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High-Intensity 

Discharge Lamps 

Proposed 

Determination 

Preliminary 

Technical Support 

Document 

This Preliminary Technical 

Support Document (TSD) 

provides the technical analyses 

and results in support of the 

proposed determination for 

high-intensity discharge (HID) 

lamps. 

Some of the following 

documents are available as 

Adobe Acrobat PDFs. Download 

Adobe Reader. 

Preliminary TSD (PDF 1.6 MB) 

Contents 

z Title Page (PDF 23 KB) 

z Acronyms and 

Abbreviations (PDF 34 

KB) 

z Chapter 1: 

Introduction (PDF 41 KB) 

z Chapter 2: Market 

Assessment (PDF 226 KB) 

z Chapter 3: Technology 

Assessment (PDF 1.1 MB) 

z Chapter 4: Engineering 

Analysis (PDF 66 KB) 

z Chapter 5: Life-Cycle Cost 

and Payback Period 

Analysis (PDF 228 KB) 

z Chapter 6: Potential 

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National Energy and 

Consumer Impacts of 

Energy Conservation 

Standards for HighIntensity Discharge 

Lamps (PDF 59 KB) 

z Appendix A: NonRegulatory Programs 

Related to High-Intensity 

Discharge 

Lamps (PDF 135 KB) 

Printable Version 

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EE-DET-03-001 COMMENT 19
PRELIMINARY TECHNICAL SUPPORT DOCUMENT:

ENERGY EFFICIENCY PROGRAM

FOR COMMERCIAL AND INDUSTRIAL EQUIPMENT:

High-Intensity Discharge Lamps 

Analysis of Potential Energy Savings

Docket #: EE-DET-03-001

April 2010

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

EE-DET-03-001 COMMENT 19
1-i 

TABLE OF CONTENTS

LIST OF ACRONYMS AND ABBREVIATIONS .............................................................. V

1.1 LEGAL AUTHORITY ................................................................................................. 1-1

1.2 HIGH-INTENSITY DISCHARGE LAMP DEFINITION ........................................... 1-2

2.1 SHIPMENT ESTIMATES ........................................................................................... 2-1

2.1.1 Energy Use by Sector..................................................................................... 2-1

2.1.2 High-Intensity Discharge Lamp Shipment Estimates .................................... 2-3

2.1.3 Manufacturers of High-Intensity Discharge Lamps, Luminaires, and 

Ballasts ........................................................................................................... 2-7

2.1.4 Distribution Channels .................................................................................... 2-7

2.1.5 Decision Makers ............................................................................................ 2-9

2.1.5.1 Residential Decision Makers ............................................................... 2-9

2.1.5.2 Commercial, Industrial, and Public Sector Lighting Decision 

Makers ............................................................................................... 2-10

2.2 APPLICATIONS FOR HIGH-INTENSITY DISCHARGE LAMPS .......................... 2-10

2.2.1 Residential Applications ................................................................................ 2-10

2.2.2 Commercial Applications .............................................................................. 2-11

2.2.3 Industrial Applications ................................................................................... 2-11

2.2.4 Other (Outdoor Public Sector) Applications.................................................. 2-11

2.3 CLASSIFICATION OF HIGH-INTENSITY DISCHARGE LUMINAIRES ............. 2-12

2.3.1 Proposed High-Intensity Discharge Luminaire Classification System .......... 2-12

2.3.1.1 Product Applications: Indoor ............................................................ 2-13

2.3.1.2 Product Applications: Outdoor .......................................................... 2-14

2.3.1.3 Product Applications: Specialty ........................................................ 2-16

2.4 REGULATORY AND NON-REGULATORY PROGRAMS ..................................... 2-16

2.4.1 Regulatory Programs and Legislation Impacting High-Intensity Discharge 

Lamps ............................................................................................................. 2-16

2.4.1.1 Federal Regulatory Programs and Legislation .................................. 2-16

2.4.1.2 Draft Legislation ................................................................................ 2-17

2.4.1.3 DOE Background Studies ................................................................. 2-19

2.4.1.4 State Regulatory Programs ................................................................ 2-20

2.4.2 Non-Regulatory Programs Affecting High-Intensity Discharge Lamps ....... 2-23

3.1 SPECIFICATIONS, TEST STANDARDS, AND PROCEDURES............................. 3-1

3.2 LAMP METRICS ......................................................................................................... 3-3

3.2.1 Lumens ........................................................................................................... 3-3

3.2.2 Mean Lumens/Lamp Lumen Depreciation/Lumen Maintenance .................. 3-3

3.2.3 Efficacy .......................................................................................................... 3-4

3.2.3.1 Visual Efficiency ................................................................................. 3-5

3.2.3.2 Moving Beyond the Limits .................................................................. 3-7

3.2.4 Color Rendering Index ................................................................................... 3-8

3.2.5 Correlated Color Temperature ....................................................................... 3-8

3.2.6 Lamp Life....................................................................................................... 3-8

3.3 MERCURY VAPOR (MV) LAMPS ............................................................................ 3-8

3.3.1 Lamp Construction......................................................................................... 3-9

3.3.2 Lamp Performance ......................................................................................... 3-10

EE-DET-03-001 COMMENT 19
1-ii

3.3.3 Electrical Characteristics ............................................................................... 3-13

3.3.4 Other Issues .................................................................................................... 3-14

3.4 HIGH-PRESSURE SODIUM LAMPS ........................................................................ 3-14

3.4.1 Lamp Construction......................................................................................... 3-14

3.4.2 Lamp Performance ......................................................................................... 3-15

3.4.3 Electrical Characteristics ............................................................................... 3-17

3.4.4 Other Issues .................................................................................................... 3-20

3.5 METAL HALIDE LAMPS........................................................................................... 3-20

3.5.1 Construction ................................................................................................... 3-20

3.5.1.1 Probe-Start Quartz Metal Halide Lamps ........................................... 3-24

3.5.1.2 Pulse-Start Quartz Metal Halide Lamps ............................................ 3-25

3.5.1.3 Pulse-Start Ceramic Metal Halide Lamps ......................................... 3-25

3.5.2 Lamp Performance ......................................................................................... 3-26

3.5.2.1 Probe-Start Quartz Metal Halide Lamps ........................................... 3-28

3.5.2.2 Pulse-Start Quartz Metal Halide Lamps ............................................ 3-29

3.5.2.3 Pulse-Start Ceramic Metal Halide Lamps ......................................... 3-30

3.5.3 Electrical Characteristics ............................................................................... 3-31

3.5.4 Other Issues .................................................................................................... 3-32

3.6 HIGH-INTENSITY DISCHARGE LAMP BALLASTS ............................................. 3-33

4.1 ENGINEERING ANALYSIS FRAMEWORK ............................................................ 4-1

4.1.1 Representative Equipment Categories ........................................................... 4-2

4.1.2 Baseline Lamps .............................................................................................. 4-2

4.1.3 Substitute Lamps ............................................................................................ 4-2

4.2 EQUIPMENT PRICE DETERMINATION ................................................................. 4-3

4.3 ENGINEERING ANALYSIS RESULTS .................................................................... 4-4

5.1 METHOD AND DATA ................................................................................................ 5-1

5.1.1 Annual Operating Hours ................................................................................ 5-1

5.1.2 Lamp Prices ................................................................................................... 5-2

5.1.3 Ballast Prices .................................................................................................. 5-4

5.1.4 Fixture Prices ................................................................................................. 5-5

5.1.5 Lamp Lifetime ............................................................................................... 5-7

5.1.6 Ballast Lifetime .............................................................................................. 5-8

5.1.7 Contractor Mark-up ....................................................................................... 5-8

5.1.8 Sales Tax ........................................................................................................ 5-9

5.1.9 Maintenance Costs ......................................................................................... 5-9

5.1.10 Electricity Price .............................................................................................. 5-10

5.1.11 Discount Rate ................................................................................................. 5-10

5.2 RESULTS FOR MEDIUM-WATTAGE MERCURY VAPOR DESIGN

OPTIONS ...................................................................................................................... 5-11

5.2.1 Event 1 – Lamp-Only Replacement ............................................................... 5-11

5.3 RESULTS FOR MEDIUM-WATTAGE PROBE-START METAL HALIDE 

DESIGN OPTIONS ...................................................................................................... 5-12

5.3.1 Event 1 – Lamp-Only Replacement ............................................................... 5-12

5.3.2 Event 2 – New Construction / Fixture Replacement ..................................... 5-14

6.1 METHODOLOGY ....................................................................................................... 6-1

6.1.1 Shipment Forecasts ........................................................................................ 6-1

EE-DET-03-001 COMMENT 19
1-iii

6.1.2 National Energy Savings Analysis................................................................. 6-2

6.1.3 Net Present Value Analysis ........................................................................... 6-2

6.2 ESTIMATES OF POTENTIAL ENERGY AND CONSUMER IMPACTS ............... 6-3

6.2.1 National Energy Savings................................................................................ 6-3

6.2.2 Net Present Value .......................................................................................... 6-3

LIST OF TABLES

Table 2.1.1. 2008 Total Lighting Technology (High-Intensity Discharge) Electricity 

Consumption ........................................................................................................ 2-1

Table 2.1.2. Installed Base of High-Intensity Discharge Luminaires in the United States ......... 2-3

Table 2.1.3. Distribution of Electricity Consumption by Sector of High-Intensity Discharge 

Lighting ................................................................................................................ 2-3

Table 2.1.4. Portion of Total NEMA High-Intensity Discharge Lamp Shipments ..................... 2-3

Table 2.1.4. Portion (continued) .................................................................................................. 2-4

Table 2.1.5. Freedonia Group High-Intensity Discharge Lamp Shipments ................................ 2-5

Table 2.1.6. 2008 NEMA Shipments by Wattage Grouping ....................................................... 2-6

Table 2.3.1. Classification for Indoor Applications ................................................................... 2-13

Table 2.3.2. Classification for Outdoor Applications ................................................................ 2-14

Table 2.3.3. Classification for Specialty Applications .............................................................. 2-16

Table 2.4.1. California Metal Halide Fixture Requirements ..................................................... 2-20

Table 3.1.1 Documents Pertaining to High-Intensity Discharge Lamps ..................................... 3-1

Table 3.2.1. Visual Efficiencies and Efficacies of Various Sources ........................................... 3-5

Table 3.2.2. Sample Energy Output for High Intensity Discharge Lamps .................................. 3-6

Table 3.2.3. Chromaticities and Maximum Spectral Efficiencies of Various Sources ................ 3-6

Table 3.2.4. Color Rendering Indexes and Spectral Efficiencies of High-Intensity Discharge 

Sources ................................................................................................................. 3-7

Table 3.2.5. Probable Efficacy Limits by Color Correlated Temperature (CCT) for 

Conventional High-Intensity Discharge Lamps................................................... 3-7

Table 3.3.1. Performance Summary of Mercury Vapor Lamps ................................................ 3-12

Table 3.4.1. Performance Summary of High-Pressure Sodium Lamps ..................................... 3-16

Table 3.5.1. Performance Summary of Probe-Start Metal Halide Lamps ................................. 3-28

Table 3.5.2. Performance Summary of Quartz Pulse-Start Metal Halide Lamps ...................... 3-29

Table 3.5.3. Performance Summary of Pulse-Start Ceramic Metal Halide Lamps ................... 3-31

Table 3.5.4. Total Mercury Sold in Lamps ................................................................................ 3-32

Table 3.5.5. Total Mercury Sold by HID Lamp Type ............................................................... 3-32

Table 4.3.1. HID Lamps Determination Engineering Analysis Results ...................................... 4-4

Table 5.1.1. Lamp Prices from RS-Means ................................................................................... 5-2

Table 5.1.2. Municipal Lamp Prices ............................................................................................ 5-2

Table 5.1.3. Lamp Price derived from Online Distributor Web Sites ......................................... 5-3

Table 5.1.4. Lamp Price derived from Online Distributor Web Sites ......................................... 5-5

Table 5.1.5. Prices from RS-Means for HID Fixtures ................................................................. 5-5

Table 5.1.6. Lamp Price derived from Online Distributor Web Sites ......................................... 5-6

Table 5.1.7. Lamp Life Data (175W MV Baseline) .................................................................... 5-7

Table 5.1.8. Lamp Life Data (250W MV Baseline) .................................................................... 5-7

EE-DET-03-001 COMMENT 19
1-iv

Table 5.1.9. Lamp Life Data (400W MV Baseline) .................................................................... 5-7

Table 5.1.10. Lamp Life Data (175W Baseline) .......................................................................... 5-7

Table 5.1.11. Lamp Life Data (250W MH Baseline) .................................................................. 5-8

Table 5.1.12. Lamp Life Data (360W Baseline) .......................................................................... 5-8

Table 5.1.13 Lamp Life Data (400W Baseline) ........................................................................... 5-8

Table 5.2.1. LCC-PBP Analysis for 175W MV Baseline.......................................................... 5-11

Table 5.2.2. LCC-PBP Analysis for 250W MV Baseline.......................................................... 5-11

Table 5.2.3. LCC-PBP Analysis for 400W MV Baseline.......................................................... 5-12

Table 5.3.1. LCC-PBP Analysis for 175W MH Baseline.......................................................... 5-12

Table 5.3.2. LCC-PBP Analysis for 250W MH Baseline.......................................................... 5-13

Table 5.3.3. LCC-PBP Analysis for 360W MH Baseline.......................................................... 5-13

Table 5.3.4. LCC-PBP Analysis for 400W MH Baseline.......................................................... 5-13

Table 5.3.5. LCC-PBP Analysis for 175W MH Baseline.......................................................... 5-14

Table 5.3.6. LCC-PBP Analysis for 250W MH Baseline.......................................................... 5-14

Table 5.3.7. LCC-PBP Analysis for 360W MH Baseline.......................................................... 5-15

Table 5.3.8. LCC-PBP Analysis for 400W MH Baseline.......................................................... 5-15

Table 6.2.1. Cumulative National Energy Savings for HID Lamps (2017–2046) ...................... 6-3

Table 6.2.2. Cumulative NPV Results for HID Lamps (2017–2046) .......................................... 6-4

LIST OF FIGURES

Figure 2.1.1. Shares of Sectoral Energy Use by Lighting Technology ....................................... 2-2

Figure 2.1.2. Proportion of Lamp Type in High-Intensity Discharge Market, 1990–2008 ......... 2-5

Figure 2.1.3. High-Intensity Discharge Lamp Distribution Channels ......................................... 2-8

Figure 3.3.1. Mercury Vapor Lamp Construction ..................................................................... 3-10

Figure 3.3.2. Spectral Power Distribution of Mercury Vapor Lamps (a) Without Phosphors 

and (b) With Phosphors ..................................................................................... 3-11

Figure 3.4.1. High-Pressure Sodium Lamp Construction .......................................................... 3-15

Figure 3.4.2. Spectral Power Distribution*

 of High-Pressure Sodium Lamps........................... 3-17

Figure 3.4.3. Sample Power Flow of a 400 W High-Pressure Sodium Lamp ........................... 3-18

Figure 3.4.4. Trapezoid Boundary for High-Pressure Sodium Ballast Design .......................... 3-19

Figure 3.5.1. Tin Halide ............................................................................................................. 3-21

Figure 3.5.2. Dysprosium Iodide ............................................................................................... 3-21

Figure 3.5.3. Formed Arc-Tube Configuration for Horizontal MH Lamps ............................... 3-22

Figure 3.5.4. Offset Electrode Configuration for Horizontal MH Lamps ................................. 3-23

Figure 3.5.5. Metal Halide Arc Tube with a Shroud ................................................................. 3-23

Figure 3.5.6. Metal Halide Lamp Construction ......................................................................... 3-24

Figure 3.5.7. Common Arc Tubes ............................................................................................. 3-25

Figure 3.5.8. Spectral Power Distribution of Metal Halide Lamps (a) Without Phosphors 

and (b) With Phosphors ..................................................................................... 3-27

Figure 5.1.1. Lamp Wattage/Price Comparison........................................................................... 5-3

Figure 5.1.2. Ballast Prices .......................................................................................................... 5-4

Figure 5.1.3. Lamp Wattage/Price Comparison........................................................................... 5-6

EE-DET-03-001 COMMENT 19
v 

LIST OF ACRONYMS AND ABBREVIATIONS

ACEEE American Council for an Energy-Efficient Economy

AEO Annual Energy Outlook

AK Alaska

ANSI American National Standards Institute

Ar argon

ASHRAE American Society of Heating, Refrigerating and Air Conditioning Engineers

atm atmosphere

At astatine

B self-ballasted mercury

Ba barium

Be beryllium

BBL blackbody locus

Br bromine

BR bulged reflector

BTU British thermal unit

C Celsius

Ca calcium

CA California

Caltrans California Department of Transportation

CCT correlated color temperature

Ce cerium

CFL compact fluorescent lamp

CFR Code of Federal Regulations

CIE Commission Internationale de l’Eclairage (International Commission on Illumination)

Cl chlorine

CMH ceramic metal halide

CRI color-rendering index

CW constant wattage 

CWA constant wattage autotransformer

D Democrat

DOC Department of Commerce

DOE Department of Energy

Dy dysprosium

DyI dysprosium iodide

EIA Energy Information Administration

EISA Energy Independence Security Act

EPA Environmental Protection Agency

EPCA Energy Policy and Conservation Act

EPAct Energy Policy Act

Er erbium

EE-DET-03-001 COMMENT 19
vi

ER elliptical reflector

Eu europium

F fluorine

FL fluorescent

fc footcandle

Gd gadodinium

He helium

Hg mercury

HID high-intensity discharge

HIF high-intensity fluorescent

Ho holmium

HPS high-pressure sodium

HX high-reactance autotransformer

I iodine

IC integrated circuit

IDA International Dark-Sky Association

IESNA Illuminating Engineering Society of North America

IL induction lamp

In indium

K Kelvin

kg kilograms

kPA kiloPascal

Kr krypton

kV kilovolt

kWh kilowatt-hour

La lanthanum

LA Louisiana

lbs pounds

LCC life-cycle cost

LCCF lamp current crest factor

LEDs light-emitting diodes 

LLD lamp lumen depreciation

LLF light loss factor

lm lumen

Lm/W lumens per watt

LPS low-pressure sodium

LPD lighting power density

LPW lumens per watt

LRC Lighting Research Center

Lu lutetium

Med Medium

mg milligrams

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Mg magnesium

MH metal halide, probe-start metal halide

MHLF metal halide lamp fixture

MI Michigan

MLO Model Lighting Ordinance

Mog Mogul

MR Multi-faceted reflector

MS Mississippi

MV mercury vapor

Nd neodymium

ND North Dakota

Ne neon

NEMA National Electrical Manufacturers Association

NES national energy savings

NJ New Jersey

nm nanometer

NM New Mexico

NPV net present value

Pa Pascals

PAR parabolic aluminized reflector

PBP payback period

Pin power in

Pm promethium

PMH pulse-start metal halide

Pout power out

Pr praseodymium

quads Quadrillion BTU

R Republican

Ra color-rendering index

Ra radium

RE rare earth

Rn radon

RX reactor

S/MH spacing-to-mounting height

Sc scandium

Sm samarium

Sn tin

SnI tin iodide

Sr strontium

SOx Sulfur dioxide

SPD spectral power distribution

Tb terbium

EE-DET-03-001 COMMENT 19
viii

TCLP toxicity characteristic leaching procedure

Tm thullium

torr Torr

TSD Technical support document

TWhr terawatt-hour

UL Underwriter's Laboratory

UV ultraviolet

V volt

W watt(s)

Xe xenon

Y yttrium

Yb ytterbium

EE-DET-03-001 COMMENT 19
1-1 

CHAPTER 1. INTRODUCTION

The Department of Energy (the Department or DOE) is preparing an analysis to 

determine the potential energy savings for high-intensity discharge (HID) lamps. The purpose of 

this analysis is to provide a basis for the Secretary of Energy to make a determination if 

mandatory energy conservation standards are technologically feasible and economically justified, 

and would result in significant energy savings. If the Secretary makes a determination that 

standards are warranted, the Department will develop a test procedure and then initiate a 

standards rulemaking. 

This preliminary technical support document contains the market assessment; technology 

assessment; engineering analysis; life-cycle cost (LCC); payback period (PBP); the national 

energy savings (NES); and net present value (NPV) analyses. Each of these sections addresses 

questions such as: 

• Market assessment – How large is the HID lighting market? How are HID lamps 

specified (i.e., which products will service a particular application)? What are the 

distribution channels for HID lamps? What are the product applications the Department 

will consider in this analysis?

• Technology assessment – What are the HID lamp technologies and their performance 

characteristics? What are the ballasts that operate them?

• Engineering analysis – If energy conservation standard results in the removal of certain 

HID lamps from the market, which technologies might consumers choose instead? 

Which high-volume HID markets should the Department consider when it conducts its 

LCC analysis?

• LCC and PBP analysis – What LCC and PBP calculation methods does the Department’s 

LCC model for HID lamps use? What are the inputs to the model? How did the 

Department gather pricing and other input data for the model? What are the LCC and 

PBP results? 

• NES analysis – What NES and NPV calculation methods does the Department use for 

HID lamps? What are the inputs to the NES and NPV model? How did the Department 

gather input data for this model? What are the NES and NPV results? 

1.1 LEGAL AUTHORITY

The Department conducted this analysis of potential energy savings under the authority 

of Section 346 of the Energy Policy and Conservation Act (EPCA) (42 U.S.C. 6317), which 

states:

Sec. 346. Energy conservation standards for high-intensity discharge lamps, 

distribution transformers, and small electric motors

a. High-intensity discharge lamps (and distribution transformers) 

1. The Secretary shall, within 30 months after October 24, 1992, 

prescribe testing requirements for those high-intensity discharge 

lamps (and distribution transformers) for which the Secretary makes 

EE-DET-03-001 COMMENT 19
1-2 

a determination that energy conservation standards would be 

technologically feasible and economically justified, and would result 

in significant energy savings.

2. The Secretary shall, within 18 months after the date on which testing 

requirements are prescribed by the Secretary pursuant to paragraph 

(1), prescribe, by rule, energy conservation standards for those highintensity discharge lamps (and distribution transformers) for which 

the Secretary prescribed testing requirements under paragraph (1). 

3. Any standard prescribed under paragraph (2) with respect to highintensity discharge lamps shall apply to such lamps manufactured 36 

months after the date such rule is published. 

Thus, the Secretary of Energy will make a determination whether energy conservation 

standards for HID lamps are technologically feasible and economically justified, and would 

result in significant energy savings. If the Secretary finds that energy conservation standards are 

warranted, the Department will commence work on a test procedure. Following the issuance of 

the test procedure, the Department will initiate a standards rulemaking process to establish 

energy conservation standards for HID lamps, based on the Department’s annual priority setting 

process.

1.2 HIGH-INTENSITY DISCHARGE LAMP DEFINITION

The Code of Federal Regulations (CFR) currently contains definitions for HID (10 CFR 

431.282), MV (10 CFR 431.282), and MH (10 CFR 431.322) lamps. The definitions are as 

follows: 

High intensity discharge lamp means an electric-discharge lamp in whichThe light-producing arc is stabilized by the arc tube wall temperature; and

The arc tube wall loading is in excess of 3 Watts/cm2

, including such lamps that are 

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

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).

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.

No definition for HPS lamps is currently listed in the CFR. Therefore, the Department 

reviewed the American National Standards Institute (ANSI) and the Illuminating Engineering 

Society of North America (IESNA) definitions for HPS lamps. 

EE-DET-03-001 COMMENT 19
1-3 

ANSI C82.9-1996 defines high-pressure sodium lamps as “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 about 6.67 x 103 pascals (50 torr) or greater.”

The IESNA LIGHTING HANDBOOK Reference and Application 9th Edition defines 

high-pressure sodium lamp as “a high-intensity discharge (HID) lamp in which light is produced 

by radiation from sodium vapor operating at a partial pressure of about 1.33 x 104 Pa (100 Torr). 

Includes clear and diffuse-coated lamps.”

Low-Pressure Sodium (LPS) lamps are often considered HID lamps, but this distinction 

is incorrect. 

ANSI defines LPS lamps as “A discharge lamp in which light is produced by radiation 

from sodium vapor operating at a partial pressure of 0.13 to 1.3 pascals (10-3 to 10-2 torr).” 

The IESNA defines LPS lamps as “a discharge lamp in which light is produced by 

radiation from sodium vapor operating at a partial pressure of 0.1 to 1.5 Pa (approximately 10-3

to 10-2 Torr).” 

Due to the lower pressure, the arc tube wall loading for LPS lamps is lower than the three 

watts per square centimeter defined for HID lamps. The full title of ANSI C82.9-1996, American 

National Standard for High-Intensity Discharge and Low-Pressure Sodium Lamps, Ballasts and 

Transformers –Definitions, highlights that LPS lamps are not HID lamps. Therefore, this 

analysis does not incorporate LPS lamps in its scope. However, it is still important to note that 

many within the lighting industry generally treat LPS lamps as HID lamps. 

EE-DET-03-001 COMMENT 19
2-1 

CHAPTER 2. MARKET ASSESSMENT

For the market assessment of high-intensity discharge (HID) lighting, the U.S. 

Department of Energy (DOE) gathered information on the state of the industry and the market 

characteristics of HID lighting. DOE uses these data as some of the inputs to the life-cycle cost 

analysis and the national energy savings estimate. This chapter provides the quantitative and 

qualitative findings of the market assessment, including shipment estimates, market structure, 

installations and applications, and non-regulatory initiatives to improve HID lamp efficiency.

2.1 SHIPMENT ESTIMATES

The HID lamp market in the United States is an approximate $390 million per year 

industry, with annual sales exceeding 30 million units.1,2 In 2001, HID lamps consumed 

125 gigawatt-hours nationally, which is approximately 17 percent of the electricity consumed by 

all light sources and approximately 3.6 percent of total U.S. electricity generated in 2000.

3

Three light sources characterize the HID lighting market: mercury vapor (MV), 

high-pressure sodium (HPS), and metal halide (MH). Technical data on these HID lamp 

technologies, including details about their performance, light characteristics, operating life, and 

other information, are provided in chapter 3, Technology Assessment. 

 

2.1.1 Energy Use by Sector

Table 2.1.1 presents the energy consumption for lighting in four general sectors: three 

building-related (residential, commercial, and industrial) and “other,” which includes street and 

area lighting, parking garages, airport runway systems, and traffic signals. The other category 

does not, however, represent all outdoor stationary HID luminaires. The three building-related 

sectors also include some outdoor stationary lighting, where the circuit for the outdoor 

luminaires is tied to the electric meter for a building (e.g., architectural lighting, parking lot 

lighting, residential security lighting). 

Table 2.1.1. 2008 Total Lighting Technology (High-Intensity Discharge) Electricity 

Consumption 

HID Lamp Consumption by Sector

terawatt-hr (TWh)

Residential Commercial Industrial Other Total*

Mercury Vapor 1 7 3 12 22

High-Pressure Sodium 0 6 5 30 41

Metal Halide N/A 34 25 4 62

Total for HID 1 47 33 46 125

Total 202 391 108 56 756

Source: DOE, Buildings Energy Data Book 2008, table 5.6.4.

* Note: Due to rounding, the sum of the columns may not equal the total provided.

Table 2.1.1 provides the electricity consumed (TWh) per lamp type per sector. The 

estimate of total lighting electricity consumption in the United States is 756 TWh (2.6 quads) of 

primary energy. In a broader context, the total energy consumption in the United States was 

approximately 98.3 quads in 2001, of which more than one-third (about 37 quads) was used to 

EE-DET-03-001 COMMENT 19
2-2 

generate electricity.3 Thus, lighting accounted for about 7 percent of national primary energy 

consumption, or about 22 percent of the electricity generated in 2001. 

Table 2.1.1 also provides additional details on specific HID technology energy 

consumption by sector. For residential, where 90 percent of lighting energy use is consumed by 

incandescent technologies, HID sources account for less than 1 percent (0.66 TWh/year [yr] or 

0.002 quads) of the energy consumption. The commercial sector has a large share of HID 

sources, which constitute approximately 12 percent (47 TWh/yr or 0.16 quads) of the annual 

391 TWh/yr of electricity use in this sector. The industrial sector also operates a large share of 

HID sources, which constitute 31 percent (33 TWh/yr or 0.11 quads) of this sector’s 108 TWh/yr 

lighting-related energy usage. The primary lighting energy consumer in the other sector is HID, 

which accounts for 82 percent (46 TWh/yr or 0.16 quads) of the outdoor stationary’s 

56 TWh/yr lighting electricity use. Across all four sectors, HID sources consumed 125 TWh/yr 

(0.42 quads) in 2001. This amounts to approximately 17 percent of the annual electricity 

consumption for lighting in the United States.

Figure 2.1.1 shows the total lighting energy consumption for the four sectors and 

illustrates the amounts of energy used by the various lighting technologies. From this figure, the 

significance of HID technology and its dominance in the other sector becomes further evident. 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Residential

Commercial

Industrial

Other

Fluorescent

HID

Incandescent

Source: Navigant Consulting, Inc. (NCI), U.S. Lighting Market Characterization Volume I: 

National Lighting Inventory and Energy Consumption Estimate, 2002.

Figure 2.1.1. Shares of Sectoral Energy Use by Lighting Technology 

Table 2.1.2 presents the estimated installed base of HID luminaires in the United States

by technology and sector. HPS is the leading source in the outdoor stationary sector, while MH 

dominates in the commercial and industrial sectors. In the residential sector, MV is the most 

prevalent technology with nearly three times more installations than HPS. The total estimated 

EE-DET-03-001 COMMENT 19
2-3 

installed base of HID luminaires in the United States for 2001 was approximately 101 million 

units. 

Table 2.1.2. Installed Base of High-Intensity Discharge Luminaires in the United States

HID Light Source Sector

number of units

Residential Commercial Industrial Other Total

Mercury Vapor 3,103,000 5,401,000 1,750,000 12,146,000 22,400,000

High-Pressure Sodium 1,204,000 5,814,000 2,694,000 34,347,000 44,058,000

Metal Halide N/A 19,378,000 10,706,000 4,726,000 34,809,000

Total 4,307,000 30,593,000 15,150,000 51,219,000 101,267,000

Source: NCI, U.S. Lighting Market Characterization Volume I: National Lighting Inventory and Energy 

Consumption Estimate, 2002.

Table 2.1.3 shows the electricity consumption of each lamp type as a percentage of total 

HID electricity consumption. HPS is prominent in the outdoor stationary sector, and MH is the 

largest electricity consumer in the commercial and industrial sectors. Overall, the residential 

sector accounts for only one-half of 1 percent of HID electricity consumption. 

Table 2.1.3. Distribution of Electricity Consumption by Sector of High-Intensity Discharge 

Lighting 

HID Lamp Sector

% 

Residential Commercial Industrial Outdoor 

Stationary

Total

Mercury Vapor 0 5 3 9 17

High-Pressure Sodium 0 5 4 24 33

Metal Halide N/A 27 20 4 50

Total 0 37 27 36 100

Source: DOE, Buildings Energy Data Book 2008, table 5.6.4.

2.1.2 High-Intensity Discharge Lamp Shipment Estimates

Table 2.1.4 presents estimates of annual HID lamp shipments to the U.S. lighting market, 

broken down into the three primary HID lamp types. These data were provided by the National 

Electrical Manufacturers Association (NEMA), whose members are responsible for 100 percent 

of domestic HID lamp production and over 90 percent of national HID lamp sales.2

 

Table 2.1.4. Portion of Total NEMA High-Intensity Discharge Lamp Shipments

Year HID Lamp

%

Mercury Vapor High-Pressure Sodium Metal Halide

1990 32.12 38.34 29.53

1991 24.73 45.05 30.22

1992 23.62 44.22 32.16

1993 21.30 44.91 33.80

1994 19.92 43.98 36.10

1995 17.44 41.86 40.70

1996 15.77 42.65 41.58

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Table 2.1.5. Portion (continued)

Year HID Lamp

% 

Mercury Vapor High-Pressure Sodium Metal Halide

1997 12.24 41.61 46.15

1998 9.21 40.13 50.66

1999 8.08 37.72 54.19

2000 5.73 36.62 57.64

2001 8.02 35.49 56.48

2002 7.29 35.56 57.14

2003 6.83 34.85 58.32

2004 7.35 33.59 59.06

2005 7.01 36.69 56.29

2006 7.37 32.50 60.13

2007 6.37 31.60 62.03

2008 5.49 32.85 61.66

From 1990 to 2008, NEMA shipments of HID lamps nearly doubled with the largest 

shipment in 2005. 

In 1990, MV lamps represented 32 percent of the total HID lamp shipments. In 2008, MV 

only represented a mere 5 percent of total lamp shipments. Although there was a significant 

decrease in the proportion of lamp shipments, the actual amount of lamps shipped only reduced 

by 70 percent. This is due to the overall volume of HID lamps shipped increased from 1990 to 

2008 by almost a factor of two. In 2003, DOE released the draft report, Draft Framework for 

Determination Analysis of Energy Conversation Standards for High-Intensity Discharge Lamps, 

and received comments. The DOE draft report stated that in 1990, the MV lamp shipments were 

6.7 million units and in 2002, 2.9 million units were shipped. This represents a 57 percent 

decline in MV lamp shipments. Also in 2003, NEMA commented that “[a]bsent any newly 

created markets, we do not agree with the presumption that the trend of declining mercury vapor 

lamp shipments has bottomed out.”4

During the near 20-year period of data analyzed, HPS lamps accounted on average for 38 

percent of the total HID lamp shipments. In 1991, HPS represented the plurality of HID lamps 

shipped. Since that year, HPS has been on a decline in representing the total amount of HID 

lamps shipped. In 2008, HPS only represented 33 percent of the total HID lamps shipped. In 

terms of absolute shipments, HPS peaked in 1999 at 12.6 million units shipped. In 2008, only 

10.9 million lamps were shipped. 

 

Of the three lamps in the HID family, MH lamps have grown in both percentage of total 

HID lamp shipments as well as absolute amount of lamps shipped. In 1990, MH lamps only 

represented 30 percent of the HID lamps shipped, slightly less than the percentage that MV 

lamps represented. Eighteen years later, MH lamps represent 62 percent of all the HID lamps 

shipped. This growth is further demonstrated in the volume of lamps shipped. In 1990, 

5.7 million MH lamps were shipped compared with 2008, when 20.4 million lamps were 

shipped. This significant growth over the last 18 years stems from the commercialization of both 

the pulse-start quartz (PMH) and the ceramic (CMH) metal halide lamps.

EE-DET-03-001 COMMENT 19
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DOE purchased a research report from the Freedonia Group regarding lamps. Section V 

of the report focuses on Electric Discharge Lamps. The Freedonia report provides both historical 

analysis as well as future analysis. Table 2.1.5 summarizes the estimates and projections in the 

Freedonia Group report. 

Table 2.1.6. Freedonia Group High-Intensity Discharge Lamp Shipments

HID Lamp 1998 2003 2008 2013 2018

Million 

Units

Portion 

of 

Total

%

Million 

Units

Portion 

of 

Total

%

Million 

Units

Portion 

of 

Total

%

Million 

Units

Portion 

of 

Total

%

Million 

Units

Portion 

of 

Total

%

Mercury Vapor 17 30.36 16 19.28 19 16.67 10 6.67 5 2.44

High-Pressure 

Sodium

24 42.86 39 46.99 50 43.86 70 46.67 100 48.78

Metal Halide 15 26.79 28 33.73 45 39.47 70 46.67 100 48.78

Total 56 100 83 100 114 100 150 100 205 100

Although the absolute values (and thus the portions) are different from the NEMA data, 

the Freedonia Group data do reinforce the NEMA data. Both sets of data suggest that MV 

shipments are significantly curtailing, the MH has grown in considerable size since the mid1990s, and HPS represents a sizable yet relatively flat portion of the market. 

Figure 2.1.2 illustrates the annual shipments and market share by HID lamp type (MV, 

HPS, and MH).a It shows the obvious decline in MV shipments, contrasting with sales of HPS 

and MH. It also presents annual shipment data as a percent of total shipments in a given year. 

The decline in the market share of MV lamps is even more evident, as the MV lamp proportion 

of total shipments contrasts sharply with shipments of MH. 

Sources: NEMA data provided to DOE 2009. 

Figure 2.1.2. Proportion of Lamp Type in High-Intensity Discharge Market, 1990–2008 

 

a DOE prepared Figure 2.1.2 and Figure 2.1.3 from the data in Table 2.1.5. 

EE-DET-03-001 COMMENT 19
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National shipments of HPS lamps appear to have leveled off after a strong growth period 

in the early 1990s. HPS lamps are a mature technology, having been commercially available for 

more than 40 years. 

Similar to HPS lamps, MH lamp technology is mature, although this is the only type of 

HID lamp that has increased market share in the last 10 years. Industry continues to invest in 

improving MH technology, enabling it to continue to compete strongly in both the HID lamp 

markets and other lighting markets, such as those typically serviced by fluorescent sources 

(e.g., retail stores). Examples of these performance improvements (discussed in chapter 3 of this 

technical support document [TSD]) include pulse-start technology and the development of a 

ceramic arc tube. These and other improvements have lengthened the operational life and 

performance characteristics of MH technology, making it an attractive light source in many 

sectors and applications. 

Table 2.1.6 lists the domestic and import shipments of HID lamps, HPS represents 33 

percent of the total shipments, MH represents 60 percent of the shipments, and MV represents 7 

percent of the shipments. The data in Table 2.1.6 confirm the historic data shown in Table 2.1.4

and Figure 2.1.2. For the last year, 2002, of historical national sales data (Table 2.1.4), HPS 

represented 35 percent of national sales; MH represented 57 percent of national sales; and MV 

represented 8 percent of sales. Figure 2.1.2 depicted the historical shipment data for HID lamps. 

For the last year of available data (2008), MV represented about 5 percent (0 to 5 percent, Figure 

2.1.2); HPS represented about 33 percent (5 to 38 percent, Figure 2.1.2); and MH represented 62 

percent (38 to 100 percent, Figure 2.1.2) of the market.

Table 2.1.7. 2008 NEMA Shipments by Wattage Grouping

Lamp Type Wattage Range

%

1–149 W 150–500 W > 501 W

Mercury Vapor 37.68 58.75 3.58

High-Pressure Sodium 49.45 44.49 6.06

Probe-Start Quartz Metal Halide 0.48 52.11 11.41

Pulse-Start Quartz Metal Halide 8.28 9.93 0.62

Pulse-Start Ceramic Metal Halide 14.06 3.11 0.00

Source: NEMA Correspondence with DOE 2009

Table 2.1.6 shows the lamp shipments by wattage bin for HID lamps. The bins are the 

standard wattage groupings of low (less than or equal to 149 W), medium (150–500 W), and 

high (greater than or equal to 501 W). A majority of the MV lamps shipped were of medium 

wattage and a sizable amount of low-wattage MV lamps were shipped. The MV lamps 

commercially available affect the MV distribution; there are many lamps available at 175, 250, 

400, and 450 W. In contrast, fewer options are available in the other wattages. An almost equal 

amount of low and medium HPS lamps were shipped in 2008. Virtually all of the HPS lamps 

shipped were 500 W or less. The typical applications HPS lamps are used dictate the distribution 

in the low and medium groups. Of the entire metal halide lamp family (probe, pulse, and 

ceramic) a majority of lamps shipped in 2008 are medium wattage probe-start lamps. Low and 

medium wattage pulse-start both quartz and ceramic comprise roughly 18 and 17 percent, 

respectively, of the entire MH market. The other significant amount of market share is the highEE-DET-03-001 COMMENT 19
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wattage probe-start market. These values are for 2008; in the future, the probe-start MH values 

will probably not be as sizable because of current and pending legislation (Section 2.4). 

2.1.3 Manufacturers of High-Intensity Discharge Lamps, Luminaires, and Ballasts

NEMA’s website lists manufacturers that constitute the NEMA membership for HID 

lamp manufacturing who are responsible for the entire domestic (U.S.) production of HID 

lamps.1 Like many of NEMA’s members, these manufacturers may have non-domestic 

manufacturing facilities and thus bring their products into the United States as imports. 

NEMA companies also include members that manufacture HID ballasts.5 Electronic 

ballasts for HID lamps are relatively new to the marketplace;6 consequently, the list of 

manufacturers is shorter than the list established magnetic ballast technology.7

The four largest lighting conglomerates in the United States are Acuity Lighting Brands, 

Cooper Lighting, Hubbell, and Philips. These manufacturers encompass numerous other 

companies and brands, and represent the majority of the domestic production of HID luminaires. 

. All these 

manufacturers make luminaires for MH sources. Thirty-nine companies manufacture luminaires 

solely for MH sources, 42 companies manufacture luminaires for both HPS and MH sources, and 

27 companies manufacture luminaires for all HID sources (HPS, MV, and MH). Some of these 

luminaires are similar in shape, design, or construction but have specific features to 

accommodate the various light sources. Manufacturers that make products for different light 

sources may not manufacture the same luminaire type for each source.

2.1.4 Distribution Channels

Figure 2.1.3 shows the distribution channels for the HID lamp market. The structure of 

this figure is relevant for all end-use sectors (residential, commercial, industrial, and other); 

however, the volume of product going through the various channels varies. The dashed lines in 

the figure represent distribution channels that contractors infrequently use. DOE adapted this 

illustration of HID lamp distribution channels from Sardinsky,8 updating it using manufacturers’ 

and lighting specifiers’ literature to reflect the current HID lamp market. 

EE-DET-03-001 COMMENT 19
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HID Lamp Manufacturer

Internet

Manufacturer Representative

(4)

Mail Order 

Distributor

Consumer

(6)

National 

Accounts

Contractor Contractor

(5)

Electrical 

Distributor

(3)

Regional 

Retailer

(2)

Local 

Retailer

Contractor Contractor

(1)

Specialty 

Retailer

HID Lamp Manufacturer

Internet

Manufacturer Representative

(4)

Mail Order 

Distributor

Consumer

(6)

National 

Accounts

Contractor Contractor

(5)

Electrical 

Distributor

(3)

Regional 

Retailer

(2)

Local 

Retailer

Contractor Contractor

(1)

Specialty 

Retailer

Figure 2.1.3. High-Intensity Discharge Lamp Distribution Channels

HID lamp manufacturers sell products through six categories of distributors. Specialty, 

local, and regional retailers primarily serve the residential sector. Mail-order and electrical 

distributor networks are the principal outlets used by the commercial, industrial, and public 

sector lighting markets. The national accounts serve all sectors.

The specialty retailer is a broad distribution category typified by independently owned 

specialty lamp retailers. However, as an HID lamp distribution channel, it only represents 

roughly 10 percent of the total market for HID lamps.

Local retailers are relatively large retail outlets, such as local hardware stores. This 

limited outlet for HID products primarily serves the residential sector. Although product 

availability is limited, some local and small contractors may opt to purchase HID lamps through 

these channels.

Regional retailers are the larger chain stores that have multiple locations. Similar to the 

local retailers, they usually offer a limited selection of HID lamps tailored to the residential 

sector. Contractors have limited contact with this channel.

Mail-order distribution is another major distribution channel. Although these distributors 

stock products used in all sectors, lamp availability through this channel is typically limited to 

high-volume items. Smaller businesses and contractors are the primary end-users for these 

distributors. However, the Internet is expanding the end-user base for these outlets and enabling 

them to adapt their offerings more quickly to end-user needs.

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Large electrical-equipment distributors handle the majority of the HID lamp shipments, 

effectively operating as a wholesale clearinghouse for the HID lamp industry. Often, contractors 

operate as middlemen between end-users and distributors. Building-management companies, 

maintenance contractors, developers, municipalities, utilities, and related entities purchase lamps 

either directly from electrical-equipment distributors or through a contractor. 

The sixth major channel of distribution is through the national accounts. Lamp 

manufacturers sell some products through large national retailers, such as Wal-Mart, Sears, and 

big-box retailers, such as Home Depot and Lowe’s. Large maintenance companies and other 

national businesses may also purchase lamps directly from the manufacturers. However, product 

availability through these outlets is limited to high-volume (commodity) HID products. 

The advent of the Internet created new opportunities that could significantly impact all 

distribution channels and sectors. In response to the growing base of Internet users, 

manufacturers created new online databases that list product offerings and links to various 

distribution channels for purchase. Although the references primarily link to mail-order 

distribution houses, other links to walk-in retailers are also available. For end-users interested in 

accessing products, these new online sources and distributors offer an alternative to the 

traditional channels of large retailers and specialty stores. Many of these websites incorporate 

“design centers” that help end-users match lamps with their needs, much like a knowledgeable 

specifier or sales representative would do. The total impact on shipments for this industry is 

small at this time.

2.1.5 Decision Makers

After initial installation of a luminaire, the purchase of replacement lamps becomes a 

maintenance issue. Therefore, in most cases, the luminaire purchasing decision dictates the 

subsequent replacement lamps purchased because there is very little interoperability of different 

lamp wattages or lamp types for the various HID ballasts. Specifiers who determine which light 

source to install are the electrical contractors, architects, lighting designers, electrical engineers, 

building owners, homeowners, building maintenance personnel, municipal officials, state 

officials (highway departments), and corporate officials who select HID luminaires for their 

properties. In addition, electrical distributors and manufacturers may also influence the choice of 

light sources. 

2.1.5.1 Residential Decision Makers

For the residential sector, the interaction between the builder (or homeowner) and the 

other stakeholders (i.e., designer, contractor, engineer, retailer, and electrical distributor) may 

change based on the budget and type of installation: new or retrofit. 

For both new and retrofit installations, the builder or homeowner typically acts as the 

primary specifier. The budget of the project generally determines the level of involvement of the 

various stakeholders. The role and decision-making power of the designer and contractor 

typically grows with the escalating cost of the project. However, as project budgets become 

tighter, direct involvement with retailers, electrical distributors, and the Internet gains 

prominence. 

EE-DET-03-001 COMMENT 19
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2.1.5.2 Commercial, Industrial, and Public Sector Lighting Decision Makers

For the commercial, industrial, and public sectors, the interaction among decision makers 

is more complex than in the residential sector. The key decision makers in the commercial and 

industrial sectors are: (1) the owner (or developer); (2) the building manager; (3) the design team 

(i.e., architect, engineer, lighting designer); and (4) electrical contractor. 

Local utilities, municipalities, and state highway agencies install and maintain many of 

the luminaires used in the public sector. Thus, these “owners” of HID lighting systems represent 

the most influential figures in the public sector decision-making process. 

2.2 APPLICATIONS FOR HIGH-INTENSITY DISCHARGE LAMPS

The following sections discuss where and how the residential, commercial, industrial, and 

public sectors use HID lamps. 

2.2.1 Residential Applications

In comparison to other lamp technologies, such as incandescent and fluorescent, HID 

light sources occupy a very small niche in the residential sector. Of the lighting electricity 

consumed in this sector in 2001, 90 percent was consumed by incandescent sources, over 9 

percent was consumed by fluorescent sources, and less than 1 percent was consumed by HID 

sources.

3 Due to their electrical (long warm-up time, lack of quick re-strike) and photometric 

(produce too much light, poor color quality compared to incandescent lamps) characteristics, 

HID lamps are not well suited for most residential lighting applications. In this sector, HID 

lighting is used primarily in landscape and security-lighting applications.

For security applications, MV technology is popular because both the lamps and 

luminaires have low initial cost. The extremely long life of the MV lamp is an added bonus. 

These applications are typically areas in which lighting is needed for safety and visual 

assessment of the property to make the homeowner feel secure. The oldest of the three HID 

source types, MV was the first HID light source to enter the residential market. Many residential 

customers associate MV with residential security products, so the other HID sources have gained 

little penetration in the market. Initial price is also a major factor in the residential market 

decision-making process; the high initial costs of HPS and MH are another reason the MV 

dominates this application. 

In some rural areas, home and farm owners may lease a security light from an electric 

utility or a rural cooperative. This lease may carry a fixed tariff that does not measure actual 

electricity consumption. These luminaires have been primarily MV sources, but utilities now 

offer a wider array of sources, including HPS and MH. 

For landscape lighting, the capability of MV lamps to enhance the color of the foliage has 

created a niche application. The spectral power distribution (SPD) of MV light results in greater 

saturation of the shorter wavelength colors (from green to blue). Since most foliage is green, the 

light from the MV lamp gives it a richer appearance than the lumen output of the lamp would 

suggest, while creating greater contrast with its surrounding objects by muting the 

longer-wavelength colors (from red to yellow). MH lamps offer comparable performance while 

EE-DET-03-001 COMMENT 19
2-11

maintaining a much higher efficacy level; however, they have a higher initial cost and shorter 

operating life than MV lamps. MH landscape lighting has increased in recent years with the 

commercialization of numerous reflector (parabolic aluminized reflector [PAR], multi-faceted 

reflector [MR]) lamp types, offered in a variety of wattage and light output ratings.

2.2.2 Commercial Applications

Of the lighting electricity consumed in this sector in 2001, 32 percent was consumed by 

incandescent sources, 56 percent by fluorescent sources, and less than 12 percent by HID 

sources.3

 In spite of their potential for significant energy savings, HID lamps are not widely used 

in interior applications in the commercial sector for several reasons. The primary reason for HPS, 

MV, and non-ceramic MH is low color-rendering index (CRI). Other limiting factors include 

long warm-up and re-strike times, ballast noise, lamp size, and limited compatibility with 

lighting controls. 

Recent improvements in MH technology incorporating pulse-start systems and ceramic

arc tube variants made the MH lamp more attractive than incandescent and fluorescent sources in 

certain applications (e.g., retail and hospitality spaces). Despite these improvements, end-of-life 

color shift is a problem associated with MH technology. Reflectorized MH (PAR, T-shaped, 

“AR-type”) lamps are used in accent lighting applications (e.g., track lighting) often to meet 

energy codes. Most MH lamps are large in size, so these lamps are typically used in downlights 

or low-bay style luminaires lighting commercial spaces.

2.2.3 Industrial Applications

Of the lighting electricity consumed in this sector in 2008, 2 percent was consumed by 

incandescent sources, 67 percent by fluorescent sources, and less than 31 percent by HID 

sources.

3 HID lamps are popular in the industrial sector because the lamps offer a large “lumen 

package” (i.e., very high light output) with a relatively compact form factor. The maximum 

wattage for high-output fluorescent lamps is 200 W, where HID lamps in this application can be 

1000 W or greater, with light ouput exceeding 100,000 lumens. Therefore, multiple fluorescent 

lamps are needed in a luminaire to equal the flux of the high-wattage HID sources. Unlike linear 

fluorescent lamps, HID lamps are “point sources” (i.e., the actual light source is a comparatively 

small plasma arc within the lamp envelope). Point sources like HID lamps allow for luminaires 

with good optical control, which can more efficiently deliver light to the work area from greater 

mounting heights. HID sources are best operated on long operating cycles (e.g., over 12 hours 

per start), which are typical for industrial applications. MH sources are typically specified in 

industrial applications where “white light” with adequate color rendering (CRI greater than 50) is 

required. 

2.2.4 Other (Outdoor Public Sector) Applications

HID lamps dominate public-sector lighting installations. Public-sector installations 

account for roughly 8 percent of the total electricity consumed by all lighting in the United 

States, and HID sources represent 87 percent, incandescent 12 percent, and fluorescent only 

1 percent.3

 

EE-DET-03-001 COMMENT 19
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For street and roadway lighting, HPS represents the vast majority of this market, having 

replaced most MV installations. A small percentage of installations use MH, MV, or LPS 

(though LPS is not an HID source). Often, luminaires used in these applications are equipped 

with photosensors that turn the luminaires on at dusk and off at dawn. 

MH lamps are now replacing some HPS lamps that previously replaced MV lamps. 

Although MH sources are less efficacious than HPS, they offer superior color rendition and 

appear as a “white-light” source compared to HPS. In some area and street lighting applications, 

utilities turned down requests by municipalities for MH sources because maintenance costs were 

too high compared to those of HPS sources. The pulse-start metal halide (PMH) lamp addresses 

this problem, increasing lamp life as compared to the standard probe-start MH. However, the life 

for pulse-start MH is still shorter than typical HPS and MV lamps. Meanwhile, lamp 

manufacturers are addressing HPS color issues by trying to broaden the lamp SPD. The whitelight HPS products available today offer better CRI and CCT, but these improvements come at 

the cost of shorter lamp life and lower efficacy. MH and white-light HPS may be considered 

competitors in some applications, but lighting specifiers will typically specify MH for any 

application where color rendering or appearance are important.

2.3 CLASSIFICATION OF HIGH-INTENSITY DISCHARGE LUMINAIRES

Lamps are intended to be used inside fixtures, also referred to as luminaires. To describe 

how the lamps are to be used, the luminaires need to be classified. Luminaire classifications help 

describe, organize, and catalog the HID lamp market for easy identification by specifiers, 

manufacturers, and consumers. Virtually all lighting industry luminaire classifications focus on 

the distribution of the luminaire, which varies with lamp type and fixture design. For instance, a 

classification system developed by the Commission Internationale de l’Eclairage (CIE) classifies 

luminaires by the proportion of upward and downward light emission. This system most aptly 

applies to suspended luminaires where fluorescent dominates the market. A system developed by 

NEMA classifies luminaires by circular or oval distribution defined in terms of field angle. This 

system most aptly applies to floodlight luminaires where HID sources dominate the market. A 

third system developed by the Illuminating Engineering Society of North America (IESNA) 

classifies luminaires by distribution for desired patterns of illumination. This system is for 

area/roadway luminaires where HID sources dominate. 

Since the existing classifications systems focus on luminaire distribution, DOE developed 

a system that takes into account the application, construction, and photometrics of luminaires 

that most typically use HID sources (non-HID sources typical of this luminaire type will be 

addressed as needed). 

2.3.1 Proposed High-Intensity Discharge Luminaire Classification System

In the following sections, DOE categorizes luminaires by selecting their most appropriate 

and distinguishing feature, whether in terms of their source, mounting, construction, or 

application. The three primary groups are indoor (includes both industrial and commercial), 

outdoor, and specialty (can be indoor or outdoor) applications. For applications, DOE adapted 

the classifications and their descriptions from luminaire manufacturers’ literature, industry 

standard practice, and the IESNA Lighting Handbook.

9

 Although specialty-application 

luminaires do not account for a large portion of the general-service HID market, DOE presents 

EE-DET-03-001 COMMENT 19
2-13

these to complete the classification of HID light-source applications. This classification system 

constitutes the product applications that DOE used in this analysis. 

2.3.1.1 Product Applications: Indoor 

Table 2.3.1 summarizes the indoor application classifications, following which are 

detailed descriptions on each of these product applications. 

Table 2.3.1. Classification for Indoor Applications 

Classification Summary Description

Accent Luminaires providing directional lighting to emphasize a particular object or surface 

feature or to draw attention to a part of the field of view.

Down-Lighting Small direct-lighting units that direct the light downward. They may be recessed or 

surface-mounted.

Suspended Luminaires that are pendant-mounted via chain or cables or suspended from a post 

(stem). They may be direct, indirect, or direct/indirect combination luminaires.

High-Bay Luminaires providing general illumination, primarily in industrial applications, where 

the floor-to-ceiling height is greater than 25 feet.

Low-Bay Luminaires providing general illumination, primarily in industrial applications, where 

floor-to-ceiling height is equal to or less than 25 feet.

Source: IESNA, The IESNA Lighting Handbook: Reference and Application, 2000.

Accent Lighting – Luminaires that provide light from a preferred direction (directional 

lighting) to emphasize a particular object, feature, or to draw attention to a part of the field of 

view. A point-source technology (e.g., incandescent) is needed to create the directional lighting, 

and large-source technologies (e.g., fluorescent) that create diffuse lighting are the least effective 

for this application. The luminaires can be either recessed or surface-mounted. Track lighting, a 

non-fixed system with track heads (housing for the lamp and typically the ballast), is often used 

for accent lighting. Other non-track luminaires utilize some means of articulation for proper 

aiming. Although the small point source and high CRI of the new ceramic MH make it a 

competitive addition to this class, the light sources in this class are typically incandescent 

(e.g., halogen MR and PAR lamps). Ceramic MH sources are often used in applications where 

high CRI, significant illumination, small luminaires are needed, and are more often being 

installed to comply with stricter energy codes.

Down-Lighting – Luminaires that provide general lighting in residential and commercial 

spaces. These luminaires either have a reflector designed around a point source or house a 

directional light source (i.e., a PAR or MR lamp). HID down-lights have not penetrated the 

residential market. HID down-lights are commonly used in applications in which the luminaire 

will operate for long periods of time, and color appearance/rendering is not a high priority. 

Spaces with a mounting height over 9 feet are another potential application for down-lights with 

HID sources. Canopy lights—luminaires typically found under gas station canopies or used in 

parking garages—almost always are one of the three HID sources. Ceramic MH and pulse-start 

ballasts enabled the use of low to mid-wattage MH lamps in interior applications; however, 

incandescent and fluorescent sources still dominate interior down-light applications.

Suspended Lighting – Luminaires range from decorative pendants/chandeliers to 

pendants used in office lighting. These luminaires emit light directly, indirectly, or a 

combination. Ornamental or decorative chandeliers typically operate incandescent sources. A 

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small exception exists for large ornamental luminaires that typically have the option for 

incandescent, fluorescent, or MH sources. Less decorative and more functional luminaires 

typically use fluorescent or compact fluorescent lamp (CFL) sources. 

High-Bay Lighting – Luminaires in spaces with high ceilings (greater than 25 feet) that 

tend to be industrial applications. Typically, the luminaire spacing-to-mounting-height (S/MH) is 

less than or equal to 1.0 for these applications. Depending on the ceiling type and construction, 

these luminaires are either surface or pendant-mounted. HID sources previously dominated this 

market; in recent years, fluorescent and CFL high-bay luminaires (known as high-intensity 

fluorescent [HIF]) are becoming more common. Unlike HID, fluorescent technology allows for 

more control flexibility via easier dimming or switching groups of lamps. 

Low-Bay Lighting – Luminaires used for lighting spaces with ceiling heights less than 

25 feet. Applications include industrial, commercial, and retail spaces. The luminaire S/MH is 

typically greater than 1.0. These luminaires often appear similar to high-bay luminaires, but 

usually have different refractors and reflectors. HID sources represent a majority of the 

luminaires in this category, with fluorescent sources filling in the rest of the market. 

2.3.1.2 Product Applications: Outdoor 

Table 2.3.2 summarizes the classifications for outdoor applications. The IESNA defines 

seven types of classifications for outdoor luminaires: floodlight, sports light, area/roadway 

lighting, pathway, parking garage, security, and landscape. Detailed descriptions and further 

information on each of these product applications follow Table 2.3.2. 

Table 2.3.2. Classification for Outdoor Applications

Classification Summary Description

Floodlight Luminaires for building lighting and other special applications.

Sports Lighting Luminaires designed to light playing fields.

Area/Roadway Lighting Luminaires designed to produce reasonably uniform illuminance on streets and 

roadways.

Pathway Luminaires designed for lighting pedestrian pathways.

Parking Garage Luminaires designed to light parking garages and lots.

Security Outdoor luminaires typically used visually to assess an area.

Landscape Luminaires designed to light buildings, planting, water features, and walkways.

Source: IESNA, The IESNA Lighting Handbook: Reference and Application, 2000.

Floodlight – Enclosed lensed luminaire with permanent reflector. These luminaires often 

light the exterior facades of buildings or large parking lots from a pole. It is not uncommon for 

the light distribution to be a square or rectangular pattern for floodlightsHID luminaires 

completely dominate this market.

Sports Lighting – Luminaires with very narrow light distributions for lighting playing 

fields/surfaces from a great distance (often 100+ feet) either from the side or from above. This 

category is entirely comprised of HID sources. Incandescent sources could not be used to 

provide the amount of light needed from the distance at which these luminaires are often located. 

Fluorescent (linear or compact) sources cannot be used because reflector design makes it 

impractical. These luminaires have devices to prevent glare and stray light. This is a specialty

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category of outdoor luminaires with a small number of applicable light sources and only a 

handful of luminaire manufacturers making products. 

Area/Roadway Lighting – Luminaires designed for illuminating major driving surfaces 

(e.g., streets, roadways, parking lots). HPS and MH are the main sources for this application. A 

very small percentage of the luminaires installed across the country use LPS (not an HID source) 

lamps. These luminaires are classified by photometric distribution and by appearance/mounting 

method. The two classifications are neither exclusive nor concurrent. A luminaire might have a 

specific appearance and mounting and yet be capable of numerous photometric distributions. 

Luminaires in this category are typically mounted above 15 feet and up to about 50 feet. 

Luminaires mounted above 50 feet are known as high-mast and produce the same photometric 

distributions as luminaires mounted at a lower height. The most typical luminaire in this category 

is known as the cobra head. The luminaire resembles the head of a snake and, more often than 

not, the arm that supports the head curves over the roadway. This allows the pole to be located in 

a right of way or off the road, while positioning the luminaire directly over the surface being 

lighted. A majority of the cobra head installations across the country contain HPS sources. 

“Architectural” roadway luminaires incorporate aesthetic design features, materials and finishes 

not typically used in more common cobra head fixtures. 

Pathway – Luminaires designed to illuminate surfaces used by pedestrians. These 

luminaires are typically of two types: overhead or ground level. The overhead luminaires are 

often similar to street and roadway luminaires but on a pedestrian-level scale with shorter pole 

heights. Typically, the overall height of the luminaire and pole does not exceed 15 feet. 

Luminaires mounted closer to ground level use low-wattage (under 150 W) sources. The 

stereotypical pathway source is the bollard. This is a round or square luminaire between 30 and 

60 inches tall, made of concrete, aluminum, or steel. HID sources represent a large portion of the 

pathway luminaire market, but luminaires for CFL and incandescent sources are also used. 

Recently, luminaires with light emitting diodes (LEDs) have entered this market as well. 

Pathway luminaires are most prone to vandalism or accidental breakage from snowplows or 

other vehicles because the luminaire is located near the ground. 

Parking Garage – Luminaires are typically either surface-mounted or suspended near 

the ceiling. Gas station canopy luminaires often fall in this category. These produce light over a 

very wide area compared to the distance they are mounted above the surface. HID sources 

comprise a majority of the installations, followed by fluorescent sources. Recently, luminaires 

with LEDs have entered this market as well.

Security – Luminaires specifically installed to provide a sense of safety or to illuminate a 

field of view for safety/security reasons. Luminaires in this category include recessed step lights 

for lighting steps, wall-mounted luminaires at entrances to facility access into the building, and 

wall packs. Step lights are typically recessed luminaires mounted approximately 2 feet above a 

stair or walkway. Typical sources include CFL or incandescent sources; LEDs have entered this 

market as well. HID sources are sometimes used, but this luminaire typically needs both a lowwattage source and a small-size source. Wall packs are the most common security light. These 

luminaires are mounted on the exterior facades of buildings with the purpose of lighting the area 

for safety. HID sources are prevalent for wall packs. For most other security luminaires, one 

source does not dominate the market. 

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Landscape – Luminaires light foliage, parts of building facades, water features, exterior 

statues, etc. Unlike floodlights, landscape luminaires are used to illuminate discrete landscape 

and architectural features. Low-voltage halogen represents the bulk of this market. HID sources 

excluding HPS are also used. Of the HID sources, MH is most often used because its compact 

lamp types (T6, PAR, MR) allow good optical control. For specific types of foliage, MV is the 

ideal source because of the spectrum of light produced by the source. The largest drawback for 

HID sources in landscape lighting is lack of interchangeability. HID sources use wattage-specific 

ballasts, which precludes using lamps with different wattages and light output. If lighting 

requirements change over time (e.g., the lighted object grows larger), the original fixture and 

lamp type may no longer meet the application needs. 

2.3.1.3 Product Applications: Specialty 

HID luminaires in specialty applications often employ lamp shapes and bases that are not 

typically associated with general-service HID lamps discussed in the indoor and outdoor 

application groupings. Therefore, some lamps used in specialty applications would be exempt 

from standards. Although the impact from this product application would be very small, DOE

included them in this report for completeness. Table 2.3.3 presents the of specialty-product 

applications. 

Table 2.3.3. Classification for Specialty Applications 

Classification Summary Description

Theatrical

Luminaires

Luminaires designed with precise optical control and maximum flexibility. 

These are niche products used in the stage, studio, and other related fields.

Reprographics Lamps used in reprography, such as photography and photocopying.

2.4 REGULATORY AND NON-REGULATORY PROGRAMS 

As part of this analysis, DOE reviews all voluntary and compulsory programs that relate 

to HID technology. This review provides DOE with a greater understanding of the marketplace 

in which HID lamp, ballast, and luminaire manufacturers operate as well as what programs and 

trends may influence the future of the market. 

2.4.1 Regulatory Programs and Legislation Impacting High-Intensity Discharge Lamps

DOE reviewed Federal and State regulatory programs and legislation that impact HID 

technology, and applications where HID has a large market share. DOE acknowledges that not 

all programs and legislation affecting HID technology are discussed below but that its review 

addresses the major federal examples and, where possible, representative state programs are 

listed as well.

2.4.1.1 Federal Regulatory Programs and Legislation 

In 2005, the president signed into law the Energy Policy Act of 2005 (EPAct 2005), 

which amended and expanded parts of the EPAct of 1992. This regulation included the 

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requirement that ballasts for MV lampsb cannot be imported or manufactured effective 

January 1, 2008.10

Previously, the Energy Policy Act of 1992 (EPAct 1992) required states to adopt an 

energy code for buildings, which includes energy consumption guidelines for lighting. On July 

15, 2002, DOE issued a Determination that American Society of Heating, Refrigerating and Air 

Conditioning Engineers (ASHRAE) Standard 90.1-1999 was more stringent than 90.1-1989.

 

11

Both the current 90.1-2010 Standard as well as California’s Energy Efficiency Standards 

for Residential and Nonresidential Buildings, Title 24, Part 6 (Title 24) have stated minimum 

efficacy values for lighting exterior building grounds. All luminaires for exterior building 

grounds that operate at greater than 100 W must contain lamps having a minimum efficacy of 

60 lumens per watt (LPW), unless the luminaire is controlled by a motion sensor or qualifies for 

one of the exceptions. This minimum efficacy value affects HID sources and, in some cases, 

prevents them from being used in non-residential applications. 

As a result, each state must certify that it reviewed and updated the provisions of its commercial 

building code regarding energy efficiency to meet or exceed Standard 90.1-1999 by July 15, 

2004, for any “building” under the means of Section 303(2) of EPAct, as amended. EPAct 2005 

provides substantial property tax credits for commercial properties that exceed the allowed 

lighting power density (LPD) in ASHRAE Standard 90.1-2001 by at least 25 percent. Further, 

the EPAct 2005 required new federal buildings constructed to be designed 30 percent less than 

the current version of ASHRAE Standard 90.1 (90.1-2004 at time of enactment). 

In addition to the minimum efficacy values, energy codes regulate energy use via the 

power density (W per square or linear foot, depending on the application) of luminaire 

installations. Prescriptive design requirements allow for a variety of energy efficient sources to 

be used without banning or restricting technologies outright. As the power density values 

decrease, the demand for more efficient lighting increases. 

A number of states and the Federal government set requirements for MH ballasts of 

specific wattages. The Energy Independence Security Act of 2007 (EISA 2007) requires ballast 

efficiency (Pin/Pout) values for MH ballasts between 150 and 500 W of 88 percent for pulse-start, 

94 percent for probe-start, 90 percent for nonpulse-start electronic ballasts operating lamps 

between 150 and 250 W; and 92 percent for nonpulse-start electronic ballasts operating lamps 

between 250 and 500 W. EISA 2007 allows a one-time exception to California. 

In 1999, the U.S. Environmental Protection Agency (EPA) required recycling (based on 

volume of use) and proper disposal of lamps containing mercury. All HID lamps contain some 

amount of mercury. 

2.4.1.2 Draft Legislation

During 2009, different members of Congress drafted legislation focusing on energy 

efficiency, with aspects of this draft legislation affecting HID lamps and luminaires primarily 

using HID lamps. Rep. Jane Harman (D-CA36) introduced H.R. 1732: Outdoor Lighting 

Efficiency Act that was referred to Committee. The requirements in H.R. 1732 were later 

 

b Some ballasts for special applications are exempted from the ban of importation or manufacture.

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adopted in H.R. 2454: American Clean Energy and Security Act of 2009, sponsored by by Rep. 

Henry Waxman (D-CA30), and passed by the House on June 26, 2009. This bill H.R. 2454 had 

requirements for outdoor lighting: 

1. Each outdoor luminaire manufactured on or after January 1, 2016 shall: 

a. have an initial luminaire efficacy of at least 50 LPW; and

b. be designed to use a light source with a lumen maintenance, calculated as mean rated 

lumens divided by initial lumens, of at least 0.6. 

2. Each outdoor luminaire manufactured on or after January 1, 2018 shall: 

a. have an initial luminaire efficacy of at least 70 LPW; and

b. be designed to use a light source with a lumen maintenance, calculated as mean rated 

lumens divided by initial lumens, of at least 0.6. 

3. In addition to the requirements of paragraphs (1) through (3), each outdoor luminaire 

manufactured on or after January 1, 2016, shall have the capability of producing at least 

two different light levels, including 100 percent and 60 percent of full lamp output as 

tested with the maximum rated lamp power UL1598 or the manufacturers’ maximum 

specified for the luminaire under test. Outdoor luminaires used for roadway lighting 

applications shall be exempt the two light level requirement.

Other requirements in the bill focus on outdoor high light output lamps:c

On March 2, 2010, Senator Jeff Bingaman (D-NM) introduced the National Energy 

Efficiency Enhancement Act of 2010. The bill was cosponsored by Evan Bayh (D-IN), Thad 

Cochran (R-MS), Byron Dorgan (D-ND), Mary Landrieu (D-LA), Robert Menendez (D-NJ), 

Lisa Murkowski (R-AK), Debbie Ann Stabenow (D-MI). u The main focus of the bill was to 

improvThe draft legislation includes requirements for outdoor pole-mounted lighting and MV 

lamps - A general purpose mercury vapor lamp shall not be manufactured on or after January 1, 

2016.” 

 “Each outdoor 

high light output lamp manufactured on or after January 1, 2017 shall have a lighting efficiency 

of at least 45 lumens per watt.” 

DOE’s review of legislation affecting HID technology indicated three major approaches: 

regulating lamp efficacy, regulating lumen maintenance, and requiring multi-state operation of a 

light source. 

The proposed outdoor lighting bill bans MV lamps outright because they are the most 

inefficient HID source. H.R. 2454 sets the bar for a class of lamps at 45 LPW, effectively 

eliminating most MV sources. The outdoor lighting bill set minimum luminaire efficacy values, 

calculated as the amount of light leaving the luminaire (measured in lumens) divided by the input 

power (watts) supplied to the luminaire. For HID lighting, fixture efficacy can be calculated by 

 

c This is not an industry term. The bill defines the term as “a lamp that (a) has a rated lumen output not less than 

2601 lumens; (b) is capable of being operated at a voltage of not less than 110 volts and not greater than 300 volts, 

or driven at a constant current of 6.6 amperes; (c) is not a Parabolic Aluminized Reflector Lamp; and (d) is not a Jtype double-ended (T-3) halogen quartz lamp, utilizing R-7S bases that is manufactured before January 1, 2015.

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multiplying the fixture efficiency by the lamp/ballast efficacy.d Chapter 3 will include more 

information about lamp/ballast efficacy. However, typical parking lot and area luminaires (polemounted luminaires that comprise much of exterior lighting) typically have downward fixture 

efficienciese between 54.8 to 88.7 percent with an average of 75.3 percent.12

2.4.1.3 DOE Background Studies

The minimum 

lamp/ballast efficiacy can be calculated by dividing the required 50 LPW fixture efficacy by the 

typical luminaire efficiency of 75 percent. If the outdoor lighting bill is enacted and the fixture 

efficiency stays the average, then the lamp/ballast efficacy would have to be 66.6 LPW to meet 

the required 50 LPW fixture efficacy. Again under that legislation when the minimum fixture 

efficacy increased to 70 LPW, the minimum lamp/ballast efficacy would 93.3 LPW assuming 

that the fixture efficiency stayed constant.

In 2004, DOE published High-Intensity Discharge Lamps Analysis of Potential Energy 

Savings (Docket EE-DET-03-001). The scope of the document was HID lamps but focused on an 

in-depth analysis of MV lamps. While developing and after publishing the document, DOE 

received comments on the draft document as follows:

• In 2003, a representative of California Department of Transportation (Caltrans) stated, 

“The affect on Caltrans if mercury vapor ceased to be an option would be minimal. At 

this time, we are installing no new MV street lighting fixtures, and have replaced most of 

those that were installed 30 to 40 years ago with HPS.”13

• In 2003, the American Council for an Energy-Efficient Economy (ACEEE) stated, 

“ACEEE agrees that it makes sense to establish a minimum efficacy standard that 

eliminates mercury vapor lamps for many, if not all, applications...It should be noted that 

some states are adopting even more stringent codes resulting in rapid adoption of pulsestart metal halide in new installations ...ACEEE believes that the Department should 

explore the potential for setting minimum efficacy requirements for HID that would 

effectively eliminate probe-start metal halide lamps greater than 150 W-the best high 

wattage probe-start lamps (i.e., 1000 W lamps) can match pulse-start efficacys and would 

not be affected. Pulse-start metal halide lamps offer immediate energy savings relative to 

probe-start lamps and offer the potential for even greater savings as electronic ballasts 

become more widely available. The technical, life cycle cost, and energy savings 

analyses should include the substitution of pulse-start metal halide for both mercury 

vapor and probe-start metal halide lamps to determine the cost and savings associated 

with a higher efficacy requirement.”14

• In 2004, independent lighting designer Jim Benya of Benya Lighting Design stated: “In 

my opinion, banning mercury vapor technology is warranted.”15

 

d Fixture efficiency is the percentage of light emitted by the luminaire (fixture) divided by the amount of light 

generated by the lamp.

e Downward efficiency is the percentage of light emitted by the luminaire between 0 and 90 °. It is typically reported 

for area, parking, and roadway luminaires. Although additional light may be emitted above 90 °, it provides no value 

to lighting the intended surfaces.

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• In 2005, NEMA stated that it would “oppose any DOE rulemaking that imposed a 

lumens-per-watt standard on HID lamps such that a formal, regular reporting of 

measurements of metal halide and high pressure sodium lamp efficacies would be 

required to prove that no lamps with MV-type efficacies are being placed on the market. 

Such reporting would represent a gross administrative overkill to achieve the 

objective.”16

• In 2005, ACEEE stated that it is “disappointed that DOE is not addressing other savings 

opportunities from HID lamps, specifically the savings available from replacing probestart metal halide lamps with pulse-start metal halide technology. However, at this time 

several states are developing standards on these metal halide products, so we recommend 

that DOE let states take the lead on these products rather than doing further work in ths 

area at the present time.”17

In summary, DOE received no comments advocating for MV lamps and comments to set 

pulse-start MH as the efficacy standard. 

2.4.1.4 State Regulatory Programs 

Effective January 1, 2008, MH luminaires with lamps in all operating positions ranging 

from 150 to 500 W cannot contain a probe-start ballast in Arizona, Oregon, or Washington. New 

York and Rhode Island have similar laws effective January 1, 2008. In New York and Rhode 

Island, only luminaires with lamps operating in a vertical position (± 15 degrees of vertical) shall 

not contain probe-start ballasts.

18

Under Title 20, California has an appliance efficiency program and requirements in place 

regarding metal halide luminaires (fixtures) since 2006 (

 

Table 2.4.1).

Table 2.4.1. California Metal Halide Fixture Requirements

General Title 20 Enactments

Milestone Date Description

1/1/06 Luminaires with lamps oriented vertically with the base up at rated wattages 150–500 W 

shall not contain a probe-start MH ballast. 

1/1/08 Luminaires with lamps oriented vertically with the base down at rated wattages 150–500 W 

shall not contain a probe-start MH ballast.

Luminaires rated wattages 150–500 W shall not contain a probe-start MH ballast.

Luminaires rated wattages 150–500 W shall not contain a metal halide ballast with a 

minimum ballast efficiency of 88 percent. Exceptions include:

• Luminaires with electronic ballasts that operate at 480 V. 

• Luminaires rated at 150 W, rated for use in wet locations per NEC and contain a ballast 

rated to operate at ambient air temperature above 50 °F.

1/1/10 Metal halide luminaires rated partially within the range of 150 to 5000 W shall not have 

probe-start ballasts and comply with Section 1605.3(n)(2)(A) as applicable.

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Table 2.4.2. California (continued)

1605.3(n)(2)(A) • Indoor metal halide luminaires manufactured on or after January 1, 2010 shall comply 

with at least one option of Section 1605.3(n)(2)(B). 

• Indoor metal halide luminaires manufactured on or after January 1, 2015 shall comply 

with Section 1605.3(n)(2)(B)4 and shall also comply with at least one other option of 

Section 1605.3(n)(2)(B).

• Outdoor metal halide luminaire manufactured on or after January 1, 2010 may comply 

with Section 1605.3(n)(2)(B)3 and shall comply with at least on other option of Section 

1605.3(n)(2)(B).

1605.3(n)(2)(B) • A minimum ballast efficiency of 90 percent for 150–250 W lamps or 92 percent for 251–

500 W lamps.

• A minimum ballast efficiency of 88 percent and occupant sensors that are integral control 

as defined in Section 1602(n) of this Article, shipped with the factory default setting to 

reduce lamp power automatically through dimming by a minimum of 40 percent within 30 

minutes or less after an area has been vacated.

• A minimum ballast efficiency of 88 percent and automatic daylight integral control as 

defined in Section 1602(n) of this Article, shipped with the factory default setting to 

reduce lamp power automatically through dimming by a minimum of 40 percent.

• A minimum ballast efficiency of 88 percent and a relamping rated wattage within only one 

of the four wattage bins specified. The luminaire shall be able to operate lamps within 

only one of the four wattage bins and shall not be rated for any lamp wattage outside of 

that wattage bin. The luminaire shall have a permanent, pre-printed factory-installed label 

that states the relamping rated wattage: 150–160, 200–215, 290–335, or 336–500. When 

operating 336–500 W lamps, the luminaire shall be prepackaged and sold together with at 

least one lamp per socket having a minimum lamp efficacy of 80 lumens per watt, based 

on published mean lumens and rated lamp power (watts).

Exceptions to 

1605.3(n)(2)

The following metal halide lighting systems shall not have probe-start ballasts and are not 

required to meet the minimum ballast efficiency requirements:

• Luminaires that use regulated lag ballasts;

• Luminaires that use electronic ballasts which operate 480 V; or

• Luminaires that meet all three of the following requirements:

− Rated for use only with 150 W lamps, and

− Rated for use in wet locations per NEC, and

− Contain a ballast rated to operate at ambient air temperature above 50 °F.

The effect of California’s Title 20 brings the state appliance requirements in line with the 

Federal requirements. The rules effective in 2010 push consumers towards electronic ballasts. 

The efficiencies in 1605.3(n)(2)(B) are the ballast efficiencies in EISA 2007 for nonpulse-start 

electronic ballasts. Dimming requirements (reduce power to 40 percent) per 1605.3(n)(2)(B) and 

can really only be achieved via electronic ballasts. It is possible with magnetic ballasts, but 

inefficient, more expensive, and harder to compete with electronic ballasts. Finally, California’s 

requirements of 80 mean LPW push consumers to better lamps. Better lamp lumen maintenance 

can be achieved with electronic ballasts than with magnetic ballasts, but also needs a better lamp 

to actually achieve the required system efficacy. Another example of an efficacy requirement 

indirectly affecting HID sources is the Minnesota Statute 216C.19 that states, “[n]o new 

highway, street or parking lot lighting may be installed in violation of these rules. Existing 

lighting equipment, excluding roadway sign lighting, with lamps with initial efficiencies less 

than 70 lumens per watt must be replaced when worn out with light sources using lamps with 

initial efficiencies of at least 70 lumens per watt.” Although the statute is technology neutral, it 

effectively excludes incandescent halogen lamps and virtually all CFL sources. This statute 

focuses on roadway lighting and affects applicable HID sources. MV lamps could not be 

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installed in any application under this statute.

Several states and a number of municipalities passed “dark-sky” ordinances aimed at 

reducing light pollution. While most focus on eliminating light pollution by addressing luminaire 

type and shielding, some ordinances (e.g., Arizona) specifically address the light source. Often, 

these municipalities are trying to ban a certain portion of the visible light spectrum.

Astronomical observatories and coastal areas can be negatively impacted by certain spectral 

content that affects nighttime sky observation and animal habitats.19

• Arizona’s statute states, “No new mercury vapor outdoor light fixtures shall be installed 

after the effective date of this section. No replacement equipment other than bulbs for 

mercury vapor lighting fixtures shall be sold in the state after January 1, 1991 and the use 

of mercury vapor light fixtures is prohibited after January 1, 2011.”

 However, regulatory 

authority is not consistent; some ordinances cover only the lighting owned by the regulatory 

entity (e.g., state or municipal), while others cover privately owned lighting as well. Examples of 

source-specific state requirements are as follows:

20

• The City of San José, California limits restricts source type because of the local

observatory. “The use of low-pressure (LPS) sodium lighting for outdoor, unroofed areas 

shall be required for all private development in the City of San José as a condition of 

approval on all Land Use Development Permits.”

 

21

In addition to dark-sky ordinances, numerous state departments of transportation have 

specifications that focus on HID technology. In addition to their specifications, these 

departments and other municipalities have prequalified lighting-procurement programs that 

specifically govern HID sources. For example, the Kansas Department of Transportation has a 

list of prequalified lighting systems that specifically list MH and HPS technology.

22

The Model-Lighting Ordinance (MLO) is a joint effort by IESNA and the International 

Dark-Sky Association (IDA) to provide a sample code that municipalities can adopt. The MLO 

pertains to outdoor lighting only. In contrast to the major energy codes, the MLO recommends 

restricting light output in terms of initial lumens for environmental zones. Where ASHRAE 

Standard 90.1 and California Title 24 Standard regulate installed power density for the different 

environmental zones, the MLO gives a total lumen value for the zones. At the time of this 

publication, the MLO had not been completed by the IESNA/IDA Joint Task Force. Therefore, 

no actual values were provided. 

 Although 

this is not an outright regulatory program, it is an example of municipal action that directly 

affects HID technology. 

California Title 24 requires spaces with two or more luminaires lighting building facades, 

parking lots, garages, non-sales canopies, and all outdoor sales areas to reduce the lighting power 

by 50 percent when the lighting is not needed. Compliance with this code can be achieved via 

continuous dimming and “hi-lo” ballasts (stepped dimming ballasts) as well as switching every 

other luminaire. 

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After an incident in a school in Oregon where teachers were injured by burns to their eyes 

(via excessive ultraviolet radiation exposure) by a damaged MH lamp, the State of Oregon 

mandated that all schools replace MH and MV lamps with self-extinguishing versions.23

2.4.2 Non-Regulatory Programs Affecting High-Intensity Discharge Lamps

DOE’s review of non-regulatory programs promoting higher-efficiency HID sources 

found that there are four general types of programs that are either prescriptive or performancebased. A prescriptive program would provide an incentive for using an efficient technology (with 

the assumption that with the equipment installed, energy will be saved). A performance-based 

program would provide an incentive for saving energy with little restrictions on how those 

savings were achieved. 

The first type of program promotes energy efficiency through sponsored retrofits, either 

on a prescriptive (technology) basis or on a minimum efficacy (LPW threshold) basis. The 

second type of program encourages using the most efficient technology in new installations. The 

third type of program encourages higher-efficiency technology, with the objective of reducing 

peak-load demand. This type of program is more applicable to indoor HID luminaires, rather 

than outdoor lighting that typically operates during off-peak hours. Incentives in this category are 

based on kilowatts saved during peak periods without dictating the technology used to reduce the 

load. The fourth and final type of program focuses on reducing energy (kilowatt hours) through 

more efficient technology. Again, this does not prescribe specific technologies, but instead 

rewards energy savings. 

In Appendix A, DOE provides a summary of non-regulatory programs in the United 

States that focus on lighting and HID technology. Each program is described briefly, identifying 

the target technology, the incentives offered, and a website for more information. Although the 

list is not exhaustive, 23 states offer some type of program that specifically focuses on HID 

technology. Incentives exist for either installing new HID sources or replacing HID sources with 

non-HID sources. In general, the incentives treat MV and MH as the “old inefficient” sources to 

be replaced. The three most common incentives are: 

1. PMH – These incentives are for PMH fixtures or lamps/ballasts replacing incandescent, 

MV, MH, and HPS technology. The incentives can include either quartz or ceramic PMH 

lamps. The incentives range from $18 to $100. The most common PMH incentive is the 

320W replacement for a 360W or 400W MH system. PMH being more efficacious and 

having better lumen maintenance than MH lamps means that, over the operating life, the 

lower wattage PMH system is equal or better than the standard higher wattage MH 

systems.

2. High-intensity fluorescent (HIF) – These incentives are for multi-lamp T5 or T8 

fluorescent low/high bay luminaires. Incentives range from $50 to $125 for replacing 

HID fixtures. The rationale for these incentives is that fluorescent lamps can be dimmed 

more easily than HID lamps. Multi-lamp fixtures can also be switched off in different 

pairings. These control features save energy. The high lumen maintenance (above 0.90) 

for fluorescent lamps, the high efficacy (above 90 LPW), and the long rated life when 

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operated for long periods (over 30,000 hours) makes HIF a good option compared to 

traditional HID fixtures.

3. Integrally-ballasted CMH lamp – This is a PAR lamp with an integral electronic ballast. 

Other incentives exist for CMH lamps but those are similar to other PMH incentives. 

Incentives range from $12 to $25 for this type of lamp, which directly replaces halogen 

PAR 38 lamps. This type of CMH lamp yields at least a 50 percent energy savings 

compared to the halogen lamps. The CMH lamps typically have a rated life of 12,000 

hours which is double the best rated life for halogen lamps. 

Programs or incentives for demand or energy reduction were not listed in Appendix A 

unless the program specifically mentioned HID technology. Other programs that addressed HID 

technology, but did not provide data (required user to contact agency), were also not listed in 

Appendix A.

EE-DET-03-001 COMMENT 19
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CHAPTER 3. TECHNOLOGY ASSESSMENT

High-intensity discharge (HID) lamps produce light by generating an electrical discharge 

between tungsten electrodes contained within an arc tube. By definition, HID lamps include 

mercury vapor (MV), metal halide (MH), and high-pressure sodium (HPS) lamps. HID lamps 

range from 20 to 2000 watts (W). The lamps are often subdivided by power into low (less than 

150), medium (from 150 to 500), and high (greater than 500) wattages. Because the electrical 

discharge exhibits a negative resistance, ballasts regulate this electrical discharge and prevent it 

from drawing excessive current that would lead to premature lamp failure. Therefore, HID lamps 

always operate with a ballast, which is typically external to the lamp and located within the 

luminaire. There are limited exceptions to this configuration, specifically self-ballasted (integral 

ballast) MV lamps and the MH parabolic aluminized reflector (PAR) lamps.

The following discussion examines and summarizes current specifications, standards, and 

guidelines governing the classification, testing, and evaluation of HID lamps. Because this 

analysis considers lamps only, issues concerning the effects of ballasts on HID lamp 

performance are outside the scope of this analysis. However, the availability, capability, and 

functional relationship of ballasts and lamps are important for understanding the technology and 

its market. Therefore, as appropriate, ballasts and their characteristics are addressed in this 

section.

3.1 SPECIFICATIONS, TEST STANDARDS, AND PROCEDURES

The U.S. Department of Energy (DOE) reviewed available evaluations of the electrical 

and photometric properties of HID lamps and ballasts. Table 3.1.1 presents a list of industry 

standards publications pertaining to HID lighting systems.

Table 3.1.1 Documents Pertaining to High-Intensity Discharge Lamps

Source # Year Title

ANSI* C78.1381 1998 American National Standard for Electric Lamps—70 W, M85 Double-Ended MH 

Lamps

C78.380 2007 American National Standard for Electric Lamps-High-Intensity Discharge Lamps, 

Method of Designation

C78.380a 2004 American National Standard for Electric Lamps-HID Lamps, Method of 

Designation (Amendment)

C78.389 2004

R2009

American National Standard for Electric Lamps – High Intensity Discharge —

Methods of Measuring Characteristics

C78.40 1992

R2003

Specifications for Mercury Lamps

C78.40a 1998 American National Standard for Specification for Mercury Lamps-Maximum 

Outline Drawing of Bulb BT56

C78.42 2007 American National Standard for Electric Lamps-HPS Lamps

C78.43 2007 American National Standards for Electric Lamps-Single-Ended MH Lamps

C78.44 2008 American National Standards for Electric Lamps-Double-Ended MH Lamps

C78.45 2007 American National Standard for Electric Lamps-Self-Ballasted Mercury Lamps

C78.62035 2004 American National Standard for Electric Lamps-Discharge Lamps (Excluding 

Fluorescent Lamps)-Safety Specifications

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Table 3.1.2 Documents (continued)

C78.LL 3 2003 Procedures for HID Lamp Sample Preparation and the Toxicity Characteristics 

Leaching Procedure (TCLP)

ANSI*

(contd.)

C81.62 2007 American National Standard for Electric Lampholders

C82.4 2002 American National Standard for Ballasts for HID and Low-Pressure Sodium (LPS) 

Lamps (Multiple-Supply Type)

C82.6 2005 American National Standard for Lamp Ballasts – Ballasts for HID Lamps-Methods 

of Measurement

C82.9 1996 American National Standard for HID and Low-Pressure Sodium (LPS) Lamps, 

Ballasts and Transformers—Definitions

C82.14 2006 American National Standard for Lamp Ballasts-Low-Frequency Square Wave 

Electronic Ballasts-for MH Lamps

LE 5B 1998 Procedure for Determining Luminaire Efficacy Ratings for HID Industrial 

Luminaires

LSD 14 2002 Guidelines on the Application of Dimming to HID Lamps

LSD 24 2003 Marking of Luminaire Codes on MH Lamps

LSD 25 2008 Best Practices for MH Lighting Systems, Plus Questions and Answers about Lamp 

Ruptures in MH Lighting Systems

LSD 31 2005 A Lighting Systems Division Information Bulletin: Changes to the 2005 NEC Will 

Impact Future MH Lamp Systems Options

LSD 35 2006 ANSI Code Update to Include Letter “C” for Ceramic MH Lamps

LSD 37 2008 Effects of EPAct 2005 on MV Lamp Ballasts and Lighting Systems: Frequently 

Asked Questions

LM-31-95 1995 Photometric Testing of Roadway Luminaires Using Incandescent Filament and 

High Intensity Discharge Lamps

IESNA† LM-35-02 2002 Photometric Testing of Floodlights Using HID or Incandescent Filament Lamps

LM-46-04 2004 IESNA Approved Method for Photometric Testing of Indoor Luminaires Using 

HID or Incandescent Filament Lamps

LM-47-01 2001 IESNA Approved Method for Life-Testing of HID Lamps

LM-51-00 2000 IESNA Approved Method for the Electrical and Photometric Measurements of 

High Intensity Discharge Lamps

LM-61-06 2006 IESNA Approved Guide for Identifying Operating Factors Influencing Measured 

Vs. Predicted Performance for Installed Outdoor HID Luminaires

LM-73-04 2004 IESNA Guide for Photometric Testing of Entertainment Lighting Luminaires 

Using Incandescent Filament Lamps or High Intensity Discharge Lamps

* ANSI = American National Standards Institute

† IESNA=Illuminating Engineering Society of North America.

Sources: National Electrical Manufacturers Association (NEMA) website, 2010; IESNA website, 2009.

As the Secretariat for ANSI, NEMA publishes standards for lamps (C78); bulbs (C79); 

lamp bases and holders (C81); ballasts (C82); for performing standardized tests to evaluate the 

energy efficiency of luminaires (LE); general information documents (LSD) as part of its 

lighting-standards program.24 Table 3.1.1 presents the ANSI standards specifically related to 

HID technology, excluding the more generally-applicable standards for bulbs (C79) and lamp 

bases and holders (C81). 

ANSI also publishes a system of nomenclature for the designation of HID lamps in its 

C78 technical-support documents. The designation code, at a minimum, includes the class and 

electrical characteristics of the lamp. In addition, ANSI publishes a set of corresponding 

performance and physical characteristics specifications. The designations and specifications not 

EE-DET-03-001 COMMENT 19
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only provide a system of identification, but also ensure a level of product commonality and 

interchangeability among manufacturers of HID lamps and ballasts. 

IESNA is another organization promulgating standards for HID lamps and related 

technologies, including Lighting Measurement (LM) test procedure documents. IESNA LM-35-

02, 46-04, and 73-04 focus on testing luminaires using HID technology (as well as other light 

sources). IESNA LM-41-01 and LM-51-00 focus on life and electrical/photometric 

measurements of HID lamps, respectively. These publications build on ANSI standards to 

include procedures for both electrical and photometric measurements by defining testing 

conditions, lamp stabilization, and other critical aspects to ensure consistency in the testing of 

lamp performance. Publications by IESNA reflect the consensus of industry stakeholders, 

including NEMA members. 

3.2 LAMP METRICS

Lamp characteristics and performance are evaluated on a number of factors, in addition to 

lumen output. The following discussion is a review of different metrics applicable to HID lamps. 

3.2.1 Lumens

The lumen is the basic unit of light. The IESNA defines luminous flux as the time rate of 

flow of radiant energy, evaluated in terms of a standardized visual response: 

Φ = 683 × Eq. 3-1

Where:

Φ = luminous flux (in lumens, lm).

The value of 683 LPW is a constant for the photopic luminous efficacy function. The 

equation essentially is the integral of the light source’s spectral content expressed as spectral 

power distribution (SPD) over the visible range of the electromagnetic spectrum weighted by the 

photopic luminous efficacy function. In practical terms, this equation expresses integrating the 

energy emitted by the light source across the visible light portion of the spectrum (380 to 780 

nanometers (nm)) and multiplying by the visual efficacy function (a function weighting the 

different portions of the visible light spectrum by the different photoreceptors in the eye) times 

the constant 683 lumens per watt. The units cancel out to just lumens. 

3.2.2 Mean Lumens/Lamp Lumen Depreciation/Lumen Maintenance

Lamp lumen depreciation (LLD) is also known as lumen maintenance. In use, a lamp 

loses light output over time. According to the IESNA, the LLD factor is “the fraction of the 

initial lumens produced at a specific time during the life of the lamp.”25 The LLD value is used 

in lighting calculations to account for the reduction in output over the operating life of the lamp. 

Often the mean (also known as design) lumens are used for LLD. Mean lumens are published in 

EE-DET-03-001 COMMENT 19
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the manufacturers’ catalogs and are measured at a certain point in time, typically a specific 

percentage of the lamp’s rated lifetime. 

The IESNA does not define when to measure mean lumens; however, 70 percent of 

average rated life is the recommended criterion for lamp replacement for both group and spot 

relamping programs. This value is usually not used in design calculations because it is difficult to 

determine from manufacturers’ data. Often, designers must build margins into their calculations 

and use the mean/design lumen value presented in the catalogs.

The basis for mean lumens can vary between manufacturers, as shown in DOE’s survey 

of definitions from manufacturer catalogs:

GE: “Mean Lumens – lamp light output at 40% of rated lamp life for (MH) lamps and 

50% of rated life for mercury and HPS lamps.”26

OSRAM SYLVANIA: “Mean lumens are measured on ANSI reference circuits at rated 

wattage (HQI, LUMALUX Super and SOx lamp ratings are based on input voltage) at 

40% of average rated life except for those lamps with a “+” next to their life rating; these 

lamps are measured at 50% of average rated life. All measurements are based on ballast 

operation on systems with current crest factors of 1.8 or less. Higher current crest factors 

reduce values. In actual applications on constant wattage (CW) or constant-wattage 

autotransformer (CWA) ballasts, mean lumens may be higher than published ratings.”27

Philips: “Approximate lumen output at 40% of lamp rated average life.”28 

Ushio: “Lumens, Mean: Average quantity of light output over the life of the lamp. High 

Pressure Sodium and incandescent lamps are measured for mean lumens at 50% of lamp 

life. Fluorescent and MH lamps are measured for mean lumens at 40% of rated lamp 

life.”29

 

Venture: A manufacturer of only MH lamps states, “Mean Lumens: Light output at 40% 

of rated life.”30

Chapter 2, Market Assessment, discussed both draft legislation focusing on outdoor lighting and 

requirements in California already in effect that have requirements related to mean lumens. The 

absence of an agreed definition for mean lumens complicates any discussion of standards 

compliance or recommended relamping cycles, and hinders comparing similar products from 

different manufacturers. 

3.2.3 Efficacy

Efficacy (luminous efficacy) is defined by the IESNA as quotient of the total emitted 

luminous flux and the total lamp power. Expressed mathematically: 

η = luminous flux (lm) / lamp power (W) Eq. 3-2

Where:

EE-DET-03-001 COMMENT 19
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η = luminous efficacy (in lumens per watt, lm/W or LPW). 

A 2001 paper, “An Efficacy Analysis of HID Lamps” examined the components of 

efficacy of HID lamps.31

η = ηvis × ηmax spectral × ηspectral × 683 LPW Eq. 3-3 

 The paper was not entirely based on new research but long-standing 

lighting science. The paper focused on aspects of efficacy irrespective of chromaticity and color 

rendering. The paper only examined lamp efficacy and excluded lighting system (i.e., ballasts 

and fixtures). The paper converted the mathematical efficacy function into the three components, 

rewritten as: 

Where:

ηvis = visual efficiency,

ηmax spectral = maximum spectral efficiency,

ηspectral = spectral efficiency, and

LPW = lumens per watt.

The value of 683 LPW is both a constant and the absolute photopic luminous efficacy 

value. Therefore, as the different η values approach 1.0, the closer the efficacy is to 683 LPW.

3.2.3.1 Visual Efficiency

The visual efficiency of a lamp is the quotient of the power radiated in the visible 

spectrum (380 to 780 nm) and the total lamp power. Table 3.2.1 is from the 2001 Nelson et al. 

paper.

Table 3.2.1. Visual Efficiencies and Efficacies of Various Sources

Lamp Type Pla

W 

ηvis η

LPW

High-Pressure Sodium 150 0.22 90

400 0.31 124

1000 0.33 135

White High-Pressure Sodium 100 0.20 51

Mercury Vapor 400 0.15 55

Quartz Metal Halide–NaSc Pulse Start 400 0.35 110

Quartz Metal Halide–NaTl In 400 0.24 80

Ceramic Metal Halide–3000K 100 0.35 98

Ceramic Metal Halide–4000K 100 0.38 95

The data in the table reflect visual efficiencies ranging from 0.15 to 0.38. Newly 

developed (post-1990) HID lamps (pulse start ceramic and quartz MH) have visual efficiencies 

above 0.35. As lamp power increases so does visual efficiency as shown in the HPS data (150 

W/0.22, 400/0.31, 1,000 W/0.33) data. Although related, changes in visual efficiency do not 

directly correlate to changes in efficacy. The white HPS lamp has a slightly lower efficacy than 

the mercury vapor and yet more visual efficiency, whose values are virtually the same for the 

150 W HPS (0.22) and the white HPS (0.20). The efficacy of the 150 W lamp is almost twice 

that of the 100 W white HPS lamp. 

EE-DET-03-001 COMMENT 19
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Table 3.2.2 is excerpted from the IESNA Lighting Handbook table 7-49.2 Each of the HID 

lamps produce more IR than light. This distribution of energy directly affects the visual 

efficiency value of the lamp. If the HID lamps produced more energy in the visual light region of 

the electromagnetic spectrum, the visual efficiency values would be greater.

Table 3.2.2. Sample Energy Output for High Intensity Discharge Lamps

Type of Energy 400 W

%

MV MH HPS

Light 14.6 20.6 25.5

Infrared 46.6 31.9 37.2

Ultraviolet 1.9 2.7 0.2

Conduction-Convection 27.0 31.1 22.2

Ballast 10.1 13.7 14.9

Maximum Spectral Efficiency. The 2001 paper defined the maximum spectral efficiency 

a factor expressing the effect of the eye sensitivity curve for a given chromaticity. A given 

lamp’s location in color space factors into efficacy and that is the role of the maximum spectral 

efficiency. 

The 2001 paper provided the chromaticities maximum spectral efficiencies for the lamps 

that it provided the visual efficiency data for, which shown in Table 3.2.3. The paper found (and 

supported by the data republished) that the maximum spectral efficiency varied from 0.70 to 0.76 

for HID lamps. 

Table 3.2.3. Chromaticities and Maximum Spectral Efficiencies of Various Sources

Lamp Type Pla

W

x y CCT MPCD ηmax spectral

High-Pressure Sodium 150 0.521 0.423 2100 11 0.75

400 0.521 0.413 2040 -1 0.72

1000 0.522 0.413 2040 -1 0.72

White High-Pressure Sodium 100 0.461 0.405 2640 -7 0.75

Mercury Vapor 400 0.331 0.395 5680 58 0.73

Quartz Metal Halide–NaSc Pulse Start 0.374 0.394 4280 26 0.75

Quartz Metal Halide–NaTl In 400 0.390 0.398 3890 20 0.76

Ceramic Metal Halide–3000K 400 0.368 0.368 4300 0 0.71

Ceramic Metal Halide–4000K 100 0.433 0.388 2950 -19 0.73

High-Pressure Sodium 100 0.372 0.366 4150 -7 0.70

Spectral Efficiency. The spectral efficiency is a measure of how well a given spectrum is 

distributed relative to the optimally efficient two line spectrum for that chromaticity. There is a 

negative correlation with spectral efficiency. As spectral efficiency increases, color rendering 

index (CRI) decreases. This is demonstrated in the high spectral values for HPS and MV (0.82 

and 0.77 respectively) and the very low CRI values of 11 (HPS) and 17 (MV). In contrast, the 

high CRI values of 93 and 89 from the HPS had lower spectral efficiency values (0.53 and 0.56, 

respectively; Table 3.2.4).

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Table 3.2.4. Color Rendering Indexes and Spectral Efficiencies of High-Intensity Discharge 

Sources 

Lamp Type Pla

W 

CRI ηmax spectral

High-Pressure Sodium 150 11 0.82

400 21 0.80

1000 17 0.82

White High-Pressure Sodium 100 84 0.50

Mercury Vapor 400 17 0.77

Quartz Metal Halide–NaSc Pulse Start 36 0.70

Quartz Metal Halide–NaTl In 400 65 0.62

Ceramic Metal Halide–3000K 400 62 0.67

Ceramic Metal Halide–4000K 100 89 0.56

High-Pressure Sodium 100 93 0.53

Nelson et al. found in the 2001 paper that this negative relationship did exist and derived 

a function expressing the relationship of CRI and spectral efficiency for HID and LPS lamps. 

The function was a straight line with an R2 value of 0.95 and is: ηspectral = 0.8461 – (0.0034 × 

CRI).8

Potential Efficacy Limits. Nelson et al. hypothesized the possible efficacy limits for 

conventional HID lamps on the blackbody locus, based on their assumptions in the 2001 paper.8

The authors assumed a visual efficiency value of 0.40. Based on the lamps they surveyed, a value 

0.38 was the highest for HID lamps. In the discussion section of their paper, this value was 

questioned. The authors defended their choice in that it represented a likely value for long life 

lamps with electrodes and were commercially available. The maximum spectral efficiency values 

were provided for the different chromaticities. Finally, a CRI of 80 was assumed and using the 

function provided the spectral efficiency values were derived. A CRI of 80 was chosen by the 

authors because end users will be more concerned with color quality in the future. A CRI of 80 

seems reasonable when reviewing other DOE lamp rules. Table 3.2.5 is a review of the probable 

efficacy limits for HID lamps that lie on the blackbody locus (BBL) and have a CRI of 80. In 

review, the efficacy ranges from 100 to 120 LPW depending on the lamp chromaticity. 

Table 3.2.5. Probable Efficacy Limits by Color Correlated Temperature (CCT) for 

Conventional High-Intensity Discharge Lamps

CCT ηvis ηmax spectral ηspectral η

LPW

2000 0.40 0.722 0.574 113

2800 0.40 0.766 0.574 120

3000 0.40 0.763 0.574 120

4000 0.40 0.722 0.574 113

5000 0.40 0.676 0.574 106

6000 0.40 0.636 0.574 100

3.2.3.2 Moving Beyond the Limits 

Nelson et al. hypothesized that an improvement in the power balance could increase the 

visual efficiency. Of the three values in the efficacy function, this value was below 0.4. Also, as 

stated in Table 3.2.2, only 15 to 26 percent of the energy being used by HID lamps is in the 

visual light portion of the spectrum. Nelson et al. hypothesized that the “a” source, such as the 

EE-DET-03-001 COMMENT 19
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sulfur lamp with a visual efficiency of 0.55 at 3000K on the BBL and a CRI of 80, could have an 

efficacy of 170 LPW. It should be stated that the sulfur lamp is no longer in production, but one 

reason that the lamp has a higher visual efficiency value is that it does not have electrodes.

Nelson et al. hypothesized that spectral optimization would increase the spectral 

efficiency. As shown in Table 3.2.5, the spectral efficiency values are limited to 0.574 due to the 

CRI of 80. If the spectrum was more optimized and the CRI held constant the spectral efficiency 

values could be 0.80 resulting in a 170 LPW lamp. Nelson et al. point out that the measures 

could be used in conjunction yielding in a possible 230 LPW lamp. Finally, the authors note that 

“even after more than 50 years of HID lamp development, the task of achieving a lamp with a 

high luminous efficacy (say, greater than 150 lm/w [LPW]), high CRI and a chromaticity near 

the black body line will not be an easy one.”8

3.2.4 Color Rendering Index

The IESNA defines CRI as “a measure of the degree of color shift objects undergo when 

illuminated by the light source as compared with those same objects when illuminated by a 

reference source of comparable color temperature.” In CRI calculation, 14 samples are 

evaluated; however, the general color rendering index (Ra) is only an average of the first 8 

samples. Samples R1–R8 are not highly saturated and are pastel colors. R9 is an oft-cited color 

value because it is a deeply saturated red. The accurate rendering of this color is often desired in 

retail applications. Light emitted at the “red end” of the visual spectrum (above 700 nm) adds 

little to total lumen output, but can add important color qualities to the lamp. Incandescent and 

halogen lamps have R9 values of 100. The R9 value for HID lamps is typically much less than 

100.8

3.2.5 Correlated Color Temperature

The IESNA defines CCT as “the absolute temperature of a blackbody whose chromaticity 

most nearly resembles that of the light source.” Color temperature is a not a performance metric

but rather characterizes the color appearance of a light source: “Color temperature is a 

specification of chromaticity only. It does not represent the SPD of the light source.”2

Chromaticity (expressed as chromaticity coordinates, e.g., x and y) is a representation of the light 

source color calculated with by the standard observer and spectroradiometric measurements. 

3.2.6 Lamp Life 

The rated lamp life is defined when 50 percent of a sample group of lamps have failed. It 

is expressed in hours, and varies with the method by which the ballast starts and operates the 

lamp. 

3.3 MERCURY VAPOR (MV) LAMPS

Mercury vapor was the first commercialized HID light source, introduced in the 1930s, 

and remains fundamentally unchanged. Mercury vapor and fluorescent (FL) lamps are both MV 

discharge lamps, but FL lamps operate at low pressure and MV lamps operate at high pressure. 

EE-DET-03-001 COMMENT 19
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 In the movement toward efficient lighting, one development was the invention of a 

self-ballasted MV lamp. This lamp originated as a longer-life substitute for the A-shaped general 

service incandescent lamp. By using a length of tungsten filament within the lamp structure to 

provide current regulation, these lamps function without ballasts. Although more efficient than 

incandescent lamps, these lamps are less efficacious than MV lamps with ballasts due to the 

resistive loss at the tungsten filament.

Because of their low CRI (CRI of 15 is typical), MV lamps are used primarily in spaces 

that are not frequently occupied by people. A phosphor coating is added to clear MV bulbs to 

obtain better CRI, but the improvement is marginal. Outdoor security, street, and landscape 

lighting are some of the applications for MV lamps, but higher performing MH and HPS lamps 

are replacing these. MV systems continue to maintain market share in some niche applications 

(e.g., the “security” or “barn” light – an arm-mounted luminaire used typically in residential 

applications) where long life and low initial cost are important. However, even in niche 

applications, MV is losing its advantage as other HID sources offer improved lifetime and initial 

cost. MV lamps are available in wattages from 50 to 1000. 

Mercury vapor lamps have applications aside from general illumination, including quality 

inspection, processing, scientific uses, reprographic (copy/duplication), fluorescent microscopy, 

and curing. The specific spectrum of MV lamps is beneficial to these applications. The selfballasted MV lamp has special niche because of its unique capability to directly replace highwattage incandescent lamps in standard mogul bases. Self-ballasted MV lamps are available in 

wattages between 100 and 400. Typical applications have included outdoor security lighting, 

area lighting, and some warehouse use. Although MV lamps offer modest energy savings over 

incandescent lamps, their more significant advantage over incandescent and other technologies is 

lamp lifetime, resulting in longer intervals between relamping. In recent years, the self-ballasted 

MV lamp has lost market share to integrally-ballast CFLs, integrally-ballasted MH lamps, and 

even LED replacement lamps. 

3.3.1 Lamp Construction

In a MV lamp arc tube, an electric-current arc passes from the starting electrode to the 

main electrode. The initial arc strikes through the ionization of argon gas. Once the arc is 

established, its heat vaporizes the liquid mercury in the arc tube. The amount of mercury in the 

lamp essentially determines the final operating pressure, which is 200 to 400 kilopascals (kPa) 

(29 to 58 pounds per square inch) in the majority of lamps.2 The arc tube construction is fused 

silica (quartz) that can operate at up to 1000 °C. 

An outer glass envelope (bulb) protects the arc tube and internal electrical connections 

from the environment. The bulb is usually in the shape of an ellipse and made of hard 

(borosilicate) glass, which absorbs most of the ultraviolet (UV) energy radiated by the discharge 

while allowing light to pass through. For lamps where UV emission is desired (e.g., germicidal 

lamps), the bulb is made of other materials that allow transmission of UV energy.

2 In coated MV 

lamps, an internal coating of diffusing material coats the bulb to reduce source brightness of the 

lamp. This diffusing coating is usually a color-correcting phosphor that uses UV energy radiated 

by the arc tube to improve the lamp’s overall color-rendering properties, as in a fluorescent lamp. 

MV lamps are also available in a reflector lamp format. 

EE-DET-03-001 COMMENT 19
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There are wires within the outer bulb that are suitable for high temperatures to conduct 

electricity to the arc tube and structural components to support the arc tube. The atmosphere in 

the outer bulb is usually a low-pressure gas (usually nitrogen) or in rare cases, a vacuum.2 If the 

outer bulb breaks and the arc tube continue to operate, the lamp emits a significant amount of 

UV energy. Self-extinguishing lamps, designed to shut off the lamp should the outer bulb break, 

usually contain a tungsten filament in place of a portion of nickel wire that oxidizes quickly, 

opening the circuit. This separation renders the lamp inoperable. Figure 3.3.1 shows essential 

construction details typical of lamps with quartz inner-arc tubes within an outer envelope.2

Source: GE Lighting, High-Intensity Discharge Lamps Catalog, 2003. Reproduced with permission.32

Figure 3.3.1. Mercury Vapor Lamp Construction

3.3.2 Lamp Performance

The pressure at which MV lamps operate has a significant impact on their characteristic 

SPD. As pressure increases, the emitted radiation shifts towards longer wavelengths (from UV to 

visible light) and the spectrum lines spread into wider bands. Within the visible region, the 

mercury spectrum consists of five principal lines (404.7, 435.8, 546.1, 577, and 579 nm), which 

result in greenish-blue light at efficacies of 30 to 65 LPW, excluding ballast losses.a, 2 While the 

light source itself appears greenish-blue white, a deficiency of long-wavelength radiation distorts 

the perceived color of objects illuminated by that light source. Blue, green, and yellow are 

emphasized; orange and red appear brownish. MV lamps also emit radiation outside the visible 

region in the form of UV in the range of approximately 250 to 365 nm. These wavelengths do 

not contribute to seeing, but are useful for non-illumination purposes (e.g., reprographic or 

germicidal applications).

Clear MV lamps generally have a CRI value of approximately 15 and are not desirable 

for use where people will occupy the space. Phosphor-coated MV lamps convert some of the 

 

a Ballast Loss – Power drawn by the ballast in addition to the rated lamp power used to operate the lamp.

EE-DET-03-001 COMMENT 19
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lamp’s UV radiation to visible light, as occurs with a FL lamp. The most widely used lamps of 

this type (designated “DX”) have a coating of vanadate phosphor that emits long-wavelength 

radiation (orange-red) where MV lamps are otherwise deficient, thus improving CRI.2 This 

phosphor may also blend with other phosphors to produce a cooler or warmer CCT between

3200 and 7000K. The phosphor coating can raise the CRI rating to 50. Figure 3.3.2 shows the 

SPDs of a clear lamp and coated lamp using these phosphors. 

H39KB-175

0.00

0.10

0.20

0.30

0.40

0.50

0.60

0.70

0.80

200 300 400 500 600 700 800

Wavelength (nm)

Output (Watts per 5nm for 1000 lumens)

H39KB-175

0.00

0.10

0.20

0.30

0.40

0.50

0.60

0.70

0.80

200 300 400 500 600 700 800

Wavelength (nm)

Output (Watts per 5nm for 1000 lumens)

(a)

H39KC-175/DX

0.00

0.10

0.20

0.30

0.40

0.50

0.60

200 300 400 500 600 700 800

Wavelength (nm)

Output (Watts per 5nm for 1000 lumens)

H39KC-175/DX

0.00

0.10

0.20

0.30

0.40

0.50

0.60

200 300 400 500 600 700 800

Wavelength (nm)

Output (Watts per 5nm for 1000 lumens)

(b)

Source: Sylvania, 2003. Reproduced with permission.33

Figure 3.3.2. Spectral Power Distribution of Mercury Vapor Lamps (a) Without Phosphors 

and (b) With Phosphors

Efficacies of self-ballasted lamps are slightly better than those of the incandescent lamps 

they replace. Typically, efficacies range between 15 to 25 LPW. The spectrum consists of the 

line spectrum of mercury in addition to the blackbody radiation pattern from the incandescent 

component of the tungsten filament broadening the spectrum into long-wavelength range (red). 

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Although not significantly increasing total light output, the light in these wavelengths increases 

the CRI of the source. The CCT ranges from 3300 to 4000K, with a CRI of 50, depending on 

mercury pressure and phosphor coating used (if any). 

The light output from MV lamps decreases over the operating life of the lamp. Typically, 

lumen output depreciates about 25 percent from initial output level at 50 percent of its rated life. 

The depreciation in light output is a result of the bulb becoming darker because the cathode 

material evaporates through use and is deposited on the arc tube bulb wall. Typical rated life is 

24,000 hours, but it is not uncommon for the lamp to continue operating long after its rated life. 

One of the major failure points for discharge lamps is that the cathode material eventually 

evaporates and fails to strike an arc. MV lamps are notorious for never burning out, but simply 

diminishing in output over time, because the evaporating cathode material has to diffuse through 

mercury vapor, a very heavy gas at high pressure, thereby slowing the evaporation process. The 

lamp power remains constant as light output declines, meaning that the efficacy of the light 

source steadily decreases over time. 

To achieve the necessary high vapor pressures within the arc tube, MV lamps require a 

significant warm-up time of approximately 5 to 7 minutes. Re-strike times are about as long, 

requiring 5 to 7 minutes for the vapor pressure to reach the level where the arc can restart. 

Warm-up time for self-ballasted lamps is approximately 3 minutes, with a re-strike time of 

5 minutes. Table 3.3.1 summarizes the performance of common MV lamps. 

Table 3.3.1. Performance Summary of Mercury Vapor Lamps 

Lamp Power*

W 

CRI CCT†

K 

Initial 

Lumens

Life

Hrs

Initial Efficacy

@ 100 hrs‡ 

LPW

Mean Efficacy

@ 40-50% life§

LPW

50 Minimum 20 3,200 1,050 6,000 22 13

Median 45 4,100 1,575 8,000 30 24

Maximum 50 5,700 1,900 24,000 40 33

75 Minimum 20 3,200 2,700 16,000 36 24

Median 45 4,100 2,700 18,000 36 30

Maximum 50 5,700 3,000 24,00 40 32

100 Minimum 15 3,200 1,100 6,000 11 8.3

Median 40 4,100 4,000 2,4000 40 26

Maximum 60 7,000 4,500 2,4000 45 37

175 Minimum 15 3,700 5,100 16,000 29 21

Median 40 4,300 7,800 24,000 45 39

Maximum 50 6,800 8,900 24,000 51 43

250 Minimum 15 3,200 3,200 12,000 13 11

Median 43 4,100 8,900 24,000 36 24

Maximum 50 6,700 13,700 24,000 55 45

400 Minimum 15 3,700 1,500 12,000 37.5 13.25

Median 43 4,000 21,000 24,000 53 36

Maximum 50 6,500 24,000 24,000 60 49

1000 Minimum 15 3,700 13,000 16,000 45 13

Median 40 4,100 45,200 24,000 58 45

Maximum 50 6,300 52,240 24,000 64 52

* A minimum of three different manufacturers had to produce the type and similar wattage to have that wattage class 

listed in this table. See Appendix D for a comprehensive list of lamp data from manufacturers’ catalogs.

† Correlated-color temperature is not a performance metric; the values are listed to show the range of available 

CCTs for the product.

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‡ Initial efficacy is initial lumens divided by the lamp rated power (the power use of the ballast is not factored into 

this table).

§ Mean efficacy is the mean lumen value provided by the manufacturer divided by the lamp rated power (the power 

use of the ballast is not factored into this table). Lumen depreciation still occurs after this point.

3.3.3 Electrical Characteristics

Because MV lamps have an additional electrode located at one end of the arc tube to 

assist in lamp starting, they do not require a separate starter circuit. These lamps typically require 

an open-circuit voltage of approximately twice the operational lamp voltage to initiate and 

sustain the arc discharge.

MV lamps may operate with any of the commonly available MV and MH ballasts 

without an ignitor. All MH ballasts will operate MV lamps of the corresponding wattage, 

although most MV lamp ballasts will not operate MH lamps reliably. Ballasts for MV lamps tend 

to be small and inexpensive, and fall into four basic categories: (1) reactor (RX) ballasts; 

(2) high-reactance autotransformer (HX) ballasts; (3) CWA ballasts; and (4) CW isolated 

transformer ballasts. Ballast losses may reduce the system efficacy of MV sources (and other 

HID sources) by 5 to 15 percent. This results in an efficacy range for MV systems (lamp plus 

ballast) of approximately 26 to 55 LPW. 

Figure 3.3.3 shows the energy balance from a typical 400-W MV lamp.34

Figure 3.3.3

 Although this 

diagram dates from the mid-1970s and is for one lamp wattage, the diagram is representative of 

how the input power is used in this lamp type. The percentage values in parentheses are the 

portion of power for that input or output per rated lamp wattage. Typically, only 15 percent of 

the power used by the lamp is actually converted into visible radiation. The efficiency of the 

conversion of power into radiation increases with power. As shown in , MV lamps 

produce equal or more energy in the IR region than in the visible light region. 

 

Figure 3.3.3. Sample Power Flow of a Mercury Vapor Lamp

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3.3.4 Other Issues

Although the Occupational Safety and Health Administration does not require lamp 

manufacturers to do so, all three major MV lamp manufacturers (General Electric, Philips, and 

OSRAM SYLVANIA) provide material safety data sheets (MSDS) for manufactured articles, 

such as HID lamps. The MSDS reports that MV lamps contain anywhere from 15 milligrams 

(mg) of mercury in 50 W lamps to 250 mg of mercury in the 1000 W examples. Although other 

toxic materials are in the lamps, these are present in trace amounts and are not classified as 

hazards. Lead is typically used in soldering the connection in the lamp. 

Although lead in the lamp and mercury in the arc tube pose little risk under normal use, a 

toxicity characteristic leaching procedure (TCLP) for lead and mercury, as prescribed by NEMA

standards publication LL 3-1999, results in MV lamps being classified as hazardous waste. 

Therefore, the Universal Waste Rule published by the U.S. Environmental Protection Agency 

(EPA) on July 6, 1999 (64 FR 36466) prescribes specific disposal requirements for spent MV 

lamps. 

3.4 HIGH-PRESSURE SODIUM LAMPS

HPS lamps were introduced in the 1960s, prior to the introduction of MH lamps. HPS 

lamps are currently the most efficacious HID light source ranging from 38 to 150 LPW, with 

typical efficacy being greater than 80 LPW. These values are initial lamp efficacy (rated lamp 

lumens/rated lamp power) and do not take in account any ballast losses. The 38 LPW value is 

from a directional (reflector-type) lamp. This is an atypical lamp and its low efficacy is not 

representative of HPS lamps in general. Typical HPS lamps have low CCT (e.g., 2100K) and 

low CRI (e.g., 22), but there are some enhanced-spectrum HPS lamps that have a higher CRI 

(and a higher CCT as a byproduct of the change in spectrum). 

HPS lamps are in use in public (e.g., outdoor roadway), commercial, and industrial 

sectors. Although HPS lamps are available in wattages from 35 up to 1000, the most common

wattages in these sectors range from 50 to 500. Typical applications include vehicular traffic

areas (e.g., roadways and parking lots) and pedestrian areas (e.g., public-access areas, subways, 

and parks). HPS lamps are also used in commercial and industrial applications where color 

quality may not be critical (e.g., storage and loading areas, and corridors). Many of these 

application overlap with MH, creating competition between the technologies for market share.

3.4.1 Lamp Construction

Figure 3.4.1 shows the basic construction of HPS lamps. Similar to MV lamps, they have 

an inner arc tube and an outer bulb. The arc tube is made of a ceramic material that contains 

electrodes, a sodium and mercury amalgam, and a small amount of xenon gas. No starter probe is 

present in the HPS arc tube, and a high-voltage, high-frequency pulse is used to ionize the 

starting gas. The high temperatures needed to vaporize sodium dictate the arc tube geometry and 

material. Further, the highly corrosive nature of sodium, especially at elevated temperature and 

pressure (700 °C/27 kPa [3.9 pounds per square inch]), precludes the use of certain materials 

(e.g., quartz). An amalgam reservoir inside the arc tube helps to stabilize pressure, similar to 

EE-DET-03-001 COMMENT 19
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amalgam-based fluorescent lamps. This allows HPS lamps to operate in any physical orientation, 

simplifying stocking and installation.35 

Source: GE Lighting, High-Intensity Discharge Lamps Catalog, 2003. Reproduced with permission.9

Figure 3.4.1. High-Pressure Sodium Lamp Construction

The lamp’s outer glass envelopes are typically elliptical in shape and are made of a hard 

glass that protects the arc tube from damage. Usually, an outer envelope contains a vacuum that 

reduces convection and heat losses from the arc tube to maintain high efficacy.12 

In some HPS lamps, an additional coil is wrapped around the outside of the ceramic arc 

tube to assist in starting the lamp.12 This coil is similar in function to the starting probe in probestart MH and MV lamps. This type of HPS lamp can directly replace MV lamps and operate on 

the same ballast without an ignitor. However, HPS retrofit lamps produce significantly more 

light for the same wattage. Therefore, to realize any energy savings a lower-wattage HPS retrofit 

lamp should replace a higher-wattage MV lamp.

3.4.2 Lamp Performance 

The high luminous efficacy of HPS lamps corresponds to the emittance of sodium in the 

yellow-orange portion of the visible spectrum, to which the human visual system responds most 

efficiently. The efficiency of HPS lamps is critically dependent on the specific vapor pressure of 

sodium in the arc tube. Any deviation from this optimum pressure results in reduced 

performance of the lamp. Notwithstanding, HPS lamps offer the highest efficacy of HID sources, 

achieving 64 LPW for 35-W sources and up to 133 LPW for 1000-W sources. HPS lamps of 100 

watts or more have efficacies over 100 LPW. Rated lifetimes of 24,000 hours are typical, with 

some long-life lamps rated at 40,000 hours. These lamps have expected LLD value of 10 percent 

at mean rated life. A historical perspective of how these values have changed in the 40 years 

since HPS lamps entered the market can be found in another IESNA significant paper. A 1965 

publication in Illuminating Engineering stated that with initial efficacy in excess of 100 LPW, 

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“10,000 hour lumen maintenance has been measured on laboratory test lamps at over 90 percent. 

Median life at the present time is in the 3,000- to 6,000-hour range. From an engineering 

viewpoint it is reasonable to expect that this can be increased as techniques for constructing the 

lamps are improved.”36 From the data in Table 3.4.1, it appears that the comment was true in that 

life of HPS lamps have improved and efficacy somewhat improved. The historical perspective 

shows that in over 40 years, the efficacy of the lamp has increased 20 to 30 percent since the 

introduction of the lamp. 

Table 3.4.1. Performance Summary of High-Pressure Sodium Lamps

Lamp Power*

W 

CRI CCT†

K 

Initial 

Lumens

Life

hrs

Initial Efficacy

@ 100 hrs‡ 

LPW

Mean Efficacy

@ 40-50% life§

LPW

35 Minimum 21 1,900 2,100 16,000 60 55

Median 22 1,900 2,250 16,000 64 58

Maximum 22 2,100 2,250 24,000 64 59

50 Minimum 17 1,900 2,300 6,000 46 40

Median 22 1,900 4,000 24,000 80 72

Maximum 85 2,700 4,000 30,000 80 72

70 Minimum 17 1,900 3,350 6,000 48 41

Median 22 1,900 6,300 24,000 90 76

Maximum 83 2,500 6,500 40,000 93 84

100 Minimum 17 1,900 4,900 10,000 49 42

Median 22 2,100 9,500 24,000 95 80

Maximum 85 2,700 10,500 40,000 105 95

150 Minimum 17 1,800 5,900 6,170 39 41

Median 22 2,100 15,000 13,500 100 90 

Maximum 85 2,500 16,000 14,400 107 96

200 Minimum 21 2,000 21,400 24,000 107 90

Median 22 2,100 22,000 24,000 110 99

Maximum 25 2,100 22,000 40,000 110 99

250 Minimum 15 2,000 9,500 9,000 38 32

Median 22 2,100 27,000 24,000 112 99

Maximum 85 2,500 29,000 40,000 121 109

400 Minimum 22 2,000 18,000 9,000 45 38

Median 22 2,100 48,500 24,000 121 111

Maximum 85 2,500 54,000 40,000 135 122

1000 Minimum 21 2,000 125,000 15,000 125 112

Median 22 2,100 138,750 24,000 139 126

Maximum 25 2,100 146,000 40,000 146 136

* A minimum of three different manufacturers had to produce the type and similar wattage to have that wattage class 

listed in this table. See Appendix D for a comprehensive list of lamp data from manufacturers’ catalogs.

† Correlated-color temperature is not a performance metric; the values are listed to show the range of available 

CCTs for the product.

‡ Initial efficacy is initial lumens divided by the lamp rated power (the power use of the ballast is not factored into 

this table).

§ Mean efficacy is the mean lumen value provided by the manufacturer divided by the lamp rated power (the power 

use of the ballast is not factored into this table). Manufacturers select the time at which they provide the mean lumen 

data, which vary between 40 and 50 percent of rated life. Lumen depreciation still occurs after this point. Also, not 

all manufacturers publish mean lumen values, which can be higher than the initial efficacy values because the mean 

lumens were not provided. This column is based on mean lumens published by manufacturers (a full list can be 

found in Appendix D).

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Figure 3.4.2 shows the SPD for a typical HPS lamp. During warm-up, the lamp’s color 

appearance shifts from red to blue, before stabilizing at the characteristic yellow-white.2 A 

typical CCT value is 2100K with a CRI of 22. Higher CCT values are possible at the cost of 

reduced efficacy and lifetime. The highest commercially available CCT is 2700K with a CRI of 

85.37 Applying diffuse coatings does not significantly change the SPD of HPS lamps because 

most of the radiation emitted by the lamp is in the visible portion of the spectrum. 

LU400/ECO

0.00

0.05

0.10

0.15

0.20

0.25

0.30

 

300 400 500 600 700 800

Wavelength (nm)

Output (Watts per 5nm for 1000 lumens)

LU400/ECO

0.00

0.05

0.10

0.15

0.20

0.25

0.30

 

300 400 500 600 700 800

Wavelength (nm)

Output (Watts per 5nm for 1000 lumens)

Source: Sylvania, 2003. Reproduced with permission.10

* Same distribution for bare and coated lamps.

Figure 3.4.2. Spectral Power Distribution* of High-Pressure Sodium Lamps

3.4.3 Electrical Characteristics

Given their arc tube geometry and lack of starting probes, HPS lamps require an ignitor 

to generate the high-voltage pulse necessary to initiate the electrical arc across the electrodes.

Once the ignitor initiates the arc, the cold lamp requires approximately 3–4 minutes of warm-up 

time to attain full light output, with a re-strike time typically ranging 1–3 minutes.

Figure 3.4.3 shows the energy balance from an example 400 W HPS lamp.11 Although 

this diagram dates from the mid-1970s and is for one lamp wattage, the diagram is representative 

of how the power is used. The percentage values in parentheses are the portion of power for that 

input or output per rated lamp wattage. Only 30 percent of the power used by the lamp is actually 

converted into visible radiation. The efficiency of the conversion of power into radiation 

increases with power. Very little lamp power (approximately 1 percent) is emitted in the UV 

range. Some power (20 percent) is emitted in the IR range; however, a larger portion of the 

power is emitted in the visible range. The values in Figure 3.4.3 are consistent in relationship to 

the energy output of an HPS lamp as listed in Table 3.2.2. 

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Figure 3.4.3. Sample Power Flow of a 400 W High-Pressure Sodium Lamp

Unlike a typical MV or MH lamp, where voltage remains relatively constant throughout its 

lifetime, the arc-tube voltage increases significantly during the operating life of HPS lamps. 

Sodium is lost over the operating lifetime of the lamp, and the arc voltage rises as the ratio of 

sodium to mercury changes. Although the voltage rises over life, the technology needs to operate a 

constant wattage. Therefore, HPS ballasts must compensate for the change in operating lamp 

voltage to maintain an acceptable average wattage. The lamp/ballast combination “constitutes a 

dynamic system in which the intrinsic voltage rise of an HPS lamp is either amplified or attenuated 

by the nature of the characteristic curve of the ballast on which the lamp is operated.”38 Figure 

3.4.4 illustrates the boundary conditions that restrict the performance of the lamp and the ballast to 

certain acceptable limits. These boundary conditions, due to their shape on the graph, are referred 

to as the trapezoid-shaped boundaries (ANSI C78.42). HPS ballasts operate HPS lamps within this 

trapezoid for any input voltage within the designed range of the ballast. 

EE-DET-03-001 COMMENT 19
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Source: NEMA, 2001. Reprinted by permission from ANSI document C78.42-2001 High-Pressure 

Sodium Lamps.

39

Figure 3.4.4. Trapezoid Boundary for High-Pressure Sodium Ballast Design

Toward the end of the lamp’s life, the lamp-operating voltage will rise to a level beyond 

the ballast’s capability to sustain the arc. At this point, the lamp will start, warm up to full 

brightness, and extinguish. The repeating of this sequence is known as cycling and signals endof-life for HPS lamps. If the lamp is then not replaced within a reasonable amount of time, 

premature failure of the ballast can occur. In the 1990s, the industry introduced non-cycling HPS 

lamps. Manufacturers increased the xenon pressure and added a starting strip on the arc tube to 

assist starting. They also reduced the mercury dose and included lead-free construction. This 

type of lamp operates on standard HPS ballasts. Non-cycling lamps, with lowered additive dose 

construction, do not have a voltage rise at end-of-life. Because sodium loss cannot be eliminated 

completely, the lamp will gradually become fully unsaturated in the useful operating regime at 

some point in life. As the lamp then ages, its operating point will begin to shift downward and to 

the left on the watts-volts plot.40 Other research in the 1990s found that a specific combination of 

mercury and sodium in the lamp to maintain mercury and sodium pressures lead to a lamp in 

which the voltage did not significantly increase over life.41

The simplest and most economical ballast for HPS is the RX ballast, which is commonly 

used with 35- to 150-W HPS lamps. HX ballasts are used where the input voltage does not 

generate sufficient voltage to operate the lamp. The CWA is the most popular ballast type for 

balancing cost and performance (similar to ballasts for MH and MV lamps). CW ballasts have 

some advantages over the previous three, but are physically larger, have higher losses, and are 

more expensive. Other ballasts may incorporate three coils in their design instead of the usual 

two or one; the third coil and the capacitor stabilize the lamp. 

 Through the use of this specification 

relationship and changing the material of the emitter in the lamp, less sodium was lost and lumen 

maintenance was slightly improved. 

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3.4.4 Other Issues

Typical HPS lamps contain mercury as an amalgam with sodium. Over the years, 

manufacturers lowered the dose of mercury in many of their lamps with common dosage for a 

250 W lamp of approximately 15 mg. This is much less than that found in MH lamps because of 

the sodium-mercury amalgam used in HPS technology. In addition, some manufacturers are 

selling lamps free of lead solder. TCLP tests classify some HPS lamps as exempt and others as 

hazardous waste, subject to state and local disposal regulations. 

3.5 METAL HALIDE LAMPS

Developed in the 1960s after HPS lamps, MH lamps offer an excellent combination of 

quality, performance, and flexibility for “white light” applications. The first lamps were probestart quartz (circa 1960), then pulse-start quartz (circa early 1990s), and then pulse-start ceramic 

(circa late 1990s). The sources provide significant amount of light for the package. Unlike MV 

and HPS lamps, MH lamps have many suitable uses in both interior and exterior applications. 

The lamps are available in a wide range of CCTs and CRIs ranging from 2,900 to 10,000K and 

65 to 90, respectively. The small physical dimensions and high intensity of the arc make it an 

ideal point source around which to create application-specific light distributions through precise 

optical design in reflector lamps and fixtures. MH lamps are in use in public, commercial, 

industrial, and residential sectors. The lamps are even used in transportation activities like 

vehicle forward lighting and range in wattages from 20 to 2000. Low-wattage (below 150) lamps 

are used floodlighting and recessed lighting. Very low-wattage MH lamps (in the range of 20 to 

60) can be found in exterior accent and landscape luminaires (both residential and commercial) 

and retail track lighting. Also, since around 2000, very low-wattage MH lamps can be found in 

automotive headlights. Medium-wattage MH lamps (150 to 500) typically are used in area (e.g., 

parking lot and pedestrian walkways), roadway, low-bay and high-bay applications. Finally, 

high-wattage MH lamps are used in some parking lots, search lights, and stadium/sports lighting.

Some manufacturers produce MH retrofit lamps capable of directly replacing other 

lamps. Some lamps are designed to replace MV lamps of similar wattage, and operate on the 

same MV ballasts. However, like HPS retrofit lamps, MH retrofit lamps produce significantly 

more lumens for the same wattage. For example, replacing a 400 W MV lamp with a 400 W MH 

retrofit lamp generates about twice the light of the original MV lamp. MH lamp manufacturers 

have also developed self-ballasted, very low-wattage (under 40) PAR38 lamps intended as direct 

replacement for higher wattage halogen and incandescent reflector lamps. These PAR38 lamps 

are used in high-end retail applications and even grocery stores. 

3.5.1 Construction 

The standard MH lamp is similar to MV lamp technology; the lamp is essentially a MV 

lamp containing one or more MHs (usually iodides) which vaporize in the lamp arc.42

The use of MHs presents two advantages. First, they are more volatile at typical lamp

operating temperatures than pure metals. This allows metals with desirable emission properties to 

The added 

compounds broaden the MV spectrum, producing better color rendering and lamp efficacy in 

MH lamps. 

EE-DET-03-001 COMMENT 19
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be introduced into the arc at reasonable arc tube temperatures. Second, they do not readily react 

with a fused silica arc tube, instead remaining in the arc. When the lamp attains full operating 

temperature, MHs in the arc tube partially vaporize. As halide vapors approach the hightemperature central core of the discharge, they dissociate into halogen and metals, with the metals 

radiating their light spectrum. As halogen and metal atoms move near the cooler arc tube wall by 

diffusion and convection, they recombine, and the cycle repeats.

43

Figure 3.5.1 and Figure 3.5.2 compare and contrast power flow of two 400-W MH 

lamps. Although dated, the diagrams illustrate how different MHs used in MH lamps affect SPD 

and overall lumen output.11 Figure 3.5.1 is a tin iodide (SnI) lamp and produces 24,000 lumens, 

CCT of 4100K, and a CRI of 91. In contrast, another lamp at the same wattage and type (MH) 

has very different output. Figure 3.5.2 is a dysprosium iodide (DyI) lamp and produces 32,400 

lumens, CCT of 5250K, and a CRI of 85. 

Figure 3.5.1. Tin Halide Figure 3.5.2. Dysprosium Iodide

MH lamp construction is similar to that of MV lamps. One significant difference is that 

arc tubes of MH lamps are usually smaller for equal wattages. The arc tube is typically made of 

either fused quartz or ceramic. MH arc tubes operate at a higher temperature and pressure than 

their MV counterparts. Quartz arc tubes typically use a white coating at their ends to increase 

temperature and vaporization of MHs by trapping thermal energy inside the arc tube. Replacing 

quartz in the arc tube with ceramic materials enables the lamp to operate at even higher 

temperatures and pressures, resulting in improved efficacy, CRI, and color stability. 

An elliptical-shaped outer bulb, usually made of borosilicate glass, contains the arc tube. 

The bulb protects and buffers the arc tube and internal electrical connections from the 

environment. The outer envelope contains low-pressure inert gas (i.e., nitrogen) or a vacuum, 

which not only helps minimize the oxidation of internal components, but also provides a margin 

of safety against threat of arc tube rupture (also known as non-passive failure). The outer 

envelope also provides additional thermal buffering for a more stable arc temperature. The glass 

itself absorbs the majority of UV energy.20 

EE-DET-03-001 COMMENT 19
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Manufacturers may coat the outer glass bulb with diffusing material. Usually, this is a 

phosphor coating that helps change emission spectra for small improvements in CRI. However, 

the primary purpose of the coating is to reduce source brightness of the lamp for glare control. 

The technology advantage of MH lamps is their capability to emit the desired spectra without the 

addition of a phosphor coating. Adding a diffuse coating to the lamp reduces the efficiency and 

effectiveness of luminaires with optics.

Within the outer bulb are wires suitable for high temperatures to conduct electricity to the 

arc tube and structural components to support the arc tube. There might be other components, 

including resistors, diodes, and bimetallic switches used to help start the arc discharge as well as 

devices called “getters” to purify the atmosphere in the outer lamp. Most MH lamps use getters 

to control (reduce or eliminate) impurities that, if present in the outer jacket of MH lamps in 

sufficient concentrations, can compromise performance. 

Like other lamps in the HID group, MH lamps typically have screw bases (medium or 

mogul) made from brass, nickel, or special alloys to minimize corrosion. A characteristic of MH 

arc tubes is that they can take different forms and can be made from different materials.

In a horizontally operated MH lamp, the arc discharge bows away from the axis of the arc 

tube due to convection currents. The MH pool (liquid) moves to the center of the arc tube. The 

bowed arc moves farther from the MHs than when the lamp is vertical, causing them to cool. 

This lowers the vapor pressure of MH chemicals and decreases the concentration of metals in the 

arc, resulting in loss of light. The bowed arc moves closer to the top of the arc tube wall, causing 

its temperature to increase. The higher heat loading on the arc-tube material can result in a 

decrease in life of approximately 25 percent. Therefore, manufacturers employ additional shapes 

to compensate for this sensitivity in operating position. High-output lamps designed to operate 

horizontally use a special base and socket, such as the ANSI EP39 Mog position-oriented mogul 

base, to help ensure proper arc tube orientation and position. 

Figure 3.5.3 shows a bowed arc-tube shape that follows the natural bowing of the 

horizontal arc.20

Note: POM means position oriented mogul.

Source: Sylvania, High Intensity Discharge Metalarc® Lamps, 1998.20 Reproduced with permission.10

Figure 3.5.3. Formed Arc-Tube Configuration for Horizontal MH Lamps 

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Figure 3.5.4 shows an asymmetric arc tube with offset electrodes. In this design, the 

electrodes are lower in the arc tube body, and the arc discharge bows to the center of the arc 

tube. 

Arc Tube

Main Electrode

Starter Electrode

Main Electrode

Source: Philips, 2003. Reproduced with permission.44

Figure 3.5.4. Offset Electrode Configuration for Horizontal MH Lamps

Some lamps use a transparent sleeve called a shield or shroud, to surround the arc tube 

(Figure 3.5.5). The sleeves are useful as heat shields because they help the arc tube achieve a 

uniform temperature profile. Shrouds also prevent the outer jacket of the lamp from breaking in 

case of a violent arc-tube failure; however, they are not the only method of protection (e.g., some 

new ceramic tubes have a wrapped wire instead of a sleeve). HID lamps with protective shrouds 

carry the ANSI O-rating, signifying that they meet ANSI requirements for safe operation in an 

open-luminaire not equipped to protect against violent failure. To prevent user misapplication, 

the industry developed unique socket and base combinations in both medium and mogul bases 

for these open-luminaire lamps.

Source: Venture Lighting, 2003. Reproduced with permission.45

Figure 3.5.5. Metal Halide Arc Tube with a Shroud 

Some applications, such as sports lighting, use MH lamps without outer jackets. Due to 

high levels of UV energy present in its emission spectra, luminaires that operate with these lamps 

(no outer jackets) require a glass cover to adsorb some of this harmful UV radiation. 

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3.5.1.1 Probe-Start Quartz Metal Halide Lamps

The first MH lamp was the probe-start lamp (Figure 3.5.6), where the arc tube is shaped 

into what is called the classic pinched body. These lamps require a starter electrode (or probe) in 

the arc tube. The lamp body must also contain a system that provides for cutting starting voltage 

after the lamp is started, typically with a bimetal switch. Continued application of high starting 

voltages can severely shorten lamp life. The location and type of bimetal switch can restrict the 

lamp operating position, as the bimetal must achieve a certain temperature to function. 

Source: GE Lighting, High-Intensity Discharge Lamps Catalog, 2003. Reproduced with permission.9

Figure 3.5.6. Metal Halide Lamp Construction 

 An evolutionary development of the probe-start lamp configuration is the formed-body 

arc tube. Manufacturers can mold arc tubes into unique shapes such as an ovoid (Figure 3.5.7), 

resulting in significant improvements in performance. The contour of the formed-body arc-tube 

wall follows the shape of the arc, thereby allowing for a more uniform temperature profile for the 

arc tube. Also, formed-body arc tubes have much smaller pinch-seal areas. This allows MH

chemicals to heat up more rapidly than those in conventional pinched-body arc tubes, resulting in 

a shorter warm-up time than pinched-body arc tubes of the same wattage. Probe-start MH lamps 

typically employ pinch-seal designs (Figure 3.5.7) that have a starter electrode (or probe) to help 

initiate the breakdown of arc-tube gases.

EE-DET-03-001 COMMENT 19
3-25

(a) Ovoid (b) Pinched-Body

Source: Advanced Lighting Technologies Inc., 2003. Reproduced with permission.22

Figure 3.5.7. Common Arc Tubes

3.5.1.2 Pulse-Start Quartz Metal Halide Lamps

Thirty years after probe-start MH lamps entered the market, pulse-start MH (PMH) lamps 

were introduced. These lamps are similar to probe-start, however, these lamps lack a starting 

probe in the arc tube. 

 Pulse-start MH lamps (section 3.5.1.3) were the first to incorporate formed-body arc 

tubes, but this arc-tube shape is not exclusive to pulse-start configurations. Some manufacturers 

still use pinched-body arc tubes in their PMH lamps.46

Pulse-start MH lamps have a higher starting-gas fill pressure to decrease the starting time 

and minimize the transport of electrode material to the wall. These improvements result in longer 

life (up to 50 percent longer) and improved lumen maintenance (up to 33 percent) compared with 

traditional probe-start MH lamps. 

 

3.5.1.3 Pulse-Start Ceramic Metal Halide Lamps

The most recent development in MH arc tube design incorporates the ceramic arc tube. 

Like formed-body arc tubes, this pulse-start technology lacks a starter probe. This arc tube 

represents the newest evolution in the development of MH lamps. The lamp performance and 

electrical-characteristic segments of this MH lamp chapter discuss the improvements in 

performance from these new shapes and materials. 

EE-DET-03-001 COMMENT 19
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3.5.2 Lamp Performance 

Commercially available MH lamps have initial efficacies from 30 to 125 LPW (excluding 

ballast losses). The lowest efficacy is related to a type of directional lamp, and is not typical of 

the MH lamp family. Depending the on the type of MH lamp, the CRI ranges from 65 to 90, far 

superior to virtually every other HID lamp (MV and HPS). This unique capability results from 

manufacturers’ ability to tailor the spectral outputs of the lamps. 

Metal halides are binary compounds consisting of halogen and metal elements. Halogens 

are a group of non-metal including fluorine (F), chlorine (Cl), bromine (Br), iodine (I), and 

astatine (At). Iodine in the form of ions (also known as iodide) is the most common halogen used 

in MH lamps. Bromine is the other halogen used, but less often than iodine. Metal halides are 

additive compounds, so nearly any metal can be combined with halogens. However, certain 

metals are not used because of toxicity, instability, or other problems with the metals at the 

required vapor pressures. Excluding those metals, roughly 50 different metals can still be used in 

MH lamps. Using two metals at a time, the number of possible combinations (not counting 

variations in concentration) is 1225. The metals can be used three, four, or five at a time, giving 

19,600, 230,300, or 2,118,760 combinations.47

Typical metals used in MH lamps include indium (In), tin (Sn), and the rare earth (RE) 

elements which include scandium (Sc), yttrium (Y), and 15 lanthanoids: lanthanum (La), cerium 

(Ce), praseodymium (Pr), neodymium (Nd), promethium (Pm), samarium (Sm), europium (Eu), 

gadodinium (Gd), terbium (Tb), dysprosium (Dy), holmium (Ho), erbium (Er), thulium (Tm), 

ytterbium (Yb), and lutetium (Lu). 

 Although a significant number of possible 

combinations exist, metals are typically selected with strong emission lines in the desired portion 

of the spectrum. 

Other MHs that have been explored are alkaline earth haides, a series of metals that 

comprise Group 2 of the periodic table: beryllium (Be), magnesium (Mg), calcium (Ca), 

strontium (Sr), barium (Ba), and radium (Ra). A 1976 study examining improving MH lamps 

found that: 

In many cases, e.g., sodium and the rare earth halides, an increase in vapour pressure will 

result in a higher luminous efficacy. In other cases, e.g., the alkaline earth halides, one 

could enhance the emission at certain wavelengths and thus substantially improve the 

colour rendering properties of the lamp.48

Metal halides in these lamps have characteristic emissions that are spectrally selective. 

Some metals emit visible radiation in narrow spectral bands, generating specific colors to the eye 

(i.e., Na for yellow-orange, Tm for green, and In for blue). A 1985 study examining the spectral 

properties of MH lamps with rare earth iodides found that the spectra of the metal can be 

selectively used:

This results in the possibility of optimizing the spectra for distinct applications. In 400 W, 

lamps the highest efficacies obtained were reached with Ce-Na and Pr-Na mixtures, η = 

110 to 115 lm/W [LPW]. The best colour rendering properties can be obtained with Tm 

and Dy (Ra>80).49

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Other metals such as tin, when introduced as halides, radiate predominantly as molecules, 

providing continuous band spectra across the visible spectrum. Various combinations of these 

halides can create a wide range of CCT and CRI for these lamps. 

Phosphor coatings also change the spectral emission of these lamps. Because phosphors 

convert shorter-wavelength radiation to longer-wavelength radiation, these phosphors effectively 

lower the CCT of lamps by approximately 300K. Although a slight improvement in CRI may 

occur, the primary function of a phosphor coating of MH lamps is to create a more diffuse light 

source. These combinations of metals and their halides as well as phosphors (to a lesser extent) 

create an almost infinite palette of possibilities, giving MH lamps flexibility in light-output 

design unique to the HID sources. Figure 3.5.8 shows typical SPD plots for MH lamps with and 

without a phosphor coating. 

MP100UMED

0.00

0.05

0.10

0.15

0.20

0.25

0.30

300 400 500 600 700 800

Wavelength (nm)

Output (Watts per 5nm for 1000 lumens)

 TR20014366

MP100UMED

0.00

0.05

0.10

0.15

0.20

0.25

0.30

300 400 500 600 700 800

Wavelength (nm)

Output (Watts per 5nm for 1000 lumens)

 TR20014366

(a)

Wavelength (nm) 204443b

Output (Watts per 5nm for 1000 lumens)

MP100/C/U/MED

0.00

0.05

0.10

0.15

0.20

0.25

0.30

300 400 500 600 700 800

Wavelength (nm) 204443b

Output (Watts per 5nm for 1000 lumens)

MP100/C/U/MED

0.00

0.05

0.10

0.15

0.20

0.25

0.30

300 400 500 600 700 800

(b)

Source: Sylvania, 2003. Reproduced with permission.10

Figure 3.5.8. Spectral Power Distribution of Metal Halide Lamps (a) Without Phosphors 

and (b) With Phosphors 

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3-28

Because the physical operating orientation of the lamp affects performance, MH lamps 

are typically life-rated and lumen-rated in the vertical operating position. For example, MH 

lamps classified as universal orientation (able to operate in any orientation) achieve their rated 

performance in the vertical position. 

3.5.2.1 Probe-Start Quartz Metal Halide Lamps

When operated to specifications, probe-start lamps have a rated life from 10,000 to 

20,000 hours with an average efficacy of 84 LPW. The actual efficacy varies by both the lamp 

wattage and type (omni-directional are more efficacious than directional lamps). The rated LLD 

is about 25 percent at 40 percent of rated life. 

Color quality is an important aspect of MH lamps. The average CRI for probe-start lamps 

is 76; actual values range as in Table 3.5.1). However, CRI only examines a sample of eight (R1-

R8) pastel color samples, atypical for some applications. Therefore in addition to the CRI values, 

many MH manufacturers are now reporting the R9 (deep red color) for specification in interior 

applications, especially retail. The R9 value of probe-start lamps is negative.

50 Therefore probestart lamps have limited use in interior applications and are not practical for retail installations. 

Over life, the color shift amongst the same batch of MH lamps can be from 300 to 800K.51 

Table 3.5.1. Performance Summary of Probe-Start Metal Halide Lamps

Lamp Power*

W 

CRI CCT†

K 

Initial 

Lumens

Life

hrs

Initial Efficacy

@ 100 hrs‡ 

LPW

Mean Efficacy

@ 40% life§

LPW

50 Minimum 70 2,900 3,200 10,000 64 30

Median 85 3,500 3,525 10,000 71 46

Maximum 92 4,000 4,100 20,000 82 55

70 Minimum 70 2,900 2,610 3,200 37 43

Median 92 4,000 5,000 9,000 71 55

Maximum 96 6,500 6,200 20,000 89 66

100 Minimum 65 2,900 6,000 9,000 60 48

Median 92 4,000 8,400 15,000 80 59

Maximum 96 6,500 9,500 20,000 95 71

150 Minimum 65 2,800 5,400 2,800 36 48

Median 95 3,850 11,950 10,000 80 60

Maximum 96 6,500 14,000 20,000 93 70

175 Minimum 55 3,000 10,000 7,500 57 43

Median 65 4,000 13,600 10,000 78 50

Maximum 75 10,000 15,000 10,000 86 69

250 Minimum 62 3,000 17,500 7,500 70 38

Median 65 4,000 20,750 10,000 83 55

Maximum 90 10,000 23,000 20,000 92 78

360 Minimum 60 3,600 31,700 15,000 88 57

Median 65 4,000 36,000 20,000 100 65

Maximum 80 4,300 43,200 30,000 120 98

400 Minimum 60 3,000 25,000 8,000 63 44

Median 65 4,000 36,050 20,000 90 60

Maximum 90 10,000 43,000 20,000 108 84

1000 Minimum 65 3,200 72,000 6,000 80 52

Median 65 3,700 110,000 12,000 110 86

Maximum 72 5,500 120,000 18,000 120 96

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Table 3.5.2. Performance (continued)

1500 Minimum 60 3,400 125,000 3,000 83 67

Median 65 4,000 163,000 3,000 109 93

Maximum 92 5,500 170,000 6,000 113 102

* A minimum of three different manufacturers had to produce the type and similar wattage to have that wattage class 

listed in this table. See Appendix D for a comprehensive list of lamp data from manufacturers’ catalogs.

† Correlated-color temperature is not a performance metric; the values are listed to show the range of available 

CCTs for the product.

‡ Initial efficacy is initial lumens divided by the lamp rated power (the power use of the ballast is not factored into 

this table).

§ Mean efficacy is the mean lumen value provided by the manufacturer divided by the lamp rated power (the power 

use of the ballast is not factored into this table). Manufacturers select the time at which they provide the mean lumen 

data, which vary between 40 and 50 percent of rated life. Lumen depreciation still occurs after this point. Also, not 

all manufacturers publish mean lumen values. The mean efficacy values can be higher than the initial efficacy 

values because the mean lumens were not provided, and this column is based on mean lumens.

3.5.2.2 Pulse-Start Quartz Metal Halide Lamps

When operated to specifications, the rated life of pulse-start MH lamps is 15,000 to 

30,000 hours with efficacies in excess of 100 LPW. The LLD is about 25 percent at 40 percent of 

rated life. 

Table 3.5.2 summarizes the performance of PMH sources.

Table 3.5.3. Performance Summary of Quartz Pulse-Start Metal Halide Lamps 

Lamp Power*

W 

CRI CCT†

K 

Initial 

Lumens

Life

hrs

Initial 

Efficacy

@ 100 hrs‡ 

LPW

Mean 

Efficacy

@ 40 % life§

LPW

50 Minimum 60 2,900 2,900 10,000 58 30

Median 70 3,300 3,300 10,000 66 41

Maximum 92 4,000 4,100 20,000 82 55

70 Minimum 65 2,800 2,610 3,200 64 40

Median 82 3,500 5,200 12,000 74 54

Maximum 96 6,500 7,400 20,000 106 79

100 Minimum 65 2,700 5,800 7,500 58 48

Median 73 3,200 8,500 15,000 85 58

Maximum 92 4,200 9,500 20,000 95 72

150 Minimum 60 2,800 5,400 2,800 73 55

Median 85 3,550 12,500 12,000 83 64

Maximum 96 6,500 15,000 20,000 100 75

175 Minimum 62 3,200 13,000 10,000 74 57

Median 65 4,000 16,000 15,000 93 71

Maximum 75 4,200 17,500 15,000 100 80

250 Minimum 60 3,000 16,500 10,000 66 52

Median 70 4,000 22,500 15,000 90 69

Maximum 94 6,500 26,000 20,000 104 80

320 Minimum 62 3,200 22,500 10,000 70 28

Median 70 4,000 30,000 20,000 94 72

Maximum 90 5,000 34,000 20,000 106 84

350 Minimum 62 3,200 25,000 10,000 88 57

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Table 3.5.4. Performance (continued)

Median 67 4,000 34,500 20,000 99 74

Maximum 90 5,000 51,628 30,000 120 98

400 Minimum 60 3,600 27,000 10,000 68 39

Median 65 4,000 39,850 20,000 100 75

Maximum 90 6,500 44,000 20,000 110 90

1000 Minimum 65 3,400 80,000 5,000 0 64

Median 65 3,900 110,000 12,000 110 88

Maximum 92 5,500 120,000 15,000 120 96

* A minimum of three different manufacturers had to produce the type and similar wattage to have that wattage class 

listed in this table. See Appendix D for a comprehensive list of lamp data from manufacturers’ catalogs.

† Correlated-color temperature is not a performance metric; the values are listed to show the range of available 

CCTs for the product.

‡ Initial efficacy is initial lumens divided by the lamp rated power (the power use of the ballast is not factored into 

this table).

§ Mean efficacy is the mean lumen value provided by the manufacturer divided by the lamp rated power (the power 

use of the ballast is not factored into this table). Manufacturers select the time at which they provide the mean lumen 

data, which vary between 40 and 50 percent of rated life. Lumen depreciation still occurs after this point. Also, not 

all manufacturers publish mean lumen values. The mean efficacy values can be higher than the initial efficacy 

values because the mean lumens were not provided, and this column is based on mean lumens.

3.5.2.3 Pulse-Start Ceramic Metal Halide Lamps

Advancements in arc tube materials led to the development of the ceramic arc tube. This 

material allows MH lamps to operate at even higher temperatures and vapor pressures. The 

technology is currently available only in wattages up to 400. Improvements in ceramic arc-tube 

design will soon make higher-power versions available. When operated to specifications, CMH 

lamps have a rated life from 6,000 to 20,000 hours with an efficacy of approximately 88 LPW. 

The LLD improves over quartz MH lamps to about 20 percent at 40 percent of rated life. In 

addition, CMH lamps have excellent CRI with an average CRI of 88. Typical R9 values are 

positive but very low. 

Recent advances in CMH lamp design allows for both high CRI (90), good R9 (over 40), 

greater efficacy and improved lumen maintenance. These new CMH lamps, currently produced 

by Philips, are medium wattage (315 and 210) and have an efficacy over 120 LPW. In contrast, 

other similar wattage CMH or PMH lamps are between 90 and 115 LPW. The lumen output on 

these new lamps is 90 percent at 40 percent of rated life; in contrast to typical 80 percent for 

CMH, 

75 percent for PMH, and 70 percent for MH. The developers of this new CMH lamp attribute the 

performance enhancements to operating the lamp on an electronic ballast; utilizing new chemical 

additives (presumably different MHs); and optimized arc tube shape.27 Table 3.5.3 summarizes 

the performance of CMH lamps.

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Table 3.5.5. Performance Summary of Pulse-Start Ceramic Metal Halide Lamps

Lamp Power*

W 

CRI CCT†

K 

Initial 

Lumens

Life

hrs

Initial Efficacy

@ 100 hrs‡ 

LPW

Mean Efficacy

@ 40-50% life§

LPW

50 Minimum 81 2,900 1,400 6,000 72 49

Median 85 3,000 2,225 10,000 76 52

Maximum 92 4,200 3,500 15,000 82 57

70 Minimum 80 2,900 2,850 9,000 51 37

Median 88 3,000 5,800 12,000 81 61

Maximum 95 4,300 7,300 24,000 104 93

100 Minimum 81 3,000 5,700 10,000 57 40

Median 85 3,000 8,200 12,500 82 62

Maximum 93 4,100 9,500 24,000 95 72

150 Minimum 80 2,800 9,100 5,000 61 55

Median 90 3,000 12,800 10,000 85 63

Maximum 96 5,500 15,500 24,000 103 83

250 Minimum 85 3,000 20,750 12,000 83 66

Median 90 4,050 22,500 20,000 90 73

Maximum 94 4,200 25,000 24,000 115 103

400 Minimum 85 3,000 34,800 15,000 87 70

Median 90 4,000 38,000 20,000 95 78

Maximum 90 4,200 41,000 20,000 102 82

* A minimum of three different manufacturers had to produce the type and similar wattage to have that wattage class 

listed in this table. See Appendix D for a comprehensive list of lamp data from manufacturers’ catalogs.

† Correlated-color temperature is not a performance metric; the values are listed to show the range of available 

CCTs for the product.

‡ Initial efficacy is initial lumens divided by the lamp rated power (the power use of the ballast is not factored into 

this table).

§ Mean efficacy is the mean lumen value provided by the manufacturer divided by the lamp rated power (the power 

use of the ballast is not factored into this table). Manufacturers select the time at which they provide the mean lumen 

data, which vary between 40 and 50 percent of rated life. Lumen depreciation still occurs after this point. Also, not 

all manufacturers publish mean lumen values. The mean efficacy values can be higher than the initial efficacy 

values because the mean lumens were not provided, and this column is based on mean lumens.

3.5.3 Electrical Characteristics

The additional electrode located at one end of the arc tube in probe-start MH lamps 

allows operation without an ignitor circuit, making it possible for MH lamps to share the same 

ballast with MV lamps, within limits. However, MH ballasts typically have more rigorous 

operating requirements than MV ballasts. Thus, MV lamps can operate universally on similar 

wattage probe-start MH ballasts, but the reverse is true only with specially designed MH lamps. 

Lamp manufacturers took advantage of this and produced MH lamps that could operate on MV 

lamp ballasts. However, replacement raises issues of economy and utility, in addition to 

technological issues. The engineering analysis (chapter 4) of this document addresses these 

issues.

Pulse-start MH lamps lack the secondary electrode found in probe-start MH lamps, 

resulting in different electrical requirements and performance. Using an ignitor, a high-voltage 

pulse (typically in excess of 3 kilovolts) is applied directly across the main electrodes to initiate 

the arc, resulting in faster starting and re-strike times than for probe-start MH lamps. The warmup and re-strike time are 2 minutes and 3–4 minutes, respectively. That is an improvement over 

EE-DET-03-001 COMMENT 19
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the typical probe-start MH warm-up time of 4 minutes and a restrike time of 15–20 minutes; 

these results are also better than those of typical MV and HPS lamps. 

Common probe-start MH ballast systems for mid-wattage MH lamps include CWA and 

CW ballasts. Pulse-start MH lamps require ballasts similar to those for probe-start lamps, but 

also require an ignitor. Common pulse-start ballasts include CWA, HX, RX, regulated lag 

(magnetically regulated), and CW ballasts. Electronic ballasts also are available (in limited 

wattages) for these lamps, promising even better performance in the specific lamp/ballast 

combination (Appendix E). In addition, high-ignition voltages necessitate the use of high-voltage 

lamp sockets. 

3.5.4 Other Issues

Mercury is a double-sided issue in the lighting industry. Although HID lamps are more 

efficacious than halogen/incandescent (mercury free) lamps; mercury is needed in most vapor 

discharge sources (both low and high pressure). However, the use of these sources displaces 

more mercury released in energy production, so it still is beneficial to use a discharge source 

over incandescent/halogen. The amount of mercury in an HID source varies by lamp type as well 

as by wattage. 

Table 3.5.4 is from a 2008 report about trends in mercury use in products.52

Table 3.5.5

 In both 2001 

and 2004, lamps represented about 8 percent of the total use of mercury in products. There was 

roughly a 6 percent reduction in overall mercury usage in lamps between 2001 and 2004. The 

total use of mercury in HID lamps increased by 15 percent, whereas the use by fluorescent lamps 

declined by 14 percent between 2001 and 2004. The reasons behind total mercury usage being 

relatively flat, while these two lamp types changed significantly is that fluorescent lamps have 

been designed to use less mercury and more HID lamps were specified between the two years. 

 breaks down the mercury sold by HID lamp type. The vast majority of mercury 

usage in HID lamps is in the MH family.

Table 3.5.6. Total Mercury Sold in Lamps 

All Lamps Total Mercury Weight

lbs (kg)

2001 2004

Fluorescent 16,657 (7,555.48) 14,372 (6,519)

High Intensity Discharge 2,749 (1,246.93) 3,156 (1,431.54)

Compact Fluorescent 877 (397.80) 1,479 (670.86)

Neon 1,103 (500.31) 1,070 (485.34)

Short Arc 10 (4.54) 17 (7.71)

Miscellaneous 42 (19.05) 24 (10.89)

Total 21,438 (9,724.11) 20,118 (9,125.37)

Table 3.5.7. Total Mercury Sold by HID Lamp Type 

Lamp Type 2001 Total Mercury 

Sold by Weight

lbs (kg)

Portion of 

total HID

% 

2004 Total Mercury 

Sold by Weight

lbs (kg)

Portion of 

total HID

% 

MH 2,145 (972.95) 78 2,426 (1100.42) 77

Ceramic MH N/A 0 31 (14.06) 1

HPS 401 (181.89) 15 453 (205.47) 14

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Table 3.5.8. Total (continued)

MV 203 (92.08) 7 213 (96.62) 7

Total 2,749 -- 3,156 --

Mercury is integral to the three lamp types, though more for some than others. HPS 

lamps have been designed with low mercury and even no mercury content (labeled as such in 

catalogs). The typical amount of mercury for HPS lamps from 35 to 1000 W is between 10 and 

50 mg. By definition, MV lamps must have mercury in them. The typical mercury content in MV 

lamps from 50 to 1000 W is between 50 and 150 mg. Because MH technology is related to MV 

lamps, mercury plays a vital role in these lamps. The typical mercury content in MH lamps from 

39 to 50 W is between 1 to 10 mg; 70 to 250 W is between 5 to 50 mg; 350 to 400 W is between 

30 to 100 mg; and 400 to 2000 W is between 100 to 150 mg. 

In response to reducing mercury in products, mercury-free HID lamps have been 

investigated. A 2007 research paper considered replacing mercury with noble gases. Noble gases 

include helium (He), neon (Ne), argon (Ar), krypton (Kr), xenon (Xe), and radon (Rn). The study 

experimented with Ne, Ar, and Xe. “The presented results emphasize Ar and Xe as proper Hg 

substitute candidates.”53

Lead is sometimes present in these lamps as solder for the coupling. A TCLP test on 

these lamps classifies them as hazardous waste for mercury and lead. Therefore, they are subject 

to the Universal Waste Rule (EPA, July 6, 1999). State and local regulations will vary on their 

disposal, but recycling is recommended. 

A small percentage of MH lamps contain the radioactive isotope, krypton 85. The MH 

lamps that contain this radioactive isotope are primarily used in special applications of theatrical 

and film luminaires.

3.6 HIGH-INTENSITY DISCHARGE LAMP BALLASTS

High-intensity discharge lamp ballasts apply sufficient voltage for lamp ignition, regulate 

the operating current, and essentially relight the lamp at each one-half cycle of the voltage. A 

1983 paper focusing on the relationship between HPS lamp voltage rise and the ballast 

summarized the relationship: “A lamp and ballast cannot be considered separate elements but 

each contributes to a dynamic system influencing each other in achieving total system 

performance.”15 Although this quote was in relation to HPS lamps, it is applicable to HID lamps 

in general. For HPS and PMH lamps, an additional ignitor circuit generates the high-voltage 

starting pulse necessary to initiate the arc discharge. Typical input voltages for HID lighting 

systems are 120, 208, 240, 277, and 480 V. 

There are two types of HID ballasts: magnetic and electronic. The majority of ballasts 

sold for HID lamps are magnetic, also known as core-and-coil. The ballasts operate at 60 Hz. 

Within the magnetic HID ballast family, there are seven sub-types of ballasts: (1) high-reactance 

autotransformer; (2) reactor-normal power factor; (3) reactor-high power factor; (4) regulatedlag, also known as magnetically regulated; (5) CWA; (6) constant-wattage isolated; and (7) super 

constant-wattage autotransformer. CWA has become the most popular HID ballast for lamp 

EE-DET-03-001 COMMENT 19
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power levels above 150 W.54 Ballast efficiency varies with rated lamp power, less ballast loses 

occur as the rated power increases.b

The other major type of ballast is electronic; currently, electronic ballasts only exist for 

pulse-start lamps. Within the electronic HID ballast category, there are only two types: low 

frequency (less than or equal to 400 Hz) and high frequency (equal to or above 100 kHz). Most 

electronic HID ballasts are for MH lamps, with a small portion for HPS lamps, and no electronic 

ballasts for MV lamps. A 1990 paper comparing some of the first electronic HID ballast with 

conventional ballasts found that when electronic ballasts for high pressure lamps will be different 

than electronic ballasts for low pressure discharge lamps. For electronic ballasts, “more 

sophisticated, forms of generators for lamp operation must be used than in the field of lowpressure discharge lamps.”

 

55 Unlike electronic ballasts for FL lamps, HID electronic ballasts do 

not always make the lamp-ballast system more efficient. In 2006, the Lighting Research Center 

(LRC) compared 70 W MH lamps from various manufacturers operating on both magnetic and 

electronic ballasts by different manufacturers. The LRC study found that ballast efficiency was 

directly affected by the type of ballast: “Because of design and manufacturing practicalities, the 

ballast efficiency of magnetic ballasts is approximately 10 percent lower than that of electronic 

ballasts.”56 There are some system (lamp plus ballast) efficiency gains from converting from 

magnetic to electronic HID ballasts, but there are other electrical issues associated with 

electronic HID ballasts that affect HID lamps. During the public meeting for the framework 

document for the MH lamp fixture energy conservation standard, both the disadvantages and 

advantages of electronic HID ballasts were discussed. A comment from the meeting sums up the 

issue of electronic HID ballasts: “Some electronic ballasts do improve lamp maintenance and 

lamp life, others do not; as a mater of fact, some electronic ballasts can decrease lamp life.”57

One of the desirable features of HID lamps compared to other sources is the long-rated 

operating lifetimes of the lamps. Electronic ballasts can both start and operate a lamp more 

“gently” than a magnetic ballast, with positive benefits in the lamp performance. A study from 

the mid-1990s found electronic ballasts can extend lamp life once other electrical issues are 

addressed: “[W]ith attention paid to the proper features of the electronic ballast, namely high 

extinguishing resistance, it can be concluded that lamp service life with electronic ballasts will 

be 1.5 to 2.0 times longer than with conventional ballasts.”58

One of the principal disadvantages of electronic ballasts is that the lamps operate at high 

frequency and this creates acoustic resonance. The LRC study comparing 70 W lamps operating 

on electronic ballasts describes the negative issue of acoustic resonance: “At frequencies above 

4 kHz, standing pressure sound waves (acoustic resonances) build inside the lamp’s arc tube, 

which can lead to visible distortions and instability of the electrical discharge, light flickering, 

and possible cracking of the tube.”33 As stated earlier, lamp life can be extended via the use of an 

electronic ballast but also cut short if special precautions in either the ballast or lamp design are 

not utilized. 

Ballast design is not the purview of the document. Therefore, only aspects of the lamp 

that directly affect acoustic resonance are reviewed here, specifically arc tube size and geometry.

Pressure waves are created in the lamp when the resonant frequency is close to the operating 

 

b Ballast Efficiency – the ratio of lamp rated power/ballast input power (Pout/Pin).

EE-DET-03-001 COMMENT 19
3-35

frequency. These pressure waves move through the lamp distorting the arc tube path, causing 

flicker and, in extreme cases, arc contact with the tube wall. If the arc touches the tube wall, the 

arc tube can crack. A cracked arc tube seriously affects the lamp and can lead to non-passive 

failure (i.e., rupture) of the arc tube and bulb wall. 

Lamp Current Crest Factor (LCCF)c

31

is an aspect of either magnetic or electronic ballasts 

that can affect both the HID lamp life and lumen maintenance. Many within the lighting industry 

consider lamp life and lumen deprecation the primary performance metrics of a lamp-ballast 

system. The lamp electrodes can be damaged by high LCCFs which directly affects lumen 

maintenance and lamp life. LCCF values can range from 1.0 to infinity; however, ANSI specifies 

maximum LCCF values. For example, ANSI C78.43-2007 covers single-ended MH lamps from 

39 to 1650 watts and sets a maximum LCCF of 1.8 for these lamps. A 2008 paper comparing the 

effects on lamp life and lumen depreciation for two different types of ballasts for 400W MH 

lamps articulated the value of an LCCF limit: “The rationale for placing an upper limit upon the 

LCCF is to prevent the lamp current from falling to an unsuitably low value for a significant 

period of time on a half-cycle basis.”31 Lower LCCF values are better for the lamp electrode and 

thus the lamp life and lumen maintenance. The LRC study articulated the waveform and LCCF 

issues of magnetic and electronic ballasts in their comparison: “An ideal sinusoidal waveform 

(and therefore, a magnetic ballast) cannot have an LCCF below 1.4. Most magnetic ballasts have 

LCCFs ranging from 1.5 to 1.7. The square current waveform of an electronic ballast allows the 

LCCF to approach 1.0.”33 

Appendix E provides summary descriptions of each ballast type.

 

c Lamp Current Crest Factor (LCCF) – the ratio of the peak lamp current to the root-mean-square (rms) value of the 

lamp current

EE-DET-03-001 COMMENT 19
4-1 

CHAPTER 4. ENGINEERING ANALYSIS

This chapter provides the technical support documentation for the engineering analysis of 

high-intensity discharge (HID) lamps. For purposes of this determination, the engineering 

analysis identifies representative equipment classes with baseline lamps and energy-efficient 

substitutes, and develops power rating estimates for the equipment analyzed. The outputs from 

the engineering analysis are critical inputs to subsequent cost-benefit calculations for individual 

consumers. 

In this determination, DOE developed end-user prices for analyzed lamp, lamp-andballast, and luminaire designs using a commercially-available pricing database. By combining 

the results of the engineering analysis and the equipment price determination, DOE derived the 

necessary inputs for use in the life cycle cost (LCC) analysis and national energy savings/net 

present value (NES/NPV) analysis. The LCC and NES/NPV analyses are discussed in chapters 5 

and 6 of this determination, respectively. 

4.1 ENGINEERING ANALYSIS FRAMEWORK

DOE based the engineering analysis on commercially-available equipment that 

incorporate the design options identified in the market assessment (chapter 2) and technology 

assessment (chapter 3). For this determination, the engineering analysis employed the following 

approach: 

1. Representative Equipment Categories. DOE reviewed potentially covered lamps 

and selected certain broad categories as “representative,” based on their market 

share, wattage, and color characteristics. 

2. Baseline Lamps. Within the broad equipment categories, DOE selected baseline 

lamps as representative equipment. Generally, a baseline lamp is one that 

represents the typical lamp sold. DOE selected specific characteristics such as 

certain color rendering index, operating lifetimes, and light outputs to characterize 

the most common lamps consumers purchase. DOE selected multiple baseline 

lamps to ensure consideration of different high-volume lamps and their associated 

consumer economics. 

3. Substitute Lamps. DOE selected more efficacious substitute lamps for each 

baseline lamp in the representative equipment classes. In identifying more 

efficacious lamp designs, DOE recognizes that a lamp’s lumen package and 

performance characteristics are important design criteria for consumers. For 

example, if consumers do not have the option to purchase substitute lamps, lampand-ballast systems, or luminaires with similar lumen packages under an energy 

conservation standard, consumers would need to change the lighting design to 

maintain a similar light output. Therefore, DOE established energy-efficient 

designs for the LCC analysis so that potential light output is equal to or within 90 

percent (or greater) of the mean light output of the baseline system. 

EE-DET-03-001 COMMENT 19
4-2 

The sections that follow discuss how DOE applied this methodology to create the 

engineering analysis.

4.1.1 Representative Equipment Categories

For this determination, DOE developed representative equipment classes that represent 

the plurality of U.S. HID lamp shipments. The equipment classes are categorized broadly by 

lamp wattage and baseline lamp technology. HID lamp wattages were segregated into three 

categories: low (<150W), medium (150 – 500W), and high (>500W). Based on its market 

assessment, DOE selected medium wattage categories as most representative of lamp shipments, 

comprising an estimated 38 percent of U.S. HID lamp shipments. 

The equipment categories are further specified by lamp technology—in this case, 

mercury vapor (MV) and probe-start metal halide (MH) lamps—which broadly characterizes the 

color requirements of HID lamp applications. For the MV baseline equipment classes, DOE 

assumed that color appearance and color rendering are not critical (e.g., roadway lighting and 

industrial applications), which allows for energy-efficient substitute lamp types with poor or 

moderate color rendering (e.g., high-pressure sodium (HPS) and probe-start MH). DOE selected 

probe-start MH as the baseline lamp technology for equipment classes where color appearance 

and color rendering may be important (e.g., interior and exterior “white light” applications in 

commercial facilities).

4.1.2 Baseline Lamps

Within the broad wattage and lamp technology categories, DOE created multiple 

equipment classes to capture high-volume equipment and their associated economic impacts. The 

equipment classes are identified by a nominal initial light output and an associated baseline lamp 

(MV or probe-start MH), and are presented in section 2.1.3 below. 

In this determination, DOE based its equipment classes on lamps. This is because the 

potential energy conservation standards would apply only to lamps. However, DOE used a 

systems approach in analyzing the representative equipment classes because both lamps and 

ballasts determine a system’s energy use and light output. Accordingly, DOE paired lamps with 

ballasts to develop representative lamp-and-ballast systems, which demonstrate the actual energy 

usage and light output of operating lamps. It should be noted that, for this analysis, DOE only 

considered magnetic ballasts. Although electronic ballasts exist for some HID lamps, these types 

of ballasts represent a very small segment of the market.

4.1.3 Substitute Lamps

For each representative equipment class, DOE considered the following when identifying 

acceptable substitute HID lamps:

• Light Output: Some substitutions are not suitable because of light output differences. 

Substitute lamps with significantly increased light output may not be appropriate, despite 

EE-DET-03-001 COMMENT 19
4-3 

their higher efficacy. Higher light output for a system in an existing luminaire may cause 

glare, which may be a safety hazard and/or create lighting quality issues. In this 

determination, DOE analyzed lamp-and-ballast systems that both save energy and 

maintain comparable light output. In particular, DOE considered lamp-and-ballast 

designs that emit mean lumens equal to, greater than, or no more than 90 percent less 

than the light output of the baseline system. DOE maintains light output across efficacy 

levels to ensure that products supply comparable service. 

In assessing light output, DOE makes a distinction between mean and initial lumens. 

DOE uses initial lumens in its test procedures to measure compliance with a standard. 

This is consistent with consensus industry standards on efficacy measurements. 

Therefore, DOE uses initial lumens to identify energy-efficient substitutes in this 

determination. However, the light output of a lamp decreases over time. To account for 

this real-world depreciation in lumens, DOE used mean lumens in determining equivalent 

substitutes in the LCC and NES/NPV analyses. 

• Color Characteristics

•

: Some substitutions are not suitable because of color (i.e., spectral) 

differences, which may exclude some technology options for specific applications. For 

example, an HPS system (with its characteristic amber color appearance and poor color 

rendering) would not be an appropriate substitute for a MH system in color-critical 

“white light” applications (e.g., an interior lobby). However, HPS can be a viable 

substitute for MH in some exterior applications (e.g., parking structures), where energy 

efficiency may be a higher priority than color quality. 

Fixture Constraints

•

: Some substitutions are not suitable because of fixture constraints. A 

substitution of a different HID technology type may mean the use of a lamp with a 

different socket type (e.g., mogul, medium, pin) that does not exist in the luminaire. 

Replacement lamp options and their ballast may not fit in the existing luminaire. Some 

HID luminaires are not enclosed and cannot provide protection against the possibility of a 

lamp rupture for some technology replacements. 

Economics

4.2 EQUIPMENT PRICE DETERMINATION

: Lighting economics could significantly affect the choice of a substitution. 

Lamps that provide acceptable light output and/or color quality can have a high first cost, 

making their LCC too high to be a reasonable substitute. Material and maintenance costs 

associated with shorter life and increased lamp replacements can also adversely affect the 

LCC of the substitute product. 

For substitutions requiring luminaire replacement, it is important to note that 

manufacturers typically package fixtures without a lamp, i.e., they package and sell only the 

fixture, which includes the housing, ballast, and other associated electrical and mechanical 

components (e.g., wires, sockets, mounting brackets, fasteners). Therefore, to calculate the total 

price of a luminaire for the LCC analysis, DOE determined the price of associated lamps 

separately and added this to the fixture price.

EE-DET-03-001 COMMENT 19
4-4 

4.3 ENGINEERING ANALYSIS RESULTS

For purposes of this determination, DOE identified seven representative equipment 

classes of HID lamps that represent an estimated 35% of U.S. HID lamp shipments. The 

analyzed baseline lamps and their energy-efficient substitutes fall in two broad wattage 

categories (<150W and 150W-500W) and are classified by initial lumen output. The engineering 

analysis also captures associated lamp-and-ballast input power ratings, light output, lamp life and 

pricing information needed for the LCC and NES/NPV analyses. Table 4.3.1 summarizes the 

engineering data for all baseline and substitute equipment. 

Table 4.3.1. HID Lamps Determination Engineering Analysis Results

Wattage 

Category

Baseline 

Lamp Type

Equipment

Class ID

Approx. 

Light Output 

(mean 

lumens)

Efficiency 

Level

Lamp 

Description

System 

Input Power 

Rating (W)

Medium 

Wattage

(150W500W)

MV 1 6,800 Baseline 175W MV 202

Substitute 1 150W PMH 185

Substitute 2 100W HPS 122

2 10,000 Baseline 250W MV 283

Substitute 1 150W PMH 185

Substitute 2 150W HPS 185

3 14,400 Baseline 400W MV 454

Substitute 1 250W PMH 285

Substitute 2 150W HPS 185

Probe-start 

MH

4 8,800 Baseline 175W MH 208

Substitute 1 150W PMH 185

Substitute 2 100W HPS 122

5 13,700 Baseline 250W MH 291

Substitute 1 175W PMH 209

Substitute 2 150W HPS 185

6 23,500 Baseline 360W MH 400

Substitute 1 320W PMH 367

Substitute 2 250W HPS 295

7 25,200 Baseline 400W MH 456

Substitute 1 320W PMH 367

Substitute 2 250W HPS 295

EE-DET-03-001 COMMENT 19
5-1 

CHAPTER 5. LIFE-CYCLE COST ANALYSIS AND PAYBACK PERIOD 

ANALYSIS

5.1 Method and Data

To assess the life-cycle cost (LCC) to end users of designs that improve lamp efficacy, 

DOE conducted an analysis that compares the incremental first cost to the value of electricity 

savings. In particular, the LCC analysis compares the incremental first cost to the discounted 

value of electricity savings over the life of the lamp system. The simple payback period (PBP) 

analysis calculates the amount of time required for the electricity savings to equal the 

incremental first cost, assuming the electricity savings in future years is constant and equal to 

that in the first year.

The analysis requires several inputs:

1. Typical annual operating hours; 

2. Typical price for the lamp and new fixture; 

3. Typical lamp lifetime;

4. Typical ballast lifetime;

5. Contractor mark-up; 

6. Sales tax;

7. Typical maintenance costs;

8. Electricity price; and

9. Discount rate (to convert future operating cost savings into present value terms). 

DOE discusses these variables below.

5.1.1 Annual Operating Hours

HID lamps were assumed to operate in both exterior and interior environments, with the 

following assumed operating schedules. 

• Annual hours of use: 4,200 – Exterior applications

• Annual hours of use: 5,840 – Interior applications 

The exterior operating hours value was derived by assuming that the fixture is controlled 

by a photocell and operates roughly from dusk to dawn. This translates to roughly 4,200 hours 

annually59. This is based on a typical operation of 11.5 hours per day. The interior operating 

hours value was derived from published research, as reported in three different documents 

focusing on high-bay luminaires. Reported operating periods ranged between 5,000 and 6,000 

hours60,61, with one document specifically citing 16 hours per day as typical operation62. DOE’s 

assumed operation of 16 hours per day (5,840 hours per year) is in line with surveyed research, 

as well as the 2004 draft report, which used a value of 5;080 hours per year. 

EE-DET-03-001 COMMENT 19
5-2 

5.1.2 Lamp Prices

Published prices for lighting equipment vary widely, depending on their source. DOE 

surveyed several typical pricing data sources in developing representative, conservative prices 

for HID lamps in this determination. 

First, DOE reviewed a commonly cited construction estimation reference book, RSMeans. Table 5.1.1 presents HID lamp prices from the 2008 version. 

Table 5.1.1. Lamp Prices from RS-Means

MV Lamps MH Lamps HPS Lamps

Lamp Power

W

Price

$

Lamp Power

W

Price

$

Lamp Power

W

Price

$

--- --- --- --- 70 $44.50

100 $31.00 --- --- --- ---

--- --- 175 $38.25 --- ---

250 $41.25 --- --- 250 $50.50

400 $33.00 400 $41.00 400 $52.00

1000 $77.25 1000 $99.00 1000 $143.00

DOE also reviewed the prices on municipal web sites. These are procurement contracts 

that the different municipalities negotiate with distributors. As illustrated in Table 5.1.2, these 

values can vary widely from state to state for the same lamp63,64,65,66,67,68

Table 5.1.2. Municipal Lamp Prices

. 

Lamp 

Type

Lamp 

Power

W

Arkansas 

Price

$

West Virginia

Price

$

North Dakota 

Price

$

Oklahoma 

Price

$

Ohio 

Price

$

New Jersey 

Price

$

MV 250 44.15 18.89 --- --- --- ---

MV 400 45.69 19.54 --- --- --- ---

MH 175 31.68 15.31 --- --- --- ---

MH 250 35.87 15.20 --- --- --- ---

MH 360 39.11 13.95 --- --- --- ---

MH 400 88.52 32.56 --- --- --- ---

HPS 100 --- 10.17 --- 8.87 11.65 ---

HPS 150 --- --- 9.30 8.87 11.65 ---

HPS 250 --- 10.47 --- 9.89 --- 7.49

PMH 150 45.93 19.19 --- --- --- ---

PMH 175 39.95 40.20 --- --- --- ---

PMH 250 66.52 66.95 --- --- --- ---

PMH 320 68.79 69.24 --- --- --- ---

Finally, DOE surveyed lamp prices on publicly-accessible websites for W.W. Grainger, 

Inc. (Grainger) and GoodMart.com69,70

Figure 5.1.1

in March 2010. These online retailer price catalogues 

were selected because they offer a wide range of products (i.e., lamps, ballasts, and fixtures) for 

multiple types of HID lamps and wattages. presents the lamp type, wattage, and 

price from the data surveyed. This methodology of reviewing Grainger for prices is consistent 

with the pricing methodology used in previous rulemakings, including the Small Electric Motor 

Determination. 71 FR 38799, 38803 (July 10, 2006). 

EE-DET-03-001 COMMENT 19
5-3 

Comparison of Lamp Power (W) and Price ($)

0

50

100

150

200

250

300

350

400

0 200 400 600 800 1000 1200

Lamp Rated Power (W)

Initial Price (U.S. $)

MH

MV

HPS

PMH

Figure 5.1.1. Lamp Wattage/Price Comparison 

DOE developed trendlines to interpolate the price for different wattages. The interpolated 

lines resulted in the following functions per lamp type where “x” is the lamp wattage and “y” is 

the lamp price:

• Mercury Vapor: y = 4.1461x0.4271 R2

= 0.2472 

• Probe-Start Metal Halide: y = 15.366x0.1915 R2

= 0.1059 

• Pulse-Start Metal Halide: y=5.4365x0.456 R2=0.5063 

• High-Pressure Sodium: y=3.6562x0.525 R2

=0.4029 

Based on its analysis, DOE chose to base HID lamp prices for the LCC-PBP analysis on 

the wattage-price functions developed from Grainger and Goodmart.com price data. This online 

retailer price data is publicly available (requiring no special log in to access the data) and offers 

product information that could be applied to the full range of HID lighting system technologies 

and components. Table 5.1.3 summarizes the assumed prices for the evaluated lamps.

Table 5.1.3. Lamp Price derived from Online Distributor Web Sites

Baseline Option Substitute Option

Lamp 

Type

Lamp Power

W

Lamp Price

$

Lamp Type Lamp Power

W

Lamp Price

$

MV 175 $37.64 HPS 100 $41.02

MV 250 $43.83 HPS 150 $50.75

MV 400 $53.58 HPS 250 $66.37

MH 175 $41.31 PMH 150 $53.41

MH 250 $44.24 PMH 175 $57.30

MH 360 $47.43 PMH 250 $67.42

MH 400 $48.40 PMH 320 $75.45

EE-DET-03-001 COMMENT 19
5-4 

5.1.3 Ballast Prices

As with HID lamps, DOE evaluated pricing for HID ballasts from typical, publiclyavailable sources. First, DOE reviewed a commonly cited construction estimation reference 

book, RS-Means. However, RS-Means only had prices for fluorescent ballasts, not HID ballasts. 

DOE also surveyed ballast prices on publicly-accessible websites for W.W. Grainger, 

Inc. and GoodMart.com in April 2010. Figure 5.1.2 provides the lamp type, wattage, and price 

from the data surveyed. 

Comparison of Ballast Lamp Rated Power (W) and Price ($)

0

100

200

300

400

500

600

700

800

900

1000

0 500 1000 1500 2000

Lamp Rated Power (W)

Ballast Price (U.S. $)

MH

HPS

PMH

Figure 5.1.2. Ballast Prices

Based on the data graphed, DOE used trendlines to interpolate the ballast price for 

different lamp wattages. The interpolated lines resulted in the following functions per lamp type 

where “x” is the lamp wattage and “y” is the fixture price:

• Probe-Start Metal Halide: y = 0.1582x+147.77 R2

= 0.3377 

• Pulse-Start Metal Halide: y =0.1775x+131.89 R2= 0.7368 

• High-Pressure Sodium: y=0.4347x+151.61 R2=0.5627 

As with HID lamps, DOE chose to base HID ballast prices on the wattage-price functions 

developed from Grainger and Goodmart.com price data. Although some MV ballasts exist, the 

long-term supply is restricted because these ballasts have not been manufactured or imported 

since December 31, 2007. DOE assumes that MV ballast shipments will decline to zero by the 

effective date of a possible energy conservation standard. 

EE-DET-03-001 COMMENT 19
5-5 

Table 5.1.4. Lamp Price derived from Online Distributor Web Sites

Baseline Option Substitute Option

Lamp 

Type

Lamp 

Wattage

W

Ballast Price

$

Lamp Type Lamp Power

W

Ballast Price

$

MV 175 --- HPS 100 195.08

MV 250 --- HPS 150 216.82

MV 400 --- HPS 250 260.29

MH 175 175.46 PMH 150 158.52

MH 250 187.32 PMH 175 162.95

MH 360 204.72 PMH 250 176.27

MH 400 211.05 PMH 320 188.69

5.1.4 Fixture Prices 

As with HID lamps and ballasts, DOE evaluated pricing for HID fixtures (luminaires) 

from typical, publicly-available sources. First, DOE reviewed a commonly cited construction 

estimation reference book, RS-Means. Table 5.1.5 presents HID fixture prices from the 2008 

version. 

Table 5.1.5. Prices from RS-Means for HID Fixtures

MH Fixtures HPS Fixtures

Roadway / Area Floodlighting Roadway / Area Floodlighting

Power

W

Price

$

Power

W

Price

$

Power

W

Price

$

Power

W

Price

$

175 325 70 224

400 465 400 405 400 485 400 365

1,000 525 1,000 555 1,000 550 1,000 625

DOE also surveyed fixture prices on publicly-accessible websites for W.W. Grainger, 

Inc. and GoodMart.com in March 2010. Figure 5.1.3 provides the lamp type, wattage, and price 

from the data surveyed. 

EE-DET-03-001 COMMENT 19
5-6 

Comparison of Interior Fixture Power and Price

0

100

200

300

400

500

600

700

0 100 200 300 400 500

Fixture Power (W)

Fixture Price (U.S. $)

MH

HPS

Figure 5.1.3. Lamp Wattage/Price Comparison 

Based on the data graphed, DOE used trendlines to interpolate the price for different 

fixture wattages. The interpolated lines resulted in the following functions per lamp type where 

“x” is the lamp wattage and “y” is the fixture price:

• Metal Halide: y = 0.5176x+180.75 R2= 0.0942 

• High-Pressure Sodium: y=0.0944x+204.18 R2=0.0271 

As with HID lamps, DOE chose to base HID fixture prices on the wattage-price functions 

developed from Grainger and Goodmart.com price data. DOE added $100 to the cost (e.g., 

180.75+100 = 280.75) for the exterior prices regardless of the source technology. DOE assumed 

that probe-start MH luminaires were 20 percent less expensive than pulse-start MH fixtures for 

both interior and exterior luminaires. Prices for comparable MV fixtures were generally not 

available; consequently, DOE assumed that the prices for MV fixtures were 67% (two-thirds) of 

the comparable pulse-start fixtures. Table 5.1.6 presents a summary of assumed HID fixture 

prices used in the LCC-PBP analysis.

Table 5.1.6. Lamp Price derived from Online Distributor Web Sites

Baseline Option Substitute Option

Lamp 

Type

Lamp 

Wattage

Interior

Fixture Price

Exterior

Fixture Price

Lamp 

Type

Lamp 

Wattage

Interior

Fixture Price

Exterior

Fixture Price

MV 175 --- $248.81 HPS 100 $213.62 $313.62

MV 250 --- $274.82 HPS 150 $218.34 $318.34

MV 400 --- $326.84 HPS 250 $227.78 $327.78

MH 175 $217.09 $297.09 PMH 150 $258.42 $358.42

MH 250 $248.14 $328.14 PMH 175 $271.36 $371.36

MH 360 $293.69 $373.69 PMH 250 $310.18 $410.18

MH 400 $310.26 $390.26 PMH 320 $346.41 $446.41

EE-DET-03-001 COMMENT 19
5-7 

5.1.5 Lamp Lifetime

Lifetime for HID lamps is determined when 50 percent of a sample population has failed. 

Within the lighting industry, this metric is known as B50. 

After issuing the 2003 draft report, DOE received comments about the rated lamp 

lifetimes. Routine group relamping time for MV and HPS lamps is typically four years and MH 

lamps is two years. (Caltrans, No. 8 at p. 2; Allegheny, No. 12 at p.1) Allegheny further stated 

that the lamp life is generally the rated lamp life by the manufacturer. 

DOE surveyed the available lamp catalogs and found that for any given wattage, the rated 

life of the lamp can vary. Table 5.1.7– Table 5.1.13 list the minimum, median, and maximum 

rated lifetimes for the different lamps. DOE is using the median rated life as the basis for 

relamping schedules in the LCC-PBP modeling. 

Table 5.1.7. Lamp Life Data (175W MV Baseline) 

Lamp Type Lamp Power

W

Minimum 

Rated Life

Median 

Hours

Rated Life

Maximum 

Rated Life

Hours

Baseline

Hours

MV 175 16,000 24,000 24,000

Substitute 1 PMH 150 2,800 12,000 20,000

Substitute 2 HPS 100 9,000 24,000 40,000

Table 5.1.8. Lamp Life Data (250W MV Baseline) 

Lamp Type Lamp Power

W

Minimum 

Rated Life

Median 

Hours

Rated Life

Maximum 

Rated Life

Hours

Baseline

Hours

MV 250 12,000 24,000 24,000

Design Option 1 PMH 150 2,800 12,000 20,000

Design Option 2 HPS 150 9,000 24,000 40,000

Table 5.1.9. Lamp Life Data (400W MV Baseline) 

Lamp Type Lamp Power

W

Minimum 

Rated Life

Median 

Hours

Rated Life

Maximum 

Rated Life

Hours

Baseline

Hours

MV 400 12,000 24,000 24,000

Design Option 1 PMH 250 10,000 15,000 20,000

Design Option 2 HPS 150 9,000 24,000 40,000

Table 5.1.10. Lamp Life Data (175W Baseline) 

Lamp Type Lamp Power

W

Minimum 

Rated Life

Median 

Hours

Rated Life

Maximum 

Rated Life

Hours

Baseline

Hours

MH 175 10,000 10,000 10,000

Design Option 1 PMH 150 2,800 12,000 20,000

Design Option 2 HPS 100 10,000 24,000 40,000

EE-DET-03-001 COMMENT 19
5-8 

Table 5.1.11. Lamp Life Data (250W MH Baseline) 

Lamp Type Lamp Power

W

Minimum 

Rated Life

Median 

Hours

Rated Life

Maximum 

Rated Life

Hours

Baseline

Hours

MH 250 10,000 10,000 15,000

Design Option 1 PMH 175 10,000 15,000 15,000

Design Option 2 HPS 150 9,000 24,000 40,000

Table 5.1.12. Lamp Life Data (360W Baseline) 

Lamp Type Lamp Power

W

Minimum 

Rated Life

Median 

Hours

Rated Life

Maximum 

Rated Life

Hours

Baseline

Hours

MH 360 20,000 20,000 30,000

Design Option 1 PMH 320 10,000 20,000 20,000

Design Option 2 HPS 250 9,000 24,000 40,000

Table 5.1.13 Lamp Life Data (400W Baseline) 

Lamp Type Lamp Power

W

Minimum 

Rated Life

Median 

Hours

Rated Life

Maximum 

Rated Life

Hours

Baseline

Hours

MH 400 8,000 20,000 20,000

Design Option 1 PMH 320 10,000 20,000 20,000

Design Option 2 HPS 250 9,000 24,000 40,000

5.1.6 Ballast Lifetime

In the technical support document for the 2003 draft report, DOE assumed a ballast 

lifetime of 50,000 hours71. During the public meeting for the metal halide lamp fixture 

rulemaking framework, a manufacturer stated that NEMA, when in California for a meeting 

related to a similar California rule, agreed that the typical lifetimes for magnetic HID ballasts 

was 60,000 hours and electronic HID ballasts was between 30,000 and 50,000 hours72. DOE 

reviewed California’s Database for Energy Efficient Resources website which lists the life of 

electronic ballasts at 70,000 hours and magnetic ballasts at 45,000 hours73

The Environmental Protection Agency (EPA) developed a lighting maintenance checklist 

as part of the EPA’s Green Lights program. Within the document, the EPA acknowledges that 

there is no reliable long-term test data and recognizes the manufacturer’s claims about lifetime. 

Additionally, the EPA states, “...that ballast failure rate can be expected to be small in the first 

70% of average life and increase beyond that point.

. 

74

Based on this research, DOE assumed that the average life of magnetic ballast was 

50,000 hours. Electronic ballasts represent a very small segment of the HID market and thus 

were not considered in the LCC-PBP analysis. 

” 

5.1.7 Contractor Mark-up

DOE received comments after the 2003 draft report. The American Council for an 

Energy Efficient Economy commented that DOE should use 13% for contractor markup. 

(ACEEE, No. 11 at p 2) This value is consistent with the contractor markup used in previous 

rulemakings, including the Fluorescent Ballasts Energy Conservation Standards Final Rule 65 

EE-DET-03-001 COMMENT 19
5-9 

FR 56740 (September 19, 2000) as well as the current revision to that rule. 75 FR 14319 (March 

24, 2010). 

5.1.8 Sales Tax

DOE assumed a national average sales tax of 7% for the LCC-PBP analysis. This value is 

consistent with that presented in the Fluorescent Ballasts Energy Conservation Standards 

preliminary technical support document (TSD)75

5.1.9 Maintenance Costs

. 75 FR 14319 (March 24, 2010). 

The costs associated with maintenance is a real cost in the life cycle analysis of a product. 

Typical applications of HID lamps often require lifts to access the fixture for lamp replacement.

The actual cost of maintenance will vary if the fixture is located inside or outside; by geographic 

region; and by mounting height. The overall wattage of the lamp should not factor in the 

individual relamping costs; however, the higher mounting heights typically require higherwattage lamps with higher light output.

To determine the maintenance costs, DOE surveyed a number of sources. 

During the January public meeting for the framework document for the Metal Halide 

Lamp Fixture 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 and just wanted to make that comment76

As part of DOE’s solid-state lighting commercialization efforts, DOE conducts 

demonstrations of light-emitting diode (LED) technology in real-world applications through its 

GATEWAY program. A number of the GATEWAY demonstrations have focused on exterior 

lighting where the maintenance costs often help with the payback of the typically more 

expensive LED fixtures. The following are maintenance costs used in the GATEWAY 

demonstration program: 

. 

• A demonstration with the Federal Aviation Administration in Atlantic City, New Jersey 

assumed that annual maintenance costs for relamping was $39.24 for labor. These 

luminaires are mounted roughly 15’ above finished grade (AFG) and thus do not require 

a truck. This annual relamping labor rate was estimated from a much larger general 

facilities maintenance contract77

• A demonstration in Portland, Oregon replacing HPS fixtures with LED fixtures in a 

parking structure assumed an annual relamping cost of $10.5 including the lamp. The 

fixtures here were mounted just over 7’ AFG and thus did not require a lift

. Assuming that the lamp will be replaced a 5.5 year 

schedule; the typical cost of relamping is then $215.82. 

78. Assuming 

that the lamp will be replaced a 2.8 year schedule; the typical cost of relamping is then 

$28.76. 

EE-DET-03-001 COMMENT 19
5-10

• A demonstration with Minnesota Department of Transportation (Mn/DOT) where LED 

fixtures were installed on a bridge on an interstate found the typical cost for relamping 

was $137.25 per fixture. This was similar to average rate across all of Mn/DOT’s 

territory of $130 - $150 per fixture79

• A demonstration with Pacific Gas & Electric that replaced HPS streetlights with LEDs 

assumed an annual maintenance cost of $24.44

. 

80

• A demonstration with Pacific Gas & Electric that replaced probe-start metal halide 

fixtures in a parking lot in the Sacramento, California area had maintenance costs 

between $200 – $215 per luminaire for lamp servicing

. Assuming that the lamp will be 

replaced a 5.5 year schedule; the typical cost of relamping is then $134.42. 

81

• A demonstration in Portland, Oregon that replaced HPS street lights with LED street 

lights had the following annual maintenance costs of $32.40 (100W), $32.52 (150W), 

$32.76 (250W), and $32.88 (400W)

. 

82

A case study by Kwantlen Polytechnic University found that when replacing 16 

incandescent fixtures with compact fluorescent lamps, a total of $3,500 in maintenance was 

deferred. This translates to a cost of $218.75 per luminaire for maintenance

. Assuming that the lamp will be replaced a 5.5 

year schedule; the typical cost of relamping is then between: $178.20 and $180.84. 

83

Based on this research, DOE assumed the average ($225) of the range ($150 – $300) 

provided during the metal halide lamp fixture public meeting for the maintenance cost per 

relamping for exterior applications in the LCC-PBP analysis.

. 

DOE could not find reliable cost data for interior relamping. Therefore, DOE assumed 

that the exterior maintenance is three times as expensive as interior relamping. This is consistent 

with the comment received during the metal halide lamp fixture public meeting that exterior 

relamping is more expensive than interior relamping. Therefore, DOE used $75 for interior 

relamping for the LCC-PBP analysis.

5.1.10 Electricity Price

DOE determined the relevant price of electricity based on the type of entities that 

purchase and own considered HID lamps. DOE based commercial and industrial electricity 

prices on the average of the 2017 and 2030 forecasts from the Energy Information 

Administration’s Annual Energy Outlook 200984 This approach is consistent with that presented 

in the Fluorescent Ballasts Energy Conservation Standards preliminary TSD85

5.1.11 Discount Rate

. 75 FR 14319 

(March 24, 2010). 

The discount rate is the rate at which future expenditures are discounted to estimate their 

present value. For this determination, DOE used the industrial and commercial discount rates 

calculated in the Fluorescent Ballasts Energy Conservation Standards preliminary TSD, made 

available on March 24, 2010. 75 FR 14319 For commercial and industrial consumers, DOE 

estimated the cost of capital for commercial and industrial companies by examining both debt 

and equity capital, and developed an appropriately weighted average of the cost to the company 

EE-DET-03-001 COMMENT 19
5-11

of equity and debt financing. The resulting average discounted industrial and commercial 

discount rates used in the LCC-PBP analysis are 7.6 percent and 7.0 percent, respectively.

5.2 RESULTS FOR MEDIUM-WATTAGE MERCURY VAPOR DESIGN OPTIONS

DOE did not present LCC-PBP analysis results for MV lamps in the notice of proposed 

determination for HID lamps. MV ballasts can no longer be imported or manufactured; 

consequently, DOE assumed that consumers would have to switch to another HID technology 

when existing MV ballasts failed, regardless of financial benefit or penalty. DOE also assumed 

that MV fixtures were not a viable option in a new construction or fixture scenario and does not 

present related LCC-PBP results here. All LCC-PBP analysis results for MV lamps are presented 

for reference only.

5.2.1 Event 1 – Lamp-Only Replacement

Table 5.2.1-Table 5.2.3 below present the results for medium wattage (150-500W) MV

lamps and higher-efficiency substitute HID lamps in a lamp-only replacement scenario. DOE 

considered MH lamps in exterior applications only. In this scenario, a failed baseline lamp is 

replaced either with an identical baseline lamp, or with a substitute lamp-and-ballast system. 

These analyses were based on representative, incremental lamp and fixture prices as well as 

maintenance costs. Given the assumed disappearance of MV products from the marketplace, 

DOE did not consider the negative LCC savings for MV substitutes in its proposed 

determination.

Table 5.2.1. LCC-PBP Analysis for 175W MV Baseline 

Commercial/Exterior

Baseline

175 W MV

$

Substitute 1

150 W PMH

$

Substitute 2

100 W HPS

$

Ballast Price -- 190.22 234.10

Lamp Price 45.17 64.09 49.23

Total First Cost 45.17 254.31 283.33

Incremental First Cost -- 209.14 238.16

Annual Operating Cost 294.90 288.18 263.26

Annual Operating Cost Differential -- 6.72 31.64

Life-Cycle Cost (7% Discount Rate) 1,837.32 2,191.63 2,059.27

LCC Savings -- -354.31 -221.95

Payback Period (years) -- 31.12 7.53

Table 5.2.2. LCC-PBP Analysis for 250W MV Baseline 

Commercial/Exterior

Baseline

250 W MV

$

Substitute 1

150 W PMH

$

Substitute 2

150 W HPS

$

Ballast Price -- 190.22 260.18

Lamp Price 52.60 64.09 60.91

EE-DET-03-001 COMMENT 19
5-12

Table 5.2.3. LCC-PBP (continued)

Total First Cost 52.60 254.31 321.09

Incremental First Cost -- 201.71 268.49

Annual Operating Cost 326.94 288.18 288.18

Annual Operating Cost Differential -- 38.76 38.76

Life-Cycle Cost (7% Discount Rate) 1,874.13 2,193.63 2,126.51

LCC Savings -- -319.50 -252.38

Payback Period (years) -- 5.20 6.93

Table 5.2.4. LCC-PBP Analysis for 400W MV Baseline

Commercial/Exterior

Baseline

400 W MV

$

Substitute 1

250 W PMH

$

Substitute 2

150 W HPS

$

Ballast Price -- 312.34 260.18

Lamp Price 64.29 80.90 60.91

Total First Cost 64.29 393.24 321.09

Incremental First Cost -- 328.95 256.80

Annual Operating Cost 394.58 327.73 288.18

Annual Operating Cost Differential -- 66.85 106.40

Life-Cycle Cost (7% Discount Rate) 1,943.34 2,255.98 2,126.51

LCC Savings -- -312.64 -183.17

Payback Period (years) -- 4.92 2.41

5.3 Results for Medium-Wattage probe-start metal halide DESIGN Options

5.3.1 Event 1 – Lamp-Only Replacement

Table 5.3.1-Table 5.3.4 below present the results for medium wattage (150-500W) probestart MH lamps and higher-efficiency substitute HID lamps in a lamp-only replacement scenario. 

DOE considered MH lamps in both interior and exterior applications. In this scenario, a failed 

baseline lamp is replaced either with an identical baseline lamp, or with a substitute lamp-andballast system. These analyses were based on representative, incremental lamp and fixture prices 

as well as maintenance costs. A full rulemaking would yield more detailed results than the 

representative analyses conducted. Generally, the LCC of a high-efficiency lamp and ballast 

replacement is higher than the LCC of an inefficient lamp-only replacement. 

Table 5.3.1. LCC-PBP Analysis for 175W MH Baseline 

Industrial/Interior Commercial/Exterior

Baseline

175 W MH

$

Substitute 1

150 W PMH

$

Baseline

175 W MH

$

Substitute 2

100 W HPS

$

Ballast Price -- 190.22 -- 234.10

Lamp Price 49.58 64.09 49.58 49.23

Total First Cost 49.58 254.31 49.58 283.33

EE-DET-03-001 COMMENT 19
5-13

Table 5.3.2. LCC-PBP (continued)

Incremental First Cost -- 204.73 -- 233.75

Annual Operating Cost 149.23 141.02 297.28 263.26

Annual Operating Cost Differential -- 8.21 -- 34.02

Life-Cycle Cost (7% Discount Rate) 808.83 1,056.34 1,947.52 2,059.27

LCC Savings -- -247.51 -- -111.75

Payback Period (years) -- 24.94 -- 6.87

Table 5.3.3. LCC-PBP Analysis for 250W MH Baseline 

Industrial/Interior Commercial/Exterior

Baseline

250 W MH

$

Substitute 1

175 W PMH 

$

Baseline

250 W MH

$

Substitute 2

150 W HPS

$

Ballast Price -- 195.54 -- 260.18

Lamp Price 53.08 68.76 53.08 60.91

Total First Cost 53.08 264.30 53.08 321.09

Incremental First Cost -- 211.22 -- 268.01

Annual Operating Cost 178.85 149.59 330.11 288.18

Annual Operating Cost Differential -- 29.26 -- 41.93

Life-Cycle Cost (7% Discount Rate) 853.30 994.23 1,983.51 2,126.51

LCC Savings -- -140.93 -- -143.00

Payback Period (years) -- 7.22 -- 6.39

Table 5.3.4. LCC-PBP Analysis for 360W MH Baseline 

Industrial/Interior Commercial/Exterior

Baseline

360 W MH

$

Substitute 1

320 W PMH

$

Baseline

360 W MH

$

Substitute 2

250 W HPS

$

Ballast Price -- 226.43 -- 211.52

Lamp Price 56.92 90.54 56.92 79.64

Total First Cost 56.92 316.97 56.92 291.16

Incremental First Cost -- 260.05 -- 234.24

Annual Operating Cost 217.75 205.97 373.22 331.69

Annual Operating Cost Differential -- 11.78 -- 41.53

Life-Cycle Cost (7% Discount Rate) 788.24 1,083.54 1,919.94 2,146.17

LCC Savings -- -295.30 -- -226.23

Payback Period (years) -- 22.08 -- 5.64

Table 5.3.5. LCC-PBP Analysis for 400W MH Baseline 

Industrial/Interior Commercial/Exterior

Baseline

400 W MH

$

Substitute 1

320 W PMH

$

Baseline

400 W MH

$

Substitute 2

250 W HPS

$

Ballast Price -- 226.43 -- 211.52

Lamp Price 58.08 90.54 58.08 79.64

EE-DET-03-001 COMMENT 19
5-14

Table 5.3.6. LCC-PBP (continued)

Total First Cost 58.08 316.97 58.08 291.16

Incremental First Cost -- 258.89 -- 233.08

Annual Operating Cost 237.74 205.97 395.37 331.69

Annual Operating Cost Differential -- 31.77 -- 63.68

Life-Cycle Cost (7% Discount Rate) 810.40 1,083.54 1,937.06 2,146.17

LCC Savings -- -273.14 -- -209.11

Payback Period (years) -- 8.15 -- 3.66

5.3.2 Event 2 – New Construction / Fixture Replacement

Table 5.3.5-Table 5.3.8 below present the results for medium wattage (150-500W) probestart MH lamps and higher-efficiency substitute HID lamps in a new construction or fixture 

replacement scenario. DOE considered MH lamps in both interior and exterior applications. In 

this scenario, a consumer selects either a baseline or substitute fixture and lamp. In the exterior 

lighting cases, the HPS substitutes have a lower LCC. These analyses were based on 

representative and incremental lamp and fixture prices as well as maintenance costs. A full 

rulemaking would yield more detailed results than the representative analyses conducted. 

Table 5.3.7. LCC-PBP Analysis for 175W MH Baseline 

Industrial/Interior Commercial/Exterior

Baseline

175 W MH

$

Substitute 1

150 W PMH

$

Baseline

175 W MH 

$

Substitute 2

100 W HPS

$

Fixture Price (incl. ballast) 260.51 310.10 356.51 376.34

Lamp Price 49.58 64.09 49.58 49.23

Total First Cost 310.09 374.19 406.09 425.57

Incremental First Cost -- 64.10 -- 19.73

Annual Operating Cost 149.23 141.02 297.28 263.26

Annual Operating Cost Differential -- 8.21 -- 34.02

Life-Cycle Cost (7% Discount Rate) 1,069.34 1,176.22 2,304.03 2,201.51

LCC Savings -- -106.89 -- 102.52

Payback Period (years) -- 7.81 -- 0.58

Table 5.3.8. LCC-PBP Analysis for 250W MH Baseline 

Industrial/Interior Commercial/Exterior

Baseline

250 W MH

$

Substitute 1

175 W PMH

$

Baseline

250 W MH

$

Substitute 2

150 W HPS

$

Fixture Price (incl. ballast) 297.77 325.63 393.77 382.01

Lamp Price 53.08 68.76 53.08 60.91

Total First Cost 350.85 394.39 446.85 442.92

Incremental First Cost -- 43.54 -- -3.93

Annual Operating Cost 178.85 149.59 330.11 288.18

Annual Operating Cost Differential -- 29.26 -- 41.93

Life-Cycle Cost (7% Discount Rate) 1,151.07 1,124.32 2,377.28 2,248.34

EE-DET-03-001 COMMENT 19
5-15

Table 5.3.9. LCC-PBP (continued)

LCC Savings -- 26.75 -- 128.94

Payback Period (years) -- 1.49 -- -0.09

Table 5.3.10. LCC-PBP Analysis for 360W MH Baseline 

Industrial/Interior Commercial/Exterior

Baseline

360 W MH

$

Substitute 1

320 W PMH

$

Baseline

360 W MH

$

Substitute 2

250 W HPS

$

Fixture Price (incl. ballast) 352.43 415.69 448.43 393.34

Lamp Price 56.92 90.54 56.92 79.64

Total First Cost 409.35 506.23 505.35 472.98

Incremental First Cost -- 96.88 -- -32.37

Annual Operating Cost 217.75 205.97 373.22 331.69

Annual Operating Cost Differential -- 11.78 -- 41.53

Life-Cycle Cost (7% Discount Rate) 1,140.67 1,272.81 2,368.37 2,328.00

LCC Savings -- -132.14 -- 40.37

Payback Period (years) -- 8.22 -- -0.78

Table 5.3.11. LCC-PBP Analysis for 400W MH Baseline 

Industrial/Interior Commercial/Exterior

Baseline

400 W MH

$

Substitute 1

320 W PMH

$

Baseline

400 W MH

$

Substitute 2

250 W HPS

$

Fixture Price (incl. ballast) 372.31 415.69 468.31 393.34

Lamp Price 58.08 90.54 58.08 79.64

Total First Cost 430.39 506.23 526.39 472.98

Incremental First Cost -- 75.84 -- -53.41

Annual Operating Cost 237.74 205.97 395.37 331.69

Annual Operating Cost Differential -- 31.77 -- 63.68

Life-Cycle Cost (7% Discount Rate) 1,182.71 1,272.81 2,405.37 2,328.00

LCC Savings -- -90.10 -- 77.37

Payback Period (years) -- 2.39 -- -0.84

EE-DET-03-001 COMMENT 19
6-1 

CHAPTER 6. NATIONAL ENERGY SAVINGS AND CONSUMER IMPACTS

For this determination analysis, the U.S. Department of Energy (DOE) estimated the 

following national impacts from representative energy-efficient substitutes for baseline HID 

lamps: (1) national energy savings (NES), (2) monetary value of the energy savings due to 

standards, (3) increased total installed costs of the considered products due to standards, and (4) 

the net present value (NPV) of energy savings (difference between value of energy savings and 

increased total installed costs). 

DOE prepared a spreadsheet model to forecast energy savings and national consumer 

economic costs and savings resulting from new standards. The next two sections present details 

of the methodology and results of the national impact estimates.

6.1 METHODOLOGY

6.1.1 Shipment Forecasts

Shipment forecasts for HID lamps are key inputs to the NES and NPV calculations, and 

were developed by DOE using a three-step process. First, DOE used historical shipment data 

from NEMA to estimate the total historical shipments of each lamp type analyzed. Second, DOE 

calculated an installed stock for each lamp type based on the average service lifetime of each 

lamp type. Third, by applying estimated market growth rates and HID lamp shipment trends, 

DOE developed annual shipment projections. 

As discussed in chapter 2, NEMA provided two sets of HID lamp shipment data for the 

periods 1990 to 2002 and 2003 to 2008. Based on the NEMA shipments data, DOE estimated the 

average annual growth rate to be 1.5 percent until 2016. DOE assumed that mercury vapor (MV) 

lamps would decline to extinction and not exist for lighting applications by 2016. DOE also 

assumed that high-pressure sodium (HPS) lamps would represent one-third of all HID lamps, and 

that metal halide lamps (both probe and pulse-start) would constitute the remaining shipments. 

Historically, probe-start metal halide (MH) has dominated total metal halide lamp shipments, but 

DOE assumed that MH shipments will gradually decrease as luminaire requirements and other 

incentives promote the use of pulse-start MH (PMH) or non-HID technologies. 

DOE assumed that the overall number of HID lamps shipped would peak near 2020. The 

following are the factors in DOE’s assumptions: 

• DOE’s metal halide lamp fixture rule could affect the price of fixtures. More efficient 

ballasts could require redesign of the fixtures as noted during the metal halide lamp 

fixture (MHLF) public meeting86. The effective dates of future MHLF rules are 2015 and 

2022. 

• Many non-HID technologies are competing in the traditional HID market. For instance, 

the high-bay and low-bay market, traditionally dominated by HID technology, has lost 

significant ground to the fluorescent versions of these fixtures known as high-intensity 

fluorescent (HIF). During the metal halide lamp fixture public meeting, DOE heard that 

EE-DET-03-001 COMMENT 19
6-2 

since 2002 there has been a major shift away from metal halide high-bay fixtures to 

fluorescent high-bay fixtures87. DOE believes that this trend will continue. 

• Many energy codes (both state and the Federal ANSI/ASHRAE/IESNA Standard 90.1) 

have requirements in either parking lot or structures for increased use of controls. The 

controls turn off or reduce the lighting power in response to either daylight or low 

frequency of occupants. HID technology has dominated parking lot and structure 

applications, but the control requirements will require other technologies to be 

considered. DOE believes that induction, fluorescent, and solid-state lighting will fill the 

void left by HID from the increased lighting control requirements. 

In summary, DOE assumes a growth of 1.5 percent from 2008 to 2016 in overall HID 

lamp shipments with MV trending to 0 percent by 2016, HPS consistently representing 33 

percent of the total HID shipments, and metal halide (MH and PMH) constituting the remaining 

shipments. DOE assumes that overall HID lamps will peak and chose 2016 as the year of 

maximum shipments. After 2016, DOE assumed the HID lamp shipments would decline at a rate 

of 1.5 percent per year. Under these assumptions, the total HID shipments in 2024 will be 

roughly the same number of HID lamps shipped in 2008. 

6.1.2 National Energy Savings Analysis 

The inputs for determining NES are (1) annual energy consumption per unit; (2) 

shipments; (3) equipment stock; (4) national energy consumption (calculated from consumption 

per unit and equipment stock); and (5) site-to-source conversion factors. 

DOE calculated the national energy consumption by multiplying the number of units, or 

stock, of lamp-and-ballast systems (by vintage, which represents the age of the ballasts) by the 

unit energy consumption (also by vintage). Then, DOE calculated national annual energy savings 

from the difference between national energy consumption in the base case (without efficiency 

standards) and a higher-efficiency standards case. DOE estimated energy consumption and 

savings based on site energy, and converted the electricity consumption and savings to source 

energy. Cumulative energy savings are the sum of the annual NES, which DOE determined over 

the analysis period (2017 – 2046). Cumulative NES results are presented as undiscounted and 

based on a 7- and 3-percent real discount rate.

6.1.3 Net Present Value Analysis

The inputs for determining NPV are (1) total annual installed cost, (2) total annual 

operating cost savings, (3) discount factor, (4) present value of costs, and (5) present value of 

savings. DOE calculated net savings each year as the difference between total operating cost 

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

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

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

operating cost savings and the present value of increased total installed costs, and used discount 

rates of 7 and 3 percent to discount future costs and savings to the present. 

EE-DET-03-001 COMMENT 19
6-3 

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, with total annual shipments 

assumed as equal in both cases. Because purchase costs of the higher-efficiency 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 efficiency 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. 

6.2 ESTIMATES OF POTENTIAL ENERGY AND CONSUMER IMPACTS

DOE estimated national energy savings and consumer effects of energy conservation 

standards for the considered HID lamps using its own engineering analysis data. Cumulative 

NES values are presented in quadrillion British thermal units (quads), and NPV values are 

presented in billion 2009$. 

6.2.1 National Energy Savings 

The results using DOE’s analysis of design options indicate potential cumulative energy 

savings for medium-wattage HID lamps of 2.8 quads at a 7-percent discount rate over a 30-year 

analysis period (2017–2046). Table 6.2.1 presents the cumulative NES values for each pairing of 

baseline and substitute lamps, as well as the total cumulative NES.

Table 6.2.1. Cumulative National Energy Savings for HID Lamps (2017–2046) 

NES Discount

quads

Baseline Lamp Substitute Lamp Undiscounted 3% 7%

175 W MV 150 W PMH -1.5 -0.9 -0.5

175 W MV 100 W HPS 0.0 0.0 0.0

250 W MV 150 W PMH -1.5 -0.9 -0.5

250 W MV 150 W HPS 0.0 0.0 0.0

400 W MV 250 W PMH -7.0 -4.3 -2.4

400 W MV 150 W HPS 0.0 0.0 0.0

175 W MH 150 W PMH 1.2 0.8 0.4

175 W MH 100 W HPS 2.6 1.6 0.9

250 W MH 175 W PMH -1.9 -1.2 -0.7

250 W MH 150 W HPS 3.7 2.3 1.3

360 W MH 320 W PMH 0.5 0.3 0.2

360 W MH 250 W HPS 5.1 3.1 1.8

400 W MH 320 W PMH 1.2 0.8 0.4

400 W MH 250 W HPS 5.8 3.6 2.0

TOTAL 8.2 5.1 2.8

6.2.2 Net Present Value

DOE estimated the national economic effect on end users in terms of the NPV of 

cumulative benefits from 2017 to 2046. The results indicate a potential NPV of $15.0 billion 

(2009$) at a 3-percent discount rate and $3.5 billion at a 7-percent discount rate. Table 6.2.2 

presents the cumulative NPV results for each pairing of baseline and substitute lamps, as well as 

the total cumulative NPV.

EE-DET-03-001 COMMENT 19
6-4 

Table 6.2.2. Cumulative NPV Results for HID Lamps (2017–2046) 

NES Discount

billion 2009$

Baseline Lamp Substitute Lamp Undiscounted 3% 7%

175 W MV 150 W PMH -21.0 -13.0 -7.4

175 W MV 100 W HPS -0.5 -0.4 -0.3

250 W MV 150 W PMH -21.2 -13.2 -7.5

250 W MV 150 W HPS -0.5 -0.4 -0.3

400 W MV 250 W PMH -82.8 -51.3 -29.1

400 W MV 150 W HPS -0.5 -0.4 -0.3

175 W MH 150 W PMH 8.6 5.0 2.5

175 W MH 100 W HPS 29.0 17.3 9.2

250 W MH 175 W PMH -21.9 -14.2 -8.6

250 W MH 150 W HPS 38.7 23.3 12.5

360 W MH 320 W PMH -1.0 -1.0 -1.0

360 W MH 250 W HPS 47.4 28.7 15.6

400 W MH 320 W PMH 4.1 2.1 0.7

400 W MH 250 W HPS 53.6 32.5 17.6

TOTAL 31.9 15.0 3.5

EE-DET-03-001 COMMENT 19
A-1 

APPENDIX A. NON-REGULATORY INCENTIVE PROGRAMS

A.1 CALIFORNIA INCENTIVE PROGRAMS 

Alameda Power and Telecom offers rebates for its commercial customers to install 

energy-efficient lighting. The Alameda Municipal site claims rebates available for T8 fluorescent 

lamps and electronic ballasts, for compact fluorescent, high-pressure sodium (HPS) and metal 

halide lamps, for occupancy sensors, and other energy saving products. However, upon further 

investigation, Alameda only offers $100 per interior fluorescent high-bay fixture, also known as 

high-intensity fluorescent (HIF). 

More information: http://www.alamedapt.com/electricity/com_rebates.html. 

Anaheim Public Utilities not only offers rebates on certain lighting equipment, they 

actually give away equipment for free. As part of their Dusk-to-Dawn Lighting Program, 

residents can receive a 70W HPS or fluorescent (details not actually provided) fixture for free. In 

addition to the fixture, residents receive a photosensor so the fixture can operate the entire night. 

When APU is not giving away lighting equipment, they are performing lighting audits and 

making recommendations for improvements. At the end of the audits, APU provides specific 

rebates. 

More information: http://www.anaheim.net/article.asp?id=990. 

City of Palo Alto Utilities, through the Commercial Advantage Program, offers several 

incentives for their commercial customers to replace old equipment with new, more efficient 

equipment. CPAU offers rebates on complete new pulse-start metal halide (PMH) fixtures or 

retrofit kits replacing existing MV (MV), probe-start metal halide (MH) or HPS fixtures only. 

Replacements must be equipped with PMH lamps and either magnetic or electronic ballasts. 

New fixtures must replace, one for one, existing incandescent, MV, T12/High output 

Fluorescent, T12/Very High Output Fluorecent, MH, or HPS fixtures in interior installations. 

Rebates are available based on lamp wattages. Same incentives are applicable for exterior 

applications as well. The incentives are as follows:

• $10.00/Fixture for replacing a 175 watt lamp, up to 190 watt replacement fixture. 

• $40.00/Fixture for replacing a 176 - 399 watt lamp, up to 275 watt replacement 

fixture.

• $45.00/Fixture for replacing a 400 watt lamp, up to 400 watt replacement fixture. 

• $50.00/Fixture for replacing 400 watt or more lamp, up to 821-950 watt 

replacement fixture.

• $100.00/Fixture for replacing 400 watt or more lamp, up to 820 watt replacement 

fixture.

EE-DET-03-001 COMMENT 19
A-2 

More information: 

http://www.cityofpaloalto.org/civica/filebank/blobdload.asp?BlobID=3976. 

The Modesto Irrigation Department (MID) 2009 Business Rebates offers rebates on 

complete new PMH fixtures or retrofit kits replacing existing MV, MH or HPS fixtures only. 

Replacements must be equipped with PMH lamps and either magnetic or electronic ballasts. 

New fixtures must replace, one for one, existing incandescent, MV, T12/High output 

Fluorescent, T12/Very High Output Fluorecent, MH, or HPS fixtures in interior installations. 

Rebates are available based on lamp wattages. Same incentives are applicable for exterior 

applications as well. The incentives are as follows:

• $7.50/Fixture for replacing a 175 watt lamp, up to 190 watt replacement fixture. 

• $30.00/Fixture for replacing a 176 - 399 watt lamp, upto 275 watt replacement 

fixture.

• $35.00/Fixture for replacing a 400 watt lamp, up to 400 watt replacement fixture. 

• $40.00/Fixture for replacing 400 watt or more lamp, up to 821-950 watt 

replacement fixture.

• $75.00/Fixture for replacing 400 watt or more lamp, up to 820 watt replacement 

fixture.

• Rebate of $9.50/ lamp is also offered for replacing existing reflector-type 

incandescent, PAR halogen, or PAR halogen IR lamps or fixtures with an 

Integrated Ballast ceramic metal halide (CMH) PAR lamps of 25 W.

More information: http://www.mid.org/services/rebates/rbts-com.htm. 

Roseville Electric - Commercial Energy Efficiency Rebate Program offers incentives for 

its commercial customers to increase the efficiency of their existing facilities. Rebates are 

offered upto $50/fixture for PMH. 

More information: http://www.roseville.ca.us/electric/business/rebates/default.asp. 

The Los Angeles Department of Water and Power (LADWP) manages the Commercial 

Lighting Efficiency Offer. This program seeks to promote energy-efficient lighting retrofits, 

including MH. High bay T8/T5 fixtures replacing ≥400W fixtures that result in a ≥45% energy 

savings are eligible for a $100 per fixture rebate. In applications replacing fixtures less than 

400W, there is only a $50 rebate. In addition to the rebates for the equipment, occupancy sensors 

for fluorescent high bay fixtures have a $20 per sensor rebate. Installations where induction 

lamps replace fixtures with incandescent, MH, HPS, or MV lamps are also eligible for rebates - 

$35 per 55W to 100W lamp and $50 for lamps greater than 100W. MH interiors or PMH in 

exterior applications replacing incandescent, HPS, or MV have rebates of $40 per fixture. 

Incentives for CMH are both lamp and fixture focused. $40 per CMH fixture ≥35W and $15 per 

CMH lamp that is less than 35W exists. 

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More information: http://www.ladwp.com/ladwp/cms/ladwp000572.jsp. 

Pacific Gas and Electric (PG& E) jointly manages a statewide program called Express 

Efficiency with Southern California Edison. The program is quite comprehensive, not only in 

lighting, but in many other areas. In the Display and Accent Lighting category, integrated ballast 

CMH PAR lamps have a $12.50 per lamp rebate and CMH adjustable accent lighting has a $45 

per fixture rebate. For the PMH fixtures (exterior and interior), $10 to $100 rebates are offered 

per fixtures ranging in power from 1W to 950W. High bay fluorescent fixtures ranging from $35 

to $125. 

More information: http://www.pge.com/biz/rebates/rebates_assistance/ (PG&E) or 

http://www.sce.com/RebatesandSavings/LargeBusiness/expressEfficiency.htm (SCE).

Silicon Valley Power has a lighting rebate program. New high bay linear fluorescent 

fixtures under 250W have a $100 per fixture rebate if they are replacing incandescent, T12, or 

HID fixtures 400W and greater. Interior PMH fixtures ranging in power from 1W to 400W have 

rebates of $18 to $50 per fixture if they are replacing MV or incandescent technology. A 

lamp/ballast system efficacy of 45 LPW for sources under 100W and a 55 LPW for sources 

greater than 100W is required. There are no restrictions on ballast type. $100 to $36 per fixture is 

available for HID exterior fixtures ranging in power from 1W to 175W. No specific information 

is provided for the exterior HID exterior fixtures, but it should be assumed that the requirements 

are the same or similar to the interior PMH requirements. PMHde lamp/ballasts less than 350 

replacing 400W or greater systems have a $45 per lamp rebate. CMH fixtures replacing 

incandescent or halogen fixtures have a $25 per fixture rebate. The lamp must be less than 75W 

and the mean lamp/ballast efficact must exceed 55 LPW. 

More information: http://www.siliconvalleypower.com/bus/?sub=rebatelight. 

A.2 COLORADO INCENTIVE PROGRAMS

Longmont Power and communication in collaboration with Platte River 

PowerAuthority’s offers the LightenUP program. Loveland Water & Power also collaborates 

with Platte River PowerAuthority’s to offer the same program. The program recommends 

replacing HPS, MV, and MH with fluorescent fixtures. Incentive amounts for retrofit of high 

performance T8 system is $500/kilowatt and of 8 ft. fluorescent retrofit or replacement is 

$600/kilowatt 

For more information, http://www.ci.longmont.co.us/lpc/bus/eep_homepage.htm

Specifically for the LightenUP program, 

http://www.prpa.org/productservices/eeservicesbus/i/lightenup2009whatsnew.pdf

Xcel EnergySM offers a variety of technology specific rebate incentives. The following 

rebates are offered:

• $ 85 - $210 / unit per fixture for replacing 250W – 1000 W HID (HPS, MH, MV) 

with multi-lamp HIF. 

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• $30 is available per fixture for replacing incandescent, HPS, or MV with 151W to 

250W PMH. 

• $45 per fixture for replacing incandescent, HPS, or MV with 251 W or more 

PMH. 

• $25 per fixture for replacing incandescent, HPS, MV or MH with 175W or less 

PMH system.

• $50 per fixture for replacing incandescent, HPS, MV or MH with 176W to 319W 

PMH system.

• $45 per fixture for replacing incandescent, HPS, MV or MH with 320W to 749W 

PMH system.

• $140 per fixture for replacing incandescent, HPS, MV or MH with 750W or more 

PMH system.

• $55 per fixture for replacing incandescent, halogen or HID systems with 150W or 

less CMH fixtures.

• $60 per fixture for replacing incandescent, halogen or HID systems with 151W to 

250W or less CMH fixtures. 

• $75 per fixture for replacing incandescent, halogen or HID systems with 251W or 

more CMH fixtures.

• $25 per lumianire for replacing 75W or greater incandescent or halogens with 

25W integrated CMH lamps. 

More information: 

http://www.xcelenergy.com/Business/Programs_Resources/ConservationRebates_Incentives_Bu

siness/Pages/Lighting_Efficiency.aspx

A.3 CONNECTICUT INCENTIVE PROGRAMS

Connecticut Light and Power (part of Northeast Utilities) sponsors an Express Service 

Lighting Rebate program. The rebate works to promote energy-efficient lighting in retrofit 

applications. Incentive of $30 per fixture is offered for upgrading from MV, HPS, and MH to 

PMH. 

More information: http://www.cl-p.com/Business/SaveEnergy/BusinessRebates.aspx. 

Groton Utilities’ lighting efficiency program cash incentives for new fixture installation 

or retrofits of old lighting fixtures to energy efficient systems. Groton Utilities’ lighting 

efficiency program also provides rebates for installation of lighting occupancy controls and 

daylight harvesting and dimming controls. $20 rebate per fixture is offered for installing new 

PMH fixture. 

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More information: http://www.grotonutilities.com/elec_conserv_comm_light.asp. 

United Illuminating manages three programs promoting energy-efficiency lighting that 

applies to HID lighting. Energy Blueprint Program focuses on reducing energy consumption in a 

building. This program offers incentives on both a lighting power density basis, as well as, a 

technology basis. Outdoor Lighting, Lite the NiteSM provides commercial customers with 

exterior lighting design services, the ability to have equipment purchased, installed, and 

maintained for a monthly fee. The program offers a variety of fixture types with HPS and MH 

lamps available in a variety of wattages. Finally, United Illuminating also participates in the 

Express Service that Connecticut Light and Power also promotes. 

More information: 

http://www.uinet.com/uinet/connect/UINet/Top+Navigator/Your+Business/UI+Products+%26+

Services/. 

A.4 FLORIDA INCENTIVE PROGRAMS

Florida Power and Light (FP&L) manages a Business Lighting Program that works to 

reduce the utility’s peak demand from 3 pm to 6 pm during summertime weekdays. Installation 

of PMH and electronic ballasts in MH fixtures and CMH in hard wired fixtures qualify for 

lighting incentives. The incentive is an upfront discount for the work performed by an 

independent contractor. 

More information: http://www.fpl.com/business/savings/lighting.shtml. 

Progress Energy will pay between $1 and $5 per fixture replaced in a retrofit (for new 

construction, the space must exceed code by 15% to be eligible for incentives). CMH technology 

is eligible. 

More information: http://progressenergy.com/custservice/flabusiness/efficiency/efficiencyservices.asp. 

A.5 IDAHO INCENTIVE PROGRAMS

Avista Utilities Commercial Lighting Incentives offers incentives for HID interior and 

exterior fixtures. When replacing 400W MH high bay with multi-lamp fluorescent high bay, 

$125-$460 per fixture is available. Incandescent flood of 100 W or more replaced with CMH are 

eligible for $35 rebate per fixture. Avista’s incentives are also available for new construction on 

a case-by-case basis. 

More information: 

https://www.avistautilities.com/business/rebates/washington_idaho/Documents/Lighting%20We

b.pdf

Idaho Power offers a series of incentives related to HID lighting. MH lighting is 

specifically identified. These incentives only apply to lighting upgrades for interior lighting 

(street, area, and parking lot lighting is excluded). Eligible metal halide fixtures include PMH or 

CMH are replacing higher wattage MH, MV, or other sources. The incentives are the following: 

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• $18.00 for PMH fixtures between 30W to 70W when replacing a fixture drawing 

20W more than the MH wattage. 

• $22.00 for PMH fixtures between 70W to 150W when replacing a fixture drawing 

25W more than the MH wattage. 

• $26.00 for PMH fixtures between 150W to 250W when replacing a fixture 

drawing at least 40W more than the MH wattage.

• $55.00 for PMH fixtures between 250W to 360W when replacing a fixture 

drawing at least 80W more than the MH wattage.

• $75.00 for PMH fixtures between 360W to 500W when replacing a fixture 

drawing at least 120W more than the MH wattage.

• $105.00 for PMH fixtures for 500W and more when replacing a fixture drawing at 

least 200W more than the MH wattage. 

More information: 

http://www.idahopower.com/EnergyEfficiency/Business/Programs/EasyUpgrades/default.cfm. 

A.6 INDIANA INCENTIVE PROGRAMS

Duke Energy offers $25 per fixture for replacing 400W MH with 320W PMH (if the 

fixture operates a minimum of 1800 hours per year). 

More information: http://www.duke-energy.com/indiana-business/energymanagement/energy-efficiency-incentives.asp. 

A.7 IOWA INCENTIVE PROGRAMS

Ames Electric Department manages the Commercial High efficiency Lighting Program 

offers only a handful of rebates for select technologies and power ranges. The incentives are 

available for replacing existing or for new equipment:

• $15 per fixture is available for MH fixtures with lamps rated under 250W 

• $25 per fixture is available for PMH fixtures with lamps in the range of 250W350W 

• $20 per fixture is available for HPS fixtures with lamps under 250W 

• $25 per fixture is available for HPS fixtures with lamps in the range of 250W400W 

More information: http://www.cityofames.org/SmartEnergy/ 

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MidAmerican Energy Company’s EnergyAdvantage offers rebates for some fixture 

technologies, but also for specific HID lamps. $ 25 per fixture is available for 320W or less and 

$50 per fixture for greater than 320W PMH fixtures. MidAmerican also provides a rebate of $3 

per lamp for the 360W MH lamps. This lamp is for reduced wattage replacements. The 

incentives are available for replacing existing or for new equipment. 

More information: http://midamericanenergy.com/html/energy6b.asp. 

A.8 KANSAS INCENTIVE PROGRAMS

Kansas City Light & Power only focuses on PMH technology. $50 per fixture is avaible 

for 320W and 360W PMH replacing 400W MH and HPS fixtures. 

More information: http://www.kcplprograms.com/content/prescriptiverebates. 

A.9 KENTUCKY INCENTIVE PROGRAMS

Duke Energy offers $25 per fixture for replacing 400W MH with 320W PMH (if the 

fixture operates a minimum of 1800 hours per year). It also offers rebates of $30 - $75 for 

replacing HID lamps with T5 HO High Bay (2 -8) lamp. 

More information: http://www.duke-energy.com/kentucky-business/energymanagement/lighting-incentive.asp. 

A.10 MAINE INCENTIVE PROGRAMS

Efficiency Maine, a program of the Maine Public Utilities Comission, does not offer a 

rebate for HID fixtures. However, the program offers $ 65 (retrofit fixtures) and $35 (new 

construction) for High Intensity Fluorescent technology. No specific requirements were 

mentioned. 

More information: http://www.efficiencymaine.com/business_programs.htm. 

A.11 MASSACHUSETTS INCENTIVE PROGRAMS

National Grid offers incentives for new equipment as well as replacing existing

equipment. The Energy Initiative for existing facilities offers rebates for both fixtures and 

lamp/ballast systems. For existing metal halide systems, National Grid offers $45 per 

lamp/ballast kit. No specific wattage requirement is listed, but a minimum savings of 13W is 

required. The incentive is only available for interior fixtures. Besides replacing the lamp/ballast 

system, National Grid offers $70 per fixture for completely replacing an existing MH fixture 

with a new PMH fixture. Again, the program does not list any specific wattage requirements for 

the existing or new fixture, but a saving of 20W is required. $100 per fixture is available for 

replacing a MH fixture with an HPS fixture. The program states that HPS is more energy 

efficient than MH. No specific fixture wattages are listed, but a minimum savings of 29 watts is 

required. No incentives specifically for HID fixtures are listed in National Grid’s new 

constrcuction program. However, the program offers $30 to $40 per fixture for HIF. The 

applications recommended for these fixtures are some of the typical locations for HID fixtures. 

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More information: 

https://www.nationalgridus.com/masselectric/business/energyeff/3_large.asp. 

Nstar manages a Construction Solution and Business Solutions program that aims to 

promote energy-efficient lighting in renovations and new construction projects. The Commercial 

Section of the program provides $70 for MH speciality fixture for a minimum of 55 wattage 

reduction per fixture. The Industrial Lighting section of solutions program offers the following 

incentives for HID or rival technology. 

• $45 for a PMH kit with electronic ballast for a minimum of 37 wattage reduction 

per fixture.

• $60 for a PMH fixture with electronic ballast for a minimum of 37 wattage 

reduction per fixture. 

More information: 

http://www.nstaronline.com/business/energy_efficiency/electric_programs/business_solutions.as

p. 

Reading Municipal Lighting Department offers incentives to replace existing HID 

fixtures with new T5 or T8 HO fixtures. The program offers $100 per fixture and no other 

requirements are listed. For more information, 

http://www.rmld.com/from_priscilla/programs/light_rebate_08.pdf

Western Massachusetts Electric (WMECO) offers rebates to commercial customers for 

lighting. New construction projects are not eligible for this program. $25 incentive is offered for 

replacing MH, MV or HPS fixtures with PMH fixtures. It offers rebate of $150 for replacing 

250W MH to 54T5Ho (2/3 lamp) (117/176 W) and for replacing 400W MH to 54T5HO (4 lamp) 

(234 W). It offers rebate of $150 for replacing 250 W/400 W MH to high performance 4’ 4- 

lamp/6- lamp T8 with electronic ballast and reflector. 

More information: 

http://www.wmeco.com/business/saveenergy/EnergyEfficiencyPrograms/Lighting.aspx. 

A.12 MINNESOTA INCENTIVE PROGRAMS

Alexandria Light and Power – Commercial Energy Efficiency Rebate Program offers the 

Bright Energy Solution. The following incentives are offered: 

• $75 incentive per fixture for replacing 100W or larger incandescent with 20W 

CMH.

• $75 incentive per fixture for replacing 150W or larger incandescent with 39W 

CMH.

• $75 incentive per fixture for replacing 500W or larger incandescent with 150W 

CMH.

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• $20 incentive per fixture for replacing 400W or larger HID or incandescent with 

320W PMH fixture. 

• $30 incentive per fixture for replacing 1000W or larger HID or incandescent with 

750W PMH fixture. 

There are 23 Utilities participate in this program. 

More information: 

http://www.brightenergysolutions.org/municipalities/?category=business&state=mn

Anoka Municipal Utility has a Commercial Lighting Rebate program that includes both 

retrofit and new construction applications. Within their Lighting Rebate Guide, the utility 

recommends replacing MV with MH or HPS, MH or T12 fluorescent with high-bay multilamp 

CFL fixtures, MH or HPS with linear fluorescent, and MH or HPS with PMH. For retrofit 

applications, $33-$80 per fixture is available for replacing the existing 400W or MH fixture with 

a multi-lamp linear or CFL fixture. $25 to $80 per fixture is available for replacing standard MH 

or HPS with PMH. New construction has similar incentives. $15.40-$37.50 per fixture is 

available for using multi-lamp linear or CFL fixtures where HID high bay fixtures could also be 

used. $11 to $18.50 per fixture is available for using PMH rather than just installing standard 

MH or HPS. 

More information: 

http://www.ci.anoka.mn.us/index.asp?Type=B_BASIC&SEC={F366614A-5300-4465-BC0D279ADDD33B82}

Austin Utilities offers incentives to its commercial and industrial customers to install 

energy-efficient equipment in their facilities. The incentives offered on HID lamps are as 

follows: 

• $7.5 rebate per fixture for installing new PMH fixture of 32W, 50W, 70W and 

100W. 

• $6 rebate per fixture for installing new PMH of 150W and 175W 

• $8 rebate per fixture for installing new PMH of 200Wand 250W. 

• $12 rebate per fixture for installing new PMH fixture of 320W, 350W and 400W. 

• $24 rebate per fixture for installing new PMH fixture of 400W with two lamps. 

• $20 rebate per fixture for installing new PMH fixture of 575W. 

• $15 rebate per fixture for installing new PMH fixture of 750W. 

• $15, $30 and $45 rebate per fixture for installing new PMH of 875W with 1, 2 

and 3 lamps respectively. 

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• $8 rebate per fixture for installing 25W Integrated CMH. 

• $20 rebate per fixture for installing 150W or less CMH. 

• $10 rebate per fixture for installing 151W-250W CMH.

• $15 rebate per fixture for installing 251W or more CMH. 

• $7.5 rebate per fixture for installing new HPS fixture of 35W, 50W, 70W, 100W 

and 150W. 

• $15 rebate per fixture for installing new HPS fixture of 200W, 250W, 310W, 

400W, 600W and 750W. 

More information: http://www.austinutilities.com/pages/business_conserve.asp. 

City of North St. Paul (Rebates on hold till Jan 2010). HPS, PMH and CMH are eligible 

for incentives. The incentives are as follows:

• $28 and $45 for replacing incandescent, HPS or MV with MH with 151 to 250W 

and 251W or more repectively. 

• $28 and $45 for replacing incandescent or MV with HPS with 151 to 250W and 

251W or more repectively. 

• $50 for replacing incandescent, halogen or HID with CMH fixtures of 150W or 

less.

• $45 for replacing incandescent, halogen or HID with CMH fixtures of 151 to 

250W or less. 

• $60 for replacing incandescent, halogen or HID with CMH fixtures of 251W or 

higher. 

• $20 for replacing incandescent, halogen or HID with integrated CMH fixtures of 

25W. 

• $25 for replacing incandescent, HPS, MV or MH with PMH of 175W or less. 

• $40 for replacing incandescent, HPS, MV or MH with PMH of 176 to 319W. 

• $55 for replacing incandescent, HPS, MV or MH with PMH of 320 to 749W. 

• $65 for replacing incandescent, HPS, MV or MH with PMH of 750W or higher. 

• $50, $75, $100 and $125 for replacing HID lamps of 250W, 310- 400W, 

750Wand 1000W with high bay fluorescent fixtures (T5HO) with electronic 

ballast having 2-3, 4-6, 8 and 10 lamps respectively. 

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• $50, $75, $100 and $125 for replacing HID lamps of 250W, 310- 400W, 

750Wand 1000W with high bay fluorescent fixtures (T8) with electronic ballast 

having 4, 6- 8, 12-16, and 18-20 lamps respectively. 

More information: http://www.ci.north-saintpaul.mn.us/index.asp?Type=B_BASIC&SEC={F5C1E5FE-1ADD-49AF-ACD8-

59C3FB4192FF}

Connexus® Energy, along with the Dakota Electric Association (East Central Energy, 

Elk River Municipal Utilities, Minnesota Valley Electric cooperative, Shakopee Public Utilities, 

Stearns Electric Association) offers rebates for both retrofit applications and new construction. 

Connexus recommends replacing T12 or metalide systems with MH and HPS fixtures. $25 per 

fixture rated 150W and under, $35 per fixture rated between 151W to 250W, and $55 per fixture 

rated over 251W. 

Incentives also exist for the installation of new PMH over older less efficient technology. 

• Fixtures ≤175W are eligible for $35 per fixture, 

• fixtures in the range of 176W to 319W are eligible for $55 per fixture, 

• fixtures between 320W to 749W have a $70 per fixture rebate, and 

• fixtures over 750W have a rebate of $80 per fixture. 

CMH technology is also included in the retrofit program. 

• $35 per fixture ≤150W 

• $50 per fixture that draws power in the range of 151W to 250W 

• $75 per fixture that draws more than 251W 

Connexus’s new construction program is similar. MH or HPS fixtures rated at less than 

151W are eligible for a $6.60 per fixture rebate. 

PMH fixtures have the following incentives: 

• $6.50 per fixture ≤175W 

• $8.80 per fixture in the range of 176W to 319W 

• $13.20 per fixture in the 320W to 749W range 

• $19.80 per fixture rated over 749W 

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CMH technology rebates are as follows: 

• $22 per fixture ≤150W, 

• $11 per fixture that draws power in the range of 151W to 250W 

• $16.50 per fixture that draws more than 250W 

More information: 

• http://www.connexusenergy.com/busrebates.htm

• http://www.dakotaelectric.com/cirebate.asp. 

• https://www.eastcentralenergy.com/rebatesbusiness.aspx

• http://www.elkriverutilities.com/cipeleccomm.php

• http://www.mvec.net/business/grants_rebates.asp

• http://www.shakopeeutilities.com/commrebates.htm

• http://www.stearnselectric.org/grantsbus.htm

Otter Tail Power Company focuses on demand reduction with incentives based on a kW 

savings. Though, their program specifically addresses HID technology by including in their 

definition of eligible fixtures, efficient HID lighting. Rebates of 20¢/KWh saved is offered when 

MV lamps are replaced with HPV or high efficiency PMH. 

More information: http://www.otpco.com/SaveEnergyMoney/Rebates.asp. 

A.13 MISSOURI INCENTIVE PROGRAMS

Empire District Electric Company offers rebates to certain commercial and industrial 

customers for the installation of energy efficiency equipment. They provide a rebate of 

$50/fixture for installing a PMH. The lamp wattage must be either 320 or 360W as a replacement 

for 400W MH or HPS. $50 rebate on replacing high intensity HID with T5 or T5HO lamps with 

electronic ballast. 

More information: http://empire.programprocessing.com/content/Home. 

Kansas City Light & Power only focuses on PMH technology. $50 per fixture is avaible 

for 320W and 360W PMH replacing 400W MH and HPS fixtures. $50 rebate on replacing high 

intensity HID with T5 or T5HO lamps with electronic ballast. 

More information: http://www.kcplprograms.com/content/prescriptiverebates. 

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A.14 MONTANA INCENTIVE PROGRAMS

Flathead Electric Cooperative offers a variety of incentives for new and existing 

equioment in their Commercial Lighting Rebate Program. 

For new construction projects: 

• $40 per CMH fixture ranging in wattage from 20W to 100W 

• $50 per CMH fixture ranging in wattage from 101 to 400W 

• $50 per HIF fixture 

For retrofit applications: 

• $80 per CMH fixture in wattage range of 99W or less 

• $150 per CMH fixture for wattages 100W or more 

• $150 per PMH fixture in wattage range of 200W to 399W 

• $200 per PMH fixture in wattage range of 400W to 750W 

• $80 to $140 per HIF fixtures ranging in wattage from 85W to 600W 

• Finally, there are other incentives for replacing incandescent and MV sources 

with LEDs, fluorescent, or compact fluorescent. 

More information: http://www.flatheadelectric.com/energy/Rebates.html. 

A.15 NEW HAMPSHIRE INCENTIVE PROGRAMS

National Grid offers incentives for new equipment as well as replacing existing 

equipment. For new construction, $15 per new PMH fixtures is available if lamps are greater 

than 150W with linear ballasts or 250W with CWA ballasts. HIF fixtures incentives include $30 

for low-bay fixtures in the 125W to 219W range and $50 for high-bay fixtures greater than 

219W. $90 for new low-wattage MH fixtures for retail or display lighting exists. Fixtures must 

be from 20W to 100W and may be track, recessed, or surface mounted and used for high quality 

display type lighting. $90 per HID fixture exists for HID controls. Either occupancy controlled 

hi-low systems or daylight dimming systems. For existing facilities, $40 per fixture is offered for 

new PMH lamp and ballast installed per the manufacturer’s specifications and applicable codes. 

$60 per fixture is offered for an entirely new PMH. $70 per fixture is offered for new HPS. They 

consider HPS more efficient than MH. 

More information: 

https://www.nationalgridus.com/granitestate/business/energyeff/5_light.asp

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The New Hampshire Electric Cooperative has quite a comprehensive incentive program 

for lighting. $15 per new PMH fixtures is available if lamps are greater than 150W with linear 

ballasts or 250W with CWA ballasts. HIF fixtures incentives include $30 for low-bay fixtures in 

the 125W to 219W range and $50 for high-bay fixtures greater than 219W. $90 for new lowwattage MH fixtures for retail or display lighting exists. Fixtures must be from 20W to 100W 

and may be track, recessed, or surface mounted and used for high quality display type lighting. 

$90 per HID fixture exists for HID controls. Either occupancy controlled hi-low systems or 

daylight dimming systems. 

More information: http://www.nhec.com/business_energysolutions_newbusiness.php. 

The New Hampshire Electric Cooperative also offers incentives for its large businesses. 

HID interior fixtures are eligible for rebates. $40 per fixture is offered for new PMH lamp and 

ballast installed per the manufacturer’s specifications and applicable codes. $60 per fixture is 

offered for an entirely new PMH. $70 per fixture is offered for new HPS. They consider HPS 

more efficient than MH. 

More information: http://www.nhec.com/business_energysolutions_largebusiness.php. 

A.16 NEW JERSEY INCENTIVE PROGRAMS

New Jersey Clean Energy is a statewide program that promotes energy efficiency and 

renewable energy. The specific program with HID rebates is the New Jersey SmartStart 

Buildings® and offers the following incentives: 

• $25 per PMH fixture rated at 150W or more 

• $75 per HID fixture controlled via Hi-Low or dimming ballasts

• $284 per T5 or T8 fixture replacing an HID, T12, or incandescent fixture rated at 

1000 W 

• $16 per T5 or T8 fixture for replacing HID lumainires rated between 75-99W 

• $30 per T5 or T8 fixture for replacing HID fixtures rated between 100-175W 

• $43 per T5 or T8 fixture for replacing HID fixtures rated between 175-249W 

• $50 per T5 or T8 fixture for replacing HID fixtures rated between 250-399W 

• $100 per T5 or T8 fixture for replacing HID fixtures rated between 400-499W 

More information: http://www.njcleanenergy.com/

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A.17 NEW YORK INCENTIVE PROGRAMS

The Long Island Power Authority manages a Commercial Construction Program to 

promote energy-efficient lighting in new construction projects. Applicable incentives are as 

follows: 

• $45 per CMH fixture replacing one-for-one incandescent, halogen, MV, and HPS 

fixtures

• $35 per T5 or T8 high-bay fixture

• $40 per multi-lamp CFL high-bay fixture

• $20 per integrated ballast CMH PAR lamp 

• $20 per PMH fixture with electronic ballast

• $75 per HID fixture controlled via Hi-Low occupancy sensor or daylight controls 

More information: http://www.lipower.org/cei/commercial.pre.html. 

A.18 OHIO INCENTIVE PROGRAMS

Dayton Power and Light offers the following incentives: 

• $35 for PMH or CMH rated between 0-100 W 

• $40 for PMH or CMH rated between 100-250W 

• $50 for PMH or CMH rated above 250W 

• $75 for MH track lighting 

It offers rebates for replacing HID systems with the following T5 HO lamps:

• $30 per T5 HO High-Bay 2-lamp fixture replacing HID fixtures

• $40 per T5 HO High-Bay 3-lamp fixture replacing HID fixtures

• $50 per T5 HO High-Bay 4-lamp fixture replacing HID fixtures

• $60 per T5 HO High-Bay 6-lamp fixture replacing HID fixtures

• $75 per T5 HO High-Bay 8-lamp fixture replacing HID fixtures

More information: http://www.dpandl.com/bizprograms.php. 

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Duke Energy offers $25 per fixture for replacing 400W MH with 320W PMH (if the 

fixture operates a minimum of 1800 hours per year). 

More information: http://www.duke-energy.com/indiana-business/energymanagement/energy-efficiency-incentives.asp. 

A.19 OREGON INCENTIVE PROGRAMS

Columbia River Public Utility District sponsors a Business LightingRetrofit program. 

MV, HPS, and MH are listed as existing equipment with recommended replacement technology. 

Columbia River PUD recommends and offers rebates for replacing incandescent, T12 and MV 

with new fluorescent fixtures. 

In a separate section, rebates are offered for specific HID technology to replace 

incandescent and MV lamps. 

• $80 per new CMH fixture ranging from 20W to 100W 

• $150 per new CMH fixture ranging from 101W to 250W 

For high bay or industrial applications, the program recommends replacing T12, MV, 

HPS, incandescent or MH with either high output fluorescent or PMH. The following incentives 

exist:

• $80 to $140 per fluorescent (T8, T5, or long biax CFL) fixture raninging in 

wattage from 85W to 600W 

• $150 per PMH fixture in the 300W to 399W range 

• $200 per PMH fixture in the 400W to 750W range 

More information: http://www.crpud.net/business/lighting. 

Emerald People’s Utility District previously sponsored a Lighting Retrofit Rebate 

Program. This program has changed to the Commercial Energy Program. EPUD will perform 

lighting audits of existing buildings. Recommnedations will be made for improvements. EPUD 

will estimate the possible rebates and perform economic analysis. If the project moves forward, 

EPUD can help with construction management assistance. EPUD’s website about the progam 

explains past projects include fluorescent lighting retrofits in offices, gyms, and retail stores-MV 

replacements, to high efficiency metal halide, or HPS lights and dimming and lighting control 

upgrades. 

More information: http://www.epud.org/comnrg.aspx. 

Eugene Power offers incentives for energy-efficient lighting design. This is a two-tiered 

program. In the first tier, the lighting power density must be reduced by 10% but the design must 

still meet the lighting requirements of the program. The only HID technology allowed is PMH, 

all other are excluded. This tier has an incentive rate of 0.420. The second tier is similar, yet, the 

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lighting power savings must be a minimum of 20%. In this tier, no HID sources are allowed for 

interior applications. The incentive rate for this tier is 0.560. For replacing existing HID with 

fluorescent fixtures, the following rebates are offered:

• $50 for 120 or less wattage T5, T5HO, or T8 high-performance fixture replacing 

175 to 250W HID 

• $130 for 260 or less wattage T5, T5HO, or T8 high-performance fixture replacing 

400W HID 

• $90 for 310 or less wattage T5, T5HO, or T8 high-performance fixture replacing 

400W HID 

• $60 for 370 or less wattage T5, T5HO, or T8 high-performance fixture replacing 

400W HID 

• $25 per 25W integral ballast CMH PAR replacing 90W to 150W incandescent

More information: 

http://www.eweb.org/public/documents/energy/Commercial_Retrofit_Lighting_Catalog.pdf

The Energy Trust of Oregon manages a statewide program called the Building Efficiency 

Program. This program aims to promote energy-efficient lighting upgrades that incorporate HPS 

or MH fixtures. The Busines Energy Solutions program has rebates for replacing MV and 

incandescent lighting with HPS or MH fixtures–$25 for a HPS or MH fixture less than 175 

watts, and $30 for a HPS or MH fixture greater than 175 watts. Energy Trust also has a set of 

incentives for New Construction: $35 per T8/T5 fixture for Hi Bay applications, no specific 

wattage requirements of the fixture, but lamping requirements; $75 per HID fixtures controlled 

in Hi-Lo applications; $100 per HID fixture used for daylight dimming; $50 per ≤150W PMH, 

$60 per PMH fixture in the 150W to 400W range, and $70 for PMH fixtures 400W and greater. 

More information: http://www.energytrust.org/business/index.html. 

Idaho Power offers a series of incentives related to HID lighting. Metal Halide lighting is 

specifically identified. These incentives only apply to lighting upgrades for interior lighting 

(street, area, and parking lot lighting is excluded). Eligible metal halide fixtures include PMH or 

CMH that are replacing higher wattage MH, MV, or other sources. The incentives are the 

following: 

• $18.00 for PMH fixtures between 30W to 70W when replacing a fixture drawing 

20W more than the MH wattage. 

• $22.00 for PMH fixtures between 70W to 150W when replacing a fixture drawing 

25W more than the MH wattage. 

• $26.00 for PMH fixtures between 150W to 250W when replacing a fixture 

drawing at least 40W more than the MH wattage.

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• $55.00 for PMH fixtures between 250W to 360W when replacing a fixture 

drawing at least 80W more than the MH wattage.

• $75.00 for PMH fixtures between 360W to 500W when replacing a fixture 

drawing at least 120W more than the MH wattage.

• $105.00 for PMH fixtures for 500W and more when replacing a fixture drawing at 

least 200W more than the MH wattage. 

More information: http://www.idahopower.com/easyupgrades/. 

Midstate Electric sponsors a Commercial & Industrial Rebate Programs. MV, HPS, and 

MH are listed as existing equipment with recommended replacement technology. Midstate 

recommends and offers rebates for replacing incandescent, T12 and MV with new fluorescent 

fixtures. 

In a separate section, rebates are offered for specific HID technology to replace 

incandescent and MV lamps. 

• $50 per new CMH fixture ranging from 20W to 100W 

• $80 per new CMH fixture ranging from 101W to 250W 

For high bay or industrial applications, the program recommends replacing T12, MV, 

HPS, incandescent or MH with either high output fluorescent or PMH. The following incentives 

exist:

• $80 to $140 per fluorescent (T8, T5, or long biax CFL) fixture raninging in 

wattage from 85W to 600W 

• $100 per PMH fixture in the 300W to 399W range 

• $150 per PMH fixture in the 400W to 750W range 

In addition to providing information about the rebates, Midstate’s website lists local 

business that have reduced their operating expenses by using Midstate’s lighting rebates. 

More information: 

http://www.midstateelectric.coop/ProductsAndServices/CommercialIndustrial/EnergyEfficiency

Programs/default.aspx. 

A.20 TEXAS INCENTIVE PROGRAMS

Austin Energy sponsors a lighting rebate program, Commercial/Business Rebates and 

Incentives, with the objective of energy and demand through higher efficiency lighting systems. 

$300 per kW saved is eligible for replacing existing HID with T8 or T5 high-bay fixtures. 

More information: http://www.austinenergy.com/

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A.21 VERMONT INCENTIVE PROGRAMS

Efficiency Vermont, a statewide non-profit organization funded out of an efficiency 

charge applied to the electricity bill, manages a program called Commercial Lighting Equipment. 

A $50 rebate per fixture is available when replacing 250W or greater MH or HPS fixtures with a 

new fixture with an electronic ballast. A caveat exists stating that additional funding is available 

if dimming controls are used. A $30 rebate per fixture is available for the installation of MH or 

HPS exterior fixtures that do not use more than 100W. CMH technology has a $75 per fixture 

rebate. The incentive is directed towards trackheads or recessed downlights (“cans”), but any 

technology that uses low-wattage CMH is applicable. In addition to subsidizing equipment, a 

rebate of $20 is offered for the 25W CMH PAR38 lamp with integrated ballast. 

More information: 

http://www.efficiencyvermont.org/pages/Business/HVAC/Lighting/LightingRebates/. 

A.22 WASHINGTON INCENTIVE PROGRAMS

Avista Utilities Commercial Lighting Incentives offers incentives for HID interior and 

exterior fixtures. When replacing 400W MH high bay with multi-lamp fluorescent high bay, 

$125 - $460 per fixture is available. . Incandescent flood of 100 W or more replaced with CMH 

are eligible for $ 35 rebate per fixture. . Avista’s incentives are also available for new 

construction on a case-by-case basis. For replacing 400W HID fixtures with 4-lamp T5 high 

output fixture, 6 lamp T5 high output fixture, 6 lamp T8 fixture, 8 lamp T8 fixture and 200 Watt 

induction Fluorescent Fixture, rebates of $125, $90, $125, $110 and $220 are offered 

respectively. Rebate of $1000 is offered to replace 1000 Watt HID fixture with (2) 6 lamp T5 

High output fixtures. 

More information: 

https://www.avistautilities.com/business/rebates/washington_idaho/Documents/Lighting%20We

b.pdf 

Benton Public Utility District sponsors a Commercial Lighting & Special Projects 

program. MV, HPS, and MH are listed as existing equipment with recommended replacement 

technology. Benton PUD recommends and offers rebates for replacing incandescent, T12 and 

MV with new fluorescent fixtures $8 to $15 per fixture. 

In a separate section, rebates are offered for specific HID technology to replace 

incandescent and MV lamps. 

• $50 per new CMH (from 20W to 100W) fixture and 

• $80 per new CMH (from 101W to 250W) fixture for replacement of incandescent 

and MV sources. 

For high bay or industrial applications, the program recommends replacing T12, MV, 

HPS, incandescent or MH with either high output fluorescent or PMH fixtures. Rebates are as 

follows: 

EE-DET-03-001 COMMENT 19
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• $80 to $140 per fluorescent fixture raninging in wattage from 85W to 600W range 

• $100 per PMH fixture in the 300W to 399W range 

• $150 per PMH fixture in the 400W to 750W range 

More information: http://www.bentonpud.org/save_energy_money/comm_lighting.html. 

Richland Energy Services sponsores Energy Efficient Commercial Lighting Program. 

Customers are eligible for:

Incentives exist for replacing incandescent or MV sources as follows: 

• $80 per new CMH fixture in the 20W to 100W range 

• $150 per new CMH fixture in the 101W to 250W range 

For high bay or industrial applications, the program recommends replacing T12, MV, 

HPS, incandescent or MH with either high output fluorescent or PMH fixtures. Rebates are as 

follows: 

• $80 to $140 per fluorescent fixture raninging in wattage from 85W to 600W range 

• $100 per PMH fixture in the 300W to 399W range 

• $150 per PMH fixture in the 400W to 750W range 

More information: 

http://www.ci.richland.wa.us/RICHLAND/Electric/docs/86/docs/EECLPRebates.pdf?CFID=2222963&CFTOKEN=84833416

Puget Sound Energy has rebates for lighting improvements for small business. The 

program has subsets for different technology conversions. The subset that applied to HID 

technology is Section II: Higher Wattage Incandescent & HID Conversions. Few parameters 

exist for the equipment with the rebates. $90 to $125 per fixture is available for higher efficiency 

HPS/MH fixtures. T8/T5 fixtures for fluorescent warehouse lighting are eligible for $110 to $225 

per fixture. Finally, high wattage CFL wall packs, a traditional HID fixture, are listed with 

rebates in the range of $110 to $130 per fixture. 

More information: 

http://www.pse.com/solutions/forbusiness/pages/comRebates.aspx?tab=2&chapter=1

Seattle City Light manages a program called Energy Smart Services Financial Incentives 

that provides financial incentives to small businesses for replacing inefficient lighting with 

approved energy-efficient lighting equipment. This program offers incentives for specific 

technologies, but pays per kWh saved. MV is explicitly banned from being installed to receive 

rebates. In contrast, HPS and MH are specifically allowed for the incentive programs. 

EE-DET-03-001 COMMENT 19
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More information: http://www.seattle.gov/light/conserve/business/cv5_fi.htm. 

A.23 WISCONSIN INCENTIVE PROGRAMS

Baron Electric Cooperative offers $10 per MH and $10 per HPS fixture. Only retrofit 

applications are applicable. The only parameters are that the fixtures be hard-wired. 

More information: http://www.barronelectric.com/services/efficientlighting.html. 

Cedarburg Light & Water Utility offers some incentives. To be eligible, a representative 

from the organization must perform an energy audit. At the end of the audit, if potential savings 

exist, cash incentives might be provided to help reduce the cost of the equipment. Technologies 

listed specifically focus on more efficient HID technologies. 

More information: 

http://www.cedarburglightandwater.com/business_customers/participationrequest.asp?Category

Number=1&SubcategoryNumber=2. 

Eau Claire Energy Cooperative offers $10 per MH and $10 per HPS fixture. Only retrofit 

applications are applicable. The only parameters are that the fixtures be hard-wired. 

More information: http://www.ecec.com/electric/rebates/rebateslighting.htm. 

Riverland Energy Cooperative offers $10 per MH and $10 per HPS fixture. Only retrofit 

applications are applicable. The only parameters are that the fixtures be hard-wired. 

More information: 

http://www.riverlandenergy.com/RIVERLAND%20HOMEPAGE/commercial/incentives.htm. 

EE-DET-03-001 COMMENT 19
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81 Application Assessment of Bi-Level LED Parking Lot Lighting Pacific Gas and Electric 

Company Application Assessment Report #0815 

(http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/gateway_raleys.pdf) 

82 Demonstration Assessment of Light-Emitting Diode (LED) Street Lighting PNNL-18947 

(http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/gateway_lija-loop.pdf) 

83 Sustainability Success Story – Kwantlen Polytechnic University 

(http://www.kwantlen.ca/__shared/assets/0501_Success_Story_-

_Incandescent_Exterior_Fixture_Conversion_-_Surey6592.pdf) 

84 Energy Information Administration, Annual Energy Outlook 2009, DOE/EIA-0383(2009), 

U.S. Department of Energy, Washington, D.C., February 2009 

EE-DET-03-001 COMMENT 19
7-29

85 Fluorescent Lamp Ballasts Preliminary Technical Support Document 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/fluorescent_lamp_ballast

s_ecs_prelim_tsd.html 

86U.S. Department of Energy–Office of Energy Efficiency and Renewable Energy. Comments 

from the Public Meeting for Framework Analysis: Energy Efficiency Program for 

Commercial and Industrial Equipment: Metal Halide Lamp Fixture. January 2010. Transcript 

for Docket DOE EERE-2009-BT-STD-0018/RIN 1904-AC00 – Comment 1.2.005 

87 Ibid 1 

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