamp systems f or a typical year, DOE develop ed annual operating hour s by sector . For the LCC, DOE account ed for variability in operating hours by developing a distribution of operating hours for the LCC spreadsheet. The operating hour distributions captured variation across building types, lighting applications, and HID lamp systems f or three sectors (commercial , industrial, and outdoor stationary ).

DOE primarily uses data from the 2010 U.S. Lighting Market Characterization (LMC) 1
to develop operating hours by sector. The LMC, which is based on thousands of building audits and surveys, provides national-level data on annual operating hours by building type. These data

are organized by lighting application for the commercial , industrial, and outdoor stationary

sectors.

For the commercial sector, DOE use d LMC commercial sector operating hour data by facility type to develop a distribution of annual operating hours for HID lamp systems . To develop a distribution of annual operating hours in the industrial sector, DOE used an approach

similar to that used for the commercial sector. DOE aggregate d LMC annual operating hour data by industry to develop weighted average annual operating hours.

For the outdoor stationary sector, DOE used LMC operating hour data to develop a

distri bution of annual operating hours for HID lamp systems . LMC data for outdoor stationary sources are aggregated by installation type ( e.g. , unlike the commercial and industrial sectors,

8-1DOE aggregates LMC annual operating hour data by application to develop average annual operating hours by installation type ).

For specialty (“sports lighting”) metal halide lamp fixture ( MHLF ) systems > 1000 W, DOE used the LMC operating hours for stadiums to better illustrate the limited operation of these high

- wattage systems, which are used primarily in sports lighting applications.

Table 8.2.1 summarizes the weighted average annual operating hours by sector.

Table 8.2.1. Average Annual HID Lamp System Operating Hours by Sector

Sector Average Annual Operating Hours hr/yr

Commercial 3615

Industrial 6 113 Outdoor Stationary 4 399 Outdoor Stationary
≥2800 K and ≤4500 K; >1000 W and ≤2000 W;

clear; enclosed

- rated 350

Figure 8.2.1 displays the annual operating hours DOE used for HID lamp systems in the

commercial sector. DOE used these annual operating hours in the LCC calculation s.

Figure 8.2.1 Commercial Sector Annual Operating Hour Distribution by Building Type

Figure 8.2.2 displays the annual operating hours for HID lamp systems oper ating in the

industrial sector. DOE used this distribution of annual operating hours in the LCC calculation. 0 1000 2000 3000 4000 5000Hours of Operation per Year

Building Type 

### Commercial Sector Operating Hours by Building Type

8-2Figure 8.2.2 . Industrial Sector Annual Operating Hour Distribution by Building Type

Figure 8.2.3 displays the annual operating hours for HID lamp systems operating in the outdoor stationary sector. DOE use d this distribution of annual operating hours in the LCC

calculation s.

Figure 8.2.3 Outdoor Stationary Sector Annual Operating Hour Distribution by

Installation Type 5200 5400 5600 5800 6000 6200 6400 6600 6800Hours of Operation per Year

Building Type 

### Industrial Sector Operating Hours by Building Type

0 1000 2000 3000 4000 5000 6000

Building Exterior Billboard Stadium Parking RoadwayHours of Operation per Year

Building Type 

### Outdoor Stationary Operating Hours by Application

8-38.3 RESULTS OF THE ENERG Y USE ANALYSIS

DOE calculate d the annual energy use for representative HID lamp systems using annual operating hours and measured input power rating estimates. DOE used the annual energy use results in the LCC and PBP analysi s and the NIA to calculate the operating cost of systems and

to estimate the po tential energy savings of the considered efficacy level s. The results obtained for the energy use analysis can be examined in the “Information Hub” tab of the Microsoft Excel spreadsheet for the LCC and PBP analysis available on the DOE Building Technologies website

at: www1.eere.energy.gov/buildings/appliance_standards/ rulemaking .aspx/ rule id/23

.

8-4REFERENCES

1. U.S. Department of Energy– Office of Energy Efficiency and Renewable Energy. Building Technologies Program

. 2010 U.S. Lighting Market Characterization

. January 2012. DOE

EERE: Washington, D.C. < http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/

2010- lmc

- final

- jan -2012.pdf >

8-5CHAPTER 9. LIFE

- CYCLE COST AND PAYBACK PERIOD ANALYSIS

TABLE OF CONTENTS

9.1 INTRODUCTION ........................................................................................................... 9-1

9.1.1 General Approach for LCC and PBP Analysis .................................................... 9-1

9.1.2 Overview of LCC and PBP Inputs ....................................................................... 9-2

9.2 LIFE

- CYCLE COST INPUTS ........................................................................................ 9-5

9.2.1 Definition ............................................................................................................. 9-5

9.2.2 Total Installed Cost Inputs ................................................................................... 9-6

9.2.2.1 Installation Costs ...................................................................................... 9-7

9.2.3 Operating Cost Inputs .......................................................................................... 9-8

9.2.3.1 Operating Hours ....................................................................................... 9-9

9.2.3.2 Power Rating .......................................................................................... 9-10

9.2.3.3 Electricity Prices .................................................................................... 9-10

9.2.3.4 Electricity Price Trend ........................................................................... 9-11

9.2.4 Lifetime .............................................................................................................. 9-13

9.2.5 Replacement Cost .............................................................................................. 9-13

9.2.6 Disposal Cost ..................................................................................................... 9-14

9.2.7 Analysis Period and Triggering Events ............................................................. 9-14

9.2.8 Discount Rate ..................................................................................................... 9-15

9.2.9 Effective Date of Standard ................................................................................. 9-18

9.3 PAYBACK PERIOD INPUT S ...................................................................................... 9-18

9.3.1 Definition ........................................................................................................... 9-18

9.3.2 Rebuttable Presumption Payback Period ........................................................... 9-18

9.3.3 Inputs.................................................................................................................. 9-19

9.4 LIFE

- CYCLE COST AND PAYBACK PER IOD RESULTS ...................................... 9-19

REFERENCES .......................................................................................................................... 9-23

LIST OF TABLES

Table 9.1.1 Summary Information of Inputs for the Life- Cycle Cost and Payback Period Analysis

................................................................................................................ 9-5 Table 9.2.1 Installation Costs for HID Lamp System Components ............................................ 9-8

Table 9.2.2 Average Annual Operating Hours for HID Lamp Systems by Sector ...................... 9-9 Table 9.2.3 Electricity Prices by State, 2012 ............................................................................. 9-10 Table 9.2.4 Summary of Triggering Events and Purchase Options ........................................... 9-14 Table 9.2.5 Variables Used to Estimate Company Discount Rates ........................................... 9-17

Table 9.2.6 Average Discount Rate by Sector ........................................................................... 9-17

Table 9.4.1 HID Lamps ≥2800 K and ≤4500 K and ≥50 W to ≤400 W—LCC and PBP

Results ................................................................................................................ 9-20

Table 9.4.2 HID Lamps ≥2800 K and ≤4500 K and >400 and ≤1000 W—LCC and PBP

Results ................................................................................................................ 9-20

Table 9.4.3 HID Lamps ≥2800 K and ≤4500 K and >1000 W to ≤2000 W—LCC and

PBP Results ........................................................................................................ 9-21

9-iTable 9.4.4 HID Lamps ≥2800 K and ≤4500 K and ≥50 W to ≤400 W—LCC and PBP Results (2022 Projec ted Market Basis) .............................................................. 9-21

Table 9.4.5 HID Lamps ≥2800 K and ≤4500 K and >400 and ≤1000 W—LCC and PBP Results (2022 Projected Market Basis) .............................................................. 9-22

Table 9.4.6 HID Lamps ≥2800 K and ≤4500 K and >1000 W to ≤2000 W—LCC and PBP Results (2022 Projected Market Basis) ...................................................... 9-22

LIST OF FIGURES

Figure 9.1.1 Flow Diagram of Inputs for the Determination of LCC and PBP ........................... 9-4 Figure 9.2.1 Commercial Sector Electricity Price Trend ........................................................... 9-12 Figure 9.2.2 Industrial Sector Electricity Price Trend ............................................................... 9-12 Figure 9.2.3 Outdoor Stationary Sector Electricity Price Trend ................................................ 9-12

9- iiCHAP TER 9 . LIFE

- CYCLE COST AND PAYBACK PERIOD ANALYSIS

9.1 INTRODUCTION

This chapter describes the analysis the U.S. Department of Energy (DOE) conducts to

evaluate the economic effects on individual consumer s of potential energy conservation

standards for high -intensity discharge (HID) lamps. Because HID lamps must operate with

ballasts , DOE identified a representative ballast and fixture used with each lamp to develop representative HID lamp

- ballast

- fixture systems (hereafter “HID lamp systems”) . HID ballasts and fixtures would not be regulated under potential energy con servation standards for HID lamps ; however, the characteri stics of HID systems (energy consumption, installed cost, etc.) must be considered for estimating economic impacts of analyzed lamp designs.

Energy conservation standards usually decrease operating costs and increase purchase

costs for consumers. This chap ter describes the three metrics used in this analysis to determine

the effect of standards on individual consumers:

1. Life

- cycle cost (LCC) is the total (discounted) consumer cost over the analysis period including purchase price , operating costs (including energy expenditures), and

installation costs.

2. Payback period (PBP) is the number of years it takes a consumer to recover the generally higher purchase price of more energy

- efficient equipment through the operating cost savings of using the more energy- eff icient equipment . The PBP is calculated as the change in first cost divided by the change in operating costs in the first year.

3. Rebuttable payback period is a special case in which the PBP is calculated based on laboratory conditions, specifically DOE test procedure inputs. DOE calculates the aforementioned LCC and PBP using a range of inputs, which are designed to reflect

actual conditions.

Sections 9.2 and 9.3 discuss inputs to the LCC and PBP, respectively. Section 9.4 presents the results for the LCC and PBP analysis. Key variables and calculations are presented for each metric. DOE performs the calculations discussed here using two Microsoft Excel spreadsheet s developed for this rulemaking. Interested parties are invited to download and examine the spreadsheets available at www1.eere.energy.gov/buildings/appliance_standards/ rulemaking.aspx/ruleid/23 . Appendix 9 A of the notice of proposed determination ( NOPD ) technical support document ( TSD ) presents details and instructions for using the spreadsheets.

9.1.1 General Approach for LCC and PBP Analysis

The relationship between increasing selling price and increasing energy efficiency is the predominant influence on the LCC and PBP results. However, other factors related to the

characteristics of the consumer using the equipment also affect the results. Based on the geographic region, sector, and application in which a consumer uses the HID lamps , factors such as energy prices, sales tax, and energy usage can vary. DOE also considers variability in the

9-1discount rate, operating hours, and fixture lifetimes

. DOE accounts for variability by using a Monte Carlo simulation, which reflects separate sensitivity runs.

DOE also considers various scenarios that trigger consumer s to replace existing equipment or install new equipment. DOE analyze d the LCC s of three distinct triggering events.
The “ fixture ” event signifies a consumer inst alling an entire HID fixture with lamp and ballast

. The “ballast” event outlines the costs associated with replacing a lamp and ballast within an existing fixture. Finally, the “lamp” event analyzes the costs associated with replacing only a lamp within an existing fixture and ballast. In several equipment classes when baseline models could no longer be purchased ( because the Energy Policy Act of 2005 (EPAct 2005) prohibition

of the sale of mercury vapor ( MV ) ballasts and of the limitation of 150 –500 W probe- start metal

halide fixtures after 2008 per the Energy Independence and Security Act of 2007 (EISA 2007)),

any incompatible triggering events were excluded from the analysis

.

DOE conducted the LCC and PBP analys is on the baseline HID lamp system s fr om the representative equipment classes identified in the HID market and technology assessment.
NOPD TSD chapter 3 p resents the representative equipment classes and lamp types that DOE

evaluated in this analysis. The following list shows the representative HID lamp equipment

classes that DOE evaluated in this analysis :

• ≥2800 kelvin (K) and ≤4500 K and ≥50 watts ( W) to ≤400 W ; clear; enclosed

• ≥2800 K and ≤4500 K and >400 and ≤1000 W ; clear; enclosed

• ≥2800 K and ≤4500 K and >1000 W to ≤2000 W ; c lear; enclosed

The time period used for the LCC and PBP analyses in this rulemaking is the average remaining lifetime of the baseline HID lamp f i xture

. Recognizing that several inputs to the LCC and PBP analysis are either variable or uncertain, DOE incorp orates Monte Carlo simulation and probability distributions into its LCC and PBP model, by using Microsoft Excel in combination with Crystal Ball, a commercially available add -in program.

9.1.2 Overview of LCC and PBP Inputs

As mentioned previously, t he LCC represents the total consumer expense over the analysis period, including purchase expenses, operating costs (including energy expenditures),

and installation costs. DOE discount ed future operating costs to the time of purchase and

sum med them over the analysis period. The PBP represents the number of years it takes

consumer s to recover the purchase price of more energy -efficient equipment through lower operating costs. The PBP is calculated as the change in first cost divided by the change in
operat ing costs in the first year.

DOE categorize d inputs to the LCC and PBP analysis as follows: (1) inputs for establishing the purchase expense, otherwise known as the total installed cost; and (2) inputs for calculating the expenses incurred during operatio n of the HID lamp system otherwise known as the operating cost.

9-2The primary inputs for calculating the installed cost are:

• End

- User Equipment Price: The end

- user equipment prices represent the consumer price before tax and installation.

• Sales Tax : DOE the n applied sales tax to convert the end

- user equipment price to a

final equipment price including sales tax. Chapter 7 of the NOPD TSD describes the sales tax markup in detail.

• Installation Cost : This input represents the cost to consumer s of installing the HID systems. The installation cost represents all costs required to install the system but

does not include the final equipment price. The installation cost includes labor and overhead. Thus, the total installed cost equals the final eq uipment price plus the

installation cost.

The primary inputs for calculating the operating cost include the following:

• Annual Operating Hours: The annual operating hours are the hours that an HID
system is estimated to be in use during one year. The energy use analysis ( NOPD

TSD chapter 8 ) details how DOE determine d the system operating hours as a function of end-user sector and building type.

• Power Rating : The power draw is the site

- energy usage rate associated with operating

the HID fixture . The energy use analysis ( NOPD TSD chapter 8 ) details how DOE

determine d the power ratings for the HID fixtures considered in the analys is

.

• Electricity Prices: DOE uses the average price per kilowatt -hour ($/kWh) paid by

consumers . DOE determine d e lectricity prices using national average commercial and industrial electricity prices

. For the Monte Carlo analysis at the NOPD stage of this rulemaking , DOE samples from a distribution of electricity prices that includes commercial and industrial prices f or all 50 states and the District of Columbia. DOE develop ed electricity price inputs using 2013 U.S. Energy Information Administration ( EIA ) data.

• Electricity Price Trends : DOE uses the EIA’s Annual Energy Outlook 2013 ( AEO201 3 ) to project electricity prices. 1 For the results presented in this chapter,

DOE used the AEO201 3 reference case.

• Lifetime: Lifetime is the total time in operation after which the consumer retires the

HID lamp, ballast

, or fixture from service.

• Discount Rate : The d iscount rate is the rate at which DOE discount ed future expenditures to establish their present value.

• Analysis Period: Analysis period is the time span over which DOE calculates the

LCC. For th e NOPD analysis , it was assumed as equal to the average rema ining

baseline fixture lifetime for each equipment class.

9-3Figure 9.1.1 depicts the relationships between the installed cost and operating cost inputs for the calculation of the LCC and PBP. In this figure, the rectangular boxes indicate the inputs,

the hexagons indicate intermediate calculated values, and the circles indicate the analysis outputs (LCCs and PBPs).

----------------------------------

Figure 9.1.1 Flow Diagram of Inputs for the Determination o f LCC and PBP

Table 9.1.1 summarizes the input values that DOE uses to calculate the LCC and PBP for

HID systems using analyzed lamp types. DOE characterized several of the operating cost inputs with probability distributions that capture the input’s uncertainty and/or variability. Table 9.1.1

also lists the NOPD TSD chapter that details the inputs.

9-4Table 9.1.1 Summary Information of Inputs for the Life -Cycle Cost and Payback Period Analys is

Factor Input Value TSD Reference Section

End

- User Equipment Price Varies with HID lamp technology ; future real price

decline is projected using AEO indices Chapters 6 , 7 , 9

Sales Tax Varies by state Chapter 7

Installation Cost Varies by equipment class Chapter 9 Annual Operating Hours Vary by equipment class and sector Chapter 8 Power Rating Varies with HID lamp system Chapter 5

, 7 Electricity Prices Vary by sector and state Chapter 9 Electricity Price Trends Vary with AEO price projection scenario Chapter 9

Total Installed Cost Varies with HID lamp system, state , and sector Chapters 6

, 7

Fixture Lifetime Varies by fixture location Chapters 5, 9

Ballast Lifetime Varies by ballast technology Chapters 5, 9 Lamp Lifetime Varies with HID lamp system Chapters 5, 9 Disposal Cost Varies by equipment type Chapter 9

Discount Rate Varies with sector Chapter 9 Analysis Period Varies by baseline fixture

, triggering event , and vintage category Chapter 9

Sections 9.2 and 9.3 discuss the inputs depicted in this table of installed costs and operating costs.

9.2 LIFE

- CYCLE COST INPUTS

9.2.1 Definition

LCC is the total consumer cost over the life of equipment , including total installed costs, operating costs, replacement costs, and residual value. Future operating costs and replacement

costs are discounted to the analysis start year ( 2017) and summed over the analysis period. The

LCC of an HID system is defined by the following equation:



# ∑

= 

###        

+ + += N

t t tt



### r RC OC ICLCC

1 

### )1(

Eq. 9.1

Where:

LCC = life

- cycle cost ($),

IC = total installed cost ($),

N = analysis period, ∑ = sum over the analysis period, from year 1 to year N

, OC = operating cost ($),

RC = lamp

, ballast

, or fixture replacement cost ($),

r

= discount rate,

t = year for which operating cost

, replacement cost , or disposal cost is determined

.

DOE expresses all the costs in its LCC and PBP analyses in 2012 dollars (2012$).

9-59.2.2 Total Installed Cost Inputs

The total installed cost to the consumer is defined by the following equation:

INST FEP IC += Eq. 9.2

W here :

FE P = final equipment price ( i.e. , consumer price for the equipment only, including sales tax; $),

and

INST = installation cost or the consumer price to install equipment ( i.e. , the cost for labor and

materials ; $).

In the equipment price determination ( NOPD TSD chapter 6) and markups analysis ( NOPD TSD chapter 7), DOE develop ed end

- user equipment prices and sales taxes to derive

final equipment prices. DOE then applied installation costs where necessary to derive the total

installed costs for use in the LCC. The following shows inputs to d etermine the total installed

costs:

• end-u ser equipment p rice ($)

• s ales t ax ($) , and

• i nstallation cost ($).

The end

- user equipment price represents the average purchase price a consumer pays before sales tax for the HID system . The sales tax represents s tate and local sales taxes applied to

the end

- user equipment price. It is a multiplicative factor that increases the end

- user equipment price. The installation cost represents all costs required to install the HID system but does not include the final equipment price. The installation cost includes labor and overhead. Thus, the total installed cost equals the final equipment price plus the installation cost. DOE calculate d the

total installed cost for the HID systems, analyzed based on the following equation:

INST MU PRICE INST FEP IC

TAX +×= +=

Eq. 9.3

W here :

IC = total installed cost,

FE P = f inal equipment price

, INST = installation cost,
PRICE = end

- user equipment price, and

MU TAX = sales tax mark up

.

As mentioned previously, DOE also considers various scenarios that prompt consumer s to replace existing equipment or install new equipment. DOE analyzed the LCCs of three d istinct triggering events. The “fixture” event signifies a consumer installing an entire HID fixture with

9-6lamp and ballast. The “ballast” event outlines the costs associated with replacing a lamp and ballast within an existing fixture. Finally, the “lamp” event analyzes the costs associated with replacing only a lamp within an existing fixture and ballast.

On February 22, 2011, DOE published a notice of data availability (NODA; 76 FR at 9696) stating that DOE may consider improving regulatory analysis by a ddressing equipment price trends. For this NOPD analysis and consistent with the NODA, DOE examined two methods for estimating price trends for HID lamp system s : using historic al producer price indices (PPI) and using projected price indices (called deflators). With PPI data, DOE found both positive and negative real price trends, depending on the specific time period examined, and did not use this method to adjust system prices. DOE instead adjusted system p rices using deflators used by EIA to develop the AEO . When adjusted for inflation, the deflator- based price indices

decline from 1.00 in 20 17 to approximately 0.90 in 2046. DOE used these indices to adjust equipment prices across the national impact analysis (NIA) analysis period (see NOPD TSD chapter 11) and the LCC analysis periods. A more detailed discussion of price trend modeling and calculations is provided in appendix 9B of the NOPD TSD

.

Chapter s 6 and 7 of the NOPD TSD provide detail on end- user equ ipment pric es and

sales tax. Discussion about installation costs follows.

9.2.2.1 Installation Costs

Installation costs for HID lamp systems include the installation of the fixture, maintenance of the ballast, and replacement of the lamp. DOE used data gathered in the HID lamps determination of 2010 2 as well as other research to estimate the installation costs.

During the January 2012 public meeting for the f ramework document for the metal halide lamp fixtures energy conservation standard, a manufacturer commented:

As far as maintenance costs, we’d urge you to consider that, particularly in exterior environments; maintenance costs can be quite significant. It's difficult to get a bucket truck to a site to work on pole-mounted luminaires for less than a thousand dollars just to get it there and the average that our experience shows needs to be attributed somewhere between $150 and $300 per luminaire per servicing. So that is higher than you would traditionally think it would be for interior... (Docket No. EERE-2009- BT

- STD -0018, Philips, No. 8 at p. 16) a

For this NOPD analysis, DOE assigned each equipment class a certain percentage of indoor vs. outdoor fixtures. In general, 25

- 30 percent of MV and MH lamps are assumed to operate indoors. DOE assumed that the installation time to replace an existing fixture and to

install a new construction fixt ure is equal. DOE also assumed that all lamp rep lacements are spot

a A notation in this form provides a reference for information that is in the docket of DOE’s rulemaking to develop energy conservation standards for metal halide lamp fixtures ( Docket No. EERE

- 2009

- BT

- STD

- 0018 ), which is

maintained at www.regulations.gov . This notation indicates that the statement preceding t he reference is document

number 8 in the docket for the metal halide l amp fixtures energy conservation standards rulemaking, and appears at

page 16 of that document.

9-7replacements, versus the group relamping more prevalent in fluorescent lamp systems. Table

9.2.1 lists installation costs by equipme nt class to install a n HID fixture, ballast, or lamp.

Table 9.2.1 Installation Costs for HID L amp S ystem Component s

Representative Equipment Class Representative Lamp Type Installation Costs
2012$

Fixture Ballast Ballast

Retrofit Kit Lamp

≥2800 K and ≤4500 K;

≥50 W and ≤400 W; clear; enclosed 100 W MV 380.30 250.13 282.12 202.31

175 W MV 386.91 244.98 277.47 196.66

250 W MV 402.11 245.99 278.98 197.16

400 W MV 432.79 248.15 282.14 198.32

400 W MH probe 433.04 248.30 282.29 198.47

≥2800 K and ≤4500 K >400 W and ≤1000 W; clear; enclosed 1000 W MV 570.45 263.53 301.54 209.68

1000 W MH probe 570.45 263.53 301.54 209.68

≥2800 K and ≤4500 K;

>1000 W and ≤2000
W; clear; enclosed 2000 W MH 779.63 276.92 321.62 216.38

DOE derived times for installation, cost s of related equipment ( e.g. , bucket truck), and

labor rates for electricians from RS Means 3 and Sweets Electrical Cost Guide

. 4 Labor rates are

the sum of the wage rate, employer -paid fringe benefits ( i.e. , vacation pay, employer-paid health, and welfare costs), and any appropriate training and industry advancement funds costs. DOE

used the labor rate from RS Means and Sweets coupled with a markup for benefits for an hourly

rate of $67.00 (in 2012$).

9.2.3 Operating Cost Inputs

The operating cost represents the costs incurred in the operation of the HID lamp system

. Below are the inputs for operating costs:

• annual operating hours

• power rating (W)

• electricity prices ($/k Wh)

• electricity price trends

• discount rate (%)

• analysis period ( years )

• annualized replacement costs for ballasts

• annualized replacement costs for lamps

The analysis period, discount rate, and effective date of the potential energy conservation standard are required for determining the operating cost and for establishing the operating cost

9-8present value. The electricity consumption for the baseline and other efficacy levels examined enable comparison of the standards’ operating costs.

The annual operating hours are the estimated hours that an HID lamp system is in use during 1 year. Power rating refers to the rate of site energy usage associated with operating the

HID lamp system . Both the annual operating hours and power rating are used to calcul ate the total annual energy consumption. Electricity prices used in the analysis are the price per

kilowatt -hour in cents or dollars ( e.g. , $/kWh) paid by each consumer for electricity. DOE uses electricity price trends from AEO201 3 to forecast electricity prices for future year analysis. These trends with the electricity price and annual energy consumption are used to calculate the energy cost in each year. DOE defines energy cost s by the following equation:



## ( ) EPTEP OH PWR EPTEP E OC

cons



### ××× = ××=
)1000/(

Eq. 9.4

Where:

OC = operating costs,

E

cons = annual energy consumed,

EP = electricity price,

EPT = electricity price trend factor relative to 20 12,

PWR = power rating (rate of energy use, measured in watts), and

OH = annual operating hours.

The remainder of this section provides information about each of the above input variables that DOE used to calculate the operating costs.

9.2.3.1 Operating Hours

The energy use analysis ( NOPD TSD chapter 8) details how DOE determines the annual energy consumption for baseline and standar ds- compliant equipment. An important input in determining the energy consumption is the total hours per year that the equipment is in operation.

DOE establishe d operating hour distributions for HID fixtures b ased primarily on data from the 2010 U.S. Lighting Market Characterization

. 5 Table 9.2.2 presents the weighted average operating hours for HID fixtures for each sector.

Table 9.2.2 Average Annual Operating Hours for HID Lamp Systems by Sector

Sector Averag e Annual Operating

h r

/yr

Commercial 3615

Industrial 6 113
Outdoor Stationary 4399
Sports Lighting ( >1000 W ) 350

9-99.2.3.2 Power Rating

As described in the energy use analysis ( NOPD TSD chapter 8), DOE uses the power rating (in watts) with the annual operating hours (in hours) to calculate the annual energy usage (in kilowatt -hours) of the HID lamp systems

.

9.2.3.3 Electricity Prices

DOE estimates electricity prices for commercial, industrial and outdoor stationary sectors by state using EIA F orm 8 26 data. 6 For the NOPD analysis, DOE derived outdoor stationary electricity prices by scaling the average commercial sector electricity rate by a factor of 0.82 to reflect the lower rate faced by outdoor sector consumers. Table 9.2.3 lists the values for 2012 as of June 2013.

Table 9.2.3 Electricity Prices by State , 2012

State Electricity Prices

2012 cents/kWh

Commercial Sector Industrial Sector Outdoor Stationary Sector

Alabama 10.58 6.20 8.68

Alaska 14.79 16.75 12.13

Arizona 9.54 6.53 7.82

Arkansas 7.68 5.65 6.30

California 13.60 10.73 11.15

Colorado 9.34 6.94 7.66

Connecticut 14.70 12.76 12.05

Del a ware 10.11 8.34 8.29

Dist. of Columbia 12.00 5.43 9.84

Florida 9.76 8.04 8.00

Georgia 9.47 5.89 7.77

Hawaii 34.83 30.77 28.56

Idaho 6.83 5.55 5.60

Illinois 8.19 5.91 6.72

Indiana 9.07 6.35 7.44

Iowa 8.00 5.33 6.56

Kansas 9.13 6.88 7.49

Kentucky 8.66 5.35 7.10

Louisiana 7.79 4.75 6.39

Maine 11.58 7.87 9.50

Maryland 10.52 8.12 8.63

Massachusetts 13.97 12.91 11.46

Michigan 10.95 7.73 8.98

Minnesota 8.86 6.59 7.27

Mississippi 9.28 6.16 7.61

Missouri 8.16 5.85 6.69

Montana 9.16 5.04 7.51

Nebraska 8.40 6.81 6.89

Nevada 8.86 6.46 7.27

New Hampshire 13.40 11.82 10.99

New Jersey 12.83 10.54 10.52

9- 10State Electricity Prices

2012 cents/kWh

Commercial Sector Industrial Sector Outdoor Stationary Sector

New Mexico 9.30 5.83 7.63

New York 15.08 6.67 12.37

North Carolina 8.61 6.34 7.06

North Dakota 7.98 6.66 6.54

Ohio 9.47 6.21 7.77

Oklahoma 7.26 5.03 5.95

Oregon 8.34 5.61 6.84

Pennsylvania 9.37 7.24 7.68

Rhode Island 12.04 10.86 9.87

South Carolina 9.57 5.96 7.85

South Dakota 8.01 6.57 6.57

Tennessee 10.29 7.12 8.44

Texas 8.17 5.73 6.70

Utah 8.05 5.62 6.60

Vermont 14.30 9.96 11.73

Virginia 8.11 6.72 6.65

Washington 7.67 4.11 6.29

West Virginia 8.42 6.33 6.90

Wisconsin 10.54 7.41 8.64

Wyoming 8.23 6.03 6.75

9.2.3.4 Electricity Price Trend

To project future energy prices, DOE used AEO201 3 price estimates to compute real price increases. DOE calculates the LCC and PBP using three separate projections from

AEO201 3 : reference case, low economic growth, and high economic growth. 1 These three cases reflect the uncertainty of economic growth in the forecast period. The high and low growth cases show the projected effects of alternative growth assumptions on energy markets. DOE

normalizes t hese three AEO2013 scenarios to the 2012 electricity price, and then uses that electricity price factor to scale the 20 12 electricity prices into the future. Figure 9.2.1 through Figure 9.2.3 show commercial, industrial, and outdoor stationary electricity p rice trends, respectively, based on the three AEO2013 projections. The LCC results presented in this chapter

are based on the AEO201 3 reference case.

9- 11Figure 9.2.1 Commercial Sector Electricity Price Trend

Figure 9.2.2 Industrial Sector Electricity Price Trend

Figure 9.2.3 Outdoor Stationary Sector Electricity Price Trend 0.6 0.7 0.8 0.9 1.0 1.1 1.2 1.3 1.4

2010 2015 2020 2025 2030 2035 2040Price Trend (1=Price in 2012)

Year Low Economic Growth

Reference Case

High Economic Growth

0.6 0.7 0.8 0.9 1.0 1.1 1.2 1.3 1.4

2010 2015 2020 2025 2030 2035 2040Price Trend (1=Price in 2012)

Year Low Economic Growth

Reference Case

High Economic Growth

0.6 0.7 0.8 0.9 1.0 1.1 1.2 1.3 1.4

2010 2015 2020 2025 2030 2035 2040Price Trend (1=Price in 2012)

Year Low Economic Growth

Reference Case

High Economic Growth

9- 12In the LCC spreadsheet, these electricity price trends are used to project electricity prices into the future, which are then multiplied by the annual energy usage. The resulting operating costs are presented in both the LCC spreadsheets and the LCC results tables in this chapter.

9.2.4 Life time

DOE define d lifetime as the age in years or hours of operation when a fixture, ballast

, or lamp is retired from service. For fixtures in all equipment classes, DOE assumed lifetimes for

interior and exterior fixtures as 20 and 25 years , respectively. DOE assumed magnetic and

electronic ballast lifetimes of 40,000 hours and 50,000 hours, respectively. HID lamp lifetimes vary by technology and equipment class. Based on estimated shares of interior and exterior applications, DOE developed weighted average fixture

, ballast

, and lamp lifetimes for each representative lamp type

. The se lifetimes can be examined in the “Information Hub” tab of the

Microsoft Excel spreadsheet for the LCC and PBP analysis available on the DOE Building Technologies website at: www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23

DOE also assumed that equipment lifetimes can vary due to both physical failure and economic factors ( e.g. , early replacements due to retrofits). Consequently, DOE accounted for variability in equipment lifetime s in the LCC and PBP analysis via the Monte Carlo simulation.

9.2.5 Replacement Cost

Replacement costs are the labor and materials costs associated with replacing a lamp or ballast at the end of its lifetime. Becaus e the LCC analysis period is based on the remaining lifetime of the baseline fixture, it is at times necessary to replace a lamp or ballast within the analysis period. Each year in which a lamp or ballast reaches the end of its life, a new lamp or ballast is purchased and installed at the beginning of that year, and the equipment cost and installation cost are discounted back to the base year of the analysis period. During y ears in which replacement is necessary, DOE based the replacement costs on the total installed cost inputs, as seen in the following equation:



### INST MU PRICE INST FEPRC

TAX 

### +×= +=

Eq. 9.5

Where:

RC = replacement cost, expressed in dollars,

FEP = final equipment price (price for the equipment only) expressed in dollars,

INST = installation cost,
PRICE = end

- user equipment price expressed in dollars, and

MU TAX = sales tax.

For the years when no replacement is necessary, the replacement costs are set to zero.

9- 13Replacement costs are annualized in such a way that national net present value ( NOPD

TSD chapter 11) calculations are unaffected by computing annualized values instead of capital

costs. Similar to calculating the monthly premiums on a loan, replacement costs during a fixture lifetime are discounted to the beginning of the analysis period, and monthly payments are calculated such that the sum of annualized, discounted replacement costs equals the sum of discounted capital costs across a HID lamp system’s lifetime. The replacement costs only include

the end

- user equipment price of the ballast or lamp and the installation cost of the ballast or lamp, rather than prices or co sts associated with the entire HID lamp system

.

9.2.6 Disposal Cost

The cost of recycling the HID lamp and/or ballast is its disposal cost. DOE performed research on recycling costs for HID lamps and ballasts and found that, on average, disposing of a

ballast c osts about $3 and disposing of lamps costs about $2. 7 Balla st recycling rate data are not available, so DOE conservatively assumes 10 percent of ballasts used in the commercial and industrial sectors are recycled and 15 percent of lamps are recycled. A common approach to include disposal costs would be to average out recycling costs across the entire consumer base ; however, given the assumed low recycling rates, the average recycling cost per consumer for

eith er a lamp or a ballast would be approximate ly $0.30. DOE regarded this cost as insignificant, and did not include a disposal cost component in the NOPD LCC analysis.

9.2.7 Analysis Period and Triggering Events

In general, three equipment- purchase triggering events were modeled: lamp purchase (replaceme nt lamp), lamp and ballast purchase (lamp that is purchased when the fail ed ballast is replaced

— also referred to as a ballast event ), and fixture purchase (fixture replacement or new

constructi on). These are the base

- case events. In the standards case, up to six purchase options may be available as compliance paths , depending on the triggering event and technology availability

. Table 9.2.4 provides a summary of the bas ic triggering event and purchase option compatibility , with gray cells indicating incompatibility

.

Table 9.2.4 Summary of Triggering Event s and Purchase Options

Compliance Path Triggering Event

Fixture Replacement Ballast Replacement Lamp Replacement Reduced wattage fixture Fixture Fixture Fixture Reduced wattage ballast

retrofit kit Ballast retrofit kit and lamp Ballast retrofit kit and lamp Reduced wattage lamp Retrofit lamp Equal wattage fixture Fixture Fixture Fixture Equal wattage ballast retrofit

kit Ballast retrofit kit and lamp Ballast retrofit kit and lamp Equal wattage lamp Retrofit lamp

The analysis period is the time span over which the LCC is calculated. Typically, analysis periods are set to the remaining life of the baseline fixture

. In the case of a fixture event, the analysis period is generally the life of the (newly installed) baseline fixture

. With ballast and lamp events, the analysis period, by default, is one half the full baseline fixture life, as the existing fixtures are assumed to be at half

- life ( and e xisting ballasts are also assumed to be at

9- 14half

- life in the case of a lamp event ). In order to avoid exchanging a fixture during the analysis period, the analysis periods for such cases are shortened.

However, due to existing regulatory restrictions, there are a number of special cases for analysis period and/or triggering event compatibility. For equipment classes with MV lamp system baselines, DOE assumed a max imum analysis period of 6 years (2017

- 2022). MV ballasts, except for those with specialty applications ( e.g. , reprographics), can no longer be manufactured or imported as of January 1, 2008. (42 U.S.C. 6295(ee)); 10 CFR 431.286 Therefore, DOE assumed that consumers could not purchase a new MV fixture or ballast and lamp in 2017, and that the LCC analysis period would equal the minimum of the following: 1 ) half the expected ballast life for the particular technology, and 2 ) the remaining lifetime of an

exist ing MV fixture ballast purchased in 2008. In the latter case, the MV ballast was assumed to have a lifetime of 15 years ( i.e. , 2008

- 2022), with a remaining lifetime of 6 years beginning in

2017.

For equipment classes with probe- start metal halide (probe

- MH ) lamp system baselines (175 W, 250 W, 400 W, and 1000 W ), DOE did not analyze fixture events

. The EISA 2007

mandate d minimum ballast efficiencies for MH fixtures sold after January 1, 2009 , effectively eliminating probe -MH fixtures in the >=150 to <=500 W range from the marketplace . (42 U.S.C. 6295(hh)(1)) Similarly, the 2014 Metal Halide Lamp Fixture s Final Rule does not allow metal halide lamp fixture manufacturers to utilize a probe

- start ballast for fixtures in the >500 W to <= 1000 W range. 79 FR 7745, 7844 (February 10, 2014). Therefore, DOE assumed that consumers could not purchase such new probe-MH fixtures in 2017.

The specific analysis periods utilized by the analysis can be examined in the “Information

Hub” tab of the Microsoft Excel spreadsheet for the LCC and PBP analysis available on the DOE Building Technologies website at: www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23

9.2.8 Discount Rate

The discount rate is the rate at which DOE discounts future expenditures to establish their present values. DOE derived the discount rates for this rulemaking separately for commercial, industrial, and outdoor stationary applications using the same analytical framework.

Most companies use both debt and equity capital to fund investments; for most companies, therefore, the cost of capital is the weighted average of the cost to the firm of equity and debt financing. 8

DOE estimates the cost of equity financing using the Capital Asset Pricing Model (CAPM) . A mong the most widely used models to estimate the cost of equity financing, the

CAPM assumes that the cost of equity is proportional to the amount of systematic risk associated

with a firm. For example, the cost of equity financing tends to be high when a firm faces a large degree of systematic risk, and the cost tends to be low when the firm faces a small degree of systematic risk.

9- 15The degree of systematic risk facing a firm and the s ubsequent cost of equity financing are determined by several variables, including the risk coefficient of a firm (beta

, 

### β ), the expected return on risk- free assets ( R f ), and the additional return expected on assets facing average market risk (known as the equity risk premium, or ERP). The beta indicates the degree of risk associated with a given firm, relative to the level of risk (or price variability) in the overall stock market. Betas usually vary between 0.5 and 2.0. A firm with a beta of 0.5 faces half the risk of other stocks in the market; a firm with a beta of 2.0 faces twice the overall stock

market risk.

Following this approach, the cost of equity financing for a particular company is

determined by the equation:



## ( ) ERP Rk

fe



### ×+= β

Eq. 9.6

Where:

k

e = the cost of equity for a company, expressed in dollars,

R

f = the expected return of the risk free asset, expressed in dollars,



### Β = the risk coefficient , and

ERP = the equity risk premium, expressed in dollars.

The cost of debt financing ( k d

) is the yield or interest rate paid on money borrowed by a company (raised, for example, by selling bonds). As defined here, the cost of debt includes compensation for default risk and includes deduction s for taxes.

DOE estimates the cost of debt for companies by adding a risk adjustment factor to the current yield on long-term corporate bonds (the risk- free rate). This procedure is used to estimate current and future company costs to obtain debt financing. The adjustment factor is based on indicators of company risk, such as credit rating or variability of stock returns.

The discount rate of companies is the weighted average cost of debt and equity financing, less expected inflation. DOE estimates the dis count rate using the equation:

k = k

e × w e + k d × w d Eq. 9.7

Where:

k = the ( nominal ) cost of capital,

k

e and k d = the expected rates of return on equity and debt, respectively, and

w e and w d = the proportion of equity and debt financing, respectively.

The real discount rate is the nominal discount rate adjusted for expected inflation.

The expected return on risk- free assets, or the risk

- free rate, is defined by the current yield on long- term (10- year) government bonds, as suggested b y Damodaran

. 9 The ERP

9- 16represents the difference between the expected (average) stock market return and the risk

- free

rate. As Table 9.2.5 shows, DOE uses an ERP estimate of 4.0 percent, which it took from the Damodaran Online site (a private website associated with New York University’s Stern School of Business, which aggregates information on corporate finance, investment, and valuation). 10

Table 9.2.5 Variables Used to Estimate Company Discount Rates

Variable Symbol Average Value

% Source

Risk

- Free Asset Return R f 6. 4 Damodaran Online
Equity Risk Premium ERP 4.0 Damodaran Online
Expected Inflation R 3.8 U.S. Bureau of Economic Analysis
Cost of Debt (After Tax) k d 6.7 Damodaran Online
Percent Debt Financing w d 24.0 Damodaran Online
Systematic Firm Risk B 1.02 Damodaran Online

DOE calculates an expected inflation of 3. 8 percent from the average of the inflation rate

over 1972

- 2012. 11 DOE obtained the cost of debt, percent debt financing, and systematic firm

risk from the Damodaran Online website. Ta ble 9.2.5 shows the average values across all private companies. However, the cost of debt, percent debt financing, and systematic firm risk vary by

sector.

DOE took the sample from the list of companies included in the Value Line investment

survey 12 and listed on the Damodaran Online website to calculate cost of capital by sector

. The sample includes the cost of debt, the firm beta, the percent of debt and equity financing, the riskfree return, and the equity risk premium, and it contains 1259 companies in the commercial

sector, 3293 entities in the industrial sector , and 4423 entities in the outdoor stationary sector. DOE estimates the cost of debt financing for these companies from the long

- term government bond rate and the standard deviation of the stock price. For publicly owned entities , the discount rate represents an average of the Federal rate and the state and local bond rate. DOE drew the Federal rate directly from the U.S. Office of Management and Budget (OMB) discount rate for

investments in government building energy efficiency. 13 DOE estimates the s tate and local

discount rate from the interest rate on state and local bonds between 1973 and 2012. 14 DOE uses this information to estimate the weighted

- average cost of capital for all the sectors.

DOE estimates discount rate distributions for the different sectors as a weighted average of the distributions for the different ownership types. The resulting weighted average discount

rates are summarized in Table 9.2.6

.

Table 9.2.6 Average Discount Rate by Se ctor

Sector Discount Rate

%

Commercial 4. 9

Industrial 4. 7
Outdoor Stationary 3.4

9- 179.2.9 Effective Date of Standard

The effective date is the date when a standard becomes operative ( i.e. , the date by which lamp manufacturers must manufacture equipment that complies with the standard). DOE

calculated the LCCs for all consumer s as if each would purchase new equipment in the year the potential new standard takes effect (2017) . However, DOE b ased the cost of the equipment on

the most recent available data . A ll dollar values are expressed in 2012$.

9.3 PAYBACK PERIOD INPUT S

9.3.1 Definition

The PBP is the amount of time it takes the consumer to recover the assumed higher purchase cost of more energy

- effi cient equipment as a result of lower operating costs. Numerically, the PBP is the ratio of the increase in purchase cost ( i.e. , from a less efficient design to a more efficient design) to the decrease in annual operating expenditures. This type of

calculation is kno wn as a “simple” PBP, because it does not take into account changes in operating cost over time or the time value of money. That is, the calculation is done at an

effective discount rate of 0 percent.

The equation for PBP is:

OC IC PBP ∆ ∆

=

Eq. 9.8

Where:

PBP = payback period ( years ),

∆ IC = difference in the total installed cost between the more effic acious standard level equipment (effica cy levels 1, 2, etc.) and baseline (effic a cy level 0) equipment, and



### ∆ OC = difference in annual operating costs.

PBPs are expressed in years. PBPs greater than the life of the equipment mean that the

increased total installed cost of the more effic acious equipment is not recovered in reduced operatin g costs over the lifetime of that equipment. PBPs were capped at 100 years, a value deemed to sufficiently show lack of cost- effectiveness under the PBP metric.

9.3.2 Rebuttable Presumption Payback Period

Section 325(o)(2)(B)(iii) of the Energy Policy and Conservation Act establishes a rebuttable presumption that an amended standard for HID lamps is economically justified if the Secretary finds that “the additional cost to the consumer of purchasing a product complying with

an energy c onservation standard level will be less than three times the value of the energy. . . savings during the first year that the consumer will receive as a result of the standard, as calculated under the applicable test procedure .” (42 U.S.C. 6295(o)(2)(B)(iii )) This rebuttable presumption test is an alternative path to establishing economic justification compared to consideration of the seven factors set forth in 42 U.S.C. 6295(o)(2)(B)(i)(I)– (VII).

9- 18To calculate energy savings for the rebuttable presumption payback period, the input power of the HID lamp system is multiplied by the usage profile ( i.e. , hours of operation) of that system. For the engineering analysis, DOE estimated the input power of representative HID lamp systems based on manufacturer catalog data , which represents real -world operating conditions

for th is equipment. Energy savings calculations in the LCC and PBP analys is use these representative system power ratings as well as the applicable usage profiles. Because DOE

calculate d PBP s in a meth odology consistent with the rebuttable presumption test in the LCC and PBP analyses, DOE did not perform a stand

- alone rebuttable presumption analysis, as it is already embodied in the LCC and PBP analyses.

9.3.3 Inputs

The data inputs to PBP are the total inst alled cost of the equipment to the consumer for each efficacy level (EL) and the annual (first year) operating costs for each EL . The inputs to the

total installed cost are the final equipment price and the installation cost. The inputs to the operating costs are the fixture input power rating, annual operating hours, and electricity cost. The PBP uses the same inputs as the LCC calculation described in section 9.2 , except that electricity price trends are not required. Since the PBP is a “simple” (undiscounted) PBP, the required electricity cost is only for the year in which an energy conservation stan dard is to take

effect ( e.g. , 2017) . The electricity price DOE uses in the PBP calculation for electricity cost is the price projected for 201 7, expressed in 2012$, but not discounted to 2012. DOE does not use

discount rates in the PBP calculation.

9.4 LIFE

- CYCLE COST AND PAYBACK PERIOD RESULTS

This section presents LCC results for each HID lamp design DOE considers. This section uses the terms “positive LCC savings” and “negative LCC savings.” When a potential energy conservation standard results in “positive LCC savings,” the LCC of the standards- compliant system is less than the LCC of the baseline system and the consumer benefits. A consumer is adversely affected when a n amended standard results in “negative LCC savings” ( i.e. , when the

LCC of the standards- compliant system is higher than the LCC of the baseline system ).

As stated earlier, DOE conducts a series of LCC calculations for each baseline HID lamp
system

. Key inputs consist of using historical electricity prices from EIA File 8 26 , electricity price projections from the AEO201 3 reference case, and an analysis period based on fixture

lifetimes.

DOE is analyzing 3 representative equipment classes for HID lamps , as discussed in

section 9.1.1

. Table 9.4.1 through Table 9.4.3 present the NOPD results for each of these representative equipment classes by baseline lamp type

. DOE is also presenting the installed costs
of HID lamp systems in order to compare the up

- front costs that consumers must bear when purchasing baseline or standards

- case systems. All dollar figures are given in 2012$.

The results in Table 9.4.1 are mixed

. The average LCC savings at EL 1 are negative, with essentially all consumer s experiencing either no impact or negative impact

. For EL 2, the average LCC savings are positive, but only 1 2 percent of consumer s enjoy net benefits. However, for EL 3, the LCC savings are positive, with net benefits experienced by majority of impacted consumers

.

9- 19This line item is the exception in the LCC analysis, though. In Table 9.4.2 and Table 9.4.3 , the average LCC savings at all ELs are negative, with almost all consumers experienc ing either no impact or negative impact.

Table 9.4.1 HID Lamps ≥2800 K and ≤4500 K and ≥50 W to ≤400 W— LCC and PBP

Results

Effic a cy

Level Life

- Cycle Cost
2012$ Life

- Cycle Cost Savings

Median Payback

Period

Y ears Installed

Cost Discounted Operating

Cost LCC Average Savings
2012$ Percent age of

Consumer s that

Experience *

Net

Cost No Impact Net

Benefit

Baseline 309.16 1671.22 1980.38

-- -- -- -- --

1 316.37 1667.70 1984.07

- 3.69 2 98 0 100

2 368.59 1602.68 1971.27 9.11 53 35 12 100

3 520.38 1374.17 1894.55 85.83 35 23 42 11.3

* Any minor incongruities among various reported metrics are the result of rounding.

Table 9.4.2 HID Lamps ≥2800 K and ≤4500 K and >400 and ≤1000 W— LCC and PBP

Results

Effic a cy

Level Life

- Cycle Cost
2012$ Life

- Cycle Cost Savings

Median Payback

Period

years Installed

Cost Discounted Operating

Cost LCC Average Savings
2012$ Percent age of

Consumer s that

Experience *

Net

Cost No Impact Net

Benefit

Baseline 444.54 5755.21 6199.75

-- -- -- -- --

1 445.65 5754.56 6200.22

- 0.47 0 100 0 100

2 486.34 5792.61 6278.94

- 79.19 91 7 1 100

* Any minor incongruities among various reported metrics are the result of rounding, including cases where the percentage of consumers experiencing a net cost or net benefit are greater than zero, but round to

zero.

9- 20Table 9.4.3 HID Lamps ≥2800 K and ≤4500 K and >1000 W to ≤20 00 W

— LCC and PBP

Results

Effic a cy

Level Life

- Cycle Cost
2012$ Life

- Cycle Cost Savings

Median Payback

Period

years Installed

Cost Discounted Operating

Cost LCC Average Savings
2012$ Percent age of

Consumer s that

Experience *

Net

Cost No Impact Net

Benefit

Baseline 534.23 596.88 1131.11

-- -- -- -- --

1 592.96 554.33 1147.29

- 16.18 6 91 2 39. 1

* Any minor incongruities among various reported metrics are the result of rounding.

It is important to note that these results reflect a snapshot of the market in 2017, with the

LCC line

- item results aggregated to the EL

- level via the use of 2017 equipment shipments as weights. As a result, these results do not reflect the long

- term dynamics o f the declining market for HID equipment. The standard LCC a nalysis, by its nature, does not account for the declining HID fixture stock, as the NIA does over its analysis period

.

To examine to what degree near

- term changes in the market impact the results, DOE also aggregated the LCC results using 2022 shipment weights. These results are reported in Table 9.4.4 through Table 9.4.6 . These results are generally more negative than those for the standard, 2017

- based results. Only EL3 in Table 9.4.4 offers positive LCC savings , and those are substantially reduced from the prior levels. For every equipment class and EL, a majority of impacted consumers experience negative benefits.

Table 9.4.4 HID Lamps ≥2800 K and ≤4500 K and ≥50 W to ≤400 W— LCC and PBP

Results (2022 Projected Market Basis)

Effic a cy

Level Life

- Cycle Cost
2012$ Life

- Cycle Cost Savings

Median Payback

Period

Y ears Installed

Cost Discounted Operating

Cost LCC Average Savings
2012$ Percent age of

Consumer s that

Experience *

Net

Cost No Impact Net

Benefit

Baseline 303.01 1626.38 1929.39

-- -- -- -- --

1 303.41 1626.17 1929.58

- 0.19 0 100 0 100

2 508.38 1479.10 1987.48

- 58.09 52 37 11 41.3

3 569.12 1337.34 1906.45 22.94 42 23 35 16.1

* Any minor incongruities among various reported metrics are the result of rounding, including cases where the percentage of consumer s experiencing a net cost or net benefit are greater than zero, but round to

zero.

9- 21Table 9.4.5 HID Lamps ≥2800 K and ≤4500 K and >400 and ≤1000 W— LCC and PBP

Results (2022 Projected Market Basis)

Effic a cy

Level Life

- Cycle Cost
2012$ Life

- Cycle Cost Savings

Median Payback

Period

years Installed

Cost Discounted Operating

Cost LCC Average Savings
2012$ Percent age of

Consumer s that

Experience *

Net

Cost No Impact Net

Benefit

Baseline 442.66 5772.61 6215.27

-- -- -- -- --

1 442.66 5772.61 6215.27 0.00 0 100 0 N/A**

2 695.12 5718.91 6414.03

- 198.76 91 8 0 100

* Any minor incongruities among various reported metrics are the result of rounding. ** Zero impacted consumers (median PBP calculated for affected consumers only).

Table 9.4.6 HID Lamps ≥2800 K and ≤4500 K and >1000 W to ≤20 00 W

— LCC and PBP

Results (2022 Projected Market Basis)

Effic a cy

Level Life

- Cycle Cost
2012$ Life

- Cycle Cost Savings

Median Payback

Period

years Installed

Cost Discounted Operating

Cost LCC Average Savings
2012$ Percent age of

Consumer s that

Experience *

Net

Cost No Impact Net

Benefit

Baseline 581.65 611.01 1192.67

-- -- -- -- --

1 649.70 562.86 1212.57

- 19.90 9 88 3 30.6

* Any minor incongruities among various reported metrics are the result of rounding.

Comparing these 2022

- based results to the standard results, by definition the change in product mix over time accounts for the entirety of the changes in results, given that only the shipment weights used during the aggregation process differ. Note that, for ELs 2 and 3, the change in installed costs relative to the baseline is a greater driver for the reduced LCC savings than the relative change in discounted operating costs. Close examination of the shipment data reveals that the large jump in installed costs for EL2 is driven by a substantial shift to full fixture purchase options, in place of ballast retrofit kits or lamp retrofits, which are more heavily utilized in 2017. Thus, purchase

- type shifts in the changing market play a significant role in the change in

outcomes.

9- 22REFERENCES

1. U.S. Energy Information Administration. Annual Energy Outlook 2013 with Projections to

2040 . 2013. EIA: Washington, DC. < www.eia.gov/forecasts/archive/aeo13/index.cfm >

2. U.S. Department of Energy– Office of Energy Efficiency and Renewable Energy. Energy Conservation Program for Consumer Products and Certain Commercial and Industrial Equipment: Final Determination Concerning the Potential for Energy Conservation Standards for High-Intensity Discharge (HID) Lamps. 2010. (Last accessed February 19, 2013.) < www.regulations.gov/#!documentDetail;D=EERE-2006- DET -0112-0002 >

3. R.S. Means Company, Inc. 2013 RS Means Electrical Cost Data . 2013. Kingston, MA.

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- final

- jan

2012.pdf >

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Investment

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United States. (Last accessed February 19, 2013.) < http://pages.stern.nyu.edu/~adamodar >

10. Damodaran, A. Damodaran Online . Current U.S. Data. (Last accessed February 19, 2013.)

< http://pages.stern.nyu.edu/~adamodar >

11. U.S. Department of Commerce– Burea u of Economic Analysis. Table 1.1.9 Implicit Price Deflators for Gross Domestic Product. 2012. (Last accessed February 19, 2013.)

< www.bea.gov/iTable/iTable.cfm?ReqID=9 >

12. Value Line. Value Lin e Investment Survey . 2011. (Last accessed February 19, 2013.)

< www.valueline.com >

13. U.S. Office of Management and Budget. Circular No. A-94. Appendix C. 2012. (Last accessed February 19, 2013.) < www.whitehouse.gov/omb/circulars/a094/a94_appxc.html >

9- 2314. Federal Reserve Board. Statistics: Releases and Historical Data

– Selected Interest Rates

– State and Local Bonds. 2011. (Last accessed Feb ruary 19, 2013.)

< www.federalreserve.gov/datadownload/Build.aspx?rel=H15 >

9- 24CHAPTER 10. SHIPMENTS ANALYSIS

TABLE OF CONTENTS

10.1 INTRODUCTION ............................................................................................................ 10-1

10.2 SHIPMENTS MODEL METH ODOLOGY ..................................................................... 10-1

10.2.1 Historical Shipments ............................................................................................. 10-1

10.3 BASE

- CASE INPUTS AND PROJ ECTIONS ................................................................. 10-2

10.3.1 Base

- Case Scenarios ............................................................................................. 10-2

10.3.1.1 High -Pressure Sodium Lamps ............................................................... 10-3

10.3.1.2 Mercury Vapor Lamps ........................................................................... 10-4

10.3.1.3 Metal Halide Lamps ............................................................................... 10-5

10.3.2 Representative Lamps ........................................................................................... 10-5

10.3.3 Base -Case Results for HID Lamps ≥2800 K and ≤4500 K and ≥50 W to ≤400 W; Clear; Enclosed

- Rated .......................................................................................... 10-7

10.3.4 Base -Case Projections Results for HID Lamps ≥2800 K and ≤4500 K and >400 W and ≤1000 W; Clear; Enclosed- Rated ................................................................. 10-10

10.3.5 Base -Case Projections Results for HID Lamps ≥2800 K and ≤4500 K and >1000 W and ≤2000 W; Clear; Enclosed- Rated ................................................................. 10-12

10.4 STANDARDS

- CASE SHIPMENTS .............................................................................. 10-12

10.4.1 Shipments Scenario ............................................................................................. 10-12

10.4.2 Triggering Events................................................................................................ 10-13

10.4.3 Differences in Lifetimes ..................................................................................... 10-14

10.5 RESULTS ....................................................................................................................... 10-14

REFERENCES ........................................................................................................................ 10-16

LIST OF TABLES

Table 10.3.1 Portion Rated Life of Mercury Vapor Ballasts as of Effective Date .................... 10-4 Table 10.3.2 Representative and Typical Mercury Vapor Lamp Mixture ................................. 10-6 Table 10.3.3 Representative and Typical Probe- Start Metal Halide Lamp Mixture ................. 10-6

Table 10.3.4 Representative and Typical Pulse- Start Metal Halide Lamp Mixture .................. 10-7 Table 10.3.5 Representative and Typical Ceramic Meta l Halide Lamp Mixture ...................... 10-7 Table 10.4.1 Choice Path Options in the Base- Case and Standards

- Case ............................... 10-13 Table 10.5.1 Cumulative Lamp Shipments by Efficacy Level, Lamps Shipped in 2017–

2046.................................................................................................................. 10-14

LIST OF FIGURES

Figure 10.2.1 Historical HID Lamp Shipments ......................................................................... 10-2 Figure 10.3.1 100 W MV Equipment Class Lamp Shipments .................................................. 10-8 Figure 10.3.2 175 W MV Equipment Class Lamp Shipments .................................................. 10-8 Figure 10.3.3 250 W MV Equipment Class Lamp Shipments .................................................. 10-9 Figure 10.3.4 400 W MV Equipment Class Lamp Shipments .................................................. 10-9 Figure 10.3.5 400 W Probe- Start MH Equipment Class Lamp Shipments ............................. 10-10 Figure 10.3.6 1000 W MV MH Equipment Class Lamp Shipments ....................................... 10-11

10 -iFigure 10.3.7 1000 W Probe-Start MH Equipment Class Lamp Shipments ........................... 10-11 Figure 10.3.8 2000 W Probe- Start MH Equipment Class Lamp Shipments ........................... 10-12

10

- iiCHAPTER 1 0 . SHIPMENTS ANALYSIS

10.1 INTRODUCTION

Shipments of high

- intensity discharge (HID) lamps are key inputs to the national energy savings (NES) and net present value (NPV) calculations. Shipments are also a necessary input to the manufacturer impact analysis, which the U.S. Department of Energy (DOE) conduct ed for

this n otice of proposed determination (NOPD) . This chapter describes DOE’s methodology for projecting annual shipments and presents initial inputs and results for HID lamps

.

In the shipments analysis, DOE develops a base

- case shipment projection for each HID lamp type to depict what would happen to energy use and customer costs for the purchase and operation of HID lamp

- ballast

- fixture systems (herein “HID lamp systems”) in the absence of potential Federal energy conservation standards. In determining the base case, DOE considers historical shipments, emerging technologies, the mix of efficiencies sold in the absence of potential standards, and how that mix might change over time. To evaluate the effects of any potential standard on HID lamps

, DOE then compares the base

- case projection with projections of what could happen if DOE promulgates new standards (the standards case ). To determine the

cumulative NES and NPV of any potential standards , DOE compares projected shipments of a

base case to a standards case over a 30

- year analysis period.

The shipments model and the n ational i mpacts m odel are Microsoft Excel spreadsheet s accessible at www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23

. Th is NOPD technical support document chapter explains the shipments model. Section 10.2 presents the shipments model methodology for HID lamps; section 10.3 describes the data inputs, historical shipments, base

- case scenarios , and shipments projection s; section 10.4

discusses the effects of potential new standards on the mix of HID lamp designs; and

section 10.5 presents the shipments results for three alternative higher efficacy cases.

10.2 SHIPMENTS MODEL METH ODOLOGY

In general, DOE follow ed a three -step process to project lamp shipments . First, DOE

used historical lamp shipment data from the National Electrical Manufacturers Association (NEMA) and data from DOE sources to estimate the total historical shipments of each HID lamp type analyzed. Second, DOE calculate d an installed stock for each lamp from 201 7 (effective date of the standard) forward factoring in the mean service lifetime of each lamp type . Third, by modeling events that trigger lamp purchases, such as replacement and new construction, and applying growth rate, replacement rate, and emerging technologies penetration rate assumptions, DOE developed both base- case and potential standards

- case annual shipment projections for

2017–2046.

10.2.1 Historic al Shipments

DOE has HID lamp shipments data from NEMA for 1990–2010. The resolution differs across the time period, but DOE does have total shipments for each lamp type during these years. NEMA has also published periodic reports of HID lamp shipments since 2010. The values in these reports were factored into the shipments model as they became available, and DOE will

10 -1reference the most current available NEMA reports in its NOPD analyses

. With these high level values of total shipments per lamp type, DOE makes additional estimates on the proportion of shipments for each of the sub- types of each of the HID lamps.

Figure 10.2.1 shows the historical shipments for all HID lamps as well as each of the three major types of HID lamps

— high -pressure sodium (HPS), mercury vapor (MV), and metal halide (MH)

— over the last two decades. Since 1990 , HID lamps have increased in volume of shipments. It appears circa 2005 that HID lamps reached a peak in total shipment volume, and

al though supporte d by data, more time and data are needed to determine if 2005 is the actual

zenith . The economic recession circa 2008–2009 probably accounts more for some reduction in HID lamps (and most spending).

Since 1990, MV lamps have been on a slow, gradual decline. Between 1995 and 2010,

HPS lamps constitute d roughly the same amount of shipments each year. The only HID lamp
type to increase significantly since 1990 is MH lamps.

Figure 10.2.1 Histori cal HID Lamp Shipments

10.3 BASE

- CASE INPUTS AND PROJECTION S

This section describes the base

- case scenario DOE employs in its analysis and the base

case input market

- share apportioning for HID lamps and presents the base

- case projection for

each lamp type along with historical lamp shipments data.

10.3.1 Base- Case Scenarios

In general, DOE believes that the overall HID lamp market is on a decline. During the

HID l amps framework p ublic meeting, General Electric (GE) discussed its concern about the fate 0 5,000,000 10,000,000 15,000,000 20,000,000 25,000,000 30,000,000 35,000,000 40,000,000

1990 1995 2000 2005 2010Total Amount of Shipments

Year 

## Historical Shipments

All HID Lamp Shipments

HPS Lamps

MV Lamps

MH Lamps

10 -2of the technology in relation to a 30- year projection of shipments. GE stated that there is significant flux in the lighting marketplace, specifically with HID lighting. GE elaborated that

the near term (less than 20 years) is very uncertain and that some HID lamps may not even exist in the marketplace 10 years from the start of the effective date of a potential rule. (Docket No.

EERE -2010- BT

- STD -0043, GE, Public Meeting Transcript, No. 12 at p. 127) a During the metal

halid e lamp fixture (MHLF) energy conservation standard framework public meeting, manufacturers stated that many metal halide high bay fixtures had been replace d with fluorescent high bay fixtures between 2000 and 2010. (Docket No. EERE-2009- BT

- STD -0018, Philips, No. 8 at p. 101) Du ring the MHLF preliminary analysis public meeting, manufacturers expressed

their belief that MHLF shipments had plateaued or were declining. (Docket No. EERE-2009- BT

STD -0018, Philips, No. 33 at pp. 113–122)

A January 2012 DOE report on the energy savings potential of solid

- state lighting predicts significant penetration of light- emitting diode (LED) light sources in the commercial

, industrial, and outdoor stationary lighting markets, significantly reducing the number of HID lighting installations

. 1 Total H ID lighting in these three markets ( as a percentage of lighting

service in tera lumen -hours , Tlm -hr) is projected to decrease from approximately 8 ,900 Tlm-hr in 2010 to 4,170 Tlm-hr in 2030, a decrease of approximately 50 percent . Within each of the

sectors, HID lighting in the commercial sector is expected to remain largely unchanged until 2020, then decrease 20 percent by 2025 and 40 percent by 2030 ; i n the industrial sector, HID lighting is projected to decrease 25 percent by 2020, 45 percent by 2025, and 55 percent by 2030; and outdoor stationary lighting is projected to decrease 20 percent by 2020, 40 percent by 2025, and 60 percent by 2030.

10.3.1.1 High

- Pressure Sodium Lamps

Currently HPS lamps, ballasts, or fixtures are not covered by existing Federal regulations. HPS lamps are predominantly used in exterior applications and comprise the majority (over 80
percent ) of the 52 million (as of 2010) street and highway lighting fixtures in the United S tates

. 2
This represents a significant in stalled base of HPS ballasts and fixtures needing to be serviced by replacement lamps. Since 2010, roughly 100 different requests for proposals (RFPs) have been issued for LED fixtures to replace the ex isting street lighting in the United S tates

. 3 These 10 0 RFPs represent a cumulative $ 29 million in available funding to replace roughly 54,000 existing street lights. These RFPs often represent only a smaller portion of the total amount of installed street lights for the respective agency issuing the RFP. In addition to these RFPs, the City of

Los Angeles has already replaced 107,000 street lights, with near- term plans to replace an additional 50,000 street lights. 4 Although these examples focus on street lighting, DOE also believes that other exterior light fixtures using HPS lamps are also being replaced by LED and

other non-HID sources.

a A notation in this form provides a reference for information that is in the docket of DOE’s Energy Conservation Program for Certain Commercial and Industrial Equipment: Energy Conservation Program: High

- Intensity Discharge Lamps (Docket No. EERE

- 2010

- BT

- STD

- 0043) , which is maintained at.www.regulations.gov. This notation indicates that the statement preceding the reference is document number 00013 in the docket for the metal halide lamp bal lasts test procedure rulemaking, and appears at page 8 of that document.

10 -3Traditional HPS streetlights are not only being replaced by LED fixtures, but other light

sources as well. In January 2012, the City of Kennewick, Washington, announced plans to replace their 5 000 streetlights (mostly using HPS lamps) with fixtures utilizing induction light

sources. 5

As of the effective date of a potential HID lamps standard, HPS lighting technology will be over 50 years old. As demonstrated by the examples of the RFPs and other municipalities quickly replacing HPS installations , it is expected that future shipments of HPS lamps will decline through the shipments analysis period.

10.3.1.2 Mercury Vapor Lamps

The Energy Policy Act of 2005 banned the sale or importation of MV ballasts after January 1, 2008. 10 CFR 431.286 The effective date of any potential HID lamps standards would be January 1, 2017. This would be 9 years afte r the last MV ballast was allowed to be sold or imported into the United S tates

. Table 10.3.1 shows the percent of rated life of MV ballasts from

the time the last bal last could be sold (Jan. 1, 2008) to the start of the analysis period (Jan. 1, 2017) based on the operating hours of the different sectors and a ballast life of 50,000 hours. b

Table 10.3.1 Portion Rated Life of Mercury Vapor Ballasts as of Effective D ate

Sector Annual Operating

Hours Years Between Last

Sale and Start of Analysis P eriod Total Estimated

Number of Hours of

O peration Percent of

Rated L ife

Commercial 3 961 9 35,649 71

Industrial 6 113 9 55,017 110

Outdoor 4 493 9 40,437 81

Based on the percent of rated life of the ballast per Table 10.3.1 , DOE expects many of the ballasts to start failing soon after the start of the analysis period. Once the ballast fails,

customer s will have to consider a different lighting source. Ballasts w ill start failing in greater quantities in the earliest years of the potential rule.

Periodically, NEMA releases data related to shipments of different light sources. For the final quarter of 2011, NEMA stated that MV posted a decline of 19.4 percent on a year -over- year basis. MV lamps represent 4.7 percent of HID lamp shipments in general. 6 During the first quarter of 2012, MV shipments increased 5 percent

. 7

At the end of 2012, the City of Boston had replaced over 40 percent of their 64,000 streetlights (primarily mercury vapor) with LED street light fixtures

. 8

In April 2009, the New Jersey Board of Public Utilities approved a Public Service Enterprise Group Incorporated (PSE&G) plan to replace 96,400 MV municipal street lights in

220 towns in PSE&G ’s service territory with induction fixtures. 9

b DOE researched the life of HID ballasts for the MHLF rule. DOE’s research indicated the magnetic HID ballasts typically have a life of 50,000 hours and electronic ballasts have a li fe of 40,000 hours. DOE is not aware of any electronic MV ballasts prior to January 1, 2008.

10 -4Because of the anticipated failure of sales

- restricted MV ballasts, the existing decline of shipments reported by NEMA, and the plans of cities and municipalities (as demonstrated by Boston and Detroit), DOE expects MV lamps to represent 1 percent of HID lamp shipments in 2017 and for shipments to decline over the shipment analysis period.

10.3.1.3 Metal Halide Lamps

The Energy Independence and Security Act of 2007 set minimum ballast efficiencies for

MHLFs with a rated lamp wattage of 150 W to 500 W. (42 U.S.C. 6292 (hh)(1)(A)) The minimum efficiency of 94 percent for probe- start MHLFs curtailed the specification and installation of probe- start MHLFs . Shipment data supports this assessment in that probe- start
metal halide represented 64 percent of all MH lamp shipments in 2008, and declined to 47 percent in 2010. DOE believes that this reduction in probe- start MH lamp shipment s correlates to a reduction in probe- start lamp fixtures and that the remaining lamps being shipped serve existing fixtures.

During the January 2010 MHLF f ra mework document public meeting, Philips

commented that it expected to see a significant change between the 2002 and 2010 versions of

the Lighting Market Characterization reports , illustrating a significant reduction of MH system usage due to market penetra tion by fluorescent lighting systems . (Docket No. EERE-2009- BT

STD -0018, Philips, No. 8 at p . 101)

Historic al data of HID lamp shipments have shown HPS to be roughly one- third of all HID shipments regardless of year. Since 1990, MV market share has declined as it was replaced with MH lamp systems, with HPS market share staying relatively constant. As stated earlier, MV lamp shipments are expected to continue to decline. It is expected that as MV lamps disappear from the marketplace, those lamps (and ultimately fixtures) will be replaced by either MH lamp
systems or other lighting technologies. Therefore, DOE expects the proportion of MH lamp shipments to increase in the near term.

10.3.2 Representative Lamps

Table 10.3.2 through Table 10.3.5 show how the commercially available (typica l) rated lamp wattages are apportioned to the representative lamp wattage. Typically

, the conventional lamps are equal to or lower than the representative wattage. Usually , a typical lamp is 100 percent apportioned to the representative wattage, but some lamps are apportioned to two different representative lamps (see Table 10.3.4 ). The lamps are split because the typical lamp falls squarely between the two representative lamp wattages and should be apportioned equally.

10 -5Table 10.3.2 Representative and Typical Mercury Vapor Lamp Mixture

Representative Lamp Wattage Typical Lamp Wattages Typical Lamp Wattage Assigned to Representative Lamp Wattage

100 50 100%

75 100%

80 100%

100 100%

125 100%

175 160 100%

175 100%

250 250 100%

300 100%

400 400 100%

450 100%

1 000 700 100%

750 100%

1 000 100%

Table 10.3.3 Representative and Typical Probe

- Start Metal Halide Lamp Mixture

Representative Lamp Wattage Typical Lamp Wattages Typical Lamp Wattage Assigned to Representative Lamp Wattage

175 150 100%

175 100%

250 250 100%

320 100%

400 360 100%

400 100%

1 000 750 100%

950 100%

1 000 100%

1 500 1 500 100%

1 650 100%

2 000 1 800 100%

2 000 100%

10 -6Table 10.3.4 Representative and Typical Pulse -Start Metal Halide Lamp Mixture

Representative Lamp Wattage Typical Lamp Wattages Typical Lamp Wattage Assigned to Representative Lamp Wattage

70 50 100%

70 100%

100 100 100%

125 50% to 100 / 50% to 150

150 150 100%

200 175 100%

200 100%

320 250 50% to 200 / 50% to 320

320 100%

360 100%

400 100%

450 100%

750 750 100%

775 100%

875 875 100%

1 000 100%

1 500 100%

2 000 100%

Table 10.3.5 Representative and Typical Ceramic Metal Halide Lamp Mixture

Representative Lamp Wattage Typical Lamp Wattages Typical Lamp Wattage Assigned to Representative Lamp Wattage

50 50 100%

70 70 100%

100 100 100%

150 150 100%

250 210 100%

250 100%

320 100%

315 100%

350 100%

360 100%

400 100%

10.3.3 Base- Case Results for HID Lamps ≥2800 K and ≤4500 K and ≥50 W to ≤400 W; Clear; Enclosed

- Rated

Figure 10.3.1 th rough Figure 10.3.5 present the base

- case lamp shipments projections

from 2017–2046, modeled from h istorical data (1990 –2010) and other factors as explained in

section 10.3.1

.

10 -7Figure 10.3.1 100 W MV Equipment Class Lamp Shipments

Figure 10.3.2 175 W MV Equipment Class Lamp Shipments - 500,000 1,000,000 1,500,000 2,000,000 2,500,000

2010 2015 2020 2025 2030 2035 2040 2045 2050Amount of Lamps Shipped

Year 

## 100 W MV Base

- Case Shipments

Baseline

EL1

EL2

EL2

Effective Date

- 250,000 500,000 750,000 1,000,000 1,250,000 1,500,000

2010 2015 2020 2025 2030 2035 2040 2045 2050Amount of Lamps Shipped

Year 

## 175 W MV Base

- Case Shipments

Baseline

EL1a

EL1b

EL2

EL3

Effective Date

10 -8Figure 10.3.3 250 W MV Equipment Class Lamp Shipments

Figure 10.3.4 400 W MV Equipment Class Lamp Shipments - 250,000 500,000 750,000 1,000,000 1,250,000 1,500,000 1,750,000 2,000,000

2010 2015 2020 2025 2030 2035 2040 2045 2050Amount of Lamps Shipped

Year 

## 250 W MV Base

- Case Shipments

Baseline

EL1a

EL1b

EL2a

EL2b

EL3

Effective Date

- 250,000 500,000 750,000 1,000,000 1,250,000 1,500,000 1,750,000 2,000,000 2,250,000 2,500,000

2010 2015 2020 2025 2030 2035 2040 2045 2050Amount of Lamps Shipped

Year 

## 400 W MV Base

- Case Shipments

Baseline

EL1a

EL1b

EL2

EL3a

EL3b

Effective Date

10 -9Figure 10.3.5 400 W Probe- Start MH Equipment Class Lamp Shipments

10.3.4 Base- Case Projections Results for HID Lamps ≥2800 K and ≤4500 K and >400 W and ≤1000 W; Clear; Enclosed- Rated

Figure 10.3.6 and Figure 10.3.7 present the base

- case lamp shipments projections from
2017–2046, modeled from historical data (1990–2010) and other factors as explained in section

10.3.1

. - 500,000 1,000,000 1,500,000 2,000,000 2,500,000 3,000,000

2010 2015 2020 2025 2030 2035 2040 2045 2050Amount of Lamps Shipped

Year 

## 400 W Probe

- Start MH Base

- Case Shipments

Baseline

EL1

EL2

EL3

Effective Date

10

- 10Figure 10.3.6 1000 W MV MH Equipment Class Lamp Shipments

Figure 10.3.7 1000 W Probe

- Start MH Equipment Class Lamp Shipments - 5,000 10,000 15,000 20,000 25,000 30,000 35,000 40,000 45,000 50,000

2010 2020 2030 2040 2050Amount of Lamps Shipped

Year 

## 1000 W MV Base

- Case Shipments

Baseline

EL1

EL2

Effective Date

- 250,000 500,000 750,000 1,000,000 1,250,000 1,500,000

2010 2015 2020 2025 2030 2035 2040 2045 2050Amount of Lamps Shipped

Year 

## 1000 W Probe

- Start MH Base

- Case Shipments

Baseline

EL1

EL2

Effective Date

10

- 1110.3.5 Base- Case Projections Results for HID Lamps ≥2800 K and ≤4500 K and >1000 W and ≤2000 W; Clear; Enclosed- Rated

Figure 10.3.8 present s the base

- case lamp shipments projections from 2017–2046,

modeled from historical data (1990–2010) and other factors as explained in section 10.3.1

.

Figure 10.3.8 2000 W Probe

- Start MH Equipment Class Lamp Shipments

10.4 S TANDARDS

- CASE SHIPMENTS

10.4.1 Shipments Scenario

To characterize customer be havior in the potential standards case, DOE considered many characteristics that customers take into account when purchasing lamp systems

.

The potential standards- case scenario for HID lamps envisages a ‘ roll -up’ scenario. The

roll -up scenario represents a standards case in which all equipment efficacies in the base- case that do not meet the potential standard would roll up to meet the new standard level efficacies

. Customers in the base case who purchase HID lam p systems above the potential standard efficacy level are not affected as they are assumed to continue to purchase the same base

- case equipment in the roll- up scenario (‘pass

- through’ lamps) . The roll- up scenario characterizes customers primarily driven by the first cost of the analyzed lamp system . In a roll-up scenario,

DOE assumes that customers will switch to the first lowest enhanced efficacy standardcompliant system available and will attempt to buy a lamp system from the same equipment

class as the ir previously owned system. The total shipment of lamp s could differ in the base - 25,000 50,000 75,000 100,000 125,000 150,000 175,000 200,000

2010 2015 2020 2025 2030 2035 2040 2045 2050Amount of Lamps Shipped

Year 

## 2000 W Probe

- Start MH Base

- Case Shipments

Baseline

EL1

Effective Date

10

- 12case and any potential standards case depending on the differences in the lifetimes of the base case lamp and the standard case lamp displacing the base case lamp

. However t o keep the lamps

in service at any given point of time unchanged for all alternative scenarios, the stock of the sockets in service, estimated from the base case lamp shipment data and their mean service life, is held invariant in all shipment scenarios. Thus less number of lamps is required to maintain the same socket stock for lamps with higher lifetimes than for lamps with lower lifetimes.

10.4.2 Triggering Events

The aggregate lamp shipments comprise of:

1. Lamps purchased as replacement of failed lamps in pre

- existing fixtures (Lamp Event);

2. Lamps shipped with the replacement of failed ballasts in pre

- existing fixtures (Ballast event) ;

3. Lamps shipped with new fixtures for existing sockets (Fixture event) ; and

4. Lamps shipped with new fixtures in new construction ( Fixture event)

.

While in the base case shipments, only the first three streams are explicitly tracked over the analysis period, DOE tracked all the four lamp streams separately and aggregated them on an annual basis to obtain the standard case estimates of annual lamp shipment for three different

alternative effic acy scenarios. In the se scenarios, DOE assumed that for any of the triggering events described above, customers choose between either an equal wattage – but potentially higher efficacious lamp ( lam p system ) or a lower wattage lamp ( lamp s ystem ) that can deliver nearly the same amount of light as the original lamp due to its higher efficacy. The choice path s available are shown in Table 10.4.1

.

Table 10.4.1 Choice Path Options in the Base

- Case and Standards

- Case

Choice Paths Scenarios Triggering Event Lamp Event Ballast Event Fixture Event

Equal Wattage

Equal efficacy Lamp Only Base Case Lamp and Ballast Base Case Lamp, Ballast and Fixtures Base Case

Equal Wattage

– Higher Efficacy Lamp Only Standards case Lamp and Ballast Standards case Lamp, Ballast and Fixtures Standards case Standards case Standards case

Reduced Wattage

Higher efficacy Lamp Only Lamp and Ballast Standards case Lamp, Ballast and Fixtures Standards case Standards case Standards case

For the base case, the replacement and new purchase options are limited to identical lamp or lamp systems , i.e., an equal wattage– equal efficacy replacement. For the lowest efficacy scenario considered (Scenario 1), most of the lamps are considered ‘pass -through’ and are unimpa cted by the standard. However for Scenario 1, only for the MV lamps, a complete lamp system replacement was the considered switch path for lamp events . For the hi ghest efficacy

10

- 13level considered (Scenario 3), a few higher efficacy lamps currently available in the market were considered as ‘pass - through, ’ and for the remaining lamps, the triggering events often led to a higher proportion of the lamps following reduced w attage

– higher efficacy switch paths.

10.4.3 Differences in Lifetimes

In the scenario where the replaced standard case lamp has a different mean lifetime as compared to the base case lamp displaced by the standard, DOE made adjustments to the shipment estimates initially obtained by applying the switch path ‘roll coefficients’ to th e base

case sh ipment estimates. The adjusted shipments were estimated on the basis of translating the base case lamp

- years of service obtained from the base case shipment and base case lamp life to the standard case lamp shipments and standard case lamp life and modif ied by the socket stock

decline. The ratio of the adjusted shipped quantit y to the base case ship ped quantity closely

tracked the inverse of the ir respective lamp lives. The adjusted shipped quantities obtained in this step were further smoothed using a 3 year moving average for obtaining the annual standard case shipments.

10.5 RESULTS

Table 10.5.1 gives cumulative shipments by equipment class, by efficacy level , for lamps shipped in 2017–2046.

Table 10.5.1 Cumulative Lamp Shipments by Efficacy Level

, Lamps Shipped in 2017–2046

Efficacy Level

Selected Equipment Class Shipments at Equipment EL for Alternative Effi cacy Scenarios Chosen

Scenario 1 Scenario 2 Scenario 3

1 ≥2800 K and ≤4500 K ; ≥50 W to ≤400 W;

c lear; e nclosed 191,328,313

--- ---

≥2800 K and ≤4500 K ; >400 W and ≤1000 W ; clear; enclosed 22,399,388

--- ---

≥2800 K and ≤4500 K ; >1000 W and ≤2000 W ; clear; enclosed 1,063,984

--- ---

2 ≥2800 K and ≤4500 K ; ≥50 W to ≤400 W

clear; enclosed 42,621,322 233,949,635 69,735,395

≥2800 K and ≤4500 K ; >400 W and ≤1000 W ; clear; enclosed 2,045,579 24,444,968 24,444,968

≥2800 K and ≤4500 K ; >1000 W and ≤2000 W; clear; enclosed 1,063,984

--- ---

3 ≥2800 K and ≤4500 K ; ≥50 W to ≤400 W ;

clear; enclosed 69,7375,395 69,735,395 303,685,030

≥2800 K and ≤4500 K ; >400 W and ≤1000 W ; clear; enclosed --- - ---

≥2800 K and ≤4500 K ; 1,063,984

--- ---

10

- 14Efficacy Level

Selected Equipment Class Shipments at Equipment EL for Alternative Effi cacy Scenarios Chosen

Scenario 1 Scenario 2 Scenario 3
>1000 W and ≤2000 W ; clear; enclosed

10

- 15REFERENCES

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- savings -report_10-30.pdf >

2. U.S. Department of Energy– Office of Energy Efficiency and Renewable Energy

. Energy Savings Estimates of Light Emitting Diodes in Niche Lighting Applications . 2011. Washington, D.C. < http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/ nichefinalreport_january2011.pdf >

3. New Streetlights. New Streetlights . 2012. (Last accessed February 19, 2013.)

< www.newstreetlights.com >

4. Bureau of Street Lighting, City of Los Angeles – Department of Public Works . 2012. (Last

accessed February 19, 2013. ) < http://bsl.lacity.org / >

5. Hulse, J. L. St r eetlight switch to save city big bucks. Tri

- City Herald . January 23, 2012. (Last accessed February 19, 2013.) < www.tri -cityherald.com/2012/01/23/1797681/ streetlight

- switch

- to

- save

- city.html?storylink=tacoma >

6. National Electrical Manufacturers Association. Sodium Vapor HID Lamp Index Lone Bright Spot for HID Shipments . 2011. (Last accessed February 19, 2013.)

< www.nema.org/news/Pages/Sodium-Vapor- HID

- Lamp

- Index -Lone-Bright-Spot- for

- HID

Shipments.aspx >

7. National Electrical Manufacturers Association

. HID Lamp Shipment Indexes Show Growth for First Quarter. 2012. (Last accessed February 19, 2013.)

< www.nema.org/news/Pages/HID- Lamp -Shipment- Index es -Show- Growth

- for

- First

Quarter.aspx >

8. City of Boston. LED Street Lighting . 2012. (Last accessed February 19, 2013. )

< www.cityofboston.gov/publicworks/lighting/led.asp >

9. PSG& E. Combating Climate Change . 2011. (Last accessed February 19, 2013 .) < https://www.pseg.com/family/holdings/global/solar_source/pdf/Cl imate%20Change%20Ini tiatives%20Update.pdf >

10

- 16CHAPTER 11. NATIONAL IMPACT ANALYSIS

TABLE OF CONTENTS

11.1 INTRODUCTION ............................................................................................................. 11-1

11.2 BASE

- CASE AND STANDARDS

- CASE PROJECTED EFFICIENCY

DISTRIBUTIONS AND FIXTURE STOCKS ................................................................. 11-1

11.2.1 Base

- Case and Standards

- Case Efficiency Distributions .................................. 11-2

11.2.2 Installed Lamp Stock (Base Case) ..................................................................... 11-2

11.3 NATIONAL ENERGY SAVINGS ................................................................................... 11-3

11.3.1 National Energy Savings Definition .................................................................. 11-3

11.3.2 National Energy Savings Inputs ........................................................................ 11-4

11.3.2.1 Unit Energy Consumption .................................................................. 11-4

11.3.2.2 Standard Case Lamp Shipment and Stock .......................................... 11-4

11.3.2.3 Site

- to -Source Conversion Factors ..................................................... 11-5

11.3.2.4 Full

- Fuel

- Cycle Energy ...................................................................... 11-6

11.3.2.5 Interactions with Heating, Ventilation, and Air-Conditioning (HVAC) Systems ................................................................................ 11-6

11.3.2.6 Rebound Rate ...................................................................................... 11-6

11.4 NET PRESENT VALUE .................................................................................................. 11-7

11.4.1 Net Present Value Definition ............................................................................. 11-7

11.4.2 Net Present Value Inputs ................................................................................... 11-8

11.4.2.1 Total Annual Installed Cost Increases ................................................ 11-8

11.4.2.2 Total Annual Operating Cost Savings ................................................ 11-8

11.4.2.3 Discount Factor ................................................................................... 11-9

11.5 NATIONAL ENERGY SAVINGS AND NET PRESENT VALUE RESULTS ............. 11-9

11.5.1 National Energy Savings and Net Present Value Input Summary .................. 11-10

11.5.2 National Energy Savings Results .................................................................... 11-10

11.5.3 Net Present Value Analysis ............................................................................. 11-11

11.5.4 N et Present Value Results ............................................................................... 11-12

LIST OF TABLES

Table 11.3.1 National Energy Saving Inputs ............................................................................. 11-4

Table 11.3.2 Site- to -Source Conversion Factors ....................................................................... 11-5

Table 11.3.3 Full- Fuel

- Cycle Energy Multipliers

...................................................................... 11-6 Table 11.4.1 Net Present Value Inputs ...................................................................................... 11-8 Table 11.5.1 Approach and Data Used for National Energy Savings and Customer Net Present Value Analyses

.................................................................................... 11-10 Table 11.5.2 Cumulative National Energy Savings for HID Lamps Purchased from 2017–

2046 for EL 1 ................................................................................................... 11-10 Table 11.5.3 Cumulative National Energy Savings for HID Lamps Purchased from

2017–2046 for EL 2 ......................................................................................... 11-11 Table 11.5.4 Cumulative National Energy Savings for HID Lamps Purchased from

2017–2046 for EL 3 ......................................................................................... 11-11

11 -iTable 11.5.5 Cumulative Net Present Value for HID Lamps Purchased from 2017–2046

for EL 1 ............................................................................................................ 11-12 Table 11.5.6 Cumulative Net Present Value for HID Lamps Purchased from 2017–2046

for EL 2 ............................................................................................................ 11-13

Table 11.5.7 Cum ulative Net Present Value for HID Lamps Purchased from 2017 –2046

for EL 3 ............................................................................................................ 11-13

11

- iiCHAPTER 11 . NATIONAL IMPACT ANALYSIS

11.1 INTRODUCTION

This chapter describes the method for estimating the national impacts of the three potential efficacy levels (EL s ) considered for high -intensity discharge (HID) lamps. Because lamps are designed to operate together with ballasts and most changes to a new lamp/ballast will require a new fixture , the U.S. Department of Energy ( DOE ) i dentified a representative HID

ballast and fixture pairing used with each lamp to develop representative HID system s (herein “HID lamp systems”) . Although HID ballasts and fixtures are not covered under th is notice of proposed determination ( NOPD ) analysis for HID lamps , the characteristics of complete HID lamp system s ( e.g. , energy use, installed cost, etc.) must be considered for estimating national

benefits and costs of the three ELs considered in this NOPD.

In the national impact analysis (NIA), DOE assesse d the cumulative national energy savings (NES) and the cumulative national economic impacts of the three ELs . DOE estimated energy savings as the cumulative quadrillion British thermal units ( quads) of energy a ny potential EL is expected to save the nation. DOE measured economic effects as the net present value (NPV) in dollars of total customer costs and savings expected to result from a potential EL

.

DOE determine d both the NPV and the NES for each EL and each representative equipment class it select ed in the engineering analysis ( NOPD technical support document, TSD, chapter 5). In this rulemaking, DOE consider ed up to three EL s for each representative HID lamp equipment class

.

DOE perform ed all NIA calculations using a Microsoft Exce l spreadsheet, available at www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23 . Appendix 11 A

of t he NOPD TSD provides instructions for using the spreadsheet.

The following sections describe in detail the methodology and inputs for the NIA. Several NIA inputs, including per-unit costs, per- unit energy use, and national shipments, are discussed in other analyses. In describing the inpu ts to the NIA, this chapter references those analyses and presents new information on the installed stock of lamps. Section 11.2 discusses

DOE’s lamp shipment projections by potential EL , the installed stock of lamps , and the mix of

efficacies of that stock. Section 11.3 discusses DOE’s calculation of national energy consumption in the base and the three EL cases, and the resulting difference in NES between

these cases. Section 11.4 discusses the NPV calculation. Section 11.5 presents the NES and NPV results by representative equipment class

.

11.2 BASE

- CASE AND STANDARDS

- CASE PROJECTED EFFICIENCY

DISTRIBUTIONS AND FIXTURE STOCKS

The char acteristics of DOE’s shipment projection s (such as equipment costs and operating costs) and projected lamp stocks (such as average efficacy and energy use ) are key aspects of DOE’s NES and NPV estimates

. This section describes these key characteristics of stock and shipments as they relate to the NES and NPV.

11 -1Two main inputs to the NPV are the per- unit total installed cost increase and per-unit annual operating cost savin gs . The per

- unit total installed cost often varies with the efficacy of the lamps shipped. When higher- efficacy lamps are shipped, higher inst alled costs are often

incurred. T he projected distribution s of lamp efficacies shipped and subsequently in service ( stock ) over the analysis period are two key factors in determining the operating cost.

Per -unit annual energy consumption (AEC) is a key input to the NPV (as an input to the

per -unit operating cost) and NES. The per-unit AEC is a function of HID lamp system
characteristics in the installed stock. The total installed stock of HID lamp s ystem s is used to determine total annual energy use, a key input into the NES and NPV calculations.

Also important for determining NES and NPV is the average efficacy of the lamp stock. The engineering analysis ( NOPD TSD chapter 5) discusses the relationship between HID lamp
system designs and system input power.

Sections 11.3.2 and 11.4.2 discuss inputs to calculation of the NES and NPV in further

detail

.

11.2.1 Base- Case and Standards

- Case Efficiency Distributions

Because the end

- user price of lamps varies with efficacy level , the base- case and

standards- case projected efficacy distributions of shipments affect the average total installed cost per unit. Generally, as the efficacy of a n HID lamp system ’s design increases, the total installed

cost increases as well . In addition, the base-case and standards- case efficacy distributions affect the average lamp efficacy in the installed stock, an indication of annual energy use. For lamps

, DOE first presented the market share apportionments in the base case in the NOPD TSD chapter 10. These market share apportionm ents characterize the shipments of lamps for each analyzed equipment class . The projected efficacy distributions of shipments for lamp s depend directly on these apportionments and the total shipments of a partic ular lamp type in each year of the analysis period.

11.2.2 Installed Lamp Stock (Base Case)

The installed lamp stock in a given year is the sum of the total number of lamp s shipped that year and in prior years that are still is service . The NES model tracks the base case lamp s shipped each year , and lamps are retired when they reach the end of their mean lifetime

. From this information and the shipments projections presented in the NOPD TSD c hapter 10 , DOE established the installed lamp stock profile for all anal yzed lamp equipment classes in the base

case

.

All the lamp type s out of the 32 base case representative lamps considered in the analysis experience a decline in stocks over the analysis period due to displacement of the HID technology by newer technologies such as induction, high-intensity fluorescent, light

- emitting diode, and light- emitting plasma

.

11 -211.3 NATIONAL ENERGY SAVINGS

11.3.1 National Energy Savings Definition

DOE calculate d annual national energy savings as the difference in energy consumption by HID lamp systems between the base case and the higher efficacy cases (with potential standards). Positive values of NES correspond to net energy savings following implementation of the higher efficacy standards; i.e. , national AEC with standards is less than AEC in the base

case.

t std t baset t 

### conv src AEC AEC NES _) (

, , 

### ×

− = Eq. 11.1

Where :

NES t = national energy savings in year t

, AEC = annual national site energy consumption each year (kWh per yr ),

t = year in the projection,

base = base case

, std = standards case , and

sr c_conv t = time -dependent conversion factor to convert from site energy ( kilowatt -hours, kWh ) to source energy (Btu/kWh).

Cumulative energy savings are the sum of energy savings over a lifetime of equipment, shipped from the implementation of a potential standard in 2017 to 2046:



# ∑

=

t t cum 

### NES NES

Eq. 11.2

Where :

NES

cum = cumulative national energy savings.

DOE calculated the AEC (in any year) by multiplying the number or stock of lamp s by the annual unit energy consumption (UEC) , shown by the following equation:

ld

ld ld 

### UEC STOCK AEC × = 

# ∑

Eq. 11.3

Where :

ld = lamp ID number,

STOCK ld = stock of lamp s of a given design surviving in the year for which DOE calculated AEC, and

UEC ld

= unit energy consumption (kWh per year).

11 -311.3.2 National Energy Savings Inputs

Table 11.3.1 lists the inputs for the determination of NES.

Table 11.3.1 National Energy Saving Inputs

Input

Unit Energy Consumption ( UEC ) Lamp Stock by Design ( STOCK l d )

Site

- to

- Source Conversion Factor ( src_conv )

11.3.2.1 Unit Energy Consumption

DOE present s the per -unit UEC for each HID lamp system design in the energy use analysis in NOPD TSD chapter 8. For the NES and NPV calculations, DOE used an average number of annual operating hours for each application sector ( i.e. , commercial, industrial, and outdoor stationary ) in calculating the UEC of each HID lamp system design.

11.3.2.2 Standard Case Lamp Shipment and Stock

T he lamp stock in a given year is the sum of the shipments in that year and the total surviving number of standard case lamp s shipped in prior years. The NIA spreadsheet model keeps track of the surviving stock and new lamps shipped each year in the three alternative higher efficacy cases

. DOE discusse s projected shipments for the base case and all higher efficacy cases in NOPD TSD chapter 10. To generate the shipments that eventually comp ri se the lamp stock, one base- case scenari o and a set of standards- case scenarios are developed in the shipments model. From the base case shipment of lamps, DOE estimated the total number of sockets in service for each of the base case lamp types in any given year of the analysis period.

DOE further assumed that the socket stock for each of the base case lamp types stays invariant

under all potential standard- case scenarios and determined the shipment of standard case lamps

to maintain the number of sockets in service. Since in many cases the standard case l amp had a different lifetime compared to its base case counterpart lamp, the shipment quantities for these lamps are different from the shipment of the corresponding base case lamp . The standards- case scenarios are composed of numerous roll-up scenarios. These scenarios dictate the inputs to the

market -share apportionments, and therefore the breakdown of the installed stock by lamp type from 2017 to the end of life of the equipment shipped through 2046.

Since many of the roll

- up sce narios in the standard cases require shipment of the higher efficacy lamp with a new matching fixture and ballast on the event of failure of a base case lamp, DOE accounted for the pre empted shipment of fixtures and ballasts by separately tracking the remaining stock of pre

- 2017 vintage fixtures and ballasts requiring replacement over the analysis period in each standards scenario from post

- 2017 fixture shipments and adjusted the shipment of replacement fixtures and ballasts for the remaining pre

- 2017 fixture failures accordingly. DOE

determined that where standards case lamps required new fixtures, all the fixtures and ballasts

stock would match the standard case lamps within a period of ten years. Replacements for all post

2017 fixtures were calculated using a Weibull survival function based on the average fixture

11 -4lifetime and annual adjustments (fixture removals) to maintain the stock of sockets invariant from

the base case.

11.3.2.3 Site

- to

- Source Conversion Factors

The site

- to -source conversion factor is the multiplier DOE use d for converting siteenergy consumption into primary or source energy consumption. For electricity, the conversion

factors can vary over time due to projected changes in generation sources ( i.e. , the power plant types projected to provide electricity to the country). For th is NOPD , DOE used time -dependent

site

- to -source conversion factors derived from the 2013 version of the U.S. Energy Information Administration’s (EIA’s) Annual Energy Outlook ( AEO20 13 ). 1 Table 11.3.2 presents the site

- to

source conversion factors used in the NES spreadsheet model. Because AEO projections only go through 2035, the factors after 2035 are derived as the average of the last 5 years of the AEO projection (2031–2035).

Table 11.3.2 Site

- to

- Source Conversion Factors

Year Site

- to

- Source Conversion Factor for HID Fixtures

Btu/kWh

2017 8,595

2018 8,595

2019 8,595

2020 8,595

2021 8,307

2022 8,307

2023 8,307

2024 8,307

2025 8,307

2026 8,109

2027 8,109

2028 8,109

2029 8,109

2030 8,109

2031 8,149

2032 8,149

2033 8,149

2034 8,149

2035 8,149

2036 8,331

2037 8,331

2038 8,331

2039 8,331

2040 8,331

2041 8,331

2042 8,331

2043 8,331

2044 8,331

2045 8,331

2046 8,331

11 -511.3.2.4 Full

- Fuel

- Cycle Energy

The full- fuel

- cycle (FFC) measure incl udes point-of- use (site) energy; the energy losses associated with generation, transmission, and distribution of electricity; and the energy consumed in extracting, processing, and transporting or distributing primary fuels. DOE’s traditional approach encompasses site energy and the ener gy losses associated with generation, transmission, and distribution of electricity. To complete the FFC energy calculations by encompassing the energy consumed in extracting, processing, and transporting or distributing primary fuels, which are referred t o as “upstream” activities, DOE developed FFC multipliers using the data and projections generated by the National Energy Modeling System (NEMS) and published in AEO2013 . While the AEO does not provide direct calculations of FFC metrics, it does provide extensive information about the energy system, including projections of future oil, natural gas , and coal supply, energy use for oil and gas field and refinery operations, and fuel consumption and emissions related to electric power production. This information can be used to define a set of parameters representing the energy intensity of energy production.

Table 11.3.3 shows the FFC energy multipliers used for HID l amps for selected years. The method used to calculate a time series of FFC energy multipliers is described in appendix

11 B of the NOPD TSD

.

Table 11.3.3 Full

- Fuel

- Cycle Energy Multipliers

Fuel 2020 2025 2030 2035 2040 Electricity (power plant energy use) 1.041 1.040 1.040 1.041 1.040

11.3.2.5 Interactions with Heating, Ventilation, and Air- Conditioning (HVAC) Systems

The HVAC factor reflects the extent to which the energy savings from mo re

- efficient equipment are offset by increased demands placed on heating and cooling equipment in the presence of more- efficient equipment. Typically

, this takes the form of increased efficiency being achieved through less energy wasted as heat, increasing the burden on HVAC equipme nt
in winter months.

Consistent with previous and ongoing lighting rulemakings ( for HID l amps and fluorescent lamp ballasts 2 3 ), DOE found that the HVAC factor is highly dependent on the composition of building stock.

Due to the high level of uncertainty in building stock and the majority share of lamps being used outdoors without interaction with HVAC , DOE used an HVAC factor of 1 for calculating energy savings in this NOPD

.

11.3.2.6 Rebound Rate

In its analysis, DOE consider ed the rebound effect that occurs after installation of energy efficient lighting equipment. Under economic theory, “rebound effect” refers to the tendency of a

customer to respond to the co st savings associated with more

- efficient equipment in a manner

11 -6that actually leads to marginally greater equipment usage, thereby diminishing some portion of the anticipated benefits related to improved efficiency. DOE examined a summary of the literature regarding the rebound effect in relation to lighting equipment. 4 Based on four studies, the summary estimated that for a 100

- percent increase in energy effic ien cy , “ take

- back ” or rebound values for commercial and industrial lighting are between 0 and 2 percent. In this NOPD, DOE assume d a 0 percent rebound rate in all three sectors analyzed.

A m ajority of the lamps covered by this proposed determination are exterior and their operating hours, as well as energy use, are driven by daylight hours ( the majority of HID lamps
operat ing only at night), not by the perceived energy ex penses of a customer.

11.4 NET PRESENT VALUE

11.4.1 Net Present Value Definition

The NPV is the value in the present of a time series of costs and savings. The NPV is

calcula ted as follows:

PVCPVS NPV −= Eq. 11.4

Where :

PVS = present value of operating cost savings, and

PVC = present value of increased total installed costs.

The PVS and PVC are determined according to the following expressions:


# ∑ ×=

t tt



### DFOCS PVS

Eq. 11.5


# ∑ ×=

t tt 

### DF TICI PVC

Eq. 11.6

Where :

OCS t = total annual operating cost savings in year t

, TIC I

t = total annual installed cost increases in year t

, DF t = discount factor associated with year t , and

t = year ( PVS and PVC are summed over the lifetime of equipment shipped in 2017–2046).

DOE determine d the contributions to PVC and PVS for each year from 2017, an assumed effective date for any potential standard, to the end of life of the equipment shipped through 2046, and discount ed these costs to 2013 . DOE calculate d savings as the difference between a potential standards case ( i.e. , with standards) and a base case ( i.e. , without any standards). DOE

discount ed savings using the discount rate and the number of years between the “present” ( i.e.

,

11 -7year to which the sum is being discounted) and the year in which the costs and savings occur.

DOE calculated the NPV as the sum over time of the discounted net savings (which is equival ent to the approach shown in Eq. 11.4 through Eq. 11.6 ).

11.4.2 Net Present Value Inputs

Table 11.4.1 summarizes the inputs to the NPV calculation.

Table 11.4.1 Net Present Value Inputs

Input

Total Annual Installed Cost ( TIC t ) Total Annual Operating Cost ( OC t )

Discount Factor (DF)

11.4.2.1 Total Annual Installed Cost Increases

DOE calculated the increase in total annual installed costs (TICI t ) from the difference in

total annual installed costs in any potential standards case and the total annual installed costs in the base case. For each case, the total annual installed cost s equal the product of the shipmen ts
and per -unit installed cost (summed over each lamp system design):

) (

t ld ld ld

ld t r pricefacto UPPUIC shipments TIC ×+× = 

## ∑

Eq. 11.7

Where:

TI C

t = total installed costs in year t

, shipments ld = total shipments of lamp type ld

, UIC ld

= unit installation costs of lamp/fixture type ld

, UPP ld = unit post tax price of lamp/fixture type ld

, price factor = price learning index for year t,

t = year, and

ld = lamp ID number.

T he increase in total annual installed costs (TICI t ) equals the total annual installed costs

in any potential standards case minus th e total annual installed costs in the base case.

11.4.2.2 Total Annual Operating Cost Savings

As the life

- cycle cost ( LCC ) and payback period ( PBP ) analysis ( NOPD TSD chapter 9 ) describes, DOE calculate d total annual operating costs based on national average electricity prices by sector . (The only component of annual operating cost for HID lamp system s that is different between the base case and any potential standards case is unit energy use .) In either case, the total annual operating cost is calculated as:



# ∑ ×× =

ld t ld ld t 

### price y electricit UEC STOCK OC

11 -8Eq. 11.8

Where:

OC t = total annual operating cost in year t

, STOCK ld

= total stock of lamp type ld

, UEC ld

= unit energy consumption of lamp type ld

, electricity price t = electricity price associated with lamp type ld

, t = year, and

ld = lamp ID number.

DOE calculate d total annual operating cost savings (OCS) as the total annual operating

costs in the base case minus the total annual operating cost in any potential standards case

. DOE used an average number of annual operating hours for each sector and lamp type in calculating

the UEC of each HID lamp system

. DOE use d AEO 2013 and EIA’s Form 826 to establish all

electr icity prices

. 1 Chapter 9 of the NOPD TSD provides the electricity price projection s DOE

used to calculate the NPV.

11.4.2.3 Discount Factor

DOE multiplie d monetary values in future years by the discount factor (DF) to calculate the present value. The following equation describes how to calculate the discount factor:



## ( ) ( )

p tt 

### r DF − 

### +=

11
Eq. 11.9

Where :

r = discount rate,

t = year of the monetary value, and

t p = year in which the present value is being determined.

DOE estimate d national impacts of any potential higher efficacy standard with both a 3- percent and a 7

- percent real discount rate as the average real rate of return on private investment in the U.S. economy. These discount rates were used in accordance with Office of Management and Budget (OMB) guidance to Federal agencies on the development of regulatory analysis (OMB Circular A -4, September 17, 2003), and section E, Identifying and Measuring Benefits

and Cos ts

, therein. 5 DOE define d the present year as 2013 for this NOPD

.

11.5 NATIONAL ENERGY SAVINGS AND NET PRESENT VALUE RESULTS

The NES spreadsheet model provides estimates of the NES and NPV due to various ELs

. The inputs to the NES and NPV spreadsheet are discussed in sections 11.3.2 and 11.4.2

, respectively . DOE generated the NES and NPV results using Microsoft Excel spreadsheet s, accessible at www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23

.

11 -911.5.1 National Energy Savings and Net Present Value Input Summary

Table 11.5.1 summarizes the inputs to the NES sp readsheet model. A brief description of the data is given for each input.

Table 11.5.1 Approach and Data Used for National Energy Savings and Customer Net

Present Value Analyses

Inputs NOPD TSD

Shipments Developed annual shipments from shipments model ( NOPD TSD chapter 1 0 )

Assumed Compliance Date of

Potential Standard 20 17

Annual Energy Consumption per

Unit Established in the energy use analysis ( NOPD TSD chapter 8 )

Rebound Effect 0% Electricity Price Forecast AEO201 3 Energy Site

- to

- Source Conversion

Factor Used annually variable site kWh

- to

source

- Btu conversion factors

Discount Rate 3% and 7% real

Present Year 201 3

11.5.2 National Energy Savings Results

The following section provides NES results for each EL that DOE calculated for HID lamps. Table 11.5.2 through Table 11.5.4 show cumulative NES r esults over the lifetime of the equipment sold in 2017–2046 in quads of primary and FFC energy for each of the three ELs

.

Table 11.5.2 Cumulative National Energy Savings for HID Lamps Purchased from 2017–

2046 for EL 1

Efficacy

Level Representative Equipment

Class Representative Lamp Type National Energy Savings quads* ( Roll

- up Scenario )

Primary Full

- Fuel

- Cycle

1 ≥2800 K and ≤4500 K; ≥50 W and ≤400 W; clear; enclosed MV 100 W 0.000 0.000

MV 175 W 0.000 0.000

MV 250 W 0.001 0.001

MV 400 W 0.003 0.003

MH 400 W

- - ≥2800 K and ≤4500 K >400 W and ≤1000 W; clear; enclosed MV 1000 W 0.000 0.000

MH 1000 W

- -

≥2800 K and ≤4500 K; >1000 W and ≤2000 W; clear; enclosed MH 2000 W 0.001 0.001

TOTAL EL 1 0.006 0.007
* quads = quadrillion British thermal units.

11

- 10Table 11.5.3 Cumulative National Energy Savings for HID Lamps Purchased from

2017–2046 for EL 2

Efficacy

Level Representative Equipment

Class Representative Lamp Type National Energy Savings quads* ( Roll

- up Scenario )

Primary Full

- Fuel

- Cycle

2 ≥2800 K and ≤4500 K; ≥50 W and ≤400 W; clear; enclosed MV 100 W 0.005 0.005

MV 175 W 0.005 0.005

MV 250 W 0.017 0.018

MV 400 W 0.086 0.0 88

MH 400 W 0.051 0.05 2
≥2800 K and ≤4500 K >400 W and ≤1000 W; clear; enclosed MV 1000 W 0.002 0.002

MH 1000 W 0.001 0.001

≥2800 K and ≤4500 K; >1000 W and ≤2000 W; clear; enclosed MH 2000 W 0.001 0.001

TOTAL EL 2 0.169 0.17 2
* quads = quadrillion British thermal units

.

Table 11.5.4 Cumulative National Energy Savings for HID Lamps Purchased from

2017–2046 for EL 3

Efficacy

Level Representative Equipment

Class Representative Lamp Type National Energy Savings quads* ( Roll

- up Scenario )

Primary Full

- Fuel

- Cycle

3 ≥2800 K and ≤4500 K; ≥50 W and ≤400 W; clear; enclosed MV 100 W 0.050 0.05 0

MV 175 W 0.068 0.0 69

MV 250 W 0.201 0.20 5

MV 400 W 0.008 0.008

MH 400 W 1.219 1.2 39
≥2800 K and ≤4500 K >400 W and ≤1000 W; clear; enclosed MV 1000 W 0.002 0.002

MH 1000 W 0.001 0.001

≥2800 K and ≤4500 K; >1000 W and ≤2000 W; clear; enclosed MH 2000 W 0.001 0.001

TOTAL EL 3 1.550 1. 576
* quads = quadrillion British thermal units

11.5.3 Net Present Value Analysis

The NPV calculation attempts to calculate the total monetary costs and benefits of the

standard for all customers of HID lamp systems. This calculation relies primarily on two inputs: (1) the NES calculations described in the previous section, which are translated into a decrease (or in some cases increase) in operating costs ; and (2) the increase (or in some cases decrease) in

installed costs.

In most cases the present value of the annual operating cost savings and installed costs increases trend toward zero over time, reflecting the impacts of discounting.

11

- 11NPV results are cumulative and shown as the discounted value of these savings in dollar

t erms. DOE use d national averages for key inputs such as electricity pricing and sector

- specific point values for operating hours in calculating operating cost savings and installed cost increases

. Thus, the NPV results are discrete point values rather than a distribution of values as in the LCC and PBP analyses.

The present value of increased total installed costs is the total installed cost increase ( i.e.

, the difference between the standards case and base case in a given year), discounted to the present, and summed over the time period in which DOE evaluated the impact of standards ( i.e.

, from the assumed effective date of potential standards, 2017, to the end of life of the equipment shipped through 2046).

Operating cost savings are decreases in operati ng costs associated with higher- efficacy lamps purchased in the standards case compared to the base case. DOE calculated total annual operating cost savings as the difference between total annual operating costs in the base case

minus those in the standards case. Eq. 11.8 gives the total annual operating costs in each case.

11.5.4 Net Present Value Results

Table 11.5.5 through Table 11.5.7 show the NPV results in tabular format for both 7- and 3-percent discount rates. Energy savings do not necessarily correspond to NPV savings. T he results of this NOPD analysis shows that, with few exceptions, introduction of any higher efficacy level would result in higher costs than benefits ( i.e.

, negative NPV). This is due to the

need to replace a large number of fixtures in the higher efficacy , potential standards case s since the higher efficacy lamps are not drop-in replacements, but require installation of complete ly

new lamp system s. In most cases, w hen a customer can no longer buy a lamp due to a ny potential standard, they cannot operate a pre-2017 fixture anymore, which necessitates a new fixture purchase in the potential standards case. In the base case, the replacement lamps designed and matched to the original fixture are st ill available, so a lamp or lamp and ballast purchase will

often suffice.

Table 11.5.5 Cumulative Net Present Value for HID Lamps Purchased from 2017–2046 for

EL 1

Efficacy

Level Representative Equipment

Class Representative Lamp Type Net Present Value

billion 201 2$

Roll

- up Scenario

7

- Percent

Discount Rate 3

- Percent

Discount Rate

1 ≥ 2800 K and ≤4500 K; ≥50 W and ≤400 W; clear; enclosed MV 100 W

- 0.013

- 0.008

MV 175 W

- 0.027

- 0.023

MV 250 W

- 0.019

- 0.011

MV 400 W 0.004 0.017

MH 400 W

--- --- ≥ 2800 K and ≤4500 K >400 W and ≤1000 W; clear; enclosed MV 1000 W

- 0.0001 0.0002

MH 1000 W --- ---

≥ 2800 K and ≤4500 K; >1000 W and ≤2000 W; clear; enclosed MH 2000 W - 0.018

- 0.030

TOTAL EL 1

- 0.074

- 0.055

11

- 12Table 11.5.6 Cumulative Net Present Value for HID Lamps Purchased from 2017 –2046 for

EL 2

Efficacy

Level Representative Equipment

Class Representative Lamp Type Net Present Value

billion 201 2$

Roll

- up Scenario

7

- Percent

Discount Rate 3

- Percent

Discount Rate

2 ≥ 2800 K and ≤4500 K; ≥50 W and ≤400 W; clear; enclosed MV 100 W

- 0.315

- 0.570

MV 175 W

- 0.156

- 0.268

MV 250 W

- 0.388

- 0.667

MV 400 W

- 0.213

- 0.304

MH 400 W

- 0.930

- 1.608

≥ 2800 K and ≤4500 K >400 W and ≤1000 W; clear; enclosed MV 1000 W - 0.013

- 0.022

MH 1000 W

- 0.472

- 0.879

≥ 2800 K and ≤4500 K; >1000 W and ≤2000 W; clear; enclosed MH 2000 W - 0.018

- 0.030

TOTAL EL 2

- 2.51

- 4.35

Table 11.5.7 Cumulative Net Present Value for HID Lamps Purchased from 2017 –2046 for

EL 3

Efficacy

Level Representative Equipment

Class Representative Lamp Type Net Present Value

billion 201 2$

Roll

- up Scenario

7

- Percent

Discount Rate 3

- Percent

Discount Rate

3 ≥ 2800 K and ≤4500 K; ≥50 W and ≤400 W; clear; enclosed MV 100 W

- 1.08

- 1.63

MV 175 W

- 1.27

- 1.93

MV 250 W

- 1.79

- 2.50

MV 400 W

- 2.12

- 3.11

MH 400 W 1.28 2.79

≥ 2800 K and ≤4500 K >400 W and ≤1000 W; clear; enclosed MV 1000 W - 0.013

- 0.022

MH 1000 W

- 0.472

- 0.879

≥ 2800 K and ≤4500 K; >1000 W and ≤2000 W; clear; enclosed MH 2000 W - 0.018

- 0.030

TOTAL EL 3

- 5.48

- 7.30

11

- 13REFERENCES

1. U.S. Energy Information Administration. Annual Energy Outlook 2013 with Projections to

2035 . 2013. EIA: Washington, D.C.

< www.eia.gov/forecasts/archive/aeo13/index.cfm >

2. U.S. Department of Energy – Office of Energy Efficiency and Renewable Energy. Energy Efficiency Program for Consumer Products and Certain Commercial and Industrial Equipment : Preliminary Technical Support Document: Metal Halide Lamp Fixtures. 2011. Washington, D.C. < www.regulations.gov/#!documentDetail;D=EERE-2009- BT

- STD

0018-0021 >

3

. U.S. Department of Energy – Office of Energy Efficiency and Renewable Energy. Energy Conservation Program for Consumer Products: Final Rule Technical Support Document: Fluorescent Lamp Ballasts. 2011. Washington, D.C.

< www.regulations.gov/#!documentDetail;D=EERE-2007- BT

- STD -0016-0067 >

4. Greening, L.A., D.L. Greene, and C. Difiglio. 2000. Energy E fficiency and Consumption–

T he Rebound E ffect : A Survey. Energy Policy . 28: pp. 389–401.

5. Office of Management and Budget. Circular A -4. September 2003. Washington, D.C.

< www.whitehouse.gov/sites/default/files/omb/assets/regulatory_matters_pdf/a -4.pdf >

11

- 14CHAPTER 1 2. MANUFACTURER IMPACT ANALYSIS

TABLE OF CONTENTS

12.1 INTRODUCTION ......................................................................................................... 12-1

12.2 METHODOLOGY ........................................................................................................ 12-1

12.2.1 Phase I: Industry Profile ..................................................................................... 12-2

12.2.2 Phase II: Industry Cash -Flow Analysis and Interview Guide ............................ 12-2

12.2.2.1 Industry Cash-Flow Analysis ....................................................................... 12-2

12.2.2.2 Interview Guides .......................................................................................... 12-3

12.2.3 Phase III: Subgroup Analysis............................................................................. 12-3

12.2.3.1 Manufact uring Interviews ............................................................................ 12-3

12.2.3.2 Revised Industry Cash -Flow Analysis ......................................................... 12-4

12.2.3.3 Small

- Business Manufacturer Subgroup ..................................................... 12-4

12.2.3.4 Manufacturing Capacity Impact .................................................................. 12-5

12.2.3.5 Employment Impact ..................................................................................... 12-5

12.2.3.6 Cumulative Regulatory Burden ................................................................... 12-5

12.3 MANUFACTURER IMPACT ANAL YSIS KEY ISSUES .......................................... 12-5

12.3.1 Energy Savings From Replacement HID Lamps ............................................... 12-6

12.3.2 Testing Burden ................................................................................................... 12-6

12.3.3 Technology Shift ................................................................................................ 12-6

12.3.4 Product Innovation ............................................................................................. 12-6

12.4 GRIM INPUTS AND ASSUMPTIONS ........................................................................ 12-6

12.4.1 Overview of the GRIM ...................................................................................... 12-7

12.4.2 Sources for GRIM Inputs ................................................................................... 12-7

12.4.2.1 Corporate Annual Reports ........................................................................... 12-8

12.4.2.2 Standard and Poor’s Credit Ratings ............................................................. 12-8

12.4.2.3 Shipment Model ........................................................................................... 12-8

12.4.2.4 Engineering Analysis and Equipment Price Determination ........................ 12-8

12.4.2.5 Manufacturer Interviews .............................................................................. 12-9

12.4.3 Financial Parameters .......................................................................................... 12-9

12.4.4 Corporate Discount Rate .................................................................................. 12-10

12.4.5 NIA Shipment Forecast .................................................................................... 12-12

12.4.6 Production Costs .............................................................................................. 12-12

12.4.7 Product and Capital Conversion Costs ............................................................ 12-15

12.4.8 Markup Scenarios ............................................................................................ 12-17

12.4.8.1 Flat Markup Scenario ................................................................................. 12-17

12.4.8.2 Preservation of Operating Profit Markup Scenario ................................... 12-17

12.5 INDUSTRY FINANCIAL IMPACTS ........................................................................ 12-21

12.5.1 Impacts on Industry Net Present Value ........................................................... 12-21

12.5.1.1 50 W – 400 W Equipment Class INPV Results ......................................... 12-22

12.5.1.2 401 W – 1000 W Equipment Class INPV Results ..................................... 12-22

12.5.1.3 1001 W – 2000 W Equipment Class INPV Results ................................... 12-23

12.5.2 Impacts on Annual Cash Flow ......................................................................... 12-23

12.6 IMPACTS ON MANUFACTURER SUBGROUPS ................................................... 12-28

12-i12.6.1 Impacts on Small Business Manufacturers ...................................................... 12-28

12.6.1.1 Description and Estimated Number of Small Entities Regulated .............. 12-28

12.7 OTHER IMPACTS ...................................................................................................... 12-29

12.7.1 Employment ..................................................................................................... 12-29

12.7.2 Production Capacity ......................................................................................... 12-31

12.7.3 Cumulative Regulatory Burden ....................................................................... 12-31

12.8 CONCLUSION ............................................................................................................ 12-31

REFERENCES ........................................................................................................................ 12-33

LIST OF TABLES

Table 12.2.1 SBA and NAICS Classification of Small Businesses Potentially Affected by This

NOPD ............................................................................................................................. 12-4

Table 12.4.1 GRIM Financial Parameters Based on 2005– 2012 Weighted Company Financial

Data ................................................................................................................................ 12-9 Table 12.4.2 GRIM Revised HID Lamp Industry Financial Parameters ................................. 12-10 Table 12.4.3 Cost of Equity Calculation .................................................................................. 12-11

Table 12.4.4 Cost of Debt Calculation..................................................................................... 12-11 Table 12.4.5 Manufacturer Production Cost Breakdown (2012$) for the 100 W Mercury Vapor Representative Lamp Type .......................................................................................... 12-13 Table 12.4.6 Manufacturer Production Cost Breakdown (2012$) for the 175 W Mercury Vapor Representative Lamp Type .......................................................................................... 12-13 Table 12.4.7 Manufacturer Production Cost Breakdown (2012$) for the 250 W Mercury Vapor Representative Lamp Type .......................................................................................... 12-14 Table 12.4.8 Manufacturer Production Cost Breakdown (2012$) for the 400 W Mercury Vapor Representative Lamp Type .......................................................................................... 12-14 Table 12.4.9 Manufacturer Production Cost Breakdown (2012$) for the 400 W Metal Halide Representative Lamp Type .......................................................................................... 12-14 Table 12.4.10 Manufacturer Production Cost Breakdown (2012$) for the 1000 W Mercury Vapor Representative Lamp Type .......................................................................................... 12-15 Table 12.4.11 Manufacturer Production Cost Breakdown (2012$) for the 1000 W Metal Halide Representative Lamp Type .......................................................................................... 12-15 Table 12.4.12 Manufacturer Production Cost Breakdown (2012$) for the 2000 W Metal Halide Representative Lamp Type .......................................................................................... 12-15 Table 12.4.13 Product and Capital Conversion Costs for the 50 W – 400 W Equipment Class HID Lamps by EL ........................................................................................................ 12-16 Table 12.4.14 Product and Capital Conversion Costs for the 401 W – 1000 W Equipment Class HID Lamps by EL ........................................................................................................ 12-16 Table 12.4.15 Product and Capital Conversion Costs for the 1001 W – 2000 W Equipment Class HID Lamps by EL ........................................................................................................ 12-17 Table 12.4.16 Preservation of Operating Profit Markups for the 100 W Mercury Vapor Representative Lamp Type .......................................................................................... 12-18 Table 12.4.17 Preservation of Operating Profit Markups for the 175 W Mercury Vapor Representative Lamp Type .......................................................................................... 12-18

12- iiTable 12.4.18 Preservation of Operating Profit Markups for the 250 W Mercury Vapor Representative Lamp Type .......................................................................................... 12-19 Table 12.4.19 Preservation of Operating Profit Markups for the 400 W Mercury Vapor Representative Lamp Type .......................................................................................... 12-19 Table 12.4.20 Preservation of Operating Profit Markups for the 400 W Metal Halide Representative Lamp Type .......................................................................................... 12-20 Table 12.4.21 Preservation of Operating Profit Markups for the 1000 W Mercury Vapor Representative Lamp Type .......................................................................................... 12-20 Table 12.4.22 Preservation of Operating Profit Markups for the 1000 W Metal Halide Representative Lamp Type .......................................................................................... 12-20 Table 12.4.23 Preservation of Operating Profit Markups for the 2000 W Metal Halide Representative Lamp Type .......................................................................................... 12-21 Table 12.5.1 Changes in Industry Net Present Value for the 50 W – 400 W Equipment Class

– Flat Markup Scenario ................................................................................................... 12-22 Table 12.5.2 Changes in Industry Net Present Value for the 50 W – 400 W Equipment Class

– Preservation of Operating Profit Markup Scenario ..................................................... 12-22

Table 12.5.3 Changes in Industry Net Present Value for the 401 W – 1000 W Equipment Class – Flat Markup Scenario ................................................................................................... 12-22 Table 12.5.4 Changes in Industry Net Present Value for the 401 W – 1000 W Equipment Class – Preservation of Operating Profit Markup Scenario ..................................................... 12-22 Table 12.5.5 Changes in Industry Net Present Value for the 1001 W – 2000 W Equipment Class

– Flat Markup Scenario ................................................................................................ 12-23 Table 12.5.6 Changes in Industry Net Present Value for the 1001 W – 2000 W Equipment Class – Preservation of Operating Profit Markup Scenario .................................................. 12-23 Table 12.7.1 Potential Changes in the Total Number of All Domestic HID Lamp Production

Workers in 2017 ........................................................................................................... 12-30

LIST OF FIGURES

Figure 12.4.1 Using the GRIM to Calculate Cash Flow ............................................................ 12-7 Figure 12.5.1 Annual Free Cash Flow from the 50 W – 400 W Equipment Class HID Lamps - Flat Markup Scenario ................................................................................................... 12-25 Figure 12.5.2 Annual Free Cash Flow from the 50 W – 400 W Equipment Class HID Lamps - Preservation of Operating Profit Markup Scenario ..................................................... 12-25 Figure 12.5.3 Annual Free Cash Flow from the 401 W – 1000 W Equipment Class HID Lamps – Flat Markup Scenario ................................................................................................... 12-26 Figure 12.5.4 Annual Free Cash Flow from the 401 W – 1000 W Equipment Class HID Lamps – Preservation of Operating Profit Markup Scenario ..................................................... 12-26 Figure 12.5.5 Annual Free Cash Flow from the 1001 W – 2000 W Equipment Class HID Lamps

– Flat Markup Scenario ................................................................................................ 12-27 Figure 12.5.6 Annual Free Cash Flow from the 1001 W – 2000 W Equipment Class HID Lamps – Preservation of Operating Profit Markup Scenario .................................................. 12-27

12- iiiCHAPTER 12. MANUFACTURER IMPACT ANALYSIS

12.1 INTRODUCTION

In determining whether a potential standard is economically justified, the U.S. Department of Energy (DOE) is required to consider “the economic impact of the standard on

the manufacturers and on the consumers o f the products subject to such a standard.” (42 U.S.C. 6312(a)(6)(B)(i)) The law also calls for an assessment of the impact of any lessening of competition as determined in writing by the Attorney General. Id. DOE conducted a manufacturer impact analysis ( MIA) to estimate the financial impact of potential energy conservation standards on manufacturers of high intensity discharge (HID) lamps , and assessed the impact of such potential standards on direct employment and manufacturing capacity.

The MIA has both quantitative and qualitative aspects. The quantitative part of the MIA primarily relies on the Government Regulatory Impact Model (GRIM), an industry cash- flow model adapted for products in this NOPD . The GRIM inputs include information on industry

cost structure, shipments, and pricing strategies. The GRIM’s key output is the industry net present value (INPV). The model estimates the potential financial impact of more stringent energy conservation standards for each equipment class by comparing changes in INPV between a base case and higher efficacy levels (ELs) for each equipment class in the standards case. The qualitative part of the MIA addresses product characteristics, manufacturer characteristics, market and product trends, a s well as the impact of potential standards on subgroups of

manufacturers.

12.2 METHODOLOGY

DOE conducted the MIA in three phases. Phase I, “Industry Profile,” consisted of preparing an industry characterization for the HID lamp industry, including data on mark et share, sales volumes and trends, pricing, employment, and financial structure. In p hase II, “Industry Cash Flow,” DOE used the GRIM to assess the impacts of potential energy conservation

standards on HID lamps

.

In p hase II, DOE created a GRIM for HID l amp s and an interview guide to gather information on the potential impacts on manufacturers. DOE presented the MIA results for HID lamp s for each equipment class at each EL

.

In p hase III, “Subgroup Impact Analysis,” DOE interviewed manufacturers represent ing

more than 80 percent of HID lamp sales. Interviewees included large and small manufacturers with various market shares and market focus, providing a representative cross- section of the industries. During interviews, DOE discussed financial topics speci fic to each manufacturer and obtained each manufacturer’s view of the industry. The interviews provided DOE with valuable information for evaluating the impacts of potential energy conservation standards on manufacturer cash flows, investment requirements, and employment.

12-112.2.1 Phase I: Industry Profile

In phase I of the MIA, DOE prepared a profile of the HID lamp industry that built upon the market and technology assessment prepared for this notice of proposed determination (NOPD) (see chapter 3 of this NOP D t echnical support document [ TSD ]). Before initiating the detailed impact studies, DOE collected information on the present and past structure and market characteristics of each industry. This information included market share data, unit shipments,

manufactu rer markups, and the cost structure for various manufacturers. The industry profile includes: (1) further detail on the overall market and equipment characteristics; (2) estimated manufacturer market shares; (3) financial parameters such as net plant, prop erty, and equipment (PPE) ; selling, general and administrative (SG&A) expenses; cost of goods sold, etc.; and (4) trends in the number of firms, market, and equipment characteristics. The industry profile included a top -down cost analysis of HID lamp manufacturers that DOE used to derive preliminary financial inputs for the GRIM ( e.g., revenues, depreciation, SG&A, and research and development (R&D) expenses).

DOE also used public information to further calibrate its initial characterization of the

HID lamp industry, including Securities and Exchange Commission (SEC) 10–K reports, 1
Standard & Poor’s (S&P) stock reports, 2 and corporate annual reports. DOE supplemented this public information with data released by privately held companies.

12.2.2 Phase II: Indust ry Cash- Flow Analysis and Interview Guide

Phase II focused on the financial impacts of potential energy conservation standards on

manufacturers of HID lamp s. E nergy conservation standards can affect manufacturer cas h flows in three distinct ways: (1) creat e a need for increased investment, (2) raise production costs per unit, and (3) alter revenue due to higher per- unit prices and/or possible changes in sales volumes. To quantify these potential impacts, DOE used the GRIM to perform a cash -flow analysis for HID lamp s . In performing these analyses, DOE used the financial values derived during p hase I and the shipment scenarios used in the national impact analysis (NIA). In p hase II, DOE performed these preliminary industry cash- flow analyses and prepared writ ten guid es for

manufacturer interviews.

12.2.2.1 Industry Cash -Flow Analysis

The GRIM uses several factors to determine a series of annual cash flows from the announcement year of potential energy conservation standards until several years after the potential stand ards’ compliance date. These factors include annual expected revenues, costs of sales, SG&A, taxes, and capital expenditures related to the potential standards. Inputs to the GRIM include manufacturing production costs (MPCs), selling prices, and shipments forecasts developed in other analyses. DOE derived the end

- user prices from the engineering analysis and information provided by the industry and estimated typical distribution and manufacturer markups from public financial reports and interviews with manufacturers to arrive at typical MPCs for representative lamps . DOE developed alternative markup scenarios for the GRIM based on discussions with manufacturers. DOE’s shipments analysis, presented in chapter 10 of

this NOP D TS D, provided the basis for the shipment projections in the GRIM. The financial parameters were developed using publicly available manufacturer data and were revised with

12-2information submitted confidentially during manufacturer interviews. The GRIM results a re compared to base case projections for the industry. The financial impact of potential energy

conservation standards is the difference between the discounted annual cash flows in the base case and standards case for each equipment class at each EL

.

12.2.2.2 I nter view Guides

During p hase III of the MIA, DOE interviewed manufacturers to gather information on

the effects of potential energy conservation on revenues and finances, direct employment, capital assets, and industry competitiveness. Before the interviews, D OE distributed an interview guide

for the HID lamp industry. The interview guide provided a starting point to identify relevant issues and help identify the impacts of potential energy conservation standards on individual manufacturers or subgroups of manu facturers. Most of the information DOE received from these meetings is protected by non- disclosure agreements and resides with DOE’s contractors. Before each telephone interview or site visit, DOE provided company representatives with an interview guide that included the topics for which DOE sought input. The MIA interview topics included (1) scope ; (2) market and technology; (3 ) engineering ; ( 4 ) key i ssues ; (5 ) company overview and organizational c haracteristics ; (6) markups and profitability ; ( 7 ) shipment projections ; (8)

f inancial p arameters; ( 9 ) c onversion costs; ( 10 ) cumulative regulatory burden; ( 11 ) direct employment assessme nt; (1 2 ) manufacturing capacity and non- US sales ; (13 ) impact on competition ; (1 4) HID ballast impacts; and (15) impacts on smal l business es . The interview guides are presented in appendix 12A.

12.2.3 Phase III: Subgroup Analysis

Using average cost and financial assumptions to develop an industry cash-flow model is not adequate for assessing differential impacts among a potential subgroup of manufacturers. Small manufacturers, niche players, or manufacturers exhibiting a cost structure that differs largely from the industry average could be more negatively impacted. During interviews, DOE identified one potential manufacturer subgroup (small business manufacturers) that could be disproportionately impacted by potential energy conservation standards. As a result, DOE will analyze small business manufacturers as a subgroup.

12.2.3.1 Manufacturing Interviews

The information gathered in p hase I and the cash -flow analysis performed in p hase II are supplemented with information gathered from manufacturer interviews in p hase III. The interview process provides an opportunity for interested parties to express their views on important issues privately, allowi ng confidential or sensitive information to be consid ered in the rulemaking process.

DOE used these interviews to tailor the GRIM to reflect unique financial characteristics

for HID lamp manufacturers. DOE contacted companies from its database of manufact urers and interviewed small and large companies, subsidiaries and independent firms, and public and private corporations to provide a n accurate representation of the industry. Interviews were scheduled well in advance to provide every opportunity for key individuals to be available for comment. Although a written response to the questionnaire was acceptable, DOE sought

12-3interactive interviews, which help ed clarify responses and identify additional issues. The resulting information provides valuable inputs to the GRIM developed for the equipment classes.

12.2.3.2 Revised Industry Cash

- Flow Analysis

In phase II of the MIA, DOE provided manufacturers with preliminary GRIM input financial figures for review and evaluation. During the interviews, DOE requested comments on the values it selected for the parameters. DOE revised its industry cash -flow models based on

this feedback. Section 12.4.3 provides more informati on on how DOE calculated the parameters

.

12.2.3.3 Small

- Business Manufacturer Subgroup

DOE investigated whether small business manufacturers should be analyzed as a manufacturer subgroup. DOE used the Small Business Administration (SBA) small business size

standard s published on January 22, 2014, as amended, and the North American Industry Classification System (NAICS) code, presented in Table 12.2.1 , to determine whether any small entities would be affected by the potential standards. a For the equipment classes under review, the SBA bases its small business definition on the total number of employees for a business, its subsidiaries, and its parent c ompanies. An aggregated business entity with fewer employees than

the listed limit is considered a small business.

Table 12.2.1 SBA and NAICS Classification of Small Businesses Potentially Affected by

This NO PD

Industry Description Revenue Limit Employee Limit NAICS

Electric Lamp Bulb and Part Manufacturing N/A 1,000 335110

DOE used the National Electrical Manufacturers Association (NEMA) 3 member directory to identify manufacturers of HID lamps. DOE also used information from previous rulemakings, individual company websites, and market research tools ( e.g., Hoover’s reports) to create a list of companies that potentially manufacture HID la mps covered by this NOPD

. Additionally, DOE also asked interested parties and industry representatives if they were aware of other small business manufacturers. DOE contacted select companies on its list, as necessary, to determine whether they met the SBA ’s definition of a small business manufacturer of covered HID lamps. DOE screened out companies that did not offer equipment covered by this NOPD

, did not meet the definition of a “small business,” or are completely foreign owned and operated.

During its research, DOE identified approximately 16 companies which manufacture equipment analyzed in this NOPD and qualify as small businesses per the applicable SBA definition. DOE contacted the small businesses to solicit feedback on the impacts of potential

ener gy conservation standards. One of the small businesses consented to being interviewed during the MIA interviews. In addition to posing the standard MIA interview questions, DOE solicited data from manufacturers on differential impacts that these small comp anies might experience from potential standards. Because DOE is not proposing a new standard in this

NOP D, DOE is able to certify that no small entities would be impacted and DOE did not analyze

a The size standards are available on the SBA’s website at http://www.sba.gov/content/table

- small

- business

- size

standards

12-4small business manufacturers as a subgroup. More information on DOE’s efforts to contact small

businesses is available in section 12.6

.

12.2.3.4 Manufacturing Capacity Impact

One significant outcome of potential energy conservation standards could be the obsolescence of existing manufacturing assets, including tooling and investment. The manufacturer interview guides have a series of questions to help identify impacts of potential standards on manufacturing capaci ty, specifically capacity utilization and plant location decisions in the United States, with and without potential standards; the ability of manufacturers to upgrade or remodel existing facilities to accommodate the potential requirements; the nature and value of any potential stranded assets; and estimates for any one

- time changes to existing

PPE. DOE’s estimates of the one

- time capital changes and stranded assets affect the cash

- flow

estimates in the GRIM. These estimates can be found in s ection 12.4.7 and DOE’s discussion of the production capacity impact can be found in s ection 12.7.2

.

12.2.3.5 Employment Impact

The impact of potential energy conservation standards on employment is an important consideration when considering potential standards . To assess how domestic direct employment patterns might be affected, the interviews explored current employment trends in the HID lamp industry. The interviews also solicited manufacturer views on changes in employment patterns that may result if standards were implemented . The employment impacts section of the interview guide focused on current employment levels associated with manufacturers at each production facility, expected future employment levels with and without new energy conservation standards,

and differences in workforce skills and issues related to the retraining of employees. The empl oyment impacts are reported in s ection 12.7.1

.

12.2.3.6 Cumulative Regulatory Burden

DOE seeks to mitigate the overlapping effects on manufacturers due to the potential energy conservation standards and other regulatory actions affecting the same products . DOE analyzed the impact on manufacturers of multiple, product-specific regulatory actions. Based on its own research and discussions with manufacturers, DOE identified regulations relevant to HID lamp manufacturers, such as state regulations and other f ederal regulations that impact other products made by the same manufacturers. Discussion of the cumulative reg ulatory burden can

be found in s ection 12.7.3

.

12.3 MANUFACTURER IMPACT ANALYSIS KEY ISSUES

An important aspect of the MIA is the opportunity it creates for DOE to identify key manufacturer issues early in the evaluation of potential energy conservation standards. During preliminary analysis and NOP D analysis interviews manufacturers identified four major areas of concern: (1) energy savings from replacement HID lamps, (2) testing burden, (3) technology shift, and (4) product innovation.

12-512.3.1 Energy Savings From Replacement HID Lamps

Some manufactures expressed doubt that potential energy conservation standards for HID lamps would realize significant energy savings in the replacement HID lamp market. Because HID ballasts and fixtures typically work with only one lamp type and lamp wattage, customers cannot simply replace a failed lamp with a reduced wattage lamp or different kind of HID lamp. Some manufacturers argued that customers would instead install wattage -equivalent lamps and accept high lumen output (given more efficacious lamps). Alternatively, customers would face the high costs of replacing the ballast and/or fixture as well.

12.3.2 Testing Burden

Several manufacturers expressed concern about the testing burden associated with potential effic acy standards for HID lamps. HID lamp burning r acks require a substantial amount of space and potential standards could force manufacturers to increase the size of their test laboratories or even build new testing facilities. Standards for HID lamps would also likely

increase the number of man -hours associated with compliance testing. Additionally, manufacturers pointed out that the testing process for HID lamps is very energy intensive and any potential standards would likely significantly increase their electricity bills.

12.3.3 Technology Shift

Manufacturer s agreed that regardless of any potential standards, a technological shift away from HID lighting is already occurring. According to manufacturers, LEDs and fluorescent technologies are capturing significant market share of new construction in both indoor and outdoor applications. Manufacturers are concerned that any potential standards will accelerate this migration to alternative technologies due to potential price increases from any potential energy conservation standards for HID lamps.

12.3.4 Product Innovati on

Manufacturers expressed concern that any potential energy conservation standards for HID lamps could divert R&D resources away from newer and more efficacious solid state lighting technologies, such as LEDs. Manufacturers generally agreed that any poten tial standards for HID lamps would force manufacturers to allocate limited resources to developing a product that is steadily losing market share. Manufacturers also expressed concern that they would have to redesign HID luminaires, as well as lamps as a r esult of any potential HID lamps standards. They argued this would result in substantial costs that they otherwise would not incur. They pointed out that these expensive changes to HID lamps could ultimately drive manufacturers and

customers out of the HID market.

12.4 GRIM INPUTS AND ASSU MPTIONS

The GRIM serves as the main tool for assessing the impacts on industry due to potential energy conservation standards. DOE relies on several sources to obtain inputs for the GRIM. Data and assumptions from these sources are then fed into an accounting model that calculates the industry cash flow both with and without the potential energy conservation standards.

12-612.4.1 Overview of the GRIM

The basic structure of the GRIM, illustrated in Figu re 12.4.1 , is an annual cash

- flow analysis that uses MPCs , manufacturer markups, shipments, and industry financial information as inputs, and accepts a set of regulatory conditions such as changes in costs, investments, and associated manufacturer margins. The GRIM spreadsheet uses a number of inputs to arrive at a series of annual cash flows, beginning with the base year of the analysis, 2014, and continuing to

2046 . The model calculates th e INPV by summing the stream of annual discounted cash flows during this period and adding a discounted terminal value. 4

Figure 12.4.1 Using the GRIM to Calculate Cash Flow

The GRIM projects cash flows using standard accounting principles and compares changes in INPV between the base case and the standard case scenario induced by potential energy conservation standards. The difference in INPV between the base case and the standard case(s) represents the estimated financial impact of the potential standard on manufacturers. Appendix 12B provides more technical details and user information for the GRIM.

12.4.2 Sources for GRIM Inputs

The GRIM uses several different sources for data inputs in determining industry c ash flow. These sources include corporate annual reports, company profiles, Census data, credit ratings, the shipments model, the engineering analysis, and the manufacturer interviews.

12-712.4.2.1 Corporate Annual Reports

Corporate annual reports to the SEC (SEC 10- Ks ) provided many of the initial financial inputs to the GRIM. These reports exist for publicly held companies and are freely available to the general public. DOE developed initial financial inputs to the GRIM by examining the annual

SEC 10

- K reports filed b y publicly- traded manufacturers that produce HID lamp s, among other products. Since these companies do not provide detailed information about their individual product lines, DOE used financial information at the parent company level as its initial estimate s of the financial parameters in the GRIM analysis. These figures were later revised using feedback from interviews to be representative of HID lamp manufacturing. DOE used corporate annual reports to derive the following initial inputs to the GRIM:

• Tax rate

• Working capital

• SG&A

• R&D

• Depreciation

• Capital expenditures

• Net PPE

12.4.2.2 Standard and Poor ’s Credit Ratings

S&P provides independent credit ratings, research, and financial information. DOE relied on S&P reports to determine the industry’s average cost of debt when calculating the cost of capital.

12.4.2.3 Shipment Model

The GRIM used shipment projections derived from DOE’s shipments model in the NIA. The model relied on historical shipments data for HID lamp s. Chapter 10 of th is NOP D TSD describes the methodology a nd analytical model DOE used to forecast shipments.

12.4.2.4 Engineering Analysis and Equipment Price Determination

The engineering analysis and equipment price determination establish the relationship

between MPC s and lamp effic acy for HID lamp s covered in this NO PD . DOE began its analysis by conducting industry research to determine equipment class groupings , select baseline HID lamp s , and select representative HID lamp s for further testing and analysis. Typically, DOE develops MPCs for the covered equipment and u ses the prices as an input to the life

- cycle cost (LCC) analysis and NIA. However, because HID lamps are difficult to reverse -engineer, DOE

derived end

- user prices in the equipment price determination for the lamps analyzed in this

NOPD . DOE observed a range of end-user prices paid for HID lamps depending on the distribution channel through which the lamps are purchased. DOE then developed three sets of discounts from the manufacturer blue-book prices representing low (state procurement), medium (electrical distributors), and high (Internet retailers) lamp prices for HID lamps. See chapter 5 of

this NOP D TSD for a complete discussion of the engineering analysis and chapter 6 of this NOPD TSD for a complete discussion of the equipment price determination.

12-812.4.2.5 Manufacturer Interviews

During the course of the MIA, DOE conducted interviews with a representative crosssection of manufacturers. DOE also interviewed manufacturers representing a significant portion

of sales in each equipment class. During these discussions, DOE obtained information to determine and verify GRIM input assumptions in each industry. Key topics discussed during the

interviews and reflected in the GRIM include:

• c apital conversion costs (one

- time investments in PPE);

• product conversion costs (one-time investments in research, product development, testing, certification, and marketing);

• production cost structure, or the portion of the MPCs related to materials, labor, overhead, and depreciation costs;

• possible profitability impacts;

• impacts on small businesses; and

• cost

- effic acy curves calculated in the engineering analysis.

12.4.3 Financial Parameters

Table 12.4.1 below provid es financial parameters for six public companies engaged in manufacturing and selling HID lamp s. The values listed are ave rages over a n 8-year period (2005 to 2012 ).

Table 12.4.1 GRIM Fi nancial Parameters Based on 2005–2012 Weighted Company

Financial Data

Parameter Weighted Average Manufacturer

A B C D E F

Tax Rate % of taxable income 26.1 % 13.8 % 35.3 % 27.6 % 39.6% 31.3% 18.7%

Working Capital % of revenues 12.7%

- 8.4 % 16.4 % 4.2 % 32.8 % 58 .0 % 25 .0 %

SG&A % of revenues 19.8% 13.7 % 23.9 % 15.8 % 24.5 % 22.6 % 24.5 %

R&D % of revenues 4.2% 3.1 % 5.0 % 5.0 % 2.1 % 4.4 % 3.8 %

Depreciation % of revenues 3.7% 2.0 % 4.8 % 3.8 % 3.1 % 4.4 % 3.8 %

Capital Expenditures % of revenues 3.5% 2.6 % 3.6 % 4.1 % 1.9 % 5.1 % 3.6 %

Net PPE % of revenues 24.2% 20.0 % 25.1 % 13.8 % 31.8 % 67.8 % 24.9%

During interviews, HID lamp manufacturers were asked to provide their own figures for the parameters listed in Table 12.4.1

. Where applicable, DOE adjusted the parameters in the GRIM using this feedback, more recent data from publicly traded companies, and values used during the metal halide lamp fixture (MHLF) notice of proposed rulemaking ( NOPR ) at 78 FR 51464 (August 20, 2013) to reflect the current HID lamp industry. Table 12.4.2 presents the revised parameters used for HID lamp manufacturers for this NOP D.

12-9Table 12.4.2 GRIM Revised HID L amp Industry Financial Parameters

Parameter Revised Estimates

Tax Rate % of taxable income 26.1%

Working Capital % of revenues 12.7%

SG&A % of revenues 19.8%

R&D % of revenues 4.0%

Depreciation % of revenues 4.4%

Capital Expenditures % of revenues 2.9%

Net PPE % of revenues 24.2%

12.4.4 Corporate Discount Rate

DOE used the weighted- average cost of capital (WACC) as the discount rate to calculate the INPV. A company’s assets are financed by a combination of debt and equity. The WACC is the total cost of debt and equity weighted by their re spective proportions in the capital structure of the industry. DOE estimated the WACC for the HID lamp industry based on several representative companies, using the following formula:

WACC = After -Tax Cost of Debt x (Debt Ratio) + Cost of Equity x (Equity Ratio) Eq. 1

The cost of equity is the rate of return that equity investors (including, potentially, the company) expect to earn on a company’s stock. These expectations are reflected in the market price of the company’s stock. The capital asset pricing model (CAPM) provides one widely used means to estimate the cost of equity. According to the CAPM, the cost of equity (expected return) is:

Cost of Equity = Riskless Rate of Return + β x Risk Premium Eq. 2

where:

Riskless rate of return is the rate of return on a “safe” benchmark investment, typically

considered the short- term Treasury Bill (T

- Bill) yield.

Risk premium is the difference between the expected return on stocks and the riskless

rate.

Beta (β) is the correlation between the movement in the price of the stock and that of the broader market. In this case, Beta equals one if the stock is perfectly correlated with the S&P 500

market index. A Beta lower than one means the stock is less volatile than the market index.

DOE determi ned that the industry average cost of equity for the HID lamp industry is

14.1 percent

.

12-10Table 12.4.3 Cost of Equity Calculation

Parameter Industry

Weighted Average

% Manufacturer

A B C D E F

(1) Average Beta 1.46 1.57 1. 45 1.5 4 1.5 4 0 .7 3 1.46

(2) Yield on 10

- Year T

- Bi ll (1928

- 2012 ) 5.1 %

- - - - - - (3 ) Market Risk Premium (1928

- 2012 ) 6.1 %

- - - - - - Cost of Equity (2)+[(1)*(3)] 14.1%

- - - - - - Equity/Total Capital 67.9 % 91.5 % 79.8 % 65.0 % 85.4 % 95.5 % 1.1 %

Bond ratings are a tool to measure default risk and arrive at a cost of debt. Each bond rating is associated with a particular spread. One way of estimating a company’s cost of debt is to treat it as a spread (usually expressed in basis points) over the risk

- free rate. DOE used this

method to calculate the cost of debt for all six manufacturers by using S&P ratings and adding

the relevan t spread to the risk

- free rate.

In practice, investors use a variety of different maturity Treasury bo nds to estimate the

risk -free rate. DOE used the 10- year Treasury bond return because it captures long

- term inflation expectations and is less volatile than short- term rates. The risk free rate is estimated to be approximately 5.1 percent, which is the ave rage 10

- year Treasury b ond return between 1928 and

2012.

For the cost of debt, S&P’s Credit Services provided the average spread of corporate

bonds for the six public manufacturers. DOE added the industry- weighted average spread to the average T

- Bill rate . Since proceeds from debt issuance are tax deductible, DOE adjusted the gross cost of debt by the industry average tax rate to determine the net cost of debt for the industry. Table 12.4.4 presents the derivation of the cost of debt and the capital structure of the industry ( i.e., the debt ratio (debt/total capital)).

Table 12.4.4 Cost of Debt Calculation

Parameter Industry

Weighted Average

% Manufacturer

A B C D E F

S&P Bond Rating

- AA A- A+ A A+ BB+

(1) Yield on 10

- Year T

- Bill (1928

- 201 2) 5.1 %

- - - - - -

(2) Gross Cost of Debt 6.4 % 5.8 % 6.2 % 6.0 % 6.1 % 6.0 % 8.1 %

(3) Tax Rate 26.1 % 13.8% 35.3% 27.6% 39.6% 31.3% 18.7%

Net Cost of Debt (2) x (1

- (3)) 4.7 % 5.0 % 4.0 % 4.3 % 3.7 % 4.1 % 6.6 %

Debt/Total Capital 32.1 % 8.5 % 20.2 % 35.0 % 14.6 % 4.5 % 98.9 %

12-11Using public information for these six companies, the initial estimate for the HID lamp industry’s WACC was approximately 11.1 percent. Subtracting an inflation rate of 3 .1 percent

between 1928 and 2012 , the inflation -adjusted WACC and the initial estimate of the discount

rate used in the straw- man GRIM was 8.0 percent. When DOE asked for feedback on the 8.0 percent discount during manufacturer interviews , most manufacturers agreed this value was appropriate to use as an industry discount rate for HID lamps.

12.4.5 NIA Shipment Forecast

The GRIM estimates manufacturer revenues based on t otal unit

- shipment forecasts and the distribution of these values by effic acy level. Changes in the effic acy mix for each equipment

class at each EL are a key driver of manufacturer finances. For this analysis, the GRIM used the NIA’s annual shipment forec asts from 201 4 to 2046, the end of the analysis period. DOE developed shipment projections based on an analysis of key market drivers for each considered HID lamp type. In DOE’s shipments model, shipments of equipment are driven by new construction, stock replacements, and other types of purchases. The shipments model takes an accounting approach, tracking market shares of each equipment class and the vintage of units in the existing stock. The assumptions and methodology that drive this analysis are descri bed in chapter 10 of th is NOP D TSD.

12.4.6 Production Costs

Typically during the engineering analysis, DOE develops the MPCs for the representative

units at each EL analyzed either by teardowns or by software modeling. However, because HID lamps are difficult to reverse -engineer, DOE derived end- user prices as part of the equipment price determination for the lamps covered in this NOPD . DOE observed a range of end- user prices paid for HID lamps depending on the distribution channel through which the lamps are purchased. DOE then developed three sets of discounts from the manufacturer blue-book prices representing low (state procurement), medium (electrical distributors), and high (Inter net retailers) lamp prices for HID lamps. DOE then decided to use the low (state procurement) end use lamp prices to estimate MSPs. In manufacturer interviews, HID lamp manufacturers indicated that distribution channel markups range from 10 to 50 percent, and are typically around 15 to 30 percent. DOE determined that using a distribution chain markup of 1.15 would be most representative of the high-volume, lower price equipment covered by this NOPD . DOE divided

the low end- user price for all HID lamps by th is value to arrive at MSPs for all HID lamps. DOE

also examined the SEC 10- Ks of all publicly traded HID lamp manufacturers to estimate the average HID lamp manufacturer markup. The manufacturer markup represents the markup lamp manufacturers apply to thei r MPCs to arrive at the MSPs. Based on SEC 10 -Ks, DOE found the typical manufacturer markup for HID lamp manufacturers on a corporate level was 1.53. During manufacturer interviews, DOE asked manufacturers if 1.53 was an appropriate markup to use for

HID l amps. Based on manufacturer feedback that the 1.53 manufacturer markup was too high for HID lamps and should be lowered, DOE revised the manufacturer markup for HID lamps to be 1.52. DOE divided the estimates calculated for MSPs by the 1.52 manufacturer markup to

estimate manufacturers’ MPCs.

Table 12.4.5 through Table 12.4.12 show the average production cost estimates used in the GRIM for each representative lamp type at each efficacy level

.

12-12Table 12.4.5 Manufacturer Production Cost Breakdown (201 2$ ) for the 100 W Mercury Vapor Representative Lamp Type

EL Materials Labor Depr. Overhead MPC Markup MSP

Baseline_MV_100W $5.15 $1.73 $0.68 $2.67 $10.23 1.52 $15.55

EL1_MH Quartz 1_70WPulse $5.71 $1.92 $0.76 $2.96 $11.36 1.52 $17.27

EL1_MH Quartz 1_100WPulse $5.78 $1.95 $0.77 $3.00 $11.49 1.52 $17.46

EL2_MH Quartz 2_70WPulse $6.51 $2.19 $0.87 $3.38 $12.95 1.52 $19.69

EL2_MH Quartz 2_100WPulse $7.17 $2.41 $0.95 $3.72 $14.25 1.52 $21.66

EL3_CMH_50W $6.14 $2.07 $0.82 $3.18 $12.20 1.52 $18.54

EL3_CMH_70W $10.06 $3.39 $1.34 $5.22 $20.01 1.52 $30.41

EL3_CMH_100W $8.40 $2.83 $1.12 $4.36 $16.71 1.52 $25.39

Table 12.4.6 Manufacturer Production Cost Breakdown (2012$) for the 175 W Mercury Vapor Representative Lamp Type

EL Materials Labor Depr. Overhead MPC Markup MSP

Baseline_MV_175W $2.51 $0.85 $0.33 $1.30 $5.00 1.52 $7.59

EL1_MH Quartz 1_150WProbe $6.28 $2.11 $0.83 $3.26 $12.48 1.52 $18.97

EL1_MH Quartz 1_150WPulse $5.32 $1.79 $0.71 $2.76 $10.57 1.52 $16.07

EL1_MH Quartz 1_175WPulse $8.45 $2.85 $1.12 $4.38 $16.81 1.52 $25.54

EL2_MH Quartz 2_100WPulse $7.17 $2.41 $0.95 $3.72 $14.25 1.52 $21.66

EL2_MH Quartz 2_150WProbe $7.07 $2.38 $0.94 $3.67 $14.06 1.52 $21.37

EL2_MH Quartz 2_150WPulse $5.82 $1.96 $0.77 $3.02 $11.56 1.52 $17.58

EL2_MH Quartz 2_175WPulse $11.23 $3.78 $1.49 $5.83 $22.34 1.52 $33.95

EL3_CMH_70W $10.06 $3.39 $1.34 $5.22 $20.01 1.52 $30.41

EL3_CMH_100W $8.40 $2.83 $1.12 $4.36 $16.71 1.52 $25.39

EL3_CMH_150W $8.96 $3.02 $1.19 $4.65 $17.82 1.52 $27.09

12-13Table 12.4.7 Manufacturer Production Cost Breakdown (2012$) for the 250 W Mercury Vapor Representative Lamp Type

EL Materials Labor Depr. Overhead MPC Markup MSP

Baseline_MV_250W $3.17 $1.07 $0.42 $1.64 $6.30 1.52 $9.58

EL1_MH Quartz 1_175WProbe $4.35 $1.47 $0.58 $2.26 $8.66 1.52 $13.16

EL1_MH Quartz 1_175WPulse $4.89 $1.65 $0.65 $2.54 $9.72 1.52 $14.77

EL1_MH Quartz 1_250WPulse $5.97 $2.01 $0.79 $3.09 $11.86 1.52 $18.03

EL2_MH Quartz 2_150WProbe $7.07 $2.38 $0.94 $3.67 $14.06 1.52 $21.37

EL2_MH Quartz 2_150WPulse $6.77 $2.28 $0.90 $3.51 $13.45 1.52 $20.45

EL2_MH Quartz 2_175WProbe $9.62 $3.24 $1.28 $4.99 $19.12 1.52 $29.07

EL2_MH Quartz 2_175WPulse $11.38 $3.83 $1.51 $5.90 $22.63 1.52 $34.40

EL2_MH Quartz 2_250WPulse $6.33 $2.13 $0.84 $3.28 $12.58 1.52 $19.13

EL3_CMH_100W $8.40 $2.83 $1.12 $4.36 $16.71 1.52 $25.39

EL3_CMH_150W $8.96 $3.02 $1.19 $4.65 $17.82 1.52 $27.09

EL3_CMH_250W $11.30 $3.80 $1.50 $5.86 $22.46 1.52 $34.14

Table 12.4.8 Manufacturer Production Cost Breakdown (2012$) for the 400 W Mercury Vapor Representative Lamp Type

EL Materials Labor Depr. Overhead MPC Markup MSP

Baseline_MV_400W $4.29 $1.44 $0.57 $2.22 $8.53 1.52 $12.96

EL1_MH Quartz 1_250WProbe $6.29 $2.12 $0.84 $3.26 $12.51 1.52 $19.01

EL1_MH Quartz 1_250WPulse $5.97 $2.01 $0.79 $3.09 $11.86 1.52 $18.03

EL1_MH Quartz 1_325WProbe $5.17 $1.74 $0.69 $2.68 $10.28 1.52 $15.63

EL1_MH Quartz 1_400WPulse $8.81 $2.97 $1.17 $4.57 $17.52 1.52 $26.63

EL2_MH Quartz 2_200WPulse $6.81 $2.29 $0.91 $3.53 $13.53 1.52 $20.57

EL2_MH Quartz 2_250WPulse $6.33 $2.13 $0.84 $3.28 $12.58 1.52 $19.13

EL2_MH Quartz 2_400WPulse $10.26 $3.46 $1.37 $5.32 $20.41 1.52 $31.02

EL3_CMH_150W $16.32 $5.50 $2.17 $8.47 $32.45 1.52 $49.33

EL3_CMH_250W $11.30 $3.80 $1.50 $5.86 $22.46 1.52 $34.14

Table 12.4.9 Manufacturer Production Cost Breakdown (2012$) for the 400 W Metal Halide Representative Lamp Type

EL Materials Labor Depr. Overhead MPC Markup MSP

EL1_MH Quartz 1_400WProbe $7.00 $2.36 $0.93 $3.63 $13.91 1.52 $21.15

EL1_MH Quartz 1_400WPulse $8.81 $2.97 $1.17 $4.57 $17.52 1.52 $26.63

EL2_MH Quartz 2_320WPulse $9.25 $3.12 $1.23 $4.80 $18.40 1.52 $27.97

EL2_MH Quartz 2_360WProbe $8.33 $2.81 $1.11 $4.32 $16.57 1.52 $25.19

EL2_MH Quartz 2_400WProbe $7.74 $2.61 $1.03 $4.01 $15.38 1.52 $23.39

EL2_MH Quartz 2_400WPulse $10.26 $3.46 $1.37 $5.32 $20.41 1.52 $31.02

EL3_CMH_250W $11.30 $3.80 $1.50 $5.86 $22.46 1.52 $34.14

12-14Table 12.4.10 Manufacturer Production Cost Breakdown (2012$) for the 1000 W Mercury Vapor Representative Lamp Type

EL Materials Labor Depr. Overhead MPC Markup MSP

Baseline_MV_1000W $10.58 $3.56 $1.41 $5.49 $21.03 1.52 $31.96

EL1_MH Quartz 1_750WPulse $16.85 $5.67 $2.24 $8.74 $33.50 1.52 $50.91

EL1_MH Quartz 1_1000WProbe $12.50 $4.21 $1.66 $6.48 $24.85 1.52 $37.77

EL2_MH Quartz 2_575WPulse $12.14 $4.09 $1.61 $6.30 $24.14 1.52 $36.70

EL2_MH Quartz 2_750WPulse $22.15 $7.46 $2.95 $11.49 $44.04 1.52 $66.93

EL2_MH Quartz 2_1000WPulse $15.93 $5.37 $2.12 $8.27 $31.68 1.52 $48.16

Table 12.4.11 Manufacturer Production Cost Breakdown (2012$) for the 1000 W Metal Halide Representative Lamp Type

EL Materials Labor Depr. Overhead MPC Markup MSP

EL1_MH Quartz 1_1000WProbe $12.50 $4.21 $1.66 $6.48 $24.85 1.52 $37.77

EL1_MH Quartz 1_1000WPulse $14.45 $4.87 $1.92 $7.50 $28.74 1.52 $43.68

EL2_MH Quartz 2_875WPulse $14.24 $4.79 $1.89 $7.38 $28.31 1.52 $43.03

EL2_MH Quartz 2_1000WProbe $16.50 $5.56 $2.19 $8.56 $32.81 1.52 $49.88

EL2_MH Quartz 2_1000WPulse $15.93 $5.37 $2.12 $8.27 $31.68 1.52 $48.16

Table 12.4.12 Manufacturer Production Cost Breakdown (2012$) for the 2000 W Metal Halide Representative Lamp Type

EL Materials Labor Depr. Overhead MPC Markup MSP

Baseline_MH Quartz 1_2000WPulse $20.69 $6.97 $2.75 $10.73 $41.15 1.52 $62.54

EL1_MH Quartz 2_1500WProbe $15.70 $5.29 $2.09 $8.15 $31.22 1.52 $47.46

EL1_MH Quartz 2_2000WPulse $19.89 $6.70 $2.65 $10.32 $39.56 1.52 $60.13

12.4.7 Product and Capital Conversion Costs

DOE expects potential energy conservation standards to cause manufacturers to incur one-time conversion costs to bring their production facilities and product designs into compliance with these potential standards. For the MIA, DOE classified these one

- tim e conversion costs into two major groups: (1) product conversion costs and (2) capital conversion costs. Product conversion costs are one-time investments in research, development, testing, marketing, and other non- capitalized costs necessary to make produ ct designs comply with potential standards. Capital conversion costs are one- time investments in PPE necessary to adapt or change existing production facilities such that new equipment designs can be fabricated and

assembled.

DOE calculated the product an d capital conversion costs using both a top-down approach and a bottom-up approach based on feedback from manufacturers during manufacturer interviews and manufacturer submitted comments. DOE then adjusted these conversion costs if there were any discrepan cies in the final costs using the two methods to arrive at a final product and capital conversion cost estimate for each equipment class at each EL.

12-15During manufacturer interviews, DOE asked manufacturers for their estimated total product and capital conv ersion costs needed to produce HID lamp s at specific ELs. To arrive at top-down industry wide product and capital conversion cost estimates for each equipment class at each EL, DOE calculated a market share weighted average value for product and capital conversion costs based on the data submitted during interviews and the market share of the

interviewed manufacturers.

To conduct the bottom-up analysis, DOE used manufacturer input from manufacturer interviews regarding the types and dollar amounts of discrete capital and product expenditures that would be necessary at each EL to upgrade specific HID lamp production lines

. Manufacturers identified batch ovens, ceramic furnaces, powder mixing equipment, sintering equipment, and injection molding equipment as the primary capital costs that would be necessary to meet higher efficacy levels for HID lamps. Manufacturers identif ied engineering hours necessary to redesign lamps and the testing and certification costs necessary to comply with higher efficacy standards as the primary product conversion costs they would incur as a result of potential standards. Once DOE compiled these capital and product conversion costs, DOE took average values ( i.e., average number of hours or average dollar amounts) based on the ranges of responses given by manufacturers for each capital and product conversion cost at each EL. The bottom-up convers ion costs estimates DOE created were consistent with the manufacturer top

down estimates provided, so DOE used the bottom- up conversion cost estimates as the final

values for each equipment class in the MIA.

DOE’s estimates of the product and capital conversion costs for each equipment class can be found in Table 12.4.13 through Table 12.4.15 below.

Table 12.4.13 Product and Capital Conversion Costs for the 50 W – 400 W b Equipment

Class HID Lamp s by EL

EL Product Conversion Costs

2012$ millions Capital Conversion Costs

2012$ millions Total Conversion Costs

2012$ million

EL 1 7.4 0.0 7.4

EL 2 31.4 6.0 37.4

EL 3 55.0 54.5 109.5

Table 12.4.14 Product and Capital Conversion Costs for the 401 W – 1000 W Equipment

Class HID Lamp s by EL

EL Product Conversion Costs

2012$ millions Capital Conversion Costs

2012$ millions Total Conversion Costs

2012$ million

EL 1 0.5 0.0 0.5

EL 2 4.9 0.8 5.7

b The wattage ranges of the equipment classes are ≥50 and ≤400 W, >400 W and ≤1000 W, and >1000 W and ≤2000 W, but for the sake of simplicity are referred to in this NOP D TSD as 50 W

– 400 W, 401 W

– 1000 W, and 1001 W

– 2000 W, respectively.

12-16Table 12.4.15 Product and Capital Conversion Costs for the 1001 W – 2000 W Equipment Class HID Lamps by EL

EL Product Conversion Costs

2012$ millions Capital Conversion Costs

2012$ millions Total Conversion Costs

2012$ million

E L 1 0.6 0.4 0.9

12.4.8 Markup Scenarios

DOE used two standards case markup scenarios to represent the uncertainty about the impacts of potential energy conservation standards on prices and profitability. In the base case, DOE used the same baseline manufacturer markups calculated in the engineer ing analysis for all representative units. In the standards case, DOE modeled two markup scenarios to represent the uncertainty about the potential impacts on prices and profitability following the implementation

of potential energy conservation standards: (1) flat markup scenario and ( 2 ) a preservation of operating profit markup scenario. These scenarios lead to different markup values, which, when applied to the inputted MPCs, result in varying revenue and cash- flow impacts.

12.4.8.1 Flat Markup Scenario

Under the flat , or preservation of gross margin, markup scenario, DOE applied a single uniform markup across all effic acy levels. As MPCs increase with effic acy , this scenario implies that the absolute dollar markup will increase as well. Based on publicly available financial

information for manufacturers of HID lamp s and comments from manufacturer interviews, DOE assumed the non-production cost markup—which incl udes SG&A expenses; R&D expenses; interest; and profit —to be 1. 52 for all representative lamp s . Because this markup scenario assumes that manufacturers would be able to maintain their gross margin percentage as production costs increase in response to pote ntial energy conservation standards , it represents a n

upper bound to industry profitability under these potential standard s.

12.4.8.2 Preservation of Operating Profit Markup Scenario

DOE implemented the preservation of operating profit markup scenario because

manu facturers stated that they do not expect to be able to markup the full cost of production given the highly competitive market, in the standards case. The preservation of operating profit markup scenario assumes that manufacturers are able to maintain only the base case total operating profit in absolute dollars in the standards case, despite higher production costs and investment. The base case total operating profit is derived from marking up the cost of goods

sold (COGS) for each equipment by a flat percentage (the flat markup, discussed above) to cover standard SG&A expenses, R&D expenses, interest, and profit. DOE adjusted the manufacturer markups in the GRIM for each equipment class at each E L to yield approximately the same earnings before interest and taxes in the standards case in the year after the compliance date of

the potential standards as in the base case. DOE altered the markups only for the minimally compliant equipment in this scenario, with margin impacts not occurring for equipment that

alr eady exceed the potential standard s. The preservation of operating profit markup scenario

represents the lower bound markup scenario of industry profitability following potential standards. Under this scenario, while manufacturers are not able to earn additional operating

12-17profit on higher production costs and the investments required to comply with the potential

standard s, like they are in the flat markup scenario, they are able to maintain the same operating profit in the standards case as was earned in the base case.

Table 12.4.16 Preservation of Operating Profit Markups for the 100 W Mercury Vapor Representative Lamp Type

EL Markups by Selected EL

Baseline EL 1 EL 2 EL 3

Baseline_MV_100W 1.520

EL1_MH Quartz 1_70WPulse 1.520 1.520

EL1_MH Quartz 1_100WPulse 1.520 1.520

EL2_MH Quartz 2_70WPulse 1.520 1.520 1.49 94

EL2_MH Quartz 2_100WPulse 1.520 1.520 1.49 94

EL3_CMH_50W 1.520 1.520 1.520 1.4 60

EL3_CMH_70W 1.520 1.520 1.520 1.4 60

EL3_CMH_100W 1.520 1.520 1.520 1.4 60

Table 12.4.17 Preservation of Operating Profit Markups for the 1 75 W Mercury Vapor Representative Lamp Type

EL Markups by Selected EL

Baseline EL 1 EL 2 EL 3

Baseline_MV_175W 1.520

EL1_MH Quartz 1_150WProbe 1.520 1.512

EL1_MH Quartz 1_150WPulse 1.520 1.512

EL1_MH Quartz 1_175WPulse 1.520 1.512

EL2_MH Quartz 2_100WPulse 1.520 1.520 1.50 6

EL2_MH Quartz 2_150WProbe 1.520 1.520 1.50 6

EL2_MH Quartz 2_150WPulse 1.520 1.520 1.50 6

EL2_MH Quartz 2_175WPulse 1.520 1.520 1.50 6

EL3_CMH_70W 1.520 1.520 1.520 1.47 1

EL3_CMH_100W 1.520 1.520 1.520 1.47 1

EL3_CMH_150W 1.520 1.520 1.520 1.47 1

12-18Table 12.4.18 Preservation of Operating Profit Markups for the 250 W Mercury Vapor Representative Lamp Type

EL Markups by Selected EL

Baseline EL 1 EL 2 EL 3

Baseline_MV_250W 1.520

EL1_MH Quartz 1_175WProbe 1.520 1.51 8

EL1_MH Quartz 1_175WPulse 1.520 1.51 8

EL1_MH Quartz 1_250WPulse 1.520 1.51 8

EL2_MH Quartz 2_150WProbe 1.520 1.520 1.42 0

EL2_MH Quartz 2_150WPulse 1.520 1.520 1.42 0

EL2_MH Quartz 2_175WProbe 1.520 1.520 1.42 0

EL2_MH Quartz 2_175WPulse 1.520 1.520 1.42 0

EL2_MH Quartz 2_250WPulse 1.520 1.520 1.42 0

EL3_CMH_100W 1.520 1.520 1.520 1.4 48

EL3_CMH_150W 1.520 1.520 1.520 1.4 48

EL3_CMH_250W 1.520 1.520 1.520 1.4 48

Table 12.4.19 Preservation of Operating Profit Markups for the 400 W Mercury Vapor Representative Lamp Type

EL Markups by Selected EL

Baseline EL 1 EL 2 EL 3

Baseline_MV_400W 1.520

EL1_MH Quartz 1_250WProbe 1.520 1.518

EL1_MH Quartz 1_250WPulse 1.520 1.518

EL1_MH Quartz 1_325WProbe 1.520 1.518

EL1_MH Quartz 1_400WPulse 1.520 1.518

EL2_MH Quartz 2_200WPulse 1.520 1.520 1. 489

EL2_MH Quartz 2_250WPulse 1.520 1.520 1. 489

EL2_MH Quartz 2_400WPulse 1.520 1.520 1. 489

EL3_CMH_150W 1.520 1.520 1.520 1.44 0

EL3_CMH_250W 1.520 1.520 1.520 1.44 0

12-19Table 12.4.20 Preservation of Operating Profit Markups for the 400 W Metal Halide Representative Lamp Type

EL Markups by Selected EL

Baseline EL 1 EL 2 EL 3

EL1_MH Quartz 1_400WProbe 1.520 1.520

EL1_MH Quartz 1_400WPulse 1.520 1.520

EL2_MH Quartz 2_320WPulse 1.520 1.520 1.49 0

EL2_MH Quartz 2_360WProbe 1.520 1.520 1.49 0

EL2_MH Quartz 2_400WProbe 1.520 1.520 1.49 0

EL2_MH Quartz 2_400WPulse 1.520 1.520 1.49 0

EL3_CMH_250W 1.520 1.520 1.520 1.473

Table 12.4.21 Preservation of Operating Profit Markups for the 1000 W Mercury Vapor Representative Lamp Type

EL Markups by Selected EL

Baseline EL 1 EL 2

Baseline_MV_1000W 1.520

EL1_MH Quartz 1_750WPulse 1.520 1.51 8

EL1_MH Quartz 1_1000WProbe 1.520 1.51 8

EL2_MH Quartz 2_575WPulse 1.520 1.520 1.47 4

EL2_MH Quartz 2_750WPulse 1.520 1.520 1.47 4

EL2_MH Quartz 2_1000WPulse 1.520 1.520 1.47 4

Table 12.4.22 Preservation of Operating Profit Markups for the 1000 W Metal Halide Representative Lamp Type

EL Markups by Selected EL

Baseline EL 1 EL 2

EL1_MH Quartz 1_1000WProbe 1.520 1.520

EL1_MH Quartz 1_1000WPulse 1.520 1.520

EL2_MH Quartz 2_875WPulse 1.520 1.520 1.48 8

EL2_MH Quartz 2_1000WProbe 1.520 1.520 1.48 8

EL2_MH Quartz 2_1000WPulse 1.520 1.520 1.48 8

12-20Table 12.4.23 Preservation of Operating Profit Markups for the 2000 W Metal Halide Representative Lamp Type

EL Markups by Selected EL

Baseline EL 1

Baseline_MH Quartz 1_2000WPulse 1.520

EL1_MH Quartz 2_1500WProbe 1.520 1.52 4

EL1_MH Quartz 2_2000WPulse 1.520 1.52 4

12.5 INDUSTRY FINANCIAL IMPACTS

Using the inputs and scenarios described in the previous sections, the GRIM estimated indicators of financial impacts on the HID lamp industry. The following sections detail additional inputs and assumptions for HID lamp s. The main results of the MIA are also reported in this section. The MIA consists of two key financial metrics: INPV and annual cash flows.

12.5.1 Impacts on Industry Net Present Value

The INPV measures the industry value and is used in the MIA to compare the economic impacts of different E Ls for each equipment class in the standards case. The INPV is different from DOE’s net present value, which is applied to the U.S. economy. The INPV is the sum of all net cash flows discounted at the industry’s cost of capital, or di scount rate. The HID lamps

GRIM estimates cash flows from 201 4 to 2046. This timeframe models both the short- term impacts on the industry from the announcement of the potential standard s until the compliance date (2014 until an estimated compliance date of 2017) and a long- term assessment over the 30

- year analysis period used in the NIA (2017 – 2046 ).

In the MIA, DOE compares the INPV of the base case (no new energy conservation standards) to that of each EL in the standards case. The difference between the base case and a standards case INPV is an estimate of the economic impacts that implementing that particular EL for a given equipment class would have on the industry. For the HID lamp industry, DOE

examined the two m arkup scenarios described above, the flat markup scenario ( preservation of gross margin per centage ) and the preservation of operating profit markup scenario. Table 12.5.1

and Table 12.5.2 provide the INPV estimates for the two markup scenarios for the 50 W - 400 W equipment class HID lamp s; Table 12.5.3 and Table 12.5.4 provide the INPV estimates for the two markup scenarios for the 401 W – 1000 W equipment class HID lamp s; and Table 12.5.5

and Table 12.5.6 provide the INPV estimates for the two markup scenarios for the 1001 W – 2000 W equipment class HID lamp s.

12-2112.5.1.1 50 W – 400 W Equipment Class INPV Results

Table 12.5.1 Changes in Industry Net Present Value for the 50 W – 400 W Equip ment

Class

– Flat Markup Scenario

Units Base Case EL 1 EL 2 EL 3

INPV (2012$ millions) 351.0 346.6 327.8 335.9

Change in INPV (2012$ millions)

- (4.5) (23.3) (15.2)

(%)

- - 1.3%

- 6.6%

- 4.3%

Table 12.5.2 Changes in Industry Net Present Value for the 50 W – 400 W Equipment

Class

– Preservation of Operating Profit Markup Scenario

Units Base Case EL 1 EL 2 EL 3

INPV (2012$ millions) 351.0 345.9 300.2 268.9

Change in INPV (2012$ millions)

- (5.1) (50.9) (82.1)

(%)

- - 1.5%

- 14.5%

- 23.4%

12.5.1.2 401 W – 1000 W Equipment Class INPV Results

Table 12.5.3 Changes in Industry Net Present Value for the 401 W – 1000 W Equipment

Class

– Flat Markup Scenario

Units Base Case EL 1 EL 2

INPV (2012$ millions) 55.3 55.0 56.1

Change in INPV (2012$ millions)

- (0.3) 0.8

(%)

- - 0.6% 1.4%

Table 12.5.4 Changes in Industry Net Present Value for the 401 W – 1000 W Equipment

Class

– Preservation of Operating Profit Markup Scenario

Units Base Case EL 1 EL 2

INPV (2012$ millions) 55.3 55.0 51.5

Change in INPV (2012$ millions)

- (0.3) (3.9)

(%)

- - 0.6%

- 7.0%

12-2212.5.1.3 1001 W – 2000 W Equipment Class INPV Results

Table 12.5.5 Changes in Industry Net Present Value for the 1001 W – 2000 W Equipment

Class

– Flat Markup Scenario

Units Base Case EL 1

INPV (2012$ millions) 4.7 4.0

Change in INPV (2012$ millions)

- (0.8)

(%)

- - 15.9%

Table 12.5.6 Changes in Industry Net Present Value for the 1001 W – 2000 W Equipment

Class

– Preservation of Operating Profit Markup Scenario

Units Base Case EL 1

INPV (2012$ millions) 4.7 4.0

Change in INPV (2012$ millions)

- (0.7)

(%)

- - 15.4%

12.5.2 Impacts on Annual Cash Flow

While INPV is useful for evaluating the long- term effects of potential energy conservation standards, short-term changes in cash flow are also important indicators of the industry’s financial situation. For example, a large investment over one or two years could strain the industry’s access to capital. Consequently, the sharp drop in financial performance could cause investors to flee, even though recovery may be possible. Thus, a short- term disturbance can have long-term effects that the INPV cannot capture. To get an idea of the behavior of annual free cash flows, Figure 12.5.1 through Figure 12.5.6 present the annual free cash flows

from all equipment class from 2014 through 202 5 for the base case and differ ent ELs in the

standards case.

Annual cash flows are discounted to the base yea r, 2014. Between 2014 and the 2017 compliance date of potential energy conservation standard s, cash flows are driven by the level of conversion costs and the proportion of these investments spent every year. After the potential standard announcement date ( i.e., the publication date of the final determination ), industry cash flows begin to decline as companies use their financial resources to prepare for the potential

standard s. The more stringent the potential standard s, the greater the impact on industry c ash flows in the years leading up to the compliance date, as product conversion costs lower cash inflows from operations and capital conversion costs increase cash outflows for capital expenditures.

Free cash flow in the year the potential energy conservation standards take effect is driven by two competing factors. In addition to capital and product conversion costs, potential

standards could create stranded assets ( i.e., tooling and equipment that would have enjoyed longer use if the poten tial standard s had not made them obsolete). In this year, manufacturers write down the remaining book value of existing tooling and equipment whose value is affected by the potential standard s. This one- time write

- down acts as a tax shield that alleviates decreases in cash flow from operations in the year of the write -down. In this year, there is also an increase

12-23in working capital that reduces cash flow from operations. A large increase in working capital is needed due to more costly production components and materials, higher inventory carrying to sell more expensive equipment, and higher accounts receivable for more expensive equipment. Depending on these two competing factors, cash flow can either be positively or negatively

affected in the year the pote ntial standard s takes effect.

In the years following the compliance date of the potential energy conservation standard s, the impact on cash flow depends on the operating revenue. In the flat markup scenario , the manufacture markup is held constant to yiel d the same gross margin percentage in the standards case for each equipment class at each E L as in the base case in the year after the potential

standard s take effect

. The implicit assumption is that manufacturers can freely pass on and mark up higher cost units. The result under this scenario is that operating cash flow increases (in

absolute terms ) as revenue increases. At the highest E Ls where MPC s dramat ically increase, this scenario drives large increases in operating cash flow relative to the base case. The larger the

MPC increase, the more likely it is that the increase in operating cash flow after the potential

standard s take affect will outweigh the initial conversion costs.

Under the preservation of ope rating profit scenario, cash flow decreases at each EL in the standards case compared to the base case because , since the absolute dollar amount of the gross margin does not change despite an increase in sales and COGS , the gross margin percentage is

reduc ed

. Figure 12.5.1 and Figure 12.5.2 present the annual free cash flow for the 50 W – 400 W equipment class; Figure 12.5.3 and Figure 12.5.4 present the annual free cash flow for the 401 W – 1000 W equipment class; and Figure 12.5.5 and Figure 12.5.6 present the annual free cash flow for the 1001 W – 2000 W equipment class.

12-24Figure 12.5.1 Annual Free Cash Flow f rom the 50 W – 400 W Equipment Class HID Lamps - Flat Markup Scenario

Figure 12.5.2 Annual Free Cash Flow fr om the 50 W – 400 W Equipment Class HID Lamps - Preservation of Operating Profit Markup Scenario Insert FCF Chart Here

$0.0 $5.0 $10.0 $15.0 $20.0 $25.0 $30.0 $35.0 $40.0 $45.0 $50.0 Net Cash Flows (2012$ MM)

Base Case EL 1 EL 2 EL 3

Insert FCF Chart Here

$0.0 $5.0 $10.0 $15.0 $20.0 $25.0 $30.0 $35.0 $40.0 $45.0 $50.0 Net Cash Flows (2012$ MM)

Base Case EL 1 EL 2 EL 3

12-25Figure 12.5.3 Annual Free Cash Flow from the 401 W – 1000 W Equipment Class HID Lamps

– Flat Markup Scenario

Figure 12.5.4 Annual Free Cash Flow from the 401 W – 1000 W Equipment Class HID Lamps

– Preservation of Operating Profit Markup Scenario $0.0 $1.0 $2.0 $3.0 $4.0 $5.0 $6.0 $7.0 $8.0 $9.0 Net Cash Flows (2012$ MM)

Base Case EL 1 EL 2

$0.0 $1.0 $2.0 $3.0 $4.0 $5.0 $6.0 $7.0 $8.0 $9.0 Net Cash Flows (2012$ MM)

Base Case EL 1 EL 2

12-26Figure 12.5.5 Annual Free Cash Flow from the 1001 W – 2000 W Equipment Class HID Lamps

– Flat Markup Scenario

Figure 12.5.6 Annual Free Cash Flow from the 1001 W – 2000 W Equipment Class HID Lamps

– Preservation of Operating Profit Markup Scenario $0.0 $0.2 $0.4 $0.6 $0.8 $1.0 $1.2 Net Cash Flows (2012$ MM)

Base Case EL 1

$0.0 $0.2 $0.4 $0.6 $0.8 $1.0 $1.2 Net Cash Flows (2012$ MM)

Base Case EL 1

12-2712.6 IMPACTS ON MANUFACTURER SUBGROUPS

As described in section 12.2.3 , DOE identified one subgroup of HID lamp manufacturers:

small business manufacturers. The results of th is small business inquiry are described in the following section.

12.6.1 Impacts on Small Business Manufacturers

12.6.1.1 Description and Estimated Number of Small Entities Regulated

DOE conducted a more focused inquiry of the companies that could be small business

manufactu rers of equipment covered by this NOPD . During its market survey, DOE used publicly available information to identify potential small business HID lamp manufacturers. DOE’s research involved industry trade association membership directories (including NEMA ), the SBA’s database, individual company websites, and market research tools ( e.g. , Hoover’s ) to create a list of every company that manufactures or sells HID lamp s covered by this NOPD

. DOE also asked stakeholders and industry representatives if they were aware of any other small manufacturers during manufacturer interviews and at previous HID lamp DOE public meetings.

DOE attempted to contact every potential small HID lamp manufacturer on its list to determine whether they met the SBA’s definition of a s mall business manufacturer of covered HID lamp s. DOE screened out companies that did not offer equipment covered by this NOPD , did not meet

SBA’s definition of a “small business,” or are completely foreign owned and operated.

DOE initially identified 61 potential manufacturers of HID lamp s sold in the United

S tates . After reviewing publicly available information on these potential HID lamp manufacturers, DOE determined that 41 were either large manufacturers, manufacturers that were completely foreign owned and operated, or did not sell HID lamp s covered by this NOPD

. DOE then contacted the remaining 20 HID lamp companies to determine whether they met SBA’s definition of a small business and whether they manufactured or sold HID lamp s that

would be affect ed by today’s proposal. Based on these efforts, DOE estimated that there are 16

small businesses that either manufacture or sell covered HID lamps in the United S tates

.

Before issuing this NOPD , DOE attempted to contact the small business manufacturers of HID lamp s it had identified to invite them to take part in a small business manufacturer impact analysis interview. Of the 16 HID lamp manufacturers DOE contacted, five responded and 11 did not respond. Four of the five responding manufacturers declined to be interviewed. DOE was able to reach and discuss potential standards with one of the 16 small business manufacturers. DOE also obtained information about small business manufacturers and potential impacts while interviewing large manufacturers.

Four major manufacturers supply approximately 80 percent of the market for HID lamp s. None of the major manufacturers of HID lamp s analyzed in this NOPD are small businesses

. DOE estimates that none of the small businesses competing with large manufacturers have a HID

market share higher than one percent

. Many of the small businesses that compete in the HID lamp s tend to be companies that outsource the manufacturing to overseas companies who produce the lamps specified by the small businesses as well as distrib utors of equipment manufactured by the five large HID lamp manufacturers. These small businesses provide the

12-28specifications for these lamps as well as the testing and certification in order to comply with any potential U.S. energy conservation standards.

However, since no standards are being proposed in this NOPD , small businesses will not be affected by this NOP D. Therefore, DOE did not conduct a complete small business subgroup impact analysis.

12.7 OTHER IMPACTS

12.7.1 Employment

DOE quantitatively assessed the impact of potential energy conservation standards on direct employment. DOE used the GRIM to estimate the domestic labor expenditures and number of domestic production workers in the base case and at each EL for the 50 W – 4 00 W equipment class, since the 50 W – 400 W equipment class represented over 90 percent of all covered HID lamp shipments in 2017. Furthermore, manufacturers stated that most domestic employment decisions would be based on the standards set for the 50 W – 400 W equipment

class. DOE used statistical data from the U.S. Census Bureau’s 2011 Annual Survey of Manufacturers (ASM), the results of the engineering analysis, and interviews with manufacturers to determine the inputs necessary to calculate industry

- wi de labor expenditures and domestic employment levels. Labor expenditures involved with the manufacturing of HID lamps are a function of the labor intensity of the equipment , the sales volume, and an assumption that wages

remain fixed in real terms over tim e.

In the GRIM, DOE used the labor content of each equipment class and the MPCs to estimate the annual labor expenditures of the industry. DOE used Census data and interviews with manufacturers to estimate the portion of the total labor expenditures attri butable to domestic

labor.

The production worker estimates in this employment section cover only workers up to the

line -supervisor level who are directly involved in fabricating and assembling HID lamp s within a lighting facility. Workers performing servi ces that are closely associated with production operations, such as material handling with a forklift, are also included as production labor. DOE’s estimates account for only production workers who manufacture the specific equipment analyzed by this NOPD . For example, a worker on a general service incandescent lamp production line would not be included with this estimate of the number of HID lamps workers.

The employment impacts shown in Table 12.7.1 represent the potential production employment that could result following potential energy conservation standards. The upper bound of the results estimates the maximum change in the number of production workers that could occur after compliance with any potential energy conservation standards assuming that manufacturers continue to produc e the same scope of covered equipment in the same production facilities. It also assumes that domestic production does not shift to lower labor- cost countries. Because there is a real risk of manufacturers evaluating sourcing decisions in response to

poten tial energy conservation standards, the lower bound of the employment results includes the estimated total number of U.S. production workers in the industry who could lose their jobs if some or all existing production were moved outside of the United S tate s . While the results

12-29present a range of employment impacts following 2017 , the sections below also include qualitative discussions of the likelihood of negative employment impacts at the various E Ls for the 50 W – 400 W equipment class . Finally, the employ ment impacts shown are independent of the indirect employment impacts from the broader U.S. economy.

Using 2011 ASM data and interviews with manufacturers, DOE estimates that approximately one third of the HID lamps sold in the United States are manufactured domestically. With this assumption, DOE estimates that in the absence of potential energy conservation standards, there would be approximately 292 domestic production workers involved in manufacturing HID lamps in 2017. The table below shows the range of the impacts of potential standards on U.S. production workers in the HID lamp industry.

Table 12.7.1 Potential Changes in the Total Number of All Domestic HID Lamp Production

Workers in 201 7

Base Case 50 W

– 400 W Equipment Class EL

1 2 3

Total Number of Domestic Production

Workers in 2017
(without changes in production locations) 292 294 317 388

Potential Changes in Domestic Production

Workers in 2017 * 2 – 0 25

– (146) 96

– (292)

*DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative numbers

At the upper end of the range, all examined E Ls show positive impacts on domestic employment levels. Producing more efficacious lamps tends to require more labor. DOE estimates that if HID lamp manufacturers chose to keep their current production in the U.S., domestic employment could increase at each E L as lamps became more efficacious. DOE, however, acknowledges that manufacturers may not keep their production domestic and also may choose to exit the market entirely.

DOE does not expect any significant changes in domestic employment at E L 1 for the 50

W

– 400 W equipment class because approximately 98 percent of 50 W – 400 W equipment

class shipments already meet the proposed efficacy levels. At E L 2 for the 50 W – 400 W equipment class , DOE acknowledges that there could be a potential loss of domestic employment due to the increased production costs of these HID lamps. Manufacturers may be unwilling to

invest in what several manufacturers pointed out is already a declining market and may choose to focus resources on developing newer technologies, such as LEDs. DOE’s lower bound approximation, estimates that up to half the domestic HID lamp manufacturing could be

reloca ted abroad. Manufacturers cautioned that any standard that required CMH technology for

the 50 W - 400 W equipment class ( i.e., EL 3) could cause large losses in domestic employment. Manufacturers generally agreed that a shift toward CMH technology would require extensive retooling engineering efforts that some, if not most, manufacturers would be unwilling to undertake. It is possible that some manufacturers would choose to exit the market entirely if CMH technology were required by potential energy conservation standards.

12-30DOE is not proposing any new energy conservation standards in this NOP D, and

therefore there will be no impacts on domestic employment as a result of this NOPD

.

12.7.2 Production Capacity

HID lamp manufacturers stated that they did not anticipate any significant capacity constraints unless all lamps in the 50 W – 400 W equipment class had to be converted to CMH technology ( i.e., EL 3) . Most manufacturers stated that they do not have the equipment to produce the volume of CMH lamps that w ould be necessary to satisfy demand. Manufacturers would have to expend significant capital resources to obtain additional equipment that is specific to CMH lamp production. Manufacturers also pointed out that thousands of man hours would be necessary to redesign specific lamps and lamp production lines at efficacy levels requiring CMH. The combination of obtaining new equipment and the massive engineering effort that manufacturers would have to undergo could cause significant downtime for manufacturers. Mo st manufacturers agreed that there would not be any significant capacity constraints at any efficacy levels that did not require CMH technology.

DOE is not proposing any new energy conservation standards in this NOP D, and therefore there will be no impact s on production capacity as a result of this NOPD

.

12.7.3 Cumulative Regulatory Burden

While any one regulation may not impose a significant burden on manufacturers, the combined effects of recent or impending regulations may have serious consequences for some

ma nufacturers, groups of manufacturers, or an entire industry. Assessing the impact of a single regulation may overlook this cumulative regulatory burden. In addition to potential energy conservation standards, other regulations can significantly affect manufacturers’ financial operations. Multiple regulations affecting the same manufacturer can strain profits and lead companies to abandon product lines or markets with lower expected future returns than competing equipment. For these reasons, DOE conducts a c umulative regulatory burden analysis as part of its rulemakings pertaining to lighting efficacy to make sure that this potential proposed standard does not create a cumulative regulatory burden that is unacceptable to the overall lighting industry. However, because DOE is not proposing standards for HID lamps in this

NOP D, HID lamp manufacturers would not experience an increase in regulatory burden. Therefore, DOE did not analyze the cumulative regulatory burden as part of this NOPD analysis.

12.8 CONCLUSION

At E L 1 for the 50 W – 400 W equipment class , DOE estimates impacts on INPV that is

derived from the sale of 50 W – 400 W covered H ID lamps to range from -$4.5 million to -$5.1 million, or a change in INPV of -1.3 percent to -1.5 percent . Additionally, indust ry free cash flow (operating cash flow minus capital expenditures) is estimated to decrease by approximately

5 percent to $ 42.7 million, compared to the base case value of $ 45.1 million in 2016, the year leading up to the potential energy conservation standards. At E L 1 for the 401 W – 1000 W equipment class, DOE estimates impacts on INPV that is derived from the sale of 401 W

– 1000 W covered HID lamps to be approximately -$0.3 million, or a change in INPV of -0.6 percent. A ddition ally, industry free cash flow is estimated to decrease by approximately 2

12-31percent to $ 7.2 million, compared to the base case value of $7.4 million in 2016. At E L 1 for the

1001 W – 2000 W equipment class , DOE estimates impacts on INPV that is derived from the sale of 1001 W – 2000 W covered HID lamps to range from -$0.8 million to -$0.7 million, or a change in INPV of -15.9 percent to -15.4 percent. Additionally, industry free cash flow is estimated to decrease by approximately 40 percent to $ 0.5 million, c ompared to the base case
value of $0.9 million in 2016.

A t E L 2 for the 50 W – 400 W equipment class , DOE estimates impacts on INPV that is derived from the sale of 50 W – 400 W covered HID lamps to range from -$23.3 million to -$50.9 million, or a change in INPV of -6.6 percent to -14.5 percent. A dditionally, industry free cash flow is estimated to decrease by approximately 30 percent to $ 32.2 million, compared
to the base case value of $ 45.1 million in 2016, the year leading up to the potential energy

conservation standards. At E L 2 for the 401 W – 1000 W equipment class , DOE estimates impacts on INPV that is derived from the sale of 401 W – 1000 W covered HID lamps to range
from $ 0.8 million to -$ 3.9 million, or a change in INPV of 1.4 percent to -7.0 percent.

A dditionally, industry free cash flow is estimated to decrease by approximately 27 percent to $5.4 million, compared to the base case value of $ 7.4 million in 2016.

At E L 3 for the 50 W – 400 W equipment class , DOE estimates impacts on INPV that is derived from the sale of 50 W – 400 W covered HID lamps to range from -$15.2 million to -$82.1 million, or a change in INPV of -4.3 percent to -23.4 percent. At E L 3 for the 50 W – 400 W equipment class , industry free cash flow is estimated to decrease by approximately 94 percent to $ 2.7 million, compared to the base case value of $45.1 million in 2016, the year leading up to the potential energy conservation standards.

12-32REFERENCES

1 Securities and Exchange Commission, Annual 10- K Reports, Various Years, Washington DC. <www.sec.gov>.

2 Standard and Poors Financial Services LLC, Company Credit Ratings, Various Companies, New York, NY. < www2.standardandpoors.com>.

3 NEMA

– NEMA Members. Last Accessed December 30, 2013

. <www.nema.org/about/members >.

4 McKinsey & Company, Inc. Valuation: Measuring and Managing the Value of Companies , 3rd Edition, Copeland, Koller, Murrin. New York: John Wiley & Sons, 2000.

12-33APPENDIX 5A. ALTERNATIVE STARTING METHOD LAMPS

TABLE OF CONTENTS

5A.1 INTRODUCTION

................................................................................... 5A -1

5A.2 METHODOLOGY

.................................................................................. 5A -1

5A.3 RESULTS

.............................................................................................. 5A -2

LIST OF TABLES

Table 5A.3.1 Alternative Starting Method Lamps for Representative Lamp Types ................ 5A-2

5A-iAPPENDIX 5A. ALTERNATIVE STARTING METHOD LAMPS

5A.1 INTRODUCTION

In the engineering analysis (found in chapter 5 of this notice of proposed determination [ NOPD ] technical support document [TSD]), DOE chose a single metal halide (MH) lamp as the representative lamp for certain efficacy levels (ELs). However, choosing one MH lamp means that only one of the two possible starting methods ( i.e. , probe- start and pulse

- start) was modeled in the engineering analysis. Because in most cases there are customers who would have lam ps with the star ting method that was not chosen for the representative unit in the engineering analysis, the U.S. Department of Energy (DOE) determined it was important to identify lamps

with the alternative starting methods when they were available. This appendix presents the methodology and results of identifying these alternative starting method lamps.

5A.2 METHODOLOGY

In the engineering analysis (chapter 5 of this NOPD TSD)

, a set of representative lamps

was identified to model the range of efficacies avai lable at certain wattages and light outputs . As previously mentioned, the engineering analysis only selected one MH lamp to represent EL1 and one MH lamp to represent EL2 . EL1 and EL2 are both represented by quartz MH lamps, which means probe-start and pul se -start technologies are both common for a number of wattages. Thus

in order to more accurately reflect the potential effect of efficacy standards, DOE sought to account for customers with lamps at EL1 and EL2 that had the alternative starting method

relative to the selected representative lamps. a

As detailed in the market and technology assessment (chapter 3 of this NOPD TSD),

DOE tentatively determined that there is not a n inherent difference in initial efficacy between probe-start and pulse- start lamps. Thus when analyzing the alternative starting method lamps

, DOE assumed that the lamp performance characteristics are identical to those of the representative lamp. Instead, DOE iden tifies these lamps to accurately reflect the notion that the economic impact on customers may differ depending on the starting method of the currently installed system. The prices determined for these alternative starting method lamps , along with the prices for the representative units, can be found in chapter 6 of this NOPD TSD.

When selecting these alternative starting method lamps, DOE first identified whether or not a lamp with that particular wattage and starting method was commercially available at each

EL

. Lamps with an alternative starting method were not available at EL1 and EL2 for every wattage ( e.g. , there are no commercially available probe

- start lamps at 70 watts [ W] ). In these

instances , DOE did not model the alternative starting method and those situations are noted with

“ N/A ” in both Table 5A.3 .1 and in the lamp price tables in chapter 6 of this NOPD TSD.

a The alternative starting method lamps did not need to be considered for EL3 because all EL3 lamps are ceramic metal halide lamps that are exclusively pulse

- start lamps.

5A-15A.3 RESULTS

Table 5A.3.1 shows lamps for which an alternative starting method was found. As mentioned previously, the alternative starting method lamps are assumed to have identical performance characteristics as the representative units. See chapter 6 of this NOPD TSD for the prices for all representative units and alternative starting method lamps.

Table 5A.3.1 Alternative Starting Method Lamps for Representative Lamp Type s

Effic a cy Level Representative Unit
Alternative Starting Method Lamp Reduced or Equal Wattage

Unit * Wattage Lamp Type

MH Baseline/EL 1 Reduced 70 W Pulse

- start MH N/A

EL 2 Equal 70 W Pulse

- start MH N/A

MH Baseline/EL 1 Equal 100 W Pulse

- start MH N/A

EL 2 Reduced /Equal 100 W Pulse

- start MH N/A

MH Baseline/EL 1 Reduced 150 W Pulse

- start MH 150 W Probe

- start MH

EL 2 Reduced /Equal 150 W Probe

- start MH 150 W Pulse

- start MH

MH Baseline/EL 1 Reduced /Equal 175 W Probe

- start MH 175 W Pulse

- start MH

EL 2 Equal 175 W Probe

- start MH 175 W Pulse

- start MH

EL 2 Reduced 200 W Pulse

- start MH N/A

MH Baseline/EL 1 Reduced /Equal 250 W Pulse

- start MH 250 W Probe

- start MH

EL 2 Equal 250 W Pulse

- start MH 250 W Probe

- start MH

EL 2 Reduced 320 W Pulse

- start MH N/A

MH Baseline/EL 1 Reduced /Equal 400 W Probe

- start MH 400 W Pulse

- start MH

EL 2 Equal 400 W Probe

- start MH 400 W Pulse

- start MH

EL 2 Reduced 575 W Pulse

- start MH N/A

MH Baseline/EL 1 Reduced 750 W Pulse

- start MH N/A

EL 2 Equal 750 W Pulse

- start MH N/A

EL 2 Reduced 875 W Pulse

- start MH N/A

MH Baseline/EL 1 Reduced /Equal 1000 W Pulse

- start MH N/A

EL 2 Equal 1000 W Probe

- start MH 1000 W Pulse

- start MH

EL 1 Reduced 1500 W Probe

- start MH N/A

Baseline Reduced 2000 W Pulse

- start MH N/A

EL 1 Equal 2000 W Pulse

- start MH N/A

*Units marked as “Reduced/Equal” indicate a combination of wattage and EL was used both as a reduced wattage replacement and equal wattage replacement for different lamps. The alternative starting method lamps found are applicable to these lamps in both the reduced wattage and equal wattage replacement scenarios.

5A-2APPENDIX 5B. H ID REPLACEMENT PATHWAYS

TABLE OF CONTENTS

5B.1 INTRODUCTION

........................................................................................ 5B -1

5B.2 METHODOLOGY

....................................................................................... 5B -1

5B.2.1 Lamps Included in Analysis .........................................................................5B-2

5B.2.2 Lamp and Ballast Replacement Rules .........................................................5B-2

5B.2.2.1 Rules Applicable to All Six Replacement Options ................................5B-2

5B.2.2.2 Rules Applicable to Lamp-and- Ballast Retrofit & Full Fixture Replacement Purchase Options ..............................................................5B-3

5B.2.2.3 Non

- Feasible Lamp Replacement Pathways .........................................5B-3

5B.2.3 Ballast Efficiency Rules ...............................................................................5B-4

5B.2.4 Existing Fixtures ..........................................................................................5B-6

5B-iAPPENDIX 5B. HID REPLACEMENT PATHWAYS

5B.1 INTRODUCTION

This appendix presents the methodology the U.S. Department of Energy (DOE) followedin modeling the replacement pathways customers would follow in response to potential highintensity discha rge (HID) lamp standards. DOE researched the likely options a customer would have when presented with energy conservation standards, assuming customers would retain the HID technology analyzed in this notice of proposed determination (NOPD). Based on

manuf acturer feedback and market analysis, DOE found that customers had the choice of remaining at their existing wattage or reducing wattage, as well as the choice of replacing the entire fixture, retrofitting the existing fixture with a new lamp -and- ballast s ystem, or replacing just the lamp. This combination of choices results in the following six total replacement pathways:

• Reduced wattage fixture replacement;

• Reduced wattage lamp -and- ballast replacement;

• Reduced wattage lamp replacement;

• Equal wattage fixt ure replacement;

• Equal wattage lamp -and- ballast replacement; and

• Equal wattage lamp replacement.

At each of the pathways, DOE identified which lamp, ballast, and fixture would be used in order to accurately model the cost and energy use of each pathway. T his appendix details the rules that

DOE followed to select which system components from the engineering (chapter 5 of this NOPD technical support document [ TSD ]) would be used for each replacement pathway.

5B.2 METHODOLOGY

When selecting which lamp, ballast, and fixture to use for each replacement pathway, DOE considered factors such as commercial availability, technological feasibility, and likely response of a customer based on energy use, cost , and convenience. In considering these factors,

the result of th ese decisions is the mapping of technically viable options that customers have in response to standards. While all the options identified are technically viable, a number of the options are unlikely to be chosen by customers for reasons such as cost or convenience. Certain technically viable options may even be so unlikely that DOE does not expect any customers to adopt them. While the engineering analysis (chapter 5 of this NOPD TSD) and this appendix identify the options that are technically viable, the s hipments analysis (chapter 10 of this NOPD TSD) weights the percentage of customers who choose each option.

5B-15B.2.1 Lamp s Included in Analysis

For each replacement pathway, DOE selected from the group of reduced and equal wattage lamps presented in chapter 5 and appendix 5A of this NOPD TSD. For lamp replacement criteria, DOE used the following rules.

• Reduced wattage lamp replacements

o As discuss ed in further detail in chapter 5 of this NOPD TSD, the reduced wattage lamp replacements for baseline lamps are selected to have mean lumens within ten percent of the baseline.

o When available, DOE identified both probe- start and pulse

- start metal halide ( MH ) lamps at efficacy level ( EL ) 1 and EL2 for reduced wattage lamp replacements. The probe- start and pulse

- start MH lamps at each wattage and EL are assumed to have the same performance, but different prices. See appendix 5A

for details.

• Equal wattage lamp replacements

o As discussed in further detail in chapter 5 of this NOPD TSD, DOE models customers switching to a more efficacious lamp at the same wattage. These lamps

, by definition, provide increased light output, so mean lumens are not kept within

ten p ercent.

o When available, DOE identified both probe- start and pulse

- start MH lamps at EL1 and EL2 for equal wattage lamp replacements. The probe- start and pulse

start MH lamps at each wattage and EL are assumed to have the same performance, but different prices. See appendix 5A for details.

• Reduced wattage retrofit lamps

o As discussed in further detail in chapter 5 of this NOPD TSD, DOE models customers using reduced wattage retrofit lamps in their existing HID systems. These lamps do not keep mean lumens within ten percent, but DOE included them in the analysis as long as they met the respective EL required.

5B.2.2 Lamp and Ballast Replacement Rules

When identifying which of the available lamp replacement options are used and, when required, the ballast used in a replacement pathway, DOE used the following rules.

5B.2.2.1 Rules Applicable to All Six Replacement Options

• When the lamp being replaced is a probe-start lamp, at EL1 and EL2 it is assumed the customer will replace it with a probe

- start lamp whenever available. This assumption was made because DOE assumed customers would prefer to keep the same technology as the existing lamp that reached end-of-life. If a probe- start lamp is not available at the wattage and EL, a pulse- start lamp can be selected.

• When the lamp being replaced is a pulse -start lamp, at EL1 and EL2 it is assumed the customer will replace it with a pulse

- start lamp whenever available. This assumption was made because DOE assumed customers would prefer to keep the same technology as the

5B-2existing lamp that reached end -of- life. If a pulse

- start lamp is not available at the wattage and EL, a probe- start lamp can be selected.

• When the lamp being replaced is a mercury vapor (MV) lamp, at EL1 and EL2 it is assumed the customer will replace it with a pulse

- start lamp whenever available. This assumption was made because pulse -start lamps are more common than probe- start lamps at a number of wattages that MV lamps are analyzed, particularly low wattages ( i.e. , 150 W and below). Additionally, a customer will typicall y need to purchase an entirely new

fixture when faced with a MV lamp failure. Based on EISA 2007 and the metal halide lamp fixtures (MHLF) energy conservation standards rulemaking (hereafter referred to as

the 2014 MHLF rule a ), MH ballasts in new fixtures from 150 W to 1000 W must be pulse-start and not probe- start. If a pulse

- start lamp is not available at the wattage and EL for which a replacement lamp is needed for a MV baseline, a probe

- start lamp is selected.

• When any lamp being replaced is shifting to EL3, it is assumed the customer will replace it with a ceramic metal halide (CMH) lamp whenever available. If a CMH lamp is not available, no replacement options are available for that pathway. These assumptions were made because the portfolio of lamps th at meet EL3 is made up almost entirely of CMH lamps.

5B.2.2.2 Rules Applicable to Lamp

- and -Ballast Retrofit & Full Fixture Replacement Purchase Options

• When the purchase option requires a new fixture or a new lamp-and- ballast system, the new ballast that is require d will have its wattage and starting method match that of the new lamp. The type of ballast selected is based on the lamp type, as discussed in detail in chapter 5 of this NOPD TSD.

• When a customer is using a lamp -and- ballast replacement option and the bal last being replaced is magnetic, a customer shifting to a CMH lamp is assumed to use a replacement ballast that is pulse

- start magnetic. This assumption is made because, while CMH lamps can run on pulse- start magnetic or pulse

- start electronic ballasts, th e existing fixtures in these situations are assumed to be designed for use with magnetic ballasts and not electronic ballasts. Use with electronic ballasts requires design modifications to the fixture, so the fixture is not assumed to have been designed fo r use with an electronic

ballast.

5B.2.2.3 Non

- Feasible Lamp Replacement Pathways

• When the lamp being replaced is a probe-start lamp, at EL3 a customer cannot choose a reduced wattage lamp replacement pathway or equal wattage lamp replacement pathway. Instead, thes e customers must choose either a lamp -and- ballast replacement or full fixture replacement pathway, at either reduced wattage or equal wattage. This assumption is made because CMH lamps are the only lamps that can meet EL3 and they are not designed to opera te on probe- start ballasts.

a The final rule in this MHLF rulemaking was published in the Federal Register on February 10, 2014. 79 FR 7745. For more information on this rulemaking, see http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/16

.

5B-3• When the lamp being replaced is a pulse-start lamp (and the ballast is not being replaced), at EL3 a customer cannot choose a reduced wattage lamp replacement pathway, but can choose an equal wattage lamp replacement pathway using a CMH lamp. This is because a typical pulse-start ballast cannot operate lamps at any wattages other than that for which it was designed. It can operate an equal wattage CMH lamp, though, because CMH lamps can operate on pulse- start magnetic ballasts.

5B.2.3 Ballast Efficiency Rules

When identifying the efficiency of the ballast used in each replacement option (according to the lamp and ballast replacement rules discussed previously), the ballasts could potentially be compliant with the Energy Independence and Security Act (EISA 2007), the 2014 MHLF rule, or

no standards at all . When determining with which standards, if any, the ballasts would be required to comply, DOE used the assumptions summarized below. DOE also modeled the ballast efficiency of customers with HID systems installed before the potential compliance date

of st andards analyzed in this NOPD in order to accurately reflect the potential change in energy use they would experience in response to energy conservation standards.

• Fixture Replacement Purchase Option

o For any new fixture purchased after the potential compl iance date of the standards analyzed in this NOPD at EL1 and EL2, the ballast efficiency of fixtures covered by the 2014 MHLF rule will be the minimum ballast efficiency required by the 2014 MHLF rule. This applies to any replacement pathway that involves the purchase of a new fixture, either reduced wattage or equal wattage.

o For any new fixture purchased after the potential compliance date of the standards analyzed in this NOPD at EL3, the ballast efficiency will be represented by the

least efficient elect ronic ballast commercially available at the wattage. This assumption was made because DOE assumed customers would most likely pair

EL3

- compliant CMH lamps with electronic ballasts, and the least efficient electronic ballasts commercially available are more efficient than the efficiencies mandated by the 2014 MHLF rule and EISA 2007.

o For any fixture using the 250 W CMH lamp that is designed for use on a highpressure sodium (HPS) ballast, DOE assumes the ballast efficiency representative

of the least efficie nt 250 W HPS ballast commercially available. This assumption was made because HPS ballasts are currently unregulated, and the majority of shipments fall at the least efficient ballast.

• Lamp -and- Ballast Replacement Option

o When choosing a replacement pathwa y that does not require full fixture replacement, customers can choose ballasts that do not comply with fixture regulations (EISA 2007 or the 2014 MHLF rule) because those regulations only apply to ballasts sold with new fixtures. In these instances, it is assumed the efficiency of the replacement ballast chosen will relate to the efficiency of the existing HID system.

 When the ballast being replaced is a MV ballast, it is assumed that the replacement ballast will represent the least efficient commercially

5B-4available ballast for the designated replacement ballast type. This assumption is made because customers of MV systems are typically less concerned about increasing energy efficiency and more focused on reducing first costs.

 When the ballast being replaced is a MH ballast, the efficiency of the replacement ballast is based the regulations, if any, with which the ballast being replaced was required to meet. This then ensures that the replacement ballast will generally represent the same degree of efficiency as the ballast being replaced.

• If the existing HID system was installed before the compliance dates of EISA 2007 or the 2014 MHLF rule, or it is not in the scope of either of these regulations, the replacement ballast will represent the least efficient commercially available ballast of the technology at that wattage.

• If the existing HID system was in the scope of EISA 2007 and was installed after the compliance date of EISA 2007, the replacement ballast will also be compliant with EISA 2007.

• If the existing HID system was in the scope of the 2014 MHLF rule and was installed after the compliance date of the 2014 MHLF rule, the replacement ballast will also be compliant with the 2014

MHLF rule.

o All existing 150 W systems are assumed to be the 150 W systems tha t were exempt from EISA 2007 standards for being rated for use in wet locations and in locations with an ambient temperature of 50 o C. This assumption was made because the majority of 150 W shipments are exempt from the EISA 2007

standards.

o For any lamp-and-ballast replacement using the 250 W CMH lamp that is designed for use on an HPS ballast, DOE assumes the ballast efficiency representative of the least efficient 250 W HPS ballast commercially available. This assumption was made because HPS ballasts are c urrently unregulated, and the majority of shipments fall at the least efficient ballast.

• Lamp Replacement Purchase Option

o When choosing the replacement option of just replacing the lamp with a compliant reduced wattage lamp, the new ballast efficiency is calculated with the following formula that was determined based on research and manufacturer feedback regarding the effect on ballast efficiency of reduced wattage lamps on full wattage ballasts:

efficiency
new = wattage new ( wattage original efficiency original ) ⁄

− wattage original + wattage new

 Where: efficiency

new = efficiency of the ballast running the retrofit lamp

wattage new = wattage of the reduced wattage retrofit lamp

wa ttage original = wattage of the original lamp -and- ballast system efficiency original = rated efficiency of the original ballast

5B-5o When choosing the replacement option of just replacing the lamp with a compliant equal wattage lamp, it is assumed the ballast efficiency is equal to the ballast efficiency of the initial system because the ballast has not changed.

5B.2.4 Existing Fixtures

To model the energy use associated with the installed base of HID lamps, DOE needed to establish the efficiency of the ballasts used i n these existing fixtures. In addition, ballast efficiencies dictate the replacement ballast efficiencies selected by customers even after the potential compliance date of the standards analyzed in this NOPD. DOE assumed the ballasts

would be the least eff icient available, taking into account any applicable regulations that impact the allowed efficiency or presence of certain ballast types. The assumptions relating to ballast efficiency are summarized below.

• When the fixture was installed before the compli ance date of EISA 2007, there were no ballast efficiency standards for HID systems. As such, fixtures installed before the compliance date of EISA 2007 are assumed to have ballasts with efficiencies representative of the least efficient commercially availa ble ballast for the wattage and ballast type.

• When the fixture was installed after the compliance date of EISA 2007 but before the compliance date of the 2014 MHLF rule, fixtures that are within the scope of EISA 2007 are assumed to have ballasts with efficiencies that just meet the levels mandated by EISA 2007. However, fixtures installed in this time period that are not within the scope of EISA 2007 are assumed to have ballasts with efficiencies representative of the least efficient commercially available ballast for the wattage and ballast type.

• When the fixture was installed after the compliance date of the 2014 MHLF rule, fixtures that are within the scope of the 2014 MHLF rule are assumed to have ballasts with efficiencies that just meet the levels man dated by the 2014 MHLF rule. However fixtures installed in this time period that are not within the scope of the 2014 MHLF rule are assumed to have ballasts with efficiencies representative of the least efficient commercially available ballast for the wattage and ballast type.

5B-6APP ENDIX 6A. HID BALLAST AND FIXT URE PRICES

TABLE O F CONTENTS

6A.1 I NTRODUCTION

. .................................................................................................... .. . 6A-1

6A.2 METHODOLOGY

....................................................................................................... 6A-1

6A.2.1 Manufacturer Production Cost .................................................................... 6A-2

6A.2.1.1 Teardowns ....................................................................................... 6A-2

6A.2.1.2 Mercury Vapor Technology ............................................................ 6A-5

6A.2.1.3 Metal Halide Ballast and Fixture Cost Adders

............................... 6A-5

6A.2.1.4 Retrofit Kit Components

................................................................. 6A-7

6A.2.2 Manufacturer Markup

................................................................................. 6A-8

6A.3 RESULTS

................................................................................................................... 6A-11

LIS T OF FIGURES

Fi gure 6A.2.1 Manufacturer Selling Price ................................................................................ 6A-2

LIS T OF TABLES

Ta ble 6A.2.1 Metal Halide Lamp Fixtures Selected for Teardowns ........................................ 6A-3 Table 6A.2.2 Incremental Costs for Electronically Ballasted MH Fixtures ............................. 6A-7 Table 6A.2.3 Lamp Socket MSP .............................................................................................. 6A-8 Table 6A.2.4 Gross Profit Margin for Four HID Ballast Manufacturers* ................................ 6A-9 Table 6A.2.5 Gross Profit Margin for Six HID Fixture Manufacturers* ............................... 6A-10 Table 6A.2.6 Calculated Manufacturer Markups for HID Ballasts ........................................ 6A-10 Table 6A.2.7 Calculated Manufacturer Markups for HID Fixtures ........................................ 6A-10 Table 6A.3.1 HID Replacement Ballast MSPs – Not Regulated ............................................ 6A-12 Table 6A.3.2 HID Replacement Ballast MSPs – EISA 2007 ................................................. 6A-13 Table 6A.3.3 HID Replacement Ballast MSPs – 2014 MHLF Final Rule ............................. 6A-14

Table 6A.3.4 HID Fixture MSPs ............................................................................................ 6A-15

6A-iAPPENDIX 6A. HID BALLAST AND FIXTURE PRICES

6A.1 INTRODUCTION

This appendix presents the methodology the U.S. Department of Energy (DOE) followed in developing manufacturer selling prices (MSPs) for the high- intensity discharge (HID) ballasts

and fixtures analyzed in this notice of proposed determination (NOPD). DOE developed prices

for HID ballasts

, fixtures

, a and retrofit kit s because DOE recognizes that customers may be required to purchase these items to accommodate higher efficacy HID lamps. DOE applies markups ( see chapter 7 of th is NOP D technical support document [ TSD ] ) to these MSPs to develop the end

- user prices that are used as inputs in the life

- cycle cost (LCC) analysis (chapter

9 of this NOPD TSD) and the national impact analysis (NIA; chapter 11 of th is NOPD TSD ).

6A.2 METHODOLOGY

When purchasing a more efficacious lighting system, DOE acknowledges that a customer may be required to purchase a n entirely new HID fixture , or retrofit an existing fixture with new lamp -and- ballast system to accommodate the higher effi cacy lamp. Thus, DOE also developed prices for HID ballasts , fixtures, brackets, and sockets . For these components , DOE developed

MSPs and applied markups instead of determining end- user prices directly because MSP data for metal halide (MH) ballasts and M H lamp fixtures (MHLFs) w ere already available from the energy conservation standards rulemaking for MHLFs , hereafter referred to as the 2014 MHLF rulemaking. b

Using data from the 2014 MHLF rulemaking and feedback from manufacturer

interviews , DOE developed prices for the representative ballasts, fixtures, and ballast retrofit kit components proposed in the engineering analysis. The full cost of production is broken down into two main costs: the manufacturer production cost (MPC) and the non-pr oduction cost. To develop prices, DOE first conducted teardowns to calculate the MPC . The MPC comprise s the total cost of materials, labor, and direct overhead used to manufacture the equipment. DOE then calculated a manufacturer markup to estimate the non -production costs and profit associated with these components. DOE multiplied the MPC by the manufacturer markup to calculate the MSP for each ballast and fixture, as well as brackets and sockets

. The MSP represents the price at

which a manufacturer sells a product to the next entity in the distribution channel. As discussed in chapter 7 of th is NOPD TSD , DOE applied further markups to each MSP to calculate an end

user price. The following sections discuss the methodology DOE used to develop MSPs for HID

ba llasts and fixtures.

As discussed in chapter 5 of this NOPD TSD, DOE characterizes the ballast efficiencies of fixtures a customer can buy after the potential compliance date of standards analyzed in this

a Here, DOE uses the term “fixture” to refer to the enclosure that houses the lamp and ballast.

b The final rule in this MHLF rulemaking was published in the Federal Register on February 10, 2014. 79 FR 7745. For more information on this rulemaking, see http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ru leid/16

.

6A-1NOPD, as well as the ballast efficiencies of customers’ existing fixtures that were purchased before the potential compliance date of standards analyzed in this NOPD. MHLFs purchased after the potential compliance date of standards analyzed in this NOPD must comply with the standards adopted in the 2014 MHLF rulemaking. Customers’ existing fixtures purchased before the potential compliance date of standards analyzed in this NOPD can be characterized by two different types of ballast efficiencies : those covered by the Energy Independence and Security

Act o f 2007 (EISA 2007) and those not covered by EISA 2007. MHLFs are assumed to have EISA 2007 compliant efficiencies if they are purchased after the compliance date of EISA 2007 and are covered by the scope of EISA 2007. Otherwise, MHLFs are assumed to not ha ve EISA

2007 compliant efficiencies and instead are assumed to have the least efficient ballast efficiency commercially available with th e specific wattage and ballast type. The one exception to th is categorization is if the ballast is electronic, then the ballast efficiency is assumed to be the least efficient electronic ballast commercially available. This assumption is used because electronic

ballast efficiencies are more efficient than the standards adopted in th e 2014 MHLF rulemaking

and EISA 2007 standards.

6A.2.1 Manufacturer Production Cost

Figure 6A.2.1 shows the general breakdown of costs and profit associated with manufacturing and selling equipment. The full cost of production is broken down into two main

costs: the MPC and the non-production cost. The MPC comp ri se s direct labor, direct material,

and overhead costs. The direct labor costs include fabrication a nd assembly labor. The nonproduction cost plus profits is equal to the manufacturer markup.

Figure 6A.2.1 Manufacturer Selling Price

6A.2.1.1 Teardowns

To develop MPCs for HID ballasts and fixtures, DOE utilize d data from the 2014 MHLF rulemaking. The 2014 MHLF rulemaking developed MPCs for several MH ballast s and MHLFs that shared characteristics and wattages with units analyzed in this NOPD

. MPCs were developed by conducting teardowns, an analysis in which DOE creates a bill of materials included in the ballast and an estimate of the direct labor required to assemble and test the finished product. Table 6A.2.1 summarizes all the MHLFs selected for teardowns. Specification sheets for fixtures typically show the dimensions and properties of the fixtures, along with the various ballast types and wattages that can be used with that fixture. For the fixtures torn down,

6A-2DOE notes each MH ballast wattage that the MHLF is suitable for housing according to the fixture specifications

.

Table 6A.2.1 Metal Halide Lamp Fixture s Selecte d for Teardowns

Indoor/ Outdoor Application Ballast Wattages Listed for Use (W)

Indoor Low

- Bay 100 , 175, 250, 320, 400

Indoor Low

- Bay 320 , 350, 400

Outdoor Low

- Bay 250, 400

Indoor High

- Bay 400

Indoor High

- Bay 320, 350, 400

Indoor High

- Bay 1000

Outdoor Wallpack 70 , 100

Outdoor Wallpack 150

Outdoor Wallpack 250 , 400

Outdoor Wallpack 70 , 100, 150, 175, 200, 250, 320, 350, 400

Outdoor Parking Lot 70 , 100, 150

Outdoor Canopy 175 , 200, 250, 320, 350, 400

Outdoor Canopy 70 , 100, 150

Indoor Recessed Can 70 , 100

Indoor Flood 400

Outdoor Flood 50, 70, 100

Outdoor Flood 70, 100, 150

Outdoor Flood 250, 400, 1000

Outdoor Flood 150, 250, 400

Outdoor Flood 70, 100, 150, 175, 200, 250, 320, 350, 400

Outdoor Flood 150, 175, 200, 250, 320, 350, 400

Outdoor Pole Top 70

Outdoor Pole Top 150, 250, 320, 400

Outdoor Sports 400, 1000, 1500

All teardown results included the direct material estimates, as well as the direct labor costs associated with the assembly of the HID ballasts and fixtures. Because the materials involved in ballast and fixture manufacturing are highly correlated to commodity pricing, DOE

used five -year average material prices from 2006 to 2010 when possible to maintain the same

cost basis as the 2014 MHLF rulemaking. Separate labor rates were used for components that required manual insertion versus those that were automated. During manufacturer interviews, DOE learned that HID ballasts are typically manufactured in Mexico and China and that HID fixtures are typically manufact ured in the United States

. Therefore, DOE applied the appropriate

labor rate s for the HID ballast and fixture teardowns

, respectively

.

The teardown results did not include overhead estimates. Overhead includes indirect material and labor costs, maintenance, depreciation, taxes, and insurance related to assets. To

6A-3calculate overhead, DOE utili zed information available in the recent standar ds rulemaking for fluorescent lamp ballasts. c In that rulemaking, DOE used financial data to estimate the overhead cost by calculating it as a percentage of the MPC. DOE found overhead and depreciation to be about 6.2 percent of the MPC or 6.6 percent of the material and labor costs. The 6.6 percent factor was then used to mark up the material and labor costs contained in the teardown results to

the MPC. Because HID ballasts are produced by many of the same manufacturers as fluorescent

ballasts and should h ave a similar material and labor percentage of the overall MPC , DOE used the same factor to represent overhead when developing MPCs in this NOPD

.

If a teardown was not conducted for a MH ballast at an analyzed wattage or efficiency

, DOE modeled the MPCs using a cost model. When determining the MPC of a ballast with an analyzed wattage but at an increased efficiency, DOE modeled the increased efficiency ballast MPC based on the lower efficiency ballast. DOE model ed such a ballast by starting with the

comme rcially available lower efficiency ballast and replacing the steel type with a higher grade

steel , as determined by using manufacturer input. The stack height and ballast weight of the increased efficiency ballast was kept constant compared to the lower ef ficiency ballast . When the new steel type used had thinner laminations than the original steel type used in the lower efficiency ballast , DOE accounted for the cost of an increased number of laminations that would be required to keep the same stack height by assigning higher production costs based on the increased laminations required.

To model the MPCs of ballasts with a wattage that was not analyzed , DOE modeled the

new wattage ballast MPC based on a n existing ballast teardown at the nearest analyzed wattage that had the same footprint as the new wattage ballast

. DOE modeled this new wattage ballast by applying the ratio of stack heights of the two different wattages to determine the approximate mass of the core and coils of the new ballast. For exampl e, if the stack height of the new wattage was 1.2 times the stack height of the existing wattage, then DOE determined the core mass and conductor mass of the new wattage w ere 1.2 times those measurements of the existing wattage.

This would allow DOE to det ermine the MPC of a ballast at a new wattage that was at approximately the same efficiency as the existing wattage. To determine the MPC of a ballast at this new wattage , but at higher efficienc ie s, DOE then conducted the modeling procedure

discussed in th e previous paragraph.

When the 2014 MHLF rulemaking analyzed fixtures of a particular wattage, the fixture MPC used for that wattage was also used in this NOPD . However, if a teardown was not

conducted for an MHLF at an analyzed wattage, DOE estimated the price based on the wattage versus price relationship for fixture s with similar applications and sizes . The on ly exceptions are that fixtures at 575 watts ( W), 750 W, and 875 W were all assumed to have the same MPC as 1000 W fixtures. This assumption is made because fixtures at 575 W, 750 W, and 875 W are typically advertised as having the same applications and having the same dimensions as 1000 W

fixtures . Thus for those wattages, DOE found it appropriate to use the same MPC as 1000 W

fixtures.

c For more information on the fluorescent lamp ballast energy conservation standards rulemaking, see http://www1.eere.energy.gov/buildings/applianc e_standards/product.aspx/productid/62

6A-46A.2.1.2 Mercury Vapor Technology

DOE did not perform teardowns for mercury vapor (MV) ballasts and fixtures. Instead,

f or ballasts, DOE utilized blue -book prices to determine the appropriate costs of MV technology. Using the teardown- sourced MPCs described in the previous section , DOE calculated an average discount factor between the MPCs and blue-book prices for the analyzed MH ballast models. DOE then applied this discount factor to the most recent blue -book prices of the analyzed MV

ballast models.

For fixtures, manufacturers provided feedback that MH LF s are similar in material makeup and construction to MV fixtures. Because of this, fixture manufacturers recommended

that the MPCs for MH LF s could be used as the MPCs for MV fixtures

, if used in the same applications and at the same wattages. DOE agreed and reviewed the typical applications in

which MV fixtures are used. DOE found that MV fixtures are generally used in similar applications as MH LF s. Therefore , DOE assumed tha t MV fixture MPCs were the same as

MH LF MPCs at the same wattage

.

6A.2.1.3 Metal Halide Ballast and Fixture Cost Adders

When purchasing a more efficacious lighting system, the customer may be required to purchase a new ballast and fixture to accommodate the higher efficacy lamp. When the more efficacious lamp is a ceramic metal halide (CMH) lamp, DOE assumed these lamps would be paired with an electronic ballast. DOE calculated different fixture costs depending on whether or

not the fixture is used with an electron ic ballast, and if the electronic ballast itself required any modification to provide equivalent functionality to a magnetic ballast. While DOE found that each fixture type was capable of physically containing either a magnetic or electronic ballast,

DOE f ound three changes required for a fixture to accommodate an electronic ballast rather than a magnetic ballast. These changes only apply to MH systems because electronic ballasts are not used with MV lamps. In addition, DOE determined that the cost adders a re different depending

on whether or not the fixture will be used in indoor versus outdoor locations. This section describes the rationale and cost values associated with these design changes. Both the designs and cost adders are the same as those develope d and presented in the final rule of the 2014 MHLF rulemaking.

Design Changes

. The first requirement is that electronic ballasts are able to withstand a voltage transient of up to 10 kilovolts (kV ), based on American National Standards Institute (ANSI) s tandard C62.41.1-2002 for area and roadway lighting in the utility division and ANSI C82.14-2006 for low-frequency square wave electronic ballasts. ANSI C62.41.1-2002 serves as the guideline to manufacturers for the classification of surge protection definitions and equipment. ANSI C82.14-2006 specifies the requirement of ballasts in roadway applications to be designed with a transient insulation level of 10 kV when the maximum rated supply voltage exceeds 600 V. An inline surge protection device external t o the ballast, also called a metal oxide varistor (MOV)

, is required for electronic ballasts in outdoor fixtures . The MOV is used to clamp off the circuit if the energy surge exceeds 10 kV. A portion of commercially available electronic

ballasts have 10 kV surge protection built in, but most electronic ballasts are rated for 6 kV

6A-5voltage spikes. Thus, DOE applied incremental costs for transient protection in outdoor locations, further discussed later in this section

.

The second requirement relates to thermal management. Generally, electronic ballasts are more vulnerable than magnetic ballasts to high ambient temperatures. In order to allow electronic ballasts to be used in the same environments as magnetic ballasts , fixtures housing electronic

ballasts wou ld need to be designed differently to account for thermal management in both indoor and outdoor applications. Electronic ballasts are more efficient than magnetic ballasts, and therefore generate less heat and are meant to run at cooler temperatures. However, electronic ballasts generally cannot operate at temperatures exceeding 90 ° C, while magnetic ballasts can operate at temperatures as high as 150 °C. This temperature limit makes it impossible to place

electronic ballasts in a fixture in the traditional location near the lamp. Additionally, these ballasts use a power foldback feature to manage the temperature of the ballast and prevent damage to the ballast in extreme high heat conditions. The sensitivity of electronics to the rmal

conditions can involve a different fixture or ballast design

, such as additional potting material to create adequate thermal contact between the ballast and fixture, thermal shields, or fixture venting to sink the heat outside of the fixture. Thus, DOE applied incremental costs to the fixture for electronic ballast thermal management

, discussed in more detail later in this section

.

The third requirement is for ballasts to include 120 V auxiliary power functionality. This input is typically used for an emergency incandescent lamp that operates only after a temporary loss of power and while the MH lamp is still too hot to restart. These taps are primarily used in indoor applications and because this auxiliary tap is primarily required for emergency lighting purposes, they are only needed in about one out of every ten indoor fixtures. A 120 V tap is easily incorporated into a magnetic ballast due to its traditional core and coil design, and incurs a negligible cost increment. Electronic ballasts, though, require modification to add this 120 V auxiliary power functionality. The incremental cost for this 120 V auxiliary power functionality

is discussed later in this section

.

Cost Adders

. DOE applied several cost adders to the fixture and electronic ballast MPCs

based on indoor or outdoor application

. d While this appendix presents indoor and outdoor ballast

and fixture MSPs separately , subsequent analyses including the LCC analysis and NIA use a weighted average of the two prices to represent the end- user price at each trial standard l evel ( TSL ). This aggregation of the two prices is discussed in chapter 9 of th is NOPD TSD.

Based on manufacturer input and teardown-source data, DOE applied a 20 percent fixture cost adder to all fixtures with electronic ballasts, to account for thermal management due to the vulnerability of electronic ballasts to high temperatures. In aggregate, manufacturers indicated a 20 percent increase in fixture MPC is associated with thermal management. Additionally, DOE conducted teardown analyses of MHLFs . Through analysis of pairs of fixtures designed for electronic ballasts and fixtures designed for comparable magnetic ballasts, DOE also found an approximately 20 percent increase in fixture MPCs to include thermal management for electronic ballasts. Accordingly, both indoor and outdoor MHLF s shipped with electronic ballasts are assessed a 20 percent adder to the fixture MPCs.

d DOE conducted teardowns of fixtures designed for magnetic ballasts. DOE applied cost adders to the MPC of these magnetically ballasted fixtures to estimate the cost of an electronically ballasted fixture of the same wattage.

6A-6Based on a review of selling prices from voltage transient protection device manufacturers, DOE applied a $10.31 fixture cost adder to outdoor electronic fixtures, to account

for voltage transient protection in outdoor applications that are more prone to voltage surges.

Because most electronic ballasts do not have this feature buil t in, DOE applies this adder to the fixture MPC for fixtures that include electronic ballasts in outdoor applications.

Lastly, DOE found that about 10 percent of indoor fixtures require 120 V auxiliary power functionality for use when emergency lighting is needed and the MH lamp is still too hot to be restarted. Using a combination of manufacturer information and market research, DOE determined that the cost of adding this auxiliary functionality to magnetic ballasts is so small that

no incremental cost w as applied to price models. Through the same method, DOE concluded that a representative value for electronic ballasts to incorporate this auxiliary functionality is $7.50.

Because this functionality is only needed for 10 percent of indoor fixtures , a cost adder of $0.75

is assessed per indoor electronic ballast. These three cost adders are summarized in Table 6A.2.2

below.

Table 6A.2.2 Incremental Costs for Electronically Ballasted MH Fixtures

Indoor MPC Adder
(2010$) Outdoor MPC Adder
(2010$)

Thermal Management 20% fixture MPC increase 20% fixture MPC increase

Voltage Transient

Protection -- $ 10.31 fixture MPC

increase

120 V Auxiliary Power Functionality $0.75 ballast MPC

increase --

6A.2.1.4 Retrofit Kit Components

DOE included lamp-and- ballast retrofit kits as a purchase option, which allow s a customer to install an HID lamp -and- ballast system in their existing fixture , at either an equal wattage or reduced wattage . As detailed in chapter 5 of this NOPD TSD, a number of

manufacturers offer different packages for these retrofit kits , which can include a lamp, ballast, lamp socket, and ballast brackets. DOE determined the additional cost of the lamp socket and the

ballast brackets included in retrofit kits to accurately reflect the kit MSPs

.

Lamp Sockets

. DOE determined that the two characteristics important to lamp socket selection are wattage capacity and base type. Each socket is identified with a wattage capacity

that is the maximum wattage possible for a lamp to be able to operate with that socket. Sockets also differ according to the base type of the lamps they can operate. In this NOPD , DOE analyzed prices for the most common base types used with HID lamps: mogul screw base

, medium screw base , and pin base . Using discounted retail prices, DOE identified the MPC of mogul screw base lamp sockets with the common wattage capacities of 660 W, 1500 W, and 2000 W. DOE then used market prices of lamp sockets of different base types to determine the average difference between mogul screw base sockets and both medium screw base and pin base sockets. With this average difference, DOE was then able to calculate the lamp socket MPCs of medium screw base and pin base sockets with wattage capacities of 660 W, 1500 W, and

6A-72000 W. DOE chose to represent all types of pin bases collectively, due to the variety of different types of pin bases used with HID lamps. DOE th en applied a markup from the ballast manufacturer to the lamp socket MPCs to calculate lamp socket MSPs , as shown in Table

6A.2.3

. These lamp socket MSPs were used for any retrofit kit modeled in the engineering analysis.

Table 6A.2.3 Lamp Socket MSP

660 W 1500 W 2000 W

Mogul Screw Base $1.886 $1.889 $1.821

Medium Screw Base $1.308 $1.310 $1.263

Pin Base $2.194 $2.198 $2.119

Ballast Brackets

. DOE analyzed lamp -and-ballast retrofit kits from 150 W to 1000 W and noted that the size and design of the ballast brackets included with retrofit kits did not vary

based on the size of the ballast. DOE used a teardown cost model to determine the MPC of each of the brackets analyzed, and then averaged each of those MPCs to get an average MPC of

ballast brackets. DOE then applied a markup from the ballast manufacturer to the ballast bracket

MPC to calculate a ballast bracket MSP o f $2.71. This ballast bracket MSP was used for any retrofit kit modeled in the engineering analysis.

6A.2.2 Manufacturer Markup

More efficient ballast and fixture technologies typically have higher production costs than existing ballasts and fixtures. To meet new energy conservation standards, manufacturers often must introduce design changes to their existing equipment or discontinue less efficient equipment, resulting in standards-compliant equipment with higher costs. Depending on the competitive environment for the particular equipment types, some or all of the increased production costs can be “passed on” from manufacturers to customers in the form of higher purchase prices. As production costs increase, manufacturers also typically incur additional overhead at the factory and corporate levels. The MSP must cover both of these additional contributions to overhead if a company is to maintain its current level of profitability

.

As discussed previously, overhead costs within the DOE model are a function of investments, material costs, labor costs, or total costs, depending on the overhead category. Together, materials, labor, and factory overhead compo se the MPC . DOE applies another multiplier to the MPC to account for corporate non -production costs and profit. This latter multiplier, the manufacturer markup, is the focus of this section.

DOE calculated the HID ballast MSP for ballasts sold directly to fixture manufacturers

for use in new fixtures by multiplying the ballast MPC by a ballast

- to

- fixture manufacturer markup. DOE then used this value to calculate the MSP for full HID fixtures ( fixtures packaged

and sold with a ballast) by adding the ballast (for use in new fixture s) MSP to the empty fixture MPC, and then applying the fixture manufacturer markup to that sum. DOE also calculated the MSP for HID ballasts sold into distribution as a replacement ballast by multiplying the MPC by

the calculated replacement ballast manufa cturer markup to determine the replacement ballast

MSP. In general, the manufacturer markup s should ensure that the MSP of the equipment is high

6A-8enough to recover the full cost ( i.e., production and non- production costs), and yield a satisfactory profit. The following paragraphs discuss the methodology for developing this markup in more detail.

Publicly owned companies are required by law to disclose financial information on a regular basis by filing different forms with the U.S. S ecurities and Exchange Commission (SEC)

. The SEC form 10 -K, filed by companies on an annual basis, provides a comprehensive overview of the company’s business and financial conditions. Relevant information in the 10-K reports includes the company’s revenues and direct and indirect costs. To derive the manufacturer markup, DOE used 10-K reports from publicly owned ballast or fixture manufacturing companies and inputs from manufacturer interviews. The financial figures necessary for calculating the manufacturer markup are net sales, costs of sales, and gross profit. The income

statement section of the 10 -K reports often reports these figures. DOE used averages of the financial figures spanning from 2002 to 2008 to calculate the manufacturer markup for ballasts

and from 2000 to 2009 t o calculate the manufacturer markup for fixtures, in keeping with the figures used in the final rule of the 2014 MHLF rulemaking.

DOE used the following equations to calculate the gross profit and gross profit margins:

Gross Profit ($) = Net Sales

– Cost of Sales Eq. 6A.1

Gross Profit Margin (%)= Gross Profit

Net Sales Eq. 6A.2

Table 6A.2.4 contains the calculated gross profit margins for four sample ballast

manufacturers. Table 6A.2.5 contains the calculated gross profit margins for six sample fixture

manufacturers.

Table 6A.2.4 Gross Profit Margin for Four HID Ballast Manufacturers*

Parameter Industry

Weighted Average Manufacturer

A B C D

Net Sales Million $ 66,614 90,705 46,952 38,118 63,862

Cost of Sales Million $ 44,203 58,350 29,567 27,562 44,804

Gross Profit Million $ 22,411 32,355 17,385 10,556 19,057

Gross Profit Margin % 33.6 35.7 37.0 27.7 29.8

* Data taken from 2002, 2003, 2004, 2005, 2006, 2007, and 2008 SEC 10

- K reports.

6A-9Table 6A.2.5 Gross Profit Margin for Six HID Fixture Manufacturers*

Parameter Industry

Weighted Average Manufacturer

A B C D E F

Net Sales Million

$ 65,337 100,996 44,363 34,988 15,164 15,877 0,978

Cost of Sales

Million $ 44,237 65,844 31,614 28,824 10,119 11,317 0,489

Gross Profit

Million $ 20,757 35,152 12,749 6,164 5,045 4,560 0,489

Gross Profit Margin % 31.8 34.8 28.7 17.6 33.3 28.7 50.0

* Data taken from 2000, 2001, 2002, 2003, 2004, 2005, 2006, 2007, 2008, and 2009 SEC 10

- K reports.

To calculate the time -averaged gross profit margin for each firm, DOE first summed the gross profit for all the years and then divided the result by the sum of the net sales for those years. Each manufacturer’s markup was calculated using the following equation.

Manufacturer Markup = 1

Manufacturer Markup = Net Sales

Cost of Sales Eq. 6A.3

Table 6A.2.6 shows the ballast manufacturer markups, and Table 6A.2.7 shows the fixture manufacturer markups using this method.

Table 6A.2.6 Calculated Manufacturer Markups for HID Ballasts

Manufacturer Manufacturer Markup

Manufacturer A 1.56

Manufacturer B 1.59

Manufacturer C 1.38

Manufacturer D 1.42

Average 1.50

Table 6A.2.7 Calculated Manufacturer Markups for HID Fixtures

Manufacturer Manufacturer Markup

Manufacturer A 1.53

Manufacturer B 1.40

Manufacturer C 1.21

Manufacturer D 1.50

Manufacturer E 1.40

Manufacturer F 2.00

Average 1.48

6A-10DOE calculated the average ballast manufacturer markup to be 1. 50, and the average fixture manufacturer markup to be 1.48 based on the estimated market share of each manufacturer. In other words, on average, HID ballast manufacturers sell their products to the next party in the distribution channel at 50 percent above the MPC , and HID fixture manufacturers sell their equipment at 48 percent above the manufacturing production cost.

Although all publicly owned companies file 10- K reports, the financial info rmation summarized therein is not usually exclusive to the HID ballast and fixture portion of

manufacturers’ business. It can include financial information from other equipment sectors, whose margins could be quite different from those of the HID ballast and fixture industries. DOE interviewed the lighting division of manufacturers and received input to more

- accurately estimate actual manufacturer markup values.

Considering the calculations above, the information provided in Table 6A.2 .6

, Table

6A.2.7 , and manufacturer feedback, DOE determined that a manufacturer markup of approximately 1.47 was appropriate for HID ballast s sold to fixture manufacturers , a manufacturer markup of approximately 1.60 was appropriate for HID ballasts sold to distributors, and a manufacturer markup of 1.58 was appropriate for HID fixture s . DOE applied these multipliers to MPCs to determine the MSPs of ballasts and fixtures in this NOPD

. This methodology is the same as that used in the 2014 MHLF rulemaking.

6A.3 RESULTS

Table 6A.3.1 through Table 6A.3.4 summarize the MSPs for the HID replacement

ballasts and fixtures e analyzed in this NOPD . The replacement ballast MSP tables are categorized by the relevant compliance standards ( not regulated, EISA 2007, and the 2014 MHLF final rule standards).

e In this case, fixture refers to the product that includes the enclosure, optics, ballast, and wiring.

6A-11Table 6A.3.1 HID Replacement Ballast MSPs – Not Regulated

Lamp Characteristics Ballast MSPs* (2011$)

CCT EL Lamp Type Wattage Indoor Outdoor

>2800

K and
≤4500

K Baseline MV 100 $ 59.64 $ 59.64

EL 1/Baseline MH Standard efficacy quartz p ulse MH 70 $ 29.15 $ 29.15

EL 2 N/A

--
EL 3 CMH 50 $ 27.54 $ 27.54

Baseline MV 175 $ 33.20 $ 33.20

EL 1/Baseline MH Standard efficacy quartz p robe MH Standard efficacy quartz p ulse MH ** 150

150 $ 33.38 $ 42.32 $ 33.38 $ 42.32

EL 2 High efficacy quartz p ulse MH 100 $ 32.32 $ 32.32

EL 3 CMH 70 $ 29.15 $ 29.15

Baseline MV 250 $ 38.73 $ 38.73

EL 1/Baseline MH Standard efficacy quartz p robe MH **
Standard efficacy quartz p ulse MH 175

175 $ 37.08 $ 46.10 $ 37.08 $ 46.10

EL 2 High efficacy quartz p robe MH High efficacy quartz p ulse MH ** 150

150 $ 33.38 $ 42.32 $ 33.38 $ 42.32

EL 3 CMH 100 $ 32.32 $ 32.32

Baseline MV 400 $ 44.02 $ 44.02

EL 1/Baseline MH Standard efficacy quartz p robe MH

Standard efficacy quartz p ulse MH ** 250

250 $ 33.44 $ 42.69 $ 33.44 $ 42.69

EL 2 High efficacy quartz p ulse MH 200 $ 47.06 $ 47.06

EL 3 CMH 150

250 $ 42.32 $ 51.05 $ 42.32 $ 51.05

Baseline N/A

--

EL 1/Baseline Standard efficacy quartz p robe MH **

Standard efficacy quartz p ulse MH 400

400 $ 35.43 $ 45.14 $ 35.43 $ 45.14

EL 2 High efficacy quartz p ulse MH 320 $ 46.77 $ 46.77

EL 3 CMH 250 $ 51.05 $ 51.05

Baseline MV 1000 $ 93.64 $ 93.64

EL 1/Baseline MH Standard efficacy quartz p ulse MH 750 $ 66.03 $ 66.03

EL 2 High efficacy quartz p ulse MH 575 $ 57.47 $ 57.47

Baseline N/A

--

EL 1/Baseline MH Standard efficacy quartz probe MH Standard efficacy quartz pulse MH ** 1000

1000 $ 57.55 $ 69.07 $ 57.55 $ 69.07

EL 2 High efficacy quartz p ulse MH 875 $ 69.38 $ 69.38

Baseline Baseline p ulse MH 2000 $ 173.39 $ 173.39

EL 1 High efficacy quartz p robe MH 1500 $ 90.83 $ 90.83

* The ballast MSP includes the cost adders discussed in section 6A.2.1.3

. ** Where options existed for pulse and probe start lamps, the lamp type indicated is considered the representative unit for the efficacy level.

6A-12Table 6A.3.2 HID Replacement Ballast MSPs

– EISA 2007

Lamp Characteristics Ballast MSPs* (2011$)

CCT EL Lamp Type Wattage Indoor Outdoor

>2800

K and
≤4500

K Baseline MV 100 $ 59.64 $ 59.64

EL 1/Baseline MH Standard efficacy quartz pulse MH 70 $ 29.15 $ 29.15

EL 2 N/A

-- -- --
EL 3 CMH 50 $ 27.54 $ 27.54

Baseline MV 175 $ 33.20 $ 33.20

EL 1/Baseline MH Standard efficacy quartz probe MH Standard efficacy quartz pulse MH ** 150

150 $ 33.38
$ 42.32 $ 33.38 $ 42.32

EL 2 High efficacy quartz pulse MH 100 $ 32.32 $ 32.32

EL 3 CMH 70 $ 29.15 $ 29.15

Baseline MV 250 $ 38.73 $ 38.73

EL 1/Baseline MH Standard efficacy quartz probe MH **
Standard efficacy quartz pulse MH 175

175 -- $ 62.00 -- $ 62.00

EL 2 High efficacy quartz probe MH High efficacy quartz pulse MH ** 150

150 $ 33.38
$ 42.32 $ 33.38 $ 42.32

EL 3 CMH 100 $ 32.32 $ 32.32

Baseline MV 400 $ 44.02 $ 44.02

EL 1/Baseline MH Standard efficacy quartz probe MH Standard efficacy quartz pulse MH ** 250

250 -- $ 54.64 -- $ 54.64

EL 2 High efficacy quartz pulse MH 200 $ 61.18 $ 61.18

EL 3 CMH 150

250 $ 42.32
$ 51.05 $ 42.32 $ 51.05

Baseline N/A

--

EL 1/Baseline Standard efficacy quartz probe MH **
Standard efficacy quartz pulse MH 400

400 -- $ 45. 73 -- $ 45.73

EL 2 High efficacy quartz pulse MH 320 $ 45.74 $ 4 5.74

EL 3 CMH 250 $ 51.05 $ 51.05

Baseline MV 1000 $ 93.64 $ 93.64

EL 1/Baseline MH Standard efficacy quartz pulse MH 750 $ 66.03 $ 66.03

EL 2 High efficacy quartz pulse MH 575 $ 57.47 $ 57.47

Baseline N/A

--

EL 1/Baseline MH Standard efficacy quartz probe MH Standard efficacy quartz pulse M H ** 1000

1000 $ 57.55
$ 69.07 $ 57.55
$ 69.07

EL 2 High efficacy quartz pulse MH 875 $ 69.38 $ 69.38

Baseline Baseline pulse MH 2000 $ 173.39 $ 173.39

EL 1 High efficacy quartz p robe MH 1500 $ 90.83 $ 90.83

* The ballast MSP includes the cost adders discussed in section 6A.2.1.3

. ** Where options existed for pulse and probe start lamps, the lamp type indicated is considered the representative unit for the efficacy level.

6A-13Table 6A.3.3 HID Replacement Ballast MSPs – 2014 MHLF Final Rule

Lamp Characteristics Ballast MSPs* (2011$)

CCT EL Lamp Type Wattage Indoor Outdoor

>2800

K and
≤4500

K Baseline MV 100 $ 59.64 $ 59.64

EL 1/Baseline MH Standard efficacy quartz pulse MH 70 $ 35.07 $ 35.07

EL 2 N/A

-- -- --
EL 3 CMH 50 $ 34.34 $ 34.34

Baseline MV 175 $ 33.20 $ 33.20

EL 1/Baseline MH Standard efficacy quartz probe MH Standard efficacy quartz pulse MH ** 150

150 $ 33.38
$ 53.63 $ 33.38
$ 53.63

EL 2 High efficacy quartz pulse MH 100 $ 41.81 $ 41.81

EL 3 CMH 70 $ 35.07 $ 35.07

Baseline MV 250 $ 38.73 $ 38.73

EL 1/Baseline MH Standard efficacy quartz probe MH **
Standard efficacy quartz pulse MH 175

175 $ 37.08
$ 62.00 $ 37.08
$ 62.00

EL 2 High efficacy quartz probe MH High efficacy quartz pulse MH ** 150

150 $ 33.38 $ 53.63 $ 33.38
$ 53.63

EL 3 CMH 100 $ 41.81 $ 41.81

Baseline MV 400 $ 44.02 $ 44.02

EL 1/Baseline MH Standard efficacy quartz probe MH Standard efficacy quartz pulse MH ** 250

250 $ 33.44
$ 75.89 $ 33.44
$ 75.89

EL 2 High efficacy quartz pulse MH 200 $ 61.18 $ 61.18

EL 3 CMH 150

250 $ 53.63 $ 51.05 $ 53.63
$ 51.05

Baseline N/A

--

EL 1/Baseline Standard efficacy quartz probe MH **
Standard efficacy quartz pulse MH 400

400 $ 35.43
$ 75.94 $ 35.43
$ 75.94

EL 2 High efficacy quartz pulse MH 320 $ 56.48 $ 56.48

EL 3 CMH 250 $ 51.05 $ 51.05

Baseline MV 1000 $ 93.64 $ 93.64

EL 1/Baseline MH Standard efficacy quartz pulse MH 750 $ 66.03 $ 66.03

EL 2 High efficacy quartz pulse MH 575 $ 95.31 $ 95.31

Baseline N/A

--

EL 1/Baseline MH Standard efficacy quartz probe MH Standard efficacy quartz pulse M H ** 1000

1000 $ 57.55
$ 69.07 $ 57.55
$ 69.07

EL 2 High efficacy quartz pulse MH 875 $ 84.67 $ 84.67

Baseline Standard efficacy quartz pulse MH 2000 $ 173.39 $ 173.39

EL 1 High efficacy quartz p robe MH 1500 $ 90.83 $ 90.83

* The ballast MSP includes the cost adders discussed in section 6A.2.1.3

. ** Where options existed for pulse and probe start lamps, the lamp type indicated is considered the representative unit for the efficacy level.

6A-14Table 6A.3.4 HID Fixture MSPs

Lamp Characteristics Fixture MSPs* (2011$)

CCT EL Lamp Type Wattage Indoor Outdoor

>2800

K and
≤4500

K Baseline MV 100 $ 25.00 $ 52.96

EL 1/Baseline MH Standard efficacy quartz pulse MH 70 $ 22.83 $ 50.53

EL 2 N/A

-- -- --
EL 3 CMH 50 $ 27.26 $ 42.42

Baseline MV 175 $ 24.77 $ 88.92

EL 1/Baseline MH Standard efficacy quartz probe MH Standard efficacy quartz pulse MH ** 150

150 $ 25.01 $ 25.01 $ 60.12 $ 60.12

EL 2 High efficacy quartz pulse MH 100 $ 25.00 $ 52.96

EL 3 CMH 70 $ 27.40 $ 76.92

Baseline MV 250 $ 28.39 $ 84.47

EL 1/Baseline MH Standard efficacy quartz probe MH **
Standard efficacy quartz pulse MH 175

175 $ 24.77 $ 24.77 $ 88.92
$ 88.92

EL 2 High efficacy quartz probe MH High efficacy quartz pulse MH ** 150

150 $ 25.01 $ 25.01 $ 60.12
$ 60.12

EL 3 CMH 100 $ 29.99 $ 79.84

Baseline MV 400 $ 68.21 $ 110.90

EL 1/Baseline MH Standard efficacy quartz probe MH Standard efficacy quartz pulse MH ** 250

250 $ 28.39 $ 28.39 $ 84.47
$ 84.47

EL 2 High efficacy quartz pulse MH 200 $ 24.70 $ 83.29

EL 3 CMH 150

250 $ 30.01 $ 28.39 $ 88.43
$ 84.47

Baseline N/A

-- -- --

EL 1/Baseline Standard efficacy quartz probe MH **
Standard efficacy quartz pulse MH 400

400 $ 68.21 $ 68.21 $ 110.90 $ 110.90

EL 2 High efficacy quartz pulse MH 320 $ 66.63 $ 111.68

EL 3 CMH 250 $ 28.39 $ 84.47

Baseline MV 1000 $ 91.88 $ 94.96

EL 1/Baseline MH Standard efficacy quartz pulse MH 750 $ 91.88 $ 94.96

EL 2 High efficacy quartz pulse MH 575 $ 91.88 $ 94.96

Baseline N/A

-- -- --

EL 1/Baseline MH Standard efficacy quartz probe MH Standard efficacy quartz pulse M H ** 1000

1000 $ 91.88
$ 91.88 $ 94.96
$ 94.96

EL 2 High efficacy quartz pulse MH 875 $ 91.88 $ 94.96

Baseline Standard efficacy quartz pulse MH 2000 $ 91.37 $ 91.37

EL 1 High efficacy quartz probe MH 1500 $ 83.06 $ 83.06

* The fixture MSP includes the cost adders discussed in section 6A.2.1.3

. Fixture refers to the product that includes an enclosure, optics, ballast, and wiring.

** Where options existed for pulse and probe start lamps, the lamp type indicated is considered the repr esentative unit for the efficacy level.

6A-15APPENDIX 9A. USER INSTRUCTIONS FOR LIFE

- CYCLE COST AND PAYBACK

PERIOD SPREADSHEET S

TABLE OF CONTENTS

9A.1 INTRODUCTION ........................................................................................................ 9A-1

9A.2 MODEL CONVENTIONS ........................................................................................... 9A-1

9A.3 INDIVIDUAL WORKSHEETS IN LCC AND PBP SPREADSHEET ...................... 9A-1

9A.4 INDIVIDUAL WORKSHEETS IN MEDIAN PBP SPREADSHEET ........................ 9A-2

9A -iAPPENDIX 9 A . USER INSTRUCTIONS FOR LIFE

- CYCLE COST AND PAYBACK

PERIOD SPREADSHEET S

9A.1 INTRODUCTION

The results obtained for the life

- cycle cost (LCC) and payback period (PBP) analysi s can be examined and reproduced using the Microsoft Excel spreadsheet s available on the U.S. Department of Energy (DOE) Building Technologies website at: www1.eere.energy.gov/ buildings/appliance_standards/ rulemaking .aspx/ rule id/23

.

There is one primary spreadsheet covering all combinations of high

- intensity discharge (HID) lamp equipment classes. The LCC and PBP spreadsheet performs calculations to forecast the change in LCC from a potential energy conservation standard and the PBP that such a change implies. These concepts are expla ined in chapter 9 of the technical support document (TSD)

. A second spreadsheet is used to perform Monte Carlo analysis unique to the median PBP

derivation.

To operate the main spreadsheet

, a user chooses values of interest in the LCC &PBP tab

. Triggering Event, Analysis Mode, and E conomic Growth Scenarios are all selected via drop

down menus. A ny market and energy price behavior can be set by adjusting the values entered in named ranges embedded throughout the LCC and PBP spreadsheet model . Therefore, strictly speaking

, no “instructions” are necessary to operate the spreadsheet. Rather, in this appendix,

DOE describes the model in case users wish to examine DOE’s assumptions and methods or to test alternative assumptions.

9A.2 MODEL CONVENTIONS

Both of the model’s primary outputs, LCC savings and PBP, are calculated on the

LCC &PBP worksheet by using base- case and standards

- case HID lamp

- and

- ballast systems (hereafter “HID lamp systems”) as inputs ( e.g. , the LCC savings for a particular HID lamp
system are calculated by subtracting the LCC associated with that unit f rom the LCC associated with a unit of the same equipment class at a baseline efficiency ). In general, logic flows fr om the data sources and assumption worksheets ( assembled as the right-most worksheets) toward outputs (produced i n the left -most worksheets).

9A.3 INDIVIDUAL WORKSHEETS IN LCC AND PBP SPREADSHEET

The LCC and PBP spreadsheet consists of the following worksheets.

Instructions – 1 Contains notes from the model developer for spreadsheet users.

Instructions – 2 Contains instructions on how to derive deterministic/sensitivity

and Monte Carlo results.

Trig

. Events, Spcl. Cases Provides details on the compatibility of the fixture, ballast, and lamp -failure triggering events with the various purchase options provided in the engineering data. Also discusses regulatory special

9A -1cases impacting analysis period s or triggering events. S uch cases include fixture or ballast restrictions associated with the Energy Independence and Security Act of 2007 (EISA 2007) or the Energy Policy Act of 2005 (EPAct 2005).

Notes on Simple Paybacks Contains detailed exp lanation of simple payback outputs.

LCC &PBP Choose values of interest from drop-down controls on this sheet. This sheet presents LCC savings and PBP results by HID lamp
system type to produce the results that DOE provides in the notice of proposed determination ( NOPD ) TSD chapter 9. A lso

condenses the information from the Lifetime Costs worksheet for

ease of use.

Information Hub Along with Lifetime Costs, contains many of the core calculations necessary to calculate the LCCs and PBPs. Derivation of residual

values is contained in thi s sheet.

Lifetime Costs Compiles data from several other worksheets to calculate the actual LCC of each HID lamp system. This worksheet also contains assumptions for some equipment lives and market

characteristics.

Engineering Data Contains the engi neering data, as well as several other inputs, including markups, lamp- price category weights, ballast lives, labor rates, and indoor/outdoor percentages.

Discount Rate Derives discount rates for commercial, industrial, and outdoor stationary sector sys tems.

Operating Hours Provides the data and calculations used to develop operating hours for commercial, industrial, and outdoor stationary sectors.

Electricity and Tax Rates Contains data and calculations f or electricity prices over time, and sales tax rates. Also contains economic growth scenario

information.

Monte Carlo

– Lifetimes Contains distributions of fixture, ballast, and lamp lifetimes for use in the Monte Carlo analysis.

9A.4 INDIVIDUAL WORKSHEETS IN MEDIAN PBP SPREADSHEET

The median PBP derivation spreadsheet consists of the following worksheets.

9A -2Instructions – 1 Contains notes from the model developer for spreadsheet users.

Instructions – 2 Contains instructions on how to derive median paybacks.

CB

– LCC Results Provides copies of the Monte Carlo Analysis Mode results for each of the three triggering events. This sheet is a copy of the likenamed sheet in the LCC&PBP spreadsheet.

CB

– LampEvent Stats Contains selected, sorted PBP columns from the like- named sheet in the LCC&PBP spreadsheet.

CB

– BallastEvent Stats Contains selected, sorted PBP columns from the like- named sheet in the LCC&PBP spreadsheet.

CB

– FixtureEvent Stats Contains selected, sorted PBP columns from the like- named sheet in the LCC&PBP spre adsheet.

Shares for Application Contains a copy of the information in the like -named sheet in the LCC&PBP spreadsheet. Provides shares structured for use in the aggregation process.

Payback Derivation Utiliz es Monte Carlo analysis to derive median payb acks for impacted customers, by product class and TSL.

9A -3APPENDIX 9B. ESTIMATION OF POTENTIAL EQUIPMENT PRICE TRENDS FOR

HIGH

- INTENSITY DISCHARGE LAMPS

TABLE OF CONTENTS

9B.1 INTRODUCTION .........................................................................................................9B-1

9B.2 EXPERIENCE CURVE APPROACH ..........................................................................9B-1

9B.3 AEO PRICE TREND APPROACH ...............................................................................9B-3

LIST OF TABLES

Table 9B.3.1 Price Factors for High -Intensity Discharge Lamps and Related Equipment .......9B-3

LIST OF FIGURES

Figure 9B.2.1 PPI Data for High-Intensity Discharge Lamps and Related Equipment ............9B-2

9B -iAPPENDIX 9 B. ESTIMATION OF POTENTIAL EQUIPMENT PRICE TRENDS FOR

HIGH

- INTENSITY DISCHARGE LAMPS

9B.1 INTRODUCTION

In its previous n otice of d ata a vailability (NODA) , 76 FR 9696 (Feb. 22, 2011), the U.S. Department of Energy ( DOE ) stated that it may consider improving regulatory analysis by addressing equipment price trends. Consistent with the NODA, DOE examined historical

p roducer price indices (PPI) for high -intensity discharge (HID) lamps, ballasts, and fixtures and found both positive and negative real price trends depending on the time period examined. Therefore, in the absence of a definitive trend, DOE decided to use p rice deflators from the U.S. Energy Information Administration’s (EIA) Annual Energy Outlook 2013 ( AEO20 13 ) to adjust equipment prices over the analysis period.

The following paragraphs briefly describe the experience curve approach and deflator approach and the reasons why the latter was adopted.

9B.2 EXPERIENCE CURVE APPROACH

DOE state d in the NODA that e xamination of historical price data for certain appliances and equipment that have been subject to energy conservation standards indicates that the assumption of constant real prices and costs may, in many cases, overestimate long- term appliance and equipment price trends. Economic literature and historical data suggest that the

real costs of these products may in fact trend downward over time according to “learning” or “experience” curves , or alternatively that the price trends for certain sectors of the U.S. economy may be different than the price trends for the economy as a whole. A draft paper

, “Using the Experience Curve Approach for Appliance Price Forecasting ,” posted on the DOE website at http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/experience_curve_appliance_p rice_forecasting_3 -16-11.pdf , provides a summary of the data and literature currently available to DOE that is relevant to price forecasts for selected appliances and equipment.

The extensive literature on the “learning” or “experience” curve phenomenon is typically based on observations in the manufacturing sector. a In the experience curve method, the real cost of production is related to the cumulative production or “experience” with a manufactured product. A common fun ctional relationship used to model the evolution of production costs in

this case is :

Y = aX - b

Eq. 9B .1

W here :

a is an initial price (or cost),

b is a positive constant known as the learning rate parameter,

a In addition to the draft paper mentioned above, see Weiss, M., H.M. Junginger, M.K. Pat el, and K. Blok. A Review

of Experience C urve Analyses for Energy Demand T echnologies. Technological Forecasting & Social Change

. 2010. 77:411

- 428

.

9B -1X is cumulative production, and

Y

is the price as a function of cumulative production.

Thus, as experience (production) accumulates, the cost of prod ucing the next unit decreases. The percentage reduction i n cost that occurs with each doubling of cumulative production is known as the learning rate (LR), given by:

LR = 1 – 2 - b

Eq. 9B .2

In typical learning curve formulations, the learning rate parameter is derive d using two historical data series: cumulative production and price (or cost).

DOE examined h istorical price s using the Bureau of Labor Statistics’ PPI and gross domestic product ( GDP ) deflator, available from the Bureau of Economic Analysis. The PPI dat a for industrial- type electric lighting fixtures, including parts and accessories

, are available for

1987–2010 and are us ed to represent aggregate industrial lighting system prices. Figure 9B.2 .1

shows this PPI data series

.

Inflation -adjusted price indices were calculated by dividing the PPI series by the GDP

deflator for the same years . The GDP deflator was used as opposed to the Consumer P rice I ndex because nearly all HID lamp s and related equipment are shipped to commercial and industrial

customers.

Figure 9B.2.1 PPI D ata for High

- Intensity Discharge Lamps and Related Equipment

Figure 9B.2 .1 shows an apparent price trend in lighting equipment that is trending downward from 1987 to 2005, but shows an increase in the real PPI from 2005 to 2010. Given the presence of both positive a nd negative real price trends, DOE elected to not use the experience curve approach to adjust equipment prices.

0.5 0.6 0.7 0.8 0.9

1 1.1 1.2 1.3

1985 1990 1995 2000 2005 2010

PPI for industrial

- type electric lighting fixtures, including parts and

accessories

9B -29B.3 AEO PRICE TREND APPROACH

For this proposed determination , DOE instead used the AEO price trend approach. DOE has access to the forecasted price indexes used by EIA to develop AEO20 13 . The price index projections used in the EIA model are called deflators. The narrowest index that includes HID lamps and related equipment

— the series “Non

- residential investment – Other equipment”— was used. Th is inde x was inflation -adjusted by dividing by the “GDP Deflator” index, also available

from AEO20 13

. The resulti ng factor was reset to 1 in 2010.

The AEO price ind exes begin in 1990 and extend to 2040 . Because the AEO time series does not extend to the end of the analysis period, the forecasted trend was extrapolated for 2041–

2080. Table 9B.3.1 presents the resulting pr ice factors used in the national impact analysis and all downstream analyses for this proposed determination

.

Table 9B.3.1 Price Factors for High

- Intensity Discharge Lamps and Related Equipment

Year Price Factor

2011 0.99

2012 1.00

2013 1.00

2014 1.00

2015 1.00

2016 1.00

2017 1.00

2018 1.00

2019 1.00

2020 1.00

2021 0.99

2022 0.99

2023 0.99

2024 0.98

2025 0.98

2026 0.98

2027 0.97

2028 0.97

2029 0.96

2030 0.96

2031 0.96

2032 0.95

2033 0.95

2034 0.94

2035 0.94

2036 0.94

2037 0.93

2038 0.93

2039 0.93

2040 0.92

2041 0.92

2042 0.91

2043 0.91

2044 0.91

2045 0.90

9B -3Table 8.B.3.1 (cont.)

Year Price Factor

2046 0.90

2047 0.90

2048 0.89

2049 0.89

2050 0.88

2051 0.88

2052 0.88

2053 0.87

2054 0.87

2055 0.87

2056 0.86

2057 0.86

2058 0.86

2059 0.85

2060 0.85

2061 0.84

2062 0.84

2063 0.84

2064 0.83

2065 0.83

2066 0.83

2067 0.82

2068 0.82

2069 0.82

2070 0.81

2071 0.81

2072 0.81

2073 0.80

2074 0.80

2075 0.80

2076 0.79

2077 0.79

2078 0.79

2079 0.78

2080 0.78

9B -4APPENDIX 11A. USER INSTRUCTIONS FOR SHIPMENTS AND NATIONAL

IMPACT ANALYSIS SPREADSHEETS

TABLE OF CO NTENTS

11A.1 INTRODUCTION ...................................................................................................... 11A-1

11A.2 INDIVIDUAL MODEL WORKSHEETS .................................................................. 11A-1

11A -iAPPENDIX 11A. USER INSTRUCTIONS FOR SHIPMENTS AND NATIONAL

IMPACT ANALYSIS SPREADSHEET S

11A.1 INTRODUCTION

The results obtained for the shipments analysis and national impact analysis (NIA) can be examined and reproduced using Microsoft Excel spreadsheets available on the U.S. Department of Energy (DOE) Building Technologies website at : www1.eere.energy.gov/ buildings/appliance_standards/product.aspx/productid/60

.

Th e NIA spreadsheet performs calculations of the national energy savings (NES, i.e. , the change in national energy use from the base to standards cases) and the net present values (NPV s ) from potential energy conservation standards. The energy use and associated costs for a given efficacy level (EL) are determined by calculating the energy use and costs for all equipment shipped under that EL . The differen ces between the standards and base cases can then be compared , and the overall NES and NPV determined.

11A.2 INDIVIDUAL MODEL WORKSHEETS

There are several worksheets in the NIA workbook , as listed and described below.

Instructions Contains instructions on how to use the model

Output Consolidates the NES and NPV values into a convenient format for output to text tables

Formats Contains critical formats for use elsewhere in the model

Raw Shipments Contains shipments in raw form, to be reformatted and used

elsewhere in the model

Base Shipments Contains shipments by equipment class and EL in the absence of

new or amended standards

Base Stock Contains the present and future national stock of high

- intensity discharge ( HID ) lamps in the absence of a po tential standard

St Shipments Contains shipments by equipment class and EL for different

standard levels

St Stock Contains the present and future national stock of HID lamps for

different standard levels

Scenario Contains matrices for determining how equipment changes among

EL s

11A -1NES Inputs Contains energy use and other information for use in the NES

calculations

N PV Inputs Contains values for calculating NPV

NES Contains NES calculations

NPV Combines operating cost savings from “Oper Costs” tab and installed costs increase from “Inst Costs” tab to compute NPVs for

both 3- and 7- percent discount rates

Oper Costs Computes operating costs for all Roll scenarios

Inst Costs Computes installed costs for all Roll scenarios based on the data from tabs “Percentages

, ” “Fixt inst

, ” “Ball inst ,” and “Lamp inst”

Percentages Contains percentages for the lamps shipments that are associated with fixture installations, ballasts installations or lamp installations

for each EL

Fixt inst Contains fixture installed costs for all equipment classes and analysis years

Ball inst Contains ballast installed costs for all equipment classes and analysis years

Lamp inst Contains fixture installed costs for all equipment classes and analysis ye ars

11A -2APPENDIX 11B. FULL

- FUEL

- CYCLE MULTIPLIERS

TABLE OF CONTENTS

11B.1 INTRODUCTION .......................................................................................................11B-1

11B.2 METHODOLOGY ......................................................................................................11B-1

11B.3 FU LL

- FUEL

- CYCLE ENERGY MULTIPLIERS .....................................................11B-3

REFERENCES ........................................................................................................................11B-4

LIST OF TABLES

Table 11B.2.1 Dependence of FFC Parameters on AEO Inputs ..............................................11B-3

Table 11B.3.1 Full Fuel Cycle Energy Multipliers (Based on AEO2013 ) ..............................11B-3

11B -iAPPENDIX 11B. FULL

- FUEL

- CYCLE MULTIPLIERS

11B.1 INTRODUCTION

This appendix summarizes the methods used to calculate full- fuel

- cycle (FFC) energy savings expected to result from potential standards. The FFC measure includes point-of- use (site) energy; the energy losses associated with generation, transmission, and di stribution of electricity; and the energy consumed in extracting, processing, and transporting or distributing primary fuels. The U.S. Department of Energy’s ( DOE’s ) traditional approach encompassed only site energy and the energy losses associated with generation, transmission, and distribution of electricity. Per DOE’s

2011 Statement of Policy for Adopting Full Fuel Cycle Analyses , DOE now uses FFC measures of energy use and emissions in its energy conservation standards analyses. 76 FR 51281 (Aug. 18, 2011), as amended at 77 FR 49701 (Aug. 17, 2012)

. This appendix summarizes the methods used to incorporate the FFC impacts into the analysis.

This analysis uses several different terms to reference energy use. The physical sources of

energy are the primary fuels such as coal, natural gas, and liquid fuels. Primary energy is equal to the heat content ( British thermal units ) of the primary fuels used to provide an end- use service. Site energy use is defined as the energy consumed at the point-of-use in a building or industrial process. Where natural gas and petroleum fuels are consumed at the site (for example

, in a furnace), site energy is identical to primary energy, with both equal to the heat content of the primary fuel consumed. For electricit y, site energy is measured in kilowatt -hours. In this case,

the primary energy is equal to the quadrillion British thermal units ( quads) of primary energy required to generate and deliver the site electricity. This primary energy is calculated by multiplying the site kilowatt -hours by the site

- to

- power plant energy use factor

, given in chapter 11 of the technical support document. For the FFC analysis, the upstream energy use is defined as the energy consumed in extracting, processing, and transporting or d istributing primary fuels. FFC energy use is the sum of primary plus upstream energy use.

Both primary fuels and electricity are used in upstream activities. The treatment of electricity in fuel cycle analysis must distinguish between electricity generated by fossil fuels and uranium, and electricity generated from renewable fluxes (wind, solar, and hydro). For the former, the upstream fuel cycle impacts are derived from the amount of fuel consumed at the power plant. For the latter, no fuel per se is used, so there is no upstream component.

11B.2 METHODOLOGY

The mathematical approach is discussed in the paper A Mathematical Analysis of Full Fuel Cycle Energy Use

, 1 and details on the fuel production chain analysis are presented in the

paper Projections of Full Fuel Cycle Energy and Emissions Metrics

. 2 The text below provides a brief summary of the methods used to calculate FFC energy.

When all energy quantities are normalized to the same units, the FFC energy use can be represented as the product of the p rimary energy use and an FFC multiplier. The FFC multiplier is defined mathematically as a function of a set of parameters representing the energy intensity and material losses at each production stage. These parameters depend only on physical data, so the calculations do not require any assumptions about prices or other economic data. While in

11B -1general these parameter values may vary by geographic region, for this analysis national averages are used.

In the notation below, the indices x and y are used to i ndicate fuel type, with x=c for coal, x=g for natural gas, x=p for petroleum fuels, x=u for uranium, and x=r for renewable fluxes. The fuel cycle parameters are as follows :

• a x is the quantity of fuel x burned per unit of electricity output, on average, fo r grid electricity; t he calculation of a x includes a factor to account for transmission and distribution system losses;

• b y is the amount of grid electricity used in production of fuel y, in megawatt -hours per physical unit of fuel y;

• c xy is the amount of fuel x consumed in producing one unit of fuel y;

• q x is the heat content of fuel x ( million British thermal units/physical unit) ;

• z x (s) is the emissions intensity for fuel x (mass of pollutant s per physical unit of x)

.

The parameters are calculated as a function of time with an annual time step; hence, a time series of annual values is used to estimate the FFC energy and emissions savings in each year of the analysis period. Fossil fuel quantities are converted to energy units using the heat

content fac tors q x . To convert electricity in kilowatt -hours to primary energy units, on- site electricity consumption is multiplied by the site

- to -power plant energy use factor. The site- to

power plant energy use factor is defined as the ratio of the total primary en ergy consumption by the electric power sector (in quads ) divided by the total electricity generation in each year.

The FFC multiplier is denoted μ (mu). A separate multiplier is calculated for each fuel used on site. A multiplier is also calculated for electricity reflecting the fuel mix used in its generation. The multipliers are dimensionless numbers that are applied to primary energy savings to obtain the FFC energy savings. The upstream component of the energy savings is proportional to (μ-1). The fuel type is denoted by a subscript on the multiplier μ.

For DOE’s appliance standards energy savings estimates, the fuel cycle analysis methodology is designed to make use of data and projections published in the Annual Energy

Outlook (

AEO ). Table 11B.2.1 provides a summary of the AEO data used as inputs to the different parameter calculations. The AEO does not provide all the information needed to estimate total energy u se in the fuel production chain. Reference 2 describes the additional data sources used to complete the analysis. However, the time dependence in the FFC multipliers arises exclusively from variables taken from the AEO . The FFC analysis for the high-intens ity discharge lamps rulemaking used data from AEO201 3

. 3

11B -2Table 11B.2.1 Dependence of FFC Parameters on AEO Inputs

Parameter Fuel AEO Table Variables

qx all Conversion Factors MMBtu per physical unit

ax all Electricity Supply, Disposition, Prices, and Emissions Generation by fuel type

Energy Consumption by Sector and Source Electric power sector energy consumption

bc, cnc, cpc coal Coal Production by Region and Type Production by coal type

and sulfur content

bp, cnp, cpp petroleum Refining Industry Energy Consumption Refining only energy use Liquid Fuels Supply and Disposition Crude supply by source International Liquids Supply and Disposition Crude oil imports

Oil and Gas Supply Crude oil domestic production

cnn natural

gas Oil and Gas Supply U

. S

. dry gas production

Natural Gas Supply, Disposition and Prices Pipeline, lease

, and plant

fuel

zx all Electricity Supply, Disposition, Prices and Emissions Power sector emissions

11B.3 F ULL

- FUEL

- CYCLE ENERGY MULTIPLIERS

FFC energy multipliers are presented in Table 11B.3.1 for selected years. To extend the analysis period beyond 2040 , the last year in the AEO2013 projection , the multipliers are assumed constant through the final year of the analysis period. The multiplier for electricity reflects the shares of various primary fuels in total electricity generation over the forecast period.

Table 11B.3.1 Full Fuel Cycle Energy Multipliers (Based on AEO2013 )

2015 2020 2025 2030 2035 2040 Electricity (power plant primary energy use) 1.042 1.041 1.040 1.040 1.041 1.04 0

Natural Gas (site) 1.103 1.10 1 1.100 1.09 8 1.09 9 1.100

Petroleum Fuels (site) 1.1 32 1.14 0 1.148 1.1 58 1.1 66 1.1 68

11B -3REFERENCES

1. Coughlin, K. A Mathematical Analysis of Full Fuel Cycle Energy Use . Energy . 2012. 37(1): pp. 698–708. < www.sciencedirect.com/science/article/pii/S0360544211006803 >.

2. Coughlin, K. Projections of Full- Fuel -Cycle Energy and Emissions Metrics . 2013. Lawrence Berkeley National Lab oratory: Berkeley, CA. Report No. LBNL -6025E.

3. U.S. Department of Energy

- Energy Information Administration. Annual Energy Outlook 2013 with Projections to 2040 . 2013. EIA: Washington, D.C.

< www.eia.gov/forecasts/archive/aeo13/index.cfm >.

11B -4APPE NDIX 12A MANU F ACTURER IMPACT ANA LYSIS INTERVIEW GUID E

TABLE OF CONTENTS

12A.1 MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDE FOR HIGH

I NTENSITY DISCHARGE L AMPS

........................................................................ .. 12A- 1

12A.2 MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDE FOR HIGH

I NTENSITY DISCHARGE L AMPS ( FIXTURE M ANUFACTURERS)

................ 12A- 22

12A.3 SMALL BUSINESS MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDE

FOR HI GH INTENSITY DISCHARGE L AMPS

..................................................... 12A- 35

12A- i12A.1 MANUFACTURER I MPACT ANALYSIS INTERVIEW GUIDE FOR HI GH

INTENSITY DISCHARGE LAMP S

June 2013

12A -1Purpose: To gather information on the U.S. high- intensity discharge lamp market to assist in the Department of Energy’s energy conservation standards analysis.

Method: Navigant Consulting, Inc. (Navigant) is circulating this interview guide to a limited number of manufacturers of high-intensity discharge lamps who operate in the U.S. market. Navigant will

combine all the responses from individual manufacturers to protect proprietary information of any one manufacturer. Individual responses to this questionnaire and any other data provided will all be covered under a non-disclosure agreement, which Navigant will enter into with each participating manufacturer. Navigant will handle all individual company data in the strictest

confidence.

If you have any questions, please contact:

Matthew Walker Navigant Consulting, Inc.

mat thew.walker@navigant.com

Tel: 202.481.8482

Fax: 202.973.2401 The U.S. Department of Energy (DOE) is conducting a manufacturer impact analysis (MIA) as part of the rulemaking process to set energy conservation standards for high- intensity discharge lamps (H ID lamps). In this analysis, DOE uses publicly available information and information provided during interviews to assess possible impacts on manufacturers due to energy conservation standards. DOE began the rulemaking process with the publication of a framework document, followed by a publication of an interim analysis. Both can be found at: http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23

.

1 SCOPE

1.1 Specialty Application

– Base Type. For the NOPR, DOE is considering defining a specialty application lamp as any quartz metal halide (MH) or mercury vapor (MV) lamp that

has a non- screw base . Do you agree with this definition? Why are lamps used in specialty applications typically non

- screw

- base lamps? What percentage of market share are the screw

base lamp types, in terms of shipments? Do non- screw -base lamps have unique photometric

characteristics?

1.2 Specialty Application

– St age/Studio. Do stage and studio lamps (and other specialty lamps) have unique photometric characteristics? What differs between a stage and studio lamp and a lamp of equivalent CCT advertised for general applications? Are any general use lamps

used in stag e/studio applications?

1.3 High

- CRI MH Lamps. Are there applications for which customers would specifically

12A-2require high- CRI quartz MH lamps? Are there any technical differences between high

- CRI quartz MH lamps and high- CRI CMH lamps?

1.4 Double

- ended Lamps. DOE received comments that double -ended lamps should be

excluded from consideration for standards. Do double-ended lamps provide a unique utility or specialty use or have unique photometric characteristics? What portion of your shipments are double-ended lamps?

1.5 F-rated Lamps. DOE found that along with enclosed-rated, open-rated, and S- rated , MH lamps can also be classified as F -rated according to ANSI standard C78.380-2007. Why are there

no alternatives to F

- rated lamps for some applications? Is there a technical difference in the efficacy potential of F- rated lamps compared to enclosed

- rated lamps ?

1.6 Sports Lighting. High wattage (≥1000 W) lamps are often advertised as sports lights, though many are also listed as general application lamps. DOE also found that sometimes certain lamp models appear both in the ‘sports lighting’ and ‘general application’ parts of manufacturer catalogs. Do lamps listed for sports lighting differ from general application lamps of equivalent wattage? If yes, please explain.

2 MARKET AND TECHNOLOG Y ASSESSMENT

2.1 CMH Lamp Availability. DOE found that CMH lamps are almost exclusively available at and below 400 W. Is there a technical reason that CMH lamps are not offered above 400 W? Are you looking to expand your CMH availability to include higher wattages now or in the future? If so, please describe the expected product offerings.

2.2 Pulse MH Lamp Availability. DOE found that pulse- start MH lamps are only available at and below 1000 W. Is there a technical reason that pulse- start MH lamps are not offered above 1000 W? Are you looking to expand your pulse- start MH availability to include higher wattages now or in the future? If so, please describe the expected product offerings.

2.3 Unsaturated CMH Lamps. Unsaturated CMH lamps (lamps that do not have a liquid salt pool during steady- state operation) have been identified as a possible option for improving the efficacy of traditional CMH lamps. Are any of your CMH lamps unsaturated? If so, which

models?

2.4 Quartz MH Lamp Initial Efficacy. DOE received feedback on the interim analysis that there is no difference in initial efficacy between probe -start and pulse- start MH lamps. Does the presence of the third electrode in probe- start lamps affect the maximum achievable efficacy for these products? If so, please explain.

2.5 Quartz MH Lamp Initial Efficacy. Initial efficacy for quartz MH lamps varies widely, particularly at medium wattages (150 to 400 W). What design options account for this range (arc

- tube fill gas, arc tube shape, arc tube mater ial quality, etc.)?

12A-32.6 Probe MH Lamp Efficacy. Probe-start MH lamps above 1000 W have a large range of initial efficacies available (from below 100 lm/W to above 120 lm/W). What characteristics or features of probe-start MH lamps above 1000 W account for th is range in efficacy?

3 ENGINEERING

3.1 Catalog Data. What do the values of initial efficacy in catalogs represent? Do they represent long

- term average data?

3.2 Retrofit Kit Compatibility. Ballast retrofit kits include a ballast, bracketing, screws, a capacitor and/or igniter, and some wiring. Lamp and ballast retrofit kits also include a lamp (and sometimes a socket) . What are the shipments of these types of products compared to lamps-only? Do customers also create their own retrofit kit by purchasing a ballast & bracket, lamp, and socket separately? For which situations would a new socket be required? How do customers identify a retrofit kit that will fit properly in their fixture?

3.3 Retrofit Lamps. DOE found a number of lamps designed as retrofits for existing

b allasts. This retrofit pairs a reduced wattage lamp with a full wattage ballast (e.g., a 360 W lamp that operates on a 400 W ballast). Are there technical difficulties for manufacturing these lamps at all wattages ? How does the performance of a ballast ope rating a retrofit lamp compare to a ballast operating a full wattage lamp ?

3.4 Retrofit Kit Customer Adoption. For which lamp technologies and wattage ranges do

customers currently utilize retrofit kit s? What prompts a customer to purchase a retrofit kit?

Ene rgy conservation standards may limit the availability of certain HID lamps. Do you expect the use of retrofit kits to change in response to standards? If so, please explain.

3.5 Customer Response to Standards. For Table 1-1 below, indicate the expected customer response to lamp standards.

12A-4Table 1-1 Customer Response to Standards
Percentage of Customers (%) Equipment Class Equal Wattage Lamp Replacement Reduced Wattage Lamp and Ballast

Retrofit Reduced Wattage Replacement Lamp, Ballast, and

Fixture Reduced Wattage Retrofit Lamp

1900

- 2 8 00K, 50

- 1000W *

2 8 01

- 4500K, 50

- 400W **

2 8 01

- 4500K, 401

- 1000W †

2 8 01

- 4500K, 1001

- 2000W ††

Other subcategories

* Refers to lamps ≥1900K and ≤2800K; ≥50W and ≤1000W ** Refers to lamps ≥2800K and ≤4500K; ≥50W and ≤400W † Refers to lamps ≥2800K and ≤4500K; >400W and ≤1000W †† Refers to lamps ≥2800K and ≤4500K; > 1000W and ≤2000W

3.6 Lamp

- Ballast Retrofit Kit Pricing. Can the price of a lamp and ballast retrofit kit be estimated by summing the individual prices of a lamp, ballast , bracket, and socket? Do the distribution channel markups differ between retrofit products and individual lamps or ballasts?

3.7 Engineering and Price Results. shows DOE’s preliminary engineering results for each equipment class. Are the lamp end

- user prices appropriate for the efficacy levels?

12A-5Table 1-2 Engineering Summary and Lamp End

- User Prices

Rep. Lamp Type* EL Lamp Type Wattage Initial Efficacy (lm/W) Lamp End

- User Prices

Low Medium High

70 W

HPS Baseline HPS 70 90.0 $ 15.43 $ 21.16 $ 26.88

EL 1 Sapphire HPS 67 93.9 $ 46.29 $ 63.47 $ 80.65

100 W

HPS Baseline HPS 100 95.0 $ 21.91 $ 30.04 $ 38.17

EL 1 Sapphire HPS 96 99.2 $ 65.74 $ 90.13 $ 114.52

250 W

HPS Baseline HPS 250 108.0 $ 21.78 $ 29.86 $ 37.94

EL 1 Sapphire HPS 240 112.7 $ 65.33 $ 89.58 $ 113.82

400 W

HPS Baseline HPS 400 117.5 $ 22.38 $ 30.68 $ 38.98

EL 1 Sapphire HPS 383 122.6 $ 67.13 $ 92.04 $ 116.95

1000 W

HPS Baseline HPS 1000 130.0 $ 54.37 $ 74.54 $ 94.71

EL 1 Modeled HPS 958 135.7 $ 163.10 $ 223.62 $ 284.14

100 W

MV Baseline MV 100 40.0 $ 13.82 $ 18.95 $ 24.07

EL 1 N/A

-- -- -- -- -- Baseline MH/EL 2 Pulse MH 70 78.6 $ 15.29 $ 20.97 $ 26.64

EL 3 CMH 50 82.0 $ 16.55 $ 22.70 $ 28.84

175 W

MV Baseline MV 175 44.6 $ 8.66 $ 11.87 $ 15.09

EL 1 N/A

-- -- -- -- -- Baseline MH/EL 2 Pulse MH 100 81.0 $ 17.94 $ 24.60 $ 31.26

EL 3 CMH 70 102.9 $ 38.78 $ 53.17 $ 67.56

250 W

MV Baseline MV 250 50.0 $ 15.49 $ 21.24 $ 26.99

Baseline MH/ EL 1 Probe MH 175 77.1 $ 16.34 $ 22.40 $ 28.47

EL 2 Pulse MH 150 88.7 $ 19.85 $ 27.22 $ 34.59

EL 3 CMH 100 95.0 $ 33.38 $ 45.77 $ 58.15

400 W

MV Baseline MV 400 57.5 $ 14.64 $ 20.07 $ 25.50

Baseline MH/ EL 1 Probe MH 250 88.0 $ 16.66 $ 22.85 $ 29.03

EL 2 Pulse MH 200 95.0 $ 26.54 $ 36.39 $ 46.24

EL 3 CMH 150 100.0 $ 36.82 $ 50.48 $ 64.14

400 W

MH Baseline N/A

-- -- -- -- -- Baseline/EL 1 Probe MH 400 90.0 $ 22.39 $ 30.70 $ 39.01

EL 2 Pulse MH 320 93.8 $ 29.33 $ 40.22 $ 51.10

EL 3 CMH 250 100.0 $ 45.37 $ 62.20 $ 79.03

1000 W

MV Baseline MV 1000 59.0 $ 33.20 $ 45.52 $ 57.83

EL 1 N/A

-- -- -- -- -- EL 2 Pulse MH 750 100.0 $ 52.63 $ 72.16 $ 91.70

1000 W

MH Baseline N/A

-- -- -- -- -- Baseline/EL 1 Probe MH 1000 105.0 $ 44.98 $ 61.67 $ 78.37

EL 2 Pulse MH 875 109.7 $ 60.94 $ 83.55 $ 106.17

2000 W

MH Baseline Probe MH 2000 85.0 $ 70.65 $ 96.87 $ 123.09

EL 1 Probe MH 1500 103.3 $ 53.61 $ 73.50 $ 93.39
*All lamps listed are in the representative equipment classes. All high

- pressure sodium (HPS) lamps are in the ≥1900 K and ≤2800 K, clear, enclosed

- rated class; all the MH and MV lamps are >2800 K and ≤4500 K, clear, and

enclosed

- rated classes.

12A-63.8 Lamp End

- User Price Discount Factors

. DOE estimated the end

- user prices listed in

Table 1-2 by applying discounts off of manufacturer price lists (blue books). Are the discounts

listed in Table 1-3 accurate?

Table 1-3 Lamp End

- User Discounts off of Blue Book Prices

End

- User Category Discount

State Procurement (High Volume) 81.8%

Distributor (Medium Volume) 75.0%

Internet Retailer (Low Volume) 68.2%

3.9 Lamp MSP Calculation. In the interim analysis, DOE put forward an approach for estimating lamp manufacturer selling price (MSP). DOE would apply a discount of 1.15 to the

low end-use r price to calculate MSP. Do you agree with this estimate?

3.10 Max Tech. Can the efficacy of HID lamps be increased beyond the commercially

available levels identified in Table 1-4 ? What is the maximum technologically feasible efficacy for HPS and MH lamps? What are the associated costs and design pathways required?

Table 1-4 Max Tech Levels

Equipment Class Max

Tech Efficacy Wattage Corresponding

to Max Tech Efficacy Cost and Design Pathways to Reach

Max Tech

1900

- 2 8 00 K, 50

- 1000 W

2 8 01

- 4500 K, 50

- 400 W

2 8 01

- 4500 K, 401

- 1000 W

2 8 01

- 4500 K, 1001

- 2000 W

3.11 Proprietary Technology. Do any of the efficacy levels or max tech designs require the use of proprietary technology?

3.12 Ballast MSPs. Table 1-5 shows the MSPs determined by DOE for each ballast type and wattage. Are the ballast MSPs appropriate for the wattages and technologies?

12A-7Table 1-5 HID Ballast MSPs

Lamp and Ballast Characteristics Ballast MSPs

CCT EL Lamp Type Wattage (W) Efficiency* (%) Indoor Outdoor

1900

- 2800 K Baseline HPS 70 77 $ 30.35 $ 30.35

EL 1 Modeled HPS 67 77 $ 30.35 $ 30.35

Baseline HPS 100 78 $ 31.76 $ 31.76

EL 1 Modeled HPS 96 78 $ 31.76 $ 31.76

Baseline HPS 250 84 $ 51.05 $ 51.05

EL 1 Modeled HPS 240 84 $ 51.05 $ 51.05

Baseline HPS 400 86 $ 57.62 $ 57.62

EL 1 Modeled HPS 383 86 $ 57.62 $ 57.62

Baseline HPS 1000 92 $ 79.44 $ 79.44

EL 1 Modeled HPS 958 92 $ 79.44 $ 79.44

2801

- 4500 K Baseline MV 100 83 $ 25.15 $ 25.15

EL 1 N/A

-- -- -- -- Baseline MH/EL 2 Pulse MH 70 72 $ 29.15 $ 29.15

EL 3 CMH 50 89 $ 32.09 $ 30.89

Baseline MV 175 85 $ 27.47 $ 27.47

EL 1 N/A

-- -- -- -- Baseline MH/EL 2 Pulse MH 100 77 $ 40.96 $ 40.96

EL 3 CMH 70 90 $ 34.70 $ 33.50

Baseline MV 250 87 $ 34.14 $ 34.14

Baseline MH/ EL 1 Probe MH 175 88 $ 46.34 $ 46.34

EL 2 Pulse MH 150 81 $ 45.15 $ 45.15

EL 3 CMH 100 90 $ 43.04 $ 41.84

Baseline MV 400 89 $ 38.80 $ 38.80

Baseline MH/ EL 1 Probe MH 250 88 $ 45.55 $ 45.55

EL 2 Pulse MH 200 88 $ 49.64 $ 49.64

EL 3 CMH 150 90 $ 49.31 $ 48.11

Baseline N/A

-- -- -- -- Baseline/EL 1 Probe MH 400 88 $ 35.45 $ 35.45

EL 2 Pulse MH 320 88 $ 42.33 $ 42.33

EL 3 CMH 250 92 $ 87.60 $ 86.40

Baseline MV 1000 92 $ 94.99 $ 94.99

EL 1 N/A

-- -- -- -- EL 2 Pulse MH 750 91 $ 59.09 $ 59.09

Baseline N/A

-- -- -- -- Baseline/EL 1 Probe MH 1000 92 $ 57.66 $ 57.66

EL 2 Pulse MH 875 90 $ 63.04 $ 63.04

Baseline Probe MH 2000 95 $ 95.47 $ 95.47

EL 1 Probe MH 1500 92 $ 64.06 $ 64.06

* CMH lamps are paired with an electronic ballast. All other lamps are paired with magnetic ballasts.

3.13 Scaling . DOE updated its database of lamps and expanded its dataset for the scaling

12A-8calculation to include pairs of lamps from non- representative equipment classes. Based on these revisions, DOE found the scaling factor to from 2800-4500 K lamps to 4501-7000K lamps to be 17.8%. NEMA commented that the scaling factor should be 25%. How was the 25%

recommendation determined?

4 KEY ISSUES

4.1 In general, what are the key issues for your company regarding energy conservation standards and this rulemaking?

4.2 Do any of these issues become particularly significant at a specific efficiency level or for a specific equipment class?

12A-9Table 1-6 Equipment Class Summary

CCT Range Wattage Bulb

Finish * Luminaire

Characteristic**

1900

- 2800 K 50

- 1000 W Clear Enclosed
Open

Coated Enclosed
Open

2801

- 4500 K 50

- 400 W Clear Enclosed
Open

Coated Enclosed

Open

401

- 1000 W Clear Enclosed
Open

Coated Enclosed
Open

1001

- 2000 W Clear Enclosed
Open

Coated Enclosed
Open

4501

- 7000 K 50

- 400 W Clear Enclosed
Open

Coated Enclosed

Open

401

- 1000 W Clear Enclosed

Open

Coated Enclosed
Open

1001

- 2000 W Clear Enclosed
Open

Coated Enclosed
Open

* MV lamps regardless of bulb finish are placed in the clear equipment classes for their respective wattage and CCT. ** MV and HPS lamps are placed in the enclosed equipment classes for their respective wattage

and CCT.

12A-105 COMPANY OVERVIEW AND ORGANIZATIONAL CHARACTERISTICS

DOE is interested in understanding manufacturer impacts at the plant or profit center level directly pertinent to HID lamp production. However, the context within which the plant operates and the details of plant production and costs are not always readily available from public sources. Therefore, DOE invites you to provide these details confidentially in your own words to the extent possible and practical. Understanding the organizational setting around the HID lamp industry profit center will help DOE understand the probable future of the manufacturing activity with and without energy conservation standards.

5.1 Do you have a parent company, and/or any subsidiaries relevant to the HID lamp industry?

5.2 What is your company’s app roximate market share of the HID lamp market? Does this vary significantly for any particular equipment class that you manufacture?

5.3 Do you manufacture any products other than HID lamps? If so, what other products do you manufacture? What percentage of your total manufacturing revenue corresponds to HID lamps?

5.4 Please complete Table 1-7 to the best of your ability for your company. If possible, please express revenue i n both dollar amount and in percentage of HID lamp sales. Additionally, please express shipments in both volume and percentage of all HID lamp shipments. Please indicate if you do not manufacture products in any given equipment class.

12A-11Table 1-7 HID Lamp Revenue and Shipment Volumes

Lamp Technology Rated Lamp Wattage 2012 Revenue ($) (%) 2012 Shipments (volume) (%)

HPS 50

- 1000 W

MV 50

- 400 W

MV 401

- 1000 W

Probe (quartz) MH 50

- 400 W

Probe (quartz) MH 401

- 1000 W

Probe (quartz) MH 1001

- 2000 W

Pulse (quartz) MH 50

- 400 W

Pulse (quartz) MH 401

- 1000 W

Pulse (quartz) MH 1001

- 2000 W

CMH 50

- 400 W

CMH 401

- 1000 W

CMH 1001

- 2000 W

6 MARKUPS AND PROFITABILITY

One of the primary objectives of the MIA is to assess the impact of energy conservation standards on industry profitability. In this section, DOE would like to understand the current markup structure of the industry and how energy conservation standards would impact your company’s markup structure and profitability.

DOE defines manufacturer production cost as all direct costs associated with manufacturing a product: direct labor, direct materials, and overhead (which includes depreciation). Themanufacturer markup is a multiplier applied to manufacturer production cost to cover nonproduction costs, such as SG&A and R&D, as well as profit. Some manufacturers also refer to this as gross margin. It does not reflect a “profit ma rgin.”

The manufacturer production cost times the manufacturer markup equals the manufacturer selling price. Manufacturer selling price is the price manufacturers charge their first customers, but does not include additional costs along the distribution channels.

6.1 Is the 1.53 baseline markup representative of an average industry markup for HID lamps?

6.2 Please comment on the baseline markup DOE calculated as compared to your company’s

12A-12baseline markup for HID lamps. Does this markup vary by lamp wattage or lamp type?

6.3 Does the markup differ for a retrofit kit relative to an individual lamp or ballast?

6.4 Because the market disruption caused by standards can alter the pricing of premium products, DOE is interested in understanding how margins currently change wi th efficacy. Is this markup different than the markup applied to higher efficacy HID lamps? If yes, please provide information about the markups at higher efficacies.

6.5 What factors besides efficacy affect the profitability of HID lamps?

6.6 Do you expect changes in your estimated profitability following an energy conservation standard? If so, please explain why.

7 SHIPMENT PROJECTIONS

Energy conservation standards can change overall shipments by altering product attributes, marketing approaches, product availability, and prices. The industry revenue calculations are based on the shipment projections developed in DOE’s shipments model. The shipments model includes forecasts for the base case shipments (i.e., total industry shipments absent energy conservation standards) and the standards case shipments (i.e., total industry shipments with new energy conservation standards). In its shipment scenarios, DOE intends to model the effect of emerging technologies on the HID market.

7.1 Do you expect characteristics o f HID lamps to change in response to the standards?

7.2 Do you expect your market share to change when higher energy conservation standards

take effect?

7.3 In the base-case (without standards), to which non- HID technologies are existing HID lamp customers transitioning? Do these percentages vary by equipment class? Please provide your responses in Table 1-8

.

12A-13Table 1-8 Base

- Case Shifts to Non -HID Technology

Base

- Case Shipment Percentage (%) Equipment Class Fluorescent LED Other

NC R/R NC R/R NC R/R

1900

- 2 8 00 K, 50

- 1000 W

2 8 01

- 4500 K, 50

- 400 W

2 8 01

- 4500 K, 401

- 1000 W

2 8 01

- 4500 K, 1001

- 2000 W

“NC” means new construction. “R/R” means replacement/renovation.

7.4 Do you expect the market to shift to HID lamps outside of the scope of coverage (e.g., HID lamps at low wattages) in response to standards? If so, please explain.

7.5 Do you expect standards to impact the magnitude of the shift to non- HID lamp technology? Does this standards-induced shift to non-HID technology vary by equipment class? Would a standards-induced shift be expected at all standard levels (EL 1, EL 2, or EL 3)? Please provide your responses in Table 1-9

.

Table 1-9 Standards

- Case Shifts to Non -HID Technology

Standards

- Case Shipment Percentage (%) Equipment Class Fluorescent LED Other

NC R/R NC R/R NC R/R

1900

- 2 8 00 K, 50

- 1000 W

2 8 01

- 4500 K, 50

- 400 W

2 8 01

- 4500 K, 401

- 1000 W

2 8 01

- 4500 K, 1001

- 2000 W

“NC” means new construction. “R/R” means replacement/renovation.

12A-148 FINANCIAL PARAMETERS

Navigant has developed a “strawman” model of the HID lamps industry financial performance called the Government Regulatory Impact Model (GRIM) using publicly available data. However, this public information might not be reflective of manufacturing at the HID lamp profit center. This section attempts to understand the financial parameters for HID lamp manufacturing and how your company’s financial situation could differ from the industry aggregate picture.

8.1 In order to accurately collec t information about HID lamp manufacturing, please compare your financial parameters to the GRIM parameters tabulated below in Table 1-10

.

Table 1-10 Financial Parameters for HID Lamp Manufacturers

GRIM Input Definition Industry

Estimated

Value Your Actual (If Significantly

Different from DOE’s Estimate)

Income Tax Rate Corporate effective income tax paid (percentage

of earnings before taxes, EBT) 26.1%

Discount Rate Weighted average cost of capital (inflation

adjusted weighted average of corporate cost of debt and return on equity) 8.0%

Working Capital Current assets less current liabilities (percentage of revenues) 12.7%

Net PPE Net plant property and equipment (percentage of revenues) 24.2%

SG&A Selling, general, and administrative expenses (percentage of revenues) 19.8%

R&D Research and development expenses (percentage of revenues) 4.2%

Depreciation Amortization of fixed assets (percentage of revenues) 3.7%

Capital Expenditures Outlay of cash to acquire or improve capital assets (percentage of revenues, not including acquisition or sale of business units) 3.5%

Cost of Goods

Sold Includes material, labor, overhead, and depreciation (percentage of revenues) 65.3%

8.2 Do any of the financial parameters in Table 1-10 change significantly based on equipment class? Please describe any differences.

8.3 Do any of the financial parameters in Table 1-10 change for a particular subgroup of manufacturers (e.g. small business manufacturers)? Please describe any differences.

8.4 How would you expect an energy conservation standard to impact any of the financial parameters for the industry?

12A-158.5 Can you please provide the breakdown in the total production costs for HID lamps by the percentage for labor, materials, overhead, and depreciation by filling in Table 1-11 below?

Table 1-11 Breakdown of Total Production Costs for HID Lamps

Labor % of full production costs Materials % of full production costs Overhead % of full production costs Depreciation % of full production costs

9 CONVERSION COSTS

DOE understands that new energy conservation standards may cause your company to incur capital and product conversion costs to redesign existing products and make changes to existing production lines. Understanding the nature and magnitude of the conversion costs is a critical part of the MIA. Depending on their magnitude, the conversion costs can have a substantial impact on the outputs used by DOE to evaluate the industry impacts. The MIA considers two types of co nversion costs:

• Capital conversion costs are one-time investments in plant, property, and equipment (PPE) necessitated by new energy conservation standards. These may be incremental additions to existing PPE or the replacement of existing PPE. Included are expenditures on buildings, equipment, and tooling.

• Product conversion costs are costs related to research, product development, testing, marketing and other costs for redesigning products necessitated by new energy

conservation standards.

Table 1-2 shows the ELs DOE is considering analyzing for this rulemaking. DOE asks a number of questions to understand the nature and magnitude of your expected capital and product

conversion costs. Please refer to Table 1-2 when considering your response to the following questions.

9.1 At your manufacturing facilities, would the design pathways you would choose to meet these ELs be difficult to implement? If so, would your company modify the existing facility or develop a new facility?

9.2 Are there certain design pathways that would require relatively minor changes to existing products? Are there certain efficiency levels where the capital or product conversion costs significantly in crease over the previous efficiency levels? Would your answer change for different equipment classes? Please describe these changes qualitatively.

9.3 For each of the equipment classes shown in Table 1-2 , which ELs could be achieved within existing platform designs and which would result in major product redesigns?

12A-169.4 Please provide estimates for your capital conversion costs for HID lamps by equipment

class in Table 1-12 below. In the description column, DOE is interested in understanding the kinds of changes that would need to be implemented to production lines and production facilities at each efficiency level. Where applicable, please quantify the number and cost of new production equipment, molds, etc., that would be required to implement the specified design changes.

9.5 What level of product development and other product conversion costs would you expect to incur to achieve each of these efficiency levels for each equipment class for HID lamps? Please provide your estimates in Table 1-12 considering such expenses as product development expenses, prototyping, testing, certification, and marketing. In the description column, please describe the assumptions behind the estimates provided.

Table 1-12 Expected Product and Capital Conversion Costs for HID Lamps

Equipment Class EL Total Product

Conversion

Costs Total Capital

Conversion

Costs Description

1900

- 2800 K, 50

- 1000 W Baseline

1

28 01

- 4500 K, 50

- 400 W Baseline

1

2

3

28 01

- 4500 K, 401

- 1000 W Baseline

1

2

28 01

- 4500K, 1001

- 2000 W Baseline

1

10 CUMULATIVE REGULATORY BURDEN Cumulative regulatory burden refers to the burden that industry faces from overlapping effects of new or revised DOE standards and/or other regulatory actions affecting the same product or industry.

10.1 T able 1-13 provides a list of regulations that could affect manufacturers of HID lamps. Please provide any comments on the listed regulations and provide an estimate for your expected compliance cost.

12A-17T able 1-13 Other Regulations Identified by DOE

Regulation Estimated or

Actual Effective Date(s) Expected Expense for Compliance Comments

DOE’s Energy Conservation

Standards for IRL and GSFL July 14, 2012

DOE’s Energy Conservation

Standards for Fluorescent Lamp Ballasts November 14,

2014

EISA 2007 Standards for

General Service Incandescent Lamps (GSIL) 2012

International Energy Efficiency

Standards

Restriction of Hazardous Substances (RoHS)

10.2 Are there any other recent or impending regulations that HID lamp manufacturers face (from DOE or otherwise)? If so, please identify the regulation, the corresponding effective dates, and your expected compliance cost.

10.3 Under what circumstances would you be able to coordinate any expenditure related to these other regulations with new energy conservation standards?

11 DIRECT EMPLOYMENT IMPACT ASSESSMENT

The impact of energy conservation standards on employment is an important consideration in the rulemaking process. This section of the interview guide seeks to explore current trends in HID lamp employment and solicit manufacturer views on how domestic employment patterns might be affected by new energy conservation standards.

11.1 Where are your facilities that produce HID lamps for the United States located? What types of products are manufactured at each location? Please provide annual shipment figures for your company’s HID lamp manufacturing at each location by equipment class in Table 1-14

. Please also provide employment levels at each of these facilities.

12A-18Table 1-14 HID Lamp Manufacturing Facilities

Facility Location Equipment Types

Manufactured Employees Annual Shipments

Example Jackson, TN CMH

50

- 400W pulse MH 650 300,000 CMH 150,000 pulse MH

1

2

3

4

5

11.2 Would your domestic employment levels be expected to change significantly under energy conservation standards? If so, please explain how and why they would change if higher efficiency levels are required.

11.3 Would the workforce skills necessary under energy conservation standards require extensive retraining or replacement of employees at your manufacturing facilities?

11.4 Would energy conservation standards require extensive retraining of your service/field technicians? If so, could you expand on how your service infrastructure would be impacted in general as a result of energy conservati on standards?

12 MANUFACTURING CAPACITY AND NON

- US SALES

12.1 How would energy conservation standards impact your company’s manufacturing capacity?

12.2 For any design changes that would require new production equipment, please describe how much downtime would be required. What impact would downtime have on your business? Are there any design changes that could not be implemented before the compliance date (3 years after publication of the final rule) for certain equipment classes?

12.3 What percentage of your domestic HID lamp sales are produced in the United States?

12.4 What percentage of your U.S. production of HID lamps is exported?

12.5 Are there any foreign companies with North American production facilities?

12A-1912.6 Would amended energy conservation standards impact your domestic vs. foreign manufacturing or sourcing decisions? Is there an efficiency level that would cause you to move existing domestic production facilities outside the U.S.?

13 IMPACT ON COMPETITIO N

Energy conservation standards can alter the competitive dynam ics of the market. This can include prompting companies to enter or exit the market, or to merge. DOE and the Department of Justice are both interested in any potential reduction in competition that would result from an energy conservation standard.

13.1 How w ould industry competition change as a result of energy conservation standards? How would energy conservation standards affect your ability to compete in the marketplace? Would the effects on your company be different than others in the industry?

13.2 Do any firms hold intellectual property that gives them a competitive advantage following energy conservation standards?

14 HID BALLAST IMPACTS

14.1 In general, what are the key issues and potential concerns for HID ballast manufacturers regarding HID lamp energy conservation standards?

14.2 Do any of these issues become particularly significant at a specific HID lamp efficiency level or for a specific HID lamp equipment class?

14.3 Would HID lamp standards alter the pricing and/or markups of current HID ballasts?

14.4 Would you expect changes in the profitability of HID ballast manufacturers following HID lamp standards? If so, please explain why.

14.5 Would HID lamp standards alter the total number of HID ballast shipments (as opposed to simply altering the distribution of HID balla st shipments)?

14.6 Please describe the types of product and capital conversion costs HID ballast manufacturers would incur to comply with HID lamp standards. Do these activities significantly increase at specific HID lamp efficiency levels? If possible, please describe the necessary activities HID ballast manufacturers would take in order to comply with HID lamp standards (i.e. retooling, product development, testing and certification, marketing, etc.).

14.7 If possible, please list the dollar amounts associated with each of the activities described in the question 14.6 . If providing that level of detail is not possible, please provide a rough estimate of the total product and capital conversion costs for HID ballast manufacturers to comply with HID lamp standards. Do these amounts significantly increase at specific HID lamp

12A-20efficiency levels?

14.8 Would you expect any change in the number of employees associated with manufacturing HID ballasts if HID lamp standards were implemented?

14.9 Would HID lamp standards affect HID ballast manufacturing capacity?

15 IMPACTS ON SMALL BUSNESSES

15.1 The Small Business Administration (SBA) denotes a small business in the HID lamp manufacturing industry as having less than 1,000 total employees, including the parent company and all subsidiaries. By this definition, is your company considered a small business?

15.2 Are there any reasons that a small business manufacturer might be at a disadvantage relative to a larger business under energy conservation standards? Please consider such factors as technical expertise, access to capital, bulk purchasing pow er for materials/components, engineering resources, and any other relevant issues.

15.3 To your knowledge, are there any small businesses for which the adoption of energy conservation standards would have a particularly severe impact? If so, why?

15.4 To your knowledge, are there any niche manufacturers or component manufacturers for which the adoption of energy conservation standards would have a particularly severe impact? If so, why?

12A-2112A.2 MANUFACTURER IMP ACT ANALYSIS I NTERVIEW G UI DE FOR HIGH

INTENSITY DISCHARGE LAMP S ( FIXTURE MANUFACTURER S)

Au gust 2013

12A-22Purpose: To gather information on the U.S. high- intensity discharge lamp market to assist in the Department of Energy’s energy conservation standards analysis.

Method: Navigant Consulting, Inc. (Navigant) is circulating this interview guide to a limited number of manufacturers of high- intensity discharge lamp fixtures who operate in the U.S. market. Navigant will combine all the responses from individual manufac turers to protect proprietary information of any one manufacturer. Individual responses to this questionnaire and any other data provided will all be covered under a non- disclosure agreement, which Navigant will enter into with each participating manufacturer. Navigant will handle all individual company data in

the strictest confidence.

If you have any questions, please contact:

Matthew Walker Navigant Consulting, Inc. matthew.walker@navigant.com

Tel: 202.481.8482

Fax: 202.973.2401

12A-23The U.S. Department of Energy (DOE) is conducting a manufacturer impact analysis (MIA) as part of the rulemaking process to set energy conservation standards for high- intensity discharge lamps (HID lamps). In this analysis, DOE uses publicly available information and information provided during interviews to assess possible impacts on manufacturers due to energy

conservation standards. DOE began the rulemaking process with the publication of a framework document, followed by a publication of an interim analysis. Both can be found at: http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23

1 MARKET AND TECHNOLOGY

1.1 Specialty Application
- Base Type

. For the Notice of Proposed Rulemaking ( NOPR ), DOE is considering defining a specialty application lamp as any quartz metal halide (MH) or mercury vapor (MV) lamp that has a non- screw base. Do you agree with th is definition? How common are general illumination fixtures with non- screw base type lamps and sockets, in terms of shipments?

1.2 Specialty Application

– Fixture Type. Do some specialty applications require a unique fixture in addition to a specialty lamp? How (if at all) do fixtures for stage/studio applications, double-ended lamps, and F-rated lamps differ from those designed for general use applications?

1.3 End of Ballast Life

. How often will a customer attempt to reuse an existing fixture by replac ing a lam p and ballast when the ballast reaches the end of its life, as opposed to replacing the entire lamp, ballast, and fixture assembly?

1.4 Remotely Ballasted Fixtures

. How common are fixtures where the ballast and igniter

are located outside of the fixture? Are these available at all wattages? What lamp types and applications are most common for these types of fixtures?

1.5 Lamp Sourcing. For fixtures sold with lamps, what percentage of these lamps is imported versus purchased from NEMA- member lamp manufacturers? Does the efficacy of the imported lamps deviate from NEMA

- member lamps? Are certain wattages more likely to be imported than others?

2 ENGINEERING

2.1 Lamp Bases

. Is it possible or practical to modify a fixture to accept lamps of a different base type? Are there fixtures that are impossible to adapt to a different lamp base type?

2.2 Double

- ended Lamps

. Can fixtures designed for double- ended lamps be retrofitted with single- ended lamps?

2.3 Retrofit Kits

. Ballast retrofit kits include a ballast, bracketing, screws, a capacitor and/or igniter, and some wiring. Lamp and ballast retrofit kits also include a lamp (and sometimes a socket) . What are the shipments of these types of products? Do customers also create their own

12A-24retrofit kit by purchasing a ballast & bracket, lamp, and socket separately? For which situations would a new socket be required? How do customers identify a retrofit kit that will fit properly in

their fixture?

2.4 Technology Compatibility of a Fixture. Can a MV fixture be retrofitted with a MH (or high-pressure sodium [HPS]) lamp and ballast system? If so, in which applications?

2.5 Starting Method Compatibility of a Fixture

. Can an existing probe- start MH fixture be retrofitted with pulse -start technology? If so, in which applications is this most common?

2.6 Electronic Ballast Compatibility of a Fixture . Can an existing fixture with a magnetic

ballast be retrofitted with an electronic ballast?

2.7 Wattage Compatibility of a Fixture . By compiling information from catalogs of multiple fixture manufacturers, DOE ana lyzed the potential for a fixture to be retrofitted with a reduced wattage system. Table 2-1 summarizes the results, showing the percentage of fixture with wattage X whose data sheets indicate they can also accommodate lamp wattage Y. Do you agree with these percentages? Are there other factors that limit compatibility?

Table 2-1 Wattage Compatibility of a Fixture
Compatible Lamp/Ballast Combination

Probe

- start Pulse

- start Wattage 175 250 400 1000 70 100 150 175 250 400 1000Original Lamp/Ballast/Fixture Combo. Probe

- start 175 100% 72% 60% 7% 53% 60% 73% 68% 68% 50% 8%

250 84% 100% 84% 15% 34% 40% 58% 67% 94% 74% 15%

400 74% 88% 100% 26% 25% 29% 47% 60% 87% 85% 26%

1000 28% 50% 84% 100% 4% 6% 18% 22% 50% 82% 86%

Pulse

start 70 57% 31% 22% 1% 100% 92% 70% 37% 29% 11% 1%

100 62% 35% 24% 2% 88% 100% 73% 41% 32% 14% 2%

150 75% 51% 39% 5% 67% 74% 100% 50% 50% 31% 5%

175 85% 71% 61% 7% 43% 50% 61% 100% 80% 59% 8%

250 72% 85% 75% 13% 28% 33% 51% 68% 100% 78% 15%

400 57% 71% 79% 24% 12% 16% 34% 55% 84% 100% 25%

1000 33% 54% 88% 90% 4% 6% 21% 27% 58% 92% 100% Each cell shows the percentage of fixtures with the start

- type/wattage listed in the blue column that is also

advertised for the start

- type/wattage shown in the red row. For example, the darkly bordered ‘60%’ cell indicates that of all the 175 W probe

- star t MH fixtures, 60% were also listed in fixture catalogs as able to accommodate a 400 W probe

- start lamp and ballast.

2.8 Optical Compatibility of a Fixture. How sensitive are fixtures to various parameters of HID lamps? That is, do dimensions such as light center length, maximum overall length, and effective arc length need to be held constant for satisfactory light distribution? Are there tolerances or allowable ranges for these dimensions when establishing lamp- fixture compatibility?

2.9 Retrofit Kit Customer Adoption. For which lamp technologies, wattage ranges , and applications do customers currently utilize retrofit kit s? What prompts a customer to purchase a

12A-25retrofit kit? Energy conservation standards may limit the availability of certain HID lamps . Do you expect the use of retrofit kits to change in response to standards? If so, please explain.

2.10 Customer Response to Standards

. For Table 2-2 below, indicate the expected customer response to lamp standards. In the interim analysis, efficiency levels (ELs) were established that generally required a transition from one lamp type to another. In the 50-400W, 2800-4500K equipment classes, DOE considered levels of effi cacy meant to correspond to MV, quartz probe MH, quartz pulse MH, and ceramic metal halide (CMH) lamps. Table 2-2 lists possible customer responses to those increased efficacy standards. For example, the first column (equal wattage lamp and ballast retrofit), could represent an existing quartz probe MH fixture being retrofitted with an equal wattage quartz pulse

- start or CMH lamp and ballast in response to lamp efficacy standards. In contrast, the fourth column (reduced wattage replacement lamp, ballast, and fixture) could represent an existing quartz probe MH fixture that would be replaced by a reduced wattage quartz pulse or CMH lamp, ballast, and fixture in response to standards.

Table 2-2 Customer Response to Standards
Percentage of Customers (%)

CCT and Wattage Range Equal Wattage Lamp and

Ballast Retrofit Equal Wattage Replacement Lamp, Ballast,

and Fixture Reduced Wattage Lamp

and Ballast

Retrofit Reduced Wattage Replacement Lamp, Ballast,

and Fixture Reduced Wattage Retrofit Lamp

1900

- 2 8 00 K,

50

- 1000 W

2801

- 2800 K,

50

- 400 W

2 8 01

- 4500 K,

401

- 1000 W

2 8 01

- 4500 K,

1001

- 2000 W

Other subcategories

2.11 Lamp End

- User Prices. Table 2-3 shows DOE’s preliminary engineering results for each equipment class. Are the lamp end

- user prices appropriate for the efficacy levels? If you are

unsure of the end- user prices, do the differ entials from one EL to the next seem reasonable?

12A-26Table 2-3 Lamp End

- User Prices

Rep. Lamp Type* EL Lamp Type Wattage Initial Efficacy (lm/W) Lamp End

- User Prices**

Low Medium High

70 W

HPS Baseline HPS 70 90.0 $ 15.43 $ 21.16 $ 26.88

EL 1 Sapphire HPS 67 93.9 $ 46.29 $ 63.47 $ 80.65

100 W

HPS Baseline HPS 100 95.0 $ 21.91 $ 30.04 $ 38.17

EL 1 Sapphire HPS 96 99.2 $ 65.74 $ 90.13 $ 114.52

250 W

HPS Baseline HPS 250 108.0 $ 21.78 $ 29.86 $ 37.94

EL 1 Sapphire HPS 240 112.7 $ 65.33 $ 89.58 $ 113.82

400 W

HPS Baseline HPS 400 117.5 $ 22.38 $ 30.68 $ 38.98

EL 1 Sapphire HPS 383 122.6 $ 67.13 $ 92.04 $ 116.95

1000 W

HPS Baseline HPS 1000 130.0 $ 54.37 $ 74.54 $ 94.71

EL 1 Sapphire HPS 958 135.7 $ 163.10 $ 223.62 $ 284.14

100 W

MV Baseline MV 100 40.0 $ 13.82 $ 18.95 $ 24.07

EL 1 N/A

-- -- -- -- -- Baseline MH/EL 2 Pulse MH 70 78.6 $ 15.29 $ 20.97 $ 26.64

EL 3 CMH 50 82.0 $ 16.55 $ 22.70 $ 28.84

175 W

MV Baseline MV 175 44.6 $ 8.66 $ 11.87 $ 15.09

EL 1 N/A

-- -- -- -- -- Baseline MH/EL 2 Pulse MH 100 81.0 $ 17.94 $ 24.60 $ 31.26

EL 3 CMH 70 102.9 $ 38.78 $ 53.17 $ 67.56

250 W

MV Baseline MV 250 50.0 $ 15.49 $ 21.24 $ 26.99

Baseline MH/ EL 1 Probe MH 175 77.1 $ 16.34 $ 22.40 $ 28.47

EL 2 Pulse MH 150 88.7 $ 19.85 $ 27.22 $ 34.59

EL 3 CMH 100 95.0 $ 33.38 $ 45.77 $ 58.15

400 W

MV Baseline MV 400 57.5 $ 14.64 $ 20.07 $ 25.50

Baseline MH/ EL 1 Probe MH 250 88.0 $ 16.66 $ 22.85 $ 29.03

EL 2 Pulse MH 200 95.0 $ 26.54 $ 36.39 $ 46.24

EL 3 CMH 150 100.0 $ 36.82 $ 50.48 $ 64.14

400 W

MH Baseline N/A

-- -- -- -- -- Baseline/EL 1 Probe MH 400 90.0 $ 22.39 $ 30.70 $ 39.01

EL 2 Pulse MH 320 93.8 $ 29.33 $ 40.22 $ 51.10

EL 3 CMH 250 100.0 $ 45.37 $ 62.20 $ 79.03

1000 W

MV Baseline MV 1000 59.0 $ 33.20 $ 45.52 $ 57.83

EL 1 N/A

-- -- -- -- -- EL 2 Pulse MH 750 100.0 $ 52.63 $ 72.16 $ 91.70

1000 W

MH Baseline N/A

-- -- -- -- -- Baseline/EL 1 Probe MH 1000 105.0 $ 44.98 $ 61.67 $ 78.37

EL 2 Pulse MH 875 109.7 $ 60.94 $ 83.55 $ 106.17

2000 W

MH Baseline Probe MH 2000 85.0 $ 70.65 $ 96.87 $ 123.09

EL 1 Probe MH 1500 103.3 $ 53.61 $ 73.50 $ 93.39

12A-27Rep. Lamp Type* EL Lamp Type Wattage Initial Efficacy (lm/W) Lamp End

- User Prices**

Low Medium High

*All lamps listed are in the representative equipment classes. All high

- pressure sodium (HPS) lamps are in the ≥1900 K and ≤2800 K, clear, enclosed

- rated class; all the MH and MV lamps are >2800 K and ≤4500 K, clear, and

enclosed

- rated classes. ** MV lamp prices are included for the purpose of accounting for a MV customer’s prior expenditure.

2.12 Fixture MSPs. Table 2-4 lists the MSPs determined by DOE for each HID fixture. Are the fixture MSPs appropriate for the wattage and technologies?

12A-28Table 2-4 HID Fixture MSPs

Lamp Characteristics Fixture MSPs* †

CCT EL Lamp Type Wattage Indoor Outdoor

≥1900 K and ≤2800 K Baseline HPS 70 $ 35.86 $ 35.86

EL 1 Sapphire HPS 67 $ 35.86 $ 35.86

Baseline HPS 100 $ 35.86 $ 35.86

EL 1 Sapphire HPS 96 $ 35.86 $ 35.86

Baseline HPS 250 $ 105.43 $ 105.43

EL 1 Sapphire HPS 240 $ 105.43 $ 105.43

Baseline HPS 400 $ 93.20 $ 93.20

EL 1 Sapphire HPS 383 $ 93.20 $ 93.20

Baseline HPS 1000 $ 98.01 $ 98.01

EL 1 Sapphire HPS 958 $ 98.01 $ 98.01

>2800 K and ≤4500 K Baseline MV 100 $ 34.09 $ 34.09

EL 1 N/A

-- -- -- Baseline MH/ EL 2 Pulse MH 70 $ 25.69 $ 25.69

EL 3 CMH 50 $ 29.10 $ 59.10

Baseline MV 175 $ 48.85 $ 48.85

EL 1 N/A

-- -- -- Baseline MH/ EL 2 Pulse MH 100 $ 34.09 $ 34.09

EL 3 CMH 70 $ 30.83 $ 60.83

Baseline MV 250 $ 62.88 $ 62.88

Baseline MH/ EL 1 Probe MH 175 $ 48.85 $ 48.85

EL 2 Pulse MH 150 $ 44.29 $ 44.29

EL 3 CMH 100 $ 40.91 $ 70.91

Baseline MV 400 $ 97.39 $ 97.39

Baseline MH/ EL 1 Probe MH 250 $ 62.88 $ 62.88

EL 2 Pulse MH 200 $ 53.77 $ 53.77

EL 3 CMH 150 $ 53.14 $ 83.14

Baseline N/A

-- -- -- Baseline/ EL 1 Probe MH 400 $ 97.39 $ 97.39

EL 2 Pulse MH 320 $ 77.38 $ 77.38

EL 3 CMH 250 $ 75.46 $ 105.46

Baseline MV 1000 $ 209.78 $ 209.78

EL 1 N/A

-- -- -- EL 2 Pulse MH 750 $ 161.99 $ 161.99

Baseline N/A

-- -- -- Baseline/ EL 1 Probe MH 1000 $ 209.78 $ 209.78

EL 2 Pulse MH 875 $ 186.59 $ 186.59

Baseline Probe MH 2000 $ 407.95 $ 407.95

EL 1 Probe MH 1500 $ 309.57 $ 309.57

* The fixture MSP includes housing and optics, not the ballast or lamp.

† MV fixture prices are included for the purpose of accounting for a MV customer’s prior expenditure.

2.13 Ballast MSPs

. Table 2-5 shows the MSPs determined by DOE for each ballast type and wattage. Are the ballast MSPs appropriate for the wattages and technologies?

12A-29Table 2-5 HID Ballast MSPs

Lamp and Ballast Characteristics Ballast MSPs**

CCT EL Lamp Type Wattage (W) Efficiency* (%) Indoor Outdoor

≥1900 K and

≤2800 K Baseline HPS 70 77 $ 27.89 $ 27.89

EL 1 Sapphire HPS 67 77 $ 27.89 $ 27.89

Baseline HPS 100 78 $ 29.18 $ 29.18

EL 1 Sapphire HPS 96 78 $ 29.18 $ 29.18

Baseline HPS 250 84 $ 46.90 $ 46.90

EL 1 Sapphire HPS 240 84 $ 46.90 $ 46.90

Baseline HPS 400 86 $ 52.94 $ 52.94

EL 1 Sapphire HPS 383 86 $ 52.94 $ 52.94

Baseline HPS 1000 92 $ 72.98 $ 72.98

EL 1 Sapphire HPS 958 92 $ 72.98 $ 72.98

>2800 K and

≤4500 K Baseline MV 100 83 $ 23.10 $ 23.10

EL 1 N/A

-- -- -- -- Baseline MH/EL 2 Pulse MH 70 72 $ 26.78 $ 26.78

EL 3 CMH 50 89 $ 29.48 $ 28.38

Baseline MV 175 85 $ 25.23 $ 25.23

EL 1 N/A

-- -- -- -- Baseline MH/EL 2 Pulse MH 100 77 $ 37.63 $ 37.63

EL 3 CMH 70 90 $ 31.88 $ 30.78

Baseline MV 250 87 $ 31.36 $ 31.36

Baseline MH/ EL 1 Probe MH 175 88 $ 42.57 $ 42.57

EL 2 Pulse MH 150 81 $ 41.48 $ 41.48

EL 3 CMH 100 90 $ 39.55 $ 38.44

Baseline MV 400 89 $ 35.65 $ 35.65

Baseline MH/ EL 1 Probe MH 250 88 $ 41.85 $ 41.85

EL 2 Pulse MH 200 88 $ 45.61 $ 45.61

EL 3 CMH 150 90 $ 45.31 $ 44.20

Baseline N/A

-- -- -- -- Baseline/EL 1 Probe MH 400 88 $ 32.57 $ 32.57

EL 2 Pulse MH 320 88 $ 38.89 $ 38.89

EL 3 CMH 250 92 $ 80.48 $ 79.38

Baseline MV 1000 92 $ 87.27 $ 87.27

EL 1 N/A

-- -- -- -- EL 2 Pulse MH 750 91 $ 54.29 $ 54.29

Baseline N/A

-- -- -- -- Baseline/EL 1 Probe MH 1000 92 $ 52.97 $ 52.97

EL 2 Pulse MH 875 90 $ 57.92 $ 57.92

Baseline Probe MH 2000 95 $ 87.72 $ 87.72

EL 1 Probe MH 1500 92 $ 58.85 $ 58.85

* CMH lamps are paired with an electronic ballast. All other lamps are paired with magnetic ballasts. ** MV ballast prices are included for the purpose of accounting for a MV customer’s prior expenditure.

12A-303 KEY IMPACTS ON YOUR COMPANY

3.1 In general, what are the key issues for your company regarding lamp energy conservation

standards?

3.2 Do any of these issues become particularly significant at a specific efficiency level or for a specific equipment class?

Table 2-6 Equipment Class Summary

CCT Range Wattage Bulb

Finish * Luminaire

Characteristic**

≥1900 K and ≤2800 K ≥ 50 W and ≤1000 W Clear Enclosed
Open

Coated Enclosed
Open

>2800 K and ≤4500 K ≥ 50 W and ≤400 W Clear Enclosed
Open

Coated Enclosed

Open

>400 W and ≤1000 W Clear Enclosed
Open

Coated Enclosed
Open

>1000 W and ≤2000 W Clear Enclosed
Open

Coated Enclosed
Open

>4501 K and <7000 K ≥ 50 W and ≤400 W Clear Enclosed
Open

Coated Enclosed

Open

>400 W and ≤1000 W Clear Enclosed

Open

Coated Enclosed
Open

>1000 W and ≤2000 W Clear Enclosed
Open

Coated Enclosed
Open

* MV lamps regardless of bulb finish are placed in the clear equipment classes for their respective wattage and CCT. ** MV and HPS lamps are placed in the enclosed equipment classes for their respective wattage

and CCT.

4 HID FIXTURE IMPACTS

DOE defines manufacturer production cost as all direct costs associated with manufacturing a

12A-31product: direct labor, direct materials, and overhead (which includes depreciation). Themanufacturer markup is a multiplier applied to manufacturer production cost to cover nonproduction costs, such as SG&A and R&D, as well as profit. It does not reflect a “profit margin.” The manufacturer production cost times the manufacturer markup equals the manufacturer selling price. Manufacturer selling price is the price manufacturers charge their first customers, but does not include additional costs along the distribution channels.

4.1 In the interim analysis, DOE used a manufacturer markup of 1.58 for all MV, MH, and HPS fixtures. Do you agree with this estimate?

4.2 Would HID lamp standards alter the pricing and/or markups of current HID fixtures?

4.3 Would you expect changes in the profitability of HID fixture manufacturers following HID lamp standards? If so, please explain why.

New energy conservation standards could caus e your company to incur capital and product conversion costs to redesign existing products and make changes to existing production lines. Understanding the nature and magnitude of the conversion costs is a critical part of the MIA. Depending on their magnitude, the conversion costs can have a substantial impact on the outputs used by DOE to evaluate the industry impacts. The MIA considers two types of conversion costs:

• Capital conversion costs are one-time investments in plant, property, and equipment (PPE) necessitated by new energy conservation standards. These may be incremental additions to existing PPE or the replacement of existing PPE. Included are expenditures on buildings, equipment, and tooling.

• Product conversion costs are costs related to researc h, product development, testing, marketing and other costs for redesigning products necessitated by new energy

conservation standards.

4.4 Please describe the types of product and capital conversion costs HID fixture manufacturers would incur to comply with H ID lamp standards. Do these activities significantly increase at specific HID lamp efficiency levels? If possible, please describe the necessary activities HID fixture manufacturers would take in order to comply with HID lamp standards (e.g., retooling, product development, testing and certification, marketing, etc.).

4.5 If possible, please identify the dollar amounts associated with each of the activities described in question 4.4 . If providing that level of detail is not possible, please provide a rough estimate of the total product and capital conversion costs for HID fixture manufacturers to comply with HID lamp standards. Do these amounts significantly increase at specific HID lamp efficiency levels?

4.6 Would you expect any change in the number of employees associated with manufacturing

HID fixture s if HID lamp standards were implemented?

12A-324.7 Would HID lamp standards affect HID fixture manufacturing capacity?

5 SHIPMENTS

Energy conservation standards can change overall shipments by altering product attributes, marketing approaches, product availability, and prices. The industry revenue calculations are based on the shipment projections developed in DOE’s shipments model. The shipments model includes forecasts for the base case shipments (i.e., total industry shipments absent energy conservation standards) and the standards case shipments (i.e., total industry shipments with new energy conservation standards). In its shipment scenarios, DOE intends to model the effect of emerging technologies on the HID market.

5.1 Do you expect your market share to change if higher energy conservation standards take

effect?

5.2 In general, what trends do you anticipate in the HID fixture market? How will sales volumes change over the next 5, 10, or 30 years? How do these trends differ among wattages or HID technologies?

5.3 In the base-case (without standards), to which non- HID technologies are existing HID lamp /fixture customers transitioning? Do th ese percentages vary by equipment class? Please provide your responses in Table 2-7

.

Table 2-7 Base

- Case Shifts to Non -HID Technology

Base

- Case Shipment Percentage (%) CCT and Wattage Range Fluorescent LED Other

NC R/R NC R/R NC R/R

1900

- 2 8 00 K, 50

- 1000 W

2801

- 2800K, 50

- 400 W

2 8 01

- 4500 K, 401

- 1000 W

2 8 01

- 4500 K, 1001

- 2000 W

“NC” means new construction. “R/R” means replacement/renovation.

5.4 Do you expect the market to shift to HID lamps /fixtures outside of the scope of coverage (e.g., to HID lamps/fixtures at low wattages) in response to standards? If so, please explain.

Table 2-8 lists the categories of lamps included in the scope of coverage.

12A-33Table 2-8 Scope Considered in the Interim Analysis Stage

Lamp Type Rated Watta ge Correlated Color Temperature (CCT)Included Metal Halide ≥ 50 W and ≤ 2000 W ≥ 2800 K and <7000 K

Mercury Vapor ≥ 50 W and ≤ 1000 W ≥ 3200 K and ≤ 6800 K

High

- Pressure Sodium ≥ 50 W and ≤ 1000 W ≥ 1900 K and ≤ 2700 KExcluded Directional HID lamps All All

Self

- ballasted HID lamps All All

HID lamps intended for use with electronic ballasts only All All

Pulse

- start MH lamps with CRI ≥95 All All

Colored metal halide (MH) lamps (color rendering index [CRI] <40) All All

Mercury vapor (MV) lamps labeled for use with specialty applications All All

Electrodeless HID lamps All All

5.5 Do you expect standards to impact the magnitude of the shift to non- HID lamp technology? Does this standards-induced shift to non-HID technology vary by equipment class? Would a standards-induced shift be expected at all standard levels (EL 1, EL 2, or EL 3)? Please provide your responses in Table 2-9

.

Table 2-9 Standards

- Case Shifts to Non -HID Technology

Standards

- Case Shipment Percentage (%) CCT and Wattage Range Fluorescent LED Other

NC R/R NC R/R NC R/R

1900

- 2 8 00 K, 50

- 1000 W

2 8 01

- 4500 K, 50

- 400 W

2 8 01

- 4500 K, 401

- 1000 W

2 8 01

- 4500 K, 1001

- 2000 W

“NC” means new construction. “R/R” means replacement/renovation.

12A-3412A.3 SMALL BUSINESS MANUF ACTURER IMPACT ANALYSIS INTERVIEW

GUIDE FOR HIGH

- I NTENSI TY DISCHARGE LAMP S

12A -35June 2013

Purpose: To gather information on the U.S. high- intensity discharge lamp market to assist in the Department of Energy’s energy conservation standards analysis.

Method: Navigant Consulting, Inc. (Navigant) is circulating this interview guide to a limited number of manufacturers of high- int ensity discharge lamps who operate in the U.S. market. Navigant will combine all the responses from individual manufacturers to protect proprietary information of any one manufacturer. Individual responses to this questionnaire and any other data provided will all be covered under a non-disclosure agreement, which Navigant will enter into with each participating manufacturer. Navigant will handle all individual company data in the strictest

confidence.

If you have any questions, please contact:

Matthew Wal ker Navigant Consulting, Inc. matthew.walker@navigant.com

Tel: 202.481.8482

Fax: 202.973.2401

12A-36The U.S. Department of Energy (DOE) is conducting a manufacturer impact analysis (MIA) as part of the rulemaking process to set new energy conservation standards for high- intensity discharge lamps (HID lamps). In this analysis, DOE uses publicly available information and information provided during interviews to assess possible impacts on manufacturers due to energy conservation standards. DOE began the rulemaking process with the publication of a framework document, followed by a publication of an interim analysis. Both can be found at: http://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23 . The HID lamps covered in this rulemaking are separated into equipment classes, based on CCT range, wattage, bulb finish, and luminaire characteristics, as shown below.

Table 3-1 HID Lamp Equipment Class Summary

CCT Range Wattage Bulb

Finish * Lumin aire

Characteristic**

1900

- 2800 K 50

- 1000 W Clear Enclosed
Open

Coated Enclosed
Open

2801

- 4500 K 50

- 400 W Clear Enclosed
Open

Coated Enclosed

Open

401

- 1000 W Clear Enclosed
Open

Coated Enclosed
Open

1001

- 2000 W Clear Enclosed
Open

Coated Enclosed
Open

4501

- 7000 K 50

- 400 W Clear Enclosed
Open

Coated Enclosed

Open

401

- 1000 W Clear Enclosed

Open

Coated Enclosed
Open

1001

- 2000 W Clear Enclosed
Open

Coated Enclosed
Open

* MV lamps regardless of bulb finish are placed in the clear equipment classes for their respective wattage and CCT. ** MV and HPS lamps are placed in the enclosed equipment classes for their respective wattage

and CCT.

12A-37DOE is currently considering up to four candidate standard levels (CSLs) of efficiency for HID lamps in the scope of this rulemaking, including a baseline CSL. In responding to this questionnaire, please refer to the CSLs in the table below. The table show s DOE’s preliminary engineering results for each equipment class.

12A-38Table 3-2 HID Lamp Efficiency Level Summary

Rep. Lamp Type* CSL Lamp Type Wattage Initial Efficacy (lm/W)

70 W HPS Baseline HPS 70 90.0

CSL 1 Sapphire HPS 67 93.9

100 W HPS Baseline HPS 100 95.0

CSL 1 Sapphire HPS 96 99.2

250 W HPS Baseline HPS 250 108.0

CSL 1 Sapphire HPS 240 112.7

400 W HPS Baseline HPS 400 117.5

CSL 1 Sapphire HPS 383 122.6

1000 W HPS Baseline HPS 1000 130.0

CSL 1 Modeled HPS 958 135.7

100 W MV Baseline MV 100 40.0

CSL 1 N/A

-- -- Baseline MH/CSL 2 Pulse MH 70 78.6

CSL 3 CMH 50 82.0

175 W MV Baseline MV 175 44.6

CSL 1 N/A

-- -- Baseline MH/CSL 2 Pulse MH 100 81.0

CSL 3 CMH 70 102.9

250 W MV Baseline MV 250 50.0

Baseline MH/ CSL 1 Probe MH 175 77.1

CSL 2 Pulse MH 150 88.7

CSL 3 CMH 100 95.0

400 W MV Baseline MV 400 55.0

Baseline MH/ CSL 1 Probe MH 250 88.0

CSL 2 Pulse MH 200 95.0

CSL 3 CMH 150 100.0

400 W MH Baseline N/A

-- -- Baseline/CSL 1 Probe MH 400 90.0

CSL 2 Pulse MH 320 93.8

CSL 3 CMH 250 100.0

1000 W MV Baseline MV 1000 59.0

CSL1 N/A

-- -- CSL2 Pulse MH 750 100.0

1000 W MH Baseline N/A

-- -- Baseline/CSL 1 Probe MH 1000 105.0

CSL 2 Pulse MH 875 109.7

2000 W MH Baseline Probe MH 2000 85.0

CSL 1 Probe MH 1500 103.3 *All lamps listed are in the representative equipment classes. Thus all HPS lamps are in the ≥ 1900 K and ≤ 2800 K, clear, enclosed

- rated class; all the MH and MV lamps are >2800 K and ≤4 500 K, cle ar, and enclosed

- rated

classes.

12A-391 INTRODUCTION

1.1 Are you aware of DOE’s ongoing rulemaking to establish new national minimum energy conservation standards for HID lamps? If you are not already in it, would you like to be added to

DOE’s email database for updates relating to this rulemaking?

1.2 We are assessing the impacts of a potential energy conservation standard on small businesses. Is your company a small business (defined as less than 1,000 employees by the US Small Business Administration (SBA), in cluding all subsidiaries and parent companies, and employees in all countries where you operate)?

1.3 Are there any reasons that a small business manufacturer might be at a disadvantage relative to a larger business under adopted energy conservation standards ? Please consider such factors as technical expertise, access to capital, bulk purchasing power for materials/components, engineering resources, and any other relevant issues.

1.4 To your knowledge, are there any small businesses for which the adoption of energy conservation standards would have a particularly severe impact? If so, why?

2 KEY ISSUES

2.1 In general, what are the key issues for your company regarding new energy conservation

standards for HID lamps and this rulemaking?

2.2 Do any of these issues beco me particularly significant for a specific equipment class or at a specific efficiency level? Please reference Table 3-1 and Table 3-2

.

3 COMPANY OVERVIEW AND ORGANIZATIONAL CHARACTERISTICS

DOE is interested in understanding manufacturer impacts at the plant or profit center level directly pertinent to HID lamp production. However, the context within which the plant operates and the details of plant production and costs are not always readily available from public sources. Therefore, DOE invites you to provide these details confidentially in your own words to the extent possible an d practical. Understanding the organizational setting around the HID lamp industry profit center will help DOE understand the probable future of the manufacturing activity with and without energy conservation standards.

3.1 Do you have a parent company, and/o r any subsidiaries relevant to the HID lamp industry?

3.2 What types of HID lamps do you manufacture? What is your company’s approximate market share of the HID lamps market?

3.3 Do you manufacture any equipment other than HID lamps? If so, what other equipment

12A-40do you manufacture? What percentage of your total manufacturing revenue corresponds to HID lamps?

3.4 Please complete Table 3-3 to the best of your ability for your company. If possible, please express revenue in both dollar amount and in percentage of HID lamp sales. Additionally, please express shipments in both volume and percentage of all HID lamp shipments. Please indicate if you do not manufacture equipment in any g iven equipment class.

Table 3-3 HID Lamp Revenue and Shipment Volumes

Lamp Technology Rated Lamp Wattage 2012 Revenue ($) (%) 2012 Shipments (volume) (%)

HPS 50

- 1000 W

MV 50

- 400 W

MV 401

- 1000 W

Probe (quartz) MH 50

- 400 W

Probe (quartz) MH 401

- 1000 W

Probe (quartz) MH 1001

- 2000 W

Pulse (quartz) MH 50

- 400 W

Pulse (quartz) MH 401

- 1000 W

Pulse (quartz) MH 1001

- 2000 W

CMH 50

- 400 W

CMH 401

- 1000 W

CMH 1001

- 2000 W

4 MARKUPS AND PROFITABILITY

One of the primary objectives of the MIA is to assess the impact of energy conservation standards on industry profitability. In this section, DOE would like to understand the current markup structure of the industry and how energy conservation standards would impact your company’s markup structure and profitability. DOE defines manufacturer production cost as all direct costs associated with manufacturing a product: direct labor, direct materials, and overhead (which includes depreciation). Themanufacturer markup is a multiplier applied to manufacturer production cost to cover nonproduction costs, such as SG&A and R&D, as well as profit. Some manufacturers also refer to this as gross margin. It does not reflect a “profit margin.”

12A-41The manufacturer production cost times the manufacturer markup equals the manufacturer selling price. Manufacturer selling price is the price manufacturers charge their first customers,

but does not include additional costs along the distribution channels. DOE estimates an industry

- wide manufacturer markup of 1.53 (this corresponds to a gross margin of 35%) for HID lamps

.

4.1 Is the 1.53 baseline markup representative of an average industry markup for HID lamps?

4.2 Does this markup vary by lamp wattage or lamp type?

4.3 Do you expect changes in your estimated profitability following an energy conservation standard? If so, please explain why.

5 FINANCIAL PARAMETERS

Navigant has developed a “strawman” model of the HID l amps industry financial performance called the Government Regulatory Impact Model (GRIM) using publicly available data. However, this public information might not be reflective of manufacturing at the HID lamp profit center. This section attempts to unders tand the financial parameters for HID lamp manufacturing and how your company’s financial situation could differ from the industry aggregate picture.

5.1 In order to accurately collect information about HID lamp manufacturing, please compare your financial pa rameters to the GRIM parameters tabulated below in Table 3-4

.

12A-42Table 3-4 Financial Parameters for HID Lamp Manufacturers

GRIM Input Definition Industry

Estimated

Value Your Actual (If Significantly

Different from DOE’s Estimate)

Income Tax Rate Corporate effective income tax paid (percentage of earnings before taxes, EBT) 26.1%

Discount Rate Weighted average cost of capital (inflation

adjusted weighted average of corporate cost of debt and return on equity) 8.0%

Working Capital Current assets less current liabilities (percentage of revenues) 12.7%

Net PPE Net plant property and equipment (percentage of revenues) 24.2%

SG&A Selling, general, and administrative expenses (percentage of revenues) 19.8%

R&D Research and development expenses (percentage of revenues) 4.2%

Depreciation Amortization of fixed assets (percentage of revenues) 3.7%

Capital Expenditures Outlay of cash to acquire or improve capital assets (percentage of revenues, not including acquisition or sale of business units) 3.5%

Cost of Goods

Sold Includes material, labor, overhead, and depreciation (percentage of revenues) 65.3%

5.2 How would you expect a n ew energy conservation standard to impact any of the financial parameters for the industry?

5.3 Can you please provide the breakdown in the total production costs for HID lamps by the percentage for labor, materials, overhead, and depreciation b y filling in below Table 3-5 ?

Table 3-5 Breakdown of Total Production Costs for HID Lamps

Labor % of full production costs Materials % of full production costs Overhead % of full production costs Depreciation % of full production costs

6 CONVERSION COSTS

DOE understands that new energy conservation standards may cause your company to incur capital and equipment conversion costs to redesign existing equipment and make changes to existing production lines. Understanding the nature and magnitude of the conversion costs is a critical part of the MIA. Depending on their magnitude, the conversion costs can have a substantial impact on the outputs used by DOE to evaluate the industry impacts. The MIA considers two types of conversion costs:

12A-43• Capital conversion costs are one-time investments in plant, property, and equipment (PPE) necessitated by new energy conservation s tandards. These may be incremental additions to existing PPE or the replacement of existing PPE. Included are expenditures on buildings, equipment, and tooling.

• Equipment conversion costs are costs related to research, product development, testing,

marketi ng and other costs for redesigning equipment necessitated by new energy

conservation standards.

For the industry cash flow model, DOE must estimate the conversion costs for all covered equipment. It is difficult to estimate these costs due to variations in efficiency between equipment classes. The questions below attempt to capture the capital and equipment conversion costs that would be required to convert all covered equipment at the CSLs studied by DOE.

6.1 For the HID lamps you manufacture within each equipment class, what capit al and equipment conversion costs do you expect to incur at each designated EL ?

Table 3-6 Expected Equipment and Capital Conversion Costs for HID Lamps

Equipment Class EL Total Equipment

Conversion

Costs Total Capital

Conversion

Costs Description

1900

- 2800 K, 50

- 1000 W Baseline

1

28 01

- 4500 K, 50

- 400 W Baseline

1

2

3

28 01

- 4500 K, 401

- 1000 W Baseline

1

2

28 01

- 4500K, 1001

- 2000 W Baseline

1

6.2 Please provide additional qualitative information to help DOE understand the types and nature of your investments, including the plant and tooling changes and the product development effort required at different efficiency levels.

7 DIRECT EMPLOYMENT AS SESSMENT

The impact of new energy conservation standards on employment is an important consideration

12A-44in the rulemaking process. This section of the interview guide seeks to explore current trends in HID lamp employment and solicit manu facturer views on how domestic employment patterns might be affected by new energy conservation standards.

7.1 Where are your facilities that produce HID lamps for the United States located? What types of equipment are manufactured at each location? Please pr ovide annual shipment figures , if possible, for your company’s HID lamp manufacturing at each location by equipment class in

Table 3-7 . Please also provide employment levels at each of these facilities.

Table 3-7 HID Lamp Manufacturing Facilities

Facility Location Equipment Types

Manufactured Employees Annual Shipments

Example Jackson, TN CMH

50

- 400W pulse MH 650 300,000 CMH 150,000 pulse MH

1

2

3

4

5

7.2 Would your domestic employment levels be expected to change significantly under new energy conservation standards? If so, please explain how and why they would change if higher efficiency levels are required.

12A-45APPENDIX 12B GOVERNMENT REGULATORY IMPACT MODEL ( G RIM )

OVERVIEW

TABLE OF CONTENTS

12B.1 INTRODUCTION AND PURPOSE .......................................................................... 12B-1

12B.2 HIGH INTENSITY DISCHARGE LAMP DESCRIPTIO N ...................................... 12B-1

12B.3 HIGH INTENSITY DISCHARGE LAMP DETAILED CASH FLOW EXAMPLE 12B-4

12B-iAPPENDIX 12B GOVERNMENT REGULATORY IMPACT MODEL ( G RIM )

OVERVIEW

12B.1 I NT R ODUCTION AND P URPOSE

The purpose of the Government Regulatory Impact Model (GRIM) is to help quantify the impacts of potential energy conservation standards and other regulations on manufacturers. The basic mode of analysis is to estimate the change in the value of the industr y or manufacturers following a regulation or a series of regulations. The model structure also allows an analysis of multiple equipment classes with regulations taking effect over a period of time, and of multiple regulations on the same equipment.

Industr y net present value (INPV) is defined, for the purpose of this analysis, as the discounted sum of industry free cash flows plus a discounted terminal value. The model calculates the actual cash flows by year and then determines the present value of those cash flows both without an energy conservation standard ( i.e. , the base case) and under different efficacy levels ( E Ls) for each equipment class ( i.e. , the standards case).

Output from the model consists of summary financial metrics, graphs of major variabl es, and, when appropriate, access to the complete cash flow calculation.

12B.2 HIGH INTENSITY DISCH ARGE LAMP D ESCRIPTION

DOE analyze d the impacts of potential standards on high i nte n sity d ischarge (HID) lamp

manufacturers

. The basic structure of the GRIM is a standard annual cash flow analysis that uses manufacturer selling prices, manufacturing costs, a shipments forecast, and financial parameters as inputs and accepts a set of regulatory conditions as changes in costs and investments. The cash flow analysis is separated into two major blocks: income and cash flow. The income calculation determines net operating profit after taxes. The cash flow calculation converts net operating profit after taxes into an annual cash flow by including investment and non- cash items. The line

items below relate to the HID lamp manufacturers and are definitions of listed items on the printout of the output sheet (see section 12B.3 ).

(1) Revenues: Annual revenues - computed by multiplying the equipment classes’ per

unit prices at each effic acy level by the appropriate manufacturer markup;

(2) Total Shipments: The total covered units shipped;

(2) Material s: The portion of cost of goods sold (COGS) that includes materials;

(3) Labor: The portion of COGS that includes direct labor, commissions, dismissal pay, bonuses, vacation, sick leave, social security contributions, fringe, and assembly labor

up- time;

(4) Depreciation: The portion of COGS that includes an allowance for the total amount

of fixed asset s used to produce that one unit;

12B-1(5) Overhead: The portion of COGS that includes indirect labor, indirect material, energy use, maintenance, property taxes, and insurance related to assets;

(6) Standard SG&A: Selling, general, and administrative costs are computed as a percentage of Revenues ( 1) ;

(7

) R&D: GRIM separately accounts for ordinary research and development (R&D) as a percentage of Revenues ( 1) ;

(8

) Pro duct Conversion Costs : Product conversion costs are one- time investments in research, development, testing, marketing, and other costs focused on making equipment designs comply with potential energy conservation standards . The GRIM allocates these

costs o ver the period between the potential standards’ announcement and compliance dates;

(9

) Stranded Assets: In the year the potential standard becomes effective, a one

- time

write

- off of stranded assets is accounted for;

(1 0 ) Earnings Before Interest and Taxes (EBIT) : Includes profits before deductions for interest paid and taxes;

(11) Per U nit EBIT: The average amount of EBIT (10 ) per covered unit shipped;

(1 2 ) EBIT/Revenues : The GRIM calculates EBIT as a percentage of sales to compare with the industry’s aver age reported in financial statements;

(1 3 ) Taxes: Taxes on EBIT (1 0) are calculated by multiplying the tax rate contained in the Discounted Cash Flow tab by EBIT (1 0) ;

(1 4 ) Net Operating Profits After Taxes (NOPAT): Computed by subtracting Taxes (1 2)

from EBIT (1 0);

(1 5 ) NOPAT repeated: NOPAT (1 3) is repeated in the Statement of Cash Flows;

(1 6 ) Depreciation repeated : Depreciation (4) is added back in the Statement of Cash

Flows because it is a non

- cash expense;

(1 7 ) Stranded Assets repeated : Stranded Assets ( 9) is added back in the Statement of

Cash Flows because it is a non

- cash expense;

(1 8 ) Change in Working Capital: Change in cash tied up in accounts receivable, inventory, and other cash investments necessary to support operations is calculated by multiplying working capital (as a percentage of revenues) by the change in annual

revenues;

(19 ) Cash Flow From Operations: Calculated by taking NOPAT (1 4), adding back noncash items such as Depreciation (1 6) and Stranded Assets (1 7), and subtracting the Change in Working Capital (18);

12B-2(20 ) Ordinary Capital Expenditures: Ordinary investments in property, plant, and equipment to maintain and replace existing production assets, computed as a percentage

of Revenues ( 1) ;

(2 1) Capital Conversion Costs: Capital conversion costs are one- time investments in property, plant, and equipment to adapt or change existing production facilities so that

new equipment designs can be fabricated and assembled under the potential regulation s ;

t he GRIM allocates these costs over the period between the potential standard s ’ announcement and compliance dates;

(2 2 ) Free Cash Flow: Calculated by taking annual Cash Flow From Operations (1 9) and subtracting (20 ) Ordinary Capital Expenditures and (2 1 ) Ca pital Conversion Costs;

(2 3 ) Free Cash Flow repeated: Free Cash Flow ( 22) is repeated in the Discounted Cash Flow section;

(2 4 ) Terminal Value: Estimate of the continuing value of the industry after the analysis period. Computed by growing the Free Cash Flow at the beginning of 2046 at a constant rate in perpetuity;

(2 5 ) Present Value Factor: Factor used to calculate an estimate of the present value of an amount to be received in the future;

(2 6 ) Discounted Cash Flow: Free Cash Flow (2 2) multiplied by the Present Value Factor (25) . For the end of 2046, the discounted cash flow includes the discounted Terminal Value (2 4) ; and

Industry Value thru the end of 2046 : The sum of Discounted Cash Flows (2 6)

.

12B-312B.3 HIGH INTENSITY DISCH ARGE LAMP D ETAILED C ASH F LOW E XAMPLE

12B-4