NOTICE OF PROPOSED DETERMINATION

TECHNICAL SUPPORT DOCUMENT: 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 20585 
This Document was prepared for the Department of Energy

by staff members of

Navigant Consulting, Inc. and Pacific Northwest National Laboratory 
CHAPTER 1. INTRODUCTION

TABLE OF CONTENTS

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

1.2 OVERVIEW OF THE APPLIANCES AND COMMERCIAL EQUIPMENT 

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

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

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

1.5 STRUCTURE OF THE DOCUMENT ............................................................................ 1-6

LIST OF TABLES

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

1-i 
CHAPTER 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 III, Part C of the Energy Policy and Conservation Act of 1975 (42 U.S.C. 6291–

6317; EPCA), as amended, established the Energy Conservation Program 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 potential 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 amount of energy savings likely to result directly from 

imposition of the standard; 

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

imposition of the standard; 

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

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

a 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 determinationb (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 (hereafter the “framework 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 

relationship among the various analyses.d

On February 28, 2013, DOE published the interim 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.

1-2 

 
78 FR 13566. DOE also posted the interim TSD on its website describing interim methodologies 

and results. DOE held the public 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 detailed 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 encourages the participation of all stakeholders during the 

comment period of each rulemaking stage. Beginning with the framework document and 

continuing through subsequent comment periods, interactions among interested parties provide a 

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

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

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

For this 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 standards. (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 standard 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. 

1-3 

 
Subsequent 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 standards. 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 weighing of the impacts. 

Table 1.4.1 Analyses under the Process Rule

Interim Analysis NOPD Final Determination* 

Market and technology assessment Revised interim analyses Revised NOPD analyses

Screening analysis

Engineering analysis

Energy use characterization

Markup analysis

Equipment price determination

Life-cycle cost and payback period 

analysis 

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 

availability 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 framework 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 framework presented at the 

framework public meeting described rulemaking analyses, such as the engineering analysis and 

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

1-4 
conducting them, and the relationships among the various analyses. See Table 1.4.1 for all the 

analyses discussed at the framework public meeting to be undertaken in each of the formal 

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

public meeting are available 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. DOE had five 

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

(2) solicit feedback on the engineering analysis; (3) solicit feedback on topics related to the 

interim manufacturer impact analysis (MIA); (4) provide an opportunity early in the rulemaking 

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

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

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

equipment mix, conversion costs, and cumulative regulatory burden. Appendix 12A of the 

interim TSD contains a complete copy of the interview guide. 

DOE published a notice announcing the availability of the interim analysis on February 

28, 2013 (78 FR 13566), and held a public meeting 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 rulemaking, 

the considered equipment classes, sapphire arc tubes as a design option for high-pressure sodium 

lamps, engineering analysis (including the representative 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 2013 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 NOPD 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 business.

1-5 
For 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 spreadsheets calculate the national 

energy savings (NES) and national net present values (NPVs) at various efficacy levels and 

include a model that forecasts the impacts of energy conservation standards at various levels on 

equipment shipments. These spreadsheets are available on the DOE website through: 

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

NOPD analyses, DOE tentatively determines 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 NOPD 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: describes the rulemaking process, provides an 

overview of each analysis, including rationale for proposed 

conclusions, and discusses comments received during the framework 

and 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: determines which technology design options are 

viable for consideration in the engineering analysis 

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

analysis, and establishes efficacy levels based on lamp efficacy

Chapter 6 Equipment Price 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 markups 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

1-6 
Chapter 9 LCC and PBP Analysis: 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 NIA: 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 LCC and PBP Spreadsheet

Appendix 9B Estimation of Potential Equipment Price Trends for HID Lamps

Appendix 11A User Instructions for Shipments and NIA Spreadsheet

Appendix 11B Full-Fuel-Cycle Multipliers

Appendix 12A Manufacturer Interview Guide 

Appendix 12B Government Regulatory Impact Model Overview 

1-7 
CHAPTER 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 THIS DETERMINATION ..................................................... 2-5

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

2.3.2 Specific 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 Combined 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 TECHNOLOGY 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

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2.4.3.7 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 Summary ..................................................................................................................... 2-49

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

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

2.6.1.1 Representative 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 Replacement Options ........................................................................................... 2-72

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

2.7 EQUIPMENT PRICE DETERMINATION ................................................................... 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-ii
LIST 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 Classes 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 Interim Analysis ...................................................... 2-75

Table 2.6.7 NOPD Scaling Factors ............................................................................................ 2-76

2-iii
CHAPTER 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 used 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 (NOPD) 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 analysis 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 (ELs), 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 markups analysis to evaluate distribution channels to develop end-user equipment 

prices of ballasts and fixtures for the LCC analysis and national impact analysis 

(NIA); the markups 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 analysis 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 define 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 (including 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 determinationa (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 the 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).

2-2 

 
HID 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 conservation 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 

interim 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. 

This chapter of the NOPD TSD responds to the issues raised 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 procedures NOPR at a public meeting on 

January 19, 2012. Comments received in response to the test procedures NOPR and a transcript 

2-3 
of the public meeting are available at www.regulations.gov, docket number EERE-2010-BT-TP0044. 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 requirements 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 for 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 Consumption

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

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

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

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

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

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

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

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

sensor-based functions. Id. 

 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 refers to a comment: (1) submitted 

by NEMA during the interim analysis public meeting on February 28, 2013; (2) in the transcript of that public 

meeting, document number 23 in the docket of this rulemaking; and (3) appearing on page 73 of the transcript.

2-4 

 
general 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 lamp 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 at 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 lamps.

2.3 LAMPS ANALYZED IN THIS DETERMINATION

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

NOPD and its determination of the HID lamp types analyzed. DOE analyzed 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 catalogs 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 electric-discharge lamp in which – 

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

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

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

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

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 

2-5 
produced by radiation from mercury typically operating at a partial vapor pressure in 

excess of 100,000 Pa (approximately 1 atm). (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 SNOPR, 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 6,670 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 respond 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 exclude 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 agree 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. 

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For the interim analysis and this NOPD 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 two 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 exclusions 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 technology 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 

technologically 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 designed 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 decision of which lamps are considered for potential energy 

conservation standards in both the framework document and interim analysis. DOE received 

comment on covered wattages and CCT ranges and the exclusion of directional lamps, selfballasted lamps, lamps designed 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 responds 

to these comments in the sections that follow. 

2-7 
2.3.2.1 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 analyzing 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 input 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 wattages 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 specialty applications exist in this wattage range, the exemptions outlined 

in section 2.3.2.8 effectively target those specialty lamps. In this 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 this 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 potential for energy savings and are 

2-8 
technologically 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 greater 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 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 MV lamps in the framework document. As 

such, in the interim analysis, DOE preliminarily determined 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 analyzed in 

the framework document and interim analysis. In this 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 on 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 this 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 this 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.

2-9 
2.3.2.2 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 source 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 lamps range in CCT from 

3200 K to 6800 K, while MH lamps range 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 advertised 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 predominantly 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 specialized 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 some 

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 analysis. 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 commented 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 lamps 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 determined that this CCT range represents 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 4500 K 

and less than 7000 K CCT. 

2-10 
In response to the framework document, 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 

efficacy. 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 determines for this NOPD that sapphire arc tube 

technology should not be included as a technology option for increased efficacy in HPS lamps 

(see section 2.4.2.2 for further details). As a result, there were no technology options for 

increasing the efficacy of HPS lamps, indicating standards for this lamp type was not 

technologically feasible. Therefore, in this NOPD, DOE is not conducting a full economic 

analysis on standards for HPS lamps to determine whether standards would be economically 

justified. 

In summary, in this 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 standards 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 elements 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 specific beam 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. 

2-11 
In 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 at 

p. 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 could 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 manufacturer 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, DOE 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 standards 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 comments 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-Ballasted 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 self2-12 
ballasted. 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 decreasing maintenance costs. Given the 

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

to incandescent technology if self-ballasted HID lamps were made unavailable or more 

expensive by standards, DOE does not believe 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 not considering standards for self-ballasted lamps in 

the framework document. NEEA commented that the market share of self-ballasted HID lamps is 

increasing 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 market, 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 have 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 constitute potential for significant energy savings. All self-ballasted 

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

minimizing 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 efficient 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. 

2-13 
2.3.2.5 Lamps Designed to Operate Exclusively on Electronic Ballasts 

In its market research, DOE found catalogs that indicated some HID lamps were designed 

to operate exclusively on electronic ballasts. In the framework document, DOE indicated that 

lamps designed to operate exclusively on electronic ballasts currently represent a small share 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 document, 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) Additionally, 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 referred 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 IOUs 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

 The 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. 

2-14 

 
manufacturer interviews. DOE recognizes that a number of CMH lamps on the market are 

designated as for use with electronic ballasts only, 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 exclude 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 lamps is lower than the typical CRI for MH lamps. What is considered highCRI 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 are 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 responded 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 may 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 one 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.

2-15 

 
for HPS lamps that would exceed the efficacy of high-CRI 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 framework document, DOE did not identify high-CRI 

lamps as a category to be exempted from energy conservation standards. NEMA commented that 

less efficacious and higher CRI HID sources are needed for some applications. (NEMA, No. 11 

at p. 20) 

For the interim analysis, 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 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 lamps with CRI values greater than or equal 

to 95 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) 

2-16 
DOE reassessed its analysis of 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 eliminate 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, DOE 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 greater 

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 

DOE 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 substitutes 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 definition 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 standards 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.

2-17 

 
recommended 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 

such, 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 MH 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 availability 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 standards, 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 stakeholders 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 lighting, 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-based 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, horticultural 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 lighting (e.g., CMH lamps with bi-pin 

bases). Therefore, in the interim analysis, DOE preliminarily determined that these kinds of nonscrew-based general lighting lamps should be considered for standards. 

2-18 
In 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 

Meeting 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 lamps 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, including the intended 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 applications 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 theater 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 purposes. (CA IOUs, No. 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 encourage their use in nonspecialty 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 determine 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 this NOPD, DOE is not conducting a 

full economic analysis to determine the economic justification of standards for any HPS lamps

(see section 2.3.2), including HPS horticulture lamps. MH horticulture lamps are available with 

2-19 
greater 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 and MH lamps used in general illumination, and tentatively 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 CCTs 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 3000 K to 50,000 K. Aquarium 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 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 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 economic 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 highest 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 ELs considered in the 

2-20 
engineering 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 Specialty 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 something 

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 difficulties 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 recommended exempting only MV lamps whose applications 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, 

2-21 
such as quality inspection, material testing, industrial processing, scientific uses (e.g., fluorescent 

microscopy), and UV curing. Based on their reduced UV output, DOE tentatively determined 

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 feasible. DOE considered using a UV 

intensity metric to exclude 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 standards 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 baseh

 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, stage, 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, which 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 design 

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 general 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. In this 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. 

2-22 

 
2.3.2.9 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 most 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 the lamps, and that 

Venture cannot predict where the market will go. (Venture, Public Meeting Transcript, No. 12 at 

pp. 21-22) GE stated 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 further 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 exempted 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/cm2

; (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 meet 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 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 lamps 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/#!documentDetail;D=EERE-2010-BT-STD-0043-0016. 

2-23 

 
the 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 interim 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. Electrodeless 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 this 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 response 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 interlock 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 percent 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 should 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 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 the NOPD for wattages greater 

2-24 
than 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. 

As 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 this NOPD, DOE considers the economic justification of standards for MH lamps 

with rated wattages of greater than or equal to 50 W and less than or equal to 2000 W, and MV 

lamps with rated wattages 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 than 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 this HID 

lamp rulemaking and 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 

MHLFs.

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

maintained 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 2014 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 

2-25 
not 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 this 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 

omnidirectional 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 after 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 maintenance 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) 

2-26 
GE 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 for 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 lamp 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 efficacy 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 preliminarily determined to use initial 

lamp efficacy 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 unclear 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 uses 

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

2-27 
rulemaking. (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, DOE 

did not develop or analyze potential metrics for these lamps. DOE maintains this approach for 

the NOPD. 

2.4 MARKET AND TECHNOLOGY 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, this 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, regulatory 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 the 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 NOPD 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 NEMA, 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 

2-28 
development. 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. Chapter 3 of this NOPD 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 United States 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 

proposedk 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 NOPD 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 evaluated 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 the 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 shipment data and market trend 

information contributes to the shipments analysis and base case forecast for HID lamp shipments 

(see chapter 10 of the NOPD TSD for additional detail). DOE analyzes historical shipment data 

on market trends and calibrates forecast assumptions with recent data. Second, DOE uses the 

data to develop the installed stock of HID lamps for the NIA (see chapter 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 lamp 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

2-29 

 
Table 2.4.1 Historical Shipments 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.

2-30 
2.4.2.1 Mercury Vapor Lamps

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 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 change 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 characteristics 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 sapphire 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, No. 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, 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, HPS lamps using sapphire 

arc tubes are much more susceptible to catastrophic failure and would require enclosed fixtures 

2-31 
for 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 manufacturers, 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 interview 

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 differences. 

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 could 

improve MH lamp efficacy. These technology options included changing from probe- to pulsestart technology, improving arc tube design through the use of ceramic arc tubes or 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) 

2-32 
DOE 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 probe-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 available. While starting method is addressed in the 2014 MHLF rule, that 

rulemaking impacts only ballasts sold in new fixtures. Because this 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 

commented 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-start 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 pulse-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 efficacies 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 lamps 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 

2-33 
will not 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 mass manufacturing difficulties and economics behind doing so are the 

main reasons 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 result 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 agreed 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 description 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 type, bulb shape). In each of these instances, DOE ensured that either there 

2-34 

 
efficacious, 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 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). 

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 currently 

using 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. (NEMA, 

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 

efficacies. 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 with 

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 electrode design and material to 

be a technology option. 

2.4.3 Equipment Classes

In analyzing 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-universal, thus ensuring that no wattage could have 

universal lamps eliminated by potential standards.

2-35 

 
particular 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 operating orientation as potential equipment class-setting factors. In the interim analysis, 

2-36 
DOE 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.

2-37 
As 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 classsetting factors that DOE discussed.

2.4.3.1 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 directional and omnidirectional lamps, it would be necessary for these two types of 

lamps 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 

would 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 equipment 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 

incandescent 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 less 

efficacious 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 self-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 

consideration for self-ballasted HID lamps, DOE removed ballast location as an equipment classsetting 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-ballasted lamps in the economic analysis in this 

2-38 
NOPD. 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 consumer 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 application. 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, however, DOE revised 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 exhibit 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 retains the structure 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.

2-39 

 
2.4.3.4 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 application 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 output (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 separate equipment classes. 

Because light output more directly addresses the feature valued by customers, DOE established

separate equipment classes based on light 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 pp. 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 that 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 output 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 analysis, 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 

2-40 
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.

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 

available 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 the 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 divisions for 

equipment classes. In 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 Finish

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 that 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 that 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 separated 

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 

2-41 
MV 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 clear bulb finish equipment classes (regardless of the bulb 

finish of the MV lamp itself).

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, white, 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 comments 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 enclosed-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 characteristic 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 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 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 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. DOE also found commercially available lamps that were labeled as 

2-42 
S-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 comparable 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-setting 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 operating 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 universal 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 standard 

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 horizontal 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 the 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 retains the approach of not 

using operating orientation as an equipment class-setting factor but selecting universal lamps as 

representative units whenever possible. 

2-43 
2.4.3.8 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 identified 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 increase 

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 further 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 

did 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 results 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 separate equipment classes by CRI in 

this NOPD. 

2.4.3.9 Standby Lamps

In the framework document, 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 lifetimes. 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 

2-44 
preliminarily 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 separate standby lamps into a different equipment class in 

this NOPD. 

2.4.3.10 Summary 

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.

2-45 
2.5 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 maximum 

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 options 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 practicable 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 NOPD TSD. DOE received several 

comments, discussed below, in response to the design options presented. 

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

Lamp 

Technology

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

High-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 

commented 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 

understands that there are numerous limitations to HID systems because of the various 

components required for a full system and unique compatibility issues 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, section 4(a)(4)(i)) However there are no 

working prototypes to improve 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 

2-47 
percent. 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 produce 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 wattages 

would not be feasible because the ballasts 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 

commented 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 operating 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) 

As 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 

2-48 
interim analysis and continues to consider those design options as passing 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 NOPD 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

 Manufacturers 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 the 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 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 use this lamp as an example of CMH lamps 

being commercially available from 401 W – 2000 W.

2-49 

 
Table 2.5.2 NOPD HID Lamp Design Options

Lamp Technology 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 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

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 discusses 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 compliant 

products, DOE found in this NOPD that simply modeling compliant lamps replacing noncompliant lamps does not capture the entirety of the actual customer economics. In certain 

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, while appendix 6A of the NOPD TSD discusses the 

2-50 
equipment price determination for HID ballasts, fixtures, and retrofit system components. The 

following discussion summarizes the general steps 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 equipment 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 “representative 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 manufacturer 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 technology 

(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 reasons, DOE selects both MV and MH lamps as baselines for certain 

equipment 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 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 this NOPD 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 

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 considers only design 

options that meet the criteria outlined in the screening analysis (see section 2.5).

In this NOPD, DOE considered a number of different potential pathways a customer 

might choose when identifying replacements that are more efficacious. DOE analyzed the 

2-51 
possibility 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 analyzed in this NOPD (based on CCT, lamp wattage, bulb finish, and 

luminaire characteristic) and the criteria used for development are presented in section 2.4.3. Of 

these equipment classes, DOE analyzed 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 are more 

commonly shipped than coated lamps. Finally, for luminaire characteristic, DOE chose enclosedrated to be 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. 

2-52 
Table 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 option 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.

2-53 
NEMA 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 designed 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 Meeting 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 catalogs, 

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 lamps are more commonly sold. 

After considering the comments received in response to the framework document and the 

changes to the equipment class structure, DOE analyzed 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 appropriate representative lamp 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 since 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 replaces it. Because of 

this and the fact that MV lamps comprise less 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 would 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 with the highest volume, which would 

lead the HID baseline lamp to always be MV. (NEMA, Public Meeting Transcript, No. 23 at p. 

2-54 
61; 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 pulsestart 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 efficacious 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 

requested 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 changes 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 consumer 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 instances, 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 (including 

each baseline) based on market share. Using this shipment distribution, the NIA calculates the 

weighted average economic impact. In this way, a MH lamp represents both the baseline and EL 

1 because while it can be a more efficacious substitute for a MV lamp, the least efficacious MH 

lamp may also be representative of the lamp used 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 justified. 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.

2-55 
One additional 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 

the inclusion of a 150 W MH lamp as a baseline selection.

Lastly, as discussed in section 2.4, DOE does not consider starting method as a design 

option in this NOPD. In the 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 and 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 baseline 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 concluded 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 

efficacious 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 number of options for their more efficacious 

substitute lamps, due to the variety of lamp technologies available and wattages that could 

provide the same light output. This section analyzes the issues relevant to these different design 

pathways. 

Fixture Spacing 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.

2-56 
2. 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 alternative 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 commented that it is 

highly unlikely that manufacturers will develop a reduced wattage lamp for every standard 

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

manufacturers 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 stated 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 customer 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 pointed 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 wattage 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 fixture spacing 

2-57 
or 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 because 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 decrease the 

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

In the interim analysis, DOE stated 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 from 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, DOE 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 

pointed 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 ballast and fixture. 

DOE also recognized 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 understands 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 position-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 lamps 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 assume 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. 

2-58 

 
lesser-wattage lamp 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 life. 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 existing 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-start 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 operate 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 wattage retrofit lamps that were used in DOE’s analysis.

In response to the interim analysis, CA IOUs stated 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 energy savings options to improve existing fixtures or to be installed in new fixtures. 

Reduced wattage lamps were designed to be the simplest way for customers to save energy, and 

pulse-start MH and CMH lamp-and-ballast systems have also been designed as energy 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, was 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 efficacious 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 the 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 stated 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 or 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 Meeting Transcript, No. 12 at p. 77) 

DOE acknowledges that MV customers are transitioning to MH and HPS systems, in 

addition to non-HID technology. As discussed in section 2.11, the shipments analysis 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 output, 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 substitutes 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 levels. (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 the 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 this NOPD, DOE 

analyzed up to three more efficacious substitute lamps for the MV baselines corresponding to 

standard efficacy quartz MH, high efficacy quartz MH, and CMH lamps. These more efficacious 

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substitute lamps maintain mean lumens within ten percent of the baseline.p

 DOE also sought to 

keep other lamp characteristics 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 

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

In this NOPD, DOE also analyzed 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 section 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 starting 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 the NOPD 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 lamps 

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 given 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 analysis. 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.

2-61 

 
their 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 proprietary 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 includes 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 subject 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 with 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 HID 

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.

2-62 

 
systems 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 catalogs 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 example, 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, pulse-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 in an attempt to identify the relationship between wattage and efficacy. DOE

analyzed 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 Transcript, 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 

2-63 
progression of lamp efficacy as a function of wattage. Alternatively, an 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 where 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 use equations to set ELs within each

equipment class, while separating lamps with certain efficacy altering characteristics into 

different equipment classes (e.g., bulb finish). In this 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 such, 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 efficacious 

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 would 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 analyzed in this NOPD would not inadvertently eliminate 

any highly efficacious lighting systems. DOE discusses 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 options, 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 

representative equipment class.

NEMA commented that the constants used in the 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 using manufacturer catalog ratings for the basis of the proposed equations, and because 

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different manufacturers can choose to make conservative or aggressive claims in their catalogs, 

DOE cannot focus simply on aggressive claim statements for setting these efficacy 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 recommended 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 interim analysis to represent a particular design 

option, and to just allow the representative units of a particular design option. They were not 

levels that were 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 were 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 that 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, the 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. In this NOPD, the ELs were again modeled to ensure that they 

allowed the representative units of a particular 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.

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In 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×P0.1350 44.4×P0.1350 40.4×P0.1809

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 Systems 

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 fixturer 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 commented 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 that 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 than a ballast for a MH lamp, 

r Here, DOE uses the term “fixture” to refer to the enclosure that houses the lamp and ballast.

2-66 

 
and 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 clarified that some newly developed CMH lamps (which typically 

operate only on pulse-start technology) work on probe-start ballasts. (Philips, Public Meeting 

Transcript, 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 lamp-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 efficacious 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, 

the 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 lamp.

Ballast 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 ballasts with all 

representative CMH lamps. These ballast type to lamp technology 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 EPCA (42 U.S.C. 6295(hh)), DOE assumed the efficiency of the 

representative ballast type would just meet those minimum requirements. For all other fixture 

types, DOE assumed ballast efficiencies representative of the least efficient representative ballast 

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type 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. 24 at p. 

9) DOE does not analyze the regulation of ballast efficiency in this NOPD. However, DOE 

continues to account for any changes in ballast 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 replacing 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. To accurately account for the energy 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 EISA 2007 (42 U.S.C. 6295(hh)) or the 2017 MHLF standards, (2) fixtures 

covered by EISA 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 efficiencies 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 EISA 

2007 compliant efficiencies if they are purchased after January 1, 2009 but before February 10, 

2017 and are covered by the scope of EISA 2007 (42 U.S.C. 6295(hh)). Otherwise, fixtures are 

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assumed 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 and the 

minimum ballast efficiencies required by EISA 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 50o

C, and thus are excluded from EISA 2007.

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Table 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 accommodate 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 change 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-and-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 positioned 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 lengthss

 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.

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CA IOUs stated that customers are more likely to replace only the lamp-and-ballast 

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 MH. 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 savings 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 fixture replacement was 

the more likely customer 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. However, 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 thus 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 fixture replacements as affecting the price of a 

lamp-and-ballast system to the customer, but not affecting the performance. 

In this NOPD, DOE analyzed additional purchase options relative to the interim analysis. 

While full fixture replacement was the most likely 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 more often opt to replace an 

entire fixture instead of retrofitting 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 

2-71 
igniter). 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 fixture’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, retrofitting 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 lampand-ballast system. DOE also acknowledges that this is not an option for every customer, and so 

the models used in this 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 include 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 ballast, 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 and 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 replacement 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 to 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 

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lamp-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 gave 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 existing 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 installing 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 to 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. 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 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. 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 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 the 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 ballast), and option 6 uses the 

compliant lamp with the existing fixture and ballast. The details of the lamps selected are in 

chapter 5 and appendices 5A and 5B of the NOPD TSD. DOE requests comment on the six 

replacement options analyzed in this NOPD. 

2-73 
In 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 the 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 pulse-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 NOPD TSD.

2.6.6 Scaling to Equipment Classes Not Analyzed

For the equipment classes not analyzed directly, DOE discussed an approach in the 

framework 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 

extrapolation 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 engineering 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 

scaling 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 appropriate. (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 identified pairs of lamps in which the only difference 

between the lamps was the parameter under consideration for scaling. For example, to identify 

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the scaling factor between clear lamps and coated lamps, 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 

independent. 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

*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.

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. This manufacturer’s ratings show a 0.75 scaling factor compared to similar pulse-start 

MH lamps, while no other “major” MH manufacturers had more than a single model with a CCT 

greater 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 includes 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 

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were then used to calculate the scaling factors. For this NOPD, DOE allowed pairs of lamps that 

were not in representative equipment classes to be used in the calculations. 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 representative 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 this 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

*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.

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 collect 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 lamps, as well as 

on 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-book 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 pricing 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 

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between 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 analysis 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 this NOPD, DOE continued using the pricing methodology described in the 

interim analysis to estimate lamp prices. However, DOE updated 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 as 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 ballasts 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. 

DOE 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.

2-77 

 
To 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 interim analysis, and received no adverse comment. DOE continued 

with the same approach for this 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 analyzes 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 

ballasts 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-based 

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 this NOPD 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 

Transcript, No. 12 at pp. 104-105) 

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For 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 prices 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 this 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 estimates 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 use 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 this 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-efficacy relationship derived in the engineering 

analysis, as well as 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 compute 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 efficient standard.

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In 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) Regarding 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 estimated electricity prices for commercial, industrial, and 

outdoor stationary sectors using publicly available, state-level U.S. Energy Information 

Administration (EIA) Form 826 data,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 resultsu

 to verify RS

Means labor rates) to estimate installation costs for the LCC and PBP analysis. EEI and NEEA 

commented 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 

lamp lifetimes could vary due to both physical failure and economic factors (e.g., early 

replacements due to retrofits). ASAP and CA IOUs commented 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 capture 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 

2-80 

 
further noted that lumen maintenance is important in instances where lamps are 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 “L70” metric (i.e., the operating hours at which light output 

declines to 70 percent of initial output) is widely 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 comparison 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 maintenance 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. In its review of manufacturer literature, DOE also 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 consider 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 analysis, 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 ballastretrofit kits are analyzed. Lamp failures entail options of full fixture replacement, ballast-retrofit 

kits, and lamp retrofits. ASAP further noted that DOE’s analysis 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 lamp 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 

2-81 
construction, 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 

market 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 equipment 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 scenario. 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 analysis, 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 each 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 cost 

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 the 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 national 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 

2-82 
from the difference between national energy consumption in the base case (without new efficacy 

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 efficacy 

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 calculated net savings each year as the difference between total 

operating cost savings and increases in total installed costs (including price and installation cost). 

DOE calculated savings over the life of the equipment, accounting for differences in yearly 

energy rates. DOE calculated NPV as the difference between the present value of operating cost 

savings and the present value 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 efficacy 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 incorporate these requirements, but nonetheless illustrated 

that new HID lamp standards would not provide net economic benefits for the Nation. 

2-83 
DOE’s interim shipments analysis accounted for non-HID technologies (e.g., LED, highintensity fluorescent) penetrating 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 and 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 changes 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 

manufacturing 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 conducted 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.

2-84 
2.13.1 Discussion of Comments

Interested parties commented on the assumptions and results of the both the framework 

document and the interim analysis. Comments addressed 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 

increasing 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 INPV.

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. 

Manufacturers must determine the extent to which they will balance investment in the HID lamp

market with investment in emerging technologies, such as LEDs. These 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 testing 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 

2-85 
companies 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 subject 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 manufacturers 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 justified, 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 DETERMINATION

DOE analyzed the benefits and burdens of several potential ELs for HID lamps that were 

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 

decades 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 efficacies 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 efficacy 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 feasibility, 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 discussed below. 

2-86 
2.14.1 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 lamps (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 (2017–2046). 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 efficacy 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 classes 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 

2-87 
3-percent discount rate for EL1. Available designs result in negative mean LCC savings for all 

three of the representative equipment classes at EL 1, with 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.

2-88 
REFERENCES

1

 U.S. Census Bureau. Manufacturing, Mining, and Construction Statistics. Current Industrial 

Reports, Electric Lighting Fixtures, MA335L. 2001. (Last accessed March 2, 2012). 

www.census.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 Engineering Society. IES DG-4-03: Design Guide for Roadway Lighting 

Maintenance. 2003. New York, NY. 

2-89 
CHAPTER 3. MARKET AND TECHNOLOGY ASSESSMENT

TABLE OF CONTENTS

3.1 INTRODUCTION ........................................................................................................... 3-1

3.2 LAMPS ANALYZED BY THIS 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 Electronic 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-Regulatory 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 ASSESSMENT .................................................................................. 3-29

3.4.1 Basic Structure and Operation of HID Lamps ................................................... 3-29

3.4.2 Mercury Vapor Lamps ....................................................................................... 3-32

3-i 
3.4.2.1 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-ii
Table 3.3.10 ENERGY STAR Residential and Commercial Directional Luminaire Requirements

.................................................................................................................................................... 3-21

Table 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 Construction23 .................................................................... 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 Seal 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 Configurations 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 Magnetic Ballast .................................................. 3-51

Figure 3.4.15 Electronic HID Ballast ........................................................................................ 3-53

Figure 3.4.16 Electronic HID Ballast Block Diagram ............................................................... 3-53

3-iii
CHAPTER 3. MARKET AND TECHNOLOGY 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 improvement 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 THIS DETERMINATION

In this 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 analyzed 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 category’s potential for energy savings initially using lamp catalog 

data as a proxy for market share, the values for which were then revised and vetted using 

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. 

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 

3-1 
HID lamps final determinationa (hereafter the “2010 determination”) and HID lamps test 

procedure supplemental notice of proposed rulemaking (SNOPR).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 Watts/cm2, including such lamps as 

mercury vapor, metal halide, and high-pressure sodium lamps.

3.2.1.2 Mercury Vapor Lamp 

The CFR defines 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 ultraviolet 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/appliance_standards/rulemaking.aspx/ruleid/21. 

3-2 

 
3.2.1.4 High-Pressure Sodium Lamp

The CFR does currently not define HPS lamps. However, the 2010 determination and test 

procedure SNOPR proposed to adopt the American 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 emitted 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 of 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 lamps with rated wattages ≥50 W 

and ≤2000 W, hereafter 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 of 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 models and their low operating hours provide limited energy 

savings potential. Conversely, as described in chapter 5 of this 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 be 

economically justified for MH lamps rated 50 W – 2000 W in this NOPD. This wattage range 

3-3 
analyzed 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, hereafter 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 

technologically 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 variety 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. 

DOE 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 available 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 economic 

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.

3-4 

 
tentatively 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 with 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. 

Omnidirectional lamps emit light in all directions with approximately equal intensity, whereas 

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

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

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 omnidirectional 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 external 

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 interchangeable parts.b

 

3-5 
A survey of the market revealed that MH and MV lamp types are both available in selfballasted 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 standards for directional lamps. Many of the remaining omnidirectional, self-ballasted 

lamps, which span a range from 160 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 eliminate 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 lamps 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. Furthermore, DOE 

discovered that the reason that such lamps are designated for exclusive use with an electronic

ballast stems from ANSI 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 C78.43-2007e

 or ANSI C78.44-2008f 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 committee, 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, leading 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 operated 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 published 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 forth 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

3-6 

 
market, 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 percent, 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 

properties 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 typical 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 lamps, because a high-CRI MH lamp is 

not currently a cost-saving option. For these reasons, 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 

3-7 
MH 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 define 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 economic 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 cannot 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 this 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://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:076:0017:0044:EN:PDF. 

3-8 

 
which 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 

levels 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 eliminated from the market. Accordingly, in this

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 standards 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 catalogs and observed a 

family of HID lamps predominantly used in the entertainment industry, which is typically 

advertised as lamps for stage, theater, 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 found 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. iDOE 

tentatively determined that although some of these entertainment lamps share similar 

photometric properties used in general lighting purposes, their 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 higher 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. 

3-9 

 
process, 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 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/cm2

; (2) the light-producing arc is stabilized by the arc tube wall temperature; 

(3) the lamp is either an MV, HPS, or MH lamp; and (4) the lamp is an “electric-discharge 

lamp.” Electrodeless HID lamps meet 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-Rated 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 exclusively 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 

technologically 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 – 1000 W are 

technologically feasible and have the potential for energy savings ,and these lamps will be 

3-10
included 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 directional 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 equipment 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 

numerous 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 compose 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 lighting, 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 following: 

• “Advising ... DOE and executive agencies on lighting research and market 

transformation needs 

• Participating in the climate change discussions with the Administration and Congress 

• Monitoring 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
• Supporting 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 programs 

• Advocating 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. Grainger, 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).

3-12
3.3.3 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 federal 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 federal 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 energy 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. 

3-13

 
On 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 this 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 statutorily 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 locations, 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-Intensity-Discharge Lamp Ballasts”].

(42 U.S.C. 6292 (hh)(1)(B)) 

On February 10, 2014, DOE published a final rule for MHLFsc

 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. 

3-14

 
for MHLFs. The final rule prescribed standards for a wider range of wattages, and increased 

minimum ballast efficiency standards where it was deemed technologically feasible, 

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 lamp 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 utilize 

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 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.

††P is defined as the rated 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) 

3-15
 In 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 that 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 temperatures 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 Directives 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 energyefficiency 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 levels in the Table 3.3.7 and 

Table 3.3.8. The EU assigns different requirements to HID lamps based on the nominal wattage 

and bulb finishl

 (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 remains 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 

Index (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)

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Table 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.

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Table 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 having: 

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/klm; 

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. 

3-19
While 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 

3-20
factor, 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 PostMounted 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 (CMH), 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 

qualification requirements for those lamps.

EPA is currently developing a new product specification for lamps that will replace 

existing CFL and integral LED lamp specifications. EPA published a Version 1.0 Specification 

3-21
updating 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 systems. 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-efficient 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 Pacific 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, firstserve 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

3-22
Table 3.3.12 PG&E HID Lamp and Fixture Rebates (2013-2014) 

Description Rebate/Unit Measure

Indoor HID Fixtures with Electronic Ballasts

Existing > 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 manufactured 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 

pulse-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, firstserve basis until all funds are committed, 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

3-23
Table 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 bilevel 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 with 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 Public Power District (OPPD) offers lighting incentives to commercial and 

industrial customers for replacing and retrofitting their current lighting systems to more energyefficient ones. Table 3.3.14 summarizes the financial incentives that OPPD offers related to HID 

retrofits and replacements.

17 18

3-24
Table 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 pulsestart MH Reduced W Direct pulse-start 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 solutions 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 with 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 wattage20

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 energy use. In February 2009, 

NCPMA1 launched the Hometown Green program, which runs the NCMPA1 Lighting Rebate 

Program 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-efficient 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 

regulations.21

3-25
3.3.6 High-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 calibrating 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 NOPD 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 2010

Shipments (millions)

Year

High Pressure Sodium

Mercury Vapor

Probe-Start MH

Pulse-Start and Ceramic MH

3-26
In 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 because 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 shipments 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 while 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 1990 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 CMH 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 2010

Market Share

Year

High Pressure Sodium

Mercury Vapor

Probe-Start MH

Pulse-Start and Ceramic MH

3-27
effective 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 CMH lamps began 

to absorb some of the market share of probe-start MH lamps in 2008. Since then, pulse-start and 

CMH lamps market share has increased at the expense of probe-start MH lamps. The 2010 

market share distribution between 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%

33% 5%

29% HPS

MV

Probe MH

Pulse MH

and CMH

3-28
Table 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 Basic Structure and Operation 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 Starter 

gases 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 lamps also contain

buffer gases, which serve to increase the pressure inside the arc tube to vaporize the light3-29
producing molecules. The arc tube also contains electrodes, typically made of tungsten, that 

deliver an electric field to the arc tube.

The outer bulb that contains 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 the 

environment. The atmosphere in the outer bulb is often a vacuum—though sometimes a lowpressure 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 onto 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 emitted 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 wiring, 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 removing 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 generated 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 electrons 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 withstand 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.

3-30

 
Figure 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

3-31
3.4.2 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, while 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.

3-32

 
Figure 3.4.2 Mercury Vapor Lamp Construction23

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 

metallic 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 contains 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 arc 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 transmittance further by converting some 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-electrode MV lamps are uncommon and 

are used in specialty applications.24

3-33

 
3.4.2.2 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 arc 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. Once 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 

mercury 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 

available 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 lower 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

3-34

 
lamps. 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 coatings 

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 Distributions24

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. The 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 

3-35
therefore 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 initial 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 construction, 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 lamps 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 (Al2O3). However, it is 

grown as a single crystal from molten alumina. As such, it is far purer and denser, and its 

superior mechanical properties allow it to withstand a higher wall loading and achieve higher 

efficacy. Furthermore, DOE found academic papers indicating that 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 that this increase in efficacy is not necessarily true 

(see chapters 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 amalgams 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.

3-36

 
Figure 3.4.4 High-Pressure Sodium Lamp Construction24

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 brazedt

or weldedu 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 brazingv 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 melting 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 “wettability” 

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 cap 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.

3-37

 
Figure 3.4.5 Cross Section of a Typical Seal Assembly for an HPS Lamp with a Ceramic

Arc Tube23

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 starts 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

3-38
turning 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 relatively 

high xenon pressures improving 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 spectrum, 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 adds to the yellow-orange light of the sodium spectrum.23 At sodium pressures 

of 27 kPa or higher, the resulting spectrum is a nearly continuous one, with 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 reradiated in random directions, effectively 

scattering these photons into other wavelengths. The leftmost panel of Figure 3.4.6 shows the 

resulting 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 into the infrared region. HPS lamps with CCTs of 2200 K to 2700 

K and CRI between 65 and 85 have been developed by employing this method. These high-CRI

lamps 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-CRI lamp.

3-39
Figure 3.4.6 High-Pressure Sodium Spectral Power Distributions24

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 primarily 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

Sodium 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 Towards 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 cycling 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 the 

tube. 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 

3-40
accommodate 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 Lamp29

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 values 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 127 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 the 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.

3-41

 
Figure 3.4.8 Metal Halide Lamp Construction24

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 Depending 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 arc 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. 

3-42
Figure 3.4.9 Common Configurations for Horizontal Metal Halide Lamps24

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 lamps 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 switch 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 tube.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 areas, 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

3-43
Figure 3.4.10 Common MH Arc Tubes: (a) Ovoid, (b) Pinched Body24

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 remarkably 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 

3-44
lamps.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 Arc 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 Designs33

3-45
Additive 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 at 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 that react chemically with 

fused silica.23 These advantages allow nearly any metal of the periodic table—including those 

with more desirable emission 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 two 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 phase 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 With 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, I2, near the arc tube wall, whose gas is purple and highly light-absorbing.23

Therefore, excess iodine is typically introduced in the form of mercury iodide, HgI2, which is 

3-46
unstable 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 other 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 used 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 is 

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 with 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 

3-47
industry 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 relamped 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 installations 

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 lowpressure 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 lamps 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 

3-48
starting 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 an 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 metal 

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 the 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 

spectrum 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 Distributions24

3-49
3.4.5 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.” (ANSI 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 lumen 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 this 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 fiber such as silica and housed in a steel case. Figure 3.4.14

presents a view of a typical core and coil assembly.

3-50
Source: GE Lighting

Figure 3.4.14 Core and Coil Assembly of a Magnetic Ballast

The core 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 power 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-reactance autotransformer (HX-HPF), constant-wattage 

autotransformer (CWA), constant-wattage isolated (CWI), and magnetically regulated lag (magreg 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 susceptibility 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 sufficient 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 an 

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.

Constant-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 

3-51
economical size, yet still provides a reasonable degree of wattage regulation. The CWA ballast 

also offers the advantage of an 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 use 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 

important 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 to 

CWA ballasts in both structure and function, the primary difference being a conventional twocoil transformer in place 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 are 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 smaller 

circuitry components and the elimination of a power processing stage from the ballast, highefficiency electronic HID ballasts can be found operating lamps at both high and low 

frequencies. Figure 3.4.15 depicts a typical electronic HID ballast.

3-52
Source: 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 Electronic HID Ballast Block Diagram40

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.

3-53
Table 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. PF 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

3-54
3.4.6 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 desired. 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 retrofit 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 operating 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 lamp 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 also 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 of 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 ballast may be installed external to the fixture. For example, the ballast is installed inside the 

pole in lighting applications that use pole-mounted fixtures.

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3.4.7.2 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 characteristics 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 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 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. 

3-56
Ceramic 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 higher 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, 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).

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; change the 

thickness of quartz; optimize electrode positioning; 

improve the purity of the materials; and improve 

manufacturing processes to ensure the consistency 

and quality of the arc tube

Fill Gas Optimization Optimize the gas fill pressure and chemistry

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3.5 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 directional 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, DOE 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 analyzing standards for selfballasted 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.

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3.5.3 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 an approximation of the color appearance 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 CCT 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 SNOPR 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 shorthand to refer to the CCT value ranges of ≥2800 K and ≤4500 K and >4500 K and <7000 K, 

respectively.

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In the interim analysis, however, DOE noted that the use of light output as a class-setting 

factor could result in HID lamps of the same wattage being placed in separate equipment classes 

and therefore subject to different standards. DOE received feedback that customers typically 

choose lamps based on the wattage, 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 only 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 affecting 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 

provides 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, DOE uses wattage as a potential class-setting factor rather 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 

(ELs) 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 this NOPD TSD. However, even when using an equation to relate efficacy and 

wattage, DOE observed 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 throughout 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. 

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Table 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 classified 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 reduced 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 generate 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 class 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 replacements for coated MV lamps in the applicable CCT ranges, DOE determined that 

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MV 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 that 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-rated.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 comparable to 

traditional enclosed-rated lamps. 

bb DOE proposes to adopt the ANSI C78.380-2007 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/(m2

∙klx) for a reflector lamp. Metal halide Type O lamps must meet specified containment test requirements.” cc DOE proposes to adopt the ANSI C78.380-2007 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/(m2

∙klx) for a reflector lamp.”

dd ANSI C78.380-2007 defines 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 actinic 

UV output of the lamp shall not exceed 2 mW/klm for a non-reflector lamp or 2 mW/(m2

∙klx) for a reflector lamp. 

This letter is not to be used for luminaire designation on lamps other than metal halide.” 

3-62

 
DOE 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 enclosedrated MH lamps are more efficacious than their open-rated counterparts. DOE attributes the 

efficacy gain 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. 

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Table 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 served 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 

3-64
horizontal 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 orientation 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 in the engineering analysis, are discussed in chapter 5 of this 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 

relationship 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 high 

CRI 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. 

3-65
Though certain CRIs 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 reflects 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 efficacy of HID lamps. Therefore, 

DOE does not analyze base type as a class-setting factor in this NOPD. 

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Similar 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 this 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.

3-67
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3-71
CHAPTER 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 ANALYSIS ....................................... 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-i 
CHAPTER 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 document (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 out.

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 justified. (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 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. 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 consider 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. 

4-1 
4.2 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, quartz 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 NOPD 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 Optimization 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 

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 for improving efficacy is a change of technology 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 higher temperatures and pressures in the arc tube, which allows 

4-2 
them 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, however, 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 summarizes 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 use this lamp as an example of CMH lamps 

being commercially available from 401 W – 1000 W.

4-3 

 
Table 4.3.1 Design Options Not Screened Out of the Analysis

Lamp Type NOPD 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 from50 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 – 2000 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. 

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 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 design option for 401 W – 2000 W.

4-4 
4.4.2 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 – 2000 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 – 2000 W) Practicability to manufacture, install, and service

4-5 
CHAPTER 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 REPLACEMENTS ..................................................................... 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 Representative 

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 Lamps ........................................................................................... 5-19

5.7 DETAILED DISCUSSION OF REPRESENTATIVE LAMP 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 Baseline 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-i 
5.7.5.3 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 SUMMARY ................................................................................. 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-ii
Table 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

Table 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 - Retrofit 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-iii
Table 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 Representative 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-iv
CHAPTER 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 efficacious 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 operate 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 analysis 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 selecting 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 measure 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.

5-1 
DOE 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 customers of MH lamp-and-ballast systems incur different costs than customers of 

MV lamp-and-ballast systems. For these reasons, DOE selects both MV and MH lamps as 

baselines for certain equipment classes.

DOE notes that 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 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 this NOPD 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 (maxtech) 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 engineering analysis.

5.3 REPRESENTATIVE EQUIPMENT 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 

5-2 
representative. For CCT, DOE considered the ≥2800 K to ≤4500 K range (hereafter referred to as 

the 2800 K – 4500 K CCT range) to be representative. 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 enclosed-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 that MV lamps would be placed in the enclosed equipment classes. 

5-3 

 
Table 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 – 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

* 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 NOPD TSD as 50 W – 400 W, 401 W – 1000 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 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, reduced-wattage replacements collectively herein as a “representative lamp 

5-4 
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, 

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 classes; 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 that 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 used 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 potential 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 representative 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 selected the most common MV lamps as baseline

lamps. 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 identified to be reduced wattage replacements for MV lamps

and MH baselines, DOE also selected a 400 W MH baseline lamp to analyze. Including this MH 

baseline lamp ensured DOE accurately characterized the HID lamp market because this 400 W 

MH baseline lamp represents 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 lamps representing two separate representative lamp types. Based on 

catalog availability and manufacturer feedback, DOE found the most common, least efficient

lamp in 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 equipment class are shown below in Table 5.3.2. 

5-5 
For 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 REPLACEMENTS

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 replace 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 representative 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 these instances, DOE ensured that either there 

5-6 

 
DOE analyzed all quartz MH lamps and found that the variation 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 

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 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 customer 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 analyzed 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 convenience 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 wattage 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 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.

5-7 

 
technology 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 approach, 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 

constant-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 constant-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 decided not to pursue a constantvalue approach 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 of 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 ELs. 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 

5-8 
Initial 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 EL 

equation.

5.5.2.1 Efficacy Levels for 2800 K – 4500 K, 50 W – 400 W Representative

Equipment Class

In the 2800 K – 4500 K CCT range, 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 separated 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 EL 

equations across all covered wattages. Ensuring continuity between equipment classes prevents 

lamps of slightly different input power being subject to very different standards. 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 ELs above the baseline, which represent commercially available 

standard efficacy quartz MH, high efficacy quartz MH, and CMH 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 below.

Table 5.5.1 Efficacy Levels for 2800 K – 4500 K, 50 W – 400 W Representative Equipment 

Class

Efficacy Level Technology Level Equation

EL 1 Standard Efficacy Quartz MH lm/W = 38.5 × W0.1350

EL 2 High Efficacy Quartz MH lm/W = 44.4 × W0.1350

EL 3 CMH lm/W = 40.4 × W0.1808

5-9 
Figure 5.5.1 Efficacy Levels for 2800 K – 4500 K CCT, 50 W – 400 W Representative

Equipment Class

5.5.2.2 Efficacy 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 ELs 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

50 100 150 200 250 300 350 400

Initial Lamp Efficacy (lm/W)

Lamp Wattage (W)

EL1

EL2

EL3

5-10 
Table 5.5.2 Efficacy Levels for 2800 K – 4500 K, 401 W – 1000 W Representative

Equipment Class

Efficacy Level Technology Level Equation

EL 1 Standard Efficacy Quartz MH lm/W = 0.0116 × W + 81.8

EL 2 High Efficacy Quartz MH lm/W = 0.0173 × W + 92.8

Figure 5.5.2 Efficacy Levels for 2800 K – 4500 K, 401 W – 1000 W Representative

Equipment Class

5.5.2.3 Efficacy 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 93.4 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 1000

Initial Lamp Efficacy (lm/W)

Lamp Wattage (W)

EL1

EL2

5-11 
met 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 Efficacy Level for 2800 K – 4500 K, 1001 W – 2000 W Representative

Equipment Class

Efficacy Level Technology Level Equation

EL 1 High Efficacy Quartz MH lm/W = 93.4

Figure 5.5.3 Efficacy Level for 2800 K – 4500 K CCT, 1001 W – 2000 W Representative

Equipment Class

5.5.2.4 Efficacy 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 2000

Initial Lamp Efficacy (lm/W)

Lamp Wattage (W)

EL1

5-12 
Table 5.5.4 Representative Equipment Class Efficacy Levels

CCT 

Range Wattage Range EL Technology Level Equation

2800 K – 

4500 K

50 W – 400 W

EL 1 Standard Efficacy Quartz MH lm/W = 38.5 × W0.1350

EL 2 High Efficacy Quartz MH lm/W = 44.4 × W0.1350

EL 3 CMH lm/W = 40.4 × W0.1808

401 W – 1000 W

EL 1 Standard Efficacy Quartz MH lm/W = 0.0116 × W + 81.8

EL 2 High Efficacy Quartz MH lm/W = 0.0173 × W + 92.8

1001 W – 2000 W EL 1 High Efficacy Quartz MH lm/W = 93.4

Figure 5.5.4 Efficacy 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 fixturee 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 2000

Initial Lamp Efficacy (lm/W)

Lamp Wattage (W)

EL1

EL2

EL3

5-13 

 
expected 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 fixture, 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 all 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 reaches 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 reaches 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 

5-14 
followed 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 temperatures 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 type of ballast to use 

for the MH representative lamp types, DOE analyzed 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 feasible 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 retrofit and the ballast 

being replaced is magnetic, a customer shifting to a CMH lamp is assumed to use a replacement ballast that is pulsestart magnetic. This assumption is made because, while CMH lamps can run on pulse-start magnetic or pulse-start 

5-15 

 
Table 5.6.1 Representative 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 

characterized 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 these 

potential standards must have ballasts that comply with the energy conservation standards 

rulemaking for metal halide lamp fixtures (MHLFs), hereafter referred to as the 2014 MHLF 

rule.

g Fixtures purchased before the compliance date of these 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. One 

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 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 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://www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/16.

5-16 

 
Table 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 50o

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 increase lamp efficacy while also decreasing system power. 

5-17 
5.6.3 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 an 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 ballasts 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 standards 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 an HID lamp with a more efficacious substitute, 

a change in ballast is often required. After seeking input from manufacturers of both HID lamps 

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 replacement lamp-and-ballast systems will be a different size, and will not fit into the 

existing fixture. Changing lamp-and-ballast systems risks resulting in non-optimal optics with 

the 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 of 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 instances where the wattage is 

being reduced and thus the size will likely drop. In terms of optics, customers 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 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 

h UL, or Underwriters Laboratories, is an organization that independently certifies a wide variety of product safety, 

including luminaires. When HID fixture manufacturers submit products 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.

5-18 

 
system can decertify a fixture’s UL rating, DOE has tentatively determined that some customers

would still choose to do so. Thus DOE is modeling a portion of customers, in specific 

replacement options where it is technologically feasible, retrofitting existing fixtures with a new 

lamp-and-ballast systems instead of replacing the entire fixture. 

5.6.5 Replacement Lamps

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 Lamps 

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, 

customers already have MH systems and when the lamps need to be replaced, they purchase 

more efficacious lamps that are compatible with the existing systems. 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 

5-19 
pathway. 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. The least efficacious MH lamp with similar characteristics to the 100 W MV 

baseline was a 70 W quartz MH lamp.

5-20 
Table 5.7.1 Baseline Lamps 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 Standard Efficacy Quartz MH 70 3000 78.6 3000 Universal

5.7.1.2 Efficacy 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 ELs. 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)) 

Table 5.7.2 Summary of the ELs for the 100 W MV Representative Lamp Type

EL Technology Level Initial Efficacy Requirement

MH Baseline/EL 1 Standard Efficacy Quartz MH lm/W = 38.5 × W0.1350

EL 2 High Efficacy Quartz MH lm/W = 44.4 × W0.1350 

EL 3 CMH lm/W = 40.4 × W0.1808

 

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 

ELs.

5-21 
Figure 5.7.1 Efficacy 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 identified 

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/EL 1 Standard Efficacy

Quartz MH 70 3000 78.6 3000 Universal

EL2* N/A N/A N/A N/A N/A N/A

EL 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 95 100

Initial 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

5-22 
Table 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

5-23 
5.7.1.3 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 Wattage EL Lamp Type Starting Method Arc Tube Wattage W CCT K Initial Lumens Initial Efficacy lm/W Mean Lumens Change in Mean Lumens From Baseline

%

Mean Efficacy lm/W

Operating Orientation

Bulb Finish

Ballast Type

Ballast Efficiency 

%

Lamp-and-Ballast System 

Power 

W

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/

EL 1

N/A Pulse Quartz 70 4000 5500 78.6 3000 +7.1% 42.9 Universal Clear MH 

Magnetic 78.2 89.5

EL 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

EL 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.

5-24 
Table 5.7.6 Engineering Summary for 100 W MV Representative Lamp Type - Equal Wattage EL Lamp Type Starting Method Arc Tube Wattage W CCT K Initial Lumens Initial Efficacy lm/W Mean Lumens Mean Efficacy lm/W Operating Orientation Bulb Finish

Ballast Type

Ballast Efficiency 

%

Lamp-and-Ballast 

System Power 

W

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

5-25 
5.7.2 175 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 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 175 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, bulb 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 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. The least efficacious MH lamp with similar characteristics to the 175 W MV 

baseline was a 150 W quartz MH lamp.

Table 5.7.7 Baseline Lamps 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 Efficacy 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 ELs. Finally, DOE tentatively 

5-26 
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 5.7.8 Summary of the ELs for the 175 W MV Representative Lamp Type

EL Technology Level Initial Efficacy Requirement

MH Baseline/EL 1 Standard Efficacy Quartz MH lm/W = 38.5 × W0.1350

EL 2 High Efficacy Quartz MH lm/W = 44.4 × W0.1350

EL 3 CMH lm/W = 40.4 × W0.1808

Figure 5.7.2 illustrates the three ELs 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 technologies in this representative lamp type, while the lines correspond to the three 

ELs.

Figure 5.7.2 Efficacy Levels for the 175 W MV Representative Lamp Type

Table 5.7.9 summarizes the lamp designs for the 175 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 

0

20

40

60

80

100

120

55 70 85 100 115 130 145 160 175 190

Initial 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

5-27 
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 5.7.2 and are summarized in Table 5.7.10. 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 5.7.9 Lamp Designs for the 175 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/EL 1 Standard Efficacy

Quartz MH 150 3000 75.0 8000 Universal

EL 2 High Efficacy Quartz

MH 100 4000 68.0 7200 Universal

EL 3 CMH 75 3000 90.0 6708 Universal

Table 5.7.10 Lamp Designs for the 175 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

5-28 
5.7.2.3 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 175 W MV Representative Lamp Type - Reduced Wattage EL Lamp Type Starting Method Arc Tube Wattage

W

CCT

K

Initial Lumens

Initial Efficacy

lm/W

Mean Lumens

Change in Mean Lumens From 

Baseline

%

Mean Efficacy

lm/W

Operating Orientation

Bulb Finish

Ballast Type

Ballast Efficiency

%

Lamp-and-Ballast System 

Power

W

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 Baseline/

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

5-29 
Table 5.7.12 Engineering Summary for 175 W MV Representative Lamp Type - Equal Wattage EL Lamp Type Starting Method Arc Tube Wattage

W

CCT

K

Initial Lumens

Initial Efficacy

lm/W

Mean Lumens

Change in Mean Lumens From 

Baseline

%

Mean Efficacy

lm/W

Operating Orientation

Bulb Finish

Ballast Type

Ballast Efficiency

%

Lamp-and-Ballast System 

Power

W

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

5-30 
5.7.3 250 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 equipment class.

5.7.3.1 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 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 lamp with similar 

characteristics to the 250 W MV baseline was a 175 W quartz MH lamp.

Table 5.7.13 Baseline Lamps 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 Efficacy 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 

5-31 
design options are the basis upon which DOE developed ELs. 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)) 

Table 5.7.14 Summary of the ELs for the 250 W MV Representative Lamp Type 

EL Technology Level Initial Efficacy Requirement

MH Baseline/EL 1 Standard Efficacy Quartz MH lm/W = 38.5 × W0.1350 

EL 2 High Efficacy Quartz MH lm/W = 44.4 × W0.1350 

EL 3 CMH lm/W = 40.4 × W0.1808 

 

Figure 5.7.3 illustrates the three ELs 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 ELs.

Figure 5.7.3 Efficacy 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 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 

0

20

40

60

80

100

120

75 100 125 150 175 200 225 250 275

Initial 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

5-32 
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 5.7.3 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/EL 1 Standard Efficacy

Quartz MH 175 4000 77.7 7400 Universal

EL 2 High Efficacy Quartz

MH 150 4000 90.0 7200 Universal

EL 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

5-33 
5.7.3.3 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 Wattage EL Lamp Type Starting Method Arc Tube Wattage

W

CCT

K

Initial Lumens

Initial Efficacy

lm/W

Mean Lumens

Change in Mean Lumens 

From Baseline

%

Mean Efficacy

lm/W

Operating Orientation

Bulb Finish

Ballast Type

Ballast Efficiency

%

Lamp-and-Ballast System 

Power

W

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

5-34 
Table 5.7.18 Engineering Summary for 250 W MV Representative Lamp Type - Equal Wattage EL Lamp Type Starting Method Arc Tube Wattage

W

CCT

K

Initial Lumens

Initial Efficacy

lm/W

Mean Lumens

Mean Efficacy

lm/W

Operating Orientation

Bulb Finish

Ballast Type

Ballast Efficiency

%

Lamp-and-Ballast 

System Power

W

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

5-35 
5.7.4 400 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 equipment class.

5.7.4.1 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 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 

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 lamp with similar 

characteristics to the 400 W MV baseline was a 250 W quartz MH lamp.

Table 5.7.19 Baseline Lamps 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 Efficacy 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 ELs. Finally, DOE tentatively 

5-36 
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 5.7.20 Summary of the ELs for the 400 W MV Representative Lamp Type 

EL Technology Level Initial Efficacy Requirement

MH Baseline/EL 1 Standard Efficacy Quartz MH lm/W = 38.5 × W0.1350 

EL 2 High Efficacy Quartz MH lm/W = 44.4 × W0.1350 

EL 3 CMH lm/W = 40.4 × W0.1808 

Figure 5.7.4 illustrates the three ELs 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 four technologies in this representative lamp type, while the lines correspond to the 

three ELs. 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 Efficacy Levels for the 400 W MV Representative Lamp Type

0

20

40

60

80

100

120

125 150 175 200 225 250 275 300 325 350 375 400

Initial 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

5-37 
Table 5.7.21 summarizes the lamp designs for the 400 W MV baseline and the reduced 

wattage, increased efficacy replacement 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.

5-38 
Table 5.7.22 Lamp 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

5-39 
Table 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 EL 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 such 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 options. 

Table 5.7.24 Engineering Summary for 400 W MV Representative Lamp Type - Reduced Wattage EL Lamp Type Starting Method Arc Tube Wattage

W

CCT

K

Initial Lumens

Initial Efficacy

lm/W

Mean Lumens

Change in Mean Lumens 

From Baseline

%

Mean Efficacy

lm/W

Operating Orientation

Bulb Finish

Ballast Type

Ballast Efficiency

%

Lamp-and-Ballast System 

Power

W

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

EL 1

MH Pulse Quartz 250 3800 22,000 88.0 15,400 -2.7 61.6 Universal Clear MH Magnetic 88.8 281.5

EL 2 MH Pulse Quartz 200 4000 19,000 95.0 16,300 +3.3 81.7 Horizontal Clear MH Magnetic 88.0 227.3

EL 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

5-40 
Table 5.7.25 Engineering Summary for 400 W MV Representative Lamp Type - Equal Wattage EL Lamp Type Starting Method Arc Tube Wattage

W

CCT

K

Initial Lumens

Initial Efficacy

lm/W

Mean Lumens

Mean Efficacy

lm/W

Operating Orientation

Bulb Finish

Ballast Type

Ballast Efficiency

%

Lamp-and-Ballast System 

Power

W

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 400 W MV Representative Lamp Type - Retrofit Lamps EL Lamp Type Starting Method Arc Tube Wattage

W

CCT

K

Initial Lumens

Initial Efficacy

lm/W

Mean Lumens

Change in 

Mean 

Lumens 

From 

Baseline

%

Mean Efficacy

lm/W

Operating Orientation

Bulb Finish

Ballast Type

Ballast Efficiency

%

Lamp-and-Ballast System 

Power

W

MH 

Baseline/

EL 1

MH Probe Quartz 325 4000 28,000 86.2 12,200 -22.7 37.5 Universal Clear MV 

Magnetic 86.8 374.4

5-41 
5.7.5 400 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 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 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 Lamps 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/

EL 1

Standard 

Efficacy Quartz 

MH

400 4000 36,000 90.0 24,000 60.0 Universal

5.7.5.2 Efficacy 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 basis upon which 

DOE developed ELs and optimizing arc tube construction 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 required by section 325(o) of EPCA. (42 

U.S.C. 6295 (o)) 

5-42 
Table 5.7.28 Summary of the ELs for the 400 W MH Representative Lamp Type 

EL Technology Level Initial Efficacy Requirement

MH Baseline/EL 1 Standard Efficacy Quartz MH lm/W = 38.5 × W0.1350 

EL 2 High Efficacy Quartz MH lm/W = 44.4 × W0.1350 

EL 3 CMH lm/W = 40.4 × W0.1808 

 

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 ELs.

Figure 5.7.5 Efficacy 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

225 250 275 300 325 350 375 400

Initial 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/EL 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

EL 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

5-44 
Table 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 Wattage EL Lamp Type Starting Method Arc Tube Wattage 

W

CCT

K

Initial Lumens

Initial Efficacy

lm/W

Mean Lumens

Change in Mean Lumens 

From Baseline

%

Mean Efficacy

lm/W

Operating Orientation

Bulb Finish

Ballast Type

Ballast Efficiency

%

Lamp-and-Ballast System 

Power

W

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

/EL 1

MH Probe Quartz 400 4000 36,000 90.0 24,000 N/A 60.0 Universal Clear MH Magnetic 86.0 465.1

EL 2 MH Pulse Quartz 320 4000 31,000 96.9 26,000 +8.3 81.3 Universal Clear MH Magnetic 89.6 357.1

EL 3 MH Pulse Ceramic 250 3700 28,000 112.0 23,800 -0.8 95.2 Universal Clear HPS Magnetic 84.0 297.6

5-45 
Table 5.7.33 Engineering Summary for 400 W MH Representative Lamp Type - Equal Wattage EL Lamp Type Starting Method Arc Tube Wattage

W

CCT

K

Initial Lumens

Initial Efficacy

lm/W

Mean Lumens

Mean Efficacy

lm/W

Operating Orientation

Bulb Finish

Ballast Type

Ballast Efficiency

%

Lamp-and-Ballast System 

Power

W

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 400 W MH Representative Lamp Type - Retrofit Lamps EL Lamp Type Starting Method Arc Tube Wattage

W

CCT

K

Initial Lumens

Initial Efficacy

lm/W

Mean Lumens

Change in 

Mean 

Lumens 

From 

Baseline

%

Mean Efficacy

lm/W

Operating Orientation

Bulb Finish

Ballast Type

Ballast Efficiency

%

Lamp-and-Ballast System 

Power

W

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

5-46 
5.7.6 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 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 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 identified 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 Lamps 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 Efficacy 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. These design options are the basis upon which 

DOE developed ELs. 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)) 

5-47 
Table 5.7.36 Summary of the ELs for the 1000 W MV Representative Lamp Type

EL Technology Level Initial Efficacy Requirement

MH Baseline/EL 1 Standard Efficacy Quartz MH lm/W = 0.0116 × W + 81.8

EL 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 ELs.

Figure 5.7.6 Efficacy 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 1000

Initial 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

5-48 
Table 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/EL 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

5-49 
5.7.6.3 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 Wattage EL Lamp Type Starting Method Arc Tube Wattage

W

CCT

K

Initial Lumens

Initial Efficacy

lm/W

Mean Lumens

Change in Mean Lumens 

From Baseline

%

Mean Efficacy

lm/W

Operating Orientation

Bulb Finish

Ballast Type

Ballast Efficiency

%

Lamp-and-Ballast System 

Power

W

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/

EL 1

MH Pulse Quartz 750 4000 68,000 90.7 47,600 -1.9 63.5 Horizontal Clear MH Magnetic 91.0 824.2

EL 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

5-50 
Table 5.7.40 Engineering Summary for 1000 W MV Representative Lamp Type - Equal Wattage EL Lamp Type Starting Method Arc Tube Wattage 

W

CCT

K

Initial Lumens

Initial Efficacy

lm/W

Mean Lumens

Change in Mean Lumens 

From Baseline

%

Operating Orientation

Bulb Finish

Ballast Type

Ballast Efficiency

%

Lamp-and-Ballast System 

Power

W

MH 

Baseline/EL 1 MH Pulse Quartz 1000 3400 110,000 110.0 79,000 +62.9 Horizontal 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

5-51 
5.7.7 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 lamps 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 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 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 Efficacy Levels and More Efficacious Substitutes

As outlined in chapter 4 of this 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 ELs. 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)) 

5-52 
Table 5.7.42 Summary of the ELs for the 1000 W MH Representative Lamp Type

EL Technology Level Initial Efficacy Requirement

MH Baseline/EL 1 Standard Efficacy Quartz MH lm/W = 0.0116 × W + 81.8

EL 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 representative lamp type, while the lines correspond to the two ELs.

Figure 5.7.7 Efficacy 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 1000

Initial Lamp Efficacy (lm/W)

Wattage (W)

EL1

EL2

EL3

MH Baseline/ EL 1 Representative Unit

EL 2 Representative Unit

Equal Wattage Units

5-53 
Below, 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 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 5.7.7 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/EL 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

5-54 
5.7.7.3 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 Wattage EL Lamp Type Starting Method Arc Tube Wattage

W

CCT

K

Initial Lumens

Initial Efficacy

lm/W

Mean Lumens

Change in Mean Lumens From 

Baseline

%

Mean Efficacy

lm/W

Operating Orientation

Bulb Finish

Ballast Type

Ballast Efficiency

%

Lamp-and-Ballast

System Power

W

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/

EL 1 MH Pulse Quartz 1000 3400 110,000 110.0 77,000 N/A 77.0 Horizontal Clear MH 

Magnetic 91.8 1089.3

EL 2 MH Pulse Quartz 875 4000 96,000 109.7 82,500 +7.1 94.3 Universal Clear MH 

Magnetic 92.3 948.0

5-55 
Table 5.7.46 Engineering Summary for 1000 W MH Representative Lamp Type - Equal Wattage EL Lamp Type Starting Method Arc Tube Wattage

W

CCT

K

Initial Lumens

Initial Efficacy

lm/W

Mean Lumens

Mean Efficacy

lm/W

Operating Orientation

Bulb Finish

Ballast Type

Ballast Efficiency

%

Lamp-and-Ballast

System Power

W

EL 2 MH Probe Quartz 1000 3700 115,000 115.0 82,000 82.0 Universal Clear MH 

Magnetic 93.6 1068.4

5-56 
5.7.8 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 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 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 representative 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 characteristics 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 operating 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 Efficacy 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 ELs. 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. 

5-57 
Table 5.7.48 Summary of the EL for the 1000 W MV Representative Lamp Type 

EL Technology Level Initial Efficacy Requirement

EL 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 

EL.

Figure 5.7.8 Efficacy 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 2000

Initial Lamp Efficacy (lm/W)

Wattage (W)

EL1

Baseline Representative Unit

EL 1 Representative Unit

Equal Wattage Units

5-58 
Table 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

5-59 
5.7.8.3 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 Wattage EL Lamp Type Starting Method Arc Tube Wattage

W

CCT

K

Initial Lumens

Initial Efficacy

lm/W

Mean Lumens

Change in Mean Lumens From 

Baseline

%

Mean Efficacy

lm/W

Operating Orientation

Bulb Finish

Ballast Type

Ballast Efficiency

%

Lamp-and-Ballast

System Power

W

Baseline MH Pulse Quartz 2000 4000 170,000 85.0 153,000 N/A 76.5 Horizontal Clear MH 

Magnetic 95.0 2105.3

EL 1 MH Probe Quartz 1500 3700 155,000 103.3 140,000 -8.5% 93.3 Universal Clear MH 

Magnetic 92.9 1614.6

5-60 
Table 5.7.52 Engineering Summary for 2000 W MH Representative Lamp Type - Equal Wattage EL Lamp Type Starting Method Arc Tube Wattage

W

CCT

K

Initial Lumens

Initial Efficacy

lm/W

Mean Lumens

Mean Efficacy

lm/W

Operating Orientation

Bulb Finish

Ballast Type

Ballast Efficiency

%

Lamp-and-Ballast

System Power

W

EL 1 MH Pulse Quartz 2000 4000 200,000 100.0 170,000 85.0 Horizontal Clear MH 

Magnetic 95.0 2105.3

5-61 
5.7.9 Summary of Representative Lamp Type Efficacy Levels

The figures below depict the EL 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 75 100 125 150 175 200 225 250 275 300 325 350 375 400

Initial Lamp Efficacy (lm/W)

Wattage (W)

EL1

EL2

EL3

MV Baseline Representative Unit

MH Baseline/ EL 1 Representative Unit

EL 2 Representative Unit

5-62 
Figure 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 1000

Initial Lamp Efficacy (lm/W)

Wattage (W)

EL1

EL2

MV Baseline Representative Unit

MH Baseline/ EL 1 Representative Unit

EL 2 Representative Unit

5-63 
Figure 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-rated and openrated luminaire 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 between 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 2000

Initial Lamp Efficacy (lm/W)

Wattage (W)

EL1

MV Baseline Representative Unit

MH Baseline/ EL 1 Representative Unit

5-64 
and 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 

luminaire 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. Therefore,

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, coated 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-rated equipment classes were 

multiplied by a scaling factor of 0.950 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

Clear 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. 

5-65 

 
5.8.3 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 efforts 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 the 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* 0.945 0.950 0.812

*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. 

5-66 
Table 5.9.1 Efficacy Level Equations CCT Range Wattage Bulb Finish* Luminaire Characteristic**

EL1 EquationEL2 EquationEL3 Equation

2800 K – 

4500 K

50 W – 

400 W

Clear

Enclosed lm/W = 38.5×P0.1350 lm/W = 44.4×P0.1350 lm/W = 40.4×P0.1808

Open lm/W = 0.950× (38.5×P0.1350) lm/W = 0.950× (44.4×P0.1350) lm/W = 0.950× (40.4×P0.1808) 

Coated

Enclosed lm/W = 0.945× (38.5×P0.1350) lm/W = 0.945× (44.4×P0.1350) lm/W =

0.945× (40.4×P0.1808) 

Open lm/W = 0.945×0.950×(38.5×P0.1350) lm/W = 0.945×0.950×(44.4×P0.1350) lm/W =

0.945×0.950× (40.4×P0.1808) 

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×P0.1350) lm/W = 0.812×(44.4×P0.1350) lm/W = 0.812×(40.4×P0.1808) 

Open lm/W = 0.812×0.950×(38.5×P0.1350) lm/W = 0.812×0.950×(44.4×P0.1350) lm/W =

0.812×0.950×(40.4×P0.1808) 

Coated

Enclosed lm/W = 0.812×0.945×(38.5×P0.1350) lm/W = 0.812×0.945×(44.4×P0.1350) lm/W =

0.812×0.945×(40.4×P0.1808) 

Open lm/W = 0.812×0.945×0.950×

(38.5×P0.1350) 

lm/W = 0.812×0.945×0.950×

(44.4×P0.1350) 

lm/W =

0.812×0.945×0.950×

(40.4×P0.1808) 

5-67 
CCT Range

Wattage

Bulb Finish*

Luminaire 

Characteristic**

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.

5-68 
CHAPTER 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-i 
CHAPTER 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 (NOPD). In energy conservation standards rulemakings, DOE 

often develops cost-efficiency relationships in the engineering analysis. Then, DOE applies 

markups to derive end-user prices. For this NOPD, DOE derived efficacy levels (ELs) in the 

engineering analysis (chapter 5 of this 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; the lamps are not easily disassembled, and fill 

gas 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 this NOPD TSD).

Because DOE recognizes that customers may be required to purchase new ballasts and 

fixtures to accommodate higher efficacy HID lamps, DOE also developed prices for HID ballasts 

and fixtures. Appendix 6A of this NOPD TSD describes the methodology used to derive the 

manufacturer selling prices (MSPs) for the representative HID ballasts and fixtures that are 

analyzed in the engineering analysis. 

6.2 METHODOLOGY

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 observation 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 collected 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 therefore 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 

6-1 
appropriate, to derive the total, installed end-user cost for the LCC analysis (chapter 9 of this

NOPD TSD).

DOE analyzed lamp prices for reduced wattage and equal wattage replacement options 

outlined in the engineering analysis (chapter 5 of this NOPD TSD). For the representative lamps 

for 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, DOE 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 starting 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 the 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.

6-2 
6.3 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 low, medium, and high end-user 

prices for reduced wattage retrofit HID lamps. Prices for the representative HID ballasts and fixtures 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

Probe

Pulse** 

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

6-3 
Lamp 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 enclosed equipment 

classes for their respective wattage and CCT.

**Where pulse- and probe-start lamp options are presented, the starting method indicated corresponds to the representative lamp for the equipment class.

6-4 
Table 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

6-5 
Lamp 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 options 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

Baseline N/A -- 100 -- -- --

EL 1/Baseline MH N/A -- 70 -- -- --

EL 2 N/A -- -- -- -- --

EL 3 N/A -- 50 -- -- --

6-6 
Lamp 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.

**Where pulse- and probe-start lamp options are presented, the starting method indicated corresponds to the representative lamp for the equipment class.

6-7 
CHAPTER 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 WHOLESALER, CONTRACTOR, AND 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-i 
CHAPTER 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 

it 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. For 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 and 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 

7-1 
calculate the first costs that customers would face under the various efficacy 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 analysis (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:

END MFR ×= MUPP WHOLE MUCONT ×× MUTAX ) (

Eq. 7.1 

Where:

PEND = equipment price to the end-user ($),

PMFR = MSP of baseline or standard-level equipment ($),

MUWHOLE = wholesaler markup, 

MUCONT = contractor markup, and 

MUTAX = 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 changes 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 ballasts, fixtures, and related equipment because DOE 

does not expect 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 calculation of baseline markups: 

PWHOLE _ BASE = PMFR _ BASE × ( MUWHOLE _ BASE)

Eq. 7.2 

PCONT _ BASE = (PWHOLE _ BASE × MUCONT _ BASE)

Eq. 7.3 

PEND _ BASE = (PCONT _ BASE × MUTAX ) 

Eq. 7.4 

Where:

PMFR _ BASE = MSP of baseline equipment ($), 

7-2 
PWHOLE _ BASE = wholesaler selling price of baseline equipment ($), 

PCONT _ BASE = contractor selling price of baseline equipment ($), 

PEND _ BASE = end-user purchase price for baseline equipment ($), 

MUWHOLE _ BASE = wholesaler markup for baseline equipment, 

MUCONT _ BASE = contractor markup for baseline equipment, and 

MUTAX = sales tax markup. 

7.2 ESTIMATION OF WHOLESALER, 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 Exchange Commission (SEC). 

Filed 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 wholesaler 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 income 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 Profit Margin

Gross Profit

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: 

 ofCost Sales

Net Sales

1( Gross Profit Margin)

1 Baseline Markup = − =

Eq. 7.7 

Table 7.2.1 contains the calculated gross profit margins for a sample of electrical 

wholesalers. 

7-3 
Table 7.2.1 Gross Profit Margins for Electrical Wholesalers*

Company

Financial 

Figure

$

Year

2012 2011 2010 2009 2008 

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 1.23

Average 1.23

7.2.2 Sales Tax 

The sales tax rate represents state 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 state 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 developed for the LCC and 

PBP analysis. 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.

7-4 
Table 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 

Average 

7.13

7-5 
REFERENCES

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) 

7-6 
CHAPTER 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 ENERGY 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-i 
CHAPTER 8. ENERGY USE ANALYSIS

8.1 PURPOSE OF THE DOCUMENT

This chapter presents the methodology the U.S. Department of Energy (DOE) followed to 

estimate the annual energy use of the high-intensity discharge (HID) lamp designs DOE 

considered in the HID lamp notice of proposed determination (NOPD) analyses. 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)

chapter 9) and the national impact analysis (NIA; NOPD TSD chapter 11). DOE requires 

information on annual energy use to determine the potential energy and operating cost savings to 

customers from the use of more efficient equipment.

DOE determined 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 chapter 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 for a typical year, DOE 

developed annual operating hours by sector. For the LCC, DOE accounted 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 for 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 used 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 aggregated 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 

distribution 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, 

8-1 
DOE 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 6113

Outdoor Stationary 4399

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 calculations. 

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 operating in the 

industrial sector. DOE used this distribution of annual operating hours in the LCC calculation. 

0

1000

2000

3000

4000

5000

Hours of Operation per Year

Building Type

Commercial Sector Operating Hours by Building Type

8-2 
Figure 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 used this distribution of annual operating hours in the LCC 

calculations. 

Figure 8.2.3 Outdoor Stationary Sector Annual Operating Hour Distribution by 

Installation Type

5200

5400

5600

5800

6000

6200

6400

6600

6800

Hours 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 Roadway

Hours of Operation per Year

Building Type

Outdoor Stationary Operating Hours by Application

8-3 
8.3 RESULTS OF THE ENERGY USE ANALYSIS

DOE calculated 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 analysis and the NIA to calculate the operating cost of systems and 

to estimate the potential energy savings of the considered efficacy levels. 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/ruleid/23. 

8-4 
REFERENCES

1. U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Building 

Technologies Program. 2010 U.S. Lighting Market Characterization. January 2012. DOEEERE: Washington, D.C. <http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/ 

2010-lmc-final-jan-2012.pdf> 

8-5 
CHAPTER 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 INPUTS ...................................................................................... 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 PERIOD 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-i 
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) .............................................................. 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-ii
CHAPTER 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 consumers 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 conservation standards for HID 

lamps; however, the characteristics 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 chapter 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-efficient 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 

spreadsheets 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 9A 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 

9-1 
discount 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 consumers to replace existing 

equipment or install new equipment. DOE analyzed the LCCs of three distinct triggering events. 

The “fixture” event signifies a consumer installing 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 analysis on the baseline HID lamp systems from the 

representative equipment classes identified in the HID market and technology assessment. 

NOPD TSD chapter 3 presents 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; clear; enclosed

The time period used for the LCC and PBP analyses in this rulemaking is the average

remaining lifetime of the baseline HID lamp fixture. Recognizing that several inputs to the LCC 

and PBP analysis are either variable or uncertain, DOE incorporates 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, the LCC represents the total consumer expense over the 

analysis period, including purchase expenses, operating costs (including energy expenditures), 

and installation costs. DOE discounted future operating costs to the time of purchase and 

summed them over the analysis period. The PBP represents the number of years it takes 

consumers 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 

operating costs in the first year. 

DOE categorized 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 operation of the HID lamp system otherwise known as 

the operating cost.

9-2 
The 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 then 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 consumers 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 equipment 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 determined 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 

determined the power ratings for the HID fixtures considered in the analysis. 

• Electricity Prices: DOE uses the average price per kilowatt-hour ($/kWh) paid by 

consumers. DOE determined electricity 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 for all 50 states and the District of Columbia. DOE 

developed electricity price inputs using 2013 U.S. Energy Information Administration 

(EIA) data.

• Electricity Price Trends: DOE uses the EIA’s Annual Energy Outlook 2013

(AEO2013) to project electricity prices.1

 For the results presented in this chapter, 

DOE used the AEO2013 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 discount rate is the rate at which DOE discounted future 

expenditures to establish their present value. 

• Analysis Period: Analysis period is the time span over which DOE calculates the 

LCC. For the NOPD analysis, it was assumed as equal to the average remaining 

baseline fixture lifetime for each equipment class.

9-3 
Figure 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 of 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.

9-4 
Table 9.1.1 Summary Information of Inputs for the Life-Cycle Cost and Payback Period 

Analysis

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

OC RC 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$). 

9-5 
9.2.2 Total Installed Cost Inputs

The total installed cost to the consumer is defined by the following equation: 

IC FEP += INST

Eq. 9.2 

Where: 

FEP = 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 developed 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 determine the total installed 

costs: 

• end-user equipment price ($)

• sales tax ($), and 

• installation 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 state 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 calculated the 

total installed cost for the HID systems, analyzed based on the following equation: 

PRICE MU INST

IC FEP INST

TAX +×=

+=

Eq. 9.3 

Where: 

IC = total installed cost,

FEP = final equipment price, 

INST = installation cost,

PRICE = end-user equipment price, and

MUTAX = sales tax mark up. 

As mentioned previously, DOE also considers various scenarios that prompt consumers 

to replace existing equipment or install new equipment. DOE analyzed the LCCs of three distinct 

triggering events. The “fixture” event signifies a consumer installing an entire HID fixture with 

9-6 
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. 

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 addressing equipment

price trends. For this NOPD analysis and consistent with the NODA, DOE examined two 

methods for estimating price trends for HID lamp systems: using historical 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 prices using deflators 

used by EIA to develop the AEO. When adjusted for inflation, the deflator-based price indices 

decline from 1.00 in 2017 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. 

Chapters 6 and 7 of the NOPD TSD provide detail on end-user equipment prices 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 20102 as well as other research to estimate the installation costs. 

During the January 2012 public meeting for the framework 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 fixture is equal. DOE also assumed that all lamp replacements 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 the reference is document 

number 8 in the docket for the metal halide lamp fixtures energy conservation standards rulemaking, and appears at 

page 16 of that document.

9-7 

 
replacements, versus the group relamping more prevalent in fluorescent lamp systems. Table 

9.2.1 lists installation costs by equipment class to install an HID fixture, ballast, or lamp. 

Table 9.2.1 Installation Costs for HID Lamp System Components 

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, costs of related equipment (e.g., bucket truck), and 

labor rates for electricians from RS Means3 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 ($/kWh) 

• 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 

9-8 
present 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 calculate 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 AEO2013 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 costs by the following equation: 

( PWR OH ) EPTEP

OC Econs EPTEP

= ×××

××=

)1000/(

Eq. 9.4 

Where:

OC = operating costs,

Econs = annual energy consumed, 

EP = electricity price,

EPT = electricity price trend factor relative to 2012, 

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 standards-compliant equipment. An important input in

determining the energy consumption is the total hours per year that the equipment is in operation. 

DOE established operating hour distributions for HID fixtures based 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 Average Annual Operating

hr/yr

Commercial 3615

Industrial 6113

Outdoor Stationary 4399

Sports Lighting (>1000 W) 350

9-9 
9.2.3.2 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 Form 826 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

Delaware 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

9-10
State

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 AEO2013 price estimates to compute real 

price increases. DOE calculates the LCC and PBP using three separate projections from 

AEO2013: 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 these three AEO2013 scenarios to the 2012 electricity price, and then uses that 

electricity price factor to scale the 2012 electricity prices into the future. Figure 9.2.1 through 

Figure 9.2.3 show commercial, industrial, and outdoor stationary electricity price trends, 

respectively, based on the three AEO2013 projections. The LCC results presented in this chapter 

are based on the AEO2013 reference case. 

9-11
Figure 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 2040

Price 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 2040

Price 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 2040

Price Trend (1=Price in 2012)

Year

Low Economic Growth

Reference Case

High Economic Growth

9-12
In 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 Lifetime

DOE defined 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. These 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 lifetimes 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. Because 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 years in 

which replacement is necessary, DOE based the replacement costs on the total installed cost 

inputs, as seen in the following equation: 

PRICE MU INST

FEPRC INST

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

MUTAX = sales tax.

For the years when no replacement is necessary, the replacement costs are set to zero. 

9-13
Replacement 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 costs 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 costs about $3 and disposing of lamps costs about $2.7 Ballast 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 

either a lamp or a ballast would be approximately $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 

(replacement lamp), lamp and ballast purchase (lamp that is purchased when the failed ballast is 

replaced—also referred to as a ballast event), and fixture purchase (fixture replacement or new 

construction). 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 basic triggering event and purchase option 

compatibility, with gray cells indicating incompatibility. 

Table 9.2.4 Summary of Triggering Events 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 existing ballasts are also assumed to be at 

9-14
half-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 maximum 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 

existing 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 

mandated 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 Fixtures 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). Among 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. 

9-15
The degree of systematic risk facing a firm and the subsequent 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 (Rf), 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: 

Rk fe ( ) β ×+= ERP

Eq. 9.6 

Where:

ke = the cost of equity for a company, expressed in dollars,

Rf = 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 (kd) 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 deductions 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 discount rate using the equation: 

k = ke × we + kd × wd

Eq. 9.7 

Where:

k = the (nominal) cost of capital, 

ke and kd = the expected rates of return on equity and debt, respectively, and 

we and wd = 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 by Damodaran.

9 The ERP 

9-16
represents 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 Rf 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) kd 6.7 Damodaran Online

Percent Debt Financing wd 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. Table 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 

survey12 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 state 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 Sector

Sector Discount Rate

%

Commercial 4.9

Industrial 4.7

Outdoor Stationary 3.4

9-17
9.2.9 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 consumers as if each would purchase new equipment in the year the 

potential new standard takes effect (2017). However, DOE based the cost of the equipment on 

the most recent available data. All dollar values are expressed in 2012$. 

9.3 PAYBACK PERIOD INPUTS 

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-efficient 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 known 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 efficacious standard level 

equipment (efficacy levels 1, 2, etc.) and baseline (efficacy 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 efficacious equipment is not recovered in reduced 

operating 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 conservation 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).

9-18
To 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 this equipment. Energy savings calculations in the LCC and PBP analysis use these 

representative system power ratings as well as the applicable usage profiles. Because DOE 

calculated PBPs in a methodology 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 installed 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 standard is to take 

effect (e.g., 2017). The electricity price DOE uses in the PBP calculation for electricity cost is 

the price projected for 2017, 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 an 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 826, electricity 

price projections from the AEO2013 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 EL1 are negative, with 

essentially all consumers experiencing either no impact or negative impact. For EL2, the average 

LCC savings are positive, but only 12 percent of consumers enjoy net benefits. However, for EL3, 

the LCC savings are positive, with net benefits experienced by majority of impacted consumers. 

9-19
This 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 experiencing 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

Efficacy 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

Years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percentage of 

Consumers 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

Efficacy 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percentage of 

Consumers 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.

9-20
Table 9.4.3 HID Lamps ≥2800 K and ≤4500 K and >1000 W to ≤2000 W—LCC and PBP 

Results

Efficacy 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percentage of 

Consumers 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 of the declining market for 

HID equipment. The standard LCC analysis, 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)

Efficacy 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

Years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percentage of 

Consumers 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 consumers experiencing a net cost or net benefit are greater than zero, but round to 

zero.

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)

Efficacy 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percentage of 

Consumers 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 ≤2000 W—LCC and PBP 

Results (2022 Projected Market Basis)

Efficacy 

Level

Life-Cycle Cost

2012$ Life-Cycle Cost Savings

Median

Payback 

Period

years

Installed 

Cost

Discounted 

Operating 

Cost

LCC

Average 

Savings 

2012$

Percentage of 

Consumers 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.

9-22
REFERENCES

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. 

4 Sweets-McGraw Hill Construction. Sweets Electrical Cost Guide 2013. 2012. Vista, CA. 

5. U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Building 

Technologies Program: U.S. Lighting Market Characterization. January 2012. Washington, 

D.C. <http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan2012.pdf> 

6. U.S. Energy Information Administration. Form EIA-826 Detailed Data. 2013. EIA: 

Washington, D.C. <www.eia.gov/cneaf/electricity/page/eia826.html> 

7. Environment, Health and Safety Online. EHSO’s Fluorescent Lights and Lighting Disposal 

and Recycling Web Page – Recycling Costs. Atlanta, GA. (Last accessed February 19, 

2013.) <www.ehso.com/fluoresc.php> 

8. Modigliani, F. and M. Miller. The Cost of Capital, Corporation Finance and the Theory of 

Investment. American Economic Review. 1958. (June): pp. 261–297. 

9. Damodaran, A. Damodaran Online. Historical Returns on Stocks, Bonds and Bills – 

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–Bureau 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 Line 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> 

9-23
14. Federal Reserve Board. Statistics: Releases and Historical Data – Selected Interest Rates – 

State and Local Bonds. 2011. (Last accessed February 19, 2013.) 

<www.federalreserve.gov/datadownload/Build.aspx?rel=H15> 

9-24
CHAPTER 10. SHIPMENTS ANALYSIS

TABLE OF CONTENTS

10.1 INTRODUCTION ............................................................................................................ 10-1

10.2 SHIPMENTS MODEL METHODOLOGY ..................................................................... 10-1

10.2.1 Historical Shipments ............................................................................................. 10-1

10.3 BASE-CASE INPUTS AND PROJECTIONS ................................................................. 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 Metal 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-i 
Figure 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-ii
CHAPTER 10. 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) conducted for 

this notice 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 national impacts model are Microsoft Excel spreadsheets 

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

This 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 projections; 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 METHODOLOGY

In general, DOE followed 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 calculated an installed stock for each lamp from 2017 (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 Historical 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 

10-1 
reference 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 

although supported 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 constituted 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 Historical HID Lamp Shipments

10.3 BASE-CASE INPUTS AND PROJECTIONS 

This section describes the base-case scenario DOE employs in its analysis and the basecase 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 lamps framework public 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 2010

Total Amount of Shipments

Year

Historical Shipments

All HID Lamp Shipments

HPS Lamps

MV Lamps

MH Lamps

10-2 
of 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 

halide lamp fixture (MHLF) energy conservation standard framework public meeting, 

manufacturers stated that many metal halide high bay fixtures had been replaced with fluorescent 

high bay fixtures between 2000 and 2010. (Docket No. EERE-2009-BT-STD-0018, Philips, No. 

8 at p. 101) During the MHLF preliminary analysis public meeting, manufacturers expressed 

their belief that MHLF shipments had plateaued or were declining. (Docket No. EERE-2009-BTSTD-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 HID lighting in these three markets (as a percentage of lighting 

service in teralumen-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; in 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 States.

2

This represents a significant installed 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 existing street lighting in the United States.

3 These 100 

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 ballasts test procedure rulemaking, and appears at page 8 of that document.

10-3 

 
Traditional 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 5000 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 after the last MV ballast was allowed to be sold or 

imported into the United States. Table 10.3.1 shows the percent of rated life of MV ballasts from 

the time the last ballast 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 Date

Sector Annual Operating 

Hours

Years Between Last 

Sale and Start of 

Analysis Period

Total Estimated 

Number of Hours of 

Operation

Percent of 

Rated Life

Commercial 3961 9 35,649 71

Industrial 6113 9 55,017 110

Outdoor 4493 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, 

customers will have to consider a different lighting source. Ballasts will 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 life of 40,000 hours. DOE is not aware of any 

electronic MV ballasts prior to January 1, 2008.

10-4 

 
Because 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 shipments correlates to 

a reduction in probe-start lamp fixtures and that the remaining lamps being shipped serve 

existing fixtures.

During the January 2010 MHLF framework 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 penetration by fluorescent lighting systems. (Docket No. EERE-2009-BTSTD-0018, Philips, No. 8 at p. 101)

Historical 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 (typical) 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. 

10-5 
Table 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%

1000

700 100%

750 100%

1000 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%

1000

750 100%

950 100%

1000 100%

1500 1500 100%

1650 100%

2000 1800 100%

2000 100%

10-6 
Table 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%

1000 100%

1500 100%

2000 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 through Figure 10.3.5 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.

10-7 
Figure 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 2050

Amount 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 2050

Amount of Lamps Shipped

Year

175 W MV Base-Case Shipments

Baseline

EL1a

EL1b

EL2

EL3

Effective Date

10-8 
Figure 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 2050

Amount 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 2050

Amount of Lamps Shipped

Year

400 W MV Base-Case Shipments

Baseline

EL1a

EL1b

EL2

EL3a

EL3b

Effective Date

10-9 
Figure 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 2050

Amount of Lamps Shipped

Year

400 W Probe-Start MH Base-Case Shipments

Baseline

EL1

EL2

EL3

Effective Date

10-10
Figure 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 2050

Amount 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 2050

Amount of Lamps Shipped

Year

1000 W Probe-Start MH Base-Case Shipments

Baseline

EL1

EL2

Effective Date

10-11
10.3.5 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 presents 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 STANDARDS-CASE SHIPMENTS

10.4.1 Shipments Scenario

To characterize customer behavior 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 lamp 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 their previously owned system. The total shipment of lamps 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 2050

Amount of Lamps Shipped

Year

2000 W Probe-Start MH Base-Case Shipments

Baseline

EL1

Effective Date

10-12
case 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 to 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 efficacy scenarios. In these scenarios, DOE assumed that for any of the triggering 

events described above, customers choose between either an equal wattage – but potentially 

higher efficacious lamp (lamp system) or a lower wattage lamp (lamp system) that can deliver 

nearly the same amount of light as the original lamp due to its higher efficacy. The choice paths 

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 WattageEqual 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 WattageHigher 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 unimpacted 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 highest efficacy 

10-13
level 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 wattage–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 the base 

case shipment 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 modified by the socket stock 

decline. The ratio of the adjusted shipped quantity to the base case shipped quantity closely 

tracked the inverse of their 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 EfficacyScenarios Chosen

Scenario 1 Scenario 2 Scenario 3

1 

≥2800 K and ≤4500 K;

≥50 W to ≤400 W;

clear; enclosed

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 --- ---

10-14
Efficacy Level 

Selected Equipment Class Shipments at Equipment EL for Alternative EfficacyScenarios Chosen

Scenario 1 Scenario 2 Scenario 3

>1000 W and ≤2000 W;

clear; enclosed

10-15
REFERENCES

1. U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Energy 

Savings Potential of Solid-State Lighting in General Illumination Applications. 2012. 

Washington, D.C. <http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/ 

ssl_energy-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. Streetlight 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-HIDShipments.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-Indexes-Show-Growth-for-FirstQuarter.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/Climate%20Change%20Ini

tiatives%20Update.pdf> 

10-16
CHAPTER 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 Net 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-i 
Table 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 Cumulative Net Present Value for HID Lamps Purchased from 2017–2046 

for EL 3 ............................................................................................................ 11-13

11-ii
CHAPTER 11. NATIONAL IMPACT ANALYSIS 

11.1 INTRODUCTION 

This chapter describes the method for estimating the national impacts of the three 

potential efficacy levels (ELs) 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) identified a representative HID 

ballast and fixture pairing used with each lamp to develop representative HID systems (herein 

“HID lamp systems”). Although HID ballasts and fixtures are not covered under this notice of 

proposed determination (NOPD) analysis for HID lamps, the characteristics of complete HID

lamp systems (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 assessed 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 any

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 determined both the NPV and the NES for each EL and each representative 

equipment class it selected in the engineering analysis (NOPD technical support document, TSD, 

chapter 5). In this rulemaking, DOE considered up to three ELs for each representative HID 

lamp equipment class. 

DOE performed all NIA calculations using a Microsoft Excel spreadsheet, available at

www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/23. Appendix 11A 

of the 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 inputs 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 characteristics of DOE’s shipment projections (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. 

11-1 
Two main inputs to the NPV are the per-unit total installed cost increase and per-unit 

annual operating cost savings. The per-unit total installed cost often varies with the efficacy of 

the lamps shipped. When higher-efficacy lamps are shipped, higher installed costs are often 

incurred. The projected distributions 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 systems 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 an 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 apportionments characterize the shipments of lamps for each 

analyzed equipment class. The projected efficacy distributions of shipments for lamps depend 

directly on these apportionments and the total shipments of a particular 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 lamps shipped 

that year and in prior years that are still is service. The NES model tracks the base case lamps 

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 chapter 10, DOE 

established the installed lamp stock profile for all analyzed lamp equipment classes in the base 

case. 

All the lamp types 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. 

11-2 
11.3 NATIONAL ENERGY SAVINGS

11.3.1 National Energy Savings Definition 

DOE calculated 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 baset t std t NES (AEC AEC src _) conv = , − , ×

Eq. 11.1 

Where: 

NESt = 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 

src_convt = 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: 

= ∑tNEScum NESt

Eq. 11.2 

Where: 

NEScum = cumulative national energy savings. 

DOE calculated the AEC (in any year) by multiplying the number or stock of lamps by 

the annual unit energy consumption (UEC), shown by the following equation: 

ld

ld

AEC = ∑STOCKld ×UEC

Eq. 11.3 

Where: 

ld = lamp ID number, 

STOCKld = stock of lamps of a given design surviving in the year for which DOE calculated 

AEC, and

UECld = unit energy consumption (kWh per year). 

11-3 
11.3.2 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 (STOCKld)

Site-to-Source Conversion Factor (src_conv)

11.3.2.1 Unit Energy Consumption 

DOE presents 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

The lamp stock in a given year is the sum of the shipments in that year and the total 

surviving number of standard case lamps 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 discusses projected shipments for the base case and all higher 

efficacy cases in NOPD TSD chapter 10. To generate the shipments that eventually comprise the 

lamp stock, one base-case scenario 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 lamp 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 scenarios 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 preempted 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 post2017 fixtures were calculated using a Weibull survival function based on the average fixture 

11-4 
lifetime 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 used 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 this 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 (AEO2013).1 Table 11.3.2 presents the site-tosource 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 

11-5 
11.3.2.4 Full-Fuel-Cycle Energy

The full-fuel-cycle (FFC) measure includes 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 energy 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 to 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 lamps for selected years. 

The method used to calculate a time series of FFC energy multipliers is described in appendix 

11B 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 more-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 equipment 

in winter months. 

Consistent with previous and ongoing lighting rulemakings (for HID lamps and 

fluorescent lamp ballasts2 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 considered 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 cost savings associated with more-efficient equipment in a manner 

11-6 
that 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 efficiency, “take-back” or 

rebound values for commercial and industrial lighting are between 0 and 2 percent. In this 

NOPD, DOE assumed a 0 percent rebound rate in all three sectors analyzed.

A majority 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 

operating only at night), not by the perceived energy expenses 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 

calculated as follows: 

NPV −= PVCPVS

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

PVS DFOCS tt

Eq. 11.5 

∑ ×=

t

PVC TICI DFtt

Eq. 11.6 

Where: 

OCSt = total annual operating cost savings in year t, 

TICIt = total annual installed cost increases in year t, 

DFt = discount factor associated with year t, and 

t = year (PVS and PVC are summed over the lifetime of equipment shipped in 2017–2046). 

DOE determined 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 discounted these costs to 2013. DOE calculated savings as the difference between a 

potential standards case (i.e., with standards) and a base case (i.e., without any standards). DOE 

discounted savings using the discount rate and the number of years between the “present” (i.e., 

11-7 
year 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 equivalent 

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 (TICt)

Total Annual Operating Cost (OCt)

Discount Factor (DF)

11.4.2.1 Total Annual Installed Cost Increases 

DOE calculated the increase in total annual installed costs (TICIt) 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 costs equal the product of the shipments 

and per-unit installed cost (summed over each lamp system design): 

( ) ld ld ld t

ld

t TIC = ∑ shipments UPPUIC ×+× pricefactor

Eq. 11.7 

Where:

TICt = total installed costs in year t, 

shipments ld = total shipments of lamp type ld, 

UICld = unit installation costs of lamp/fixture type ld, 

UPPld = unit post tax price of lamp/fixture type ld, 

pricefactor = price learning index for year t,

t = year, and

ld = lamp ID number. 

The increase in total annual installed costs (TICIt) equals the total annual installed costs 

in any potential standards case minus the 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 calculated total annual operating costs based on national average electricity 

prices by sector. (The only component of annual operating cost for HID lamp systems 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 OC STOCK UEC electricity price

11-8 
Eq. 11.8 

Where:

OCt = total annual operating cost in year t, 

STOCKld = total stock of lamp type ld, 

UECld = unit energy consumption of lamp type ld, 

electricity pricet = electricity price associated with lamp type ld, 

t = year, and

ld = lamp ID number. 

DOE calculated 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 used AEO2013 and EIA’s Form 826 to establish all 

electricity prices.

1 Chapter 9 of the NOPD TSD provides the electricity price projections DOE 

used to calculate the NPV.

11.4.2.3 Discount Factor 

DOE multiplied 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: 

( )( ) ptt DF r − 11 +=

Eq. 11.9 

Where: 

r = discount rate, 

t = year of the monetary value, and

tp = year in which the present value is being determined. 

DOE estimated 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 Costs, therein.5 DOE defined 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 Excelspreadsheets, 

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

11-9 
11.5.1 National Energy Savings and Net Present Value Input Summary

Table 11.5.1 summarizes the inputs to the NES spreadsheet 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 10)

Assumed Compliance Date of 

Potential Standard

2017

Annual Energy Consumption per 

Unit

Established in the energy use 

analysis (NOPD TSD chapter 8)

Rebound Effect 0% 

Electricity Price Forecast AEO2013

Energy Site-to-Source Conversion 

Factor

Used annually variable site kWh-tosource-Btu conversion factors

Discount Rate 3% and 7% real

Present Year 2013

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 results 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.

11-10
Table 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 0.088

MH 400 W 0.051 0.052

≥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 0.172

* 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 0.050

MV 175 W 0.068 0.069

MV 250 W 0.201 0.205

MV 400 W 0.008 0.008

MH 400 W 1.219 1.239

≥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. 

11-11
NPV results are cumulative and shown as the discounted value of these savings in dollar 

terms. DOE used 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 operating 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. The 

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 cases since 

the higher efficacy lamps are not drop-in replacements, but require installation of completely 

new lamp systems. In most cases, when a customer can no longer buy a lamp due to any 

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 still 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 2012$ 

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

11-12
Table 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 2012$ 

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 2012$ 

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

11-13
REFERENCES

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-STD0018-0021> 

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 Efficiency and Consumption–

The Rebound Effect: 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> 

11-14
CHAPTER 12. 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 Manufacturing 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 ANALYSIS 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-i 
12.6.1 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-ii
Table 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-iii
CHAPTER 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 of 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, as 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 market share, 

sales volumes and trends, pricing, employment, and financial structure. In phase II, “Industry 

Cash Flow,” DOE used the GRIM to assess the impacts of potential energy conservation 

standards on HID lamps. 

In phase II, DOE created a GRIM for HID lamps and an interview guide to gather 

information on the potential impacts on manufacturers. DOE presented the MIA results for HID 

lamps for each equipment class at each EL. 

In phase III, “Subgroup Impact Analysis,” DOE interviewed manufacturers representing 

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 specific 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. 

12-1 
12.2.1 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 NOPD technical 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, 

manufacturer 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, property, 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: Industry Cash-Flow Analysis and Interview Guide

Phase II focused on the financial impacts of potential energy conservation standards on 

manufacturers of HID lamps. Energy conservation standards can affect manufacturer cash flows 

in three distinct ways: (1) create 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 lamps. In performing these analyses, DOE used the financial values derived during phase I 

and the shipment scenarios used in the national impact analysis (NIA). In phase II, DOE 

performed these preliminary industry cash-flow analyses and prepared written guides 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 standards’ 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 NOPD TSD, provided the basis for the shipment projections in the GRIM. The financial 

parameters were developed using publicly available manufacturer data and were revised with 

12-2 
information submitted confidentially during manufacturer interviews. The GRIM results are 

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 Interview Guides

During phase 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, DOE 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 manufacturers. 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 issues; (5) company overview and 

organizational characteristics; (6) markups and profitability; (7) shipment projections; (8) 

financial parameters; (9) conversion costs; (10) cumulative regulatory burden; (11) direct 

employment assessment; (12) manufacturing capacity and non-US sales; (13) impact on 

competition; (14) HID ballast impacts; and (15) impacts on small businesses. 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 phase I and the cash-flow analysis performed in phase II are 

supplemented with information gathered from manufacturer interviews in phase III. The 

interview process provides an opportunity for interested parties to express their views on 

important issues privately, allowing confidential or sensitive information to be considered 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 manufacturers and 

interviewed small and large companies, subsidiaries and independent firms, and public and 

private corporations to provide an 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 

12-3 
interactive interviews, which helped 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 information 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 

standards 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 companies. 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 NOPD

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 lamps 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 

energy 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 companies might 

experience from potential standards. Because DOE is not proposing a new standard in this 

NOPD, 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-sizestandards

12-4 

 
small 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 capacity, 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 section 12.4.7 and DOE’s discussion of 

the production capacity impact can be found in section 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 

employment impacts are reported in section 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 federal regulations that impact other 

products made by the same manufacturers. Discussion of the cumulative regulatory burden can 

be found in section 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 NOPD 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. 

12-5 
12.3.1 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 efficacy standards for HID lamps. HID lamp burning racks 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

Manufacturers 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 Innovation 

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 potential 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 result 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 ASSUMPTIONS

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. 

12-6 
12.4.1 Overview of the GRIM

The basic structure of the GRIM, illustrated in Figure 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 the 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 cash 

flow. These sources include corporate annual reports, company profiles, Census data, credit 

ratings, the shipments model, the engineering analysis, and the manufacturer interviews. 

12-7 
12.4.2.1 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 by publicly-traded manufacturers that produce HID lamps, 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 estimates 

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 lamps. Chapter 10 of this NOPD TSD 

describes the methodology and 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 MPCs and lamp efficacy for HID lamps covered in this NOPD. DOE began its analysis 

by conducting industry research to determine equipment class groupings, select baseline HID 

lamps, and select representative HID lamps for further testing and analysis. Typically, DOE 

develops MPCs for the covered equipment and uses 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 NOPD 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. 

12-8 
12.4.2.5 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:

• capital 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-efficacy curves calculated in the engineering analysis.

12.4.3 Financial Parameters

Table 12.4.1 below provides financial parameters for six public companies engaged in 

manufacturing and selling HID lamps. The values listed are averages over an 8-year period 

(2005 to 2012).

Table 12.4.1 GRIM Financial 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 NOPD. 

12-9 
Table 12.4.2 GRIM Revised HID Lamp 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 respective 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 determined that the industry average cost of equity for the HID lamp industry is 

14.1 percent. 

12-10 
Table 12.4.3 Cost of Equity Calculation

Parameter

IndustryWeighted 

Average

%

Manufacturer

A B C D E F 

(1) Average Beta 1.46 1.57 1.45 1.54 1.54 0.73 1.46

(2) Yield on 10-Year T-Bill (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 relevant spread to the risk-free rate.

In practice, investors use a variety of different maturity Treasury bonds 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 average 10-year Treasury bond 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

IndustryWeighted 

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 

(1928-2012) 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% 

12-11 
Using 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 total unit-shipment forecasts and 

the distribution of these values by efficacy level. Changes in the efficacy 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 forecasts from 2014 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 described in 

chapter 10 of this NOPD 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 (Internet 

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 this 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 their 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 lamps. 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. 

12-12 
Table 12.4.5 Manufacturer Production Cost Breakdown (2012$) 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

12-13 
Table 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

12-14 
Table 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-time 

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 product 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 and 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 discrepancies 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.

12-15 
During manufacturer interviews, DOE asked manufacturers for their estimated total 

product and capital conversion costs needed to produce HID lamps 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 identified 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 conversion costs estimates DOE created were consistent with the manufacturer topdown 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 Wb Equipment

Class HID Lamps 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 Lamps 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 NOPD TSD as 50 W – 400 W, 401 W – 1000 W, and 1001 W 

– 2000 W, respectively.

12-16 

 
Table 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

EL 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 engineering 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 efficacy levels. As MPCs increase with efficacy, this scenario implies 

that the absolute dollar markup will increase as well. Based on publicly available financial 

information for manufacturers of HID lamps and comments from manufacturer interviews, DOE 

assumed the non-production cost markup—which includes SG&A expenses; R&D expenses; 

interest; and profit—to be 1.52 for all representative lamps. Because this markup scenario 

assumes that manufacturers would be able to maintain their gross margin percentage as 

production costs increase in response to potential energy conservation standards, it represents an 

upper bound to industry profitability under these potential standards. 

12.4.8.2 Preservation of Operating Profit Markup Scenario

DOE implemented the preservation of operating profit markup scenario because 

manufacturers 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 EL 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 

already exceed the potential standards. 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 

12-17 
profit on higher production costs and the investments required to comply with the potential 

standards, 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 1.4994 

EL2_MH Quartz 2_100WPulse 1.520 1.520 1.4994 

EL3_CMH_50W 1.520 1.520 1.520 1.460

EL3_CMH_70W 1.520 1.520 1.520 1.460

EL3_CMH_100W 1.520 1.520 1.520 1.460

Table 12.4.17 Preservation of Operating Profit Markups for the 175 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 1.506 

EL2_MH Quartz 2_150WProbe 1.520 1.520 1.506 

EL2_MH Quartz 2_150WPulse 1.520 1.520 1.506 

EL2_MH Quartz 2_175WPulse 1.520 1.520 1.506 

EL3_CMH_70W 1.520 1.520 1.520 1.471 

EL3_CMH_100W 1.520 1.520 1.520 1.471 

EL3_CMH_150W 1.520 1.520 1.520 1.471 

12-18 
Table 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 1.518 

EL1_MH Quartz 1_175WPulse 1.520 1.518 

EL1_MH Quartz 1_250WPulse 1.520 1.518 

EL2_MH Quartz 2_150WProbe 1.520 1.520 1.420 

EL2_MH Quartz 2_150WPulse 1.520 1.520 1.420 

EL2_MH Quartz 2_175WProbe 1.520 1.520 1.420 

EL2_MH Quartz 2_175WPulse 1.520 1.520 1.420 

EL2_MH Quartz 2_250WPulse 1.520 1.520 1.420 

EL3_CMH_100W 1.520 1.520 1.520 1.448

EL3_CMH_150W 1.520 1.520 1.520 1.448

EL3_CMH_250W 1.520 1.520 1.520 1.448

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 1.440 

EL3_CMH_250W 1.520 1.520 1.520 1.440 

12-19 
Table 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 1.490 

EL2_MH Quartz 2_360WProbe 1.520 1.520 1.490 

EL2_MH Quartz 2_400WProbe 1.520 1.520 1.490 

EL2_MH Quartz 2_400WPulse 1.520 1.520 1.490 

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 1.518 

EL1_MH Quartz 1_1000WProbe 1.520 1.518 

EL2_MH Quartz 2_575WPulse 1.520 1.520 1.474 

EL2_MH Quartz 2_750WPulse 1.520 1.520 1.474 

EL2_MH Quartz 2_1000WPulse 1.520 1.520 1.474 

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 1.488 

EL2_MH Quartz 2_1000WProbe 1.520 1.520 1.488 

EL2_MH Quartz 2_1000WPulse 1.520 1.520 1.488 

12-20 
Table 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 1.524 

EL1_MH Quartz 2_2000WPulse 1.520 1.524 

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 lamps. 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 ELs 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 discount rate. The HID lamps

GRIM estimates cash flows from 2014 to 2046. This timeframe models both the short-term 

impacts on the industry from the announcement of the potential standards 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 markup scenarios described above, the flat markup scenario (preservation of 

gross margin percentage) 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 lamps; 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 lamps; 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 lamps. 

12-21 
12.5.1.1 50 W – 400 W Equipment Class INPV Results

Table 12.5.1 Changes in Industry Net Present Value for the 50 W – 400 W Equipment 

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%

12-22 
12.5.1.3 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 2025 for the base case and different ELs in the 

standards case.

Annual cash flows are discounted to the base year, 2014. Between 2014 and the 2017 

compliance date of potential energy conservation standards, 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 

standards. The more stringent the potential standards, the greater the impact on industry cash 

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 potential standards 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 standards. 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 

12-23 
in 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 potential standards takes effect.

In the years following the compliance date of the potential energy conservation standards, 

the impact on cash flow depends on the operating revenue. In the flat markup scenario, the 

manufacture markup is held constant to yield the same gross margin percentage in the standards 

case for each equipment class at each EL as in the base case in the year after the potential

standards 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 ELs where MPCs dramatically 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 

standards take affect will outweigh the initial conversion costs.

Under the preservation of operating 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 

reduced. 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. 

12-24 
Figure 12.5.1 Annual Free Cash Flow from the 50 W – 400 W Equipment Class HID 

Lamps - Flat Markup Scenario

Figure 12.5.2 Annual Free Cash Flow from 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

12-25 
Figure 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

12-26 
Figure 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

12-27 
12.6 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 this 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 

manufacturers 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 lamps 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 small business manufacturer of covered HID lamps. 

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 lamps sold in the United 

States. 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 lamps 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 lamps that 

would be affected 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 States. 

Before issuing this NOPD, DOE attempted to contact the small business manufacturers of

HID lamps 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 lamps. 

None of the major manufacturers of HID lamps 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 

lamps tend to be companies that outsource the manufacturing to overseas companies who 

produce the lamps specified by the small businesses as well as distributors of equipment 

manufactured by the five large HID lamp manufacturers. These small businesses provide the 

12-28 
specifications 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 NOPD. 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 – 400 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-wide 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 time.

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 attributable 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 lamps within a 

lighting facility. Workers performing services 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 produce 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 

potential 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 States. While the results 

12-29 
present a range of employment impacts following 2017, the sections below also include 

qualitative discussions of the likelihood of negative employment impacts at the various ELs for 

the 50 W – 400 W equipment class. Finally, the employment 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 2017 

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 ELs 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 EL 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 EL 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 EL 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 

relocated 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.

12-30 
DOE is not proposing any new energy conservation standards in this NOPD, 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 would 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. Most 

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 NOPD, and 

therefore there will be no impacts 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 

manufacturers, 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 cumulative 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 

NOPD, 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 EL 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 HID 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, industry 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 EL 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. Additionally, industry free cash flow is estimated to decrease by approximately 2 

12-31 
percent to $7.2 million, compared to the base case value of $7.4 million in 2016. At EL 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, compared to the base case 

value of $0.9 million in 2016.

At EL 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. Additionally, 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 EL 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. 

Additionally, 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 EL 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 EL 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. 

12-32 
REFERENCES

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. 

12-33 
APPENDIX 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-i 
APPENDIX 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 lamps 

with the starting 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 available 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 pulse-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 an 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 identifies 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-1 

 
5A.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 Types 

Efficacy 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-2 
APPENDIX 5B. HID 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-i 
APPENDIX 5B. HID REPLACEMENT PATHWAYS

5B.1 INTRODUCTION

 This appendix presents the methodology the U.S. Department of Energy (DOE) followed 

in modeling the replacement pathways customers would follow in response to potential highintensity discharge (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 

manufacturer 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 system, 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 fixture 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. This 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 these 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 shipments analysis (chapter 10 of this NOPD 

TSD) weights the percentage of customers who choose each option.

5B-1 
5B.2.1 Lamps 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 discussed 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 percent.

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 pulsestart 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-2 
existing 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 typically 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 rulea), 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 that 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 required 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 ballast 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, the 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 for 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, these 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 operate 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 standards 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 compliance 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 electronic 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 efficient 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 pathway 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-4 
available 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 that were 

exempt from EISA 2007 standards for being rated for use in wet locations and in 

locations with an ambient temperature of 50o

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 currently 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:

efficiencynew = 

wattagenew

(wattageoriginal⁄efficiencyoriginal) − wattageoriginal + wattagenew

 Where:

efficiencynew = efficiency of the ballast running the retrofit lamp

wattagenew = wattage of the reduced wattage retrofit lamp

wattageoriginal = wattage of the original lamp-and-ballast system

efficiencyoriginal = rated efficiency of the original ballast

5B-5 
o 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 in 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 efficient 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 compliance 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 available 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 mandated 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-6 
APPENDIX 6A. HID BALLAST AND FIXTURE PRICES

TABLE OF CONTENTS

6A.1 INTRODUCTION ........................................................................................................ 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

LIST OF FIGURES

Figure 6A.2.1 Manufacturer Selling Price ................................................................................ 6A-2

LIST OF TABLES

Table 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-i 
APPENDIX 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 kits 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 this NOPD 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 this NOPD TSD).

6A.2 METHODOLOGY

 When purchasing a more efficacious lighting system, DOE acknowledges that a customer 

may be required to purchase an entirely new HID fixture, or retrofit an existing fixture with new 

lamp-and-ballast system to accommodate the higher efficacy 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 MH lamp fixtures (MHLFs) were 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-production cost. To 

develop prices, DOE first conducted teardowns to calculate the MPC. The MPC comprises 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 this NOPD TSD, DOE applied further markups to each MSP to calculate an enduser price. The following sections discuss the methodology DOE used to develop MSPs for HID 

ballasts 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/ruleid/16.

6A-1 

 
NOPD, 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 of 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 have EISA 

2007 compliant efficiencies and instead are assumed to have the least efficient ballast efficiency 

commercially available with the specific wattage and ballast type. The one exception to this

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 the 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 comprises direct labor, direct material, 

and overhead costs. The direct labor costs include fabrication and 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 utilized data from the 2014 MHLF 

rulemaking. The 2014 MHLF rulemaking developed MPCs for several MH ballasts 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-2 
DOE notes each MH ballast wattage that the MHLF is suitable for housing according to the 

fixture specifications. 

Table 6A.2.1 Metal Halide Lamp Fixtures Selected 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 manufactured in the United States. Therefore, DOE applied the appropriate 

labor rates 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-3 
calculate overhead, DOE utilized information available in the recent standards 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 have 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 modeled such a ballast by starting with the 

commercially 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 efficiency 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 an 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 example, 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 were 1.2 times those measurements of the existing wattage. 

This would allow DOE to determine 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 efficiencies, DOE then conducted the modeling procedure 

discussed in the 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 fixtures with similar applications and sizes. The only 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/appliance_standards/product.aspx/productid/62

6A-4 

 
6A.2.1.2 Mercury Vapor Technology 

 DOE did not perform teardowns for mercury vapor (MV) ballasts and fixtures. Instead, 

for 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 MHLFs are similar in material 

makeup and construction to MV fixtures. Because of this, fixture manufacturers recommended 

that the MPCs for MHLFs 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 MHLFs. Therefore, DOE assumed that MV fixture MPCs were the same as

MHLF 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 electronic 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 found 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 are 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 developed 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) standard 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 to 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-5 
voltage 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 would 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 thermal 

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 level 

(TSL). This aggregation of the two prices is discussed in chapter 9 of this 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 MHLFs 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-6 

 
Based 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 built 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 was 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 allows 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-7 
2000 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 then 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 of $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 compose 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 fixtures) 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 manufacturer markup to determine the replacement ballast 

MSP. In general, the manufacturer markups should ensure that the MSP of the equipment is high 

6A-8 
enough 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. Securities 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 to 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

IndustryWeighted 

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-9 
Table 6A.2.5 Gross Profit Margin for Six HID Fixture Manufacturers*

Parameter

IndustryWeighted 

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-10 
DOE 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 information 

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 ballasts 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 fixtures. 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 fixturese 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-11 

 
Table 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 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

$ 37.08

$ 46.10

$ 37.08

$ 46.10

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

$ 33.44

$ 42.69

$ 33.44

$ 42.69

EL 2 High efficacy quartz pulse 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 probe MH**

Standard efficacy quartz pulse MH

400

400

$ 35.43

$ 45.14

$ 35.43

$ 45.14

EL 2 High efficacy quartz pulse 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 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 MH** 

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 probe 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-12 
Table 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 $ 45.74

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 MH** 

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 probe 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-13 
Table 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 MH**

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 probe 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-14 
Table 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 MH**

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 representative 

unit for the efficacy level.

6A-15 
APPENDIX 9A. USER INSTRUCTIONS FOR LIFE-CYCLE COST AND PAYBACK 

PERIOD SPREADSHEETS 

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-i
APPENDIX 9A. USER INSTRUCTIONS FOR LIFE-CYCLE COST AND PAYBACK 

PERIOD SPREADSHEETS 

9A.1 INTRODUCTION

The results obtained for the life-cycle cost (LCC) and payback period (PBP) analysis can

be examined and reproduced using the Microsoft Excel spreadsheets available on the 

U.S. Department of Energy (DOE) Building Technologies website at: www1.eere.energy.gov/ 

buildings/appliance_standards/rulemaking.aspx/ruleid/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 explained 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 Economic Growth Scenarios are all selected via dropdown menus. Any 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 from the LCC associated 

with a unit of the same equipment class at a baseline efficiency). In general, logic flows from the 

data sources and assumption worksheets (assembled as the right-most worksheets) toward 

outputs (produced in 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-1
cases impacting analysis periods or triggering events. Such 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 explanation 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. Also

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 this 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 engineering 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 systems.

 

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 for 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-2
Instructions – 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 spreadsheet. 

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 Utilizes Monte Carlo analysis to derive median paybacks for 

impacted customers, by product class and TSL. 

9A-3
APPENDIX 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-i 
APPENDIX 9B. ESTIMATION OF POTENTIAL EQUIPMENT PRICE TRENDS FOR 

HIGH-INTENSITY DISCHARGE LAMPS

9B.1 INTRODUCTION

In its previous notice of data availability (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 

producer 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 price deflators from the U.S. 

Energy Information Administration’s (EIA) Annual Energy Outlook 2013 (AEO2013) 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 stated in the NODA that examination 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 functional relationship used to model the evolution of production costs in 

this case is: 

Y = aX-b

 

Eq. 9B.1 

Where: 

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. Patel, and K. Blok. A Review 

of Experience Curve Analyses for Energy Demand Technologies. Technological Forecasting & Social Change. 

2010. 77:411-428. 

9B-1

 
X is cumulative production, and 

Y is the price as a function of cumulative production. 

Thus, as experience (production) accumulates, the cost of producing the next unit decreases. The 

percentage reduction in 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 derived using two 

historical data series: cumulative production and price (or cost). 

DOE examined historical prices using the Bureau of Labor Statistics’ PPI and gross 

domestic product (GDP) deflator, available from the Bureau of Economic Analysis. The PPI data 

for industrial-type electric lighting fixtures, including parts and accessories, are available for 

1987–2010 and are used 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 Price Index 

because nearly all HID lamps and related equipment are shipped to commercial and industrial 

customers.

Figure 9B.2.1 PPI Data 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 and 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-2
9B.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 AEO2013. 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. This index was inflation-adjusted by dividing by the “GDP Deflator” index, also available 

from AEO2013. The resulting factor was reset to 1 in 2010. 

The AEO price indexes 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 price 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-3
Table 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-4
APPENDIX 11A. USER INSTRUCTIONS FOR SHIPMENTS AND NATIONAL 

IMPACT ANALYSIS SPREADSHEETS

TABLE OF CONTENTS

11A.1 INTRODUCTION ...................................................................................................... 11A-1

11A.2 INDIVIDUAL MODEL WORKSHEETS .................................................................. 11A-1

11A-i 
APPENDIX 11A. USER INSTRUCTIONS FOR SHIPMENTS AND NATIONAL 

IMPACT ANALYSIS SPREADSHEETS 

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. 

The 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 

(NPVs) 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 differences 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 potential 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 

ELs 

11A-1 
NES Inputs Contains energy use and other information for use in the NES 

calculations

NPV 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 years

11A-2 
APPENDIX 11B. FULL-FUEL-CYCLE MULTIPLIERS

TABLE OF CONTENTS

11B.1 INTRODUCTION .......................................................................................................11B-1

11B.2 METHODOLOGY ......................................................................................................11B-1

11B.3 FULL-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-i 
APPENDIX 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 distribution 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 electricity, 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 distributing 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 primary 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-1 
general 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 indicate 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: 

• ax is the quantity of fuel x burned per unit of electricity output, on average, for grid 

electricity; the calculation of ax includes a factor to account for transmission and 

distribution system losses; 

• by is the amount of grid electricity used in production of fuel y, in megawatt-hours per 

physical unit of fuel y; 

• cxy is the amount of fuel x consumed in producing one unit of fuel y; 

• qx is the heat content of fuel x (million British thermal units/physical unit); 

• zx(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 factors qx. 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-topower plant energy use factor is defined as the ratio of the total primary energy 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 use 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-intensity 

discharge lamps rulemaking used data from AEO2013.

3

11B-2 
Table 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 FULL-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 1.040 

Natural Gas (site) 1.103 1.101 1.100 1.098 1.099 1.100

Petroleum Fuels (site) 1.132 1.140 1.148 1.158 1.166 1.168

11B-3 
REFERENCES

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 Laboratory: 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-4 
APPENDIX 12A MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDE 

TABLE OF CONTENTS

12A.1 MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDE FOR HIGH 

INTENSITY DISCHARGE LAMPS ..........................................................................12A-1

12A.2 MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDE FOR HIGH 

INTENSITY DISCHARGE LAMPS (FIXTURE MANUFACTURERS)................12A-22

12A.3 SMALL BUSINESS MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDE 

FOR HIGH INTENSITY DISCHARGE LAMPS.....................................................12A-35

12A-i 
12A.1 MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDE FOR HIGHINTENSITY DISCHARGE LAMPS 

June 2013 

12A-1 
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-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.

matthew.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 (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 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 screwbase lamp types, in terms of shipments? Do non-screw-base lamps have unique photometric 

characteristics? 

1.2 Specialty Application – Stage/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 stage/studio applications?

1.3 High-CRI MH Lamps. Are there applications for which customers would specifically 

12A-2 
require 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 TECHNOLOGY 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 material quality, etc.)? 

12A-3 
2.6 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 this 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 

ballasts. 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 operating 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 kits? What prompts a customer to purchase a retrofit 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. 

3.5 Customer Response to Standards. For Table 1-1 below, indicate the expected customer 

response to lamp standards.

12A-4 
Table 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

1900-2800K, 50-1000W*

2801-4500K, 50-400W**

2801-4500K, 401-1000W†

2801-4500K, 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-5 
Table 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-6 
3.8 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-user 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

1900-2800 K, 50-1000 W

2801-4500 K, 50-400 W

2801-4500 K, 401-1000 W

2801-4500 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-7 
Table 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-8 
calculation 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-9 
Table 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-10 
5 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 approximate 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 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 products in any given equipment class. 

12A-11 
Table 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). The 

manufacturer 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.” 

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-12 
baseline 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 with 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 of 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-13 
Table 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

1900-2800 K, 50-1000 W

2801-4500 K, 50-400 W

2801-4500 K, 401-1000 W

2801-4500 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

1900-2800 K, 50-1000 W

2801-4500 K, 50-400 W

2801-4500 K, 401-1000 W

2801-4500 K, 1001-2000 W

“NC” means new construction. “R/R” means replacement/renovation.

12A-14 
8 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 collect 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 (inflationadjusted 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 1-10change significantly based on equipment 

class? Please describe any differences.

8.3 Do any of the financial parameters in Table 1-10change 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-15 
8.5 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 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 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 increase 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-16 
9.4 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 

2801-4500 K, 50-400 W 

Baseline

1 

2 

3 

2801-4500 K, 401-1000 W 

Baseline

1 

2 

2801-4500K, 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 Table 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-17 
Table 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-18 
Table 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 CMH150,000 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 conservation 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-19 
12.6 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 COMPETITION 

Energy conservation standards can alter the competitive dynamics 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 would 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 ballast 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-20 
efficiency 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 power 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-21 
12A.2 MANUFACTURER IMPACT ANALYSIS INTERVIEW GUIDE FOR HIGHINTENSITY DISCHARGE LAMPS (FIXTURE MANUFACTURERS) 

August 2013 

12A-22 
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-intensity discharge lamp fixtures 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.

matthew.walker@navigant.com

Tel: 202.481.8482 

Fax: 202.973.2401 

12A-23 
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 (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 this 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 

replacing a lamp 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-24 
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?

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 analyzed 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 1000

Original 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%

Pulsestart70 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-start 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 kits? What prompts a customer to purchase a 

12A-25 
retrofit 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 efficacy 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

1900-2800 K, 

50-1000 W 

2801-2800 K, 

50-400 W

2801-4500 K, 

401-1000 W 

2801-4500 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 differentials from one EL to the next seem reasonable?

12A-26 
Table 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-27 
Rep. 

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-28 
Table 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-29 
Table 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-30 
3 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-31 
product: direct labor, direct materials, and overhead (which includes depreciation). The 

manufacturer 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 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 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 research, 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 HID 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 fixtures if HID lamp standards were implemented?

12A-32 
4.7 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 these 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

1900-2800 K, 50-1000 W

2801-2800K, 50-400 W

2801-4500 K, 401-1000 W

2801-4500 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-33 
Table 2-8 Scope Considered in the Interim Analysis Stage

Lamp Type Rated Wattage 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 K

Excluded

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

1900-2800 K, 50-1000 W

2801-4500 K, 50-400 W

2801-4500 K, 401-1000 W

2801-4500 K, 1001-2000 W

“NC” means new construction. “R/R” means replacement/renovation.

12A-34 
12A.3 SMALL BUSINESS MANUFACTURER IMPACT ANALYSIS INTERVIEW 

GUIDE FOR HIGH-INTENSITY DISCHARGE LAMPS 

12A-35 
June 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-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.

matthew.walker@navigant.com

Tel: 202.481.8482 

Fax: 202.973.2401 

12A-36 
The 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*

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-37 
DOE 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 shows DOE’s preliminary 

engineering results for each equipment class. 

12A-38 
Table 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 ≤4500 K, clear, and enclosed-rated 

classes.

12A-39 
1 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), including 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 become 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 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. 

3.1 Do you have a parent company, and/or 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-40 
do 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 given 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). The 

manufacturer 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-41 
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.

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 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. 

5.1 In order to accurately collect information about HID lamp manufacturing, please compare 

your financial parameters to the GRIM parameters tabulated below in Table 3-4.

12A-42 
Table 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 (inflationadjusted 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 new 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 by 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 standards. 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, 

marketing 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 capital 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 

2801-4500 K, 50-400 W 

Baseline

1 

2 

3 

2801-4500 K, 401-1000 W 

Baseline

1 

2 

2801-4500K, 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 ASSESSMENT

The impact of new energy conservation standards on employment is an important consideration 

12A-44 
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. 

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 provide 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 CMH150,000 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-45 
APPENDIX 12B GOVERNMENT REGULATORY IMPACT MODEL (GRIM) 

OVERVIEW

TABLE OF CONTENTS

12B.1 INTRODUCTION AND PURPOSE .......................................................................... 12B-1

12B.2 HIGH INTENSITY DISCHARGE LAMP DESCRIPTION ...................................... 12B-1

12B.3 HIGH INTENSITY DISCHARGE LAMP DETAILED CASH FLOW EXAMPLE 12B-4

12B-i 
APPENDIX 12B GOVERNMENT REGULATORY IMPACT MODEL (GRIM) 

OVERVIEW

12B.1 INTRODUCTION AND PURPOSE

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 industry 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. 

Industry 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 (ELs) for each equipment class (i.e., the standards case).

Output from the model consists of summary financial metrics, graphs of major variables, 

and, when appropriate, access to the complete cash flow calculation. 

12B.2 HIGH INTENSITY DISCHARGE LAMP DESCRIPTION

DOE analyzed the impacts of potential standards on high intensity discharge (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 efficacy level by the appropriate manufacturer markup; 

(2) Total Shipments: The total covered units shipped; 

(2) Materials: 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 assets 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) Product 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 over 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;

(10) Earnings Before Interest and Taxes (EBIT): Includes profits before deductions for 

interest paid and taxes;

(11) Per Unit EBIT: The average amount of EBIT (10) per covered unit shipped; 

(12) EBIT/Revenues: The GRIM calculates EBIT as a percentage of sales to compare 

with the industry’s average reported in financial statements;

(13) Taxes: Taxes on EBIT (10) are calculated by multiplying the tax rate contained in 

the Discounted Cash Flow tab by EBIT (10); 

(14) Net Operating Profits After Taxes (NOPAT): Computed by subtracting Taxes (12) 

from EBIT (10); 

(15) NOPAT repeated: NOPAT (13) is repeated in the Statement of Cash Flows;

(16) Depreciation repeated: Depreciation (4) is added back in the Statement of Cash 

Flows because it is a non-cash expense;

(17) Stranded Assets repeated: Stranded Assets (9) is added back in the Statement of 

Cash Flows because it is a non-cash expense;

(18) 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 (14), adding back noncash items such as Depreciation (16) and Stranded Assets (17), 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); 

(21) 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 regulations; 

the GRIM allocates these costs over the period between the potential standards’ 

announcement and compliance dates; 

(22) Free Cash Flow: Calculated by taking annual Cash Flow From Operations (19) and 

subtracting (20) Ordinary Capital Expenditures and (21) Capital Conversion Costs; 

(23) Free Cash Flow repeated: Free Cash Flow (22) is repeated in the Discounted Cash 

Flow section;

(24) 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;

(25) Present Value Factor: Factor used to calculate an estimate of the present value of an 

amount to be received in the future; 

(26) Discounted Cash Flow: Free Cash Flow (22) multiplied by the Present Value 

Factor (25). For the end of 2046, the discounted cash flow includes the discounted 

Terminal Value (24); and

Industry Value thru the end of 2046: The sum of Discounted Cash Flows (26). 

12B-3 
12B.3 HIGH INTENSITY DISCHARGE LAMP DETAILED CASH FLOW EXAMPLE

12B-4